1737 King Street, Suite 390 ● Alexandria, VA 22314 ●(571) 970

- 3359 ● Fax (571) 970

- 3271 www.vinylinfo.org ● www.vinylindesign.com July 14, 2014

Sent via E lectronic M ail and Fed E x

M s

. Jodi Howard Refining and Chemicals Group U.S. EPA

- Office of Air Quality Planning and Standards 109 T.W. Alexander Drive Mail Code: E143

- 01 Research Triangle Park, NC 27 711 Howard.Jodi @ epa.gov

RE: Polyvinyl Chloride and Copolymers Facilities Section 114 Sampling and Analysis, and Information Request for Process Vents

Dear Ms. Howard :

T he Vinyl Institute PVC MACT Process Vent Subg roup 1 requests additional clarification concerning the Agency’s Clean Air Act S ection 114 Information Collection Request (“the § 114 Request”) , which was issued to the Subgroup members on May 15, 2014

. The § 114 R equest follows the Agency ’s grant of severa l petitions to reconsider the National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production; Final Rule , 77 Fed. Reg. 22,848 (April 17, 2012).

The § 114 Request requires sampling and analysi s of process vent emissions , as well as the submission of other process, operation, and facility information from certain facilities operated by Subgroup members

. The Subgroup seek s clarification on t he following documents, collectively re ferred to a s t he § 114 Request :

• “ MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST ”, Enclosure 1, May 1 5 , 2014 ;

• “2014 PVC 114 Process Vent Workbook” , May 15, 2014

.

The se documents do not specifically request sampling and analysis for a class of chemicals known as pol ychlorinated biphenyls (PCBs). The working group assumes that this omission is intentional, for several reasons: First, the PVC MACT does not

1 The PVC MACT Process Vent Subgroup includes Vinyl Institute members Formosa Plastics Corporation, U.S.A.
, Wacker Chemical Corporat ion, Lubrizol Corporation, Shintech Corporation, Oxy Vinyls, LP, and Westlake Chemicals Company

.VI PVC MACT Subgroup Clarification on S114 Request for Process Vents

Page 2 of 3 The Vinyl Institute, 1737 King Street, Suite 390, A lexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com contain a specific limit for PCBs

. More importantly, although PCBs were included in the calculation for total organic hazardous air pollutant (TOHAP) limits using data generated from the Agency’s 2009 § 114 Request, their contribution was infinitesimally small :
r eported concentrations ranged from 1.01E

- 09 to 1.96E

- 12 ppm for the specific PCB congeners ; and of the 420 PCB data points reported for the 2009 S114 Request , 313 (75%) were at or below detection levels

. 2 In contrast , the TOHAP limits in the final PVC MACT are 56 ppmv for PVC

- Only and 9 .8 ppmv for PVC

- Combined process vents
, meaning that PCB concentrations are a full 10 orders of magnitude below the limit. Critically , the Agency did not include PCBs in its 2011 § 114 Request for process vents at EDC/VCM facilities , and no PCB data was generated from that sampl ing and analy sis

. As the 2011 data was used in calculating the PVC

- combined limits
, t he Subgroup understood the Agency to have determined that the 2009 PCB data was sufficient and did not need to be collected again.
We have j ust become aware of this difference between the 2009 Request, on the one hand, and the 2011 and 2014 Requests, on the other. As our members are very well along in the planning and, in some cases, the actual sampling to comply with the 2014 Request, any new requirement to inclu de PCB sampling and analysis would impose significant additional costs and delay on the completion of the data collection. Given the nature of the PVC manufacturing process, as well as the minute concentrations of PCBs

sa mpled
, Subgroup members request confirmation that EPA will continue using, as it has, the 2009 PCB data , and that no new PCB sampling and analysis is required.
Given the testing underway or planned to start shortly
, The Vinyl Institute and its PVC MACT Process Vent Subg roup would appreciate EPA’s prompt reply to this inquiry

. We also would appreciate confirmation that PCB testing is not required for the upcoming performance complian ce testing under the PVC MACT. Please do not hesitate to contact me with any questions.

S incerely,

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

- 970

- 3392

2 ERG Technical Memorandum “ Revised Maximum Achievable Control Technology (MACT) Floor Analysis for the Polyvinyl Chloride and Copolymers (PVC) Production Sour ce Category ” , February 8, 2012, EPA Docket Number EPA

- HQ

- OAR

- 2002

- 0037

- 0193, p.67

- 133.VI PVC MACT Subgroup Clarification on S114 Request for Process Vents

Page 3 of 3 The Vinyl Institute, 1737 King Street, Suite 390, A lexandria, VA 22314 (571) 970

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- 216

- 4474

CC: Ms. Penny Lassiter , EPA

- RTP M r

. Andr ew Bouchard , EPA

- RTP Mr. Mark Kataoka , EPA

- OCG JC Walker, Keller and Heckman Vinyl Institute PVC MACT Process Vent Subg roup