### January 15, 2014

V ia E lectronic and First Class M ail

Ms. Jodi Howard Environmental Engineer , Refining and Chemicals Group

U.S. EPA

– Office of Air Quality Planning and Standards

109 T.W. Alexander Drive

, Mail Code: E143

- 01 Research Triangle Park, NC 27711

Howard.Jodi @epa.gov

RE: Supplement al Information for Reconsideration: **National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and**  **Copoly mers Production**  ( PVC MACT ” ) , 77 Fed. Reg. 22,848 (April 17, 2012)

Dear Ms

. Howard :

As a follow up to the November 19, 2013 conference call and webcast between

the Vinyl Institute PVC MACT Working Group (hereinafter, “Working Group”) 1 

### and the

U.S. Environme ntal Protection Agency ( EPA ” ) , t his submission provides , as you requested, the charts and data presented to the Agency with further explanation. The Working Group remains committed to ensuring that EPA has sufficient data on which to

base a PVC MACT rule that complies with the mandates of the Clean Air Act (the “Act”) and related legal precedents, that allows the PVC and copolymer industry to continue producing the mix of products upon which its customers depend, and that permits U.S. manufacturers to grow their businesses in a competitive global environment. In pursuit of those goals, we would like to reemphasize several critical points as the Agency

considers this submission:

1. The D.C. Circuit has repeatedly held that EPA may reasonably estimate

emissio ns performance provided that it does so based on actual data from the best performers in the industry ;

2. While certain pollution control devices in the PVC industry are well known and achieve a similar level of control, the key to ultimate emission levels is the variability of resin recipe s . Therefore, the best performing “similar” source used to set new source limits, as required by the Act, is the one for which data from a broad array of resin slates is available. This notion also is in keeping with Secti on 112(d)(2)’s mandate that emission control

1 In addition to Vinyl Institut e ( VI ) members Formosa Plastics Corporation, U.S.A., Occidental Chemical Corporation/Oxy Vinyls, LP, Mexichem Specialty Resins Inc

. (formerly PolyOne Corporation ) , Shintech Inc., and Westlake Chemical Corporation, the PVC MACT Working Group has included no n

- VI members The Dow Chemical Company and Axiall (formerly Georgia Gulf) Corporation. The Vinyl Institute, Inc., founded in 1982, is a U.S. trade association representing the leading manufacturers of vinyl, vinyl chloride monomer, vinyl additives and modi fiers, and vinyl compound materials.

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### Page 2 of 29

The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 327 

### measures should not “in any way compromise” trade secrets or intellectual property rights.

The history of this rulemaking supports these points . As we have pointed out before, the D.C. Circuit in Mossville Envi ronmental Action Now v. EPA

, upheld EPA’s determination that it was impossible to determine the best performing five sources in the PVC production category because of the great variability in residual vinyl chloride

monomer ( RVCM ) emissions resulting from product slates

. 2 

### Indeed, the data collected by EPA during this rulemaking further demonstrates that this variability is a result of the type of resin being produced, not the technology or processes applied to control

emission s

.

Although the D.C. Circuit has stated that EPA cannot base the MACT floor exclusively on technology if non

- technology factors , such as inputs, affect emission

levels

, 3 

### nowhere has the court indicated that EPA could so restrict inputs as to change the nature of the product produced by the affected facil i ties

. Restrictions on PVC ingredients are particularly problematic for this rulemaking, as PVC ingredients and recipes are not drop

- in replacement s for the industry’s customer base. 4 

### The problem s in the Agency’s current approach are especially evident in the ne w source emission

limits

, because the limits as currently set would restrict future facilities to the limited product slate used to set the limit.

I. New Source Non

- VC TOHAP Limit for S tripped S uspension R esins Does Not Truly Ref lect the Best Performing Facility

As the Working Group has stated often, t he resin stripper s used in the PVC industry are designed to control VC, the major raw material used and the only common ingredient used within every facility. Although focused on VC control , the resin strippers

also control , to a degree, 5 

### the individual hazardous air pollutants ( HAPs) that constitute total organic HAP ( TOHAP). What drives residual non

- VC TOHAP, however, is the

initial concentration of non

- VC TOHAP in the resin sampl e , which is largely a function of

2 Mossville Environmental Action Now v. EPA, 370 F. 3d 1232, 1242

- 43 (D.C. Cir. 2004). The D.C. Circuit supported the validity of this approach most recently in NACWA v. EPA , No. 11

- 1131 at *32, *69 (D.C. Cir. Aug. 20, 2013) (Sewage Sludge Incinerator MACT case).

3 Sierra Club v. EPA

, 479 F.3d 875 , 883 (D.C. Cir. 2007) (“ EPA ’ s decision to base floors exclusively on technology even though non

- technology factors affect emission levels thus violates the Act. ”).

4 Docket Do cument EPA

- HQ

- OAR

- 2002

- 0037

- 0146 at p. 7

- 11; Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at p. 6

- 7.

5 As noted before, additional stripping to increase removal of HAPs results in significant degradation of

the resin. Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 014 6 at 12, 37; Docket Document EPA

- HQ

- OAR

2002

- 0037

- 0146 at 12, 37; Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0146, Attachment 4 ( Vendor Letters Regarding Stripping of PVC Slurries ) and Attachment 5 ( Powerpoint Presentation from Oxy Vinyls,

LP

– Joint Industry/EP A Meeting, June 30, 2011, Regarding PVC Stripping to Reduce PVC RVCM and Impact of Particle Morphology and Column Operating Parameters )

.

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### Page 3 of 29

The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 327 

### resin recipes and product slates. 6 

### This makes determining “the emission control that is achieved in practice by the best controlled similar source ” 7 

### ( i.e. , the new source MACT floor) practically impossible for TOHAP , beca use sources with strippers capable of the “best” level of performance are not “similar” and residual TOHAP is not indicative

of achievable control.

This issue is most prominent for suspension resins, a subcategory that encompasses a broad range of resin grades , resin recipes

, and product uses

. As discussed with EPA during the November 19 th 

### conference call , the Working Group examined the stripped resin data for suspension resins provided in response to the 2009 Section 114 Request. The interactive databa se demonstrated during the meeting

is included with this letter as Attachment I

. 8 

### As the Working Group noted, when these

different resins (made with different recipes) are compared to the 15 ppm non

- VC TOHAP new source limit for suspension resin

, it is cl ear that very few resins can comply
with this limit, as seen in Figure 1

.

6 Table 1 “Suspension and Dispersion Resin Chemistry” 6 in the Working Group’s comments on the proposed PVC MACT provide s additional information on the roles of different ingredients. Docket

Document EPA

- HQ

- OAR

- 2002

- 0037

- 0146 at 11.

7 42 U.S.C. § 7412(d)(3).

8 Letter designators were assigned to each resin grade to blind the data.

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### Page 4 of 29

The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 327 Figure 1 : Non

- VC TOHAP Concentrations by Resin Recipe

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### Page 5 of 29

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### This fact is unsurprising, given that the facility used to set the new source non

VC TOHAP limit f or suspension resin only manufactured two resins during the sampling period. This limited product slate encompasses only a sliver of the product ingredient and morphology combinations used in suspension resins, as illustrated in Figure 2

.

Figure 2 : Resin Morphology



### Figure 1 also makes clear that the high concentrations observed for some resins

are a function of resin recipe rather than stripper performance . For example, Oxy Vinyls, LP Deer P ark ( Oxy DP) produced several resins that were consistently below the 15 ppm non

- VC TOHAP limit and several resins that were always above the limit. This discrepancy is common to the subcategory, as several o ther facilities produced some resins near the 15 ppm limit and other s significantly above the new source limit

.

Returning to the initial point, recall that the resin stripper is designed to remove VC. Thus, the best measure of whether a resin stripper is performing well is VC

concentration . Viewed from this perspective, some of the so urces and resins that are the worst performers ( for TOHAP ) should actually be considered among the best performers. For example, two resins produced by Axiall Plaquemine had some of t he highest TOHAP concentrations

, but were in the top ten for VC concentr ation. 9


### Moreover, the best performer used to set the new source limit for VC, Formosa Baton Rouge, would be unable to meet the new source TOHAP limit for any of its resins based on the average TOHAP concentration

.

9 Axiall Plaquemine AB and V resins. Plea se note that Axiall is identified as “GG” in Figure 1 and

Attachment I

.

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### Page 6 of 29

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- 327 

### To better illustrate the difficulty in se lecting a best performer, the Working Group

reviewed the VC and TOHAP concentration range and average for each resin grade for

which such data is available . This information

, presented below in Table 1 and included

as Attachment II , demonstrates that only four resins (highlighted in green) could be produced at a new PVC facility to meet both the new source VC and non

- VC TOHAP

limit s on a continual basis. If the low range of non

- VC TOHAP data is used, another eight resins (highlighted in blue) would be exp ected to be made on an occasional basis and meet the new source VC and TOHAP limits. Of the 53 total suspension resins studied during the 2009 S ection 114 Request, some 41 grades would not be able to be produced at all under the new source VC and non

- VC T OHAP limits.

The Working Group recognizes that under the PVC MACT, existing sources must

meet a non

- VC TOHAP limit of 670 ppm . Given, however, that (1) to date the industry has not had to design strippers that control for TOHAP

, and (2) the 15 ppm new so urce limit is based on two resins, none of which can meet the new source VC limits

, W orking

G roup members currently are unaware of any technology that would provide for such combined VC and TOHAP performance across the entire slate of resins produced by

th e industry, even in a newly designed facility. In short, 15 ppm represents a dramatic

reduction in TOHAP by any sort of measure and would appear, by extrapolation, to preclude the continued production of 85% of resins now produced by the PVC industry.

Th e Working Group previously identified the wide variation in stripped resin performance on an individual HAP basis in its August 17, 2013 letter, which further emphasizes the difficulty in selecting a best performer. 10

Table 1 : Stripped Resin Data by Grad e by Producer
(Source: 2009 S114 Request for 30 Day Resin Analysis)
Vinyl Chloride M107 New Source Limit = 7.3 ppm Non

- VC TOHAP New Source Limit = 15 ppm

Reporting Plant Resin Grades Sampled Min.

( ppm ) Max

. ( ppm ) Average

( ppm ) Min.

( ppm ) Max

. ( ppm ) Ave rage ( ppm )

FPC

- LA A,B 0.21 1.11 0.54 35.05 54.63 41.61

A,B,C 1.08 1.08 1.08 54.12 54.12 54.12

A,C 0.14 0.86 0.35 12.95 61.75 41.24

A,C,E 0.11 0.11 0.11 44.37 44.37 44.37

A,D 0.66 0.72 0.69 11.76 38.45 25.10

A,D,G 0.43 0.43 0.43 47.42 47.42 47.4 2

A,E 0.29 1.51 0.73 37.43 44.57 40.86

A,E,F 2.07 2.07 2.07 35.80 35.80 35.80

A,F 0.47 0.47 0.47 36.42 36.42 36.42

A,F,D 0.18 0.18 0.18 36.88 36.88 36.88

A,G 0.22 0.60 0.37 32.09 42.63 36.67

A,G,B 0.26 0.52 0.39 13.46 38.18 25.82

FPC

- TX H,I,K 0.51 1.05 0.70 12.56 25.36 18.70

H,I,K,L 0.54 0.57 0.56 14.28 19.10 16.69

H,I,L 0.52 0.75 0.58 17.11 19.87 18.45

H,J,I,K 0.57 0.68 0.62 15.62 21.05 18.51

H,J,K 0.60 0.75 0.67 17.31 19.80 18.90

10 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at 15.

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### Page 7 of 29

The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 327 Table 1 : Stripped Resin Data by Grad e by Producer
(Source: 2009 S114 Request for 30 Day Resin Analysis)
Vinyl Chloride M107 New Source Limit = 7.3 ppm Non

- VC TOHAP New Source Limit = 15 ppm

Reporting Plant Resin Grades Sampled Min.

( ppm ) Max

. ( ppm ) Average

( ppm ) Min.

( ppm ) Max

. ( ppm ) Ave rage ( ppm )

Axiall

- Aberdeen M 0.26 87.63 29.60 261.92 318.63 285.0 2

N 1.00 100.39 27.27 205.73 228.91 216.44

O 0.17 88.10 9.50 190.44 267.50 231.20

P 1.39 9.02 4.61 226.21 250.42 236.23

Q 150.90 150.90 150.90 250.79 250.79 250.79

R 1.09 7.38 3.23 179.75 213.33 192.20

S 0.14 0.14 0.14 2.56 246.37 124.47

Axial l

- Plaquemine AA 2.25 2.25 2.25 211.96 211.96 211.96

AB 0.27 0.27 0.27 237.80 290.46 264.13

AC 0.32 0.32 0.32 246.80 246.80 246.80

AD 0.41 0.41 0.41 365.76 365.76 365.76

T 0.23 1,063.00 153.35 226.80 346.35 258.40

U 3.82 11.50 8.77 196.01 213.72 2 06.09

V 0.24 0.24 0.24 228.40 258.79 237.72

W 234.86 234.86 234.86

X 0.30 0.86 0.54 226.89 238.37 231.71

Y 2.27 5.05 3.41 119.17 244.43 199.25

Z 19.30 19.30 19.30 229.47 229.47 229.47

Oxy DP AE 0.62 4.28 2.51 15.84 19.42 17.63

AF 0.29 7. 09 2.21 7.55 17.41 10.18

AG 0.11 0.36 0.23 6.57 12.84 9.23

AH 0.06 0.25 0.14 4.65 6.05 5.18

AI 0.03 0.39 0.18 4.60 6.38 5.70

AJ 0.02 0.14 0.06 4.39 6.63 5.27

AK 0.06 109.60 18.49 20.11 24.68 22.22

Oxy Pas AL 2.02 5.65 3.92 48.10 104.90 78.45

A M 0.57 1.06 0.92 94.49 128.52 107.04

AN 0.52 1.10 0.75 74.05 121.25 96.37

AO 2.31 10.60 6.92 42.41 114.32 63.56

Oxy Ptown AP 3.91 33.00 9.52 22.77 95.67 36.63

AQ 0.22 0.52 0.34 12.34 84.61 63.31

AR 0.06 2.61 0.74 27.89 38.82 33.06

Shintech AD AS 2.36 4.98 3.67 67.28 70.05 68.11

AT 1.51 1.82 1.66 67.84 67.93 67.89

AT,AS 4.14 4.14 4.14 67.71 67.71 67.71

AU 0.25 0.43 0.36 67.77 68.15 68.00

AU,AT 1.43 1.43 1.43 67.97 67.97 67.97

AV 0.38 0.38 0.38 68.02 68.02 68.02

AV,AU 0.37 0.37 0.37 68.2 3 68.23 68.23

Shintech PL AX 0.30 3.37 2.01 67.28 68.03 67.72

Shintech TX AW 3.00 9.00 6.81 66.36 67.19 66.75

Westlake

- LA AY 50.37 142.01 96.45 0.09 8.39 0.69

AZ 15.00 40.00 23.88 0.09 5.09 3.19

Westlake

- KY BA 4.90 95.08 29.26 207.41 332.41 247.55

- - 4 Resin Grades that can meet both the 7.3 ppm VC limit and the 15 ppm Non

- VC TOHAP limit are highlighted in green

.

-- 8 Resin Grades that can meet both the 7.3 ppm VC limit and the 15 ppm Non

- VC TOHAP limit some of the time are highlighted in blue

.



### Ult imately, the question is whether the new source suspension resin limit is

based on the best

- controlled similar source

, given the facility resin mix, and whether the limit reflects what is achieved in practice. The Agency is aware that the 2009 Section

114 Request data represents only 44% (53 out of 120) of the total number of

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### Page 8 of 29

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- 3392 Fax (571) 970

- 327 

### suspension resins produced by the industry, as shown in Table 2

. In contrast, W orking

G roup members submitted a 4

- year data set for VC, which we would agree can be

assumed to represe nt most, if not all

, grades produced by the submitting facilit ies. A

similar assumption cannot be made for the non

- VC TOHAP data available to the Agency, however, because the data was obtained only over 30 days of sampling . Such

a small data set raises t he question of whether the TOHAP data fully captures what is achieved in practice.

Table 2: Number of Suspension Resin Grades Sampled in 2009 S114 Request

Company & Facility Resin Type # of Resin

Grades # of Resins Sampled in 2009 S114 Request

Axiall Ab erdeen Suspension 7 7 Axiall Plaquemine Suspension 17 11 Formosa Baton Rouge Suspension 15 7

Formosa Point Comfort Suspension 15 5 Oxy Vinyls, LP Deer Park Suspension 9 7 Oxy Vinyls, LP Pasadena Suspension 6 3 Oxy Vinyls, LP Pedricktown Suspension 10 4

Shintech Addis Suspension 12 4 Shintech Freeport Suspension 12 1 Shintech Plaquemine Suspension 12 1 Westlake Calvert City Suspension 1 1

Westlake Geismar Suspension 4 2

Totals 120 53



### In light of the disparity in TOHAP data, the W orking G roup r eviewed the data provided in Table 1 for indications on how best to identify “ the emission control that is achieved in practice by the best controlled similar source

. ” Table 3 show s the range

of VC and non

- VC TOHAP values for each facility during the 30

- d ay sampling period. The Working Group submits that EPA could use these ranges to develop a reasonable

estimate of the best performing facility , as permitted by D.C. Circuit precedent, that not only provides the needed variability that accounts for the man y different resin grades and their corresponding recipe ingredients, but one that represents what is actually achieved in practice for a number of different resin grades.

Table 3: VC and TOHAP for Suspension Resin Facilities Using 4

- Year and 30

- Day Databa ses *

Rank Suspension Resin Analysis VC 4

- year VC 30

- day TOHAP 30

- day

4 Yr.

VC

AVG Facility #

Resins Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm) #

Resins Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm) Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm)

1 Form osa Baton Rouge 15 0.05 19.83 0.54 0.40 7 0.11 2.07 0.55 0.41 13.21 62.22 39.80 38.84

2 Oxy Vinyls, LP Deer

Park 9 0.01 49.29 0.86 0.40 7 0.06 109.60 4.91 0.41 6.26 24.80 12.11 8.98

3 Formosa Point Comfort 15 0.44 23.63 1.70 1.52 5 0.51 1.05 0.66 0.62 13 .02 26.02 19.08 19.21

4 Shintech Plaquemine 12 0.05 11.04 3.38 3.30 1 0.30 3.37 2.01 2.07 67.53 68.28 67.97 67.99

5 Shintech Freeport 12 0.55 14.82 3.64 3.56 1 3.00 9.00 6.81 7.00 67.36 68.19 67.75 67.74

6 Axiall Plaquemine 17 0.20 35.69 3.68 2.70 11 0. 23 1,063.00 45.56 0.76 128.19 365.76 241.13 235.79

7 Oxy Vinyls, LP

Pasadena 6 0.72 28.33 5.51 4.79 3 0.84 8.85 4.57 5.10 50.96 128.65 77.22 73.92

8 Shintech Addis 12 0.31 24.67 6.11 5.83 4 0.25 4.98 3.02 3.49 67.53 70.30 68.32 68.22

9 Oxy Vinyls, LP

Pe dricktown 10 0.01 73.19 6.89 5.83 4 0.06 33.00 7.63 7.31 12.83 95.94 39.59 33.92

10 Westlake Calvert City 1 0.10 194.10 13.55 9.63 1 4.90 95.08 29.26 21.00 207.56 332.63 247.75 239.46

11 Axiall Aberdeen 7 0.26 163.59 18.65 14.88 7 0.14 150.90 16.42 2.33 181.17 329.72 236.93 233.79

12 Westlake Geismar 4 5.00 201.67 68.91 65.00 2 33.39 142.01 91.93 96.03 0.19 8.49 1.09 0.33

* Data for this table is located in Attachment II

.

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### Page 9 of 29

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- 3392 Fax (571) 970

- 327 

### This is not to suggest that the Agency should set a new source limit by resin typ e

or grade , but rather that simply averaging the VC and TOHAP concentrations to identify the best performing facility overlooks the wide range of resin recipe variability that exists within each facility. New source limits for suspension resin facilities were based on the VC performance of Formosa Baton Rouge, and the TOHAP performance of Westlake

Geismar. The Working Group submits , however, that when taking into consideration

the number of resins sampled, VC and TOHAP concentration ranges , as well as dat a consistency and other factors

, Formosa Baton Rouge should be used to set both the

new source VC and TOHAP limits

.

In reaching this conclusion

, the Working Group first compared the two facilities

with the lowest average 4

- year vinyl chloride data. As T able 4 below indicates, the Working Group noted that the Oxy V inyls , LP Deer Park facility achieved the lowest

level of residual VC in a single sample with a concentration of 0.01 ppm , but had a wide variation in VC profile, as evidenced by the highest mea surement of 49 ppm. Moreover, as both facilities had an identical median of 0.4 ppm

, it follows that the Deer Park measurements above the median were significantly higher than those of the Formosa Baton Rouge facility . Thus, it is not surprising that the Deer Park facility had a higher 4

- year average (0.86 ppm) than the Formosa Baton Rouge facility (0.54)

.

Given that both facilities had a median measurement of 0.4 ppm over four years, and that the lowest VC concentration measured varied by no more than 0.06 ppm, the Working Group submits that the resin stripping performance between the two facilities is nigh indistinguishable, and that any variations can be attributed to differences in resin

slate s

. Critically, a comparison of the 4

- year and 30

- day VC data for the Deer Park

f acility indicates that even after sampling seven resins with less variability

, the median figure for the 30

- day data set was fairly close

, if not identical. The Baton Rouge facility

is the better on e on which to base the n ew source limit, however, because: (1) it produced 15 different resins during the 4

- year data collection; (2) the Deer Park facility is an area source; (3) the Baton Rouge facility is a major source ; and most importantly

, (4) i ts 30

- day VC data produced almost iden tical results to the 4

- year VC data set.

The similarity of the 3 0

- day and 4

- year data set is important because it provides a means of obtaining real world calculations for the UPL developed for the new source limit. The Working Group submits that if use o f the UPL on the 30

- day VC data set yields an estimated future sample value that appears within the 4

- year data set, th en use of the UPL on the 30

- day TOHAP is also supportable

. Indeed, at 7.3 ppm, the new source VC limit does not appear to reflect the le vel of variability achieved in practice by either of the facilities with the lowest VC concentration, and arguably should be raised to

20 ppm to reflect the condition that the new source in practice meet the limit all day and every day, even during startup , shutdown, and malfunction ( SSM) events

. Nevertheless, EPA’s calculation of 7.3 ppm using 99.9 percentile is highly supportable with the data reported in the 4

- year data set.

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### Page 10 of 29

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- 3392 Fax (571) 970

- 327 Table 4: VC and TOHAP Comparison at Best Performer Candidate Facilities

VC 4

- year VC 30

- day TOHAP 30

- day

Facility #

Resins Min.

(ppm) Max.

(ppm) Avg.

(ppm) Median

(ppm) #

Resins Min.

(ppm) Max.

(ppm) Avg.

(ppm) Median

(ppm) Min.

(ppm) Max.

(ppm) Avg.

(ppm) Median

(ppm)

Deer Park 9 0.01 49.3 0.86 0.4 7 0.0 6 109.6 4.9 0. 41 6.3 2 4. 8 1 2.1 9 Baton Rouge 15 0.0 5 19.8 0.54 0.4 7 0.11 2.07 0.5 5 0.41 13.2 62.2 39.8 38. 8

Westlake Geismar 4 5 201.7 68. 9 65 2 33.4 142 91.9 96.0 0. 1 9 8. 5 1.1 0. 33



### Turning to the new source TOHAP calculation, we believe that a similar analysis
supports th e use of the Baton Rouge facility to set the non

- VC TOHAP limit

. The

Westlake Geismar facility produces very few resins and even fewer of these (only two ) were sampled for TOHAP. Indeed, the fact that Westlake Geismar did not achieve its

lowest 4

- year VC concentration (5 ppm) during the 30

- day S ection 114 sampling, suggests that it also did not reach its highest TOHAP concentration during the 30

- day

S ection 114 sampling either during which time the facility’s lowest VC concentration was 33.4 ppm. Given t he apparent inverse correlation at this facility between low TOHAP and high VC concentrations, one would expect a higher TOHAP value than that measured during the 30

- day sampling (8.5 ppm)

, as the resin VC concentration approaches the aforementioned 4

- year low.

C ompare this to Formosa Baton Rouge, which makes 15 resins and sampled

seven grades for TOHAP. Seven resins present greater opportunity to measure variability than two, and the Working Group submit s that the Baton Rouge facility presents the best opportunity for developing the new source TOHAP limit. Using the

99.9 % UP L calculations in Table 5 , the Working Group submits that the new source

non

- VC TOHAP limit should be set at 78 ppm, which corresponds favorably with actual

measurements obtained fro m the Baton Rouge facility. This value is based on the use of 99.9% UPL as further explained below, and is consistent with the 99.9 percentile approach ( i.e.

, 1 in 1,000) used in the determination of the VC limit. The full calculations for these approach es are included as Attachment III

.

Table 5: Non

- VC TOHAP New Source Suspension Resin Limits

Plant Limit Is Based On Non

- VC TOHAP

( ppm ) 99% UPL

( m=1 ) 99.9% UPL

( m=1 ) 99th Percentile 99.9th Percentile

Formosa Baton Rouge 67 78 67 77



### The Working Grou p believes that calculation of non

- VC TOHAP limit using 99.9 % UPL is justifiable over the 99 % UPL since when using the UPL on the 30 day VC data

set, the 99% UPL under

- predicts the top 1% and 0.1% of the data values in the 4 year

VC data set for two out of the three facilities examined , as shown in Table 6.

Table 6: New Source Vinyl Chloride Limit Determination Comparing UPL

Based on 30

- Day Data Set to Maximum Value in 4

- Year Data Set

Plant 30

- Day UPL Is Based On Vinyl Chloride

(p pm )

9 9 % UPL 99.9 % UPL Max . Value From

4 Year Data

Formosa Baton Rouge 3 5 19.83 Oxy Vinyls , LP Deer Park 58 79 49.29

Formosa Point Comfort 2 2 23.63

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### Since the use of the UPL essentially says “99% (or 99.9%) of all future runs will

be below this number

, ” the 4

- year data wa s studied in Table 7 to determine the number of data points over each of these limits and how that compared to 1% or 0.1% of the amount of data points.

Table 7: Number of Data Points Predicted by UPL Above Limit in 4

- Year VC Data Set

Plant 30 Day UPL Is

Based On Count of 4 Year

Data Over 99 % UPL Count of 4 Year Data

Over 99.9 % UPL Count of Total

Data Points 1% of Total Data

Points 0.1% of Total

Data Points

Formosa Baton Rouge 11 6 1

, 446 14 1 Oxy Vinyls , LP Deer Park 0 0 1

, 305 13 1

Formosa Point Comfor t 1

, 056 890 1

, 461 15 1



### The numbers should closely match between the 99 % UPL and 1% columns and

between the 99.9 % UPL and 0.1% columns

, but it comes close for Formosa Baton Rouge

. Examining the 4

- year data set would drive the n ew s ource suspension resin VC limit to be 20 ppm, since the best performer (Formosa Baton Rouge ) must be in compliance all day, and every day, even during startup, shutdown, and malfunction

events. Yet the n ew s ource VC limit was established at 7 .3 ppm

, which is approximately the 9 9.9 percentile limit determined with the 4

- year data set. Given that

the 99.9% UPL for Formosa Baton Rouge calculates to be only 5 ppm VC , the

conclusion can be reached that the 99.9% UPL under

- reports the values for expected future runs. Applying this r easoning and example adds further support for the use of

99.9% UPL for the TOHAP determination using the data from the best performing VC facility. Further examination of the data sets show s that Formosa Baton Rouge and

Formosa Point Comfort composited th eir resin samples during the 30

- day S ection 114 Request

, while Oxy V inyls , LP Deer P ark did not. This would be a further reason to use

Formosa Baton Rouge as the new source facility for determining both VC and non

- VC

TOHAP limits because compliance will b e demonstrated using a weighted average of the resins produced during the sampling period

.

The Working Group submits that comparison of the S ection 114 30

- day sampling data set to the 4 years of samples collected during normal plant operations generally

p rovides a suitable means of validating the UPLs and illustrates that it can be a good predictor of maximum values for the PVC resin industry at the 99.9% level or higher

. The UPL considers the variability of the data only, not the factors that make up tha t variability. In the case of vinyl chloride analysis, a number of factors will influence

minimum and maximum number ranges

, including:

1. Resin slate

– some resins strip more easily than others, so the data represents a different resin slate practically eve ry day;

2. Processing rates

– highly variable from day to day, which will affect stripping efficiency to a degree;

3. Stripper operating conditions

– small changes in temperature and pressure due to system fluctuations will influence residual vinyl chloride

cont ent;

4. Analytical test methods

– there is inherent variability in every analytical test procedure, and test equipment must be calibrated daily to smooth out

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### this variability. We do n o t know the techniques used by each laboratory

, so it is difficult to remove analytical procedure as a variable.

In summary, the Working Group submits that taking into con sideration the issues noted above concerning the resin data sets, variability in resin slates, VC and TOHAP concentration ranges, and other factors, Formosa Baton Rouge should be used to set both the new source VC limit (using the 99.9 percentile approach, which EPA did in the final PVC MACT rule) and the new source TOHAP limit (using a 99.9% UPL) for stripped resin. The Working Group’s calculations can be found in Attachment III

.

II. Approaches for Existing and New S ource L imits for P rocess W astewater

A. EPA Mu st Incorporat e Monthly Averages from 13 Month VC W astewater

Data for Existing and New Source Limits

The Working Group previously provided supplemental wastewater ( WW) VC data

in letters dated A ugust 17, 2013 11 

### and October 31, 2013

. 12 

### Combined, these supplem ental submissions provide d EPA with a total of 13 months of VC data for every facility in the Working Group for which such data is available

. This significantly expands the number of data points (from 211 for the top 5 in the 30

- day data set to 2,986 for the same top 5 in the 13

- month data set) and better supports the use of resulting monthly

averages of wastewater stripper performance for most of the existing PVC facilities in

the U.S. by incorporating data that is more representative for almost all resin grades produced at each facility. The Working Group is unaware of any principled or rational

basis for not i ncorporat ing the full extent of this data into the MACT floor calculations for both existing and new sources so that the VC limits include seasona l variations in production volume s

, process efficiencies , and product slates . Of the wastewater data available to the Agency, only the 13

- month VC data set r eflect s the “ average emission

limitation achieved” and the “emission control achieved in practice

, ” respectively. 13



### The Working Group notes that n ot all facilities had the same number of data points available per month. Since the number of VC sample results for PVC industry wastewater strippers varied from once a month/week to multiple samples per da y, normalization of the data must be done before performing statistical analyses to develop

emission limits. The Working Group expect s that EPA will use the 13

- month data set to determine the best performer s and set the VC WW limits using 13 monthly avera ge s of the top 5 performing facilities. As the Agency has r ecognized in other rulemakings

, the method for determining compliance should reflect the statistical method used to

calculate the MACT floor. Consequently, EPA should allow compliance through

mon thly sample averaging rather than a single grab sample for both VC and TOHAP sampling

. T he resin database illustrates the variation in product slates at any given facility from one day to the next. Because the use of monthly averages to set the WW

limit will not account for the spikes that occur due to product slate variation, monthly

11 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561, Attachment II.

12 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0570.

13 42 U.S.C. § 7412(d)(3).

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### sample averaging for compliance is necessary. Following this concept, the Working Group calculated vinyl chloride limits

, detailed in Table 8

, using 13 monthly averages for

which t he full calculations are provided as Attachment I V

.

Table 8: VC Wastewater Limit Determination Using 13

- Month Data Set

Existing Sources New Sources

Top 5 Facilities Monthly Averages

(ppm , 99 % UPL, m=1) Best Performing Facility Monthly Averages

(ppm , 99 % UPL, m=1) 1. Oxy Pasadena, TX

2. Formosa LA 3. Shintech Freeport, TX 4. Oxy Deer Park, TX 5. Shintech Plaquemine, LA 3.1 1. Oxy Pasadena, TX 0.43



### B. Determining Best Performers for Process Wastewater TOHAP Limits

Wastewater steam strippers used by PVC facilities have been designed to remove vinyl chloride in accordance with the VC NESHAP

. Other non

- VC TOHAP constituents may be removed to a lesser degree than vinyl chloride; however, their

removal has historically not been a design criterion

. T herefore, the floor analysis for other TOHAP needs to focus on the performance for TOHAP using the best performing facilities for vinyl chloride concentration at the outlet of the steam stripper.

Table 9a: Range, Average

, and Median for Vinyl Chloride in Steam Stripped Wastewater

Rank (by 13 Month Avg VC) Wastewater Analysis VC 13 Month VC 30 Day

Homopolymer Facility Total #

Resins Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm) Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm)

1 Oxy Vinyls, LP Pasadena 6 0.01 0.91 0.04 0 .01 0.01 0.91 0.07 0.02

2 Formosa Baton Rouge 15 0.00 17.70 0.11 0.02 0.01 0.20 0.04 0.03

3 Shintech Freeport 12 0.01 1.81 0.11 0.08 0.01 0.08 0.02 0.01

4 Oxy Vinyls, LP Deer Park 9 0.01 4.64 0.28 0.13 0.01 0.95 0.11 0.04

5 Shintech Plaquemine 12 0.01 3.87 0.52 0.48 0.01 0.18 0.05 0.04

6 Westlake Calvert City 1 0.00 123.51 0.52 0.01 0.01 0.01 0.01 0.01

7 Shintech Addis 12 0.03 2.16 0.59 0.64 0.03 0.18 0.08 0.08

8 Axiall Aberdeen 7 0.05 8.01 1.00 0.77 0.39 5.35 1.75 1.43

9 Westlake Geismar 4 0.01 9.6 7 1.20 0.62 0.31 3.60 1.31 1.10

10 Formosa Point Comfort 15 0.01 6.12 1.49 1.57 0.10 0.60 0.20 0.10

11 Axiall Plaquemine 17 0.14 8.78 2.63 2.28 0.14 8.78 2.63 2.28

12 Mexichem Pedricktown 11 0.02 9.63 3.41 2.82 0.02 9.63 4.02 3.60

13 Mexichem Henry 12 0.08 17.84 3.60 1.75 0.08 17.84 7.36 7.14

Rank (by 13 Month Avg VC) Copolymer Facility #

Resins Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm) Min. (ppm) Max. (ppm) Avg. (ppm) Median (ppm)

1 Formosa Delaware 14 0.01 16.78 0.78 0.41 0.10 16.78 1.25 0.38

2 Formosa TX SPVC 20 N/A N/A N/A N/A 1.30 9.89 3.04 2.50



### P roduct slates are the determining factor for TOHAP profiles throughout the PVC
facility . Each of the 177 product grade s produced by the industry has a unique recipe
and yields a unique TOHAP profi le

, reflected in the WW stream at each facility

. Although s team stripp ers designed to remove vinyl chloride also will be effective at
removing other insoluble analytes

, soluble HAPs are not as well remove d

. It stands to
reason that, overall, the best per formers for WW stripping of organic HAPs are those
that achieve in practice the lowest VC effluent concentration. Oxy Vinyls , LP Pasadena

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### plant, the best VC performer, has very comparable TOHAP performance to the rest of
the industry when soluble analytes are not included in the sum, as depicted in the far
right columns of Table 9b

.

T he full set of steam stripped WW data submitted to EPA ( see Attachment IV )

, as summarized and presented in Table 9a and Table 9b, helps to illustrate this point across the industry

. 14

Tabl e 9b: Range, Average

, and Median for TOHAP in Steam Stripped Wastewater

Rank (by 13
Month Avg
VC) Wastewater Analysis Non

- VC TOHAP 30

- day Non

- VC, Non

- Soluble (Acetophenone

& Methanol E xcluded) TOHAP 30

- day

Homopolymer Facility Total #

Resins Min.
(ppm) Max.
(ppm) Avg

. ( ppm) Median
(ppm) Min.
(ppm) Max.
(ppm) Avg.
(ppm) Median
(ppm)

1 Oxy Vinyls, LP Pasadena 6 543.27 1,083.13 770.63 753.61 14.71 19.06 16.39 16.14

2 Formosa Baton Rouge 15 18.32 107.65 44.20 37.06 4.76 64.31 17.36 11.72

3 Shintech Freeport 12 46.68 66.24 53.64 51.70 8.24 15.32 13.37 14.05

4 Oxy Vinyls, LP Deer Park 9 18.77 27.79 23.66 23.45 13.66 17.64 15.22 15.16

5 Shintech Plaquemine 12 61.51 106.71 78.61 77.66 10.37 19.72 16.17 16.51

6 Westlake Calvert City 1 14.72 76.38 37.15 35.99 1.32 11.65 3.51 1.77

7 Shintech Addis 12 36.41 81.62 56.64 55.57 6.86 14.26 12.70 13.16

8 Axiall Aberdeen 7 25.48 2,349.68 580.25 209.64 5.14 73.51 12.56 8.42

9 Westlake Geismar 4 12.22 252.94 73.41 35.05 1.38 11.95 4.61 4.31

10 Formosa Point Comfort 15 113.02 22 6.77 154.27 152.98 2.78 18.92 7.33 5.95

11 Axiall Plaquemine 17 18.39 803.57 209.99 71.70 4.59 32.19 13.71 12.52

12 Mexichem Pedricktown 11 23.66 102.50 49.96 45.23 13.77 43.98 18.89 17.96

13 Mexichem Henry 12 3.98 38.62 17.60 16.76 1.97 16.49 11.88 11. 94

Rank (by 13
Month Avg
VC) Copolymer
Facility # Resins Min.
(ppm) Max.
(ppm) Avg.
(ppm) Median
(ppm) Min.
(ppm) Max.
(ppm) Avg.
(ppm) Median
(ppm)

1 Formosa Delaware 14 15.53 10,946.61 585.25 36.91 8.98 10,943.74 452.39 18.41

2 Formosa TX SPVC 20 21. 92 4,541.10 458.56 216.49 21.18 4,540.74 454.39 216.15



### One question that may arise is whether additional steam stripping of wastewater, as opposed to resin which would experience degradation, is feasible. As the Agency has recognized in other MACTs, 15 

### ho wever, although repeated stripping of wastewater would seem to be intuitive as a method of control, such repetition, in fact, does not

overcome the technical limit s from efforts to strip out partially soluble and soluble HAPs. The stripped WW data for the best performer in the industry from a vinyl chloride perspective, Oxy Vinyls, LP Pasadena, shows that even after steam stripping the WW to remove as much vinyl chloride as possible, significant amounts of soluble analytes

can still remain.

14 Please note that data from Dow was not available.

15 The Miscellaneous Organic NESHAP ( MON ) , the Hazardous Organic NESHAP ( HON ) , and the Pharma MACT all incorporate separate control approaches for WW streams with high concentrations of soluble HAPs, which cannot be effectively removed via WW steam stripping.

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### Indeed, the dat a in Tables 9a and 9b confirms that repeated steam stripping of WW from a PVC facility can be very effective for controlling insoluble analytes such as vinyl chloride, but not as effective at removing partially soluble and soluble analytes

such as methanol . Indeed, Oxy Vinyls, LP Pasadena, the best performer for low VC

concentration in stripped wastewater with an average VC concentration of 0.04 ppm

, has a non

- VC TOHAP concentration range of 543 ppm to 1083 ppm. Conversely, Mexichem Henry had the highest average VC in WW (3.6 ppm) yet had one of the

lowest non

- VC TOHAP ranges (4 ppm to 39 ppm).

Some 54 resin grades were produced at the top 5 VC facilities identified in Table

9a , which equates to just over 10 resin grades per facility. If EPA were to bas e its non

VC TOHAP limit on the data associated with the top 5 VC performers, the limits would address product variability by including a broad spectrum of resins in calculating the

limit. Note that producers such as Oxy Vinyls, LP mak e different resin gr ades at its Pasadena and Deer Park facilities, both in the top 5 for VC performance. Likewise

, Shintech uses different resin recipes at its Freeport, Texas facility than what is being made at its Plaquemine, Louisiana plant, also both in the top 5 for VC performance.

C. Copolymer Production Should be Subcategorized for Wastewater

Examination of the non

- VC TOHAP data reveals that facilities that make both PVC and copolymer resins have unique WW emission profiles that reflect the comonomer used. Days of copoly mer production at Formosa’s Delaware and Point Comfort SPVC plants are readily identifiable by their vinyl acetate profile in their WW. 16


### As the Working Group has previously advised, vinyl chloride has low water solubility (2.7 g/L), yet a relatively high Henry’s Law coefficient (2.65 x 10 - 2 

### atm

- m 3 

### /mol), 17 

### which reflects a high level of volatility. Thus, steam in proper proportions and in a properly designed and operated wastewater stripper is the most practical and efficient design for removing vinyl chlori de and other relatively insoluble organics in wastewater. Vinyl acetate is much more soluble in water than VC, making it more difficult to control using steam stripping. Compared to vinyl chloride, v inyl acetate has moderate water solubility (23 g/L)

, 18 

### a nd a low Henry’s Law coefficient ( 5.1 x 10 - 4 

### atm

- m 3 

### /mol), 19 

### which reflects a

low level of volatility. Vinyl acetate may not be fully removed by a wastewater stripper,

but should have a low HAP emission rate from the wastewater stream in any case.

As shown in Table s 9a and 9b , the WW at these two facilities contains higher

non

- VC TOHAP, yet these plants’ VC performance coincides with the rest of the industry. Examining non

- VC TOHAP data in Table 9b shows Formosa Delaware values ranging from 15.5 to 10,900 p pm and Formosa TX SPVC values ranging from

16 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 , Figures 4 & 5, at 28, 29.

17 EPA, Air Emissions Models for Waste and Wastewater, Appendix C. EPA

- 453/R

- 94

- 080A.

18 Celanese Product Description and Handling Guide V inyl Acetate, Nov. 2011, http://www.celanese.com/

- media/Intermediate%20Chemistry/Files/Product%20De scriptions/Product_Description_and_Handling_Gu

ide

- Vinyl_Acetate.pdf

.

19 EPA, Air Emissions Models for Waste and Wastewater, Appendix C. EPA

- 453/R

- 94

- 080A.

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### 21.9 to 4,540 ppm. Thus, the data supports the proposition that wastewater from a facility’s copolymer operations should, at the minimum, have a separ ate non

- VC TOHAP limit from that facility’s PVC homopolymer op eration. The Working Group recommends that copolymer operations, during which the separate copolymer limits would apply, be defined as those when the vinyl acetate concentration in the WW a t the stripper exceeds 50 ppm. A concentration

- based trigge r is necessary because some facilities use a batch WW stripper, such that days of copolymer production do not necessarily correspond with the days the copolymer WW will be stripped.

D. EPA’s Original 1,000 ppm TOHAP Limit is Supported by the Data

The Working Group continues to believe that a 1,000 ppm non

- VC TOHAP limit

, as originally proposed by the Agency, 20 

### is the best approach ; the rationale for this approach is discussed in detail in the Working Group’s August 17, 2013 letter, along with the negative conse quences that will result if producers are no longer able to

manufacture certain resin grades. 21



### The WW data submitted to EPA indicates that a non

- VC TOHAP wastewater limit of 1,000 ppm is justifiable. As depicted in Table 1 0

, u sing the top 5 VC performers to

determine the non

- VC TOHAP limit

, at 99% UPL the limit calculates to be 770 ppm and at 99.9% UPL the limit calculates to be 970 ppm . The Working Group notes that limits calculated using this approach appear to adequately address soluble HAPs and suppor t the Agency’s original proposal to set the limit at 1,000 ppm TOHAP. It should be

mentioned that a 99.9% UPL considers more fully the SSM scenarios now mandated to be controlled as per Section 63.11890(a). Moreover, in concert with the preceding

discuss ion regarding the new source limits for stripped resin and factors contributing to variability, the 99.9% UPL more appropriately predicts this variability for WW in the PVC industry.

Table 10 : Non

- VC TOHAP Wastewater Limit Determination Using 30

- Day Dat a Set and Top 5 VC Performers

Resins Type VC Top 5 Non

- VC TOHAP

(ppm , 99% UPL, m=1) Non

- VC TOHAP

(ppm

, 99.9% UPL, m=1)

PVC Homopolymer 1. Oxy Pasadena, TX 2. Shintech Freeport, TX

3. Formosa LA 4. Oxy Deer Park, TX 5. Shintech Plaquemine, LA 770 970

PV C Copolymer 1. Formosa DE

2. Formosa SPVC TX 8,400 30,000 22



### As shown in Table 9b

, the daily high non

- VC TOHAP was 1,08 3 ppm for the Oxy Vinyls, LP Pasadena facility during the 30

- day sampling period. The 30

- day non

-

20 National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers

Pr

oduction , 76 Fed. Reg. 29,528, 29,537, 29,600

- 01 (May 20, 2011).

21 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at 26

– 37

.

22 Given the magnitude of this number, the Working Group recommends EPA determine the limit at 99.9 percentile for the copolymer data repo rted by these facilities.

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### VC TOHAP data set contains 13 data point s out of the total 211 data points that are above the 770 ppm limit

, and 3 data points out of 211 that are above the 970 ppm limit. Although the size of the 30

- day data set is suitable to apply UPL methods for limit
determination, limits based on 99.9 per centile will more appropriately predict what is actually achieved at these facilities across periods of operation far beyond the 30 days

studied

. The full calculations for these approaches are included in Attachment V

. However, the Working Group submits that using the top 5 VC performers to establish

the non

- VC TOHAP limits as described below in Section II.F is the most appropriate method of determining the WW limits separately for soluble and insoluble HAPs

.

E. Soluble HAP Analytes Should be Managed Separat ely from Insoluble

Volatile HAP Analytes

If the Agency is unwilling to re consider their original 1,000 ppm non

- VC TOHAP proposal , another alternative may be feasible: s oluble HAPs conceivably could be regulated sepa rately as was done in the MON, H ON, and Pharma MACT s

. Table 1 1

sets out the PVC MACT WW analyte list and their status under the MON and HON

. In total, MON Tables 8 & 9 encompass 23 of the PVC MACT Table 10 HAPs , while HON

Table 9 encompasses 26 of the PVC MACT HAPs

. T he MON and HON list metha nol and acetophenone as soluble HAPs and the Working Group proposes alternatively that a category of soluble HAPs could be established in the PVC MACT that includes at

least these two HAP chemicals

.

Table 11 : Treatment of PVC MACT HAPs in MON and HON

CAS No. HA P s Listed @ Table 10 of PVC MACT

(Sub part HHHHHHH) Partially Soluble HAP s Listed @

Table 8 of MON

(Sub part FFFF) Soluble HAP Listed @ Table 9

of MON & HON

(Subparts FFFF and G, respectively)

107211 Ethylene glycol

67561 Methanol Yes

75070 Acetal dehyde Yes

50000 Formaldehyde

51285 2,4

- dinitrophenol

98862 Acetophenone Yes

117817 Bis(2

- ethylhexyl) phthalate (DEHP)

123319 Hydroquinone

108952 Phenol

79345 1,1,2,2

- tetrachloroethane Yes

106990 1,3

- butadiene

540841 2,2,4

- trimethylpentane

71432 Benzene Yes

108907 Chlorobenzene Yes

67663 Chloroform Yes

126998 Chloroprene Yes

98828 Cumene Yes

75003 Ethyl chloride (Chloroethane) Yes

100414 Ethylbenzene Yes

107062 Ethylene dichloride (1,2

- Dichlor oethane) Yes

75343 Ethylidene dichloride (1,1

- Dichloroethane) Yes

74873 Methyl chloride (Chloromethane) Yes

75092 Methylene chloride Yes

110543 n

- Hexane Yes

108883 Toluene Yes

71556 Methyl chloroform (1,1,1

- Trichloroethane) Yes

79005 1 ,1,2

- Trichloroethane

108054 Vinyl acetate Yes

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- 327 Table 11 : Treatment of PVC MACT HAPs in MON and HON

CAS No. HA P s Listed @ Table 10 of PVC MACT

(Sub part HHHHHHH) Partially Soluble HAP s Listed @

Table 8 of MON

(Sub part FFFF) Soluble HAP Listed @ Table 9

of MON & HON

(Subparts FFFF and G, respectively)

593602 Vinyl bromide

75014 Vinyl chloride Yes

75354 Vinylidene chloride (1,1

- Dichloroethylene) Yes

1330207 Xylenes (isomers and mixtures) Yes



### F. Establishing Separate Limits for Soluble an d Insoluble TOHAPs

Should EPA decide to set separate limits for copolymer wastewater, the n the Working Group suggests that EPA consider one of two approaches for calculating the

non

- VC TOHAP limits. The alternative approach depicted in Table 12 ( see Attac hment

V ) uses the top 5 VC performers to set the TOHAP limit s using a 99 % UPL. In this alternative, soluble HAPs (methanol and acetophenone) are segregated and their limit s determined separat ely, and the remaining non

- VC TO HAPs are determined without the soluble components. For copolymer operations, the limit for vinyl acetate is calculated separately instead of soluble TOHAPs using only the data points for copolymer production at those facilities (>50 ppm at Formosa ’ s Point Comfort SPVC plant and the designated copolymer data at Formosa ’ s Delaware plant )

.

Table 1 2 : Alternative Limit for Non

- VC and Non

- Soluble TOHAP with Solubles Separate (Methanol, Acetophenone)

Resin Type VC Top 5 Non

- VC & Non

- Soluble

TOHAP

(ppm , 99 % UPL, m=1) Soluble HAP (Methanol & Acetophenone)

(ppm, 99 % UPL, m=1)

PVC Homopolymer 1. Oxy Pasadena, TX

2. Shintech Freeport, TX

3. Formosa L A

4. Oxy Deer Park, TX

5. Shintech Plaquemine, LA 45 1,100

Non

- VC & Non

- VA TOHAP

( ppm ) Vinyl Acetate

( ppm )

PVC Copolymer 1. Formosa DE

2. Formosa SPVC TX 340 38

, 000



### G. EPA Should Rely on 99.9% UPL for TOHAP Limit Determination and Monthly Average Compli ance Sampling

In vacating the Part 63 SSM exemption, the D.C. Circuit stated that the Clean Air Act requires “ continuous section 112

- compliant standards .” 23 

### Thus, the PVC MACT requires that facilities be in compliance with the process WW limits during all types of emission events (normal operations, startups, shutdowns and malfunction events), per

Section 63.11890(a). Because the Agency is required to base the emissions limits on the actual performance of existing sources, the limits should reflect all ope rating scenarios. There will be times when a WW stripper experiences short

- term upset
conditions or different TOHAP effluent concentration s during a startup or shutdown

23 Sierra Club v. EPA , 551 F.3d 1019, 1027 (D.C. Cir. 2008).

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### event. The TOHAP limit should be inclusive of those times. The necessity of this

app roach is underlined by the method for demonstrating compliance: facilities are to

take a “grab” ( i.e. , instantaneous) sample, so there is no opportunity to average sample results that encompass SSM events over a relatively long period of time

.

The limit ed 30

- day WW data for TOHAP does not adequately capture these operating scenarios. The Working Group suggests two potential approaches. As previously discussed, a 99.9% UPL better addresses variability in TOHAP

concentrations at the outlet of the WW stri pper, whether from differences in resin slates, production rate changes, or SSM events that occur as production lines are switched back and forth from one resin product to another. Using a 99.9% UPL for the TOHAP WW limits would address shortcomings in t he data set with regard to data from

SSM events.

Alternatively, the Working Group strongly recommends that the Agency allow monthly average compliance sampling by allowing the analysis of up to five samples per month, with averaging of all samples analyzed to determine compliance . This approach would match the Working Group’s proposed approach for VC sampling in WW, as discussed in Section II.A of this letter, and appropriately address the comparatively small impact of SSM events on overall WW stripper per formance.

III. Alternative A ppr oaches for P rocess V ent L imits

The Working Group has previously discussed with the Agency the unique challenges associated with applying a process vent limit calculated from facilities using a thermal oxidizer to facilities using vent gas absorbers ( VGA ” ) as a control and recovery device for process vents. In the Working Group’s August 17, 2013 letter, 24 

### we proposed and explained how a mass

- based limit would address VGAs. As we detail below, a mass

- based alternative limit would n ot need to be adjusted based on confidential production volumes.

To address additional concerns raised by the Agency, the Working Group also submits that an outlet flow applicability threshold of one dry standard cubic meter per

minute ( DSCMM ” ) should be included for the mass

- based limit to prevent any emissions performance differences among facilities with like technology and similar size. With these qualifications, the Working Group views mass

- based limits as a necessary option

for EPA to include in th e reconsidered PVC MACT rule.

The Working Group is also concerned by the new source limits for process vents, which do not account for the capabilities and actual performance of the control devices used in PVC facilities. The Working Group submits that th e best performing facility on

the basis of VC should be used to set the limits for new sources for all emissions controlled by the thermal oxidizer, in order to meet the Clean Air Act’s requirement that new source limits reflect what is achieved in practic e.

24 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at 56

- 57

.

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### Page 20 of 29

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### A. Clarification on Production Adjustment for M ass

- B ased L imits

As the Working Group noted in discussions with EPA, process vent volumes are poorly correlated with production rates because the vent volume is driven by the
recovery system. Figure 3 depicts the closed vent system and process vent in an effort to show the typical components, but configurations will vary by plant. Flow from the recovery system is a factor of efficiency and the presence of inerts, non

- condensables, impurities, and byproducts. These factors do not increase linearly with production

, but are driven by recipe and equipment.

Figure 3 : Typical PVCPU Closed Vent Systems



### The Working Group s uggest ed in its August 17, 2013 letter an optional

demonstrati on of compliance for output

- based mass limit s

, acknowledging that compliance would be relatively unchanged between concentration

- and standardized

flow

- based mass limits for most facilities. 25 

### As a result, the Working Group did not propose any production a djustment in its alternate mass limit compliance. The Working Group continues to believe that such an adjustment is neither necessary nor appropriate.

B. Standardized F low Ad justment Mass

- Based Limits a s Alternative or in Addition to Oxygen Normalization for L ow F low (VGA) Process Vent Existing Source L imits

The detailed calculations associated with converting volume based limits in the

final rule to the alternative compliance mass

- based limits and standardized flow adjustments are included in Attachment V I

. In order to prevent any emissions

25 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at 55

- 58.

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### performance differences among facilities with like technology and similar size

, the Working Group suggests that EPA include a n outlet flow applicability threshold for the

mass

- based limit. Examining the flow of the contr ol device for the top 5 PVC

- only plants , reproduced in Figure 4

, indicates they are in a reasonable range of one anot her

. The Mexichem facilities that use VGA s, however, reported significantly lower flow from

the outlet of the control device

. Therefore, it would be a simple matter to apply a low

flow threshold that would permit VGAs to use a mass

- based limit alternative

, but that

would exclude facilities that use a thermal oxidizer . The Working Group proposes that a

threshold of 1 DSCMM would be appropri ate

. Only Mexichem’s VGA units would meet

this criteria because the exhaust flow from the other PVC

- o nly thermal oxidizers are all greater than 10 DSCMM

.

Figure 4 : Top 5 (VC Basis) PVC

- Only Flow Data (Source: EPA 2009 S114 Emi ssions Tests)



### The rationale for establishing a low flow threshold accounts for the difference in technology used to control emissions. When using a thermal oxidizer, enough air is added to the device to combust the supplemental fuel gas and the incoming p rocess vent emissions. This creates a large outflow volume of combustion byproducts and

non

- combustibles in the air (mostly nitrogen based ) from the control device. The volume of this outflow depends primarily on the load of emissions being combusted, the

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### supp lemental fuel type, and the design of the unit. In order to determine comparable emissions performance, the outflow volumes are standardized to the 3% oxygen content typical for what is considered good combustion efficiency in a thermal oxidizer

type cont rol device. Any uncombusted process vent emissions are then divided by the total outflow of combustion gases to determine their concentrations, which typically are in the single digi ts to tens ppm range.

In a VGA

- type device, there are no combustion gas es to divide the uncaptured process vent emissions, so the concentrations will correspondingly be very high. In theory

, the concentration of uncaptured pr ocess vent emissions from a VGA

- type control device should be tens of thousands of ppm since there ar e no other gases to divide the process vent emissions by other than inert gases from system vacuum leaks. In reality, a small amount of absorber liquid is vaporized and emitted along with any unabsorbed process vent emissions and inerts. T he volume of va porized absorber liquid and inerts is simply not comparable to the volume of combustion gases from a thermal oxidizer, thus forcing any device that does not use combustion technology to be automatically out of compliance. T he range of outlet flow of the t op 5 facilities depicted

in Figure 4 is 10.4 to 15.8 DSCMM

. This is in stark contrast to the outlet flow range of

the two Mexichem VGA units of 0.04 to 0.16 DSCMM . Because the VGA outlet flow is
so low, 1 DSCMM would be an appropriate applicability thres hold

.

C. N ew S ource L imits for P rocess V ents S hould be Based on a S ingle

C ontrol D evice for VC, THC, Dioxin, TOHAP and S eparate C ontrol D evice

for HC l

The Working Group is concerned by what appears to be a misapprehension in

the rule about the capabilities o f the control devices used in PVC facilities. Specifically, the use of different facilities to set the limits for individual HAPs appears to be based on

the unsubstantiated belief that plants have the ability to control certain HAPs individually

in a ther mal oxidizer. The data submitted in response to the 2009 Section 114 R equest

demonstrate s that varying levels of VC and other organic HAPs in the control device emissions are a function of combustion efficiency in the firebox , the amount of auxiliary

fuel used, and the process vent destruction load

. A thorough analysis of these factors using the S ection 114 emissions test data would shed light on what is feasible with these control devices in practice.

O peration al factors are significant for combustion efficiency, but it is the physical size and configuration of the firebox , along with the burner technology employed, that

drives combustion efficiency and emissions

. For the PVC

- c ombined category, the Westlake Geismar thermal oxidizer whose thermal input is 87 MM BTU/hr. set the n ew

s ource limit for vinyl chloride

, whereas the Dow Midland thermal oxidizer whose thermal input is 3 MM BTU/hr

. set the n ew s ource limit s for dioxin, TOHAP, and THC. Westlake Geismar’s thermal oxidizer is roughly 30 times larger than the Dow Midland thermal

oxidizer

, yet it must comply with process vent limits determined on a significantly

smaller control device

.

The two control devices can hardly be considered to be of like size and therefore should not be used to set the perfor mance standard for the other , n or can these units be

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### operationally adjusted to control one HAP over another. For reasons set forth in VI’s August 17, 2013 letter, the Working Group is recommending that the Dow control device

not be used as a basis for the PVC

- c ombined process vent category. 26 

### On its face, a

new source emission limit that was developed from various thermal oxidizer sizes, configurations, and burner technologies simply cannot reflect “the emission control that is achieved in practice by the best controlled similar source.”

Different considerations apply for HCl, which is a byproduct of combustion. HC l

is controlled with a separate control device ( a scrubber) and emissions for this HAP can be adjusted through varying the operation of the scru bber.

The b est performing facility ’s thermal oxidizer performance data should be used

to set the limits for new sources in order to reflect what is achieved in practice. The basis for determining which is the best performing control device should be what the control device was designed to c on t rol , namely vinyl chloride. On this basis, Table 13 was prepared to show how the limits for process vents can be determined for the respective categories. For PVC

- o nly using Shintech Freeport data

, there would be n o change in the new source limits for organic HAP and hydrocarbons other than the VC

correction as explained in Section D below

. F or PVC

- c ombined using Westlake Geismar data, however, both the dioxin limit and the TOHAP limit increase as does the

corrected VC . The detailed calculations are included as Attachment VII

.

Table 13: New Source Process Vent Calculations Summary (Other than HCl)

Organic HAP & Hydrocarbon Limits Only Final Rule New Source

Determination Basis VI Proposed New Source

Determination Basis

PVC

- Only

Process Vent Vinyl Chloride, ppmv 0.56 Shintech Freeport 3X DL 0.6 (1) Shintech Free port 3X DL
Dioxin, ng/dscm 0.038 Formosa Delaware 3X DL 0.038 Shintech Freeport 3X DL
Total Hydrocarbon, ppmv as C3 7 Shintech Freeport 99.0% UPL 7 Shintech Freeport 99.0% UPL
Total Organic HAP, ppmv 5.5 Shintech Freeport 3X DL 5.5 Shintech Freeport 3X DL

PVC

- Combined

Process Vent Vinyl Chloride, ppmv 0.56 Westlake Geismar 3X DL 0.6 (1) Westlake Geismar 3X DL

Dioxin, ng/dscm 0.034 Dow Midland 3X DL 0.074 Westlake Geismar 99.0% UPL
Total Hydrocarbon, ppmv as C3 2.3 Dow Midland 3X DL 2.3 Westlake Geismar 3X DL

Total Organic HAP, ppmv 5.5 Dow Midland 3X DL 29 Westlake Geismar 99.0% UPL

(1) This value is based on not including a ‘0’ value in determining the industry average detection limit, as explained below.



### D. EPA Should Correct the Industry A verage Vinyl Chloride Detection Limit

for Process Vents

In calculating the industry average detection limit for vinyl chloride process vents

emissions using the 2009 and 2010 S ection 114 Requests emissions testing data, EPA incorrectly substituted a zero v alue for the detection limit o n the day where no data was reported due to a lab error reported for the vinyl chloride analyte by Formosa Point Comfort, T exas during the facility’s August 2, 2011 test run

. When the zero value is not included, the three tim es method detection limit calculates to b e 0.60 ppm for vinyl
chloride, as detailed in Attachment VIII

.

26 Docket Document EPA

- HQ

- OAR

- 2002

- 0037

- 0561 at 7

- 11.

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### IV. New Compliance Dates Are Needed

A. Uncertainty is Impacting Compliance Planning

As the Agency is aware, the industry has argued that some of the limits

pr omulgated in the final rule constitute clear error. For example, the wastewater limit for existing area sources is based on an erroneous data point from equipment outside the

PVCPU. Accordingly, continued delay in promulgating a reconsidered final rule r aise s significant questions about the feasibility of complying with the current limits. Uncertainty about revisions to other limits ultimately means that industry members simply do not have enough information to design and implement new equipment, if

need ed

.

For example

, the Working Group believes that the stripped resin limits for existing source s are appropriate, and some producers may be able to meet the limits

with l ess complicated retrofits while others will need to replace their strippers alt ogether

. However, these limits were challenged in another party’s petition for reconsideration, which calls into question whether entirely new resin strippers may be required. Facilities are appropriately reluctant to invest in equipment upgrades to meet the limits in the final rule without knowing whether these changes will be sufficient after the reconsideration proceeding.

Some facilities have taken preliminary steps towards compliance, but remaining work could take years, depending on the outcome of the reconsideration process

. For example, some facilities will need to install new wastewater strippers to meet the new requirements, but others may choose to refurbish an existing stripper since only minor improvements in their performance may be needed . The approach a facility takes depends completely on how much improvement in its current performance is needed. Without knowing the final limits, it is impractical to complete a design for either retrofitting or replacing equipment. Resin producers sho uld not be required to expend

resources on equipment or modifications that may in the end not be necessary, or worse, might be insufficient to meet an amended limit.

EPA must understand that the many different control devices within a PVC facility

are all interdependent. The resin stripper rec over s vinyl chloride and other analytes and remaining equilibrium amounts are recovered in the wastewater stripper and eventually

some sent to the process vent control device. A change in configuration of the resin

s tripper will necessarily change the required compliance at the wastewater stripper and thermal oxidizer. In the event that stripped resin limits do not change for existing source facilities, the uncertainty with what the final limits will be for wastewate r strippers and process vents will cause challenges if those control devices must be redesigned to handle a new greater load from a reconfigured or replaced resin stripper. Consider as an example a situation where one site must replace its resin stripper to meet the final PVC MACT stripped resin limits. If that plant’s WW stripper is already operating at its full capacity, then changes must be completed to the WW stripper to accommodate the potentially increased load from the improved resin stripper opera tion. But that plant will not have any final performance parameters to reconfigure its WW stripper design to.

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### It is unfair that PVC producers must be financially penalized by complying with one category of limits ( e.g.

, stripped resins) at one date (April 15, 2015) while other

inter

- related downstream control device limits are corrected (wastewater strippers and process vents) with compliance at a future date, when the design firm handling plant retrofits for compliance needs to have the entire set of limi ts to use as its design basis for equipment configurations and construction, thereby preventing any economy of

scale. More examples of specific impacts of uncertainty are presented in Attachment

IX

, “ Examples of Major Issues of Concern with the Final PVC MACT Emission Limit Compliance Date of April 17, 2015

. ” Repeated shutdowns of resin plan t s to handle changing compliance in a fragmented manner is not only disruptive to that plant and its
customer base, it also creates a very unsafe work environment. Fo r example, shutting down the process vent to add in discharge lines from pressure relief devices is most efficiently accomplished during a plant

- wide shutdown. Performing this while the plant is operating presents enormous challenges and safety considerations.

B. Time Required for PVC Unit Projects

An example of the time required to design, fund, purchase, construct, startup, and permit a PVC resin stripper at the Westlake Chemicals Calvert City, Kentucky facility is shown in Table 14

. This was a new stripper added to an exist ing unit to accommodate higher throughput rates. Start to finish, this project took 26 months, and it was completed during a slow period of construction activity and demand in 2006 through 2008

.

Table 14 : New Resin Stripper Installation, Westlake, KY

Timeframe Activity

Oct 20 06 Column PFD d evelopment

Sep

- Oct 2006 Instrument list and specification

Nov 20 06 Column P&ID development

Apr 20 07 Expansion scope complete

22 May 20 07 Expansion AFE a pproved

Jun 20 07 Column shell design spec sheet complete

July

- August 2007 Tray evaluation

25 Sep 20 07 Kick

- off meeting with engineering firm for construction

11 Nov 20 07 Tray drawings approved for construction

January

- Feb 2008 Civil construction

15 Jan 20 08 PO i ssued for column shell

31 Jan 20 08 PO i s sued for column trays

Mar 20 08 Tray installation at column manufacturer

March

- May 2008 Auxiliary equipment deliveries (pumps, heat exchangers, etc.)

1 Apr 20 08 Column delivery

April 1

- 15, 2008 Column insulated

15 Apr 20 08 Column installed

May 20 08 Piping design complete

19 May 20 08 Structural steel complete

Sep 20 08 Operator t raining

Nov 3

- 7, 2008 Plant shutdown for tie

- ins (5d)

Nov 20 08 Column c ommissioned

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### A second example is provided by Oxy Vinyls , LP in Attach ment X that

documents the time required from start to finish of between 18 to 21 months to retray an existing resin stripper column. A total of six PVC resin strippers were retrayed during its 2006 to 2010 stripper improvement project at the Pasadena, Texas plant pursuant to a

consent decree . As Oxy Vinyls , LP notes in Attachment X

, the need to fully replace a stripper, rather than retray the existing stripper, could significant ly impact the time needed to complete the project.

As a result of expanding supplies of low cost natural ga s and associated light hydrocarbon liquid petrochemical precursors, the level of petrochemical construction activity is accelerating in the U.S. Gulf Coast region where many PVC producers are

located. As shown in Figure 5 , this is already dramatically inc reasing demand for skilled construction and craft workers as construction employment will increase some 35% by 2016. This comes at a time when the PVC producers will be required to retrofit and improve their facilities to meet the new tighter emissions li mits of the PVC MACT

and could extend completion times for these projects.

Figure 5 : Louisiana Workforce Commission

– Workforce Development Task Force



### C. New Compliance Date Recommendations

Based on the real examples outline d abo ve, and given that the process construction industry is heavily booked through this time period

, the Working Group believes significant time will be required to come into compliance. Decisions on the technological approach must be made significantly in ad vance of the compliance date.

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### The Working Group believes that compliance date s less than 24 months ( for retrofits of existing equipment ) or 3 6 months ( for replacement of or add

- ons to equipment ) after the

effective date of the reconsidered rule would be i mpracticable.

V. Summary of Recommendations

The Working Group recognizes that it has proposed or raised a number of different possible approaches to address the issues raised on reconsideration. In order to assist and streamline the Agency’s review, we pre sent below a summary of our

recommendations on the approaches for revising the PVC MACT during the

reconsideration:

A. New Source Suspension resin limits:

1. Determine non

- VC TOHAP limits for suspension resin on the basis of the best VC performer (Formosa Bato n Rouge ) per **Attachment III** ;

B. Wastewater Limits:

1. Exclude Dow Midland data from wastewater calculations since it is not based on comparable source steam stripper technology; and

2. Determine vinyl chloride wastewater limits for existing source s (major and area) using 99 % UPL based on 13

- month vinyl chloride database

per **Attachment IV** ; and one of the following options:

i. Establish separate non

- VC TOHAP limit of 1,000 ppm similar to HON and MON; or

ii. Calculate n on

- VC TOHAP wastewater limits for existing PVC

ho mopolymer sources (major and area) based on top 5 performers for vinyl chloride (using 99% UPL, the Working Group calculated the limit to be 770 ppm ; see **Table 12**  and

**Attachment III** ) . Calculate n on

- VC TOHAP wastewater limits for existing PVC copolymer on ly operations (using 99% UPL, the Working Group calculated the limit to be 8,400 ppm ; see **Table 12**  and **Attachment V** ) ; or

iii. Calculate n on

- VC and n on

- soluble TOHAP was tewater limits for existing PVC homopolymer sources (major and area) based on top 5 performer s for vinyl chloride (using 99% UPL and m=1, the Working Group calculated the non

- VC and non

- soluble TOHAP

limit to be 4 5 ppm and the soluble limit (methanol & acetophenone) to be 1,100 ppm; see **Table 11** and **Att achment** 

**III**

)

. Calculate n on

- VC and n on

- v inyl a cetate TOHAP wastewater limit for existing PVC VA copolymer only operations (using 99% UPL and m=1, the Working Group calculated the

non

- VC and non

- vinyl acetate limit to be 340 ppm and the v inyl

a cetate TOHAP wastewater limit to be 38,000 ppm ; see **Table**

**11** and **Att achment**  **V** )

.
C. Process Vent Limits

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### 1. Exclude Dow Midland data from PVC

- c ombined limit determination;

and

2. Provide alternative mass

- based compliance option for low flow control

devices ( below 1 DSCMM ) using volume concentration limits

converted to mas s limits for all analytes (VC, THC, TOHAP, dioxin, and HCL) and using standardized flow as per Attachment V I ; and

3. For n ew s ource limits for process vents ( PVC only and PVC

combined ) , use a single control device to determine the limits for VC, THC, TOHAP, a nd dioxin based on the best VC performer and set the

HC l limit based on the facility with the best HCl performance as per **Attachment V II** 

; and

4. Correct Process Vent 3X DL to eliminate ‘0’ value in average determination, resulting in 0.60 ppm limit for vinyl chloride , as per **Attachment VIII**

.
D. Compliance Dates

1. Establish new compliance dates 36 months after the effective date of

the final reconsidered rule.

* * *

We appreciate the Agency’s willingness to include our supplemental data

submissions in its determin ation of emissions limits

. The explanations and analysis

included in this letter we re developed to aid the Agency ’s understanding o f the intricate and complicated operations of the industry and the steps needed to continu e the industry’s record of year

- ov er

- year emissions reductions. We welcome an additional

conference call or meeting with OAQPS personnel to go over the details of this

document and its implications for the reconsideration of the PVC MACT rule

. P lease do not hesitate to contact me if you have any questions, or require any additional

information

.

Sincerely,

Richard P. Krock

Technical Director The Vinyl Institute

E

- mail: rkrock@vinylinfo.org

P hone: 571

- 970

- 3392

Cell: 571

- 216

- 4474

cc : Penny Lassiter, EPA

- RTP Mark Kataoka, EPA

- OCG

J ea n

- C yril Walker, Keller and Heckman LLP

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### Vinyl Institute PVC MACT Working Group

Attachment Number Description

Attachment I Interactive Database for Daily Suspension Resin Grade TOHAP by Plant Using 2009 S114 Data

Attachment II Daily TOHAP Ranges for New S ource Suspension Resins

Attachment III Non

- VC TOHAP New Source Suspension Resin Limits

Calculations

Attachment IV Determination of VC Wastewater Limit Using 13 Month Data Set

Attachment V Determination of Non

- VC TOHAP Limit for Wastewater

Attachment V I Conversion of Volume

- B ased Process Vent Limits to Mass

B ased Limits and Standardized Flow Adjustment

Attachment VII New Source Process Vent Limit Calculations Using Single

Control Device

Attachment VIII Correc tion of 3X Detection Limit for Vinyl Chlori de Process Vent

Emissions

Attachment IX Examples of Major Issues of Concern with the Final PVC MACT Emission Limit Compliance Date of April 17, 2015

Attachment X Oxy Vinyls, LP Resin Stripper Reconfiguration Project Time