Memorandum

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MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford

, ERG

DATE: March 3 , 201 1

SUBJECT: S ummary of February 1 6

, 201 1 US EPA Industry Meeting in Baton Rouge

,

LA

1.0 Introduction

On February 1 6 , 201 1

, EPA held an industry in formation 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 pollutant s (NESHAP) as well as the Clean Air Act (CAA) section 114 vinyl chloride monomer (VCM) information request.

2.0 Date and Location

February 1 6 , 201 1

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 Th omey Environmental Chemistry Amy Marshall URS

Kevin Bloomer Westlake

Allen Bodron Westlake Reed Mackay Georgia GulfMemorandum

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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 A M 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 me eting. 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 durin g the meeting

. EPA briefly described the process to determine maximum achievable control technology (MACT) floor s , 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 inc inerator 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.Memorandum

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EPA di scussed 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 yea rs 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 v ariability 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

unk nown 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 accou nted for new products, requesting that facilities be able to petition for new raw materials. EPA stat ed 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 futu re. 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 w ould 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 assume s tha t 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

o nly 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

aver age. EPA responded that ND values were noted, and then treated as numericalMemorandum

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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 b eyond

- 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 audienc e member questioned if B TF 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 de tail 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, declassifie d 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 wi ll 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 t hat 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 metho ds, 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 t he 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 Serv ices (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 discusse d 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.Memorandum

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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 c alculation. EPA confirmed that data from facilities running a VCM plant were included in the MACT floor

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

r eferring 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 upco ming 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 i f total HAP included vinyl chloride. EPA confirmed that

total HAP include d vinyl chloride.

An audience member asked i f the emission limits were combined for incinera tors and resin. EPA responded b y 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 so urces. 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 t est 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 coll ection. 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 Met hod 26 or 26A and Method 23, respectively wouldMemorandum

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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 malfuncti on (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 P art 61

, subpart F, facilities must always be in

c ompliance. EPA stated that the new rule cannot b e 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 referre d 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

flexibi lity. 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 incinerato rs. 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 t hat 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 indi cated 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 re sponses. 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 facili ty.

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 wasMemorandum

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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 question ed 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 O LD 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 propose d 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 rela tive 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 Agen cy 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 faciliti es 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 Metho d 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 vi nyl 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 cont inued 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 ofMemorandum

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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 accu rate 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 disso lution 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 fr om 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 acr oss all facilities, or a majority of the facilities. The VI responded that the compounds eliminated were only detected a

few times a t one company and not at any of the others. The VI added that the compounds in the primary list were not necessarily detec ted 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 p resentation 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 rev iew ed 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.

E CI 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

instr uments, 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
ind entify the technical limits of current methods used to analyze the PVC matrix. ECI

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

and identification of better methods for methanol ( CH 3 OH ), 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.Memorandum

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ECI described Method 8260 CH 3 OH extraction. ECI stated th at Method 8260 did not provide 100% extraction efficiency in t he 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 requir ed at high dilutions which result in high

detection limits.

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

of CH 3 OH because other compounds may be identified as CH 3 OH

.

ECI described Method 8315. ECI stated that t he 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 w h ere the resin sample wa s pretreated at 90°C, cool ed 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 immedia tely 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 form aldehyde and Method 8015 with different variations to improve separation of CH 3 OH from other compounds.

ECI discussed the results of phase I testing. ECI stated that Method 8260 CH 3 OH 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 CH 3 OH 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 l arge 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 r esolve co

- elution problems with CH 3 OH 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 recove ry of HM8260. ECI stated 4 differentMemorandum

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manufacturing companies provided resin samples to aid in the analysi s 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 deviation s (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 resultin g 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 anal yzed using a very small sample weight , but as a result, error was induced. ECI found that

Method 8260 CH 3 OH extraction results were lower than HM8260 or Method 107. ECI also reported internal standard recovery issues for the dry resin matrix.

ECI conclud ed that HM8260 is not a perfect method because precision is sacrificed to improve accuracy. ECI reported increased recovery with HM8260 compared to Method

8260B CH 3 OH 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 includ ing acetophenone and acetaldehyde except with dispersion resins containing high amounts of vinyl acetate. ECI reco mmended Method 8015 for CH 3 OH , but noted co

- elution issue

. ECI recommended NCASI 99.02 for formaldehyde. ECI reported total analysis duration of 1.5 hours, yield ing a maximum of 3 to 4 samples analyzed per shift.

The VI presented the following conclusi ons. 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 b e 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 rec overy 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 t he current dataset, and if the rubric would be ready by April 15 th . EPA also asked if the VI would be able to collect and submit supplemental data before April 15 th . 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.Memorandum

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An audience member asked on which method the upcoming rule was ba sed . 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 statin g 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 replace d with consideration to what m ethod

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 l ab 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 a n 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 an other 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 addition al 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

me mber responded that they must use 4 test methods to analyze total HAP. EPA responded by request ing 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 Ge orgia Gulf pretreatment step.

Th e 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 memb er 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 high er 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 p resentation, 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 toMemorandum

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propose limits in April of 2011. An audi ence 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 th at Method 8260 will not pr ovide total HAP , only important ones. EPA responded that the Agency must
account for total HAP . An au dience member responded by stating industry efforts will

need to be “tighten ed up,” but that it appeared that EPA was willing to l isten.

An audience me mber 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 per iodically 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 as ked how the list was determined.

Another audience member added that initial testing was performed under the though t 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 i f indus try 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 orga nic 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 av ailable 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 82 60 is biased low and requires a higher recovery method for compliance, then industry will not be able to meet the limits. Another audience memberMemorandum

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state d that if the vinyl chloride limit was set using Method 8260, compliance would be impossible using Metho d 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 14 th . All facilities confirmed.

An audience member stated that the testing and surveys were impossible to complete by the July 1 st deadline. The audience member stated that additional funding and lack of a reasonable planning period would hinder efforts. E PA and audience members discussed the timeline as a result of recent EPA initiatives and legal actions. An audience member stated that industry trie d 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 o n 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 ap proval.” 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 we re 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 e xplanation 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 incinerator s that combust combined liquid and process v ent 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 tim es 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

no t 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.

A n 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 a sked 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 standa rds 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 r ule. 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 st andards. 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 exchanger s 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 stat ing 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 devel opment.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 r ecess 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

- 1A

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#  

# 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

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#  

# 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

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#  

# 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 best

performing sources can expect to meet

 

# The types of variability accounted for include operational distinctions between and within
tests of the same unit

A

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#  

# 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

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# ◦ 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

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#  

# 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

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##  

# 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

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# ◦ 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

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#  

# 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

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#  

# 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

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#  

# 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

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## 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

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# 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

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###  

# 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

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