"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 Unitwhich 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)