Enclosure 1

PVC Section 114 Enclosure 1

- Page 1 04/01/2014 

## 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 samp les 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 product ion 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 fo llows:

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 samp ling, 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.Enclosure 1

PVC Section 114 Enclosure 1

- Page 2 04/01/2014 Table 1. PVC Resin and Process W astewater 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 yo ur sampling and analysis results using Forms E

- 2

- a, and E

- 2

- b as described in section 2.1

.Enclosure 1

PVC Section 114 Enclosure 1

- Page 3 04/01/2014 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 mus t 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 proce ss 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 wh ether 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 re sponsible 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;Enclosure 1

PVC Section 114 Enclosure 1

- Page 4 04/01/2014 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 composi ted; otherwise, a statement that samples were not composited;

7. Identification of the process(es) used to extract the sample for analysis (e.g. semi

volatile, 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

- vol atile, 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 r educe 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 iden tified during analysis, list its method d etection 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., compari ng 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 me asurements requiring the use of improved testing procedures.Enclosure 1

PVC Section 114 Enclosure 1

- Page 5 04/01/2014 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 i n 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 s ingle Microsoft Excel 2007 workbook. The workbook is included with this enclosure and is titled:

“ PVCICR _[Company]_[Facility].xls x ”

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 submi t 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 re corded 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 wor ksheets 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 col lection 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.Enclosure 1

PVC Section 114 Enclosure 1

- Page 6 04/01/2014 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 Inf ormation 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 PVC ICR _[Company]_[Facility].xls x

Plot Plan [Company]_[Facility] _PlotPlan

Process Flow Diagram [Company]_[Facility] _PFD

Emissions Test Reports [Company]_[Facility]_[ProcessUnitID]_[Process Equipment /Control Device ID]_[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 PVC ICR _Generic_Anytown.xls

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

Please e

- mail the completed non

- confidential response to:Enclosure 1

PVC Section 114 Enclosure 1

- Page 7 04/01/2014 CCG

- PVC@epa.gov

If you are submitting confidential business information (CB I) 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 Servi ce 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 DVD

ROM 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 CONFIDENTIA L 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 e missions 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 lega l 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 facil ity 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 5 th decimal place, and longitudes should inc lude 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 qu estions III.1 through III.3 on Form A

- 2.Enclosure 1

PVC Section 114 Enclosure 1

- Page 8 04/01/2014  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 a s 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 cont rols, in the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 to ns 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
req uest. 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 i dentify 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 facili ty. 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 d otted

- 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 Emis sion 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 uniqueEnclosure 1

PVC Section 114 Enclosure 1

- Page 9 04/01/2014 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. I nclude 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 co ntrol 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 devic e 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 FormEnclosure 1

PVC Section 114 Enclosure 1

- Page 10 04/01/2014 B

- 1. This unique code/identifier will be used on subsequent form s. 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 identif ier.

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 F orm F

- 3 for the condenser(s).

Specific Instructions by Form Column

Table 1

 Column 1: Each recovery system i s to be given a unique code or identifier in the form of RS

x, 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 de scription 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 atmosphe re. 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 u nique 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.Enclosure 1

PVC Section 114 Enclosure 1

- Page 11 04/01/2014  Column 3: Identify if the emission point is used as a bypass for the control device, or, if the emission point is a pro cess 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.

Fo rm 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 equip ment.

 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 I D(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 co ntrolled (and therefore listed in Form B

- 1) do not duplicate the emission point in Form B

- 4; only list uncontrolled emission points.Enclosure 1

PVC Section 114 Enclosure 1

- Page 12 04/01/2014  Column 7: If you answered “No” in column 3, indicate if emissions from the process equipment are routed to a recovery syst em.

 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 controlle d 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 (C

2)).

Form D

- 1

– Resin Production Inf ormation

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 othe r 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 i f 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 no t 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.Enclosure 1

PVC Section 114 Enclosure 1

- Page 13 04/01/2014  Row 8: If t he 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

– Stri pper 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 instruction s 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 me asure (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 associat ed with your closed vent system(s).

 In addition to completing Form H, s ubmit 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 equipme nt 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 selectin g 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.

 In dicate how the HAP concentration of the equipment is determined, and how (if at all) HAP emissions are controlled.

Table 2Enclosure 1

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 t he 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 f or 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 desc ription.

 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 l ist 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. Provi de 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 comple tely as possible.

 Each column in Form L represents a single startup, shutdown or malfunction event. Provide emissions in total pounds for the event.

 S ubmit with your response to this information collection request , copies of all records of emissions during periods of process startup, shutdown and malfunctions for 2013.Enclosure 1

PVC Section 114 Enclosure 1

- Page 15 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 cont aining 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