Page 1 of 3 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271

www.vinylinfo.org www.vinylindesign.com November 9, 2010

Ms. Jodi Howard U.S. EPA

- Office of Air Quality Planning and Standards Sector Policies and Program Divisions Coatings and Chemicals Group Mail Code: E143

- 01 Research Triangle Park, NC 27711

RE: PVC MACT R ulemaking: October 26, 2010 Meeting and PVC Resin Steam Stripping Comments

Dear Ms. Howard,

T he Vinyl Institute (VI) and its members appreciated the opportunity to meet with you and your colleagues on October 2 6 , 2010, to discuss the supplemental r esin
concentration data submitted to EPA

, and to further explain resin steam stripping at polyvinyl chloride (PVC) manufacturing operations. I have prepared the following summary of our discussions, which we intend to use as a guide in responding to the
A gency’s inquiry and request for additional information

.

1. EPA has issue d a separate Section 114 Letter for resin sampling
clarifications. As EPA stated during the meeting

, a supplemental Section 114 request letter was sent on November 1, 2010 to each PVC resin manufacturer for additional information regarding the locations from which resin samples were taken, sample handling protocols, laboratory sample compositing, laboratory tests used, establishment of detection limits, reporting of non

- detects, actual lab test results, explanation of pounds per day calculations, and other details about the sampling process and results. T est plans for individual PVC facilities were submitted and approved within tight EPA

- mandated time constraints

. As a result, the Agenc y believes the additional information will enable it to better understand the underlying calculated pounds

- per

- day submissions and supplemental resin
concentration data

, which will be used to calculate MACT floor. The Oxy Vinyls,
LP information reviewed at this meeting appears to be a useful template for other industry member s to follow.Page 2 of 3 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271

www.vinylinfo.org www.vinylindesign.com 2. Time and Temperature are the controlling parameters for good steam stripping of PVC resin. During our meeting, you asked whether constantly operating the resin steam str ipper under vacuum pressure conditions would enhance vinyl chloride monomer (VCM) removal from PVC resin. The limiting factor in stripping VCM from PVC resin is the time for diffusion from the interior of the PVC resin particle at a certain operating tempe rature

. Resin grade and particle morphology are key to the size and porosity of PVC resin particles and
their ability to be efficiently stripped of vinyl chloride. Higher operating temperatures, rather than lower pressure s , are key to speeding the diffus ion of vinyl chloride from the solid resin phase into the liquid phase where it is insoluble and quickly transferred to the gaseous phase , where the upward flowing steam carries it away

.

The o perating pressure of stripping columns is typically maintained near atmospher ic pressure (slightly above or below)

, depending on the temperature at
which the resin must be stripped to meet a particular grade or other customer specification

. Any further decease in pressure beyond the indicated range will
result in a corresponding decrease in temperature , thereby reducing the rate of
diffusion

. To the extent stripp er towers are operated under vacuum , it is to help preserve the resin particle stability and color, which is important for high product quality

. Operating a PVC resin stripper under a vacuum will not remove greater amounts of vinyl chloride or associated HAPs from PVC resin. The attached power point slide helps to depict the various physical interactions at work in a resin stripper. P lease let us know what more information is needed to support the Agency’s consideration of what is in essence a well

- known and understood

, and widely practiced operating procedure within the PVC industry

.

3. Use of surrogates and total HAPS. As we discussed, a c lose examination o f
the resin concentration data suggests that vinyl chloride could serve as a n appropriate surrogate for VOCs. Summation of all measureable HAPs in resin could serve as an achievable emissions parameter.Page 3 of 3 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271

www.vinylinfo.org www.vinylindesign.com 4. Phase II of the PVC resin test method developme nt program has been approved

. Environmental Chemistry, Inc., the laboratory retained to conduct this study, expects to complete Phase II in approximately 6 weeks. The hybrid 8260 B test method will be validated, and Oxy will use the method to retest some of its resins as a comparison to data already submitted under the Section 114 request. Per your request, a copy of the recently completed Phase I final report has been forwarded to you

. Regarding the intent to issue a separate Section 114 Request Letter to EDC/VCM facilities, a communication will be forthcoming to review industry’s position on this

matter. We appreciate the opportunity to continue our dialogue with EPA. P lease do not hesitate to contact me if you have any questions concerning the issue s discussed during our meeting or the enclosed information, or if you require additional information.

Sincerely,

Richard P. Krock Technical Director

e

- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 571

- 216

- 4474