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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

July 12, 2011

Sent via Electronic Mail

Ms. Jodi Howard

Environmental Engineer

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

Mail Code: E143-01

Research Triangle Park, NC 27711

Howard.Jodi@epamail.epa.gov

RE: PVC-Only Facilities to Use for Process Vent MACT Floor Calculations

Dear Ms. Howard:

During our meeting on June 30, 2011, we discussed certain issues associated with the 

types of facilities EPA used to calculate the MACT floor for process vents under the 

proposed PVC MACT standard. As a follow-up to our discussion, The Vinyl Institute 

prepared the attached Table to highlight the differences between control device 

operations at the various facilities subject to the proposal.

Due to a variety of real-world operating circumstances outlined below, only the first five 

facilities listed in the Table are the PVC facilities for which the emissions tests nearly1

reflect the “maximum operating conditions” for normal PVC production, as requested by 

EPA in the Section 114 Information Request:

For thermal oxidizer emissions testing, EPA specifically required that PVC-only 

process vent gas be isolated from non-PVC vent gases generated by adjacent 

non-PVC chemical production facilities.

Although Westlake’s Calvert City, Kentucky facility conducted the emissions test 

with isolated PVC-only vent gas, the test results should not be included in the

floor calculation because the thermal oxidizer is designed and operated to also 

accept a larger process vent stream from an adjacent co-polymer manufacturer. 

Consequently, the test results do not represent the “maximum operating 

conditions” relevant for calculating the MACT Floor because the co-polymer vent 

stream was not present during the test.

None of the emissions tests from the other facilities that submitted test data from 

thermal oxidizers (listed as facilities 7 – 14 in the Table) are representative of 

normal operating conditions for PVC-only thermal oxidizers. These conditions 

are explained in the Table for each facility, most of which are designed and 

 

1

The Vinyl Institute’s letter to EPA on September 24, 2010 explained seasonal production of PVC resin manufacturing and that 

during the S.114 testing in 2009 and 2010, the industry operating rates were reported as being 25% to 34% below their highest 

production month of the prior 3 years, which occurred in May, 2007.
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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

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operated to process PVC production vent streams in thermal oxidizers comingled with vent streams from other types of co-located chemical production 

facilities. In summary:

o the thermal oxidizer for facility 7 malfunctioned during the stack test 

period. OxyVinyls communicated this factor to EPA when submitting its 

test results on February 28, 2011. Using the results of this test introduces 

an inappropriate bias in calculating the MACT Floor;

o for facilities 8 – 10, inordinately large-volume natural gas streams were

required in order to operate the thermal oxidizers for testing PVC-only vent 

streams, which may have biased the HAPs quantities in the test streams,

and likely resulted in non-representative emissions profiles more similar to 

natural gas fired boilers than PVC production thermal oxidizers;

o for facilities 11 and 12, the PVC-only vent streams were not isolated from 

the co-located vent streams and the emissions contribution are calculated 

numbers, not actual numbers;

o for facilities 13 and 14, it was not possible to isolate the PVC-only vent 

stream for the test and the results are not representative of the 

performance of a thermal oxidizer processing a PVC-only vent stream; 

o Facility 15 is new and was not yet operational during the test period and 

did not submit test results.

o Facilities 16 – 18 use non-combustion recovery devices, not thermal 

oxidizers, and the emissions from devices should not be calculated with 

emissions from thermal oxidizers.

 

I am very interested in discussing with you the specifics surrounding the emissions tests 

and our proposal for relying on the first five facilities listed in the Table for calculating 

the MACT Floor for process vents. Please do not hesitate to contact me at your 

convenience. 

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

phone: 571-970-3392

Cell: 571-216-4474

cc: Penny Lassiter, OAQPS

Jason DeWees, OAQPS

Barrett Parker, OAQPS
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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

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No. Company City State

Source 

Type

PVC Resin 

Type

Co-located 

with 

EDC/VCM

StandAlone PVC 

Producer

Approximate % of 

Total Vent Gas 

from PVC 

Production 

Present During 

S.114 Test

Approximate % of 

Total Vent Gas 

from Other 

Sources Diverted 

for S.114 Test

Comments

1 Formosa Plastics Delaware City DE Major

Dispersion, 

Copolymer X 100 0

2 Georgia Gulf Aberdeen MS Major Suspension X 100 0

3 Shintech Addis LA Major Suspension X 100 0

4 Shintech Freeport TX Major Suspension X 100 0

5 Certainteed Lake Charles LA Area Mass X 100 0

6

Westlake 

Chemicals Calvert City KY Major Suspension (*) 30 70

Westlake Calvert City processes 

Wacker copolymer vent gas 

between 40 and 90% of the time; 

large volume of nat. gas burned 

during S.114 test

(*) Westlake Calvert City facility accepts process vent gas from Wacker Chemical; test completed on new TO and may not have been optimized yet.

7 OxyVinyls Pasadena TX Major Suspension (**) 100 0

Malfunction occurred during 

S.114 Test

8 Formosa Plastics Point Comfort TX Major Suspension X 1 99

Large volume of nat. gas burned 

during S.114 test

9 Formosa Plastics Baton Rouge LA Major Suspension X 1 99

Large volume of nat. gas burned 

during S.114 test

10 OxyVinyls

Deer 

Park/LaPorte TX Area Suspension X 1 99

large volume of nat. gas burned 

during S.114 test

11 Shintech Plaquemine LA Major Suspension X 1 99

Shintech Plaquemine did not 

isolate its PVC-only vent gas for 

the S. 114 test, but calculated its 

emission contribution.

12 Georgia Gulf Plaquemine LA Major Suspension X 20 80

GG Plaquemine did not isolate its 

PVC-only vent gas for the test, 

but calculated its emission 

contribution

13

Westlake 

Chemicals Geismar LA Major Suspension X 10 90

Westlake Geismar was not able 

to divert its non-PVC vent gas 

during the test

14 Dow Chemical Midland MI Major Copolymer (***) <1 >99

Dow Midland does not have the 

ability to isolate its PVC-only 

vent gas for the test purposes 

because it is one of many 

streams handled by a common 

control device. 

(**) OxyVinyls Pasadena PVC MACT S114 test was completed during a period of malfunction

15 Formosa Plastics Point Comfort TX Major

Dispersion, 

Suspension 

Copolymer , 

Suspension 

Blending X ( ) (** **)

( ) Formosa's Specialty PVC Unit completed a PVC MACT S.114 survey but was not yet operational during the S.114 test period

16 PolyOne Pedricktown NJ Major Dispersion X - VGA 100 0

17 PolyOne Henry IL Major

Dispersion, 

Suspension 

Blending, 

Suspension X - VGA 100 0

18 OxyVinyls Pedricktown NJ Major Suspension X (** ***) (*****)

(*****) OxyVinyls Pedricktown process vent gas is sent to PolyOne Pedricktown plant

Table 1: U.S. PVC Producers Process Vent Gas Control Device Operation for PVC MACT S. 114 Tests

Thermal Oxidizer Control Devices Representative of Normal PVC-Only Operations During S.114 Test

Thermal Oxidizer Control Devices Not Representative of Normal PVC-Only Operations During S.114 Test

 Non-Combustion Recovery Devices 

New Site Control Devices Not Yet Operational at Time of S. 114 Test 

(***) Dow Midland sends its copolymer process vent gas to a control device shared with vent streams from plant's non-PVC processing operations and a stream from 

a Pharma multi-product plant