May 15,2014 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

Mr. Tom Anderson 

Environmental Manager 

Shintech Incorporated 

5618 Highway 332 East 

Freeport, Texas77541 

Dear Mr. Andersen: 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Pursuant to section 114 ofthe Clean Air Act (CAA), the U.S. Environmental Protection Agency 

(EPA) is collecting information to characterize hazardous air pollutant emissions from process 

vents at polyvinyl chloride and copolymer (PVC) production facilities. 

PVC production is subject to the provisions of 40 CFR Part 63, Subparts HHHHHHH and 

DDDDDD. The purpose of this request is to gather process vent data and other information 

necessary to inform our reconsideration of these emissions standards. 

We request the 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) of Enclosure 1 to this letter: 

Pollutants to be tested 

HCl I TOHAP 

We are also requesting other information regarding PVC production at your facility and are 

providing the survey response forms in Microsoft® Excel spreadsheet format. Test results that 

are collected using test methods that are supported by EPA's Electronic Reporting Tool (ERT) 

must be 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 

of PVC process vents. Enclosure 1 contains 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 Enclosure# 

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 of ERG as authorized representative 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 designed to collect emissions information, which by 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 of information requested in the survey concerning production and 

production capacity which you may seek to claim as confidential. If you are submitting 

confidential business information (CBI) as described in Enclosure 3, you must mail a 

separate CD-ROM or DVD-ROM disk containing only the CBI portion of your data to EPA. 

Clearly mark the disk with the 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. 
If you would like to use the required Section 114 testing to satisfy the initial compliance 

requirements for process vents in the PVC rules (40 CFR part 63, subparts DDDDDD and 

HHHHHHH), please contact Cynthia Kaleri at Region 6, at (214) 665-6772 or 

kaleri.cynthia@epa.gov to discuss the requirements prior to beginning the 114 testing. 

Be aware that there are significant penalties for submitting false information, including the 

possibility of fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC 

§7413). Failure to comply fully with this request for information may subject you to an 

enforcement action. We may use any information submitted in response to this request in an 

administrative, civil, or criminal action. 

If you have 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 in this effort. 

6 Enclosures 

Sincerely, 

' /;_// ·/ 

(/ -~~4'f/,J/f?\~~V~"'7ve~ Pennf 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 1 only 

Celena Cage, Environmental Scientist Manager, LDEQ, Enforcement Division, 

w/Enclosure 1 only