Requested Documents -- Proposed MACT Rule for Polyvinyl Chloride and 

Copolymer (PVC)Production 

Higgins, Cortney to Jodi Howard 04/06f2011 01:1 0 PM 

Cc: Penny Lassiter 

History: This message has been forwarded. 

Hi Jodi, 

Can you send us the following documents? 

let me know when they will be ready: 

If they are not yet ready, please 

MACT Floor Analysis for the Polyvinyl Chloride (PVC) and Copolymers Production 

Source Category (79, other pages) 

Analysis for the PVC Production Source Category (p 94) 

MACT Floor Analysis for the PVC Production Source Category (p 96, 99) 

Analysis of Beyond MACT Floor Controls for the PVC Production Source Category 

(101) 

Costs and Emission Reductions of the MACT Floor Level of Control for the PVC 

Production Source Category (149) 

Secondary Impacts of the Proposed Level of Control for the PVC Production 

Source Category (156) 

Economic Impact Analysis (156) 

Cost and Impacts of the PVC and Copolymers Proposed Standard (157) 

ICR Supporting Statement (163) 

Regards, 

Cortney 

202.395.7856 

-----Original Message----­

From: Higgins, Cortney 

Sent: Friday, April 01, 2011 12:17 PM 

To: Howard.Jodi@epamail.epa.gov 

Cc: Lassiter.Penny@epamail.epa.gov 

Subject: RE: Proposed MACT Rule for Polyvinyl Chloride and Copolymer 

( PVC) Production 

Hi Jodi, 

Thanks for the email. This rule has a settlement agreement deadline of 4/15? 

We are available at the following times next week -- can we schedule an hour 

for a briefing call? Also, could you please send briefing slides before the 

call that include the costs and the estimated emissions reductions? 

4/4: 10-11, 1-2, 3-5 

4/5: 10-2, 3-4 

4/6: 10-12:30, 3-5 

Thanks, 

Cortney 

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

From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov] 

Sent: Thursday, March 31, 2011 4:14 PM 

To: Higgins, Cortney 

Subject: Proposed MACT Rule for Polyvinyl Chloride and Copolymer 

( PVC) Production 
Hi, 

I'm the project manager for the PVC MACT rule that was sent to OMS this 

morning. Penny Lassiter, Bill Nickerson, Mark Kataoka, and I would like 

to talk to you about the rule, so please let me know if we could meet 

sometime early next week. Thanks. 

Jodi Howard 

******�***************�************************************* 

Jodi Howard, Environmental Engineer 

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

Sector Policies and Progra.m Divisions 

Refining and Chemicals Group 

Mail Code: E143-01 

Research Triangle Park, NC 27711 

Phone: 919-541-4607 Fax: 919-541-0246 
His(c;ry: 

Hi Penny, 

PVC Memos 

Higgins, Cortney �o Penny Lassiter 

Cc: Jodi Howard 

This message has been replied to and forwarded. 

04/08/2011 11 :54 AM 

I wanted to check in and see if the memos/documents listed below can be sent to us today? If not 

today, when will they be done? 

Thanks, 

Cortney 

MACT Floor Analysis for the Polyvinyl Chloride (PVC) and Copolymers Production 

Source Category (79� other pages) 

Analysis for the PVC Production Source Category (p 94) 

MACT Floor Analysis for the PVC Production Source Category (p 96� 99) 

Analysis of Beyond MACT Floor Controls for the PVC Production Source Category 

(lel) 

Costs and Emission Reductions of the MACT Floor Level of Control for the PVC 

Production Source Category (149) 

Secondary Impacts of the Proposed Level of Control for the PVC Production 

Source Category (156) 

Economic. Impact Analysis (156) Cost and Impacts of the PVC and Copolymers 

Proposed Standard (157) 

ICR Supporting Statement (163) 

Referenced materials In PVC memos 

Higgins. Cortney �o Jodi Howard 

Cc: Penny Lassiter 

04/12/2011 10:38 AM 

----

I hstory· This message has been forwarded. 

Hi Jodi, 

The baseline emission memo on page 2 has a footnote "2" that points to the determination of HAP 

concentrations, which is in a separate memo. Can you send that memo, and can the source be added to 

the memo? I can't find what footnote 2 references. 

Regards, 

Cortney 

RE: Revised PVC Memos 

Higgins, Cortney to Jodi Howard --

Cc: Penny Lassiter, Mark Kataoka, William Nickerson 

History· This message has been replied to and forwarded. 

Thanks! 

Do you also have a copy of the EJ analysis? 

Regards, 

Cortney 

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

04/12/2011 11 :42 AM 

From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov] 

Sent: Tuesday, April 12, 2011 11:41 AM 

To: Higgins, Cortney 

Cc: Lassiter.Penny@epamail.epa.gov; Kataoka.Mark@epamail.epa.gov; 

Nickerson.William@epamail.epa.gov 

Subject: Revised PVC Memos 

Cortney, 

Attached are the revised MACT floor, Secondary Impacts, and Floor Reductions 

and Costs memos. The Beyond-the-Floor memo was not amended. 

I will be sending you the revised preamble and Economic Impacts memo shortly. 

Thanks. 

(See attached file: Memo PVC Secondary Impacts DRAFT 201100411.pdf) (See 

attached file: Memo PVC MACT-Floor DRAFT 20110411.pdf) (See attached 

file: Memo_PVC_MACT=Floor_Reductions_CostS_DRAFT_20110411.pdf) 

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

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 

History: 

Hi Jodi, 

RE: Revised PVC proposal package 

Higgins, Cortney �o Jodi Howard 

Cc: Penny Lassiter, Mark Kataoka, Janet Eck, "Kymn, Christine J." 

This message has been replied to and forwarded. 

04/12/2011 10:22 PM 

I have no additional comments -- can you send a clean version to Christine 

(copied above)? 

Thanks, 

Cortney 

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

Sent: Tuesday, April 12, 2011 6:39 PM 

To: Higgins, Cortney 

Cc: lassiter.penny@epa.gov; kataoka. mark@epa.gov; eck. janet@epa.gov 

Subject: Revised PVC proposal package 

Cortney, 

Our server is down, so I'm sending you the revised package with OGC and OMB 

comments/edits addressed from my personal email address. We still need to 

check cross references and do a few other minor edits to the package. 

Thanks. 

Jodi Howard 

howard.jodi@epa.gov 

919-541-4607 

� 

PVC Package 04·12·11 v3.doc 

Jodi, 

OIRA Review Concluded, EPA NPRM: NESHAP: Polyvinyl Chloride and 

Copolymers Production, Amendme.nts 

Kymn, Christine J. �o Jodi Howard 04/14/2011 06:23 PM 

Cc: "Higgins, Co.rtney", Penny Lassiter, Darryl Adams 

This message has been forwarded. 

OIRA has concluded review of EPA's NPRM, NESHAP: Polyvinyl Chloride and 

Copolymers Production, Amendments. Please let us know if you have any 

questions. 

Thank you, 

Christine 

History: 

EO 12866 13563 Review: Revised PVC proposal package 

Kymn, Christine J. to Jodi Howard 

Cc; "Higgins, Cortney", Penny Lassiter 

This message has been replied to and forwarded. 

Thanks, Jodi. On the two edits: 

04/14/2011 12:29 PM 

1) The sentence of most import that I do not see in the latest draft is: 

"We further solicit comment on whether we should issue MACT standards under 

CAA section 112(d) (2) and (3) in lieu of GACT standards under section 

112 (d) (5) given the significant amount of additional information on the one 

area source that was not available to EPA at the time of the 2007 area source 

GACT promulgation." 

2) On the GACT same as MACT sentences, I saw the changes but noted that there 

is one less occurrence of a version of this sentence. I don't think this need 

be a huge issue. 

On item 1 above, I could not find that sentence anywhere in the latest draft. 

I'll give you a quick call on this. 

Thanks, 

Christine 

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

From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov] 

Sent: Thursday, April 14, 2011 12:07 PM 

To: Kymn, Christine J. 

Cc: Higgins, Cortney; Lassiter. Penny@epamail.epa.gov 

Subject: RE: Revised PVC proposal package 

Christine, 

I have answers to your two questions about changes on the PVC package 

that I sent to Cortney on Tuesday evening (with OGC and OMB revisions) 

p. 86 of the redline version: 

the following sentence was modified from 

- "As explained explained in greater detail below, we determined that 

GACT is the same as MACT based on" 

to "As explained in greater detail below, we determined that GACT 

standards for area sources should be the same as the major source MACT 

standards based on" 

p. 90 of the redline version: 

The "we solicit comments" sentence is on page 78 of the version that I 

sent to you last night. 

Please let me know if you have any other questions. 

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 

From: "Kymn, Christine J. " <Christine_J. _Kymn@ornb.eop. gov> 

To: Jodi Howard/RTP/USEPA/US@EPA 

Cc: "Higgins, Cortney" <Cortney_Higgins@ornb.eop.gov>, Penny 

Lassiter/RTP/USEPA/US@EPA 

Date: 04/14/2011 11:04 AM 

Subject: RE: Revised PVC proposal package 

Thanks, Jodi. I 'm reviewing. Looks like there are some language 

changes as compared to the last redline? Maybe we can chat briefly 

once I'm done going through it all. 

From: Howard.Jodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa. gov] 

Sent: Wednesday, April 13, 2011 9:32 PM 

To: Kymn, Christine J. 

Cc: Higgins, Cortney; Lassiter.Penny@epamail. epa. gov 

Subject: RE: Revised PVC proposal package 

Christine, 

Attached is the clean version of the PVC proposal package. Please let 

me know if you have any questions. 

Thanks. 

Jodi 

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

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 
History: 

RE: Revised PVC proposal package 

Kymn, Christine J

. to Jodi Howard 

Cc: "Higgins, Cortney", Penny Lassiter 

This message has been replied to and forwarded. 

04/14/2011 11 :04 AM 

Thanks, Jodi. I'm reviewing. Looks like there are some language changes as compared to the last 

redline? Maybe we can chat briefly once I'm done going through it all. 

From: HowardJodi@epamail.epa.gov [mailto:Howard.Jodi@epamail.epa.gov] 

Sent: Wednesday, April 13, 2011 9:32 PM 

To: Kymn, Christine J. 

Cc: Higgins, Cortney; Lassiter.Penny@epamail.epa.gov 

Subject: RE: Revised PVC proposal package 

Christine, 

Attached is the clean v ersion of the PVC proposal p ackag e. Please let me know if you have 

any questions. 

Than ks. 

Jodi 

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

Jodi Howard, Environmental Engineer 

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

Sector Policies and Program Di visions 

Refining and Chemicals Group 

Mail Code: E143-01 

Research Triangle Park, NC 2 7711 

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