May 15,2014 

Mr. Lloyd Stone 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

RESEARCH TRIANGLE PARK, NC 27711 

Corporate HSE Director 

Westlake Chemical Corporation 

2801 Post Oak Blvd. 

Houston, Texas 77056 

Dear Mr. Stone: 

OFFICE OF 

AIR QUALITY PLANNING 

AND STANDARDS 

Pursuant to section 114 ofthe Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) 

is collecting information to characterize hazardous air pollutant emissions from process vents at 

polyvinyl chloride and copolymer (PVC) production facilities. 

PVC production is subject to the provisions of 40 CFR Part 63, Subparts HHHHHHH and DDDDDD. 

The purpose of this request is to gather process vent data and other information necessary to inform our 

reconsideration ofthese emissions standards. 

We request the following testing be performed for your PVC production facility, Westlake Chemical 

Corporation- Calvert City, KY as specifically listed below and discussed in Attachment B (tables 1.1 

and 1.6) of Enclosure 1 to this letter: 

Pollutants to be tested 

HCl TO HAP Dioxin Vinyl THC 

Chloride 

We are also requesting other information regarding PVC production at your facility and are providing 

the survey response forms in Microsoft® Excel spreadsheet format. Test results that are collected using 

test methods that are supported by EPA's Electronic Reporting Tool (ERT) must be submitted using the 

ERT. We are also providing PVC process vent response forms in Microsoft® Excel spreadsheet format 

for test methods that are not supported by the ER T. Please see Enclosure 1, Attachment B for specific 

ER T submission instructions. 

The requested testing is designed to collect information on emissions and other relevant aspects of PVC 

process vents. Enclosure 1 contains a summary of the information we are requesting. 

Supplemental information is contained in the following enclosures: 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed wnh Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 
Description Enclosure# 

Maximum Achievable Control Technology Enclosure I 

(MACT) Standards Development Information 

Collection Request 

Section 114 Authority and CBI claims Enclosure 2 

CBI emissions data disclosure Enclosure 3 

Designation of ERG as authorized representative Enclosure 4 

Policies and Procedures for handling CBI Enclosure 5 

Certification Statement Enclosure 6 

2014 PVC 114 Process Vent Testing Workbook N/A 

2014 PVC 114 Process Vent Testing Workbook NIA 

Example 

The testing request is designed to collect emissions information, which by law cannot be confidential 

information. You are required to return all requested information on or before November 17, 2014. 

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

CCG-PVC@epa.gov 

There is a small amount of information requested in the survey concerning production and 

production capacity which you may seek to claim as confidential. If you are submitting confidential 

business information (CBI) as described in Enclosure 3, you must mail a separate CD-ROM or 

DVD-ROM disk containing only the CBI portion of your data to EPA. Clearly mark the disk with 

the words "Confidential Business Information" and send via U.S. Postal Service Express Mail, 

registered mail, or private courier to: 

Jodi Howard 

U.S. Environmental Protection Agency 

OAQPS/SPPD/RCG (Mail Code El43-0l) 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

DO NOT ELECTRONICALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION TO 

EPA. 

If you would like to use the required Section 114 testing to satisfy the initial compliance requirements 

for process vents in the PVC rules (40 CFR part 63, subparts DDDDDD and HHHHHHH), please 

contact Region 4 to discuss the requirements prior to beginning the 114 testing. 
Be aware that there are significant penalties for submitting false information, including the possibility of 

fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC §7413). Failure to 

comply fully with this request for information may subject you to an enforcement action. We may use 

any information submitted in response to this request in an administrative, civil, or criminal action. 

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. 

Thank you for your assistance in this effort. 

6 Enclosures 

Sincerely, 

a~ Penny L · siter 

Group Leader 

Refining and Chemicals Group 

Sector Policies and Programs Division 

cc: Kevin Bloomer, Westlake Chemical Corporation, (electronically) w/Enclosures 

Beverly Banister, USEPA, Region 4, Air Division Director, w/Enclosure 1 only 

Keith H. Talley, KY Natural Resources and Environmental Protection, Division of Air 

Quality, w/Enclosure 1 only