PVC Production Process Wastewater Section 114 Q&A November 20, 2012 Page 1 of 2 PVC Production Section 114 Process Wastewater Sampling a nd Analysis Questions and
EPA Re sponses

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. I s 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 a ppreciate 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." P lease confirm that the reviewing PE does not have to be licensed in the state in which a facility may be loc ated,
but rathe r that the PE's knowledge about the sampling and analytical processes is the
critical consideration.

Response: The reviewing Profes sional 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 def inition 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 wit hin 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 pro cess 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 y ear 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 compou nds of interest, they may submit the proficiency sampling results used for certification, even if the results are not within the last calendar year.