May 15,2014 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711

Mr. Barry Christenson Air Quality Manager Occidental Chemical Corporation (OxyVinyls, LP) Post Office Box 809050 Dallas, Texas 75380-9050 Dear Mr. Christenson: OFFICE OF AIR QUALITY PLANNING AND STANDARDS

Pursuantto section 114 ofthe Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) is collecting information to characterize hazardous air pollutant emissions from process vents atpolyvinyl chloride and copolymer (PVC) production facilities. PVC productionis subjectto the provisions of40 CFRPart 63, Subparts HHHHHHH and DDDDDD. Thepurpose ofthisrequest is to gatherprocess vent data and other information necessaryto inform ourreconsideration ofthese emissions standards. We request the following testing be performed for your PVC production facility, OxyVinyls, LP

- Deer Park, TX as specifically listed below and discussed inAttachmentB ofEnclosure 1 (tables 1.1 and 1.6) to this letter: Pollutants to be tested HCl ITOHAP

We are also requesting other information regarding PVC production at your facility and are providing the survey response forms inMicrosoft® Excel spreadsheet format. Test results that are collected using test methods that are supported by EPA's Electronic Reporting Tool (ERT) must be submitted using the ERT. We are also providing PVC process vent response forms in Microsoft® Excel spreadsheet format for test methods that are not supported bythe ERT. Please see Enclosure 1, Attachment B for specific ERT submission instructions. The requestedtesting is designed to collect information on emissions and other relevant aspects ofPVC process vents. Enclosure 1 contains a summary ofthe information we are requesting.

Internet Address (URL) • http://www.epa.gov RecyclediRecyclable • Printed**w~h** Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)Supplemental information is contained inthe following enclosures: 

### Description Enclosure# Maximum Achievable Control Technology Enclosure 1 (MACT) Standards Development Information Collection Request Section 114 Authority and CBI claims Enclosure 2 CBI emissions data disclosure Enclosure 3 Designation ofERG as authorizedrepresentative Enclosure 4 Policies and Procedures for handling CBI Enclosure 5 Certification Statement Enclosure 6 2014 PVC 114 Process Vent Testing Workbook NIA 2014 PVC 114 Process VentTesting Workbook N/A Example
The testing request is designed to collect emissions information, which by law cannot be confidential information. You are required to return all requested information on or before 

### November 17,2014. Please e-mail the completed non-confidential survey andtesting workbook response to: 

### CCG-PVC@epa.gov There is a small amount ofinformation requested inthe survey concerning production and production capacity which you may seekto claim as confidential. Ifyou are submitting confidential business information (CBI) as described inEnclosure 3, you must mail a separate CD-ROM or DVD-ROM disk containing onlythe CBI portion ofyour datato EPA. Clearly markthe disk withthe words "Confidential Business Information" and send via U.S. Postal Service Express Mail, registered mail, orprivate courier to: Jodi Howard U.S. Environmental ProtectionAgency OAQPS/SPPD/RCG (Mail Code E143-01) 109 T.W. Alexander Drive Research Triangle Park, NC 27711 DONOTELECTRON!CALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.Ifyou would like to use the required Section 114 testing to satisfythe initial compliance requirements for process vents inthe PVC rules (40 CFRpart 63, subparts DDDDDD and HHHHHHH), please contact Cynthia Kaleri at Region 6, at (214) 665-6772 or kaleri.cynthia@epa.gov to discuss the requirements priorto beginningthe 114 testing. Be aware thatthere are significantpenalties for submitting false information, including the possibility offines and imprisonment as explained in Section 113 ofthe Clean Air Act (42 USC §7413). Failure to comply fully withthis request for information may subject you to an enforcement action. We may use any information submitted inresponse to this request in an administrative, civil, or criminal action. Ifyou have questions regarding this request, please contactMs. Jodi Howard, Refining and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov. Thankyoufor your assistance in this effort.

6 Enclosures Sincerely,



# /)~/'/. 7<,t 

# /

**~&~ ~** 

# (.v

**Petm~** assiter Group Leader Refining and Chemicals Group Sector Policies and Programs Division

cc: Steve Thompson, USEPA, Region 6, Air, Toxics & Inspections Coordination Branch, w/Enclosure 1 only Michael Beatty, TX Commission on Environmental Quality, w/Enclosure 1 only