PVC Production Process Wastewater Section 114 Q&A

November 20, 2012

Page 1 of 2

PVC Production Section 114 Process Wastewater Sampling and Analysis Questions and 

EPA Responses

1. Question: Vinyl chloride is included in the list of analytes in Table 1 of Enclosure 1 -

Industry only petitioned for reconsideration of TOHAP limits, as the wastewater data set 

for vinyl chloride was understood to be sufficient. Indeed, the draft 114 request made it 

clear that non-vinyl TOHAPs were to be sampled. Is it now the Agency's intent that vinyl 

chloride must be resampled or did the final 114 request merely reproduce the broader Table 

10 from the PVC MACT final rule?

Response: It is now the Agency’s intent that vinyl chloride be sampled. 

2. Question: We appreciate that certification by a registered Professional Engineer ("PE") is 

not required in the final 114 request, but the certification to be signed by a responsible 

corporate official is unclear as to the state credentials of the PE that is to observe "the 

collection of at least one sample to ensure that proper sampling techniques and handling 

were followed according to the correct methods and procedures specified in this letter and 

has verified that the results are properly documented in the report." Please confirm that the 

reviewing PE does not have to be licensed in the state in which a facility may be located, 

but rather that the PE's knowledge about the sampling and analytical processes is the 

critical consideration.

Response: The reviewing Professional Engineer does not have to be licensed in the state 

which a facility is located, but should be a licensed and practicing PE in the United States 

and should have knowledge of the sampling and analytical processes necessary to complete 

this survey.

3. Question: EPA defines a PVC wastewater treatment system as "a specific technique or 

collection of techniques that remove organic compounds from a process wastewater stream 

before the process wastewater stream exits the PVC production facility." This definition 

affects the Agency's request for wastewater sampling throughout, and has caused quite a bit 

of confusion about the scope of the 114 request. Heretofore, and as set out in the final PVC 

MACT rule, industry has been directed to sample wastewater within the PVCPU before it 

exits the PVC process unit. Is it EPA's intent to expand the scope of sample collection 

beyond the boundary set out by the PVC MACT?
PVC Production Process Wastewater Section 114 Q&A

November 20, 2012

Page 2 of 2

Response: Samples should be taken at the location(s) where process wastewater streams 

exit a process wastewater treatment system that is associated with one or more PVCPU 

(e.g., steam stripper).

4. Question: The analytical requirements indicate that the laboratory must supply 

performance evaluation test results completed within the last year for the compounds of 

interest. Why is this requirement necessary given the performance tests are conducted as 

part of the laboratory accreditation process under NELAP?

Response: If the laboratory has a current valid NELAP certification for the compounds of 

interest, they may submit the proficiency sampling results used for certification, even if the 

results are not within the last calendar year.