From: Barry_H._Christensen@oxy.com [mailto:Barry_H._Christensen@oxy.com]

Sent: Thursday, August 21, 2014 7:03 PM To: Kaleri, Cynthia Cc: Deanna_Strain@oxy.com; Dewees, Jason; Bouchard, Andrew; Handrich, Charles; Howard, Jodi; Stephanie_Engwall@oxy.co m Subject: Follow

- up to OxyVinyls Test Plan for PVC NESHAPs Importance: High

Ms. Kaleri,

This submission is a follow

- up to our meeting of August 13, 2014, to
review
the Site

- Specific Performance Test Plan submitted to EPA on July 30,
2014. The testing will be performed to comply with the CAA114 ICR request and compliance performance test requirements of the Area Source PVC NESHAP and, as a contingency, the Major Source PVC NESHAP. The following paragraphs
address the information you requ ested during the meeting.

1. Additional information on the similarity of the two oxidizer/scrubber
trains.

A table is enclosed which summarizes the design and operating
characteristics of both trains. OxyVinyls does not foresee any signific ant emission
differences in our two trains. It should be noted that at the time of
the last performance test in 2011, the two trains were identical. Subsequent

to that test, OxyVinyls installed the two

- stage burner on the "A" oxidizer

to
allow fo r more efficient turn down operation. We plan to test the "A"
train in our performance test scheduled for next month. We will then have data
from past CAA 114 tests indicating that both units comply with the area or major source

PVC MACT limits.

2. Alternate Monitoring Request (AMR) for absorber/scrubber operation.

Enclosed is an AMR, filed as a contingency, should it be necessary for
the LaPorte Plant to comply with the major source limits in the future. We respectfully request a pproval from EPA Region 6 prior to our performance

testof 9/29/2014 to ensure that we capture the correct operational data

during the

test.

3. Request to submit the 2009 30

- day THC data in lieu of gathering

new data for the CAA 114 IC R.

During the meeting, a statement was made that our 2009/2010 was too

outdated to be used. However, that testing was performed 12/10/2009 through 2/07/2010; therefore the data less than 5 years old. Also, as shown in the data provided in Append ix E of our test plan, the only detectable THC values occurred
for a few hours on only 2 or 3 days when oxidizer startup or shutdown events
took place, which is to be expected with all combustion devices. Therefore, OxyVinyls believes that gathering additional days of non detectable THC
values seems of limited value. We do, however, endorse EPA's continued effort

to correlate THC and TOH data. As indicated previously, the earliest the plant can begin testing is 9/22/2014. Due to staggered an nual outages for each plant, it is not likely that we will have a full 30 days of THC data compiled for reporting by the 11/17/2014 deadline, however we will make our best

effort
to do so.

4. Request to use the 2011 D/F data in lieu of gather ing new data
for the compliance performance test.

Based upon your verbal feedback, OxyVinyls understands that our prior D/F

data gathered for a CAA114 ICR at our LaPorte Plant can be used in lieu of gathering additional D/F data. Accordingly, we are not planning to
include that sampling in our September 2014 testing.

5. Thermal Oxidizer Firebox Temperature

We understand that EPA (Region 6) is assessing whether the oxidizer temperature operating limit (OPL) will be set at the minim um 1

- hr run
value or the average of the 1

- hr test runs.

6. Correction to Method 8270 referenced in Test PlanYou indicated that our test plan incorrectly referred to analytical

method 8270C in lieu of 8270D. We acknowledge that this method was updated in February 2007, and we will modify our plans accordingly (i.e., and
utilize the updated method as required in the performance test).

Finally, thank you to Mr. Charles Handrich for forwarding the technical
information about alkalinit y vs. pH measurement and ORP probes. We will review it for possible future application.

We trust this information answers EPA's questions to date. If you have

any additional questions or require additional information, please do not
hesitate

to contact either Ms. Deanna Strain at (281) 476

- 2909 or Stephanie Engwall at (972) 404

- 3291.

Barry Christensen Mgr. Air Quality
Occidental Chemical
972 404 3209

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