Comment submitted by Jean-Cyril Walker, Keller and Heckman LLP on behalf of The Vinyl Institute, PVC MACT Working Group

On behalf of the Vinyl Institute PVC MACT Working Group, the attached letter respectfully request an extension of 45 additional days to comment on the Proposed National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production, 76 Fed. Reg. 29,528 (May 20, 2011), Docket ID No. EPA–HQ–OAR–2002–0037. An extension is warranted because: • The proposed MACT floor limits are the keystone of the Agency’s proposal. Unfortunately, limits proposed for certain critical emission points appear to have been based on a sampling method that is inconsistent with the method proposed for demonstrating compliance. The Working Group must analyze EPA’s extensive databases and other appropriate data and must propose correct floor limits because these limits are crucial to responding to EPA’s individual requests for information and comments on many aspects of the proposal; • Technical analysis spreadsheets were not made available for review in the rulemaking docket until two weeks after publication of the proposed rule. Other important documents appear to be missing from the docket; • There are a limited number of industry experts and qualified employees available to analyze the data and answer EPA’s questions accurately. This small group must also work on survey and stack testing responses to EPA’s Clean Air Act Section 114 Request for manufacturers of ethylene dichloride (“EDC”) and vinyl chloride monomer (“VCM”), issued on March 16, 2011, with completion of all sampling and submission of responsive data by August 31, 2011; and • The amount of time requested is not unreasonable, given the amount of work that still needs to be done. Such an extension is fully within the Agency’s discretion and is consistent with settled notions of administrative due process and relevant provisions of the Settlement Agreement that set the schedule for this rulemaking. See Attached File.