1 Attachment 

Nick - 

For the KY Plant NBR emissions for 2009, then I would assume with an allowed variability of 42% that 

the emission rate would be ~2.41 Mg/yr (1.7 Mg/year, as originally proposed plus 42%). 

I just reviewed the wording in the first paragraph of my last note and would like to slightly change it. 

(It's always risky when you write something without a thorough review.) Here is how I would restate the 

case: 

The processes which contribute to the majority of the back-end emissions are very comparable between 

the KY Plant NBR and MS Plant ECO (Epi) manufacturing operations. The two ECO drying processes 

at the MS Plant are apron-type dryers, where heated air is passed over and through the wet crumb rubber 

as it passes down through an oven-like chamber on a moving perforated stainless steel apron conveyor. 

The two main NBR drying processes at the KY Plant are also apron dryers. As product mix varies, so 

can residual monomer and/or residual solvent vary and, as a result, so can HAP emissions vary. Recent 

product mix variability has not been as great at the MS Plant as it has at the KY Plant. Nevertheless, the 

potential for variability is there at the MS Plant. To offset this lack of recent data to represent the MS 

Plant and its ECO manufacturing variability, we propose to use the same variability factor for ECO 

manufacturing as has been developed for NBR manufacturing. 

Thanks again for your cooperation. 

- Tom 

---03/04/2011 02:52:23 PM---Tom, This looks great and should be enough rationale for using the 

same emission variability factor

From: <Parsons.Nick@epamail.epa.gov>

To: Tom Herman <Herman@zeonchemicals.com>

Date: 03/04/2011 02:52 PM

Subject: Re: Epichlorohydrin Concerns

Re: Epichlorohydrin Concerns 

Tom Herman 

to: 

Nick Parsons 

03/04/2011 03:33 PM 

Cc: 

Bill Simpson 

Show Details 

History: This message has been replied to.

graycol.gif

Page 1 of 4

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notesFCBCEE\~web2817.... 3/31/2011
Tom, 

This looks great and should be enough rationale for using the same emission variability factor for 

Epichlorohydrin that we applied to NBR. Your understanding of the correction factor is correct, though I 

think the exact number that we came up w/ was 42% (probably due to rounding). If my math is correct, 

that should raise your 2009 emissions for Epi in the regulation from 36 Mg/yr to 51 Mg/yr (as this was

how the rule was proposed). 

Let me know if you have any additional concerns; otherwise you should see the final rule early next 

month. Thanks for you help. 

- - 

Nick Parsons

Environmental Engineer 

U.S. Environmental Protection Agency 

OAR/OAQPS/SPPD/RCG 

919.541.5372

parsons.nick@epa.gov

"No man is more important than the team." -Bo Schembechler 

-----Tom Herman <Herman@zeonchemicals.com> wrote: ----- 

To: Nick Parsons/RTP/USEPA/US@EPA 

From: Tom Herman <Herman@zeonchemicals.com>

Date: 03/04/2011 02:44PM 

Subject: Re: Epichlorohydrin Concerns 

Nick - 

As we discussed, we would prefer what you have designated as option 3. The processes which 

contribute to the majority of the back-end emissions are very comparable between the KY Plant NBR 

and MS Plant ECO manufacturing operations. The two ECO drying processes at the MS Plant are aprontype dryers, where heated air is passed over and through the wet rubber as it passes through an oven-like 

chamber on a moving perforated stainless steel apron. The two main NBR drying processes at the KY 

Plant are also apron dryers. The principal source of HAP emissions from all four of these units is 

residual monomer. As product mix varies, so can residual monomer vary and, as a result, so can HAP 

emissions vary. Recent product mix has not been as great at the MS Plant as it has at the KY Plant. 

Nevertheless, the potential for variability is there at the MS Plant. To offset this lack of recent data to 

represent the MS Plant and its ECO manufacturing variability, we propose to use the same variability 

factor for ECO manufacturing as has been developed for NBR manufacturing. 

So that we may be clear on how EPA is treating the data for NBR manufacturing at the KY Plant, I 

wanted to present what I understand the resultant effects to be. It is my understanding that you are taking 

the ratio of annual HAP emissions per annual amount of production for 2008 and applying it to the 2009

production total. That would yield a HAP emission value for 2009 of 5087#. Another way of looking at 

this is that the KY Plant NBR processes could emit at a rate (Em./Prod.) up to ~44% above the rate we 

reported for 2009 in the 114 response. 

Please let me know if this explanation is adequate for your needs and if I have properly understood the 

Page 2 of 4

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notesFCBCEE\~web2817.... 3/31/2011
variability situation.

- Tom 

---03/04/2011 11:57:01 AM---Hi Tom, I spoke to our contractor and found that we have an issue in 

trying to apply a variability

From: <Parsons.Nick@epamail.epa.gov>

To: Tom Herman <Herman@zeonchemicals.com>

Date: 03/04/2011 11:57 AM

Subject: Epichlorohydrin Concerns 

Hi Tom, 

I spoke to our contractor and found that we have an issue in trying to apply a variability factor to your 

epichlorohydrin plant in MS. We establish variability in a given source category based on the variation 

in emissions from affected facilities in that source category. As your MS plant is the only facility in the 

epichlorohydrin facility, there is a problem since, as you stated earlier today, your emission rate is fairly 

stagnant but slowly trending upwards, and is expected to continue to do so in the future as you switch to 

a different product mix. I see several options here, though I honestly don't know the viability of each 

(from either a data-gathering or legality aspect): 

(1) Leave the emission rate standard where it is now, at 2009 levels, which will require you to adjust

your production or process as necessary to meet the standards. 

(2) Use your historical emissions data to look at the rate at which you're trending upwards and apply 

some sort anticipated future variability factor to your current emission rate (this is likely the option that 

will take the most time to do, which is probably not a luxury we have at this point, as it would require 

you to gather the data, submit it to our CBI office, them to process it, me to analyze it, etc.). 

(3) Apply the NBR variability factor to your current epichlorohydrin emission rate, arguing that they are 

similar processes (or something to that effect) and so we expect a similar variation in emissions (I would 

need some input/guidance from you as to whether this is correct based on how your plants work). 

(4) Apply some other emission variability factor, based on a rational that you come up w/ (meaning that 

perhaps there's an additional option that I'm not thinking of). 

As the rule is already at OMB, time is of the essence here, and I would like to be able to come to a 

resolution that works for both of us. Let me know what you think. 

- - 

Nick Parsons

Environmental Engineer 

U.S. Environmental Protection Agency 

OAR/OAQPS/SPPD/RCG 

919.541.5372

parsons.nick@epa.gov

"No man is more important than the team." -Bo Schembechler

Page 3 of 4

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notesFCBCEE\~web2817.... 3/31/2011
"This transmission including any attachments is confidential and may be legally privileged. If you are

not the intended recipient, or their agent, you are hereby notified that reading, disclosing, copying,

distributing or using any information contained in this transmission is strictly prohibited. If you have 

received this transmission in error, please immediately notify the sender or forward the e-mail to 

abuse@zeonchemicals.com and destroy the transmission. Thank you for your assistance." 

"This transmission including any attachments is confidential and may be legally privileged. If you are

not the intended recipient, or their agent, you are hereby notified that reading, disclosing, copying,

distributing or using any information contained in this transmission is strictly prohibited. If you have 

received this transmission in error, please immediately notify the sender or forward the e-mail to 

abuse@zeonchemicals.com and destroy the transmission. Thank you for your assistance." 

Page 4 of 4

file://C:\Documents and Settings\nparsons\Local Settings\Temp\notesFCBCEE\~web2817.... 3/31/2011