>>> "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 the 
best 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 any 
immediate 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

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