Enclosure 1

MAXIMUM ACHIEVABLE CONTROL TEC HNOLOGY (MACT) STANDARDS DEVELOPMENT INFORMATION REQUEST

I. Introduction

This information request is to be complete d for operations that comprise the Polyvinyl Chloride (PVC) and Copolymers Production source category at your company. “The Polyvinyl Chloride (PVC) and Copolymers Production so urce category includes any facility which manufactures polymerized vinyl chloride. Polyvinyl chloride may be produced by the suspension, mass emulsion/dispersion, and soluti on processes, although other methods may be used.” 1 The source category includes the collection of all equipment and activities necessary to produce PVC homopolymer and copolymer resin. Furthermore, this surv ey applies to major sources of hazardous air pollutant (HAP) emissions or facilities that are locat ed at, or are part of, a major source of HAP emissions. You are a major source of HAP emissions if you own or operate a plant site that emits or has the potenti al to emit any single HAP at a rate of 10 tons (9.07 megagrams) or more per year or any co mbination of HAP at a rate of 25 tons (22.68 megagrams) or more per year. Facilities that have not yet commenced production of PVC or copolymer resin or that are e xpanding existing production capacity are required to complete all parts of this survey. For those facilities, projected actual emissions (not “potential to emit”) are to be provided in lieu of actual operating emissions.

We are requesting information regarding volatile organic com pounds (VOC) and each compound identified as a HAP that is used in or emitted by any operations in the polyvinyl chloride and copolymers production source category at your company. Fill out this information request as completely as possi ble from existing information. At a minimum, provide (1) information on the presence of HAP and VOC emissions and (2) HAP and VOC emission estimates based on existing source test data, sa mpling, recorded operating data, or engineering calculations, including the engineer ing basis for a ll calculations.

Instructions for obtaining the survey res ponse forms are found in Section II of this enclosure. A summary of the supplemental data and information requested in this survey can be found in Section III. Instructions for subm itting your response can be found in Section IV. Section V contains general in structions for completing your responses and form-specific guidance. For your convenience, we have provi ded in Attachment A additional information on the scope and purpose of this surv ey as well as useful definitions . Respondents should read this material before attempting to complete the survey. As part of this survey, we are also requiring sampling and emissions testing for selected emi ssion sources. Additional information regarding the sampling and emissions testing requirements can be found in Attachment B.

If you have questions regardi ng this request, please contac t Ms. Jodi Howard, Coatings and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.

1 Documentation for Develop ing the Initial Source Category List, Final Report . US Environmental Protection Agency, Office of Air Quality Planning and Stan dards. EPA-450/3-91-030, July 1992. p. A-64.

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II. Instructions for Obtaining the Survey Files

The survey response forms are available as two Microsoft Excel workbook templates. The workbooks can be downloaded from the following website:

http://www2.ergweb.com/projects/PVCSurvey/index.html

There are two workbooks available:

“SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls”

This workbook will be completed once for each process unit. Before submitting the file, the file name will be changed to reflect the actual company and facility and to include the process unit ID ( see Section III).

“SURVEYPart2_[Company]_[Facility]_[Pr ocessUnitID]_[CampaignNumber].xls”

This workbook will be completed for each production campaign completed at a single process unit. This workbook may be completed multiple times for each process unit depending on the number of production campaigns that occurred in the process unit during 2008. Before subm itting the file(s), the file name(s) should be changed to reflect the actual company and facility and to include the process unit ID and campaign num ber (discussed below; also see Section III).

There should be consistency between the wo rkbook file names w ith respect to the company name, facility name, and pro cess unit. The campaign number will match the campaign numbers provided on Form B-1 of the completed survey. This numbering convention will be duplicated throughout the other response Forms in the workbooks.

Other files available for download include an example process flow diagram and a copy of this enclosure. Where necessary, examples of how to complete selected portions of the survey response forms are included directly in the fo rms themselves. Refer to examples and the instructions contained in this enclosure when co mpleting your response.

III. Supplemental Data and Information Requested

In addition to completing the survey, we ar e requesting the submission of supplemental data and information to support the informati on submitted for all parts of the survey. The following table summarizes the supplemental data and information that must be submitted with your response. Provide actual r ecorded data where possible and submit that data in Microsoft Excel format. If recorded process data (such as CEMS data) is not available, then provide estimates based on engineering assessments, mate rial balances, etc. and provide copies of estimation worksheets and other supporting documentation. Reco rded process data, sampling results, test results, estimation worksheets, engineering calculations, assessments, etc. must be provided to support the information su bmitted for all parts of the survey.

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Information requested through completion of the survey forms is for each resin production campaign at each process unit for 2008.

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 Material Safety Data Sheets for all raw materials and finished products Process Unit N/A

Emissions Test Reports (2) All Control Equipment Most recent, including test report required for this survey

CEMS Data All process unit CEMS for all monitored pollutants Each production campaign in 2008
Leak Monitoring, Detection, and Repair Records All Heat Exchange Systems 2008

Records or Estimates of Emissions Process Unit Startup and Shutdown Each startup and shutdown for 2008 Leak Monitoring, Detection, and Repair Records Process Unit Equipment Leaks (LDAR) 2008

Flowrate All Emission Points and Process Streams Exiting the Resin Stripper and Downstream from the Resin Stripper Each production campaign in 2008

HAP/Total VOC Concentration, Emissions Data or Estimates All Uncontrolled Emission Points Each production campaign in 2008

HAP/Total VOC Concentration Data or Estimates All Process Streams Exiting the Resin Stripper and Downstream from the Resin Stripper Each production campaign in 2008

Safety/Pressure Relief Notifications Process Unit Safety/Pressure Relief Devices 2008

IV. Instructions for Submitting Your Survey Response

Use the appropriate file naming format as listed below for the files you submit when responding to this survey:

Submission File Name Format

Survey – Part 1 SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls

Survey – Part 2 SURVEYPart2_[Company]_[F acility]_[ProcessUnitID]_[CampaignNumber].xls

Emissions Test Reports [Company]_[Facility]_[ProcessUnitID]_[Process/Control EquipmentID]_[YYYYMMDD]

Data/Estimates [Company]_[Facility]_[ProcessUnitID]_[Pr ocessVent/EmissionPoint/Stream/Waste waterStream/ProcessEquipment/ControlEquipment ID]_[YYYYMMDD]to[YYYYMMDD]

Process Unit Plot Plan [Company]_[Facility]_[ProcessUnitID]_PlotPlan

Process Unit Flow Diagram [Compa ny]_[Facility]_[ProcessUnitID]_PFD Leak Detection and Repair Procedures (Equipment Leaks, Heat Exchange [Company]_[Facility]_[ProcessUnitID]_ELproc [Company]_[Facility]_[ProcessUnitID]_HXproc

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Syste ms)

Material Safety Data Sheets for all raw materials and finished products [Company]_[Facility]_[ProcessUnitID]_MSDS_[Material Name]

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 that has only one PVC process unit. That process unit produced six resin grades in 2008.

For that facility, the company will complete one (1) copy of:

“SURVEYPart1_[Company]_[F acility]_[ProcessUnitID].xls”

and six (6) copies of:

“SURVEYPart2_[Company]_[Facility]_[Pro cessUnitID]_[CampaignNumber].xls”

According to the instructions in Section II and IV, the files w ould be renamed as:

Submission File Name

Survey – Part 1 SURVEYPart1_Generic_Anytown_P-1.xls

Survey – Part 2 SURVEYPart2_Generic_Anytown_P-1_1.xls SURVEYPart2_Generic_Anytown_P-1_2.xls SURVEYPart2_Generic_Anytown_P-1_3.xls SURVEYPart2_Generic_Anytown_P-1_4.xls SURVEYPart2_Generic_Anytown_P-1_5.xls SURVEYPart2_Generic_Anytown_P-1_6.xls

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

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

CCG-PVC@epa.gov

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If you are submitting confidential business info rmation (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 th e 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 Divi sion, Coatings 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 survey response to the email address listed above. DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO EPA.

If you have questions regardi ng this request, please contac t Ms. Jodi Howard, Coatings and Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.

V. Instructions for Completing the Survey

NOTE: For the purposes of this survey, all HAP and VOC concentrations and emissions are to be quantified. Do not report con centrations 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

 Complete Form A-1 and A-2 for each facility owned by your company and covered under the source category.

Form B – Process Unit and Production

 Form B-1 and B-2 must be completed for each process unit at your f acility(ies) covered by the source category. Provide separate forms for each process unit (Form B-1). For process units that are not yet operat ional, provide information on the projected actual production.

 A unique identifier, P-x, where x = 1, 2, 3,...n, shoul d be used to identify each process unit. This process unit identifier will be used on the process flow diagram and on subsequent forms.

 A unique identifier, G-x, where x = 1, 2, 3,...n, should be used for each unique resin grade produced. This identifier will be used on subsequent forms.

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Forms C-1 and C-2 – Process E quipment and Control Equipment

 Provide a copy of an existing plot plan and existing process flow diagram(s) for each process unit at your facility(ies) covered by the source category and for which Form B was completed. Separate plot plans and process flow diagrams are to be provided for each process unit if multiple process un its are used in the manufactur e of PVC or copolymer resin. Do not copy the example process flow diagram th at is available on the survey website and do not create new process flow diagrams. Do not submit “block flow diagrams.” The level of detail requested is more than generally containe d in “block flow” diagrams but less than that generally contained in piping and instrumenta tion diagrams (P&IDs). If process flow diagrams are not available, then submit copies of P&IDs. Process flow diagrams should accurately show all process equi pment, control equipment, process streams, process vents, emission points, heat exchange systems, proce ss wastewater streams, combustion equipment, transfer operations, storage tanks and ve ssels, and other sources of emissions.

 In addition, the submitted process flow diagra m(s) should clearly indicate the following:

 The unique process unit identifier (ID), P-x. This identifier should be consistent with the identifiers listed on Form B-1.

 All process equipment used to collect and recover vinyl chloride monomer.

 All heat exchange systems, including heat exchangers a nd cooling towers.

 All equipment used to collect, transfer , store, or treat process wastewater.

 All combustion equipment.

 For the purposes of this survey, vent surface condensers, and wastewater collection, handling and treatment equipment, are considered pro cess equipment and not control equipment. Complete Forms C-1-b and C-1-c fo r these pieces of equipment.

 For the purposes of this survey, cooling towers are considered process equipment. Complete Form D for heat exchange systems.

 Each piece of process equipment shown on the process flow diagram (except for emissions control equipment) is to be given a unique code or identifier of the form U-x, where x = 1, 2, 3,...n. This unique code/identifier will be used on subsequent forms. For the purposes of this survey, process equipment also includes vent condensers, resin strippers, and equipment used to collect, handle, st ore, and treat process wastewater.

 Each piece of emissions control equipment shown on the process flow diagram is to be given a unique code or identifier in the form of C-x, where x = 1, 2, 3,...n. This unique code/identifier will be used on subsequent forms.

 Each individual process stream (excluding emission points and process wastewater streams) shown on the process flow diagram is to be give n a unique code or identifier of the form S-x, where x = 1, 2, 3,...n. This unique code/identif ier will be used on subsequent forms.

 Each emission point that exhausts directly to the atmosphere and each stream that exits a control device and immediately enters anot her control device, s hould 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. This unique code/identifier will be used on subsequent forms.

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 Each individual process wastewat er stream shown on the process flow diagram is to be given a unique code or identifier of the fo rm W-x, where x = 1, 2, 3,...n. This unique code/identifier will be used on subsequent forms.

 Process equipment may be grouped on the process flow diagram if and on ly if the individual pieces of equipment in the group are of identic al design and all proce ss vents exiting each piece of process equipment are routed to the same control equipment.

 Complete Form C-1 for all process equipment.

 Complete Form C-2 (a, and b through h, as necessary) for all control equipment.

o For each piece of control equipment, submit a copy of the most recent emissions test report. The report s hould include information on the process operations that influenced emissions during the test, in cluding the resin t ype and resin grade being produced. Include information such as the purpose of the test, when it was conducted, and what test methods were use d. If emissions test reports are not available, calculations based on emissi on factors, material balances, or engineering principles must be subm itted and supported by submitting a step-bystep description of the calculations, including assumptions used, and a brief rationale for the validity of the cal culation method used. (See guidance documents listed in Attachment A, Section IV).

o Forms C-2-b through C-2-h must be completed for all emissions control equipment located downstream of the resi n stripping operation, including, but not limited to, equipment to control emissions from centrifuges, dryers, storage tanks and vessels, material handling equi pment, and packaging operations.

o Forms C-2-b through C-2-h must be completed for all emissions control equipment regardless of whether the e quipment is currently regulated under another standard.

 Submit with your response process unit plot pl ans, process flow diagrams, and Material Safety Data Sheets (MSDS) and chemical comp osition data for each raw material used and final product manufactured in 2008.

Form D – Heat Exchange Systems

 Complete Form D for all heat exchange systems in the process unit.

 Emissions from cooling towers should be included on Form K-1.

 Submit copies for 2008 of monitoring data, record s or any leaks detected, dates of efforts to repair leaks, methods and proce dures used to confirm repair of leaks and dates final repairs were completed.

 Submit a copy of the heat exchange system leak detection and repair procedures.

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Form E – Combustion Units Other Than Thermal Oxidizers, Catalytic Oxidizers, and Flares

 Complete Form E for all combustion units a nd emergency combustion equipment, including engines, but not thermal oxidizers , catalytic oxidizers, or flar es. Complete Forms C-2-e and C-2-f for thermal/catalytic oxidi zers and flares, respectively.

Form F – Process Unit Startup, Shutdown, and Malfunction

 Complete Form F for process unit startups , shutdowns, and malfunctions during each production campaign in 2008. Provide emissions in total pounds for the event.

 For the purposes of this survey, emergency/safety relief events are not considered malfunctions.

 Submit with your response to this survey, copies of all reco rds of emissions during periods of process startup, shutdown, and malfunctions for 2008.

Form G – Equipment Leaks

 Complete Form G-1 for equipment leaks at each process unit.

 Submit a copy of the leak detection and re pair procedures for the process unit.

 Provide copies of quarterly equipment leak monitoring, detection, and repair records for 2008.

Form H – Feedstock Unloading

 Complete a separate Form H for each feedstoc k unloading activity at the process unit in 2008 that resulted in emissions to the atmosphere.

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

Form I – Factors that Affect HAP/VOC Em issions Reductions

 During the completion of Form I, clearly di stinguish between pollu tion reduction and source reduction measures. Pollution reduction measures alter the physical, chemical, or biological characteristics or the volume of a HAP and VO C through a process or activity which itself is not integral to and necessary to produce a product or provide a service. The use of “add-on” devices to capture and contro l (recover or destroy) HAP a nd VOC emissions are pollution reduction measures. In contra st, source reduction measures reduce the amount of any HAP and VOC prior to recycling, treatment, or disposal. Source reduction measures include equipment or technology modifi cations, process or procedure m odifications, reformulation or redesign of products, substitution of raw mate rials, and improvements in housekeeping, maintenance, training, or inventory control.

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Form J – Miscellaneous

 Complete Form J for each process unit.

Forms K-1, K-2, and K-3 – Emission Points, Pr ocess Stream s, Process Wastewater Streams

 For each process unit, and for each production campaign in 2008, complete Forms K-1, K-2, and K-3.

 Values should be reported for normal ope rations; not for startups, shutdowns, or malfunctions.

 Complete Form K-1-a and K-1-b for all emissi on points. Do not in clude emissions from feedstock unloading operations, feedstock stor age and holding tanks, vessels, and portable containers on these forms. See Form O.

 Complete Form K-1-c for all emission points, controlled and uncontrolled.

 Complete Form K-2-a and K-2-b for all pro cess streams (except process vents, emission points, and process wastewater streams) immediately follow ing and downstream from the resin stripping operation.

o For each production campaign in 2008, submit with your response records of the HAP concentration in the resin immediatel y exiting the resin stripping operation and at each point downstream where the resin is sampled and the HAP concentration is measured.

 Complete Form K-3 for process wastewater streams.

o Do not include wastewater generated from maintenance activities. See Form N.

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

 To support the information supplied on Forms K-1, K-2 and K-3, submit copies of test reports, recorded operating data, and sampling re sults with the completed questionnaire for each production campaign in each process unit for 2008. Submit copies of unplanned releases or safety/pressure relief event notific ations completed and submitted for each event that occurred during 2008. For test reports a nd sampling data, include information such as the purpose of the test, when it was conducted, wh at test methods were used, and information on the process operation during th e test. If test reports, recorded operating data, and sampling results are not availabl e, calculations based on emissi on factors, material balances, or engineering principles must be 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).

Form L – Equipment Opening

 Complete a separate Form L for each proce ss unit and for each production campaign in 2008.

 Values should be reported for normal ope rations; not for startups, shutdowns, or malfunctions.

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PVC Section 114 Enclosure 1 - Page 10 08/14/2009  Provide copies of estimation worksheets and any other relevant documentation.

 Complete this Form for individual equipment, including equipment that is not assigned an Equipment ID (e.g., in-line filters).

 If any material is removed from the equipment, complete Form M.

Form M – Off-Specification Resin and Material Rem oval from Equipment

 Complete a separate Form M for each proce ss unit and for each production campaign in 2008.

 Form M covers resin that is removed from equipment and is not processed further through the normal processing steps. Examples include, but are not limited to, off-specification resin removed from the polymerization reactor or a ny other downstream process equipment, resin removed from equipment during mainte nance and cleanout operations, etc.

 For all resin in 2008 that was discharged from further processing, di d not continue through the process under normal operating conditions , or was otherwise removed from the polymerization reactor(s) as off-grade or off-sp ecification resin or rem oved at any other point in the process unit other than finished resin storage; submit with your response records of:

 Resin type and resin grade

 Amount of resin removed (in pounds)

 HAP and VOC content (weight %)

 Description of the circumstances that resu lted in the removal of the resin from the process, and

 Ultimate disposition of the resin

Form N – Maintenance Wastewater

 Complete a separate Form N for each proce ss unit and for each production campaign in 2008.

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

Form O – Tanks, Storage Vessels, and Portable C ontainers Used for Feedstock Storage, Holding, and Wastewater

 Complete a separate Form O for each process unit and for each production campaign in 2008.

 Form O requests information related to f eedstock storage and hol ding tanks, portable containers/totes, transfer tanks, gas holders, and wastewater tanks.

 Provide copies of estimation worksheets and any other relevant documentation.Enclosure 1 Attachment A

BACKGROUND FOR POLYVINYL CHLORIDE AND COPOL YMERS PRODUCTION MACT STANDARDS DEVELOPMENT SURVEY

I. Introduction

The purpose of this attachment is to provi de the respondent with additional detail on the relevant requirements of the Clean Air Act, the regulatory background of the polyvinyl chloride and copolymers production source ca tegory, and to provide an e xplanation, where appropriate, for the purpose and objectives of individual survey sections or questions . Finally, a list of definitions of key terms used in the survey is provided.

II. Summary of Clean Air Act Requirements

The maximum achievable control technology (MACT) standards development survey was developed by the U. S. Environmental Protection Agency’s (EPA) Office of Air Quality Planning and Standards Emission Standards Di vision (OAQPS/ESD) to help EPA meet its obligations under the Clean Air Act Amendmen ts of 1990. Specifically, the Clean Air Act Amendments require EPA to develop regulatio ns under Section 112(d) to limit emissions of hazardous air pollutants (HAP) fr om major and area sources of emissions. Section 112(a)(1) defines a major source as “any stationary source or group of stationary so urces located within a contiguous area and under common control that emits or has the potential to emit considering controls, 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.” Based on the Administrator’s determination, EPA may lower the major source cutoff for individual HAP. An area source is “any stationary source of hazardous air pollutants that is not a major source.”

The Clean Air Act Amendments of 1990 prescr ibe an analytical framework that EPA is to apply in developing national emission standa rds for hazardous air pollutants (NESHAP) for major sources. A key concept in this framework is the establishment of the MACT floor. The amendments specify that NESHAP for existing s ources in a particular category or subcategory are to be no less stringent (but may be more stringent) than the average emission limitation achieved by the best performing 12 percent of the existing sources in such category or subcategory of sources. In cate gories or subcategories with less than 30 sources, the floor is to be based on the average emission limitation ach ieved by the best performing 5 sources. The MACT floor for new sources is the emission contro l that is achieved in practice by the best controlled similar source.

The Clean Air Act Amendments allow the EPA Administrator to "distinguish among classes, types, and sizes of sources within a category or s ubcategory in establishing such standards" (Section 112(d)).

III. Regulatory Background for the Polyvinyl Chloride and Copolymers Production Source Category

On October 21, 1976, EPA promulgated emissi on standards for vinyl chloride under the risk-based standard then in effect (41 FR 46560; 40 C.F.R. Subpart F (§§ 61.60 - 61.71); “the

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Part 61 NESHAP”). When Congress amended th e CAA in 1990, it required EPA to implem ent technology based standards. As a result, EP A proposed MACT standards for the Polyvinyl Chloride and Copolymers Production source category on December 8, 2000 (65 FR 76958) and promulgated final MACT standards for the s ource category on July 10, 2002 (67 FR 45886) (“the Part 63 NESHAP”). EPA adopted most of the Part 61 NESHAP as the new Part 63 NESHAP and the Part 61 standards becam e the MACT floor for existing sources.

Mossville Environmental Action NOW and Sierra Club petitioned the U.S. Court of Appeals of the District of Columbia to review various provisions of the Part 63 NESHAP. The Part 63 NESHAP was vacated on June 18, 2004 in Mossville v. EPA, 370 F. 3d. 1232 (D.C.Cir. 2004) and remanded to the agency for it to rec onsider or properly explain its methodology for regulating HAPs emitted in PVC production other than vinyl chloride by use of a surrogate.

The purpose of the current information co llection is to gather data necessary to determine if the existing Part 61 rule is suffici ent and, if not, to support the development of a new MACT rule for the Polyvinyl Chloride and Copolymers Production source category. The collected data will also support analyses of environmental and economic impacts of various regulatory alternatives, including the MA CT floor and beyond-the-floor options.

IV. Explanation of Key Survey Sections and Questions

Form A – Company and Facility Information

 Forms A-1 and A-2 are where the respondent comp any and facilities are identified. Because of the complex relationships between and amon g corporations, the resp ondent is asked to verify the information between the facility a nd the legal owner. In some cases, one owner may sell a specific operation to another company, but continue to operate the facility. In this case, the legal owner information may be used in the EPA’s economic analysis to distinguish small businesses.

 Form A-1, Section I, question 7 is asked so that EPA may identify small businesses. The Regulatory Flexibility Act (P ublic Law 96-354, September 19, 1980) requires consideration of the impacts of regulations on small businesse s. The major purpose of the Act is to keep regulatory requirements from getting out of pr oportion to the scale of the businesses being regulated, without compromising the objectives of , in this case, the Clean Air Act. If a regulation is likely to have a significant economic impact on a substantial number of small businesses, EPA may, to the extent allowed by la w, give special consideration to those small businesses when analyzing regula tory alternatives and drafti ng a regulation. For producers and users of HAP, the Small Business Administ ration uses employment ranges to separate businesses into "large" and "small" categories. These employment ranges are substantial, as given in question 4. (In any given situation, the actual cutoff between large and small will depend on the North American Industrial Clas sification System (NAICS) code of the establishments in question. Furthermore, EP A sometimes finds that different employment ranges or even other criteria are more suitable for the process of defining which businesses are large and which are small.)

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 On Form A-2, Section IV, respondents are asked to identify whether they are a major source of HAP. Section 112(a)(1) of the CAA define s a major source as any stationary source or group of stationary sources located within a contiguous area and unde r 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 tons per year or more of any combination of hazardous air pollutants. Aff ected sources that have not yet commenced production of PVC resin or that are expanding exis ting production capacity are asked to complete all parts of this survey. For those sources, proj ected actual emissions (not “Pot ential to Emit”) are requested in lieu of actual operating emissions. For f acilities that are not major sources of HAP emissions, the respondent is asked to identify if they have taken a limit for their potential HAP emissions to avoid being classified as a major source.

 Information on the facility, legal owner, and tech nical contact is used by EPA to ensure that the plant is properly identified and that the appropriate contact s are available to answer any questions EPA might have on the completed survey.

 The respondent is also asked to provide the la titudinal and longitudina l coordinates of the facility. Sources of these data include EPA permits (e.g., NPDES permits), county property records, facility blueprints, and site plans.

Form B – Process Unit and Production Information

 The purpose of Form B-1 is to identify th e processes within th e source category and information on the relative magnitude of the opera tions in terms of resi n grades and types of resins produced, production amounts, production capacity, and operating schedule. EPA is requesting that the operations be divided in to discrete production campaigns (resin grade changes) so that EPA may identify variations in emissions that might result from the production of different resin grades. Info rmation on resin grades produced, production amounts, capacity and operating schedules may be used in making subcategory decisions. For example, these data may be used in evalua ting size distinctions between facilities. In addition, information on production capacity is used to size control devices. The process unit and resin grades listed on Form B-1 will define the scope of the rest of the survey and ensure that consistent terminology is used throughout th e survey. On Form B-2, the information on age of the line and its remaini ng economic life is used in the economic analysis to determine the potential impacts of equipment retrofit.

Form C – Process and Control Equipment

 On Forms C-1 and C-2, respondents are asked to provide specific information on process equipment and emissions control equipment. Respondents are also asked to submit a plot plan (plant layout schematic) and process flow diagram(s) for each process unit. Correctly and accurately identifying and labeling all pro cess equipment, control equipment, emission points, process streams, process wastewater st reams, heat exchange systems, etc. on the process flow diagram(s) is a necessary step in completing the rest of the survey. The process flow diagram is an essential tool for EPA to use in understanding how the emissions data relate to plant-specific processes.

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 Forms C-1-b, C-1-c, and C-2-b through C-2-g re quire the respondent to provide information on design and operating parameters for key proce ss equipment and control equipment. This information will be used by EPA to establis h the MACT floor in terms of technological options and control strategies , and to help EPA determine the economic and environmental impacts of implementing these options.

Form D – Heat Exchange Systems

 Form D requests specific information related to heat exchange systems. The information provided on this form will allow EPA to evalua te work practices, programs, and procedures to reduce or eliminate emissions due to leak s of HAP containing pro cess fluids or heat exchange fluids within heat exchange systems.

Form E – Combustion Units Other Than Thermal Oxidiz ers, Catalytic Oxidizers, and Flares

 Form E requests specific information relate d to combustion units other than thermal oxidizers, catalytic oxidizers, and flares. Examples of such equipment include boilers and dryers.

Form F – Process Unit Startup, Shutdown, and Malfunction

 Form F requests information that will enable EPA to evaluate and qua ntify emissions during startup, shutdown, and malfunction of the process unit.

Form G – Equipment Leaks

 Form G requests information on leak detecti on and repair programs and HAP/VOC emission control techniques. This information will assist EPA in understanding how and to what extent equipment leaks are controlled.

Form H – Feedstock Unloading

 Form H requests information related to emissi ons that may result from feedstock unloading operations.

Form I - Factors that Aff ect HAP Emission Reductions

 This Form requests information that will enab le EPA to consider source reduction measures, which reduce the amount of any HAP/VOC prior to recycling, treatmen t, or disposal, in establishing the MACT floor.

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Form J – Miscellaneous

 This Form includes a question on whether the co ntrols or process changes on the source are the result of new source review (NSR) requirements. The last question asks the respondent to describe any other factors not addressed in the above questions that might serve to distinguish subcategories.

Form K –Emission Points, Process Stream s, and Process Wastewater Stream s

 Forms K-1-a through K-3-b provide the bulk of the HAP and VOC usage and emissions information needed by EPA to set the MACT fl oor, identify potential subcategories, and identify and set potential “beyond-the-floor” limits . It is particularly important that EPA be able to determine when certain control techno logies may prove to be infeasible for some

sources.

 On Form K-1-a, respondents are asked to provide a listing of a ll HAP-containing and VOCcontaining emission points in the process unit and to provide information on whether those emission points are controlled or uncontrolled. On Forms K-1-b a nd K-1-c, the respondent is asked to cross-reference the list of HAP with each emission point identified in the process flow diagram(s) and on Form K-1-a. The information on this table will allow EPA to determine the variability in HAP /VOC emissions from uncontroll ed emission points. Similar information is requested on Forms K-3-a a nd K-3-b for process wastewater streams.

 Form K-2-a requests information on the flow rates for resin-containing process streams exiting the resin stripping ope ration and all process streams that follow downstream. For sources that utilize stripp ing technology to control HAP emissions from equipment downstream of the resin stripping operation, it is necessary for EPA to characterize the levels of HAP remaining in the resin fo llowing stripping to set the MA CT floor and identify and set potential “beyond-the-floor” limits. For sources that use a technology other than stripping to reduce HAP concentration, the information pr ovided on Form K-2-a and K-2-b will allow EPA to identify potential subcategories.

 The following remaining Forms request information that will allow EPA to evaluate emissions from other sources w ithin the process unit and to identify and evaluate operating practices and pollution preventi on techniques associated with these activities and emissions

sources.

 Form L –Opening Equipment

 Form M –Off-Specification Resin and Material Removal From Equipment

 Form N – Maintenance Wastewater

 Form O – Tanks, Vessels, and Portable C ontainers Used for Feedstock Storage, Holding, and Wastewater

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A-IV. Guidance Documents

Following is a list of EPA guidance docum ents and resources that may be useful to respondents in estimating HAP emissions.

1. Compilation of Air Pollutant Emission Factor s: Volume I: Stationary Point and Area Sources. U. S. Environmental Prot ection Agency. Research Triangle Park, N.C. 1995. http://www.epa.gov/ttn/chief/ap42/index.html

2. Factor Information Retrieval (FIRE) Data System. U. S. Environmental Protection Agency. http://cfpub.epa.gov/oarweb/inde x.cfm? action=fire.main

3. Protocol for Equipment Leak Emission Estim ates. U. S. Environmental Protection Agency. Research Triangle Park, N.C. November 1995. Publication No.: EPA453/R-95-017.

4. Batch Process ACT. U. S. Environmenta l Protection Agency. Research Triangle Park, N.C. February 1994. Publication No.: EPA-453/R-94-020.

A-V. Key Term Definitions

The following definitions are provided for the purpose of the survey only. They are not intended to replace statutory definitions or regul atory definitions developed elsewhere.

Bulk process/resin: A resin which is produced by a polymerization process in which no water is used.

Control equipment: Any equipment that re duces the quantity of a pollutant that is emitted to the air. The device may destroy or secure the pollutant for subsequent r ecovery. Examples include thermal and catalytic oxidizers, adsorbers, absorbers/scrubbers, and fabric filters. For the purposes of this survey, control equipmen t does not include condensers and resin strippers.

Dispersion process/resin: A resin manufactured in such a way as to form fluid dispersions when dispersed in a plasticizer or plasticizer/diluent mixtures.

Feedstock: Raw material/input to the process unit.

Hazardous Air Pollutants (HAP): See 42 U.S.C. §7412(a)(6).

Latex resin: A resin which is pr oduced by a polymerization process which initiates from free radical catalyst sites and is sold undried.

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Malfunction: Any sudden, infrequent , and not reasona bly preventable failure of air pollution control and m onitoring equipment, process equipment, or a process to operate in a normal or usual manner which causes, or has the potential to cause, the emission limitations in an applicable standard to be exceeded. Failures that are caused in part by poor maintenance or careless operati on are not malfunctions. (40 CFR 63.2)

Process unit: The sum of unit operations and its associated equipment assembled to process raw materials and manufacture polyvinyl chloride products (i ncluding but not limited to storage, mixing operations, materials handling, piping and conveying equipment, reactors, separation equipment, transfer operations, wastewat er collection and treatment, and waste management). Process units are analogous to “plants.”

Process wastewater stream: Each individual waste stream exiting an individual piece of process equipment (including, but not limited to, resin stripping equipment, knoc kout pots, condensers, centrifuges, and scrubbers) prio r to being combined with any other stream. Process wastewater streams also include combined streams exiting wastewater collection tanks, wastewater treatment equipment/processes, etc.

Production campaign: The continuous pr oduction of a unique resin grade in a process unit. Multiple production campaigns can occur in a single process unit that manufact ures more than one resin at a time. A new production campaign is initiated when the process unit production changes from one resin grade to another and commences polymerization.

Resin grade: The subdivision of resin classification which describes it as a unique resin, i.e., the most exact description of a resin with no further subdivision. Resi n grade is a subdivision of resin type (suspension, dispersion, etc.).

Resin type: The broad classificati on of resin referring to the basic manufacturing process for pr oducing that resin, including, but not limited to, suspension, dispersion, solvent, and bulk
processes.

Shutdown: The cessation of operation of an affected source or portion of an affected source for any purpose. (40 CFR 63.2)

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Startup: The setting in operation of an affected source or portion of an affected source for any purpose. (40 CFR 63.2)

Stream : Any contained or non-contai ned solid, liquid, gas, or vapor entering or exiting an indivi dual unit operation or single piece of equipment.

Suspension process/resin: A resin which is produced by a polymerization process in which polymer formation occu rs within monomer droplets suspended in water.

Volatile Organic Compounds (VOC): See 40 CFR 51.100(s).

Waste management: Handling, treatment, storage, and disposal of waste products.

A-VI. Key Acronyms and Units of Measure

% percent

acfm actual cubic feet per minute

acfm/ft 2 actual cubic feet per minute per square foot

batches/yr batches per year

Btu/scf British thermal units per standard cubic foot

CAA Clean Air Act

CCG Coatings and Chemicals Group

day/yr days per year

DC District of Columbia

dscfm dry standard cubic feet per minute

EPA U.S. Environmental Protection Agency

ft feet

ft/s feet per second

ft 3 /1,000 afcm cubic feet per thousand actual cubic feet per minute

PVC Section 114 Enclosure 1, Attachment A – Page 8 08/14/2009Enclosure 1 Attachment A

gpm U.S. gallons per minute

gr/dscf grains per dry standard cubic foot

HAP Hazardous Air Pollutants

hr/day hours per day

in inches

in H 2 O inches of water

kPa kilopascals

LAER lowest achievable emission rate

lb/day pounds (mass) per day

lb/gal pounds (mass) per U.S. gallon

LDAR leak detection and repair

MACT maximum achievab le control technology

mg/ l milligrams per liter

MMlb/yr million pounds (mass) per year

NAICS North American Indus try Classification System

NESHAP National Emission Standards for Hazardous Air Pollutants

OAQPS Office of Air Qualit y Planning and Standards

oC degrees Celsius

oF degrees Fahrenheit

ohm-cm ohm-centimeter

P&ID piping and instrumentation diagram

PFD process flow diagram

ppmv parts per million, by volume

ppmw parts per million, by weight

PVC Section 114 Enclosure 1, Attachment A – Page 9 08/14/2009Enclosure 1 Attachment A

PVC Section 114 Enclosure 1, Attachment A – Page 10 08/14/2009 PVC polyvinyl chloride

s second or seconds

scfm standard cubic feet per minute

SPPD Sector Policies and Programs Division

ton/yr tons per year, or short tons per year

VOC Volatile Organic Compounds

vol% volume percent, or percent by volume

wt% weight percent, or percent by weightEnclosure 1 Attachment B



## Summary of Test Procedures, Methods, and Reporting Requirements for Polyvinyl Chloride and Copolymers Facility Emission Points

This document provides an overview of approved me thods, target pollutant units of measure, and reporting requirements for polyvinyl chloride (PVC) and copolymer production facilities required to provide emission test data based on the section 114 le tter. The purpose for this testing is to gather data on air pollutant emissi ons from certain emissions points in this source category. The document is organized as follows:

1.0 Stack Testing Procedures and Methods 2.0 How to Report Data
3.0 How to Submit Data 4.0 Contact Information for Questi ons on Test Plan and Reporting

1.0 Stack Testing Procedures and Methods

This information collection request includes stac k (performance) test data requests for several pollutants. If you operate a PVC and copolym ers production facility, you are requested to conduct sampling to determine your emissions, if any, of the following pollutants:

Acetaldehyde (75-07-0) Acetophenone (98-86-2) 1,3-butadiene (106-99-0) Chlorine (7782-50-5) Cumene (98-82-8) Dioxin and Furans Ethyl Chloride (75-00-3) Ethylene Dichloride (107-06-2) Formaldehyde (50-00-0) Hydrogen Chloride (7647-01-0) Methanol (67-56-1) Methyl Chloride (74-87-3) Phenol (108-95-2) Polychlorinated Biphenyls (1336-36-3) Poly-aromatic Hydrocarbons (both volatile and semi-volatile) Vinyl Acetate (108-05-4) Vinyl Bromide (593-60-2) Vinyl Chloride (75-01-4) Total Hydrocarbons Any other initiators or inhib itors you use or emit that ar e hazardous air pollutants

PVC Section 114 Enclosure 1, Attachment B – Page 1 08/14/2009Enclosure 1 Attachment B

1.1 How to Select Sample Location and Gas Composition Analysis Methods

U.S. EPA M ethod 1 of Appendix A of Part 60 must be used to select the lo cations and number of traverse points for sampling. See http://www.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance information.

Analysis of flue gas composition, including oxygen concentration, must be performed using U.S. EPA Methods 3A or 3B of Appendix A of Part 60. See http://www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information.

1.2 Polyvinyl Chloride and Copolymers Production Test Methods and Reporting

Testing should be conducted on both the inlet and th e outlet to at least one of the control systems such as but not limited to, a thermal oxidizer and scrubber used to control emissions from polyvinyl chloride and copolymer production. Inlet testing for al l pollutants should be conducted using the methods presented in Table 1.2. For outlet testing, Table 1.3 pr esents a summary of the recommended test methods for each pollu tant and possible alternative methods.

Since most of the PVC and copolymer production f acilities are co-located with other production facilities such as vinyl chloride monomer (VCM) facilities and so metimes have a common system to control emissions, performance testi ng to determine emissions from only the PVC and copolymer production emissions points is more co mplicated. We believe that testing all the inlets to control system from all processes prior to them being combined is needed to adequately characterize and separate the emissions.

In some cases, there is a scr ubber located after a thermal oxidi zer to control hydrogen chloride and chlorine emissions. Performance testi ng for these compounds should be conducted at sampling ports after the scrubber. Some of th e methods listed below do not work well in “wet” stacks; therefore, we are asking for performance testing of these pollutants to be conducted at sampling ports located after the thermal oxidizer, but before the scrubber. Inlet and outlet testing must be done concurrently and any othe r sampling should be scheduled during testing as well.

A conservative mass balance of the resin immediatel y after the stripper to after the dryers should be used to estimate emissions. This must be done by using an appropriate sampling method and the mass balance should account for any hazardous air pollutant compounds used in the resin making process including impurities. The mass balance should be done on integrated samples that have at least 4 grab sample s separated by a minimum of one hour . Thirty days of integrated samples for the mass balance should be taken conc urrently with the 30 da ys of CO/THC testing required in Section 1.3.

We are also seeking performance testing, sampli ng, or other emissions qua ntification approaches at a number of other emissions points and activitie s. Specifically, we want to work with you to quantify the emissions at the “gas holder” tanks , off gassing of “off spec” piles, containers, or filters, and the reactor during “hydroblasting.” Due to variability in the frequency of use or the

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kinds of emissions from these sources or act ivities, we are seeki ng your input on potential monitoring, sam pling, or other emissions quantifica tion approaches through stack testing and the 114 survey. Please send your input and recommendations for quantif ication approaches as part of the testing and sampling plan for our review and approval prior to co nducting any testing or sampling.

If you would like to use a method not on this list, please contact EPA for approval of an alternative method

If, during the performance testing, it becomes clear that the batch process will result in an “off spec” run, the testing and process data and any other associated information must still be submitted and labeled as an “off spec” test. The testing should characterize the entire cycle of the batch processes under “normal” operation and should not include st artup, shut down, or malfunction emissions. A thorough description of the batch processes du ring the entire testing cycle should also be provided.

Each test should be comprised of a minimum of three valid runs. All pollutant concentrations should be corrected to 3 percent oxygen and should be reported on the same moisture basis. Report the results of the stack test s according to the inst ructions in Section 4.0 of this enclosure. In addition to the emission test data, you should also report the following process information taken during the 30 day period before, at the time of , and during the emissions test: the type of resin being processed and the resi n grade; heat input; fuel com position and feed rate; emissions control device(s) in use duri ng the test; control device operating or monitoring parameters (including, as appropriate to the control device, flue gas flow rate, pressure drop, scrubber liquor pH, scrubber liquor flow rate, sorb ent type and sorbent injection rate), and process parameters (such as oxygen).

For copies of the recommended U.S. EPA meth ods and additional information, please refer to EPA’s Emission Measurement Center website: http://www.epa.gov/ttn/emc/. 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/hazar d/testm ethods/sw846/index.htm

. As mentioned above, please send us a Monitori ng and Sampling Plan describing the monitoring, sampling, and other emissions quantifi cation techniques you plan to use by October 9, 2009

. For more information about the contents of a good testing and sampling plan, see the Emission Measurement Center website referenced above.

We are not specifying numerical detection limits; instead we have specified testing conditions and methods, including test run times when appropr iate, which we believe will provide data of a quality sufficient for decision making. We remind source owners and testers of the Clean Air Act section 114(a)(1) requirement to provide informa tion requested for the development of emissions standards using methods that provide data necess ary for the decisions. That includes data of quality sufficient to support those decisions. For the most part, we can identify test methods and procedures that will satisfy those decision making needs (e.g., minimum sampling times). In other cases, we recognize that the source owner's or tester's se lection of test procedures or equipment could bear significantly on the quality of the data.

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We believe that the Act is clear that it is incu m bent on the source and the tester to apply methods and procedures resulting in data quality necessa ry for those decisions including providing for the lowest possible detection limits considering practical and reasona ble limitations. For example, source owners and testers should not automati cally choose to use low or medium quality equipment for testing (e.g., for co st reasons) if high quality equipm ent 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 report ed minimum measurement detec tion levels between tests and testers). If we believe that a source owner or tester has failed to meet the requirement of the Act to provide data sufficient decisions, we can a nd will request additional measurements requiring the use of improved testing procedures.

Table 1.2: Summary of Polyvinyl Chloride a nd Copolymers’ Control System Inlet Emissions Measurement Methods and Alternative Methods

Pollutant Recommended Method Alternative Method Target Reported Units of Measure CO U.S. EPA Method 10, 10A, or 10B. Have a minimum sample time of 4 hours per run. None ppmvd @ 3% O 2

Total Organic HAPs U.S. EPA Method 320 with a minimum sample time of 4 hours
per run. None ppmvd @ 3% O 2

Vinyl Chloride U.S. EPA Method 320 with a minimum sample time of 4 hours
per run. U.S. EPA Method 106 with a minimum sample time of 4 hours
per run. ppmvd @ 3% O 2

HCl/Cl 2 U.S. EPA Method 26A or U.S. EPA Method 26 if there are no entrained water droplets in the sample. Have a minimum sample time of 4 hours per run. None ppmvd @ 3% O 2

THC U.S. EPA Method 25A with a minimum sampling time of 4 hours per run. Calibrate the measuring instrument with a mixture of the organic compounds being emitted or with
propane. None ppmvd @ 3% O 2

CH 4 U.S. EPA Method 320. Have a minimum sample time of 4 hours
per run. None ppmvd @ 3% O 2

O 2 / CO 2 U.S. EPA Method 3A U.S. EPA Method 3B % Moisture U.S. EPA Method 4 None % Flow rate U.S. EPA Method 2 None dscf

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Table 1.3: Summary of Polyvinyl Chloride a nd Copolymers’ Control System Outlet Emissions Measurement Methods and Alternative Methods

Pollutant Recommended Method Alternative Method Target Reported Units of Measure CO U.S. EPA Method 10, 10A, or 10B with a minimum sample time of 4 hours per run. None ppmvd @ 3% O 2

Formaldehyde, Methanol, Ethylene dichloride, Ethyl Chloride, Methyl Chloride, Ethylene, HCl U.S. EPA Method 320 with a minimum sample time of 4 hours per run. Sampling must be performed before the scrubber (if applicable). None ppmvd @ 3% O 2

Vinyl Chloride U.S. EPA Method 320 with a minimum sample time of 4 hours per run. U.S. EPA Method 106 with a minimum sample time of 4 hours per run. ppmvd @ 3% O 2

HCl/Cl 2 U.S. EPA Method 26A U.S. EPA Method 26A with a minimum sample time of 4 hours per run. Sampling must be performed after the scrubber (if applicable). None ppmvd @ 3% O 2

THC U.S. EPA Method 25A with a minimum sampling time of 4 hours per run. Calibrate the measuring instrument with a mixture of the organic compounds being emitted or with propane. Sampling must be performed before scrubber (if applicable). None ppmvd as propane @ 3% O 2

CH 4 U.S. EPA Method 320. Have a minimum sample time of 4 hours per run. Sampling must be performed before scrubber (if applicable). U.S. EPA Method 18. Have a minimum sample time of 4 hours per run. Sampling must be performed before scrubber (if applicable). ppmvd @ 3% O 2

Dioxins/Furans U.S. EPA Method 23. Collect a minimum volume of 5 cubic meters or have a minimum sample time of 4 hours per run. Use high resolution GCMS for the analytical finish. Sampling must be performed after scrubber (if applicable). None ng/dscm @ 3% O 2

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Pollutant Recommended Method Target Reported Alternative Method Units of Measure “dioxin-like” PCB
congeners (3,3',4,4'- Tetrachlorobiphenyl, 3,4,4',5- Tetrachlorobiphenyl, 2,3,3',4,4'- Pentachlorobiphenyl, 2,3,4,4',5- Pentachlorobiphenyl, 2,3',4,4',5- Pentachlorobiphenyl, 2,3',4,4',5'- Pentachlorobiphenyl, 2,3,3',4,4',5- Hexachlorobiphenyl, 3,3',4,4',5- Pentachlorobiphenyl, 2,3,3',4,4',5'- Hexachlorobiphenyl, 2,3',4,4',5,5'- Hexachlorobiphenyl, 3,3',4,4',5,5'- Hexachlorobiphenyl, 2,3,3',4,4',5,5'- Heptachlorobiphenyl U.S. EPA Method 23. Collect a minimum volume of 5 cubic meters or have a minimum sample time of 4 hours per run. Use high resolution GCMS for the analytical finish. Sampling must be performed after scrubber (if applicable). None ng/dscm @ 3% O 2

Speciated Volatile Organic Hazardous Air Pollutants (HAP) U.S. EPA Method 0031 with SW-846 Method 8260B. Sampling must be performed before scrubber (if applicable). None μ g / dscm @ 3% O 2

Speciated SemiVolatile Organic HAPs U.S. EPA Method 0010 with SW-846 Method 8270D. Collect a minimum volume of 5 cubic meters or have a minimum sample time of 4 hours per run. Use high resolution GCMS for the analytical finish. Sampling must be performed after scrubber (if applicable). None μ g / dscm @ 3% O 2

O 2 / CO 2 U.S. EPA Method 3A. Sampling must be performed before and after scrubber (if applicable). Have a minimum sample time of 4 hours per run. U.S. EPA Method 3B %

Moisture U.S. EPA Method 4. Sampling must be performed before and after scrubber (if applicable). None %

Flowrate U.S. EPA Method 2. Sampling must be performed before and after scrubber (if applicable). None dscf

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1.3 Reporting CO/HC Monitoring Data

You m ust conduct CO/THC/CH 4 monitoring continuously for a 30-day period, as specified in Table 1.4. The purpose of the monitoring is to assess the variability in organic compound emissions during the overlapping batch operatio ns that take place during normal process operations. You must also concurrently m onitor the stack oxygen concentration, the PVC production rate, and the control device temperature. Again, all the emissions testing required in Tables 1.2 and 1.3 must be conducted during the 30-day monitoring period.

Table 1.4 30-Day Monitoring

Pollutant Recommended Method Alternative Method Target Reported Units of Measure CO U.S. EPA Method 10, 10A, or 10B continuously for 30 days. Plant CO CEMS meeting PS-4 requirements ppmvd @ 3% O 2

THC U.S. EPA Method 25A continuously for 30 days. None ppmvd as propane @ 3% O 2 CH 4 U.S. EPA Method 320. EPA Method 18 or instrument that uses chromatographic column to split methane from all other organic compounds. ppmvd @ 3% O 2

If a CO CEMS is already insta lled at the site, it may be used to collect the monitoring data provided it meets the requirements of Perfor mance Specification 4 (PS 4). CO CEMS monitoring must also follow the quality assurance and quality control procedures of PS 4. When submitting the results from CO CEMS monito ring, you must also submit the results of the following quality assurance procedures:

 The most recent Relative Accu racy Test Audits (RATA)

 Charted Results of Drift Tests

 Protocol Gas Certificates

 Summary of data and times the monitori ng was conducted from field testing sheets.

If there are no CO CEMS, the 30-day CO mon itoring data may be collected using Method 10 operated continuously for 30 days. If you choose th is option, the test run period for the purposes of the post-run system bias check and drift assessment is 24 hours

. While monitoring the THC, methane should be monitored separately. Ther e are two suggested monitoring approaches for monitoring the methane.

 Use an instrument to measure the THC that uses chromatographic columns to split the methane from all other organic compounds.

 Use the onsite gas chromatograph option in Method 18 to measure the methane at least once each 15 minutes.

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PVC Section 114 Enclosure 1, Attachment B – Page 8 08/14/2009 2.0 How to Report Data

The method for reporting the resu lts of any testing and monitoring requests depend on the type of tests and methods used to complete the test requirements. This section discusses the requirements for reporting the data.

2.1 Reporting stack test data

You must report the results of this test in an Emission Test Template at http://www2.ergweb.com/project/PVCSuvery/index.html . You must report th e results of each test on appropriately labeled work sheet corresponding to the specific tests. After completing the worksheet, you must also submit an electronic co py of the emission test report including all raw data (PDF format preferred).

3.0 How to Submit Data

You may submit your data in one of three ways as listed below. However, in order 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. To submit your data:

 E-mail an electronic copy of all requested files to http://www2.ergweb.com/project/PVCSuvery/index.html

 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 av ailable, mail a hard copy of all requested files to the EPA address shown in your section 114 letter.

 If you are submitting Confidential Business Info rmation (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.

4.0 Contact Information for Question s on Test Plan and Reporting

For questio ns on the test methods contact:

Jason DeWees (U.S. EPA) 919-541-9724 Dewees.jason@epa.gov

Gary McAlister (U.S. EPA) 919-541-1062 mcalister.gary@epa.gov

Peter Westlin (U.S. EPA) 919-541-1058 westlin.peter@epa.gov