Page 1 of 4 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com 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 MAC T 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 forth coming 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

- ap proved 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 ar e 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 conver t 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 m oisture 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 so lids 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 representsPage 2 of 4 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com 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 C l 2 ) 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 inappropr iate 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

r equired 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 Grade s
The enclosed spreadsheet goes beyond resin polymerization categ ory (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 s pecific recipe . The

1 Sampling data is provided for all VI members and Georgia Gulf only.Page 3 of 4 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com 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 (VA CO)

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 an alyzed 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 th at 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 vari ous 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 anal ytes. 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 characterizati ons become available.

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

As you know, m ost 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 us ing other test methods. It is important to note that average daily residual vinyl chloride (R VC M) data was obtained us ing EPA Method 107

, which was developedPage 4 of 4 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com specifically for RVCM in PVC resins using Henry’s Law constant s and equilibrium calculations speci fic to R VC M . 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 col lected 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 pretreatm ent 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 S ection 11 4 request . W hile 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

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