"Borrelli,

Frank"

<Frank_Borrelli@ To

americanchemistr Greg Nizich/RTP/USEPA/US@EPA

y.com> cc

<akinsk@ggc.com>,

12/21/2007 03:31 <barry_h._christensen@oxy.com>,

PM <david.a.labelle@saint-gobain.com

>, "de la Cruz, Peter"

<delacruz@khlaw.com>,

<dyopak@teknorapex.com>,

"Givonetti, Raymond"

<ray_givonetti@oxy.com>,

<jbell@shin-tech.com>, "John

Yonge" <JYonge@shin-tech.com>,

<mbachynsky@fpcusa.com>,

"Sheridan, Kevin"

<SheridanKevin@westlakechemical.c

om>, "Sistrunk, Otis J. (PED)"

<Otis.Sistrunk@polyone.com>,

"Tinsley, Wendell"

<wtinsley@westlakechemical.com>,

"TOM BERGER" <Berger@khlaw.com>,

<Walker@khlaw.com>,

<Yves.Blanchet@polyone.com>

Subject

VI PVC MACT Submittal

Dear Greg,

As discussed at our meeting, enclosed please find four documents. The

first is an updated list of PVC production facilities, their nameplate

capacities and current operators based on data from CMAI. I have also

included generic process flow sheets that we intend to enhance as we

develop the additional information on HAPs associated with the PVC

process. We think that the flow sheets accurately describe the boundary

of the PVC process as they were part of the docket on the original

NESHAP back in the 1970’s.

The third document is a list of potential HAPs that may be associated

with PVC production. Substances are listed based on responses to a

survey of VI member companies. Please note that we have included

substances in the list even if they were reported by only one facility.

In addition, we listed materials without regard to the amount involved

or potential for emissions. Our goal was to define the universe of

potential HAPs that might fall under the PVC MACT rule with the

understanding that both the need for inclusion in the rule or the need

to develop a surrogacy analysis would come at a later date. The

inclusion of a substance on this list does not reflect any agreement by

the VI or its members that the substance merits regulation under the PVC

MACT. We have not included vinyl chloride monomer on the list because

we understand that the agency will certainly include that HAP in the

regulation. We have attempted to identify the possible source and noted

expected fate of these HAPS following the polymerization step of the PVC

process. A number of these HAPs are identified as VCM impurities.

These HAPS normally exist at trace levels in commercial monomer grade

vinyl chloride. They remain in the vinyl chloride monomer following the

purification steps in a vinyl chloride process as a result of having

similar physical properties, (volatility and solubility), as vinyl

chloride but normally exist at part per million (ppm) levels. In some

cases, certain HAPs would undergo free radical polymerization similarly

to the vinyl chloride and become part of the PVC polymer molecule. In

other cases they may remain and concentrate in the recovered vinyl

chloride until they enter the vinyl chloride process vent gas control

system. I have also included a vinyl chloride specification sheet that

provides expected maximum levels of these impurities in normal

commercial grade vinyl chloride. Actual levels are expected to be much

lower.

We had looked into you concerns on compounding operations and offer the

following. Under the Miscellaneous Organic NESHAP (Part 63 Subpart

FFFF), EPA determined at 40 CFR 63.2435(a), (b) and (c), that a Unit
which is located at, or is part of, a major source of hazardous air

pollutants (HAP) engaged in compounding purchased plastic resin is

exempt from the MACT Standard. This is due to the minimal potential for

emissions from such an operation. For the same reason, EPA determined

that a Unit which is located at, or is part of, a major source of HAPs,

engaged in compounding its own resin is also exempt from the MACT

Standard, as long as the compounding operation does not involve

processing with HAP solvent or the intended purpose of the operation is

to remove residual HAP monomer.

After you have an opportunity to review this information, we would like

to discuss the next steps, which we believe would involve the

quantification of potential HAPS and information regarding surrogacy.

If you have any immediate questions, please do not hesitate to contact

us. As you know I will be retiring at year end and in the interim ask

that you contact Peter de la Cruz of Keller and Heckman and Mary

Bachynsky of Formosa Plastics regarding this program. It has been a

pleasure working with you, good luck with your efforts and have a

wonderful holiday season.

Regards

Frank Borrelli

Mary P. Bachynsky

Formosa Plastics Corp. U.S. A.

9 Peach Tree Hill Road

Livingston, New Jersey 07039

Phone: 973-716-7342 Cell: 862-485-5542

mbachynsky@fpcusa.com

mailto:mbachynsky@fpcusa.com>

Peter L. de la Cruz

Partner Keller and Heckman

1001 G Street, N.W., Suite 500 West | Washington, D.C. 20001

Tel: 202.434.4141 | fax 202.434.4646 | delacruz@khlaw.com

(See attached file: VI PVC MACT Submittal 2007-12-21.pdf)