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 used in the survey. EPA 

tried to select appropriate reporting units based on how facilities might 

commonly record those parameters and/or variables. EPA also realizes that 

facilities in the PVC industry likely use different units for the same 

parameter or variable. EPA’s intent is to be able to compare information 

and reported values consistently and on the same basis for all facilities and to 

minimize the errors that might be introduced by allowing facilities to 

potentially report multiple units for the same parameter or variable. EPA 

will be making revisions and clarifications to selected sections of the survey 

and for certain units and will be posting revised survey forms. 

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

A2. 

1. Right click on the tab for the Form you wish to copy and select “Move 

or Copy.” 

2. In the pop-up “Move or Copy” window, move the selected sheet 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 before form C2-a, then click “Create a Copy” and then “OK.” 

5. Form C-1-c will then be copied and the copied worksheet 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 numbered 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 the materials listed as 

HAPs? 

A3. No. 

Q4. Some cells on some forms have restricted access that 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 operations. For 

example, the water used for reactor hydroblasting is considered maintenance 

wastewater. Water from the resin centrifuge is considered 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 contacted 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 contacted and 

given specific guidance. 

Form B-1

Q8. If a plant is manufacturing multiple resin grades simultaneously, how should form 

B-1 be completed or should the facility be divided into multiple 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 campaign? 

A9. See response to question 6. 

Q10. Is the EPA willing to accept survey data on different resin grades as opposed to 

different production campaigns? 

A10. See response to question 6. 

Q11. What is “intrinsic viscosity” and is this the same as “inherent viscosity” (as 

referred to in Form B-1)? 

A11. If the term “inherent viscosity” is the term used by industry, 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 different 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 for 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 forms 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-2
PVC Section 114 Survey Q&A 

11/10/2009 

Page 4 of 7 

Q15. If the thermal oxidizer is shared with another process 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 manufacturing process and 

shared with another process and/or covered under another operating permit, 

that equipment should still be included in your survey response. Clearly 

indicate the permit information and other information requested 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 request is geared toward gathering 

process information on control equip for HAPs, we assume this form is not to be 

filled out for baghouses and other fabric filters that are "inherent to the process" 

and/or do not control HAPs. To expand this form to all fabric filters would 

greatly increase the reporting burden while providing no additional information 

on HAP control technology. 

A17. If a fabric filter is present anywhere in the PVC process, then Form C-2-c 

should be completed for each fabric filter. EPA does want to collect 

information on particulate controls used in the PVC industry as the resin or 

other particulate may contain entrained HAP. 

Form D

Q18. Should separate copies of form D be filled out for each unique heat exchanger 

system or should a single sheet be submitted for the entire 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 heat exchange system. 

Individual heat exchangers, cooling tower, other equipment connected to the 

same heat exchange fluid stream should be listed in row 6 on Form D. All 

heat exchangers, cooling towers, other connected equipment should be 

included in the response, whether those equipment appear 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 systems 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 steam 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 are part of and/or are 

used by the PVC manufacturing process. This applies to all 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 specific to the process unit only? 

 A21. See response to question 20. 

Form O

Q22. On form O, it is assumed gas holders, VCM storage tanks, 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 for each chemical that is 

loaded, or do we complete one sheet for each loading for 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 unloading of each 

chemical/raw material for 2008. If the type of unloading activity for a single 

chemical or raw material changed or the transfer process changed at any 

time during the year (rail car unloading versus tanker truck), then a 

separate Form H must be completed for each type of transfer used. If the 

unloading activity or transfer process did not change during the entire year 

for the same chemical or raw material, then a single Form H can be 

completed. 

Q24. Please define what a “feedstock” is (as referred to in Form H) – this is not clear 

within the survey. 

A24. For the purposes of this survey, a “feedstock” means any chemical 

introduced to the PVC manufacturing process and used within 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, etc. 

Form J

Q25. On Form J – why is there reference to form G-1 (Process 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 assumed to mean the percent of 

time the control equipment was in operation relative to its associated 

stream/equipment and not the percent of time the equipment operated relative to a 

year. Is this correct? 

A26. Yes. The percent of time control equipment is operated is intended to mean 

the percent of time the control equipment is operating relative to the amount 

of time the process and process stream that feeds the equipment 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 of VCM. Is the intention to 

identify what the quality of the waste water is when it 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 stream 

(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 process wastewater 

stream is a closed stream (i.e., a pipe), then enter “No” in column H. For 

each stream listed, the HAP concentrations should then be 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 closed 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 for wastewater and 

if there is one or more emission point from that tank, vessel, 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 completed 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.