May 15,2014 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

Mr. Sam Striegel, Plant Manager 

Lubrizol Advanced Materials, Inc. 

4200 Bells Lane 

Louisville, Kentucky 40211 

Dear Mr. Striegel: 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency 

(EPA) 

' , 

is collecting: -

information to characterize hazardous air nollnt:mt emissions from nror.Pss ' .J._ ~ - - - --

vents at polyvinyl chloride and copolymer (PVC) production facilities. 

PVC production is subject to the provisions of 40 CFR Part 63, Subparts HHHHHHH and 

DDDDDD. The purpose of this request is to gather process vent data, stripped resin data, process 

wastewater data and other information necessary to inform our reconsideration of these 

emissions standards. 

We request the following testing be performed for your PVC production facility, Lubrizol 

Advanced Materials, Inc. - Louisville, KY as specifically listed below and discussed in 

Attachment B (tables 1.1 and 1.6) of Enclosure 1 to this letter: 

Pollutants to be tested 

HCl TO HAP Dioxin Vinyl THC 

Chloride 

Test results that are collected using test methods that are supported by EPA's Electronic 

Reporting Tool (ERT) must be submitted using the ERT. We are also providing PVC process 

vent response forms in Microsoft® Excel spreadsheet format for test methods that are not 

supported by the ERT. Please see Enclosure 1, Attachment B for specific ERT submission 

instructions. 

The requested testing is designed to collect information on emissions and other relevant aspects 

of PVC process vents. Enclosure 1 contains a summary ofthe information we are requesting. 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed wnh Vegetable 011 Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
Supplemental information is contained in the following enclosures: 

Description Enclosw·e # 

Maximum Achievable Control Technology Enclosure 1 

(MACT) Standards Development Information 

Collection Request 

Section 114 Authority and CBI claims Enclosure 2 

CBI emissions data disclosure Enclosure 3 

Designation of ERG as authorized representative Enclosure 4 

Policies and Procedures for handling CBI Enclosure 5 

Certification Statement Enclosure 6 

2014 PVC 114 Process Vent Testing Workbook NIA 

2014 PVC 114 Process Vent Testing Workbook NIA 

Example 

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

CCG-PVC@epa.gov 

The testing request is designed to collect emissions information, which by law cannot be 

confidential information. You are required to return all requested information on or before 

November 17,2014. 

If you would like to use the required Section 114 testing to satisfy the initial compliance 

requirements for process vents in the PVC rules (40 CFR part 63, subparts DDDDDD and 

HHHHHHH), please contact Region 4 to discuss the requirements prior to beginning the 114 

testing. 

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. 

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. 
Thank you for your assistance in this effort. 

6 Enclosures 

Sincerely 

a~ . 4'-L#/:2 

PennY. ass1ter 

Group Leader 

Refining and Chemicals Group 

Sector Policies and Programs Division 

cc: Alice Simpson, Lubrizol Advanced Materials, (electronically) w/Enclosures 

Beverly Banister, USEPA, Region 4, Air Division Director, w/Enclosure 1 only 

Keith H. Talley, Louisville Air Pollution Control, Air Pollution Control Executive 

Director, w/Eoclosure 1 onJy