Page 1 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

- 3359 ● Fax (571) 970

- 3271 www.vinylinfo.org ● www.vinylindesign.com September 2 1 , 2009

Ms. Jodi Howard 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

RE: PVC MACT Testing Request Pursuant to Section 114 Letter, Vinyl Institute Working Group

Dear Ms. Howard,

Members of The Vinyl Institute’s Working Group on PVC MACT Testing Requirements

met t his week to review the testing, methods, and timing requirements of the U.S.
Environmenta l Protection Agency (EPA) information collection request sent to the respective PVC manufacturing companies pursuant to 42 U.S.C § 7414 (hereinafter, “114 Request”)

. In responding to the 114 Request, the industry’s guiding principle and objective will con tinue to be to develop and submit meaningful and accurate data in accordance with the dates specified in the 114 Request that the EPA can use to develop a maximum achievable control technology (“MACT”) standard for the polyvinyl chloride (“PVC”) industry ( hereinafter “PVC MACT”).

In order t o meet this objective, however, or the test related submission deadlines prescribed in the 114 Request

, the PVC industry and EPA must come to a quick
resolution on the following issues : (1) a number of questions that have previously been submitted to the Agency; and (2) the issues and proposals submitted herein. We are submitting the following requests for clarification and proposed approaches in advance of our September 28 meeting at your RTP, NC office to inform our forthcoming discussions, and in the hopes of expediting the Agency’s careful consideration ahead of the October 9 sampling plan submission deadline:Page 2 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

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- 3271 www.vinylinfo.org ● www.vinylindesign.com 1) It would be very helpful for the EPA to review and restate its rationale for testing and to set forth the expected levels of detection for the pollutants of
interest for the required stack testing.

a) Understanding the intent for the collection of numerous samples at various points in the process would help the PVC industry complete the stack sampling and
testin g program in a manner that meets the EPA’s expectations for the sampling requirements. Furthermore, this information could lead to the identification of alternative sampling activities that would fulfill A gency requirements.

b) As the test methods indicated in the 114 Request are examined by testing companies, questions consistently are arising about the levels of detection required by the Agency . A summary of the levels of detection for each pollutant
of interest would help ensure that the stack testing com panies use the correct sampling and analytical equipment and procedures.

2) We have reviewed the physical configuration s of our thermal oxidizers an d

s ampling between the thermal oxidizer outlet and acid recovery /

scrubber inlet is not possible in the allotted time frame . The PVC industry proposes an alternative plan.

a) Physical constraints prevent successful and safe sampling of this stream at this
location.

i) Because of the short distances in the installed units between the thermal
oxidizer and the scrubber syst ems , there is not sufficient room to install a flow metering device and measure accurate flow rates according to standardized testing methods. Any flow measurement under these constraints could produce erroneous volumetric measurements and hence inaccurat e mass flow rates.

ii) Even if a sufficient pipe run did exist, no sample ports currently exist in the industry equipment configurations at the required sampling location. Because of the high temperature nature of this stream (>1,000 °F) and the corrosive

n ature of this acid gas exhaust from the fire box, the ductwork is refractoryPage 3 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

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- lined. It is neither safe nor practical to add a sample port with the unit operating, so a plant

- wide shutdown would be required to add this port to a control device. Spec ial pipe or duct spools would need to be shop fabricated to include this port and its integral protective heat resistant and corrosion resistant lining. Even with a protective engineering design and a thermal and
corrosion resistant material

- of

- constructi on, a sample port will always be a potential source of leakage and corrosion. Thus, plant safety personnel strongly advise against implementing this type of unsafe practice. While this may seem to be a minor project, it could involve considerable work in cluding, but not limited to, relocation of upstream (firebox) and downstream (acid recovery/scrubber system) equipment and instrumentation, scheduling outages to complete the work, fabrication of required components, etc. In summary, the installation of t his specific sample port poses a considerable project for each affected source.

iii) We are concerned with data collection at this specific location , as we believe the Agency would be as well, to emphasize that the result s of any attempted
measurement of flow a t this location w ould give inaccurate flow data in some

cases, and at a minimum , would require an extension of the testing program completion date in order to properly install the necessary sample ports for long term safe operations.

b) As an alternative to t he approach contained in the 114 Request and one that we believe will satisfy Agency requirements, t he industry proposes to eliminate altogether the sampling and testing at this location (between the thermal oxidizer
and the acid recovery/ scrubber system ) in favor of the following sampling and testing proposal (please refer to the attached Stack Testing Block Flow Diagram) :

i) Only t est inlet streams to the thermal oxidizer and stack exhaust streams from
the scrubber.

ii) On the exhaust stack, employ an EPA Method 316 configured sampling train that incorporates elements of NCASI Method IM/CAN/WP

- 99.02 whichPage 4 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

- 3359 ● Fax (571) 970

- 3271 www.vinylinfo.org ● www.vinylindesign.com (please refer to the attached Sketch for Modified Method 316 for Isokinetic Sampling of Scrubber Stack Gas) :

(1) Utilizes an isokinetic sampling technique ;

(2) Use s the condensation and impingement sampling procedure of Method 316 to separate and collect any entrained liquids in the sample stream; analyze s the collected liquid sample fraction following the NCASI 99.02 protocol for HAPs for the aqueous sample fraction ; an d

(3) Pull s off a volume monitored slipstream of the sampled gas immediately after the third impinger and route s it either to a Method 320 on

- line FTIR for real time analysis of VHAPs or into a Summa canister for subsequent laboratory analy s is of the VHAPs of interest using a combination of
GC/MS and GC/FID.

c) Method 2 for determining flow rates into the thermal oxidizer cannot be safely used for pressurized streams. The industry recommends that each facility provide for a calibrated mechanical flow measurement device in the process stream sent to the thermal oxidizer following the protocol of EPA Method 2D or an approved alternative

. d) The inlet streams to the thermal oxidizer are gaseous in nature as recognized by EPA’s requested test methods. The small diam eters and higher pressures of the
thermal oxidizer inlet lines preclude the use of Method 26A as written, thus the industry proposes to perform Method 26A non

- isokinetically, similar to Method
26. This will enable the moisture content of the streams to be ascertained at the
same time as the HCl/CL 2 concentrations.

We believe that the proposal above will satisfy Agency data gathering requirements and allow industry facilities to safely and accurately test the
affected source.Page 5 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

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- 3271 www.vinylinfo.org ● www.vinylindesign.com 3) The industry recognizes the n eed to sample resin. In an effort to provide
consistent data to the A gency, we propose , or seek clarification, with regard to the following:

a) The current Vinyl Chloride NESHAP requires industry sources to draw a resin sample once every 8 hours. The indust ry would like to continue this practice for the PVC MACT testing which represents a change from the EPA’s request of 4 grab samples spaced a minimum of one hour apart. The i ndustry proposes to sample once every 8 hours because this practice is consistent with a long established regulatory and operating practice that is ingrained at all sources. The industry recommend s continuing th is practice during the 30

- day test program, but to expand the analytical activities to measure the levels of the
accountable H AP substances used in the resin making process . Gathering
short

- term data

, as currently proposed by the Agency, will provide a larger data

set

, although average HAP concentrations over the sample period should not vary to any significant degree. Maintain ing the current sampling schedule provides for consistency with an existing government

- required data gathering program, and would not sacrifice either data quality or the robustness of the data

set.

b) The samples will be drawn after the stripper (slurry of l iquid and resin) and after the final product dryer.

c) To account for the HAPS, t he industry recommends EPA method SW846 be followed for analyzing the slurry and resin samples

, such as M ethod 8260B for VOCs, M ethod 8270D for SVOCs, M ethod 8315A for carbonyl c ompounds and
Method 8015 C for non

- halogenated compounds , if appropriate. The corresponding sample acquisition and preparation prescribed by each method for the nature of the sample matrix should be followed. It is the industry’s intention
to use the atta ched Resin Testing Block Flow Diagram as a guide for submitting individual facility resin sampling and analysis plans.

d) Doe s the EPA’s request for “integrated” samples imply that each set of daily discrete samples be composited and then analyzed and presen ted as a dailyPage 6 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

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- 3271 www.vinylinfo.org ● www.vinylindesign.com value, or that each daily discrete sample be analyzed separately and the results be averaged to provide a daily value?

4) The mandated timeframe for completion of testing is a brief period of a manufacturing year and this should be accounted fo r in the development of
the PVC MACT rule

.
a) We anticipate that the tests will be conducted at each manufacturing facility during nearly identical 30

- day time periods from mid

- Nov ember to mid

- January.
This may severely limit the selection of appropriate re sin type campaigns, and

may provide the EPA with a limited database of information upon which to base
its rule.

b) The industry advocates the acceptance of any prior stack or CEMS test data as a method to support modification of the testing requirement, if it complies with the
EPA validation criteria.

c) The industry also requests that EPA agree to accept , following the mandated test
submission date

, certain test results if the industry believes they would be of particular interest and benefit to the EPA in developing the regulation.

Each affected source is currently developing its test plans. However, o nce these issues are resolved and questions answered in a timely manner , individual facility sampling and testing plans can be completed in a manner that pr ovides a high degree of
confidence that the industry is meeting EPA expectations. The industry understands the importance of meeting EPA’s testing timeframe, but recognizes that the most critical step in the process

— EPA’s approval of each company’s testi ng plan

– is beyond our
control

. Therefore, we respectfully request that the Agency review test plans quickly, so that sampling and analytical activities can proceed without delay.

The contractors to whom we forwarded the 114 Request have raised many
conf iguration and implementation questions that impinge on their ability to prepare sampling bids. As a result, the industry is unsure how to proceed with testing

contracto rs until their individual facility plans are approved by the A gency. Assuming
that the se issues can be clarified, we also have been informed by many of thePage 7 of 7 1737 King Street, Suite 390 ● Alexandria, VA 22314 ● (571) 970

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- 3271 www.vinylinfo.org ● www.vinylindesign.com contractors we have consulted that any delay in sampling plan approval beyond October 28, 2009, will undermine their ability to obtain and report sampling results by the February 28, 201 0 deadline.

Accordingly, the industry looks forward to discussing its outstanding questions, the
additional concerns raised in this communication , and our proposed solutions in greater detail during our September 28 th , 2009 meeting. We view the opportuni ty to meet with EPA staff at this juncture to be an integral and extremely critical step to expediting the

114 R equest collection process and meeting the Agency’s reporting timeframe. The
A gency’s thorough consideration of these issues and our proposed so lutions is greatly appreciated. Please do not hesitate to contact me with any questions or comments.

Sincerely,

Richard P. Krock Technical Director

e

- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 5 71

- 216

- 4474

Attachments: 1.) Stack Testing Block Flow Diagram for proposed thermal oxidizer &

s crubber sampling and testing; 2.) Sketch for Modified Method 316 for Isokinetic Sampling of Scrubber Stack Gas; 3 .) Resin Testing Block Flow Diagram for proposed resin sampling and analysis