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 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 Resear ch 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 Subg roup , 1 several questions concerning the Agency’s April 1, 2014 Clean Air Act S ection 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 Pollutant s 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 t he following documents, collectively re ferred to as “The 114 Request” :

• “ MA XIMUM 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 Corpora tion

.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 F ax (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 Subg roup appreciate EPA’s efforts to address our v arious questions and comments about The 114 Request for r esins and process w astewater

. 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.

S incerely,

Richard P. Krock Technical Director
e
- mail: rkrock@vinylinfo.org phone: 571

- 970

- 3392 cell: 571

- 2 16

- 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 Subg roup

Attachments:

Attachment 1 : “ Questions on EPA S114 Request for PVC Resin and Copolym ers and Process Wastewater, Submitted by Vinyl Institute PVC MACT Copolymers Subgroup, May 16, 2014

.