PVC Section 114 Survey Q&A

11/10/2009 Page 1 of 7 PVC and Copolymer Manufacturing Section 114 Survey Questions EPA Responses

11/10/2009

General

Q1. Can the survey forms be consistent in the units used, i.e. SI and US engineering units are mixed in the request?

A1. EPA realizes that a consistent set of units is not us ed in the survey. EPA tried to select appropriate reporting units based on how fac ilities might commonly record those parameters and/or variables. EPA also re alizes that facilities in the PVC industry likely use different un its for the same parameter or variable. EPA’s intent is to be able to compa re information and reported values consistently and on the same basis for al l facilities and to minimize the errors that might be introduced by allowing f acilities to potentially report multiple units for the same parameter or variable. EPA will be making revisions and clarifications to selected sec tions of the survey and for certain units and will be posting revised survey for ms.

Q2. How should multiple sheets for a single form be lab eled?

A2. 1. Right click on the tab for the Form you wish to copy and se lect “Move or Copy.”

2. In the pop-up “Move or Copy” window, move the selected she et to be copied before the next form in the sequence.

3. Click the “Create a Copy” check box and then click “OK.” For example, to copy form C-1-c, right click the worksheet tab for Form

C-1-c.

4. Then select “Move or Copy.” Move the selected sheet befor e form C2-a, then click “Create a Copy” and then “OK.”

5. Form C-1-c will then be copied and the copied workshee t name will be “C-1-c (2).”

Do not change the default worksheet name after it has been copied.

Additional copies of the same Form will be sequentially num bered as “C-1-c (3),” “C-1-c (4),” etc.PVC Section 114 Survey Q&A

11/10/2009 Page 2 of 7 Q3. Survey Part 2: Several forms ask for itemization of specific HAP and Total VOC

concentrations or amounts. Is total VOC exclusive of t he materials listed as

HAPs?

A3. No.

Q4. Some cells on some forms have restricted access t hat do not allow a response to be entered. Can EPA suggest a workaround so that information can be entered

into restricted access cells?

Q4. EPA will post revised survey forms that should correct this problem.

Definitions

Q5. Define Maintenance wastewater.

A5. For the purposes of this survey, maintenance wastewater is wastewater that is generated from routine maintenance activities and is not wastewater generated by or within the process during normal process ope rations. For example, the water used for reactor hydroblasting is consid ered maintenance wastewater. Water from the resin centrifuge is considere d process

wastewater.

Q6. Clarify definition of process unit.

A6. Since there is not a consensus among the PVC industry on this term and how each manufacturer views this term, each manufacturer was con tacted and given specific guidance.

Q7. Clarify definition of production campaign.

A7. Since there is not a consensus among the PVC industry on this term and how each manufacturer views this term, each manufacturer was con tacted and given specific guidance.

Form B-1

Q8. If a plant is manufacturing multiple resin grades sim ultaneously, how should form B-1 be completed or should the facility be divided into mu ltiple process units?PVC Section 114 Survey Q&A

11/10/2009 Page 3 of 7 A8. See response to question 5.

Q9. Can multiple batches of one resin grade be one campa ign?

A9. See response to question 6.

Q10. Is the EPA willing to accept survey data on differen t resin grades as opposed to different production campaigns?

A10. See response to question 6.

Q11. What is “intrinsic viscosity” and is this the same a s “inherent viscosity” (as referred to in Form B-1)?

A11. If the term “inherent viscosity” is the term used by i ndustry, then EPA will correct this on the survey forms.

Q12. On Form B-1, the industry measures molecular weight using inherent viscosity. The form asks for intrinsic viscosity which is a diffe rent test and is not practiced in the PVC industry. For purposes of clarification, can the EPA clarify the use of inherent viscosity for reporting?

A12. See response to question 11.

Q13. On Form B-1, because production runs will be reported by resin grade, can the form be modified to allow ranges in inherent viscosity f or grade groups?

A13. If a range of inherent viscosity is associated with a single resin grade, then the range may be reported. EPA will correct the survey f orms to allow a range to be entered.

Q14. On Form B-1, the cell for reporting production volume needs to be able to allow a number greater than 100,000.

A14. EPA will post revised survey forms that should correct this problem.

Form B-2PVC Section 114 Survey Q&A

11/10/2009 Page 4 of 7 Q15. If the thermal oxidizer is shared with another proc ess and is covered under a separate Title V operating permit, should it be include on the PFD and form B-2?

A15. For any equipment that is used by the PVC manufacturi ng process and shared with another process and/or covered under another oper ating permit, that equipment should still be included in your survey r esponse. Clearly indicate the permit information and other information reque sted for that equipment on Form B-2 and on other survey forms as appropriate.

Form C

Q16. The liquid loading rate is listed as liters/sq. meter . What is the time basis e.g. seconds, minutes, hours?

A16. The units for liquid loading rate on Form C-1-c should be gallons per minute (gpm)

Q17. Form C-2-c - Since this information collection reque st is geared toward gathering process information on control equip for HAPs, we assum e this form is not to be filled out for baghouses and other fabric filters that a re "inherent to the process" and/or do not control HAPs. To expand this form to all fa bric filters would greatly increase the reporting burden while providing no addit ional information on HAP control technology.

A17. If a fabric filter is present anywhere in the PVC pr ocess, then Form C-2-c should be completed for each fabric filter. EPA does wan t to collect information on particulate controls used in the PVC indus try as the resin or other particulate may contain entrained HAP.

Form D

Q18. Should separate copies of form D be filled out for ea ch unique heat exchanger system or should a single sheet be submitted for the enti re system i.e. cooling tower? Should the slurry stripper feed /bottoms exchanger be included? Should heat exchangers in steam service be included?

A18. Facilities should complete a separate Form D for each h eat exchange system. Individual heat exchangers, cooling tower, other equipment con nected to the same heat exchange fluid stream should be listed in row 6 on Form D. All heat exchangers, cooling towers, other connected equipment s hould be included in the response, whether those equipment appe ar on one Form D or across multiple Forms for multiple systems.PVC Section 114 Survey Q&A

11/10/2009 Page 5 of 7 Q19. Do we need to report data for heat exchange system s that are not in contact with a HAP? Do we need to report on heat exchange systems that do not rely on cooling

water?

A19. Form D must be completed for each heat exchange system , whether or not it utilizes a cooling tower. If the answer to BOTH “Does the heat exchange system heat or cool process fluids that contain HAP or VOC?” ( Form D, Column C, Row 15) AND “... does the intervening fluid contain HAP or VOC?” (Form D, Column C, Row 17) is No , then you do not need to complete the rest of the Form.

Form E

Q20. What is the significance of having boilers used for st eam generation included in Form E (Combustion Units other than Thermal Oxidizers, Catalytic Oxidizers and Flares) when they have their own MACT standard?

A20. EPA is requesting information on these units if they ar e part of and/or are used by the PVC manufacturing process. This applies to al l equipment if it is used by the process, regardless of whether or not it is already regulated by

another MACT standard.

Q21. Form E - Is this form for combustion devices specif ic to the process unit only?

A21. See response to question 20.

Form O

Q22. On form O, it is assumed gas holders, VCM storage t anks, and wastewater storage tanks are included. Should vessels in PVC slurry service and raw material service (e.g. suspending agents, termination chemicals) be included?

A22. Yes.

Form H

Q23. What is the definition of “activity” here? (I think they are asking for the number of unloading events of each material per year, but I don’ t see a clear definition of that term.) In other words, do we complete one sheet f or each chemical that is loaded, or do we complete one sheet for each loading f or each chemical?PVC Section 114 Survey Q&A

11/10/2009 Page 6 of 7 A23. A separate Form H should be completed for the unloadin g of each chemical/raw material for 2008. If the type of unloading acti vity for a single chemical or raw material changed or the transfer process ch anged at any time during the year (rail car unloading versus tanker truck ), then a separate Form H must be completed for each type of transf er used. If the unloading activity or transfer process did not change during th e entire year for the same chemical or raw material, then a single For m H can be completed.

Q24. Please define what a “feedstock” is (as referred to i n Form H) – this is not clear within the survey.

A24. For the purposes of this survey, a “feedstock” means any c hemical introduced to the PVC manufacturing process and used withi n the process, including, but not limited to, raw materials, initiators , inhibitors, suspending agents, terminators, processing aids, etc. Feedstock would not include steam, heat transfer fluids, lubricants, seal fluids, et c.

Form J

Q25. On Form J – why is there reference to form G-1 (Proc ess Control Changes)?

A25. The reference should be to Form I, not Form G-1. EPA will post revised survey forms that will make this correction.

Form K

Q26. “Percent of time control equipment operated” is ass umed to mean the percent of time the control equipment was in operation relative t o its associated stream/equipment and not the percent of time the equipm ent operated relative to a year. Is this correct?

A26. Yes. The percent of time control equipment is operat ed is intended to mean the percent of time the control equipment is operating r elative to the amount of time the process and process stream that feeds the eq uipment is operating.

Q27. On Form K34 – Is waste water exposed to atmosphere at any point? Waste water is normally stripped if it contains a certain amount o f VCM. Is the intention to identify what the quality of the waste water is when i t first becomes exposed to atmosphere and if so, should that be identified?

A27. For each process wastewater stream identified on Form K-3-a, if that wastewater is exposed to the atmosphere at any point along that s tream (from the point it exits one piece of equipment to when it enters the next),PVC Section 114 Survey Q&A

11/10/2009 Page 7 of 7 then indicate “Yes” in column H of Form K-3-a. If the proc ess wastewater stream is a closed stream (i.e., a pipe), then enter “N o” in column H. For each stream listed, the HAP concentrations should then b e listed on Form K3-b.

Form O

Q28. Is the intended tank survey for those only vented to the atmosphere? A number of vessels are used for intermediate holding and are clo sed systems.

A28. Form O should be completed for each tank, vessel, and portable container that is used for feedstock storage, as a holding vessel, or fo r wastewater and if there is one or more emission point from that tank, vess el, or container. If a tank, vessel, or container vents to a closed system and there are no other emissions (e.g., from seals, roofs, connectors, flanges, etc) from that tank, vessel, or container, then Form O does not need to be comple ted for that equipment.

Q29. Our operations do not use gas holders. All vessels used for feedstock storage and holding are closed-loop and have no emissions. Wastewater (prior to steam stripping) in also contained in closed vessels as required by the NESHAP. It is our intention to treat this form as NA. Do you agree?

A29. See response to question 28.