U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

General Information

Company Name: ExxonMobil Chemical Company

Facility Name: ExxonMobil Chemical Company - Baytown

Facility Address: 5000 Bayway Dr; Baytown, tX 77520

Mailing Address (if different from 

facility address): P.O. Box 4004; Baytown TX 77522-4004

Site Contact Name: Diane Otto

Site Contact Title: Air Issue Advisor

Site Contact Phone Number: 281-834-1169

Site Contact Email Address: diane.e.otto@exxonmobil.com

Page 1 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Facility Information

Is the facility a major source for HAP?

Are there one or more process units at the facility subject to the 

Polymers and Resins I (P&R I) MACT (40 CFR 63, subpart U)?

Are there one or more P&R I process units that do not “use or 

manufacture any organic HAP”? (See §63.480(b))

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

For this base year, what was the solid rubber production rate 

(tons/yr)?

For this base year, what was the liquid latex production rate 

(tons/yr)?

For each elastomer product process unit (EPPU), please provide 

the primary product, capacity, and annual production 

information: EPPU ID Primary Product

Capacity 

(tons/yr)

Annual Production 

(tons/yr)

BPB

Halobutyl, Butyl 

and Exxpro

Confidential 

Information

Confidential 

Information

Please provide EPPU IDs that are flexible operating units which 

produce other products.

Are any P&R I operations scheduled to be discontinued? 

Are any P&R I operations scheduled to be added or expanded?

(add information for more EPPUs as necessary)

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:

(If no, you need not complete any further portions of 

this survey)

2009 - Routine Emissions

Confidential Information

0

If yes, please explain:

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Page 2 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

If no, please explain.

If no, please explain.

If "Other", please explain:

If yes, please provide details:

Smart LDAR Scan prior to startup

For the organic HAP emissions, are you implementing work 

practices or other control techniques beyond those required 

by the MACT standard?

Equipment Leaks

Have you verified and/or corrected the equipment leak 

emissions for your P&R I processes in the dataset?

Have you completed all control information fields for your 

P&R I equipment leaks in the dataset?

What emissions calculation approach was used to estimate 

the equipment leak emissions?

Screening ranges approach

EPA correlation approach

Unit-specific correlation approach

Other

Yes

No

Yes

No

Yes

No

Page 3 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

If no, please explain.

If no, please explain.

Emission Unit ID

Mass Emission Rate of 

Halogen Atoms (kg/hr)

BPB 3.00E-06

Are you controlling these HCl emissions?

EPPU ID

Front-End Process 

Vent ID

Originating source of 

chlorinated compounds Batch or continuous?

If batch, 

operating 

schedule 

(hrs/yr)* 

BPB FS-12 T-7 Overhead Continuous

BPB FS-12 Drier Regenerations Batch 1087.5

BPB FS-12 T-71 Overhead Continuous

BPB FS-12 LR34 Batch - Unloading Railcars 6

BPB FS-12 C-1 (Seal Gas) Continuous

BPB FS-12 J-541 Batch 504

*(please use the base year identified in "Facility Information")

(add information for more EPPUs as necessary)

If yes, what is the limit and how are you required to demonstrate 

compliance (e.g., source testing, continuous emissions monitoring, 

continuous or periodic parameter monitoring, etc)? Please describe 

or provide a copy of these requirements.

Monitor MeCl to flare using HRVOC analyzer

We control amount of MeCl to flare by minimizing the amount sent.

If yes, please describe the control device or control strategy:

Stack test for flare operations and then engineering 

calculations based on HRVOC analyzer

Front-End Process Vent Emissions Information

Have you verified and/or corrected the front-end process 

vent emissions for your P&R I processes in the dataset?

Have you completed all control information fields for your 

P&R I front-end process vent streams in the dataset?

What emissions calculation approach was used to estimate 

the front-end emissions?

(add information for more emission units as 

necessary)

If "Other", please explain:

Please complete the following table for each elastomer product process unit (EPPU) for which there HCl 

emissions that result from combustion of a halogen in a control device. 

Do you have a permit/emission limit for 

HCl emissions?

If yes, please please complete the following section:

From P&R I processes, are there HCl emissions that result 

from combustion of a halogen in a control device?

Please provide the Emission Unit ID and 

mass emission rate of halogen atoms 

Stack Test

Continuous Emissions Monitoring

Engineering Calculations

Other

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Page 4 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

If no, please explain.

If no, please explain.

Rubber that enters the backend process has hexane 

entrained in it. Throughout the process, a majority of 

the vapors are evolved from the rubber and sent to the 

regenerative thermal oxidizer (RTO) to be combusted. 

A small porition of the vapors are uncontrolled.

If "Other", please explain:

Stack test for RTO DRE determination, and engineering 

calculations. 

If yes, what is the limit/requirement and how are you 

required to demonstrate compliance (e.g. source testing, 

continuous emissions monitoring, continuous or periodic 

parameter monitoring, etc)? Please describe or provide a 

copy of these requirements.

The RTO DRE limit is 98%, and minimum operating 

temperature of 1400 deg F. HAPs component limits are 

included in total plant VOC limits of 2137.54 lb/hr and 432.98 

tpy. Engineering calculations based on stack testing , 

composition and flow.

What type of emission sources are there from your back-end 

processes?

Do you have any permit limits or conditions for the 

emissions from the back-end process operations?

Back-End Process Operations

Have you verified and/or corrected the back-end process 

operation emissions for your P&R I processes in the dataset?

Have you completed all control information fields for your 

P&R I back-end processes in the dataset?

What emissions calculation approach was used to estimate 

the back-end emissions?

Are the back-end process operations continuous or batch?

If the back-end process operations are batch, what is the 

operating schedule (hrs/yr) (please use the base year 

identified in "Facility Information")

Please describe the back-end emission processes at this 

facility (i.e., the operations in an EPPU following the 

stripping operations):

Stack Test

Continuous Emissions Monitoring

Other

Continuous 

Batch

Stack

Fugitive (not including equipment leaks)

Yes

No

Yes

No

Yes

No

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U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Storage Vessels Emissions Information

Other engineering calculations' - used for TK550A/B and TK560 

in EPN CASRHB to calculate emissions (tanks use condenser and 

carbon absorbers to control hexane emissions).

Have you verified and/or corrected the storage vessels 

emissions for your P&R I processes in the dataset?

Have you completed all control information fields for 

your P&R I storage vessels in the dataset?

What emissions calculation approach was used to 

estimate the storage vessels, surge control vessels, and 

bottoms receivers emissions?

If no, please explain.

If no, please explain.

If "Other", please explain:

TANKS

Other engineering calculations

Stack Test

Other

Yes

No

Yes

No

Page 6 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Wastewater

If no, please explain.

If no, please explain.

If "Other", please explain:

If "Other", please explain:

Wastewater Management 

Unit ID Control Control Efficiency

Sep-182 None 0

(add information for more waste management units as necessary)

Have you verified and/or corrected the wastewater 

emissions for your P&R I processes in the dataset?

Have you completed all control information fields for your 

P&R I wastewater in the dataset?

What emissions calculation approach was used to estimate 

the emissions from tanks, containers, and oil-water 

separators?

What emissions calculation approach was used to estimate 

the emissions from surface impoundments and drain 

systems?

Please list all waste management units that receive, manage, or treat Group 2 wastewater streams and their 

controls (these waste management units may not match the wastewater unit ID in the dataset):

TANKS

Other engineering calculations

Stack Test

WATER9

Other

Yes

No

Yes

No

Engineering calculations

WATER9

Other

Page 7 of 8
U.S. EPA Information Collection Request for Group 1 Polymers and Resins Production

Startup and Shutdown Events

If no for any of the above, please explain:

When opening vessels to atmosphere after 

clearing concentrations could be higher that 

the HAPs concentration limit. Back end 

process operations can have control device 

bypassed during a S/D and S/U.

Do you wish to recommend a standard that would apply during startup and shutdown? If so, please:

Turn arounds, weather emergencies (hurricanes, 

etc.), critical equipment failure, cleaning of 

equipment, safety system activation.

When opening equipment to the atmoshphere a 

minimum of 10% of LEL achieved, 10,000 ppmv 

VOC concentration or 50 lbs. 

On stream time for back end process operations 

allowed for maintenance, shutdown, startup, 

and safety system checks and activation - 240 

hr/yr.

VOC concentration instrument, LEL instrument 

and/or engineering calculations. 

Back-end process will be determined by hrs of 

on-stream time.

VOC concentration, LEL, lb/hr - State Draft 

Permit; 

On-stream time - 240 hr/yr based on current 

MACT regulations.

LEL/VOC concentration limit will reduce 

concentration limits going to atmosphere prior 

to opening; The on stream time per year will 

limit the amount of uncontrolled operations.

Wastewater

For each emission source type, do the annual emissions estimate in the dataset "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?

Equipment Leaks

Front-End Process Vents

Back-End Process Operations

Storage Vessels

Wastewater

5. Explain why and how the standard would minimize emissions during 

the event

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?

Equipment Leaks

Front-End Process Vents

Back-End Process Operations

Storage Vessels

1. Describe the event(s) to which the standard would apply

2. Provide the recommended standard (this could be an emission 

limitation, work practice, or operational standard) that would apply 

during the period

3. Provide a compliance determination method

4. Provide the basis for the recommended standard

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

Yes

No

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