Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

[Comments are indicated in bold and bracketed regarding yellow highlighted areas]

PVC Section 114 Enclosure 1, Attachment B – Page 1

04/03/2014

Draft Summary of Test Procedures, Methods, 

and Reporting Requirements

for Polyvinyl Chloride and Copolymers 

Facility Emission Points

This document provides an overview of approved sampling and analysis methods, target 

reported units of measure, and reporting requirements for polyvinyl chloride and copolymer 

(PVC) production facilities required to conduct emissions testing and provide emission test data 

according to the section 114 letter. The purpose for this testing is to gather data on air pollutant 

emissions from certain emissions points in this source category. [COMMENT RK1: Current

PVC MACT limits apply to the combined-stream fed TO’s at all times. The S114 request 

does not appear to provide for the collection of combined-stream data.

Given that this the third set of process vent data that will be used for this rule, and given 

that not all facilities covered by this rule are submitting data this time around, the Agency 

should provide a bit more information about its data needs to ensure that as much 

consistency as possible is maintained across the data sets.] The document is organized as 

follows:

1.0 Stack Testing Procedures and Methods

2.0 How to Report Data

3.0 How to Submit Data

4.0 Contact Information for Questions on Test Plan and Reporting

1.0 Stack Testing Procedures and Methods

This information collection request includes stack (performance) test data requests for 

several pollutants. If you operate a PVC production facility, then you are required to conduct 

testing as outlined in this document to determine your emissions.

1.1 How to Select Sample Location and Gas Composition Analysis Methods

You must use U.S. EPA Method 1 of Appendix A of part 60 to select the locations and 

number of traverse points for sampling. [COMMENT RK2: In order to perform all of the 

specified methods simultaneously, the stack will need to have at least three (and preferably 

four) orthogonal sampling ports at 90° of each other for isokinetic sampling. 

(Alternatively, two sets of two ports at 90° on different sampling platforms could be used if 

they exist. The ports need to be 3” inside diameter (“ID”) or preferably 4” ID.) Is this 

really the Agency’s intent? There will also need to be one or two stack sampling ports 

available for non-isokinetic sampling for volatile organics (Method 0031), THC (Method 

25A), GC (Method 18), and FTIR (Method 320). It may be possible to use a single 

sampling line for all of these analyses, but this may also cause some problems if the sample 

volume isn’t large enough to support all of these analyzers. Would EPA allow use of the 

single sampling line or can the Agency provide guidance on this problem? The Working 
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Group requests that EPA review and approve in writing or email sampling plans submitted 

by facilities in order to ensure the required tests are performed to EPA’s satisfaction. The 

WG trusts it will receive timely responses on the submitted sampling plans.] See 

http://www.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance 

information.

You must use U.S. EPA Method 3A or 3B of Appendix A of part 60 for analysis of flue 

gas composition, including oxygen concentration. See 

http://www.epa.gov/ttn/emc/methods/method3a.html for Method 3A or 

http://www.epa.gov/ttn/emc/methods/method3b.html for Method 3B information.

1.2 Polyvinyl Chloride and Copolymers Production Test Methods and Reporting

Testing must be conducted on the outlet to [COMMENT RK3: Testing is to be 

conducted at the “outlet to at least one of the control systems.” It appears that this should 

be read to mean that testing is to be conducted at the exhaust stack downstream of the 

thermal oxidizer and scrubber (i.e., exhaust to atmosphere). Is this correct?] at least one of 

the control systems including, but not limited to, a thermal oxidizer and acid gas scrubber (in 

series) used to control emissions from PVC production. Table 1.1 summarizes the required test 

methods for each pollutant [COMMENT RK4: Regarding the sample volumes and run 

times, many are different than what was required in EPA’s August 14, 2009 Enclosure 1 

Attachment B for the PVC S114 Request. As it stands now, if we proceed with the run 

times in this request, it appears that the Agency will be looking at a dataset based on 

different sets of run and sample times. 

Regarding the list of targeted compounds (Tables 1.3 through 1.6): Previous PVC MACT 

and EDC/VCM rule S114 testing did not speciate HAPs in such a manner. This appears to 

create inconsistencies with the data collected in 2009 and 2011. 

The Working Group understands that the individual S114 requests will be tailored for each 

facility to address perceived gaps in the data. As these are expensive tests, we understand 

that EPA will allow companies to rely on previously submitted S114 data. Therefore the 

S114 request for each facility should specifically indicate the data being requested from 

that facility to fill the specific data gap. In addition, if a facility elects to use this S114 

testing to satisfy the compliance test requirement under the PVC MACT, the facility may 

supply additional data beyond the S114 request.], possible alternative methods [COMMENT 

RK5: If a testing company has a directly-connected GC, for example, that provides the 

same method of performance for a given compound as a volatiles train, will EPA allow a 

facility to use that option?], and the target reported units of measure. 

If you would like to use a method not listed in Table 1.1, then please contact the EPA for 

approval of an alternative method. For copies of the recommended U.S. EPA methods and 

additional information, please refer to EPA’s Emission Measurement Center website: 

http://www.epa.gov/ttn/emc/. For copies of the SW-846 methods, please refer to EPA’s SW-846 

Online website: http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm.
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Each test should be comprised of a minimum of three valid runs at each sampling 

location. All pollutant concentrations should be corrected to 3 percent oxygen and should be 

reported on the same moisture basis. The target units of measure are specified in Table 1.1. 

Report the results of each stack test according to the instructions in Section 2.0 of this 

attachment. 30 days of THC monitoring is also required as specified in Section1.3. In addition to 

the emission test data, you must also report the following process information taken during the 

30 day period before [COMMENT RK6: What is the purpose of the 30-day survey before 

the test period? Does the Agency mean the 30 days during the 30-day test period? At what 

frequency should this type of information be provided? The Agency’s CBI instructions 

appear to mirror the more problematic version of the 2009 S114 request. Will EPA 

provide a mechanism to clearly separate CBI information?] , at the time of, and during the 

emissions test [COMMENT RK7: What is the difference between “at the time of, and 

during the emissions test”?]: 

• the type of resin being processed and the resin grade;

• emissions control device(s) in use during the test; 

• control device operating or monitoring parameters (including, as appropriate to the 

control device, flue gas flow rate, pressure drop, scrubber liquor pH, scrubber liquor flow 

rate, sorbent type and sorbent injection rate); and

• process parameters (such as oxygen).

The testing should be conducted while the PVC production [COMMENT RK8: There 

do not seem to be any specific instructions, or required data about what other waste gas 

vents are being vented to a combined control device that has an emission profile that 

includes more than just PVC waste gases. 

a. The Working Group would recommend that process descriptions, 

production rates, and other operational information for the other waste gas streams be 

included in the descriptions. 

b. Is it EPA’s intent that the non-PVC process units operate at maximum 

production capacity and under normal operation? This is not explicitly stated in the 114.] 

process is operating as close as possible to maximum production capacity [COMMENT RK9: 

Is EPA looking for maximum capacity of the process vent control device, worst case HAP 

concentration, or simply maximum amount of resin product produced? Maximum HAP 

may require multiple products running simultaneously with different combinations of 

products. Can EPA confirm that routing process vent gas from a parallel control device 

into the device being tested is acceptable as a means of maximizing operating conditions for 

the device being tested?] and under “normal” operation, that is, not during periods of startup, 

shut down, or malfunction. [COMMENT RK10: Testing requires max rate without SSM. 

This might be tricky for timing with multiple batch reactors. What are normal operations? 

PVC reactors are batch and startups/shutdowns are part of normal operations. The SU/SD 

definition of Part 63 does not address this.

a. Startup means the setting in operation of an affected source or portion of an 

affected source for any purpose.

b. Shutdown means the cessation of operation of an affected source or portion of 

an affected source for any purpose.] A thorough description of the process, including 
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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PVC Section 114 Enclosure 1, Attachment B – Page 4

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production rate(s) and a comparison of those production rates to maximum production capacity

during the entire testing cycle should also be provided. If, during the performance testing, it 

becomes clear that one or more “off specification” or “out of specification” resin [COMMENT 

RK11: The Working Group believes that “off specification” or “out of specification” resin 

should not invalidate a test run. Note that off specification batches are unlikely to affect

TO emissions. On the other hand, we understand that an equipment malfunction 

occurring during the tests would invalidate a sample run – per the rule.] batches will be 

produced, then the testing and process data and any other associated information must still be 

submitted and labeled as an “off spec” test.

In most instances, we are not specifying numerical detection limits; [COMMENT 

RK12: It would appear that the Agency believes the run times and collection volumes are 

sufficient to meet its data quality objectives. The Working Group requests confirmation 

that those facilities that follow the prescribed practices or an EPA-approved alternate 

method have met their obligation for data quality.] instead we have specified testing 

conditions and methods, including test run times and minimum sample volumes when 

appropriate, which we believe will provide sufficient data quality for decision making. We 

remind source owners and testers of the Clean Air Act section 114(a)(1) requirement to provide 

information requested for the development of emissions standards using methods that provide 

data necessary for the decisions. That includes data of quality sufficient to support those 

decisions. For the most part, we can identify test methods and procedures that will satisfy those 

decision making needs (e.g., minimum sampling times). In other cases, we recognize that the 

source owner's or tester's selection of test procedures or equipment could bear significantly on 

the quality of the data. See Attachment C of this enclosure for information regarding guidance 

for calculating and reporting values measured below method detection levels.

We believe that the Clean Air Act is clear that it is incumbent on the source and the tester 

to apply methods and procedures resulting in data quality necessary [COMMENT RK13: In 

light of the possibility for inconsistency and variability, the Working Group requests that

EPA agree to review and approve sampling and testing plans for unlisted HAPs to provide 

assurance to the source that the methods and equipment chosen are going to be accepted 

prior to testing.] for those decisions including providing for the lowest possible detection limits 

considering practical and reasonable limitations. For example, source owners and testers should 

not automatically choose to use low or medium quality equipment for testing (e.g., for cost 

reasons) if high quality equipment is reasonably available. We will review test reports in light of 

this expectation and will be particularly mindful of whether the testing procedures applied are 

representative of the highest reasonably expected capabilities (e.g., comparing reported 

minimum measurement detection levels between tests and testers). If we believe that a source 

owner or tester has failed to meet the requirement of the Act to provide data sufficient decisions, 

we can and will request additional measurements requiring the use of improved testing 

procedures. The enclosed certification statement must be signed by a responsible official (See 

Enclosure 6).
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

[Comments are indicated in bold and bracketed regarding yellow highlighted areas]

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Table 1.1: Summary of Polyvinyl Chloride and Copolymers’ Control System Outlet Emissions 

Measurement Methods and Alternative Methods

Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Vinyl Chloride U.S. EPA Method 18 1

[COMMENT RK14: Method 

18; footnote 1 points to 

dioxin/furan list. Is this 

correct? Footnote 1 is 

repeated for Dioxins/Furans 

in column 1, row 3.] with a 

minimum sample time of 1 

hour per run and a nominal 

detection level of less than 200 

ppbv.

None [COMMENT RK15: 

Vinyl Chloride and Table 1.6 

Target Analytes are required 

to be measured by Method 

18. Method 18 is a Tedlar

bag collection followed by 

GC/FID or ECD or PID or 

other detector procedure. 

Vinyl chloride and 

chloromethane can be done 

by GC/MS using Method 

8260B. Will EPA consider 

Method 8260B as an 

alternative?]

ppbvd @ 3% O2

HCl/Cl2 U.S. EPA Method 26 or 26A. 

Collect a minimum sample 

volume of 2 dscm per run. 

None ppmvd @ 3% O2

Dioxins/Furans1 U.S. EPA Method 23. Collect a 

minimum sample volume of 5 

dscm per run. Use high

resolution GC/MS for the 

analytical finish. 

None ng/dscm @ 3% O2

Speciated HAP listed 

in Table 1.32

SW-846 Method 0031 with 

preparation and analysis by 

SW-846 Methods 5041A

[COMMENT RK16: We 

understand this to mean we 

are to take our sample by 

Method 0031 and analyze by 

Method 5041A. Method 

5041A does not list all of the 

Table 1.3 compounds, namely 

chloroprene and vinylidene 

chloride. Method 0031 does 

list them. Can Method 5041A

still be used for these 

compounds?] and 8260B. 

Combine traps in each run if 

lower detection limit is needed. 

Sample at a rate of 1 L/min, 

unless a slower sampling rate 

will yield detectable levels.

None [COMMENT RK17: 

EPA is requiring the

collection of all volatile HAPs 

in Table 1.3, Table 1.5, and 

Table 1.6 + vinyl chloride via 

multiple methods. A single 

method, such as 8260B is 

available for all these HAPs.

Will EPA allow for a more 

streamlined approach to 

analyzing these HAPs?]

ppmvd @ 3% O2
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Speciated HAP listed 

in Table 1.42

SW-846 Method 0010 with 

preparation and analysis by 

SW-846 Methods 3542

[COMMENT RK18: Method 

3542 says it replaces Method 

0010 and both Methods show 

sampling trains, so this is 

confusing. We understand we 

are to take the sample by 

Method 0010 and analyze by 

instructions in Method 3542. 

Is that correct?] and 8270D. 

Collect a minimum sample 

volume of 3 dscm per run. Use 

high resolution GC/MS for the 

analytical finish. [COMMENT 

RK19: Method 8270D does 

not call for a high resolution 

GC/MS. This appears to be 

an error. Does EPA have 

different guidance for 

Method 8270D?]

None ppmvd @ 3% O2

Speciated HAP listed 

in Table 1.52

U.S. EPA Method 320.

Minimum sample time of 4 

hours per run. All compounds 

must be validated according to 

Section 13.0. [COMMENT 

RK20: “Section 13” is 

referring to Section 13 of 

Method 320, which is the 

method validation section. 

Method 320 is an FTIR 

method. This technique can 

be prone to interference and 

is semi-qualitative/semiquantitative. Some of the 

compounds in Table 1.5 can 

be done via Method 8260 as 

in Table 1.3. Will EPA 

consider allowing Method 

8260 as an alternative?]

None ppmvd @ 3% O2
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Pollutant Required Method

Possible Alternative 

Method

Target Reported 

Units of Measure

Speciated HAP listed 

in Table 1.62

U.S. EPA Method 18.

Minimum sample time of 4 

hours per run. 

None [COMMENT RK21: 

Vinyl chloride and Table 1.6 

target analytes are required 

to be measured by Method 

18. Method 18 is a Tedlar 

bag collection followed by 

GC/FID or ECD or PID or 

other detector procedure. 

Vinyl chloride and 

chloromethane can be done 

by GC/MS using Method 

8260B. Will EPA consider 

Method 8260B as an 

alternative? Will EPA also 

allow hexane to be captured 

under the 8260B run since it 

is the required method in 

Table 10 of the final rule?]

ppmvd @ 3% O2

O2 / CO2 U.S. EPA Method 3A. 

Simultaneous with each 

pollutant test run.

U.S. EPA Method 3B % volume, dry

Moisture U.S. EPA Method 4. 

Simultaneous with each 

pollutant test run.

None % volume

Flowrate U.S. EPA Method 2. 

Simultaneous with each 

pollutant test run.

U.S. EPA Method 2A, 2B, 2C, 

2D, 2F, or 2G, as appropriate.

ascfm and dscfm

1 You must include the results for the individual dioxin/furan congeners as specified in Table 1.2. 2 If any other HAP could be emitted from the process, you must also test for those HAP using US EPA Method 

320, US EPA Method 18 or SW-846 Method 0010, [COMMENT RK22: The Working Group requests that 

this footnote also indicate that alternate methods can be approved by EPA] as applicable. 

Table 1.2 Dioxin/Furan Congeners 

Dioxin/furan congener

2,3,7,8-tetrachlorodibenzo-p-dioxin.

1,2,3,7,8-pentachlorodibenzo-p-dioxin.

1,2,3,4,7,8-hexachlorodibenzo-p-dioxin.

1,2,3,7,8,9-hexachlorodibenzo-p-dioxin.

1,2,3,6,7,8-hexachlorodibenzo-p-dioxin.

1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin.

octachlorodibenzo-p-dioxin.

2,3,7,8-tetrachlorodibenzofuran.

2,3,4,7,8-pentachlorodibenzofuran.
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Dioxin/furan congener

1,2,3,7,8-pentachlorodibenzofuran.

1,2,3,4,7,8-hexachlorodibenzofuran.

1,2,3,6,7,8-hexachlorodibenzofuran.

1,2,3,7,8,9-hexachlorodibenzofuran.

2,3,4,6,7,8-hexachlorodibenzofuran.

1,2,3,4,6,7,8-heptachlorodibenzofuran.

1,2,3,4,7,8,9-heptachlorodibenzofuran.

Octachlorodibenzofuran.

Table 1.3 Target Analytes Using SW-846 Method 0031

Pollutant CAS Number Pollutant CAS Number

Benzene 71432 Methylene chloride 75092

Chloroethane 75003 Toluene 108883

Chloroform 67663 1,1,1-Trichloroethane 71556

Chloroprene 126998 1,1,2-Trichloroethane 79005

1,1-Dichloroethane 75343 Vinylidene chloride 75354

1,2-Dichloroethane 107062

Table 1.4 Target Analytes Using SW-846 Method 0010

Pollutant CAS Number Pollutant CAS Number

Acetophenone 98862 Hydroquinone 123319

Bis(2-ethylhexyl) phthalate 

(DEHP)

117817 Naphthalene 91203

1,4-Dichlorobenzene 106467 Phenol 108952

2,4-Dinitrophenol 51285 1,2,4-Trichlorobenzene 120821

Hexachlorobutadiene 87683 123319

[COMMENT 

RK23: This 

appears to be a 

stray CAS # (for 

hydroquinone) and 

should be deleted.]

Table 1.5 Target Analytes Using US EPA Method 320

Pollutant CAS Number Pollutant CAS Number

Acetaldehyde 75070 Methanol 67561

1,3-Butadiene 106990 1,1,2,2-Tetrachloroethane 79345

Chlorobenzene 108907 2,2,4-Trimethylpentane 540841

Cumene 98828 Vinyl acetate 108054

Ethylbenzene 100414 Vinyl bromide 593602

Ethylene glycol 107211 Xylenes (isomers and mixtures) 1330207

Formaldehyde 50000
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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Table 1.6 Target Analytes Using US EPA Method 18

Pollutant CAS Number Pollutant CAS Number

Chloromethane 74873 n-Hexane 110543

1.3 Total Hydrocarbon 30-Day Monitoring

You must conduct total hydrocarbon (THC) monitoring [COMMENT RK24: For those 

units that use SCR technology, can methane be excluded from THC? Also, will EPA allow 

those point sources that have previously submitted this test information to rely on the 

previous submission for this S114 Request?] continuously for a 30-day period as specified in 

Table 1.7. You must also concurrently record the types and grades of PVC resin [COMMENT 

RK25: Should production information for the other process units venting to the combined

control device be recorded as well?] being produced and the control device temperature. All 

the emissions testing required in Table 1.1 must be conducted during this 30-day monitoring 

period. [COMMENT RK26: For 30 days of THC and O2 sampling, will EPA allow use of a 

THC capable CEMS installation if it better meets the facility’s needs?]

Table 1.7 30-Day THC Monitoring

Pollutant Recommended Method Alternative Method

Target Reported 

Units of Measure

THC U.S. EPA Method 25A 

continuously for 30 days.

Calibrate the measuring 

instrument with propane. The 

low level and high level 

calibration gases (see sections 

7.1.3 and 7.1.5 of Method 25A) 

must bracket the measured 

concentrations or a maximum 

high level calibration gas (see 

section 7.1.5 of Method 25A) of 

10 ppm propane must be used.

None ppmvd as propane @ 

3% O2

O2 U.S. EPA Method 3A

continuously for 30 days. 

U.S. EPA Method 3B % volume, dry
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

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Pollutant Recommended Method Alternative Method

Target Reported 

Units of Measure

Moisture U.S. EPA Method 4 continuously 

for 30 days. [COMMENT 

RK27: Moisture is supposed to 

be run continuously and this 

method requires grab samples. 

This does not make sense. Can 

EPA clarify what is meant 

here? The Working Group 

proposes using the moisture 

measurement from the stack 

test and apply it to the THC 

testing. As an alternative, the 

temperature of the stack gas 

can be monitored and assumed

to be saturated to determine 

the moisture content.]

None % volume

2.0 How to Report Data

The method for reporting the results of testing and monitoring depends upon the tests and 

methods used to complete the testing and monitoring requirements. This section discusses the 

requirements for reporting the collected data.

2.1 Reporting stack test data

For data collected using test methods supported by the EPA’s Electronic Reporting Tool 

(ERT) as listed on the ERT website (see http://www.epa.gov/ttn/chief/ert/index.html), the results 

of the performance test must be submitted in the file format generated through the use of the 

latest version of the ERT existing at the time the source test is conducted. The following test 

methods are supported by the ERT:

• EPA Method 23

• EPA Methods 25/25A

• EPA Methods 26/26A

For data collected using test methods that are not supported by the EPA’s ERT as listed 

on the ERT website, you must submit the results of the performance test in the Emission Test 

Template to CCG-PVC@epa.gov. [COMMENT RK28: Can EPA clarify that it does not 

want the test results reported in a single data file, that it indeed does want part of the test 

results data input into ERT and the remainder submitted on spreadsheets to this website?] 

You must report the results of each test on an appropriately labeled worksheet corresponding to 

the specific tests. After completing the worksheet, you must also submit an electronic copy of 

the emission test report including all raw data (PDF format preferred).

If you claim that some of the results of the performance test being submitted are 

confidential business information (CBI), you must submit the complete file including 

information claimed to be CBI. The submitted materials must be clearly marked as CBI 
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

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PVC Section 114 Enclosure 1, Attachment B – Page 11

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submitted according to Section 3.0 of this Attachment. You must submit a separate copy of the 

file with all CBI data removed. Submit the non-CBI version of the file according to one of the 

options in Section 3.0 of this Attachment.

2.2 Stack test data to be included in the report [COMMENT RK29: Some of the 

information requested was already provided in prior S114 Requests. Will EPA allow the 

facilities to reference the past submittals?]

At a minimum, all performance test reports [COMMENT RK30: Does EPA have a 

template format for the information such as was done for the Wastewater Stripper S114

Request?] must include the following information:

• General identification information for the facility including a mailing address, the actual 

address, the owner or operator or responsible official (where they are applicable) or an 

appropriate representative and an email address for this person, and the appropriate 

Federal Registry System (FRS) number for the facility;

• A brief process description;

• A complete unit description, including a description of feed streams and control devices, 

the appropriate source classification code (SCC), the latitude and longitude of the 

emission point being tested (to five decimal points), and the permitted maximum process 

rate (where applicable); [COMMENT RK31: Is Section 2.2 exclusive to PVC Unit 

data? As this is a stack test for combined process gases to a common control device,

shouldn’t at least a brief process description of the other waste gas streams, as well 

as some of the other process-related bullets be required (e.g., 2nd and 3rd bullets)?]

• Sampling site description; description of sampling and analysis procedures and any 

modifications to standard procedures; quality assurance procedures;

• Any process data and control device monitoring data required in this attachment;

• Raw data sheets for field sampling;

• Raw data sheets for field and laboratory analyses;

• Chain-of-custody documentation;

• Explanation of laboratory data qualifiers;

• Example calculations of all applicable stack gas parameters, emission rates, percent 

reduction rates, and analytical results, as applicable;

• Identification information for the company conducting the performance test including a 

contact person and his/her email address; and

• Any other information required by the test method, a relevant standard, or the 

Administrator.

Make clear, using the “Notes” section of the ERT or Excel spreadsheet, the correlation 

between emissions measurements and process data (e.g., identify Method 29, run 1 for the 

associated process data on the process data details tab of the ERT).
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

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2.3 Flagging data and handling data that is below the detection limit

See Attachment C of this enclosure for information on how to flag data and on how to 

calculate and report values measured below the method detection limit.

3.0 How to Submit Data

You may submit your data in one of three ways as listed below. However, in order to avoid 

duplicate data and to keep all data for a particular facility together, we request that you submit all 

of the data requested from your facility in the same way. To submit your data:

• E-mail an electronic copy of all requested files to CCG-PVC@epa.gov

• Mail a CD or DVD containing an electronic copy of all requested files to the EPA 

address shown in your section 114 letter. If no electronic copy is available, mail a hard 

copy of all requested files to the EPA address shown in your section 114 letter.

• If you are submitting Confidential Business Information (CBI), you must mail a separate 

CD or DVD containing only the CBI portion of your data to the EPA address shown in 

your section 114 letter.

4.0 Contact Information for Questions 

For questions on how to report data using the ERT contact:

Ron Myers 

(919) 541-5407

myers.ron@epa.gov

For questions on the test methods contact: 

Jason DeWees 

919-541-9724 

dewees.jason@epa.gov

Stef Johnson

(919) 541-4790

johnson.steffan@epa.gov

For all other questions contact:

Jodi Howard 
Questions and Comments of the Vinyl Institute PVC MACT Working Group Enclosure 1

April 11, 2014 Attachment B

[Comments are indicated in bold and bracketed regarding yellow highlighted areas]

PVC Section 114 Enclosure 1, Attachment B – Page 13

04/03/2014

919.541.4607

howard.jodi@epa.gov
Enclosure 1

Attachment C

PVC Section 114 Enclosure 1, Attachment C – Page 1

04/03/2014

Guidance for Calculating and Reporting Values Measured Below 

Method Detection Levels

1. Identification of Detection Levels

Identify the status of measured values relative to detection levels on the spreadsheet or in the 

ERT using the following descriptions:

• BDL (below detection level) – all analytical values used to calculate and report an instack emissions value are less than the laboratory’s reported detection level(s); 

• DLL (detection level limited) – at least one but not all values used to calculate and report 

an in-stack emissions value are less than the laboratory’s reported detection level(s); or

• ADL (above detection level) – all analytical values used to calculate and report an instack emissions value are greater than the laboratory’s reported detection level(s).

2. Reporting and Calculating Method Detection Limits

For reporting and calculating individual test run data:

• You must use the method specified approach for calculation and determination of the 

method detection limit (MDL). If the method does not specify the approach and 

calculation of the MDL, determine the MDL as follows:

o For air sampling and analysis methods, you must determine the MDL in 

accordance with the procedures specified in Section 15 of Method 301 (located in 

Appendix A of 40 CFR part 63).

o For water sampling and analysis, you must determine the MDL in accordance 

with the procedures specified in Appendix B of 40 CFR part 136. 

• For analytical data reported from the laboratory as above the MDL, include the ADL flag 

in the Notes line of the Excel spreadsheet template or in the Comments line in the ERT.

• For analytical data reported from the laboratory as “nondetect” or “below detection 

level;”

o Include a brief description of the procedures used to determine the analytical 

detection and in-stack detection levels:

 In the Notes line of Excel spreadsheet template; or

 In the Comments line of Lab Data tab in the Run Data Details in the ERT.

o Describe these procedures completely in the full test report including the 

measurements made, the standards used, and the statistical procedures applied.

o Calculate the in-stack emissions rate for any analytical result reported as below 

detection level using the relevant MDL, sampling volumes and other relevant run 

specific parameters (such as oxygen or flowrate). The reported value must 

assume that the analyte is present at the full MDL value. 

o Report the calculated emissions concentration or rate result: 

 As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line; or 

 As a numerical value in the ERT with the appropriate flag in the 

Comments line.
Enclosure 1

Attachment C

PVC Section 114 Enclosure 1, Attachment C – Page 2

04/03/2014

o Report as numerical values (i.e., no brackets or < symbol) any analytical data 

measured above the MDL, including any data between the MDL and a laboratoryspecific reporting or quantification level (i.e., flag as ADL).

o Apply these reporting and calculation procedures to measurements made with 

Method 23:

 Report data in the ERT for each of the D/F congeners measured with 

Method 23 below the detection level as [< detection level];

 Do not report emissions as zero, as described in the method.

• For pollutant measurements composed of multiple components or fractions (e.g., Hg and 

other metals sampling trains) when the result for the value for any component is 

measured below the MDL:

o Calculate in-stack emissions rate or concentrations as outlined above for each 

component or fraction; 

o Sum the measured values and/or calculated values (using the MDL as outlined 

above) for all of the components or fractions; and

o Report the sum of all components or fractions:

 As a bracketed “less than” detection level value (e.g., [<0.0105]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line; or 

 As a numerical value in the ERT with the appropriate flag in the 

Comments line.

 If all components or fractions are BDL, the appropriate flag is BDL. If 

any component or fraction is ADL, the appropriate flag is DLL.

o In addition to reporting the sum of the components or fractions, report the 

individual component or fraction values for each run if the Excel spreadsheet 

template or ERT format allows.

o If the Excel spreadsheet template or ERT format does not allow reporting of the 

individual components or factions (i.e., the format allows reporting only a single 

sum value):

 For the Excel spreadsheet template, next to the sum reported as above 

report in the Notes line the appropriate flag along with the values for the 

measured or MDL value for each component or fraction as used in the 

calculations (e.g., 0.036, [<0.069], 1.239, [<0.945] for a four fraction 

sample)

 For the ERT, next to the sum reported as above, report on the Comments

line the appropriate flag and the measured or MDL value for each 

component or fraction as used in the calculations (e.g., 0.036, [<0.069], 

1.239, [<0.945] for a four fraction sample)

• For measurements conducted using instrumental test methods (e.g., Methods 3A, 6C, 7E, 

10, 25A):

o Record gaseous concentration values as measured including negative values and 

flag as ADL; do not report as BDL

o Calculate and report in-stack emissions rates using these measured values

o Include relevant information relative to calibration gas values or other technical 

qualifiers for measured values in Comments line in the ERT or Notes line of the 

Excel spreadsheet.
Enclosure 1

Attachment C

PVC Section 114 Enclosure 1, Attachment C – Page 3

04/03/2014

• For reporting and calculating average emissions rate or concentration for a test when 

some results are reported as BDL:

o Sum all of the test run values including those indicated as BDL or DLL as 

numerical values

o Calculate the average emissions rate or concentration (e.g., divide the sum by 3 

for a three-run test)

o Report the average emissions rate or concentration average:

 As a bracketed “less than” detection level value (e.g., [<20.06]) in the 

Excel spreadsheet template and include the appropriate flag in the Note 

line

 As a numerical value in the ERT and include the appropriate flag in the 

relevant Comments line

 If all test run values are BDL, the appropriate flag is BDL. If any test run 

value is ADL or DLL, the appropriate flag is DLL.