From:	Barry_H._Christensen@oxy.com
Sent:	Thursday, April 10, 2014 12:35 PM
To:	Barry_H._Christensen@oxy.com
Subject:	FW: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1
Attachments:	DPPlanCoverPVC MACT 110909.pdf; OxyVinyls Deer Park Test Plan.pdf; 
OxyVinyls_ LaPorte VCM_ ThermOxidizer200806Test Report.pdf



-----Original Message-----
From: Christensen, Barry H.
Sent: Friday, February 07, 2014 11:14 AM
To: 'Howard.Jodi@epamail.epa.gov'
Cc: Pryor, Jadie L.; Strain, Deanna K; Krishna, Chris
Subject: RE: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1

Jodie,

In our conversation on Wednesday you indicated you lacked data for some of the 
facilities controlling combined PVC plant and other vent gas streams. In one 
of our prior meetings, we indicated 2008 HCL/Cl2 test data submitted with our 
original test plan for our Deer Park/LaPorte location may have been over 
looked. You also mentioned that you have a new Email system and some of your 
prior Emails may not have transferred properly.

Enclosed is the original stack test plan for our Deer Park PVC plant which 
sends vent gas to our LaPorte EDC/VCM plant. It contains a summary of prior 
June 2008  HCL/CL2 test data (page 6-1) that was approved by EPA to be used in 
lieu of additional 2009/2010
HCL/CL2 testing.

As indicated below, a copy of the actual 2008 test report was provided on CD 
which was submitted to your office separately. The purpose of our 2008 testing 
was to demonstrate compliance with our TCEQ permit limit after rebuilding our 
scrubbers. For convenience, I added a copy of our 2008 test report to this 
mail.

You also had inquired about estimated costs for some additional stack testing 
which I have not yet been able to assemble.

If you have questions, please contact me.


Barry Christensen
Mgr Air Quality
Occidental Chemical Corp.

972-404-3209
-----Original Message-----
From: Christensen, Barry H.
Sent: Monday, November 09, 2009 3:55 PM
To: 'CCG-PVC@epa.gov'
Cc: Shirey, Michael E.; Pryor, Jadie L.; 'Howard.Jodi@epamail.epa.gov'
Subject: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1

Directed to Ms Jodi Howard,

in accordance with your request below and your original 9/21/09 CAA
114 letter, we are submitting plans pertain to our Deer Park site which 
operates a PVC manufacturing plant and which qualifies as an area source.

Enclosed are the following:

1) DP PVC Stack test and Misc. Fugitive Source Plan (w/o Appendices, which are 
being sent by FedEx).

2) Deer Park PVC plant Resin Sampling Plan

Due to the size of the files, they are split into two Emails.
This Email has the cover letter and Test Plan w/o appendices.
The second Email has the Stack test QAPP and the resin sampling plan.

These documents are also being sent, along with a CD with the appendices, by 
Fed Ex. They contain no confidential information.

Should you have questions or wish to discuss, pls contact me at 972-404-3209.



Barry Christensen
Mgr Air Quality
Occidental Chemical Corp.

972-404-3209

-----Original Message-----
From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov]
Sent: Tuesday, October 20, 2009 12:44 PM
To: Christensen, Barry H.
Cc: Kataoka.Mark@epamail.epa.gov; Mia.Marcia@epamail.epa.gov; 
Mcalister.Gary@epamail.epa.gov; Gibbs.Jennifer@epamail.epa.gov
Subject: OxyVinyl (Deer Park, TX) 114 Survey Extension Request


Barry,

In your October 8, 2009 letter, you requested that the OxyVinyl Deer Park 
facility be granted a 45 day extension "to  collect the required
information and submit the survey response."   We will not be granting
your request for a 45 day extension for the Deer Park facility's 114 PVC 
survey  response.  The survey is due on November 30, 2009.  However, we are 
granting you an additional three weeks to submit your PVC test plan for the 
Deer Park facility.  The test plan is due to EPA by November 10, 2009.

As we previously discussed, you may request that existing stack test data be 
considered in lieu of testing.  With this request, you must indicate which 
parameters you wish to use existing test data for and specify the methods that 
were used.  You must also submit test reports and any other documentation to 
support your request.

Attached to this email, is an example of EPA using area source emissions data 
to develop a major source NESHAP.  The attachment is the final Brick and Clay 
Products NESHAP preamble [68 FR 26690, 26697-98 (May 16, 2003)], which 
contains a discussion of the issue.


Thanks.

Jodi
************************************************************
Jodi Howard, Environmental Engineer
U.S. EPA - Office of Air Quality Planning and Standards Sector Policies and 
Program Divisions Coatings and Chemicals Group Mail Code:  E143-01 Research 
Triangle Park, NC 27711
Phone:  919-541-4607                Fax:  919-541-0246





(See attached file: Brick FRN 05162003.pdf)