Enclosure 1

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Summary of Test Procedures, Methods, 

And Reporting Requirements

For Resin Sampling and Analysis at Polyvinyl Chloride and 

Copolymer (PVC) Facilities 

Under the authority of Section 114 of the Clean Air Act, the 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 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 nd reporting requirements for PVC production facilities required to provide resin 

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 in this source category. The 

document is organized as follows:

1.0 Sampling Procedures and Analysis Methods

2.0 Data Reporting Procedures

2.1 Background Information and Instructions

3.0 Data Submission Procedures

4.0 Contact Information for Questions 

1.0 Sampling Procedures and Analysis Methods

We are requiring sampling of each type of resin at the base of each PVC resin stripper at your 

facility. Resin sampling is required for all HAP listed in Table 1, which can be detected by the 

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 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. 
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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

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

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 E-2-a, and E-2-b as described in section 2.1.
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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 (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.

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 of total wet resin 

and dry resin; 

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;

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

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. 

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;
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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

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 

information collection request response forms is the detection level or 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.
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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.

2.1 Background Information and Instructions for Completing the Information Collection 

Request Response Forms

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:

“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 process flow diagram 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.

I. 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 stripping analyses, the information provided in 

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

information from the 2013 calendar year. 
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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

II. 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:
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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

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.

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.

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.
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 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 

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

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 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 and Process Equipment

 Prior to completing the remainder of the forms, 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;

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);

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);

o Pressure relief devices (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 
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identifier should exactly match between the process flow diagram and information provided 

in the completed response workbook(s). 

Control devices (C-x)

Recovery systems (RS-x)

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

Process equipment (U-x)

Emission points (EP-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 
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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. 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. 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 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.
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 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-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 

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

points. 
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 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 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 and production amounts. 

 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.”

 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.

 Row 6: Provide the 2013 annual production (in pounds of resin) for the resin type, 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.
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 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 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 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.

Form I – Equipment Opening

Table 1

 Complete this Form for each piece of process equipment, 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
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PVC Section 114 Enclosure 1 - Page 14

04/01/2014

 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.

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 

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

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

Form L –Startup, Shutdown, and Malfunction

 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.
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04/01/2014

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 howard.jodi@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.

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)

garwood.gerri@epa.gov

919-541-2406

For all other questions contact:

Jodi Howard (U.S. EPA)

919.541.4607

howard.jodi@epa.gov