 "Borrelli,                                                 
             Frank"                                                     
             <Frank_Borrelli@                                        To 
             americanchemistr         Greg Nizich/RTP/USEPA/US@EPA      
             y.com>                                                  cc 
                                      <akinsk@ggc.com>,                 
             12/21/2007 03:31         <barry_h._christensen@oxy.com>,   
             PM                       <david.a.labelle@saint-gobain.com 
                                      >, "de la Cruz, Peter"            
                                      <delacruz@khlaw.com>,             
                                      <dyopak@teknorapex.com>,          
                                      "Givonetti, Raymond"              
                                      <ray_givonetti@oxy.com>,          
                                      <jbell@shin-tech.com>, "John      
                                      Yonge" <JYonge@shin-tech.com>,    
                                      <mbachynsky@fpcusa.com>,          
                                      "Sheridan, Kevin"                 
                                      <SheridanKevin@westlakechemical.c 
                                      om>, "Sistrunk, Otis J. (PED)"    
                                      <Otis.Sistrunk@polyone.com>,      
                                      "Tinsley, Wendell"                
                                      <wtinsley@westlakechemical.com>,  
                                      "TOM BERGER" <Berger@khlaw.com>,  
                                      <Walker@khlaw.com>,               
                                      <Yves.Blanchet@polyone.com>       
                                                                Subject 
                                      VI PVC MACT Submittal             
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        
                                                                        





Dear Greg,

As discussed at our meeting, enclosed please find four documents.  The
first is an updated list of PVC production facilities, their nameplate
capacities and current operators based on data from CMAI.  I have also
included generic process flow sheets that we intend to enhance as we
develop the additional information on HAPs associated with the PVC
process.  We think that the flow sheets accurately describe the boundary
of the PVC process as they were part of the docket on the original
NESHAP back in the 1970’s.

The third document is a list of potential HAPs that may be associated
with PVC production.  Substances are listed based on responses to a
survey of VI member companies.  Please note that we have included
substances in the list even if they were reported by only one facility.
In addition, we listed materials without regard to the amount involved
or potential for emissions.  Our goal was to define the universe of
potential HAPs that might fall under the PVC MACT rule with the
understanding that both the need for inclusion in the rule or the need
to develop a surrogacy analysis would come at a later date.  The
inclusion of a substance on this list does not reflect any agreement by
the VI or its members that the substance merits regulation under the PVC
MACT.  We have not included vinyl chloride monomer on the list because
we understand that the agency will certainly include that HAP in the
regulation.  We have attempted to identify the possible source and noted
expected fate of these HAPS following the polymerization step of the PVC
process.   A number of these HAPs are identified as VCM impurities.
These HAPS normally exist at trace levels in commercial monomer grade
vinyl chloride. They remain in the vinyl chloride monomer following the
purification steps in a vinyl chloride process as a result of having
similar physical properties, (volatility and solubility), as vinyl
chloride but normally exist at part per million (ppm) levels.  In some
cases, certain HAPs would undergo free radical polymerization similarly
to the vinyl chloride and become part of the PVC polymer molecule.  In
other cases they may remain and concentrate in the recovered vinyl
chloride until they enter the vinyl chloride process vent gas control
system.   I have also included a vinyl chloride specification sheet that
provides expected maximum levels of these impurities in normal
commercial grade vinyl chloride.  Actual levels are expected to be much
lower.

We had looked into you concerns on compounding operations and offer the
following.   Under the Miscellaneous Organic NESHAP (Part 63 Subpart
FFFF), EPA determined at 40 CFR 63.2435(a), (b) and (c), that a Unit
which is located at, or is part of, a major source of hazardous air
pollutants (HAP) engaged in compounding purchased plastic resin is
exempt from the MACT Standard.  This is due to the minimal potential for
emissions from such an operation.  For the same reason, EPA determined
that a Unit which is located at, or is part of, a major source of HAPs,
engaged in compounding its own resin is also exempt from the MACT
Standard, as long as the compounding operation does not involve
processing with HAP solvent or the intended purpose of the operation is
to remove residual HAP monomer.

After you have an opportunity to review this information, we would like
to discuss the next steps, which we believe would involve the
quantification of potential HAPS and information regarding surrogacy.
If you have any immediate questions, please do not hesitate to contact
us.   As you know I will be retiring at year end and in the interim ask
that you contact   Peter de la Cruz of Keller and Heckman and Mary
Bachynsky of Formosa Plastics regarding this program.  It has been a
pleasure working with you, good luck with your efforts and have a
wonderful holiday season.

Regards
Frank Borrelli

Mary P. Bachynsky
Formosa Plastics Corp. U.S. A.
9 Peach Tree Hill Road
Livingston, New Jersey  07039
Phone: 973-716-7342   Cell: 862-485-5542
mbachynsky@fpcusa.com
mailto:mbachynsky@fpcusa.com>




Peter L. de la Cruz
Partner Keller and Heckman


1001 G Street, N.W., Suite 500 West | Washington, D.C. 20001
Tel: 202.434.4141 | fax 202.434.4646 | delacruz@khlaw.com
(See attached file: VI PVC MACT Submittal 2007-12-21.pdf)