April 1, 2014 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

Mr. Sam Striegel, Plant Manager 

Lubrizol Advanced Materials, Inc. 

4200 Bells Lane 

Louisville, Kentucky 40211 

Dear Mr. Striegel: 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) 

is collecting information to characterize hazardous air pollutant emissions from process wastewater and 

copolymer resin production at polyvinyl chloride and copolymer (PVC) production facilities. 

PVC production is currently subject to the provisions of 40 CFR Part 63, Subparts HHHHHHH and 

DDDDDD. The purpose of this request is to gather data to inform a potential reconsideration of the 

process wastewater and copolymer stripped resin emission standards contained within subparts 

HHHHHHH and DDDDDD and, if necessary and appropriate to support the development of revised 

process wastewater and copolymer stripped resin emission standards under section 112(d) of the CAA 

applicable to PVC production. The collected data may also be used in analyses of environmental and 

economic impacts of regulatory alternatives. 

We request information on your company's PVC production facility specifically listed below: 

Lubrizol Advanced Materials, Inc. Louisville, KY 

We are providing the survey response forms and the copolymer stripped resin and process wastewater 

sampling response forms in Microsoft® Excel spreadsheet format. 

The requested sampling is designed to collect information on emissions and other relevant aspects of 

copolymer stripped resin and the process wastewater treatment system. Enclosure 1 contains a summary 

of the information we are requesting. 

Supplemental information is contained in the following enclosures: 

Intemet Address (URL) • http://www.epa.gov 

RecycledIRecyclable • Printed wnh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 

, . 
• 

Description Enclosure # 

Summary of Test Procedures, Methods, and Enclosure 1 

Reporting Requirements for Resin and Process 

Wastewater Sampling and Analysis at Polyvinyl 

Chloride and Copolymer (PVC) Facilities 

Section 114 Authority and CBI claims Enclosure 2 

CBI emissions data disclosure Enclosure 3 

Designation of ERG as authorized representative Enclosure 4 , 

Policies and Procedures for handling CBI Enclosure 5 

Certification Statement Enclosure 6 

2014 PVC 114 Wastewater and Resin Sampling N/A 

Workbook 

2014 PVC 114 Wastewater and Resin Sampling N/A 

Workbook Example 

Please e-mail the completed non-confidential survey response to: 

CCG-PVC@epa.gov 

The sampling request is designed to collect emissions information, which by law cannot be confidential 

information. There is a small amount of information requested in the survey concerning production and 

production capacity which you may seek to claim as confidential. If you are submitting confidential 

business information (CBI) as described in Enclosure 3, you must mail a separate CD-ROM or DVDROM disk containing only the CBI portion of your data to EPA. Clearly mark the disk with the words 

"Confidential Business Information" and send via U.S. Postal Service Express Mail, registered mail, or 

private courier to: 

Jodi Howard 

U.S. Environmental Protection Agency 

OAQPS/SPPD/RCG (Mail Code E143-01) 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO 

EPA. 

You are required to return all requested information on or before July 31, 2014. 

Be aware that there are significant penalties for submitting false information, including the possibility of 
fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC §7413). Failure to 

comply fully with this request for information may subject you to an enforcement action. We may use 

any information submitted in response to this request in an administrative, civil, or criminal action. 

If you have questions regarding this request, please contact Ms. Jodi Howard, Refining and Chemicals 

Group, at (919) 541-4607 or howard.jodi@epa.gov. 

Thank you for your assistance in this effort. 

7 Enclosures 

Sincerely, 

~~A- Group Leader 

Refining and Chemicals Group 

Sector Policies and Programs Division 

cc: Alice Simpson, Air Pollution Control Executive Director 

Lubrizol Advanced Materials 

Keith H.Talley, Louisville Air Pollution Control 

Beverly Banister, U.S.EPA, Region 4, Air Division Director