Enclosure 1
ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Off-Site Waste and Recovery Operations

This information collection request is being conducted by the Environmental Protection Agency’s (EPA) 

Office of Air and Radiation (OAR) to assist the EPA Administrator in developing emission standards for 

Off-Site Waste and Recovery Operations under Clean Air Act (CAA) section 112. The survey is being sent 

under the authority of Section 114 of the CAA. 

BACKGROUND:

Section 112 (d) of the Clean Air Act (CAA) calls for EPA to promulgate national technology-based emission 

standards for hazardous air pollutants (NESHAP) for sources emitting one or more of the HAP listed in CAA 

section 112(b). For major sources, these technology-based standards must reflect the maximum degree of 

emissions reductions of HAP achievable (after considering cost, energy requirements, and nonair quality 

health and environmental impacts). In addition, under CAA section 112(d)(6), EPA is required to review 

the technology-based standards and revise them “as necessary (taking into account developments in 

practices, processes, and control technologies)” no less frequently than every 8 years. Furthermore, we are 

required by section 112(f) (2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight 

years after the promulgation of maximum achievable control technology (MACT) standards under section 

112(d). If we find the residual risk fails to protect public health with an ample margin of safety or to prevent 

(taking into consideration various factors) adverse environmental effects, we are required to promulgate 

more stringent standards. 

The Off-Site Waste and Recovery Operations maximum achievable control technology (MACT) standards 

were promulgated on July 1, 1996 (see 61 FR 34140). We are collecting specific detailed information to 

support development of standards as part of our review as described above. Please note this survey is for offsite waste and recovery operations only. 

CAA section 114(a) states that the Administrator may require any person who owns or operates any emission 

source, who manufactures emission control equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in section 114(a), or who is subject to any 

requirement of the CAA (other than certain provisions under Title II), to provide EPA with information for 

the following purposes:

1. Developing or assisting in the development of the following:

a. State implementation plans (§§ 110 and 111(d));

b. New Source Performance Standards (NSPS) (§ 111);

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112);

d. Solid waste combustion or other related solid waste regulations (§ 129);

2. Determining whether any person is in violation of any standards or requirements developed under 

the authorities cited above; or

3. Carrying out any provision under the CAA (except certain provisions under Title II).

The Administrator may require that those persons identified above do the following so the Administrator 

may have the information necessary for the items listed in #1-3:

 establish and maintain records; 

 make reports; 
 install, use, and maintain monitoring equipment, and use audit procedures, or methods; 

 sample emissions (in accordance with such procedures or methods, at such locations, at such 

intervals, during such periods, and in such manner as the Administrator shall prescribe); 

 keep records on control equipment parameters, production variables or other indirect data when 

direct monitoring of emissions is impractical; 

 submit compliance certifications in accordance with section 114(a)(3); and 

 provide such other information as the Administrator may reasonably require.

DIRECTIONS: 

 All recipients must complete and return this survey by April 10, 2013.

 Please identify clearly any response(s) that you consider to be confidential business 

information (CBI). Any responses not so identified will be included in a publicly available 

database. Refer to Enclosures 3, 4, 5, and 6 for more information on the treatment of CBI and a list 

of information you may be asked to submit later to substantiate a claim of confidentiality.

DEFINITIONS: For the purposes of this ICR only, terms used have the meanings attributed to them in 40 

CFR 63.681. 

CONFIDENTIAL BUSINESS INFORMATION (CBI): 

Please indicate if any CBI is included in this survey response: Y N 

OFF-SITE WASTE AND RECOVERY OPERATIONS

We believe that you own a facility that has Off-Site Waste and Recovery Operations. If you believe that 

this survey does not pertain to you, please indicate your reason below: 

 The Off-Site Waste and Recovery Operations are permanently shut down. Please also identify the 

date the Off-Site Waste and Recovery Operations were shut down, what steps were taken to close the

equipment or stop operations, and if you still have a permit.

_________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 No Off-Site Waste and Recovery Operations at this facility. Please identify the operations at the 

facility. 

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

If your facility does not have Off-Site Waste and Recovery Operations, please respond as soon as 

possible. We will review that information and respond as to whether you need to complete any other part 

of the survey.
Enclosure 2
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 1 of 13

General Information

Name of Legal Owner: Hydrite Chemical Co.

Legal Owner Address: 300 N. Patrick Boulevard, Brookfield, WI 53045

Number of Legal Owner Employees: (262) 792-1450

Facility Name: Hydrite Chemical Co.

Facility Address: 114 N. Main Street, Cottage Grove, WI 53527

Mailing Address (if different from 

facility address):

Facility Contact Name: Joy Warborg

Facility Contact Title: Associate Environmental Manager

Facility Contact Phone Number: (608) 839-8153

Facility Contact Email Address: joy.warborg@hydrite.com

Number of Company Employees at 

the Entire Facility: 130

Please enter any other comments 

regarding general ownership 

information here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 2 of 13

Facility Information

Is the facility a major source for HAP? (see definition below)

Major sources are any stationary source or group of stationary 

sources located within a contiguous area and under common 

control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year (TPY) or more of 

any hazardous air pollutant or 25 TPY or more of any 

combination of HAP. 

Are there one or more off-site waste management or recovery 

operations at the facility subject to the Off-Site Waste and 

Recovery Operations (OSWRO) MACT (40 CFR 63, subpart DD)?

Is the facility exempt from complying with the OSWRO MACT?

What type(s) of off-site waste does the facility accept? (please 

include shipment method, physical form (i.e., solid, liquid, 

sludge), and a general description)

Approximately how many sources (facilities) does that waste 

come from?

What is the base year for which information is being provided? 

(please limit reporting years between 2006 and 2012, and 

provide the most current year)

For this base year, what was the amount of off-site waste 

received? (please specify units; e.g., gal/yr)

For this base year, what was the HAP content of the off-site 

waste received? (please specify units; e.g., tons)

How many hours per year are control devices bypassed to the 

atmosphere to perform routine maintenance?

Are any OSWRO operations scheduled to be discontinued? 

Are any OSWRO operations scheduled to be added or 

expanded?

What is the permitting classification of your facility?

What are the operating permit IDs for the OSWRO operations at 

your facility?

Is your operating permit available online?

Please provide the coordinates (in decimal degrees) of your 

facility property boundary at each corner (node). Alternatively, 

please provide the minimum distance from any OSWRO 

emission point to the facility property boundary.

Please enter any other comments regarding the facility here:

If yes, please provide date(s) that addition(s) and/or expansion(s) 

will begin production and explain changes:

If yes, please provide dates of closure and explain changes:

Please note that an CAAPP Operation Permit Renewal application 

was submitted to the Wisconsin DNR on 10/26/12. An application 

completeness determination was received from the Wisconsin DNR 

on 11/02/12.

2012

19,171,503 pounds of off-site waste was received in 2012

Average incoming waste composition was 18% HAP, or roughly 

3,450,871 lbs.

If yes, please explain:

None - All equipment is shut down and/or prevented from venting 

emissions when the control device requires maintenance.

NW - 43.077481, -89.204687

SW - 43.076274, -89.204784

NE - 43.079437, -89.19486

SE - 43.077728, -89.19494

No OSW is stored or processed within 50' of the property line.

The facility receives liquid solvents (primarily F005, F003, and D001 

waste codes) in bulk tankers and containers (primarily 55-gallon 

drums).

125 current profiles

Copies of the facility permits are available on the Wisconsin DNR 

webpage 

(Air Permit -> http://dnr.wi.gov/topic/AirPermits/)

(Waste Permit/Licenses -> 

http://dnr.wi.gov/topic/waste/licenses.html). 

A copy of the most recent CAAPP Operating Permit is also attached.

Wisconsin FID No. 113063390

Wisconsin CAAPP Operation Permit No. 113063390-P12

EPA ID No. WID000808824 - RCRA Part B Permit

License No. 6006 - Storage of Hazardous Waste in Containers

License No. 3200 - Storage of Hazardous Waste in Tanks

License No. 4437 - Treatment of Hazardous Waste in Tanks

If yes, please provide a link to or a copy of your most recent 

operating permit. If no, please provide a copy of your most recent 

operating permit.
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 3 of 13

If no, please explain.

If no, please explain.

If "Other", please explain:

If "Other", please explain:

If neither apply, please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Pumps 7

Compressors 0

Agitators 11

Pressure relief devices 24

Sampling connection systems 0

Open-ended valves or lines 115

Connectors 1065

Instrumentation systems unknown

Please enter any other comments regarding equipment leaks 

here:

What is the number of each type of component for the 

equipment in OSWRO HAP service (equipment that contacts 

off-site material having a total HAP concentration ≥ 10% by 

weight for 300 hours/year or more)?

With which subpart do you comply for equipment leaks?

Please provide documentation demonstrating the basis for 

the equipment leak emissions estimates. What type of 

documentation are you providing?

Equipment Leaks

Have you verified and/or corrected the equipment leak 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO equipment leaks in Enclosure 2A?

What emissions calculation approach was used to estimate 

the equipment leak emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

Facility OSW transfer systems are comprised entirely of 

piping. Emissions from transfer systems are limited to 

fugitive emissions from equipment leaks, and are included 

in the equipment leak emission calculations.

If "Other", please explain:

If "Other", please explain:

Please reference the Equipment Leak Emissions Estimate.

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please enter any other comments regarding transfer 

systems here:

Transfer Systems

Have you entered the OSWRO transfer system emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO transfer systems in Enclosure 2A?

What emissions calculation approach was used to estimate 

the transfer system emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the transfer system emissions estimates. Are you providing 

emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

The facility does not operate any oil-water or organicwater separators.

If no, please explain.

The facility does not operate any oil-water or organicwater separators.

If "Other", please explain:

None - Not applicable to the facility.

If "Other", please explain:

None - Not applicable to the facility.

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please enter any other comments regarding organic or oilwater separators here:

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the oil-water and organic-water separators emissions 

estimates. Are you providing emissions factors or source 

test data?

Oil-water and organic-water separators

Have you entered the OSWRO oil-water and organic-water 

separators emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO oil-water and organic-water separators in Enclosure 

2A?

What emissions calculation approach was used to estimate 

the oil-water and organic-water separators emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

If "Other", please explain:

Please list each OSWRO container requiring Level 1 or Level 2 control: 

Container ID Container capacity

Container emissions control level 

implemented

Upon receipt each 

container (drum) of OSW 

receives a unique 

authorization number 55-gallons DOT approved packaging

Please provide the additional capital and annual 

costs of this practice above that required by the 

OSWRO NESHAP:

None - Fugitive losses only.

If "Other", please explain:

Please enter any other comments regarding containers here:

(add information for more containers as necessary)

Containers

Have you entered the OSWRO containers emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO containers in Enclosure 2A?

What emissions calculation approach was used to estimate 

the containers emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the containers emissions estimates. Are you providing 

emissions factors or source test data?

Containers used for storing off-site waste 

materials meet the DOT regulations on 

packaging hazardous materials for 

transportation. Containers remain closed with 

covers in place except when the contents are 

sampled to verify the composition and when the 

contents are transferred to an OSW process 

vessel or storage tank. Sampling and material 

transfers are completed by inserting a wand into 

the container through a bung opening. 

Containers are not loaded with OSW at the 

facility. 

Emissions from OSW containers are limited to 

fugitive losses from the bung opening while removing 

or sampling material. Work practices require that 

the containers be closed as soon as the material 

transfer or sampling is complete, so these emissions 

are considered negligible.

If yes, please describe the control technique(s):
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

The facility does not operate any surface impoundments.

If no, please explain.

The facility does not operate any surface impoundments.

If "Other", please explain:

None - Not applicable to the facility.

If "Other", please explain:

None - Not applicable to the facility.

Please enter any other comments regarding surface 

impoundments here:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

Surface Impoundments

Have you entered the OSWRO surface impoundments 

emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO surface impoundments in Enclosure 2A?

What emissions calculation approach was used to estimate 

the surface impoundments emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the surface impoundments emissions estimates. Are you 

providing emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 8 of 13

If no, please explain.

If no, please explain.

All OSW process vents are routed to a thermal oxidizer 

through a closed vent system.

Please enter any other comments regarding process vents 

here:

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please provide documentation demonstrating the basis for 

the process vent emissions estimates. Are you providing 

emissions factors or source test data?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

If "Other", please explain:

Process Vent Emissions Information

Have you verified and/or corrected the process vent 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO process vent streams in Enclosure 2A?

What emissions calculation approach was used to estimate 

the process vent emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 9 of 13

Tanks Emissions Information

Please list each OSWRO tank requiring Level 1 or Level 2 control: 

Tank ID Tank capacity Tank content MTVP1 Tank content AVP2 Tank height Tank diameter

Tank average 

annual throughput

Tank emissions 

control equipment

T212 6,650 gallons 1.55 psia 0.17 psia 14 feet 9.5 feet 358,000 gallons Thermal Oxidizer

T213 6,650 gallons 1.12 psia 0.20 psia 14 feet 9.5 feet 24,000 gallons Thermal Oxidizer

T214 6,650 gallons 0.16 psia 0.13 psia 14 feet 9.5 feet 221,000 gallons Thermal Oxidizer

T215 6,650 gallons 0.26 psia 0.22 psia 14 feet 9.5 feet 17,000 gallons Thermal Oxidizer

T218 6,650 gallons 1.55 psia 0.27 psia 14 feet 9.5 feet 439,000 gallons Thermal Oxidizer

T219 6,650 gallons 1.12 psia 0.13 psia 14 feet 9.5 feet 20,000 gallons Thermal Oxidizer

T220 6,650 gallons No HAP Contents No HAP Contents 14 feet 9.5 feet 44,000 gallons Thermal Oxidizer

T221 6,650 gallons 1.55 psia 0.08 psia 14 feet 9.5 feet 160,000 gallons Thermal Oxidizer

T241 6,650 gallons 1.55 psia 0.27 psia 14 feet 9.5 feet 115,000 gallons Thermal Oxidizer

T242 6,650 gallons 1.55 psia 0.22 psia 14 feet 9.5 feet 66,000 gallons Thermal Oxidizer

1

 Maximum True HAP Vapor Pressure 

2

 Average HAP Vapor Pressure 

For each tank with an internal floating roof, please list the slotted ladder information: 

Tank ID

Number of ladders 

with slotted legs

Gasketed deck cover 

over slotted ladder(s)?

Ladder sleeve over 

slotted ladder(s)?

Pole wipers in place for 

slotted ladder legs?

None

For each tank with a fixed roof, please list the tank fitting information: 

Tank ID

Number of access 

hatches

Number of gauge 

hatches

Number of conservation 

vents

Number of 

valves/instruments

Number of emergency 

pressure relief vents

T212 2 1 0 10 2

T213 2 1 0 10 2

T214 2 1 0 14 2

T215 2 1 0 14 2

T218 2 1 0 11 2

T219 2 1 0 11 2

T220 2 1 0 15 2

T221 2 1 0 11 2

T241 2 1 0 11 2

T242 2 1 0 10 2

1

 Maximum True HAP Vapor Pressure

For each tank with a floating roof (internal or external), please list the tank information: 

Tank ID

Annual number of 

days roof rests on 

landing legs Length of landing legs

None

Please enter any other comments regarding tanks here:

If yes, please describe the control technique(s):

Please provide documentation demonstrating the basis 

for the tanks emissions estimates. Are you providing 

emissions factors, source test data or other data?

Are you implementing work practices or other HAP 

control techniques beyond those required by the MACT 

standard?

If "Other", please explain:

If "Other", please explain:

(add information for more tanks as necessary)

(add information for more tanks as necessary)

(add information for more tanks as necessary)

(add information for more tanks as necessary)

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

Have you entered the tanks emissions for your OSWRO 

processes in Enclosure 2A?

Have you completed all control information fields for 

your OSWRO storage vessels in Enclosure 2A?

What emissions calculation approach was used to 

estimate the tank emissions?

If no, please explain.

If no, please explain.
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 10 of 13

Off-Site Material Treatment

If you treat off-site waste using biological degradation, please answer the following questions:

What method of off-site waste HAP reduction is used?

Thin-Film Evaporation

Distillation

Fuel Blending

OSW Emissions are treated by a Thermal Oxidizer

How do you characterize the components of the waste 

products you receive that are treated with biological 

degradation?

Please enter any other comments regarding off-site waste 

treatment here:

Do you perform any testing or other practices to 

determine whether fouling agents may be in the waste 

received?

If "Other" or more than one of the above applies, please 

explain.
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 11 of 13

Startup and Shutdown Events

If no for any of the above, please explain:

Please provide the following information about all startup and shutdown events:

1. OSW processes

 (Luwa 1 - P11 and Column 1 - P01)

2. Emission control device 

 (Thermal Oxidizer)

Equipment Leaks

Transfer Systems

Organic and Oil-Water Separators

Containers

Surface Impoundments

Process Vents

Organic and Oil-Water Separators

Tanks

Process Vents

1. What emissions source types experience startup and shutdown events?

The United States Court of Appeals for the District of Columbia Circuit vacated portions of two provisions in the EPA’s CAA section 112 

regulations governing the emissions of HAP during periods of startup, shutdown and malfunction (SSM). Sierra Club v. EPA, 551 F.3d 

1019 (D.C. Cir. 2008). Specifically, the Court vacated the SSM exemption contained in 40 CFR 63.6(f)(1) and 40 CFR 63.6(h)(1), that are 

part of a regulation, commonly referred to as the “General Provisions Rule,” that the EPA promulgated under section 112 of the CAA. 

When incorporated into CAA section 112(d) regulations for specific source categories, these two, now vacated, provisions exempted 

sources from the requirement to comply with the otherwise applicable CAA section 112(d) emission standard during periods of SSM. 

To be consistent with the Court’s decision, facilities must comply with the applicable standards at all times.

For each emission source type, do the annual emissions estimate in the Enclosure 2A "Emissions (TPY)" field include the annual 

emissions from startup and shutdown events that you added in the "STARTUP EMISSIONS (TPY)" and "SHUTDOWN EMISSIONS (TPY)" 

fields? Please enter a separate response for each emissions point type below:

For each emission source type, can you comply with the emissions limitation and/or work practices in the regulation that apply during 

normal operation during startup and shutdown events? Please enter a separate response for each emissions point type below:

Surface Impoundments

Tanks

Equipment Leaks

Transfer Systems

Containers
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 12 of 13

Startup and Shutdown Events

1. OSW processes are batch operations.

2. Emission control device operates continuously. 

1. Start or completion of a batch.

2. Equipment failure or malfunction.

3. Shutdown/re-start for control device malfunction.

4. Shutdown / startup for maintenance.

1. Routine startup/shutdown of OSW processes do not 

result in operating conditions different from normal 

operations. Emergency shutdown for an equipment or 

control device malfunction also should not result in 

operating conditions different from normal operation.

2. Startup/shutdown of the emission control device 

(thermal oxidizer) results in the firebox temperature 

being lower than during normal operations.

1. Emissions from OSW processes vent through a control 

valve to the thermal oxidizer. During an extreme 

incident, emissions may vent through a process safety 

element to a catch tank. 

2. Emssions from the control device (thermal oxidizer) 

release through a vertical stack.

1. Routine startup/shutdown of the OSW processes 

(Luwa 1 - P11 and Column 1 - P01) occurs daily as batches 

are started or completed. Emergency shutdowns for 

equipment or control device malfunctions are less 

frequent (12 shutdowns for thermal oxidizer 

malfunctions occurred during 2012).

2. Startup/shutdown of the thermal oxidizer occurs only 

during malfunctions and for scheduled/planned 

maintenance activities. Preventative maintenance 

activities for the thermal oxidizer are schedule at least 

once each year.

1. Routine startup/shutdown of OSW process between 

product batches varies from a few hours to several days 

depending on customer needs and the production 

schedule. 

2. The average duration of an emergency shutdown for a 

thermal oxidizer malfunction in 2012 was less than 2.2 

hours.

3. A planned facility-wide shutdown (all processes and 

emission control equipment) is scheduled for one week 

every year.

1. For OSW processes (Luwa 1 - P11 and Colunn 1 - P01), 

startup is marked by material being added to the vessel 

and/or the hot oil or steam system being restarted (i.e. 

system heating started). 

2. For the thermal oxidizer the startup/shutdown event 

is over when the firebox temperature is back in 

compliance (1433°F).

None

HAP emissions are only calculated when OSW processes 

continue to operate (do not shutdown) during emission 

control device (thermal oxidizer) malfunctions, which is a 

violation of facility procedures. Uncontrolled emissions 

are calculated using the engineering emission factors 

determined for the applicable process vents.

6. How do you determine the HAP emissions during the event? 

4. What marks the end of the startup or shutdown event?

5. What safety issues are connected with a startup or shutdown event?

2. How often do startup or shutdown events occur? 

3. What is the average and range of event duration?

1.d. How are emissions released to the atmosphere (e.g., through a 

pressure relief device)?

1.c. How does the startup or shutdown event compare to normal 

operations (e.g., differences in flowrate, temp., pressure, alternate fuels 

used, alternate control devices used, etc.)?

1.a. Under normal operating conditions, do these emissions sources 

operate continuously?

1.b. What triggers the equipment to experience a startup or shutdown 

event (e.g. hot startup, startup after an emergency shutdown, re-start, 

control device startup)?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 13 of 13

Startup and Shutdown Events

All OSW process equipment must shutdown during 

emission control device malfunctions, and is not allowed 

to startup until the emission control device is operating in 

compliance. Checking the process equipment venting 

and the operation of the control device (thermal oxidizer) 

is required during system preparations for each batch. 

Equipment shutdown invloves turing off the hot oil or 

steam system (stopping system heating), engaging 

system cooling, shutting down the vaccuum system, and 

stopping all material transfers. The control valve on the 

vent line to the emission control device may also be 

closed.

1. Continuous monitoring of the thermal oxidizer 

temperature.

2. All control device malfunctions are required to be 

recorded on a malfunction log. Shift supervisors record 

the thermal oxidizer shutdown time, the cause of the 

malfunction, any maintenance or corrective actions 

performed, the thermal oxidizer startup time, the state of 

each process, and the process shutdown time.

Facility procedures require that no OSW be processed 

when the emission control device (thermal oxidizer) is 

not operating in compliance (temperature is < 1433°F). 

If a process was unable to be shutdown, due to an 

equipment failure or safety concern, uncontrolled 

emissions could still be limited by other in process 

equipment. The minimum emission level would vary 

depending upon which materials were being processed. 

Emergency shutdown procedures require the hot oil or 

steam (heating) system, the vacuum system, and all 

material transfers be stopped. If one or more of these 

systems failed, HAP emissions could still be minimized by 

the in-line process heat exchangers or demister pads, or 

by controlling the material reflux ratio. In worst-case 

scenarios, emissions and process material would be sent 

through the process safety element (i.e. rupture disk) to a 

catch tank.

All of these emergency systems are currently in place. 

In this scenario, emissions would effectively be the 

equivalent of an uncontrolled event.

Please enter any other comments 

regarding startup or shutdown here: Facility has a written Malfunction Prevention and Abatement Plan (SOP # AC014CG).

7. How are control devices and work practices used to minmize emissions 

during the startup or shutdown event?

8. What compliance determination method(s) do you use during startup and 

shutdown events (e.g., monitor with CEMS)? 

9.a. Please describe how HAP emissions would be minimized.

9.b. How much would it cost to minimize HAP emissions in this 

manner?

9.c. How much would HAP emissions be reduced compared to an 

uncontrolled event? (If "emission factor" is used as basis for emissions 

estimate, please provide the emission factor and sources of the 

emission factor.1

)

9. During startup and shutdown events, if you cannot comply with the emissions 

limitation and/or work practices in the regulation that apply during normal 

operation, what is the minimum emissions level that could be achieved? 

1

 If "source test" is used as basis for emissions estimate, please provide a copy of the 

source test.
Enclosure 2a
Enclosure 2a

Page 1

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emission 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name (include organic 

and non-organic pollutants)

Actual 

Emissions 

(TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emissions 

Max Hourly 

(lbs/hr)

Startup 

Emissions 

(TPY)

Startup 

Emissions 

(lbs/hr)

Shutdown 

Emissions 

(TPY)

Shutdown 

Emissions 

(lbs/hr) MACT Source Category

Emission 

Release 

Point 

Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas Flow 

Rate (ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (N-S) 

(ft)

Fugitive 

Angle 

(degrees) 5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is Control 

Measure In 

Place? Control Measure 7

Control 

Measure 

Efficiency Comments

Hydrite Chemical Co. NA NA NA 50310001 01/01/12 12/31/12 110543 Hexane 0.0003 10.00 0.0001 0.00 0.00 0.00 0.00 Equipment Leaks Fugitive NA NA NA NA NA NA NA NA NA NA Yes

Leak Detection and 

Repair Program

Varies by 

Equipment

LDAR Program follows Subpart V with 

a leak definition of 10,000 ppm.

67561 Methanol 0.16 10.00 0.04 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.91 10.00 0.21 0.00 0.00 0.00 0.00

108883 Toluene 1.61 10.00 0.37 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 1.43 10.00 0.33 0.00 0.00 0.00 0.00

Glycol ethers 0.58 10.00 0.13 0.00 0.00 0.00 0.00

Hydrite Chemical Co. NA NA NA 50310002 01/01/12 12/31/12 NA NA NA NA NA NA NA NA NA Containers Fugitive NA NA NA NA NA NA NA NA NA NA Yes

Pollution Prevention 

Technique 100%

Containers of OSW are DOT 

regulated, and are only opened to 

sample and transfer material. No 

containers are filled with OSW.

Hydrite Chemical Co. Tank 212 P42 / P200 S60 50310003 01/01/12 12/31/12 110543 Hexane 0.00017 10.00 0.10 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

67561 Methanol 0.00019 10.00 0.10 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.00047 10.00 0.26 0.00 0.00 0.00 0.00

108883 Toluene 0.00022 10.00 0.12 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00016 10.00 0.09 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.001 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 213 P42 / P200 S60 50310003 01/01/12 12/31/12 67561 Methanol 0.000006 10.00 0.02 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

108101 Methyl isobutyl ketone (Hexone) 0.000017 10.00 0.05 0.00 0.00 0.00 0.00

108883 Toluene 0.000030 10.00 0.08 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.000002 10.00 0.01 0.00 0.00 0.00 0.00

Glycol ethers 0.000000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 214 P42 / P200 S60 50310003 01/01/12 12/31/12 108101 Methyl isobutyl ketone (Hexone) 0.00014 10.00 0.12 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

Hydrite Chemical Co. Tank 215 P42 / P200 S60 50310003 01/01/12 12/31/12 108883 Toluene 0.00003 10.00 0.09 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

Hydrite Chemical Co. Tank 218 P42 / P200 S60 50310003 01/01/12 12/31/12 110543 Hexane 0.00001 10.00 0.00 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

67561 Methanol 0.00033 10.00 0.15 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.00006 10.00 0.03 0.00 0.00 0.00 0.00

108883 Toluene 0.00189 10.00 0.86 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00003 10.00 0.01 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 219 P42 / P200 S60 50310003 01/01/12 12/31/12 67561 Methanol 0.00001 10.00 0.04 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

108101 Methyl isobutyl ketone (Hexone) 0.00006 10.00 0.20 0.00 0.00 0.00 0.00

108883 Toluene 0.00006 10.00 0.19 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00002 10.00 0.07 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 221 P42 / P200 S60 50310003 01/01/12 12/31/12 110543 Hexane 0.00001 10.00 0.01 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

67561 Methanol 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.00031 10.00 0.34 0.00 0.00 0.00 0.00

108883 Toluene 0.00004 10.00 0.04 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00011 10.00 0.12 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 241 P42 / P200 S60 50310003 01/01/12 12/31/12 110543 Hexane 0.00001 10.00 0.01 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

67561 Methanol 0.00022 10.00 0.31 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.00006 10.00 0.09 0.00 0.00 0.00 0.00

108883 Toluene 0.00050 10.00 0.70 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00004 10.00 0.06 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Tank 242 P42 / P200 S60 50310003 01/01/12 12/31/12 110543 Hexane 0.00001 10.00 0.03 0.00 0.00 0.00 0.00 Tanks Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes

Fixed Roof Tank 

Vented to Control 

Device 99.9%

Control Device = Thermal Oxidizer - 

Efficiency based on stack test 

peformed in 12/2008. Emissions 

estimated using TANKS 409d.

67561 Methanol 0.00008 10.00 0.16 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.00008 10.00 0.15 0.00 0.00 0.00 0.00

108883 Toluene 0.00021 10.00 0.41 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.00003 10.00 0.06 0.00 0.00 0.00 0.00

Glycol ethers 0.00000 10.00 0.00 0.00 0.00 0.00 0.00

Hydrite Chemical Co. NA NA NA 50310006 01/01/12 12/31/12 NA NA NA NA NA NA NA NA NA Transfer Systems Fugitive NA NA NA NA NA NA NA NA NA NA Yes

Leak Detection and 

Repair Program

Varies by 

Equipment

OSW transfer systems are comprised 

of piping. Emissions, which consist of 

fugitive losses from equipment leaks, 

are included in the equipment leak 

calculations.

Hydrite Chemical Co. Luwa 1 P11 S60 50310007 01/01/12 12/31/12 110543 Hexane 0.002 10.00 0.14 0.00 0.00 0.00 0.00 Process Vents Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes Combustor 99.9%

Thermal Oxidizer - Efficiency based 

on stack test peformed in 12/2008. 

Emissions estimated using 

engineering calculations.

67561 Methanol 0.14 10.00 0.14 0.00 0.00 0.00 0.00

108101 Methyl isobutyl ketone (Hexone) 0.38 10.00 0.14 0.00 0.00 0.00 0.00

108883 Toluene 0.42 10.00 0.14 0.00 0.00 0.00 0.00

1330207 Xylenes (isomers and mixture) 0.49 10.00 0.14 0.00 0.00 0.00 0.00

Glycol ethers 0.27 10.00 0.14 0.00 0.00 0.00 0.00

Hydrite Chemical Co. Column 1 P01 S60 50310007 01/01/12 12/31/12 1330207 Xylenes (isomers and mixture) 0.02 10.00 0.45 0.00 0.00 0.00 0.00 Process Vents Vertical 32.5 400 3 2.85 20.15 NA NA NA -89.198085 43.077956 Yes Combustor 99.9%

Thermal Oxidizer - Efficiency based 

on stack test peformed in 12/2008. 

Emissions estimated using 

engineering calculations.

67561 Methanol 0.01 10.00 0.83 0.00 0.00 0.00 0.00

1

 For SCC Code, please input one of the following codes:

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release Point 

Parameters
Enclosure 2a

Page 2

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emission 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name (include organic 

and non-organic pollutants)

Actual 

Emissions 

(TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emissions 

Max Hourly 

(lbs/hr)

Startup 

Emissions 

(TPY)

Startup 

Emissions 

(lbs/hr)

Shutdown 

Emissions 

(TPY)

Shutdown 

Emissions 

(lbs/hr) MACT Source Category

Emission 

Release 

Point 

Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas Flow 

Rate (ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (N-S) 

(ft)

Fugitive 

Angle 

(degrees) 5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is Control 

Measure In 

Place? Control Measure 7

Control 

Measure 

Efficiency Comments

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release Point 

Parameters

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating Roof 

Tank

Fixed Roof Tank with 

Internal Floating Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

Leak Detection and 

Repair Program

Condenser

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process Modification

describe in 

Control 

Measure 

Comments 

column
DRAFT

Pollutant Name CAS No.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorene 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Asbestos 1332214

Benzene (including benzene from gasoline) 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Calcium cyanamide 156627

Captan 133062

Carbaryl 63252

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

Catechol 120809

Chloramben 133904

Chlordane 57749

Chlorine 7782505

Chloroacetic acid 79118

2-Chloroacetophenone 532274

Chlorobenzene 108907

Chlorobenzilate 510156

Chloroform 67663

Chloromethyl methyl ether 107302

Chloroprene 126998

Cresols/Cresylic acid (isomers and mixture) 1319773

o-Cresol 95487

m-Cresol 108394

p-Cresol 106445

Cumene 98828

2,4-D, salts and esters 94757

DDE 3547044

Diazomethane 334883

Dibenzofurans 132649

1,2-Dibromo-3-chloropropane 96128

Dibutylphthalate 84742

1,4-Dichlorobenzene(p) 106467

3,3-Dichlorobenzidene 91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444

1,3-Dichloropropene 542756

Dichlorvos 62737

Diethanolamine 111422

N,N-Diethyl aniline (N,N-Dimethylaniline) 121697

List of Hazardous Air Pollutants (HAP)
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Diethyl sulfate 64675

3,3-Dimethoxybenzidine 119904

Dimethyl aminoazobenzene 60117

3,3'-Dimethyl benzidine 119937

Dimethyl carbamoyl chloride 79447

Dimethyl formamide 68122

1,1-Dimethyl hydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

4,6-Dinitro-o-cresol, and salts 534521

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

1,4-Dioxane (1,4-Diethyleneoxide) 123911

1,2-Diphenylhydrazine 122667

Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 106887

Ethyl acrylate 140885

Ethyl benzene 100414

Ethyl carbamate (Urethane) 51796

Ethyl chloride (Chloroethane) 75003

Ethylene dibromide (Dibromoethane) 106934

Ethylene dichloride (1,2-Dichloroethane) 107062

Ethylene glycol 107211

Ethylene imine (Aziridine) 151564

Ethylene oxide 75218

Ethylene thiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000

Heptachlor 76448

Hexachlorobenzene 118741

Hexachlorobutadiene 87683

Hexachlorocyclopentadiene 77474

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydrochloric acid 7647010

Hydrogen fluoride (Hydrofluoric acid) 7664393

Hydrogen sulfide 7783064

Hydroquinone 123319

Isophorone 78591

Lindane (all isomers) 58899

Maleic anhydride 108316

Methanol 67561

Methoxychlor 72435

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

Methyl chloroform (1,1,1-Trichloroethane) 71556

Methyl hydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert butyl ether 1634044

4,4-Methylene bis(2-chloroaniline) 101144

Methylene chloride (Dichloromethane) 75092

Methylene diphenyl diisocyanate (MDI) 101688

4,4'¬-Methylenedianiline 101779

Naphthalene 91203
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Nitrobenzene 98953

4-Nitrobiphenyl 92933

4-Nitrophenol 100027

2-Nitropropane 79469

N-Nitroso-N-methylurea 684935

N-Nitrosodimethylamine 62759

N-Nitrosomorpholine 59892

Parathion 56382

Pentachloronitrobenzene (Quintobenzene) 82688

Pentachlorophenol 87865

Phenol 108952

p-Phenylenediamine 106503

Phosgene 75445

Phosphine 7803512

Phosphorus 7723140

Phthalic anhydride 85449

Polychlorinated biphenyls (Aroclors) 1336363

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

1,2-Propylenimine (2-Methyl aziridine) 75558

Quinoline 91225

Quinone 106514

Styrene 100425

Styrene oxide 96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746016

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Titanium tetrachloride 7550450

Toluene 108883

2,4-Toluene diamine 95807

2,4-Toluene diisocyanate 584849

o-Toluidine 95534

Toxaphene (chlorinated camphene) 8001352

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylenes 95476

m-Xylenes 108383

p-Xylenes 106423

Antimony Compounds 0

Arsenic Compounds (inorganic including arsine) 0

Beryllium Compounds 0

Cadmium Compounds 0

Chromium Compounds 0

Cobalt Compounds 0

Coke Oven Emissions 0
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Cyanide Compounds 0

Glycol ethers 0

Lead Compounds 0

Manganese Compounds 0

Mercury Compounds 0

Fine mineral fibers 0

Nickel Compounds 0

Polycylic Organic Matter 0

Radionuclides (including radon) 0

Selenium Compounds 0
Other ICR 

Response Info.