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 Testing- 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 other 

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 final 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 possibility 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 

resubmitted 

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 the 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, places 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 

stack 
test 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 constraints. 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 support 

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, please 

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. OxyVinyls, 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

E143-01

Research Triangle Park, NC 27711

(919) 541-4607

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