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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

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September 16, 2010

Ms. Jodi Howard

U.S. EPA - Office of Air Quality Planning and Standards 

Sector Policies and Program Divisions 

Coatings and Chemicals Group 

Mail Code: E143-01 

Research Triangle Park, NC 27711

RE: PVC MACT Rulemaking—PVC Resin Concentration Data Base to Supplement 

Submissions in Response to EPA’s Section 114 Request 

Dear Ms. Howard,

Thank you again for meeting with The Vinyl Institute (VI) and its members on August 24, 

2010, to discuss the Agency’s forthcoming promulgation of a maximum achievable 

control technology (“MACT”) standard for the polyvinyl chloride (“PVC”) and copolymer 

source category under the Clean Air Act (hereinafter, “PVC MACT”). During our 

meeting we identified differences in the EPA-approved methods used by our members 

to respond to the information collection request issued pursuant to the Agency’s Clean 

Air Act section 114 authority. These differences in methodology have resulted in 

hazardous air pollutant (HAP) emissions data that are not entirely comparable from 

company to company, and in some cases, across individual company facilities. 

In particular, VI members have determined that in the absence of specific instructions in 

the 114 Request, inconsistent methods were used to convert HAP concentrations to 

pounds per day, dry. For instance, some facilities used production volume from the 

entire plant while others used only the volume from the production lines being sampled. 

Our review of the data submitted to EPA also reveals that moisture corrections to the 

wet resin portion of the stripper bottom stream were applied inconsistently. Some, but 

not all, manufacturers corrected for dry resin reporting basis. Of these, some corrected 

for dry resin reporting basis using the measured solids content of a split sample, but not 

all. We also determined that detection limits were not reported consistently in the 

spreadsheets submitted to the Agency. In some cases the value reported represents 
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the method detection limit, in others it is the quantitation limit, whereas other members 

used estimates below the reporting limit. 

One manufacturer’s laboratory tested and reported for the HAP chlorine (molecular Cl2) 

and total petroleum hydrocarbons (TPH) for PVC resins from its 3 plants. The total

chloride analysis used to test for chlorine is a destructive test method that is 

inappropriate for this purpose because it converts all forms of the chlorine atom to

chloride. The TPH analysis determines the sum of C6 to C35 hydrocarbons and is 

inappropriate for PVC resin because it is not specific for HAPs. We also noted that at 

least one company reported HAP concentration values as pounds per day, dry 

estimated emissions.

As you know, the bulk of these issues stem from the procedures and calculations 

required to convert the results of resin sampling analysis to EPA’s requested pounds 

per day (dry) unit of measure. Conversely, the underlying measured concentration data 

and attendant reports, for the most part, provide a more uniform and comparable data

set. Accordingly, VI and its members submit that this sampling concentration data is the 

best and most accurate basis from which to develop the PVC MACT. 

As we demonstrated during our meeting, VI has compiled the concentration data, which 

was collected pursuant to EPA’s 114 Request, into a spreadsheet with relational and 

data analysis capabilities.1 As promised, we enclose a copy of the spreadsheet with 

this cover letter for your consideration and further use. Although some anomalies exist 

in this data, it is a more appropriate and accurate basis for considering HAPs in PVC 

resin. In reviewing the enclosed spreadsheet, we would recommend that EPA consider 

the following points:

A. Resin Grades

The enclosed spreadsheet goes beyond resin polymerization category (suspension, 

dispersion, bulk, etc.) to more fully reflect the different process chemistry and resin 

grades required by, and produced for, the marketplace. Overall, the industry produces 

over 100 different resin grades with each grade having its own specific recipe. The 

 

1

Sampling data is provided for all VI members and Georgia Gulf only.
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spreadsheet identifies each day’s samples by resin grade and inherent viscosity as set 

forth below, which reflects industry practice:

Resin Grade Low Molecular 

Weight (LMW)

General 

Purpose

(GP)

High Molecular 

Weight (HMW)

Copolymer 

(VACO)

Resin Inherent 

Viscosity (IV) 

(deciliters/gram)

Less than 0.85 0.85 to 1.0 Greater than 1.0

Vinyl Acetate / 

Vinyl Chloride 

Copolymer

B. Characterization of Detection Limits 

As we discussed and previously reported, each analytical laboratory, which analyzed 

the resin samples, appears to have characterized detection limits differently. For 

example, some laboratories did not report results below the quantitation limit (QL) on 

grounds that the level of confidence in such data is poor. It also appears that the 

laboratories were inconsistent in their determination of method detection limits (MDL), 

using laboratory water, clean sand, Teflon® chips or PVC resin as the matrix for lab 

specific MDL determinations. We reviewed the sampling reports from the various 

laboratories and attempt to characterize the reported detection limits based on their 

descriptions in the column entitled “Measurement Type” in the hope that this will provide 

the Agency with a more appropriate basis for comparing data on specific analytes. 

Many of the detection limits reported in the spreadsheet have been characterized 

properly, but information is still outstanding from some of the testing laboratories. We 

will provide EPA with an updated spreadsheet as the revised MDL characterizations 

become available. 

C. Comparison of Methods 8260B and 107 Data for Vinyl Chloride 

As you know, most of the industry responded to the 114 Request for analysis of volatile 

organic compounds (VOCs) in PVC resin by using EPA’s approved Method 8260B. 

Some, but not all, facilities also provided 30-day sampling data obtained using Method 

107. We have now updated the spreadsheet to include Method 107 data collected 

pursuant to the VCM NESHAP from all facilities as a supplement to what was already 

reported using other test methods. It is important to note that average daily residual 

vinyl chloride (RVCM) data was obtained using EPA Method 107, which was developed 
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specifically for RVCM in PVC resins using Henry’s Law constants and equilibrium 

calculations specific to RVCM. EPA method 8260B, on the other hand, does not use 

Henry’s Law constants and equilibrium headspace calculation methods for each analyte 

because it is a test designed for a broad range of VOCs and sample matrices. 

With regards to the data collected pursuant to Method 8260B, VI understands that at 

least one company used a modified version of Method 8260B that incorporated a 

pretreatment step approved by EPA. The spreadsheet identifies those analytes that are 

being reported using this pretreatment step prior to Method 8260B. 

* * *

We trust you will find that the enclosed spreadsheet provides a more consistent and 

sound basis for developing the PVC MACT regulation than the calculated pounds per 

day (dry) information required by the Section 114 request. While we recognize that 

EPA needs to complete its work on this standard promptly, we would appreciate the 

opportunity to meet or hold conference calls with the Agency to discuss this critical 

information. Finally, we trust EPA will continue to be receptive to additional data 

submission to ensure that the final PVC MACT is comprehensive, in accordance with 

the Clean Air Act and legal precedents, and uncontroversial. Should you have any 

questions, please do not hesitate to contact me.

Sincerely, 

Richard P. Krock

Technical Director

E-mail: rkrock@vinylinfo.org

Phone: 571-970-3392

Cell: 571-216-4474