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www.vinylinfo.org www.vinylindesign.com July 1 2 , 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 propos al

. Due to a variety of real

- world operating circumstances ou tlined below, only the first five facilities listed in the Table are the PVC facilities for which the emissions tests nearly 1 reflect the “ maximum operating conditions ” for normal PVC production , as requested by EPA in the Section 114 Information Reques t :

For thermal oxidizer emissions testing, EPA specifically required that PVC

- only process vent gas be iso lated from non

- PVC vent gases generated by adjacent

non

- PVC chemical production facilities.

Although Westlake’s Calvert City, K entucky facilit y 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 large r process vent stream from an adjacent co

- polymer m anufacturer

. Consequently

, the test results do not represent the “ maximum operating

c onditions ” 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 facilit ies 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 . The se conditions are explained in the Table for each facility , most o f which are designed and

1 The Vinyl Institute ’ s letter to EPA on September 24, 2010 explained season al production of PVC resin manufacturing and that during the S.114 testing in 2009 and 2010

, the indus try operating rates were reported as being 2 5% to 34% below their highest production month of the prior 3 years

, which occurred in May, 2007

.Page 2 of 3 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com operated to process PVC production vent streams in thermal oxidizers co

mingled 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 . Oxy Vinyls 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 F loo r ;

o for facilities 8

– 10

, inordinately l arge

- volume natural gas stream s were required in order to operate the thermal oxidizers for testing PVC

- only vent stream s , which may have biase d the HAPs quantities in the test stream s, and likely resulted in non

- rep resentative 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 no t isolated from the co

- located vent streams and the emissions contribution are calcu lated numbers, not actual numbers;

o for facilit ies 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 F acility 15 is new and was not yet operational during the test period and did not submit test results

.

o F acilities 16

– 18 use non

- combustion recovery devices, not thermal oxidizers, and the emissions from devices should not be calculated with emissions from therm al oxid izers.

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 t he MACT Floor for process vents . Please do not hesit ate 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, OAQPSPage 3 of 3 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

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www.vinylinfo.org www.vinylindesign.com