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| From: | |------------>

>----------------------------------------------------------------------------- -----------------------------------------------------------| |Richard Krock <rkrock@vinylinfo.org> |

>----------------------------------------------------------------------------- -----------------------------------------------------------| |------------> | To: | |------------>

>----------------------------------------------------------------------------- -----------------------------------------------------------| |Jodi Howard/RTP/USEPA/US@EPA |

>----------------------------------------------------------------------------- -----------------------------------------------------------| |------------> | Date: | |------------>

>----------------------------------------------------------------------------- -----------------------------------------------------------| |08/26/2009 04:40 PM |

>----------------------------------------------------------------------------- -----------------------------------------------------------| |------------> | Subject: | |------------>

>----------------------------------------------------------------------------- -----------------------------------------------------------| |VI Questions on EPA PVC MACT Testing Requirements |

>----------------------------------------------------------------------------- -----------------------------------------------------------|

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 isrequired. 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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