Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 1

04/03/2014

Draft 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 air pollutant 

emissions from certain emissions points in this source category. 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 on the outlet to at least one of the control systems 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. 

If you would like to use a method not listed in Table 1.1, then please contact the EPA for 

approval of an alternative method. For copies of the recommended U.S. EPA methods and 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 2

04/03/2014

additional information, please refer to EPA’s Emission Measurement Center website: 

http://www.epa.gov/ttn/emc/. For 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.

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 Section1.3. In addition to 

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

30 day period before, at the time of, and during the emissions test: 

 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 oxygen).

The testing should be conducted while the PVC production process is operating as close 

as possible to maximum production capacity and under “normal” operation, that is, not during 

periods of startup, shut down, or malfunction. A thorough description of the process, including 

production rate(s) and a comparison of those production rates to maximum production capacity

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 

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 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 3

04/03/2014

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 Methods

Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Vinyl Chloride U.S. EPA Method 18 1 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

Dioxins/Furans1 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

Speciated HAP listed 

in Table 1.3

2

SW-846 Method 0031 with 

preparation and analysis by 

SW-846 Methods 5041A and

8260B. 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 1.4

2

SW-846 Method 0010 with 

preparation and analysis by 

SW-846 Methods 3542 and

8270D. Collect a minimum 

sample volume of 3 dscm per 

run. Use high resolution 

GC/MS for the analytical 

finish. 

None ppmvd @ 3% O2

Speciated HAP listed 

in Table 1.5

2

U.S. EPA Method 320.

Minimum sample time of 4 

hours per run. All compounds 

must be validated according to 

Section 13.0.

None ppmvd @ 3% O2

Speciated HAP listed 

in Table 1.6

2

U.S. EPA Method 18.

Minimum sample time of 4 

hours per run. 

None ppmvd @ 3% O2

O2 / CO2 U.S. EPA Method 3A. 

Simultaneous with each 

pollutant test run.

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

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 4

04/03/2014

Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

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 include the results for the individual dioxin/furan congeners as specified in Table 1.2.

2

If any other HAP could be emitted from the process, you must also test for those HAP using US EPA Method 

320, US EPA Method 18 or SW-846 Method 0010, as applicable. 

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 0031

Pollutant CAS Number Pollutant CAS Number

Benzene 71432 Methylene chloride 75092

Chloroethane 75003 Toluene 108883

Chloroform 67663 1,1,1-Trichloroethane 71556
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 5

04/03/2014

Pollutant CAS Number Pollutant CAS Number

Chloroprene 126998 1,1,2-Trichloroethane 79005

1,1-Dichloroethane 75343 Vinylidene chloride 75354

1,2-Dichloroethane 107062

Table 1.4 Target Analytes Using SW-846 Method 0010

Pollutant CAS Number Pollutant CAS Number

Acetophenone 98862 Hydroquinone 123319

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 123319

Table 1.5 Target Analytes Using US EPA Method 320

Pollutant CAS Number Pollutant CAS Number

Acetaldehyde 75070 Methanol 67561

1,3-Butadiene 106990 1,1,2,2-Tetrachloroethane 79345

Chlorobenzene 108907 2,2,4-Trimethylpentane 540841

Cumene 98828 Vinyl acetate 108054

Ethylbenzene 100414 Vinyl bromide 593602

Ethylene glycol 107211 Xylenes (isomers and mixtures) 1330207

Formaldehyde 50000

Table 1.6 Target Analytes Using US EPA Method 18

Pollutant CAS Number Pollutant CAS Number

Chloromethane 74873 n-Hexane 110543

1.3 Total Hydrocarbon 30-Day Monitoring

You must conduct total hydrocarbon (THC) monitoring continuously for a 30-day period

as specified in Table 1.7. You must also concurrently record the types and grades of PVC resin 

being produced and the control device temperature. All the emissions testing required in Table 

1.1 must be conducted during this 30-day monitoring period.
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 6

04/03/2014

Table 1.7 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

O2 U.S. EPA Method 3A

continuously for 30 days. 

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

Moisture U.S. EPA Method 4 continuously 

for 30 days.

None % volume

2.0 How to Report Data

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

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 test methods supported by the EPA’s Electronic Reporting Tool 

(ERT) as listed on the ERT website (see http://www.epa.gov/ttn/chief/ert/index.html), the results 

of the performance test must be submitted in the file format generated through the use of the 

latest version of the ERT existing at the time the source test is conducted. The following test 

methods are supported by the ERT:

 EPA Method 23

 EPA Methods 25/25A

 EPA Methods 26/26A

For data collected using test methods that are not supported by the EPA’s ERT as listed 

on the ERT website, you must submit the results of the performance test in the Emission Test 

Template to CCG-PVC@epa.gov. You must report the results of each test on an appropriately

labeled worksheet corresponding to the specific tests. After completing the worksheet, you must 

also submit an electronic copy of the emission test report including all raw data (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 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 7

04/03/2014

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:

 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;

 A complete unit description, including a description of feed 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 Excel spreadsheet, 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.
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 8

04/03/2014

3.0 How to Submit Data

You may submit your data in one of three ways as listed below. However, in order to avoid 

duplicate data and to keep all data for a particular facility together, we request that you submit all 

of the 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

 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

04/03/2014

Guidance for Calculating and Reporting Values Measured Below 

Method Detection Levels

1. 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. 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 Notes line of the Excel spreadsheet template 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 

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 bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line; or 

 As a numerical value in the ERT with the appropriate flag in the 

Comments line.
Enclosure 1

Attachment C

PVC Section 114 Enclosure 1, Attachment C – Page 2

04/03/2014

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 bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line; 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.

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.
Enclosure 1

Attachment C

PVC Section 114 Enclosure 1, Attachment C – Page 3

04/03/2014

 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 bracketed “less than” detection level value (e.g., [<20.06]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line

 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.