May 15,2014 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711



### Mr. TomAnderson Environmental Manager ShintechIncorporated 5618 Highway 332 East Freeport, Texas77541 DearMr. Andersen: OFFICE OF AIR QUALITY PLANNING AND STANDARDS

Pursuantto section 114 ofthe CleanAir Act (CAA), the U.S. Environmental Protection Agency (EPA) is collecting information to characterize hazardous air pollutant emissions from process vents atpolyvinyl chloride and copolymer (PVC) production facilities. PVC production is subject to the provisions of40 CFRPart 63, Subparts HHHHHHH and DDDDDD. The purpose ofthis request is to gatherprocess vent data and other information necessary to inform our reconsideration ofthese emissions standards. We requestthe following testing be performed for your PVC production facility, Shintech Louisiana, LLC

- Plaquemine Plant as specifically listed below and discussed in Attachment B (tables 1.1 and 1.6) ofEnclosure 1to this letter: Pollutants to be tested HCl ITOHAP

We are also requesting other information regarding PVC production at your facility and are providing the survey response forms inMicrosoft® Excel spreadsheet format. Testresults that are collected using test methods that are supportedbyEPA's Electronic Reporting Tool (ERT) mustbe submitted using the ERT. We are also providing PVC process vent response forms in Microsoft® Excel spreadsheet format for test methods that are not supported by the ER T. Please see Enclosure 1, Attachment B for specific ERT submission instructions. The requested testing is designed to collect information on emissions and other relevant aspects ofPVC process vents. Enclosure 1contains a summary ofthe information we are requesting.

Internet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed

**w~h** Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)Supplemental information is contained in the following enclosures: 

### Description Enclos ure# Maximum Achievable Control Technology Enclosure 1 (MACT) Standards Development Information Collection Request**Secti~n** 114 Authority and CBI claims Enclosure 2 CBI emissions data disclosure Enclosure 3 Designation ofERG as authorizedrepresentative Enclosure 4 Policies and Procedures for handling CBI Enclosure 5 Certification Statement Enclosure 6 2014 PVC 114 Process Vent Testing Workbook NIA 2014 PVC 114 Process Vent Testing Workbook N/A Example
The testing request is designedto collect emissions information, whichby law cannot be confidential information. You are required to return all requested information on or before 

### November 17,2014. Please e-mail the completed non-confidential survey and testing workbook response to: 

### CCG-PVC@epa.gov There is a small amount ofinformation requested inthe survey concerning production and production capacity which you may seekto claim as confidential. Ifyou are submitting confidential business information (CBI) as described inEnclosure 3, you must mail a separate CD-ROM or DVD-ROM disk containing only the CBI portion ofyour data to EPA. Clearly markthe disk withthe words "Confidential Business Information" and send via U.S. Postal Service Express Mail, registered mail, or private courier to: Jodi Howard U.S. Environmental Protection Agency OAQPS/SPPD/RCG (Mail Code E143-01) 109 T.W. Alexander Drive Research Triangle Park, NC 27711 DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.Ifyouwould like to use the required Section 114 testing to satisfy the initial compliance requirements for process vents inthe PVC rules (40 CFRpart 63, subparts DDDDDD and HHHHHHH), please contact Cynthia Kaleri at Region 6, at (214) 665-6772 or kaleri.cynthia@epa.govto discuss the requirements priorto beginning the 114 testing. Be aware thatthere are significantpenalties for submitting false information, including the possibility offines and imprisonment as explained in Section 113 ofthe CleanAir Act (42 USC §7413). Failure to comply fully withthis requestfor information may subjectyou to an enforcement action. We may use any information submitted in response to this request in an administrative, civil, or criminal action. Ifyouhave questions regarding this request, please contact Ms. Jodi Howard, Refining and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov. Thank you for your assistance inthis effort.

6 Enclosures Sincerely,

# ' 

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## (/**-~~ 4'f/,J/f?\~~V~"'** **7ve~** Penn f Lassiter Group Leader Refining and Chemicals Group Sector Policies and Programs Division

cc: Tom Gilder, Shintech Corporation, (electronically) w/Enclosures Steve Thompson, USEPA, Region 6, Air, Taxies & Inspections Coordination Branch, w/Enclosure 1only Celena Cage, Environmental ScientistManager, LDEQ, Enforcement Division, w/Enclosure 1only