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MEMORANDUM

To: Greg Nizich, U.S. EPA, Office of Air Quality Planning and Standards

From: Colin Hayes and Jason Huckaby, Eastern Research Group, Inc.

Date: August 27, 2008

Subject: Summary of August 18, 2008 Teleconference Between EPA and The 

Vinyl Institute to Discuss Remanded Polyvinyl Chloride and Copolymers 

Production (PVC) NESHAP Issues and Future Activities

On August 18, 2008, members of The Vinyl Institute (VI) and representatives of PVC 

manufacturing companies met with EPA via teleconference. The attendees and affiliation 

are listed below:

Name Representing

Barry Christenson Occidental Chemical Corporation

Ken Atkins Georgia Gulf Corporation

Mary Bachynsky Formosa Plastics Corporation

Carlos Davis CertainTeed Corporation

Mark Graham Shintech Incorporated

Danielle Lincoln The Dow Chemical Company

Peter de la Cruz Keller and Heckman (Attorney representing the 

Vinyl Institute)

Greg Nizich U.S. EPA OAQPS

Ken Hustvedt U.S. EPA OAQPS

Jason Huckaby Eastern Research Group, Inc.

Colin Hayes Eastern Research Group, Inc.

The meeting began at 1:00 PM (EST). A summary of the meeting’s discussion follows.
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EPA stated that it intends to move forward with developing a CAA section 114 

questionnaire for the polyvinyl chloride and copolymers production source 

category.

EPA stated it intends to have a draft of the questionnaire ready to send to VI for 

its review before the VI’s September 10

th meeting.

EPA appreciated the VI’s efforts to submit information to the Agency voluntarily, 

but EPA did not feel the information provided addressed all of EPA’s information 

needs adequately and was too general to help support NESHAP emission limits. 

The VI supplied ranges of HAP emission information covering several plants, but 

EPA needs plant-by-plant emissions information for each HAP present in the 

process and for each specific emission point in the process. EPA also needs plant 

specific information to be able to gauge variability in the data. EPA added that it 

needs the specific data to support issues raised by petitioners with respect to the 

vacated Part 63 NESHAP.

The VI asked EPA if it had looked at the data submitted by VI. EPA responded 

that it had looked at the information, but the information submitted seemed to deal 

mostly with addressing surrogacy, but there was no information provided by VI 

that would allow EPA to evaluate controls and provide an adequate basis for EPA 

to establish emissions limits. EPA has to be able to verify what HAP and what 

controls are present.

The VI stated that at the meeting with EPA in October of 2007, their focus was on 

discussing residual vinyl chloride monomer (RVCM).

EPA stated that it was very clear in the October 2007 and in subsequent 

correspondence about the need for plant-specific data.

The VI noted that nothing much has changed in the industry since the VC 

NESHAP from the 70’s.

The VI noted that, due to their data collection efforts to date, they may already 

have all of the information EPA needs that would be requested from a 

questionnaire.

An industry representative noted that there are only two control devices present in 

the PVC industry: incinerators and strippers. Furthermore, there is not a lot of 

HAP emissions data kept by industry on equipment downstream of the strippers. 

Much of what is known is based on engineering estimates.

The VI noted that even with a section 114 questionnaire, EPA may not get a lot of 

information. The VI added that the best thing to do would be provide comments 

to EPA on the draft 114 questionnaire.
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The VI asked EPA if it would be helpful to provide stack test data, but also noted 

that a lot of that information may be publicly available. EPA responded that stack 

test data would be helpful.

VI inquired as to the schedule and timeline. EPA noted that it would like to have 

a proposed rule by Spring of 2009.

EPA indicated to VI that it would send a draft of the 114 questionnaire by 

September 5th so that they may review the draft and discuss at their meeting on 

September 10th. A separate copy would be sent to Dow.

The meeting concluded at 1:50 PM (EST).