Enclosure 1

PVC Section 114 Enclos ure 1

– Page 1 05/ 15 /2014 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST

I. Introduction

Under the authority of Section 114 of the Clean Air Act, t his information collection request is to be completed for operations that comprise the Polyvinyl Chloride and Copolymers (PVC)

sou rce category at your company. The PVC Production source category includes any facility which manufactur es polymerized vinyl ch loride. 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 o r copolymer resin.

This information collection request consists of two parts: (1) completion of information collection request response forms (survey) and submission of supplemental data and information; and (2) testing and analysis of emissions from PVC process vents (i.e.

, at the outlet of the final control device ). The results of testing are reported in either the Electronic Reporting Tool (ERT) or in dedicated worksheets that are contained in a single Microsoft Excel workbook file along with the requir ed response forms. Except for the required testing, complete this information 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 in 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 gene ral instructions for completing your response and includes specific guidance 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 before 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 process vent testing and analysis requirements can be found in Attachment B of this enclosure

. Infor mation regarding how to calculate and report method detection levels in located in Attachment C 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 Enclos ure 1

– Page 2 05/ 15 /2014 II. Instructions for Obtaining the Information Collection Request Files

The information collection request response forms are available as a single Microsoft Excel 2007 workbook. The workbook is included with this enclosure and is titled:

“ 2014 PVC 114 PV Testing.xlsx ”

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 packag e are an example of how to complete the Excel workbook and a copy of this enclosure. Where necessary, examples of how to complete selected portions of the information collection request response forms are included directly in the forms themselves. Refer to examples and the instructions contained in this enclosure when completing

your response.

III. Supplemental Data and Information Requested

We are requesting you submit supplemental data and information to support the information submitted in the informat ion 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 data in Microsoft Excel format. If recorded p rocess data (such as CEMS data) are not 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, tes t results, estimation worksheets, engineering 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 process vent testing, the infor mation provided in response 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 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 Enclos ure 1

– Page 3 05/ 15 /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 2014 PVC 114 PV Testing.xlsx

Plot Plan [Company]_[Facility] _PlotPlan

Process Flow Diagram [Company]_[Facility] _PFD

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.

All recipients must perform the requested stack testing and submit the test results, reports
, and documentation along with the responses to the information collection request and supplemental data and information specified in Attachments A , B and C of Enclosure 1 no later than November 17 , 2014 . Any submissions made after this date will be in violation of this Secti on 114 request.

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 “ConfidentialEnclosure 1

PVC Section 114 Enclos ure 1

– Page 4 05/ 15 /2014 Business Information” and send either via U.S. Postal Service 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 Group 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 the email address listed above. DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.

If you have questions regarding this request, please contact Ms. Jodi Howard, Re fining 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 at 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 parent company/legal corporate owner name. In questions I.2 through I.6 provide the mailing address for the lega l parent company/legal corporate owner.

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

 On Form A

- 2, provide the facil ity name and address information requested in question II.1, including the latitudinal and longitudinal coordinates of the facility. Facility latitudes and longitudes should be reported in decimal degrees to the 5 th decimal place, and longitudes should inc lude 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 q uestions III.1 through III.3 on Form A

- 2.

 On Form A

- 2

, Section IV, respondents are asked to identify 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 under common control that emits or has the potential toEnclosure 1

PVC Section 114 Enclos ure 1

– Page 5 05/ 15 /2014 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 have not yet commenced production of PVC resin or that are expanding existing production capacity are asked to complete all parts of this information collection

req uest. 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 i dentify if and when a permit limit for their potential HAP emissions to avoid being classified as a major source in questions 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 questio n IV.6 on Form A

- 2.

Form B

– Control Devices, Recovery 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 diagram (s) for the P VC 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). Process flow diagra ms should accurately show ALL:

o Process equipment;

o Recovery systems including all recovery equipment;

o Process 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 Pressure relief devices (PRDs); and

o Emission points;Enclosure 1

PVC Section 114 Enclos ure 1

– Page 6 05/ 15 /2014  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 ma tch between the process flow diagram and information provided in the completed response workbook(s). Refer to Attachment A of this Enclosure for relevant definitions.

Control devices (C

- x) Recovery systems (RS

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

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

- x)
Process equipment (U

- x) Emission points (EP

- 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 strippe rs) are considered wastewater treatment equipment and not control or recovery devices.

 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 emission s 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, mat erial 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 document s listed in Attachment 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.Enclosure 1

PVC Section 114 Enclos ure 1

– Page 7 05/ 15 /2014  Column 2 : Select the type of control device from the list provided in the Form.

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

 Column 4 : Each emission point from a control device (or from the last control devic e 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 Form
B

- 1. This unique code/identifier will be used on subsequent form s. If the exhaust stream from 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 identif ier.

Form B

- 2

– Recovery Systems 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.

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

- 3 for the condenser(s).

Specific Instructions by Form Column

Table 1

 Column 1: Each recovery 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.

 Colu mn 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 discharged directly to the atmosphere. If you answer yes, complete Table 2.

 Columns 4

- 6 : List the control devices that 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.Enclosure 1

PVC Section 114 Enclos ure 1

– Page 8 05/ 15 /2014  Column 2: Identify each emission point that discharges directly to the atmosphe re. 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 flow diagram and given a u nique 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.

 Column 3: Identify if the emission point is used as a bypass for the control device, or, if the emission point is a pro cess 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 recovery system should be show n 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 the recovery equipment.

 Co lumn 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

- 4

– Process Equipment

General Instructions

 All remaining process equipmen t should be listed on Form B

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

- 1 through B

- 2

.

 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 recovery 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 an indication if emissions from the process equipment ar e routed directly to the atmosphere without passing first through a recovery system or control device.Enclosure 1

PVC Section 114 Enclos ure 1

– Page 9 05/ 15 /2014  Column 4

- 6: If you answered “Yes” in column 3, list the emission point ID(s). Each 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 in Form B

- 1) do not duplicate the emission 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 appropriate recovery system ID entered on Form B

- 2.

 Column 9

- 11: If you answered “No” in column 7, list the control device identifiers 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 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 condenser 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., 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 absor ber from the pick list. If “other,” provide a description of the absorber type in row 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 t he 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).Enclosure 1

PVC Section 114 Enclos ure 1

– Page 10 05/ 15 /2014  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 catalytic).

 Rows 6

- 35: Provide the design parameters and operating characteristics requested in rows 6 through 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 applicable 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.

 Rows 5

- 12 : Provide the operating characteristics of the condenser in rows 5 through 12. Provide as much of the information as possible.

 Rows 15

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

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, provide equipment counts fo r all equipment at your facility in the source category. In addition, provide the subtotal of the equipment that are associated 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

.

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 equipment (by selecting the recovery or process equipment ID from Forms 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.Enclosure 1

PVC Section 114 Enclos ure 1

– Page 11 05/ 15 /2014  Indicate how the HAP concentration of the equipment is determined, and how (if at all) HAP emissions are controlled.

Table 2

 In Ta ble 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 repor ted for normal operations; not for startups, shutdowns, or malfunctions.

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

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 th e 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).

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

- 2 or Form B

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

- 2 or 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 extern al roof.

 Select the purpose of the equipment from the pick list provided. If none 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 turnov ers 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 the corresponding vapor pressure. Provide concentration values and total emissions for 2013.

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

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 represents a single startup, shutdown or malfunction event. Provide emissions in total pounds for the event.Enclosure 1

PVC Section 114 Enclos ure 1

– Page 12 05/ 15 /2014  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 P

– Process Vent Emissions Testing Data

 Form P is used to collect results of performance tests that are not supported by the EPA’s
E lectronic R eporting T ool (ERT) . Refer to Attachment B to this Enclosure 1 , Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolymers Facility Emis sion Points for more information for additional information.

 Copy Form P as necessary for pollutants/compounds sampled on different dates

.

 For multiple control devices, users may copy Form P within the response workbook.

 For each test run , provide the req uired operating parameters collected during the test. Note the selection for “PVC Production Rate Units.” If your final product is sold and shipped dried (e.g., a suspension resin), select “dry lbs PVC/day.” If your final product is sold and shipped withou t being dried (e.g., an emulsion resin), select “total lbs PVC/day.”

 Provide a numerical result for each compound. Do not provide non

- numerical data in the compound results columns.

 In the “ Run # Detection” columns, identify the status of the measured values relative to detection levels following the instructions in Attachment C to this Enclosure 1, “Guidance for Calculating and Reporting Values Measured Below Method Detection Levels.”

Form Q

– Total Hydrocarbon 30

- Day Monitoring

 Form Q is used to col lect the results of the 3 0

- day, continuous total hydrocarbon (THC) and methane (CH 4 ) monitoring required in Section 1.3 of Attachment B to this Enclosure 1, Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolyme rs Facility Emission Points.

 For multiple control devices, users may copy Form Q within the response workbook.

 Along with the continuous 30

- day THC and CH 4 readings, provide the corresponding oxygen and moisture values, along with the PVC type and grade being manufactured.

 Supply the control device temperature, and the control device and THC monitoring operations indicator.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 1 0 5 / 15 /2014 

### B ackground for Polyvinyl Chloride and Copolymers Production MACT Standards Development Information Collection Request

1.0 Introduction

The purpose of this attachment is to provide the respondent with additional detail on the relevant requirements of the Clean Air Act , 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 co llection request

.

2.0 Summary of Clean Air Act Requirements

The maximum achievable 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 EPA meet its obligations under the Clean Air Act Amendments of 1990

. Specifically, the Clean Air Act Amendments require EPA to develop regulations under Section 112(d) to limit emission s 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, 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 EPA is to apply in developing national emission standards f or hazardous air pollutants (NESHAP) for major sources

. A key 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 limitation 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 o n the average emission limitation achieved by the best performing 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 Administra tor to "distinguish among classes, types, and sizes of sources within a category or subcategory in establishing such standards" (Section 112(d)).

3.0 Regulatory Background for the Po lyvinyl Chloride and Copolymers Production Source Category

On October 21, 1976, EPA promulgated emission standards for vinyl 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 EPA to implementEnclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 2 0 5 / 15 /2014 te chnology based standards

. As a result, EPA proposed 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 4 5886) (“the Part 63 NESHAP”)

. EPA adopted most 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 met hodology for regulating HAPs emitted in PVC production other than vinyl chloride by use of a surrogate.

On April 17, 2012 , 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 gather data from PVC production facilities that were either not included in the EPA’s previous data collection efforts for the source category or whose data were excluded by the Agency from various technical analyses that supported the April 2012 rulemaking. The colle cted data will support analyses of environmental and economic impacts of various revisions to the current Part 63 NESHAP for PVC major and

area sources

.

4.0 Guidance Documents

Following is a list of EPA guidance documents and resources that may be usef ul 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. Environmental 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

. Re search Triangle Park, N.C. February 1994. Publication No.: EPA

- 453/R

- 94

- 020.

5.0 Key Term DefinitionsEnclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 3 0 5 / 15 /2014 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.

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 resin particles in a post polymerization reactor using additional vinyl chloride monomer

. Resins produc ed 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

. Emulsifie rs are used to disperse vinyl chloride monomer in the water phase. Initiators 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).Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 4 0 5 / 15 /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 dur ing periods not associated with a shutdown. Examples of activities that can generate maintenance wastewaters include descaling of heat exchanger tubing bundles, hydroblasting PVCPU process components such as polymerization reactors, vessels and heat exchan gers, draining of low legs and high point bleeds, draining of pumps into an individual 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 alrea dy been opened to the atmosphere.

Malfunction: A ny sudden, infrequent, and not reasonably 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 th e potential to cause, the emission limitations in an applicable standard to be exceeded

. 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, storage vessels, surge control vessels, heat exchange systems, wastewater, and process wastewater treatment systems that are associated with producing polyvinyl chloride.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 5 0 5 / 15 /2014 Pol yvinyl 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 copolymer s. A PVCPU includes, but is not limited to, polymerization reactors; resin stripping operations; resin blend tanks; resin centrifuges; resin dryers; resin product separators; recovery devices; reactant and raw material charge vessels and tanks; holding tan ks, mixing and weighing tanks; finished resin product storage tanks or storage silos; finished resin product loading operation; connected ducts and piping; equipment including pumps, compressors, agitators, pressure relief devices, sampling connection syst ems, open

- ended valves or lines, valves and connectors and instrumentation 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 polymerizat ion

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 structu re (

- H2CCHCl

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

processe s.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 6 0 5 / 15 /2014 Process equipment: Any unit operation or group of unit operations 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 equipment 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, polyvinyl chloride production process.

Process wastewater: Wastewater that com es 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 that has not been discharged untreated as wastewater. Examples are product ta nk 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 cool or quench organic vapor streams through direct contact; water discarded f rom 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 strea m 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 comb ined 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 was tewater stripper feed/bottoms heat exchanger.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 7 0 5 / 15 /2014 PVC process wastewater treatment system: A collection of PVC process wastewater treatment equipment that removes organic compounds from a process wastewater stream before the process wastewater stream is disch arged from the PVC production facility.

Recovery equipment: 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

was tewater stripper overheads and return those feedstocks for reuse in the resin production process and/or eventual destruction or disposal. For the purposes of this information collection request, wastewater steam and vacuum strippers are considered PVC proc ess wastewater treatment equipment and not recovery equipment.

Recovery system: 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 strippe r: 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. Exampl es 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. Resin 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)Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 8 0 5 / 15 /2014 Startup: 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 blending 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 blend ing 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 li quid 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 ch loride 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.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 9 0 5 / 15 /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.Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 10 0 5 / 15 /2014 6.0 Key Acronyms and Units of Measure

% percent

a cfm 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

d scfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

f t feet

ft/s feet per second

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

g pm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

i n 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. gallonEnclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 11 0 5 / 15 /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 0 5 / 15 /2014 

## Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolymers Facility Emission Points

This document provides an overview of approved sampling and analysis methods, target reported units of measure, and reporting requirements for polyvinyl chloride and copolymer (PVC) production facilities required to conduct emissions testing and provide emission test data according to the section 114 letter. The purpose for this testing is to gather data on hazardous air pollutant emissions from process vents within this source category. These data will be used to supplement the existing HAP data set for process vents. The document is organized as follows:

1.0 Stack Testing Procedures and Methods

2 .0 How to Report Data
3 .0 How to Submit Data

4 .0 Contact Information for Questions on Te st Plan and Reporting

1.0 Stack Testing Procedures and Methods

This information collection request includes stack (performance) test data requests for several pollutants

. If you operate a PVC p roduction facility

, then you are required to conduct testing as outlined in this document to determine your emissions.

1.1 How to Select Sample Location and Gas Composition Analysis Methods

You must use U.S. EPA Method 1 of Appendix A of p art 60 to select the locations and number of traverse points for sa mpling. See http://www.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance information.

Y ou must use U.S. EPA Method 3A or 3B of Appendix A of p art 60 f or analysis of flue gas composition, including oxygen concentration. See http: //www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information.

1.2 Polyvinyl Chloride and Copolymers Production Test Methods and Reporting

Testing must be conducted at the outlet or in the stack of the final control device including, but not limited to, a thermal oxidizer and acid gas scrubber (in series) used to control emissions from PVC production. Table 1.1 summarizes the required test methods for each pollutant

, possib le alternative methods , and the target reported units of measure

.
For copies of the recommended U.S. EPA methods and additional information, please refer to EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. ForEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 2 0 5 / 15 /2014 copies of the SW

- 846 methods, please refer to EPA’s SW

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

. If you w ould like to use a method not listed in Table 1.1 , please contact the EPA for approval of an alternative test method

. The request for an alternative test method should include the alternative test method or prescriptive alternative procedure, the reason f or the request (e.g., lower detection limit, site specific matrix interference, increased precision, etc

. )

, supporting empirical data (e.g. comparison with specified method, precision determination, etc.), and quality control procedures which ensure result s are sufficiently accurate and precise

. See the Emission Measurement Center’s Guideline Document 22 ( http://www.epa.gov/ttn/emc/guidlnd/gd22.pdf ) for more information on what information should be included in an alternative test method request

.

Each tes t should be comprised of a minimum of three valid runs at each sampling location

. All pollutant concentrations should be corrected to 3 percent oxygen and should be reported on the same moisture basis. The target units of measure are specified in Table 1.1. Report the results of each stack test according to the instructions in Section 2.0 of this attachment

. 30 days of THC monitoring is also required as specified in Section 1.3. In addition to the emis sion test data, you must also report the following process information taken during the testing period :

 T he type of resin being processed and the resin grade;

 E missions control device(s) in use during the test;

 C ontrol device operating or monitoring pa rameters (including, as appropriate to the control device, flue gas flow rate, pressure drop, scrubber liquor pH, scrubber liquor flow rate, sorbent type and sorbent injection rate) ; and

 P rocess parameters (such as percent oxygen).

The testing should be c onducted while the PVC production process and any other non

PVC production process(es) that send emission streams to the same control device, is/are operating as close as possible to maximum mass loading of all HAP compounds to the control device and under “normal” operation, that is, not during periods of startup, shut down, or malfunction. A thorough description of the process (es) , including production rate(s) and a comparison of those production rates to maximum production capacity for PVC process unit s and non

- PVC process units during the entire testing cycle should also be provided. If, during the performance testing, it becomes clear that one or more “off specification” or “out of specification” resin batches will be produced, then the testing and process data and any other associated information must still be submitted and labeled as an “off spec” test.

In most instances, we are not specifying numerical detection limits; instead we have specified testing conditions and methods, including test run times and minimum sample volumes when appropriate, which we believe will provide sufficient data quality for decision making. We remind source owners and testers of the Clean Air Act section 114(a)(1) requirement to provide information requested for the de velopment of emissions standards using methods that provide data necessary for the decisions. That includes data of quality sufficient to support those decisions. For the most part, we can identify test methods and procedures that will satisfy those deci sion making needs (e.g., minimum sampling times). In other cases, we recognize that the source owner's or tester's selection of test procedures or equipment could bear significantly onEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 3 0 5 / 15 /2014 the quality of the data. See Attachment C of this enclosure for infor mation regarding guidance for calculating and reporting values measured below method detection l evels

.

We believe that the Clean Air Act is clear that it is incumbent on the source and the tester to apply methods and procedures resulting in data quality necessary for those decisions including providing for the lowest possible detection limits considering pr actical and reasonable limitations. For example, source owners and testers should not automatically 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 testing 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 requirement of the Act to provide data sufficient decisions, we can and will request additional measurements requiring the use of improved testing procedures. The enclosed c ertification statement must be signed by a responsible official (See Enclosure 6)

.

Table 1.1 : Summary of Polyvinyl Chloride and Copolymers’ Control System Outlet Emissions

Measurement Methods and Alternative Methods 1

Pollutant Required Method Possible Al ternative Method Target Reported

Units of Measure Vinyl Chloride U.S. EPA Method 18 with a minimum sample time of 1 hour per run and a nominal detection level of less than 200 ppbv. None pp b vd @ 3% O 2

HCl / Cl 2 U.S. EPA Method 26 or 26A. Collect a minimum sample volume of 2 ds cm per run. None ppmvd @ 3% O 2

THC U.S. EPA Method 25A with a minimum sampling time of 4 hours per run. Calibrate the measuring instrument with a mixture of the organic compounds being emitted or with propane. None p pmvd as propane @ 3 % O 2

CH 4 U.S. EPA Method 320 . Have a minimum sample time of 4 hour s per run. U.S. EPA Method 18. Have a minimum sample time of 4 hour s per run

. ppmvd @ 3 % O 2

Dioxins/Furans 2 U.S. EPA Method 23. Collect a minimum sample volume of 5 dscm per run. Use high resolution GC/MS for the analytical finish. None ng/dscm @ 3% O 2Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 4 0 5 / 15 /2014 Pollutant Required Method Possible Al ternative Method Target Reported

Units of Measure Speciated HAP listed in Table 1.3 3 Sample collection by SW

- 846 Method 0031 , sample preparation by SW

- 846 Method 5041A, and sample analysis by SW

- 846 Method 8260B 4

. Combine traps in each run if lower detection limit is needed. Sample at a rate of 1 L/min, unless a slower sampling rate will yield detectable levels. None ppmvd @ 3% O 2

Speciated HAP listed in Table 1.4 3 Sample collection by SW

- 846 Method 0010 , sample preparation by SW

- 846 Method 3542 5 , and sample analysis by SW

- 846 Method 8270D 4 . Collect a minimum sample volume of 3 ds cm per

run . Use low resolution GC / MS with the use of selected ion monitoring (SIM) mode for the analytical finish. None ppmvd @ 3% O 2

Speciated HAP listed in Table 1.5 3 U.S. EPA Method 18 or 320 6

. Minimum s ampl e time of 1 hour per run. All compounds quantified by Method 320 must be validated according to Section 13.0 of Method 320. All compounds quantified by Method 18 meet the recovery study specified in Section 8.4 of Method 18. None ppmvd @ 3% O 2

O 2 / CO 2 U.S. EPA Method 3A. Simultaneous with each pollutant test run. U.S. EPA Method 3B % volume, dry

Moisture U.S. EPA Method 4. Simultaneous with each pollut ant test run. None % volume

Flowrate U.S. EPA Method 2. Simultaneous with each pollutant test run. U.S. EPA Method 2A, 2B, 2C, 2D, 2F, or 2G, as appropriate

. ascfm and dscf m

1 You must sample THC, vinyl chloride, and all speciated HAP concu rrently.

2 You must include the results for the individual dioxin/furan congeners as specified in Table 1.2

. 3 If any HAP other than those listed in Tables 1.3

- 1.5 could be emitted from the process, you must test for th ose HAP using US EPA Method 320, US EPA Method 18

, SW

- 846 Method 0010, or an approved alternative test method

, as applicable

. 4 You must use all three SW

- 846 methods in combination to obtain a measurement result. The first method is the sampling method to be used at the stack. The second method is a preparatory method that readies for analysis the sample obtained from the first method. The third method is the analysis method.

5 SW

- 846 Method 3542 replaces Section 8.1 of SW

- 846 Method 0010.Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 5 0 5 / 15 /2014 6 The selection of technique [ Method 320, Method 18

– Bag Sampling (Section 8.2.1 ) , Method 18

– Direct Interface (Section 8.2.2 ) , or Method 18

– Absorption Tube (Section 8.2.4 )] must be made for each compound in Table 1.5 to achieve the lowest detection limit and meet method quality parameters.

Table 1.2 Dioxin/Furan Congeners

Dioxin/furan congener

2,3,7,8

- tetrachlorodibenzo

- p

- dioxin.

1,2,3,7,8

- pentachlorodibenzo

- p

- dioxin.

1,2,3,4,7,8

- hexachlorodibenzo

- p

- dioxin.

1,2,3,7,8,9

- hexachlorodibenzo

- p

- dioxin.

1,2,3,6,7,8

- hexachlorodibenzo

- p

- dioxin.

1,2,3,4,6,7,8

- heptachlorodibenzo

- p

- dioxin.

octachlorodibenzo

- p

- dioxin.

2,3,7,8

- tetrachlorodibenzofuran.

2,3,4,7,8

- pentachlorodiben zofuran.

1,2,3,7,8

- pentachlorodibenzofuran.

1,2,3,4,7,8

- hexachlorodibenzofuran.

1,2,3,6,7,8

- hexachlorodibenzofuran.

1,2,3,7,8,9

- hexachlorodibenzofuran.

2,3,4,6,7,8

- hexachlorodibenzofuran.

1,2,3,4,6,7,8

- heptachlorodibenzofuran.

1,2,3,4,7,8,9

- heptachlorodibenzofuran.

Octachlorodibenzofuran.

Table 1.3 Target Analytes Using SW

- 846 Method 8260B

Pollutant CAS Number Pollutant CAS Number
Benzene 71432 n

- Hexane 110543 Chloroethane 75003 Methylene chloride 75092 Chloroform 67663 Toluene 108883 Chloroprene 126998 1,1,1

- Trichloroethane 71556 1,1

- Dichloroethane 75343 1,1,2

- Trichloroethane 79005 1,2

- Dichloroethane 107062 Vinylidene chloride 75354

Table 1.4 Target Analytes Using SW

- 846 Method 8270D

Pollutant CAS Number Pollutant CAS Number Acetophenone 98862 Hydroquinone 123319Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 6 0 5 / 15 /2014 Pollutant CAS Number Pollutant CAS Number Bis(2

- ethylhexyl) phthalate (DEHP) 117817 Naphthalene 91203

1,4

- Dichlorobenzene 106467 Phenol 108952 2,4

- Dinitrophenol 51285 1,2,4

- Trichlorobenzene 120821 Hexachlorobutadiene 87683

Table 1.5 Target Analytes Using US EPA Method 18 and 320

Pollutant CAS Number Pollutant CAS Number Acetaldehyde 75070 Formaldehyde 50000 1,3

- Butadiene 106990 Methanol 67561 Chlorobenzene 108907 1,1,2,2

- Tetrachloroethane 79345 Chloromethane 74873 2,2,4

- Trimethylpentane 540841 Cumene 98828 Vinyl acetate 108054 Ethylbenzene 100414 Vinyl bromide 593602 Ethylene glycol 107211 Xylenes (isomers and mixtures) 1330207

1.3 Total Hydrocarbon 30

- Day Monitoring

Y ou must conduct total hydrocarbon (T HC ) monitoring continuously for a 30

- day period as specified in Table 1.6. You must also concurrently record the exhaust gas oxygen and moisture levels, the types and grades of PVC resin being produced and the control device temperature. Also indicate period s of abnormal operation for the control device and/or THC monitoring equipment. All the emissions testing required in Table 1.1 must be conducted during this 30

- day monitoring period.

Table 1. 6 30

- Day THC Monitoring

Pollutant Recommended Method Alternati ve Method Target Reported Units of Measure
THC U.S. EPA Method 25A

continuously for 30 days. Calibrate the measuring instrument with propane. The low level and high level calibration gases (see sections 7.1.3 and 7.1.5 of Method 25A) must bracket the mea sured concentrations or a maximum high level calibration gas (see section 7.1.5 of Method 25A) of 10 ppm propane must be used. None ppmvd as propane @ 3% O 2

CH 4 U.S. EPA Method 320 U.S. EPA Method 18 or instrument that uses chromatographic column to split methane from all other organic compounds. ppmvd @ 3% O 2

O 2 U.S. EPA Method 3A

continuously for 30 days. U.S. EPA Method 3B % volume, dryEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 7 0 5 / 15 /2014 Pollutant Recommended Method Alternati ve Method Target Reported Units of Measure
Moisture U.S. EPA Method 4 once per

day fo r 30 days

. W here the exhaust stream is saturated (e.g. the outlet of a wet scrubber), you may measure the temperature by thermocouple and report the moisture at saturation levels. W here a stack is not saturated

, moisture may be determined by wet/dry bulb psychrometry (ASTM E

- 337) twice daily (at least one hour apart)

, by Met hod 320

, or by ASTM D6348

- 12 (FTIR) % volume

2 .0 How to Report Data

The method for reporting the results of testing and monitoring depend s up on the methods used to complete the test ing and monitoring requirements. This section discusses the requirements for reporting the collected data.

2.1 Reporting stack test data

For data collected using EPA Methods 23, 25/25A, and 26/26A, you must report the results of the performance test using the EPA’s Elect ronic Reporting Tool ( ERT ) . You do not need to use the ERT to report the results of the 30

- d ay THC monitoring; you only need to use the ERT to report the results of the Table 1.1 stack test. T he ERT website (see http://www.epa.gov/ttn/chief/ert/index.htm l) contains the latest version of the ERT, as well as frequently asked questions and a user’s guide. The ERT is a Microsoft Access program that must be downloaded onto your computer prior to data entry. T he file generated from the ERT must be submitted a ccording to one of the methods specified in Section 3.0 of this Attachment.

For data collected using all other test methods, you must report the results of the performance test (s) using Form P in the information collection request response forms Microsoft Excel workbook

. Y ou must also submit an electronic copy of the emission test report that includ es all of the information specified in Section 2.2 of this Attachment (PDF format preferred).

If you claim that some of the results of the performance test be ing submitted are confidential business information (CBI), you must submit the complete file including information claimed to be CBI. The submitted materials must be clearly marked as CBI submitted according to Section 3.0 of this Attachment. You must su bmit a separate copy of the file with all CBI data removed. Submit the non

- CBI version of the file according to one of the options in Section 3.0 of this Attachment.

2.2 Stack test data to be included in the report

At a minimum, a ll performance test reports must include the following information:Enclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 8 0 5 / 15 /2014  General identification information for the facility including a mailing address, the actual address, the owner or operator or responsible official (where they are applicable) or an appropriate representative and an email address for this person, and the appropriate Federal Registry System (FRS) number for the facility ;

 A brief process description , including a flow diagram clearly showing all process vent piping at the inlet to the first control device includi ng manifolds and tie

- in points for non

PVC process unit process vents (with those non

- PVC process units identified), any piping that allows a process vent to bypass the control device(s), and the sampling site ;

 A complete unit description for PVC and non

- P VC process units , including a description of emission streams and control devices, the appropriate source classification code (SCC), the latitude and longitude of the emission point being tested (to five decimal points), and the permitted maximum process r ate (where applicable) ;

 Sampling site description; description of sampling and analysis procedures and any modifications to standard procedures; quality assurance procedures ;

 Any process data and control device monitoring data required in this attachment ;

 Raw data sheets for field sampling ;

 Raw data sheets for field and laboratory analyses ;

 Chain

- of

- custody documentation ;

 Explanation of laboratory data qualifiers ;

 Example calculations of all applicable stack gas parameters, emission rates, percent reduction rates, and analytical results, as applicable ;

 Identification information for the company conducting the performance test including a contact person and his/her email address ; and

 Any other information required by the test method, a relevant standard, or t he Administrator.

Make clear, using the “ Notes ” section of the ERT or Form P, the correlation between emissions measurements and process data (e.g., identify Method 29 , run 1 for the associated process data on the process data details tab of the ERT).

2. 3 Flagging data and handling data that is below the detection limit

See Attachment C of this enclosure for information on how to flag data and on how to calculate and report values measured below the method detection l imit.

3.0 How to Submit Data

You may submit your data in one of the three ways listed below. However, in order to avoid duplicate data and keep all data for a particular facility together, we request that you submit all non

- CBI data requested from your facility in the same way. To s ubmit your data:

 E

- mail an electronic copy of all requested files to CCG

- PVC@epa.govEnclosure 1 Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 9 0 5 / 15 /2014  Mail a CD or DVD containing an electronic copy of all requested files to the EPA address shown in your s ection 114 letter. If no electronic copy is availab le, mail a hard copy of all requested files to the EPA address shown in your s ection 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 addre ss shown in

your s ection 114 letter.

4 .0 Contact Information for Questions

For questions on how to report data using the ERT contact:

Ron Myers (919) 541

- 5407 myers.ron@epa.gov

For questions on the test methods contact:

Jason DeWees (919) 541

- 9724 dewees.jason@epa.gov

Stef Johnson (919) 541

- 4790 johnson.steffan@epa.gov

For all other questions contact:

Jodi Howard (919) 541

- 4607 howard.jodi@epa.govEnclosure 1 Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 1 5 / 15 /2014 

### Guidance for Calculating and Reporting Values Measured Below Method Detection Levels

1.0 Identification of Detection Levels

Identify the status of measured values relative to detection levels on the spreadsheet or in the ERT using the following descriptions:

 BDL (below detection level)

– all analytical values used to calculate and report an in

stack emissions value are less than the laboratory’s reported detection level(s);

 DLL (detection level limited)

– at least one but not all values used to calculate and repo rt an in

- stack emissions value are less than the laboratory’s reported detection level(s); or

 ADL (above detection level)

– all analytical values used to calculate and report an in

stack emissions value are greater than the laboratory’s reported detection level(s).

2.0 Reporting and Calculating Method Detection Limits

For reporting and calculating individual test run data:

 You must use the method specified approach for calculation and determination of the method detection limit (MDL). If the method does not specify the approach and calculation of the MDL, determine the MDL as follows:

o For air sampling and analysis methods, you must determine the MDL in accordance with the procedures specified in Section 15 of Method 301 (located in Appendix A of 40 CFR part 63).

o For water sampling and analysis, you must determine the MDL in accordance with the procedures specified in Appendix B of 40 CFR part 136.

 For analytical data reported from the laboratory as above the MDL, include the ADL flag in the Form P columns labeled “ Run #1 Detection”, “ Run #2 Detection”, and/or “ Run #3 Detection” as appropriate or in the Comments line in the ERT.

 For analytical data reported from the laboratory as “nondetect” or “below detection level;”

o Include a brief description of the procedures used to determine the analytical detection and in

- stack detection levels:

 In the Notes line of Excel spreadsheet template; or

 In the Comments line of Lab Data tab in the Run Data Details in the ERT.

o Describe these procedures completely in the full test re port including the measurements made, the standards used, and the statistical procedures applied.

o Calculate the in

- stack emissions rate for any analytical result reported as below detection level using the relevant MDL, sampli ng volumes and other relevant runEnclosure 1 Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 2 5 / 15 /2014 specific parameters (such as oxygen or flowrate). The reported value must assume that the analyte is present at the full MDL value.

o Report the calculated emissions concentration or rate result:

 As a detection level num erical value (i.e., no brackets or < symbol) in the Excel spreadsheet template (Form P; columns “ Run 1”, “ Run 2”, and/or

“ Run 3” as appropriate) and select the appropriate flag in the Form P columns labeled “ Run #1 Detection”, “ Run #2 Detection”, and/or “ Run #3 Detection” as appropriate ; or

 As a numerical value in the ERT with the appropriate flag in the Comments line.

o Report as numerical values (i.e., no brackets or < symbol) any analytical data measured above the MDL, including any data between the MDL and a laboratory

specific reporting or quantification level (i.e., flag as ADL).

o Apply these reporting and calculation procedures to measurements made with Method 23 :

 Report data in the ERT for each of the D/F congeners measured with Method 23 below the de tection level as [< detection level];

 Do not report emissions as zero, as described in the method.

 For pollutant measurements composed of multiple components or fractions (e.g., Hg and other metals sampling trains) when the result for the value for any com ponent is measured below the MDL:

o Calculate in

- stack emissions rate or concentrations as outlined above for each component or fraction;

o Sum the measured values and/or calculated values (using the MDL as outlined above) for all of the components or fractio ns; and

o Report the sum of all components or fractions:

 As a detection level numerical value (i.e., no brackets or < symbol) in the Excel spreadsheet template (Form P; columns “ Run 1”, “ Run 2”, and/or

“ Run 3” as appropriate) and select the appropriate flag in the Form P columns labeled “ Run #1 Detection”, “ Run #2 Detection”, and/or “ Run #3 Detection” as appropriate ; or

 As a numerical value in the ERT with the appropriate flag in the Comments line.

 If all components or fractions are BDL, the appropriate flag is BDL. If any component or fraction is ADL, the appropriate flag is DLL.

o In addition to reporting the sum of the components or fractions, report the individual component or fraction values for each run if the Excel spreadsheet template or ERT format allows.Enclosure 1 Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 3 5 / 15 /2014 o If the Excel spreadsheet template or ERT format does not allow reporting of the individual components or factions (i.e., the format allows reporting only a single sum value):

 For the Excel spreadsheet template, next to the sum reported as above

rep ort in the Notes line the appropriate flag along with the values for the measured or MDL value for each component or fraction as used in the calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four fraction sample)

 For the ERT, next to the sum repor ted as above, report on the Comments line the appropriate flag and the measured or MDL value for each component or fraction as used in the calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four fraction sample)

 For measurements conducted using ins trumental test methods (e.g., Methods 3A, 6C, 7E, 10, 25A):

o Record gaseous concentration values as measured including negative values and flag as ADL; do not report as BDL

o Calculate and report in

- stack emissions rates using these measured values

o Include relevant information relative to calibration gas values or other technical qualifiers for measured values in Comments line in the ERT or Notes line of the Excel spreadsheet.

 For reporting and calculating average emissions rate or concentration for a test when some results are reported as BDL:

o Sum all of the test run values including those indicated as BDL or DLL as numerical values

o Calculate the average emissions rate or concentration (e.g., divide the sum by 3 for a three

- run test)

o Report the avera ge emissions rate or concentration average:

 As a detection level numerical value (i.e., no brackets or < symbol) in the Excel spreadsheet template (Form P; columns “ Run 1”, “ Run 2”, and/or

“ Run 3” as appropriate) and select the appropriate flag in the Form P columns labeled “ Run #1 Detection”, “ Run #2 Detection”, and/or “ Run #3 Detection” as appropriate;

 As a numerical value in the ERT and include the appropriate flag in the relevant Comments line

 If all test run values are BDL, the appropriate flag is BDL. If any test run value is ADL or DLL , the appropriate flag is DLL.