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.com

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 requested 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 significant 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 for 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 approval from EPA Region 6 prior to our performance 

test 
of 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 ICR.

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outdated 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 Appendix 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 annual 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 gathering 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 minimum 1-hr run 

value 

or the average of the 1-hr test runs.

6. Correction to Method 8270 referenced in Test Plan
You 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 alkalinity 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

CONFIDENTIALITY NOTICE: This communication (including any attachments) is 

for 

the sole use of the intended recipient and may contain confidential 

information. Unauthorized use, distribution or disclosure of this 

communication is prohibited. If you are not the intended recipient, 

please 

promptly notify the sender by return e-mail or telephone and permanently 

delete or destroy all electronic and hard copies of this e-mail and any 

attachments.