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

meth odologies 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 ot hers 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

thes e 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 movin g 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 th e 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 wo uld 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). Comp aring 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

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