From: Barry_H._Christensen@oxy.com [mailto:Barry_H._Christensen@oxy.com]

Sent: Friday, April 11, 2014 4:29 PM

To: Howard, Jodi

Cc: Chris_Krishna@oxy.com; Deanna_Strain@oxy.com; John_Westendorf@oxy.com

Subject: Draft PVC Section 114 Process Vent Testin g

- Comments

Ms Howard,

From the conversation that we had on Monday April 7, 2014, I understand

that

you are collecting this additional data to fill in some gaps in the

combined

process vent category and intend to gather new emissions data two ot her

locations. Since this is the third CAA 114 request to sample our Deer

Park

PVC/LaPorte site, we are disappointed, particularly since we are

currently

engaged in planning to conduct our compliance sampling to comply with the

deadlines in the fin al rule which is effective on April 17, 2015.

When we spoke, you indicated that since we did a second test in response

to

the August 2011 CAA 114 request, your final CAA 114 request to us would

be

paired down to testing for THC and TOH, with a possi bility for HCL/CL2.

Our

existing HCL/CL2 data was done for a TCEQ compliance test of both of our

units

and was included in our test plan for the August 21, 2014 request. It was

approved in your series of Emails from 11/19/09 to 11/23/09. I

resubmitt ed

our

HCL/CL2 data in the 2/07/14 mail below, since the rule background

documents

failed to reference it and you had indicated you lacked

HCL/Cl2 data for the combined vent category.

Given the planning for this additional test overlaps with th e period

necessary to plan and conduct our compliance tests, it is vitally

important

that EPA clarify that data gathered in this third CAA 114 request can be

utilized to satisfy the performance testing requirements of 63.11945. To

do

otherwise, pla ces an additional financial burden on the affected

companies,

such as ours. Based on review of this draft sampling plan with our

sampling

contractor, we estimate it will more than double the cost of our planned

compliance tests for this location.

You also indicated that you will clarify the procedure for submitting

stacktest plans for approval. We suggest this step is necessary to ensure that

the

data EPA receives is consistently gathered and conforms to the required

methods and quality cons traints. Of course, as you know, prior

notifications

and approval is a requirement for MACT compliance tests.

Enclosed are comments and questions that we have on your Draft CAA 114

request. In addition, we are a member of the Vinyl Institute and sup port

comments they are offering, which may include some of our comments. We

look

forward to a future discussion on these items during the call scheduled

with

the Vinyl Institute.

Should you have questions or require additional information, ple ase

contact me

at 972 404

- 3209 or by this Email address. I would appreciate you letting

me

know you received this, as it has large attachments.

Barry Christensen

Manager Air Quality

Occidental Chemical Corp.

barry_h._christensen@oxy.com<mailto: barry_h._christensen@oxy.com>

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.

From: Howard, Jodi [mailto:Howard.Jodi@epa.gov]

Sent: Thursday, April 03, 2014 2:19 PM

To: Christensen, Barry H.

Cc: Lassiter, Penny; Bouchard, Andrew; Kataoka, Mark; Mia, Marcia; Huser,

Jennifer

Subject: Draft PVC Section 114 Process Vent Testing

Barry,

Attached to this email is the draft Section 114 Process Vent Test Memo

for you

review. OxyVin yls, LP will be required to perform this testing at the

following facilities:

OxyVinyls, LP

- Deer Park, TX

Please submit your comments to me by Friday, April 11, 2014.

Thanks.Jodi L. Howard

US EPA

OAR/OAQPS/SPPD/RCG

E14 3

- 01

Research Triangle Park, NC 27711

(919) 541

- 4607

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