From: Barry_H._Christensen@oxy.com [mailto:Barry_H._Christensen@oxy.com] 
Sent: Thursday, August 21, 2014 7:03 PM
To: Kaleri, Cynthia
Cc: Deanna_Strain@oxy.com; Dewees, Jason; Bouchard, Andrew; Handrich, Charles; 
Howard, Jodi; Stephanie_Engwall@oxy.com
Subject: Follow-up to OxyVinyls Test Plan for PVC NESHAPs 
Importance: High

Ms. Kaleri,

This submission is a follow-up to our meeting of August 13, 2014, to review 
the Site-Specific Performance Test Plan submitted to EPA on July 30, 2014. The 
testing will be performed to comply with the CAA114 ICR request and compliance 
performance test requirements of the Area Source PVC NESHAP and, as a 
contingency, the Major Source PVC NESHAP.  The following paragraphs address 
the information you requested during the meeting.

1.      Additional information on the similarity of the two oxidizer/scrubber 
trains.

A table is enclosed which summarizes the design and operating characteristics 
of both trains.  OxyVinyls does not foresee any significant emission 
differences in our two trains.  It should be noted that at the time of the 
last performance test in 2011, the two trains were identical.  Subsequent to 
that test, OxyVinyls installed the two-stage burner on the "A" oxidizer to 
allow for more efficient turn down operation.  We plan to test the "A" train 
in our performance test scheduled for next month.  We will then have data from 
past CAA
114 tests indicating that both units comply with the area or major source PVC 
MACT limits.


2.      Alternate Monitoring Request (AMR) for absorber/scrubber operation.

Enclosed is an AMR, filed as a contingency, should it be necessary for the 
LaPorte Plant to comply with the major source limits in the future.  We 
respectfully request approval from EPA Region 6 prior to our performance test 
of 9/29/2014 to ensure that we capture the correct operational data during the 
test.




3.      Request to submit the 2009 30-day THC data  in lieu of gathering new 
data for the CAA 114 ICR.

During the meeting, a statement was made that our 2009/2010 was too outdated 
to be used.  However, that testing was performed 12/10/2009 through 2/07/2010; 
therefore the data less than 5 years old.  Also, as shown in the data provided 
in Appendix E of our test plan, the only detectable THC values occurred for a 
few hours on only 2 or 3 days when oxidizer startup or shutdown events took 
place, which is to be expected with all combustion devices.  Therefore, 
OxyVinyls believes that gathering additional days of non detectable THC values 
seems of limited value.  We do, however, endorse EPA's continued effort to 
correlate THC and TOH data.  As indicated previously, the earliest the plant 
can begin testing is 9/22/2014.  Due to staggered annual outages for each 
plant, it is not likely that we will have a full 30 days of THC data compiled 
for reporting by the 11/17/2014 deadline, however we will make our best effort 
to do so.

4.      Request to use the 2011 D/F data in lieu of gathering new  data for 
the compliance performance test.

Based upon your verbal feedback, OxyVinyls understands that our prior D/F data 
gathered for a CAA114 ICR at our LaPorte Plant can be used in lieu of 
gathering additional D/F data.  Accordingly, we are not planning to include 
that sampling in our September 2014 testing.

5.      Thermal Oxidizer Firebox Temperature

We understand that EPA (Region 6) is assessing whether the oxidizer 
temperature operating limit (OPL) will be set at the  minimum 1-hr run value 
or the average of the 1-hr test runs.

6.      Correction to Method 8270 referenced in Test Plan

You indicated that our test plan incorrectly referred to analytical method 
8270C in lieu of 8270D.  We acknowledge that this method was updated in 
February 2007, and we will modify our plans accordingly (i.e., and utilize the 
updated method as required in the performance test).

Finally,  thank you to Mr. Charles Handrich for forwarding the technical 
information about alkalinity vs. pH measurement and ORP probes.  We will 
review it for possible future application.

We trust this information answers EPA's questions to date.  If you have any 
additional questions or require additional information, please do not hesitate 
to contact either Ms. Deanna Strain at (281) 476-2909 or Stephanie Engwall at 
(972) 404-3291.


Barry Christensen
Mgr. Air Quality
Occidental Chemical
972 404 3209


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