  From:       Richard Krock <rkrock@vinylinfo.org>                                                                               
                                                                                                                                 
  To:         Jodi Howard/RTP/USEPA/US@EPA                                                                                       
                                                                                                                                 
  Date:       09/24/2010 03:52 PM                                                                                                
                                                                                                                                 
  Subject:    VI Letter to EPA on Seasonality of PVC Production                                                                  
                                                                                                                                 





Dear Ms. Howard,

The VI has made prior comments on the potential bias that seasonal
production rates may introduce into the PVC MACT rulemaking.  The
attached letter documents some of those periods of seasonal production
for your consideration.  Please do not hesitate to contact me with any
questions regarding the information or its impact on the survey
responses.  Thank you for the opportunity to submit this document for
the PVC rule development.

Regards,



Richard Krock
Technical Director

The Vinyl Institute
1737 King Street Suite 390
Alexandria, VA 22314
Direct:  571.970.3392
Mobile:  571.216.4474
Fax:  571.970.3271
Email:  rkrock@vinylinfo.org 
http://www.vinylinfo.org 
http://www.vinylindesign.com(See attached file: VI Letter to EPA on
Resin Seasonality 09-24-10.pdf)