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Nick

- For the KY Plant NBR emissions for 2009, then I wou ld 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 i t. (It's always risky when you write something without a thorough review.) Here is how I would restate th e

case:

The processes which contribute to the majority of t he back-end emissions are very comparable between the KY Plant NBR and MS Plant ECO (Epi) manufacturi ng operations. The two ECO drying processes at the MS Plant are apron- type dryers, where heated air is passed over and th rough 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 a re also apron dryers. As product mix varies, so can residual monomer and/or residual solvent vary a nd, as a result, so can HAP emissions vary. Recent product mix variability has not been as great at th e 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 th e MS Plant and its ECO manufacturing variability, we pro pose to use the same variability factor for ECO manufacturing as has been developed for NBR manufac turing.

Thanks again for your cooperation.

- Tom

---03/04/2011 02:52:23 PM---Tom, This looks great a nd 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.

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...Tom,

This looks great and should be enough rationale for using the same emission variability factor for Epichlorohydrin that we applied to NBR. Your unders tanding 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 th e 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; ot herwise 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 Schem bechler

-----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 desi gnated as option 3. The processes which contribute to the majority of the back-end emission s 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 th rough the wet rubber as it passes through an oven- like chamber on a moving perforated stainless steel apro n. The two main NBR drying processes at the KY Plant are also apron dryers. The principal source o f HAP emissions from all four of these units is residual monomer. As product mix varies, so can res idual 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 ther e at the MS Plant. To offset this lack of recent da ta to represent the MS Plant and its ECO manufacturing va riability, 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 e ffects to be. It is my understanding that you are t aking 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 v alue 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 th e Page 2 of 4

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...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 y our epichlorohydrin plant in MS. We establish variabili ty in a given source category based on the variatio n in emissions from affected facilities in that sourc e category. As your MS plant is the only facility i n 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 expect ed 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 eac h (from either a data-gathering or legality aspect):

(1) Leave the emission rate standard where it is no w, 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 t he rate at which you're trending upwards and apply some sort anticipated future variability factor to your current emission rate (this is likely the opti on that will take the most time to do, which is probably no t a luxury we have at this point, as it would requi re 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 curren t epichlorohydrin emission rate, arguing that they are similar processes (or something to that effect) and so we expect a similar variation in emissions (I w ould need some input/guidance from you as to whether thi s is correct based on how your plants work).

(4) Apply some other emission variability factor, b ased on a rational that you come up w/ (meaning tha t perhaps there's an additional option that I'm not t hinking of).

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

resolution that works for both of us. Let me know w hat 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

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