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MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford, ERG

DATE: March 3, 2011

SUBJECT: Summary of February 16, 2011 US EPA Industry Meeting in Baton Rouge, 

LA

1.0 Introduction

On February 16, 2011, EPA held an industry information meeting at Louisiana 

Department of Environmental Quality (LDEQ) in Baton Rouge, LA to present information 

regarding the polyvinyl chloride and copolymers (PVC) national emission standards for 

hazardous air pollutants (NESHAP) as well as the Clean Air Act (CAA) section 114 vinyl 

chloride monomer (VCM) information request.

2.0 Date and Location

February 16, 2011

Louisiana Department of Environmental Quality

602 N. Fifth Street

Baton Rouge, LA 70802

3.0 Attendees 

Name Affiliation 

John Westendorf OxyChem/OxyVinyls

Barry Christensen OxyChem/OxyVinyls

Laura Whiting OxyChem/OxyVinyls (by telephone)

Mary Bachynsky Formosa Plastics

Bob Elman Dow Chemical

Otis Sistrunk PolyOne Corp

Nan Thomey Environmental Chemistry

Amy Marshall URS 

Kevin Bloomer Westlake

Allen Bodron Westlake

Reed Mackay Georgia Gulf
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Dave Goldsmith Georgia Gulf

Nate Johnson Georgia Gulf

Hillary Garner Georgia Gulf

Bliss Higgins Certain Teed

Bruce Brocka Certain Teed

Don Johnson PPG

Peter De La Cruz Keller and Heckman

Rickard Krock Vinyl Institute

Mary Caldwell LDEQ

Chris Kotrik LDEQ

Russell Wozniak Dow (by telephone)

Jodi Howard US EPA - Office of Air Quality Planning and Standards 

(OAQPS)

Jason Dewees US EPA - OAQPS

Barrett Parker US EPA - OAQPS

Marcia Mia US EPA – Office of Enforcement and Compliance 

Assurance

Jennifer Gibbs US EPA Region Six

Mark Kataoka US EPA – Office of General Counsel

Penny Lassiter US EPA - OAQPS

Philip Crawford ERG

4.0 Summary of Meeting

The meeting began at approximately 8:15 AM with EPA introductions and an overview 

of the meeting structure. EPA and the Vinyl Institute (VI) each gave a presentation. The EPA 

presentation can be found in Attachment A. Questions were addressed during and after each 

presentation. A summary of the meeting’s discussion follows. Questions and talking points are 

noted in the order which they were addressed during the meeting. The description of the meeting 

is not verbatim, but merely a summary of the topics discussed. 

General Discussion 

EPA presented information related to the upcoming PVC NESHAP. The following is a 

brief summary of the main points discussed during the meeting.

EPA briefly described the process to determine maximum achievable control technology 

(MACT) floors, referencing Section 112(d) of the CAA. EPA indicated that floors were 

determined on a pollutant by pollutant basis, not a company/pollutant basis. 

An audience member requested the definition of source, plant, or emission source. EPA 

responded that a source was considered to be a PVC production plant. EPA confirmed 

that testing was only required at one point for each facility (e.g., one incinerator or one 

total resin number). Therefore, each facility represented one source. 

EPA further discussed the data sources used to calculate the MACT floors. EPA 

referenced Agency required testing, state required testing, and previous rules. 
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EPA discussed emissions variability and referenced the recent sewage sludge incinerator 

(SSI) proposed rule. EPA indicated that before the use of variability analyses, MACT 

floors were strictly the average of the top 5 sources. However, a variability analysis 

incorporates an upper prediction limit (UPL) to account for operational distinctions 

within and between emissions tests for the same unit. An audience member questioned if 

EPA accounted for the variation in the 30 day or 3 year data, referencing the 3 years of 

Method 107 data submitted to the VI. EPA responded that variation was accounted for in 

the 30 day sampling data. An audience member asked how EPA accounted for 

variability in resin grades. EPA responded that variability was assessed for the 30 day

data. An audience member stated that EPA was applying a commodity principle to a 

non-commodity product. EPA responded that industry concerns of variability were 

understood. EPA requested industry to submit comments on different methods to 

account for variability during the upcoming comment period. 

An audience member asked how EPA determined the top 5 sources. EPA responded that 

facilities were compared using the 30 day average for resins and the 3 test run average for 

process vents. An audience member asked how the 30 day average accounted for 

unknown variability across grades that were not produced during those 30 days. EPA 

requested industry to submit comments on different methods to account for variability 

during the upcoming comment period. 

An audience member asked if the upcoming rule accounted for new products, requesting 

that facilities be able to petition for new raw materials. EPA stated that the Agency

understands the issue of variability and that industry nor EPA has any way of knowing 

what products industry will be making in the future. EPA stated that the possibility exists 

to revisit the rule as more data is collected. 

An audience member asked if numerical emission limits would be presented. EPA 

responded that no numerical limits would be presented. 

An audience member asked if longer averaging times would be used for compliance, 

given the issue of variability. EPA responded that averaging times will be addressed later 

in the presentation. 

EPA briefly described the variability calculation and the incorporation of non-detect 

(ND) data. An audience member asked if ND values were selected from the data set as a 

whole, or only the top 5 sources. EPA replied that ND values were selected from the top 

5 sources. An audience member stated that EPA’s method for ND values assumes that 

the pollutant was present, and the method may not account for what is actually in the raw 

materials. EPA responded that the Agency must work with the data they have. An 

audience member stated that a method detection limit (MDL) suggests that the HAP is

either not present, or present, but below the detection level. The audience member 

questioned if the MDL was truly a result of the HAP being below detection limits or if 

the HAP was absent from the stream. The audience member added that if the HAP was 

only present in the process 2 days out of 30, then the HAP emission limit would be 

skewed low. In response, EPA noted that the issue of ND values is a difficult subject. 

An audience member asked EPA to clarify how ND values were treated in the 30 day 

average. EPA responded that ND values were noted, and then treated as numerical 
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values for averaging purposes. EPA requested industry to submit comments on different 

methods to account for variability during the upcoming comment period. 

EPA described the beyond-the-floor (BTF) process, and the 8 year residual risk review. 

An audience member asked if data were analyzed differently for area sources, or if 

economics were calculated differently for area sources. EPA responded that MACT is 

MACT, once MACT is chosen to apply to area source. EPA added that applying MACT 

to area sources is a case by case determination (referring to the source category, not 

individual sources). EPA referenced the boiler/process heater MACT area source 

determination. 

An audience member questioned if BTF calculations considered cost or greenhouse gas 

(GHG) impacts. EPA responded that the calculations used for BTF analyses incorporate 

cost and GHG emissions. 

EPA reiterated that the preamble issued with the proposed rule will detail data analyses

and that the technical memos will outline how the data were used. EPA discussed the 

CAA section 114 data collection, the VI supplemental resin sampling data set, problems

that arose during processing of the survey responses, declassified confidential business 

information (CBI), and the format of the upcoming VCM and ethylene dichloride (EDC) 

survey. 

An audience member asked if the databases used to calculate the MACT floor will be 

available. EPA responded that the databases may become available in the future, but not 

at the current time. An audience member responded that industry is very interested in 

looking at data used to calculate the MACT floors. 

EPA discussed issues that arose from companies reporting concentration for a single 

compound using multiple test methods. EPA reviewed the logic used in determination of 

which values to use for the MACT floor dataset. EPA stated that for the PVC survey 

EPA allowed flexibility in test methods, however; the VCM/EDC testing requirements 

will be much less flexible. An audience member questioned EPA, asking why the 

Agency did not just specify the test method with the lowest detection limits. EPA 

responded that there was uncertainty regarding the composition of emission streams and 

methods were chosen to try and reasonably capture all HAP in emissions streams. 

EPA described steps taken to standardize data submitted by facilities. EPA noted 

conflicting compound names and Chemical Abstract Services (CAS) numbers. EPA also 

discussed flow rate unit conversions. 

EPA briefly described the supplemental VI resin sampling data set. 

EPA presented the majority of HAP compounds found in the PVC emissions testing and 

resin sampling data. EPA discussed the issue of vinyl chloride surrogacy. EPA stated 

that a number of the compounds found in emissions and resin sampling data are 

carcinogenic. EPA also stated that some compounds were common to a majority of 

facilities, and other compounds were present at only a few facilities. 

An audience member asked if EPA analyzed removal efficiencies. EPA replied that 

removal efficiency was not evaluated for the control devices used for the process vents.
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An audience member stated that during a call between the EPA Assistant Administrator 

and Vinyl Institute, Peter Tsirigotis of OAQPS indicated that CDD/CDF levels from 

process vent emissions testing were low. EPA responded that no Agency personnel 

present participated on the conference call. 

An audience member asked if EPA used inlet data to determine MACT floors, indicating 

a review of the inlet data may eliminate the “not there/ND issue.” EPA referenced the 

upcoming proposal. 

An audience member asked if data submitted by facilities which were running a VCM

process during PVC testing were used in the MACT floor calculation. EPA confirmed 

that data from facilities running a VCM plant were included in the MACT floor 

calculation. EPA noted that the data were not necessarily present in the top 5 calculation, 

referring to the upcoming proposal. 

An audience member asked if all data for an analyte were labeled ND, if that analyte was 

removed from the list. EPA responded that the issue has been considered and requested 

industry to submit comments during the upcoming comment during the comment period. 

EPA presented proposed MACT standards (not numerical emission limits). EPA 

indicated that MACT would apply to area sources. EPA listed the emission points (e.g., 

process vents, resin, equipment leaks, etc.) and indicated that numerical limits and 

performance standards will be proposed for vinyl chloride, CDD/CDF, total HAP, and 

hydrogen chloride (HCl). EPA noted that the upcoming rule will include continuous 

emissions monitoring (CEMS) and continuous parametric monitoring (CPMS) 

requirements. EPA also stated the upcoming rule will include annual source testing. 

An audience member asked if total HAP included vinyl chloride. EPA confirmed that 

total HAP included vinyl chloride. 

An audience member asked if the emission limits were combined for incinerators and 

resin. EPA responded by reviewing which limits (e.g., HCl and CDD/CDF) applied to 

which emission sources. 

An audience member asked if EPA used different total HAP constituents for different 

emission sources. EPA responded that the data submitted by industry was used to 

determine the total HAP emission limits. EPA noted that industry will demonstrate 

compliance with the total HAP emission limit using Method 25A for total hydrocarbon 

(THC). An audience member pointed out that Method 25A is used for THC, not total 

HAP. EPA replied that THC would serve as a surrogate for total HAP. 

An audience member asked which method would be used for compliance with the resin 

sampling limits. EPA responded that a test plan will be used for compliance. EPA noted 

that time was not available to wait for a new method to be developed. EPA clarified that 

the Agency is asking for a monitoring plan which points to SW 846 methods for analysis 

and Method 107 for sample collection. An audience member asked if EPA was 

specifying analytes to test for. EPA replied that facilities will specify analytes in the test 

plan. An audience member asked which methods would be used to comply with HCl and 

CDD/CDF. EPA responded that Method 26 or 26A and Method 23, respectively would 
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be used to demonstrate compliance. EPA stressed that all information presented should 

be considered as draft and subject to change. 

An audience member asked how EPA handled startup, shutdown, and malfunction 

(SSM). EPA responded that facilities must be in compliance at all times. An audience 

member further questioned how EPA accounted for SSM in determining MACT floor 

limits. EPA responded that in 40 CFR Part 61, subpart F, facilities must always be in 

compliance. EPA stated that the new rule cannot be less stringent than part 61 and those 

requirements from part 61 will transfer over into the new rule. An audience member 

asked EPA to confirm that flexibility during SSM would not be removed. EPA referred 

to the upcoming proposal for discussion of SSM for opening losses. An audience 

member stated that the 10 parts per million (ppm) emission limit cannot be met when 

opening equipment after shutdown and questioned if the Agency was eliminating that 

flexibility. EPA responded that the Agency has taken such issues into consideration 

when setting limits. EPA added that during equipment openings, there will be an 

alternate standard, but that emissions will have to be controlled. EPA stated that the new 

rule could not be any less stringent that part 61. An audience member questioned if 

emission standards must be met at all times, were there circumstances that industry 

knows of that were not accounted for during setting the standard. EPA requested 

industry to submit comments during the upcoming comment period. 

EPA discussed annual testing requirements, CPMS, and CEMS. 

An audience member asked if CEMS equipment was commercially available. EPA 

responded that the equipment is commercially available, but that EPA is working on 

standards for using such equipment for compliance. 

An audience member asked if CEMS will be required over annual testing. EPA did not 

provide a response to the question. 

An audience member asked how EPA is handling shared incinerators. EPA responded 

that if a PVC unit is contributing to the incinerator inlet stream, that incinerator must 

meet the emission standards for PVC. 

An audience member asked if the upcoming rule will follow part 61 for wastewater 

standards. EPA responded that the upcoming rule will follow part 61 for wastewater 

standards. An audience member asked if a total organic HAP limit would be set for 

wastewater, which methods would be used to determine total HAP, and where the 

concentration is determined. EPA indicated that total HAP concentrations will be 

determined at the point of generation. EPA requested industry to submit comments 

during the upcoming comment period. EPA also noted that very little information 

regarding wastewater was submitted with survey responses. EPA indicated that the 

VCM/EDC survey will collect additional information on wastewater. An audience 

member commented that EPA did not ask for wastewater data in the PVC survey and any 

wastewater data provided was at the discretion of the facility.

EPA discussed the sub categorization of resin types for resin sampling. An audience 

member asked EPA to clarify the testing schedule for compliance. EPA indicated that 

testing for vinyl chloride will continue as required in part 61 and total HAP will be 

similar to vinyl chloride. An audience member stated that daily testing for total HAP was 
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not possible. EPA retracted the statement concerning the total HAP testing schedule and 

decline to provide any additional comment. 

An audience member questioned if part 61 is being replaced by the upcoming part 63 

rule. EPA responded that part 63 will be no less stringent than part 61. EPA stated that 

certain aspects of part 61, such as calculations, are being corrected. 

An audience member asked if part 63 will overlap with the organic liquids distribution 

(OLD) MACT. EPA referenced the uniform standards for equipment leaks and stated 

that the part 63 rule will not change current obligations with other regulations. An 

audience member pointed out that the OLD MACT overlaps with storage vessels in the 

PVC industry. EPA responded that the part 63 rule will address storage vessels. 

An audience member asked about the proposed regulations for heat exchangers and 

equipment leaks. EPA indicated that the proposed rule will reference applicable HON 

sections directly. 

An audience member asked EPA to confirm that the slide titled “What are we proposing 

to do,” which can be found in Attachment B, will be the extent of emission points 

covered by the upcoming rule. EPA responded that the only regulated emission source, 

in addition to part 61 will be maintenance wastewater. 

An audience member asked EPA to further discuss annual stack testing requirements 

related to CEMS or CPMS. EPA responded that CEMS require relative accuracy test 

audits. EPA added that CPMS systems require annual source testing for verification of 

operating limits. An audience member stated that their facility currently uses CEMS to 

monitor vinyl chloride emissions. EPA responded that the Agency did not want to 

impose additional unnecessary testing burdens on facilities currently using CEMS. 

EPA concluded the presentation at approximately 10:40 AM. Following the EPA 

presentation, the VI presented information regarding an alternative testing method for vinyl 

chloride resin. The following is a summary of the presentation and resulting discussion. 

The VI presented concerns regarding the PVC resin sampling campaign conducted in 

response to EPA’s Section 114 request. The VI stated that facilities did not have 

adequate time to standardize testing methods and resin sampling was performed without a 

standardized quality assurance project plan or standard operating procedures. 

The VI indicated that vinyl chloride concentrations as a result of Method 8260B were not 

as high as concentrations obtained using Method 107. The VI added that, in some cases, 

mass balances used to estimate emissions of HAP from resin resulted in negative values. 

The VI stated that if Method 8260B yielded low recovery for vinyl chloride, low 

recovery probably occurred for other HAP as well. The VI also added that compound 

concentrations may have been double counted in the original data set reported to EPA. 

EPA asked why Method 8260B resulted in lower recovery. The VI continued with the 

presentation to answer EPA’s question. 

The VI described an alternative method development project scope. The goals of the 

project were to develop a method as similar to published methods as possible, improve 

HAP recoveries within SW-846, simplify sample preparation steps, reduce the number of 
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methods and potential for contamination or loss, and provide a uniform way to adjust 

EPA’s current dataset based on an alternative method. 

The VI stated that properties of the resin matrix made accurate testing difficult. The VI 

added that a certain company conducted Method 8260B using Method 107 pretreatment,

heating the sample at 90 degrees Celsius (°C). The VI briefly described another 

technique that involved headspace analysis and solvent dissolution with gas 

chromatography and mass spectrometry (GC/MS) used during the resin sampling 

campaign. 

The VI presented a list of HAP potentially present in the resin slurry and those that were 

actually detected. The VI indicated that HAP were removed from the list based on 

knowledge that the HAP could not be present, or that in all resin sampling testing, the 

HAP was noted as ND. The VI then presented a “primary list of HAP” which was found 

regularly in the resin sampling data set. EPA asked the VI to clarify how the list was 

devised. The VI replied that the sampling plans provided the basis for the initial list, and 

HAP were eliminated based on process knowledge, water sampling, and resin sampling. 

EPA asked if the compounds presented were common across all facilities, or a majority 

of the facilities. The VI responded that the compounds eliminated were only detected a 

few times at one company and not at any of the others. The VI added that the compounds 

in the primary list were not necessarily detected at a majority of facilities. An audience 

member asked if HAP in the primary list were feeds or impurities found in the process. 

The VI responded that feeds and impurities were a starting point for the original HAP list. 

EPA asked if the list was only for suspension resin. The VI responded that the same 

exercise was executed for dispersion resin, but difficulties were encountered. The VI 

added that the process wasn’t impossible for dispersion resin. 

The VI turned the presentation over to Non Thomey from Environmental Chemistry, Inc 

(ECI). 

ECI described the timeline of their contract with the VI. Conceptual design began in 

June 2010, followed by phase I in July, August, and September. In October 2010, phase I 

was reviewed and phase II was planned. Phase II ran from November 2010 to January 

2011. 

ECI stated that Method 107 and Method 8260B were designed to be used on water and 

soil samples, and that issues arise when one applies the methods to a PVC resin matrix. 

ECI reiterated the vinyl chloride results were lower using Method 8260B as compared to 

Method 107. ECI described other methods including Method 8270, 8015, and 8315. ECI 

added that these methods generally require a specially trained chemist, special 

instruments, and a specially designed laboratory. ECI stated that PVC facilities are 

equipped to run Method 107, but do not have the equipment required for other methods. 

ECI expanded on the goals of the method development project, presenting the goal to

indentify the technical limits of current methods used to analyze the PVC matrix. ECI 

reiterated the goal of evaluating other methods which might lead to increased recovery 

and identification of better methods for methanol (CH3OH), acetaldehyde, acetophenone, 

and formaldehyde analysis. ECI stated that they aimed to reduce the number of methods 

used to analyze HAP in the PVC resin matrix. 
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ECI described Method 8260 CH3OH extraction. ECI stated that Method 8260 did not 

provide 100% extraction efficiency in the PVC matrix for vinyl chloride. ECI 

hypothesized that since vinyl chloride was not fully extracted, neither were other HAP. 

ECI described Method 8270. ECI stated that the required solvents dissolve low 

molecular weight PVC and that analysis is required at high dilutions which result in high 

detection limits. 

ECI described Method 8015. ECI stated that Method 8015 may result in over estimation 

of CH3OH because other compounds may be identified as CH3OH. 

ECI described Method 8315. ECI stated that the method is not offered by a majority of 

laboratories and that holding times were difficult to meet for large project orders. 

ECI described the methods which were analyzed during phase I. ECI considered the 

Georgia Gulf method where the resin sample was pretreated at 90°C, cooled to 40°C and 

purged. ECI also considered the OxyVinyls method where samples were continuously 

purged at 90°C, and a method deemed as “Hybrid Method 8260” (HM8260) where 

samples were pretreated at 90°C for 60 minutes and immediately purged at 90°C. 

ECI described methods analyzed for water soluble HAP. ECI described a method using 

tetrahydrofuran (THF) for dissolution of resin. ECI also described the National Council 

for Air and Stream Improvement (NCASI) Method 99.02 for formaldehyde and Method 

8015 with different variations to improve separation of CH3OH from other compounds.

ECI discussed the results of phase I testing. ECI stated that Method 8260 CH3OH

extraction results were lower than HM8260. ECI expressed concern regarding Georgia 

Gulf’s pretreatment process due to the cooling step and the fact that standards are not 

pretreated. THF dissolution was unsuccessful due to incomplete separation of CH3OH

formaldehyde and acetaldehyde. ECI stated that vinyl chloride results from HM8260 

were comparable to Method 107. ECI also indicated positive results using NCASI 99.02 

and analysis of acetophenone and acetaldehyde with HM8260. ECI concluded phase one 

by developing the HM8260 method for volatile HAP. ECI stated that moisture 

management during analysis was concerning due to the interaction of moisture with 

ketones and vinyl chloride, adding the auto-sampler used during analysis was not 

designed to handle large amounts of moisture. 

ECI described the purpose of phase II. Phase II was used to further develop and test 

HM8260. Phase II was also used to test alternate methods for acetaldehyde, 

acetophenone, and formaldehyde. ECI used phase II to attempt to resolve co-elution 

problems with CH3OH by Method 8015. 

ECI reported that HM8260 demonstrated robustness, precision, and accuracy, and 

correlated well with Method 107. ECI added that HM8260 could be used for 

acetophenone and acetaldehyde in a solid matrix, and Method 8260B could be used for 

acetaldehyde in a water matrix. ECI reported success with NCASI 99.02 for 

formaldehyde. 

ECI described the robustness testing of HM8260. ECI determined the concentration 

range, measurement reproducibility, and recovery of HM8260. ECI stated 4 different 
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manufacturing companies provided resin samples to aid in the analysis of HM8260; 3 

suspension resin samples and 1 dispersion resin sample. 

ECI described the detection and quantitation limit determination method used for 

HM8260. ECI used federal methodology to determine detection limits. ECI presented 

response factors and relative standard deviations (RSD) of the HM8260 tests. ECI stated 

that all recovery and calibration verification targets were met except for the recovery

target for tetrachloroethane due to the pretreatment resulting in degradation of 

tetrachloroethane to trichloroethane. 

ECI stated precision was acceptable and reported less than 30% difference in most cases. 

ECI noted that recoveries were acceptable when relative percent differences were greater 

than 30%. ECI also reported acceptable matrix spikes, with failures resulting from high 

recovery. ECI presented results from HM8260 and Method 107 for comparison. 

ECI discussed inadequacies of phase II. ECI stated that dispersion samples containing 

vinyl acetate were not able to be analyzed in large amounts. Samples were analyzed 

using a very small sample weight, but as a result, error was induced. ECI found that 

Method 8260 CH3OH extraction results were lower than HM8260 or Method 107. ECI 

also reported internal standard recovery issues for the dry resin matrix.

ECI concluded that HM8260 is not a perfect method because precision is sacrificed to 

improve accuracy. ECI reported increased recovery with HM8260 compared to Method 

8260B CH3OH extraction. ECI also stated more compounds were detected with HM8260 

(not able to test for a wider range of compounds, but with lower detection limits, one can 

detect more compounds). ECI recommended using HM8260 for HAP including

acetophenone and acetaldehyde except with dispersion resins containing high amounts of 

vinyl acetate. ECI recommended Method 8015 for CH3OH, but noted co-elution issue. 

ECI recommended NCASI 99.02 for formaldehyde. ECI reported total analysis duration 

of 1.5 hours, yielding a maximum of 3 to 4 samples analyzed per shift. 

The VI presented the following conclusions. Method 107 is the preferred method for 

vinyl chloride. HM8260 has not been demonstrated in other labs. Consistent methods 

should be used between regulatory development and compliance testing. The VI also 

added that some commercial labs might not be able, or willing, to run HM8260, and 

running HM8260 at a plant site would be very difficult. The VI stated that if HM8260 

was used to demonstrate compliance with the limits based on Method 8260B, facilities 

would be out of compliance based on higher recovery factors. 

EPA asked if the VI was requesting to use HM8260 as a replacement method. The VI 

responded that the intention of the study was to address issues discovered during the resin 

sampling campaign. 

EPA asked if the VI had a rubric to adjust the current dataset, and if the rubric would be 

ready by April 15th. EPA also asked if the VI would be able to collect and submit 

supplemental data before April 15th. The VI responded by asking EPA which test method 

EPA wants companies to use for compliance, adding that the court ordered deadline for 

rule proposal doesn’t match the timeline required for method development. 
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An audience member asked on which method the upcoming rule was based. EPA 

responded by stating information with such detail will be released during proposal. EPA 

stated their understanding was that the VI was working to develop a direct replacement 

for Method 107 or Method 8260. 

An audience member responded by stating Method 107 was preferred for vinyl chloride 

analysis and industry did not want to replace Method 107 at the plant level. The audience 

member added that Method 8260 could be replaced with consideration to what method 

the rule was based on. The audience member stated that the results to an analysis are 

always biased based on the method used to perform the analysis. 

An audience member stated that costs would be high to run a total organic HAP analysis 

method 3 times a day. EPA responded by asking what lab would perform the HM8260 

method on a quarterly basis. An audience member responded that there was not an 

answer to the question. The audience member added an estimate of cost for HM8260 at 3 

times the cost of Method 8260, but stated the estimate was an oversimplification and the 

cost was probably less. 

EPA asked if the VI planned to provide additional data regarding the HM8260 method by 

the end of the comment period. The VI responded by reiterating if EPA uses one method 

to determine the limit and another to determine compliance, industry will not be able to 

comply. EPA responded by requesting more data regarding HM8260. EPA added that 

the Agency could not endorse an alternate test method, or development of an alternate 

test method, without additional data. 

An audience member asked if EPA would reconsider floor levels based on new test 

method data. EPA responded by requesting additional data. EPA advised audience 

members that their concerns may change based on the proposed limits. An audience 

member responded that they must use 4 test methods to analyze total HAP. EPA 

responded by requesting industry to comment on how total HAP should be determined 

during the upcoming comment period. 

EPA asked if all companies performed resin testing. The VI responded that resin testing 

was not completed by Certain Teed and Dow. EPA asked which test methods were used 

for resin testing. An audience member responded that there were inconsistencies in the 

test methods used between companies, for example, the Georgia Gulf pretreatment step. 

The audience member added that the deficiencies of Method 8260 have been indentified 

and the industry wishes to improve the test methods. EPA asked if the new HM8260 

method had been compared to Method 8260. An audience member referred EPA to the 

presentation given by the VI and ECI. 

EPA asked if a compliance factor based on 3 days of testing using HM8260 would be 

adequate for facilities to comply. An audience member responded that more components 

would be detected at higher levels. EPA asked if 6 days would be an adequate amount of 

testing to develop a factor, adding variability is a result of the process in addition to the

test method. An audience member stated that to perform the comparison provided in the 

VI and ECI presentation, reproducibility was sacrificed. 

EPA stated that industry concerns of methods used to determine limits and methods used 

to determine compliance were understood, but reiterated that EPA was required to 
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propose limits in April of 2011. An audience member stated that additional data would 

not be available by April. 

An audience member pointed out that EPA required testing based on individual HAP, but 

EPA is now setting limits on total HAP. The audience member added that Method 8260 

will not provide total HAP, only important ones. EPA responded that the Agency must 

account for total HAP. An audience member responded by stating industry efforts will 

need to be “tightened up,” but that it appeared that EPA was willing to listen. 

An audience member asked if the proposed rule will specify methods for compliance. 

EPA responded that the proposed rule will specify methods for compliance. 

An audience member asked if EPA would consider a list of “top 10” HAP, determined on 

a facility basis, and periodically re-evaluated. EPA indicated that a “top 10” list would 

become a heavily debated legal issue. An audience member stated that the proposed 

Portland Cement rule did something similar and asked how the list was determined. 

Another audience member added that initial testing was performed under the thought of 

“what’s in there?” but argued that industry shouldn’t have to prove that a compound isn’t 

present every day. 

EPA requested methods for measuring pollutants of concern. EPA also asked if industry 

wished to help write the upcoming rule. An audience member responded, with 

enthusiasm, “yes. “

EPA discussed surrogacy and the legal issues surrounding the use of surrogacy. An 

audience member responded that they would like to use total volatile organic compounds 

as a surrogate to demonstrate compliance, but asked EPA how to arrive at that solution. 

EPA requested a method and supporting data. The audience member added that different 

labs test for different compounds using Method 8260. The audience member emphasized 

that they want to demonstrate compliance, correctly, and without question. 

An audience member stated that large amounts of vinyl chloride concentration data are

available, as the data have been collected for a number of years under part 61. EPA 

responded by stating compliance data is held at the state level and some data are more 

easily accessed than others. EPA discussed the ERT. 

An audience member asked if a copy of the preamble was available. EPA responded that 

a copy would be available one day after signature of the upcoming rule. 

EPA again asked how long it would take to compile comparison data for HM8260. An 

audience member responded that the only lab (ECI) available to run HM8260 could 

process a maximum of 8 samples per day. EPA reiterated that if data were submitted 

during the comment period, the data would have a better chance of being considered 

during the rulemaking process. An audience member asked why a placeholder could not 

be used for the resin limit in the rule. EPA responded that changing a rule after 

promulgation would require a federal register notice. EPA requested a copy of the 

HM8260 procedure. 

An audience member expressed concern that if the rule is written using Method 8260 and 

EPA decides that Method 8260 is biased low and requires a higher recovery method for 

compliance, then industry will not be able to meet the limits. Another audience member 
Memorandum

p. 13 of 15

stated that if the vinyl chloride limit was set using Method 8260, compliance would be 

impossible using Method 107. 

The PVC section of the discussion ended at approximately 2:35 PM. The VCM/EDC 

discussion began at approximately 2:50 PM. 

EPA confirmed that all facilities received a revised draft test plan for VCM on Monday 

February 14th. All facilities confirmed. 

An audience member stated that the testing and surveys were impossible to complete by 

the July 1st deadline. The audience member stated that additional funding and lack of a 

reasonable planning period would hinder efforts. EPA and audience members discussed 

the timeline as a result of recent EPA initiatives and legal actions. An audience member 

stated that industry tried to match EPA’s regulatory calendar, but felt that items 

surrounding VCM/EDC were put on a tight deadline. 

EPA stated sufficient data exist for most sectors, but not VCM. An audience member 

stated that EPA has a large amount of data for VCM as a result of the VCM NESHAP 

and Hazardous Organic NESHAP (HON). 

An audience member requested additional guidance on using previously acquired data in 

response to the VCM/EDC survey. The audience member specifically discussed the 

requirement of previously approved test data, adding that they rarely receive an 

“approval” on any data submitted to EPA. EPA responded by clarifying that approval 

relates to regulatory testing data. EPA added that engineering study data was not 

acceptable. An audience member responded by requesting feedback on test plans. EPA 

and audience members continued to discuss the issue of “data approval.” EPA stated the 

language in the previous data requirement might change to “performance test data to 

demonstrate compliance which was accepted.” EPA added that if a facility is not notified 

that data submitted were not acceptable, then the data were accepted. 

EPA confirmed that facilities should not submit information regarding hazardous liquid 

waste incineration units. 

EPA confirmed that the data collection request was in response to a MACT rulemaking 

effort. An audience member asked for an explanation to give to company management 

when requesting funding. EPA advised companies to use MACT as a rationale to request 

additional funding. 

An audience member asked if testing was required on incinerators that combust 

combined liquid and process vent streams. EPA did not directly respond to the question.

EPA stated the Agency would clarify what type of control devices will be required to 

provide test data in the VCM/EDC test plan. 

An audience member asked if the 5 year requirement for previously conducted stack test 

was a “hard and fast” rule. EPA responded that the Agency will consider data past 5 

years, but no later than 6 years. 

An audience member requested the turnaround time for waiver request approvals. EPA 

responded that turnaround times were based on the completeness and organization of 

facility submissions. 
Memorandum

p. 14 of 15

An audience member asked if test plans were required to be approved. EPA clarified that 

test plans were not required to be approved and the testing memo would be clear enough 

not to require submission of a test plan. 

An audience member asked what would become of part 61 once the new VCM NESHAP 

was promulgated. EPA responded that once the new chemical sector rule was proposed, 

part 61 will no longer apply to VCM. 

An audience member asked if EPA was changing the HON specifically for VCM/EDC. 

EPA responded that limits would be set for EDC and VCM. EPA added that 

requirements would be the same as the HON. 

EPA and the audience briefly discussed other chemical sector rules. 

An audience member asked for an explanation of what changed since the residual risk 

assessment. EPA stated startup, shutdown, and malfunction issues, brick MACT, and 

technology reviews have changed since the residual risk assessment. 

An audience member asked if the dioxin issue was related only to VCM/EDC/PVC. EPA 

stated that the issue was not related to only VCM/EDC/PVC, but an audience member 

responded that the situation appeared as if it was. 

EPA briefly described the current plan for uniform standards rulemaking for equipment 

leaks, closed vent systems and control devices, storage vessels and transfer operations, 

wastewater and heat exchangers. 

An audience member asked if new source performance standards (NSPS) would be 

incorporated into the new rule. EPA did not provide a direct response. An audience 

member asked if the consolidated air rule (CAR) would apply. EPA responded that CAR 

would not apply. EPA added clarification that the uniform standards are only referenced

by other rules and that burden will show up with other rules. An audience member 

responded that burdens will therefore not be immediately apparent, but still exist and will 

eventually affect industry. 

An audience member asked how to participate in development of the uniform standards. 

EPA responded that uniform standards will be promulgated with other rules and the 

ability to comment is contained in those proposals. EPA stated that industry will be able 

to comment when an applicable rule points to the uniform standards. EPA also added 

that the standard standards have been used for 20 years and a number of rules reference 

the standard standards. 

An audience member asked if VCM/EDC would be the first to point to the uniform 

standards. EPA replied that refinery heat exchangers have pointed to the uniform 

standards. An audience member stated that part 63 referencing part 64 appears to be busy 

work. 

An audience member asked if EPA was proposing uniform standards in the summer of 

2011. EPA did not provide a direct response. An audience member asked EPA to clarify 

the framework. EPA responded by stating subpart UU level 2 was used as a model for 

equipment leaks and that subpart TT might be used as well. EPA stated that the uniform 

standards were in draft form and under development. 
Memorandum

p. 15 of 15

An audience member asked why EPA removed the wastewater testing requirement from 

the VCM/EDC testing plan. EPA responded that time was the deciding factor. An 

audience member responded that information was available from previous testing. 

A recess was taken at approximately 3:55 PM. A number of EPA and ERG personnel 

left the meeting for return flights, but the meeting continued until 5 PM. 
Attachment A

Attachment A

EPA Presentation: “PVC Industry Workshop” February 16, 2011 Baton Rouge, LA
February 16, 2011

Baton Rouge, LA

A-1
A-2
 Section 112(d) of the CAA 

◦ Set HAP emissions standards for major sources 

based on maximum achievable control technology 

(MACT)

◦ For existing sources, MACT standards must be at 

least as stringent as the average of the 5 best 

performing sources for source categories with less 

than 30 sources 

◦ For new sources, MACT standards must be at least 

as stringent as the best controlled similar source 

◦ MACT floor is the level of minimum stringency

◦ Costs or other impacts may not be considered

A-3
 MACT assessment can be based on:

◦ Actual emissions data

◦ Knowledge of the air pollution control in place in 

combination with actual emissions data

◦ Federal and State regulatory requirements that may 

enable us to estimate the actual performance of the 

regulated units and other relevant emissions 

information

 MACT assessment involves a review of actual 

emissions data with an appropriate 

accounting for emissions variability 

A-4
 Variable conditions are considered in 

determining the level of emission control that 

has been achieved by the average of the 

best-performing 5 units

 Floors may be set at a level that bestperforming sources can expect to meet

 The types of variability accounted for include 

operational distinctions between and within 

tests of the same unit

A-5
 Variability can be accounted for using 

statistical methods to determine MACT Floor 

emission standards

 Upper Prediction Limit (UPL)

◦ A prediction interval for a future observation is an 

interval that will, with a specified degree of 

confidence, contain the next randomly selected 

observation from a population

◦ The prediction interval estimates what future values 

will be, based on present or past background 

samples taken

A-6
◦ Represents the value the mean of 3 future test run 

observations (3-run average) can be expected to 

fall below, based on the results of the independent 

sample of size (n) from the same population

A-7
 114 Data included:

◦ Below detection levels

◦ Above detection levels

◦ Detection levels

 The highest test-specific MDL reported in a 

data set that is also <= the average emission 

calculated for the data set was indentified

 The value equal to 3x the representative MDL 

was determined and compared to the 

calculated 99 % UPL value

A-8
 If 3x the representative MDL were < than the 

calculated UPL value, the measurement variability is 

adequately addressed and the calculated UPL is 

used

 If the value = to 3x the representative MDL was > 

than the calculated UPL value, the calculated UPL 

value does not account entirely for measurement 

variability and the MDL is used assuring that the 

floor emission limit accounts for measurement 

variability and imprecision

A-9
◦ Consider whether more stringent beyond-the-floor 

standards are achievable, considering costs, non-air 

quality health and environmental impacts and energy 

requirements

◦ MACT standards may be set for area sources

◦ The Administrator may elect to promulgate for area 

sources “generally available control technologies or 

management practices” (GACT) standards

◦ Emission standards must be reviewed, and revised as 

necessary (taking into account developments in 

practices, processes, and control technologies), no 

less often than every 8 years

A-10
A-11
 CAA Section 114 sent to PVC Industry

◦ Survey

◦ Testing 

 Stack testing

 Resin sampling

◦ Historical data (ex. existing stack testing)

 VI sent supplemental resin sampling

A-12
 Multiple versions of survey data were 

submitted

 Nine companies submitted CBI data

◦ Several forms were declassified as non-CBI

 Data was imported into MS Access database

 Several facilities modified Excel forms

◦ Form structure was corrected

◦ Data was not changed

A-13
 Corrections made

◦ Blank or duplicative records were removed

◦ Control equipment gas flow rates standardized 

◦ CAS numbers or compound names

◦ Mass concentration data converted to volumetric 

concentrations 

◦ Multiple emission concentrations reported for single HAP 

due to overlapping test methods

A-14

Methods Used to Report Compound Result Selection Criteria

Method 0031 & Method 0010 Method resulting in higher 

concentration

Method 320 and Method 0031 Method 0031

Method 23/23A & Method 0031 Method 0031

Method 320 & Method 0010 Method 0010

Method 26A & Method 320 > 1 ppm; Method 26A

< 1ppm; Method 320
 Resin sampling data received from February 

2010 until August 2010

 Mass of compounds required but 

concentrations were reported by several 

facilities

 VI submitted resin data in concentration form 

for members and non-members

 Corrections made

◦ Blank or duplicative records were removed

◦ CAS numbers or compound names

A-15
Stack Testing HAP* Resin Sampling HAP*

1,3 Butadiene**

2,2,4 Trimethylpentane

Acetaldehyde**

Chloroform

Cumene

Dioxin/furan

Ethyl Chloride

Ethylene Dichloride**

Ethylene Glycol

Formaldehyde**

Hydrogen Chloride 

Methanol

Methyl Chloride**

Phenol

Vinyl Acetate 

Vinyl bromide**

Vinyl Chloride**

Vinylidene chloride

1,3 Butadiene**

Acetaldehyde

Cumene

Ethyl Chloride

Ethylene Dichloride**

Formaldehyde**

Hydroquinone

Methanol

Methyl Chloride**

Toluene

Trichloroethane

Vinyl Acetate

Vinyl Chloride**

* Bolded HAP are in both lists.

**Known or probable carcinogens.

A-16
A-17
 Set MACT for all sources (major and area):

◦ Process vents 

◦ PVC resin sampling

◦ Equipment leaks

◦ Process wastewater

◦ Heat exchangers

◦ Storage Vessels

◦ Other Emission Sources (Opening losses and loading/unloading 

operations)

 Set emissions limits for:

◦ Vinyl chloride

◦ Total organic HAP

◦ Dioxin & furans (as TEQ)

◦ Hydrogen chloride (HCl)

 Set monitoring requirements:

◦ Continuous emissions and parametric monitoring 

◦ Annual source testing

A-18