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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

September 24, 2010

Ms. Jodi Howard

U.S. EPA - Office of Air Quality Planning and Standards 

Sector Policies and Program Divisions 

Coatings and Chemicals Group 

Mail Code: E143-01 

Research Triangle Park, NC 27711

RE: PVC MACT Rulemaking: Update on Vinyl Institute Resin Test Method 

Development Program 

Dear Ms. Howard,

During our August 24, 2010 meeting to discuss the Agency’s forthcoming maximum 

achievable control technology (“MACT”) standard for the polyvinyl chloride (“PVC”) and 

copolymer source category (hereinafter, “PVC MACT”), VI members briefly updated you 

on an ongoing program to study alternative analytical methods to EPA Method 8260B. 

As stated in our November 2, 2009 letter to the Agency which pointed out deficiencies 

with approved EPA SW-846 test methods when applied to PVC resin, our member’s 

ultimate goal is the development of methods that more accurately detect the range of 

HAPs that may exist in PVC resin. 

As you know, in order to develop a more accurate, consistent, test method than the test 

methods available at the time of PVC MACT Section 114 testing, work began on an 

alternative to Method 8260 B in early 2010 when two VI member company laboratories 

studied multiple injection techniques to modify Method 107 and compared this approach 

to the extended heating and purge times at elevated temperatures used to modify 

Method 8260B. These internal comparison studies showed the most promise for 

accuracy was with the modifications to Method 8260B instead of modifying Method 107. 

Different modifications to test method 8260 were submitted by Georgia Gulf and 

subsequently approved for use by EPA for that company's test plan. Based on this

early work, the VI and its members then contracted with Environmental Chemistry, Inc. 

(ECI) to develop additional modifications to Method 8260 in order to maximize method 

performance for PVC resin samples.
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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

The attached letter from ECI provides the status and presents its conclusion about the 

development program’s recently completed phase I. To summarize, ECI is suggesting 

a hybrid of the studied modifications that appears to be more promising than either of 

the other Method 8260B modifications by themselves. ECI has further identified in its 

letter the additional data to be gathered in phase II to be able to demonstrate if method 

performance is indeed acceptable with the hybrid modifications to Method 8260B. VI 

members have not yet approved this work, which is expected to take between 6 and 8 

weeks to complete. If approval from VI members to perform phase II is obtained, VI 

members can move to phase II. Once this phase II is done, we will have a method to 

take to the verification step (phase III). 

In order to complete the verification step (phase III), a sampling round from different 

producer facilities must be undertaken to achieve desired validation parameters. This is 

estimated to take between 8 and 10 weeks to complete. The VI trusts that the Agency 

appreciates the possibility that the hybrid method may not provide acceptable 

performance or achieve verification across various types of PVC resin. However, VI 

members believe the effort to develop and validate test procedures that would provide 

more accurate analysis of key HAPs should continue through to full completion in order 

to make a method determination for rule promulgation.

If after reviewing the attached information EPA would like further discussion or 

clarification on this subject, please do not hesitate to contact me. Thank you for the 

opportunity to submit this additional information. 

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

phone: 571-970-3392

cell: 571-216-4474