>>> "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>

____________________________________________________________ This communication is solely for use by the intended recipient and may contain information that is privileged, confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby formally notified that any use, copying or distribution of this communication, in whole or in part, is strictly prohibited. Unless explicitly stated, this communication does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This communication also does not constitute consent to the use of sender's contact information for direct marketing purposes or for transfers of data to third parties.(See attached file: EPA Surrogacy Letter2008-06-26.doc)(See attached file: VI EPA Submittal2008-06-26.pdf)