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 Electronic Mail and FedEx 

Ms. 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 27711

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

Subgroup,

1 several questions concerning the Agency’s May 15, 2014 Clean Air Act 

Section 114 Information Collection Request (“the § 114 Request”), which was issued to

the Subgroup members. The § 114 Request follows the Agency’s grant of several 

petitions to reconsider certain aspects of the National Emission Standards for 

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

77 Fed. Reg. 22,848 (April 17, 2012). 

The § 114 Request requires sampling and analysis of process vent emissions 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 the following documents, collectively referred to as the § 114 Request:

• “MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION COLLECTION REQUEST”, Enclosure 1, 

May 15, 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, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

The Vinyl Institute and its PVC MACT Process Vent Subgroup appreciate EPA’s efforts

to address our various questions and comments on the § 114 Request for Process 

Vents. As some Subgroup members are preparing for their process vent testing, a 

prompt reply to this inquiry would be appreciated.

Please do not hesitate to contact me with any questions. 

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

phone: 571-970-3392

cell: 571-216-4474

CC: Ms. Penny Lassiter, EPA-RTP

Mr. Andrew Bouchard, EPA-RTP

Mr. Mark Kataoka, EPA-OCG

JC Walker, Keller and Heckman

Vinyl Institute PVC MACT Copolymers Subgroup

Attachments:

Attachment 1: “Questions on EPA S114 Request for PVC Production Facility 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, Alexandria, 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 Facility 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 several 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-1which 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 contained 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 to 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) Please 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 understands 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 weight 

range designations: 

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

Weight