Enclosure 1

PVC Section 114 Enclosure 1

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05/ 15 /2014 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS
DEVELOPMENT INFORMATION COLLECTION REQUEST

I. Introduction

Under the authority of Section 114 of the Clean Air Act, t his information collection request is to be completed for operations that comprise the Polyvinyl Chloride and Copolymers (PVC) sou rce category at your company. The PVC Production source category includes any facility which
manufactur es polymerized vinyl ch loride. PVC is be produced by the suspension, suspension blending, emulsion/dispersion or bulk processes, although other methods may be used. T he source category includes the collection of all equipment and activities necessary to produce PVC
ho mopolymer o r 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 enclos ure

. 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 h oward.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 Attachme nts 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).Enclosure 1

PVC Section 114 Enclosure 1

– Page 2
05/ 15 /2014 Other files included in this package are an exa mple 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 an d 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 e missions are to be quantified. Do not report concentrations or emissions as “t race” or “minimal.” If a concentration is at or below a detection limit, then provide the detection limit.

Form A 1

– 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
E lectronic R eporting T ool (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/compou nds 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.” I f 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 co mpound. 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
f or Calculating and Reporting Values Measured Below Method Detection Levels.”

Form Q

– Total Hydrocarbon 30

- Day MonitoringEnclosure 1

PVC Section 114 Enclosure 1

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05/ 15 /2014  Form Q is used to collect the results of the 3 0

- day, continuous total hydrocarbon (THC) and methane (CH 4 ) 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 workboo k.

 Along with the continuous 30

- day THC and CH 4 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 operatio ns indicator.Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 

### B ackground 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 defini tions 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 Pro tection 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 regul ations under Section 112(d) to limit emissions of hazardous air pollutants (HAP) from major and area sources of
emissions

. Section 11 2(a)(1) defines a major source as “ any stationary source or group of stationary sources located within a contiguous area an d 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 combinati on of hazardous air pollutants.” Based on the Administrator’ s determin ation, EPA may lower the major source cutoff for indi vidual HAP. An area source is “ any stationary source of hazardous air pollutant s 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 categor y 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 b est 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 Po lyvinyl Chloride and Cop olymers 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 implementEnclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

– Page 2
0 5 / 15 /2014 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 promu lgation, 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 pr evious 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 var ious 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.: EPA

45 3 / R

- 9 5

- 01 7

.

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.Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 Bulk process/ resin : A p rocess for producing polyvinyl chloride resin that is characterized by a two

- step anhydrous polymerization process: the formation of small resin particles in a pre

polymerized reactor using small amounts of vinyl chloride monomer, an initiator, and agitati on; 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 th at 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 ma terial /input to the process unit

.

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

Malfunction: A ny sudden, infrequent, and not reasonably preventable failure of air pollution control and monitoring equipment, process equipment, or a process to op erate 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.Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 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 manufac ture 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; reac tant 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, a gitators, 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 o f 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),

suspen sion, dispersion/emulsion, blending and bulk

processes.Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 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 equi pment include, but are not limited to, polymerization
reactors, PVC resin strippers, resin dewatering and dry ing 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 product ion process.

Resin grade: T he 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 suspen sion
resins.

Shutdown: T he cessation of operation of an affected source or portion of an affected source for any purpose. (40 CFR 63.2)

Startup: T he 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.

Su spension 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 resi ns. 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 usi ng 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.Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 Suspens ion 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: T he broa d 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 CF R 51.100(s).Enclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 6.0 Key Acronyms and Units of Measure

% percent

a cfm actual cubic feet per minute

acfm/ft 2 actual cubic feet per minute per square foot

batches/yr batches per year

B tu /scf British thermal units per standard cubic foot

CAA Clean Air Act

day/yr days per year

DC District of Columbia

d scfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

f t feet

ft/s feet per second

ft 3 /1,000 afcm cubic feet per thousand actual cubic feet per minute

g pm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

i n inches

in H 2 O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallonEnclosure 1
Attachment A

PVC Section 114 Enclosure 1, Attachment A

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0 5 / 15 /2014 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 weightEnclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

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0 5 / 15 /2014 

## 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 p roduction facility

, then you are required to conduct

tes ting 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 p art 60 to select the locations and number of traverse points for sampl ing. See http://www.epa.gov/ttn/emc/methods/method1.html for a copy 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 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

, possib le 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/. ForEnclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

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0 5 / 15 /2014 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 l ike 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 :

 T he type of resin being processed and the resin grade;

 E missions control device(s) in use during the test;

 C ontrol 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 inject ion rate) ; and

 P rocess parameters (such as percent oxygen).

The testing should be conducted while the PVC production process and any other non

PVC production process(es) that send emission streams to the same control device, is/are operating as close as p ossible 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

comp arison 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 specificatio n” 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 lim its; 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 m ost 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 signi ficantly onEnclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

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0 5 / 15 /2014 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 te sters 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 E nclosure 6)

.

Table 1.1 : Summary of Polyvinyl Chloride and Copolymers’ Control System Outlet Emissions

Measurement Methods and Alternative Methods 1

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 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

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 p pmvd as propane @ 3 % O 2

CH 4 U.S. EPA Method 320 . Have a minimum sample time of 4
hour s per run

. U.S. EPA Method 18. Have a minimum sample time of 4
hour s per run.

. ppmvd @ 3 % O 2

Dioxins/Furans 2 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 2Enclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

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0 5 / 15 /2014 Pollutant Required Method Possible Alternative
Method Target Reported

Units of Measure Speciated HAP listed
in Table 1.3 3 Sample collection by SW

- 846
Method 0031 , sample preparation by SW

- 846
Method 5041A, and sample analysis by SW

- 846 Method
8260B 4

. 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 3 Sample collection by SW

- 846
Method 0010 , sample preparation by SW

- 846
Method 3542 5 , and sample analysis by SW

- 846 Method
8270D 4 . Collect a minimum sample volume of 3 ds cm per

run . Use low resolution
GC / MS with the use of selected ion monitoring (SIM)
mode for the analytical finish. None ppmvd @ 3% O 2

Speciated HAP listed
in Table 1.5 3 U.S. EPA Method 18 or 320 6

. Minimum s ampl e 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 recove ry study specified in Section 8.4
of Method 18. 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

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 dscf m

1 You must sample THC, vinyl chloride, and all speciated HAP concu rrently.

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 th ose 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.Enclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

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0 5 / 15 /2014 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 pa rameters.

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 75354Enclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 6
0 5 / 15 /2014 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 Method s 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

Y ou must conduct total hydrocarbon (T HC ) 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 th e 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 p ropane must be used. None ppmvd as propane @
3% O 2

CH 4 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% O 2

O 2 U.S. EPA Method 3A

continuously for 30 days. U.S. EPA Method 3B % volume, dryEnclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 7
0 5 / 15 /2014 Pollutant Recommended Method Alternative Method Target Reported Units of Measure

Moisture U.S. EPA Method 4 once per

day fo r 30 days

. W here the exhaust stream is
saturated (e.g. the outlet of a wet scrubber), you may measure the temperature by thermocouple and report the moi sture at saturation levels. W here 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 depend s up on the methods used to complete the test ing 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

- d ay THC monitoring; you only need to use the ERT to report the results of the Table 1.1 stack test. T he 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. T he 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

. Y ou must also submit an electronic copy of the emission test report that
includ es all of the i nformation 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
informati on 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, a ll performance test reports must include the following information:Enclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 8
0 5 / 15 /2014  General identification information for the facility including a ma iling 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 non

PVC 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 classific ation 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
modifica tions 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

e missions 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.

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 an d 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.govEnclosure 1
Attachment B

PVC Section 114 Enclosure 1, Attachment B

– Page 9
0 5 / 15 /2014  Mail a CD or DVD containing an electronic copy of all requested files to the EPA address shown in your s ection 114 letter. If no electronic copy 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

your 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 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.govEnclosure 1
Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 1
5 / 15 /2014 

### 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 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 analytical values used to calculate and report an in

stack 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 deter mination 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 specifi ed 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 lab oratory 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 D etails in the ERT.

o Describe these procedures completely in the full test re port 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
d etection level using the relevant MDL, sampling volumes and other relevant runEnclosure 1
Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 2
5 / 15 /2014 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 concentrat ion 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 laboratory

specific 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
othe r 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 (us ing 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.Enclosure 1
Attachment C

PVC Section 114 Enclosure 1, Attachment C

– Page 3
5 / 15 /2014 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 t he 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, [<0.9 45] 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 re port 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 an d 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” a s 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.