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September 21, 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 this week to review the testing, methods, and timing requirements of the U.S. 

Environmental 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 continue 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 to 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:
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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 

testing 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 Agency 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 companies use the correct 

sampling and analytical equipment and procedures.

2) We have reviewed the physical configurations of our thermal oxidizers and

sampling 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 systems, 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 inaccurate 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 

nature of this acid gas exhaust from the fire box, the ductwork is refractory 
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brick-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. Special 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-construction, 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 including, 

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 this 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 results of any attempted 

measurement of flow at this location would 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 the approach contained in the 114 Request and one that we 

believe will satisfy Agency requirements, the 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 test 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 which
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(please refer to the attached Sketch for Modified Method 316 for Isokinetic 

Sampling of Scrubber Stack Gas):

(1) Utilizes an isokinetic sampling technique;

(2) Uses the condensation and impingement sampling procedure of Method 

316 to separate and collect any entrained liquids in the sample stream; 

analyzes the collected liquid sample fraction following the NCASI 99.02 

protocol for HAPs for the aqueous sample fraction; and

(3) Pulls off a volume monitored slipstream of the sampled gas immediately 

after the third impinger and routes it either to a Method 320 on-line FTIR 

for real time analysis of VHAPs or into a Summa canister for subsequent 

laboratory analysis 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 diameters 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/CL2 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. 
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3) The industry recognizes the need to sample resin. In an effort to provide 

consistent data to the Agency, 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 industry 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 industry 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 recommends continuing this practice during the 30-day test 

program, but to expand the analytical activities to measure the levels of the 

accountable HAP 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. Maintaining 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 liquid and resin) and after 

the final product dryer.

c) To account for the HAPS, the industry recommends EPA method SW846 be 

followed for analyzing the slurry and resin samples, such as Method 8260B for 

VOCs, Method 8270D for SVOCs, Method 8315A for carbonyl compounds and 

Method 8015C 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 attached Resin Testing Block Flow Diagram as a guide for submitting 

individual facility resin sampling and analysis plans. 

d) Does the EPA’s request for “integrated” samples imply that each set of daily 

discrete samples be composited and then analyzed and presented as a daily 
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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 for 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-November to mid-January. 

This may severely limit the selection of appropriate resin 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, once these issues 

are resolved and questions answered in a timely manner, individual facility sampling 

and testing plans can be completed in a manner that provides 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 testing 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 

configuration and implementation questions that impinge on their ability to prepare 

sampling bids. As a result, the industry is unsure how to proceed with testing 

contractors until their individual facility plans are approved by the Agency. Assuming 

that these issues can be clarified, we also have been informed by many of the 
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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, 2010 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 28th, 2009 meeting. We view the opportunity to meet with 

EPA staff at this juncture to be an integral and extremely critical step to expediting the 

114 Request collection process and meeting the Agency’s reporting timeframe. The 

Agency’s thorough consideration of these issues and our proposed solutions 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: 571-216-4474

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

 scrubber 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