Corporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation Corporate Office 5005 LBJ Freeway, Dallas, TX 75 244

- 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: NESH

A P s 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 request ed 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, T exas PVC plant is permitted as an area source of HAPs and

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

chlorid e (EDC/VCM) production facility . Th e La Porte facility operates with two thermal oxidizers and two caustic scrubbers and was requested to provide data o n hydrogen chloride ( HC l)

, total organic hazardous air pollutants ( TOHAP ) , and total hydrocarbon s ( THC )

. P rocess vent data was previously gathered and submitted to EPA in March o f 2010 and in July of 2011 in response to prior EPA CAA Section 114 requ ests.

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 (majo r 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

te st ing 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 a rea and m ajor s ource PVC MACT standards (Subparts

DDDDDD and HHHHH HH). The additional demonstration (for major source standard compliance) is being included to cover a possible contingent scenario that the Deer ParkCorporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation Corporate Office 5005 LBJ Freeway, Dallas, TX 75 244

- 6119 P.O. Box 809050, Dallas, TX 75380

- 9050

972/404

- 3800 p lant becomes in the future subject to the PVC or other MACT requirements applicable to major sources ( E.g

. E PA’s developing regulations for EDC / V CM plants )

.

In addition

, it should be noted that several variations to the sampl ing and analytical methods (e.g.

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

. These method va riations were previously discussed between Enthalpy personnel and EPA’s

Mr. Jason DeWees. Our current test plan also re quests 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 s tack test performed for the PVC MACT ru lemaking

, as well as dioxins/furans (D/F) data from our July 2011 stack test

, which w as 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 stac k tests were performed in accordance with test plans that were submitted and approved by EPA staff in Research Triangle Park

.

Finally, s ince the initial part of our process involves batch reactors , we are submitting the Batch Precompliance Report ( A ppendix C) t o 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 t he 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 resul ts 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 , pl ea s e contact me at 972

- 404

- 3209 or M s

. Stephanie Engwall at 972

- 404

- 3291

.

Sincerely,

Barry Christensen Manager of Air Quality Occidental Chemical Corporation

E nclosure

Deer Park

/ La Porte , TX Test PlanCorporate Health, Environment, Safety and Security Department

Occidental Chemical Corporation Corporate Office 5005 LBJ Freeway, Dallas, TX 75 244

- 6119 P.O. Box 809050, Dallas, TX 75380

- 9050

972/404

- 3800 CC:

Mr. Andrew Bouchard,

USEPA

– Office of Air Quality P lanning 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, T X Commission on Environmental Quality, Post Office Box 13087,
Austin, TX 7871 1

- 3087