May 15,2014 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711

Mr. Randall P. Smith Vice President/General Manager FormosaPlastics Corporation, Texas 201 FormosaDrive P.O
. Box 700 Point Comfort, Texas 77978 Dear Mr. Smith: OFFICE OF AIR QUALITY PLANNING AND STANDARDS

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**C!e~!!** Ai!· Act (CAA), the U.S. EnYif0!!...1!!ental Pr0tectionAgenc.y (EPA) is collecting informationto characterize hazardous air pollutant emissions from process vents atpolyvinyl chloride and copolymer (PVC) production facilities. PVC production is subject to the provisions of40 CFRPart 63, Subparts HHHHHHH and DDDDDD. The purpose ofthis request is to gatherprocess vent data and other information necessary to inform our reconsideration ofthese emissions standards. We requestthe following testing be performed for your PVC production facility, Formosa Plastics Corporation, Texas

- Point Comfort, TX as specifically listed below and discussed in AttachmentB (tables 1.1 and 1.6) ofEnclosure 1to this letter: Pollutants to be tested HCl ITOHAP

We are also requesting other information regarding PVC production at your facility and are providing the surveyresponse forms inMicrosoft® Excel spreadsheet format. Testresults that are collectedusing test methods that are supported byEPA's Electronic Reporting Tool (ERT) mustbe submitted using the ERT. We are also providing PVC process vent response forms in Microsoft® Excel spreadsheet format for test methods that are not supported bythe ERT. Please see Enclosure 1, Attachment B for specific ERT submission instructions. The requested testing is designed to collect information on emissions and otherrelevant aspects ofPVC process vents. Enclosure 1contains a summary ofthe information we are requesting. Supplemental information is contained inthe following enclosures:

lntemet Address (URL) • http://www.epa.gov Recycled/Recyclable • Printed

**w~h** Vegetable 011 Based Inks on Recycled Paper (Minimum 25% Postconsumer)

### Description Enclosure# Maximum Achievable Control Technology Enclosure 1 (MACT) Standards Development Information Collection Request Section 114 Authority and CBI claims Enclosure 2 CBI emissions data disclosure Enclosure 3 Designation ofERG as authorized representative Enclosure 4 Policies and Procedures for handling CBI Enclosure 5 Certification Statement Enclosure 6 2014 PVC 114 Process Vent Testing Workbook N/A 2014 PVC 114 Process VentTesting Workbook N/A Example
The testing request is designedto collect emissions information, which by law cannot be confidential information. You are required to return all requested information on or before November 17,2014. Please e-mail the completed non-confidential survey and testing workbook response to: CCG-PVC@epa.gov There is a small amount ofinformation requested inthe survey concerning production and production capacity which you may seekto claim as confidential. Ifyou are submitting confidential business information (CBI) as described inEnclosure 3, you must mail a separate CD-ROM or DVD-ROM disk containing only the CBI portion ofyour data to EPA. Clearly markthe disk with the words "Confidential Business Information" and send via U.S. Postal Service Express Mail, registered mail, or private courierto: Jodi Howard U.S. Environmental Protection Agency OAQPS/SPPD/RCG (Mail Code E143-01) 109 T.W. Alexander Drive Research Triangle Park, NC 27711 DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.Ifyou would like to use the required Section 114 testing to satisfy the initial compliance requirements for process vents inthe PVC rules (40 CFRpart 63, subparts DDDDDD and HHHHHHH), please contact Cynthia Kaleri at Region 6, at (214) 665-6772 or kaleri.cynthia@epa.govto discuss the requirements prior to beginning the 114testing. Be aware thatthere are significantpenalties for submitting false information, including the possibility offines and imprisonment as explained in Section 113 ofthe CleanAir Act (42 USC §7413). Failure to comply fully withthis request for informationmay subject youto an enforcement action. We may use any information submitted inresponse to this request in an administrative, civil, orcriminal action. Ifyouhave questions regarding this request, please contactMs. Jodi Howard, Refining and Chemicals Group, at (919) 541-4607 or howard
. jodi@epa.gov. Thankyou for your assistance inthis effort.

6 Enclosures Sincerely,



# 1?~1f.:**Jf/U</rz;c** Group Leader Refining and Chemicals Group Sector Policies and Programs Division

cc: Mary Bachynsky, FormosaPlastics Corporation, (electronically) w/Enclosures Steve Thompson, USEPA, Region 6, Air, Taxies & Inspections Coordination Branch,

w/Enclosure 1 only Michael Beatty, TX Commission on Environmental Quality, w/Enclosure 1 only