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

www.vinylinfo.org ●www.vinylindesign.com

August 25, 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 – Process Flow Diagrams

Dear Ms. Howard:

Following-up on the July 21, 2014, Vinyl Institute (“VI”) discussions with Ms. Penny 

Lassiter and Mr. Andrew Bouchard, we herein propose on behalf of our PVC MACT 

Copolymer Subgroup,

1 a more streamlined and manageable method of addressing 

certain process flow diagram (PFD) details sought by the Agency’s April 1, 2014 Clean 

Air Act Section 114 Information Collection Request (hereinafter, “S114 Request”). 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). 

Specifically, Table 2 of Tab H in Excel workbook titled “2014 PVC 114 Resin Sampling”

provided with the S114 Request requires a list of all pressure relief devices (PRDs), 

open ended valves and lines (OEVLs), and sample connection points (SCPs) in a

PVCPU. The Copolymer Subgroup completed this list in their facility responses. 

However, as discussed during our July 21, 2014 conference call, identifying the 

locations of each of these items on a process flow diagram is impractical due to the 

significant number of these points in a PVCPU. A typical PVCPU may have over 100 

PRDs, over 1,000 OEVLs, and dozens of SCPs. There simply is not enough room on a 

PFD to depict the location of each of these points, which typically are depicted on piping 

and instrumentation diagrams (P&IDs). The Agency’s S114 Request understandably 

directs Subgroup members not to submit P&IDs as these contain significant amounts of 

 

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

Corporation, and Lubrizol Corporation.
Draft for Comment Only - VI PVC MACT Copolymers Subgroup Proposal for Process Flow Diagrams in 

response to EPA S114 Request for Resins and Process Wastewater, dated April 1, 2014

Page 2 of 3

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

www.vinylinfo.org www.vinylindesign.com

confidential business information. In addition, there are so many covered points that 

typical PVCPUs could have 150 to 200 P&IDs in order to provide this level of detail. 

During the July 21, 2014 call, Agency staff expressed the willingness to consider an 

alternative to illustrating the location of each individual point on the PFD, although EPA 

continues to seek an understanding of the locations within the PVCPU for these points. 

As an alternative, Copolymer Subgroup members propose to submit PFDs that identify 

the locations of PRDs, OEVLs, and SCPs at a typical PVCPU, and provide an actual 

count for each type of point in the process sections illustrated in the PFD, an example of 

which is provided as Attachment A. This approach would allow for the graphical 

augmentation of the individual PRD, OEVL and SCP listing provided in Table 2 of Tab H 

in the Excel workbook, without the need for hundreds of drawings. 

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

streamline the 114 Request for resins and process wastewater. As discussed during 

our July 21, 2014 conference call, the responses to the 114 Request which were due by 

July 31, 2014 included the Tab H Table 2 list. Subgroup members also submitted the 

PFD for their PVCPUs, but without the requested graphical indication of individual

PRDs, OEVLs, and SCPs pending EPA’s approval of this proposal. The Subgroup 

members very much appreciate a prompt reply to this proposal. Additionally, unless 

directed otherwise, the PVC MACT Working Group plans to use this same approach for 

responses to EPA’s May 15, 2014 Section 114 Request for Process Vents, since EPA 

has requested the same type of information within that request.

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
Draft for Comment Only - VI PVC MACT Copolymers Subgroup Proposal for Process Flow Diagrams in 

response to EPA S114 Request for Resins and Process Wastewater, dated April 1, 2014

Page 3 of 3

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

www.vinylinfo.org www.vinylindesign.com

Vinyl Institute PVC MACT Working Group

Attachment:

Attachment A: Generic Process Flow Diagram with typical locations of PRDs, OEVLs, and SCPs