**Enclosure 1 Attachment**  **B**

PVC Section 114 Enclosure 1, Attachment B

– Page 1 04/03/2014 

## Draft **Summ ary of Test Procedures, Methods,**  **and Reporting Requirements for Polyvinyl Chloride and Copolymers**  **Facility Emission Points** This document provides an overview of approved sampling and anal ys is methods, target reported units of measure, and reporting requirements for poly vinyl chloride and copol ym er (PVC) production facilities required to conduct emissions testing and provide emission test data according to the section 114 l etter. 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 p roduction facility , then you are required to conduct testing as outlined in this document to determine your emissions. 1.1 How to Select Sample Location and Gas Composition Analy sis Methods You must use U.S. EPA Method 1 of Appendix A of p art 60 to select the locations and number of traverse points for sampling. See http://www.epa.gov/ttn/emc/methods/method1.html for a cop y of the method and guidance information. Y ou must use U.S. EPA Method 3A or 3B of Appendix A of p art 60 f or analy sis of flue gas composition, including ox ygen 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 Poly

vinyl Chloride and Copoly mers Production Test Methods and Reporting Testing must be conducted on the outlet to at least one of the control s ys tems 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 r efer 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 ox ygen 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 day s of THC monitoring is also required as specified in Section1.3. Inaddition to the emission test data, you must also report the following process information taken during the 30 day period be fore, at the time of, and during the emissions test:

 the ty pe 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 ox ygen). 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 spec ification ” or “out of specification” resin batches will be produc ed , 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, w e 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 significantl y 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 l evels . We believe that the Clean Air Act is clear that it is incumbent on the source and the tester to apply methods and procedures resulting in data quality necessary

for those decisions including providing for the lowest possible detection limits considering practical and reasonable limitations. For example, source owners and testers should not automatically choose to use low or me dium quality

equipment for testing (e.g., for cost reasons) if high quality equipment is reasonabl y 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 particularl y mindful of whether the testing procedures applied are representative of the highest reasonabl y 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 suf ficient 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 Chlo**  **ride 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 pp b vd @ 3% O 2

HCl/ Cl 2 U.S. EPA Method 26 or 26A . Collect a minimum sample volume of 2 ds cm per run. None ppmvd @ 3% O 2 Dioxins/Furans 1 U.S. EPA Method 23. Collect a minimum sample volume of 5 dscm per run. Use high resolution GC/MS for the analytical finish. None ng/dscm @ 3% O 2 Speciated HAP listed in Table 1. 3 2 SW - 846 Method 0031 with preparation and analysis by SW - 846 Method s 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% O 2

Speciated HAP listed in Table 1. 4 2 SW - 846 Method 0010 with preparation and analysis by SW - 846 Method s 3542 and 8270D. Collect a minimum sample volume of 3 ds cm per run . Use high resolution GC/MS for the analytical finish . None ppmvd @ 3% O 2

Speciated HAP listed in Table 1. 5 2 U.S. EPA Method 320 . Minimum s am

pl e time of 4 hours per run. All compounds must be validated according to Section 13.0. None ppmvd @ 3% O 2 Speciated HAP listed in Table 1. 6 2 U.S. EPA Method 18. M inimum sample time of 4 hours per run. None ppmvd @ 3% O 2 O 2 / CO 2 U.S. EPA Method 3A. Simultaneous with each pollutant test run. U.S. EPA Method 3B % volume, dry**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 Flow rate U.S. EPA Method 2.

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

1 You must 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 Y ou must conduct total hydrocarbon ( T HC ) monitoring continuousl y for a 30 - day period as specified in Table 1. 7 . You must also concurrently record the ty pes and grades of PVC resin being produced and the control device temperature. A ll the emission s 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 M ethod 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% O 2

O 2 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 depend s up on 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 (s ee 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 metho ds 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 Emissio n 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 cop y 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

Sy stem (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 anal ys is procedures and any modifications to standard procedures; quality assurance procedures ;  Any process data and control device monitoring data required in this att achment ;  Raw data sheets for field sampling ;  Raw data sheets for field and laboratory anal ys es ;  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 ;  Id entification 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 l imit .**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 way s 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 cop y of all requested files to the EPA address shown in your s ection 114 letter. If no elec tronic cop y is available, mail a hard copy of all requested files to the EPA address shown in your s ection 114 letter.  If you are submitting Confidential Business Information (CBI), you must mail a separate CD or DVD containing only the CBI portion of your data to the EPA address shown in yo ur s ection 114 letter.
**4 .0**  **Contact Information for Questions For questions on how to report data using the ERT contact:**  Ron Myers (919) 541 - 5407 myers.ron@epa.gov **For questi ons 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**  Id entify 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 anal ytical values used to calculate and report an in stack emissions value are less than the laboratory ’s reported detection level(s);  **DLL** (detection level limited)

– at least one but not all values used to calculate and report an in - stack emissions value are less than the laboratory ’s reported detection level(s); or  **ADL** (above detection level)

– all anal ytical values used to calculate and report an in stack emissions value are greater than the laboratory ’s reported detection level(s). **2. Reporting and Calculating Method Detection Limits**  F or 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 F or 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 F or water sampling and anal ys is , you must determine the MDLin accordance with the procedures specified in Appendix B of 40 CFR part 13 6 .  For analy

tical data reported from the laboratory as above the MDL, include the ADL flag in the **Not es**  line of the Excel spreadsheet template or in the **Comments** line in the ERT.  For analy

tical data reported from the laboratory as “nondetect” or “below detection level;” o In clude a brief description of the procedures used to determine the analy tical 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 procedure s applied. o Calculate the in - stack emissions rate for any anal ytical 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 anal yt e 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 < sy mbol) any anal ytical data measured above the MDL, including any data between the MDL and a laboratoryspecif ic reporting or quantifi cation 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 a bove 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 v alue (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 In clude 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.