>>> "Mary Bachynsky/FPC Environmental Dept." <mbachynsky@fpcusa.com> 

8/11/2008 4:26 PM >>>

Hello Greg,

Regarding a list of VI survey participants, an updated list of facilities 

with their status and capacities is attached. When we conducted the survey, 

the participating facilities thought that their individual participation 

would not be disclosed. I can ask their permission to disclose the 

information, but given summer vacations and the like, there will be a delay 

in resolving that question on our end. For that reason, this is an interim 

response. A key goal of the meeting we requested is to ensure that EPA has 

an accurate idea of what these numbers represent and what we think they say 

about the industry. We suspect that an appropriate path forward will be more 

evident after the meeting.

Also attached is an interim response to your questions of July 24, 2008 and 

two updated versions of the HAP emission summary that was previously 

submitted. One version has the four corrected errors highlighted; the other 

does not have the changes highlighted.

The members of the VI's PVC MACT Committee look forward to discussing EPA's 

data needs at our upcoming conference call/meeting.

Best Regards, Mary

-----Original Message-----

From: Nizich.Greg@epamail.epa.gov [mailto:Nizich.Greg@epamail.epa.gov]

Sent: Thursday, July 24, 2008 1:54 PM

To: Mary Bachynsky/FPC Environmental Dept.

Cc: Jason.Huckaby@erg.com

Subject: Re: VI PVC MACT Submittal: Estimated HAPs

Hi Mary,

I'm still trying to see what meeting dates work for us - I do know Sept.

15-26 will not work. In addition to meeting, it would be helpful if

some information cited in your letter could be made available to us.

Below is a list of those items:

Section I addressing the Estimated HAP summary -

- Could the VI provided us with copies of the completed surveys? If

CBI is an issue ww would follow CBI procedures for receiving and

handling the data (which would probably involve communicating with the

individual companies since it is their data).

- Could you provide us with a list of the 18 active plants and the 14

respondents to the survey?

- The paragraph discussing the range of emissions data says that some

data is from stack tests. Stack test data would be very helpful for

updating our emissions information and in addressing the surrogacy

issue. Can the VI provide us with copies of these emissions tests?

Section III addressing VCM Surrogacy -

- 3rd paragraph - it would be helpful to know the population of the

different control devices mentioned. Specifically, the number of

facilities using absorber technology, whether every facility using an

incinerator also utilizes a scrubber and the number of facilities

implementing that approach as well.

- 4th paragraph - is there any test data available for post-combustion

controls for HCl?

Other -

- Exemption for storage vessels and/or transfer operations - what types

of units does the VI have in mind for this exemption?

- Exemption for process steps utilizing "minimal" HAP - The term

"minimal" is hard to quantify. Do these process steps have emission

points? controls?

Let me know if you have any questions.

Thanks. Greg.
"Mary

Bachynsky/FPC

Environmental To

Dept." Greg Nizich/RTP/USEPA/US@EPA

<mbachynsky@fpcu cc

sa.com> "de la Cruz, Peter"

<delacruz@khlaw.com>,

06/27/2008 11:12 <greg_bocchi@plastics.org>, "Mary

AM Bachynsky"

<mbachynsky@fpcusa.com>

Subject

VI PVC MACT Submittal: Estimated

HAPs

Dear Greg;

As promised, attached please find a letter, along with a referenced

enclosure, regarding the Subject issue.

Upon your review please let us know of any questions.

Best Regards,

Mary Bachynsky

<<EPA Surrogacy Letter2008-06-26.doc>> <<VI EPA

Submittal2008-06-26.pdf>>

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>

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