Summary of Test Protocol

Section 114 PVC MACT Test

Lubrizol Advanced Materials, Inc.

The following is a summary of sampling and analytical methodology for the upcoming emission test at

Lubrizol in Louisville, KY planned for the week of September 15, 2014. The sampling and analysis

summary incorporates the requirements of US EPA’s Section 114 request and subsequent conversations

and emails with US EPA staff. The test will consist of triplicate runs. Due to the length of each run, a

single run will be performed each day of testing.

Methods 2, 3A, and 4

 Conducted simultaneously with other sampling trains during testing

 Method 2C will be used on a separate set of ports due to small stack size (less than 12 inches)

Method 18

 Continuously sample and analyze via direct interface while other organic HAPs are being

sampled and analyzed (minimum of 4 hours) for vinyl chloride, methane, organic HAPs listed in

Table 1.5 of the Section 114 request, and ethyl acrylate (additional HAP specific to Lubrizol)

 Exceptions are formaldehyde, methanol, and ethylene glycol via Method 312 as noted below

and previously discussed with Enthalpy

Method 26A

 Collect 2 cubic meters over 3 hours and analyze for hydrogen chloride and chlorine

Method 25A

 Conduct 30 days of sampling and analysis, including emission test period when organic HAPs are

being sampled and analyzed

 A dilution probe must be used due to high moisture content per emails between US EPA and

Metco

 For the 30

‐ day sampling period, determine moisture by saturation tables for a measured

temperature, analyze oxygen by Method 3A, and use a THC analyzer that speciates methane

Method 23

 Collect 6 cubic meters over 6 hours and analyze for dioxins and furans

 Use US EPA ALT

‐ 052 for the recovery procedure to eliminate methylene chlorideSW

‐ 846 Method 0031

 Collect samples in four sets of tubes at 40 minutes per set for each run and analyze for the

volatile HAPs in Table 1.3 of the Section 114 request

SW

‐ 846 Method 0010

 Collect 3 cubic meters over 4 hours and analyze for semivolatile HAPs in Table 1.4 of the Section

114 request

 All fractions will be analyzed (filter, rinses, XAD, condensate) per US EPA’s email to Enthalpy

 A Method 8270C or 8270D GC/MS SIM analytical finish will be used per emails between US EPA

and Enthalpy

Method 316

 Collect 1 cubic meter over 2 hours and analyze for water soluble HAPs

 Method 316 if the most appropriate method for following due to water solubility and likelihood

of entrained moisture:

o Formaldehyde

o Ethylene glycol

o Methanol

 Ethylene glycol will be analyzed via an analytical technique that derivitizes ethylene glycol to

achieve the best precision and accuracy and to achieve lowest possible detection limit

 Method 316 also used for acrylic acid and acrylamide (additional HAPs specific to Lubrizol)

An anticipated test run schedule is attached to show the expected sampling train choreography for each

test run. There are four isokinetic ports and four isokinetic trains for HAP sampling, each with a

different sampling time. The sampling has been choreographed so that all for trains will start the first

port together and all four will start the second port together. A separate set of ports will be used for a

separate velocity pitot per US EPA Method 2C, since the stack is less than 12 inches in diameter.

The attached schedule includes a representation of the expected emission profile, relative to a single

batch being stripped. This is only a representation to show how the HAP loading to the control device is

expected to relate to the sampling trains over time. The solid lines show periods sampling is occurring

for a given train.

The highest emissions from the process (i.e., highest loading to the control device) occur when a batch is

transferred from a reactor to a stripper. Lubrizol can transfer up to two batches simultaneously with

each transfer taking about 90 minutes and total stripping time typically taking about 6 hours per batch.

There are 5 strippers and it is expected that 5 batches will be required for a test run, with two batchesbeing transferred initially and subsequently at least one batch being transferred at any given time.

Under normal production, it would be uncommon to transfer 5 batches in a given 6

‐ hour period. There

will be a sixth batch available to be transferred if needed, depending on the timing of the first stripper

being available after the first batch has been stripped.80%100%120%140%160%180%200%M316(CHO/MeOH)M0031(VOC)M3A(O2/CO2)M18(VCM/CH4)M25A(THC)M1/2(Velocity) n Rate Relative to Single Batch

g Train Method (Parameter)FTOSTACKGASSAMPLINGSCHEDULEDuringWorst‐CaseProcessEmissions0%20%40%60%80%0 60 120 180 240 300 360 420 480M23(D/F)M0010(SVOC)M26A(HCl/Cl2)M316(CH2O/MeOH) HAP EmissioRunTime(minutes)

Samplin gProcessEmissionsProfileFTOStackGasSamplingPeriod