MEMORANDUM

TO: Voluntary Program Participants 

FROM: Samantha Lewis, EPA 

 

DATE: June 22, 2007 

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to Discuss the 

Proposed Voluntary VCM Program (15 June 2007)

 EPA participated in a teleconference with The Vinyl Institute (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 Plan (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 Attachment 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 collecting 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 concern about the potential for 

dilution at the final outfall since many of the facilities discharge wastewater from non-CCH 

manufacturing operations. EPA prepared a generic sampling plan to describe their suggested 

approach for sampling and provided it to industry for discussion and comment. EPA also 

included example diagrams which describe EPA’s rationale for selecting sampling points. For 

facilities where CCH wastewater is commingled with non-CCH wastewater, EPA is requesting 

that the facility collect a sample prior to the mixing point. EPA noted that the number of 

sampling points will depend on the facility’s manufacturing processes and process flow diagrams. 

EPA is requesting that industry collect at least four samples at each sampling point, each collected 

at least one month apart. 

 EPA met with the VCP to discuss initial comments on the 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 objectives of the VMP. The VCP 

continues to have concerns about the primary and secondary objectives. In addition, the VCP 

would like to finalize the GSP prior to initiating discussions with individual member companies 

on their site-specific plans. 

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

VMP: 

• Establish a quantifiable baseline of dioxins and furans (dioxins) 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 EPA’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 addition 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 reductions from treatment units similar to 

the site’s treatment when modeling the affects of treatment. EPA will compute a baseline 

discharge for each facility. EPA can then evaluate this baseline and compare it to the VCP’s 

proposed limits or the European Union (EU) standard. Frank Borrelli noted that the EU is 

conducting a survey to determine how the EU standard is being implemented at VCM facilities 

and whether it needs to be modified. 

 The VCP would like EPA to provide additional details on their modeling 

methodology in the GSP. In particular, the VCP would like EPA to articulate how it will 

calculate annual discharges and daily maximums using the sampling 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 operations and flows, but it will be up to 

the facility personnel to decide when to collect samples that represent normal operations and how 

to compute flowrate. EPA will use the flowrate to compute a mass load; however, EPA realizes 

that not all streams will have a flowmeter installed and that it may be necessary to use engineering 

judgment when providing the flowrate. 

 The VCP wanted to clarify which PVC facilities are included in the VMP. There 

are two facilities that EPA included in the site-specific plans that are actually stand-alone PVC 

facilities. The VCP stated that if EPA intends to collect 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 reiterated that they would like a clear 

understanding of EPA’s objectives in collecting this additional data. 
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Next Steps

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

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

the GSP. 

3. After the GSP has been finalized, EPA will work with individual companies to finalize 

their site-specific plans. EPA will insure that comments 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