TECHNICAL MEMORANDUM 

TO: Jodi Howard, US EPA/OAQPS/SPPD/RCG 

FROM: Eastern Research Group, Inc.

DATE: February 8, 2012

SUBJECT: Updated Information Collection and Additional Data Received for the 

Polyvinyl Chloride and Copolymers (PVC) Production Source Category 

1.0 Introduction 

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act 

(CAA), is required to establish National Emissions Standards for Hazardous Air Pollutants 

(NESHAP) emitted from polyvinyl chloride and copolymer (PVC) production facilities. The 

complete set of air pollutants (HAP) is listed under CAA section 112(b). This memorandum 

describes the data collection and data preparation completed by EPA and ERG in an effort to 

develop NESHAP standards for the PVC production source category. This memorandum also 

describes additional data received by EPA during and after the public comment period for the 

May 20, 2011 proposed PVC production rule. Section 2.0 describes the data collection steps and 

Section 3.0 describes the data preparation and standardization completed in order to perform 

subsequent analyses. 

2.0 Data Collection 

To collect data on PVC production, EPA reviewed previously collected information, 

current literature, and data from the National Emissions Inventory (NEI). EPA also held several 

meetings with the PVC Industry and the primary industry trade group, the Vinyl Institute (VI). 

On August 21, 2009, EPA issued a section 114 survey and testing request to 9 companies 

operating an estimated 19 PVC production facilities in the U.S. A list of companies and 

corresponding facilities is presented in Table 2-1. 

Table 2-1: Companies/Facilities Issued a Section 114 Information Collection Request 

Company Facility 

The Dow Chemical Company 

Texas City, TX 

Plaquemine, LA 

Midland, MI 

Formosa Plastics Corporation 

Delaware City, DE 

Baton Rouge, LA 

Point Comfort, TX 

Georgia Gulf Corporation Aberdeen, MS 

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Company Facility 

Plaquemine, LA 

Occidental Chemical 

Corporation (OxyVinyls, LP 

Deer Park, TX 

Pasadena, TX 

Pedricktown, NJ 

PolyOne Specialty Resins 

Group 

Pedricktown, NJ 

Henry, IL 

Saint-Gobain Corporation 

North America CertainTeed 

Corporation 

Lake Charles, LA 

Shintech Incorporated 

Addis, LA 

Plaquemine, LA 

Westlake Chemical Company 

Calvert City, KY 

Geismar, LA 

Following the issue of the August 21 section 114 survey and testing request, the EPA 

learned that the Dow Plaquemine facility did not produce PVC, but instead supplied the Shintech 

Addis facility with raw materials. Dow also informed the EPA of the impending closure of the 

Texas City facility, operated by Union Carbide, a wholly owned subsidiary of Dow. Due to the 

impending closure, emissions testing and resin sampling, as described in this memo, were not 

performed at the Texas City facility. Discounting the Dow Plaquemine and Texas City facility, 

the EPA determined there are 17 PVC production facilities operating in the U.S. 

The August 21 section 114 survey and testing request required companies to complete an 

electronic based survey and conduct emissions testing and resin sampling. The survey was 

formatted as a series of Microsoft (MS) Excel worksheets and collected basic data on each 

facility such as location, contact information, and permitting information. The survey also 

collected process and control equipment information such as equipment type, flow rates, 

emission concentrations, and fuel types. The survey included specific sections such as 

wastewater, startup and shutdown, heat exchange systems, and feedstock unloading. The testing 

requirement included 2 parts: emissions testing and resin sampling. The EPA required facilities 

to perform testing on the inlet and outlet to at least one of the systems used to control emissions 

from PVC production. Facilities were required to dedicate the control system to the PVC 

production unit during testing since several of the facilities are co-located with processes that 

produce products and intermediates other than PVC. Each test consisted of 3, 4-hour runs, in 

accordance with the EPA test memorandum on testing requirements. Each facility tested only for 

those HAP which were known or suspected to be emitted from their process based on a review of 

the different resin types and grades manufactured by each facility. The following HAP were 

commonly tested: acetaldehyde (75-07-0), acetophenone (98-86-2), 1,3-butadiene (106-99-0), 

chlorine (7782-50-5), cumene (98-82-8), ethyl chloride (75-00-3), ethylene dichloride (107-06-

2), formaldehyde (50-00-0), hydrogen chloride (7647-01-0), methanol (67-56-1), methyl chloride 

(74-87-3), phenol (108-95-2), polychlorinated biphenyls (1336-36-3), poly-aromatic 

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hydrocarbons (both volatile and semi-volatile), vinyl acetate (108-05-4), vinyl bromide (593-60-

2), vinyl chloride (VC) (75-01-4), dioxins and furans (CDD/CDF), any other HAP contained in 

initiators or inhibitors used in the process, and total hydrocarbons (THC). In addition to the 

testing, the EPA requested process data concurrent with the duration of the emissions testing 

including continuous emissions monitoring system records, control equipment operating 

parameters, and fuel usage. 

The second testing requirement consisted of 30 days of resin sampling during which the 

emissions testing took place. The EPA required sampling of the PVC resin immediately 

following the resin slurry stripper(s) and the resin dryer(s). The EPA also requested 30 days of 

process data concurrent with the resin sampling such as resin stripper slurry flow rates and dryer 

throughput rates. 

Responses to the survey were due to the EPA by November 30, 2009. The testing section 

of the response was due by February 28th, 2010. 

On March 16, 2011, the EPA issued a section 114 survey and testing request to vinyl 

chloride monomer (VCM) and ethylene dichloride (EDC) manufacturing facilities, some of 

which are co-located with PVC production facilities. The March 16 section 114 testing request 

required VCM/EDC facilities to conduct process vent testing for VC, CDD/CDF and THC. The 

EPA requested that facilities conduct testing under normal operating conditions (i.e., including 

any normally controlled process vent streams). Process vent emissions data were collected from 

3 facilities co-located with PVC production facilities (Formosa Point Comfort, OxyVinyls Deer 

Park and Shintech Plaquemine). 

In a letter dated July 12, 2011, the VI submitted additional information on how each 

facility’s control system was configured for testing in response to the August 21 section 114 by 

indicating whether they were typically co-controlled non-PVC streams such as EDC/VCM. The 

VI also provided clarification of the conditions (e.g., percentage contribution of the PVC process 

to the total process vent stream) during stack testing conducted in response to the August 21, 

2009 section 114 testing request. 

On August 2, 2011, the VI also submitted approximately one year of VC concentration 

data at the outlet of the wastewater strippers for 9 PVC production facilities. All concentrations 

were obtained using EPA Method 107. The data were provided on a varying basis across 

facilities (e.g., daily, weekly, monthly). On that same date, the VI submitted four years worth of 

residual VC stripped resin measurements for 13 suspension, 3 dispersion, 1 suspension blending 

and 1 copolymer resin producing facilities. The August 2 stripped resin data set represents daily 

VC concentration data from year 2007 to 2010, determined by EPA Method 107 as part of 

compliance with 40 CFR Part 61, subpart F. 

On September 16, 2011, PolyOne Henry submitted new VC and total non-vinyl chloride 

organic HAP (total non-VC organic HAP) data for suspension blending resin as a result of 

additional sampling and testing performed by the facility independently of the original August 

12, 2009 section 114 testing request. 
On September 21, 2011, the EPA received supplemental information from Shintech Inc., 

regarding gasholders in use at their PVC production facilities. This information included 

estimated emissions, emission reductions and costs of the applicable work practices. The VI also 

provided similar data regarding the number of gasholders in operations, estimated emissions, and 

costs and emissions reductions of applicable work practices for the entire PVC industry in their 

September 22, 2011 submission. 

3.0 Data Processing and Standardization 

The survey responses, emissions testing results, and resin sampling results were 

standardized before performing technical analyses. Sections 3.1 and Section 3.2 contain 

descriptions of the data preparation and standardization steps. 

3.1 Survey Data

The ICR survey was originally formatted as a series of MS Excel spreadsheets designed 

to be imported into a MS Access database. Two sets of survey files were combined before 

analysis. The first set of surveys consisted of the original November 30th, 2009 facility 

submissions. The second set of survey files contained declassified confidential business 

information (CBI) provided by the EPA. Data originally claimed as CBI were declassified by the 

EPA for the following facilities: 

o Formosa – Baton Rouge 

o Formosa – Delaware City 

o Formosa – Point Comfort 

o Georgia Gulf – Aberdeen 

o Georgia Gulf – Plaquemine 

o Shintech – Addis 

o Shintech – Freeport 

o Shintech – Plaquemine 

Five facilities completed their survey response using a previous version of the survey 

template. The survey submissions were copied, archived, and reformatted to properly import 

into the MS Access database. The following facilities used a previous version of the survey 

template: 

o Georgia Gulf – Aberdeen 

o Georgia Gulf – Plaquemine 

o OxyVinyls – Deer Park 

o OxyVinyls – Pasadena 

o PolyOne – Pedricktown 

The structures of certain forms were also corrected due to modification by facilities. 

Data contained in the forms requiring correction were not altered. The following forms, listed by 

facility, required correction: 

o OxyVinyls – Pasadena: C-1-a, K-3-a, K-3-b 

o Shintech – Freeport: K-1-b 

4
o Georgia Gulf Chemicals – Plaquemine: C-1-a, C-2-a, C-2-c, D, K-1-a 

o Georgia Gulf Chemicals – Aberdeen: C-1-a 

 The corrected forms were imported into a MS Access database.1 Quality assurance and 

quality control (QA/QC) checks were performed to ensure the data in each MS Excel form were 

correctly imported into the Access database. Errors identified as a result of the QA/QC effort 

were addressed in subsequent iterations of the database. 

Limited amounts of data were modified to improve presentation and analysis. Data were 

only modified if the intention of the facility was directly obvious. Company and facility names, 

along with corresponding information were standardized in Forms A-1 and A-2. Units of 

latitude and longitude were also standardized. The standardized information was propagated 

throughout the database. Records contained in table Form_C2A were also modified. The extent 

of the modifications included, for example, separation of records containing multiple pieces of 

equipment and/or emission points in one field. Records from the following facilities were 

separated in table Form_C2A: 

o Formosa – Baton Rouge 

o Formosa – Point Comfort 

Five administrative tables were created in conjunction with the Section 114 survey form 

tables in the Access database. Two tables provide standardized process and control equipment 

descriptions while the 3 remaining tables provide a cross-walk between the MS Excel survey to 

MS Access field names, descriptions of the survey form tables, and a list of HAP and 

corresponding Chemical Abstract Service (CAS) number. 

3.2 Emissions Test Data

The emissions testing data were originally formatted as a series of MS Excel workbooks. 

Each facility submission was compiled into a single workbook2 and quality assured by 

comparing the compilation with the original facility submission. 

Several corrections and clarifications were made to the compiled MS Excel work book in 

preparation of data analysis. Blank and duplicate records were removed. Process unit 

identifiers, resin grades, equipment identifiers, and dates were standardized to the format 

requested by the EPA. Control equipment gas flow rates were standardized to units of dry 

standard cubic meters per minute and gas temperatures reported as Fahrenheit (°F) were 

converted to Celsius (°C). Facilities that reported flow rate data with incorrect units were 

identified since such data resulted in unnecessary and erroneous unit conversion. Gas flow rate 

units were corrected by comparing the facility submitted emissions testing template to the stack 

test report, if the report was available. The compound names that were reported were compared 

with reported CAS numbers. Multiple incorrect CAS number and compound name combinations 

were identified. The combinations were corrected based on facility input when available. If no 

facility guidance was provided, the CAS number was standardized based on the facility 

submitted compound name and CAS numbers from the year 2005 National Emissions Inventory 

and the National Institute of Standards and Technology Chemistry WebBook.3 

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Facilities reported several HAP concentrations as non-detect (ND) values by using the 

“less than” (<) symbol. The notation was removed and an indicator column was added to the 

data set to note which values were reported as ND. 

Several facilities also reported multiple emissions concentrations for a single HAP. 

Facilities reported multiple concentrations due to overlap of applicable HAP for each emission 

test. Therefore; a single concentration result was selected based on the criteria presented in 

Table 3-1. 

Table 3-1: Criteria for Selecting Emissions Testing Result

Methods Used to Report Compound Result Selection Criteria 

Method 0031 & Method 0010 Method resulting in higher 

concentration 

Method 320 and Method 0031 Method 0031 

Method 23/23A & Method 0031 Method 0031 

Method 320 & Method 0010 Method 0010 

Method 26A & Method 320 > 1 ppm; Method 26A 

< 1ppm; Method 320 

ppm – parts per million 

Mass concentration data were converted to volumetric concentration (parts per million, 

dry volume (ppmvd)) corrected to 3 percent oxygen using Equation 1. 

6

3

2 6

10

1000L 

 1m

 1mol

22.4dsL

MW g

mol

10 μg

g 1

dscm

μg

ppmvd@3% O = × × × × × (Eq. 1)

Equation 2 was used to convert nanograms per dry standard cubic meter (ng/dscm) at 3 

percent oxygen to ppmvd corrected to 3 percent oxygen. 

6

3

2 6

10

1000L 

 1m

 1mol

22.4dsL

MW g

mol

10 μg

g 1

1000ng 

 1μg

dscm

ng ppmvd@3% O = × × × × × × (Eq. 2)

 Chlorinated dibenzodioxin and chlorinated dibenzofuran (CDD/CDF) concentrations 

were standardized to ng/dscm corrected to 3 percent oxygen. CDD/CDF concentrations were 

converted to a toxic equivalency basis (TEQ) using year 2005 World Health Organization ReEvaluation of Human and Mammalian Toxic Equivalency Factors for Dioxins and Dioxin like 

Compounds.4 Concentrations for all HAP were also converted to mass flow rates using Equation 

3. 

hr

60 min MW V

385.3ft

lb1 mol

0.028m

ft1

20.9 3

20.9 O

10

1

C

hr

lb

3 3 i

3

2

i 6

× × × × ×

−

−

= × × &

 (Eq. 3)

where: 

6
 lb/hr = mass flow rate in pounds per hour, 

Ci = pollutant concentration in ppmvd at 3 percent oxygen, 

 O2 = average oxygen concentration of all pollutant three run tests, 

 385.3 ft3 = volume, in cubic feet, of 1 pound mole of ideal gas at 20 °C 

(68 °F) and 1 atmosphere of pressure, 

MWi = molecular weight of the pollutant in pounds per pound mole, and 

V& = volumetric flow rate of the exhaust gas in dry standard cubic meters per 

minute. 

The above corrections and standardizations represent the extent to which the emissions 

testing data set was modified. 

3.3 Resin Sampling Data

The resin sampling results were reported by each facility in a MS Excel spreadsheet 

template provided by the EPA. A total of 15 facilities reported results from resin sampling and 

reported those results in the requested spreadsheet template. Data were submitted to the EPA 

beginning in late February 2010 and continuing through early August 2010. The resin sampling 

results were reported as pollutant mass values for each day of sampling that was conducted at the 

outlet of the resin stripper(s). Three facilities reported their resin sampling results in terms of 

concentrations. CertainTeed – Lake Charles did not provide resin sampling results, and Dow – 

Midland provided resin sampling data in lieu of completing the requested templates. Each 

facility submission was compiled into a single master file. QA/QC was performed by comparing 

the master compilation with the original facility submissions. 

Data in the master MS Excel workbook were standardized and corrected in preparation of 

data analysis. Blank and duplicate records were identified and removed. Process unit identifiers, 

resin grades, equipment identifiers, production rates, moisture contents, and dates were 

standardized to the format requested by the EPA. The compound names reported by the facilities 

were compared with reported CAS numbers and several incorrect CAS number and compound 

name combinations were identified. Combinations were corrected based on facility input when 

available. If no facility guidance was provided, CAS numbers were corrected based on the 

facility submitted compound name using standard CAS numbers from the 2005 National 

Emissions Inventory and the National Institute of Standards and Technology Chemistry 

WebBook.3 

Several tasks were completed to prepare the emissions testing data set for analysis. Facilities 

reported several HAP mass values as below detection limit or non-detect values by using the 

“less than” (<) symbol or brackets (“[ ]”) as requested. The symbol was removed and an 

indicator column was added to note which values were reported as below detection limit or as 

ND. Pollutant results that were already reported as concentrations (micrograms per liter (ug/L) or 

micrograms per kilogram (ug/kg),) were converted to parts per million (ppm) assuming a density 

of 1 gram per milliliter (g/ml) for the resin. 

On September 9, 2010, the VI submitted a spreadsheet of the resin sampling results for all 

facilities as a supplemental data submission to the EPA. The results in the VI-supplied data were 

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reported as concentration values for each pollutant, and not as the calculated or corrected mass 

values requested by the Agency. No standardization or corrections were made to this data set. A 

revised data set was submitted to the EPA by the VI on September 28, 2010. Additionally, on 

August 2, 2011, the VI submitted an updated 30-day resin sampling concentration database for 

total non-VC organic HAP providing additional specific on resin types and corrections to 

previously submitted data. Specifically, vinyl acetate copolymer (VACO) and suspension 

blending data were separated from dispersion and suspension data, respectively. Results that 

were previously reported as composites of two or more resin types were identified by resin type, 

and previous results from OxyVinyls suspension plants indicated as a reporting limit were 

changed to ND. Vinylidene/vinyl chloride copolymer concentration data from Dow Chemical 

were also added to the database. 

 

 

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4.0 References 

1. Facility Information Collection Request Survey Database for the Polyvinyl Chloride 

Production Source Category. Docket ID EPA-HQ-OAR-2002-0037. 

2. Emissions Testing and Resin Sampling Workbook for the Polyvinyl Chloride Production 

Source Category. Docket ID EPA-HQ-OAR-2002-0037. 

3. National Institute of Standards and Technology Chemistry WebBook, Standard Reference 

Database Number 69. http://webbook.nist.gov/chemistry/

4. 2005 World Health Organization Re-Evaluation of Human and Mammalian Toxic 

Equivalency Factors for Dioxins and Dioxin Like Compounds 

http://www.who.int/ipcs/assessment/tef_update/en/

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