## In The Matter Of:

Environmental Protection Agency Public Hearing, et al.

Public Hearing - Houston, Texas

June 7, 2011

Allied Advanced Reporting, Inc.

1647 Colquitt

Houston, Texas 77006

713.524.6777

1.800.223.9409

Original File Public_Hearing_-_110607.TXT



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7 ENVIRONMENTAL PROTECTION AGENCY

8 PUBLIC HEARING ON

9 PROPOSED RULE FOR NATIONAL EMISSION STANDARDS

10 FOR HAZARDOUS AIR POLLUTANTS

11 FOR POLYVINYL CHLORIDE AND COPOLYMER PRODUCTION

12 JUNE 7, 2011

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18 BE IT REMEMBERED that the above-entitled

19 proceeding came on to be heard on the 7th day of June,

20 201, beginning at 9:00 a.m., at the Houston Marriott

21 South - Hobby Airport, 9100 Gulf Freeway, Port Aransas

22 and Brownsville Conference Rooms, Houston, Texas 77017,

23 reported by Dorothy A. Rull, a Certified Shorthand

24 Reporter in and for the State of Texas, as follows,

25 to-wit:2

1 A P P E A R A N C E S

2 FOR THE EPA:

3 Ms. Peggy Lassiter

4 Ms. Jodi Howard

5 Mr. Kevin McLaughin

6 Mr. Kelly Rimer

7

8

9

10

11 I N D E X

12

13 SPEAKERS:

14 Mr. Otis Sistrunk (PolyOne Corporation) 9

15 Mr. Richard Krock (Vinyl Institute) 12

16 Ms. Mary Bachynsky (Formosa Plastics Corporation) 16

17 Mr. Bruce Hollands (PVC Pipe Association) 21

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22 * * * * *

23

24

25Public Hearing - Houston, Texas - June 7, 2011

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1 P R O C E E D I N G S

2 MS. LASSITER: Good morning and thank you

3 for attending this public hearing on the Environmental

4 Protection Agency's proposed rules for National Emission

5 Standards for Polyvinyl Chloride and Copolymer Production

6 for major and area sources.

7 I recognize that some of you may have

8 traveled a distance to be here, and we look forward to

9 your comments.

10 My name is Penny Lassiter. I am the

11 Group Leader of the Refining and Chemicals Group. And

12 our group is part of the Sector Policies and Programs

13 Division at EPA of the Office of Air Quality Planning and

14 Standards. We're actually located in Research Triangle

15 Park, North Carolina; and I'll be chairing today's

16 hearing.

17 We are here today to listen to your

18 comments on EPA's proposed air toxic standards for

19 polyvinyl chloride and copolymer production. The

20 proposed standards were published in the Federal Register

21 on May 20th of this year.

22 Before we begin, I'd like to describe

23 briefly the proposed rules that are the subject of

24 today's hearing and provide you with some context.

25 The Clean Air Act is the main law thatPublic Hearing - Houston, Texas - June 7, 2011

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1 governs how EPA addresses air pollution in the United

2 States. Section 112 of the Clean Air Act established the

3 way in which we at EPA must address toxic air emissions

4 from industries, such as PVC production. Air toxics,

5 also known as hazardous air pollutants, are known or

6 suspected to cause cancer and other serious health

7 effects.

8 The law requires that we list categories

9 of industries to be regulated, such as PVC production.

10 It requires us to establish standards based on the

11 emission levels achieved by the best-controlled sources

12 in the industry. These standards are known as Maximum

13 Achievable Control Technology or "MACT" standards for

14 short.

15 In the case of this specific rule, we

16 initially established MACT standards in 2002. Those

17 standards established emission limits for vinyl chloride

18 for both new and existing PVC production facilities. The

19 2002 emission standards for vinyl chloride was set as a

20 surrogate for the remaining hazardous air pollutants

21 because it was the predominant HAP used and emitted at

22 PVC production plants.

23 EPA determined that compliance with the

24 existing 1976 vinyl chloride NESHAP reflected the MACT

25 and satisfied the requirements of Section 112(d) of thePublic Hearing - Houston, Texas - June 7, 2011

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1 Clean Air Act, with the exception of adding new

2 requirements for equipment leaks at new sources.

3 EPA was sued on this 2002 standard. The

4 U.S. Court of Appeals for the D.C. Circuit vacated and

5 remanded the rule and directed the Agency to either

6 reconsider the rule or properly explain its methodology

7 for regulating hazardous air pollutants emitted in PVC

8 production, other than vinyl chloride, by the use of a

9 surrogate.

10 In 2007, EPA issued new standards for

11 both new and existing PVC production area sources based

12 on generally available control technologies or management

13 practices or GACT. This rule requires area source

14 facilities -- and area source facilities are smaller

15 facilities, ones that emit less than 10 tons annually of

16 a single hazardous air pollutant or less than 25 tons

17 annually of a combination of hazardous air pollutants --

18 to meet the existing requirements as established in the

19 1976 rule. These requirements only address

20 vinyl chloride emissions.

21 However, in the May 2011 proposed PVC

22 NESHAP, we are fulfilling our obligation under the Clean

23 Air Act, Section 112(d)(6) to review and revise, as

24 necessary, the PVC production area source standards.

25 In response to the remand of the majorPublic Hearing - Houston, Texas - June 7, 2011

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1 source rule and our technology review of the area source

2 rule, we proposed PVC -- we proposed NESHAP for PVC

3 production for both major and area sources on May 20,

4 2011. It is these proposed rules that are the subject of

5 today's public hearing.

6 These proposed rules would do the

7 following:

8 Set specific emission limits to

9 significantly reduce emissions of toxic air pollution

10 from all new and existing PVC production facilities.

11 These limits include emissions from process vents,

12 stripped resin, and wastewater systems.

13 Set specific limits for hydrogen

14 chloride, dioxin/furans, total amount of toxic air

15 pollution and vinyl chloride emissions from all new and

16 existing process vents located at facilities that are

17 major or area sources of hazardous air pollutant

18 emissions.

19 Set work practice standards to control

20 toxic air pollution from equipment leaks, storage vessels

21 and heat exchange systems at PVC facilities.

22 The proposed rules also include

23 monitoring and testing requirements for vinyl chloride,

24 total emissions on toxic air pollution and dioxin and

25 furan emissions.Public Hearing - Houston, Texas - June 7, 2011

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1 More details about the proposed rules and

2 instructions for submitting public comments are available

3 in the registration area. We also have prepared a list

4 of topics in the proposed rule for which we are

5 specifically seeking comment. That list is also

6 available in the registration area and may be helpful to

7 you as you are commenting today or submitting written

8 comments later on. EPA will be accepting written

9 comments until June 19th -- I'm sorry -- July 19th of

10 this year.

11 Let me mention that the proposed rules

12 for PVC production do not include vinyl chloride monomer

13 and ethylene dichloride manufacturing, which are often

14 co-located at PVC production plants. As part of an

15 upcoming rule on the chemical manufacturing sector, the

16 Agency will revisit those emission standards. EPA has

17 required some chemical plants, including some in the

18 Mossville, Louisiana area, to test for and submit

19 information on vinyl chloride and dioxin emissions to

20 support the upcoming chemical manufacturing sector rule.

21 These are not the subject of today's hearing.

22 Now, let me turn to the public comment

23 portion of the hearing. Today's hearing will work as

24 follows: I'll call the scheduled speakers to the

25 microphone one at a time, and I'll ask you to remain atPublic Hearing - Houston, Texas - June 7, 2011

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1 the table until you have completed your testimony. We'll

2 be preparing a written transcript of today's hearing and

3 the transcript will be available as part of an official

4 record for the rule.

5 When it is time for you to speak, please,

6 state your name and your affiliation.

7 Since we have a fairly light crowd, I'm

8 going to ask that you hold your testimony to, you know,

9 about five or six minutes. If you need a couple of extra

10 minutes, that's not going to be a problem.

11 And then after you finish your testimony,

12 please remain at the table until you've completed your

13 statement so that we might have the opportunity, if

14 necessary, to ask you any clarifying questions.

15 As I mentioned, we are transcribing

16 today's hearing and each speaker's oral testimony will

17 become part of the official record. Please be sure to

18 give a copy of any written comments to our staff at the

19 registration table. We will put the full text of your

20 written comments into the docket for you. We'll work

21 hard to ensure that everyone has an opportunity to

22 comment.

23 We're scheduled to stay here until

24 8:00 p.m. We will be taking breaks for meals during the

25 day and those breaks are scheduled as follows: LunchPublic Hearing - Houston, Texas - June 7, 2011

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1 will be from 2:30 -- excuse me -- from 12:30 until 2:00

2 and then there will be a dinner break from 5:00 until

3 6:30.

4 If you'd like to testify but you have not

5 yet registered to do so, please sign up at the

6 registration table. For those who've already registered

7 to speak, we've tried to accommodate your request for

8 specific time slots. We ask for your patience as we

9 proceed as we may need to make some minor adjustments as

10 the day progresses.

11 I'd also like to introduce -- here at the

12 table with me today is Jodi Howard. She's a member of my

13 staff in the refining chemicals group, and she is the

14 lead project manager for the development of this rule.

15 So, again, I'd like to thank you all for

16 participating and coming today. And with that, I would

17 like to go ahead and get started with our first

18 commenter.

19 So at this time I'm going to ask -- did

20 you want to say anything else, Jodi?

21 MS. HOWARD: (Moving head side to side.)

22 MS. LASSITER: At this time, I'm going to

23 ask Otis Sistrunk, if he would, please come to the table.

24 MR. SISTRUNK: Good morning.

25 Good morning. My name is Otis Sistrunk,Public Hearing - Houston, Texas - June 7, 2011

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1 and I am the environmental health and safety manager with

2 PolyOne Corporation. The PolyOne Corporation is

3 headquartered in Avon Lake, Ohio.

4 PolyOne is a speciality PVC resin

5 producer and the leading PVC resin compounder of hundreds

6 of materials used in diverse products across many market

7 sectors.

8 PolyOne operates specialty resin plants

9 in Pedricktown, New Jersey and Henry, Illinois and

10 numerous PVC compounding facilities across the U.S.

11 PolyOne provides hundreds of jobs at the plants

12 themselves and corresponding support jobs within the

13 communities where these plants are located.

14 PolyOne believes that the production of

15 different types of PVC resins, dispersion and suspension

16 blending should be included in the MACT as their own

17 categories due to the very different nature of both the

18 manufacturing technologies used and the resins produced.

19 PolyOne agrees with the proposed MACT;

20 that the class of PVC resins called "dispersion resins"

21 should have their own subcategory as proposed, reflecting

22 the differences in process at dispersion resin plants.

23 Not only is the technology in chemistry

24 used to manufacture dispersion resins different from

25 other types of resin manufacturing, the resulting resinPublic Hearing - Houston, Texas - June 7, 2011

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1 particles themselves are quite different, with much

2 smaller particle size and much lower surface porosity

3 than what is typical for suspension resins. These are

4 critical factors in the effectiveness of removing

5 residual vinyl chloride monomer from the resin product

6 and ensuring low emissions from the production process.

7 Creating separate limits in the MACT for RVCM and HAP for

8 dispersion resins is appropriate given these differences.

9 PolyOne is also a producer of PVC

10 suspension blending resins. This type of specialty resin

11 is used in flooring, automotive interiors, and synthetic

12 leather products. The proposed MACT does not

13 specifically address suspensions blending resins, leaving

14 this class of resin manufacturing unclear.

15 For the same reasons discussed for

16 dispersion resins, PolyOne believes that suspension

17 blending resins require a separate subcategory under the

18 proposed MACT.

19 Suspension blending resins have very

20 different characteristics than generic suspension resins,

21 including smooth surfaces and different particle sizes of

22 distribution, all which present different challenges when

23 stripping vinyl chloride from a different resin.

24 I appreciate this opportunity to present

25 these comments this morning and thank you very much.Public Hearing - Houston, Texas - June 7, 2011

12

1 MS. HOWARD: I have one clarifying

2 question for you. When you say "subcategorization," are

3 you just referring to resin stripping or to process fees?

4 MR. SISTRUNK: I'm referring to process

5 stripping. I speak specifically for suspension blending

6 resins.

7 MS. HOWARD: So that's for the strip

8 resin?

9 MR. SISTRUNK: That's correct.

10 MS. HOWARD: Okay. Can you hear me okay?

11 MR. SISTRUNK: Yes.

12 MS. LASSITER: Okay. Thank you.

13 MR. SISTRUNK: Thank you.

14 MS. LASSITER: Okay. Next I'd like to

15 call Mr. Richard Krock.

16 MR. KROCK: Good morning. And thank you

17 for the opportunity to address the EPA's proposed Maximum

18 Achievable Control Technology Regulations.

19 I'm Rich Krock. I'm the technical

20 director for the Vinyl Institute, which is a U.S. based

21 trade association comprised of leading producers of PVC

22 resins and some associated additive supplier and

23 downstream product manufacturers.

24 The Vinyl Institute has been in existence

25 since 1982. One of our key missions is to advocate forPublic Hearing - Houston, Texas - June 7, 2011

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1 the responsible manufacture of PVC resins.

2 The VI thanks the EPA for the opportunity

3 to provide some broad-based comments on this important

4 rule-making activity today.

5 The Vinyl Institute agrees that the PVC

6 MACT rule is overdue and industry supports an update of

7 the regulatory requirements. We look forward to working

8 cooperatively with Agency staff on the development of a

9 final rule that meets Agency requirements and allows for

10 the continued growth of our industry.

11 The proposed rule is a step change from

12 the current regulatory regime, and member companies have

13 started a comprehensive review of the requirements and

14 background documents. The VI is in the process of

15 reviewing proposal related information in anticipation of

16 formulating and submitting meaningful and detailed

17 comments on the proposal.

18 Based on our preliminary review of the

19 docket materials and the proposal, there are a few points

20 which we wish to highlight. The Vinyl Institute believes

21 that the Agency selection of emission points and

22 evaluation of HAPs moves in the right direction, and we

23 look forward to working with the Agency on these

24 provisions.

25 The VI recommends that morePublic Hearing - Houston, Texas - June 7, 2011

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1 considerations be given to variety of emissions from a

2 wide array of products that the industry manufactures,

3 over 100 different resins on a seasonal basis, in

4 addition to the seasonality in production rates.

5 The VI also recommends the Agency give

6 consideration for the need for flexibility in achieving

7 lower limits. The VI would appreciate the opportunity to

8 assist the Agency staff in fully understanding these

9 topics as it is key -- as they are key to the development

10 of a technically sound rule.

11 As previously mentioned, the VI will

12 submit substantial comments to the Agency regarding the

13 proposal.

14 Thank you for the opportunity to speak

15 today, and we will look forward to working with the EPA

16 on this important activity.

17 MS. HOWARD: Thank you.

18 I have two clarifying questions. On your

19 point about more considerations for variability of

20 emissions, could you expand by emission points, by

21 certain emission points or the HAP that we have

22 identified? Could you expand on that a little bit?

23 MR. KROCK: We believe the section of

24 HAPs is appropriate. When we speak of variability, we

25 speak of each location manufacturing different grades ofPublic Hearing - Houston, Texas - June 7, 2011

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1 resin. There are hundreds of resin -- not hundreds, but

2 there are over a hundred different types of resins

3 produced by the industry. And when we speak of

4 variability, that's really what we're referring to. Each

5 resin can have a unique HAP profile and that should be

6 taken into consideration.

7 MS. HOWARD: And is that for stripped

8 resin or is that for the processes?

9 MR. KROCK: That would cover both

10 categories.

11 MS. HOWARD: Then my next question was

12 about your comment about needing flexibility and lower

13 limits. Could you explain that a little bit more?

14 MR. KROCK: The EPA's approach has been

15 on concentration, which is appropriate. There are times

16 when a flexible approach, which are in other MACT rules,

17 could be considered; and those are the types of things

18 that the VI would ask the Agency to look at.

19 MS. HOWARD: Okay.

20 MS. LASSITER: Okay. Thank you.

21 MR. KROCK: Thank you.

22 MS. LASSITER: Next I'd like to call Mary

23 Bachynsky forward.

24 MS. BACHYNSKY: Good morning. And I

25 thank you also for this opportunity to present to talkPublic Hearing - Houston, Texas - June 7, 2011

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1 today.

2 My name is Mary Bachynsky. I'm with

3 Formosa Plastics Corporation USA. I'm an air manager

4 there for the last 17 years. I am currently the chair of

5 the Vinyl Institute's Health Environmental and Safety

6 Committee, and I've been involved in EPA's rule making

7 for our industry since 1994. My oral comments today are

8 somewhat technical in nature.

9 A little bit about Formosa Plastics USA.

10 We are a leading manufacturer of PVC and copolymer

11 resins. We have four operating PVC plants in the United

12 States; two in Texas, one in Louisiana, and one in

13 Delaware.

14 We are producing dozens of PVC

15 suspension, dispersion, and copolymer products from a

16 general purpose PVC resin to a customer-specific

17 specialty blended PVC resin.

18 We provide hundreds of jobs in the

19 New Jersey, Texas, Louisiana and Delaware area.

20 My first technical comment is with regard

21 to the resin stripping complexities. Formosa recognizes

22 the extensive technical efforts that the EPA has put into

23 developing the proposed rule. Formosa will be providing

24 additional comments regarding the need to consider

25 further subcategorization of resins, PVC particlePublic Hearing - Houston, Texas - June 7, 2011

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1 morphology, and operational conditions necessary for

2 various product specifications and quality.

3 Regarding particle morphology, it is one

4 of the key concepts of understanding PVC resins. Each

5 PVC resin grade has a unique physical characteristic

6 known as particle morphology. This uniqueness is

7 necessary in order to make the variety of PVC products,

8 from a ridged blue sewer pipe to a soft flexible PVC

9 handle on a pair of pliers. Particle morphology is made

10 up of a variety of factors such as the particle size of

11 the PVC resin, which can range from 1 micron to

12 45 microns.

13 Porosity: Porosity are the pores in the

14 particles of PVC resin. Some PVC resins have more

15 porosity, more pores, more holes than others making it

16 easier to remove the PVC resin.

17 Mechanical stability is another aspect of

18 particle morphology. Mechanical stability helps us

19 understand whether the PVC is going to sheer or

20 agglomerate.

21 Heat stability is another key part of

22 particle morphology, whether heat can be applied to the

23 PVC resin and you still have the final product that you

24 need. The color is not brown or white, depending on what

25 you need to do.Public Hearing - Houston, Texas - June 7, 2011

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1 PVC resins characteristics are different.

2 They are -- PVC is a polymer. It's very different than a

3 commodity chemical, such as benzene or toluene. It's

4 not -- they are each unique.

5 And historically EPA has recognized that

6 in that PVC resins have not been characterized as

7 synthetic, organic chemical manufacturing industry

8 chemicals, such as those regulated under the hazardous

9 organic NESHAP or Part 60, Subpart VV, which is the leak

10 detection and repair requirements for SOCMA. PVC is not

11 listed there.

12 PVC resins characteristics are different.

13 Each PVC resin product is produced for a specific end use

14 and that end use may be very different in nature, whether

15 the PVC needs to flow over a smooth surface or be

16 extruded through a piece of machinery or to be poured

17 into a mold.

18 The PVC needs regulatory flexibility in

19 order to produce a full complement of different resins

20 that are used for diverse final products, such as vinyl

21 siding, PVC pipe, window frames, electrical wiring

22 insulations, roofing, credit cards, and a host of other

23 applications.

24 Formosa agrees with EPA statements that

25 steam stripping is the available control technology toPublic Hearing - Houston, Texas - June 7, 2011

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1 reduce HAPs from the PVC resin. And we also agree that

2 going beyond the floor by routing this downstream of

3 resin strippers to an additional control device is not

4 appropriate, while we're emphasizing though that the

5 residual HAP limits must be achievable on a daily basis

6 for all grades of PVC resins so that the United States

7 can stay competitive in a global market.

8 I thank you very much for the opportunity

9 to present my comments today. If you have any questions,

10 I'm ready.

11 MS. HOWARD: I just have one clarifying

12 question. It's kind of the same ones I asked

13 Mr. Sistrunk and Mr. Krock.

14 And you made a comment about needing more

15 flexibility. Could you expand on that a little bit more?

16 MS. BACHYNSKY: And, again, I'm just

17 speaking with regard to the strippable resin, not the

18 process products.

19 MS. HOWARD: Okay. That is all.

20 Ms. BACHYNSKY: Okay. Thank you very

21 much.

22 MS. HOWARD: Thank you.

23 MS. LASSITER: Okay. Well, we're running

24 considerably ahead here. Is Mr. Bruce Hollands here?

25 Okay. Not yet. He's actually scheduled to speak atPublic Hearing - Houston, Texas - June 7, 2011

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1 10:15. So he's probably going to be here in a little

2 while.

3 So, at this point, I think that we'll

4 take a break because I don't have any further speakers

5 between now and 10:15 and we'll reconvene to hear

6 Mr. Hollands at that point.

7 Okay. Thank you.

8 (Recess 9:29 to 10:15.)

9 MS. LASSITER: We're going to resume the

10 public hearing. I don't know if there are any of you

11 here. Is there anyone here that wasn't here prior to the

12 break?

13 (Show of hands.)

14 MS. LASSITER: Okay. Just to let you

15 know, there are some materials out on the registration

16 desk -- hopefully, you picked those up -- that talk about

17 how you can provide comments and list requests that we

18 have for specific comments.

19 And just to let you know that I'll ask

20 you, once you complete your statement, if you'll please

21 stay at the table and we may want to ask you some

22 clarifying questions.

23 We do have a reporter here that will be

24 taking down the notes. Also, if you have your comments

25 written, we would appreciate getting those from you asPublic Hearing - Houston, Texas - June 7, 2011

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1 well at the connection of your presentation.

2 We are scheduled to be here until

3 8 o'clock. We don't have any speakers scheduled for this

4 morning so far after this next speaker. But if there is

5 anyone in here that is not -- who does want to speak but

6 who has not registered, just please register at the table

7 outside and then they'll inform us that you want to

8 speak.

9 So I think with that brief introduction,

10 I'm going to go ahead and call Mr. Bruce Hollands to come

11 up and to give his statement.

12 MR. HOLLANDS: Thank you.

13 Is that good?

14 MS. HOWARD: Yes.

15 MR. HOLLANDS: Well, thank you very much.

16 I'm Bruce Hollands with the PVC Pipe Association. We

17 represent PVC pipe manufacturers in North America.

18 Founded in 1971 as a nonprofit

19 organization -- I don't even know if I need this mike --

20 Uni-Bell PVC Pipe Association is the authoritative source

21 of information on PVC pipe. It serves the engineering,

22 regulatory, public health and standardization

23 communities.

24 Introduced in North America in 1951,

25 corrosion-proof PVC piping offers a superior, proven, andPublic Hearing - Houston, Texas - June 7, 2011

22

1 truly sustainable solution for underground

2 infrastructure, helping municipalities spend smarter and

3 giving taxpayers the best returns on their dollar.

4 The PVC pipe industry contributes in

5 excess of $14 billion annually to the U.S. economy and

6 supports over 25,000 jobs.

7 With over 2 million miles in service, PVC

8 pipe is the product of choice for buried water, sewer,

9 drainage and irrigation infrastructure.

10 Safe and beneficial to public health:

11 PVC pipe is one of the safest and most tested materials

12 used in North America. For over 60 years, every aspect

13 of its production, use, and disposal has been evaluated

14 and approved by government and independent certification

15 and testing agencies. It meets or exceeds all required

16 healthy and safety standards and regulations governed by

17 the U.S. and Canadian Safe Drinking Water Acts and other

18 international statutes.

19 Its use is monitored by independent

20 agencies, like NSF International and governmental bodies

21 like the U.S. Environmental Protection Agency, insured

22 safety through mandatory regular testing.

23 Additionally, organizations like the

24 U.S. Food and Drug Administration and consumer product

25 safety commissions have confirmed that PVC is a safePublic Hearing - Houston, Texas - June 7, 2011

23

1 product.

2 PVC is approved for use around the world

3 in water distribution and transmission, consumer products

4 and medical applications. It is so safe that it's used

5 for intravenous medical tubing, and it is the pipe of

6 choice for ecologically sensitive environments, like,

7 saltwater aquariums which must use the inert and safest

8 pipe materials available.

9 Its smooth noncorrosive surface stays

10 clean and after decades of use, unlike that of iron pipe

11 which suffers from tuberculation, a form of internal

12 corrosion and biofield contamination, which can be a

13 breeding ground for bacteria.

14 Over 40,000 North American water

15 utilities use PVC pipe today, and some 10 million quality

16 control tests have been conducted on water carried

17 through PVC pipe since it was first introduced in North

18 America. All of them confirm the product is safe and

19 beneficial to public health.

20 The Corrosion Crisis: Corrosion is the

21 leading cause of the water main break epidemic in North

22 America, estimated at some 300,000 breaks annually.

23 According to a 2002 Congressional study, it's a drive on

24 the economy as well, costing U.S. drinking water and

25 wastewater systems over 50.7 billion annually or morePublic Hearing - Houston, Texas - June 7, 2011

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1 than one trillion dollars over the next 20 years.

2 Today's corrosion crisis is due to the

3 materials used in America's underground pipe networks

4 over the last 100 years. At first, cast iron was used

5 with ductile iron gradually replacing it as the material

6 of choice. Both now suffer from the ravages of

7 corrosion.

8 Moreover, the burden of old technology

9 and materials is not limited to the cost of repairing and

10 replacing failed pipelines. It includes the cost of

11 losing treated water from leaking systems. All told,

12 leaking pipes lose some 2.6 trillion gallons of drinking

13 water every day or 17 percent of all water pumped in the

14 United States.

15 The solution to these problems begins

16 with sustainability, durability, and corrosion

17 resistance. All attributes of PVC pipe. Increased

18 durability means fewer leaks, better water conservation

19 and lower costs.

20 PVC pipe has been celebrated by

21 Engineering News Record as one of the top 20 engineering

22 advancements of the last 125 years. A study by the

23 American Waterworks Association Research Foundation

24 recently quantified its life expectancy at more than 110

25 years and other studies suggested it could last evenPublic Hearing - Houston, Texas - June 7, 2011

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1 longer than that.

2 Furthermore, PVC pipe is more efficient

3 to manufacture, taking four times less energy to make

4 than concrete pressure pipe and half that used for iron

5 pipe. PVC's light weight reduces transportation and

6 installation costs, yielding additional greenhouse gas

7 reductions. It is also totally recyclable, though most

8 of it is yet to enter the recycling stream given its

9 great durability.

10 As well, PVC's ultra smooth surface

11 reduces pumping costs and its leak-free joints eliminate

12 water loss, which can be up to 40 percent in some old

13 technology and corrosion-prone piping networks.

14 For municipal officials, PVC's most

15 attractive feature is perhaps its cost effectiveness.

16 Annual savings derived from PVC pipe now used in sanitary

17 sewer systems throughout the U.S. are estimated at

18 $270 million a year. Converting the entire sanitary

19 sewer system network to PVC could save upward of

20 $800 million a year.

21 Helping build a greener tomorrow: PVC

22 piping is one of the world's most sustainable products.

23 It is produced with sustainable and abundant resources:

24 Chlorine, which is derived from salt, and domestically

25 produced natural gas, which helps reduce consumption ofPublic Hearing - Houston, Texas - June 7, 2011

26

1 imported oil. For real sustainability, long-term

2 performance and efficient resource management, it's

3 critical.

4 Clean and safe manufacturing: PVC pipes'

5 environmental footprint is far smaller than competing

6 piping materials. Its manufacturing is extremely

7 efficient, with virtually 100 percent of the PVC compound

8 being used. There are no smoke stacks at PVC pipe

9 facilities.

10 PVC's pipes ecological credentials has

11 been demonstrated by numerous life cycle assessments,

12 which scientifically assess the impact of a product from

13 raw material extraction to end of life.

14 And since sustainability involves a

15 social dimension, it's important to look at it in terms

16 of human resources and worker safety. According to the

17 United States Bureau of Labor, the plastic piping

18 industry has an outstanding record in this area,

19 experiencing far fewer injuries and illnesses in every

20 phase of production on average than similar industries.

21 A smaller human footprint: The PVC

22 pipe's greatest environmental attribute is perhaps

23 exceptional durability and corrosion resistance, leading

24 to better water conservation and lower replacement

25 maintenance and repair costs for our pipingPublic Hearing - Houston, Texas - June 7, 2011

27

1 infrastructure. More than ever, we need PVC pipe.

2 Thank you.

3 MS. LASSITER: Okay. Thank you.

4 Jodi, do you have any questions?

5 MS. HOWARD: (Moving head side to side.)

6 MS. LASSITER: Okay. Thank you. I

7 appreciate that.

8 Okay. At this point, we don't have

9 anyone scheduled to speak. And, let's see, do we have

10 speakers for this afternoon? So we do have -- right now

11 we have a scheduled speaker this afternoon, I believe, at

12 3 o'clock.

13 MS. HOWARD: 4:00.

14 MS. LASSITER: At 4:00, okay.

15 Anyway, we're scheduled to be here until

16 8 o'clock. I'm going to go ahead and break here, but

17 we'll be around here until about 12:30. Then we have a

18 scheduled lunch break from 12:30 to 2:00. So we'll

19 return at 2:00, and we have another speaker scheduled for

20 4:00. And then we'll break from 5:00 until 6:30 for

21 dinner.

22 And, again, if you come in and you want

23 to speak and you have not registered, I invite you to

24 register at the front table and they will sign you up for

25 a speaking slot.Public Hearing - Houston, Texas - June 7, 2011

28

1 Okay. So with that, I'm going to break

2 the meeting. And thank you.

3 (Recess, 10:26 a.m. - 8:00 p.m.)

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2529

1 STATE OF TEXAS :

2 COUNTY OF HARRIS :

3

4 I, Dorothy A. Rull, a Certified Shorthand

5 Reporter in and for the State of Texas, do hereby certify

6 that the preceding proceedings were reported by me at the

7 time and date stated on page 1 hereof;

8 I further certify that said proceedings

9 were reported by me in machine shorthand, later reduced

10 to typewritten form under my personal supervision, and

11 the above and foregoing 27 pages constitute a true and

12 correct transcript thereof.

13 GIVEN UNDER MY OFFICIAL hand and seal of

14 office, on this the 16th day of June, 2011.

15

16

17

19

Dorothy A. Rull, CSR, CRR

20 Texas CSR Number 3978, Expires 12/31/2012

21

22 Allied Advanced Reporting, Inc.

1647 Colquitt Street

23 Houston, Texas 77006

Phone: (713) 524 - 6777 Fax: (713) 524 - 6888

24 Toll Free 1-800-223-9409

aari@AlliedAdvancedReporting.com

25