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 two
PVC 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)