Enclosure 1

PVC Section 114 Enclosure 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, this information collection request 

is to be completed for operations that comprise the Polyvinyl Chloride and Copolymers (PVC)

source category at your company. The PVC Production source category includes any facility which 

manufactures polymerized vinyl chloride. PVC is be produced by the suspension, suspension 

blending, emulsion/dispersion or bulk processes, although other methods may be used. The source 

category includes the collection of all equipment and activities necessary to produce PVC 

homopolymer or 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 required 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 general instructions for completing your response and includes 

specific guidance for completing each response form. For 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 attempting 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. Information 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 Enclosure 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 package 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 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 data in Microsoft Excel format. If 

recorded process 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, test 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 information 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 2013
Enclosure 1

PVC Section 114 Enclosure 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 PVCICR_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 

Section 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 “Confidential 
Enclosure 1

PVC Section 114 Enclosure 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 DVDROM 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, 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 emissions 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 legal 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 facility 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 5th 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 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 to 
Enclosure 1

PVC Section 114 Enclosure 1 – Page 5

05/15/2014

emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air 

pollutant or 25 tons 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 

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 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 question 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 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). Process flow diagrams 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 Enclosure 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 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.

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 strippers) 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 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 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 Enclosure 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 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 Form 

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

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 first passing through a control device, complete 

Form 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 RSx, 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 

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 Enclosure 1 – Page 8

05/15/2014

 Column 2: Identify each emission point that discharges 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 flow 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.

 Column 3: Identify if the emission point is used as a bypass for the control device, or, if the 

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 recovery 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 the 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-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-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 are routed directly 

to the atmosphere without passing first through a recovery system or control device. 
Enclosure 1

PVC Section 114 Enclosure 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 (C2)).

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 absorber 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 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).
Enclosure 1

PVC Section 114 Enclosure 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 applicable 

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 for 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, submit 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 Enclosure 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 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.

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).

 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 external 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 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 

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 Enclosure 1 – Page 12

05/15/2014

 Submit 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 

Electronic Reporting Tool (ERT). Refer to Attachment B to this Enclosure 1, Summary of 

Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and 

Copolymers Facility Emission 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 required 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 

without 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 collect the results of the 30-day, continuous total hydrocarbon (THC) and 

methane (CH4) 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 Copolymers Facility Emission Points.

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

 Along with the continuous 30-day THC and CH4 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

05/15/2014

Background 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 collection 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 Protection 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 emissions of hazardous air pollutants (HAP) from major and area sources of 

emissions. Section 112(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 combination of hazardous air pollutants.” Based on the 

Administrator’s determination, EPA may lower the major source cutoff for individual HAP. An 

area source is “any stationary source of hazardous air pollutants 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 for 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 on 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 best controlled 

similar source.

The Clean Air Act Amendments allow the EPA Administrator 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 Polyvinyl 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 implement 
Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 2

05/15/2014

technology 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 45886) 

(“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 methodology 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 collected 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 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. 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.: EPA453/R-95-017.

4. Batch Process ACT. U. S. Environmental Protection Agency. Research Triangle 

Park, N.C. February 1994. Publication No.: EPA-453/R-94-020.

5.0 Key Term Definitions
Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 3

05/15/2014

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 prepolymerized 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 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 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 material/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 lowpressure 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

05/15/2014

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 during 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 exchangers, 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 already been opened to the 

atmosphere.

Malfunction: Any 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 the 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

05/15/2014

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 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 tanks, 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 systems, 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 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 white powder or colorless 

granule. Polyvinyl chloride homopolymer is produced by 

different processes, including (but not limited to), 

suspension, dispersion/emulsion, blending and bulk 

processes.
Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 6

05/15/2014

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 drying 

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 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 that 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 

cool 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.
Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 7

05/15/2014

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 

discharged 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 

wastewater 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 process 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: The 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. Resin 

stripping may occur in a polymerization reactor or is a batch 

or continuous stripper separate from the polymerization 

reactor.

Shutdown: The 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

05/15/2014

Startup: The 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 blending 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 liquid 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 chloride resins produced using 

the suspension process are referred to as suspension resins.

Type of Resin: The 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

05/15/2014

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

05/15/2014

6.0 Key Acronyms and Units of Measure

% percent

acfm actual cubic feet per minute

acfm/ft2actual cubic feet per minute per square foot

batches/yr batches per year

Btu/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

ft3/1,000 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 H2O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallon
Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 11

05/15/2014

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 weight
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 1

05/15/2014

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 Test 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 production 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 part 60 to select the locations and 

number of traverse points for sampling. See http://www.epa.gov/ttn/emc/methods/method1.html

for a copy of the method and guidance information.

You must use U.S. EPA Method 3A or 3B of Appendix A of part 60 for 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, possible 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/. For 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 2

05/15/2014

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 would 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 for 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 results 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 test 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 emission test data, you must also report the following process information taken during the 

testing period: 

 The type of resin being processed and the resin grade;

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

 Control device operating or monitoring parameters (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

 Process parameters (such as percent oxygen).

The testing should be conducted while the PVC production process and any other nonPVC 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 units 

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 development 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 

decision 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 on 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 3

05/15/2014

the quality of the data. See Attachment C of this enclosure for information regarding guidance 

for calculating and reporting values measured below method detection levels.

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 practical 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 certification 

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 Methods1

Pollutant Required Method

Possible Alternative 

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 ppbvd @ 3% O2

HCl/Cl2 U.S. EPA Method 26 or 26A. 

Collect a minimum sample 

volume of 2 dscm per run. 

None ppmvd @ 3% O2

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 ppmvd as propane

@ 3% O2

CH4 U.S. EPA Method 320. Have 

a minimum sample time of 4

hours per run.

U.S. EPA Method 18. Have a 

minimum sample time of 4

hours per run.

ppmvd @ 3% O2

Dioxins/Furans2 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% O2
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 4

05/15/2014

Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Speciated HAP listed 

in Table 1.33

Sample collection by SW-846 

Method 0031, sample

preparation by SW-846 

Method 5041A, and sample 

analysis by SW-846 Method

8260B4. 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% O2

Speciated HAP listed 

in Table 1.43

Sample collection by SW-846

Method 0010, sample

preparation by SW-846 

Method 35425, and sample 

analysis by SW-846 Method

8270D4. Collect a minimum 

sample volume of 3 dscm per 

run. Use low resolution

GC/MS with the use of 

selected ion monitoring (SIM)

mode for the analytical finish.

None ppmvd @ 3% O2

Speciated HAP listed 

in Table 1.53

U.S. EPA Method 18 or 3206.

Minimum sample 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% O2

O2 / CO2 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 

pollutant 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 dscfm

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

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 those

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

05/15/2014

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-pentachlorodibenzofuran.

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 123319
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 6

05/15/2014

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

You must conduct total hydrocarbon (THC) 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 periods 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 Alternative 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 measured 

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% O2

CH4 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% O2

O2 U.S. EPA Method 3A

continuously for 30 days. 

U.S. EPA Method 3B % volume, dry
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 7

05/15/2014

Pollutant Recommended Method Alternative Method

Target Reported 

Units of Measure

Moisture U.S. EPA Method 4 once per 

day for 30 days.

Where 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. Where 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 Method 320, or by 

ASTM D6348-12 (FTIR)

% volume

2.0 How to Report Data

The method for reporting the results of testing and monitoring depends upon the methods 

used to complete the testing 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 Electronic Reporting Tool (ERT). You do not 

need to use the ERT to report the results of the 30-day THC monitoring; you only need to use the 

ERT to report the results of the Table 1.1 stack test. The ERT website (see 

http://www.epa.gov/ttn/chief/ert/index.html) 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. The file generated from the ERT 

must be submitted according 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. You must also submit an electronic copy of the emission test report that 

includes 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 being 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 submit 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, all performance test reports must include the following information:
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 8

05/15/2014

 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 including manifolds and tie-in points for nonPVC 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-PVC 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 rate (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 the 

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 limit. 

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 submit your data:

 E-mail an electronic copy of all requested files to CCG-PVC@epa.gov
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 9

05/15/2014

 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.

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.gov
Enclosure 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 instack 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 report 

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 instack 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 report 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, sampling volumes and other relevant run 
Enclosure 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 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.

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 laboratoryspecific 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 detection 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 component 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 fractions; 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 

report 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 reported 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 instrumental 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 average 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.