From: Barry_H._Christensen@oxy.com [mailto:Barry_H._Christensen@oxy.com] 
Sent: Friday, April 11, 2014 4:29 PM
To: Howard, Jodi
Cc: Chris_Krishna@oxy.com; Deanna_Strain@oxy.com; John_Westendorf@oxy.com
Subject: Draft PVC Section 114 Process Vent Testing- Comments 

Ms Howard,

From the conversation that we had on Monday April 7, 2014, I understand that 
you are collecting this additional data to fill in some gaps in the combined 
process vent category and intend to gather new emissions data two other 
locations. Since this is the third CAA 114 request to sample our Deer Park 
PVC/LaPorte site, we are disappointed, particularly since we are currently 
engaged in planning to conduct our compliance sampling to comply with the 
deadlines in the final rule which is effective on April 17, 2015.

When we spoke, you indicated that since we did a second test in response to 
the August 2011 CAA 114 request, your final CAA 114 request to us would be 
paired down to testing for THC and TOH, with a possibility for HCL/CL2. Our 
existing HCL/CL2 data was done for a TCEQ compliance test of both of our units 
and was included in our test plan for the August 21, 2014 request. It was 
approved in your series of Emails  from 11/19/09 to 11/23/09. I resubmitted 
our
HCL/CL2 data in the 2/07/14 mail below, since the rule background documents 
failed to reference it and you had indicated you lacked
HCL/Cl2 data for the combined vent category.


Given  the planning for this additional test overlaps with the period 
necessary to plan and conduct our compliance tests, it is vitally important 
that EPA clarify that data gathered in this third CAA 114 request can be 
utilized to satisfy the performance testing requirements of 63.11945. To do 
otherwise, places an additional financial burden on the affected companies, 
such as ours. Based on review of this draft sampling plan with our sampling 
contractor, we estimate it will more than double the cost of our planned 
compliance tests for this location.

You also indicated that you will clarify the procedure for submitting stack 
test plans for approval. We suggest this step is necessary to ensure that the 
data EPA receives is consistently gathered and conforms to the required 
methods and quality constraints. Of course, as you know, prior notifications 
and approval is a requirement for MACT compliance tests.

Enclosed are comments and questions that we have on your Draft CAA 114 
request. In addition, we are a member of the Vinyl Institute and support 
comments they are offering, which may include some of our comments. We look 
forward to a future discussion on these items during the call scheduled with 
the Vinyl Institute.



Should you have questions or require additional information, please contact me 
at 972 404-3209 or by this Email address. I would appreciate you letting me 
know you received this, as it has large attachments.


Barry Christensen
Manager Air Quality
Occidental Chemical Corp.
barry_h._christensen@oxy.com<mailto:barry_h._christensen@oxy.com>

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From: Howard, Jodi [mailto:Howard.Jodi@epa.gov]
Sent: Thursday, April 03, 2014 2:19 PM
To: Christensen, Barry H.
Cc: Lassiter, Penny; Bouchard, Andrew; Kataoka, Mark; Mia, Marcia; Huser, 
Jennifer
Subject: Draft PVC Section 114 Process Vent Testing

Barry,

Attached to this email is the draft Section 114 Process Vent Test Memo for you 
review. OxyVinyls, LP will be required to perform this testing at the 
following facilities:

                OxyVinyls, LP - Deer Park, TX

Please submit your comments to me by Friday, April 11, 2014.

Thanks.


Jodi L. Howard
US EPA
OAR/OAQPS/SPPD/RCG
E143-01
Research Triangle Park, NC 27711
(919) 541-4607







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