January 8, 2015

Via e-mail

Ms. Jodi Howard

Environmental Engineer

USEPA

QAQPS/SPPD/RCG (Mail Code E143-01)

109 T. W. Alexander Drive

Research Triangle Park, NC 27711

Subject: Supplement to Submittal of PVC and Copolymer MACT Process Vent

and Other Information in Response to EPA’s May 15, 2014 Request

under Section 114 of the Clean Air Act (42 U.S.C. § 7414)

Dear Ms. Howard:

This letter and enclosures constitute a supplement to our November 17, 2014 response

to May 15, 2014 request for process vent testing and other information pertaining to the

Oxy Vinyls, LP (OxyVinyls) Deer Park, Texas, polyvinyl chloride (PVC) production

facility, in accordance with the Clean Air Act (CAA) Section 114.

This supplement provides the emission source sampling results and operating

parameter data associated with the sampling event. Enclosed with this letter are the

following non-confidential documents in electronic format, which are provided on a

single USB flash drive:

Description Filename

Certification Statement CERTIFICATION STATEMENT.pdf

Documentation and Information Related to

Completion of CAA Section 114 Information

Collection Request for Polyvinyl Chloride and

Copolymers Production (MACT Survey) 2014

(Revision 1)

OxyVinyls_Deer Park PVC_Survey Summary

2014.pdf

PVC MACT Survey Workbook (Forms P and Q

only)

EPA PVC MACT Survey_(OxyVinyls)_(Deer

Park PVC)_(P&Q ONLY)_2014.xls

Source Emissions Survey Report OxyVinyls_Deer Park PVC_ 2014 Survey -

Sampling Report.pdf

ERT Submittal Package Oxy Vinyls, LP - Deer Park PVC_01-07-

2015_17-46_PKG.zip

Source and Control Device Operating Data OxyVinyls_Deer Park PVC_Operating Data

Supplement.pdf

Source and Control Device Operating Parameter

Monitor Calibrations

OxyVinyls_Deer Park PVC_Operating Parameter

Monitor Calibration.pdf

Occidental Chemical Corporation OxyChem®

A subsidiary of Occidental Petroleum Corporation

Corporate Health, Environment, Safety, and Security Department

5005 LBJ Freeway, Suite 2200, Dallas, Texas 75244-6152

P.O. Box 809050, Dallas, Texas 75380-9050

Phone 972.404.3291 Fax 972.404.3287

Stephanie_Engwall@oxy.com
Supplement to Submittal of CAA 114 Response

Ms. Jodi Howard, USEPA

January 8, 2014

Page 2

As presented in Section 7 of the Test Plan approved by the United States

Environmental Protection Agency (EPA) on September 29, 2014, and as discussed with

EPA on multiple occasions, OxyVinyls experienced three unplanned equipment issues

that resulted in maintenance activities and previously scheduled plant and equipment

outages that prevented us from conducting the performance test at maximum

production rates as originally scheduled on September 29, 2014. That sampling event

was aborted, and testing resumed on November 11, 2014.

Therefore, per your direction, OxyVinyls is submitting with this supplement a completed

Form P, the stack sampling report, and supporting operating parameter data for the

November 2014 sampling event. The Method 25A and 26A sampling results are being

submitted via EPA’s Electronic Reporting Tool (ERT).

Similarly, three unplanned equipment issues that resulted in maintenance activities and

previously scheduled plant and equipment outages prevented OxyVinyls from collecting

30 days of THC data prior to November 17, 2014. OxyVinyls commenced sampling on

October 3, 2014, with the intention of collecting a partial data set prior to a scheduled

Plant turnaround that commenced on October 10, 2014.

The THC sampling was conducted utilizing a temporary methane/non-methane THC

continuous emissions monitoring system (CEMS), which contains a methane channel

and a non-methane channel. Shortly after sampling commenced on October 3, 2014,

the methane channel malfunctioned. A replacement monitor was not available until

October 7, 2014. The replacement monitor was calibrated and put on line at 10:00 Hrs

on October 7, 2014, and valid sample data collection resumed. Although the nonmethane THC channel was functional during the methane channel downtime, the lack of

methane data caused the data collected during this time period to be invalid.

Therefore, per your direction, the original submittal of Form Q included valid data

collected during the October 3 through 10 sampling event (i.e., October 3 from 10:25

through 14:25 Hrs and October 7 at 11:35 through October 10 at 08:12 Hrs).

OxyVinyls resumed sampling on November 11, 2014, and continued the second

sampling event with intention of obtaining 30 consecutive days of data. A fugitive

equipment leak, for which repair required a shutdown of the PVC process unit, caused

data collection to cease at 11/15/2014 06:56, resuming 11/20/2014 13:31. Therefore,

OxyVinyls continued data collection to 12/21/2014 06:53. It should be noted that a

calibration issue on November 30 invalidated one day of data.

With this supplement, OxyVinyls is providing a revised Form Q that contains THC

sampling data for a period greater than 30 days.
Supplement to Submittal of CAA 114 Response

Ms. Jodi Howard, USEPA

January 8, 2014

Page 3

OxyVinyls truly appreciates your guidance during

If you have questions or comments

hesitate to contact me at 972-

Sincerely,

Stephanie Engwall

Manager of Air Quality

Occidental Chemical Corporation

Electronic Enclosures

cc: Mr. Greg Valentine, USEPA, Region 6 (6EN

1445 Ross Avenue, Suite 1200,

Mr. Michael Beatty, TX Commission on Environmental Quality

Post Office Box 13087,

ubmittal of CAA 114 Response

OxyVinyls truly appreciates your guidance during the preparation of this supplement.

ou have questions or comments regarding the information provided, please

-404-3291.

Occidental Chemical Corporation

, USEPA, Region 6 (6EN-AA), Toxics Section

Suite 1200, Dallas, TX 75202-2733

Mr. Michael Beatty, TX Commission on Environmental Quality (MC 224)

Post Office Box 13087, Austin, TX 7871 1-3087

preparation of this supplement.

, please do not

(MC 224),