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 Electronic Mail and FedEx 

Ms. 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 27711

Howard.Jodi@epa.gov

RE: Polyvinyl Chloride and Copolymers Facilities Section 114 Sampling and 

Analysis, and Information Request for Process Vents

Dear Ms. Howard:

The Vinyl Institute PVC MACT Process Vent Subgroup1 requests additional clarification

concerning the Agency’s Clean Air Act Section 114 Information Collection Request (“the 

§ 114 Request”), which was issued to the Subgroup members on May 15, 2014. The § 

114 Request follows the Agency’s grant of several 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 analysis 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 seeks clarification on the 

following documents, collectively referred to as the § 114 Request:

• “MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION COLLECTION REQUEST”, Enclosure 1, 

May 15, 2014;

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

These documents do not specifically request sampling and analysis for a class of 

chemicals known as polychlorinated 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 Corporation, 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, Alexandria, 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:

reported 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 sampling and

analysis. As the 2011 data was used in calculating the PVC-combined limits, the 

Subgroup understood the Agency to have determined that the 2009 PCB data was 

sufficient and did not need to be collected again. 

We have just 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 include 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 

sampled, 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 Subgroup would appreciate EPA’s prompt reply to this inquiry. We 

also would appreciate confirmation that PCB testing is not required for the upcoming 

performance compliance testing under the PVC MACT. Please do not hesitate to 

contact me with any questions. 

Sincerely, 

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 Source 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, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

cell: 571-216-4474

CC: Ms. Penny Lassiter, EPA-RTP

Mr. Andrew Bouchard, EPA-RTP

Mr. Mark Kataoka, EPA-OCG

JC Walker, Keller and Heckman

Vinyl Institute PVC MACT Process Vent Subgroup