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 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 Cod e: 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 J uly 21, 2014, Vinyl Institute (“VI”) discussions with Ms. Penny Lassiter and Mr. Andrew Bouchard, we herein propose o n behalf of our PVC MACT Copolymer Subg roup , 1 a more streamlined and manageable method of addressing certain process flow diagram (PFD) det ails sought by the Agency’s April 1, 2014 Clean Air Act S ection 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 Emissio n 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 Req uest 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 Jul y 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 direct s 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 fo r Process Flow Diagrams in

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

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. In addition, there are so many covered points that typical PVCPU s could have 150 to 200 P&IDs in order to provide this lev e l 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 Subgrou p 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 augment ation 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 a nd its PVC MACT Copolymers Subg roup appreciate EPA’s efforts to streamline t he 114 Request for r esins and process w astewater

. As discussed during

our July 21 , 2014 conference call, the responses to the 114 Reque st which were due by July 31, 2014 included the Tab H Table 2 list. Subgroup members also submitted the PFD for their PVCPU s, 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 W orking G roup 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.

S incerely,

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, Kel ler and Heckman Vinyl Institute PVC MACT Copolymers Subg roupDraft for Comment Only

- VI PVC MACT Copolymers Subgroup Proposal fo r Process Flow Diagrams in

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

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Attachment :

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