Enclosure 1

PVC Section 114 Enclosure 1 – Page 1

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MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS

DEVELOPMENT INFORMATION COLLECTION REQUEST

I. Introduction

Under the authority of Section 114 of the Clean Air Act, this information collection request is to 

be completed for operations that comprise the Polyvinyl Chloride and Copolymers (PVC) source 

category at your company. The PVC Production source category includes any facility which 

manufactures polymerized vinyl chloride. PVC is be produced by the suspension, suspension 

blending, emulsion/dispersion or bulk processes, although other methods may be used. The source 

category includes the collection of all equipment and activities necessary to produce PVC 

homopolymer or copolymer resin.

This information collection request consists of testing and analysis of emissions from 

PVC process vents (i.e., at the outlet of the final control device). The results of testing are 

reported in either the Electronic Reporting Tool (ERT) or in dedicated worksheets that are 

contained in a single Microsoft Excel workbook file along with the required response forms. 

Additional information on the PVC process vent testing and analysis requirements can be 

found in Attachment B of this enclosure. Information regarding how to calculate and report 

method detection levels in located in Attachment C of this enclosure.

If you have questions regarding this request, please contact Ms. Jodi Howard, Refining

and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.

All recipients must perform the requested stack testing and submit the test results, 

reports, and documentation along with the responses to the information collection request and 

supplemental data and information specified in Attachments A, B and C of Enclosure 1 no later 

than November 17, 2014. Any submissions made after this date will be in violation of this 

Section 114 request.

Please e-mail the completed non-confidential response to:

CCG-PVC@epa.gov

II. Instructions for Completing the Information Collection Request Response Forms

The information collection request response forms are available as a single Microsoft 

Excel 2007 workbook. The workbook is included with this enclosure and is titled:

“2014 PVC 114 PV Testing.xlsx”

The workbook should be completed for the entire PVC production facility. Before 

submitting the file, the file name will be changed to reflect the actual company and facility (see

Section III).
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Other files included in this package are an example of how to complete the Excel 

workbook and a copy of this enclosure. Where necessary, examples of how to complete selected 

portions of the information collection request response forms are included directly in the forms 

themselves. Refer to examples and the instructions contained in this enclosure when completing 

your response.

NOTE: For the purposes of this information collection request, all HAP and VOC 

concentrations and emissions are to be quantified. Do not report concentrations or 

emissions as “trace” or “minimal.” If a concentration is at or below a detection 

limit, then provide the detection limit.

Form A1 – Company Information 

 Form A-1 is where the respondent company is identified. 

 In question I.1 of Form A-1, identify the legal parent company/legal corporate owner name. 

In questions I.2 through I.6 provide the mailing address for the legal parent company/legal 

corporate owner.

 Identify the size of the company by selecting the appropriate range for the number of 

employees (including all subsidiaries, branches, and related establishments owned) in 

question I.7.

Form P – Process Vent Emissions Testing Data

 Form P is used to collect results of performance tests that are not supported by the EPA’s 

Electronic Reporting Tool (ERT). Refer to Attachment B to this Enclosure 1, Summary of 

Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and 

Copolymers Facility Emission Points for more information for additional information.

 Copy Form P as necessary for pollutants/compounds sampled on different dates. 

 For multiple control devices, users may copy Form P within the response workbook.

 For each test run, provide the required operating parameters collected during the test. Note 

the selection for “PVC Production Rate Units.” If your final product is sold and shipped dried 

(e.g., a suspension resin), select “dry lbs PVC/day.” If your final product is sold and shipped 

without being dried (e.g., an emulsion resin), select “total lbs PVC/day.”

 Provide a numerical result for each compound. Do not provide non-numerical data in the 

compound results columns.

 In the “Run # Detection” columns, identify the status of the measured values relative to 

detection levels following the instructions in Attachment C to this Enclosure 1, “Guidance 

for Calculating and Reporting Values Measured Below Method Detection Levels.”

Form Q – Total Hydrocarbon 30-Day Monitoring
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 Form Q is used to collect the results of the 30-day, continuous total hydrocarbon (THC) and 

methane (CH4) monitoring required in Section 1.3 of Attachment B to this Enclosure 1, 

Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride 

and Copolymers Facility Emission Points.

 For multiple control devices, users may copy Form Q within the response workbook.

 Along with the continuous 30-day THC and CH4 readings, provide the corresponding oxygen 

and moisture values, along with the PVC type and grade being manufactured. 

 Supply the control device temperature, and the control device and THC monitoring 

operations indicator.
Enclosure 1

Attachment A

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Background for Polyvinyl Chloride and Copolymers Production MACT 

Standards Development Information Collection Request

1.0 Introduction

The purpose of this attachment is to provide the respondent with additional detail on the 

relevant requirements of the Clean Air Act, the regulatory background of the polyvinyl chloride 

and copolymers production source category, and to provide a list of definitions of key terms used 

in the information collection request.

2.0 Summary of Clean Air Act Requirements

The maximum achievable control technology (MACT) standards development 

information collection request was developed by the U. S. Environmental Protection Agency’s 

(EPA) Office of Air Quality Planning and Standards Emission Standards Division 

(OAQPS/ESD) to help EPA meet its obligations under the Clean Air Act Amendments of 1990. 

Specifically, the Clean Air Act Amendments require EPA to develop regulations under Section 

112(d) to limit emissions of hazardous air pollutants (HAP) from major and area sources of 

emissions. Section 112(a)(1) defines a major source as “any stationary source or group of 

stationary sources located within a contiguous area and under common control that emits or has 

the potential to emit considering controls, 10 tons per year or more of any hazardous air pollutant 

or 25 tons per year or more of any combination of hazardous air pollutants.” Based on the 

Administrator’s determination, EPA may lower the major source cutoff for individual HAP. An 

area source is “any stationary source of hazardous air pollutants that is not a major source.”

The Clean Air Act Amendments of 1990 prescribe an analytical framework that EPA is 

to apply in developing national emission standards for hazardous air pollutants (NESHAP) for 

major sources. A key concept in this framework is the establishment of the MACT floor. The 

amendments specify that NESHAP for existing sources in a particular category or subcategory 

are to be no less stringent (but may be more stringent) than the average emission limitation 

achieved by the best performing 12 percent of the existing sources in such category or 

subcategory of sources. In categories or subcategories with less than 30 sources, the floor is to be 

based on the average emission limitation achieved by the best performing 5 sources. The MACT 

floor for new sources is the emission control that is achieved in practice by the best controlled 

similar source.

The Clean Air Act Amendments allow the EPA Administrator to "distinguish among 

classes, types, and sizes of sources within a category or subcategory in establishing such 

standards" (Section 112(d)).

3.0 Regulatory Background for the Polyvinyl Chloride and Copolymers Production 

Source Category

On October 21, 1976, EPA promulgated emission standards for vinyl chloride under the 

risk-based standard then in effect (41 FR 46560; 40 C.F.R. Subpart F (§§ 61.60 - 61.71); “the 

Part 61 NESHAP”). When Congress amended the CAA in 1990, it required EPA to implement 
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technology based standards. As a result, EPA proposed MACT standards for the Polyvinyl 

Chloride and Copolymers Production source category on December 8, 2000 (65 FR 76958) and 

promulgated final MACT standards for the source category on July 10, 2002 (67 FR 45886) 

(“the Part 63 NESHAP”). EPA adopted most of the Part 61 NESHAP as the new Part 63 

NESHAP and the Part 61 standards became the MACT floor for existing sources.

Mossville Environmental Action NOW and Sierra Club petitioned the U.S. Court of 

Appeals of the District of Columbia to review various provisions of the Part 63 NESHAP. The 

Part 63 NESHAP was vacated on June 18, 2004 in Mossville v. EPA, 370 F. 3d. 1232 (D.C.Cir. 

2004) and remanded to the agency for it to reconsider or properly explain its methodology for 

regulating HAPs emitted in PVC production other than vinyl chloride by use of a surrogate.

On April 17, 2012, the EPA promulgated revised standards for PVC major and area 

sources. After promulgation, the Administrator received petitions for reconsideration of certain 

provisions in the final rules. 

The purpose of the current information collection is to gather data from PVC production 

facilities that were either not included in the EPA’s previous data collection efforts for the source 

category or whose data were excluded by the Agency from various technical analyses that 

supported the April 2012 rulemaking. The collected data will support analyses of environmental 

and economic impacts of various revisions to the current Part 63 NESHAP for PVC major and 

area sources.

4.0 Guidance Documents

Following is a list of EPA guidance documents and resources that may be useful to respondents 

in estimating HAP emissions. 

1. Compilation of Air Pollutant Emission Factors: Volume I: Stationary Point and 

Area Sources. U. S. Environmental Protection Agency. Research Triangle Park, 

N.C. 1995. http://www.epa.gov/ttn/chief/ap42/index.html

2. Factor Information Retrieval (FIRE) Data System. U. S. Environmental Protection 

Agency. http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main

3. Protocol for Equipment Leak Emission Estimates. U. S. Environmental Protection 

Agency. Research Triangle Park, N.C. November 1995. Publication No.: EPA453/R-95-017.

4. Batch Process ACT. U. S. Environmental Protection Agency. Research Triangle 

Park, N.C. February 1994. Publication No.: EPA-453/R-94-020.

5.0 Key Term Definitions

The following definitions are provided for the purpose of the information collection request only. 

They are not intended to replace statutory definitions or regulatory definitions developed 

elsewhere.
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Bulk process/resin: A process for producing polyvinyl chloride resin that is 

characterized by a two-step anhydrous polymerization 

process: the formation of small resin particles in a prepolymerized reactor using small amounts of vinyl chloride 

monomer, an initiator, and agitation; and the growth of the 

resin particles in a post polymerization reactor using 

additional vinyl chloride monomer. Resins produced using 

the bulk process are referred to as bulk resins.

Control device: A combustion device, recovery device, recapture device, or 

any combination of these devices used to comply with a 

regulation, numerical emission limit, work practice 

standard, etc. Process condensers are not control devices.

Dispersion process/resin: A process for producing polyvinyl chloride resin that is 

characterized by the formation of the polymers in soap 

micelles that contain small amounts of vinyl chloride 

monomer. Emulsifiers are use to disperse vinyl chloride 

monomer in the water phase. Initiators used in the 

dispersion process are soluble in water. Resins produced 

using the dispersion process are referred to as latex or 

dispersion resins.

Feedstock: Raw material/input to the process unit.

Hazardous Air Pollutants (HAP): See 42 U.S.C. §7412(a)(6).

Malfunction: Any sudden, infrequent, and not reasonably preventable 

failure of air pollution control and monitoring equipment, 

process equipment, or a process to operate in a normal or 

usual manner which causes, or has the potential to cause, 

the emission limitations in an applicable standard to be 

exceeded. Failures that are caused in part by poor 

maintenance or careless operation are not malfunctions. (40 

CFR 63.2)

Polyvinyl Chloride and 

Copolymers Production Facility:

The collection of all polyvinyl chloride and copolymers 

production process unit, storage vessels, surge control 

vessels, heat exchange systems, wastewater, and process 

wastewater treatment systems that are associated with 

producing polyvinyl chloride.
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Polyvinyl Chloride and 

Copolymers Production Process 

Unit or PVCPU:

A collection of process components assembled and 

connected by hard-piping or duct work, used to process raw 

materials and to manufacture polyvinyl chloride and/or 

polyvinyl chloride copolymers. A PVCPU includes, but is 

not limited to, polymerization reactors; resin stripping 

operations; resin blend tanks; resin centrifuges; resin dryers; 

resin product separators; recovery devices; reactant and raw 

material charge vessels and tanks; holding tanks, mixing 

and weighing tanks; finished resin product storage tanks or 

storage silos; finished resin product loading operation; 

connected ducts and piping; equipment including pumps, 

compressors, agitators, pressure relief devices, sampling 

connection systems, open-ended valves or lines, valves and 

connectors and instrumentation systems. A PVCPU does 

not include chemical manufacturing process units, as 

defined in §63.101, that produce vinyl chloride monomer or 

other raw materials used in the PVC polymerization 

process.

Polyvinyl Chloride and Copolymer 

Resin (PVC Resin):

Polyvinyl Chloride Copolymer:

Polyvinyl Chloride Homopolymer:

The general reference to any PVC homopolymer or 

copolymer resin manufactured by the suspension, 

dispersion, bulk, and/or solution processes.

A synthetic thermoplastic polymer that is derived from the 

simultaneous polymerization of vinyl chloride and another 

monomer such as vinyl acetate. Polyvinyl chloride 

copolymer is produced by different processes, including, but 

not limited to, suspension, dispersion/emulsion, suspension 

blending, and solution processes.

Polyvinyl chloride homopolymer means a synthetic 

thermoplastic polymer that is derived from the 

polymerization of vinyl chloride and has the general 

chemical structure (-H2CCHCl-)n. Polyvinyl chloride 

homopolymer is typically a white powder or colorless 

granule. Polyvinyl chloride homopolymer is produced by 

different processes, including (but not limited to), 

suspension, dispersion/emulsion, blending and bulk 

processes.
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Process equipment: Any unit operation or group of unit operations or any part of 

a process or group of parts of a process that are assembled 

to perform a specific function. Examples of process 

equipment include, but are not limited to, polymerization 

reactors, PVC resin strippers, resin dewatering and drying 

equipment storage tanks and vessels, cooling towers and 

heat exchange systems, and transfer operations.

Process unit: The process components assembled and connected by pipes 

or ducts to process raw and/or intermediate materials and to 

manufacture an intended product. For the purposes of this 

information collection request, process unit includes, but is 

not limited to, polyvinyl chloride production process.

Resin grade: The subdivision of PVC resin that describes it as a unique 

resin, i.e., the most exact description of a type of resin with 

no further subdivision. Examples include low molecular 

weight suspension resins and general purpose suspension 

resins.

Shutdown: The cessation of operation of an affected source or portion 

of an affected source for any purpose. (40 CFR 63.2)

Startup: The setting in operation of an affected source or portion of 

an affected source for any purpose. (40 CFR 63.2)

Stream: Any contained or non-contained solid, liquid, gas, or vapor 

entering or exiting an individual unit operation or single 

piece of equipment.

Stripped resin: The material exiting the resin stripper than contains 

polymerized vinyl chloride.

Suspension blending process/resin: A process for producing polyvinyl chloride resin that is 

similar to the suspension polymerization process, but 

employs a rate of agitation that is significantly higher than 

the highest range for non-blending suspension resins. The 

suspension blending process uses a recipe that creates 

extremely small resin particles, generally equal to or less 

than 100 microns in size, with a glassy surface and very 

little porosity. The suspension blending process 

concentrates the resins using a centrifuge that is specifically 

designed to handle these small particles. Polyvinyl chloride 

resins produced using the suspension blending process are 

referred to as suspension blending resins and are typically 

blended with dispersion resins.
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Suspension process/resin: A process for producing polyvinyl chloride resin that is 

characterized by the formation of the polymers in droplets 

of liquid vinyl chloride monomer or other co-monomers 

suspended in water. The droplets are formed by agitation 

and the use of protective colloids or suspending agents. 

Initiators used in the suspension process are soluble in vinyl 

chloride monomer. Polyvinyl chloride resins produced using 

the suspension process are referred to as suspension resins.

Type of Resin: The broad classification of PVC homopolymer and 

copolymer resin referring to the basic manufacturing 

process for producing that resin, including, but not limited 

to, suspension, dispersion, bulk, and solution processes.

Volatile Organic Compounds 

(VOC):

See 40 CFR 51.100(s).
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6.0 Key Acronyms and Units of Measure

% percent

acfm actual cubic feet per minute

acfm/ft2actual cubic feet per minute per square foot

batches/yr batches per year

Btu/scf British thermal units per standard cubic foot

CAA Clean Air Act

day/yr days per year

DC District of Columbia

dscfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

ft feet

ft/s feet per second

ft3/1,000 afcm cubic feet per thousand actual cubic feet per minute

gpm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

in inches

in H2O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallon
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LDAR leak detection and repair

MACT maximum achievable control technology

mg/l milligrams per liter

MMlb/yr million pounds (mass) per year

NAICS North American Industry Classification System

NESHAP National Emission Standards for Hazardous Air Pollutants

OAQPS Office of Air Quality Planning and Standards

oC degrees Celsius

oF degrees Fahrenheit

ohm-cm ohm-centimeter

P&ID piping and instrumentation diagram

PFD process flow diagram

ppmv parts per million, by volume

ppmw parts per million, by weight

PVC polyvinyl chloride

S second or seconds

scfm standard cubic feet per minute

SPPD Sector Policies and Programs Division

ton/yr tons per year, or short tons per year

VOC Volatile Organic Compounds

vol% volume percent, or percent by volume

wt% weight percent, or percent by weight
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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 hazardous air 

pollutant emissions from process vents within this source category. These data will be used to 

supplement the existing HAP data set for process vents. 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 at the outlet or in the stack of the final control device 

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. 

For copies of the recommended U.S. EPA methods and additional information, please 

refer to EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. For 
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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. If you would like to use a 

method not listed in Table 1.1, please contact the EPA for approval of an alternative test method. 

The request for an alternative test method should include the alternative test method or 

prescriptive alternative procedure, the reason for the request (e.g., lower detection limit, site 

specific matrix interference, increased precision, etc.), supporting empirical data (e.g. 

comparison with specified method, precision determination, etc.), and quality control procedures 

which ensure results are sufficiently accurate and precise. See the Emission Measurement 

Center’s Guideline Document 22 (http://www.epa.gov/ttn/emc/guidlnd/gd22.pdf) for more 

information on what information should be included in an alternative test method request.

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 Section 1.3. In addition 

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

testing period: 

 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 percent oxygen).

The testing should be conducted while the PVC production process and any other nonPVC production process(es) that send emission streams to the same control device, is/are

operating as close as possible to maximum mass loading of all HAP compounds to the control 

device and under “normal” operation, that is, not during periods of startup, shut down, or 

malfunction. A thorough description of the process(es), including production rate(s) and a 

comparison of those production rates to maximum production capacity for PVC process units 

and non-PVC process units 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 
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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 

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 Methods1

Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Vinyl Chloride U.S. EPA Method 18 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

THC U.S. EPA Method 25A with a 

minimum sampling time of 4 

hours per run. Calibrate the 

measuring instrument with a 

mixture of the organic 

compounds being emitted or 

with propane. 

None ppmvd as propane

@ 3% O2

CH4 U.S. EPA Method 320. Have 

a minimum sample time of 4

hours per run.

U.S. EPA Method 18. Have a 

minimum sample time of 4

hours per run..

ppmvd @ 3% O2

Dioxins/Furans2 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
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Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Speciated HAP listed 

in Table 1.33

Sample collection by SW-846 

Method 0031, sample

preparation by SW-846 

Method 5041A, and sample 

analysis by SW-846 Method

8260B4. 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 1.43

Sample collection by SW-846

Method 0010, sample

preparation by SW-846 

Method 35425, and sample 

analysis by SW-846 Method

8270D4. Collect a minimum 

sample volume of 3 dscm per 

run. Use low resolution

GC/MS with the use of 

selected ion monitoring (SIM)

mode for the analytical finish. 

None ppmvd @ 3% O2

Speciated HAP listed 

in Table 1.53

U.S. EPA Method 18 or 3206.

Minimum sample time of 1

hour per run. All compounds 

quantified by Method 320 

must be validated according to 

Section 13.0 of Method 320. 

All compounds quantified by 

Method 18 meet the recovery 

study specified in Section 8.4 

of Method 18.

None ppmvd @ 3% O2

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

Simultaneous with each 

pollutant test run.

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

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 sample THC, vinyl chloride, and all speciated HAP concurrently.

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

3

If any HAP other than those listed in Tables 1.3-1.5 could be emitted from the process, you must test for those

HAP using US EPA Method 320, US EPA Method 18, SW-846 Method 0010, or an approved alternative test 

method, as applicable. 

4 You must use all three SW-846 methods in combination to obtain a measurement result. The first method is the 

sampling method to be used at the stack. The second method is a preparatory method that readies for analysis the 

sample obtained from the first method. The third method is the analysis method.

5 SW-846 Method 3542 replaces Section 8.1 of SW-846 Method 0010.
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6 The selection of technique [Method 320, Method 18 – Bag Sampling (Section 8.2.1), Method 18 – Direct 

Interface (Section 8.2.2), or Method 18 – Absorption Tube (Section 8.2.4)] must be made for each compound in 

Table 1.5 to achieve the lowest detection limit and meet method quality parameters.

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 8260B

Pollutant CAS Number Pollutant CAS Number

Benzene 71432 n-Hexane 110543

Chloroethane 75003 Methylene chloride 75092

Chloroform 67663 Toluene 108883

Chloroprene 126998 1,1,1-Trichloroethane 71556

1,1-Dichloroethane 75343 1,1,2-Trichloroethane 79005

1,2-Dichloroethane 107062 Vinylidene chloride 75354
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Table 1.4 Target Analytes Using SW-846 Method 8270D

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

Table 1.5 Target Analytes Using US EPA Methods 18 and 320

Pollutant CAS Number Pollutant CAS Number

Acetaldehyde 75070 Formaldehyde 50000

1,3-Butadiene 106990 Methanol 67561

Chlorobenzene 108907 1,1,2,2-Tetrachloroethane 79345

Chloromethane 74873 2,2,4-Trimethylpentane 540841

Cumene 98828 Vinyl acetate 108054

Ethylbenzene 100414 Vinyl bromide 593602

Ethylene glycol 107211 Xylenes (isomers and mixtures) 1330207

1.3 Total Hydrocarbon 30-Day Monitoring

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

as specified in Table 1.6. You must also concurrently record the exhaust gas oxygen and 

moisture levels, the types and grades of PVC resin being produced, and the control device 

temperature. Also indicate periods of abnormal operation for the control device and/or THC 

monitoring equipment. All the emissions testing required in Table 1.1 must be conducted during 

this 30-day monitoring period.

Table 1.6 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

CH4 U.S. EPA Method 320 U.S. EPA Method 18 or 

instrument that uses 

chromatographic column to split

methane from all other organic 

compounds.

ppmvd @ 3% O2

O2 U.S. EPA Method 3A

continuously for 30 days. 

U.S. EPA Method 3B % volume, dry
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Pollutant Recommended Method Alternative Method

Target Reported 

Units of Measure

Moisture U.S. EPA Method 4 once per 

day for 30 days.

Where the exhaust stream is 

saturated (e.g. the outlet of a wet 

scrubber), you may measure the 

temperature by thermocouple 

and report the moisture at 

saturation levels. Where a stack 

is not saturated, moisture may 

be determined by wet/dry bulb 

psychrometry (ASTM E-337)

twice daily (at least one hour 

apart), by Method 320, or by 

ASTM D6348-12 (FTIR)

% volume

2.0 How to Report Data

The method for reporting the results of testing and monitoring depends upon the 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 EPA Methods 23, 25/25A, and 26/26A, you must report the 

results of the performance test using the EPA’s Electronic Reporting Tool (ERT). You do not 

need to use the ERT to report the results of the 30-day THC monitoring; you only need to use the 

ERT to report the results of the Table 1.1 stack test. The ERT website (see 

http://www.epa.gov/ttn/chief/ert/index.html) contains the latest version of the ERT, as well as 

frequently asked questions and a user’s guide. The ERT is a Microsoft Access program that 

must be downloaded onto your computer prior to data entry. The file generated from the ERT 

must be submitted according to one of the methods specified in Section 3.0 of this Attachment.

For data collected using all other test methods, you must report the results of the 

performance test(s) using Form P in the information collection request response forms Microsoft 

Excel workbook. You must also submit an electronic copy of the emission test report that 

includes all of the information specified in Section 2.2 of this Attachment (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 

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:
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 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, including a flow diagram clearly showing all process vent 

piping at the inlet to the first control device including manifolds and tie-in points for nonPVC process unit process vents (with those non-PVC process units identified), any 

piping that allows a process vent to bypass the control device(s), and the sampling site;

 A complete unit description for PVC and non-PVC process units, including a description 

of emission 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 Form P, 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. 

3.0 How to Submit Data

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

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

submit all non-CBI 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
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 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
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Guidance for Calculating and Reporting Values Measured Below Method 

Detection Levels

1.0 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).

2.0 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 Form P columns labeled “Run #1 Detection”, “Run #2 Detection”, and/or “Run #3 

Detection” as appropriate 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 
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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 detection level numerical value (i.e., no brackets or < symbol) in the 

Excel spreadsheet template (Form P; columns “Run 1”, “Run 2”, and/or 

“Run 3” as appropriate) and select the appropriate flag in the Form P 

columns labeled “Run #1 Detection”, “Run #2 Detection”, and/or “Run #3 

Detection” as appropriate; or 

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

Comments line.

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 detection level numerical value (i.e., no brackets or < symbol) in the 

Excel spreadsheet template (Form P; columns “Run 1”, “Run 2”, and/or 

“Run 3” as appropriate) and select the appropriate flag in the Form P 

columns labeled “Run #1 Detection”, “Run #2 Detection”, and/or “Run #3 

Detection” as appropriate; 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.
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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.

 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 detection level numerical value (i.e., no brackets or < symbol) in the 

Excel spreadsheet template (Form P; columns “Run 1”, “Run 2”, and/or 

“Run 3” as appropriate) and select the appropriate flag in the Form P 

columns labeled “Run #1 Detection”, “Run #2 Detection”, and/or “Run #3 

Detection” as appropriate;

 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.