## Q&A for VI on Section 114 Information Request for Wastewater & **Stripped Resin**

**VI Question EPA Response**  RK1: We request the ability to provide with an y HAP reported at the detection limit (DL ) a textual indicator that it was reported at the DL. Facilities may provide a textual indicator that a result is at the detection limit in the Notes column within the Excel response spreadsheet(s) . Please also see our response to question RK36. RK 2: I s it the intention to declare other products in addition to PVC and copoly mer resins? I s this only regarding those products that use the same equipment or is the request for the entire site. EPA is requesting that facilities list all other products made at the site, not just other products made using the same e quipment. The purpose of such request is to provide EPA with information on the ty pes of sources /products that would be co

located with the PVC and Co

- poly mer production source category (herein referred to as PVC source category per the first sentence in the introduction of Enclosure 1)

. RK3: The PVC MACT defines recovery device and this I CR defines recovery equipment. Can EPA clarify which definition will be used going forward? Questions RK 3

- RK6 are all related to identification of various items on the requested process flow diagrams (PFD). For purposes of specifically responding to this CAA Section 114 request, EPA is requesting that facilities clearl y indicate and identify on their PFD all process equipment (e.g., poly merization reactors, storage vessels, resin strippers , dry ers, etc. ) , recovery equipment (e.g., gas holders, condensers , etc. )

, control devices (e.g., thermal oxidizers, scrubbers , strippers, vent gas absorbers , etc. ) , and piping between process equipment, recovery

equipment and contr ol devices. The PFD should also show all PRD s and for each PRD, indicate where the emissions from the PRD are discharged (e.g., into piping to control, back to the process

, directl y to the atmosphere , etc. ). The PFD should also identify

any valves on the process equipment, recovery

equipment, piping or on the control device where emissions could be diverted to the atmosphere (including, for example, sample lines, high point bleeds, low leg drains, etc.). The PFD should identify all process wastewater disc harged into the wastewater collection sy stem (e.g., into drains, sumps, hot wells, etc.) or to control (e.g., wastewater stripper, decanter, etc. ), along with showing the wastewater collection and treatment sy stem unit. The PFD doe s not need to show RK4: Can EPA confirm that the closed vent s ys tem is defined as that piping after the recovery sy stem where no further processing, storage, or recovery is done on the stream on its way to the control device? Or can EPA clarify what is meant by

the CVS in conjunction with the definition of recovery
sy stem? RK 5: Process flow diagrams ty picall y do n ot show
any by pass piping around the control device. Ty pically this is a reroute to another ty pe of control device. Maintenance lines (drains and bleeds) are not sized for by

pass functionality . Since EPA has indicated they

are not asking for a P&ID, can th e WG provide a generic diagram for a control device that would show low leg drains, and high point bleeds? RK6: I s EPA looking for only those PRDs that vent to atmosphere or all PRDs?pumps , agitators, flanges, block valves and
connectors on piping and also does not need to show process control equipment such as pressure and temperature gauges. RK7: Should the response include low leg drains and/or high point bleeds, sample ports, etc. located in the recovery

s ys tem? You can specificall y exclude on Form B

- 2 low leg drains and high point bleeds if they are clearl y identified on the PFD. RK8: Does this include low leg drains and/or high point bleeds that during unit operation, even during SSM, these devices are not emission points? See RK7.

RK9: Can EPA define what is meant by remaining economic life? I s it depreciable life? In some instances remaining depreciable life from two identical pieces of equipme nt may vary depending on their installation date. Does EPA recognize that this information is CBI ? Remaining economic life is defined here as a reasonable estimate of the remaining ph ys ical life of the equipment. This is different from the remaining depre ciable life in that the equipment in question
may continue to operate after the equipment has been full y depreciated. This definition is consistent with that definition employ ed in the EPA Air Pollution Control Cost Manual, and is the definition commonly used in other EPA issued Section 114
survey s. The facility

may submit this information to the EPA as CBI if they so choose

. RK10: Please confirm that the WG should define resin ty pe as the per PVC MACT definitions and identify the comonomer used. For pur poses of responding specificall y to this CAA section 114 request, resin ty pes are defined in Attachment A of Enclosure 1 and end with the words ‘process/resin.’ A drop down menu has been added for convenience in the Excel survey for facilities to choose th eir resin ty pe. These include options of Bulk process/resin, Dispersion process/resin, Suspension process/resin, Suspension blending process/resin , Copoly mer, and Other

. I f facilities are manufacturing a resin t ype that doesn’t
meet an y of these definition s, they should choose ‘Other’ and provide us with a detailed description that is similar in scope to our other definitions

. We are not asking facilities to provide us the comonomer used for this specific portion of the
survey

. See also our response to RK2 3. RK11: The WG intends to submit production amounts in a CBI hard copy (CD or paper copy) and then redact the information for the other submission. I s this acceptable? Yes. See RK 13 for more details.

RK12: Can EPA provide a separate sheet to submit thi s as CBI ? See RK 13.

RK13: To be reported as CBI. EPA is requesting that the total daily

resin production rate be reported. Does EPA mean the daily production of resin? The Reporting productions rates as CBI is fine, and facilities can just submit separate Excel files with this information in accordance with our outlinedway

this is requested as rate is confusing. On a batch basis, it is more accurate for each producer to simply report the amount of that batch sampled. Is EPA in agreement with that method of reporting? CBI procedures. Specifically , we are asking for each day ’s total production (i.e., over a 24 hour period). For example, if you run only 1 batch in a day and that batch produced X lbs of resin, then you would report X lbs/day

for the daily

res in production. RK14: Can the Agency

clarify that this survey

is for copol ym er facilities in addition to PVC facilities? Table 5 specifically requests non

- PVC production. Does the Agency mean non

- PVC and

non

- copol ym er wastewater? Yes to both questions. T he definition for the source category specifies that it includes poly vinyl chloride production and poly

vinyl chloride copol ym ers production.

RK15: Can the Agency

clarify that this Table is for
any non

- PVC and non

- copoly mer production process wastewater? S ee RK 14.

RK16: Can the Agency

clarify that 30 samples are what is intended as opposed to 30 continuous days or 30 operating day s? Can the Agency clarify that both PVC and copoly

mer process wastewater is being requested? The Agency is requesting that faci lities required to do wastewater sampling provide a minimum of 1 sample each day

while it is operating such that at least 30 samples (minimum) can be anal yz ed. See also Section 1.1 of Enclosure 1, Attachment B. Also, the introductory

sentence of Enclosur e 1 states that references to “PVC” are specificall y referring to the Poly vinyl Chloride and Copoly mers source category

. RK17: I s the exit stream temperature to indicate at the bottom of the WW stripper or at the point of sampling, which may

be done after the incoming feed heat exchangers? The stream temperature we are requesting should be the temperature at the point at which the sample is taken.

RK18: Can EPA clarify

that this daily

max PVC production capacity

is based on plant design and not the maxi mum achieved during the sampling period? Yes, dail y max PVC production capacity is based on plant design.

RK19: Can EPA clarify

which information should be provided as the design parameters and which provided for t ypical operating characteristics? As the form F

- 2 now stands, there are onl y two items, nos. 12 & 13, which are related to design parameters; is this correct? Yes, items 12 & 13 are design parameters while the other questions are asking about t ypical operating characteristics.

RK20: This appears to be a duplication of Form G. Can EPA clarify

that this additional request is in addition to all the information alread y provided in Form G? What is the purpose of Form G if all this information is being requested in a different format? In order to reduc e the burden and duplication of effort s, EPA is fine with fac ilities submitting this information in Form G only and not submitting copies of the 2013 data/records requested. And while the Agency

doesn’t expect to need additional follow

- up information from facilities on Form G

, we respectfull y reserve the right to request this information during our review of the data submittal s as it may provide more valuable detailed information

.RK21: Can similar equipment be grouped into one

form? As Form I is on ly asking about equipment openings that occurred in 2013 and not asking about listing all equipment within the PVCPU, the EPA requests you follow the instructions f

or Form I in Enclosure 1 that state “Complete a separate Form I for each piece of
process equipment, recovery equipment or other equipment that was opened in 2013

, ” and not group similar equipment together for this form. RK22: The Working Group intends to only report on resin that was removed from equipment before completing normal processing s teps. Please provide guidance if this is incorrect. Per instruction 2 on Form J: “This form covers resin that is removed from equipment and is not processed further through the normal processing steps...”

RK23: The Working Group intends to add resin category e.g. homopoly

mer or copol ym er and comonomers used (if an y) in order to be consistent with other reporting throughout this document Any additional information or details that facilities or the industry

can provide to the Agency is welcome.

RK24: HAP and VOC content (weight %) other than vinyl chloride may

not normally

be anal yz ed for an y resin. Does EPA understand that this data is not likely to be available? If a facility is required to conduct resin sampling and anal ys is per a CAA section 114 request, then additional anal yt ical results for compounds other than vinyl chloride must be provided, as per the CAA section 114 instructions

. RK25: Since PVC and copoly mers are made in batch reactors, can EPA clarify that start up and shutdown specificall y does no t include startup and shutdown of normal batch reactor operations? This is specificall y excluded in the MON. For purposes of responding to form L, we want information specifically

related to the startup and shutdown PVCPU

, not of specific individual pieces of process equipment like batch reactors

.

RK26: Can EPA include a definition of Closed Vent Sy stem? Given the response to RK 4 , not sure a definition is needed, however facilities can use the CVS definition in the PVC MACT ( § 63.12005 ) if this further clarification is needed

. RK27: Some copoly

mer is produced in a latex form. Id entification of resin ty pe in this CAA section 114 request is ty

pically done by t ype of process (e.g., suspension, dispersion, etc.) If facilities feel that specificit y on PVC Copolymer i s needed all the way to down to latex form , please indicate textually within the Notes section o r some other portion of the form on the survey

where appropriate

. RK28: Some homopoly

mer is produced in a latex form Id entif ication of resin ty

pe in this CAA section 114 request is ty

pically done by t ype of process (e.g., suspension, dispersion, etc.) If facilities feel that specificit y on PVC Homopolymer is needed all the
way to down to latex form, please indicate textually wi thin the Notes section or some other portion of the form on the survey

where appropriate. RK29: Not every

resin stripper was sampled in the prior S114 Request. Will EPA consider each Yes, the EPA will consider each facilities’ sampling request on how it intends to sample resin. However,facilities’ sampling request on how it intends to

sample resin? in such requests facilities need to note the resin type and ty pes of monomers used, etc. RK30: Can EPA confirm that it is only requiring the effluent wastewater exiting the PVC process wastewater treatment and not the overhead that is recovered and returned? Yes, the EPA is only asking for effluent wastewater exiting the PVC process wastewater treatment and not the overhead that is recovered and returne d.

RK31: Should EPA be asking for each ty pe of copoly mer resin by

monomoer as well, e.g. suspension vinyl acetate, disperion vinyl acetate, suspension vinylidene chloride, latex ethyl acetate, etc. Some monomers react more full y than others and each comon omer will produce a unique HAP profile. If facilities believe there are enough differences in the HAP profiles for specific resins using specific ty pes of monomers, they

should sample these resins separately and provide specific details about the
purposes for doing so to the Agency

.

RK32: The 2009 S114 allowed only selected PVC resin strippers to be sampled rather than each stripper. Should this copoly mer S114 request similar treatment? See response to question RK29.

RK33: For purposes of subcategorizing resins b y ty pe and monomer, shouldn’t composited samples only be for similar resin ty

pes and monomers? See response to question RK 31.

RK34: Can EPA clarify

this request? I sn't this covered under the lab reports? Formatting st yl es vary from lab to lab. Th e labs should perform a proficiency sample for each compound anal yz ed with the method of anal ys is identified for the response to this section 114 request. RK35: Wouldn't this assessment be somewhat speculative without a comprehensive anal ys is of the deviation? What process is EPA expecting for this assessment? What does EPA consider a deviation? for example, if hold times are exceeded slightly , is that considered a major deviation? A deviation would be a change or departure from the method or a parameter that does not meet the quality indicators. The process would be different depending on the deviation, but should assess the possible empirical impact to the data. Yes, exceeding the hold time would be a deviation. RK36: I s EPA saying to report nothing other than the method detection level? Some labs normally report quantification or reporting limits for certain anal yt es? Labs may have other values in their raw reports, but only method detection level should be reported in the Excel response spreadsheet(s)

. RK37: This is normally

done on a dail y basis for each piece of anal yt ic equipment. I s EPA asking for a daily verification of MDLand the associated calculations? MDLassessment, depending on methodology , may be done on a differing periodic basis. The EPA is asking for the specific procedure and calculations used to determine MDL

. RK38: Does EPA truly

only want those quality assurance/quality

control measures implemented during sampling and analy sis or does EPA mean QA/QC normally

done by the labs as p art of their annual compliance for laboratory method certifications? QA/QC associated with sampling and anal ys is.

RK39: EPA should understand that wet resin may Please provide throughput rat es in appropriate unitsnot be measured. In order to estimate wet resin,

detailed engineering calculations must back calculate the amount based on dry resin and sample anal ys is. Some latex resins are not dried and cannot be reported on a dry

basis. Can EPA clarify

that reporting will consistently be on what is normall y done at each facility ? of measure for the resin type being produced. Estimates based on best engineering judgment are acceptable in the absence of actual data for wet resin.

RK40: It is the Working Group’s intention to provide this as a one

- time narrati ve of the process. Please advise if EPA is expecting something different. Itis the Working Group’s understanding that the bulk of this information is provided along with chain of custod y and included in the lab reports. The working group may be able to pr ovide a consistent framework for reporting this information, but the information should be site specific.

See Section 1.0 for an example http://www.epa.gov/ttn/emc/guidlnd/gd

- 042.pdf

RK41: I s all this included in the M107 or SW 846 procedure? The report should include a table and/or narrative with each compound and the corresponding method used to collect, store, transport, prepare and anal yze the resin samples. RK42: Wouldn't this assessment be somewhat speculative without a comprehensive anal ys is of th e deviation? What process is EPA expecting for this assessment? What does EPA consider a deviation? See response to question RK35.



## Q&A for VI on Section 114 Information Request for Process Vents

## Location **VI Question EPA Response** 
Process Vent Workbook, Form Instructions Instructions at the top of several forms

have confusing references to forms not in the workbook. For example, instructions at the top of Form B

- 4 refer to Form B

- 3 which is not in the workbook. Other Subgroup Memb ers have instructions at the top of B

- 1 that reference Form G and Form E

- 1which are also not in their workbook. Can EPA clarify the instructions when referenced Forms are not in a particular workbook? If an instruction references a form that i s not part of the survey

response workbook, then the instruction for that form (and onl y that form) does not appl y.

Process Vent Workbook, Form K

- 1, and Enclosure 1, page 11 The Subgroup assumes the extent of the

inventory requested is contained in the PVC PU. Can EPA confirm that this understanding is correct? Specificall y is wastewater treatment outside of the PVC PU to be included? Yes, EPA is requesting information specificall y within the context of PVCPU, thus wastewater generated outside of the PVC PU would be excluded for purposes of this portion of survey . However, if wastewater from a non

- PVC source is mixed with wastewater generated from a PVCPU, this should be included and noted in the Notes section. Process Vent Workbook, Form L, and Enclosur e 1, pages 11 & 12 Is the information being requested

specific to a potential Startup, Shutdown, or Malfunction (SSM) event at the process vent control device or is EPA asking for information with respect to every potential SSM event facility wide?

Sinc e PVC and copoly

mers are made in batch reactors, can EPA clarify that start up and shutdown specifically does not include startup and shutdown of normal batch reactor operations? This is specificall y excluded in the MON. See RK 25.

Process Vent Workbook, Form Q, and Enclosure 1, page 12 (or pg. 3 for No Survey recipients) (1) Please confirm that the Subgroup

should define resin t ype in accordance with PVC MACT definitions and identify the comonomer used. (2) For copoly mers, it is the intention of the Subgroup to include comonomers along with the resin ty

pe so that the Agency understands the uniqueness of each manufacturer’s operations. (3) The convention for PVC Grade given as an For purposes of responding specificall y to this CAA secti on 114 request, resin ty pes are defined in Attachment A of Enclosure 1 and end with the words ‘process/resin.’ If facilities are manufacturing a resin t ype that doesn’t meet an y of these definitions, they should choose ‘Other’ and provide us with a detaile d description that is similar in scope to our other definitions. We are not asking facilities to provide us the comonomer usedexample in column H is typically for suspension ty

pe resins. Please confirm that the convention given as an example refers to these resin molecular weight range designations:

LMW : L ow Molecular Weight, GP: General Purpose, HMW: High Molecular Weight for this specific portion of the survey

. However, an y additional information or details that facilities or the industry can prov ide to the Agency

is welcome

, including, but not necessarily limited to, the identification of comonomers for resin ty pes and/or the identification of molecular weight range designations for certain resin grades.