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| From:      |
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  |Richard Krock <rkrock@vinylinfo.org>                                                                                                    |
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| To:        |
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  |Jodi Howard/RTP/USEPA/US@EPA                                                                                                            |
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| Date:      |
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  |08/26/2009 04:40 PM                                                                                                                     |
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| Subject:   |
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  |VI Questions on EPA PVC MACT Testing Requirements                                                                                       |
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Jodi,

As we discussed today, a number of Vinyl Institute (VI) member companies
have begun to examine the documents relating to the PVC MACT 114
information request.   Per your request, I am submitting the first round
of questions in writing fielded from Vinyl Institute members regarding
testing requirements that I brought up today so that you can respond in
writing after discussing the questions with your colleagues.   The VI
Health, Safety and Environmental committee is scheduled to review all
the 114 request documents for the PVC  MACT via conference call on
September 2, 2009 after which  I expect  more questions will be
submitted to you.  Your offer to conduct a webinar to go over the entire
request in detail with the PVC manufacturers is welcome, and we will let
you know after our September 2 call when we would like to schedule it.
I will instruct the VI members to submit questions specific to their
operation directly to you in writing via your e-mail address.   The
questions we discussed today are listed below along with my notes:

      1.       Re: Enclosure 1, Attachment B, Section 1.3 – Is it
      intended that 30 day CO/THC/CH4 monitoring will be conducted on
      the resin dryer and its ancillary equipment?  You will check with
      others in your organization to clarify if the dryer system will
      indeed be monitored or (as stated in Section 1.2) if mass balance
      of the resin immediately after the stripper to after the dryers to
      estimate emissions may be all that is required for this section of
      the operation.
      2.       Re: Enclosure 1, Attachment B, Section 1.3 – Is the
      30-day period to be operating days or calendar days?   Your
      requirement is 30 operating days.
      3.       Re: Enclosure 1, Attachment B, Section 1.2 – Can you
      clarify what is meant by “integrated samples” in reference to the
      4 grab samples used for the dryer mass balance?  You agreed to
      further research this and clarify more specifically what is
      required.
      4.       Re: Enclosure 1, Attachment B, Section 1.2 – Section 1.2
      begins with “Testing should be conducted on both the inlet and the
      outlet to at least one of the control systems ….”.  Is it
      acceptable to test only one of several control systems such as
      thermal oxidizers and scrubbers?  Your understanding is that as
      long as the control systems are configured similarly and in
      similar service, then only one needs to be tested.  Standby units
      do not need to be tested but they should be included in the survey
      portion.
      5.       Re: Enclosure 1, Attachment B, Table 1.3 – One member’s
      thermal oxidizer outlet duct is too short to meet the criteria
      outlined in the test method for sampling, and because it is
      refractory brick lined, adding a sample port may disrupt its
      integrity and create a safety hazard from HCl corrosion and
      leakage at the point of sampling .  The member believes it can
      sample other safer and more accessible  locations and estimate the
      mass balance between the thermal oxidizer and the scrubber.   You
      believe this falls into the category of alternative testing
      methods and the member should submit detailed drawings and
      explicit alternative sampling protocol including mass balance
      method for your review and comment.  However, you will also review
      this with your colleagues more versed in testing.

The opportunity to clarify the information request is highly
appreciated.   I look forward to receiving your clarification as needed
on the above questions.





*Please note our new contact information*

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 

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