Enclosure 1

PVC Section 114 Enclosure 1

- Page 1 04/01 /2014 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST

I. Introduction

This information collection request is to be completed for operations that comprise the Polyvinyl Chloride and Copolymers ( PVC) sou rce c ategory at your company

. The PVC Production source category includes any facility which manufactur es polymerized vinyl chloride. PVC is be produced by the suspension, suspension blending, emulsion/dispersion or bulk processes, although other methods may be used. T he source category includes the collection of all equipment and activities necessary to produce PVC ho mopolymer or copolymer resin.

This in formation collection request consists of two parts: (1) completion of information collection request response forms and submission of supplemental data and information; and (2) sampling and analysis of PVC resin streams and PVC process wastewater streams. The results of resin and process wastewater analyses are reported in dedicated worksheets that are contained in a single Microsoft Excel workbook file along with the required response forms. Except for the required sampling and analysis, complete this info rmation collection request as completely as possible from best available existing information from the 2013 calendar year

. Instructions for obtaining the information collection request response forms are i n Section II of this enclosure. A summary of the supplemental data and information requested in this information collection request is in Section III. Instructions for submitting your response are in Section IV. Section V contains general instructions for completing your response and includes specific gu idance for completing each response form

. F or your convenience, we have provided additional information on the scope and purpose of this information collection request

, as well as useful definitions

, in Attachment A

. Respondents should read this material b efore att empting to complete the response forms

. Respondents may also wish to review the rule and implementation information for PVC production before completing the response forms by visiting the EPA’s Technology Transfer Network

– Air Toxics Web Site for PVC :

http://www.epa.gov/ttn/atw/pvc/pvcpg.html.

Additional information on the PVC resin and process wastewater sampling and analysis requirements can be found in Attachment B of this enclosure

. If you have questions regarding this request, please contact Ms. Jodi Howard, Refining and Chemicals Group, at (919) 541

- 4607 or howard.jodi@epa.gov

.Enclosure 1

PVC Section 114 Enclosure 1

- Page 2 04/01 /2014 II. Instructions for Obtaining the Information Collection Request Files

The information collection reques t response forms are available as a single Microsoft Excel 2007 workbook

. The workbook is included with this enclosure and is titled:

“ PVC ICR _[ Company ]

_ [ Facility ] .xls x ”

The workbook should be completed for the entire PVC production facility

. Before submitting the file, the file name will be changed to reflect the actual company and facility ( see Section III).

Other files included in this package are an example of how to complete the Excel workbook and a copy of this enclosure. Where necessary, examp les of how to complete selected portions of the information collection request response forms are included dir ectly in the forms themselves. Refer to examples and the instructions contained in this enclosure when completing
your response.

III. Supplementa l Data and Information Requested

W e are requesting you submit supplemental data and information to support the information submitted in the information collection request response forms

. The following table summarizes the supplemental data and information that must be submitted with your response. Provide actual recorded data where possible and submit that d ata in Microsoft Excel format. If recorded process data (such as CEMS data) are no t available, then provide estimates based on engineering assessments, material balances, etc. and provide copies of estimation worksheets and other supporting documentation. Recorded process data, sampling results, test results, estimation worksheets, engi neering calculations, assessments, etc. must be provided to support the information submitted for all parts of the information collection request response

. Except for the results of PVC resin and process wastewater analyses, the i nformation provided in re sponse to this information collection request should be from the best available existing information from the 2013 calendar year

.
Supplemental Data and Information Related Equipment, Stream, Emission Point Time Period

Process Unit Plot Plan Process Unit N/A Process Unit Flow Diagram Process Unit N/A Emissions Test Reports All Control Devices M ost recent test report HAP/Total VOC Concentration, Emissions Data or Estimates All Uncontrolled Emission Points 2013 Safety/Pressure Relief Notifications and estimates of emissions from releases Process Unit Safety/Pressure Relief Devices 2013Enclosure 1

PVC Section 114 Enclosure 1

- Page 3 04/01 /2014 IV

. Instructions for Submitting Your Information Collection Request Response

Use the appropriate file naming format as listed below for the files you submit when responding to this information collection request :

Submission File Name Format
Completed Response Workbook PVC ICR _[Company]_[Facility].xls x

Plot Plan [Company]_[Facility] _PlotPlan

Process Flow Diagram [Company]_[Facility] _PFD

Emissions Test Reports [Company]_[Facility]_[ProcessUnitID]_[Process Equipment /Control Device ID ]_[YYYYMMDD]

Data/Estimates [Company]_[Facility]_[ProcessUnitID]_[ProcessVent/EmissionPoint/Stream/Waste waterStream/ProcessEquipment/ControlEquipment ID]_[YYYYMMDD]to[YYYYMMDD]

For file names that include dates or date ranges, use four digits for the year (YYYY), two digits for the month (MM), and two digits for the day (DD).

EXAMPLE

Generic Chemical Corporation has a manufacturing facility in Anytown, USA

According to the instructions in Section II and IV, the files would be renamed as:

Submission File Name

Completed Response Workbook PVC ICR _Generic_Anytown.xls

and submitted with all other required data and information outlined Section III.

Please e

- mail the completed non

- confidential response to:

CCG

- PVC@epa.gov

If you are submitting confidential business information (CBI) as described in Enclosure 2, then this information must be mailed to EPA in hard

- copy or on a CD

- ROM or DVD

- ROM disk. Clearly mark the disk and/or the materials with the words “Confidential Business Information” and send either via U.S. Postal Se rvice Express Mail, registered mail, or private courier to:

Jodi Howard

U.S. EPA Office of Air Quality Planning and Standards Sector Policies and Program Division, Refining and Chemicals GroupEnclosure 1

PVC Section 114 Enclosure 1

- Page 4 04/01 /2014 Mail Code E143

- 01 Research Triangle Park, NC 27711

Additionally, if you are submitting CBI via mail in hard

- copy or on CD

- ROM or DVD

ROM disk, you must also submit a non

- CBI version of your information collection request response to t he email address listed above. DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIA L BUSINESS INFORMATION TO EPA.

If you have questions regarding this request, please contact Ms. Jodi Howard, Refining and Chemicals Group, at (919) 541

- 4607 or howard.jodi@epa.gov.

V. Background Information and Instructions for Completing the Information Collection Request Response Forms

NOTE : For the purposes of this information collection request , all HAP and VOC

concentrations and e missions are to be quantified. Do not report concentrations or emissions as “trace” or “minimal.” If a concentration is a t or below a detection limit, then provide the detection limit.

Form A

– Company Information and Facility Information

 Forms A

- 1 and A

- 2 are where the respondent company and facilities are identified.

 In question I.1 of Form A

- 1, identify the legal paren t company/legal corporate owner name. In questions I.2 through I.6 provide the mailing address for the legal parent company/legal corporate owner.

 Identify the size of the company by selecting the appropriate range for the number of employees (including al l subsidiaries, branches, and related establishments owned) in question I.7.

 On Form A

- 2, provide the facility name and address information requested in question II.1, including the latitudinal and longitudinal coordinates of the facility. Facility latitud es and longitudes should be reported in decimal degrees to the 5 th decimal place, and longitudes should include negative sign, e.g. ( 37.91986

, - 87.32724 ) Sources of these data include EPA permits (e.g.

, NPDES permits), county property records, facility blueprints, and site plans.

 Provide the name and contact information for the facility ’s technical contact in questions III.1 through III.3 on Form A

- 2.

 On Form A

- 2

, Section IV, respondents are asked to ide ntify whether the facility is a major source of HAP emissions by selecting “Yes,” or “No,” in question IV.1

. Section 112(a)(1) of the CAA defines a major source as any stationary source or group of stationary sources located within a contiguous area and un der common control that emits or has the potential to emit considering cont rols, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 to ns per year or more of any combination of hazardous air pollutants

. Affected sources that hav e not yet commenced production of PVC resin or that are expanding existing production capacity are asked to complete all parts of this information collectionEnclosure 1

PVC Section 114 Enclosure 1

- Page 5 04/01 /2014 request

. For those sources, projected actual emissions (not “Potential to Emit”) are requested in lieu of actual operating emissions

.

 For facilities that are not major sources of HAP emissions (and select “No” for question IV.1) , the respondent is asked to identify if and when a permit limit for their potential HAP emissions to avoid being classified as a major source in question s IV.2 and IV.3, respectively was taken

.

 Indicate if the facility manufactures other products in addition to PVC resin by selecting “Yes,” or “No,” for question IV. 4 on Form A

- 2. If “Yes,” list the other products manufactured in the response field for question IV. 5

.

 Indicate if there are any HAP emission associated with any co

- located facilities by selecting “Yes,” or “No,” for question IV. 6 on Form A

- 2.

Form B

– Control Devices , Recovery Systems, PVC Process Wastewater Treatment Systems, and Process Equipment

 Prior to completing the remainder of the forms (i.e., forms B through N ) , you should complete a plot plan (plant layout schematic) and process flow diagra m (s) for the PVC production facility

. Do not submit “block flow diagrams.” The level of detail requested is more than generally contained in “block flow” diagrams but less than that generally contained in piping and instrumentation diagrams (P&IDs)

. Proce ss flow diagrams should accurately show ALL:

o P rocess equipment ;

o R ecovery systems including all recovery equipment ;

o P rocess wastewater treatment systems including all wastewater treatment equipment ;

o Closed vent systems ( identify the collection of piping for each closed vent system using a dotted

- line boundary on the process flow diagram ) ;

o Control devices ( also clearly show any piping configurations that allow a gaseous stream routed to a closed vent system and control device to bypass the control device );

o Pr essure relief devices (PRDs);

o Emission points;

o P rocess wastewater streams ;

 Each item in the table below is to be given a unique identifier in the form of Z

- x, where “Z” is a unique code for each item listed in the table below and x = 1, 2, 3,...n

. The unique identifier should exactly match between the process flow diagram and information provided in the completed response workbook(s). Refer to Attachment A of this Enclosure for relevant definitions.Enclosure 1

PVC Section 114 Enclosure 1

- Page 6 04/01 /2014 Control devices (C

- x) Recovery systems (RS

- x) Individual recovery equipment that comprise the recovery system (RE

- x) P rocess wastewater treatment systems (WWT

- x) Individual wastewater treatment equipment that comprise each process wastewater treatment system (WWE

- x) Process equipment (U

- x) Emission points (EP

- x) Process w astewater streams (W

- x) Pressure relief devices (PRD

- x) Closed vent systems (CVS

- x)

Form B

- 1

– Control Devices

General Instructions

 Each control device should be listed in Form B

- 1.

 For the purposes of this information collection request , wastewater collection, handling and treatment equipment (including process wastewater steam strippers) are considered wastewater treatment equipment and not control or recovery devices

. Complete Form B

- 3 and E

- 1

- a for proces s wastewater treatment systems and process wastewater, respectively.

 For each control device, submit a copy of the most recent emissions test report

. The report should include information on the process operations that influenced emissions during the test, including the resin type being produced

. Include information such as the purpose of the test, when it was conducted and what test methods were used

. If emissions test reports are not available, calculations based on emission factors, material balances, or engineering principles must be submitted and supported by submitting a step

- by

- step description of the calculations, including assumptions used and a brief rationale for the validity of the calculation method used

. (See guidance documents listed in Attach ment A, Section IV).

 For the following control devices, complete the appropriate Forms: absorbers

- Form F

- 1; thermal or catalytic oxidizers

- Form F

- 2 ; and, condensers

- Form F

- 3.

Specific Instructions by Form Column

 Column 1 : Each control device is to be given a unique code or identifier in the form of C

- x, where x = 1, 2, 3,...n, in Form B

- 1

. This unique code/identifier should exactly match the identifier used in the process flow diagram and will be used on subsequent forms.

 Column 2 : Select the type of control device from the list provided in the Form

.

 Column 3 : If “other” was selected in column 2, p rovide a description of the control device

.

 Column 4 : Each emission point from a control device (or from the last control device in a series) that exhausts directly to the atmosphere should be shown on the process flow diagram and is to be given a unique code or identifier of the form EP

- x, where x = 1,2,3,...n in FormEnclosure 1

PVC Section 114 Enclosure 1

- Page 7 04/01 /2014 B

- 1

. This unique code/identifier will be used on subsequent forms. If the exhaust stream fro m the control device immediately enters a subsequent control device (e.g., exhaust from a thermal oxidizer is routed to an acid gas scrubber) provide the subsequent control device identifier instead of the emission point identifier.

Form B

- 2

– Recovery Sy stems and Closed Vent Systems

General Instructions

 Each recovery system should be listed in Form B

- 2.

 For the purposes of this information collection request , wastewater collection, handling and treatment equipment (including process wastewater steam strippers) , are considered wastewater treatment equipment and not control or recovery systems. Complete Form B

- 3 and E

- 1

- a for wastewater treatment equipment and process wastewater, respectively

.

 If you use a condenser as part of a recovery system, and emissions from the condenser are routed directly to the atmosphere without first passing through a control device, complete F orm F

- 3 for the condenser(s).

Specific Instructions by Form Column

Table 1

 Column 1: Each reco very system is to be given a unique code or identifier in the form of RS

x, where x = 1, 2, 3,...n, in Form B

- 2

. This unique code/identifier should exactly match the identifier used in the process flow diagram and will be used on subsequent forms.

 Column 2: Provide a description of the recovery system.

 Column 3: Indicate if , at any point in the recovery or closed vent system, emissions can be discharge d directly to the atmosphere. If you answer yes, complete Table 2.

 Columns 4

- 6 : L ist the control devices tha t control emissions from the recovery and closed
vent system. The control device ID(s) that you provided on Form B

- 1 will be available as a pick list in columns 4 through 6

.

Table 2

 If you answered “Yes” in column 3 of Table 1, complete Table 2.

 Column 1: Identify the recovery system ID. The recovery system ID(s) that you provided in Table 1 will be available as a pick list in column 1 of Table 2.

 Column 2: Identify each emission point that discharge s directly to the atmosphere. Do not list emission points for streams exiting the recovery system that are routed through a closed vent system to a control device. Each emission point that exhausts directly to the atmosphere should be shown on the process f low diagram and given a unique code or identifier of the form EP

- x, where x = 1,2,3,...n in Form B

- 2. This unique code/identifier will be used on subsequent forms.Enclosure 1

PVC Section 114 Enclosure 1

- Page 8 04/01 /2014  Column 3: Identify if the emission point is used as a bypass for the control device, or, if th e emission point is a process vent.

 Column 4: Indicate if the equipment opening standards in 40 CFR Part 61, subpart F are met before a discharge occurs through the emission point.

Table 3

 Column 1: Each piece of recovery equipment included in the recov ery system should be shown on the process flow diagram and given a unique code or identifier of the form RE

- x, where x = 1, 2, 3,...n, in Table 2 of Form B

- 2. This unique code/identifier will be used on subsequent forms.

 Column 2: Provide a description of t he recovery equipment.

 Column 3: Indicate recovery system ID to which the recovery equipment belongs. The recovery system ID(s) you provided in Table 1 will be available as a pick list in column 3.

Form B

- 3

– PVC Process Wastewater Treatment Systems

Gene ral Instructions

 Each PVC process wastewater treatment system should be listed in Form B

- 3

. Specific Instructions by Form Column

Table 1

 Column 1: Each PVC process wastewater treatment system is to be given a unique code or identifier in the form of WWT

- x, where x = 1, 2, 3,...n, in Form B

- 3

. This unique code/identifier should exactly match the identifier used in the process flow diagram and will be used on subsequent forms.

 Column 2: Provide a description of the treatment system (a pick list of common descriptions is provided)

.

 Column 3 : If “other” was selected in column 2, provide a description of the treatment system.

 Column 4: Indicate if emissions from the treatment system are routed directly to the atmosphere without first passing through a recovery system or control device.

 Column 5

- 7: If you answered “Yes” in column 4, list the emission point ID(s). Each emission point from treatment systems that exhausts directly to the atmosphere should be shown on the process flow diag ram and given a unique code or identifier of the form EP

- x, where x = 1,2,3,...n in Form B

- 3. This unique code/identifier will be used on subsequent forms.

 Column 8: If you answered “No” in column 4, indicate if emissions from the treatment system are route d to a recovery system.Enclosure 1

PVC Section 114 Enclosure 1

- Page 9 04/01 /2014  Column 9: If you answered “Yes” in column 8, select the appropriate recovery system ID entered on Form B

- 2.

 Column 10

- 1 2 : If you answered “No” in column 8, select the control devices that control emissions from the treatment system. The control device ID(s) your provided in Form B

- 1 will be available as a pick list in columns 10 through 12.

Table 2

 Column 1: Each piece of equipment included in the treatment system should be shown on the process flow diagram and given a unique code or identifier of the form WW E

- x, where x = 1, 2, 3,...n, in Table 2 of Form B

- 3

. This unique code/identifier will be used on subsequent forms

.

 Column 2: Provide a description of the equipment

.

 Column 3: I ndicate the corresponding treatment system ID to whi ch the process wastewater treatment equipment belongs

. The PVC process wastewater treatment system ID(s) you provided in Table 1 will be available as a pick list in column 3.

Form B

- 4

– Process Equipment

General Instructions

 All remaining process equipment should be listed on Form B

- 4. Do not list any equipment previously noted on Forms B

- 1 through B

- 3.

 Process equipment may be grouped on the process flow diagram if and only if the individual pieces of equipment in the group are of identical design and all process vents exiting each piece of process equipment are routed to the same control device.

 If emissions from a condenser (not previously listed as part of a recovery system) are routed directly to the atmosphere without first passing through a r ecovery system or control device, complete Form F

- 3 for the condenser(s).

Specific Instructions by Form Column

 Column 1: Each piece of process equipment is to be given a unique code or identifier in the form of U

- x, where x = 1, 2, 3,...n, in Form B

- 4

. This unique code/identifier should exactly match the identifier used in the process flow diagram and will be used on subsequent forms.

 Column 2: Provide a description of the process equipment.

 Column 3: Provide a n indication if emissions from the process e quipment are routed directly to the atmosphere without passing first through a recovery system or control device

.

 Column 4

- 6: If you answered “Yes” in column 3, list the emission point ID(s). E ach emission point should be shown on the process flow diagram and is to be given a unique code or identifier of the form EP

- x, where x = 1,2,3,...n in Form B

- 4

. This unique code/identifier will be used on subsequent forms. If the emission point is controlled (and therefore listed inEnclosure 1

PVC Section 114 Enclosure 1

- Page 10 04/01 /2014 Form B

- 1 ) do not duplicate the emis sion point in Form B

- 4 ; only list uncontrolled emission points.

 Column 7: If you answered “No” in column 3, indicate if emissions from the process equipment are routed to a recovery system.

 Column 8: If you answered “Yes” in column 7, select the appropria te recovery system ID entered on Form B

- 2.

 Column 9

- 11: If you answered “No” in column 7, list the control device identifier s previously identified on Form B

- 1 . If emissions are controlled by multiple control devices

, list each control device identifier in the order of control (e.g., the overhead stream from a resin stripper (U

- 1) is controlled by 1) a thermal oxidizer (C

- 1) and an acid gas scrubber (C

2 ) ).

Form C

– Economic Life and Applicable Regulations

 On Form C

, provide the information on the age of the PVC production facility and its remaining economic life.

 For all regulations that apply to any part of the PVC production facility, provide the regulation citation, the regulation title, and the control device, recovery equip ment, wastewater treatment equipment, or process equipment or identifier listed in Form B.

Form D

- 1

– Resin Production Information

General Instructions

 The purpose of Form D

- 1 is to identify the relative magnitude of the operation in terms of resin type s and production amounts.

 Complete rows 1 through 8 of Form D

- 1 for each type of resin produced by the facility in 2013

. If the facility produced the same type of resin using different types of resin strippers, include multiple entries for the same resin type for each unique combination of descriptors required by the Form.

Specific Instructions by Form Row

 Row 1: Indicate each resin type produced by the facility in 2013

. Refer to Attachment A of this enclosure for definitions of each resin type that is provided in the pick list. If the resin types in the pick list, and corresponding definitions do not describe the type of resin produced by the facility in 2013, select “ot her.”

 Row 2: If you selected “other” for row 1, please provide a description of the resin type.

 Row 3: Please select a description of the resin stripper(s) used to remove vinyl chloride and/or other organic HAP from the resin. Complete multiple columns for the same resin type if resin strippers matching different descriptions were used.

 Row 4: If you selec ted “other” for row 3, please provide a description of the resin stripper(s).

 Row 5: Indicate if the resin stripping process type is “batch” or “continuous” in row 5.Enclosure 1

PVC Section 114 Enclosure 1

- Page 11 04/01 /2014  Row 6: Provide the 2013 annual production (in pounds of resin) for the resin type , resin stripper description, and resin stripping process type combination. Provide the value in terms of how the facility typically accounts for total production (i.e., if the resin is sold and accounted for on a dry basis (e.g., a suspension resin), list dry pou nds; if the resin is sold and accounted for on a wet basis (e.g., a dispersion resin that is not dried before being sold), provide the production on a wet basis).

 Row 7: List the process equipment ID(s) of the resin strippers in row 7. The process equipmen t ID(s) will be available as a pick list, based on the values provided on Form B

- 4.

 Row 8: If the equipment ID entered on Form B

- 4 represents more than one resin stripper, indicate the total number of resin strippers for the resin type, resin stripper desc ription, and resin stripping process type combination

.

Form D

- 2

– 30 Day Resin Sampling

– Stripper Outlets

 Refer to Attachment B, “Summary of Test Procedures, Methods, and Reporting Requirements for Resin and Process Wastewater Sampling and Analysis at P olyvinyl Chloride and Copolymers Facilities” of this enclosure for requirements and instructions regarding sampling and analyzing stripped resin in response to this information collection request. Use Form D

- 2 to record and submit your resin sampling and a nalysis results, following the instructions included in the Form and Attachment B

.

 Report the total daily resin production rate from the sampled resin strippers for each day. Do not report the entire facility production, unless all resin strippers were sa mpled on that day. Production rates should be provided in the facilities standard production measure (i.e., if the facility produces a suspension resin and tracks production on a dry product basis, report the daily production on a dry resin basis).

Form E

- 1

- a

– Process Wastewater

General Instructions

 Form E

- 1

- a collects information on process wastewater.

Specific Instructions by Form Column/Row

Table 1

 Columns 1

- 2: Enter the name and PVC process wastewater stream ID of each process
wastewater stream not treated by a PVC process wastewater treatment system on Table 1 of Form E

- 1

- a

. The PVC process wastewater stream should be shown on the process flow diagram and is to be given a unique code or identifier of the form W

- x, where x = 1,2,3,...n

.

 Columns 3

- 6 : Provide the stream flow rate in gallons per day in column 3 through 5. Select the flow rate determination method from the pick list in column 6.

 Column 7: Provide the number of operating days per year for the stream in column 7.Enclosure 1

PVC Section 114 Enclosure 1

- Page 12 04/01 /2014  Column 8: Select the type of originating equipment/device in column 8. The selection in column 8 will determine which equipment ID lists (i.e., recovery, process or control devices) are available for selection in column 9.

 Column 9: Select the originating equipment/device ID in co lumn 9. The available ID(s) will be based on your entries in Forms B

- 1 through B

- 4 and your selection in column 8.

 Columns 10

- 12: In column 10, select the appropriate destination code based on the descriptions in Table 4 of Form E

- 1

- a. In column 11, provid e the associate destination information corresponding to the destination description in column 3 of Table 4. In column 12, indicate if the stream is exposed to the atmosphere at any point between the originating equipment and the stream destination.

Table 2

 Complete Table 2 of Form E

- 1

- a for each wastewater steam exiting a PVC process wastewater treatment system

.

 Column 1: Select the PVC process wastewater treatment system ID from the entries on Form B

- 3.

 Column 2: Indicate if the treatment system is a ba tch or continuous operation.

 Column 3: Enter the PVC process wastewater stream ID of each process wastewater stream exiting a PVC process wastewater treatment system in column 3. The PVC process wastewater stream should be shown on the process flow diagram and is to be given a unique code or identifier of the form W

- x, where x = 1,2,3,...n.

 Columns 4

- 7: Provide the stream flow rate in gallons per day in column 4 through 6. Select the flow rate determination method from the pick list in column 7.

 Column 8: Provide the number of operating days per year for the stream in column 8

.

 Columns 9

- 11: In column 9, select the appropriate destination code based on the descriptions in Table 4 of Form E

- 1

- a. In column 10, provide the associate destination information

co rresponding to the destination description in column 3 of Table 4. In column 11, indicate if the stream is exposed to the atmosphere at any point between the originating equipment and the stream destination.

Table 3

 Row 1: Complete Table 3 of Form E

- 1

- a for each wastewater steam stripper. Select the PVC process wastewater treatment ID corresponding to each wastewater stripper entered on Table 2 of Form B

- 3

.

 Rows 2

- 7: Provide the corresponding design and operating feed rate f or each wastewater stripper in rows 2 through 7.

 Rows 8

- 19: For each wastewater stripper, complete rows 8 through 19 regarding operating and design characteristics as completely as possible.

 Rows 20

- 21: Provide the year the wastewater stripper was installe d and cite any regulations applicable to the wastewater stripper.Enclosure 1

PVC Section 114 Enclosure 1

- Page 13 04/01 /2014 Table 5

 Column 1: For any non

- PVC production process wastewater stream entering a PVC process wastewater treatment system, provide the source of the process wastewater stream.

 Columns 2

- 5: P rovide the stream flow rate in gallons per day in column 2 through 4. Select the flow rate determination method from the pick list in column 5.

 Column 6: Provide the number of operating days per year for the stream in column 6

.

 Columns 7: In column 7, sele ct the PVC process wastewater treatment system ID that the

non

- PVC production process wastewater stream enters, based on the ID(s) provided in Table 1 on Form B

- 3.

Form E

- 1

- b

– Maintenance Wastewater

 Complete Form E

- 1

- b for maintenance wastewater.

 Indicate if your facility is subject to any Federal, State, local or other requirements to store, treat or otherwise handle maintenance wastewater. If so, provide the regulation citation or permit requirement as appropriate.

 If your facility is not subject to any Federal State, local or other requirements for maintenance wastewater, provide responses to the remaining questions on the Form.

Form E

- 2

- a

– 30 Day PVC Process Wastewater Sampling and Analysis Data

 Refer to Attachment B, “Summary of Test Procedu res, Methods and Reporting Requirements for Resin and Process Wastewater Sampling and Analysis at Polyvinyl Chloride and Copolymers Facilities” of this enclosure for requirements and instructions regarding sampling and analyzing process wastewater in respo nse to this information collection request. Use Form E

- 2

- a to record and submit your process wastewater sampling and analysis results, following the instructions included in the Form and Attachment B.

Form E

- 2

- b

– 30 Day PVC Process Wastewater Sampling P roduction Data

 For questions 1 and 2 on Form E

- 2

- b, provide the process wastewater sampling start and end dates

.

 For question 3, provide the type and total pounds of resin produced during the sampling period. If more than 1 type of resin was produced, sel ect “other” and indicate all types of resins produced in response to 3.c.

 In response to question 4, provide the resin production information for resin production that generated wastewater that was treated during the sampling period.

 Provide the total daily maximum PVC production capacity in response to question 5.Enclosure 1

PVC Section 114 Enclosure 1

- Page 14 04/01 /2014 Form F

– Control Devices

General Instruction

 Complete Form F

- 1 for each absorber used as a control device, or for any absorber that emits directly to the atmosphere

.

 Complete Form F

- 2 for each thermal or catalytic oxidizer.

 Complete Form F

- 3 for each cond enser used as a control device or for any condenser that emits directly to the atmosphere.

Specific Instructions by Form Row

Form F

- 1

 Rows 1

- 2: Select the type of equipment (i.e., c ontrol device, recovery equipment or process equipment). Then in row 2, select the equipment ID you entered into the corresponding Form B

.

 Rows 3

- 4 : Select the type of absorber from the pick list. If “other,” provide a description of the absorber type in r ow 4.

 Rows 5

- 14 : Provide the operating characteristics of the absorber in rows 5 through 14. Provide as much of the information as possible.

 Rows 15

- 16: Indicate the year the equipment was installed and cite any applicable regulations.

Form F

- 2

 Row 1: Select the control device ID (based on the values you entered in Form B

- 1).

 Rows 2

- 3 : Provide the number of operating hours per year and indicate if the device is considered emergency equipment.

 Row 5 : Indicate the type of oxidizer (i.e., thermal or catal ytic).

 Rows 6

- 35: Provide the design parameters and operating characteristics requested in rows 6 though 35. Complete as much of the information as possible for each oxidizer.

 Rows 36

- 37: Indicate the year the equipment was installed and cite any applicabl e regulations.

Form F

- 3

 Rows 1

- 2: Select the type of equipment (i.e., control device, recovery equipment, or process equipment). Then in row 2, select the equipment ID you entered into the corresponding Form B.

 Rows 3

- 4 : Select the type of condenser from the pick list. If “other,” provide a description of the condenser type in row 4.Enclosure 1

PVC Section 114 Enclosure 1

- Page 15 04/01 /2014  Rows 5

- 12 : Provide the operating characteristics of the condenser in rows 5 through 1 2

. Provide as much of the information as possible.

 Rows 15

- 16: Indicate the year the equipment was installed, and cite any applicable regulations.

Form G

– Cooling Towers and Heat Exchange Systems

 Complete Form G for each recirculating heat exchange system (cooling tower) at the PVC production facility following the instructions contained within the form. If the facility has multiple cooling towers, complete a copy of Form G for each cooling tower.

 In Table 1.a, provide the requested cooling tower identification information including the equipment ID as entered on Fo rm B

- 4 and the total cooling tower return flow rate in gallons per minute. Indicate the number of processes served by the cooling tower and how many of the processes are from a PVC production process unit. Indicate if the heat exchange system is monitored for the presence of one or more HAP or VOC in the cooling water.

 In Table 1.b, provide the requested information regarding cooling tower emission reduction measures. If individual cooling tower return lines are monitored individually, provide the informati on for each heat exchange system from a PVC production process unit; otherwise, provide the requested information for the cooling tower.

 In Table 2, indicate if your PVC production facility uses any once

- through heat exchange systems. If you created copie s of Form G because you operate multiple cooling towers, a response for Table 2 is only required for one copy of Form G.

 S ubmit copies for 20 13 of monitoring data, records or any leaks detected, dates of efforts to repair leaks, methods and procedures used to confirm repair of leaks and dat es final repairs were completed.

 Submit a copy of the heat exchange system leak detection and repair procedures.

Form H

– Equipment Leaks

 Complete Form H for equipment leaks at the PVC production facility

.

 Provide information regarding your facility’s leak detection and repair ( LDAR ) program in Table 1.

 In Table 2, p rovide equipment counts for all equipment at your facility in the source category. In addition, provide the subtotal of the equipment that are a ssociated with your closed vent system(s).

 In addition to completing Form H, s ubmit a copy of the leak detection and repair procedures for the facility

.Enclosure 1

PVC Section 114 Enclosure 1

- Page 16 04/01 /2014 Form I

– Equipment Opening

Table 1

 Complete this Form for each piece of process equipment

, recovery equipment and any additional equipment that is not assigned an equipment ID (e.g., in

- line filters).

 Complete a separate Form I for each piece of process equipment , recovery equipment or other equipment that was opened in 2013

. Identify the equipm ent (by selecting the recovery

or process equipment ID from Form s B

- 2 or B

- 4 if applicable). Indicate the number of times the equipment was opened during 2013 and the reasons for opening the equipment (list all that apply). Provide the equipment volume in cubic meters.

 Indicate how the HAP concentration of the equipment is determined, and how (if at all) HAP emissions are controlled.

Table 2

 In Table 2, list the individual HAP present in the equipment and the concentration of each HAP at the equipment opening.

 Provide the total mass of each HAP emitted from opening the equipment in 2013, and a basis for the emissions values. Values should be reported for normal operations; not for startups, shutdowns, or malfunctions.

 Provide copies of estimation worksheets and any other relevant documentation.

 If any material is removed from the equipment, complete Form J.

Form J

– Off

- Specification Resin an d Material Removal from Equipment

 Form J covers resin that is removed from equipment and is not processed further through the normal processing steps

. Examples include, but are not limited to, off

- specification resin removed from the polymerization reacto r or any other downstream process equipment, resin removed from equipment during maintenance and cleanout operations, etc. Complete Form J if any material was removed from equipment in 2013. Complete this Form for individual equipment, including equipment that is not assigned an Equipment ID (e.g., in

- line filters).

Table 1

 In Table 1, identify the equipment from which the material was removed and the amount of material removed in 2013. Provide detailed descriptions of the procedures used to remove the

ma terial, the procedure for controlling HAP emissions from the material during and after removal from equipment, and the fate/disposition of the material beginning from the time it is removed from the equipment.Enclosure 1

PVC Section 114 Enclosure 1

- Page 17 04/01 /2014 Table 2

 In Table 2, identify the individual HAP and concentration present in the material immediately prior to removal from the equipment and before being mixed with other materials or fluids. In the “Notes” column, provide the basis for the concentration value.

 For all resin in 20 13 that was discharged from further processing, did not continue through the process under normal operating conditions or was otherwise removed from the polymer ization reactor(s) as off

- grade or off

- specification resin or removed at a ny other point in the process unit other than finished resin storage ; submit with your response records of:

 Resin type and resin grade

 Amount of resin removed (in pounds)

 HAP and VOC content (weight %)

 Description of the circumstances that resulted in the removal of the resin from the process, and

 Ultimate disposition of the resin

Form K

- 1

– Tanks, Vessels, and Portable Containers Used for Feedstock Storage, Product Storage, Vent Gas Storage, Holding, and Wastewater

 Complete a separate Form K

- 1 for each tank, vessel portable container used for feedstock storage, product storage, holding and wastewater, including surge control vessels that are used to hold process vent gas prior to the control device for 2013 only. Do not include gas holders on Form K

- 1 (refer to Attachment A, Section V of this Enclosure for the definition of a gas holder). Complete Form K

- 2 for gas holders.

 In Table 1, identify the process equipment by selecting the equipment ID provided on Form B

- 4 (if applicable). If the equipment was not identified on Form B

- 4, provide an equipment description.

 Provide a detailed description of the equipment, and include (if applicable) if the tank is a fixed, floating internal, or floating external roof.

 Select the purpose of the equipment from the pick list provided. If no ne of the options on the pick list accurately describe the purpose of the equipment, please select “Other” and specify the purpose in the next row.

 Indicate the number of turnovers for 2013, the equipment volume and the average storage temperature

.

 Indicate how the HAP concentration of emissions from the tank/vessel/container are determined and if HAP emissions are controlled, identify the method of control.

 In Table 2, indicate the individual HAP contained in the tank/vessel/portable container and
t he corresponding vapor pressure. Provide concentration values and total emissions for 2013.

 Provide copies of estimation worksheets and any other relevant documentation.Enclosure 1

PVC Section 114 Enclosure 1

- Page 18 04/01 /2014 Form K

- 2

– Gas Holders

 In Table 1, indicate if your facility uses gas holders (re fer to Attachment A, Section V of this Enclosure for the definition of a gas holder) . If you answer “No,” do not complete the remainder of the Form. If “Yes,” provide the number of gas holders at the PVC production facility, and if HAP emissions are contro lled, provide a description of the method of control.

 In Table 2, identify the individual HAP present in the gas holders at the PVC production facility and their corresponding vapor pressures. Provide the total emissions of each HAP for 2013. Describe the method used to estimate emissions from gas holders in the “Notes” column of Table 2.

Form L

– Startup, Shutdown and Malfunction

 Complete Form L for startups, shutdowns and malfunctions during 2013 as completely as possible

.

 Each column in Form L represen ts a single startup, shutdown or malfunction event. Provide emissions in total pounds for the event.

 S ubmit with your response to this information collection request , copies of all records of emissions during periods of process startup, shutdown and malfunctions for 2013.

Form M

– Factors that Affect HAP/VOC Emissions Reductions

 On Form M, provide the requested information regarding pollution reduction or source reduction measures taken by the PVC production facility.

 During the completion of F orm M , clearly distinguish between pollution reduction and source reduction measures

. Pollution reduction measures alter the physical, chemical or biological characteristics or the volume of a HAP and VOC through a process or activity which itself is not i ntegral to and necessary to produce a product or provide a service

. The use of “add

- on” devices to capture and control (recover or destroy) HAP and VOC emissions are pollution reduction measures

. In contrast, source reduction measures reduce the amount of any HAP and VOC prior to recycling, treatment or disposal

. Source reduction measures include equipment or technology modifications, process or procedure modifications, reformulation or redesign of products, substitution of raw materials and improvements in housekeeping, maintenance, training or inventory control.

Form N

– Miscellaneous

 This Form includes a question on whether the controls or process changes on the source are the result of new source review (NSR) requirements

. The last question asks the re spondent to describe any other factors not addressed in the above questions that might serve to distinguish subcategories

.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 1 04/01/2014 BACKGROUND FOR POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION MACT STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST

A

- I. Introduction

The purpose of this attachment is to provide the respondent with additional detail on the relevant requirements of the Clean Air A ct , the regulatory background of the polyvinyl chloride and copolymers production source category and to provide a list of definitions of key terms used in the information collection request

.

A

- II. Summary of Clean Air Act Requirements

The maximum ach ievable control technology (MACT) standards development information collection request was developed by the U. S. Environmental Pro tection Agency’ s (EPA) Office of Air Quality Planning and Standards Emission Standards Division (OAQPS/ESD) to help the EPA m eet its obligations under the Clean Air Act Amendments of 1990

. Specifically, the Clean Air Act Amendments require the EPA to develop regulations under Section 112(d) to limit emissions of hazardous air pollutants (HAP) from major and area sources of emissions

. Section 11 2(a)(1) defines a major source as “ any stationary source or group of stationary sources located within a contiguous area and under common control that emits or has the potential to emit considering controls, 10 tons per year or more of any hazardous air pollutant or 25 tons per year or more of any combinati on of hazardous air pollutants.” Based on the Administrator’ s determination, the EPA may lower the major source cutoff for indi vidual HAP

. An area source is “ any stationary source of hazardous air pollutant s that is not a major source.”

The Clean Air Act Amendments of 1990 prescribe an analytical framework that the EPA is to apply in developing national emission standards for hazardous air pollutants (NESHAP) for major sources

. A k ey concept in this framework is the establishment of the MACT floor

. The amendments specify that NESHAP for existing sources in a particular category or subcategory are to be no less stringent (but may be more stringent) than the average emission limitatio n achieved by the best performing 12 percent of the existing sources in such category or subcategory of sources

. In categories or subcategories with less than 30 sources, the floor is to be based on the average emission limitation achieved by the best perf orming 5 sources

. The MACT floor for new sources is the emission control that is achieved in practice by the b est controlled similar source.

The Clean Air Act Amendments allow the EPA Administrator to "distinguish among classes, types, and sizes of sour ces within a category or subcategory in establishing such standards" (Section 112(d)).

A

- III. Regulatory Background for the Po lyvinyl Chloride and Copolymers Production Source Category

On October 21, 1976, the EPA promulgated emission standards for vin yl chloride under the risk

- based standard then in effect (41 FR 46560; 40 C.F.R. Subpart F (§§ 61.60

- 61.71); “the Part 61 NESHAP”)

. When Congress amended the CAA in 1990, it required the EPA toDRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 2 04/01/2014 implement technology based standards

. As a result, the EPA p roposed MACT standards for the Polyvinyl Chloride and Copolymers Production source category on December 8, 2000 (65 FR 76958) and promulgated final MACT standards for the source category on July 10, 2002 (67 FR 45886) (“the Part 63 NESHAP”)

. EPA adopted mo st of the Part 61 NESHAP as the new Part 63 NESHAP and the Part 61 standards became the MACT floor for existing sources.

Mossville Environmental Action NOW and Sierra Club petitioned the U.S. Court of Appeals of the District of Columbia to review various provisions of the Part 63 NESHAP

. The Part 63 NESHAP was vacated on June 18, 2004 in Mossville v. EPA, 370 F. 3d. 1232 (D.C.Cir. 2004) and remanded to the agency for it to reconsider or properly explain its methodology for regulating HAP s emitted in PVC production other than vinyl chloride by use of a surrogate.

On April 17, 201 2 , the EPA promulgated revised standards for PVC major and area sources. After promulgation, the Administrator received petitions for reconsideration of certain provisions in the final rules.

The purpose of the current information collection is to gathe r data from additional PVC production facilities that were not included in the EPA’s data collection efforts in support of the April 201 2 rulemaking

. The collected data will support analyses of environmental and economic impacts of various revisions to the current Part 63 NESHAP

.

A

- A

- IV. Guidance Documents

Following is a list of EPA guidance documents and resources that may be useful to respondents in estimating HAP emissions

.

1. Compilation of Air Pollutant Emission Factors: Volume I: Stationary Point and Area Sources

. U. S. Environmental Protection Agency

. Research Triangle Park, N.C

. 1995

. http://www.epa.gov/ttn/chief/ap42/index.html

2. Factor Information Retrieval (FIRE) Data System

. U. S. Env ironmental Protection Agency

. http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main

3. Protocol for Equipment Leak Emission Estimates

. U. S. Environmental Protection Agency

. Research Triangle Park, N.C

. November 1995

. Publication No.: EPA

45 3 / R

- 9 5

- 01 7

.

4. Batch Process ACT

. U. S. Environmental Protection Agency

. Research Triangle Park, N.C. February 1994

. Publication No.: EPA

- 453/R

- 94

- 020.

A

- V. Key Term Definitions

The following definitions are provided for the purpose of the information collection request only

. They are not intended to replace statutory definitions or regulatory definitions developed elsewhere.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 3 04/01/2014 Bulk process/ resin : A process for producing polyvinyl chloride resin that is characterized by a two

- step anhydrous polymerization process: the formation of small resin particles in a pre

polymerized reactor using small amounts of vinyl chloride monomer, an initiator, and agitation; and the growth of the resi n particles in a post polymerization reactor using additional vinyl chloride monomer

. Resins produced using the bulk process are referred to as bulk resins.

Control device : A combustion device, recovery device, recapture device, or any combination of these devices used to comply with a regulation, numerical emission limit, work practice standard, etc

. Process condensers are not control devices.

Dispersion process/resin : A process for producing polyvinyl chloride resin that is characterized by the formation of the polymers in soap micelles that contain small amounts of vinyl chloride

monomer

. Emulsifiers are use to disperse vinyl chloride monomer in the water phase. Initiato rs used in the dispersion process are soluble in water. Resins produced using the dispersion process are referred to as latex or dispersion resins.

Feedstock: Raw ma terial/input to the process unit

.
Gas Holder: A surge control vessel with a bell that is floating in a vessel filled with water that is used to store gases from the PVC production process prior to being recovered or sent to a process vent control device. The bell rises and falls as low

pressure gases enter and leave the space beneath the bell and the water provides a seal between the enclosed gas within the floating bell and the ambient air.

Hazardous Air Pollutants (HAP): See 42 U.S.C. §7412(a)(6).DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 4 04/01/2014 Maintenance wastewater: Wastewater generated by the draining of process fluid from components in the PVCPU into an individual drain system prior to or during maintenance activities. Maintenance wastewater can be generated during planned and unplanned shutdowns and during periods not associated with a shutdown. Examples of activities that can genera te maintenance wastewaters include descaling of heat exchanger tubing bundles, hydroblasting PVCPU process components such as polymerization reactors, vessels and heat exchangers, draining of low legs and high point bleeds, draining of pumps into an indivi dual drain system, draining of portions of the PVCPU for repair and water used to wash out process components or equipment after the process components or equipment has already been opened to the atmosphere.

Malfunction: A ny sudden, infrequent and not rea sonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be

exce eded

. Failures that are caused in part by poor maintenance or careless operation are not malfunctions. (40 CFR 63.2)

Polyvinyl Chloride and Copolymers Production Facility : The collection of all polyvinyl chloride and copolymers production process unit, st orage vessels, surge control vessels, heat exchange systems, wastewater, and process wastewater treatment systems that are associated with producing polyvinyl chloride.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 5 04/01/2014 Polyvinyl Chloride and Copolymers Production Process Unit or PVCPU : A collection of process components assembled and connected by hard

- piping or duct work, used to process raw materials and to manufacture polyvinyl chloride and/or polyvinyl chloride copolymers. A PVCPU includes, but is not limited to, polymerization reacto rs; resin stripping operations; resin blend tanks; resin centrifuges; resin dryers; resin product separators; recovery devices; reactant and raw material charge vessels and tanks; holding tanks, mixing and weighing tanks; finished resin product storage tan ks or storage silos; finished resin product loading operation; connected ducts and piping; equipment including pumps, compressors, agitators, pressure relief devices, sampling connection systems, open

- ended valves or lines, valves and connectors and instru mentation systems. A PVCPU does not include chemical manufacturing process units, as defined in §63.101, that produce vinyl chloride monomer or other raw materials used in the PVC polymerization
process.
Polyvinyl Chloride and Copolymer Resin (PVC Resin):

Polyvinyl Chloride Copolymer:

Polyvinyl Chloride Homopolymer: The general reference to any PVC homopolymer or copolymer resin manufactured by the suspension, dispersion, bulk , and/or solution processes.

A synthetic thermoplastic polymer that is derived from the simultaneous polymerization of vinyl chloride and another monomer such as vinyl acetate. Polyvinyl chloride copolymer is produced by different processes, including, but not limited to, suspension, dispersion/emulsion, suspension blending, and solution processes.

Polyvinyl chloride homopolymer means a synthetic thermoplastic polymer that is derived from the polymerization of vinyl chloride and has the general chemical structure (

- H2CCHCl

- )n. Polyvinyl chloride homopolymer is typically a whi te powder or colorless granule. Polyvinyl chloride homopolymer is produced by different processes, including (but not limited to), suspension, dispersion/emulsion, blending and bulk
processes.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 6 04/01/2014 Process equipment: Any unit operation or group of unit opera tions or any part of a process or group of parts of a process that are assembled to perform a specific function. Examples of process equipment include, but are not limited to, polymerization reactors, PVC resin strippers, resin dewatering and dry ing equipm ent storage tanks and vessels, cooling towers and heat exchange systems, and transfer operations

.
Process unit : The process components assembled and connected by pipes or ducts to process raw and/or intermediate materials and to manufacture an intended product. For the purposes of this information collection request , process unit includes, but is not limited to, pol yvinyl chloride production process.

Process w astewater : Wastewater that comes into direct contact with HAP or results from the production or use of any raw material, intermediate product, finished product, by

- product or waste product containing HAP, but t hat has not been discharged untreated as wastewater. Examples are product tank drawdown or feed tank drawdown; water formed during a chemical reaction or used as a reactant; water used to wash impurities from organic products or reactants; water used to

co ol or quench organic vapor streams through direct contact; water discarded from a control device; and condensed steam from jet ejector systems pulling vacuum on vessels containing organics. Gasholder seal water is not process wastewater until it is removed from the gasholder.

Process wastewater stream: Each individual waste stream exiting an individual piece of process equipment (including, but not limited to, resin stripping equipment, knockout pots, condensers, centrifuges, and scrubbers) prior to being combined with any other stream

. Process wastewater streams also include combined streams exiting wastewater collection tanks, wastewater treatment equipment/processes, etc.

PVC process wastewater treatment equipment: An individual piece of equipment capable of and normally used for the purpose of removing organic compounds from a process wastewater stream, used alone or in combination with other PVC process wastewater treatment equipment. Examples include, but are not limited to, wastewater collection , holding, and equalization tanks, wastewater steam and vacuum strippers, and wastewater stripper feed/bottoms heat exchanger.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 7 04/01/2014 PVC p rocess wastewater treatment system: A collection of PVC process wastewater treatment equipment that remove s organic compoun ds from a process wastewater stream before the process wastewater stream is discharged from the PVC production facility.

Recovery e quipment : Recovery equipment means an individual piece of equipment capable of and normally used for the purpose of recovering chemicals for fuel value (i.e., net positive heating value), use, reuse, sale , and/or destruction or disposal . Examples of equipment that may be recovery equipment include gas holders, compressors , condensers, and liquid separators used to recover vinyl chloride or other feedstocks from gaseous streams such as resin stripper and wastewater stripper overheads and return those feedstocks for reuse in the resin production process and/or eventual destr uction or disposal . For the purposes of this information collection request, wastewater steam and vacuum strippers are considered PVC process wastewater treatment equipment and not recovery equipment.

Recovery s ystem : A recovery system is a collection of recovery equipment

. A recovery system typically vents to a control device such as a thermal oxidizer and acid gas scrubber.

Resin grade: T he subdivision of PVC resin that describes it as a unique resin, i.e., the most exact description of a type of resin with no further subdivision

. Examples include low molecular weight suspension resins and general purpose suspension resins.

Resin stripper : A unit that removes organic compounds from a raw polyvinyl chloride and copolymer product. In the production of a polymer, stripping is a discrete step that occurs after the polymerization reaction and before drying or other finishing operations. Examples of types of stripping include steam stripping, vacuum stripping, or other methods of devolatilization. For the purposes of this information collection request , devolatilization that occurs in dryers or other finishing operations is not resin stripping. Res in stripping may occur in a polymerization reactor or is a batch or continuous stripper separate from the polymerization
reactor.

Shutdown: T he cessation of operation of an affected source or portion of an affected source for any purpose. (40 CFR 63.2)DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 8 04/01/2014 S tartup: T he setting in operation of an affected source or portion of an affected source for any purpose. (40 CFR 63.2)

Stream: Any contained or non

- contained solid, liquid, gas, or vapor entering or exiting an individual unit operation or single piece of equipment.

Stripped resin: The material exiting the resin stripper than contains polymerized vinyl chloride.

Suspension blending process /resin : A process for producing polyvinyl chloride resin that is similar to the suspension polymerization process, but employs a rate of agitation that is significantly higher than the highest range for non

- blending suspension resins. The suspension b l e nd ing process uses a recipe that creates extremely small resin particles, generally equal to or less than 100 microns in size, with a glassy surface and very little porosity. The suspension blending process concentrates the resins using a centrifuge that is specifically designed to handle these small particles. Polyvinyl chloride resins produced using the suspension blendin g process are referred to as suspension blending resins and are typically blended with dispersion resins.

Suspension process/resin: A process for producing polyvinyl chloride resin that is characterized by the formation of the polymers in droplets of liqu id vinyl chloride monomer or other co

- monomers suspended in water

. The droplets are formed by agitation and the use of protective colloids or suspending agents. Initiators used in the suspension process are soluble in vinyl chloride monomer. Polyvinyl chlo ride resins produced using the suspension process are referred to as suspension resins.

Type of Resin: T he broad classification of PVC homopolymer and copolymer resin referring to the basic manufacturing process for producing that resin, including, but not limited to, suspension, dispersion, bulk , and solution processes.
Volatile Organic Compounds (VOC): See 40 CFR 51.100(s).

Waste management: Handling, treatment, storage, and disposal of waste products.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 9 04/01/2014 Wastewater: Process wastewater and maintenance wastewater. The following are not considered wastewater for the purposes of this subpart:

(1) Stormwater from segregated sewers; (2) Water from fire

- fighting and deluge systems, including testing of such systems; (3) Spills; (4) Water from safety showers; (5) Samples of a size not greater than reasonably necessary for the method of analysis that is use; (6) Equipment leaks; (7) Wastewater drips from procedures such as disconnecting hoses after cleaning lines; and (8) Noncontact cooling water.DRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 10 04/01/2014 A

- V I

. Key Acronyms and Units of Measure

% percent

acfm actual cubic feet per minute

acfm/ft 2 actual cubic feet per minute per square foot

batches/yr batches per year

B tu /scf British thermal units per standard cubic foot

CAA Clean Air Act

day/yr days per year

DC District of Columbia

dscfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

ft feet

ft/s feet per second

ft 3 /1,000 afcm cubic feet per thousand actual cubic feet per minute

gpm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

in inches

in H 2 O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallonDRAFT Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 11 04/01/2014 LDAR leak detection and repair

MACT maximum achievable control technology

mg/l milligrams per liter

MMlb/yr million pounds (mass) per year

NAICS North American Industry Classification System

NESHAP National Emission Standards for Hazardous Air Pollutants

OAQPS Office of Air Quality Planning and Standards

oC degrees Celsius

oF degrees Fahrenheit

ohm

- cm ohm

- centimeter

P&ID piping and instrumentation diagram

PFD process flow diagram

ppmv parts per million, by volume

ppmw parts per million, by weight

PVC polyvinyl chloride

s second or seconds

scfm standard cubic feet per minute

SPPD Sector Policies and Programs Division

ton/yr tons per year, or short tons per year

VOC Volatile Organic Compounds

vol% volume percent, or percent by volume

wt% weight percent, or percent by weightEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 1 04/01/2014 

## Summary of Test Procedures, Methods, And Reporting Requirements For Resin and Process Wastewater Sampling and Analysis at Polyvinyl Chloride and Copolymer (PVC) Facilities

Under the authority of Section 114 of the Clean Air Act, EPA is requesting resin and process wastewater sampling and analysis for facilities whic h produce polyvinyl chloride and copolymers (PVC). This sampling program requires you to collect resin samples from the outlet of each resin stripper and process wastewater samples from the outlet of process wastewater treatment system(s) which treat proce ss wastewater streams originating from the affected source as defined in 40 CFR Part 63, Subpart HHHHHHH or DDDDDD.

All recipients must complete the sampling and analysis and submit the results, reports, and documentation specified in Section 2.0 no later than July 31 , 2014 . Any submissions made after this date will be in violation of this Section 114 request.

This document provides an overview of approved sampling and analytical methods, target pollutants, and reporting requirements for PVC production facilities required to provide resin sampling and process wastewater sampling data based on this section 114 request. The purpose for this testing is to gather data on hazardous air pollutant (HAP) emissions from stripped resin and process wastewater in th is source category. The document is organized as follows:

1.0 Sampling Procedures and Analysis Methods 1.1 Process Wastewater 1.2 Stripped Resin 2.0 Data Reporting Procedures 2.1 Process Wastewater 2.2 Stripped Resin 3.0 Data Submission Procedures 4.0 Contact Information for Questions



### 1.0 Sampling Procedures and Analysis Methods

1.1 Process Wastewater

We are requiring sampling of each stream exiting the PVC process wastewater treatment system(s) at your facility. Sampling of each process wastewater treatment system is required for all HAP listed in Table 1, which can be detected by EPA methods listed within that same table. You must conduct sampling, sample preservation and sample storage in accordance with the specific methodology listed in Table 1 and Section 4.1.2 of SW

- 846 (Chapter 4

– Organic Analytes). You must collect one grab sample per PVC process wastewater treatment system for 30 consecutive operating days. The samples must be taken during normal operating conditions. If you have a batch process wastewater treatment system that does not operate continuously, youEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 2 04/01/2014 must sample the outlet of that batch system once for each day while it is operating such that at least 30 samples can be analyzed. [Note: Batch processes requiring multiple sample s per batch should equally distribute the samples across the time taken for the effluent to discharge from the process to properly represent the concentration.] If you have more than one PVC process wastewater treatment system, the results must be reported separately for each day and for each treatment system (i.e., the results cannot be averaged). If you have identical water treatment systems that run in parallel and the outlet streams are not combined, you only need to sample one stream (however, include the combined flow rates for each stream). If you have identical water treatment systems that run in parallel and the outlet streams are combined, then the sample must be taken after the streams are combined and the combined flow rate must be included. Each sample must be analyzed for the HAP listed in Table 1 and for any other HAP expected to be present but not listed in Table 1.

1.2 Stripped Resin

We are requiring sampling of each type of resin at the base of each PVC resin stripper at your facility. Resin s ampling is required for all HAP listed in Table 1, for any other HAP expected to be present but not listed in Table 1, which can be detected by EPA methods listed within that same table. You must conduct sampling, sample preservation and sample storage in accordance with the specific methodology listed in Table 1 and Section 4.1.2 of SW

- 846 (Chapter 4

– Organic Analytes). You must collect, at a minimum, at least one grab sample per resin grade produced every 8 hours, or per grade of PVC resin produced, whic hever is more frequent, at the outlet of each PVC stripper for 30 consecutive operating days. The grab samples may be composited by resin type and must be collected during normal operating conditions. If you have a batch PVC resin stripping operation that does not operate continuously, you must sample the outlet of the associated resin stripper for each batch of stripped resin such that at least 30 samples can be analyzed.

Table 1. PVC Resin and Process Wastewater HAP

CAS No. HAP Analyte Category Analysis Method 107211 Ethylene Glycol Alcohol SW

- 846

- 8015C 67561 Methanol Alcohol SW

- 846

- 8015C 75070 Acetaldehyde Aldehyde SW

- 846

- 8315A 50000 Formaldehyde Aldehyde SW

- 846

- 8315A 51285 2,4

- Dinitrophenol SVOC SW

- 846

- 8270D 98862 Acetophenone SVOC SW

- 846

- 8270D 117817 Bis(2

- Ethylhexyl) Phthalate (DEHP) SVOC SW

- 846

- 8270D 123319 Hydroquinone SVOC SW

- 846

- 8270D 108952 Phenol SVOC SW

- 846

- 8270D 79345 1,1,2,2

- Tetrachloroethane VOC SW

- 846

- 8260B 106990 1,3

- Butadiene VOC SW

- 846

- 8260B 540841 2,2,4

- Trimethylpentane VOC SW

- 846

- 8260B 71432 Benzene VOC SW

- 846

- 8260B 108907 Chlorobenzene VOC SW

- 846

- 8260BEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 3 04/01/2014 67663 Chloroform VOC SW

- 846

- 8260B 126998 Chloroprene VOC SW

- 846

- 8260B 98828 Cumene VOC SW

- 846

- 8260B 75003 Ethyl Chloride (Chloroethane) VOC SW

- 846

- 8260B 100414 Ethylbenzene VOC SW

- 846

- 8260B 107062 Ethylene Dichloride (1,2

- Dichloroethane) VOC SW

- 846

- 8260B 75343 Ethylidene Dichloride (1,1

- Dichloroethane) VOC SW

- 846

- 8260B 74873 Methyl Chloride (Chloromethane) VOC SW

- 846

- 8260B 75092 Methylene Chloride VOC SW

- 846

- 8260B 110543 n

- Hexane VOC SW

- 846

- 8260B 108883 Toluene VOC SW

- 846

- 8260B 71556 Methyl Chloroform (1,1,1

- Trichloroethane) VOC SW

- 846

- 8260B
79005 1,1,2

- Trichloroethane VOC SW

- 846

- 8260B 108054 Vinyl Acetate VOC SW

- 846

- 8260B 593602 Vinyl Bromide VOC SW

- 846

- 8260B 75014 Vinyl Chloride VOC EPA Method 107 75354 Vinylidene Chloride (1,1

- Dichloroethylene) VOC SW

- 846

- 8260B 1330207 Xylenes (isomers and mixtures) VOC SW

- 846

- 8260B SVOC

– semi

- volatile organic compound VOC

– volatile organic compound
For copies of the recommended U.S. EPA SW

- 846 methods, please refer to EPA’s SW

- 846 Online website: http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm

.


### 2.0 Data Reporting Procedures

Your facility’s submission in response to this request must include completed copies of the Microsoft Excel 2007 workbook that accompanies this request. Report your sampling and analysis results using Forms D

- 2, E

- 2

- a, and E

- 2

- b as described in Section V of Enclosure 1. A report from the entity (e.g., external or on

- site laboratory) analyzing samples associated with this request that contains all analytical procedures, results, and QA/QC measures must be submitted. This repo rt shall also include results of current proficiency samples analyses for all compounds and their appropriate method performed by the entity (e.g., external or on

- site laboratory) analyzing samples associated with this request. These analyses should have b een performed in the last calendar year. If proficiency samples to cover all compounds and methodologies cannot be procured, proof of analysis of a second source calibration standard during the sample analysis must be submitted.

The enclosed certification statement must be signed by a responsible official.

2.1 Process Wastewater A report that includes of all of the following must be included for process wastewater:Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 4 04/01/2014 1. A schematic diagram of the process wastewater treatment system showing where the samples w ere taken and the sampling apparatus/configuration;

2. Identify the method used to collect, store, transport, and analyze the wastewater samples. More specifically, certify which of the following methods was used: EPA Method 107, EPA SW 846 with the specific sampling extraction and analytical methods, or another method. If another method was used, summarize that method and include a complete copy of the method along with your test report;

3. A certification that each group responsible for collecting, storing, tr ansporting, and analyzing the wastewater was familiar with and understood the provisions and requirements of each method, for EPA Method 107, the Interferences; Safety; Equipment and Supplies; Reagents and Standards; Sample Collection, Preservation, Storag e, and Transport; Quality Control; Calibration and Standardization; Analytical Procedure; and Calculations and Data Analysis provisions and requirements, and

a. Performed its role without deviating from the EPA method used to collect, store, transport, and analyze resin samples, or b. Lists each and every deviation from the EPA method, along with an assessment of the impact on PVC results of each and every deviation. 4. For each compound iden tified during analysis , list its method detection level and the

mean s by which the detection level was calculated

. Affirm the value reported in the information collection request response forms is the method detection level and not some other level (e.g. reportable quantification level, method quantification) and supply ca lculations used to determine these values ; and

5. Quality assurance/quality control measures implemented during sampling and analysis. 2.2 Resin Sampling A report that includes of all of the following must be included for resin analysis:

1. A simplified block di agram depicting the location in the process where each of the resin samples was taken (e.g. stripper bottom), and throughput rates for total wet resin and dry resin;

2. Identify personnel responsible for collecting, storing, transporting, and/or analyzing

r esin samples. More specifically, identify whether your employees, the emissions testing company, the analytical laboratory or some other group was responsible for collecting the resin samples. If some other group collected the resin samples, name that grou p. In the same manner, identify the group responsible for storing, transporting, and analyzing resin samples;

3. Identify the method used to collect, store, transport and analyze the resin samples. More specifically, certify which of the following methods wa s used: EPA Method 107, EPA SW 846 with the specific sampling extraction and analytical methods, or another method. If another method was used, summarize that method and include a complete copy of the method along with your test report;Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 5 04/01/2014 4. A certification t hat each group responsible for collecting, storing, transporting, and analyzing the resin was familiar with and understood the provisions and requirements of each method, for EPA Method 107, the Interferences; Safety; Equipment and Supplies; Reagents and S tandards; Sample Collection, Preservation, Storage, and Transport; Quality Control; Calibration and Standardization; Analytical Procedure; and Calculations and Data Analysis provisions and requirements, and

a. Performed its role without deviating from the EPA method used to collect, store, transport, and analyze resin samples, or b. Lists each and every deviation from the EPA method, along with an assessment of the impact on PVC results of each and every deviation.

5. A narrative describing the procedure(s) us ed to obtain and maintain the integrity of the resin samples prior to analysis, including but not limited to:

a. How the resin samples were collected; b. Type of container used to collect samples (e.g. vials, glass jars);

c. The capacity of the sample containers; d. L ength of time between sample collection and sample analysis;

e. Procedure(s) used to preserve samples (e.g. samples maintained at a certain temperature, identification of preservatives added, head space);

6. If samples were composited, identification of the process(es) by which the samples were composited; otherwise, a statement that samples were not composited;

7. Identification of the process(es) used to extract the sample for analysis (e.g. semi

volatile, vo latile, and solid portions) for the PVC resin and the slurry water/slurry resin;

8. The procedure(s) used to analyze the sample (e.g, flame ionization detection and gas chromatography), as well as a list of reagents used during the analysis for which the

sam ples were analyzed, the analytes used during the analysis, and a description of how the semi

- volatile, VOC, methanol (if applicable), aldehydes and total solid samples were prepared and analyzed;

9. A narrative describing the procedure(s) used to maintain th e integrity of the resin samples during analysis, including but not limited to:

a. Steps taken to reduce loss of analyte immediately before and during analysis; b. Duration of sample analysis; and

c. Temperature of sample during analysis;

10. A description of the proc ess used to report the results of the analysis, including an explanation that clarifies how the original resin sampling data were translated into concentration values. The explanation must include all assumptions as well as sample calculations for each typ e of calculation conducted; and

11. For each compound iden tified during analysis, list its method detection level and the means by which the detection level was calculated

. Affirm the value reported in theEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 6 04/01/2014 information collection request response forms is the method detection level and not some other level (e.g. reportable quantification level, method quantification) and supply calculations used to determine these values.

We believe that the Clean Air Act is clear that it is incumbent on the source and the te ster to apply methods and procedures resulting in data quality necessary for those decisions including providing for the lowest possible detection limits considering practical and reasonable limitations. For example, source owners and testers should not au tomatically choose to use low or medium quality equipment for testing (e.g., for cost reasons) if high quality equipment is reasonably available. We will review test reports in light of this expectation and will be particularly mindful of whether the testi ng procedures applied are representative of the highest reasonably expected capabilities (e.g., comparing reported minimum measurement detection levels between tests and testers). If we believe that a source owner or tester has failed to meet the requireme nt of the Clean Air Act to provide data sufficient for decisions, we can and will request additional measurements requiring the use of improved testing procedures.

You must use the method detection limit (MDL) determination procedure in 40 CFR part 136, A ppendix B, to develop the MDL. Alternatively, you may use the MDL determination procedure in SW

- 846 Chapter 1, except you must perform a minimum of seven replicate analyses instead of three. The MDL must be determined in the same matrix as the samples tha t will be analyzed.

Be aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC §7413). Failure to comply fully with this request for information may subject you to an enforcement action. We may use any information submitted in response to this request in an administrative, civil or criminal action.



### 3.0 Data Submission Procedures

To avoid duplicate data and to keep all data for a particular facility together, we request that you submit all of the data requested from your facility in the same way. You may submit your data using one of the following options:

 E

- mail an electronic copy of all requested files to CCG

- PVC@epa.gov ; or

 Mail a CD or DVD containing an electronic copy of all requested files to the EPA address shown in your section 114 letter. If no electronic copy is available, mail a hard copy of all requested files to the EPA address shown in your section 114 letter.

 If you are submitting Confidential Business Information (CBI), you must mail a separate CD or DVD containing only the CBI portion of your data to the EPA address shown in your section 114 letter. DO NOT SUBMIT CBI INFORMATION TO THE EPA ELECTRONICALLY.Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 7 04/01/2014 

### 4.0 Contact Information for Questions

For questions on the sampling procedures and analytical methods contact:

Jason DeWees (U.S. EPA) 919

- 541

- 9724 dewees.jason@epa.gov

Gerri Garwood (U.S. EPA) 919

- 541

- 2406 garwood.gerri@epa.gov

For all other questions contact:

Jodi Howard (U.S. EPA) 919.541.4607 howard.jodi@epa.gov