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TECHNICAL MEMORANDUM

TO: Jodi Howard, U.S. EPA, Sector Policies and Programs Division/Coatings and 

Chemicals Group

FROM: Eastern Research Group, Inc.

DATE: April 11, 2011

SUBJECT: Information Collection for the Polyvinyl Chloride and Copolymers (PVC) 

Production Source Category 

1.0 Introduction

The U.S. Environmental Protection Agency (EPA), under section 112 of the Clean Air Act 

(CAA), is required to establish National Emissions Standards for Hazardous Air Pollutants 

(NESHAP) emitted from polyvinyl chloride and copolymer (PVC) production facilities. The 

complete set of regulated HAP is listed in CAA section 112(b). This memorandum describes the 

data collection and data preparation completed by EPA and ERG in an effort to develop 

NESHAP standards for the PVC production source category. Section 2.0 describes the data 

collection steps and Section 3.0 describes the data preparation and standardization completed in 

order to perform subsequent analyses. 

2.0 Data Collection

To collect data on PVC production, EPA reviewed previously collected information,

current literature, and data from the National Emissions Inventory (NEI). EPA also held several 

meetings with Industry and the primary industry trade group, the Vinyl Institute (VI).

On August 12, 2009, EPA issued a Section 114 Information Collection Request (ICR) to 

9 companies operating an estimated 19 PVC and copolymer production facilities in the U.S. A 

list of companies and corresponding facilities is presented in Table 2-1. 

Table 2-1: Companies/Facilities Issued a Section 114 Information Collection Request

Company Facility

The Dow Chemical Company

Texas City, TX

Plaquemine, LA

Midland, MI

Formosa Plastics Corporation

Delaware City, DE

Baton Rouge, LA

Point Comfort, TX

Georgia Gulf Corporation Aberdeen, MS
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Company Facility

Plaquemine, LA

Occidental Chemical 

Corporation (OxyVinyls, LP

Deer Park, TX

Pasadena, TX

Pedricktown, NJ

PolyOne Specialty Resins 

Group

Pedricktown, NJ

Henry, IL

Saint-Gobain Corporation 

North America CertainTeed 

Corporation

Lake Charles, LA

Shintech Incorporated

Addis, LA

Plaquemine, LA

Westlake Chemical Company

Calvert City, KY

Geismar, LA

Following the issue of the ICR, EPA learned that the Dow Plaquemine facility did not 

produce PVC, but instead supplied the Shintech Addis facility with raw materials. Dow also 

informed EPA of the impending closure of the Texas City facility, operated by Union Carbide, a 

wholly owned subsidiary of Dow. Due to the impending closure, emissions testing and resin 

sampling, as described in this memo, were not performed at the Texas City facility. Discounting 

the Dow Plaquemine and Texas City facility, EPA determined there are 17 PVC and copolymer 

production facilities operating in the U.S. 

The ICR survey required companies to complete an electronic based survey and conduct

emissions testing and resin sampling. The survey was formatted as a series of Microsoft (MS) 

Excel worksheets and collected basic data on each facility such as location, contact information, 

and permitting information. The survey also collected process and control equipment 

information such as equipment type, flow rates, emission concentrations, and fuel types. The 

survey included specific sections such as wastewater, startup and shutdown, heat exchange 

systems, and feedstock unloading. The testing requirement included 2 parts; emissions testing 

and resin sampling. EPA required facilities to perform testing on the inlet and outlet to at least 

one of the systems used to control emissions from PVC and copolymer production. Facilities 

were required to dedicate the control system to the PVC and copolymer production unit during 

testing since several of the facilities are co-located with processes that produce products and 

intermediates other than PVC. Each test was required to consist of 3, 4-hour runs, in accordance

with the EPA test memorandum on testing requirements. Each facility tested only for those 

HAPs which were known or suspected to be emitted from their process. The following HAPs 

were commonly tested: acetaldehyde (75-07-0), acetophenone (98-86-2), 1,3-butadiene (106-99-

0), chlorine (7782-50-5), cumene (98-82-8), ethyl chloride (75-00-3), ethylene dichloride (107-

06-2), formaldehyde (50-00-0), hydrogen chloride (7647-01-0), methanol (67-56-1), methyl 

chloride (74-87-3), phenol (108-95-2), polychlorinated biphenyls (1336-36-3), poly-aromatic 

hydrocarbons (both volatile and semi-volatile), vinyl acetate (108-05-4), vinyl bromide (593-60-
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2), vinyl chloride (75-01-4), dioxins and furans, any other HAP contained in initiators or 

inhibitors used in the process, and total hydrocarbons (THC). In addition to the testing, EPA 

requested process data concurrent with the duration of the emissions testing including continuous 

emissions monitoring system records, control equipment operating parameters, and fuel usage. 

The second testing requirement consisted of 30 days of resin sampling during which the 

emissions testing took place. EPA required sampling of the PVC and copolymer resin 

immediately following the resin slurry stripper(s) and the resin dryer(s). EPA also requested 30 

days of process data concurrent with the resin sampling such as resin stripper slurry flow rates 

and dryer throughput rates. 

The survey response was due to EPA by November 30, 2009. The testing section of the 

response was due by February 28th, 2010. 

3.0 Data Processing and Standardization

The survey responses, emissions testing results, and resin sampling results were

standardized before performing technical analyses. Sections 3.1 and Section 3.2 contain 

descriptions of the data preparation and standardization steps. 

3.1 Survey Data

The ICR survey was originally formatted as a series of MS Excel spreadsheets designed 

to be imported into a MS Access database. Two sets of survey files were combined before 

analysis. The first set of surveys consisted of original November 30th, 2009 facility 

submissions. The second set of survey files contained declassified confidential business 

information (CBI) provided by EPA. Data originally claimed as CBI were declassified by EPA

for the following facilities:

o Formosa – Baton Rouge

o Formosa – Delaware City

o Formosa – Point Comfort 

o Georgia Gulf – Aberdeen 

o Georgia Gulf – Plaquemine 

o Shintech – Addis

o Shintech – Freeport

o Shintech – Plaquemine

Five facilities completed their survey response using a previous version of the survey 

template. The survey submissions were copied, archived, and reformatted to properly import

into the MS Access database. The following facilities used a previous version of the survey 

template:

o Georgia Gulf – Aberdeen

o Georgia Gulf – Plaquemine

o OxyVinyls – Deer Park

o OxyVinyls – Pasadena

o PolyOne – Pedricktown
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The structures of certain forms were also corrected due to modification by facilities. 

Data contained in the forms requiring correction were not altered. The following forms, listed by 

facility, required correction:

o OxyVinyls – Pasadena: C-1-a, K-3-a, K-3-b

o Shintech – Freeport: K-1-b

o Georgia Gulf Chemicals – Plaquemine: C-1-a, C-2-a, C-2-c, D, K-1-a

o Georgia Gulf Chemicals – Aberdeen: C-1-a

The corrected forms were imported into a MS Access database.1 Quality assurance and 

quality control checks (QA/QC) were performed to ensure the data in each MS Excel form were 

correctly imported into the Access database. Errors identified as a result of the QA/QC effort 

were addressed in subsequent iterations of the database. 

Limited amounts of data were modified to improve presentation and analysis. Data were 

modified if, and only if, the intention of the facility was directly obvious. Company and facility 

names, along with corresponding information were standardized in Forms A-1 and A-2. Units of 

latitude and longitude were also standardized. The standardized information was propagated 

through the database. Records contained in table Form_C2A were also modified. The extent of 

the modifications included, for example, separation of records containing multiple pieces of 

equipment and/or emission points in one field. Records from the following facilities were 

separated in table Form_C2A:

o Formosa – Baton Rouge

o Formosa – Point Comfort 

Five administrative tables were created in conjunction with the ICR survey form tables in 

the Access database. Two tables provide standardized process and control equipment 

descriptions while the 3 remaining tables provide a cross-walk between the MS Excel survey to 

MS Access field names, descriptions of the survey form tables, and a list of HAP and 

corresponding Chemical Abstract Service (CAS) number. 

3.2 Emissions Test Data

The emissions testing data were originally formatted as a series of MS Excel workbooks. 

Each facility submission was compiled into a single workbook2and quality assured by 

comparing the compilation with the original facility submission. 

Several corrections and clarifications were made to the compiled MS Excel work book in 

preparation of data analysis. Blank and duplicate records were removed. Process unit 

identifiers, resin grades, equipment identifiers, and dates were standardized to the format 

requested by EPA. Control equipment gas flow rates were standardized to units of dry standard 

cubic meters per minute and gas temperatures reported as Fahrenheit (°F) were converted to

Celsius (°C). Facilities that reported flow rate data with incorrect units were identified. The 

incorrect units resulted in unnecessary and erroneous unit conversion. Gas flow rate units were 

corrected by comparing the facility submitted emissions testing template to the stack test report, 

if the report was available. Facility reported compound names were compared with reported 

CAS numbers. Multiple incorrect CAS number and compound name combinations were 
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identified. The combinations were corrected based on facility input when available. If no 

facility guidance was provided, the CAS number was standardized based on the facility 

submitted compound name and CAS numbers from the year 2005 National Emissions Inventory 

and the National Institute of Standards and Technology Chemistry WebBook.3

Facilities reported several HAP concentrations as non-detect (ND) values by using the 

“less than” (<) symbol. The notation was removed and an indicator column was added to the 

data set to note which values were reported as ND. 

Several facilities also reported multiple emissions concentrations for a single HAP. 

Facilities reported multiple concentrations due to overlap of applicable HAP for each emission 

test. Therefore; a single concentration result was selected based on the criteria presented in 

Table 3-1.

Table 3-1: Criteria for Selecting Emissions Testing Result

Methods Used to Report Compound Result Selection Criteria

Method 0031 & Method 0010 Method resulting in higher 

concentration

Method 320 and Method 0031 Method 0031

Method 23/23A & Method 0031 Method 0031

Method 320 & Method 0010 Method 0010

Method 26A & Method 320 > 1 ppm; Method 26A

< 1ppm; Method 320

ppm – parts per million

Mass concentration data were converted to volumetric concentration (parts per million, 

dry volume (ppmvd)) corrected to 3 percent oxygen using Equation 1. 

6

3

2 6

10

1000 L

1m

1mol

22.4 dsL

MW g

mol

10 μg

1g

dscm

μg ppmvd @3% O

(Eq. 1)

Equation 2 was used to convert nanograms per dry standard cubic meter (ng/dscm) at 3

percent oxygen to ppmvd corrected to 3 percent oxygen.

6

3

2 6

10

1000 L

1m

1mol

22.4 dsL

MW g

mol

10 μg

1g

1000 ng

1μg

dscm

ng ppmvd @3% O

(Eq. 2)

Chlorinated dibenzodioxin and chlorinated dibenzofuran (CDD/CDF) concentrations

were standardized to ng/dscm corrected to 3 percent oxygen. CDD/CDF concentrations were 

converted to a toxic equivalency basis (TEQ) using year 2005 World Health Organization ReEvaluation of Human and Mammalian Toxic Equivalency Factors for Dioxins and Dioxin like 

Compounds.4 Concentrations for all HAP were also converted to mass flow rates using Equation 

3.
6

hr

60 min MW V

385.3ft

1 lb mol

0.028 m

1 ft

20.9 3

20.9 O

10

1

C

hr

lb

3 3 i

3

2

i 6

 (Eq. 3)

where:

lb/hr = mass flow rate in pounds per hour,

Ci = pollutant concentration in ppmvd at 3 percent oxygen,

O2 = average oxygen concentration of all pollutant three run tests,

385.3 ft3= volume, in cubic feet, of 1 pound mole of ideal gas at 20 °C 

(68 °F) and 1 atmosphere of pressure,

MWi = molecular weight of the pollutant in pounds per pound mole, and

V



= volumetric flow rate of the exhaust gas in dry standard cubic meters per 

minute.

The above corrections and standardizations represent the extent to which the emissions 

testing data set was modified. 

3.3 Resin Sampling Data

The resin sampling results were reported by each facility in a MS Excel spreadsheet 

template provided by EPA. A total of 15 facilities reported results from resin sampling and 

reported those results in the requested spreadsheet template. Data was submitted to EPA 

beginning in late February 2010 and continuing through early August 2010. The resin sampling 

results were reported as pollutant mass values for each day of sampling that was conducted at the 

outlet of the resin stripper(s). Three facilities reported their resin sampling results in terms of 

concentrations. CertainTeed – Lake Charles did not provide resin sampling results, and Dow –

Midland provided resin sampling data in lieu of completing the requested templates. Each 

facility submission was compiled into a single master file. QA/QC was performed by comparing 

the master compilation with the original facility submissions.

Data in the master MS Excel workbook were standardized and corrected in preparation of 

data analysis. Blank and duplicate records were identified and removed. Process unit identifiers, 

resin grades, equipment identifiers, production rates, moisture contents, and dates were 

standardized to the format requested by EPA. Facility reported compound names were compared

with reported CAS numbers and several incorrect CAS number and compound name 

combinations were identified. Combinations were corrected based of facility input when 

available. If no facility guidance was provided, CAS numbers were corrected based on the 

facility submitted compound name using standard CAS numbers from the 2005 National 

Emissions Inventory and the National Institute of Standards and Technology Chemistry 

WebBook.3

Several tasks were completed to prepare the emissions testing data set for analysis. Facilities

reported several HAP mass values as below detection limit or non-detect values by using the 

“less than” (<) symbol or brackets (“[ ]”) as requested. The symbol was removed and an 

indicator column was added to note which values were reported as below detection limit or as 

ND. Pollutant results that were already reported as concentrations (micrograms per liter (ug/L)
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or micrograms per kilogram (ug/kg),) were converted to parts per million (ppm) assuming a 

density of 1 gram per milliliter (g/ml) for the resin. 

On September 9, 2010, the VI also submitted a spreadsheet of the resin sampling results for 

all facilities as a supplemental data submission to EPA. The results in the VI-supplied data were 

reported as concentration values for each pollutant, and not as the calculated or corrected mass 

values requested by the Agency. No standardization or corrections were made to this data set. A 

revised data set was submitted to EPA by the VI on September 28, 2010.

4.0 References

1. Facility Information Collection Request Survey Database for the Polyvinyl Chloride 

Production Source Category. Docket ID EPA-HQ-OAR-2002-0037.

2. Emissions Testing and Resin Sampling Workbook for the Polyvinyl Chloride Production 

Source Category. Docket ID EPA-HQ-OAR-2002-0037. 

3. National Institute of Standards and Technology Chemistry WebBook, Standard Reference 

Database Number 69. http://webbook.nist.gov/chemistry/

4. 2005 World Health Organization Re-Evaluation of Human and Mammalian Toxic 

Equivalency Factors for Dioxins and Dioxin Like Compounds

http://www.who.int/ipcs/assessment/tef_update/en/