We determined that you used the original PVC survey forms (parts 1 and
2) to complete the data request instead of the revised forms that were
posted on November 10, 2009.  Please take a look at the changes from the
original PVC survey forms to the revised forms and let me know if what
you submitted reflected the changes on the revised forms.

Thanks.

Below is a summary of the revisions that were made to the survey forms.

Also attached:

1.  The first set of forms that were posted:

SURVEYPart1_[Company]_[Facility]_[ProcessUnitID].xls

SURVEYPart2_[Company]_[Facility]_[ProcessUnitID]_[CampaignNumber].xls

2.  The revised set that were posted:

SURVEYPart1_[Company]_[Facility]_[ProcessUnitID]_rev111009.xls

SURVEYPart2_(Company)_(Facility)_(ProcessUnitID)_(CampaignNumber)_rev111
009.xls

3.  A separate set of the forms that has the revisions highlighted in
red.  Form tabs that had a change are colored red as is any text that
was revised.  Note that these files are NOT password protected or
protected in any way:

"SURVEYPart1_REVISIONS_IN_RED.xls"

"SURVEYPart2_REVISIONS_IN_RED.xls"

Summary of Revisions Made From First Set of Posted Spreadsheets to the
Spreadsheets Now Posted:

SURVEYPart1

Form B-1:  Changed "intrinsic viscosity" to "inherent viscosity".  

The submitted forms from GGC Aberdeen listed inherent viscosity on Form
B-1.

Form C-1-c:  Corrected the Liquid Loading Rate from "L/m3" to "gpm" (Did
you submit your data in gpm?)

The worksheet appears to be set up for continuous flow, trayed stripping
columns.  However, the facility utilizes batch wastewater strippers;
therefore no liquid loading rate was entered into the worksheet and the
change in units has no affect on the submitted survey.

Form D:  Changed "Does the heat exchange system cool process fluids that
contain HAP?" to "Does the heat exchange system heat or cool process
fluids that contain HAP or VOC?".

On the submitted survey our reply was “Yes”.  With the rewording of
this item the answer is still “Yes”.

Form J:  Corrected the reference from Form G-1 to Form I.

None of the changes listed on Form I were from new source review
requirements.  Most changes were part of company motivated process
improvements.

SURVEYPart2

Form K-1-a:  Changed flow rate units from "scfm" to "dscfm" (cell E16).
(Did you submit your data in dscfm?)

No, the data submitted was total scfm not converted to nor measured on a
dry basis.

Form K-1-b:  Changed units from ppmv to allow users to select "ppmvd @
3% O2", "ng/dscm @ 3% O2" or "ug/dscm @ 3% O2".  (What format did you
use?)

Answers were submitted as ppm.

Form K-1-c:  Added a "Basis for Emissions Values" column for each HAP
instead of only one column for all HAP.

This form required the creation of additional worksheets.  The basis for
emission values for each HAP listed on Worksheet K-1-ca is a model
created for Title V permitting activities.  The other K-1-c worksheets
list only VCM, the basis for which is the residual VCM concentration of
resin leaving the stripping column (or reactor used as a stripper) and
conservatively assuming all VCM is then emitted through the various
emission points located between the stripping operation and rail car
loading (EPs 15-34, 37-46).

Form K-2-a:  Added a "Basis for Flow Rate Value" column for each Process
Stream ID instead of only one column for all Process Stream IDs at the
end.  Added text at the top of the Form to clarify that "This Form
should be completed for streams of ALL phases, except gas/vapor
streams."

The basis for each stream is listed separately in the last column.  The
basis was “measured” for streams that have flow meters and
“calculated” for others.  The form includes all streams, excluding
vapor and gas streams.

Form K-2-b:  Removed "Units" columns and the option to select "ppmv" or
"ppmw"--consolidated with 'Concentration" column.  (Did you submit your
data in ppmv or ppmw?)

No data was submitted on this Form.  This worksheet requests
concentration data for streams downstream of the stripping operations. 
As was discussed in the original coverletter, the facility measures the
residual VCM concentration of the resin leaving the stripping
operations.  However, the facility does not currently analyze the water
portion of the slurry for pollutants.  Without such information, the
calculation of the concentration of VCM in the stream itself is not
possible.  The sampling event required as a component of this survey
will, however, provide analytical results describing the concentration
of VCM, as well as those of the other identified pollutants contained in
the approved sampling plan, in both the liquid and solid phases of the
slurry in a number of these streams.

Form K-3-b:  Removed "Units" columns and consolidated with
"Concentration" column.

Data was submitted as ppmw, parts per million by weight.  

Form L:  Changed "Concentration at Equipment Opening" units to "ppmvd @
3% O2".  (Did you submit your data in ppmvd @3% O2?)

No, the data is not submitted in ppmvd @3% O2.  Data in that format is
not available.

Form M:  Changed "Concentration Immediately Prior to Removal From
Equipment and Before Being Mixed With Other Materials or Fluids (ppm)"
to "Concentration in Resin or Resin Slurry Immediately Prior to Removal
From Equipment and Before Being Mixed With Other Materials or Fluids
(ppmw)" (Cell C18).  (Did you submit your data in ppmw?)

The approved sampling plan contains an “off-spec pile” section that
details the efforts Georgia Gulf will take during the upcoming sampling
event to quantify the emissions related to this resin.

Form N:  Changed "Concentration (ppm)" to "Concentration (ppmw)"   (Did
you submit your data in ppmw?)

Yes, data submitted is in ppmw units.

Form O:  Changed "Number of turnovers per campaign" to "Number of
turnovers."  Changed "Concentration (ppm)" to "Concentration (ppmvd @ 3%
O2)".  Added a column for "Total Emissions (pounds)".  (Did you submit
your data in ppmvd @3% O2?)

We have no equipment that falls into this category, this sheet is marked
NA for not applicable.  No data was entered.

