To: Jodi Howard/RTP/USEPA/US@EPA, <rkrock@vinylinfo.org>

From: "Bloomer, Kevin" <kbloomer@westlake.com>

Date: 09/22/2011 03:06PM

cc: "Bodron, Allen" <abodron@westlake.com>, "Stone, Lloyd" <lstone@westlake.com>, 

"Khonsari, Karen" <kkhonsari@westlake.com>, "Casey, John" <jcasey@westlake.com>, 

<Walker@khlaw.com>

Subject: Re: Westlake - Geismar and the the VI Recalculated Stripped Resin Limits

Jodi,

I wanted to briefly respond to your comment about Westlake Geismar's resin 

test results and the suggested emission limits that the VI calculated during 

the comment response period.

We were aware that the vinyl chloride limit of 38 ppmv would impact our 

operations. However, we are fully supportive of the work and the 

methodologies that the VI Working Group used in establishing these various 

limits. The approach that we took in analyzing the data conforms to the same 

floor setting techniques that EPA has used in recent rules.

We were also aware that our emissions of the others HAPs were some of the 

lowest. The uniqueness of each of these PVC units has been difficult for 

both parties to adequately explain and understand. Westlake is appreciative 

of the efforts that EPA is undertaking to promulgate a MACT rule covering 

these complex processes using the best available data in a defensible manner. 

One of the control options that has been studied is the installation of a new 

resin stripper, at a cost close to the eight to ten million dollar range. We 

have also looked at moving the current resin stripper over to replace our 

wastewater stripper as well.

Given a three-year compliance schedule, we feel that we will be able to meet 

this timeline with an effective plan for controlling all of our emissions. 

Westlake is committed to compliance with all of our regulatory mandates.

Should you have any additional comments, as always please feel free to 

contact me.

Sincerely,

Kevin Bloomer

----- Original Message -----

From: Howard.Jodi@epamail.epa.gov <Howard.Jodi@epamail.epa.gov>

To: Richard Krock <rkrock@vinylinfo.org>

Cc: Bloomer, Kevin

Sent: Wed Sep 21 10:16:38 2011

Subject: Westlake - Geismar and the the VI Recalculated Stripped Resin Limits

Mr. Krock,

On August 2, 2011, Keller and Heckman, LLP sent a letter on the behalf

of the VI and the PVC MACT Working Group which provided comments on the

proposed PVC production MACT. Within the letter, the stripped resin

limits were recalculated for both new and existing sources. Based on

these revised limits for VC, Westlake - Geismar would not be able to

comply with the revised existing VC limit of of 38 ppm. This is based on

the 4 years of VC resin data that was also submitted.
Westlake - Geismar's average vinyl chloride concentration is 69 ppmw

(based on the 4 years of VC data). Comparing each day's concentration

(1346 daily values) to the revised VI limit, they would be out of

compliance 87% of the time, or 1173 days out of 1346.

Thanks

************************************************************

Jodi Howard, Environmental Engineer

U.S. EPA - Office of Air Quality Planning and Standards

Sector Policies and Program Divisions

Refining and Chemicals Group

Mail Code: E143-01

Research Triangle Park, NC 27711

Phone: 919-541-4607 Fax: 919-541-0246

*****Celebrating 25 Years of Excellence*******

******Houston Chronicle 100, Company of the Year 2010******

******Listed as a member of the Russell 1000 Index******

******Named to Forbes's "The Most Trustworthy Companies" 2010 list******

******Named to Fortune's 1000 list for 2011******

******Ranked in Industry Week's "U.S. 500 Largest Manufacturing Companies" 

2011 list.******