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|Richard Krock <rkrock@vinylinfo.org> 

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|Jodi Howard/RTP/USEPA/US@EPA 

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| Date: |

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|08/26/2009 04:40 PM 

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|VI Questions on EPA PVC MACT Testing Requirements 

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Jodi,

As we discussed today, a number of Vinyl Institute (VI) member companies

have begun to examine the documents relating to the PVC MACT 114

information request. Per your request, I am submitting the first round

of questions in writing fielded from Vinyl Institute members regarding

testing requirements that I brought up today so that you can respond in

writing after discussing the questions with your colleagues. The VI

Health, Safety and Environmental committee is scheduled to review all

the 114 request documents for the PVC MACT via conference call on

September 2, 2009 after which I expect more questions will be

submitted to you. Your offer to conduct a webinar to go over the entire

request in detail with the PVC manufacturers is welcome, and we will let

you know after our September 2 call when we would like to schedule it.

I will instruct the VI members to submit questions specific to their

operation directly to you in writing via your e-mail address. The

questions we discussed today are listed below along with my notes:

1. Re: Enclosure 1, Attachment B, Section 1.3 – Is it

intended that 30 day CO/THC/CH4 monitoring will be conducted on

the resin dryer and its ancillary equipment? You will check with

others in your organization to clarify if the dryer system will

indeed be monitored or (as stated in Section 1.2) if mass balance

of the resin immediately after the stripper to after the dryers to

estimate emissions may be all that is required for this section of

the operation.

2. Re: Enclosure 1, Attachment B, Section 1.3 – Is the

30-day period to be operating days or calendar days? Your

requirement is 30 operating days.

3. Re: Enclosure 1, Attachment B, Section 1.2 – Can you

clarify what is meant by “integrated samples” in reference to the

4 grab samples used for the dryer mass balance? You agreed to

further research this and clarify more specifically what is
required.

4. Re: Enclosure 1, Attachment B, Section 1.2 – Section 1.2

begins with “Testing should be conducted on both the inlet and the

outlet to at least one of the control systems ....”. Is it

acceptable to test only one of several control systems such as

thermal oxidizers and scrubbers? Your understanding is that as

long as the control systems are configured similarly and in

similar service, then only one needs to be tested. Standby units

do not need to be tested but they should be included in the survey

portion.

5. Re: Enclosure 1, Attachment B, Table 1.3 – One member’s

thermal oxidizer outlet duct is too short to meet the criteria

outlined in the test method for sampling, and because it is

refractory brick lined, adding a sample port may disrupt its

integrity and create a safety hazard from HCl corrosion and

leakage at the point of sampling . The member believes it can

sample other safer and more accessible locations and estimate the

mass balance between the thermal oxidizer and the scrubber. You

believe this falls into the category of alternative testing

methods and the member should submit detailed drawings and

explicit alternative sampling protocol including mass balance

method for your review and comment. However, you will also review

this with your colleagues more versed in testing.

The opportunity to clarify the information request is highly

appreciated. I look forward to receiving your clarification as needed

on the above questions.

*Please note our new contact information*

Richard Krock

Technical Director

The Vinyl Institute

1737 King Street Suite 390

Alexandria, VA 22314

Direct: 571.970.3392

Mobile: 571.216.4474

Fax: 571.970.3271

Email: rkrock@vinylinfo.org

http://www.vinylinfo.org

http://www.vinylindesign.com

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