Page 1 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 9 70

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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 T riangle 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”) sta ndard 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, 200 9 letter to the Agency which pointed out deficiencies
with a pproved EPA SW

- 846 test methods when applied to PVC resin, o ur member’s ultimate goal is the development of method s 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 av ailable 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 studie s showed the most promise for

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

. Different m odifications 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, t he 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.Page 2 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com The attached letter from ECI provid es the status and presents its conclusion about the development program’s recently completed p hase I. To summarize, ECI is suggesting a hybrid of the studied modifications that appear s to be more promising than either of
the other Method 8260B modifications by themsel ves . 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, w hich is expected to take between 6 and 8
weeks to complete

. If approval f r om 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 di fferent producer facilit ies must be undertaken to achieve desired validation pa rameters. 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

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- 4474