‐ 1 ‐ 

Form / Question Deer Park PVC Pasadena PVC

B‐1:   

Changed Intrinsic Viscosity to

Inherent Viscosity

Reported Inherent Viscosity Reported Inherent Viscosity

C‐1‐c:

Corrected the Liquid Loading

Rate from L/m3 to gpm

Reported in units of gpm Reported in units of gpm

D:

Changed "Does the heat

exchange system cool process

fluids that

contain HAP?" to "Does the

heat exchange system heat or

cool process

fluids that contain HAP or

VOC?"

The question was interpreted

for both heating and cooling

media.  The non‐HAP

containing stream is identified

as the “cooling water” stream.

The question was interpreted

for both heating and cooling

media.  The non‐HAP

containing stream is identified

as the “cooling water” stream.

J:

Corrected the reference from

Form G‐1 to Form I

No impact on submission No impact on submission

K‐1‐a:

Changed flow rate units from

"scfm" to "dscfm" (cell E16).

(Did you submit your data in

dscfm?)

Assume flow rates are dscfm.   Assume flow rates are dscfm.

K‐1‐b:

Changed units from ppmv to

allow users to select "ppmvd

@ 3% O2", " ng/dscm @ 3%

O2" or "ug/dscm @ 3% O2"

ppmvd @ 3% O2. Oxygen

levels in our dryer stacks were

measured O2 and corrected

K‐1‐b sheets will be submitted

shortly. Note values are

calculated based on

conservative resin mass

balance data.

ppmvd. Dryers are steam fired

and available data indicates

O2 is 20.9%. Therefore no

basis for making an O2

correction. Note values are

calculated based on

conservative resin mass

balance data.

K‐1‐c:

Added a "Basis for Emissions

Values" column for each HAP

instead of only one column

for all HAP.

Data that is reported is

compiled from the 2008

Emission Inventory Report

and engineering estimates

based on sampling results of

the slurry.

Data is reported based on

previous resin sampling.    
  ‐ 2 ‐ 

Form / Question Deer Park PVC Pasadena PVC

K‐2‐a:

Added a "Basis for Flow Rate

Value" column for each

Process Stream ID instead of

only one column for all

Process Stream IDs at the

end.  Added text at the top of

the Form to clarify that "This

Form

should be completed for

streams of ALL phases, except

gas/vapor

streams."

The single basis column was

sufficient to describe the

source for the data.   

The single basis column was

sufficient to describe the

source for the data.   

K‐2‐b:

Removed "Units" columns and

the option to select "ppmv" or

"ppmw"‐‐consolidated with

'Concentration" column.  (Did

you submit your data in ppmv

or ppmw?)

ppmw ppmw

K‐3‐b:

Removed "Units" columns and

consolidated with

"Concentration" column

No impact on reported values No impact on reported values

L:

Changed "Concentration at

Equipment Opening" units to

"ppmvd @3% O2".  (Did you

submit your data in ppmvd

@3% O2?)

Assume data is ppmvd.  

However, the concentrations

were not corrected to 3%O2,

as we didn’t see that this

conversion was applicable.

Assume data is ppmvd.  

However, the concentrations

were not corrected to 3%O2,

as we didn’t see that this

conversion was applicable.
  ‐ 3 ‐ 

Form / Question Deer Park PVC Pasadena PVC

M:

Changed "Concentration

Immediately Prior to Removal

From Equipment and Before

Being Mixed With Other

Materials or Fluids (ppm)"

to "Concentration in Resin or

Resin Slurry Immediately Prior

to Removal From Equipment

and Before Being Mixed With

Other Materials or Fluids

(ppmw)" (Cell C18).  (Did you

submit your data in ppmw?)

No impact on reported values No impact on reported values

N:

Changed "Concentration

(ppm)" to "Concentration

(ppmw)"   (Did you submit

your data in ppmw?)

No data was available, so no

values were reported.

No data was available, so no

values were reported.

O:

Changed "Number of

turnovers per campaign" to

"Number of

turnovers."  Changed

"Concentration (ppm)" to

"Concentration (ppmvd @ 3%

O2)".  Added a column for

"Total Emissions (pounds)".  

(Did you submit your data in

ppmvd @3% O2?)

Concentration data was not

known, so no concentration

data was reported.   

Pls see information below on

tanks represented on Form O.

OxyVinyls Pasadena PVC Form O

    

General  

Comments:

In completing this form, no oxygen correction factor was applied to

any of the reported concentration data.  Most of the concentration

data that is reported is theoretical and not based on actual

measurements.  The below provides some additional comments for

each piece of equipment that was reported.  For several of the items,

no concentration data was available or reported because a theoretical

number could not be determined.     
  ‐ 4 ‐ 

Equipment

ID Description Comments Concentration data?

U1025 Amine Tote

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85

There were no reported

known concentrations

reported for this equipment.

U1002 Big Gas Holder

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85

There were no reported

known concentrations

reported for this equipment.

U‐121

Catalyst

Storage Tank ‐ 

LA

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85   

U‐120

Catalyst

Storage Tank ‐ 

LB

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85

There were no reported

known concentrations

reported for this equipment.

U‐122

Catalyst

Storage Tank ‐ 

LD

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85

There were no reported

known concentrations

reported for this equipment.

U1218 CEW Tanks

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85    

U1217

Methanol

Storage Tanks

Tank is maintained with a nitrogen pad to ensure no

oxygen content; correction multiplier would be 0.85    

U‐110

PV Storage

Tank

Tank is maintained with a nitrogen pad to ensure no

oxygen content; correction multiplier would be 0.86    

U‐112

Reactor

Coating

Storage Tank

Tank is maintained with a nitrogen pad to ensure no

oxygen content; correction multiplier would be 0.87

There were no reported

known concentrations

reported for this equipment.

U1205 REW Tanks

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85    

U113‐U‐114

Shortstop

Tanks Nitrogen pad

There were no reported

known concentrations

reported for this equipment.

U1012

Small Gas

Holder

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85

There were no reported

known concentrations

reported for this equipment.

U1026 TBC Tote

Closed process tank with no expected oxygen

concentration; correction multiplier would be 0.85    

      

Correction Multiplier = (20.9 ‐ 3) / (20.9 ‐ measured value)