Corporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation

Corporate Office

5005 LBJ Freeway, Dallas, TX 75244-6119

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

972/404-3800

July 31, 2014

Via Email and mail

Ms. Cynthia Kaleri

USEPA, Region 6 (6EN-AA), 

1445 Ross Avenue, 

Dallas, TX 75202-2733

Re: NESHAPs for PVC and Copolymer Production:

Requirement to Provide Test Data Pursuant to Section 114 of the Clean Air Act and 

Request for Compliance Test Plan Approval Pursuant to 40 CFR §63.7(b)

Dear Ms Kaleri,

This submission is in response to United States Environmental Protection Agency (EPA) 

correspondence dated May 15, 2014 to OxyVinyls which requested additional stack test data

in accordance with the Clean Air Act (CAA) Section 114. This correspondence was directed 

at a number of facilities so that EPA can gather additional process vent data to inform the

reconsideration of the PVC and Copolymer National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) for area and major sources of HAPs (referenced to herein as the PVC 

MACT). 

Our OxyVinyls’ Deer Park, Texas PVC plant is permitted as an area source of HAPs and 

routes its process vent gas stream to the OxyVinyls’ La Porte ethylene dichloride/vinyl 

chloride (EDC/VCM) production facility. The La Porte facility operates with two thermal 

oxidizers and two caustic scrubbers and was requested to provide data on hydrogen chloride 

(HCl), total organic hazardous air pollutants (TOHAP), and total hydrocarbons (THC).

Process vent data was previously gathered and submitted to EPA in March of 2010 and in 

July of 2011 in response to prior EPA CAA Section 114 requests.

In addition, the 2014 request indicated that the required testing may be suitable to satisfy the 

initial compliance determination required by the PVC MACT (40 CFR Part 63, Subparts 

DDDDDD (major sources) and HHHHHHH (area sources). Enclosed is our non-confidential 

Site Specific Performance Test Plan, including a Quality Assurance Project Plan. This letter 

constitutes our 60 day advance notice as required under 40 CFR §63.7(b). Our performance 

testing is scheduled for the week of September 29, 2014.

As part of this performance test, OxyVinyls intends to demonstrate compliance with the 

emission standards for both the area and major source PVC MACT standards (Subparts 

DDDDDD and HHHHHHH). The additional demonstration (for major source standard 

compliance) is being included to cover a possible contingent scenario that the Deer Park 
Corporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation

Corporate Office

5005 LBJ Freeway, Dallas, TX 75244-6119

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

972/404-3800

plant becomes in the future subject to the PVC or other MACT requirements applicable to 

major sources (E.g. EPA’s developing regulations for EDC/VCM plants).

In addition, it should be noted that several variations to the sampling and analytical methods

(e.g., Method 316) are incorporated in our stack test plan for which we are seeking approval. 

These method variations were previously discussed between Enthalpy personnel and EPA’s 

Mr. Jason DeWees. Our current test plan also requests approval to test one of our two 

thermal oxidizer/scrubber systems under worst case conditions.

Also, OxyVinyls is proposing to use, for purposes of demonstrating compliance, THC data 

from our 2009/2010 stack test performed for the PVC MACT rulemaking, as well as 

dioxins/furans (D/F) data from our July 2011 stack test, which was performed for EPA’s 

rulemaking process for EDC/VCM plants. We are doing this in order to minimize the cost 

and complexity of this third stack test for this source. The previous stack tests were 

performed in accordance with test plans that were submitted and approved by EPA staff in 

Research Triangle Park.

Finally, since the initial part of our process involves batch reactors, we are submitting the 

Batch Precompliance Report (Appendix C) to comply with 63.11985(c)(2). 40 CFR § 

63.11945 requires that the site-specific performance test plan include information on the 

emission profiles described in 40 CFR § 63.11925(g). Since the equations for batch 

operations provided in 40 CFR § 63.11950 were reviewed but not selected as the best way 

to estimate the worst case emission profile, EPA approval of Appendix C is required. The 

emission profile was developed using an engineering assessment that included analysis of 

previous test results for the Deer Park PVC plant process vent stream, along with 

engineering design data, as allowed by 40 CFR § 63.11925(g)(2)(iv). 

We look forward to further discussion on our proposed test plan. If you have questions or 

comments, please contact me at 972-404-3209 or Ms. Stephanie Engwall at 972-404-3291. 

Sincerely, 

Barry Christensen

Manager of Air Quality

Occidental Chemical Corporation

Enclosure

Deer Park/ La Porte, TX Test Plan
Corporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation

Corporate Office

5005 LBJ Freeway, Dallas, TX 75244-6119

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

972/404-3800

CC: 

Mr. Andrew Bouchard, 

USEPA – Office of Air Quality Planning and Standards

Sector Policies and Program Divisions

Coatings and Chemicals Group, and 

Mr. Jason M DeWees,

USEPA/OAQPS/AQAD

Measurement Technology Group

109 T.W. Alexander Drive (E143-02) 

Research Triangle Park, NC 27711

Mr. Michael Beatty, TX Commission on Environmental Quality, Post Office Box 13087, 

Austin, TX 7871 1-3087