April 11, 2014

Sent via Electronic Mail and FedEx 

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

Research 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 Working Group1 to

EPA’s request for comments on its draft Clean Air Act Section 114 Request sent via 

electronic mail on April 3, 2014. The request seeks sampling and analysis of process 

vents from U.S. producers of polyvinyl chloride resins and copolymers. We address the 

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 petitioners’ 

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 comments 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 members (Shintech Inc., Formosa Plastics Corporation, U.S.A., 

Occidental Chemical Company /Oxy Vinyls, LP, Westlake Chemical Corporation, and Mexichem Specialty Resins, Inc.) and other 

PVC and Copolymer producers including Axiall Corporation, Wacker Chemical Corporation, and Lubrizol Corporation.
VI Comments 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.vinylinfo.org www.vinylindesign.com

1. EPA Should Minimize Any Inconsistencies 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 

perform 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 planning 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 inconsistencies 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 would 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 MACT 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 results to satisfy 

this S114 Request. EPA should fully accept those results completed successfully in 

accordance with the approved tests by State agencies in compliance with the PVC 
VI Comments 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.vinylinfo.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 

Request, 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 Worksheets for Confidential 

Business Information in this S114 Request 

An efficient mechanism to clearly separate CBI in 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 

comment 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. 

Sincerely, 

Richard P. Krock

Technical 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 Working Group Comments on CAA Section 114 Request Draft Summary of 

Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and 

Copolymers Facility Emission Points”, April 3, 2014.