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 l etter. 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 . T he 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 shoul d 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 p roduction 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 se lect 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 f or 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 th ese 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 c an the Agency provide guidance on this problem? The WorkingQuestions 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 2 04/03/2014 Group request s t hat 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://w ww.epa.gov/ttn/emc/methods/method1.html for a copy of the method and guidance information.

Y ou must use U.S. EPA Method 3A or 3B of Appendix A of p art 60 f or 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 atmospher e). 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 RK 4 : 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 A gency will be looking at a data set based on different set s 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 m anner. 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

s upply additional data beyond the S114 request. ]

, possible alternative methods [ COMMENT
RK 5 : If a testing company has a directly

- connected GC, for example, that provide s 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 [Comments are indicated in bold and bracketed regarding yellow highlighted areas]

PVC Section 114 Enclosure 1, Attachment B

– Page 3 04/03/2014 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 ar e specified in Table 1.1

. Report the results of each stack test according t o 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 RK 6 : 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 RK 7 : What is the difference between “at the time of, and during the e mission s 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, pressur e 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 RK 8 : 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 p rocess descriptions, prod uction 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 explicitl y stated in the 114

. ]

process is operating as close as possible to maximum production capacity [ COMMENT RK 9 : Is EPA looking for maximum capacity of the process vent control device, worst case HAP concentration, or simply maximum amount of resin product pr oduced? 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 maximiz ing operating conditions for the device being tested? ] and under “normal” operation , that is, not during periods of startup

, shut down, or malfunction. [ COMMENT RK 10 : Testing requires max rate w ithout 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 set ting 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 , includin gQuestions 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 4 04/03/2014 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 spec ification ” or “out of spe cification” resin [ COMMENT
RK 11 : T he Working Group believes that “off specification” or “out of specification” resin should not invalidate a test run

. Note that o ff spec ification batches are unlikely to affect TO emissions. On the other hand, w e understand that an equipment malfunction

occurr ing during the tests w ould invalidate a sample run

– per the rule.] batches will be produ ced

, 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, w e are not specifying numerical detection limits ; [ COMMENT
RK 12 : 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 obligat ion 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 te sters 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 dec isions. 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 equipmen t 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 l evels

.

We believe that the Clean Air Act is clear that it i s incumbent on the source and the tester to apply methods and procedures resulting in data quality necessary [ COMMENT RK 13 : In light of the possibility for inconsistency and variability, the Working Group requests that EPA agree to review and approve sampl ing and testing plan s 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 practi cal 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 repo rts 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 certi fication 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]

PVC Section 114 Enclosure 1, Attachment B

– Page 5 04/03/2014 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 RK 14 : Method 18; footnote 1 points to dioxin/furan list. Is this correct? Footnote 1 is repeated for Dioxins/Furans in c olumn 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 RK 15 : 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 ? ] pp b vd @ 3% O 2

HCl / Cl 2 U.S. EPA Method 26 or 26A

. Collect a minimum sample volume of 2 ds cm per run. None ppmvd @ 3% O 2

Dioxins/ Furans 1 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% O 2

Speciated HAP listed in Table 1. 3 2 SW

- 846 Method 0031 with preparation and analysis by SW

- 846 Methods 5041A [COMMENT RK 16 : 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 chlo roprene and vinylidene chloride. Method 0031 does list them. Can Method 5041A still be use d 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 y ield detectable levels. None [ COMMENT RK 17 : EPA is requiring the collect ion of all v olatile 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

. W ill EPA allow for a more streamline d approach to analyzing these HAPs? ] ppmvd @ 3% O 2Questions 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 6 04/03/2014 Pollutant Required Method Possible Alternative Method Target Reported Units of Measure Speciated HAP listed in Table 1. 4 2 SW

- 846 Method 0010 with preparation and analysis by SW

- 846 Methods 3542 [COMMENT RK 18 : Method 3542 says it replaces Method 0010 and both M ethods 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. I s that correct? ] and 8270D. Collect a minimum sample volume of 3 ds cm per run

. Use high resolution GC/MS for the analytical finish. [ COMMENT
RK 19 : Method 8270D does not call for a high resolution GC/MS

. This appears to be an error. Does EPA have different guidance for
M eth od 8270D? ] None ppmvd @ 3% O 2

Speciated HAP listed in Table 1. 5 2 U.S. EPA Method 320

. Minimum s ampl e time of 4 hours per run. All compounds must be validated according to Section 13.0. [ COMMENT
RK 20 : “Section 13” is referring to S ection 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/semi

quantitative. Some of the compounds in Table 1.5 can be done via Method 8260 as in Ta ble 1.3. Will EPA consider allowing M ethod 8260 as an alternative? ] None ppmvd @ 3% O 2Questions 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 7 04/03/2014 Pollutant Required Method Possible Alternative Method Target Reported Units of Measure Speciated HAP listed in Table 1. 6 2 U.S. EPA Method 18.
M inimum sample time of 4 hours per run. None [ COMMENT RK 21 : Vinyl c hloride and Table 1.6
t arget a nalytes 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 a n alternative? Will EPA also allow h exane to be captured under the 8260B run since it is the required method in Table 10 of the final rule? ] ppmvd @ 3% O 2

O 2 / CO 2 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 dscf m

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 th ose HAP using US EPA Method

320, US EPA Method 18 or SW

- 846 Method 0010

, [ COMM ENT RK 22 : 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

- tetrachlorod ibenzofuran.

2,3,4,7,8

- pentachlorodibenzofuran.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 8 04/03/2014 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
RK 23 : This appears to be a stray CAS # (for
h ydroquinone ) 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 50000Questions 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 9 04/03/2014 Table 1. 6 Target Analytes Using US EPA Method 18

Pollutant CAS Number Pollutant CAS Number
Chloromethane 74873 n

- Hexane 110543

1 .3 Total H ydrocarbon 30

- Day Monitoring

Y ou must conduct total hydrocarbon ( T HC ) monitoring [ COMMENT RK 24 : 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
RK 25 : 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. A ll the emission s testing required in Table 1. 1 must be conducted during this 30

- day monitoring period. [ COMMENT RK 26 : For 30 days of THC and O2 sampling, will EPA allow use of a THC capable CEMS installation if it better meet s 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 pr opane @ 3% O 2

O 2 U.S. EPA Method 3A continuously for 30 days. U.S. EPA Method 3B % volume, dryQuestions 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 10 04/03/2014 Pollutant Recommended Method Alternative Method Target Reported Units of Measure
Moisture U.S. EPA Method 4 continuously for 30 days. [ COMMENT
RK 27 : 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

propose s using the moisture measurement from the stack
test an d apply it to the THC testing. As an alternative, the temperature of the stack gas can be monitor ed and assume d 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 depend s up on the tests and methods used to complete the test ing 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)

, t he results of the performance test must be submitted in the file format generated through the use of the latest version of the ERT exist ing 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 websi te, you must submit the results of the performance test in the Emission Test Template to CCG

- PVC@epa.gov

. [COMMENT RK 28 : 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 s ubmit 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 fil e including information claimed to be CBI. The submitted materials must be clearly marked as CBIQuestions 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 11 04/03/2014 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 th e 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 RK 29 : Some of the information requested was already provided in prior S 114 R equests . Will EPA allow the facilities to reference the past submittals ? ]

At a minimum, a ll performance test reports [ COMMENT RK 30 : Does EPA have a template format for the information such as was done for the Wastewater Stripper S 114 R equest ? ] 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 RK 31 : Is Section 2.2 exclusive to PVC Unit
data? As this is a stack t est for combined process gas es to a common control device ,

s houldn’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 o f 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 an d 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 in formation 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 April 11, 2014 Attachment B [Comments are indicated in bold and bracketed regarding yellow highlighted areas]

PVC Section 114 Enclosure 1, Attachment B

– Page 12 04/03/2014 2 .3 Flagging data and handling data that is below the d etection 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 l imit

.

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 s ection 114 letter. If no electronic copy is availa ble, mail a hard copy of all requested files to the EPA address shown in your s ection 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 addr ess shown in

your s ection 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 HowardQuestions 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.govEnclosure 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 i n

stack 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 in

stack emissions value are greater than the laboratory’s reported detection level(s).

2. Reporting and Calculating Method Detection Limits

For reporting and c alculating 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 F or 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 F or water sampling and analysis , you must determine the MDL in accordance

w ith the procedures specified in Appendix B of 40 CFR part 13 6

.

• For analytical data reported from the laboratory as above the MDL, include the ADL flag in the Not es 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 re port including the measurements made, the standards used, and the statistical procedures applied.

o Calculate the in

- stack emissions rat e 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 valu e.

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 ap propriate 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 laboratory

specific reporting or quantifi cation level (i.e., fl ag 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 o r 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, r eport 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 su m 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 measureme nts 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 mea sured 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.