## 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

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### 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 ProductCapacity (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 8U.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 compoundsBatch 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 atomsStack Test Continuous Emissions Monitoring Engineering Calculations Other Yes No

Yes No

Yes No

Yes No

Yes No

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## 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



## Page 5 of 8

## 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 8U.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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