From: Lincoln, Danielle (D)

Sent: 8/30/2005 9:47:16 AM To: Greg Nizich/RTP/USEPA/US@EPA CC: Wozniak, Russell (RA) Subject: RE: HAP Emissions Information for Dow PVC MACT Submittal Greg, Per your request, please find attached an update of Dow's previous PVC MACT Data submittal. We've updated with the current level of control for each possible source of HAP. Additionally, we've included a process description of the Suspension Polymerization Process.

If you have any additional questions, please contact me at 979-238-2346.

Thanks,

________________________________________ Danielle Lincoln EH&S Operations Regulatory Management The Dow Chemical Company 2301 N Brazosport Blvd, B-101 Freeport, TX 77541 979-238-2346

-----Original Message----- From: Nizich.Greg@epamail.epa.gov [mailto:Nizich.Greg@epamail.epa.gov] Sent: Wednesday, July 16, 2008 7:05 AM To: Wozniak, Russell (RA) Cc: Lincoln, Danielle (D); Jason.Huckaby@erg.com Subject: Re: HAP Emissions Information for Dow PVC MACT Submittal Russell, Thank you for the submittal. Below are some comments I sent to Mary and Peter de la Cruz after receiving their submittal, and they apply here as well. I have not received a response from Mary yet. ==> ----- Forwarded by Greg Nizich/RTP/USEPA/US on 06/27/2008 02:48 PM ----- Greg Nizich/RTP/USEPA /US To "Mary Bachynsky/FPC Environmental 06/27/2008 01:50 Dept." <mbachynsky@fpcusa.com> PM cc Jason.Huckaby@erg.com Subject RE: VI PVC MACT Submittal: Estimated HAPs(Document link: Greg Nizich)Mary,

Based on a very cursory review I have the following thoughts - The descriptions and pollutant breakouts are very helpful. Since the main thing that came out from earlier meetings was the variation of products across the industry, we are going to need the data on an individual plant basis since we may develop requirements based on differing end-products (i.e., subcategorization). It's not clear to me in every case if the emission ranges represent values that are controlled or uncontrolled. That could be because I haven't yet looked at the data in conjunction with the flow diagram. A Clarification sent to Peter: With all the issues raised on our rules in the years since the PVC vacature we will have to go through the steps of setting MACT floors and evaluating beyond the floor costs/technologies as part of the rulemaking. Site specific for the processes will be needed to do that.

Let me know if you have any questions. Greg Nizich, USEPA Office of Air Quality Planning and Standards Coatings and Chemicals Group 919-541-3078

"Wozniak, Russell (RA)" <wozniara@dow.co To m> Greg Nizich/RTP/USEPA/US@EPA cc 07/15/2008 05:53 "Lincoln, Danielle (D)" PM <dlincoln@dow.com> Subject HAP Emissions Information for Dow PVC MACT Submittal

Greg, Please find attached process and HAP emissions information for our twoPVC manufacturing processes in the US. We formatted our information in

a similar fashion to the VI submittal sent to EPA in late June. The attachment contains process descriptions and flow diagrams along with tables that contain HAP emissions information. We ask that you please consider these data in conjuction with the data submitted by the VI as you continue with the re-development of the PVC MACT rule. Please note that the process description for our "Suspension Process" is not included at this time, but we did not want to delay submittal of the bulk of the information. We will send this process description to you at later date to complete the file. Danielle Lincoln of Dow's Operations Regulatory Management group worked with our two sites to prepare this information. Please feel free to forward any questions you have to me or to Danielle at 979-238-2346. Regards,

Russell A. Wozniak The Dow Chemical Company EH&S Operations Regulatory Management Office 361-553-2920 Mobile 361-649-2249 -----Original Message----- From: Nizich.Greg@epamail.epa.gov [mailto:Nizich.Greg@epamail.epa.gov] Sent: Wednesday, June 25, 2008 11:51 AM To: Wozniak, Russell (RA) Subject: Re: Dow PVC MACT Submittal: Update to EPA Hi Russell, July 11, or thereabouts, will be fine. We should have no problem evaluating all the data together. Thanks for the update. Greg.

[attachment "PVC MACT 2008-07-15.doc" deleted by Greg Nizich/RTP/USEPA/US] (See attached file: PVC MACT 2008-07-25.doc)