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. 02774.015.001 
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 

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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 2012 
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 

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iv 

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 Emission Test Results ............................................................................. 2-1

Table 2-2 VCM Plant Incinerator – EPN 006C Summary 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 Schematic Drawing of Incinerator VH-801C (EPN 

006C) .................................................................................................................................... 3-4
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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/m3 Milligrams per cubic meter 

NELAC National Environmental Laboratory Accreditation Council 

O2 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. 
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1. INTRODUCTION 

Weston Solutions, Inc (WESTON ) was r etained by Form osa Plastics 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, Texas. The purpose of the testing was to supply 

requested information for the Environm ental Protection Agency (EPA) Vinyl Chloride Monomer 

and Ethylene Dichloride Production Information Request. 

WESTON performed the em ission testing during 2-4 August 2011. G eneral facility and testing 

information, including individuals 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 Coordinator 
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 INTRODUCTION 

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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 coordinated the testing with faci lity operations and served as 

WESTON's technical contact throughout the effort. 

The National Environmental La boratory Accreditation Council (NELAC) accredits WESTON’s 

emission testing practice and industr ial hygiene la boratory. The stipula tion associated with this 

accrediting authority precedes the table of contents of this report. 
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2. RESULTS AND DISCUSSION 

Table 2-1 presents a summary of t he mean emission 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% O2 as propane 

1.05 U.S. EPA Method 25A 

Vinyl Chloride, ppbvd @ 3% O2 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% O2 

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 

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Table 2-2 provides a deta iled summary of the em ission results. Any differences between the 

calculated results presented in the appendices and the 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 

CO2 Concentration, % 7.1 7.4 6.2 6.7 

O2 Concentration, % 8.5 8.4 10.3 9.4 

Stack flow rate, x 103 dscfm 4.59 4.94 4.85 4.79 

Process Data 

Production Rate, VCM short tons 2313 2306 2308 2309 

Scrubber Flow, gpm 149 149 149 149 

Scrubber pH 8.55 8.56 8.60 8.57 

Combustion Temperature oF 1951 1978 1898 1942 

Waste gas valve flow setting 45% 45% 45% 45% 

Plant O2 reading 7.76 7.77 7.86 7.80 
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 RESULTS AND DISCUSSION 

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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) NDa < 0.22 < 0.22 < 0.22 

Corrected ppbv-dry @ 3% O2 -- < 440 < 440 < 440 

mg/m3 @ 3% O2 -- < 1.143 < 1.143 < 1.143 

O2 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% O2 1.0 0.7 1.4 1.05 

O2 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 oF 1833 1873 1899 1868 

Waste gas valve flow setting 40 40 46 42 

Plant O2 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 result 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. 
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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 m3 

Total Hydrocarbons 25A B.2 E 

Equipment calibrations will be maintained on file 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 oval of chlorinated com pounds. 

Normal plant and incinerator operation parameters recorded during the test include: 

 incinerator oxygen concentration, 

 incinerator combustion temperature; 

 pH level of the scrubber solutions; and 

 scrubber solution flow during the test. 
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SOURCE TESTING METHODOLOGY 

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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 ESTON. Mr. Capra has 20 years of environmental and project 

management experience, including chem ical, polymer, 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 Austin, TX office. 

Field Team Member – Mr. Pat Turner has more than 17 years in emissions testing, field sampling, 

and on-site laboratory sample recovery 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. 
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SOURCE TESTING METHODOLOGY 

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3-3

3.3 SAMPLING LOCATION PHOTOGRAPHS AND SCHEMATIC 

A photograph of the sampling location is provided as Figure 3-1. Sampling scaffolding was built to 

allow sampling of the fiberglass stack. 

Figure 3-1 

Stack Photographs 
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

SOURCE TESTING METHODOLOGY 

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Figure 3-2 

Formosa Plastics Point Comfort 

Schematic Drawing of Incinerator VH-801C (EPN 006C)

23.0-in ID (801C) 

Sample Ports 

 191.0-in (801C) 

47.5-inches 

~50 feet Incinerator 

Fan 

Stack Location: 

Upstream Diameters = 8.3 

Downstream Diameters = 2.0 

Minimum number of traverse 

points = 12 

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

 

APPENDIX A 

SAMPLE CALCULATIONS

Appendix - 1
Weston 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. H2O 

 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. H2O 

 Hgin. 29.84 = HgO/in. Hin. 13.6

.i 17.0 + Hgin. 29.85 = Ps

2

 2OHn

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  Vmstd 

Appendix - 2
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX A 

Standard Wet Volume (Vwstd), scf

Vlc x /mLft 0.04707 Vwstd 3 

where, Vlc = volume of H2O collected, mL 

scf 62.655 = mL 1331.1x /mLft 0.04707 3 Vwstd 

Moisture Fraction (Measured), (Bws) 

0.24 = 

scf 62.655 dscf 198.4 + 

scf 62.655

 = 

Vmstd) + (Vwstd

Vwstd Bws = 

 whe re, Vwstd = standard wet volume, scf

 Vmstd = standard meter volume, dscf 

Moisture, % (M%) 

M 24.0 = 100x 0.24 = 100x Bws= %

 wh ere, Bws = moisture fraction, measured 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 2 2 22

Md mole-lb/lb 29.48 = 8.5)) - 7.1 - (100 (0.28 + 8.5)x (0.32 + 7.1)x (0.44 = 

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 

Ms mole-lb/lb 26.73 = (0.24) 18 + 0.24) - (1 mole-lb/lb 29.48 = 

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

ng/m3 0.413 = 20.9% 8.5% - 

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

 

Appendix - 3
APPENDIX B 

TEST METHODOLOGY 

B.1 VOLUMETRIC FLOW RATE

B.2 ORGANIC COMPOUNDS

B.3 DIOXINS AND FURANS

Appendix - 4
Weston 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 flow rates are calcu lated using measurement data 

obtained by EPA Reference Methods 1-4. 

The ductwork is measured at the sample location to the nearest 0.25 inch 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 recommended 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 inclined 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 barometric 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 inches 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 the gas stream is 

less than 0.25 inches of water. By convention, any m easured velocity 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 calibrated 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 velocity 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. 

Appendix - 5
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 for standards used during this test program are 

included in the Appendix E. Calibr ation results are also documented 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) 

O2/CO2 

(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 determined 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 impingers of the sampling train is 

measured and used to calculate the moisture content of the gas stream. 

 For sources with temperatures 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 than 212 ° F, wet bulb/dry bulb te mperature 

measurements may be ma de, and the moisture content calculated using va por pressure 

tables. 

Appendix - 6
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B 

When multiple methods are used for moisture determinations, 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 reprinted data sheets. Ca lculations are performed 

(where possible) with preprogrammed calculators or spreadsheet software. 

Quality Control 

Quality control procedures for volumetric flow measurements 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 verified by a second person. 

Appendix - 7
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B 

B.2 – ORGANIC COMPOUNDS 

Method 25A – A four-point linearity test was performed at the beginning of each test day. EPA 

Protocol 1 Calibration gases containing 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. Zero 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 performed between each run (inter-run) using zero 

and mid-range gases. The instrument responses were compared to the pretest calibration value. No 

drift exceeded ±3% of span. 

Method 18 Vinyl Chloride – A lung system was used to pull a stack sample into a 10-liter Tedlar 

flexible bag. The sample was extracted from the stack at a constant rate. The rate was set rate so 

that the bag (10L) volume was greater than 50% full, but no more than 70% full at the end of the 

run. A lung system was used so that the 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 recovered was used to calculate Recovery factor 

"R". The spiked bag was re-analyzed after an interval equal to the duration the original sample was 

held in that bag before analysis. The spiked bag 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 filling with UHP nitrogen and leaving under pressure 

overnight to check for deflation. 

 New bags were used for the sampling. 

 The Method requires triplicate injections agreeing ±5% of their mean. 

Appendix - 8
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 Figure B-2. The impinger train is assembled in the sample recovery 

area. The pre-cl eaned impingers are assembled with the f irst impinger being an em pty knockout 

impinger with a short st em. The pur pose of this i mpinger 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 containing 100 mL of HPLC grade water. The fourth impinger is 

empty and the fifth impinger is charged with approximately 700 grams of indicating silica gel. The 

glass fiber filter is placed in a filter holder and connected to the condenser coil and XAD resin module. 

The train components are then transferred to the sampling location and assembled completely. 

After the sam pling train is assem bled and all component s are heated appropriately, a leak check is 

performed. During sampling, the temperature of the sorbent module resin is not to exceed 70 °F. The 

probe temperature is maintained above 212 °F; t he filter temperature is controlled 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 Cubic 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 assembly is placed in the stack and operated along each 

of the traverse points for 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 Feet (DSCF). Sampling train data 

are recorded on standard data forms. 

The MM5 sampling trains are recovered following t he scheme presented in Figure B-2. Liquid 

samples are placed in pre-cleaned amber glass sample containers with Teflon® liners. The f ilters are 

Appendix - 9
Weston 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 listed in Table B.3-1. 

Appendix - 10
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B Figure B-1 Modified EPA Method Sampling Train for Dioxins, Furans, and Semi-Volatile Organics 

Appendix - 11
Weston 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/MECL2. 

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/MECL2.

SEAL. RINSE IN 

SAMPLE BOTTLE

AND MARK LIQUID

LEVEL. (BHR

RINSE UNTIL CLEAN (3X)

WITH ACETONE/MECL2.

SEAL. RINSE IN SAMPLE

BOTTLE AND MARK

LIQUID LEVEL.

(FHR)

Appendix - 12
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 CON 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 Modulea 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. 

Appendix - 13
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B 

SAMPLE ANALYSIS 

Semivolatile Organic Compounds 

The MM5 semi-volatile samples are 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 soxhlet-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 for 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 ume of 5 m L and cleaned using gel 

permeation chromatography (GPC). 

Extracts are concentrated to approximately 1-5 mL. Internal 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 resolution mass spectrometer. 

Data Acquisition and Reduction 

Data are recorded at the ti me of collection on prepri nted data sheets. Calculat ions are performed 

(where possible) with preprogrammed calculators or spreadsheet software. 

Appendix - 14
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B 

Quality Control 

The standard MM5 pre-cleanup requirements include several unique preparation steps which ensure 

that the sampling train components are not contaminated with organic compounds that may interfere 

with the analysis. The glasswar e, glass fiber filters, and XAD adsorbing resin are pr e-cleaned using 

strict protocols. 

The glassware is nor mally cleaned as shown in Tabl e B.3-2. Glas sware 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 methylene 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 ADEQUATE VENTILATION WHEN RINSING 

WITH SOLVENTS 

1. Soak all glassware in hot soapy water (AlconoxÔ). 

2. Tap water rinse to remove soap. 

3. Deionized H2O 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 demonstrated that baking at 

450 °F sufficiently removes organic artifacts. It is not used for probe liners and non-glass components of the train that cannot withstand 450 °F (i.e., 

Teflon®-coated filter screen and seals, tweezers, Teflon® squeeze bottles, nylon probe and nozzle brushes). 

Appendix - 15
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 adsorbent resin and glass fiber filters are pre-cleaned by separate procedures. 

The XAD, whi ch is pur chased in 100 gra m amber glass containers, is place d in the glass modules 

under strict labor atory-controlled conditions. Each lot of XAD resi n is recorded in a laboratory 

notebook and a control sample is withdrawn for a quality 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 for 16 hours. Afterwards, the filters are checked for holes, tears, creases, and 

discoloration. Acceptable filters are placed in pre-cleaned containers and labeled by date of extraction 

and sealed with Teflon® tape. 

The remaining equipment preparation includes routine checking and cal ibration of the Method 5-type 

equipment as specified in Method 0010 and 23. 

During one of the runs, an MM5 field blank train is assembled with glassware 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 transporting the sampling train. 

One sample train blank is prepared for each source. One set of trip blanks are collected and archived 

for future examination, if contamination is determined. A la b method blank using the control XAD 

blank that is withheld during the XAD module preparation phase is also analyzed. 

QC guidelines for MM5 can be found in SW-846 Method 0010, "Modified Method 5 Sampling Train," 

Section 11. Additional quality control considerations are outlined in EPA Reference Method 8270 and 

23. Sampling criteria are given in EPA Reference Method 5. 

To further ensure sample integrity and stability, sm oking is not al lowed in or around the Laboratory 

Recovery Area, and XAD resin samples are immediately stored at or below 4 °C. 

Appendix - 16
Weston Solutions, Inc. – 2011 VCM Plant EPA ICR Emission Test Report 

 APPENDIX B 

Data transfers are mini mized. Fiel d and labor atory data sheets are checked for c ompleteness and 

accuracy. Calculations are verified by a second person. 

Appendix - 17
APPENDIX C 

FIELD DATA 

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