**FORM A -1** 

**COMPA NY INFORMA**  **TION I. Parent Company / Legal Corporate Owner Information**  1. Legal Parent Company / Legal Corporate Name 2. Mailing Address 3. City 4. State 5. Zip Code 6. County 7. Size of Com pany

(approximate number of employ ees including all subsidiaries, branches, and related establishments owned):



### Page 1 of 1 **DRA FT**  PVC Section 114 Survey Part 1 06/23/2009**FORM A -2** 

**FA CILITY INFORMA** 

**TION II. Polyvinyl Chloride and Copolymers (PVC) Production Facility Information**  1. Facility

Name Facility Address a. Street b. City c. State d. Zip Code e. County Facility Coordinates (Decimal Degrees to the 5th decimal place) f. Latitude g. Longitude 2. Number of employ ees attached to the PVC production facility : **III. Technical Contact** 1. Name 2. Technical Contact Title 3. Telephone 4. Facsimile 5. Em ail **IV. Other** 1. Is the facility

a major source of HAP? 2. If No, did the facility

take a limit of its potential HAP em issions to avoid classification as a major source? 3. If the facility

took a limit of its potential HAP em issions to avoid classification as a major source, provide the date on which the limit was taken (MM/DD/YYYY). 4. Does the facility

manufacture other products in addition to PVC resin? 5. If Yes, list the other products manufactured at the facility

. 6. Are there any

HAP em issions associated with any co-located facilities?



### Page 1 of 1 **DRA FT** PVC Section 114 Survey Part 1 06/23/2009**FORM C ECONOMIC LIFE AND APPLICABLE REGULATIONS FOR PVC PRODUCTION UNIT** 
Year Facility Commenced PVC Production: years Remaining Economic Life PVC Production Unit: years **Table 1. Federal, State, and Local Regulations (list, include all regulations that apply to any part of the process unit)**

**Table 2. Federal, State, and Local Permits**

**Regulation Citation Regulation Title**  **Regulated Process Equipment/Control Device/Recovery Equipment (list ID provided in Form B)**

**Permit ID Permit Type**  **Regulated Process Equipment/Control Device/Recovery Equipment (list ID provided in Form B)**

Page 1 of 1 **DRAFT**PVC Section 114 Survey Part 1 06/23/2009**FORM D-2**

**30 DA Y RESIN SA**  **MP LING - STRIPPER OUTLET(S)** 

**Instructions**

2. Do not submit partial data for any day : each day

must include (at a minimum) concentration analy sis results for all HAP in Table 10 to Subpart HHHHHHH of 40 CFR Part 63. 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, daily resin production, number of samples composited, number of resin strippers sampled, analy sis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 4. Provide the total daily production from the resin strippers samples for the ty pe of resin. If your final product is sold as a dried resin, report production on a dry basis. If your final product is sold as a wet resin report production on a wet basis. 4. Enter any

other HAP expected to be present (that are not listed in Table 10 to Subpart HHHHHHH of 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 6. Enter any

notes or additional information relevant to the sampling or analysis. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**CA S No.**  **HA P**  107211 Ethy lene gly col 67561 Methanol 75070 Acetaldehy de 50000 Formaldehy de 51285 2,4-dinitrophenol 98862 Acetophenone 117817 Bis(2-ethy lhexy l) phthalate (DEHP) 123319 Hy droquinone 108952 Phenol 79345 1,1,2,2-tetrachloroethane 106990 1,3-butadiene 540841 2,2,4-trimethy lpentane 71432 Benzene 108907 Chlorobenzene 67663 Chloroform 126998 Chloroprene 98828 Cumene 75003 Ethy l chloride (Chloroethane) 100414 Ethy lbenzene 107062 Ethy lene dichloride (1,2-Dichloroethane) 75343 Ethy lidene dichloride (1,1-Dichloroethane) 74873 Methy l chloride (Chloromethane) 75092 Methy lene chloride 110543 n-Hexane 108883 Toluene 71556 Methy l chloroform (1,1,1-Trichloroethane) 79005 1,1,2-Trichloroethane **If Other, Please Provide a Description of the Resin Type -->**
**Number of Resin Strippers Sampled to Obtain Composite**

**Number of Samples Composited for A nalysis**  **Total Daily Resin Production Rate (lbs of resin per day from sampled resin strippers) Resin Type (suspension, dispersion, bulk, etc.) -->**  1. Complete the table below for each resin ty pe produced by the facility

during the 30 days of sampling. If the facility produced more than one resin ty pe during the 30 days, create multiple copies of this worksheet as necessary and complete one worksheet for each resin ty pe. Do not enter data for multiple resin ty pes on a single worksheet.108054 Viny l acetate 593602 Viny l bromide 75014 Viny l chloride 75354 Viny lidene chloride (1,1-Dichloroethy lene) 1330207 Xy lenes (isomers and mixtures)2. Do not submit partial data for any day : each day

must include (at a minimum) concentration analy sis results for all HAP in Table 10 to Subpart HHHHHHH of 40 CFR Part 63. 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, daily resin production, number of samples composited, number of resin strippers sampled, analy sis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 4. Provide the total daily production from the resin strippers samples for the ty pe of resin. If your final product is sold as a dried resin, report production on a dry basis. If your final product is sold as a wet resin report production on a wet basis. 4. Enter any

other HAP expected to be present (that are not listed in Table 10 to Subpart HHHHHHH of 40 CFR Part 63) in the table below. 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 6. Enter any

notes or additional information relevant to the sampling or analysis. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**An alysis M**  **ethod Concentration**  **(ppmw) Non-Detect?**  SW -846-8015C SW -846-8015C SW -846-8315A SW -846-8315A SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B **If Other, Please Provide a Description of the Resin Type -->**

**Lab Sample ID --> Lab Report ID -->**  **Number of Resin Strippers Sampled to Obtain Composite An**  **alysis Date --> Number of Samples Composited for A**  **nalysis Total Daily Resin Production Rate (lbs of resin per day from sampled resin strippers)**  **Resin Type (suspension, dispersion, bulk, etc.) --> Sample Date -->**  1. Complete the table below for each resin ty pe produced by the facility

during the 30 days of sampling. If the facility produced more than one resin ty pe during the 30 days, create multiple copies of this worksheet as necessary and complete one worksheet for each resin ty pe. DoSW -846-8260B

SW -846-8260B EPA Method 107 SW -846-8260B SW -846-8260B2. Do not submit partial data for any day : each day

must include (at a minimum) concentration analy sis results for all HAP in Table 10 to Subpart HHHHHHH of 40 CFR Part 63. 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, daily resin production, number of samples composited, number of resin strippers sampled, analy sis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 4. Provide the total daily production from the resin strippers samples for the ty pe of resin. If your final product is sold as a dried resin, report production on a dry basis. If your final product is sold as a wet resin report production on a wet basis. 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**Note(s) Concentration**  **(ppmw) Non-Detect?**  **Note(s) 1**  **2** 1. Complete the table below for each resin ty pe produced by the facility

during the 30 days of sampling. If the facility produced more than one resin ty pe during the 30 days, create multiple copies of this worksheet as necessary and complete one worksheet for each resin ty pe. Do7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**Concentration (ppmw)**  **Non-Detect? Note(s)**  **Concentration (ppmw)**  **Non-Detect? 3**  1. Complete the table below for each resin ty pe produced by the facility

during the 30 days of sampling. If the facility produced more than one resin ty pe during the 30 days, create multiple copies of this worksheet as necessary and complete one worksheet for each resin ty pe. Do**Note(s) Concentration**  **(ppmw) Non-Detect?**  **Note(s) 4**  **5 Concentration** 

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **6 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **7 8** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **9 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **10 11** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **12 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **13 14** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **15 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **16 17** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **18 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **19 20** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **21 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **22 23** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **24 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **25 26** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **27 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **28 29** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) 30** **FORM E-1-a**

**PROCESS WA STEWA**  **TER**

**Instructions**

2. Complete a row in Table 2 below for each PVC process wastewater stream that exits a PVC process wastewater treatment system (identified in Form B-3). 3. For each wastewater steam stripper identified in Table 2 of Form B-3, provide the requested information in Table 3 below. 4. In Table 5, please provide the source, flow rates, and the ID of the PVC process wastewater treatment system for each stream that enters a PVC process wastewater treatment sy stem but that does not originate from the PVC production facility

. 5. Refer to "Enclosure 1" for additional instructions and details.

**Table 1. Process Wastewater Streams Not Treated by a PVC Process Wastewater Treatment System 2** 

**PVC Process Wastewater Stream ID**  (W-x...ID should match those provided in the process flow diagram) 1. Complete a row in Table 1 below for each PVC process wastewater stream generated within the PVC production facility that exits a control device, a piece of recovery equipm ent, or process equipment and is not treated to reduce the concentration of viny l chloride or any other HAP before being discharged from the PVC production facility

.

**Name of PVC Process Wastewater Stream**

**1 Table 2. Process Wastewater Streams Exiting a PVC Process Wastewater Treatment System**  **1 2**  **3 4**  **5**

**Min Ma**  **x**

**Table 3. Wastewater Steam Strippers**

**1 2**  **3 4**  **5 6**  **7 8**  **9 10**  **11 12**  **13 14**  **15 16**  **17 18**  **19 20**  **21**

**Table 4. PVC Process Wastewater Destination Codes Table**
Onsite wastewater treatment system with biological treatment process

Equipm ent Currently

Regulated Under (cite regulations): Year Equipm ent Installed: Stripping Factor: Overall Calculated Tray Efficiency :

Colum n Height (meters): Number of Actual Trays: Flow configuration (countercurrent, cocurrent): Wa stewater Operating Feed Rate (liters/hr): Wa stewater Operating Feed Rate (lb/hr):

Operating Temperature (°F): Operating Pressure (psig): Total Number of Stages:

**1 Destination Description**  **PVC Process Wastewater**  **Treatment System ID**  **PVC Process Wastewater**  **Stream ID** (W-x...ID should match those provided in the process flow diagram) **Is this process wastewater**  **treatment system batch or continuous**  **operation? PVC Process Wastewater Stream Flow Rate (gallons**  **per day)**

PVC Process W astewater Treatment Equipment ID:

Wa stewater Maximum Design Feed Rate for Batch Strippers (liters) Wa stewater Maximum Design Feed Rate (liters/hr): Wa stewater Maximum Design Feed Rate (lb/hr):

Steam to Feed Ratio (kg steam/liter of wastewater): Steam Feed Rate (lb/hr): Feed Inlet Pressure (psia): Feed Temperature (°F): Wa stewater Operating Feed Rate for Batch Strippers (liters)Onsite wastewater treatment system without biological treatment process

Discharge without treatment by pipeline, sewer, or other convey ance to surface water Discharge to POTW , no treatment Discharge to PrOTW , no treatment Zero discharge or alternative disposal method Recy cle to process Other
**Table 5. Non-PVC Production Process Wastewater Streams Entering a PVC Process Wastewater Treatment System 2** 

**Min Process Wastewater Stream Flow Rate (gallons per day)**  **Source of Process Wastewater Stream**

**1**2. Complete a row in Table 2 below for each PVC process wastewater stream that exits a PVC process wastewater treatment system (identified in Form B-3). 3. For each wastewater steam stripper identified in Table 2 of Form B-3, provide the requested information in Table 3 below. 4. In Table 5, please provide the source, flow rates, and the ID of the PVC process wastewater treatment system for each stream that enters a PVC process wastewater treatment sy stem but that does not originate from the PVC production facility

.

**Table 1. Process Wastewater Streams Not Treated by a PVC Process Wastewater Treatment System 3**  **4 5**  **6 7** 

**Min Ma**  **x Av**  **erage** 1. Complete a row in Table 1 below for each PVC process wastewater stream generated within the PVC production facility that exits a control device, a piece of recovery equipm ent, or process equipment and is not treated to reduce the concentration of viny l chloride or any other HAP before being discharged from

**Operating Days Per Year**  **Flow Rate Determination**  **Me thod**  **PVC Process Wastewater Stream Flow Rate**

**(gallons per day) 6**  **7 8**  **9 10** 

**Av erage** 

**2 Code**  OSW WT -w-Biotrt **PVC Process Wastewater Stream Flow Rate (gallons Flow Rate**  **Determination Me**  **thod As**  **sociated Destination**  **Information** (Refer to Table 3 below) **Operating Days Per Year**  **PVC Process**

**Wastewater Stream**  **Destination Code**  (Refer to Table 4 below)OSW WT -w/o-Biotrt SW POTW RAW PrOTW RAW ZEROALT RECYC OTHER
**Table 5. Non-PVC Production Process Wastewater Streams Entering a PVC Process Wastewater Treatment System 3**  **4 5**  **6 7** 

**Ma x**  **Av erage**  **Flow Rate Determination**  **Me thod**  **PVC Process Wastewater Treatment**  **System ID Operating Days**  **Per Year Process Wastewater Stream Flow Rate (gallons per day)** 4. In Table 5, please provide the source, flow rates, and the ID of the PVC process wastewater treatment system for each stream that enters a PVC process wastewater treatment sy stem but that does not originate from the PVC production facility

.

**8 9**  1. Complete a row in Table 1 below for each PVC process wastewater stream generated within the PVC production facility that exits a control device, a piece of recovery equipm ent, or process equipment and is not treated to reduce the concentration of viny l chloride or any other HAP before being discharged from

**Ty pe of Originating**  **Equipment/Device Originating PVC Equipment/Device**  **ID 11** 

Provide nam e of the wastewater treatment system **3 Process Wastewater Destination Details to Provide in Column 12 of Table 1 and Column 11 of Table 2**  **Is this PVC process wastewater stream exposed to the atmosphere**  **at any point between the outlet of the PVC process wastewater**  **treatment system and its destination?** Provide nam e of the wastewater treatment system

Provide nam e of outfall Provide nam e of POTW Provide nam e of PrOTW Describe method Describe where in the process the stream is recy cled Describe**10 11**  1. Complete a row in Table 1 below for each PVC process wastewater stream generated within the PVC production facility that exits a control device, a piece of recovery equipm ent, or process equipment and is not treated to reduce the concentration of viny l chloride or any other HAP before being discharged from

**PVC Process Wastewater Stream Destination Code**  (Refer to Table 4 below) **As sociated Destination Information** **3 Process Wastewater Destination Details to Provide in Column 12 of Table 1 and Column 11 of Table 2** **12**

**Is this PVC process wastewater stream exposed to the atmosphere**  **at any point between the originating PVC process equipment**  **and its destination? FORM E-1-b** 

**MA INTENA**  **NCE WA STEWA**  **TER**
Is your facility subject to any Federal, State, local or other requirements to collect, store, treat, or otherwise handle maintenance wastewater? If "Yes," please provide the regulation citation or permit requirement as appropriate: (If you answered "No," please provide responses to the questions below). Provide a detailed description of the activities that create maintenance wastewater.

Procedures followed to collect, handle, manage, and treat maintenance wastewater? Include any further processing steps.

Is the maintenance wastewater exposed to the atmosphere at any point?

Describe procedure for controlling HAP emissions from the maintenance wastewater (if any):

Page 1 of 1 **DRA FT** PVC Section 114 Survey Part 2 06/23/2009**FORM E-2-a**

**30 DA Y PVC PROCESS WA** **STEWA TER SA**  **MP LING A**  **ND A NA**  **LYSIS DA TA** 

**Instructions** 1. Complete the table below for each PVC process wastewater steam exiting a process wastewater treatment system that was sampled and analyzed. Com plete one worksheet for each single stream (make copies of this worksheet if necessary ). 2. Enter the PVC process wastewater treatment system ID for the stream that was sampled and analyzed. The ID must match the IDs listed in Table 2 of Form 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, stream flow rate, basis for flow rate determination, stream temperature, sample ty pe, analysis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 4. Enter any

other HAP expected to be present (that are not listed in Table 10 to Subpart HHHHHHH of 40 CFR Part 63) in the table below. 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 6. Enter any

notes or additional information relevant to the sampling or analysis. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.
**PVC Process Wastewater Treatment System ID**

**CA S No.**  **HA P**  107211 Ethy lene gly col 67561 Methanol 75070 Acetaldehy de 50000 Formaldehy de 51285 2,4-dinitrophenol 98862 Acetophenone 117817 Bis(2-ethy lhexy l) phthalate (DEHP) 123319 Hy droquinone 108952 Phenol 79345 1,1,2,2-tetrachloroethane 106990 1,3-butadiene 540841 2,2,4-trimethy lpentane 71432 Benzene 108907 Chlorobenzene 67663 Chloroform 126998 Chloroprene 98828 Cumene 75003 Ethy l chloride (Chloroethane) 100414 Ethy lbenzene 107062 Ethy lene dichloride (1,2-Dichloroethane) 75343 Ethy lidene dichloride (1,1-Dichloroethane) 74873 Methy l chloride (Chloromethane) 75092 Methy lene chloride 110543 n-Hexane 108883 Toluene 71556 Methy l chloroform (1,1,1-Trichloroethane) **Stream Flow Rate Exiting the Treatment System (gallons per minute) --> Resin Type (suspension, dispersion, bulk, etc.) -->**  **If Other, Please Provide a Description of the Resin Type -->**79005 1,1,2-Trichloroethane 108054 Viny l acetate 593602 Viny l bromide 75014 Viny l chloride 75354 Viny lidene chloride (1,1-Dichloroethy lene) 1330207 Xy lenes (isomers and mixtures)**30 DA Y PVC PROCESS WA** **STEWA TER SA**  **MP LING A**  **ND A NA**  **LYSIS DA TA** 

1. Complete the table below for each PVC process wastewater steam exiting a process wastewater treatment system that was sampled and analyzed. Com plete one worksheet for each single stream (make copies of this worksheet if necessary ). 2. Enter the PVC process wastewater treatment system ID for the stream that was sampled and analyzed. The ID must match the IDs listed in Table 2 of Form 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, stream flow rate, basis for flow rate determination, stream temperature, sample ty pe, analysis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 4. Enter any

other HAP expected to be present (that are not listed in Table 10 to Subpart HHHHHHH of 40 CFR Part 63) in the table below. 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 6. Enter any

notes or additional information relevant to the sampling or analysis. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**An alysis M**  **ethod Concentration**  **(ppmw) Non-Detect?**  SW -846-8015C SW -846-8015C SW -846-8315A SW -846-8315A SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8270D SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B SW -846-8260B **Flow Rate Determination Method -->**

**Lab Sample ID --> Lab Report ID -->**  **An alysis Date -->**  **Stream Temperature (degrees F) --> Stream Flow Rate Exiting the Treatment System (gallons per minute) -->**  **Resin Type (suspension, dispersion, bulk, etc.) --> Sample Date -->**  **If Other, Please Provide a Description of the Resin Type -->**SW -846-8260B

SW -846-8260B SW -846-8260B EPA Method 107 SW -846-8260B SW -846-8260B1. Complete the table below for each PVC process wastewater steam exiting a process wastewater treatment system that was sampled and analyzed. Com plete one worksheet for each single stream (make copies of this worksheet if necessary ). 2. Enter the PVC process wastewater treatment system ID for the stream that was sampled and analyzed. The ID must match the IDs listed in Table 2 of Form B-3

. 3. Complete columns 1 through 30. Enter the sample date, resin ty pe, stream flow rate, basis for flow rate determination, stream temperature, sample ty pe, analysis date, lab report ID, and lab sample ID. Enter the concentration results for each HAP listed. 5. For compounds that were not detected, indicate as such in the "Non-Detect?" column and provide the method detection limit, in ppmw, in the "Concentration (ppmw)" column. 7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**Note(s) Concentration**  **(ppmw) Non-Detect?**  **Note(s) 1**  **2**7. Refer to Attachment B of Enclosure 1 "Summary of Test Procedures, Methods, and Reporting Requirements For Resin and Process W astewater Sampling and Analysis at Poly viny l Chloride and Copoly me r (PVC) Facilities" for additional instructions and information.

**Concentration (ppmw)**  **Non-Detect? Note(s)**  **Concentration (ppmw)**  **Non-Detect? 3** **Note(s) Concentration**  **(ppmw) Non-Detect?**  **Note(s) 4**  **5 Concentration** 

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **6 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **7 8** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **9 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **10 11** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **12 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **13 14** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **15 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **16 17** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **18 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **19 20** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **21 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **22 23** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **24 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **25 26** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) Concentration**  **(ppmw) Non-Detect?**  **27 Note(s)**  **Concentration (ppmw)**  **Non-Detect? Note(s)**  **29 28** **Concentration**

**(ppmw) Non-Detect?**  **Note(s) 30** **FORM E-2-b**

**30 DA Y PVC PRODUCTION PROCESS WA** **STEWA TER SA**  **MP LING PRODUCTION DA**  **TA**

**Instructions** 1. Please complete this worksheet for y our PVC production facility

. 2. For the complete time period covering y our PVC process wastewater treatment sy stem(s) sampling, provide the total resin production from y our PVC production facility

.
4. Refer to "Enclosure 1" for additional instructions and details.

1.) Sampling Start Date: 2.) Sampling End Date:

3). Total resin production from sampling start date to sampling end date and the ty pe of resin produced: 3.a.) Total Resin Produced: 3.b.) Resin Ty pe Produced: 3.c.) If Other, Specify :

4.a.) Total Resin Produced: 4.b.) Days of Production: 4.b.) Resin Ty pe Produced: 4.c.) If Other, Specify :
5.) Total DAILY maximum PVC production capacity : 3. If the process wastewater treatment system(s) is/are treating process wastewater that was generated by the PVC production facility PRIOR to the start of the sampling period, then also include the amount of resin produced during the period prior to the start of sampling and indicate how many days of production that represents.

4.) Total resin produced and number of day s of production prior to the start of the sampling period generated by

the process and treated during the sampling period :2. For the complete time period covering y our PVC process wastewater treatment sy stem(s) sampling, provide the total resin production from y our PVC production facility

.

and the ty pe of resin produced: pounds

pounds days

pounds per day

(max) 3. If the process wastewater treatment system(s) is/are treating process wastewater that was generated by the PVC production facility PRIOR to the start of the sampling period, then also include the amount of resin produced during the period prior to the start of sampling and indicate how many days of production that represents.

prior to the start of the sampling period and for which process wastewater was**FORM F-1 CONTROL DEVICES - ABSORBER** 

**Instructions** 1. Complete the form for each absorber used as a control device within the PVC production facility, or for any absorber that emits directly to atmosphere. 2. Refer to "Enclosure 1" for additional instructions and details.

**1** Type of Equipment or Device **2** Equipment of Device ID **3 Type of Absorber**  **4** If other, provide a description: **5** Gas inlet flow rate (dscfm): **6** Gas inlet temperature (°F): **7** Pressure drop (in H 2 O): **8** Liquid-to-gas ratio (gal/10 3 acfm): **Inlet scrubbing liquor 9**  Liquor used: **10** pH: **11** Percent solids: **12** Type of alkali added, if any: **13** Addition rate (lb/gal): **14** Wa stewater generation rate (gal/min): **15** Year Equipment Installed: **16** Equipment Currently Regulated Under (cite regulations):

Page 1 of 1 **DRAFT**PVC Section 114 Survey Part 1 06/23/2009**FORM F-2 CONTROL DEVICES - THERMAL OR CATALYTIC OXIDIZER** 

**1** Control Device ID: **2** Number of operating hours per year (hours/year): **3** Is this emergency equipment? **4 Type**  (Thermal Oxidizer or Catalytic Oxidizer) **5** Oxidizer Inlet Flow Rate (dscfm): **6** Average percentage of total flow originating from the production facility: **7** Combustion chamber temperature (°F): (please note if temperature me asurement is not in chamber) **8** Excess air (%): **9** Nominal residence time (s): **Heat recovery 10**  Recuperative, percent heat recovery **11** Regenerative, percent heat recovery **12** Design Capacity (Heat Input) (MMBtu/hr): **13** Fuel Basis for Design Capacity: **14** Heat Release Rate (Btu/scf): **15** Is the unit subject to NSPS? **16** If yes, indicate the year: **Start-up Fuel/Material 17**  Start-up fuel: **18** Number of start-ups per year: **19** Typical length of time for start-up (hours): **20** Higher heating value (HHV): **Fuels/Materials Combusted During Normal Operations (include solid, liquid, and gas waste streams) 21**  Fuel 1: **22** Hours used per year: **23** Higher heating value (HHV): **24** Fuel 2: **25** Hours used per year: **26** Higher heating value (HHV): **27** Fuel 3: **28** Hours used per year: **29** Higher heating value (HHV): **30** Fuel 4: **31** Hours used per year: **32** Higher heating value (HHV): **33** Fuel 5: **34** Hours used per year: **35** Higher heating value (HHV): **36** Year Equipment Installed: **37** Equipment Currently Regulated Under (cite regulations):

Page 1 of 1 **DRAFT** PVC Section 114 Surv ey Part 1 06/23/2009**FORM F-3 CONTROL DEVICES - CONDENSERS** 

**Instructions** 1. Complete the form for each condenser used as a control device within the PVC production facility, or for any condenser that emits directly to atmosphere. 2. Refer to "Enclosure 1" for additional instructions and details.

**1** Type of Equipment or Device **2** Equipment of Device ID **3 Type of Condenser**  **4** If other, provide a description: **5** Is the condenser refrigerated? **6** Describe the materials condensed:

**7** Describe the fate of the non-condensed gas stream:

**8** Describe the fate of the condensate outlet stream:
**9** Gas inlet flow rate (dscfm): **10** Gas inlet temperature ( ° F): **11** Gas outlet temperature ( ° F): **12** Liquid outlet for rate (gpm): **15** Year Equipment Installed: **16** Equipment Currently Regulated Under (cite regulations):

Page 1 of 1 **DRAFT** PVC Section 114 Survey Part 1 06/23/2009**FORM G**

**COOLING TOWERS A ND HEA**  **T EXCHA NGE SYSTEMS** 

**Instructions**

3. Refer to "Enclosure 1" for additional instructions and details.

**Table 1.a Cooling Tower Identification** Cooling Tower ID Total CT Return Flow Rate (gal/min): Number of processes served by cooling tower: Number of these from a PVC production process unit: Is the heat exchange system mo nitored for the presence of one or more HAP or VOC in the cooling water? **Table 1.b Cooling Tower Emission Reductions** For this cooling tower (if the single combined inlet line is monitored), OR for each heat exchange system from a PVC process unit (if individual CT return lines are monitored individually ), please provide the following:

(list sequentially

beginning with "H1") PVC HTEX System No.
Is the heat exchange system currently regulated? If Yes, cite the regulation(s): 1. Please complete one worksheet for each cooling tower, providing as much of the requested information as possible. Copy and paste additional worksheets for each cooling tower. 2. Using the table beginning on row 23, provide the requested information for the cooling tower. If only the single combined inlet line is monitored, you may delete rows 31 through 36 and enter information for the cooling tower. If cooling tower return lines are monitored individually , please provide information for each process. Identify the PVC process in column A. Copy and paste more rows to the table to add additional processes.[ADD MORE ROW S TO THIS TABLE FOR ADDITIONAL HTEX SYSTEMS FOR THIS COOLING TOW ER]**Table 2. Once-through Heat Exchange Systems**

for each heat exchange system from a PVC process unit (if individual CT return lines are monitored individually ), please provide the following:

**(gal/min)** (list speciation and/or group) (e.g., continuous, daily ,

weekly , monthly , y early , other) (e.g., visual

inspection, surrogate mo nitoring, water sampling, air stripping, other) (e.g., EPA

Method 601, EPA Method 624, Mod El Paso, etc.) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) CT Return Flow Rate for HTEX System List ALL Compounds Analy zed: Monitoring frequency Ty pe of mo nitoring Monitoring,

sampling, or air stripping analysis 1. Please complete one worksheet for each cooling tower, providing as much of the requested information as possible. Copy and paste additional worksheets for each cooling tower.

Does your PVC production facility use any once-through heat exchange systems? 2. Using the table beginning on row 23, provide the requested information for the cooling tower. If only the single combined inlet line is monitored, you may delete rows 31 through 36 and enter information for the cooling tower. If cooling tower return lines are monitored individually , please provide information for each process. Identify the PVC process in column A. Copy and[ADD MORE ROW S TO THIS TABLE FOR ADDITIONAL HTEX SYSTEMS FOR THIS COOLING TOW ER]for each heat exchange system from a PVC process unit (if individual CT return lines are monitored individually ), please provide the following:

Value Unit

(provide the num eric MDL) (provide the

MDL units) (CT inlet, outlet,

both) **(ppbw) (days)**  **(ppbw) (days)**  Em ission Reduction Measures

MDL Monitoring

Location Delay of Repair Threshold Repair Time for

Delay ed Repairs Leak Repair Threshold Repair Time for

Normal Leak Events**(#) (days)**  Total Duration of All Repairs Leaks in 2013 Number of Leaks in 2013**FORM H EQUIPMENT LEAKS** 

**Instructions** 1. Submit a copy of the leak detection and repair procedures for the PVC production facility and provide responses to the questions below. 2. Refer to "Enclosure 1" for additional instructions and details.
**Table 1. LDAR Program**

**Table 2. Equipment Counts**
**In Source Category**  **Subtotal of Equipment Associated**

**with Closed Vent System(s)** (Subset of count in source category)

In heavy liquid service In gas, vapor, and light liquid service Connectors

In heavy liquid service In gas, vapor, and light liquid service Agitators

In liquid service

In gas and vapor service Pressure Relief Devices

Open ended valves and lines Sampling connection systems Compressors Instrumentation systems Valves

In heavy liquid service

In light liquid service Pumps 40 CFR Part 61, Subpart V Other Federal LDAR Regulation Specify: State LDAR Regulation Specify: Provide the total cost to your facility for conducting the LDAR program at this process unit in 2013:

**Equipment**

In heavy liquid service In gas, vapor, and light liquid service Is there an equipment leak detection and repair (LDAR) program for all equipment at your facility included in the source category? If "No," how are equipment leaks detected and repaired?

If "Yes," is the equipment subject to the requirements of: 40 CFR Part 63, Subpart UU

Page 1 of 1 **DRAFT** PVC Section 114 Survey Part 1 06/23/2009**FORM J**

**OFF-SPECIFICATION RESIN AND MATERIAL REMOVAL FROM EQUIPMENT**
**Instructions** 1. Complete this form for 2013 only.

3. Provide copies of estimation worksheets and any other relevant documentation. 4. Complete this form for individual equipment, including equipment that is not assigned an equipment ID (e.g., in-line filters). 5. Refer to "Enclosure 1" for additional instructions and details.

**Table 1.** Source Equipment Type: Source Process Equipment ID (if applicable): Equipment Description: Total Pounds of Material Removed in 2013 ( do not include the contribution of water or other fluids(s) to remove the material from the equipment) :
Describe the procedure for removal of the material from equipment:
Is the material exposed to the atmosphere at any point during or after removal from the equipment?
Describe procedure for controlling HAP emissions from the material during and after removal from the equipment: Describe the fate/disposition of the material beginning from the time it is removed from the equipment. Include any further processing steps.

**Table 2.**

Minimum Maximum Average

(select HAP) 2. This form covers resin that is removed from equipment and is not processed further through the normal processing steps. Examples include, but are not limited to, off-specification resin removed from the polymerization reactor or any other downstream process equipment, resin removed from equipment during maintenance and cleanout operations, etc.

**Concentration in Resin or Resin Slurry Immediately**  **Prior to Removal From Equipment and Before Being Mixed With Other Materials or Fluids (ppmw)**  **Individual HAP Present Notes** 

Page 1 of 2 **DRA FT**  PVC Section 114 Survey Part 2 06/23/2009(select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP)

Page 2 of 2 **DRA FT**  PVC Section 114 Survey Part 2 06/23/2009**FORM K-1**

**TA NKS, VESSELS A**  **ND PORTA BLE CONTA**  **INERS USED FOR FEEDSTOCK STORA GE, PRODUCT STORA** **GE, VENT GA S STORA** **GE, HOLDING, A ND WA**  **STEWA TER** 
**Instructions** 1. Complete this form for 2013 only. 2. Provide copies of estimation worksheets and any other relevant documentation. 3. Complete this form for individual equipment, including equipment that is not assigned an equipment ID (e.g., portable containers). 4. Do not include gas holders on this form. Complete Form K-2 for gas holders. 4. Refer to "Enclosure 1" for additional instructions and details.

**Table 1.**

**Table 2. Vapor Pressure**  **Total Emissions** (in H2O) Minimum Maximum Average **(pounds)** (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) If Other, please specify, being as descriptive as possible: Source Process Equipment ID (if applicable): Equipment Description: If not provided in the equipment description above, describe the tank, vessel, or container and indicate (if applicable) if the tank is a fixed, floating internal, or floating external roof. Select the purpose of the equipment:

If Yes, How Are The Emissions Controlled?

**Concentration (ppmvd @ 3% O2)** How is the HAP Concentration Determined? Are HAP Emissions Controlled?

**Individual HA P Present**  Source Equipment Type:

Number of turnovers: Equipment volume (m 3 ):

**Notes** Storage Temperature (°F)

Page 1 of 1 **DRAFT** PVC Section 114 Survey Part 2 06/23/2009**FORM K-2**

**GA S HOLDERS** 
**Instructions** 1. Complete this form for 2013 only

. 2. Provide copies of estimation worksheets and any other relevant documentation. 3. Refer to "Enclosure 1" for additional instructions and details.

**Table 1.**

**Table 2.**
**Vapor Pressure Total Emissions**  (in H2O) **(pounds)** (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) (select HAP) Does your PVC production facility use gas holders: Indicate the number of gas holders in use at y our PVC production facility : Are HAP Emissions Controlled? If Y es, How Are The Emissions Controlled?

**Individual HA P Present**  **Notes**

Page 1 of 1 **DRA FT** PVC Section 114 Survey Part 2 06/23/2009**FORM L STARTUP, SHUTDOWN, AND MALFUNCTION** 
**Instructions** 1. Complete this form for 2013 only. 2. Submit with your response to this survey, copies of all records of emissions during periods of process startup, shutdown, and malfunctions for 2013 only. 3. Refer to "Enclosure 1" for additional instructions and details.

For a malfunction:

(select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) (select HAP) (pounds) **Total Emissions During Startup, Shutdown, or Malfunction Event**  We re all of the emissions control devices operating for the entire duration of the startup, shutdown, or malfunction event? Startup, Shutdown or Malfunction?

If startup or shutdown, what was the duration (hours):

Provide a short description of the malfunction and the circumstances:

If No, which control devices were not operating (Control Equipment ID), for how long, and why:

We re permitted emissions limits exceeded?

Provide a description of the procedures used to alert the owner/operator that the malfunction occurred. If the malfunction resulted in a release of emissions, describe any indicators used to signal and/or measure the release. Is there a written startup, shutdown and/or malfunction plan for the process unit? Provide a description of the systems and equipment in place that function to notify operators that a malfunction **is occurring**

.

Applicable standard or regulation: Describe what actions, if any, were taken to minimize emissions to the atmosphere:

Page 1 of 1 **DRAFT** PVC Section 114 Survey Part 1 06/23/2009**FORM M FACTORS THAT AFFECT HAP/VOC EMISSION REDUCTIONS** 

**Name of Unit Operation Description of process change or**  **other pollution prevention or source**

**reduction measure: Quantify emissions reductions (e.g. tons/year) resulting**  **from the use of pollution or source reduction measures:** For each unit operation for which pollution reduction or source reduction measures have resulted in a decrease in HAP/VOC emissions since 1976, provide the following information.

If recovery or recycling of feedstocks is used, quantify the effect of the program (e.g., estimated annual purchase of feedstock in the absence of recovery/recycling compared to actual annual purchase):

Are you aware of any alternative processes (e.g., feedstock substitutions or eliminations) or control devices or techniques that could result in fewer impacts between environmental media (water, air, and land) or reduced total release to all environmental media (e.g., reduced wastewater or solid waste)? Discuss whether these processes could be adapted to the polyvinyl chloride and copolymers production source category and any experience you have with them:

Page 1 of 1 **DRAFT** PVC Section 114 Survey Part 1 06/23/2009**FORM N**

**MISCELLA NEOUS** 
If any control or process change described on Form M was instituted as a result of new source review requirements pursuant to 40 CFR 51.160, Subpart I, Review of New Sources and Modifications, provide the date at which the lowest achievable emission rate (LAER) came into effect:

Describe any

factors not addressed in the questions in this survey that might serve to distinguish y our facility from others in this source category for purposes of developing a separate source category or subcategory

and MACT standards:

Page 1 of 1 **DRA FT** PVC Section 114 Survey Part 1 06/23/2009