We determined that you used the original PVC survey forms (parts 1 and 2) to complete the data request instead of the revised forms that were posted on November 10, 2009. Please take a look at the changes from the original PVC survey forms to the revised forms and let me know if what you submitted reflected the changes on the revised forms. Thanks. Below is a summary of the revisions that were made to the survey forms. Also attached: 1. The first set of forms that were posted: SURVEYPart1_[Company]_[F acility]_[ProcessUnitID].xls SURVEYPart2_[Company]_[Facility]_[ProcessUnitID]_[CampaignNumber].xls 2. The revised set that were posted: SURVEYPart1_[Company]_[Facility]_[ProcessUnitID]_rev111009.xls SURVEYPart2_(Company)_(Facility)_(ProcessUnitID)_(Campa ignNumber)_rev111009.xls 3. A separate set of the forms that has the revisions highlighted in red. Form tabs that had a change are colored red as is any text that was revised. Note that these files are NOT password protected or protected in any way: "S URVEYPart1_REVISIONS_IN_RED.xls" "SURVEYPart2_REVISIONS_IN_RED.xls" Summary of Revisions Made From First Set of Posted Spreadsheets to the Spreadsheets Now Posted:
SURVEYPart1 Form B - 1: Changed "intrinsic viscosity" to "inherent viscosity". The subm itted forms from GGC Aberdeen listed inherent viscosity on Form B - 1. Form C - 1 - c: Corrected the Liquid Loading Rate from "L/m3" to "gpm" (Did you submit your data in gpm?) The worksheet appears to be set up for continuous flow, trayed stripping columns. However, the facility utilizes batch wastewater strippers; therefore no liquid loading rate was entered into the worksheet and the change in units has no affect on the submitted survey. Form D: Changed "Does the heat exchange system cool process fluids t hat contain HAP?" to "Does the heat exchange system heat or cool process fluids that contain HAP or VOC?". On the submitted survey our reply was “Yes”. With the rewording of this item the answer is still “Yes”. Form J: Corrected the reference from Form G - 1 to Form I. None of the changes listed on Form I were from new source review requirements. Most changes were part of company motivated process improvements.
SURVEYPart2 Form K- 1 - a: Changed flow rate units from "scfm" to "dscfm" (cell E16). (Did you submit your data in dscfm?) No, the data submitted was total scfm not converted to nor measured on a dry basis. Form K- 1 - b: Changed units from ppmv to allow users to select "ppmvd @ 3% O2", "ng/dscm @ 3% O2" or "ug/dscm @ 3% O2". (What format did you u se?) Answers were submitted as ppm. Form K- 1 - c: Added a "Basis for Emissions Values" column for each HAP instead of only one column for all HAP. This form required the creation of additional worksheets. The basis for emission values for each HAP listed on Worksheet K - 1 - ca is a model created for Title V permitting activities. The other K - 1 - c worksheets list only VCM, the basis for which is the residual VCM concentration of resin leaving the stripping column (or reactor used as a stripper) and conservatively assuming all VCM is then emitted through the various emission points located between the stripping operation and rail car loading (EPs 15 - 34, 37 - 46). Form K- 2 - a: Added a "Basis for Flow Rate Value" column for each Process Stream ID instead of only on e column for all Process Stream IDs at the end. Added text at the top of the Form to clarify that "This Form should be completed for streams of ALL phases, except gas/vapor streams." The basis for each stream is listed separately in the last column. The basis was “measured” for streams that have flow meters and “calculated” for others. The form includes all streams, excluding vapor and gas streams.Form K- 2 - b: Removed "Units" columns and the option to select "ppmv" or "ppmw"
-- consolidated with 'Concen tration" column. (Did you submit your data in ppmv or ppmw?) No data was submitted on this Form. This worksheet requests concentration data for streams downstream of the stripping operations. As was discussed in the original coverletter, the facility me asures the residual VCM concentration of the resin leaving the stripping operations. However, the facility does not currently analyze the water portion of the slurry for pollutants. Without such information, the calculation of the concentration of VCM in the stream itself is not possible. The sampling event required as a component of this survey will, however, provide analytical results describing the concentration of VCM, as well as those of the other identified pollutants contained in the approved samp ling plan, in both the liquid and solid phases of the slurry in a number of these streams. Form K- 3 - b: Removed "Units" columns and consolidated with "Concentration" column. Data was submitted as ppmw, parts per million by weight. Form L: Changed "Con centration at Equipment Opening" units to "ppmvd @ 3% O2". (Did you submit your data in ppmvd @3% O2?) No, the data is not submitted in ppmvd @3% O2. Data in that format is not available. Form M: Changed "Concentration Immediately Prior to Removal From Equipment and Before Being Mixed With Other Materials or Fluids (ppm)" to "Concentration in Resin or Resin Slurry Immediately Prior to Removal From Equipment and Before Being Mixed With Other Materials or Fluids (ppmw)" (Cell C18). (Did you submit your d ata in ppmw?) The approved sampling plan contains an “off - spec pile” section that details the efforts Georgia Gulf will take during the upcoming sampling event to quantify the emissions related to this resin. Form N: Changed "Concentration (ppm)" to "Con centration (ppmw)" (Did you submit your data in ppmw?) Yes, data submitted is in ppmw units. Form O: Changed "Number of turnovers per campaign" to "Number of turnovers." Changed "Concentration (ppm)" to "Concentration (ppmvd @ 3% O2)". Added a column for "Total Emissions (pounds)". (Did you submit your data in ppmvd @3% O2?) We have no equipment that falls into this category, this sheet is marked NA for not applicable. No data was entered.