Enclosure 1 

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION REQUEST 

I. Introduction 

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

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

Chloride (PVC) and Copolymers Production source category includes any facility which 

manufactures polymerized vinyl chloride. Polyvinyl chloride may be produced by the 

suspension, mass emulsion/dispersion, and solution processes, although other methods may be 

used.”1

 The source category includes the collection of all equipment and activities necessary to 

produce PVC homopolymer and copolymer resin. Facilities that have not yet commenced 

production of PVC or copolymer resin or that are expanding existing production capacity are 

required to complete all parts of this survey. For those facilities, projected actual emissions (not 

“potential to emit”) are to be provided in lieu of actual operating emissions. 

We are requesting information regarding volatile organic compounds (VOC) and each 

compound identified as a HAP that is used in or emitted by any operations in the polyvinyl 

chloride and copolymers production source category at your company. Fill out this information 

request as completely as possible from existing information. At a minimum, provide (1) 

information on the presence of HAP and VOC emissions and (2) HAP and VOC emission 

estimates based on existing source test data, sampling, recorded operating data, or engineering 

calculations, including the engineering basis for all calculations. 

Instructions for obtaining the survey response forms are found in Section II of this 

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

found in Section III. Instructions for submitting your response can be found in Section IV. 

Section V contains general instructions for completing your responses and form-specific 

guidance. For your convenience, we have provided in Attachment A additional information on 

the scope and purpose of this survey as well as useful definitions. Respondents should read this 

material before attempting to complete the survey. As part of this survey, we are also requiring 

sampling and emissions testing for selected emission sources. Additional information regarding 

the sampling and emissions testing requirements can be found in Attachment B. 

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

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

 

1 Documentation for Developing the Initial Source Category List, Final Report. US Environmental Protection 

Agency, Office of Air Quality Planning and Standards. EPA-450/3-91-030, July 1992. p. A-64. 

PVC Section 114 Enclosure 1 - Page 1 

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II. Instructions for Obtaining the Survey Files

The survey response forms are available as two Microsoft Excel workbook templates. 

The workbooks can be downloaded from the following website: 

http://www2.ergweb.com/projects/PVCSurvey/index.html 

There are two workbooks available: 

“SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls” 

This workbook will be completed once for each process unit. Before submitting 

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

and to include the process unit ID (see Section III). 

“SURVEYPart2_[Company]_[Facility]_[ProcessUnitID]_[CampaignNumber].xls” 

This workbook will be completed for each production campaign completed at a 

single process unit. This workbook may be completed multiple times for each 

process unit depending on the number of production campaigns that occurred in 

the process unit during 2008. Before submitting the file(s), the file name(s) 

should be changed to reflect the actual company and facility and to include the 

process unit ID and campaign number (discussed below; also see Section III). 

There should be consistency between the workbook file names with respect to the 

company name, facility name, and process unit. The campaign number will 

match the campaign numbers provided on Form B-1 of the completed survey. 

This numbering convention will be duplicated throughout the other response 

Forms in the workbooks. 

Other files available for download include an example process flow diagram and a copy 

of this enclosure. Where necessary, examples of how to complete selected portions of the survey 

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 

In addition to completing the survey, we are requesting the submission of supplemental 

data and information to support the information submitted for all parts of the survey. 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) is 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 survey. 

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Information requested through completion of the survey forms is for each resin 

production campaign at each process unit for 2008. 

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 

Material Safety Data Sheets for all 

raw materials and finished products Process Unit N/A 

Emissions Test Reports (2) All Control Equipment Most recent, including test report 

required for this survey 

CEMS Data All process unit CEMS for all 

monitored pollutants Each production campaign in 2008 

Leak Monitoring, Detection, and 

Repair Records All Heat Exchange Systems 2008 

Records or Estimates of Emissions Process Unit Startup and Shutdown Each startup and shutdown for 2008 

Leak Monitoring, Detection, and 

Repair Records 

Process Unit Equipment Leaks 

(LDAR) 2008 

Flowrate 

All Emission Points and Process 

Streams Exiting the Resin Stripper 

and Downstream from the Resin 

Stripper 

Each production campaign in 2008 

HAP/Total VOC Concentration, 

Emissions Data or Estimates All Uncontrolled Emission Points Each production campaign in 2008 

HAP/Total VOC Concentration Data 

or Estimates 

All Process Streams Exiting the 

Resin Stripper and Downstream 

from the Resin Stripper 

Each production campaign in 2008 

Safety/Pressure Relief Notifications Process Unit Safety/Pressure Relief 

Devices 2008 

IV. Instructions for Submitting Your Survey Response 

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

responding to this survey: 

Submission File Name Format 

Survey – Part 1 SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls 

Survey – Part 2 SURVEYPart2_[Company]_[Facility]_[ProcessUnitID]_[CampaignNumber].xls 

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

EquipmentID]_[YYYYMMDD] 

Data/Estimates 

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

waterStream/ProcessEquipment/ControlEquipment 

ID]_[YYYYMMDD]to[YYYYMMDD] 

Process Unit Plot Plan [Company]_[Facility]_[ProcessUnitID]_PlotPlan 

Process Unit Flow Diagram [Company]_[Facility]_[ProcessUnitID]_PFD 

Leak Detection and Repair 

Procedures (Equipment 

Leaks, Heat Exchange 

[Company]_[Facility]_[ProcessUnitID]_ELproc 

[Company]_[Facility]_[ProcessUnitID]_HXproc 

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Enclosure 1 

Systems) 

Material Safety Data Sheets 

for all raw materials and 

finished products 

[Company]_[Facility]_[ProcessUnitID]_MSDS_[Material Name] 

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 that has 

only one PVC process unit. That process unit produced six resin grades in 2008. 

For that facility, the company will complete one (1) copy of: 

“SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls” 

and six (6) copies of: 

“SURVEYPart2_[Company]_[Facility]_[ProcessUnitID]_[CampaignNumber].xls” 

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

Submission File Name 

Survey – Part 1 SURVEYPart1_Generic_Anytown_P-1.xls 

Survey – Part 2 

SURVEYPart2_Generic_Anytown_P-1_1.xls 

SURVEYPart2_Generic_Anytown_P-1_2.xls 

SURVEYPart2_Generic_Anytown_P-1_3.xls 

SURVEYPart2_Generic_Anytown_P-1_4.xls 

SURVEYPart2_Generic_Anytown_P-1_5.xls 

SURVEYPart2_Generic_Anytown_P-1_6.xls 

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

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

CCG-PVC@epa.gov

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Enclosure 1 

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, Coatings and Chemicals Group 

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 survey 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, Coatings 

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

V. Instructions for Completing the Survey 

NOTE: For the purposes of this survey, 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. 

Form A – Company Information and Facility Information

 Complete Form A-1 and A-2 for each facility owned by your company and covered under the 

source category. 

Form B – Process Unit and Production

 Form B-1 and B-2 must be completed for each process unit at your facility(ies) covered by 

the source category. Provide separate forms for each process unit (Form B-1). For process 

units that are not yet operational, provide information on the projected actual production. 

 A unique identifier, P-x, where x = 1, 2, 3,...n, should be used to identify each process unit. 

This process unit identifier will be used on the process flow diagram and on subsequent 

forms. 

 A unique identifier, G-x, where x = 1, 2, 3,...n, should be used for each unique resin grade 

produced. This identifier will be used on subsequent forms. 

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Forms C-1 and C-2 – Process Equipment and Control Equipment

 Provide a copy of an existing plot plan and existing process flow diagram(s) for each process 

unit at your facility(ies) covered by the source category and for which Form B was 

completed. Separate plot plans and process flow diagrams are to be provided for each 

process unit if multiple process units are used in the manufacture of PVC or copolymer resin. 

Do not copy the example process flow diagram that is available on the survey website and do 

not create new process flow diagrams. 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). If process flow 

diagrams are not available, then submit copies of P&IDs. Process flow diagrams should 

accurately show all process equipment, control equipment, process streams, process vents, 

emission points, heat exchange systems, process wastewater streams, combustion equipment, 

transfer operations, storage tanks and vessels, and other sources of emissions. 

 In addition, the submitted process flow diagram(s) should clearly indicate the following: 

 The unique process unit identifier (ID), P-x. This identifier should be consistent 

with the identifiers listed on Form B-1. 

 All process equipment used to collect and recover vinyl chloride monomer. 

 All heat exchange systems, including heat exchangers and cooling towers. 

 All equipment used to collect, transfer, store, or treat process wastewater. 

 All combustion equipment. 

 For the purposes of this survey, vent surface condensers, and wastewater collection, handling 

and treatment equipment, are considered process equipment and not control equipment. 

Complete Forms C-1-b and C-1-c for these pieces of equipment. 

 For the purposes of this survey, cooling towers are considered process equipment. Complete 

Form D for heat exchange systems. 

 Each piece of process equipment shown on the process flow diagram (except for emissions 

control equipment) is to be given a unique code or identifier of the form U-x, where 

x = 1, 2, 3,...n. This unique code/identifier will be used on subsequent forms. For the 

purposes of this survey, process equipment also includes vent condensers, resin strippers, and 

equipment used to collect, handle, store, and treat process wastewater. 

 Each piece of emissions control equipment shown on the process flow diagram is to be given 

a unique code or identifier in the form of C-x, where x = 1, 2, 3,...n. This unique 

code/identifier will be used on subsequent forms. 

 Each individual process stream (excluding emission points and process wastewater streams) 

shown on the process flow diagram is to be given a unique code or identifier of the form S-x, 

where x = 1, 2, 3,...n. This unique code/identifier will be used on subsequent forms. 

 Each emission point that exhausts directly to the atmosphere and each stream that exits a 

control device and immediately enters another control device, 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. This unique code/identifier will be used on subsequent forms. 

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 Each individual process wastewater stream shown on the process flow diagram is to be given 

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

code/identifier will be used on subsequent forms. 

 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 equipment. 

 Complete Form C-1 for all process equipment. 

 Complete Form C-2 (a, and b through h, as necessary) for all control equipment. 

o For each piece of control equipment, 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 and resin grade 

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-bystep 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). 

o Forms C-2-b through C-2-h must be completed for all emissions control 

equipment located downstream of the resin stripping operation, including, but not 

limited to, equipment to control emissions from centrifuges, dryers, storage tanks 

and vessels, material handling equipment, and packaging operations. 

o Forms C-2-b through C-2-h must be completed for all emissions control 

equipment regardless of whether the equipment is currently regulated under 

another standard. 

 Submit with your response process unit plot plans, process flow diagrams, and Material 

Safety Data Sheets (MSDS) and chemical composition data for each raw material used and 

final product manufactured in 2008. 

Form D – Heat Exchange Systems

 Complete Form D for all heat exchange systems in the process unit. 

 Emissions from cooling towers should be included on Form K-1. 

 Submit copies for 2008 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. 

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

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Form E – Combustion Units Other Than Thermal Oxidizers, Catalytic Oxidizers, and Flares

 Complete Form E for all combustion units and emergency combustion equipment, including 

engines, but not thermal oxidizers, catalytic oxidizers, or flares. Complete Forms C-2-e and 

C-2-f for thermal/catalytic oxidizers and flares, respectively. 

Form F – Process Unit Startup, Shutdown, and Malfunction

 Complete Form F for process unit startups, shutdowns, and malfunctions during each 

production campaign in 2008. Provide emissions in total pounds for the event. 

 For the purposes of this survey, emergency/safety relief events are not considered 

malfunctions. 

 Submit with your response to this survey, copies of all records of emissions during periods of 

process startup, shutdown, and malfunctions for 2008. 

Form G – Equipment Leaks

 Complete Form G-1 for equipment leaks at each process unit. 

 Submit a copy of the leak detection and repair procedures for the process unit. 

 Provide copies of quarterly equipment leak monitoring, detection, and repair records for 

2008. 

Form H – Feedstock Unloading

 Complete a separate Form H for each feedstock unloading activity at the process unit in 2008 

that resulted in emissions to the atmosphere. 

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

Form I – Factors that Affect HAP/VOC Emissions Reductions

 During the completion of Form I, 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. 

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Form J – Miscellaneous

 Complete Form J for each process unit. 

Forms K-1, K-2, and K-3 – Emission Points, Process Streams, Process Wastewater Streams

 For each process unit, and for each production campaign in 2008, complete Forms K-1, K-2, 

and K-3. 

 Values should be reported for normal operations; not for startups, shutdowns, or 

malfunctions. 

 Complete Form K-1-a and K-1-b for all emission points. Do not include emissions from 

feedstock unloading operations, feedstock storage and holding tanks, vessels, and portable 

containers on these forms. See Form O. 

 Complete Form K-1-c for all emission points, controlled and uncontrolled. 

 Complete Form K-2-a and K-2-b for all process streams (except process vents, emission 

points, and process wastewater streams) immediately following and downstream from the 

resin stripping operation. 

o For each production campaign in 2008, submit with your response records of the 

HAP concentration in the resin immediately exiting the resin stripping operation 

and at each point downstream where the resin is sampled and the HAP 

concentration is measured. 

 Complete Form K-3 for process wastewater streams. 

o Do not include wastewater generated from maintenance activities. See Form N. 

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

 To support the information supplied on Forms K-1, K-2 and K-3, submit copies of test 

reports, recorded operating data, and sampling results with the completed questionnaire for 

each production campaign in each process unit for 2008. Submit copies of unplanned 

releases or safety/pressure relief event notifications completed and submitted for each event 

that occurred during 2008. For test reports and sampling data, include information such as 

the purpose of the test, when it was conducted, what test methods were used, and information 

on the process operation during the test. If test reports, recorded operating data, and 

sampling results are not available, calculations based on emission factors, material balances, 

or engineering principles must be 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). 

Form L – Equipment Opening

 Complete a separate Form L for each process unit and for each production campaign in 2008. 

 Values should be reported for normal operations; not for startups, shutdowns, or 

malfunctions. 

PVC Section 114 Enclosure 1 - Page 9 

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PVC Section 114 Enclosure 1 - Page 10 

09/15/2009 

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

 Complete this Form for individual equipment, including equipment that is not assigned an 

Equipment ID (e.g., in-line filters). 

 If any material is removed from the equipment, complete Form M. 

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

 Complete a separate Form M for each process unit and for each production campaign in 

2008. 

 Form M 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. 

 For all resin in 2008 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 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 

 Amount of resin removed (in pounds) 

 HAP and VOC content (weight %) 

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

the process, and 

 Ultimate disposition of the resin 

Form N – Maintenance Wastewater

 Complete a separate Form N for each process unit and for each production campaign in 

2008. 

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

Form O – Tanks, Storage Vessels, and Portable Containers Used for Feedstock Storage, Holding, 

and Wastewater

 Complete a separate Form O for each process unit and for each production campaign in 2008. 

 Form O requests information related to feedstock storage and holding tanks, portable 

containers/totes, transfer tanks, gas holders, and wastewater tanks. 

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

Attachment A 

BACKGROUND FOR POLYVINYL CHLORIDE AND COPOLYMERS PRODUCTION 

MACT STANDARDS DEVELOPMENT SURVEY

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 an explanation, where appropriate, 

for the purpose and objectives of individual survey sections or questions. Finally, a list of 

definitions of key terms used in the survey is provided. 

II. Summary of Clean Air Act Requirements 

 The maximum achievable control technology (MACT) standards development survey 

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 EPA meet its 

obligations under the Clean Air Act Amendments of 1990. Specifically, the Clean Air Act 

Amendments require 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, 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 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)). 

III. Regulatory Background for the Polyvinyl Chloride and Copolymers Production 

Source Category 

 On October 21, 1976, 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 

PVC Section 114 Enclosure 1, Attachment A – Page 1 

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Enclosure 1 

Attachment A 

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

technology based standards. As a result, 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. 

 The purpose of the current information collection is to gather data necessary to 

determine if the existing Part 61 rule is sufficient and, if not, to support the development of a 

new MACT rule for the Polyvinyl Chloride and Copolymers Production source category. The 

collected data will also support analyses of environmental and economic impacts of various 

regulatory alternatives, including the MACT floor and beyond-the-floor options. 

IV. Explanation of Key Survey Sections and Questions 

Form A – Company and Facility Information

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

of the complex relationships between and among corporations, the respondent is asked to 

verify the information between the facility and the legal owner. In some cases, one owner 

may sell a specific operation to another company, but continue to operate the facility. In this 

case, the legal owner information may be used in the EPA’s economic analysis to distinguish 

small businesses. 

 Form A-1, Section I, question 7 is asked so that EPA may identify small businesses. The 

Regulatory Flexibility Act (Public Law 96-354, September 19, 1980) requires consideration 

of the impacts of regulations on small businesses. The major purpose of the Act is to keep 

regulatory requirements from getting out of proportion to the scale of the businesses being 

regulated, without compromising the objectives of, in this case, the Clean Air Act. If a 

regulation is likely to have a significant economic impact on a substantial number of small 

businesses, EPA may, to the extent allowed by law, give special consideration to those small 

businesses when analyzing regulatory alternatives and drafting a regulation. For producers 

and users of HAP, the Small Business Administration uses employment ranges to separate 

businesses into "large" and "small" categories. These employment ranges are substantial, as 

given in question 4. (In any given situation, the actual cutoff between large and small will 

depend on the North American Industrial Classification System (NAICS) code of the 

establishments in question. Furthermore, EPA sometimes finds that different employment 

ranges or even other criteria are more suitable for the process of defining which businesses 

are large and which are small.) 

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Enclosure 1 

Attachment A 

 On Form A-2, Section IV, respondents are asked to identify whether they are a major source 

of HAP. 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 existing production capacity are asked to complete all parts of this 

survey. 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, the respondent is asked to identify if they have taken a limit for their potential 

HAP emissions to avoid being classified as a major source. 

 Information on the facility, legal owner, and technical contact is used by EPA to ensure that 

the plant is properly identified and that the appropriate contacts are available to answer any 

questions EPA might have on the completed survey. 

 The respondent is also asked to provide the latitudinal and longitudinal coordinates of the 

facility. Sources of these data include EPA permits (e.g., NPDES permits), county property 

records, facility blueprints, and site plans. 

Form B – Process Unit and Production Information

 The purpose of Form B-1 is to identify the processes within the source category and 

information on the relative magnitude of the operations in terms of resin grades and types of 

resins produced, production amounts, production capacity, and operating schedule. EPA is 

requesting that the operations be divided into discrete production campaigns (resin grade 

changes) so that EPA may identify variations in emissions that might result from the 

production of different resin grades. Information on resin grades produced, production 

amounts, capacity and operating schedules may be used in making subcategory decisions. 

For example, these data may be used in evaluating size distinctions between facilities. In 

addition, information on production capacity is used to size control devices. The process unit 

and resin grades listed on Form B-1 will define the scope of the rest of the survey and ensure 

that consistent terminology is used throughout the survey. On Form B-2, the information on 

age of the line and its remaining economic life is used in the economic analysis to determine 

the potential impacts of equipment retrofit. 

Form C – Process and Control Equipment

 On Forms C-1 and C-2, respondents are asked to provide specific information on process 

equipment and emissions control equipment. Respondents are also asked to submit a plot 

plan (plant layout schematic) and process flow diagram(s) for each process unit. Correctly 

and accurately identifying and labeling all process equipment, control equipment, emission 

points, process streams, process wastewater streams, heat exchange systems, etc. on the 

process flow diagram(s) is a necessary step in completing the rest of the survey. The process 

flow diagram is an essential tool for EPA to use in understanding how the emissions data 

relate to plant-specific processes. 

PVC Section 114 Enclosure 1, Attachment A – Page 3 

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Enclosure 1 

Attachment A 

 Forms C-1-b, C-1-c, and C-2-b through C-2-g require the respondent to provide information 

on design and operating parameters for key process equipment and control equipment. This 

information will be used by EPA to establish the MACT floor in terms of technological 

options and control strategies, and to help EPA determine the economic and environmental 

impacts of implementing these options. 

Form D – Heat Exchange Systems

 Form D requests specific information related to heat exchange systems. The information 

provided on this form will allow EPA to evaluate work practices, programs, and procedures 

to reduce or eliminate emissions due to leaks of HAP containing process fluids or heat 

exchange fluids within heat exchange systems. 

Form E – Combustion Units Other Than Thermal Oxidizers, Catalytic Oxidizers, and Flares

 Form E requests specific information related to combustion units other than thermal 

oxidizers, catalytic oxidizers, and flares. Examples of such equipment include boilers and 

dryers. 

Form F – Process Unit Startup, Shutdown, and Malfunction

 Form F requests information that will enable EPA to evaluate and quantify emissions during 

startup, shutdown, and malfunction of the process unit. 

Form G – Equipment Leaks

 Form G requests information on leak detection and repair programs and HAP/VOC emission 

control techniques. This information will assist EPA in understanding how and to what 

extent equipment leaks are controlled. 

Form H – Feedstock Unloading

 Form H requests information related to emissions that may result from feedstock unloading 

operations. 

Form I - Factors that Affect HAP Emission Reductions

 This Form requests information that will enable EPA to consider source reduction measures, 

which reduce the amount of any HAP/VOC prior to recycling, treatment, or disposal, in 

establishing the MACT floor. 

PVC Section 114 Enclosure 1, Attachment A – Page 4 

09/15/2009 
Enclosure 1 

Attachment A 

Form J – 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. 

Form K –Emission Points, Process Streams, and Process Wastewater Streams

 Forms K-1-a through K-3-b provide the bulk of the HAP and VOC usage and emissions 

information needed by EPA to set the MACT floor, identify potential subcategories, and 

identify and set potential “beyond-the-floor” limits. It is particularly important that EPA be 

able to determine when certain control technologies may prove to be infeasible for some 

sources. 

 On Form K-1-a, respondents are asked to provide a listing of all HAP-containing and VOCcontaining emission points in the process unit and to provide information on whether those 

emission points are controlled or uncontrolled. On Forms K-1-b and K-1-c, the respondent is 

asked to cross-reference the list of HAP with each emission point identified in the process 

flow diagram(s) and on Form K-1-a. The information on this table will allow EPA to 

determine the variability in HAP/VOC emissions from uncontrolled emission points. Similar 

information is requested on Forms K-3-a and K-3-b for process wastewater streams. 

 Form K-2-a requests information on the flow rates for resin-containing process streams 

exiting the resin stripping operation and all process streams that follow downstream. For 

sources that utilize stripping technology to control HAP emissions from equipment 

downstream of the resin stripping operation, it is necessary for EPA to characterize the levels 

of HAP remaining in the resin following stripping to set the MACT floor and identify and set 

potential “beyond-the-floor” limits. For sources that use a technology other than stripping to 

reduce HAP concentration, the information provided on Form K-2-a and K-2-b will allow 

EPA to identify potential subcategories. 

 The following remaining Forms request information that will allow EPA to evaluate 

emissions from other sources within the process unit and to identify and evaluate operating 

practices and pollution prevention techniques associated with these activities and emissions 

sources. 

 Form L –Opening Equipment

 Form M –Off-Specification Resin and Material Removal From Equipment

 Form N – Maintenance Wastewater

 Form O – Tanks, Vessels, and Portable Containers Used for Feedstock Storage, 

Holding, and Wastewater

PVC Section 114 Enclosure 1, Attachment A – Page 5 

09/15/2009 
Enclosure 1 

Attachment 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 

The following definitions are provided for the purpose of the survey only. They are not intended 

to replace statutory definitions or regulatory definitions developed elsewhere. 

Bulk process/resin: A resin which is produced by a polymerization process in 

which no water is used. 

Control equipment: Any equipment that reduces the quantity of a pollutant that 

is emitted to the air. The device may destroy or secure the 

pollutant for subsequent recovery. Examples include 

thermal and catalytic oxidizers, adsorbers, 

absorbers/scrubbers, and fabric filters. For the purposes of 

this survey, control equipment does not include condensers 

and resin strippers. 

Dispersion process/resin: A resin manufactured in such a way as to form fluid 

dispersions when dispersed in a plasticizer or 

plasticizer/diluent mixtures. 

Feedstock: Raw material/input to the process unit. 

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

Latex resin: A resin which is produced by a polymerization process 

which initiates from free radical catalyst sites and is sold 

undried. 

PVC Section 114 Enclosure 1, Attachment A – Page 6 

09/15/2009 
Enclosure 1 

Attachment A 

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) 

Process unit: The sum of unit operations and its associated equipment 

assembled to process raw materials and manufacture 

polyvinyl chloride products (including but not limited to 

storage, mixing operations, materials handling, piping and 

conveying equipment, reactors, separation equipment, 

transfer operations, wastewater collection and treatment, 

and waste management). Process units are analogous to 

“plants.” 

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. 

Production campaign: The continuous production of a unique resin grade in a 

process unit. Multiple production campaigns can occur in a 

single process unit that manufactures more than one resin at 

a time. A new production campaign is initiated when the 

process unit production changes from one resin grade to 

another and commences polymerization. 

Resin grade: The subdivision of resin classification which describes it as 

a unique resin, i.e., the most exact description of a resin 

with no further subdivision. Resin grade is a subdivision of 

resin type (suspension, dispersion, etc.). 

Resin type: The broad classification of resin referring to the basic 

manufacturing process for producing that resin, including, 

but not limited to, suspension, dispersion, solvent, and bulk 

processes. 

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

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

PVC Section 114 Enclosure 1, Attachment A – Page 7 

09/15/2009 
Enclosure 1 

Attachment A 

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. 

Suspension process/resin: A resin which is produced by a polymerization process in 

which polymer formation occurs within monomer droplets 

suspended in water. 

Volatile Organic Compounds 

(VOC): 

See 40 CFR 51.100(s). 

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

products. 

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 

CCG Coatings and Chemicals Group 

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 

ft3

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

PVC Section 114 Enclosure 1, Attachment A – Page 8 

09/15/2009 
Enclosure 1 

Attachment A 

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 

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 Section 114 Enclosure 1, Attachment A – Page 9 

09/15/2009 
Enclosure 1 

Attachment A 

PVC Section 114 Enclosure 1, Attachment A – Page 10 

09/15/2009 

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 

Summary of Test Procedures, Methods, 

and Reporting Requirements 

for Polyvinyl Chloride and Copolymers 

Facility Emission Points 

This document provides an overview of approved methods, target pollutant units of measure, and 

reporting requirements for polyvinyl chloride (PVC) and copolymer production facilities 

required to provide emission test data based on the section 114 letter. The purpose for this 

testing is to gather data on air pollutant emissions from certain emissions points in this source 

category. The document is organized as follows: 

1.0 Stack Testing Procedures and Methods 

2.0 How to Report Data 

3.0 How to Submit Data 

4.0 Contact Information for Questions on Test Plan and Reporting 

1.0 Stack Testing Procedures and Methods 

This information collection request includes stack (performance) test data requests for several 

pollutants. If you operate a PVC and copolymers production facility, you are requested to 

conduct sampling to determine your emissions, if any, of the following pollutants: 

Acetaldehyde (75-07-0) 

Acetophenone (98-86-2) 

1,3-butadiene (106-99-0) 

Chlorine (7782-50-5) 

Cumene (98-82-8) 

Dioxin and Furans 

Ethyl Chloride (75-00-3) 

Ethylene Dichloride (107-06-2) 

Formaldehyde (50-00-0) 

Hydrogen Chloride (7647-01-0) 

Methanol (67-56-1) 

Methyl Chloride (74-87-3) 

Phenol (108-95-2) 

Polychlorinated Biphenyls (1336-36-3) 

Poly-aromatic Hydrocarbons (both volatile and semi-volatile) 

Vinyl Acetate (108-05-4) 

Vinyl Bromide (593-60-2) 

Vinyl Chloride (75-01-4) 

 Total Hydrocarbons 

Any other initiators or inhibitors you use or emit that are hazardous air pollutants 

PVC Section 114 Enclosure 1, Attachment B – Page 1 

09/15/2009 
Enclosure 1 

Attachment B 

1.1 How to Select Sample Location and Gas Composition Analysis Methods 

U.S. EPA Method 1 of Appendix A of Part 60 must be used to select the locations and number of 

traverse points for sampling. See http://www.epa.gov/ttn/emc/methods/method1.html for a copy 

of the method and guidance information. 

Analysis of flue gas composition, including oxygen concentration, must be performed using U.S. 

EPA Methods 3A or 3B of Appendix A of Part 60. See 

http://www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or 

http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information. 

1.2 Polyvinyl Chloride and Copolymers Production Test Methods and Reporting 

Testing should be conducted on both the inlet and the outlet to at least one of the control systems 

such as but not limited to, a thermal oxidizer and scrubber used to control emissions from 

polyvinyl chloride and copolymer production. Inlet testing for all pollutants should be conducted 

using the methods presented in Table 1.2. For outlet testing, Table 1.3 presents a summary of 

the recommended test methods for each pollutant and possible alternative methods. 

Since most of the PVC and copolymer production facilities are co-located with other production 

facilities such as vinyl chloride monomer (VCM) facilities and sometimes have a common 

system to control emissions, performance testing to determine emissions from only the PVC and 

copolymer production emissions points is more complicated. We believe that testing all the 

inlets to control system from all processes prior to them being combined is needed to adequately 

characterize and separate the emissions. 

In some cases, there is a scrubber located after a thermal oxidizer to control hydrogen chloride 

and chlorine emissions. Performance testing for these compounds should be conducted at 

sampling ports after the scrubber. Some of the methods listed below do not work well in “wet” 

stacks; therefore, we are asking for performance testing of these pollutants to be conducted at 

sampling ports located after the thermal oxidizer, but before the scrubber. Inlet and outlet 

testing must be done concurrently and any other sampling should be scheduled during testing as 

well. 

A conservative mass balance of the resin immediately after the stripper to after the dryers should 

be used to estimate emissions. This must be done by using an appropriate sampling method and 

the mass balance should account for any hazardous air pollutant compounds used in the resin 

making process including impurities. The mass balance should be done on integrated samples 

that have at least 4 grab samples separated by a minimum of one hour. Thirty days of integrated 

samples for the mass balance should be taken concurrently with the 30 days of CO/THC testing 

required in Section 1.3. 

We are also seeking performance testing, sampling, or other emissions quantification approaches 

at a number of other emissions points and activities. Specifically, we want to work with you to 

quantify the emissions at the “gas holder” tanks, off gassing of “off spec” piles, containers, or 

filters, and the reactor during “hydroblasting.” Due to variability in the frequency of use or the 

PVC Section 114 Enclosure 1, Attachment B – Page 2 

09/15/2009 
Enclosure 1 

Attachment B 

kinds of emissions from these sources or activities, we are seeking your input on potential 

monitoring, sampling, or other emissions quantification approaches through stack testing and the 

114 survey. Please send your input and recommendations for quantification approaches as part 

of the testing and sampling plan for our review and approval prior to conducting any testing or 

sampling. 

If you would like to use a method not on this list, please contact EPA for approval of an 

alternative method 

If, during the performance testing, it becomes clear that the batch process will result in an “off 

spec” run, the testing and process data and any other associated information must still be 

submitted and labeled as an “off spec” test. The testing should characterize the entire cycle of the 

batch processes under “normal” operation and should not include startup, shut down, or 

malfunction emissions. A thorough description of the batch processes during the entire testing 

cycle should also be provided. 

Each test should be comprised of a minimum of three valid runs. All pollutant concentrations 

should be corrected to 3 percent oxygen and should be reported on the same moisture basis. 

Report the results of the stack tests according to the instructions in Section 4.0 of this enclosure. 

In addition to the emission test data, you should also report the following process information 

taken during the 30 day period before, at the time of, and during the emissions test: the type of 

resin being processed and the resin grade; heat input; fuel composition and feed rate; emissions 

control device(s) in use during the test; control device operating or monitoring parameters 

(including, as appropriate to the control device, flue gas flow rate, pressure drop, scrubber liquor 

pH, scrubber liquor flow rate, sorbent type and sorbent injection rate), and process parameters 

(such as oxygen). 

For copies of the recommended U.S. EPA methods and additional information, please refer to 

EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. 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. 

As mentioned above, please send us a Monitoring and Sampling Plan describing the monitoring, 

sampling, and other emissions quantification techniques you plan to use by October 9, 2009. 

For more information about the contents of a good testing and sampling plan, see the Emission 

Measurement Center website referenced above. 

We are not specifying numerical detection limits; instead we have specified testing conditions 

and methods, including test run times when appropriate, which we believe will provide data of a 

quality sufficient for decision making. We remind source owners and testers of the Clean Air Act 

section 114(a)(1) requirement to provide information requested for the development of emissions 

standards using methods that provide data necessary for the decisions. That includes data of 

quality sufficient to support those decisions. For the most part, we can identify test methods and 

procedures that will satisfy those decision making needs (e.g., minimum sampling times). In 

other cases, we recognize that the source owner's or tester's selection of test procedures or 

equipment could bear significantly on the quality of the data. 

PVC Section 114 Enclosure 1, Attachment B – Page 3 

09/15/2009 
Enclosure 1 

Attachment B 

We believe that the 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 Act 

to provide data sufficient decisions, we can and will request additional measurements requiring 

the use of improved testing procedures. 

Table 1.2: Summary of Polyvinyl Chloride and Copolymers’ Control System Inlet Emissions 

Measurement Methods and Alternative Methods 

Pollutant Recommended Method Alternative Method 

Target Reported 

Units of Measure 

CO U.S. EPA Method 10, 10A, or 

10B. Have a minimum sample 

time of 4 hours per run. 

None ppmvd @ 3% O2

Total Organic 

HAPs 

U.S. EPA Method 320 with a 

minimum sample time of 4 hours 

per run. 

None ppmvd @ 3% O2

Vinyl Chloride U.S. EPA Method 320 with a 

minimum sample time of 4 hours 

per run. 

U.S. EPA Method 106 with a 

minimum sample time of 4 hours 

per run. 

ppmvd @ 3% O2

HCl/Cl2 U.S. EPA Method 26A or U.S. 

EPA Method 26 if there are no 

entrained water droplets in the 

sample. Have a minimum sample 

time of 4 hours per run. 

None ppmvd @ 3% O2

THC U.S. EPA Method 25A with a 

minimum sampling time of 4 

hours per run. Calibrate the 

measuring instrument with a 

mixture of the organic 

compounds being emitted or with 

propane. 

None ppmvd @ 3% O2

CH4 U.S. EPA Method 320. Have a 

minimum sample time of 4 hours 

per run. 

None ppmvd @ 3% O2

O2 / CO2 U.S. EPA Method 3A U.S. EPA Method 3B % 

Moisture U.S. EPA Method 4 None % 

Flow rate U.S. EPA Method 2 None dscf 

PVC Section 114 Enclosure 1, Attachment B – Page 4 

09/15/2009 
Enclosure 1 

Attachment B 

Table 1.3: Summary of Polyvinyl Chloride and Copolymers’ Control System Outlet Emissions 

Measurement Methods and Alternative Methods 

Pollutant Recommended Method Alternative Method 

Target Reported 

Units of Measure 

CO U.S. EPA Method 10, 10A, or 

10B with a minimum sample 

time of 4 hours per run. 

None ppmvd @ 3% O2

Formaldehyde, 

Methanol, Ethylene 

dichloride, Ethyl 

Chloride, Methyl 

Chloride, Ethylene, 

HCl 

U.S. EPA Method 320 with a 

minimum sample time of 4 

hours per run. Sampling must 

be performed before the 

scrubber (if applicable). 

None ppmvd @ 3% O2

Vinyl Chloride U.S. EPA Method 320 with a 

minimum sample time of 4 

hours per run. 

U.S. EPA Method 106 with a 

minimum sample time of 4 

hours per run. 

ppmvd @ 3% O2

HCl/Cl2 U.S. EPA Method 26A U.S. 

EPA Method 26A with a 

minimum sample time of 4 

hours per run. Sampling must 

be performed after the scrubber 

(if applicable). 

None ppmvd @ 3% O2

THC U.S. EPA Method 25A with a 

minimum sampling time of 4 

hours per run. Calibrate the 

measuring instrument with a 

mixture of the organic 

compounds being emitted or 

with propane. Sampling must 

be performed before scrubber (if 

applicable). 

None ppmvd as propane @ 

3% O2

CH4 U.S. EPA Method 320. Have a 

minimum sample time of 4 

hours per run. Sampling must be 

performed before scrubber (if 

applicable). 

U.S. EPA Method 18. Have a 

minimum sample time of 4 

hours per run. Sampling must be 

performed before scrubber (if 

applicable). 

ppmvd @ 3% O2

Dioxins/Furans U.S. EPA Method 23. Collect a 

minimum volume of 5 cubic 

meters or have a minimum 

sample time of 4 hours per run. 

Use high resolution GCMS for 

the analytical finish. Sampling 

must be performed after 

scrubber (if applicable). 

None ng/dscm @ 3% O2

PVC Section 114 Enclosure 1, Attachment B – Page 5 

09/15/2009 
Enclosure 1 

Attachment B 

Pollutant Recommended Method 

Target Reported 

Alternative Method Units of Measure 

“dioxin-like” PCB 

congeners 

(3,3',4,4'-

Tetrachlorobiphenyl, 

3,4,4',5-

Tetrachlorobiphenyl, 

2,3,3',4,4'-

Pentachlorobiphenyl, 

2,3,4,4',5-

Pentachlorobiphenyl, 

2,3',4,4',5-

Pentachlorobiphenyl, 

2,3',4,4',5'-

Pentachlorobiphenyl, 

2,3,3',4,4',5-

Hexachlorobiphenyl, 

3,3',4,4',5-

Pentachlorobiphenyl, 

2,3,3',4,4',5'-

Hexachlorobiphenyl, 

2,3',4,4',5,5'-

Hexachlorobiphenyl, 

3,3',4,4',5,5'-

Hexachlorobiphenyl, 

2,3,3',4,4',5,5'-

Heptachlorobiphenyl 

U.S. EPA Method 23. Collect a 

minimum volume of 5 cubic 

meters or have a minimum 

sample time of 4 hours per run. 

Use high resolution GCMS for 

the analytical finish. Sampling 

must be performed after 

scrubber (if applicable). 

None ng/dscm @ 3% O2

Speciated Volatile 

Organic Hazardous 

Air Pollutants (HAP) 

U.S. EPA Method 0031 with 

SW-846 Method 8260B. 

Sampling must be performed 

before scrubber (if applicable). 

None μg / dscm @ 3% O2 

Speciated SemiVolatile Organic 

HAPs 

U.S. EPA Method 0010 with 

SW-846 Method 8270D. 

Collect a minimum volume of 5 

cubic meters or have a minimum 

sample time of 4 hours per run. 

Use high resolution GCMS for 

the analytical finish. Sampling 

must be performed after 

scrubber (if applicable). 

None μg / dscm @ 3% O2

O2 / CO2 U.S. EPA Method 3A. Sampling 

must be performed before and 

after scrubber (if applicable). 

Have a minimum sample time of 

4 hours per run. 

U.S. EPA Method 3B % 

Moisture U.S. EPA Method 4. Sampling 

must be performed before and 

after scrubber (if applicable). 

None % 

Flowrate U.S. EPA Method 2. Sampling 

must be performed before and 

after scrubber (if applicable). 

None dscf 

PVC Section 114 Enclosure 1, Attachment B – Page 6 

09/15/2009 
Enclosure 1 

Attachment B 

1.3 Reporting CO/HC Monitoring Data 

You must conduct CO/THC/CH4 monitoring continuously for a 30-day period, as specified in 

Table 1.4. The purpose of the monitoring is to assess the variability in organic compound 

emissions during the overlapping batch operations that take place during normal process 

operations. You must also concurrently monitor the stack oxygen concentration, the PVC 

production rate, and the control device temperature. Again, all the emissions testing required in 

Tables 1.2 and 1.3 must be conducted during the 30-day monitoring period. 

Table 1.4 30-Day Monitoring 

Pollutant Recommended Method Alternative Method 

Target Reported 

Units of Measure 

CO U.S. EPA Method 10, 10A, or 

10B continuously for 30 days. 

Plant CO CEMS meeting PS-4 

requirements 

ppmvd @ 3% O2

THC U.S. EPA Method 25A 

continuously for 30 days. 

None ppmvd as propane @ 

3% O2

CH4 U.S. EPA Method 320. EPA Method 18 or instrument 

that uses chromatographic 

column to split methane from all 

other organic compounds. 

ppmvd @ 3% O2

If a CO CEMS is already installed at the site, it may be used to collect the monitoring data 

provided it meets the requirements of Performance Specification 4 (PS 4). CO CEMS 

monitoring must also follow the quality assurance and quality control procedures of PS 4. 

When submitting the results from CO CEMS monitoring, you must also submit the results of the 

following quality assurance procedures: 

 The most recent Relative Accuracy Test Audits (RATA) 

 Charted Results of Drift Tests 

 Protocol Gas Certificates 

 Summary of data and times the monitoring was conducted from field testing sheets. 

If there are no CO CEMS, the 30-day CO monitoring data may be collected using Method 10 

operated continuously for 30 days. If you choose this option, the test run period for the purposes 

of the post-run system bias check and drift assessment is 24 hours. While monitoring the THC, 

methane should be monitored separately. There are two suggested monitoring approaches for 

monitoring the methane. 

 Use an instrument to measure the THC that uses chromatographic columns to split the 

methane from all other organic compounds. 

 Use the onsite gas chromatograph option in Method 18 to measure the methane at least 

once each 15 minutes. 

PVC Section 114 Enclosure 1, Attachment B – Page 7 

09/15/2009 
Enclosure 1 

Attachment B 

PVC Section 114 Enclosure 1, Attachment B – Page 8 

09/15/2009 

2.0 How to Report Data 

The method for reporting the results of any testing and monitoring requests depend on the type of 

tests and methods used to complete the test requirements. This section discusses the 

requirements for reporting the data. 

2.1 Reporting stack test data 

You must report the results of this test in an Emission Test Template at 

http://www2.ergweb.com/project/PVCSuvery/index.html. You must report the results of each 

test on appropriately labeled worksheet corresponding to the specific tests. After completing the 

worksheet, you must also submit an electronic copy of the emission test report including all raw 

data (PDF format preferred). 

3.0 How to Submit Data 

You may submit your data in one of three ways as listed below. However, in order 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. To submit your data: 

 E-mail an electronic copy of all requested files to 

http://www2.ergweb.com/project/PVCSuvery/index.html

 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. 

4.0 Contact Information for Questions on Test Plan and Reporting 

For questions on the test methods contact: 

Jason DeWees (U.S. EPA) 

919-541-9724 

Dewees.jason@epa.gov

Gary McAlister (U.S. EPA) 

919-541-1062 

mcalister.gary@epa.gov 

Peter Westlin (U.S. EPA) 

919-541-1058 

westlin.peter@epa.gov