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 C hemical 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 Chlo ride (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

R ussell Wozniak The Dow Chemical Company

Harland Beadle URSMemorandum

p. 2 of 3

4.0 Summary of Meeting

Following general i ntroductions , Dow representatives gave a presentation on the solution vinyl resin (SVR) process at the Texas City site. Main points from the presentatio n and other

items discussed are outlined below:

Process flow diagram (see attached )

. SVR process is the o nly PVC plant on site

. Solvent exchange process; uses IPA and H 2 O

.

Most ly water emissions in solvent recovery system

.
Vents are treated via carbon bed s

.
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 e missions 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

stri pper on each production line

. Each production campaign lasts about one month

.

Reactors are opened only for maintenance

. Four ( 4 ) dryers

.

The s olu tion plant is a unique process; continuo us, uses resin precipitation

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

.

Resin is a s mall 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

p. 3 of 3

Fol lowing 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 C h ristiano

.

Midland has recent testing data for their pr ocess

.
Dow asked EPA if recent testing data can be used i nstead 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 9 th , then the Texas City facili ty 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 r escission 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 i s a lot of people movement and it will take 3

- 4 weeks to get the info rmation together

. EPA reiterated that there are multiple lawsuits going on and there are concerns over dioxin emissions

.

EPA a sked that a test plan be submitted as soon as possible and st ated 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.