MEMORANDUM

TO: Record 

FROM: Samantha Lewis, EPA 

 

DATE: August 1, 2007 

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to Discuss the 

Proposed Voluntary VCM Program (11 July 2007)

 EPA participated in a teleconference with The Vinyl Institute (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 Plan (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 Attachment A. 

Background

 EPA and the VCP initially met on March 14, 2007 to discuss the VCP’s proposed 

VMP for vinyl chloride manufacturers. Industry had proposed collecting 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 expressed concern about the potential for 

dilution at the final outfall since many of the facilities discharge wastewater from non-CCH 

manufacturing operations. EPA prepared a generic sampling plan to describe their suggested 

approach for sampling and provided it to industry for discussion and comment. EPA also 

included example diagrams which describe EPA’s rationale for selecting sampling points. For 

facilities where CCH wastewater is commingled with non-CCH wastewater, EPA is requesting 

that the facility collect a sample prior to the mixing point. EPA noted that the number of 

sampling points will depend on the facility’s manufacturing processes and process flow diagrams. 

EPA is requesting that industry collect at least four samples 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 collection 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 a 
2

correlation between TSS and dioxins and furans after treatment and not at upstream 

sampling points which may have extreme conditions that could affect the 

measurement. EPA would still like to collect TSS data but 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 daily maximum 

concentrations and how this data will potentially be used to 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 percentile) 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 considers the site-specific 

plans and all data collected under the program as Confidential 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 are appropriate for all data 

collected and any methods EPA could use to help improve the transparency of the 

program and allow EPA to defend any decisions that are based on VCP’s data to the 

public. 

4. Frank Borrelli discussed the PVC data collected by the Vinyl 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 effort. EPA will provide a 

list of questions about the Vinyl Institute sampling data that may aid in EPA’s 

evaluation of this information. 

 

Next Steps

1. Samantha Lewis will deliver a final draft of the Generic 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 to 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