1747 Pennsylvania Av, Suite 825 Washington, DC 20006. ●(571) 970

- 3359 ● Fax (571) 970

- 3271 www.vinylinfo.org ● www.vinylindesign .com 

### October 26, 2014

Sent via E lectronic M ail and Fed E x

Ms. Jodi Howard Environmental Engineer , Refining and Chemicals Group
U.S. EPA

- Office of Air Quality Planning and Standards
109 T.W. Alexander Drive
Mail Code: E143

- 01
R esearch Triangle Park, NC 27711
Howard.Jodi @ epa.gov

RE: Polyvinyl Chloride and Copolymers Resins

– Definitions and Process
Information

Dear Ms

. Howard :

Following

- up on the September 22 , 2014, discussions between the Vinyl Institute (“VI”)

and the Environ mental Protection Agency (“EPA”)

, the VI PVC MACT Copolymer Subg roup 1 

### has developed proposed changes and clarifications to the definitions of the resin types and processes in the National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolym ers Production (“PVC MACT”)

. 2



### As the Agency is aware, Lubrizol Corporation and Wacker Chemical Corporation will be regulated under the PVC MACT as manufacturers of PVC copolymer resins. 3 

### The proposed changes and additional definitions , which are enclosed as Attachment A

, identify and clarify PVC and c opolymer resin types and processes for subcategorization

purposes. 4 

### Particularly, these recommendations address undried copolymer resins manufactured by these facilities

. Additional information on resin process types is

included as Attachment B for the Agency’s reference.

The Vinyl Institute and the VI PVC MACT Copolymers Subg roup appreciate EPA’s consideration of this important matter. Please do not hesitate to contact me with any questions.

1 The VI PVC MACT Copolymer Subgroup includes VI members Formosa Plastics Corporation, U.S.A.

, Wacker Chemical

Corporation, and Lubrizol Corporation

.

2 77 Fed. Reg. 22,848 (April 17, 2012).

3 Both Lubr izol and Wacker timely filed the required notification of applicability of the PVC MACT final rule within 120 days of its

effective date . In addition, these companies have filed quarterly reports for their operations under the Vinyl Chloride NESHAP.

4 B oth Wacker and the VI previously filed comments concerning copolymers for the proposed PVC MACT rule.

### VI PVC MA CT Copolymers Subgroup Proposed Definitions , October 26, 2014

Page 2 of 5
The Vinyl Institute, 1747 Pennsylv ania Av, Suite 825 Washington, DC 20006. (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com 

### S incerely,

Richard P. Krock
Technical Director

e

- mail: rkrock@vinylinfo.org phone: (202) 765

- 2287
cell: 571

- 216

- 4474

CC: 

### Ms. Penny Lassiter , EPA

- RTP
Mr. Andrew Bouchard, EPA

- RTP
Mr. Mark Kataoka , EPA

- OCG JC Walker, Keller and Heckman Vinyl Institute PVC MACT Copolymers Sub g roup Vinyl Institute PVC MACT Working Group

Enclosures :

Attachment A : Definitions and Proposed Changes for Resin Process Types in the PVC
MACT Attachment B: Resin Process Types Information

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### VI PVC MA CT Copolymers Subgroup Proposed Definitions , October 26, 2014

Page 3 of 5
The Vinyl Institute, 1747 Pennsylv ania Av, Suite 825 Washington, DC 20006. (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com 

# Attachment A

– Definitions and Proposed Changes for Resin

Process Types in the PVC MACT
October 2 6

, 2014 Draft for Discussion with Jodi Howard, EPA

Definitions in the VCM NESHAP (40 C.F.R. § 61.61) :

Note: There is no definition of “suspension resin” in the VCM NESH AP.

(c) Polyvinyl chloride (PVC) plant includes any plant where vinyl chloride alone or in combination with other materials is polymerized.

(e) Type of resin means the broad classification of resin referring to the basic manufacturing process for producing that resin, including, but not limited to, the suspension, dispersion, latex, bulk, and solution

processes.

( f) Grade of resin means the subdivision of resin classification which describes it as a unique resin, i.e., the most exact description of a resin with no further subdivision.

(g) Dispersion resin means a resin manufactured in such a way as to form fluid dispersions when dispersed in a plasticizer or plasticizer/diluent mixtures.

( h) Latex resin means a resin which is produced by a polymerization pro cess which initiates from free radical catalyst sites and is sold undried.



### Definitions in the PVC MACT (40 C.F.R. § 63.12005) :

Note: Additions to the definitions of “dispersion process, “polyvinyl chloride homopolymer”, and “polyvinyl chloride copolymer” are underlined and deletions are in strikethrough . A new term, “latex process” is
added.

Dispersion process means a process for producing polyvinyl chloride resin using either the emulsion or

m icrosuspension process. These polymerization techniques produ ce fine particles (1

- 10 microns) with little or no porosity. Emulsifier levels vary but agitation is very mild compared to other PVC polymerization

processes. The final product is either a dispersion resin or an emulsion resin and both are dried to powder form. The emulsion resins are smaller in particle size. that is characterized by the formation of the polymers in soap micelles that contain small amounts of vinyl chloride monomer. Emulsifiers are used to disperse vinyl chloride monomer in the water ph ase. Initiators used in the dispersion process are soluble in water. Resins produced using the dispersion process are referred to as latex or dispersion
resins.

Grade means the subdivision of PVC resin that describes it as a unique resin, i.e., the most ex act description of a type of resin with no further subdivision. Examples include low molecular weight suspension resins and general purpose suspension resins.

Latex process means a process for producing polyvinyl chloride resin that is characterized by me tered addition of monomer and other ingredients as the reaction progresses

, typically in a modified semi

- batch
or semi

- continuous emulsion polymerization process. This modified emulsion process creates very fine particles that have a typical average partic le size of less than 0.5 microns. L atex is stripped using steam,
oxidation

- reduction, or other method to eliminate residual monomers yet preserve the sensitive latex product form. Polyvinyl chloride resin produced using the latex process is sold in an undr ied form.

### VI PVC MA CT Copolymers Subgroup Proposed Definitions , October 26, 2014

Page 4 of 5
The Vinyl Institute, 1747 Pennsylv ania Av, Suite 825 Washington, DC 20006. (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com Polyvinyl chloride means either polyvinyl chloride homopolymer or polyvinyl chloride copolymer.

Polyvinyl chloride homopolymer means a synthetic thermoplastic polymer that is derived from the polymerization of vinyl chloride and has the general chemical structure (

- H2CCHCl

- )n. Polyvinyl chloride homopolymer is typically a white powder or colorless granule. Polyvinyl chloride homopolymer is produced by different processes, including (but not limited to), suspension, dispersion or / emulsion,
blendi ng , latex, and bulk processes.

Polyvinyl chloride copolymer means a synthetic thermoplastic polymer that is derived from the simultaneous polymerization of vinyl chloride and another monomer such as vinyl acetate. Polyvinyl chloride copolymer is produced by different processes, including, but not limited to, suspension, dispersion or / emulsion, suspension blending, latex, and solution processes.

Product means a polymer produced using the same monomers and varying in additives (e.g., initiators,
terminator s, etc.); catalysts; or in the relative proportions of monomers, that is manufactured by a process unit. With respect to polymers, more than one recipe may be used to produce the same product, and there can be more than one grade of a product. Product also means a chemical that is not a polymer, which is manufactured by a process unit. By

- products, isolated intermediates, impurities, wastes and trace contaminants are not considered products.

Suspension process means a process for producing polyvinyl chlorid e resin that is characterized by the formation of the polymers in droplets of liquid vinyl chloride monomer or other co

- monomers suspended in water. The droplets are formed by agitation and the use of protective colloids or suspending agents.
Initiators us ed in the suspension process are soluble in vinyl chloride monomer. Polyvinyl chloride resins produced using the suspension process are referred to as suspension resins.

Suspension blending process means a process for producing polyvinyl chloride resin th at is similar to the suspension polymerization process, but employs a rate of agitation that is significantly higher than the highest range for non

- blending suspension resins. The suspension blending process uses a recipe that creates extremely small resin particles, generally equal to or less than 100 microns in size, with a glassy surface and very little porosity. The suspension blending process concentrates the resins using a centrifuge that is specifically designed to handle these small particles. Polyv inyl chloride resins produced using the suspension blending process are referred to as suspension blending resins and are typically blended with dispersion resins.

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### VI PVC MA CT Copolymers Subgroup Proposed Definitions , October 26, 2014

Page 5 of 5
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- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com 

# Attachment B: Resin Process Types Information

VI PV C MACT Copolymers Subgroup, October 26 , 2014