### MEMORANDUM

TO: Record

FROM: Samantha Lewis, EPA

DATE: August 1, 2007

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to D iscuss the

Proposed Voluntary VCM Program (11 July 2007)

EPA participated in a teleconference with The Vinyl Ins titute (VI) and several member companies (referred to as the Vinyl Chloride Producers , or VCP) on July 11, 2007 to continue discussions on EPA’s Draft Generic Sampling P lan (GSP), which describes the procedures that facilities should follow in conducting the voluntary monitoring program (VMP). The list of meeting participants can be found in Attachme nt A.

Background

EPA and the VCP initially met on March 14, 2007 to discus s the VCP’s proposed VMP for vinyl chloride manufacturers. Industry had proposed c ollecting dioxin and furan and total suspended solids (TSS) data for facilities’ final outfalls at a frequency of one sample per month for nine months. At the March 14 meeting, EPA expr essed concern about the potential for dilution at the final outfall since many of the faciliti es discharge wastewater from non-CCH manufacturing operations. EPA prepared a generic sampling p lan to describe their suggested approach for sampling and provided it to industry for discussio n and comment. EPA also included example diagrams which describe EPA’s rationale f or selecting sampling points. For facilities where CCH wastewater is commingled with no n-CCH wastewater, EPA is requesting that the facility collect a sample prior to the mixi ng point. EPA noted that the number of sampling points will depend on the facility’s manufacturin g processes and process flow diagrams. EPA is requesting that industry collect at least four sam ples at each sampling point, each collected at least one month apart.

The VI provided a revised draft of the GSP to EPA on May 18, 2007. EPA met

with the VCP to discuss initial comments on the GSP on May 22, 2007 and conducted a teleconference on June 15, 2007 to discuss additional comments . This meeting was scheduled to finalize the Generic Sampling Plan.

Discussion

The primary purpose of this meeting was to walk through the Draft Generic Sampling Plan and resolve the VCP comments. Additional topics discussed are listed below:

1. The VCP continues to have concerns about the collectio n of total suspended solids (TSS) data. They would like clarification on how EPA intends to use this data. Mr. Jason Campbell, PPG, stated that EPA would probably only be able to make a2 correlation between TSS and dioxins and furans after treat ment and not at upstream sampling points which may have extreme conditions that could affect the

measurement. EPA would still like to collect TSS data b ut will consider concerns about specific sampling points during discussions on the site -specific plans.

2. The VCP asked how EPA plans to compute average daily and da ily maximum concentrations and how this data will potentially be used t o set limits. Ms. Goodwin said EPA typically reviews data from all sampling points after treatment, computes an average, and then apply statistics (usually the 95 percentil e) to compute the daily maximum. The exact path forward for the data collected under the voluntary program has not yet been determined.

3. EPA and the VCP discussed confidentiality issues. EPA c onsiders the site-specific plans and all data collected under the program as Confidentia l Business Information (CBI) and will not share data from individual sites with the public or other VCP

members. The VCP should consider whether CBI claims ar e appropriate for all data collected and any methods EPA could use to help improve the t ransparency of the program and allow EPA to defend any decisions that are base d on VCP’s data to the public.

4. Frank Borrelli discussed the PVC data collected by the Vi nyl Institute and asked what

additional data would be needed for EPA to make a decision on whether PVC facilities needed to be included in the scope of the CCH rulemaking ef fort. EPA will provide a list of questions about the Vinyl Institute sampling data th at may aid in EPA’s

evaluation of this information.

Next Steps

1. Samantha Lewis will deliver a final draft of the Generi c Sampling Plan to Frank Borrelli for approval.

2. The VCP will provide input for a memorandum of understanding letter to put the sampling plans into action.

3. EPA will work with individual companies to finalize their site-specific plans. EPA

will insure that comments on the GSP are transferred t o the site-specific plans.Appendix A. List of Participants

EPA /Industry Teleconference on Generic Sampling Plan

July 11, 2007

Name Company Contact Information

Samantha Lewis EPA 202-566-1058 Todd Doley EPA 202-566-1160

Janet Goodwin EPA 202-566-1060

Ann Johnson EPA 202-564-5966

Paul Shriner EPA 202-566-1076 Jaqueline Rios EPA Region 2 212-637-3859 Mary Bachynsky – via phone FPC USA 973-716-7342 Tom Berger Keller & Heckman 202-434-4285 Frank Borrelli Vinyl Institute 703-741-5668 Jason Campbell PPG 337-708-4450 Toni Jett – via phone Westlake 270-395-3571 Jeff Longsworth Barnes & Thornburg 202-408-6918 Jim Williams – via phone Dow 304-737-3956

Lori Weiss ERG 703-633-1658