>>> "Mary Bachynsky/FPC Environmental Dept." <mbachynsky@fpcusa.com>

1/14/2008 1:41 PM >>>

Hello Greg, Below is our response to your questions. Upon your review, please let us know of any additional questions or comments.

Q1. Are VI members working on assembling the information for #5 (i.e., mass balance information around reactors, strippers and control devices), or did you want us to provide feedback before that got underway?

A1. The VI Members were hoping for EPA feedback before getting underway with mass balance estimates.

Our approach at this point would be to use generic process flow diagrams and generic process descriptions for each PVC production process, and provide range estimates of Lb/hr, T/Yr and Lb/MMlb/yr. The Members would like to identify HAP emissions sources that have a minimal potential for emissions from the operation, which would allow both EPA and the VI Members to focus on the more significant potential HAP sources. In our experience, mass balances for small quantities of pollutants do not typically work well when actual data does not exist. Regarding mass balance information, for the more significant HAP emission sources (reactors, strippers and control devices), our plan is to provide an aggregated mass balance, based on available information, and would include range estimates. Would you please provide feedback as to whether this approach is acceptable to EPA?

Q.2 The facility list shows a Dow plant in Texas City, TX. Dow's website doesn't mention that this plant manufactures PVC products, but does mention some products that fall under the MON, so we wanted to verify their inclusion here is correct. If so, will they be participating through the VI or on their own behalf?

A.2 Dow is not a member of the VI. However, the Dow representative working with the VI on another environmental matter was contacted and your question was provided to the contact. The Dow contact is routing the information to the correct Dow representative and will provide information shortly.

Q3. Of the three process diagrams only the second one is labeled. Can you label the other two?

A3. Attached, please find a copy of the labeled flow diagrams, which were included in EPA’s February 1982 "Vinyl Chloride- A Review of National Emission Standard" document (EPA-450/3-82-003).

Q.4 In the second process diagram, there is no stripper identified, but notes on the left side of the page indicate that stripping is part of the process. Is the reactor used as the stripper? Is that typical for the bulk process?

A.4 We believe that the stripping activity occurs within the Post-polymerization reactor (number 4 on Figure 3-4). We have requested confirmation of our understanding from a Bulk PVC producer and will advise the agency if our understanding is not correct.

Q.5. The 3rd process diagram does not mention stripping of any kind. I don’t recall this being discussed in October, so if that can be described it would be helpful.

A.5. The 3rd process flow diagram addresses the Solution PVC production process. We believe, as per EPA’s 1982 review document, that there is only one Solution PVC Plant in the US. It appears that the plant may be Dow’s in Texas City, TX. Dow may be better able to address this question. Again, this will be confirmed, once Dow determines who its PVC MACT contact will be. A process description will be included, as per our response in A.1.

Q6. Some streams going to water strippers are identified on the diagrams. Can you provide information about the presence/absence of VCM or any other compounds in those streams?

A.6. VI Members may have estimated data on some HAPs into the wastewater strippers and some measured data on wastewater stripper discharges (namely VCM). We will address wastewater streams on the generic flow diagrams to thebest of our ability.

We appreciate the agency’s willingness to guide us through the data development phase, and look forward to your feedback.

Regards, Mary

Mary P. Bachynsky Formosa Plastics Corp. U.S. A. 9 Peach Tree Hill Road Livingston, New Jersey 07039 Phone: 973-716-7342 Cell: 862-485-5542 mbachynsky@fpcusa.com mailto:mbachynsky@fpcusa.com>

-----Original Message----- From: Nizich.Greg@epamail.epa.gov [mailto:Nizich.Greg@epamail.epa.gov] Sent: Monday, January 07, 2008 1:24 PM To: Mary Bachynsky/FPC Environmental Dept.; delacruz@khlaw.com Cc: Jason.Huckaby@erg.com Subject: Re: VI PVC MACT Submittal

Hi Mary and Peter,

Hope you enjoyed the holidays, but now it's back to PVC. . .

We have looked over the submittal that Frank sent in December and it looks to be heading in the right direction. About a month before our October meeting, I sent Frank an email with a summary of our overall informational needs. Here is the list from that email:

1. Confirm that our PVC facility inventory is complete; 2. Identify which emission point data are PVC, VCM, EDC, chlor-alkali (C/A), or other (provide description); [we provided a column for them to do this in each spreadsheet] 3. Key the records to a process diagram or flowsheet so that we may easily identify which parts of the process these emissions are coming from [there is a comments field where they may include this]; The process diagram would be generated by each company. 4. Provide descriptions for emission unit and control device where these are left blank or left unspecified; 5. In addition, we would like industry to provide mass balance information around the reactors, strippers and control devices (list all inputs and outputs, including vent stream composition and flowrate on a per production rate).

From the information just received it looks like items 1, 3 and 4 are close to being satisfied, with #5 being the main item to address. I think by going the process diagram route #2 is no longer being pursued. Are VI members working on assembling the information for #5, or did you want us to provide feedback before that got underway? The recent submittal also raised a couple questions that are listed below:

- The facility list shows a Dow plant in Texas City, TX. Dow's website doesn't mention that this plant manufactures PVC products, but does mention some products that fall under the MON, so we wanted to verify their inclusion here is correct. If so, will they be participating through the VI or on their own behalf?

- Of the three process diagrams only the second one is labeled. Can you label the other two? In the second process diagram, there is no stripper identified, but notes on the left side of the page indicate that stripping is part of the process. Is the reactor used as the stripper? Is that typical for the bulk process?

- The 3rd process diagram does not mention stripping of any kind. I dont' recall this being discussed in October, so if that can be described it would be helpful.

- Some streams going to water strippers are identified on the diagrams. Can you provide information about the presence/absence of VCM or any other compounds in those streams?

Let me know if you need to discuss further. Thanks. Greg.

Greg Nizich, OAQPS, Sector Policy and Programs Div. Coatings and Chemicals Group 919-469-6687.-----"Borrelli, Frank" <Frank_Borrelli@americanchemistry.com> wrote: -----

To: Greg Nizich/RTP/USEPA/US@EPA From: "Borrelli, Frank" <Frank_Borrelli@americanchemistry.com> Date: 12/21/2007 03:31PM cc: <akinsk@ggc.com>, <barry_h._christensen@oxy.com>, <david.a.labelle@saint-gobain.com>, "de la Cruz, Peter" <delacruz@khlaw.com>, <dyopak@teknorapex.com>, "Givonetti, Raymond" <ray_givonetti@oxy.com>, <jbell@shin-tech.com>, "John Yonge" <JYonge@shin-tech.com>, <mbachynsky@fpcusa.com>, "Sheridan, Kevin" <SheridanKevin@westlakechemical.com>, "Sistrunk, Otis J. (PED)" <Otis.Sistrunk@polyone.com>, "Tinsley, Wendell" <wtinsley@westlakechemical.com>, "TOM BERGER" <Berger@khlaw.com>, <Walker@khlaw.com>, <Yves.Blanchet@polyone.com> Subject: VI PVC MACT Submittal

Dear Greg,

As discussed at our meeting, enclosed please find four documents. The first is an updated list of PVC production facilities, their nameplate capacities and current operators based on data from CMAI. I have also included generic process flow sheets that we intend to enhance as we develop the additional information on HAPs associated with the PVC process. We think that the flow sheets accurately describe the boundary of the PVC process as they were part of the docket on the original NESHAP back in the 1970’s.

The third document is a list of potential HAPs that may be associated with PVC production. Substances are listed based on responses to a survey of VI member companies. Please note that we have included substances in the list even if they were reported by only one facility. In addition, we listed materials without regard to the amount involved or potential for emissions. Our goal was to define the universe of potential HAPs that might fall under the PVC MACT rule with the understanding that both the need for inclusion in the rule or the need to develop a surrogacy analysis would come at a later date. The inclusion of a substance on this list does not reflect any agreement by the VI or its members that the substance merits regulation under the PVC MACT. We have not included vinyl chloride monomer on the list because we understand that the agency will certainly include that HAP in the regulation. We have attempted to identify the possible source and noted expected fate of these HAPS following the polymerization step of the PVC process. A number of these HAPs are identified as VCM impurities. These HAPS normally exist at trace levels in commercial monomer grade vinyl chloride. They remain in the vinyl chloride monomer following the purification steps in a vinyl chloride process as a result of having similar physical properties, (volatility and solubility), as vinyl chloride but normally exist at part per million (ppm) levels. In some cases, certain HAPs would undergo free radical polymerization similarly to the vinyl chloride and become part of the PVC polymer molecule. In other cases they may remain and concentrate in the recovered vinyl chloride until they enter the vinyl chloride process vent gas control system. I have also included a vinyl chloride specification sheet that provides expected maximum levels of these impurities in normal commercial grade vinyl chloride. Actual levels are expected to be much lower.

We had looked into you concerns on compounding operations and offer the following. Under the Miscellaneous Organic NESHAP (Part 63 Subpart FFFF), EPA determined at 40 CFR 63.2435(a), (b) and (c), that a Unit which is located at, or is part of, a major source of hazardous air pollutants (HAP) engaged in compounding purchased plastic resin is exempt from the MACT Standard. This is due to the minimal potential for emissions from such an operation. For the same reason, EPA determined that a Unit which is located at, or is part of, a major source of HAPs, engaged in compounding its own resin is also exempt from the MACT Standard, as long as the compounding operation does not involve processing with HAP solvent or the intended purpose of the operation is to remove residual HAP monomer.

After you have an opportunity to review this information, we would like to discuss the next steps, which we believe would involve the quantification of potential HAPS and information regarding surrogacy. If you have anyimmediate questions, please do not hesitate to contact us. As you know I

will be retiring at year end and in the interim ask that you contact Peter de la Cruz of Keller and Heckman and Mary Bachynsky of Formosa Plastics regarding this program. It has been a pleasure working with you, good luck with your efforts and have a wonderful holiday season.

Regards

Frank Borrelli

Mary P. Bachynsky Formosa Plastics Corp. U.S. A. 9 Peach Tree Hill Road Livingston , New Jersey 07039 Phone: 973-716-7342 Cell: 862-485-5542 m bachynsky@fpcusa.com mailto:mbachynsky@fpcusa.com >

Peter L. de la Cruz Partner Keller and Heckman
1001 G Street, N.W., Suite 500 West | Washington , D.C. 20001 Tel: 202.434.4141 | fax 202.434.4646 | delacruz@khlaw.com

____________________________________________________________ This communication is solely for use by the intended recipient and may contain information that is privileged, confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use, copying or distribution of this communication, in whole or in part, is strictly prohibited. Unless explicitly stated, this communication does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This communication also does not constitute consent to the use of sender's contact information for direct marketing purposes or for transfers of data to third parties.