### MEMORANDUM

TO: Voluntary Program Participants

FROM: Samantha Lewis, EPA

DATE: June 22, 2007

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to D iscuss the

Proposed Voluntary VCM Program (15 June 2007)

EPA participated in a teleconference with The Vinyl Ins titute (VI) and several member companies (referred to as the Vinyl Chloride Producers , or VCP) on June 15, 2007 to continue discussions on EPA’s Draft Generic Sampling P lan (GSP), which describes the procedures that facilities should follow in conducting the voluntary monitoring program (VMP). The list of meeting participants can be found in Attachme nt A.

Background

EPA and the VCP met on March 14, 2007 to discuss the VCP’s proposed VMP for vinyl chloride manufacturers. Industry had proposed collec ting dioxin and furan and total suspended solids (TSS) data for facilities’ final outfalls at a frequency of one sample per month for nine months. At the March 14 meeting, EPA expressed co ncern about the potential for dilution at the final outfall since many of the faciliti es discharge wastewater from non-CCH manufacturing operations. EPA prepared a generic sampling p lan to describe their suggested approach for sampling and provided it to industry for discussio n and comment. EPA also included example diagrams which describe EPA’s rationale f or selecting sampling points. For facilities where CCH wastewater is commingled with no n-CCH wastewater, EPA is requesting that the facility collect a sample prior to the mixi ng point. EPA noted that the number of sampling points will depend on the facility’s manufacturin g processes and process flow diagrams. EPA is requesting that industry collect at least four sam ples at each sampling point, each collected at least one month apart.

EPA met with the VCP to discuss initial comments on th e GSP on May 22, 2007. The VI provided a revised draft of the GSP to EPA on May 18, 2007. The VI provided additional comments on June 15, 2007.

Teleconference Discussion

The focus of the discussion was on the goals and object ives of the VMP. The VCP continues to have concerns about the primary and secondar y objectives. In addition, the VCP would like to finalize the GSP prior to initiating discussio ns with individual member companies on their site-specific plans.2

Mary Bachynsky, Formosa, outlined what the VCP believes are the goals of the

VMP:

• Establish a quantifiable baseline of dioxins and furans (dioxi ns) at the point

of discharge;

• Understand the sources of the dioxins; and

• Understand the dioxin reductions due to treatment.

The VCP would like to see a more detailed discussion of EP A’s objectives in the GSP. They

would also like to see a discussion of how EPA intends to use the data and model treatment for the large, integrated sites which are collecting samples prior to the treatment system. The VCP plans to collect and submit data for final outfalls in additi on to the points requested by EPA.

EPA agrees with the VCP’s assessment of the program goals. EPA also agrees that industry can provide final outfall data as part of this program. Because discharges from CCH operations may be commingled with non-CCH wastestreams prior to treatment, EPA is requesting samples prior to the point of mixing and will model the effects of treatment using EPA sampling data and other treatment information. EPA will apply r eductions from treatment units similar to the site’s treatment when modeling the affects of trea tment. EPA will compute a baseline discharge for each facility. EPA can then evaluate t his baseline and compare it to the VCP’s proposed limits or the European Union (EU) standard. Fran k Borrelli noted that the EU is conducting a survey to determine how the EU standard is being im plemented at VCM facilities

and whether it needs to be modified.

The VCP would like EPA to provide additional details on th eir modeling methodology in the GSP. In particular, the VCP would l ike EPA to articulate how it will calculate annual discharges and daily maximums using the sa mpling data provided. The VCP also would like the GSP to include information about insuring consistency across the program, both in terms of how to define normal operations and how to determine flowrates. EPA will have discussions with each facility about determining normal ope rations and flows, but it will be up to the facility personnel to decide when to collect sample s that represent normal operations and how to compute flowrate. EPA will use the flowrate to comput e a mass load; however, EPA realizes

that not all streams will have a flowmeter installed a nd that it may be necessary to use engineering judgment when providing the flowrate.

The VCP wanted to clarify which PVC facilities are i ncluded in the VMP. There are two facilities that EPA included in the site-specifi c plans that are actually stand-alone PVC

facilities. The VCP stated that if EPA intends to co llect information on stand-alone PVC facilities, they may have additional facilities that EPA should consider. EPA stated they would be willing to hear the VCP’s suggestions. The VCP reiterate d that they would like a clear understanding of EPA’s objectives in collecting this additi onal data.3

Next Steps

1. Samantha Lewis will provide comments on the VCP’s revis ed GSP.

2. EPA and the VCP tentatively agreed to have a face-to-fa ce meeting on July 11 to finalize

the GSP.

3. After the GSP has been finalized, EPA will work with i ndividual companies to finalize their site-specific plans. EPA will insure that commen ts on the GSP are transferred to the site-specific plans.Appendix A. List of Participants

EPA /Industry Teleconference on Generic Sampling Plan

June 15, 2007

Name Company Contact Information

Janet Goodwin EPA 202-566-1060

Josh Hall EPA 202-566-1002

Ann Johnson EPA 202-564-5966

Samantha Lewis EPA 202-566-1058

Dwain Winters EPA 202-566-1977 Mary Bachynsky FPC USA 973-716-7342 Chris Baldridge Dow 225-353-6252 Tom Berger Keller & Heckman 202-434-4285 Frank Borrelli Vinyl Institute 703-741-5668 Jason Campbell PPG 337-708-4450

Toni Jett Westlake 270-395-3571 Jeff Longsworth Barnes & Thornburg 202-408-6918 John Westendorf OxyChem 972-404-3229

Jim Williams Dow 304-737-3956

Ken Wood DuPont 302-774-8023

Lori Weiss ERG 703-633-1658