PVC Section 114 Testing Questions 10/2/2009 Page 1 of 13 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 analy zed as two separate samples?

If the sample comes in two phases, it m ay 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 applic able to the two different phases. Please specify in the sampling plan how the samp les 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 bottl es 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 usua lly tested using air methods only and are usually done by stack tes ting. Just like with tr aditional 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 don e in lab or by the stack testers? If you do want them done in the lab what meth od do you recommend? Chlorine and Hydrogen Chloride are always air methods done by st ack testing. If you do wa nt these done in lab, what method or technique do you recommend?

Anything (e.g. initiators, etc.) that is adde d 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; pleas e 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 asPVC Section 114 Testing Questions 10/2/2009 Page 2 of 13 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 oxidize r to control hydrogen chloride and chlorine emissions. Performa nce 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 ar e asking for performance testing of these pollutants to be conducted at sampling ports lo cated after the thermal oxidizer, but before the scrubber. Inlet and outlet testing must be done concurre ntly and any other sampling should be scheduled during testing as well.

A conservative mass balance of the resin immediat ely 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 shoul d account for any hazardous air pollutant compounds used in the resin making pro cess including impurities. The mass balance should be done on integrated samples that ha ve at least 4 grab samples separated by a minimum of one hour. Thirty days of integr ated samples for the mass balance should be taken concurrently with th e 30 days of CO/THC testi ng 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 compos ited 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 combin e 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 mult iple samples would show more information about variability or would better represent yearly emissions, individual test samples are welcome.

5. Re: Enclosure 1, Attachment B, Secti on 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 sample s. If there are multiple resin grades, industry may combine the samp les from each. All grab samples for each operating day may be combined into one sample fo r analysis in order to reduce analysis burden. If a facility feels that more gr ab or composite samples would be better representative of your emissions, you may op t 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 pr ovide consistent data to the Agency, we propose, or seek clar ification, with regard to the following:PVC Section 114 Testing Questions 10/2/2009 Page 3 of 13 a. The current Vinyl Chloride NESHAP requi res industry sources to draw a resin sample once every 8 hours. The industry w ould 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 ope rating practice that is ingr ained at all sources. The industry recommends continui ng this practice during the 30-day test program, but to expand the analytical ac tivities to measure the leve ls of the accountable HAP substances used in the resin making pr ocess. Gathering short-term data, as currently proposed by the Agency, will provi de a larger data set, although average HAP concentrations over the sample peri od should not vary to any significant degree. Maintaining the current sampling sc hedule provides for consistency with an existing government-required data ga thering program, and would not sacrifice either data quality or the robustness of the data set.

Samples may be taken during the Vi nyl 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 (s lurry of liquid and resin) and after the final product dryer.

c. To account for the HAPS, the industr y recommends EPA method SW846 be followed for analyzing the slurry and re sin samples, such as Method 8260B for VOCs, Method 8270D for SVOCs, Met hod 8315A for carbonyl compounds and Method 8015C for non-halogenated compounds, if appropriate. The corresponding sample acquisition and prep aration prescribed by each method for the nature of the sample matrix should be followed. It is the in dustry’s intention to use the attached Resin Testing Block Flow Diagram as a guide for submitting individual facility resin sa mpling and analysis plans.

The test matrix and data quality ob jective 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 an alyzed 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 S ection 114 ICR testing in support of the PVC MACT rule. I conducted a site visit recently and I have concerns about the ability toPVC Section 114 Testing Questions 10/2/2009 Page 4 of 13 safely and properly obtain the samples th at are required and w ould appreciate any guidance you might be able to provide.

A brief description of the process follows. Th e process consists of two thermal oxidizers (TOs) each of which are routed via individua l ducts to a common caustic scrubber stack. The inlet ducts to the TOs are each ~6" diam eter, contain ~8.4% up to a maximum of 29 % vinyl chloride and are under 4-10 psi positiv e pressure. The ducts between the thermal oxidizer outlet and the scrubber inlet are ~8" diameter, contai n potentially hi gh levels of HCl and are at "x" inches of water positive pr essure. None of the ducts are equipped with sample ports. Our client is obviously appreh ensive (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 indi cated 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 thes e ducts can be sampled safely and question whether the data, if collected, would be of acceptable quality. Additi onally, 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 informati on based on mass balance or another type of calculation, would this be an acceptable altern ative 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 th e 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 a re asking for a mass rate from the PVC plant versus the total combined mass rate. If th ere 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 supportin g calculations and information.

We understand that the thermal oxidizer coul d 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 Encl osure 1, as a part of the testing plan,PVC Section 114 Testing Questions 10/2/2009 Page 5 of 13 industry may request to use that data instea d 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 usin g 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 th at 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 ea ch 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 cont rol systems such as thermal oxidizers and scrubbers? Your understanding is that as long as the cont rol systems are configured similarly and in similar servic e, 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 – On e 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 ma y disrupt its integrit y 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 accessibl e locations and estimate the mass balance between the thermal oxidizer and the scrubber.

See answer to question 10.

10. We have reviewed the physical configurat ions of our thermal oxidizers and sampling between the thermal oxidizer ou tlet and acid recovery/scrubber inlet is not possible in the allotted time frame. The PVC industr y proposes an alternative plan.

a. Physical constraints prevent successful a nd safe sampling of this stream at this location.

i. Because of the short distances in th e installed units between the thermal oxidizer and the scrubber systems, there is not sufficient room to install a flow metering device and measure a ccurate flow rate s according toPVC Section 114 Testing Questions 10/2/2009 Page 6 of 13 standardized testing methods. A ny flow measurement under these constraints could produce erroneous volumetric measurements and hence inaccurate mass flow rates.

We are allowing for all post therm al oxidizer measurements to be moved to after the scrubber.

ii. Even if a sufficient pipe run did exis t, 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 ex haust from the fire box, the ductwork is refractory brick-lined. It is neither sa fe 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. Spec ial pipe or duct spools would need to be shop fabricated to include this por t and its integral protective heat resistant and corrosion resistant linin g. Even with a protective engineering design and a thermal and corrosion re sistant material-of-construction, a sample port will always be a poten tial source of leakage and corrosion. Thus, plant safety personnel strongl y advise against implementing this type of unsafe practice. While this ma y seem to be a minor project, it could involve considerable work in cluding, but not limited to, relocation of upstream (firebox) and downstrea m (acid recovery/scrubber system) equipment and instrumentation, schedu ling outages to complete the work, fabrication of required components, et c. In summary, the installation of this specific sample port poses a considerable project for each affected

source.
We are allowing for all post therm al 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 orde r to properly install the necessary sample ports for long term safe operations.

We are allowing for all post therm al 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 (b etween the thermal oxidizer and the acid recovery/scrubber system) in favor of the following sampling and testing proposal (pl ease refer to the attached Stac k Testing Block Flow Diagram):PVC Section 114 Testing Questions 10/2/2009 Page 7 of 13 i. Only test inlet streams to the ther mal 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 elemen ts 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 protoc ol for HAPs for the aqueous sample fraction; and

3. Pulls off a volume monitored slipstream of the sampled gas immediately after the third impinge r and routes it either to a Method 320 on-line FTIR for real time analysis of VHAPs or into a Summa canister for subsequent la boratory analysis of the VHAPs of interest using a combination of GC/MS and GC/FID.

We would approve this as an alternativ e 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 a dditional QA/QC spikes and duplicate trains such as outlined in 99.02. Accep table 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 isokin etically 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 industr y recommends that each facility provide for a calibrated mechanical flow measuremen t device in the process stream sent to the thermal oxidizer following the protoc ol 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 thePVC Section 114 Testing Questions 10/2/2009 Page 8 of 13 industry proposes to perform Method 26A non-isokinetically, similar to Method 26. This will enable the mois ture 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 s econd paragraph of Section 1.2: "We believe that testing all the inlets to the control sy stem from all processes prior to them being combusted is needed to adequately characte rize 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 shoul d testing be conduc ted if it is not physically possible to measur e 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 in let 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 a ll other flows to the thermal treatment unit, thus excluding smaller insignificant str eams 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 airPVC Section 114 Testing Questions 10/2/2009 Page 9 of 13 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 desi gned in a flexible manner such that the inlet sampling is conducted a few hours prior to the ou tlet sampling to minimize the amount of analytical equipment that the testi ng contractor needs to bring on-site?

No. Inlet and outlet sampling must be done simultaneously.

g. How does EPA want industry to measur e the emissions (and which emissions) that potentially occur dur ing 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, res in removed from the reactor during hydroblasting or other reactor clean ou t activities, and resin removed from filters or other pieces of equipmen t 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 sou rces, 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 sa mpling 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 no t believe that certain air contaminants (such as methanol or ethylene) are present, is the owner/operato r required to conduct testing for these materials? Can the owner/operator pr opose which VOC to analyze?

Ethylene was inadvertently left in Table 1.3 (See Answer 13). Companies can propose which HAP to analyze based on pr ocess knowledge, process chemistry, andPVC Section 114 Testing Questions 10/2/2009 Page 10 of 13 the type of control technology that is us ed. This would include additives to the process such as initiators, et c. 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 inle t 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 plea se 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 te st 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 esp ecially for other VOC sampling? This dramatically increases the cost of the testing for what appe ars to be an arbitrary and capricious reason.

See response to question 6.a.

15. Why is inlet O2 correction needed? All concen trations are requested to be corrected to 3% O2 on inlet sampling. Typically O2 correctio n 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 br ings no value. Most inlets have neither of these compounds in them by nature. CO is a product of combus tion 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 pr oved 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.PVC Section 114 Testing Questions 10/2/2009 Page 11 of 13 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 wher e this is necessary, moisture and molecular weight bring no value.

Please provide detailed information a nd reasoning on the alternative methods suggested for measurement of flowrates wi thout 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 me t. 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 ve locity 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 a dditional ports in the time frame for response, please provide an alternat ive test matrix and schedule in the testing protocol for our approval.

ii. FTIR - Organic HAPs have been samp led 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 me thane. 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.PVC Section 114 Testing Questions 10/2/2009 Page 12 of 13 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 mo re information than the FTIR data.

We agree that Method 0010 could pote ntially 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 M 18 daily for 30 days is very expensive to prove that methane is not present at the outlet.

Guidance on 30-day sampling and methan e analysis can be found in the FAQ and guidance documents developed by the Emissions Measurements Center for the section 114 boilers/CISWI test ing. 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 con cerns with using EPA Reference Method 23 for specific portions of this testing. Met hod 23 might be acceptable for sampling (only!) for PCB. However it is not validated for it. Bu t in terms of analysis for PCB this method is non-adequate as it is exclus ively 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 move d to the outlet of the scrubber. Please use CARB 428 for PCBs or suggest an altern ative method in your testing protocol.PVC Section 114 Testing Questions 10/2/2009 Page 13 of 13 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 drye r and its ancillary e quipment? You will check with others in your organization to cl arify 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 em issions may be all that is required for this section of the operation.

The 30 day CEM testing (CO/T HC/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 emissi ons 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 “n ormal” please provide an explanation of the conditions that make this period different from “normal” operations. Page 3 of Enclosure 1, Attachment B specifies the proc ess 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 rationa le 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 rulemaki ng efforts for the development of a NESHAP for polyvinyl ch loride and copolymer production under section 112 of the Clean Air Act.

a. As the test methods indicated in th e 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 th e 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.