From:Barry_H._Christensen@oxy.com

Sent:Thursday, April 10, 2014 12:35 PM

To:Barry_H._Christensen@oxy.com

Subject:FW: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1

Attachments:DPPlanCoverPVC MACT 110909.pdf; OxyVinyls Deer Park Test Plan.pdf;

OxyVinyls_ LaPorte VCM_ ThermOxidizer200806Test Report.pdf

-----Original Message-----

From: Christensen, Barry H.

Sent: Friday, February 07, 2014 11:14 AM

To: 'Howard.Jodi@epamail.epa.gov'

Cc: Pryor, Jadie L.; Strain, Deanna K; Krishna, Chris

Subject: RE: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1

Jodie,

In our conversation on Wednesday you indicated you lacked data for some of the

facilities controlling combined PVC plant and other vent gas streams. In one

of our prior meetings, we indicated 2008 HCL/Cl2 test data submitted with our

original test plan for our Deer Park/LaPorte location may have been over

looked. You also mentioned that you have a new Email system and some of your

prior Emails may not have transferred properly.

Enclosed is the original stack test plan for our Deer Park PVC plant which

sends vent gas to our LaPorte EDC/VCM plant. It contains a summary of prior

June 2008 HCL/CL2 test data (page 6-1) that was approved by EPA to be used in

lieu of additional 2009/2010

HCL/CL2 testing.

As indicated below, a copy of the actual 2008 test report was provided on CD

which was submitted to your office separately. The purpose of our 2008 testing

was to demonstrate compliance with our TCEQ permit limit after rebuilding our

scrubbers. For convenience, I added a copy of our 2008 test report to this

mail.

You also had inquired about estimated costs for some additional stack testing

which I have not yet been able to assemble.

If you have questions, please contact me.

Barry Christensen

Mgr Air Quality

Occidental Chemical Corp.

972-404-3209

-----Original Message-----

From: Christensen, Barry H.

Sent: Monday, November 09, 2009 3:55 PM

To: 'CCG-PVC@epa.gov'

Cc: Shirey, Michael E.; Pryor, Jadie L.; 'Howard.Jodi@epamail.epa.gov'

Subject: OxyVinyls (Deer Park, TX) CAA 114 Test Plans - Part 1

Directed to Ms Jodi Howard,

in accordance with your request below and your original 9/21/09 CAA

114 letter, we are submitting plans pertain to our Deer Park site which

operates a PVC manufacturing plant and which qualifies as an area source.

Enclosed are the following:

1) DP PVC Stack test and Misc. Fugitive Source Plan (w/o Appendices, which are

being sent by FedEx).
2) Deer Park PVC plant Resin Sampling Plan

Due to the size of the files, they are split into two Emails.

This Email has the cover letter and Test Plan w/o appendices.

The second Email has the Stack test QAPP and the resin sampling plan.

These documents are also being sent, along with a CD with the appendices, by

Fed Ex. They contain no confidential information.

Should you have questions or wish to discuss, pls contact me at 972-404-3209.

Barry Christensen

Mgr Air Quality

Occidental Chemical Corp.

972-404-3209

-----Original Message-----

From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov]

Sent: Tuesday, October 20, 2009 12:44 PM

To: Christensen, Barry H.

Cc: Kataoka.Mark@epamail.epa.gov; Mia.Marcia@epamail.epa.gov;

Mcalister.Gary@epamail.epa.gov; Gibbs.Jennifer@epamail.epa.gov

Subject: OxyVinyl (Deer Park, TX) 114 Survey Extension Request

Barry,

In your October 8, 2009 letter, you requested that the OxyVinyl Deer Park

facility be granted a 45 day extension "to collect the required

information and submit the survey response." We will not be granting

your request for a 45 day extension for the Deer Park facility's 114 PVC

survey response. The survey is due on November 30, 2009. However, we are

granting you an additional three weeks to submit your PVC test plan for the

Deer Park facility. The test plan is due to EPA by November 10, 2009.

As we previously discussed, you may request that existing stack test data be

considered in lieu of testing. With this request, you must indicate which

parameters you wish to use existing test data for and specify the methods that

were used. You must also submit test reports and any other documentation to

support your request.

Attached to this email, is an example of EPA using area source emissions data

to develop a major source NESHAP. The attachment is the final Brick and Clay

Products NESHAP preamble [68 FR 26690, 26697-98 (May 16, 2003)], which

contains a discussion of the issue.

Thanks.

Jodi

************************************************************

Jodi Howard, Environmental Engineer

U.S. EPA - Office of Air Quality Planning and Standards Sector Policies and

Program Divisions Coatings and Chemicals Group Mail Code: E143-01 Research

Triangle Park, NC 27711

Phone: 919-541-4607 Fax: 919-541-0246

(See attached file: Brick FRN 05162003.pdf)