1737 King Street, Suite 390 ● Alexandria, VA 22314 ●(571) 970-3359● Fax (571) 970-3271

www.vinylinfo.org ●www.vinylindesign.com

May 16, 2014

Sent via Electronic Mail and FedEx 

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

Research Triangle Park, NC 27711

Howard.Jodi@epa.gov

RE: Polyvinyl Chloride and Copolymers Resins and Process Wastewater Section 

114 Sampling and Analysis, and Information Request

Dear Ms. Howard:

This letter presents, on behalf of the Vinyl Institute PVC MACT Copolymer Subgroup,

1

several questions concerning the Agency’s April 1, 2014 Clean Air Act Section 114 

Information Collection Request, which was issued to the Subgroup members. The 

Section 114 request follows the Agency’s grant of several petitions to reconsider certain 

aspects of the National Emission Standards for Hazardous Air Pollutants for Polyvinyl 

Chloride and Copolymers Production; Final Rule, 77 Fed. Reg. 22,848 (April 17, 2012). 

The Information collection requires sampling and analysis of resins and process 

wastewater in addition to other process, operation, and facility information from certain 

facilities owned by the Subgroup members. The enclosed comments seek clarification 

and request questions on the following documents, collectively referred to as “The 114 

Request”:

• “MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARDS 

DEVELOPMENT INFORMATION COLLECTION REQUEST”, Enclosure 1, 

April 1, 2014;

• “BACKGROUND FOR POLYVINYL CHLORIDE AND COPOLYMERS 

PRODUCTION MACT STANDARDS DEVELOPMENT INFORMATION 

COLLECTION REQUEST”, Enclosure 1 Attachment A, Draft, April 1, 2014;

 1 The PVC MACT Copolymer Subgroup includes Vinyl Institute members Formosa Plastics Corporation, U.S.A., Wacker Chemical 

Corporation, and Lubrizol Corporation.
VI PVC MACT Copolymers Subgroup Questions on S114 Request for Resins and Process Wastewater, 

dated April 1, 2014

Page 2 of 2

The Vinyl Institute, 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

• “Summary of Test Procedures, Methods, And Reporting Requirements For 

Resin and Process Wastewater Sampling and Analysis at Polyvinyl 

Chloride and Copolymer (PVC) Facilities” Enclosure 1 Attachment B, 

April 1, 2014

The Vinyl Institute and its PVC MACT Copolymers Subgroup appreciate EPA’s efforts to 

address our various questions and comments about The 114 Request for resins and 

process wastewater. As the responses to the 114 Request are due July 31, 2014 and 

Subgroup members are preparing for their sampling and analysis, we would very much 

appreciate a prompt reply to this inquiry.

Please do not hesitate to contact me with any questions. 

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

phone: 571-970-3392

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 Subgroup

Attachments:

Attachment 1: “Questions on EPA S114 Request for PVC Resin and Copolymers and Process 

Wastewater, Submitted by Vinyl Institute PVC MACT Copolymers Subgroup, May 16, 2014.