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 any 

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: Is it the intention to declare other products in 

addition to PVC and copolymer resins? Is 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 equipment. The purpose of 

such request is to provide EPA with information on

the types of sources/products that would be colocated with the PVC and Co-polymer 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 ICR 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 clearly indicate and identify 

on their PFD all process equipment (e.g., 

polymerization reactors, storage vessels, resin 

strippers, dryers, 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 control devices. 

The PFD should also show all PRDs and for each 

PRD, indicate where the emissions from the PRD 

are discharged (e.g., into piping to control, back to 

the process, directly 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 

discharged into the wastewater collection system

(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 

system unit. The PFD does not need to show 

RK4: Can EPA confirm that the closed vent system 

is defined as that piping after the recovery system 

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 

system?

RK 5: Process flow diagrams typically do not show 

any bypass piping around the control device. 

Typically this is a reroute to another type of control

device. Maintenance lines (drains and bleeds) are 

not sized for bypass functionality. Since EPA has 

indicated they are not asking for a P&ID, can the 

WG provide a generic diagram for a control device 

that would show low leg drains, and high point 

bleeds?

RK6: Is 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 system?

You can specifically exclude on Form B-2 low leg 

drains and high point bleeds if they are clearly 

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? Is it depreciable life? In some 

instances remaining depreciable life from two 

identical pieces of equipment 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 physical life of 

the equipment. This is different from the remaining 

depreciable life in that the equipment in question 

may continue to operate after the equipment has 

been fully depreciated. This definition is consistent 

with that definition employed in the EPA Air 

Pollution Control Cost Manual, and is the definition 

commonly used in other EPA issued Section 114 

surveys. The facility may submit this information to 

the EPA as CBI if they so choose.

RK10: Please confirm that the WG should define 

resin type as the per PVC MACT definitions and 

identify the comonomer used.

For purposes of responding specifically to this CAA 

section 114 request, resin types 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 their resin type. These include

options of Bulk process/resin, Dispersion 

process/resin, Suspension process/resin, Suspension 

blending process/resin, Copolymer, and Other. If 

facilities are manufacturing a resin type that doesn’t 

meet any of these definitions, 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 RK23.

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. Is this acceptable?

Yes. See RK 13 for more details.

RK12: Can EPA provide a separate sheet to submit 

this 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 outlined 
way 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 resin production. 

RK14: Can the Agency clarify that this survey is 

for copolymer facilities in addition to PVC 

facilities? Table 5 specifically requests non-PVC 

production. Does the Agency mean non-PVC and 

non-copolymer wastewater?

Yes to both questions. The definition for the source 

category specifies that it includes polyvinyl chloride 

production and polyvinyl chloride copolymers 

production.

RK15: Can the Agency clarify that this Table is for 

any non-PVC and non-copolymer production 

process wastewater?

See RK 14.

RK16: Can the Agency clarify that 30 samples are 

what is intended as opposed to 30 continuous days 

or 30 operating days? Can the Agency clarify that 

both PVC and copolymer process wastewater is 

being requested?

The Agency is requesting that facilities 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 analyzed. See 

also Section 1.1 of Enclosure 1, Attachment B. 

Also, the introductory sentence of Enclosure 1 states 

that references to “PVC” are specifically referring to 

the Polyvinyl Chloride and Copolymers source 

category.

RK17: Is 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 maximum achieved during the sampling 

period?

Yes, daily 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 typical operating characteristics? As 

the form F-2 now stands, there are only 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 typical 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 already 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 reduce the burden and duplication of 

efforts, EPA is fine with facilities 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 

respectfully reserve the right to request this 

information during our review of the data submittals

as it may provide more valuable detailed 

information. 
RK21: Can similar equipment be grouped into one 

form?

As Form I is only 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 for 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 steps. 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. homopolymer or copolymer and 

comonomers used (if any) 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 analyzed 

for any resin. Does EPA understand that this data is 

not likely to be available?

If a facility is required to conduct resin sampling and 

analysis per a CAA section 114 request, then 

additional analytical results for compounds other 

than vinyl chloride must be provided, as per the 

CAA section 114 instructions.

RK25: Since PVC and copolymers 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 specifically 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 System?

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 copolymer is produced in a latex 

form.

Identification of resin type in this CAA section 114 

request is typically done by type of process (e.g., 

suspension, dispersion, etc.) If facilities feel that 

specificity on PVC Copolymer is needed all the way

to down to latex form, please indicate textually

within the Notes section or some other portion of the 

form on the survey where appropriate.

RK28: Some homopolymer is produced in a latex 

form

Identification of resin type in this CAA section 114 

request is typically done by type of process (e.g., 

suspension, dispersion, etc.) If facilities feel that 

specificity on PVC Homopolymer is needed all the 

way to down to latex form, please indicate textually

within 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 types 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 returned.

RK31: Should EPA be asking for each type of 

copolymer resin by monomoer as well, e.g. 

suspension vinyl acetate, disperion vinyl acetate, 

suspension vinylidene chloride, latex ethyl acetate, 

etc. Some monomers react more fully than others 

and each comonomer will produce a unique HAP 

profile.

If facilities believe there are enough differences in 

the HAP profiles for specific resins using specific 

types 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 copolymer S114 request 

similar treatment?

See response to question RK29.

RK33: For purposes of subcategorizing resins by 

type and monomer, shouldn’t composited samples 

only be for similar resin types and monomers?

See response to question RK 31.

RK34: Can EPA clarify this request? Isn't this 

covered under the lab reports?

Formatting styles vary from lab to lab. The labs 

should perform a proficiency sample for each 

compound analyzed with the method of analysis 

identified for the response to this section 114 

request.

RK35: Wouldn't this assessment be somewhat 

speculative without a comprehensive analysis 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: Is EPA saying to report nothing other than 

the method detection level? Some labs normally

report quantification or reporting limits for certain 

analytes?

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 daily basis for 

each piece of analytic equipment. Is EPA asking for 

a daily verification of MDL and the associated 

calculations?

MDL assessment, 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 analysis or does EPA mean 

QA/QC normally done by the labs as part of their 

annual compliance for laboratory method 

certifications?

QA/QC associated with sampling and analysis.

RK39: EPA should understand that wet resin may Please provide throughput rates in appropriate units 
not be measured. In order to estimate wet resin, 

detailed engineering calculations must back 

calculate the amount based on dry resin and sample 

analysis. 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 normally 

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 narrative of the process. 

Please advise if EPA is expecting something 

different. It is the Working Group’s understanding 

that the bulk of this information is provided along 

with chain of custody and included in the lab 

reports.

The working group may be able to provide 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: Is 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 analyze 

the resin samples.

RK42: Wouldn't this assessment be somewhat 

speculative without a comprehensive analysis of 

the 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 Members 

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 is not 

part of the survey response workbook, then 

the instruction for that form (and only that 

form) does not apply.

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? Specifically is 

wastewater treatment outside of the PVC 

PU to be included?

Yes, EPA is requesting information 

specifically within the context of PVCPU, 

thus wastewater generated outside of the 

PVCPU 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 Enclosure 

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?

Since PVC and copolymers 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 

specifically 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 type in accordance 

with PVC MACT definitions and 

identify the comonomer used. (2) For 

copolymers, it is the intention of the 

Subgroup to include comonomers along 

with the resin type 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 specifically to 

this CAA section 114 request, resin types 

are defined in Attachment A of Enclosure 1 

and end with the words ‘process/resin.’ If 

facilities are manufacturing a resin type that 

doesn’t meet any of these definitions, 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 
example in column H is typically for 

suspension type resins. Please confirm 

that the convention given as an example 

refers to these resin molecular weight 

range designations:

LMW : Low Molecular Weight, GP: 

General Purpose, HMW: High 

Molecular Weight

for this specific portion of the survey. 

However, any additional information or 

details that facilities or the industry can 

provide to the Agency is welcome, 

including, but not necessarily limited to, the 

identification of comonomers for resin types 

and/or the identification of molecular 

weight range designations for certain resin 

grades.