Enclosure 1

PVC Section 114 Enclosure 1 - Page 1

04/01 /2014

Attachment 1: Questions on EPA S114 Request for PVC Resin and Copolymers and Process 

Wastewater, Submitted by Vinyl Institute PVC MACT Copolymers Subgroup, May 16, 2014

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION COLLECTION REQUEST

I. Introduction

This information collection request is to be completed for operations that comprise the 

Polyvinyl Chloride and Copolymers (PVC) source category at your company. The PVC Production 

source category includes any facility which manufactures polymerized vinyl chloride. PVC is be

produced by the suspension, suspension blending, emulsion/dispersion or bulk processes, although 

other methods may be used. The source category includes the collection of

all equipment and activities necessary to produce PVC homopolymer or copolymer resin.

This information collection request consists of two parts: (1) completion of information 

collection request response forms and submission of supplemental data and information; and (2) 

sampling and analysis of PVC resin streams and PVC process wastewater streams. The results of 

resin and process wastewater analyses are reported in dedicated worksheets that are contained in a

single Microsoft Excel workbook file along with the required response forms. Except for the 

required sampling and analysis, complete this information collection request as completely as 

possible from best available existing information from the 2013 calendar year.

Instructions for obtaining the information collection request response forms are in Section II

of this enclosure. A summary of the supplemental data and information requested in this 

information collection request is in Section III. Instructions for submitting your response are in 

Section IV. Section V contains general instructions for completing your response and

includes specific guidance for completing each response form. For your convenience, we have

provided additional information on the scope and purpose of this information collection request, as 

well as useful definitions, in Attachment A. Respondents should read this material before

attempting to complete the response forms. Respondents may also wish to review the rule and 

implementation information for PVC production before completing the response forms by visiting

the EPA’s Technology Transfer Network – Air Toxics Web Site for PVC:

http://www.epa.gov/ttn/atw/pvc/pvcpg.html.

Additional information on the PVC resin and process wastewater sampling and analysis

requirements can be found in Attachment B of this enclosure.

If you have questions regarding this request, please contact Ms. Jodi Howard, Refining 

and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.

II. Instructions for Obtaining the Information Collection Request Files

The information collection request response forms are available as a single Microsoft

Excel 2007 workbook. The workbook is included with this enclosure and is titled:
Enclosure 1

PVC Section 114 Enclosure 1 - Page 2

04/01 /2014

“PVCICR_[Company]_[Facility].xlsx”

The workbook should be completed for the entire PVC production facility. Before 

submitting the file, the file name will be changed to reflect the actual company and facility (see 

Section III).

Other files included in this package are an example of how to complete the Excel 

workbook and a copy of this enclosure. Where necessary, examples of how to complete selected 

portions of the information collection request response forms are included directly in the forms 

themselves. Refer to examples and the instructions contained in this enclosure when completing 

your response.

III. Supplemental Data and Information Requested

We are requesting you submit supplemental data and information to support the 

information submitted in the information collection request response forms. The following table 

summarizes the supplemental data and information that must be submitted with your response. 

Provide actual recorded data where possible and submit that data in Microsoft Excel format. If 

recorded process data (such as CEMS data) are not available, then provide estimates based on 

engineering assessments, material balances, etc. and provide copies of estimation worksheets and 

other supporting documentation. Recorded process data, sampling results, test results, estimation 

worksheets, engineering calculations, assessments, etc. must be provided to support the 

information submitted for all parts of the information collection request response.

Except for the results of PVC resin and process wastewater analyses, the information 

provided in response to this information collection request should be from the best available 

existing information from the 2013 calendar year.

Supplemental Data and

Information

Related Equipment, Stream, 

Emission Point Time Period

Process Unit Plot Plan Process Unit N/A

Process Unit Flow Diagram Process Unit N/A

Emissions Test Reports All Control Devices Most recent test report

HAP/Total VOC Concentration,

Emissions Data or Estimates All Uncontrolled Emission Points 2013

Safety/Pressure Relief Notifications

and estimates of emissions from 

releases

Process Unit Safety/Pressure Relief

Devices 2013
Enclosure 1

PVC Section 114 Enclosure 1 - Page 3

04/01 /2014

IV. Instructions for Submitting Your Information Collection Request Response

Use the appropriate file naming format as listed below for the files you submit when 

responding to this information collection request:

Submission File Name Format

Completed Response

Workbook PVCICR_[Company]_[Facility].xlsx

Plot Plan [Company]_[Facility] _PlotPlan

Process Flow Diagram [Company]_[Facility] _PFD

Emissions Test Reports [Company]_[Facility]_[ProcessUnitID]_[ProcessEquipment/Control

DeviceID]_[YYYYMMDD]

Data/Estimates

[Company]_[Facility]_[ProcessUnitID]_[ProcessVent/EmissionPoint/Stream/Waste

waterStream/ProcessEquipment/ControlEquipment

ID]_[YYYYMMDD]to[YYYYMMDD]

For file names that include dates or date ranges, use four digits for the year (YYYY), two digits 

for the month (MM), and two digits for the day (DD).

EXAMPLE

Generic Chemical Corporation has a manufacturing facility in Anytown, USA

According to the instructions in Section II and IV, the files would be renamed as:

Submission File Name

Completed Response Workbook PVCICR_Generic_Anytown.xls

and submitted with all other required data and information outlined Section III. 

Please e-mail the completed non-confidential response to:

CCG-PVC@epa.gov

If you are submitting confidential business information (CBI) as described in Enclosure

2, then this information must be mailed to EPA in hard-copy or on a CD-ROM or DVD-ROM 

disk. Clearly mark the disk and/or the materials with the words “Confidential Business

Information” and send either via U.S. Postal Service Express Mail, registered mail, or private

courier to:

Jodi Howard

U.S. EPA Office of Air Quality Planning and Standards

Sector Policies and Program Division, Refining and Chemicals Group
Enclosure 1

PVC Section 114 Enclosure 1 - Page 4

04/01 /2014

Mail Code E143-01

Research Triangle Park, NC 27711

Additionally, if you are submitting CBI via mail in hard-copy or on CD-ROM or DVDROM disk, you must also submit a non-CBI version of your information collection request 

response to the email address listed above. DO NOT ELECTRONICALLY TRANSMIT

CONFIDENTIAL BUSINESS INFORMATION TO EPA.

If you have questions regarding this request, please contact Ms. Jodi Howard, Refining 

and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.

V. Background Information and Instructions for Completing the Information

Collection Request Response Forms

NOTE: For the purposes of this information collection request, all HAP and VOC 

concentrations and emissions are to be quantified. Do not report concentrations or 

emissions as “trace” or “minimal.” If a concentration is at or below a detection 

limit, then provide the detection limit. [RK1: We request the ability to provide 

with any HAP reported at the detection limit (DL) a textual indicator that it was 

reported at the DL.]

Form A – Company Information and Facility Information

• Forms A-1 and A-2 are where the respondent company and facilities are identified.

• In question I.1 of Form A-1, identify the legal parent company/legal corporate owner name.

In questions I.2 through I.6 provide the mailing address for the legal parent company/legal 

corporate owner.

• Identify the size of the company by selecting the appropriate range for the number of 

employees (including all subsidiaries, branches, and related establishments owned) in 

question I.7.

• On Form A-2, provide the facility name and address information requested in question II.1, 

including the latitudinal and longitudinal coordinates of the facility. Facility latitudes and 

longitudes should be reported in decimal degrees to the 5th decimal place, and longitudes 

should include negative sign, e.g. (37.91986, -87.32724) Sources of these data include EPA 

permits (e.g., NPDES permits), county property records, facility blueprints, and site plans.

• Provide the name and contact information for the facility’s technical contact in questions

III.1 through III.3 on Form A-2.

• On Form A-2, Section IV, respondents are asked to identify whether the facility is a major 

source of HAP emissions by selecting “Yes,” or “No,” in question IV.1. Section 112(a)(1) of 

the CAA defines a major source as any stationary source or group of stationary sources 

located within a contiguous area and under common control that emits or has the potential to 

emit considering controls, in the aggregate, 10 tons per year or more of any hazardous air 

pollutant or 25 tons per year or more of any combination of hazardous air pollutants.

Affected sources that have not yet commenced production of PVC resin or that are expanding 
Enclosure 1

PVC Section 114 Enclosure 1 - Page 5

04/01 /2014

existing production capacity are asked to complete all parts of this information collection
Enclosure 1

PVC Section 114 Enclosure 1 - Page 6

04/01 /2014

request. For those sources, projected actual emissions (not “Potential to Emit”) are requested 

in lieu of actual operating emissions.

• For facilities that are not major sources of HAP emissions (and select “No” for question 

IV.1), the respondent is asked to identify if and when a permit limit for their potential HAP 

emissions to avoid being classified as a major source in questions IV.2 and IV.3, respectively 

was taken.

• Indicate if the facility manufactures other products in addition to PVC resin [RK 2: Is it 

the intention to declare other products in addition to PVC and copolymer resins? Is this 

only regarding those products that use the same equipment or is the request for the entire 

site.] by selecting “Yes,” or “No,” for question IV.4 on Form A-2. If “Yes,” list the 

other products manufactured in the response field for question IV.5.

• Indicate if there are any HAP emission associated with any co-located facilities by selecting

“Yes,” or “No,” for question IV.6 on Form A-2.

Form B – Control Devices, Recovery Systems, PVC Process Wastewater Treatment

Systems, and Process Equipment

• Prior to completing the remainder of the forms (i.e., forms B through N), you should 

complete a plot plan (plant layout schematic) and process flow diagram(s) for the PVC 

production facility. Do not submit “block flow diagrams.” The level of detail requested is 

more than generally contained in “block flow” diagrams but less than that generally 

contained in piping and instrumentation diagrams (P&IDs). Process flow diagrams should 

accurately show ALL:

o Process equipment;

o Recovery systems including all recovery equipment; [RK3: The PVC MACT 

 defines recovery device and this ICR defines recovery equipment. Can EPA clarify 

 which definition will be used going forward?]

o Process wastewater treatment systems including all wastewater treatment 

equipment;

o Closed vent systems (identify the collection of piping for each closed vent system 

using a dotted-line boundary on the process flow diagram); [RK4: Can EPA 

confirm that the closed vent system is defined as that piping after the recovery 

system where no further processing, storage, or recovery is done on the stream on 

its way to the control device? Or can EPA clarify what is meant by the CVS in 

conjunction with the definition of recovery system?]

o Control devices (also clearly show any piping configurations that allow a gaseous 

stream routed to a closed vent system and control device to bypass the control 

device); [RK 5: Process flow diagrams typically do not show any bypass piping 

around the control device. Typically this is a reroute to another type of control

 device. Maintenance lines (drains and bleeds) are not sized for bypass functionality. 

Since EPA has indicated they are not asking for a P&ID, can the WG provide a 

generic diagram for a control device that would show low leg drains, and high 

point bleeds?
Enclosure 1

PVC Section 114 Enclosure 1 - Page 7

04/01 /2014

o Pressure relief devices (PRDs); [RK6: Is EPA looking for only those PRDs that 

 vent to atmosphere or all PRDs? ]

o Emission points;

o Process wastewater streams;

• Each item in the table below is to be given a unique identifier in the form of Z-x, where “Z” 

is a unique code for each item listed in the table below and x = 1, 2, 3,...n. The unique 

identifier should exactly match between the process flow diagram and information provided 

in the completed response workbook(s). Refer to Attachment A of this Enclosure for relevant 

definitions.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 8

04/01 /2014

Control devices (C-x)

Recovery systems (RS-x)

Individual recovery equipment that comprise the recovery system (RE-x)

Process wastewater treatment systems (WWT-x)

Individual wastewater treatment equipment that comprise each process

wastewater treatment system (WWE-x)

Process equipment (U-x)

Emission points (EP-x)

Process wastewater streams (W-x)

Pressure relief devices (PRD-x)

Closed vent systems (CVS-x)

Form B-1 – Control Devices

General Instructions

• Each control device should be listed in Form B-1.

• For the purposes of this information collection request, wastewater collection, handling and 

treatment equipment (including process wastewater steam strippers) are considered 

wastewater treatment equipment and not control or recovery devices. Complete Form B-3 

and E-1-a for process wastewater treatment systems and process wastewater, respectively.

• For each control device, submit a copy of the most recent emissions test report. The report 

should include information on the process operations that influenced emissions during the 

test, including the resin type being produced. Include information such as the purpose of the

test, when it was conducted and what test methods were used. If emissions test reports are not 

available, calculations based on emission factors, material balances, or engineering principles 

must be submitted and supported by submitting a step-by-step description of the calculations, 

including assumptions used and a brief rationale for the validity of the calculation method 

used. (See guidance documents listed in Attachment A, Section IV).

• For the following control devices, complete the appropriate Forms: absorbers - Form F-1;

thermal or catalytic oxidizers - Form F-2; and, condensers - Form F-3.

Specific Instructions by Form Column

• Column 1: Each control device is to be given a unique code or identifier in the form of C-x, 

where x = 1, 2, 3,...n, in Form B-1. This unique code/identifier should exactly match the 

identifier used in the process flow diagram and will be used on subsequent forms.

• Column 2: Select the type of control device from the list provided in the Form.

• Column 3: If “other” was selected in column 2, provide a description of the control device.

• Column 4: Each emission point from a control device (or from the last control device in a 

series) that exhausts directly to the atmosphere should be shown on the process flow diagram 

and is to be given a unique code or identifier of the form EP-x, where x = 1,2,3,...n in Form
Enclosure 1

PVC Section 114 Enclosure 1 - Page 9

04/01 /2014

B-1. This unique code/identifier will be used on subsequent forms. If the exhaust stream from 

the control device immediately enters a subsequent control device (e.g., exhaust from a 

thermal oxidizer is routed to an acid gas scrubber) provide the subsequent control device 

identifier instead of the emission point identifier.

Form B-2 – Recovery Systems and Closed Vent Systems

General Instructions

• Each recovery system should be listed in Form B-2.

• For the purposes of this information collection request, wastewater collection, handling and 

treatment equipment (including process wastewater steam strippers), are considered 

wastewater treatment equipment and not control or recovery systems. Complete Form B-3 

and E-1-a for wastewater treatment equipment and process wastewater, respectively.

• If you use a condenser as part of a recovery system, and emissions from the condenser are 

routed directly to the atmosphere without first passing through a control device, complete 

Form F-3 for the condenser(s).

Specific Instructions by Form Column

Table 1

• Column 1: Each recovery system is to be given a unique code or identifier in the form of RSx, where x = 1, 2, 3,...n, in Form B-2. This unique code/identifier should exactly match the 

identifier used in the process flow diagram and will be used on subsequent forms.

• Column 2: Provide a description of the recovery system.

• Column 3: Indicate if, at any point in the recovery or closed vent system, emissions can be 

discharged directly to the atmosphere. [RK7: Should the response include low leg drains 

and/or high point bleeds, sample ports, etc. located in the recovery system?] If you 

answer yes, complete Table 2.

• Columns 4-6: List the control devices that control emissions from the recovery and closed 

vent system. The control device ID(s) that you provided on Form B-1 will be available as a 

pick list in columns 4 through 6.

Table 2

• If you answered “Yes” in column 3 of Table 1, complete Table 2.

• Column 1: Identify the recovery system ID. The recovery system ID(s) that you provided in

Table 1 will be available as a pick list in column 1 of Table 2.

• Column 2: Identify each emission point that discharges directly to the atmosphere. [RK8: 

Does this include low leg drains and/or high point bleeds that during unit operation, even 

during SSM, these devices are not emission points?]

Do not list emission points for streams exiting the recovery system that are routed through a

closed vent system to a control device. Each emission point that exhausts directly to the
Enclosure 1

PVC Section 114 Enclosure 1 - Page 10

04/01 /2014

atmosphere should be shown on the process flow diagram and given a unique code or 

identifier of the form EP-x, where x = 1,2,3,...n in Form B-2. This unique code/identifier will

be used on subsequent forms.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 11

04/01 /2014

• Column 3: Identify if the emission point is used as a bypass for the control device, or, if the 

emission point is a process vent.

• Column 4: Indicate if the equipment opening standards in 40 CFR Part 61, subpart F are met 

before a discharge occurs through the emission point.

Table 3

• Column 1: Each piece of recovery equipment included in the recovery system should be 

shown on the process flow diagram and given a unique code or identifier of the form RE-x, 

where x = 1, 2, 3,...n, in Table 2 of Form B-2. This unique code/identifier will be used on 

subsequent forms.

• Column 2: Provide a description of the recovery equipment.

• Column 3: Indicate recovery system ID to which the recovery equipment belongs. The 

recovery system ID(s) you provided in Table 1 will be available as a pick list in column 3.

Form B-3 – PVC Process Wastewater Treatment Systems

General Instructions

• Each PVC process wastewater treatment system should be listed in Form B-3.

Specific Instructions by Form Column

Table 1

• Column 1: Each PVC process wastewater treatment system is to be given a unique code or 

identifier in the form of WWT-x, where x = 1, 2, 3,...n, in Form B-3. This unique 

code/identifier should exactly match the identifier used in the process flow diagram and will 

be used on subsequent forms.

• Column 2: Provide a description of the treatment system (a pick list of common descriptions 

is provided).

• Column 3: If “other” was selected in column 2, provide a description of the treatment system.

• Column 4: Indicate if emissions from the treatment system are routed directly to the 

atmosphere without first passing through a recovery system or control device.

• Column 5-7: If you answered “Yes” in column 4, list the emission point ID(s). Each emission 

point from treatment systems that exhausts directly to the atmosphere should be shown on the 

process flow diagram and given a unique code or identifier of the form EP-x, where x =

1,2,3,...n in Form B-3. This unique code/identifier will be used on subsequent forms.

• Column 8: If you answered “No” in column 4, indicate if emissions from the treatment

system are routed to a recovery system.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 12

04/01 /2014

• Column 9: If you answered “Yes” in column 8, select the appropriate recovery system ID

entered on Form B-2.

• Column 10-12: If you answered “No” in column 8, select the control devices that control 

emissions from the treatment system. The control device ID(s) your provided in Form B-1 

will be available as a pick list in columns 10 through 12.

Table 2

• Column 1: Each piece of equipment included in the treatment system should be shown on the 

process flow diagram and given a unique code or identifier of the form WWE-x, where x =

1, 2, 3,...n, in Table 2 of Form B-3. This unique code/identifier will be used on subsequent 

forms.

• Column 2: Provide a description of the equipment.

• Column 3: Indicate the corresponding treatment system ID to which the process wastewater 

treatment equipment belongs. The PVC process wastewater treatment system ID(s) you 

provided in Table 1 will be available as a pick list in column 3.

Form B-4 – Process Equipment

General Instructions

• All remaining process equipment should be listed on Form B-4. Do not list any equipment 

previously noted on Forms B-1 through B-3.

• Process equipment may be grouped on the process flow diagram if and only if the individual 

pieces of equipment in the group are of identical design and all process vents exiting each 

piece of process equipment are routed to the same control device.

• If emissions from a condenser (not previously listed as part of a recovery system) are routed 

directly to the atmosphere without first passing through a recovery system or control device, 

complete Form F-3 for the condenser(s).

Specific Instructions by Form Column

• Column 1: Each piece of process equipment is to be given a unique code or identifier in the 

form of U-x, where x = 1, 2, 3,...n, in Form B-4. This unique code/identifier should exactly 

match the identifier used in the process flow diagram and will be used on subsequent forms.

• Column 2: Provide a description of the process equipment.

• Column 3: Provide an indication if emissions from the process equipment are routed directly 

to the atmosphere without passing first through a recovery system or control device.

• Column 4-6: If you answered “Yes” in column 3, list the emission point ID(s). Each emission 

point should be shown on the process flow diagram and is to be given a unique code or 

identifier of the form EP-x, where x = 1,2,3,...n in Form B-4. This unique code/identifier

will be used on subsequent forms. If the emission point is controlled (and therefore listed in
Enclosure 1

PVC Section 114 Enclosure 1 - Page 13

04/01 /2014

Form B-1) do not duplicate the emission point in Form B-4; only list uncontrolled emission 

points.

• Column 7: If you answered “No” in column 3, indicate if emissions from the process

equipment are routed to a recovery system.

• Column 8: If you answered “Yes” in column 7, select the appropriate recovery system ID

entered on Form B-2.

• Column 9-11: If you answered “No” in column 7, list the control device identifiers 

previously identified on Form B-1. If emissions are controlled by multiple control devices, 

list each control device identifier in the order of control (e.g., the overhead stream from a 

resin stripper (U-1) is controlled by 1) a thermal oxidizer (C-1) and an acid gas scrubber (C2)).

Form C – Economic Life and Applicable Regulations

• On Form C, provide the information on the age of the PVC production facility and its 

remaining economic life. [RK9: Can EPA define what is meant by remaining 

economic life? Is it depreciable life? In some instances remaining depreciable life 

from two identical pieces of equipment may vary depending on their installation date.

Does EPA recognize that this information is CBI?]

• For all regulations that apply to any part of the PVC production facility, provide the 

regulation citation, the regulation title, and the control device, recovery equipment, 

wastewater treatment equipment, or process equipment or identifier listed in Form B.

Form D-1 – Resin Production Information

General Instructions

• The purpose of Form D-1 is to identify the relative magnitude of the operation in terms of 

resin types [RK10: Please confirm that the WG should define resin type as the per PVC 

MACT definitions and identify the comonomer used.]

and production amounts. [RK11: The WG intends to submit production amounts in a CBI 

hard copy (CD or paper copy) and then redact the information for the other submission. 

Is this acceptable?]

• Complete rows 1 through 8 of Form D-1 for each type of resin produced by the facility in

2013. If the facility produced the same type of resin using different types of resin strippers, 

include multiple entries for the same resin type for each unique combination of descriptors 

required by the Form.

Specific Instructions by Form Row

• Row 1: Indicate each resin type produced by the facility in 2013. Refer to Attachment A of 

this enclosure for definitions of each resin type that is provided in the pick list. If the resin 

types in the pick list, and corresponding definitions do not describe the type of resin 

produced by the facility in 2013, select “other.”
Enclosure 1

PVC Section 114 Enclosure 1 - Page 14

04/01 /2014

• Row 2: If you selected “other” for row 1, please provide a description of the resin type.

• Row 3: Please select a description of the resin stripper(s) used to remove vinyl chloride 

and/or other organic HAP from the resin. Complete multiple columns for the same resin type 

if resin strippers matching different descriptions were used.

• Row 4: If you selected “other” for row 3, please provide a description of the resin stripper(s).

• Row 5: Indicate if the resin stripping process type is “batch” or “continuous” in row 5.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 15

04/01 /2014

• Row 6: Provide the 2013 annual production (in pounds of resin) for the resin type, [RK12: 

Can EPA provide a separate sheet to submit this as CBI?] resin stripper description, and resin 

stripping process type combination. Provide the value in terms of how the facility typically

accounts for total production (i.e., if the resin is sold and accounted for on a dry basis (e.g., a

suspension resin), list dry pounds; if the resin is sold and accounted for on a wet basis (e.g., a

dispersion resin that is not dried before being sold), provide the production on a wet basis).

• Row 7: List the process equipment ID(s) of the resin strippers in row 7. The process 

equipment ID(s) will be available as a pick list, based on the values provided on Form B-4.

• Row 8: If the equipment ID entered on Form B-4 represents more than one resin stripper, 

indicate the total number of resin strippers for the resin type, resin stripper description, and 

resin stripping process type combination.

Form D-2 – 30 Day Resin Sampling – Stripper Outlets

• Refer to Attachment B, “Summary of Test Procedures, Methods, and Reporting 

Requirements for Resin and Process Wastewater Sampling and Analysis at Polyvinyl 

Chloride and Copolymers Facilities” of this enclosure for requirements and instructions 

regarding sampling and analyzing stripped resin in response to this information collection 

request. Use Form D-2 to record and submit your resin sampling and analysis results, 

following the instructions included in the Form and Attachment B.

• Report the total daily resin production rate [RK13: To be reported as CBI. EPA is 

requesting that the total daily resin production rate be reported. Does EPA mean the daily 

production of resin? The way this is requested as rate is confusing. On a batch basis, it is 

more accurate for each producer to simply report the amount of that batch sampled. Is EPA 

in agreement with that method of reporting?] from the sampled resin strippers for each day. 

Do not report the entire facility production, unless all resin strippers were sampled on that 

day. Production rates should be provided in the facilities standard production measure (i.e., 

if the facility produces a suspension resin and tracks production on a dry product basis, 

report the daily production on a dry resin basis).

Form E-1-a – Process Wastewater [RK14: Can the Agency clarify that this survey is for 

copolymer facilities in addition to PVC facilities? Table 5 specifically requests non-PVC 

production. Does the Agency mean non-PVC and non-copolymer wastewater?]

General Instructions

• Form E-1-a collects information on process wastewater.

Specific Instructions by Form Column/Row

Table 1

• Columns 1-2: Enter the name and PVC process wastewater stream ID of each process 

wastewater stream not treated by a PVC process wastewater treatment system on Table 1 of 

Form E-1-a. The PVC process wastewater stream should be shown on the process flow 

diagram and is to be given a unique code or identifier of the form W-x, where x = 1,2,3,...n.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 16

04/01 /2014

• Columns 3-6: Provide the stream flow rate in gallons per day in column 3 through 5. Select 

the flow rate determination method from the pick list in column 6.

• Column 7: Provide the number of operating days per year for the stream in column 7.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 17

04/01 /2014

• Column 8: Select the type of originating equipment/device in column 8. The selection in 

column 8 will determine which equipment ID lists (i.e., recovery, process or control devices) 

are available for selection in column 9.

• Column 9: Select the originating equipment/device ID in column 9. The available ID(s) will 

be based on your entries in Forms B-1 through B-4 and your selection in column 8.

• Columns 10-12: In column 10, select the appropriate destination code based on the 

descriptions in Table 4 of Form E-1-a. In column 11, provide the associate destination 

information corresponding to the destination description in column 3 of Table 4. In column

12, indicate if the stream is exposed to the atmosphere at any point between the originating 

equipment and the stream destination.

Table 2

• Complete Table 2 of Form E-1-a for each wastewater steam exiting a PVC process 

wastewater treatment system.

• Column 1: Select the PVC process wastewater treatment system ID from the entries on Form

B-3.

• Column 2: Indicate if the treatment system is a batch or continuous operation.

• Column 3: Enter the PVC process wastewater stream ID of each process wastewater stream 

exiting a PVC process wastewater treatment system in column 3. The PVC process 

wastewater stream should be shown on the process flow diagram and is to be given a unique 

code or identifier of the form W-x, where x = 1,2,3,...n.

• Columns 4-7: Provide the stream flow rate in gallons per day in column 4 through 6. Select 

the flow rate determination method from the pick list in column 7.

• Column 8: Provide the number of operating days per year for the stream in column 8.

• Columns 9-11: In column 9, select the appropriate destination code based on the descriptions 

in Table 4 of Form E-1-a. In column 10, provide the associate destination information 

corresponding to the destination description in column 3 of Table 4. In column 11, indicate if 

the stream is exposed to the atmosphere at any point between the originating equipment and 

the stream destination.

Table 3

• Row 1: Complete Table 3 of Form E-1-a for each wastewater steam stripper. Select the PVC

process wastewater treatment ID corresponding to each wastewater stripper entered on Table

2 of Form B-3.

• Rows 2-7: Provide the corresponding design and operating feed rate for each wastewater 

stripper in rows 2 through 7.

• Rows 8-19: For each wastewater stripper, complete rows 8 through 19 regarding operating 

and design characteristics as completely as possible.

• Rows 20-21: Provide the year the wastewater stripper was installed and cite any regulations 

applicable to the wastewater stripper.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 18

04/01 /2014

Table 5

• Column 1: For any non-PVC production process wastewater [RK15: Can the Agency 

clarify that this Table is for any non-PVC and non-copolymer production process 

wastewater?] stream entering a PVC process wastewater treatment system, provide the

source of the process wastewater stream.

• Columns 2-5: Provide the stream flow rate in gallons per day in column 2 through 4. Select 

the flow rate determination method from the pick list in column 5.

• Column 6: Provide the number of operating days per year for the stream in column 6.

• Columns 7: In column 7, select the PVC process wastewater treatment system ID that the

non-PVC production process wastewater stream enters, based on the ID(s) provided in Table

1 on Form B-3.

Form E-1-b – Maintenance Wastewater

• Complete Form E-1-b for maintenance wastewater.

• Indicate if your facility is subject to any Federal, State, local or other requirements to store, 

treat or otherwise handle maintenance wastewater. If so, provide the regulation citation or 

permit requirement as appropriate.

• If your facility is not subject to any Federal State, local or other requirements for 

maintenance wastewater, provide responses to the remaining questions on the Form.

Form E-2-a – 30 Day PVC Process Wastewater Sampling and Analysis Data [RK16: Can 

the Agency clarify that 30 samples are what is intended as opposed to 30 continuous days or 

30 operating days? Can the Agency clarify that both PVC and copolymer process

wastewater is being requested?]

• Refer to Attachment B, “Summary of Test Procedures, Methods and Reporting Requirements 

for Resin and Process Wastewater Sampling and Analysis at Polyvinyl Chloride and 

Copolymers Facilities” of this enclosure for requirements and instructions regarding

sampling and analyzing process wastewater in response to this information collection

request. Use Form E-2-a to record and submit [RK17: Is the exit stream temperature to 

indicate at the bottom of the WW stripper or at the point of sampling, which may be done 

after the incoming feed heat exchangers?] your process wastewater sampling and analysis 

results, following the instructions included in the Form and Attachment B.

Form E-2-b – 30 Day PVC Process Wastewater Sampling Production Data

• For questions 1 and 2 on Form E-2-b, provide the process wastewater sampling start and end 

dates.

• For question 3, provide the type and total pounds of resin produced during the sampling 

period. If more than 1 type of resin was produced, select “other” and indicate all types of 

resins produced in response to 3.c.

• In response to question 4, provide the resin production information for resin production that 

generated wastewater that was treated during the sampling period.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 19

04/01 /2014

• Provide the total daily maximum PVC production capacity [RK18: Can EPA clarify that this 

daily max PVC production capacity is based on plant design and not the maximum achieved during the 

sampling period?] in response to question 5.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 20

04/01 /2014

Form F – Control Devices

General Instruction

• Complete Form F-1 for each absorber used as a control device, or for any absorber that emits 

directly to the atmosphere.

• Complete Form F-2 for each thermal or catalytic oxidizer.

• Complete Form F-3 for each condenser used as a control device or for any condenser that 

emits directly to the atmosphere.

Specific Instructions by Form Row

Form F-1

• Rows 1-2: Select the type of equipment (i.e., control device, recovery equipment or process 

equipment). Then in row 2, select the equipment ID you entered into the corresponding Form 

B.

• Rows 3-4: Select the type of absorber from the pick list. If “other,” provide a description of

the absorber type in row 4.

• Rows 5-14: Provide the operating characteristics of the absorber in rows 5 through 14.

Provide as much of the information as possible.

• Rows 15-16: Indicate the year the equipment was installed and cite any applicable 

regulations.

Form F-2

• Row 1: Select the control device ID (based on the values you entered in Form B-1).

• Rows 2-3: Provide the number of operating hours per year and indicate if the device is 

considered emergency equipment.

• Row 5: Indicate the type of oxidizer (i.e., thermal or catalytic).

• Rows 6-35: Provide the design parameters and operating characteristics requested in rows 6 

though 35.[RK19: Can EPA clarify which information should be provided as the design 

parameters and which provided for typical operating characteristics? As the form F-2 now 

stands, there are only two items, nos. 12 & 13, which are related to design parameters; is 

this correct?] Complete as much of the information as possible for each oxidizer.

• Rows 36-37: Indicate the year the equipment was installed and cite any applicable 

regulations.

Form F-3

• Rows 1-2: Select the type of equipment (i.e., control device, recovery equipment, or process 

equipment). Then in row 2, select the equipment ID you entered into the corresponding Form 

B.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 21

04/01 /2014

• Rows 3-4: Select the type of condenser from the pick list. If “other,” provide a description of

the condenser type in row 4.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 22

04/01 /2014

• Rows 5-12: Provide the operating characteristics of the condenser in rows 5 through 12.

Provide as much of the information as possible.

• Rows 15-16: Indicate the year the equipment was installed, and cite any applicable 

regulations.

Form G –Cooling Towers and Heat Exchange Systems

• Complete Form G for each recirculating heat exchange system (cooling tower) at the PVC 

production facility following the instructions contained within the form. If the facility has 

multiple cooling towers, complete a copy of Form G for each cooling tower.

• In Table 1.a, provide the requested cooling tower identification information including the 

equipment ID as entered on Form B-4 and the total cooling tower return flow rate in gallons 

per minute. Indicate the number of processes served by the cooling tower and how many of 

the processes are from a PVC production process unit. Indicate if the heat exchange system is 

monitored for the presence of one or more HAP or VOC in the cooling water.

• In Table 1.b, provide the requested information regarding cooling tower emission reduction 

measures. If individual cooling tower return lines are monitored individually, provide the 

information for each heat exchange system from a PVC production process unit; otherwise, 

provide the requested information for the cooling tower.

• In Table 2, indicate if your PVC production facility uses any once-through heat exchange 

systems. If you created copies of Form G because you operate multiple cooling towers, a 

response for Table 2 is only required for one copy of Form G.

• Submit copies for 2013 of monitoring data, records or any leaks detected, dates of efforts to 

repair leaks, methods and procedures used to confirm repair of leaks and dates final repairs 

were completed.[RK20: This appears to be a duplication of Form G. Can EPA clarify that 

this additional request is in addition to all the information already provided in Form G? 

What is the purpose of Form G if all this information is being requested in a different 

format?]

• Submit a copy of the heat exchange system leak detection and repair procedures.

Form H – Equipment Leaks

• Complete Form H for equipment leaks at the PVC production facility.

• Provide information regarding your facility’s leak detection and repair (LDAR) program in

Table 1.

• In Table 2, provide equipment counts for all equipment at your facility in the source 

category. In addition, provide the subtotal of the equipment that are associated with your 

closed vent system(s).

• In addition to completing Form H, submit a copy of the leak detection and repair procedures 

for the facility.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 23

04/01 /2014

Form I – Equipment Opening

Table 1

• Complete this Form for each piece of process equipment, [RK21: Can similar 

equipment be grouped into one form?] recovery equipment and any additional 

equipment that is not assigned an equipment ID (e.g., in-line filters).

• Complete a separate Form I for each piece of process equipment, recovery equipment or 

other equipment that was opened in 2013. Identify the equipment (by selecting the recovery 

or process equipment ID from Forms B-2 or B-4 if applicable). Indicate the number of times 

the equipment was opened during 2013 and the reasons for opening the equipment (list all 

that apply). Provide the equipment volume in cubic meters.

• Indicate how the HAP concentration of the equipment is determined, and how (if at all) HAP

emissions are controlled.

Table 2

• In Table 2, list the individual HAP present in the equipment and the concentration of each

HAP at the equipment opening.

• Provide the total mass of each HAP emitted from opening the equipment in 2013, and a basis 

for the emissions values. Values should be reported for normal operations; not for startups, 

shutdowns, or malfunctions.

• Provide copies of estimation worksheets and any other relevant documentation.

• If any material is removed from the equipment, complete Form J.

Form J – Off-Specification Resin and Material Removal from Equipment

• Form J covers resin that is removed from equipment and is not processed further through the 

normal processing steps. Examples include, but are not limited to, off-specification resin 

removed from the polymerization reactor or any other downstream process equipment, resin 

removed from equipment during maintenance and cleanout operations, etc. Complete Form J 

if any material was removed from equipment in 2013. Complete this Form for individual 

equipment, including equipment that is not assigned an Equipment ID (e.g., in-line filters).

Table 1

• In Table 1, identify the equipment from which the material was removed and the amount of 

material removed in 2013. Provide detailed descriptions of the procedures used to remove the 

material, the procedure for controlling HAP emissions from the material during and after 

removal from equipment, and the fate/disposition of the material beginning from the time it

is removed from the equipment.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 24

04/01 /2014

Table 2

• In Table 2, identify the individual HAP and concentration present in the material 

immediately prior to removal from the equipment and before being mixed with other 

materials or fluids. In the “Notes” column, provide the basis for the concentration value.

• For all resin in 2013 that was discharged from further processing, did not continue through 

the process under normal operating conditions or was otherwise removed from the 

polymerization reactor(s) as off-grade or off-specification resin [RK22: The Working Group 

intends to only report on resin that was removed from equipment before completing normal 

processing steps. Please provide guidance if this is incorrect.] or removed at any other point 

in the process unit other than finished resin storage; submit with your response records of:

• Resin type and resin grade [RK23: The Working Group intends to add resin 

category e.g. homopolymer or copolymer and comonomers used (if any) in order 

to be consistent with other reporting throughout this document]

• Amount of resin removed (in pounds)

• HAP and VOC content (weight %)[RK24: HAP and VOC content (weight %) 

other than vinyl chloride may not normally be analyzed for any resin. Does EPA 

understand that this data is not likely to be available?]

• Description of the circumstances that resulted in the removal of the resin from 

the process, and

• Ultimate disposition of the resin

Form K-1 – Tanks, Vessels, and Portable Containers Used for Feedstock Storage, Product

Storage, Vent Gas Storage, Holding, and Wastewater

• Complete a separate Form K-1 for each tank, vessel portable container used for feedstock 

storage, product storage, holding and wastewater, including surge control vessels that are 

used to hold process vent gas prior to the control device for 2013 only. Do not include gas

holders on Form K-1 (refer to Attachment A, Section V of this Enclosure for the definition of 

a gas holder). Complete Form K-2 for gas holders.

• In Table 1, identify the process equipment by selecting the equipment ID provided on Form 

B-4 (if applicable). If the equipment was not identified on Form B-4, provide an equipment 

description.

• Provide a detailed description of the equipment, and include (if applicable) if the tank is a 

fixed, floating internal, or floating external roof.

• Select the purpose of the equipment from the pick list provided. If none of the options on the 

pick list accurately describe the purpose of the equipment, please select “Other” and specify 

the purpose in the next row.

• Indicate the number of turnovers for 2013, the equipment volume and the average storage 

temperature.

• Indicate how the HAP concentration of emissions from the tank/vessel/container are 

determined and if HAP emissions are controlled, identify the method of control.

• In Table 2, indicate the individual HAP contained in the tank/vessel/portable container and 
Enclosure 1

PVC Section 114 Enclosure 1 - Page 25

04/01 /2014

the corresponding vapor pressure. Provide concentration values and total emissions for 2013.

• Provide copies of estimation worksheets and any other relevant documentation.
Enclosure 1

PVC Section 114 Enclosure 1 - Page 26

04/01 /2014

Form K-2 – Gas Holders

• In Table 1, indicate if your facility uses gas holders (refer to Attachment A, Section V of this 

Enclosure for the definition of a gas holder). If you answer “No,” do not complete the 

remainder of the Form. If “Yes,” provide the number of gas holders at the PVC production 

facility, and if HAP emissions are controlled, provide a description of the method of control.

• In Table 2, identify the individual HAP present in the gas holders at the PVC production 

facility and their corresponding vapor pressures. Provide the total emissions of each HAP for

2013. Describe the method used to estimate emissions from gas holders in the “Notes”

column of Table 2.

Form L –Startup, Shutdown and Malfunction [RK25: Since PVC and copolymers are made 

in batch reactors, can EPA clarify that start up and shutdown specifically does not include 

startup and shutdown of normal batch reactor operations? This is specifically excluded in 

the MON.]

• Complete Form L for startups, shutdowns and malfunctions during 2013 as completely as 

possible.

• Each column in Form L represents a single startup, shutdown or malfunction event. Provide 

emissions in total pounds for the event.

• Submit with your response to this information collection request, copies of all records of 

emissions during periods of process startup, shutdown and malfunctions for 2013.

Form M – Factors that Affect HAP/VOC Emissions Reductions

• On Form M, provide the requested information regarding pollution reduction or source 

reduction measures taken by the PVC production facility.

• During the completion of Form M, clearly distinguish between pollution reduction and 

source reduction measures. Pollution reduction measures alter the physical, chemical or 

biological characteristics or the volume of a HAP and VOC through a process or activity 

which itself is not integral to and necessary to produce a product or provide a service. The

use of “add-on” devices to capture and control (recover or destroy) HAP and VOC emissions

are pollution reduction measures. In contrast, source reduction measures reduce the amount 

of any HAP and VOC prior to recycling, treatment or disposal. Source reduction measures 

include equipment or technology modifications, process or procedure modifications, 

reformulation or redesign of products, substitution of raw materials and improvements in 

housekeeping, maintenance, training or inventory control.

Form N – Miscellaneous

• This Form includes a question on whether the controls or process changes on the source are 

the result of new source review (NSR) requirements. The last question asks the respondent to 

describe any other factors not addressed in the above questions that might serve to

distinguish subcategories.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 1

04/01/2014

BACKGROUND FOR POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION 

MACT STANDARDS DEVELOPMENT INFORMATION COLLECTION REQUEST

A-I. Introduction

The purpose of this attachment is to provide the respondent with additional detail on the 

relevant requirements of the Clean Air Act, the regulatory background of the polyvinyl chloride 

and copolymers production source category and to provide a list of definitions of key terms used 

in the information collection request.

A-II. Summary of Clean Air Act Requirements

The maximum achievable control technology (MACT) standards development 

information collection request was developed by the U. S. Environmental Protection Agency’s 

(EPA) Office of Air Quality Planning and Standards Emission Standards Division 

(OAQPS/ESD) to help the EPA meet its obligations under the Clean Air Act Amendments of

1990. Specifically, the Clean Air Act Amendments require the EPA to develop regulations under 

Section 112(d) to limit emissions of hazardous air pollutants (HAP) from major and area sources 

of emissions. Section 112(a)(1) defines a major source as “any stationary source or group of 

stationary sources located within a contiguous area and under common control that emits or has 

the potential to emit considering controls, 10 tons per year or more of any hazardous air pollutant 

or 25 tons per year or more of any combination of hazardous air pollutants.” Based on the 

Administrator’s determination, the EPA may lower the major source cutoff for individual HAP. 

An area source is “any stationary source of hazardous air pollutants that is not a major source.”

The Clean Air Act Amendments of 1990 prescribe an analytical framework that the 

EPA is to apply in developing national emission standards for hazardous air pollutants 

(NESHAP) for major sources. A key concept in this framework is the establishment of the 

MACT floor. The amendments specify that NESHAP for existing sources in a particular 

category or subcategory are to be no less stringent (but may be more stringent) than the average 

emission limitation achieved by the best performing 12 percent of the existing sources in such 

category or subcategory of sources. In categories or subcategories with less than 30 sources, the 

floor is to be based on the average emission limitation achieved by the best performing

5 sources. The MACT floor for new sources is the emission control that is achieved in practice 

by the best controlled similar source.

The Clean Air Act Amendments allow the EPA Administrator to "distinguish among 

classes, types, and sizes of sources within a category or subcategory in establishing such 

standards" (Section 112(d)).

A-III. Regulatory Background for the Polyvinyl Chloride and Copolymers Production

Source Category

On October 21, 1976, the EPA promulgated emission standards for vinyl chloride under 

the risk-based standard then in effect (41 FR 46560; 40 C.F.R. Subpart F (§§ 61.60 - 61.71); “the 

Part 61 NESHAP”). When Congress amended the CAA in 1990, it required the EPA to
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 2

04/01/2014

implement technology based standards. As a result, the EPA proposed MACT standards for the

Polyvinyl Chloride and Copolymers Production source category on December 8, 2000 (65 FR

76958) and promulgated final MACT standards for the source category on July 10, 2002 (67 FR

45886) (“the Part 63 NESHAP”). EPA adopted most of the Part 61 NESHAP as the new Part 63

NESHAP and the Part 61 standards became the MACT floor for existing sources.

Mossville Environmental Action NOW and Sierra Club petitioned the U.S. Court of 

Appeals of the District of Columbia to review various provisions of the Part 63 NESHAP. The 

Part 63 NESHAP was vacated on June 18, 2004 in Mossville v. EPA, 370 F. 3d. 1232 (D.C.Cir.

2004) and remanded to the agency for it to reconsider or properly explain its methodology for 

regulating HAPs emitted in PVC production other than vinyl chloride by use of a surrogate.

On April 17, 2012, the EPA promulgated revised standards for PVC major and area 

sources. After promulgation, the Administrator received petitions for reconsideration of certain 

provisions in the final rules.

The purpose of the current information collection is to gather data from additional PVC 

production facilities that were not included in the EPA’s data collection efforts in support of the 

April 2012 rulemaking. The collected data will support analyses of environmental and economic 

impacts of various revisions to the current Part 63 NESHAP.

A-A-IV. Guidance Documents

Following is a list of EPA guidance documents and resources that may be useful to respondents 

in estimating HAP emissions.

1. Compilation of Air Pollutant Emission Factors: Volume I: Stationary Point and 

Area Sources. U. S. Environmental Protection Agency. Research Triangle Park, 

N.C. 1995. http://www.epa.gov/ttn/chief/ap42/index.html

2. Factor Information Retrieval (FIRE) Data System. U. S. Environmental Protection

Agency. http://cfpub.epa.gov/oarweb/index.cfm?action=fire.main

3. Protocol for Equipment Leak Emission Estimates. U. S. Environmental Protection

Agency. Research Triangle Park, N.C. November 1995. Publication No.: EPA453/R-95-017.

4. Batch Process ACT. U. S. Environmental Protection Agency. Research Triangle

Park, N.C. February 1994. Publication No.: EPA-453/R-94-020.

A-V. Key Term Definitions [RK26: Can EPA include a definition of Closed Vent System?]

The following definitions are provided for the purpose of the information collection request only. 

They are not intended to replace statutory definitions or regulatory definitions developed 

elsewhere.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 3

04/01/2014

Bulk process/resin: A process for producing polyvinyl chloride resin that is 

characterized by a two-step anhydrous polymerization 

process: the formation of small resin particles in a prepolymerized reactor using small amounts of vinyl chloride 

monomer, an initiator, and agitation; and the growth of the 

resin particles in a post polymerization reactor using 

additional vinyl chloride monomer. Resins produced using 

the bulk process are referred to as bulk resins.

Control device: A combustion device, recovery device, recapture device, or 

any combination of these devices used to comply with a 

regulation, numerical emission limit, work practice 

standard, etc. Process condensers are not control devices.

Dispersion process/resin: A process for producing polyvinyl chloride resin that is 

characterized by the formation of the polymers in soap 

micelles that contain small amounts of vinyl chloride 

monomer. Emulsifiers are use to disperse vinyl chloride 

monomer in the water phase. Initiators used in the 

dispersion process are soluble in water. Resins produced 

using the dispersion process are referred to as latex or 

dispersion resins.

Feedstock: Raw material/input to the process unit.

Gas Holder: A surge control vessel with a bell that is floating in a vessel 

filled with water that is used to store gases from the PVC 

production process prior to being recovered or sent to a 

process vent control device. The bell rises and falls as lowpressure gases enter and leave the space beneath the bell and 

the water provides a seal between the enclosed gas within

the floating bell and the ambient air.

Hazardous Air Pollutants (HAP): See 42 U.S.C. §7412(a)(6).
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 4

04/01/2014

Maintenance wastewater: Wastewater generated by the draining of process fluid from 

components in the PVCPU into an individual drain system 

prior to or during maintenance activities. Maintenance 

wastewater can be generated during planned and unplanned 

shutdowns and during periods not associated with a 

shutdown. Examples of activities that can generate 

maintenance wastewaters include descaling of heat 

exchanger tubing bundles, hydroblasting PVCPU process 

components such as polymerization reactors, vessels and 

heat exchangers, draining of low legs and high point bleeds, 

draining of pumps into an individual drain system, draining 

of portions of the PVCPU for repair and water used to wash 

out process components or equipment after the process 

components or equipment has already been opened to the 

atmosphere.

Malfunction: Any sudden, infrequent and not reasonably preventable 

failure of air pollution control and monitoring equipment, 

process equipment, or a process to operate in a normal or 

usual manner which causes, or has the potential to cause, 

the emission limitations in an applicable standard to be 

exceeded. Failures that are caused in part by poor

maintenance or careless operation are not malfunctions. (40

CFR 63.2)

Polyvinyl Chloride and

Copolymers Production Facility:

The collection of all polyvinyl chloride and copolymers 

production process unit, storage vessels, surge control 

vessels, heat exchange systems, wastewater, and process 

wastewater treatment systems that are associated with 

producing polyvinyl chloride.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 5

04/01/2014

Polyvinyl Chloride and 

Copolymers Production Process 

Unit or PVCPU:

A collection of process components assembled and 

connected by hard-piping or duct work, used to process raw 

materials and to manufacture polyvinyl chloride and/or 

polyvinyl chloride copolymers. A PVCPU includes, but is 

not limited to, polymerization reactors; resin stripping 

operations; resin blend tanks; resin centrifuges; resin dryers; 

resin product separators; recovery devices; reactant and raw 

material charge vessels and tanks; holding tanks, mixing

and weighing tanks; finished resin product storage tanks or 

storage silos; finished resin product loading operation; 

connected ducts and piping; equipment including pumps, 

compressors, agitators, pressure relief devices, sampling 

connection systems, open-ended valves or lines, valves and 

connectors and instrumentation systems. A PVCPU does 

not include chemical manufacturing process units, as

defined in §63.101, that produce vinyl chloride monomer or 

other raw materials used in the PVC polymerization

process.

Polyvinyl Chloride and Copolymer

Resin (PVC Resin):

Polyvinyl Chloride Copolymer:

Polyvinyl Chloride Homopolymer:

The general reference to any PVC homopolymer or 

copolymer resin manufactured by the suspension, 

dispersion, bulk, and/or solution processes.

A synthetic thermoplastic polymer that is derived from the 

simultaneous polymerization of vinyl chloride and another 

monomer such as vinyl acetate. Polyvinyl chloride 

copolymer is produced by different processes, including, but 

not limited to, suspension, dispersion/emulsion, suspension 

blending, and solution processes.[RK27: Some copolymer is 

produced in a latex form.]

Polyvinyl chloride homopolymer means a synthetic 

thermoplastic polymer that is derived from the 

polymerization of vinyl chloride and has the general 

chemical structure (-H2CCHCl-)n. Polyvinyl chloride 

homopolymer is typically a white powder or colorless 

granule.[RK28: Some homopolymer is produced in a 

latex form] Polyvinyl chloride homopolymer is produced 

by different processes, including (but not limited to), 

i di i / l i bl di d b lk 
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 6

04/01/2014

Process equipment: Any unit operation or group of unit operations or any part of 

a process or group of parts of a process that are assembled

to perform a specific function. Examples of process 

equipment include, but are not limited to, polymerization 

reactors, PVC resin strippers, resin dewatering and drying 

equipment storage tanks and vessels, cooling towers and 

heat exchange systems, and transfer operations.

Process unit: The process components assembled and connected by pipes 

or ducts to process raw and/or intermediate materials and to 

manufacture an intended product. For the purposes of this 

information collection request, process unit includes, but is 

not limited to, polyvinyl chloride production process.

Process wastewater: Wastewater that comes into direct contact with HAP or 

results from the production or use of any raw material, 

intermediate product, finished product, by-product or waste 

product containing HAP, but that has not been discharged 

untreated as wastewater. Examples are product tank 

drawdown or feed tank drawdown; water formed during a 

chemical reaction or used as a reactant; water used to wash 

impurities from organic products or reactants; water used to 

cool or quench organic vapor streams through direct

contact; water discarded from a control device; and 

condensed steam from jet ejector systems pulling vacuum 

on vessels containing organics. Gasholder seal water is not 

process wastewater until it is removed from the gasholder.

Process wastewater stream: Each individual waste stream exiting an individual piece of 

process equipment (including, but not limited to, resin 

stripping equipment, knockout pots, condensers, 

centrifuges, and scrubbers) prior to being combined with 

any other stream. Process wastewater streams also include 

combined streams exiting wastewater collection tanks, 

wastewater treatment equipment/processes, etc.

PVC process wastewater treatment 

equipment:

An individual piece of equipment capable of and normally 

used for the purpose of removing organic compounds from 

a process wastewater stream, used alone or in combination 

with other PVC process wastewater treatment equipment. 

Examples include, but are not limited to, wastewater 

collection, holding, and equalization tanks, wastewater 

steam and vacuum strippers, and wastewater stripper 

feed/bottoms heat exchanger.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 7

04/01/2014

PVC process wastewater treatment 

system:

A collection of PVC process wastewater treatment 

equipment that removes organic compounds from a process 

wastewater stream before the process wastewater stream is 

discharged from the PVC production facility.

Recovery equipment: Recovery equipment means an individual piece of 

equipment capable of and normally used for the purpose of 

recovering chemicals for fuel value (i.e., net positive 

heating value), use, reuse, sale, and/or destruction or 

disposal. Examples of equipment that may be recovery 

equipment include gas holders, compressors, condensers,

and liquid separators used to recover vinyl chloride or other 

feedstocks from gaseous streams such as resin stripper and 

wastewater stripper overheads and return those feedstocks 

for reuse in the resin production process and/or eventual 

destruction or disposal. For the purposes of this information 

collection request, wastewater steam and vacuum strippers 

are considered PVC process wastewater treatment 

equipment and not recovery equipment.

Recovery system: A recovery system is a collection of recovery equipment. A 

recovery system typically vents to a control device such as a 

thermal oxidizer and acid gas scrubber.

Resin grade: The subdivision of PVC resin that describes it as a unique 

resin, i.e., the most exact description of a type of resin with 

no further subdivision. Examples include low molecular 

weight suspension resins and general purpose suspension 

resins.

Resin stripper: A unit that removes organic compounds from a raw 

polyvinyl chloride and copolymer product. In the 

production of a polymer, stripping is a discrete step that 

occurs after the polymerization reaction and before drying

or other finishing operations. Examples of types of stripping 

include steam stripping, vacuum stripping, or other methods 

of devolatilization. For the purposes of this information 

collection request, devolatilization that occurs in dryers or 

other finishing operations is not resin stripping. Resin 

stripping may occur in a polymerization reactor or is a batch 

or continuous stripper separate from the polymerization

reactor.

Shutdown: The cessation of operation of an affected source or portion 

of an affected source for any purpose. (40 CFR 63.2)
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 8

04/01/2014

Startup: The setting in operation of an affected source or portion of 

an affected source for any purpose. (40 CFR 63.2)

Stream: Any contained or non-contained solid, liquid, gas, or vapor 

entering or exiting an individual unit operation or single 

piece of equipment.

Stripped resin: The material exiting the resin stripper than contains 

polymerized vinyl chloride.

Suspension blending process/resin: A process for producing polyvinyl chloride resin that is 

similar to the suspension polymerization process, but 

employs a rate of agitation that is significantly higher than 

the highest range for non-blending suspension resins. The 

suspension blending process uses a recipe that creates 

extremely small resin particles, generally equal to or less 

than 100 microns in size, with a glassy surface and very 

little porosity. The suspension blending process

concentrates the resins using a centrifuge that is specifically 

designed to handle these small particles. Polyvinyl chloride 

resins produced using the suspension blending process are 

referred to as suspension blending resins and are typically 

blended with dispersion resins.

Suspension process/resin: A process for producing polyvinyl chloride resin that is 

characterized by the formation of the polymers in droplets 

of liquid vinyl chloride monomer or other co-monomers 

suspended in water. The droplets are formed by agitation 

and the use of protective colloids or suspending agents.

Initiators used in the suspension process are soluble in vinyl 

chloride monomer. Polyvinyl chloride resins produced using 

the suspension process are referred to as suspension resins.

Type of Resin: The broad classification of PVC homopolymer and 

copolymer resin referring to the basic manufacturing 

process for producing that resin, including, but not limited 

to, suspension, dispersion, bulk, and solution processes.

Volatile Organic Compounds

(VOC):

See 40 CFR 51.100(s).

Waste management: Handling, treatment, storage, and disposal of waste 

products.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 9

04/01/2014

Wastewater: Process wastewater and maintenance wastewater. The 

following are not considered wastewater for the purposes of 

this subpart:

(1) Stormwater from segregated sewers;

(2) Water from fire-fighting and deluge systems, 

including testing of such systems;

(3) Spills;

(4) Water from safety showers;

(5) Samples of a size not greater than reasonably 

necessary for the method of analysis that is use; 

(6) Equipment leaks;

(7) Wastewater drips from procedures such as 

disconnecting hoses after cleaning lines; and 

(8) Noncontact cooling water.
DRAFT Enclosure 1

Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 10

04/01/2014

A-VI. Key Acronyms and Units of Measure

% percent

acfm actual cubic feet per minute

acfm/ft2 actual cubic feet per minute per square foot

batches/yr batches per year

Btu/scf British thermal units per standard cubic foot

CAA Clean Air Act

day/yr days per year

DC District of Columbia

dscfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

ft feet

ft/s feet per second

ft

3

/1,000 afcm cubic feet per thousand actual cubic feet per minute

gpm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

in inches

in H2O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallon
PVC Section 114 Enclosure 1, Attachment A – Page 11

04/01/2014

DRAFT Enclosure 1

Attachment A

LDAR leak detection and repair

MACT maximum achievable control technology

mg/l milligrams per liter

MMlb/yr million pounds (mass) per year

NAICS North American Industry Classification System

NESHAP National Emission Standards for Hazardous Air Pollutants

OAQPS Office of Air Quality Planning and Standards

oC degrees Celsius

oF degrees Fahrenheit

ohm-cm ohm-centimeter

P&ID piping and instrumentation diagram

PFD process flow diagram

ppmv parts per million, by volume

ppmw parts per million, by weight

PVC polyvinyl chloride

s second or seconds

scfm standard cubic feet per minute

SPPD Sector Policies and Programs Division

ton/yr tons per year, or short tons per year

VOC Volatile Organic Compounds

vol% volume percent, or percent by volume

wt% weight percent, or percent by weight
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 1

04/01/2014

Summary of Test Procedures, Methods, 

And Reporting Requirements

For Resin and Process Wastewater Sampling and Analysis at

Polyvinyl Chloride and Copolymer (PVC) Facilities

Under the authority of Section 114 of the Clean Air Act, EPA is requesting resin and process 

wastewater sampling and analysis for facilities which produce polyvinyl chloride and 

copolymers (PVC). This sampling program requires you to collect resin samples from the outlet 

of each resin stripper [RK29: Not every resin stripper was sampled in the prior S114 Request. 

Will EPA consider each facilities’ sampling request on how it intends to sample resin?]

and process wastewater samples from the outlet of process wastewater treatment system(s) which 

treat process wastewater streams originating from the affected source as defined in 40 CFR Part 

63, Subpart HHHHHHH or DDDDDD.

All recipients must complete the sampling and analysis and submit the results, reports, and 

documentation specified in Section 2.0 no later than July 31, 2014. Any submissions made after 

this date will be in violation of this Section 114 request.

This document provides an overview of approved sampling and analytical methods, target 

pollutants, and reporting requirements for PVC production facilities required to provide resin 

sampling and process wastewater sampling data based on this section 114 request. The purpose 

for this testing is to gather data on hazardous air pollutant (HAP) emissions from stripped resin 

and process wastewater in this source category. The document is organized as follows:

1.0 Sampling Procedures and Analysis Methods

1.1 Process Wastewater

1.2 Stripped Resin

2.0 Data Reporting Procedures

2.1 Process Wastewater

2.2 Stripped Resin

3.0 Data Submission Procedures

4.0 Contact Information for Questions

1.0 Sampling Procedures and Analysis Methods

1.1 Process Wastewater

We are requiring sampling of each stream exiting the PVC process wastewater treatment

[RK30: Can EPA confirm that it is only requiring the effluent wastewater exiting the PVC 

process wastewater treatment and not the overhead that is recovered and returned?]

system(s) at your facility. Sampling of each process wastewater treatment system is required for 

all HAP listed in Table 1, which can be detected by EPA methods listed within that same table. 

You must conduct sampling, sample preservation and sample storage in accordance with the 

specific methodology listed in Table 1 and Section 4.1.2 of SW-846 (Chapter 4 – Organic 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 2

04/01/2014

Analytes). You must collect one grab sample per PVC process wastewater treatment system for

30 consecutive operating days. The samples must be taken during normal operating conditions. If 

you have a batch process wastewater treatment system that does not operate continuously, you
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 3

04/01/2014

must sample the outlet of that batch system once for each day while it is operating such that at 

least 30 samples can be analyzed. [Note: Batch processes requiring multiple samples per batch 

should equally distribute the samples across the time taken for the effluent to discharge from the 

process to properly represent the concentration.] If you have more than one PVC process 

wastewater treatment system, the results must be reported separately for each day and for each 

treatment system (i.e., the results cannot be averaged). If you have identical water treatment 

systems that run in parallel and the outlet streams are not combined, you only need to sample one 

stream (however, include the combined flow rates for each stream). If you have identical water 

treatment systems that run in parallel and the outlet streams are combined, then the sample must 

be taken after the streams are combined and the combined flow rate must be included. Each 

sample must be analyzed for the HAP listed in Table 1 and for any other HAP expected to be 

present but not listed in Table 1.

1.2 Stripped Resin

We are requiring sampling of each type of resin [RK31: Should EPA be asking for each type of 

copolymer resin by monomoer as well, e.g. suspension vinyl acetate, disperion vinyl acetate, 

suspension vinylidene chloride, latex ethyl acetate, etc. Some monomers react more fully than 

others and each comonomer will produce a unique HAP profile.] at the base of each PVC resin 

stripper at your facility.[RK32: The 2009 S114 allowed only selected PVC resin strippers to be 

sampled rather than each stripper. Should this copolymer S114 request similar treatment?] 

Resin sampling is required for all HAP listed in Table 1, for any other HAP expected to be

present but not listed in Table 1, which can be detected by EPA methods listed within that same 

table. You must conduct sampling, sample preservation and sample storage in accordance with 

the specific methodology listed in Table 1 and Section 4.1.2 of SW-846 (Chapter 4 – Organic 

Analytes). You must collect, at a minimum, at least one grab sample per resin grade produced 

every 8 hours, or per grade of PVC resin produced, whichever is more frequent, at the outlet of 

each PVC stripper for 30 consecutive operating days. The grab samples may be composited by

resin type [RK33: For purposes of subcategorizing resins by type and monomer, shouldn’t 

composited samples only be for similar resin types and monomers?] and must be collected 

during normal operating conditions. If you have a batch PVC resin stripping operation that does 

not operate continuously, you must sample the

outlet of the associated resin stripper for each batch of stripped resin such that at least 30 samples 

can be analyzed.

Table 1. PVC Resin and Process Wastewater HAP

CAS No. HAP Analyte Category

Analysis

Method

107211 Ethylene Glycol Alcohol SW-846-8015C

67561 Methanol Alcohol SW-846-8015C

75070 Acetaldehyde Aldehyde SW-846-8315A

50000 Formaldehyde Aldehyde SW-846-8315A

51285 2,4-Dinitrophenol SVOC SW-846-8270D

98862 Acetophenone SVOC SW-846-8270D

117817 Bis(2-Ethylhexyl) Phthalate (DEHP) SVOC SW-846-8270D

123319 Hydroquinone SVOC SW-846-8270D
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 4

04/01/2014

108952 Phenol SVOC SW-846-8270D

79345 1,1,2,2-Tetrachloroethane VOC SW-846-8260B

106990 1,3-Butadiene VOC SW-846-8260B

540841 2,2,4-Trimethylpentane VOC SW-846-8260B

71432 Benzene VOC SW-846-8260B

108907 Chlorobenzene VOC SW-846-8260B
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 5

04/01/2014

67663 Chloroform VOC SW-846-8260B

126998 Chloroprene VOC SW-846-8260B

98828 Cumene VOC SW-846-8260B

75003 Ethyl Chloride (Chloroethane) VOC SW-846-8260B

100414 Ethylbenzene VOC SW-846-8260B

107062 Ethylene Dichloride (1,2-Dichloroethane) VOC SW-846-8260B

75343 Ethylidene Dichloride (1,1-Dichloroethane) VOC SW-846-8260B

74873 Methyl Chloride (Chloromethane) VOC SW-846-8260B

75092 Methylene Chloride VOC SW-846-8260B

110543 n-Hexane VOC SW-846-8260B

108883 Toluene VOC SW-846-8260B

71556 Methyl Chloroform (1,1,1-Trichloroethane) VOC SW-846-8260B

79005 1,1,2-Trichloroethane VOC SW-846-8260B

108054 Vinyl Acetate VOC SW-846-8260B

593602 Vinyl Bromide VOC SW-846-8260B

75014 Vinyl Chloride VOC EPA Method 107

75354 Vinylidene Chloride (1,1-Dichloroethylene) VOC SW-846-8260B

1330207 Xylenes (isomers and mixtures) VOC SW-846-8260B

SVOC – semi-volatile organic compound

VOC – volatile organic compound

For copies of the recommended U.S. EPA SW-846 methods, please refer to EPA’s SW-846

Online website: http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm.

2.0 Data Reporting Procedures

Your facility’s submission in response to this request must include completed copies of the 

Microsoft Excel 2007 workbook that accompanies this request. Report your sampling and 

analysis results using Forms D-2, E-2-a, and E-2-b as described in Section V of Enclosure 1.

A report from the entity (e.g., external or on-site laboratory) analyzing samples associated with 

this request that contains all analytical procedures, results, and QA/QC measures must be 

submitted. This report shall also include results of current proficiency samples analyses for all 

compounds and their appropriate method performed by the entity [RK34: Can EPA clarify this 

request? Isn't this covered under the lab reports?] (e.g., external or on-site laboratory) analyzing

samples associated with this request. These analyses should have been performed in the last 

calendar year. If proficiency samples to cover all compounds and methodologies cannot be

procured, proof of analysis of a second source calibration standard during the sample analysis 

must be submitted.

The enclosed certification statement must be signed by a responsible official.

2.1 Process Wastewater

A report that includes of all of the following must be included for process wastewater:
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 6

04/01/2014

1. A schematic diagram of the process wastewater treatment system showing where the 

samples were taken and the sampling apparatus/configuration;

2. Identify the method used to collect, store, transport, and analyze the wastewater 

samples. More specifically, certify which of the following methods was used: EPA 

Method 107, EPA SW 846 with the specific sampling extraction and analytical 

methods, or another method. If another method was used, summarize that method and 

include a complete copy of the method along with your test report;

3. A certification that each group responsible for collecting, storing, transporting, and 

analyzing the wastewater was familiar with and understood the provisions and 

requirements of each method, for EPA Method 107, the Interferences; Safety; 

Equipment and Supplies; Reagents and Standards; Sample Collection, Preservation, 

Storage, and Transport; Quality Control; Calibration and Standardization; Analytical 

Procedure; and Calculations and Data Analysis provisions and requirements, and

a. Performed its role without deviating from the EPA method used to collect, 

store, transport, and analyze resin samples, or

b. Lists each and every deviation from the EPA method, along with an 

assessment of the impact on PVC results of each and every deviation.

[RK35: Wouldn't this assessment be somewhat speculative without a 

comprehensive analysis of the deviation? What process is EPA 

expecting for this assessment? What does EPA consider a deviation? 

for example, if hold times are exceeded slightly, is that considered a 

major deviation?]

4. For each compound identified during analysis, list its method detection level and the 

means by which the detection level was calculated. Affirm the value reported in the 

information collection request response forms is the method detection level [RK36: 

Is EPA saying to report nothing other than the method detection level? Some labs 

normally report quantification or reporting limits for certain analytes?] and not 

some other level (e.g. reportable quantification level, method quantification) and 

supply calculations used to determine these values; [RK37: This is normally done on 

a daily basis for each piece of analytic equipment. Is EPA asking for a daily 

verification of MDL and the associated calculations?]

and

5. Quality assurance/quality control measures implemented during sampling and 

analysis.[RK38: Does EPA truly only want those quality assurance/quality 

control measures implemented during sampling and analysis or does EPA 

mean QA/QC normally done by the labs as part of their annual compliance for 

laboratory method certifications?]

2.2 Resin Sampling

A report that includes of all of the following must be included for resin analysis:

1. A simplified block diagram depicting the location in the process where each of the 

resin samples was taken (e.g. stripper bottom), and throughput rates for total wet resin 

and dry resin;[RK39: EPA should understand that wet resin may not be measured. In 
Enclosure 1

Attachment B

PVC Section 114 Enclosure 1, Attachment B – Page 7

04/01/2014

order to estimate wet resin, detailed engineering calculations must back calculate the 

amount based on dry resin and sample analysis. Some latex resins are not dried and 

cannot be reported on a dry basis. Can EPA clarify that reporting will consistently be

on what is normally done at each facility?]

2. Identify personnel responsible for collecting, storing, transporting, and/or analyzing 

resin samples. More specifically, identify whether your employees, the emissions 

testing company, the analytical laboratory or some other group was responsible for 

collecting the resin samples. If some other group collected the resin samples, name 

that group. In the same manner, identify the group responsible for storing, 

transporting, and analyzing resin samples;[RK40: It is the Working Group’s 

intention to provide this as a one-time narrative of the process. Please advise if 

EPA is expecting something different. It is the Working Group’s understanding 

that the bulk of this information is provided along with chain of custody and 

included in the lab reports.]

3. Identify the method used to collect, store, transport and analyze the resin samples. 

[RK41: Is all this included in the M107 or SW 846 procedure?]

More specifically, certify which of the following methods was used: EPA Method

107, EPA SW 846 with the specific sampling extraction and analytical methods, or 

another method. If another method was used, summarize that method and include a 

complete copy of the method along with your test report;
PVC Section 114 Enclosure 1, Attachment B – Page 8

04/01/2014

Enclosure 1

Attachment B

4. A certification that each group responsible for collecting, storing, transporting, and

analyzing the resin was familiar with and understood the provisions and requirements 

of each method, for EPA Method 107, the Interferences; Safety; Equipment and 

Supplies; Reagents and Standards; Sample Collection, Preservation, Storage, and 

Transport; Quality Control; Calibration and Standardization; Analytical Procedure; 

and Calculations and Data Analysis provisions and requirements, and

a. Performed its role without deviating from the EPA method used to collect, 

store, transport, and analyze resin samples, or

b. Lists each and every deviation from the EPA method, along with an 

assessment of the impact on PVC results of each and every deviation.

[RK42: Wouldn't this assessment be somewhat speculative without a 

comprehensive analysis of the deviation? What process is EPA 

expecting for this assessment? What does EPA consider a 

deviation?]

5. A narrative describing the procedure(s) used to obtain and maintain the integrity of 

the resin samples prior to analysis, including but not limited to:

a. How the resin samples were collected;

b. Type of container used to collect samples (e.g. vials, glass jars);

c. The capacity of the sample containers;

d. Length of time between sample collection and sample analysis;

e. Procedure(s) used to preserve samples (e.g. samples maintained at a certain 

temperature, identification of preservatives added, head space);

6. If samples were composited, identification of the process(es) by which the samples 

were composited; otherwise, a statement that samples were not composited;

7. Identification of the process(es) used to extract the sample for analysis (e.g. semivolatile, volatile, and solid portions) for the PVC resin and the slurry water/slurry 

resin;

8. The procedure(s) used to analyze the sample (e.g, flame ionization detection and gas 

chromatography), as well as a list of reagents used during the analysis for which the 

samples were analyzed, the analytes used during the analysis, and a description of 

how the semi-volatile, VOC, methanol (if applicable), aldehydes and total solid 

samples were prepared and analyzed;

9. A narrative describing the procedure(s) used to maintain the integrity of the resin 

samples during analysis, including but not limited to:

a. Steps taken to reduce loss of analyte immediately before and during analysis;

b. Duration of sample analysis; and

c. Temperature of sample during analysis;

10. A description of the process used to report the results of the analysis, including an 

explanation that clarifies how the original resin sampling data were translated into 

concentration values. The explanation must include all assumptions as well as sample 

calculations for each type of calculation conducted; and
PVC Section 114 Enclosure 1, Attachment B – Page 9

04/01/2014

Enclosure 1

Attachment B

4. A certification that each group responsible for collecting, storing, transporting, and

11. For each compound identified during analysis, list its method detection level and the 

means by which the detection level was calculated. Affirm the value reported in the
PVC Section 114 Enclosure 1, Attachment B – Page

10

Enclosure 1

Attachment B

information collection request response forms is the method detection level and not 

some other level (e.g. reportable quantification level, method quantification) and 

supply calculations used to determine these values.

We believe that the Clean Air Act is clear that it is incumbent on the source and the tester to 

apply methods and procedures resulting in data quality necessary for those decisions including 

providing for the lowest possible detection limits considering practical and reasonable 

limitations. For example, source owners and testers should not automatically choose to use low 

or medium quality equipment for testing (e.g., for cost reasons) if high quality equipment is 

reasonably available. We will review test reports in light of this expectation and will be 

particularly mindful of whether the testing procedures applied are representative of the highest 

reasonably expected capabilities (e.g., comparing reported minimum measurement detection

levels between tests and testers). If we believe that a source owner or tester has failed to meet the 

requirement of the Clean Air Act to provide data sufficient for decisions, we can and will request 

additional measurements requiring the use of improved testing procedures.

You must use the method detection limit (MDL) determination procedure in 40 CFR part 136, 

Appendix B, to develop the MDL. Alternatively, you may use the MDL determination procedure in 

SW-846 Chapter 1, except you must perform a minimum of seven replicate analyses instead of three. 

The MDL must be determined in the same matrix as the samples that will be analyzed.

Be aware that there are significant penalties for submitting false information, including the 

possibility of fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC

§7413). Failure to comply fully with this request for information may subject you to an 

enforcement action. We may use any information submitted in response to this request in an 

administrative, civil or criminal action.

3.0 Data Submission Procedures

To avoid duplicate data and to keep all data for a particular facility together, we request that you 

submit all of the data requested from your facility in the same way. You may submit your data 

using one of the following options:

• E-mail an electronic copy of all requested files to CCG-PVC@epa.gov ; or

• Mail a CD or DVD containing an electronic copy of all requested files to the EPA 

address shown in your section 114 letter. If no electronic copy is available, mail a hard 

copy of all requested files to the EPA address shown in your section 114 letter.

• If you are submitting Confidential Business Information (CBI), you must mail a separate 

CD or DVD containing only the CBI portion of your data to the EPA address shown in 

your section 114 letter. DO NOT SUBMIT CBI INFORMATION TO THE EPA 

ELECTRONICALLY.
PVC Section 114 Enclosure 1, Attachment B – Page

11

Enclosure 1

Attachment B

4.0 Contact Information for Questions

For questions on the sampling procedures and analytical methods contact:

Jason DeWees (U.S. EPA)

919-541-9724 

dewees.jason@epa.gov

Gerri Garwood (U.S. EPA)

919-541-2406 

garwood.gerri@epa.gov

For all other questions contact:

Jodi Howard (U.S. EPA)

919.541.4607 

howard.jodi@epa.gov