May 15,2014
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RESEARCH TRIANGLE PARK, NC 27711
Mr. Barry Christenson
Air Quality Manager
Occidental Chemical Corporation (OxyVinyls, LP)
Post Office Box 809050
Dallas, Texas 75380-9050
Dear Mr. Christenson:
OFFICE OF
AIR QUALITY PLANNING
AND STANDARDS
Pursuant to section 114 of the Clean Air Act (CAA), the U.S. Environmental Protection Agency
(EPA) is collecting information to characterize hazardous air pollutant emissions from process
vents at polyvinyl chloride and copolymer (PVC) production facilities.
PVC production is subject to the provisions of 40 CFR Part 63, Subparts HHHHHHH and
DDDDDD. The purpose ofthis request is to gather process vent data and other information
necessary to inform our reconsideration of these emissions standards.
We request the following testing be performed for your PVC production facility, OxyVinyls, LP
- Deer Park, TX as specifically listed below and discussed in Attachment B of Enclosure 1
(tables 1.1 and 1.6) to this letter:
Pollutants to be tested
HCl I TOHAP
We are also requesting other information regarding PVC production at your facility and are
providing the survey response forms in Microsoft® Excel spreadsheet format. Test results that
are collected using test methods that are supported by EPA's Electronic Reporting Tool (ERT)
must be submitted using the ERT. We are also providing PVC process vent response forms in
Microsoft® Excel spreadsheet format for test methods that are not supported by the ERT. Please
see Enclosure 1, Attachment B for specific ERT submission instructions.
The requested testing is designed to collect information on emissions and other relevant aspects
of PVC process vents. Enclosure 1 contains a summary of the information we are requesting.
Internet Address (URL) • http://www.epa.gov
RecyclediRecyclable • Printed w~h Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer)
Supplemental information is contained in the following enclosures:
Description Enclosure#
Maximum Achievable Control Technology Enclosure 1
(MACT) Standards Development Information
Collection Request
Section 114 Authority and CBI claims Enclosure 2
CBI emissions data disclosure Enclosure 3
Designation of ERG as authorized representative Enclosure 4
Policies and Procedures for handling CBI Enclosure 5
Certification Statement Enclosure 6
2014 PVC 114 Process Vent Testing Workbook NIA
2014 PVC 114 Process Vent Testing Workbook N/A
Example
The testing request is designed to collect emissions information, which by law cannot be
confidential information. You are required to return all requested information on or before
November 17,2014.
Please e-mail the completed non-confidential survey and testing workbook response to:
CCG-PVC@epa.gov
There is a small amount of information requested in the survey concerning production and
production capacity which you may seek to claim as confidential. If you are submitting
confidential business information (CBI) as described in Enclosure 3, you must mail a
separate CD-ROM or DVD-ROM disk containing only the CBI portion of your data to EPA.
Clearly mark the disk with the words "Confidential Business Information" and send via U.S.
Postal Service Express Mail, registered mail, or private courier to:
Jodi Howard
U.S. Environmental Protection Agency
OAQPS/SPPD/RCG (Mail Code E143-01)
109 T.W. Alexander Drive
Research Triangle Park, NC 27711
DO NOT ELECTRON! CALLY TRANSMIT CONFIDENTIAL BUSINESS INFORMATION
TO EPA.
If you would like to use the required Section 114 testing to satisfy the initial compliance
requirements for process vents in the PVC rules (40 CFR part 63, subparts DDDDDD and
HHHHHHH), please contact Cynthia Kaleri at Region 6, at (214) 665-6772 or
kaleri.cynthia@epa.gov to discuss the requirements prior to beginning the 114 testing.
Be aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment as explained in Section 113 of the Clean Air Act (42 USC
§7413). Failure to comply fully with this request for information may subject you to an
enforcement action. We may use any information submitted in response to this request in an
administrative, civil, or criminal action.
If you have questions regarding this request, please contact Ms. Jodi Howard, Refining and
Chemicals Group, at (919) 541-4607 or howard.jodi@epa.gov.
Thank you for your assistance in this effort.
6 Enclosures
Sincerely,
/)~/'/. 7<,t / ~&~ ~ ( .v Petm~ assiter
Group Leader
Refining and Chemicals Group
Sector Policies and Programs Division
cc: Steve Thompson, USEPA, Region 6, Air, Toxics & Inspections Coordination Branch,
w/Enclosure 1 only
Michael Beatty, TX Commission on Environmental Quality, w/Enclosure 1 only