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PVC and Copolymer Manufacturing Section 114 Testing Questions 

EPA Responses 

Slurry/Resin Analysis 

1. Do you want the slurry samples analyzed as a single sample or separated into the liquid 

portion and solid portion and analyzed as two separate samples? 

If the sample comes in two phases, it may be necessary to analyze both the liquid 

and solid portions. Separate analyses on both the liquid and solid portions are 

required unless the method analysis is applicable to the two different phases. Please 

specify in the sampling plan how the samples will be handled and any rationale or 

limitations for these choices. 

2. For the slurry samples, what type of bottles should be used, especially for the volatile 

samples; VOA vials or regular glass jars? 

We are not specifying the type of bottle to be used. You should choose a sampling 

plan including sampling bottles that is appropriate for the components being 

measured and include a detailed description of how the sample will be taken. 

3. With regard to the parameter list below, we can analyze a solid or a slurry for most of 

these compounds but there are a few in highlight below that are usually tested using air 

methods only and are usually done by stack testing. Just like with traditional HAP testing, 

some of the parameters have to be done by stack testing and some have to be done in-lab. 

Just to clarify what is to done in-lab vs. by stack testing: 1, 3-butadiene and Vinyl 

Bromide might be analyzed using Method 8260 but they are typically done by stack 

testing. Are these parameters supposed to be done in lab or by the stack testers? If you do 

want them done in the lab what method do you recommend? Chlorine and Hydrogen 

Chloride are always air methods done by stack testing. If you do want these done in lab, 

what method or technique do you recommend? 

Anything (e.g. initiators, etc.) that is added to the manufacturing process that is or 

could decompose and potentially results in HAP (one of the 187 listed in the Clean 

Air Act under Section 112) emissions should be included in the testing. HAPs will 

vary from facility to facility and may even vary depending on the grade that is being 

produced at a facility. Please provide an explanation for why HAP that are listed on 

page 1 of Enclosure 1, Attachment B were not included in your specific facility’s 

testing. 

 

Slurry/Resin Sampling 

4. From the paragraph below in highlight; please further define integrated samples. The 

mass balance should be done on integrated samples that consists of a grab sample that is 

to be taken every hour for 4 hours. Are those 4 samples to be analyzed individually as 
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discreet samples or are they to be combined into 1 composite sample? 

From: Summary of Test Procedures, etc.: Enclosure 1, Attachment B, page 2: 

“In some cases, there is a scrubber located after a thermal oxidizer to control hydrogen 

chloride and chlorine emissions. Performance testing for these compounds should be 

conducted at sampling ports after the scrubber. Some of the methods listed below do not 

work well in “wet” stacks; therefore, we are asking for performance testing of these 

pollutants to be conducted at sampling ports located after the thermal oxidizer, but before 

the scrubber. Inlet and outlet testing must be done concurrently and any other sampling 

should be scheduled during testing as well. 

A conservative mass balance of the resin immediately after the stripper to after the dryers 

should be used to estimate emissions. This must be done by using an appropriate 

sampling method and the mass balance should account for any hazardous air pollutant 

compounds used in the resin making process including impurities. The mass balance 

should be done on integrated samples that have at least 4 grab samples separated by a 

minimum of one hour. Thirty days of integrated samples for the mass balance should be 

taken concurrently with the 30 days of CO/THC testing required in Section 1.3.” 

For the 30 day resin analysis, we expect a minimum of 30 days of composite samples 

from a point at the base of the resin stripper to a point after the dryers. At a 

minimum, the grab samples should be composited for all post resin stripper samples 

into one sample for each day for analysis and all post dryer points into one sample 

for each day for analysis. You may combine multiple dryer train grab samples into 

a single daily composite sample. The composite samples taken should be as 

representative as possible for resin dried during that day. We are expecting a 

minimum of 60 total resin sample analysis from each facility. The composite 

samples must be analyzed for any air toxics that are used in the process or could be 

produced by the process (for example: an initiator that possibly decomposes to form 

an air toxic). If a company thinks multiple samples would show more information 

about variability or would better represent yearly emissions, individual test samples 

are welcome. 

5. 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? 

“Integrated” samples mean composite samples. If there are multiple resin grades, 

industry may combine the samples from each. All grab samples for each operating 

day may be combined into one sample for analysis in order to reduce analysis 

burden. If a facility feels that more grab or composite samples would be better 

representative of your emissions, you may opt to collect more grab samples for each 

day and/or analyze for more than one composite sample per day. 

6. 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: 
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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. 

Samples may be taken during the Vinyl Chloride NESHAP sampling once 

every 8 hours. 

b. The samples will be drawn after the stripper (slurry of liquid and resin) and after 

the final product dryer. 

Samples should be taken at the base of the resin 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. 

The test matrix and data quality objective for SW846 methods should be 

submitted as a part of the test plan for our review and approval. 

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 value, 

or that each daily discrete sample be analyzed separately and the results be 

averaged to provide a daily value? 

See response to question 5.

Control Equipment Testing 

7. Our firm is preparing a bid to conduct Section 114 ICR testing in support of the PVC 

MACT rule. I conducted a site visit recently and I have concerns about the ability to 
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safely and properly obtain the samples that are required and would appreciate any 

guidance you might be able to provide. 

A brief description of the process follows. The process consists of two thermal oxidizers 

(TOs) each of which are routed via individual ducts to a common caustic scrubber stack. 

The inlet ducts to the TOs are each ~6" diameter, contain ~8.4% up to a maximum of 29 

% vinyl chloride and are under 4-10 psi positive pressure. The ducts between the thermal 

oxidizer outlet and the scrubber inlet are ~8" diameter, contain potentially high levels of 

HCl and are at "x" inches of water positive pressure. None of the ducts are equipped with 

sample ports. Our client is obviously apprehensive (and so am I) about installing test 

ports on any of these ducts and then having a contractor insert and move probes from one 

port to another. They have indicated that even if approval were granted to allow access to 

these vapor streams our personnel would be required to wear fully-encapsulated acid 

resistant suits and supplied air, the sample ports would have to be equipped with double 

block valves and our probes would have to be fitted with packing gland oversheath 

assemblies. 

Frankly, I have concerns as to whether these ducts can be sampled safely and question 

whether the data, if collected, would be of acceptable quality. Additionally, I don't feel it 

would be appropriate to expose an emissions test trailer, analyzers, or even dilution 

probes/assemblies to the inlet stream acid gas composition as the potential for ruining the 

equipment is too great. 

If the facility can provide inlet information based on mass balance or another type of 

calculation, would this be an acceptable alternative to field sampling in light of these 

challenging circumstances? We would then be prepared to conduct all of the field 

sampling ( Methods 3A, 10, 23, 25A, 26A, 320, 0010 and 0031) including the 30 day test 

for Methods 3A, 10, methane and 25A only on the scrubber exhaust stack to atmosphere. 

I realize that before granting any type of formal acceptance, EPA may want to review a 

more specific mass balance/calculation procedure which will have to be provided by the 

facility. At this point I am simply asking if this type of alternative is a possibility so that I 

can at least proceed with a proposal to my client which encompasses solely a scrubber 

outlet sampling work scope. 

We are trying to collect as much inlet data as possible. What we are seeking from 

industry is any kind of flow monitoring data they may have (such as calibration 

data or SOPs). If the data does not meet the criteria of Method 2D, it should not be 

submitted. Some processes may have combined inlets (with PVC and other 

processes); if it is at all possible, we are asking for a mass rate from the PVC plant 

versus the total combined mass rate. If there is a way for industry to test the PVC 

and total and back-calculate the PVC emissions this should be included in the 

testing plan along with supporting calculations and information. 

We understand that the thermal oxidizer could be subject to other regulations (e.g., 

HON, MON) and testing may have been done in the past. If testing was recently 

conducted for some of the HAP listed in Enclosure 1, as a part of the testing plan, 
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industry may request to use that data instead of testing for those particular HAP. 

The specific HAP tested, the test dates, test methods, test results, Agency (state or 

federal) approval, the rationale for using an alternative method and any other 

pertinent information should be included in a condensed format. Each submittal 

will be evaluated on a case-by-case basis. We are asking industry to also submit a 

testing matrix in the event that the previous test data is not accepted for standard 

setting purposes. 

Concentrations (ppm) and flowrates (lb/hr) should be submitted for each HAP 

tested. 

Method 320 should be used on the inlet for speciated data and totals. PVC industry 

asked if they should identify each HAP in the stream, down to the detection limit. 

EPA stated that industry should identify each HAP in the stream down to the lowest 

possible detection level. 

Methods 26/26A can be utilized (non-isokinetic) to obtain moisture. 

8. 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. 

As long as multiple control systems are configured the same and are of identical 

equipment design, only one needs to be tested. 

9. 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. 

See answer to question 10. 

10. 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 
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standardized testing methods. Any flow measurement under these 

constraints could produce erroneous volumetric measurements and hence 

inaccurate mass flow rates. 

We are allowing for all post thermal oxidizer measurements to be 

moved to after the scrubber. 

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 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. 

We are allowing for all post thermal oxidizer measurements to be 

moved to after the scrubber. 

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. 

We are allowing for all post thermal oxidizer measurements to be 

moved to after the scrubber. 

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): 
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i. Only test inlet streams to the thermal oxidizer and stack exhaust streams 

from the scrubber. 

This is acceptable. 

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 (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. 

We would approve this as an alternative method if the Summa canisters were 

analyzed by a method such as TO-15 which uses high res GS/MS for the 

analysis. We would also require additional QA/QC spikes and duplicate 

trains such as outlined in 99.02. Acceptable recoveries for the spikes would 

be between 50-150%. We may also use the QA recovery data to adjust the 

results since this is an unvalidated method. 

For the alternate testing location of the scrubber, Method 0031 can be used 

without modification to account for entrained water droplets. Method 320 

should be modified to allow for isokinetically sampling the emission stream, 

from a single point. No sample traverse would be required. 

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. 

This approach may be used. 

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 
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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. 

This approach may be used. 

11. Specific Questions and Items on Attachment B - Test Procedures: EPA's Attachment B 

contains the following statements in the second paragraph of Section 1.2: "We believe 

that testing all the inlets to the control system from all processes prior to them being 

combusted is needed to adequately characterize and separate the emissions". We have 

the following questions regarding this requirement: 

a. Our TTU system handles vents from three different portions of the plant. Only 

one inlet stream, which is commingled with other inlet streams, will be subject to 

the future PVC MACT rule. How should testing be conducted if it is not 

physically possible to measure each inlet stream that is associated with each 

process that feeds the thermal oxidizer? In these cases, can we provide an 

alternative testing proposal? 

An alternative testing proposal should be submitted for approval. 

b. If physically possible, is it acceptable to measure the inlet from the portion of the 

plant that will be subject to the PVC MACT rule and then sample from a separate 

header that represents the majority of all other flows to the thermal treatment unit, 

thus excluding smaller insignificant streams that are entering the oxidizer? 

Please provide detailed information and rationale for the inlet testing matrix. 

We need information on the speciated mass loading from the PVC process 

and the total speciated mass loading to the inlet to the control systems. 

c. Is it acceptable to measure the combined inlet flow and composition and then use 

engineering calculations and process knowledge to apportion the flow and 

composition back to the portion of the plant that will be subject to the future PVC 

MACT rule? 

This should be included in the test plan for our review and approval. 

d. CO/THC/CH4 monitoring for thermal treatment vent stack – Please verify that it 

is acceptable to conduct this test during operations when sources that will be 

subject to the PVC MACT rule and other sources are venting to the thermal 

oxidizer concurrently. 

Yes it is acceptable to conduct testing during these operational conditions. 

e. Is it acceptable to determine the %DRE for one or more pollutants that are 

deemed difficult to combust, and then use this measured %DRE for other 

pollutants that are easier to combust vs. sampling the exhaust for each air 
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contaminant? For example, if the DRE of compound A is > 99.99%, then other 

materials that are easier to combust will also have a % DRE > 99.99%. 

This approach is not acceptable. 

f. Can the test program be designed in a flexible manner such that the inlet sampling 

is conducted a few hours prior to the outlet sampling to minimize the amount of 

analytical equipment that the testing contractor needs to bring on-site? 

No. Inlet and outlet sampling must be done simultaneously. 

g. How does EPA want industry to measure the emissions (and which emissions) 

that potentially occur during reactor hydroblasting? 

We are interested in the emissions from PVC resin that is removed from the 

manufacturing process at any point prior to slurry stripping. This material 

includes, but is not limited to, resin removed from the reactor during 

hydroblasting or other reactor clean out activities, and resin removed from 

filters or other pieces of equipment prior to slurry stripping. 

The methodology used to sample these sources of resin should follow the 

same methodology that will be used to sample the stripped slurry. The type 

of resin being sampled, the reason that the resin that is not being stripped, 

and all of the parameters required to perform sampling (e.g. method, mass, 

etc.) should be included in the final test report and the test plan should 

include the method that will be used to conduct the sampling. 

 

In addition to unstripped resin sources, we are also interested in the 

quantification of emissions from gas holders. Gas holders used to store 

recovered VCM have the potential to emit large amounts of vinyl chloride at 

the water seal. EPA would like to obtain quantification of this emission 

source for consideration in rulemaking.

h. Inlet Sampling - Why is EPA requiring sampling for CO and Oxygen on the inlet 

lines? We cannot determine the value of conducting inlet testing for these 

components. 

CO may be removed from consideration since there is no combustion in the 

PVC process. 

12. Outlet Sampling - If the owner/operator does not believe that certain air contaminants 

(such as methanol or ethylene) are present, is the owner/operator required to conduct 

testing for these materials? Can the owner/operator propose which VOC to analyze? 

Ethylene was inadvertently left in Table 1.3 (See Answer 13). Companies can 

propose which HAP to analyze based on process knowledge, process chemistry, and 
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the type of control technology that is used. This would include additives to the 

process such as initiators, etc. that contain HAP or could react within the process to 

create HAP or combustion by-products resulting from a control device. 

13. Inlet sampling - EPA's list of chemicals does not include vinylidene chloride, but this 

material is a HAP. Not sure if the inlet sampling program has to include vinylidene 

chloride.

Ethylene should be removed from Table 1.3 of Enclosure 1, Attachment B. If 

vinylidene chloride could be emitted from PVC manufacturing please include it in 

the sampling program along with any of the other HAP that are not specifically 

listed on page 1 of Enclosure 1, Attachment B that are potentially emitted. Please 

provide a rationale for each HAP that will be removed or added to the list of HAP 

in Attachment B. 

14. The sampling protocol calls for a 4 hour test per sample run. Most traditional EPA 

performance tests consist of 3 separate 1-hour emission tests. Why is EPA extending this 

testing program over a 12+ hour period especially for other VOC sampling? This 

dramatically increases the cost of the testing for what appears to be an arbitrary and 

capricious reason. 

See response to question 6.a. 

15. Why is inlet O2 correction needed? All concentrations are requested to be corrected to 

3% O2 on inlet sampling. Typically O2 correction is used to give standardization and to 

discourage the use of additional air to dilute emissions on an outlet in order to 

demonstrate compliance. Further, most of the inlet streams in this process consist of the 

pollutant with nitrogen as the make-up, since N2 is the compound primarily used for 

purging and padding. 

Flowrate calculations require molecular weights. Oxygen data is needed to 

normalize industry data into a common unit of measure. 

16. The sampling of CO and methane on each inlet brings no value. Most inlets have neither 

of these compounds in them by nature. CO is a product of combustion which has not yet 

occurred. Methane is added to the firebox as fuel in the TTU. However, even if small 

amounts of either were to be found in any of the inlets, the TTU would immediately 

destroy them in the firebox. This is proved by the destruction of the Organic HAPs 

which are much more difficult to destroy than CO or methane. 

Since there is no combustion in the process, there should be no concern with CO. 

Methane data is needed to adjust the THC data to a non methane basis. EPA stated 

that methane may be tested using Methods 18 or 320. 
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17. If the inlet lines are pressurized above 20 PSIG, we will not insert a pitot tube in the line 

due to safety concerns for our personnel. We will be required to use process flow meters 

in these cases. Therefore, for any line where this is necessary, moisture and molecular 

weight bring no value. 

Please provide detailed information and reasoning on the alternative methods 

suggested for measurement of flowrates without moisture and/or molecular weight 

in the test protocol. 

18. Outlet sampling 

a. Concerns - Before Water Scrubber Analysis: 

i. Two additional sample ports will have to be added to accomplish the total 

sampling if all requirements are to be met. This is a 10" fiberglass line. 

EPA method 1 requirement can be met to accomplish this, but extra care 

has to be taken to make sure that velocity and isokinetic sampling are not 

affected. The installation of these sample ports will require an unplanned 

control device shutdown, which is not practical in the next few months 

since our thermal oxidizer treats vents from different processes at our site. 

If it is not feasible to install additional ports in the time frame for 

response, please provide an alternative test matrix and schedule in the 

testing protocol for our approval. 

ii. FTIR - Organic HAPs have been sampled in the past year to prove 

compliance with the MON. 

You may submit previous stack test reports with all raw data with the 

testing protocol and propose that past data be used in lieu of testing 

requested in the Section 114 letter. Please also include your testing 

matrix in the event that the previous data is not accepted.

iii. THC - THC is a general indicator and will provide no additional value to 

the FTIR or M0010 sampling since this analysis is non-specific in nature. 

THC will provide information to ensure that the other organic methods 

capture the organic emissions. THC may possibly be used as a 

surrogate for total organic hazardous air pollutants for the standard 

setting. 

iv. Methane - The TTU should destroy all methane. If any is to pass through, 

it would be picked up by the THC if the THC is required. 

Methane is necessary to adjust the THC data to a non methane total 

hydrocarbon concentration. 
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v. 0010 - Organic HAPs have been sampled to prove compliance with the 

MON. Furthermore, if FTIR is required, M0010 will be a repetitive 

analysis and will not provide much more information than the FTIR data. 

We agree that Method 0010 could potentially duplicate measurements 

that we could make with Method 320 by itself, but Method 0010 may 

also provide different useful information.

19. 30 Day sample Project: 

a. Methane analysis - THC sampling will pick up any upset that could cause 

additional methane emissions. FTIR or M18 daily for 30 days is very expensive 

to prove that methane is not present at the outlet. 

Guidance on 30-day sampling and methane analysis can be found in the FAQ 

and guidance documents developed by the Emissions Measurements Center 

for the section 114 boilers/CISWI testing. Please refer to the following 

documents on the EMC website (http://www.epa.gov/ttn/emc/guidlnd.html): 

GD 51A - Presentation from the 6/18/09 Webinar on Boiler and Process 

Heater Emission Testing (6/25/2009) 

GD 51B - Frequently Asked Questions from the 6/18/09 Webinar on Boiler 

and Process Heater Emission Testing (6/25/2009) 

GD 51C - Frequently Asked Questions from the 6/18/09 Webinar on Boiler 

and Process Heater Emission Testing - Part 3 (7/7/2009) 

GD 51D - Frequently Asked Questions from the 6/18/09 Webinar on Boiler 

and Process Heater Emission Testing - Part 4 (7/16/2009) 

GD 51E - Frequently Asked Questions from the 6/18/09 Webinar on Boiler 

and Process Heater Emission Testing - Part 5 (7/31/2009) 

GD 51F - Frequently Asked Questions from the 6/18/09 Webinar on Boiler 

and Process Heater Emission Testing - Part 6 (9/24/2009)

20. Our company has the following technical concerns with using EPA Reference Method 23 

for specific portions of this testing. Method 23 might be acceptable for sampling (only!) 

for PCB. However it is not validated for it. But in terms of analysis for PCB this method 

is non-adequate as it is exclusively written for PCDD/F. In addition most of the sampling 

methods (if not all) are not validated in a sampling environment of 400 - 500 C or even 

higher (as we can expect before the quench). 

We are allowing for the M23 train to be moved to the outlet of the scrubber. Please 

use CARB 428 for PCBs or suggest an alternative method in your testing protocol.
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Monitoring 

21. 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. 

The 30 day CEM testing (CO/THC/CH4) was only intended for testing on the PVC 

emission control system. The 30 days of process sampling and mass balance will 

provide us with the variability of emissions from the dryer and ancillary equipment 

after the stripper. Therefore, the 30-day monitoring requirement is not applicable 

during process sampling. 

22. Re: Enclosure 1, Attachment B, Section 1.3 – Is the 30-day period to be operating days or 

calendar days? 

The requirement is for 30 operating days. If monitoring occurs during an 

operational period that is not considered “normal” please provide an explanation of 

the conditions that make this period different from “normal” operations. Page 3 of 

Enclosure 1, Attachment B specifies the process information that is to be submitted 

as a part of the sampling report. 

Detection Levels 

23. 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. 

We are using our legal authority provided in section 114 of the Clean Air Act to 

collect data, partially through testing, to support our rulemaking efforts for the 

development of a NESHAP for polyvinyl chloride and copolymer production under 

section 112 of the Clean Air Act.

a. 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. 

As stated in the Section 114 Enclosure 1, we will not be specifying numerical 

detection limits.