OAR Box 1107 

Prepped by Ollie Stewart 

Document Number: 

40) IV-C-9 

Docket Number: 

A-81-21 

Printed 4/11/2008 3:03:46 PM Sheet 40 of 90 

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UNIICU JIAIt l fcNVIKUMMfcNI AL fKU I t(_ tlUN AGE 

5- A-8I-2 I 

IV-C-9 

M 1 8 1985 

Mr. Joseph Ledvina -A 

Director, Environmental Activities 

Vista Chemical Company -.'Ay. 

15990 North Barker's Landing Road >;v>:r 

Post Office Box 19029 -?*,X-~ 

Houston, Texas 77224 -iiS S 

Dear Mr. Ledvina: '-V; ~ 

While reviewing your letter, dated March 21, 

several areas for which we would like you to provj 

Specifically, we are requesting information on yc 

plant in Westlake, Louisiana, and your two polyvi 

Oklahoma City, Oklahoma, and Aberdeen, Mississippi. The requested information relates to your estimated costs to comply with Subpart V and your 

request that compliance waivers be made available for the in-reactor-stripper 

compliance method. In addition, we are requesting some clarifications on 

your comments pertaining to classification of Vista Polymers, Inc., as a 

small business and the impact of the vinyl chloride standard on industry 

profitability. Enclosure 1 lists the specific information requested. This 

additional information is necessary for us to more effectively consider your 

comments as we develop final revisions to the standard. 

The authority for the EPA's information gathering is included in 

Section 114 "of the Clean Air Act (42 U.S.C. 7414). Enclosure 2 contains a 

summary of this authority. If you believe that disclosure of the information 

we request would reveal a trade secret, you should clearly identify such 

information as discussed in the enclosure. Any information subsequently 

determined to constitute a trade secret will be protected under 18 U.S.C. 

1905. Enclosure 3 describes the EPA's procedures for safeguarding confidential business information. If no claim of confidentiality accompanies the / 

information when it is received by EPA, it may be made available to the / 

public by EPA without further notice (40 CFR Part 2.203, September 1, 1976). 

All emission data, however, will be available to the public. 

The EPA has contracted Radian Corporation to obtain this information. 

Thus, as noted in Enclosure 4, Radian Corporation has been designated by 

as an authorized representative of the Agency. Therefore, Radian Corporation

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has the rights disclosed in Enclosure 3. As a designated representative of -'.'•' 

the Agency, Radian is subject to the provisions of 42 U.S.C. 7414(c), 

respecting confidentiality of methods or processes entitled to protection as 

trade secrets. 
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We appreciate your assistance in providing the requested information. 

In order to ensure timely consideration of your input in our development of 

promulgated revisions, it is important that we receive your reply by 

July 12, 1985. However, if additional time is needed to respond to the • ;^%|bSfi*% 

requested information concerning economic impacts, we will arrange for • ••-'Wivl*^^.. 

separate submittal of those items as appropriate. Please call Mr. Leslie Evans-"*^^^.. 

at (919) 541-5671 if you have-any questions or problems. ,-•> 

Sincerely, 

L "-1 ^ O^^"-^ 

lack R. Farmer 

Director 

Emission Standards and 

Engineering Division 

OAQPS/ESED/SDB: WFDimmick, rm 1043, NCM, 541-5578 

(Radian/KKFidler/ibunn/541-9100/06-10-85) 

•."fliss'Ei-?-..;?*£*:. 

'tKJfJZ&li&i 

'.•;•:•-•&:'*&•<: 
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V" 

ENCLOSURE 1 

Requested Information 

I. General Process Information 

A. For each of the three plants subject to the vinyl chloride standard, 

identify the major process or production units reflected in the 

supplied information (e.g. oxychlorination, EDC purification, VC 

formation and purification, PVC reactors, resin stripping, monomer 

•recovery, inprocess wastewater stripping, etc.). 

B. What is the production capacity of EDC, vinyl chloride and PVC for each 

unit described in Item A. 
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II. Questions Concerning Vista Comments on Subpart V 

In order to better evaluate the impact to your company of EPA's 

proposal to incorporate 40 CFR Part 61 Subpart V in the vinyl chloride 

standard, please provide the following information. (Separate sheets have 

been provided for the three plants operated by your company that are subject 

to the vinyl chloride standard.) 

A. Open-Ended Valves and Lines 

1. Indicate the approximate number and size of open-ended valves or 

lines* in vinyl chloride service below. (If more convenient, 

information may be supplied for open-ended valves or lines in VOC 

service.) 

Open-end diameter (in.) 

<1 1- 2 >2 

Total number (capped and uncapped) 

Number currently capped 

*0pen-ended valve or line means any valve, except pressure relief valves, 

having one side of the valve seat in contact with process fluid arid one side 

open to the atmosphere, either directly or through open piping. 

Capped refers to a cap, blind flange, plug or a second valve. 
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7. 

Provide an estimate of the costs that would be incurred by your 

company to bring the uncapped components identified in Item A.l 

into compliance with the Subpart V requirements. Explain as 

completely as possible the basis for your cost estimate (e.g., 

equipment type and cost, labor cost, overhead factor, etc.). 
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. / 

B. Sensor Requirements on Pump and Compressor Seals 

1. Indicate the number of each of the following types of rotating 

pumps and compressors in vinyl chloride service that are operated: 

Pumps: Compressors: 

sealless double mechanical seal 

double mechanical seal other; explain: 

other; explain 

2. For each pump and compressor in vinyl chloride service that are 

equipped with double (or other) mechanical seals, provide an 

explanation of the method used to ensure that leaks between the 

two seals are contained (e.g., pressurized barrier fluid, barrier 

fluid system that degasses through a vent to a control device, 

etc.). 
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3. For each double (or other) mechanical seal pump and compressor in 

vinyl chloride service that minimizes leaks between seals by a 

pressurized barrier fluid system, explain what method is used to 

monitor the pressure of the barrier fluid relative to the pressure 

of the process stream that is being pumped or compressed. 

(a) Please estimate how many pumps and compressors in vinyl chloride 

service.would be affected by the Subpart V requirements for 

sensors on pump and compressor seals. 
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(b) Explain how these pumps and compressors would be brought into 

compliance with the Subpart V requirements for sensors on pump and 

compressor seals. 

(c) Provide an estimate of the actual costs that would be incurred in 

carrying out these steps. Include an explanation of the basis of 

your cost estimate (e.g. equipment type and cost, labor cost, 

overhead factor, dollar year, etc.). 
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.yIII. Questions Concerning Vista Comments on the Reactor Opening Loss 

Compliance Method for In-Reactor-Strippers 

A. List and describe the instrumentation which you anticipate will need to 

be added or replaced in order to perform the proposed calculation 

procedure for reactor opening loss for reactors used as strippers (see 

50 £R 1197-1198). Include in your description the estimated time and 

cost that would be required to select, order and install the additional 

instruments. 
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IV. Questions Concerning Vista Comments on the Regulatory Flexibility Act 

A. What is the total employment level for Vista Chemical Company including 

all subsidiaries? Please specify the number of salaried employees at 

the end of each calendar quarter during 1984 and 1985. 

Is any significant change in total employment expected during the 

remainder of calendar year 1985, and if so, for what reason? 

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C. Please provide the same employment information requested in Items A and 

B for any individual plant owned by Vista Chemical Company for which 

you believe a significant adverse effect would likely result from the 

recently proposed revisions to the vinyl chloride standard. 

D. Please explain why you believe a significant adverse effect would 

result from the vinyl chloride standard revisions and add any 

additional clarification/explanation that you feel is relevant 

concerning the above employment information. 
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V. Questions Concerning Vista Comments on Economic Impact 

A. Foreign Competition 

1. Please elaborate on the subject of foreign competition as it 

affects Vista Chemical Company overall, and more specifically 

individual plants owned by Vista Chemical Company and its 

subsidiaries. Provide quantitative information to the extent 

possible. Is the nature of your concern related to the 

possibility of increased imports into the United States, or to 

potential reduction in the ability to export and compete in 

foreign markets? 

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2. For 1984 and 1985 provide a breakdown of the following: 

(a) Vista's product categories that are under pressure from 

foreign producers; 

(b) Total sales by Vista expressed in terms of dollar value and 

quantity for each of the above products; 

(c) The percentage of total sales used captively by Vista and the 

percentage of total sales sold on the open market; 

(d) The source of foreign competition; and 

(e) Quantitative estimates held by Vista concerning the 

competitive advantages foreign producers might have in terms 

of a lower delivered product sales price, lower productions 

costs, or both. 

(f) Any other information that concerns the competitive 

advantages associated with foreign produced vinyl chloride 

and PVC. 

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B. Profitability 

1. Please elaborate on the subject of Vista's profitability for the 

product categories identified in Item A.2. Provide quantitative 

information to the extent possible. 

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For 1984, for the beginning of 1985, and projected for the 

remainder of 1985, specify the following for each of the product 

categories identified in Item A.2: 

(a) total dollar value of profits before tax; 

(b) profits before tax as a percent of sales; 

(c) quantitative financial results sought, such as before tax 

profits as a percent of sales; return on equity, etc. 

3. With respect to the recently proposed revisions to the vinyl 

chloride standard, what factors have changed unexpectedly and to 

what extent have those factors changed between the time that a 

decision was made to proceed during 1984 with the formation on 

Vista Chemical Company and the present time. 

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