October 15, 2012

Sent via Electronic Mail and Fedex 

Ms. Andrea Siefers

Environmental Engineer, Refining and Chemicals Group

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

109 T.W. Alexander Drive 

Mail Code: E143-01

Research Triangle Park, NC 27711

Siefers.Andrea@epa.gov

RE: Polyvinyl Chloride and Copolymers Process Wastewater Section 114 

Sampling and Analysis, and Information Request

Dear Ms. Siefers:

This letter responds on behalf of the Vinyl Institute PVC MACT Working Group1 to

EPA’s request for comments on its draft Clean Air Act Section 114 Request sent via 

electronic mail on October 3, 2012. The request seeks sampling and analysis of 

process wastewater from U.S. producers of polyvinyl chloride resins and copolymers. 

We address the following documents, collectively referred to hereinafter as “draft 114 

Request”:

• “Summary of Test Procedures, Methods, And Reporting Requirements For 

Process Wastewater Sampling and Analysis at Polyvinyl Chloride and 

Copolymer Facilities”, Draft October 3, 2012;

• Excel file named “CAASection114_PVC_ProcessWW_DRAFT_10-03-12.xlsx”

The 114 request will be issued following the Agency’s granting to several petitioners’ 

requests to reconsider certain aspects of the National Emission Standards for 

Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production; Final Rule, 

77 Fed. Reg. 22,848 (April 17, 2012). Petitions to review this rule were filed by VI and 

some individual Working Group members, among others. These suits are in abeyance 

 1 The PVC MACT Working Group includes Vinyl Institute members (Shintech Inc., Formosa Plastics Corporation, U.S.A., 

Occidental Chemical Company /Oxy Vinyls, LP, Westlake Chemical Corporation, and PolyOne Corporation) and other PVC and 

Copolymer producers including Georgia Gulf Corporation and The Dow Chemical Company.
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The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

pending the outcome of the Agency’s reconsideration. Accordingly, the Working Group 

is pleased to submit these comments on the draft 114 Request as discussed herein and 

in more detail in Attachments A, B, & C, which are listed at the bottom of this letter.

1. Industry Proposes to Submit the Sampling and Analysis Report by May 1, 2013

As you know, the PVC MACT rule was subjected to a very tight schedule, which 

rushed efforts in data collection, sampling, and analysis that led to a number of 

critical inconsistencies and mistakes. Accordingly, the proposed schedule is 

intended to provide adequate time for project planning, Quality Assurance Project

Plans (QAPP) preparation, and sampling/analysis plan (SAP) development. This will 

allow the industry to follow a uniform methodology, resulting in a consistent, more 

comparable data set. The schedule also accommodates the inevitable holiday period 

with low production rates, reduced staff, and shutdowns. To that end, the Working 

Group reviewed the critical steps necessary to complete the Section 114 Request in 

a timely yet comprehensive approach to assure a quality data set for the Agency to 

use in its rulemaking. 

As detailed in the timeline presented in Attachment B, the Working Group has 

identified that a number of steps must be completed before moving into the sampling 

and analysis phase. First, it is critical for industry to ensure that local laboratories 

will complete the sample analysis in as uniform manner as is possible. Certain 

analytes and their methods for analysis may not have been routinely performed at 

some commercial labs which necessitates that adequate screening and assessment 

be done to ensure that repeatable results are obtained from each laboratory. 

Industry projects some 8 weeks to complete these preliminary tasks, which would 

put the onset of sample collection into the new year. Industry also projects the 

ensuing 8 week period to complete the requested sample collection and another 8 

weeks for data and results analysis in a manner that produces a sound data base for 

EPA to use in its rulemaking.

Additional considerations for our approach are discussed in the next section.

2. The 114 Request Must Distinguish Between Batch Wastewater Stripping and 

Continuous Wastewater Stripping

The draft 114 Request would require 30 consecutive days of process wastewater 

(WW) sampling. Although such an approach may be appropriate for PVC producers 

that operate their process wastewater stripper/s continuously, it presents problems 

for those PVC producers that operate their process wastewater stripper/s in a batch 
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The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

manner. For batch WW stripper operations, process wastewater is collected and 

retained in holding tanks until certain volumes are reached, at which time the WW 

stripper is placed into service. Once the batch of process WW is stripped, the unit is 

taken out of service, which helps conserve utilities and other operating expenses. In 

some production scenarios at one PVC producer, their WW stripper may only 

operate once per week. It is not feasible for these producers to sample daily or to 

obtain 30 days of sampling in 30 consecutive days. The industry believes that the 

May 1, 2013 submission date is needed from a practical standpoint in order to 

account for those producers with intermittent batch WW stripper operations, in 

addition to other factors presented. 

3. The 114 Request Must Provide for Dealing with Unexpected Delays and Other 

Unforeseen Events that may Occur on a Case-by-Case Basis

Due to the complexity of the industry and the various methods for treating process 

wastewater, industry requests that EPA be aware of and give full consideration to 

case-by-case exceptions to completing the 114 Request by May 1, 2013. In addition 

to intermittent operations of WW strippers explained in the preceding paragraph, an 

unplanned outage may cause a temporary delay in the sample collection effort. 

Similarly, certain resin recipes are run according to product demand, and as such, 

that producer may want to provide data that is as representative as possible of 

normal operations (as required by the 114 Request instructions), which may require 

an extended period of time for sampling. 

4. Confidential Business Information (CBI) Should be Submitted in a Separate 

Workbook 

Working Group members were dismayed to learn during the prior PVC MACT 

Section 114 data collection effort that some confidential business information 

reported on the EPA derived spreadsheet request form would be publicly disclosed. 

Because of the manner in which the spreadsheet was developed, emissions 

information normally considered as publicly available was requested on the same 

spreadsheet as CBI production rates, capacities, and operating costs. EPA 

subsequently modified the forms for the EDC/VCM 114 survey request to allow CBI 

production rates, capacity information, and operating costs to be reported separately

from publicly available emissions information. The Working Group requests that 

EPA continue its practice of requesting CBI in a separate workbook or form.

The Vinyl Institute and its PVC MACT Working Group appreciate the opportunity to 

comment on EPA’s draft Section 114 Process Wastewater Sampling and Analysis 

Request. More detailed comments are included in the Attachments listed below. 
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The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

Please do not hesitate to contact me with any questions. 

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

phone: 571-970-3392

cell: 571-216-4474

CC: Ms. Penny Lassiter, EPA-RTP

Mr. Mark Kataoka, EPA-OCG

JC Walker, Keller and Heckman

Vinyl Institute PVC MACT Working Group

Attachments:

Attachment A: “PVC MACT Working Group Comments on CAA Section 114 

Request Memo for Summary of Test Procedures, Methods, and 

Reporting Requirements For Process Wastewater Sampling and 

Analysis at Polyvinyl Chloride and Copolymer Facilities, Draft

October 3, 2012”

Attachment B: “PVC MACT Working Group Proposed Sampling and Analysis 

Schedule”

Attachment C: “PVC MACT Working Group Comments on Draft CAA Section 

114 Request Excel Workbook for Process Wastewater Sampling 

Report”