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 DearMr. Striegel: OFFICE OF AIR QUALITY PLANNING AND STANDARDS

Pursuantto section 114 ofthe 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 of40 CFR Part 63, Subparts HHHHHHH and DDDDDD. The purpose ofthis request is to gather process vent data, stripped resin data, process wastewater data and other information necessary to inform our reconsideration ofthese emissions standards. We request the following testing be performed for your PVC productionfacility, Lubrizol Advanced Materials, Inc
. - Louisville, KY as specifically listed below and discussed in Attachment B (tables 1.1 and 1.6) ofEnclosure 1to this letter: Pollutants to be tested HCl TOHAP Dioxin Vinyl THC Chloride

Testresults that are collected using test methods that are supported by EPA's Electronic Reporting Tool (ERT) mustbe submitted using the ERT. We are also providing PVC process ventresponse 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 ofPVC 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 inthe 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 ofERG as authorizedrepresentative 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 testingrequest is designed to collect emissions information, which by law cannotbe confidential information. You are required to return all requested information on or before 

### November 17,2014. Ifyou would like to use the required Section 114 testing to satisfythe initial compliance requirements for process vents inthe PVC rules (40 CFRpart 63, subparts DDDDDD and HHHHHHH), please contactRegion 4 to discuss the requirements prior to beginningthe 114 testing. Be aware thatthere are significantpenalties for submitting false information, including the possibility offines and imprisonment as explained in Section 113 ofthe Clean Air Act (42 USC §7413). Failure to comply fully withthis request for information may subjectyouto an enforcement action. We may use any information submitted inresponse to this request in an administrative, civil, or criminal action. Ifyouhave questions regarding this request, please contact Ms. Jodi Howard, Refining and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.Thankyoufor your assistance inthis effort.

6Enclosures Sincerely

# a~ 

# . 4'-L#/:2 PennY. ass1ter Group Leader Refiningand Chemicals Group Sector Policies and Programs Division

cc: Alice Simpson, Lubrizol Advanced Materials, (electronically) w/Enclosures BeverlyBanister, USEPA, Region 4, Air DivisionDirector, w/Enclosure 1only KeithH. Talley, Louisville AirPollution Control, Air Pollution Control Executive Director, w/Eoclosure 1 onJy