MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Colin Hayes, ERG

DATE: April 12, 2010

SUBJECT: Summary of September 2, 2009 Meeting and Visit to The Dow Chemical 

Company, Texas City, TX

1.0 Introduction

On September 2, 2009, EPA visited the Dow Chemical Company, Texas City, TX facility 

for a meeting with plant personnel and a tour of the PVC production facility. This meeting was 

conducted to support EPA’s effort to develop national hazardous air pollutant emission standards 

for the Polyvinyl Chloride (PVC) and Copolymers Production source category.

2.0 Date and Location

September 2, 2009

8:00 AM

The Dow Chemical Company/Union Carbide Corporation

Texas City, TX

3.0 Attendees

Jodi Howard US EPA

Colin Hayes ERG

Sal Romito The Dow Chemical Company

Russell Wozniak The Dow Chemical Company

Harland Beadle URS
Memorandum

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4.0 Summary of Meeting

Following general introductions, Dow representatives gave a presentation on the solution 

vinyl resin (SVR) process at the Texas City site. Main points from the presentation and other 

items discussed are outlined below:

Process flow diagram (see attached).

SVR process is the only PVC plant on site.

Solvent exchange process; uses IPA and H2O.

Mostly water emissions in solvent recovery system.

Vents are treated via carbon beds.

Solvent tanks vent to scrubber.

There is a flare on-site: reactor vents, monomer storage, resin precipitation and

washing; shared: syngas flare/steam-assisted.

Silos are closed – air flows to carbon beds.

Continuous process.

Fluidized bed dryers vent to carbon beds.

Annual emissions inventory for 2007 and other emissions data was previously 

forwarded to Greg Nizitch (EPA).

Ten (10) reactors – acetone wash reactors.

Three (3) production lines with 2 or 3 reactors per line. There is a dedicated resin 

stripper on each production line.

Each production campaign lasts about one month.

Reactors are opened only for maintenance.

Four (4) dryers.

The solution plant is a unique process; continuous, uses resin precipitation.

End products include can coatings, blister packs, ink jet (inks), other coatings.

Resin is a small volume, specialty product.

The plant type is capital intensive and energy intensive.

Some companies in China may be exploring similar process, but likely as a batch

process.

LDAR – Texas Reg 5.
Memorandum

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Following the presentation, there was a walking tour of the SVR process. Following the 

tour, the following additional items were discussed in wrap-up:

The main contact for the Midland facility is Lori Christiano.

Midland has recent testing data for their process.

Dow asked EPA if recent testing data can be used instead of the required testing. 

EPA responded that it would prefer to have new testing data that is being required 

under the section 114 request.

Midland has 3 production lines; part or the process is subject to the MON, part 

subject to the PVC MACT.

Dow is not a member of the Vinyl Institute (VI).

EPA indicated that it may do a webinar with the industry.

EPA requested that if product is still being produced by October 9th, then the 

Texas City facility should submit a testing plan.

EPA requested that when production has stopped that a letter be sent to EPA 

stating the current status of the plant.

EPA asked Dow if the State of Texas has a permit rescission process and asked to 

be copied on any permit rescission documents. Dow stated this would not happen 

for a while.

Dow stated that two separate letters were previously sent to EPA; with the second 

towards the end of December.

Dow has not decided if they will complete the survey for Texas City. There is a 

lot of people movement and it will take 3-4 weeks to get the information together.

EPA reiterated that there are multiple lawsuits going on and there are concerns 

over dioxin emissions.

EPA asked that a test plan be submitted as soon as possible and stated that EPA 

will turn those around as quickly as possible.

ERG answered a few specific questions that Dow had regarding completing the 

section 114 survey forms.

The meeting concluded at approximately 11:00 AM.