OxyVinyls, LP Page 1 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014 

### ALTERNATIVE MONITORING REQUEST
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS FOR

POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION
ADDENDUM TO THE SITE-SPECIFIC PERFORMANCE TEST PLAN DATED JULY 30, 2014 OXY VINYLS, LP DEER PARK AND LA PORTE, TEXAS
The Oxy Vinyls, LP (OxyVinyls) requests that the United States Environmental Protection Agency (EPA) approve alternative monitoring parameters for demonstration of compliance with the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride and Copolymers Production. As stated in the reference Site-Specific Performance Test Plan (Test Plan) submitted on 7/31/14, the Deer Park Plant is subject to the NESHAP for Stationary Polyvinyl Chloride and Copolymers Production Area Sources (PVC Area Source NESHAP) codified in 40 Code of Federal Regulations (CFR) Part 63 Subpart DDDDDD. The process vents from the PVC production facility are controlled by two thermal oxidizers located at the OxyVinyls facility in La Porte, Texas. The La Porte Plant is not a PVC production facility and is therefore not subject to the PVC Area Source NESHAP. However, the thermal oxidizers are the control device for the Deer Park Plant process vent gases.
Also as stated in the Test Plan submitted on 7/31/14, OxyVinyls intends to demonstrate compliance with the emission standards of the NESHAP for Stationary Polyvinyl Chloride and Copolymers Production Major Sources (PVC Major Source NESHAP) codified in 40 CFR Part 63 Subpart HHHHHHH. The additional demonstration (for major source standard compliance) is being included as a possible future scenario that the Deer Park Plant becomes subject to the PVC Major Source NESHAP or other MACT requirements applicable to major sources (e.g., EPA’s developing regulations for ethylene dichloride (EDC)/vinyl chloride monomer (VCM) processes).
Therefore, in accordance with 40 CFR §63.8(f)(4)(i), OxyVinyls is submitting this request as an addendum to the referenced Test Plan to propose alternative monitoring parameters for the performance test (i.e., to establish operating parameter limits). If in the future Major Source NESHAP requirements apply to the Deer Park and/or LaPorte Plants, this AMR may satisfy applicable monitoring requirements.
As required by 40 CFR §63.11985(c)(5) and §63.8(f)(4)(ii), the following paragraphs present:

 A description of the parameter(s) to be monitored to ensure the control technology or pollution prevention measure is operated in conformance with its design and achieves the specified emission limit;

 An explanation of the criteria used to select the parameter(s);OxyVinyls, LP Page 2 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014  A description of the methods and procedures that will be used to demonstrate that the parameter indicates proper operation of the control device, the schedule for this demonstration, and a statement that OxyVinyls will establish an operating limit for the monitored parameter(s) as part of the notification of compliance status if required in the future under this subpart, unless this information has already been submitted;

 The frequency and content of monitoring, recording, and reporting, if monitoring and recording is not continuous; and

 The rationale for the proposed monitoring, recording, and reporting system.
The Deer Park Plant PVC process vent is routed to the La Porte Plant, commingled with the La Porte process vent streams, and controlled by two thermal oxidizers. The exhaust gas from each thermal oxidizer is routed through a waste heat boiler and then a two-stage wet scrubber. The lower section of the two-stage scrubber is an absorber that uses water to recover hydrogen chloride (HCl) to produce hydrochloric acid for plant use. The upper section is a scrubber that uses caustic and sodium thiosulfate to remove any remaining HCl and chlorine (Cl 2 ) from the exhaust gas before being exhausted to the atmosphere.
The following table presents the monitoring requirements in 40 CFR §63.11940(a-c). The monitoring options selected by OxyVinyls in our current plan are indicted by bold face type.

Citation Option 1 (i) Option 2 (ii) Option 3 (iii) §63.11940(a) Flow indicator on

intermittent stream None None
§63.11940(b) Temperature in

oxidizer firebox or in ductwork immediately downstream of firebox N/A – Applies to catalytic oxidizers N/A – Applies to catalytic oxidizers

§63.11940(c)(1) Influent liquid flow

of absorber or scrubber 1 Influent liquid flow None Influent gas stream flow and liquid-to-gas ratio (l/g):

 design blower capacity with adjustments for pressure drop,

 measurement of gas stream flow at absorber/ scrubber inlet, or

 previously determined l/g from compliance testing, if the conditions are representative of current operationsOxyVinyls, LP Page 3 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014 Citation Option 1 (i) Option 2 (ii) Option 3 (iii) §63.11940(c)(2) Pressure at inlet and

outlet of absorber or scrubber, monitoring pressure drop Scrubber gas stream exit t e m p e rat u re , i f Δ T between inlet liquid and inlet gas >38°C 1 Specific gravity on scrubbing liquid inlet a n d o u t l e t , i f Δ P ≥ 0

. 2 s p e c i fi c g ra v i ty units §63.11940(c)(3) 2 pH of scrubber

liquid effluent Caustic strength of the scrubber liquid effluent Conductivity of the scrubber liquid effluent 1 In the 7/30/2014 Test Plan, OxyVinyls indicated monitoring of parameters for the combined two-stage scrubber (i.e., absorber, or lower, section and scrubber, or upper, section). 2 Applicable if the scrubbing liquid is a reactant (e.g., lime, sodium hydroxide).
OxyVinyls is requesting EPA approval to monitor alternative parameters to those proposed in the 7/30/2014 Test Plan, as shown in the attached revised Table 4-1 of the Test Plan. Figure 1 is a process flow diagram of the control devices and the locations of the monitors that were proposed in our 7/30/2014 Test Plan. Figure 2 shows the parameters that are proposed under this AMR and reflected in the revised Table 4-1.
OxyVinyls selected the proposed monitoring parameters because these parameters have been established as indicators of proper control device performance. OxyChem is already complying with the Hazardous Organic NESHAPs (HON) process vent monitoring requirements listed in 40 CFR §63.114, including:

 Firebox temperature,

 Where a scrubber is used with an oxidizer:
o Scrubber effluent liquid pH
o Scrubber influent liquid flow rate
o Scrubber effluent gas flow rate (so that Scrubber l/g can be calculated). The absorber was included in the original Test Plan to enable the measurement of scrubber gas stream exit temperature by the use of existing monitoring equipment (i.e., the temperature difference across the absorber and scrubber combined is >38°C). Operational control is provided on the absorber so that product HCl is supplied to the plant for use. Monitoring of the absorber is not included in this AMR.
Although temperature is sometimes used as a measure of adequate scrubber liquid flow, continuous tracking of scrubber effluent pH, liquid flow rate, and l/g has proven successful in ensuring proper operation of these existing scrubbers. In scrubbers, absorption of acid gases is limited primarily by the amount of reactant available in the liquid phase to react with the contaminant in the stack gas as it diffuses into the liquid. 1 OxyVinyls believes that the proposed monitoring parameters provide effective assurance of HCl emission control. During the stack test the stack gas flow rate will be maximized and the scrubber liquid flow rate will be minimized.

1 Control of Gaseous Emissions – Student Manual APTI Course 415, Third Edition, Section 2.2.2; Author: John R. Richards, Ph.D., P.E., Air Control Techniques, P.C.; Developed by ICES Ltd.; EPA Contract 68D99022.OxyVinyls, LP Page 4 of 4 Alternative Monitoring Parameter Request

Deer Park/La Porte Texas August 21, 2014 OxyVinyls believes that the parameters shown above are adequate indicators of proper operation of the control devices used to comply with the emission limitations. OxyVinyls has demonstrated the adequacy of these parameters in the past:

 OxyVinyls utilizes the above parameters, with less frequent averaging periods, for compliance with the HON requirements listed in 40 CFR §63.113 (process vent provisions) and §63.115. OxyVinyls has conducted compliance performance tests for the HON, and continues to routinely demonstrate compliance with these parameters.

 After rebuilding the La Porte Plant scrubbers in 2007, OxyVinyls measured the above scrubber parameters during a June 2008 stack test conducted for TCEQ to demonstrate compliance and re-establish operating parameter limits (OPLs).

 EPA previously accepted the 2008 HCl test data in lieu of additional sampling for the 2009 and 2011 Section 114 Information Collection Request.
With respect to OPLs, OxyVinyls currently has OPLs established for HON compliance. OxyVinyls will reassess the OPLs as a contingency during the scheduled performance testing in September 2014 and will revise the OPLs in the future, if the test data indicates such changes are appropriate and it becomes a requirement. The existing HON monitoring practices will be revised so that the data acquisition and handling system calculates block 3-hour averages instead of daily average values from the continuous monitoring data. OxyVinyls appreciates EPA’s review and consideration of this AMR. OxyVinyls believes that the information included with this AMR, together with the Test Plan and response to EPA’s request for clarification on the Test Plan provide sufficient documentation for consideration of the AMR. However, if EPA requires additional supporting documentation or clarification, please do not hesitate to contact Ms. Deanna Strain at (281) 476-2909 or Ms. Stephanie Engwall at ( 972) 404- 3291.

### TABLE 

### 4-1 (R EVISED 

### ) C ONTINUOUS 

### P ARAMETER 

### M ONITORING 

### SYSTEMS

“A” O XIDIZER I NSTRUMENT T AG N UMBER “B” O XIDIZER

I NSTRUMENT TAG N UMBER D ESCRIPTION U NITS M EASUREMENT M ETHOD C HANGE F ROM O RIGINAL T EST P LAN D ATED 7/30/2014

FT4286 FT4286 Deer Park Plant process vent flow indicator On/Off Orifice plate and differential pressure transmitter indicating flow by measuring scfh Clarifying flow rate is used to denote when flow is present rather than monitoring a flow rate as an OPL.
TT4528, TT4529 TT4530, TT4531 Thermal oxidizer fire box temperature °C Type K thermocouples and transmitters 1 No change.
FT4197, FT42126A, FT42122A, FT42123A, FT42120A FT4199,

FT42126B , FT42122B, FT42123B, FT42120B Two

- stage Scrubber influent

liquid flow rate (l) 2 gpm, block 3-hr avg. Magnetic flow meters Revising to measuring scrubber inlet liquid flow only (i.e., removing inlet flow monitoring for absorber section of the two-stage scrubber). Clarifying block 3-hr average.

TT45105A TT45105B Two

- stage scrubber exit gas temperature 2 °C Resistance temperature detectors and transmitters Substituting scrubber effluent gas flow rate for this parameter.

FI42101A FI42101B Scrubber effluent gas flow rate (g) 2 acfm, block 3-hr avg. Orifice plate and differential

pressure transmitter indicating flow by measuring acfm Adding this parameter in lieu of scrubber exit gas temperature. Note that l/g is calculated for a block 3-hr block average for the scrubber, not absorber and scrubber combined. AT40032B, AT40032C AT40033B,

AT40033C Scrubber (second stage) effluent

pH 2 Standard units pH probes and transmitters 3 No change.

1 Each thermal oxidizer has two redundant temperature monitors to ensure continuous data availability.
2 Not required to demonstrate compliance with the PVC Area Source NESHAP. However, these parameters are being included in this test plan to allow for a smooth transition to the PVC Major Source NESHAP if ever required.
3 Each scrubber effluent has redundant pH monitors to ensure continuous data availability.