1737 King Street, Suite 390 ● Alexandria, VA 22314 ●(571) 970

- 3359 ● Fax (571) 970

- 3271 www.vinylinfo.org ● www.vinylindesign.com 

### June 13, 2014

Sent via E lectronic M ail and Fed E x

M s

. Jodi Howard Refining and Chemicals Group U.S. EPA

- Office of Air Quality Planning and Standards 109 T.W. Alexander Drive Mail Code: E143

- 01 Research Triangle Park, NC 27 711 Howard.Jodi @ epa.gov

RE: Polyvinyl Chloride and Copolymers Facilities Section 114 Sampling and Analysis, and Information Request for Process Vents

Dear Ms. Howard :

This letter presents, on behalf of the Vinyl Institute PVC MACT Process Vent Subg roup , 1 

### several questions concerning the Agency’s May 1 5 , 2014 Clean Air Act S ection 114 Information Collection Request (“the § 114 Request”) , which was issued to the Subgroup members

. The § 114 R equest follows the Agency ’s grant of several petitions to reconsid er certain aspects of the National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production; Final Rule
, 77 Fed. Reg. 22,848 (April 17, 2012).

The § 114 Request requires sampling and analysis of process vent emiss ions from, as well as the submission of other process, operation, and facility information regarding certain facilities owned by the Subgroup members

. The enclosed questions seek clarification on t he following documents, collectively re ferred to as t he § 1 14 Request :

• “ MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST ”, Enclosure 1, May 1 5 , 2014 ;

• “2014 PVC 114 Process Vent Workbook” , May 15, 2014

.

1 The PVC MACT Process Vent Subgroup includes Vinyl Institute members Formosa Plastics Corporation, U.S.A.
, Wacker Chemical Corporation, Lubrizol Corporation, Shintech Corporation, Oxy Vinyls, LP, and Westlake Chemicals Company

.VI PVC MACT Subgroup Questions on S114 Request for Process Vents

Page 2 of 3 The Vinyl Institute, 1737 King Street, Suite 390, Alexandr ia, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com 

### The Vinyl Institute and its PVC MACT Process Vent Subg rou p appreciate EPA’s efforts to address our various questions and comments on t he § 114 Request for Process Vents

. As some Subgroup m embers are preparing for their process vent testing
, a prompt reply to this inquiry would be appreciated

. Please do not hesi tate to contact me with any questions.

S incerely,

Richard P. Krock Technical Director
e
- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 571

- 216

- 4474

CC: 

### Ms. Penny Lassiter , EPA

- RTP M r

. Andrew Bouchard , EPA

- RTP Mr. Mark Kataoka , EPA

- OCG JC Wal ker, Keller and Heckman Vinyl Institute PVC MACT Copolymers Subg roup

Attachments:

Attachment 1 : “ Questions on EPA S114 Request for PVC Production Facilit y Process Vents , Submitted by Vinyl Institute PVC MACT Process Vent Subgroup

.VI PVC MACT Subgroup Questions on S114 Request for Process Vents

Page 3 of 3 The Vinyl Institute, 1737 King Street, Suite 390, Alexandr ia, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com Attachment 1 Questions on EPA S114 Request for PVC Production Facilit y Process Vents , Submitted by Vinyl Institute PVC MACT Process Vent Subgroup

Location VI Process Vent Subgroup Question

Process Vent Workbook, Form Instructions Instructions at the top of sever al forms have confusing references to forms not in the workbook. For example , instructions at the top of Form B

- 4 refer to
Form B

- 3 which is not in the workbook. Other Subgroup Members have instructions at the top of B

- 1 that reference Form G and Form E

- 1 which are also not in their workbook. Can EPA clarify the instructions when referenced Forms are not in a particular workbook ?

Process Vent Workbook, Form K

- 1, and Enclosure 1, page
11 The Subgroup assumes the extent of the inventory requested is conta ined in the PVC PU. Can EPA confirm that this understanding is correct? Specifically is wastewater treatment outside of the PVC PU to be included?

Process Vent Workbook, Form L, and Enclosure 1, pages 11 & 12 Is the information being requested specific t o a potential Startup, Shutdown, or Malfunction ( SSM ) event at the process vent control device or is EPA asking for information with respect to every potential SSM event facility wide?

Since PVC and copolymers are made in batch reactors, can EPA clarify that start up and shutdown specifically does not include startup and shutdown of normal batch reactor operations? This is specifically excluded in the MON.

Process Vent Workbook, Form Q, and Enclosure 1, page
12 (or pg. 3 for No Survey recipients) (1) Pl ease confirm that the Subgroup should define resin type in accordance with PVC MACT definitions and identify the comonomer used. (2) For copolymers, it is the intention of the Subgroup to include comonomers along with the resin type so that the Agency und erstands the uniqueness of each manufacturer’s operations. (3) The convention for PVC Grade given as an example in column H is typically for suspension type resins. Please confirm that the convention given as an example refers to these resin molecular we ight
range designations :

LMW : Low Molecular Weight
, GP: General Purpose
, HMW: High Molecular Weight