### 2011 VCM PLANT EPA ICR EMISSION TEST REPORT

FORMOSA PLASTICS CORPORATION Point Comfort, Texas August 2011

Prepared For FORMOSA PLASTICS CORPORATION 201 Formosa Drive Point Comfort, Texas 77978

Glen Capra Project Manager Approved for Transmittal

Prepared By WESTON SOLUTIONS, INC. 2705 Bee Cave Road, Suite 100 Austin, Texas 78746 Phone: (512) 651-7100 Fax: (512) 651-7101

25 August 2011
Work Order No . 02774.015.001Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 iii WESTON SOLUTIONS, INC. (WESTON  ) EMISSION TESTING PRACTICE – AUSTIN OPERATIONS ACCREDITATION STIPULATION

Laboratory: Weston Solutions, Inc. Accreditor(s): Louisiana Environmental Laboratory Accreditation Program (LELAP) – Laboratory and Emission Testing Practice
Accreditation ID: LELAP/NELAC – 03024 Scope: THC, VC, and Dioxins and Furans Sampling and Analysis
Effective: 21 December 2001 Expires: 30 June 2012Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

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### TABLE OF CONTENTS

1. INTRODUCTION .............................................................................................................. 1-1
2. RESULTS AND DISCUSSION ......................................................................................... 2-1
3. SOURCE TESTING METHODOLOGY ......................................................................... 3-1 3.1 PROCESS SUMMARY ............................................................................................. 3-1 3.2 PROJECT TEAM RESUMES ................................................................................... 3-2 3.3 SAMPLING LOCATION PHOTOGRAPHS AND SCHEMATIC .......................... 3-3

APPENDIX A SAMPLE CALCULATIONS APPENDIX B TEST METHODOLOGY APPENDIX C FIELD DATA APPENDIX D LABORATORY DATA APPENDIX E QUALITY CONTROL DATA APPENDIX F PROCESS OPERATING/PRODUCTION DATA


### LIST OF TABLES
Table 1-1 General Facility and Testing Information

...................................................................... 1-1 Table 2-1 Summary of Emi ssion Test Results ............................................................................. 2-1
Table 2-2 VCM Plant Incinerator – EPN 006C Su mmary of PCDD/PCDF Emission Results ... 2-2 Table 2-3 VCM Plant Incinerator – EPN 006C Vinyl Chloride and THC Emission Results.....2-3 Table 3-1 Source Testing Methodology ....................................................................................... 3- 1


### LIST OF FIGURES
Figure 3-1 Stack Photographs .................................................................................................. .... 3-3 Figure 3-2 Formosa Plastics Point Comfort Sche matic Drawing of Incinerator VH-801C (EPN 006C) ......................................................................................................................... ........... 3-4Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

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v 

### LIST OF ACRONYMS
EPA Environmental Protection Agency EPN emission point number Formosa Formosa Plastics Corporation GPM Gallons per minute Mg/m 3 Milligrams per cubic meter NELAC National Environmental La boratory Accreditation Council O 2 Oxygen PCDD/PCDF dioxin and furan PPMV parts per million by volume RCRA Resource Conservation and Recovery Act REC recognized environmental condition ST short tons TCEQ Texas Commission on Environmental Quality THC total hydrocarbon VC vinyl chloride VCM Vinyl Chloride Monomer WESTON Weston Solutions, Inc.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

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### 1. INTRODUCTION Weston Solutions, Inc (WESTON  ) was r etained by Form osa Plasti cs Corporation (Form osa) to conduct dioxin and furan (PCDD/PCDF), total hydrocarbon (THC), and vi nyl chloride (VC) emission testing on a representative Vinyl Chlori de Monomer (VCM) Plant incinerator (Em ission Point 006C) at the facility in Point Com fort, Te xas. The purpose of the testing was to supply requested information for the Environm ental Pr otection Agency (EPA) Vinyl Chloride Monomer and Ethylene Dichloride Pr oduction Information Request.
WESTON performed the em ission testing during 2-4 August 2011. G eneral facility and testing information, including individua ls on the project team, is listed in Table 1-1 below:

Table 1-1 General Facility and Testing Information

Facility Name Formosa Plastics Corporation Point Comfort, Texas
Contact Person Mr. Sean Woodard
Telephone Number 361-987-7000
Facility Address 201 Formosa Drive Point Comfort, Texas 77978

Types of Process Sampled VCM Plant incinerator Person Responsible for Conducting Test Mr. Glen Capra Testing Contractor Project Team Mr. Glen Capra Mr. Cory Foytik
Mr. Pat Turner Ms. Dolores Diaz – Report Coordinator Ms. Susan Brown – Safety CoordinatorWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report INTRODUCTION

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 1-2 Field Contact Telephone Number (512) 651-7132 Office (512) 965-3777 cell
Test Company Name Weston Solutions, Inc.

Address Mira Vista Building, Suite 100 2705 Bee Cave Road Austin, Texas 78746
512-651-7100 • Fax 512-651-7101
Date(s) of Test 2-4 August, 2011

Mr. Jack Millikin of Formosa c oordinated the testing with faci lity operations and served as WESTON's technical contact throughout the effort.

The National Environmental La boratory Accreditation Counc il (NELAC) accredits WESTON’s emission testing practice and industr ial hygiene la boratory. The stipula tion associated with this accrediting authority preced es the table of conten ts of this report.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

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### 2. RESULTS AND DISCUSSION Table 2-1 presents a summary of t he mean emissi on results in the units spec ified in the EPA’s information collection request.

Table 2-1 Summary of Emission Test Results

VCM Plant Incinerator (EPN 6002C Stack) Mean Test Value Test Method Total Hydrocarbons, ppmvd @ 3% O 2 as propane 1.05 U.S. EPA Method 25A
Vinyl Chloride, ppbvd @ 3% O 2 Less than 440 U.S. EPA Method 18. 9.1 average percent oxygen and 24.0 percent moisture used to correct lab result of less than 0.22 ppm-wet. Dioxins and Furans, ng/dscm @ 3% O 2 2,3,7,8-TCDD 1,2,3,7,8-PeCDD 1,2,3,4,7,8-HxCDD 1,2,3,6,7,8-HxCDD 1,2,3,4,6,7,8-HpCDD OCDD 2,3,7,8-TCDF 1,2,3,7,8-PeCDF 2,3,4,7,8-PeCDF 1,2,3,4,7,8-HxCDF 2,3,4,6,7,8-HxCDF 1,2,3,7,8,9-HxCDF 1,2,3,4,6,7,8-HPCDF 1,2,3,4,7,8,9-HpCDF OCDF 8.10e-03 4.26e-02 7.78e-02 1.34e-01 4.90e-01 5.05e-01 4.99e-02 3.41e-01 7.16e-02 1.20e-00 8.25e-02 4.01e-02 1.71e-00 4.85e-01 2.84e-00 U.S. EPA Method 23 with a minimum volume of 5 cubic meters per run.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report RESULTS AND DISCUSSION

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 2-2 Table 2-2 provides a deta iled summary of the em ission resu lts. Any differences between the calculated results presented in the appendices and th e results reported in the summary tables are due to rounding for presentation.

Table 2-2 VCM Plant Incinerator – EPN 006C Summary of PCDD/PCDF Emission Results

Run 1 Run 2 Run 3 Mean
Date Time Began Time Ended 8/2/2011 08:23 14:26 8/2/2011 15:07 21:07 8/3/2011 9:10 15:13 ----

----

---- Stack Gas Data Temperature, °F 147 148 148 148 Velocity, ft/sec 40 43 42 42 Moisture % 24 24 24 24 CO 2 Concentration, % 7.1 7.4 6.2 6.7 O 2 Concentration, % 8.5 8.4 10.3 9.4 Stack flow rate, x 10 3 dscfm 4.59 4.94 4.85 4.79
Process Data Production Rate, VCM shor t tons 2313 2306 2308 2309 Scrubber Flow, gpm 149 149 149 149 Scrubber pH 8.55 8.56 8.60 8.57 Combustion Temperature o F 1951 1978 1898 1942 Waste gas valve flow setting 45% 45% 45% 45% Plant O 2 reading 7.76 7.77 7.86 7.80Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report RESULTS AND DISCUSSION

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 2-3 Table 2-3 VCM Plant Incinerator – EPN 006C Vinyl Chloride and THC Emission Results

Run 1 Run 2 Run 3 Mean
Date Time Began Time Ended 8/3/2011 11:00 12:00 8/3/2011 12:07 13:07 8/3/2011 13:29 14:29 ----

----

---- Vinyl Chloride Emission Results Vinyl Chloride Lab result (ppmv-wet) ND a < 0.22 < 0.22 < 0.22 Corrected ppbv-dry @ 3% O 2 -- < 440 < 440 < 440 mg/m 3 @ 3% O 2 -- < 1.143 < 1.143 < 1.143 O 2 Concentration, % 9.1 9.1 9.1 9.1 Moisture % 24 24 24 24 Total Hydrocarbons Emission Results
Date Time Began Time Ended 8/4/2011 13:34 14:36 8/4/2011 14:51 15:52 8/4/2011 16:10 17:11 ----

----

---- THC analyzer result ppmv-wet as methane 1.5 1.0 2.1 1.53 THC as propane ppmv-dry @ 3% O 2 1.0 0.7 1.4 1.05 O 2 Concentration, % 9.5 9.6 9.3 9.5 Moisture % 24 24 24 24 Process Data on 8/4/11 Scrubber Flow, gpm 150 151 150 150 Scrubber pH 8.51 8.58 8.50 8.53 Combustion Temperature o F 1833 1873 1899 1868 Waste gas valve flow setting 40 40 46 42 Plant O 2 reading 7.19 7.29 7.29 7.26

a Run 1 ba g was used as the spike bag and the laboratory spiked the bag for the EPA Method 18 spike recovery study before a valid analytical re sult was obtained. The laboratory narrative is found on Appendix page 106 of the report . Runs 2 and 3 were non-detects and the method detection limit was used as the reported result. All spike recovery and QA/QC results were within method criteria.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report

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### 3. SOURCE TESTING METHODOLOGY The emission testing program was conducted in acco rdance with the U.S. EPA Reference Meth ods summarized in Table 3-1. Method descriptions and quality assurance data are provided in the referenced appendices.

Table 3-1 Source Testing Methodology

Parameter Method Number Appendix Reference

Comments Method Description Quality Control

Data
Volumetric Flow Rate 1,2,3,4 B.1 E Vinyl Chloride 18 B.2 E Dioxins and Furans 23 B.3 E Minimum of 5 m 3 Total Hydrocarbons 25A B.2 E Equipment calibrations will be ma intained on fi le at WESTON.
3.1 PROCESS SUMMARY Formosa is located in Point Comfort, Texas, and has four operational incineration units in the Vinyl Chloride Monomer (VCM) plan t. The units are p ermitted in the Texas Co mmission on Environmental Quality (TCEQ) Permit No. 7699/PSD-TX-226M6. The incinerator unit tested is designated as emission point number (EPN) 006C in Texas Commission on Environmental Quality (TCEQ) permit number 7699/PSD-TX-226M6. Additi onal information concerning the process summary is included in Appendix G.
The incinerators are all equippe d with a scru bber for the rem ova l of chlorinated com pounds. Normal plant and incinerator operation para meters recorded during the test include:

 incinerator oxygen concentration,

 incinerator combustion temperature;

 pH level of the sc rubber solutions; and

 scrubber solution flow during the test.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report SOURCE TESTING METHODOLOGY

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 3-2 The operating parameters listed on the previous pa ge and the process production rate, in short tons (ST) per day of VCM, were recorded during the testing.

3.2 PROJECT TEAM RESUMES Project Manager - Mr. Glen Capra was the single point of contact for the WESTON Tea m and provided all coordination for W EST ON. Mr. Capra has 20 years of environmental and project management experience, including chem ical, polym er, oil and gas clients, as w ell as service companies. He was re sponsible for coordinating all activities perform ed, working to establish scope, schedule, and budget exp ectations; coordinating the team s performing the projects; and overseeing the technical work performed. He is WESTON’s Air Compliance Program Manager for the Southern Division and has directed over 100 programs involving com pliance testing and reporting.

Field Task Leader – Mr. Cory Foytik has more than 6 year s experience in emissions testing and continuous emission monitor project support. He has project experien ce specific to this scope of work including continuous emissions monitoring compliance, project management, and compliance testing. Mr. Foytik is QSTI accredited for pe rforming continuous emission monitoring sampling methods. Mr. Capra and Mr. Foytik are based in WESTON’s Au stin, TX office.

Field Team Member – Mr. Pat Turner has more than 17 years in emissions testing, field sampling, and on-site laboratory sample recove ry experience. He has project experience specific to this scope of work including proficiency and certificat ion in 40 CFR 60 methods field sam pling, and experienced in laboratory prepar ation and recovery for EP A Reference Method sam pling. Mr. Turner is based in WESTON’s Charleston, South Carolina office.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report SOURCE TESTING METHODOLOGY

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 3-3 3.3 SAMPLING LOCATION PHOTOGRAPHS AND SCHEMATIC A photograph of the sampling locatio n is provided as Figure 3-1. Sa mpling scaffolding was built to allow sampling of the fiberglass stack.

Figure 3-1 Stack PhotographsWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report SOURCE TESTING METHODOLOGY

H:\FORMOSA (02774)\VCM 02774.015.001\19.0 FINAL DELIVERABLES\2011 VCM PLANT EPA ICR EMISSION TEST REPORT.DOC August 2011 3-4 Figure 3-2 Formosa Plastics Point Comfort Schematic Drawing of Incine rator VH-801C (EPN 006C)

23.0-in ID (801C)

Sample Ports

191.0-in (801C) 47.5-inches

~50 feet Incinerato 

### r

Fan Stack Location: Upstream Diameters = 8.3
Downstream Diameters = 2.0
Minimum number of traverse points = 12

Inlet Stream ScrubberWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report



### APPENDIX A SAMPLE CALCULATIONSWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX A SAMPLE CALCULATIONS Incinerator Stack (EPN 006C)

PCDD/PCDF No. 1 8/02/11 Meter Pressure (Pm), in. Hg

Hg O/in.H in. 13.6 H + Pb = Pm 2 

where, Pb = barometric pressure, in. Hg  H = Pressure differential of orifice in. H 2 O
Hgin. 29.935 = HgO/in. Hin. 13.6 O Hin. 1.151 + Hgin. 29.85 = Pm
2 2

Absolute Stack Gas Pressure (Ps), in. Hg

Hg O/in.H in. 13.6 Pg + Pb = Ps 2 where, Pb = barometric pressure, in. Hg Pg = Static Pressure, in. H 2 O
Hgin. 29.84 = HgO/in. Hin. 13.6 .i 17.0 + Hgin. 29.85 = Ps
2 2 OHn



Standard Meter Volume (Vmstd), dscf

Tm Pm x Vm x Y x Hg R/in. 17.64 Vmstd 


where, Y = meter correction factor Vm = meter volume, cf Pm = meter pressure, in. Hg Tm = meter temperature, o R

dscf 98.4 1 = R555.6 Hgin. 29.84x cf 211.078x 0.992x HgR/in. 17.64

 

 VmstdWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX A
Standard Wet Volu me (Vwstd), scf
Vlc x /mLft 0.04707 Vwstd 3
 where, Vlc = volume of H 2 O collected, mL
scf 62.655 = mL 1331.1x /mLft 0.04707 3  Vwstd
Moisture Fraction (Measured), (Bws)

0.24 = dscf 198.4 + scf 62.655 scf 62.655 = Vmstd) + (Vwstd Vwstd = Bws

whe re, Vwstd = standard wet volume, scf Vmstd = standard meter volume, dscf Moisture, % (M%) 24.0 = 100x 0.24 = 100x Bws= % M

wh ere, Bws = moisture fraction, measur ed or at saturation, whichever is lowest Molecular Weight (DRY) (Md), lb/lb-mole ))O % - CO % - (100 (0.28 + )O % x (0.32 + )CO % x (0.44 = Md 22 2 2 mole-lb/lb 29.48 = 8.5)) - 7.1 - (100 (0.28 + 8.5)x (0.32 + 7.1)x (0.44 = Md
Molecular Weight (WET) (Ms), lb/lb-mole (Bws) 18 + Bws) - (1 Md= Ms where, Md = molecular weight (DRY), lb/lb-mole Bws = moisture fraction, dimensionless mole-lb/lb 26.73 = (0.24) 18 + 0.24) - (1 mole-lb/lb 29.48 = Ms

Emissions Results – Run 1 PCDD/PCDF Correct Result to 3% Oxygen

ng/m3 0.413 = 8.5% - 20.9% 17.9% x ng/m3 0.286 = O2) % - (20.9 O2 3% - 20.9 x Result = 3%O2 @result OCDD

### APPENDIX B TEST METHODOLOGY

B.1 V OLUMETRIC F LOW R ATE B.2 O RGANIC C OMPOUNDS B.3 D IOXINS AND F URANSWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B B.1

– VOLUMETRIC FLOW RATE Mass emission rates are calculated by m ultiplying measured target analyte concentrations by calculated volumetric flow rates. Volum etric fl ow rates are calcu lated using measurement data obtained by EPA Reference Methods 1-4.

The ductwork is measured at the sa mple location to the nearest 0.25 in ch using a steel tape measure. Traverse points are selected in accordance with EPA Reference Method 1 on the basis of ductwork dimensions, geometry, and upstream and downstream disturbances. When a sample location does not meet EPA Reference Method 1 criteria, the maximum recommende d number of traverse points is used. Gas Velocity The velocity of the gas stream is measured in accordance with EPA Reference Method 2 by reading the instantaneous velocity pressure with an inclin ed manometer at each traverse point using either a standard “P” type or an “S” type pitot tube. Th e stack pressure is calcul ated from the m easured static pressure of the stack and the ambient barometr ic pressure. The static pressure is measured by using the static side of the pitot tube, and the b arometric pressure is measured using a calibrated aneroid barometer. Magnahelic  gauges with scales of 0 to 5 a nd 0 to 25 inches of water or an inclined manometer with a scale of 0 to 10 in ches of water is used f or velocity pressure measurements. Manometer selection is determined by the velocity pressure of the gas stream . A manometer with a 0 to 0.25 inch sc ale may be used when the velocity pressure of th e gas stream is less than 0.25 inches of water. By convention, any m easured ve locity pressures of less than 0.005 inches of water are recorded and reported as less than 0.005 inches of water. The stack temperature is measured with a ca librated thermocouple and pyrometer.
For low velocity pressure measurements (less than 0.005 inches of water) a hot wire anemometer may be used to measure the velocity of the gas stream. The indi cated ve locity is used without correction when the gas stream is ambient air with a moisture content of less than 65%. The i ndicated velocity is corrected in accordance with pro cedures specified by the manufact urer when t he moisture cont ent exceeds 65% or when the dry gas fraction is something other than ambient air.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B
Gas Composition and Moisture Content The composition of the gas stream is m easured in accord ance with E PA Reference Method 3A instrumental analysis. The O2, CO 2 , and THC monitors used by Weston were operated per manufacturer instructions and in accordance wi th the applicable EPA reference m ethods. The continuous analyzers were calibrated prior to tes ting using appropriately cer tified gas standards. EPA Protocol 1 gas certification docum entation fo r standards used during this test program are included in the Appendix E. Calibr ation results are also documente d in the report appendices with the CEMs data. Table B.1-1 presents the reference method CEMS performance criteria.

Table B.1-1 Reference Method CEMS Performance Criteria

Procedure Performance Criteria THC (M25A) O 2 /CO 2 (M3A) Calibration Error, % of gas value  5  2 System Bias, % of range NA  5 Zero Drift, % of range  3  3 Calibration Drift, % of range  3  3 Interference Response, % of range NA  2 The moisture content of the gas stream is dete rmined using one of the following procedures:

 For sources requiring testing by EPA Reference or Test Methods 5, 8, 12, 13, 17, 23, 26A, 29, 0010, or 0011, moisture is determined by EPA Reference Method 4. At the conclusion of each run the vol ume of condensed moisture in the impi ngers of the sampling train is measured and used to calculate the moisture content of the gas stream.

 For sources with temper atures greater than 212 ° F, the approximation technique described in EPA Re ference Method 4 ma y be us ed with midget impingers to condense moisture before dry gas volume measurement.

 For sources with a te mperature of le ss th an 212 ° F, wet bulb/dry bulb te mperature measurements may be ma de, and the moisture content calculated using va por pressure tables.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B When multiple methods are used for moisture determ inations, the lowest moisture value is used for volumetric flow calculations.
The molecular weight of the gas stream is cal culated using the m easured moisture, oxygen, and carbon dioxide concentrations. The balance of the gas stream is assum ed to be nitrogen. T he volumetric flow is then calcu lated at stack and standard con ditions using the calculated molecular weight, the measured stack tem perature, and measur ed velocity, stack and ba rometric pressures. Standard conditions are 68 °F and 29.92 inches of mercury and 0% moisture.
Data Acquisition and Reporting Data are recorded at the tim e of collection on p rep rinted data sheets. Ca lculations are performed (where possible) with preprogrammed calculators or spreadsheet software. Quality Control Quality control procedures for volumetric flow m easurements involve leak check s of pitot tubes, pitot tube lines and m anometers; periodic analysis of ambient air and duplic ate analysis of source gas samples with the Fyrite analyz er; triplicate analysis with the Ors at analyzer; and periodic calibration checks of thermocouples and pyrometers.

Data transfers are m inimized. Data sheets are checked for co mpleteness and accuracy. Calculations are verifi ed by a second person.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B

B.2 – ORGANI C COMPOUNDS

Method 25A – A four-point linearity test was performed at the beginning of each test day. EPA Protocol 1 Calibration gases contai ning methane were used for these calibrations. The FID analyzer used in this test program is designed to measure hydrocarbons as their carbon equivalent. The instrument THC readings are therefore reported as propane equivalents. Ze ro and span gases were introduced at the probe to establish the calibration curve. Then, the low and mid-range gases were introduced as a QC check. The instrument system response for each of these gases was within ±5% of the calibration gas value. A QC check was pe rformed between each run (inter-run) using zero and mid-range gases. The instrument responses were compared to the pretes t calibration value. No drift exceeded ±3% of span. Method 18 Vinyl Chloride

– A lung system was used to pull a st ack sample into a 10-liter Tedlar flexible bag. The sample was extracted from the st ack at a constant rate. The rate was set rate so that the bag (10L) volume was grea ter than 50% full, but no more th an 70% full at the end of the run. A lung system was used so that th e sample would not contact the pump.
Analysis After the bags were analyzed, one bag was selected for spiking. Vinyl Chloride was spiked at 40%- 60% of the average concentration. The amount r ecovered was used to calc ulate Recovery factor "R". The spiked bag was re-analyzed after an inte rval equal to the duration the original sample was held in that bag before analysis. The spiked ba g must meet 70% < R < 130%; all other runs are then corrected with the recovery factor. Quality Assurance Quality assurance steps completed for the sampling and analysis included:

 A leak check of the bags before use by filli ng with UHP nitrogen and leaving under pressure overnight to check for deflation.

 New bags were used for the sampling.

 The Method requires triplicate injecti ons agreeing ±5% of their mean.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B B.3

– DIOXINS/FURANS The sampling procedures and train is described in EPA Reference Method 23. The sampling train can also be used for semivolatile organics sampling. Sampling Equipment and Procedures The Sampling Train is shown in Figur e B-2. The impinger train is as sembled in the sample recovery area. The pre-cl eaned impingers are assembled with the f irst impi nger being an em pty knockout impinger with a short st em. The pur pose of this i m pinger is to collect the majority of the condensate which forms in the condenser coil and XAD resin module. The next two impingers are standard type Greenberg-Smith impingers, each cont aining 100 mL of HPLC grade wa ter. The fourth impinger is empty and the fifth impinger is ch arged with approximately 700 gram s of indicating silica gel. The glass fiber filter is placed in a filter holder and connect ed to the cond enser coil and XAD resin module. The train components are then transferred to the sampling loca tion and assembled completely.
After the sam pling train is assem ble d and all component s are heated appropriately, a leak check is performed. During sampling, the te mperature of the sorbent module re sin is not to exceed 70 °F. The probe temperature is maintained above 212 °F; t h e filter temperature is co ntrolled at 248 ° F + 25 °F, and the outlet of the silica gel impinger is maintained at less than 68 °F during operation.
The sampling train is leak -checked at the beginning and end of the run and each po rt change. An acceptable leak rate is less than 0.02 Act ual Cu bic Feet per Minute (ACFM) at the highest vacuu m measured plus one inch of Hg or less than 1.5% of the sampling rate.
After a successful pre-test leak check, the train asse mbly is placed in the stack and operated along each of the traverse points fo r each of the two hori zontal traverses. Sampling is performed for a t otal of three hours using a sa mpling rate between 0.5 and 0.75 Standard Cubic Feet per Minute (SCFM) to collect a total sample volume of at least 106 Dry Standard Cubic F eet (DSCF). Samp ling train data are recorded on standard data forms.
The MM5 sampling trains are recovered following t h e scheme presented in Figure B-2. Liquid samples are placed in pre- cleaned amber glass sample containers with Teflon ® liners. The f ilters areWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B placed in pre-cleaned glass petri dishes or amber glass sample containers. The s ample containers for the train fractions are li sted in Table B.3-1.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX BFigure B-1Modified EPA Method Sampling Train for Dioxins, Furans, and Semi-Volatile OrganicsWeston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B
Figure B-2 Sample Recovery Procedures For M23 & Mm5 Sampling Trains

NOZZLE, PROBE LINER,

AND FRONT HALF OF FILTER HOLDER FILTER BACK HALF OF FILTER HOLDER AND CONDENSER

REMOVE AND PLACE IN GLASS PETRI DISH. SEAL PETRI DISH. (FIL)

XAD SORBENT TRAP IMPINGER CONTENTS IMPINGER RINSE

CAP ENDS OF SORBENT TRAP AND STORE ON ICE FOR TRANSPORT TO LABORATORY. (XAD) MEASURE AND RECORD CONTENTS VOLUME OF ALL LIQUID CAUGHT IN

IMPINGERS. SEAL IN SAMPLE BOTTLE AND MARK LIQUID LEVEL. (IMPCON) RINSE IMPINGERS 3X WITH MEOH/MECL 2 . SEAL. RINSE AS SAMPLE

BOTTLE AND MARK LIQUID LEVEL. (IMPR)

TOLUENE RINSE SILICA GEL (MOISTURE CATCH)

RINSE ALL TRAIN COMPONENTS WITH TOLUENE FOR PCDD/PCDF ANALYSIS. (TDL) WEIGH AND RECORD WEIGHT. INDICATE

REGENERATION REQUIRED. RINSE 3X WITH ACETONE/MECL 2 . SEAL. RINSE IN SAMPLE BOTTLE AND MARK LIQUID LEVEL. (BHR RINSE UNTIL CLEAN (3X) WITH ACETONE/MECL 2 . SEAL. RINSE IN SAMPLE BOTTLE AND MARK LIQUID LEVEL. (FHR)Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B Table B.3-1 EPA Method 0010/23 Sample Fractions

Container Code Fraction 1 FHR Methanol/methylene chloride rinse of nozzle, probe, and front half of filter holder. 2 FIL Glass fiber filter. 3 BHR Solvent rinses of back half of filter holder, filter support, condenser coil, and connecting glassware. 4 XAD XAD sorbent module. 5 IMP CON Impingers contents. 6 IMPR Solvent rinse of impingers and connecting glassware. 7 Tol Rinse of all train com ponents with toluene for PCDD/PCDF analysis.
Reagent blank samples are collected as follows:

Reagent Amount Fraction Blank Trains Trip Blanks Methanol Blank HPLC Water 300 mL IMP CO N 1/source 1/trip Methanol/Methylene FHR, BHR Chloride 200 mL IMPR 1/source 1/trip Toluene 200 mL Tol 1/source 1/trip XAD Sorbent Module a N/A ---- 1/source 1/trip Glass Fiber Filter N/A ---- 1/source 1/trip 1

a XAD sorbent module is randomly selected from the on-site XAD modules used for the test program.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B SAMPLE ANALYSIS Semivolatile Organic Compounds The MM5 semi-volatile samples ar e analyzed according to SW-846 Method 8270 and EPA Ref erence Method 23. The metha nol/methylene chloride front half (FH) pr obe rinse is concentrated to about 2 mL using a Kuderna-Danish (KD) apparatus and then combined with the filter in a soxhlet apparatus. A set of 8 Base/Neutral/Acid (BNA) surrogates along with the above labeled standards are spi ked into the soxhlet at 100 m g levels. Th e combined filter and FH rinses are t hen so xhlet-extracted with methylene chloride for 16 hours (Fraction A).
The methanol/methylene chloride back half rinses (BHR) are concentrated to about 2 mL using a KD apparatus and then comb ined with the XAD resi n in a soxhlet apparatus. The eight BNA surrogat es along with the labeled standards are spiked into the soxhlet and the combined XAD and BHR are soxhlet extracted with methylene chloride fo r 16 hours (Fraction B).
The impinger water is spiked with the eight BNA surrogates and labeled stan dards at 100 mg levels and then liquid-liquid extracted with methylene chloride (Fraction C).

Each extract is dried over sodium sulfate, concentrated to a vol um e of 5 m L and cleaned using gel permeation chromatography (GPC).
Extracts are concentrated to approximately 1-5 mL. In ternal standards are added to the sample. A 2 μl 1 aliquot is injected into the GC. The organic compounds are separated by gas chromatography and detected by a high reso lution mass spectrometer.
Data Acquisition and Reduction
Data are recorded at the ti me of collection on prepri nted data sheet s. Calculat ions are performed (where possible) with preprogrammed calculators or spreadsheet software.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B
Quality Control The standard MM5 pre-cleanup requirements include several unique prepara tion steps which ensure that the sampling train components are not contaminated with organi c compounds that may interfere with the analysis. The glasswar e, glass fiber filters, and XAD adso rbing resin are pr e-cleaned using strict protocols.
The glassware is nor mally cleaned as shown in Tabl e B.3-2. Glas sw are is washed in soapy water, rinsed with distilled water, baked, and then rinsed with acetone followed by methylene chloride. Once the glassware is dried, the open ends are sealed with either methylen e chloride-rinsed aluminum foil or Teflon ® tape. Table B.3-2 Organic Glassware Cleaning Procedure (Train Components, Sample Containers, and Laboratory Glassware)

NOTE: USE VITONÔ GLOVES AND AD EQUATE VENTILATION WHEN RINSING WITH SOLVENTS 1. Soak all glassware in hot soapy water (AlconoxÔ). 2. Tap water rinse to remove soap.
3. Deionized H 2 O rinse (X3). a
4. Bake at 450° for 2 hours. b 5. Acetone rinse (X3), (pesticide grade). 6. Methylene chloride (X3), (pesticide grade). 7. Cap glassware with Teflon ® tape or methylene chloride rinsed aluminum foil. 8. Mark cleaned glassware with color-coded identification sticker.

a (X3) = three times. b Step (4) is added to the cleanup procedure to replace the dichromate soak specified in the reference method. It has been demon strated that baking at 450 °F sufficiently removes organic artifacts. It is not used for probe liners and non-glass components of the train that cann ot withstand 450 °F (i.e., Teflon ® -coated filter screen and seals, tweezers, Teflon ® squeeze bottles, nylon probe and nozzle brushes).Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B Non-glass components (such as the Teflon ® filter supports and seals, tweezers, Tefl on ® squeeze bottles, nylon nozzle, and probe br ushes) are cleaned following the same procedure, except no baking is performed. The XAD adso rbent resin and glass fiber filters are pre-cleaned by sepa rate procedures.
The XAD, whi ch is pur chased in 100 gra m amber gl ass containers, is place d in the glass modules under strict labor atory-controlled co nditions. Each lot of XAD resi n is recorded in a laboratory notebook and a control sample is withdrawn for a qua lity assurance analysis. The laboratory archives a sample from each lot for analysis with the field sample as a lab blank.
To prepare the filters, a batch of 50 filters are placed in a soxhlet extraction apparatus and extracted using methylene chloride fo r 16 hours. Afterwards, the filters ar e checked for holes, tears, creases, and discoloration. Acceptable filters are placed in pre-cl eaned containers and labeled by date of extraction and sealed with Teflon ® tape. The remaining equipment preparation includes rout ine checking and cal ibration of the Method 5-type equipment as specified in Method 0 010 and 23.
During one of the runs, an MM5 fiel d blank train is assembled with gl assware that has previously been used for MM5 sampling. This train is charged exactly as the other MM5 trains and left at a sampling location during the test r un. The fi eld blank train is recovered with t he other MM5 train for that run. The sample train resu lts are used t o assess t he level of cont amination that occu rs from handling, charging, recovering, and tran sporting the sampling train.
One sample train blank is prepared for each source. One se t of trip blanks are collected and archived for future examination, if contamination is dete rmined. A la b method blank using the control XAD blank that is wi thheld during the XAD module prepar ation phase is also analyzed.
QC guidelines for MM5 can be foun d in SW-846 Method 0 010, "Modified Method 5 Sampling Train," Section 11. Additional qu ality control considerations are outli ned in EPA Referen ce Method 8270 and 23. Sampling criteria are give n in EPA Reference Method 5.
To further ensure sample integr ity and stability, sm oking is not al lowed in or around the Laboratory Recovery Area, and XAD resin samples are immediatel y stored at or below 4 °C.Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report APPENDIX B Data transfers are mini mized. Fiel d and labor ato ry data sheets are checked for c ompleteness and accuracy. Calculations are ve rified by a second person.

### APPENDIX C FIELD DATA