MEMORANDUM

TO: Voluntary Program Participants 

FROM: Samantha Lewis, EPA 

 

DATE: October 24, 2006 

SUBJECT: Meeting Minutes for the EPA and Trade Group Discussion on the Proposed 

Voluntary VCM Site Program

 EPA met with The Vinyl Institute (VI), The American Chemistry Council (ACC), and 

several member companies on Tuesday, October 10, 2006, to discuss the industry’s proposed 

voluntary program for vinyl chloride facilities. The list of attendees can be found in Appendix A. 

Appendix B shows the slides for industry’s presentation. 

 The meeting followed the agenda below: 

• Introduction; 

• Presentation of proposal; 

• Discussion; and 

• Next Steps. 

The meeting is summarized below: 

Introduction

 Mr. Frank Borelli of VI started the meeting by introducing the proposed voluntary 

program. The program will include 13 vinyl chloride manufacturing facilities: 

1. Dow Chemical, Freeport, TX; 

2. Dow Chemical, Plaquemine, LA; 

3. Formosa Plastics, Baton Rouge, LA; 

4. Formosa Plastics, Point Comfort, TX; 

5. Georgia Gulf, Lake Charles, LA; 

6. Georgia Gulf, Plaquemine, LA; 

7. OxyChem, Ingleside, TX; 

8. OxyVinyls, Deer Park, TX; 

9. OxyVinyls, LaPorte, TX; 

10. PPG, Lake Charles, LA; 

11. Shintech, Plaquemine, LA; 

12. Westlake, Calvert City, KY; and 

13. Westlake, Geismar, LA. 

These 13 facilities account for 97 percent of vinyl chloride manufacturers in the U.S. The VI 

decided to focus the program on vinyl chloride manufacturers because industry suspects that the 
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oxyhydrochlorination (OHC) process to produce EDC is the largest dioxin source in the CCH 

manufacturing segments. The program initially attempted to isolate the OHC process. However, 

the VI determined that it was not possible to isolate OHC streams at all facilities and decided that 

the program will view the facilities as a whole. Therefore, the program will also include 

discharges from chlor-alkali operations at these sites (85 percent of U.S. chlor-alkali production 

according to industry), as well as discharges from other chlorinated hydrocarbon manufacturing 

processes on site. 

 The VI used the Integrated Pollution Prevention and Control (IPPC) Reference Document 

on Best Available Techniques in the Large Volume Organic Chemical Industry as the basis for the 

voluntary proposal.1 The document identifies a BAT concentration of 0.1ng /L TEQ for dioxin 

congeners in EDC wastewater. This concentration was based on an EDC plant in Germany that 

discharges 1μg TEQ per ton of OHC capacity. 

Voluntary Proposal

 Mr. John Westendorf of OxyChem presented the Voluntary Proposal. Under the 

voluntary program, the thirteen sites will agree to achieve dioxin and furan discharges of 0.1 ng/L 

TEQ on a collective basis. This means that the average discharge for the thirteen facilities will be 

equal to or less than 0.1 ng/L TEQ. Ms. Mary Bachynsky of Formosa Plastics explained that 

setting limits for each facility to meet this goal will consist of a two-step process: 

• Industry will establish the baseline discharges. Some facilities have extensive 

dioxin monitoring data that they can use to set a baseline. Other facilities will 

need to conduct sampling to determine their baseline discharges. 

• Industry will determine the necessary reductions for each facility. 

To convert the 0.1 ng/L TEQ into mass limits, industry will define a facility flow rate consisting 

of dry-weather discharges of process streams. In addition to wastewater streams from 

manufacturing processes, VI would like to include: 

• Scrubber water from combustion units – According to Mr. Westendorf, this is a 

known source of dioxin at several EDC/VCM plants but was excluded from the 

EU BAT; and 

• Cooling tower blowdown – Mr. Jason Campbell of PPG stated that this can be a 

source of dioxin if facilities add chlorine to the cooling tower for disinfection. 

Industry’s goal is to capture all streams that potentially contain dioxin. VI will develop a 

definition for process wastewater for discussion with EPA. 

 

1

 The Integrated Pollution Prevention and Control (IPPC) Reference Document on Best Available Techniques in the 

Large Volume Organic Chemical Industry can be accessed online at http://eippcb.jrc.es/pages/FActivities.htm.
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 Mr. Campbell stated that industry would like EPA to stop work on the Effluent 

Limitations Guidelines (ELG) rulemaking process as an incentive for the voluntary program. 

Facilities are concerned about the level of effort required to complete the questionnaire. In 

addition, industry would like EPA to stop any additional sampling episodes since this is also 

burdensome for the facilities. 

 Mr. Westendorf added that the sampling conducted under the voluntary program may be 

superior to the EPA sampling trips because sampling will occur over a longer period of time. Mr. 

Westendorf stated that the one-week CCH sampling episodes conducted by EPA do not account 

for long-term variations. EPA would receive sampling data from all 13 facilities, rather than the 

limited number of facilities in the EPA sampling program. The dioxin discharges and reductions 

that result from the voluntary program will be reflected in the facilities’ annual TRI reports. 

 Mr. Westendorf also stated that the timeline for the voluntary program will be faster than 

the schedule for the ELG process. Industry’s goal is to implement the voluntary program by 

2011. VI will be responsible for implementing the program. The CCH ELG process is currently 

scheduled to go final in 2011. However, the final ELGs will not be incorporated into permits for 

a few years. Mr. Bob Elam of ACC added that the voluntary program ensures that something will 

be implemented to control dioxin discharges for this industry. If EPA moves forward with the 

ELG process and is unable to justify an ELG, then nothing will be implemented. 

Discussion

 Ms. Mary Smith, Director of the Engineering and Analysis Division, provided her initial 

reaction to the proposal. Ms. Smith stated that it is clear that a lot of work has been done to 

develop this proposal. However, there are several details that require further development. If 

EPA were to agree to a voluntary program, EPA would need to provide the basis for the decision 

in the 2008 ELG Proposal by: 

• Demonstrating that industry is using new practices to achieve reductions under the 

voluntary program; 

• Showing that the program is verifiable; 

• Explaining the methodology of averaging discharges from 13 facilities; 

• Addressing concerns of potential geographical “hot spots” that may result from the 

averaging method; 

• Showing that the voluntary program timeline will be implemented sooner than 

EPA’s ELG schedule; and 

• Defining the scope to show that the program will cover most of the scope of the 

CCH ELG rulemaking. 
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 Ms. Jan Goodwin of EPA led the following discussion between EPA and industry 

representatives: 

How frequently will facilities be required to monitor their dioxin discharges? 

Industry has not yet developed monitoring requirements for the program. 

Once industry reaches the goal of 0.1 ng/L TEQ, will facilities continue to reduce 

dioxin discharges? 

Mr. Campbell stated that facilities are constantly evaluating and looking to reduce 

discharges that they report to TRI. As a result, he expects that reductions will continue to 

occur on their own. 

What is the incentive for compliance? 

Other plants involved in the program will pressure facilities to maintain compliance with 

their discharges. Industry believes that this “peer pressure” will provide incentive. In 

addition, if EPA determines that facilities are not complying with the voluntary program, 

EPA could always resume the ELG rulemaking effort. 

Will facilities conduct sampling of individual process streams? Will there be a focus 

on treating at the most concentrated point? EPA is concerned that dioxin may be 

diluted at the facilities’ outfalls. 

Mr. Campbell replied that facilities will most likely need to conduct upstream sampling to 

determine where it will be most economical to install treatment technologies. Mr. Borelli 

added that the purpose of the voluntary program is to achieve a certain level of 

performance – not to identify process sources of dioxin. 

What data will be used for determining baseline discharges? 

Mr. Westendorf stated that industry will need to develop a set of criteria for data that will 

be used to develop baseline loads. Industry will develop a quality assurance project plan 

(QAPP) that outlines the criteria, which will include the following at a minimum: 

− Analytical method used; and 

− Detection level criteria. 

Next Steps and Further Issues

 Following the discussion, EPA and industry representatives agreed to the following 

schedule for deliverables and next steps: 

• 18 October 2006 – Conference call to discuss definition of process wastewater; 

• 20 October 2006 – Finalize definition of process wastewater; 

• 15 November 2006 – Provide a rationale for excluding PVC facilities from the 

voluntary program; 
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• 01 December 2006 – Provide target reduction for list of facilities and formal 

proposal; and 

• 15 January 2007 – Provide QAPP for baseline development data. 

In addition to the above list of deliverables, EPA identified the following unresolved issues from 

the discussion of the voluntary proposal: 

• The program has not established requirements for monitoring frequency. 

• The program needs to address the issue of potential “hot spots.” If the group of 13 

facilities is collectively held to achieve an average discharge of 0.1 ng/L TEQ, then 

some facilities will discharge more than 0.1 ng/L TEQ and some facilities will 

discharge less. If the facilities discharging more than 0.1 ng/L TEQ are located in 

the same area, some regions may receive a disproportionate amount of the load. 

• EPA is concerned that dioxin will be diluted at the final outfall, which is the 

proposed monitoring location for the voluntary program. 

• The program does not address other pollutants, such as mercury discharges from 

mercury cell chlor-alkali plants. 

• EPA requests a description of the roles that VI, ACC, EPA, and member facilities 

will play in the program development. 
Appendix A 

Meeting Attendance Record for October 10, 2006 

Appendix B 

Presentation Slides for Voluntary Program Proposal