April 11, 2014

Sent via E lectronic M ail and Fed E x

Ms. Jodi Howard Environmental Engineer , Refining and Chemicals Group U.S. EPA

- Office of Air Quality Planning and Standards 109 T.W. Alexander Drive Mail Code: E143

- 01 Rese arch Triangle Park, NC 27711 Howard.Jodi @ epa.gov

RE: Polyvinyl Chloride and Copolymers Facility Emission Points Section 114 Sampling and Analysis, and Information Request

Dear Ms

. Howard :

This letter responds on behalf of the Vinyl Institute PVC MACT Wor king Group 1 to
EPA’s request for comments on its draft Clean Air Act S ection 114 Request sent via
electronic mail on April 3, 201 4

. The request seeks sampling and analysis of process

vents from U.S. producers of p olyvinyl c hloride resins and c opolymers

. We address t he following documents, collectively referred to hereinafter as “draft 114 Request” :

• “ Draft Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolymers Facility Emission Points ”, April 3,
2014.

The 114 request will be issued following the Agency’s granting to several petition er s ’ requests to reconsider certain aspects of the National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production; Final Rule

, 77 Fed. Reg . 22

, 848 (April 17, 2012). Accordingly, the Working Group is pleased to
submit these comment s on the draft 114 Request as discussed herein and in more detail in Attachment A which is listed at the bottom of this letter.

1 The PVC MACT Working Group includes Vinyl Institute me mbers (Shintech Inc. , Formosa Plastics Corporation, U.S.A.

, Occidental Chemical Company / O xy Vinyls, LP , Westlake Chemical Corporation, and Mexichem Specialty Resins, Inc. ) and other PVC and Copolymer producers including Axiall Corporation , Wacker Chemica l Corporation, and Lubrizol Corporation

.VI C omments on Process Vent S114 Request , April 11, 2014

Page 2 of 3 The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinyl info.org www.vinylindesign.com 1. EPA Should Minimize Any Inconsiste ncies in the Testing Procedures Required in this S114 Request With That Required for Compliance with PVC MACT
Performance Tests and with Prior Section 114 Requests

As you know, many of the facilities subject to this draft 114 Request were required to perfo rm testing and submit data on process vents in two prior Section 114 Requests dated August 14, 2009 and March 16, 2011. Also, the PVC MACT rule requires performance testing for process vent point sources and accordingly, some facilities have begun their p lanning process to begin these required performance tests. In some instances, the target analytes, test procedures, sample amounts, and sample times required in this draft 114 Request are inconsistent with those required by the PVC MACT for its compliance , and with those specified for prior S114 Requests. For purposes of this draft 114 Request, the Working Group requests that
inconsistencies be minimized with both the PVC MACT and the two prior S114 Requests that entailed process vent tests. Minimizing i nconsistencies will provide a more consistent data set for EPA’s rulemaking purposes.

2. EPA Should Allow Previously Acquired Testing Data to Satisfy Any Duplications in this S114 Request

Emissions data acquired in accordance with the detailed requirements of the two prior S114 Requests should be allowed to adequately satisfy any duplication of requirements in this draft 114 Request. As these tests are not only expensive from an outside contractor perspective , they place demands on the entire staff at each affected facility that otherwise w ould be directed to operations. This draft 114 Request has not been budgeted for by most producers, placing further pressures on funds previously planned for other needs. Recognition of prior data will simplify this

114 Request and avoid unnecessary duplication of expensive tests. Accordingly, EPA should tailor its S114 Request to focus on data gaps at each facility, rather than issue a generic Request that would unnecessarily duplicate prior tests and data
collection.

3. As an Option, EPA Should Allow Testing Required in this S114 Request to Satisfy Compliance with PVC MACT Performance Tests

Some facilities have begun their planning process for bidding, contracting, and scheduling performance tests required by the PVC MA CT rule. Those facilities affected by this S114 Request that complete their performance tests in compliance with PVC MACT requirements should have the option to use those result s to satisfy this S114 Request. EPA should fully accept those results complet ed successfully in accordance with the approved tests by State agencies in compliance with the PVCVI C omments on Process Vent S114 Request , April 11, 2014

Page 3 of 3 The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinyl info.org www.vinylindesign.com MACT as satisfying the requirements of this S114 Request. For those facilities intending to complete the PVC MACT compliance testing to satisfy this S114 Req uest, an individual facility may request and EPA should consider granting an extension beyond the intended S114 Request submission date in order to accommodate the many activities and approvals surrounding compliance testing required in the PVC MACT.

4. EPA Should Provide Separate Reporting Works heets for C onfidential
B usiness I nformation in this S114 Request

An efficient mechanism to clearly separate CBI i n a separate spreadsheet should be provided. EPA has not provided the detailed reporting spreadsheet yet for this S114 Request

. It is the Working Group’s belief that separate worksheets for CBI information best serves to protect that facility’s confidential information.

The Vinyl Institute and its PVC MACT Working Group appreciate the opportunity to

c omment on EPA’s draft Section 114 Facility Emission Points Sampling and Analysis Request. More detailed comments are included in the Attachment listed below.

Please do not hesitate to contact me with any questions.

S incerely,

Richard P. Krock Techn ical Director

e

- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 571

- 216

- 4474

CC: Ms. Penny Lassiter , EPA

- RTP Mr. Mark Kataoka , EPA

- OCG JC Walker, Keller and Heckman Vinyl Institute PVC MACT Working Group

Attachments:

Attachment A: “ PVC MACT Worki ng Group Comments on CAA Section 114 Request Draft Summary of

Test P rocedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolymers F acility Emission Points”, April 3, 2014.