a. Clean Air Act: Formosa, as a polyvinyl chloride plant emitting more than ten tons of vinyl chloride per year, is subject to the PVC MACT. 40 C.F.R. Section 63.211(a). See Annual Emission Statement to the State of Delaware. Attachment 4. Formosa is also required to meet the standards of 40 C.F.R. Part 61, Subpart F Section National Emission Standard for Vinyl Chloride (Vinyl Chloride NESHAP). 40 C.F.R. Section 63.214(a). Moreover, where the Vinyl Chloride NESHAP references 40 C.F.R. Part 61, Subpart V Section National Emission Standard for Equipment Leaks (Fugitive Emission Sources), an existing source must comply with either the provisions of 40 C.F.R. Part 63, Subpart UU Section National Emission Standards for Equipment Leaks - Control Level 2 Standards, or the provisions of 40 C.F.R. Part 61, Subpart V. Pursuant to 40 C.F.R. ?? 63.215(a), all provisions of 40 C.F.R. Part 61, Subpart A Section General Provision apply to the PVC MACT.
1. CAA-Test Method: Formosa operates its non-bulk resin reactors as strippers in conjunction with a vinyl chloride recovery system choosing to comply with the vinyl chloride emission standard as provided under 40 C.F.R. Section 61.64(f). Attachment 5. Formosa is required to use Method 107 to determine vinyl chloride emissions when a stripping operation is used to attain the emissions limit in 40 C.F.R. Section 61.64(f). 40 C.F.R. Section 61.67(g)(3). EPA inspectors observed the plant operator obtain a sample of Batch 549, F-39