Page 1 of 3 1737 King Stre et, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271

www.vinylinfo.org www.vinylindesign.com September 22, 2011

Ms. Jodi Howard U.S. EPA

- Office of Air Quality Planning and Standards Sector Policies and Program Divisions Coatings and Chemicals Group Mail Code: E143

- 01 Research Triangle Park, NC 27711

RE: Vinyl In stitute Response to EPA Request for Additional Information on Work Practices for Gasholders at PVC Resin Manufacturing Facilities

– EPA

- HQ

- OAR

2002

- 0037

Dear Ms. Howard,
This letter responds to your e

- mail of September 15, 2011 , requesting any cost and

e missions data to support The Vinyl Institute’s recommendation that work practices
, such as floating objects on water seal s, be used as a means of reducing HAP emissions from gasholder s

. 1 We have consulted with all members of our PVC MACT Working Group, and on their behalf submit the following information:

1. Approximately five years ago, Westlake Chemical’s Geismar, LA facility installed mats on supports over an 18” wide water seal in an effort to reduce fugitive emission s from a 45 foo t diameter gasholder. According to information provided by Westlake, the mats alone cost approximately $3,000. Most of the costs for this option, however, involve the installation of the mats, which includes the installation and use of rigging equipment to lift the mats and other materials into place over tank sidewalls
, in likely congested areas . The Working Group was unable to obtain this information on short notice, but understands that EPA has access to cost statistics for such operations.

2. Golden S pecialty, Westlake’s testing contractor, conducted tests of the ambient air around the Geismar, LA gasholder during the onsite emissions tests for the

1 See Comments of The Vinyl Institute, Inc. PVC MACT Working Group , Document No. EPA

- HQ

- OAR

- 2002

- 0037

- 0146, at 94

- 95

.Page 2 of 3 1737 King Stre et, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

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www.vinylinfo.org www.vinylindesign.com PVC MACT Section 114 request in 2009

. U sing EPA Method TO

- 16
, Long

- P ath Open

- Path FTIR Monitoring of Atmospheric G ases , the measur e ment s were non
detect for HAPs
, including vinyl chloride. Two possibilities explain this result. Either emission s from gasholders have been over
- estimated , or the test method is not appropriate to measure such low level ambient emissions

. 3. Shintech has recently (since the PVC MACT comment period closed) developed an installed cost at their facilities of $ 5 ,000 per gasholder for floating objects on the water seal

. 4. Because measurement of open air evaporation across the gasholder are nearly impossible, resin producers must estimate release amounts from this type of fugitive emission source

. Working Group estimates that floating objects would achieve a 70% in fugitive emissions from gasholders are based on independent laboratory studies th at were reported in Verville J, et. al., Estimation of Vinyl Chloride Emissions from Gasholders and Validation of In Situ Emission Reduction Methods , J Air Waste Manag Assoc. 54(2):172

- 80, Feb. 2004 and is enclosed for your convenience. 2

5. The enclosed articl e reviews several different options for reducing water seal emissions. The PVC MACT working Group has examined each type of installation and concluded that each has its own drawba cks, as explained in our submitted comments. Some floating objects could b ecome dislodged by high winds or clog water transfer systems . Stationary windshields could be damaged by a bell not travell ing completely perpendicular during extension or contraction

. Oil layers may present engineering and operational challenges to thos e facilities not capable of handling oil contamination in their wastewater systems.
Upon reviewing the available information and based on its own plant experience, the PVC MACT Working Group concluded in its comments that a work practice involving floatin g objects on the water seal would be the most effective means for reducing vinyl

2 Journal of the Air & Waste Management Association by AIR & WASTE MANAGEMENT ASSOCIATION. Reproduced with permission of AIR AND WASTE MANAGEMENT ASSOCIATION in the format email via Copyright Clearance Center. Any publication of this article beyond this e
- mail transmission must have permission.Page 3 of 3 1737 King Stre et, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com chloride emissions from the gasholder water seal by an estimated 70% and would be MACT

. The Vinyl Institute hopes this information meets your needs on this important issue. P lease do not hesitate to contact me if you have any questions on this information, or require additional information

. Sincerely,

Richard P. Krock Technical Director
e
- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 571

- 216

- 4474