MEMORANDUM

TO: Voluntary Program Participants 

FROM: Samantha Lewis, EPA 

 

DATE: October 31, 2006 

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

Definition of Process Wastewater for the Proposed Voluntary VCM Site 

Program (18 October 2006)

 EPA held a teleconference with The Vinyl Institute (VI) and several member companies 

on Wednesday, October 18, 2006, to discuss the industry’s definition of process wastewater for 

the proposed voluntary program for vinyl chloride facilities. This teleconference was a follow-up 

to the initial discussions about the proposed voluntary program held on October 10, 2006. The 

list of participants can be found in Appendix A. Appendix B shows industry’s draft definition of 

process wastewater for discussion. 

 The meeting followed the agenda below: 

• Introduction; 

• Discussion; and 

• Next Steps. 

The teleconference is summarized below: 

Introduction

 Ms. Jan Goodwin of EPA began the meeting by explaining that EPA has not had an 

opportunity to meet internally to discuss the draft definition. However, EPA has some questions 

for clarification of the definition. Ms. Goodwin added that EPA will require a few weeks to 

provide feedback on the proposed voluntary program. 

 Mr. Frank Borelli of the Vinyl Institute stated that the purpose of the call is for EPA to 

provide guidance on the process wastewater definition. Developing the definition will be an 

iterative process. Industry will get feedback from EPA and revise the definition as needed. 

Discussion

 Ms. Samantha Lewis of EPA began the discussion by asking if the process wastewater 

definition is intended to include only CCH process wastewater. Mr. John Westendorf of 

OxyChem explained that the definition includes all process wastewater from all chemical 

manufacturing processes on site. Industry’s intention is to capture all streams that a site would 

include in its TRI report as a dioxin source. 
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 Ms. Lewis asked for clarification on Number 5 in the definition, which states that process 

wastewater includes other site process wastewaters identified in NPDES permit fact sheets or in 

Total Maximum Daily Load (TMDL) studies. Mr. Westendorf explained that this sentence was 

added to allow for consistency with existing permits. He added that industry intends to include all 

site process wastewater, even if it is not covered by an existing ELG. 

 Ms. Lewis asked if Number 3, which states that process wastewater includes evaporations 

cooling tower discharge at chlor-alkali plants, refers to contact or non-contact cooling water. Mr. 

Westendorf explained that Number 3 refers to contact wastewater from caustic evaporation. 

Process condensates that are recovered from caustic evaporation are used as cooling tower makeup. The blowdown from the evaporations cooling tower is considered process wastewater. 

 Ms. Lewis stated that during the October 10, 2006 meeting, Jason Campbell of PPG 

discussed including non-contact cooling tower blowdown for facilities that use chlorine as a 

disinfectant. Ms. Lewis asked if this wastewater was included anywhere in the definition. Mr. 

Campbell explained that the cooling water he discussed on October 10 is non-contact wastewater 

from the utilities cooling tower. Mr. Campbell explained that he wanted the definition to allow 

flexibility for facilities to include non-contact cooling water that could be a potential source of 

dioxins. Mr. Campbell added that the non-contact cooling water would not be a significant dioxin 

source, and was brought up only for discussion. 

 Mr. Ken Wood of DuPont added that the definition of blowdown under 401.11 can 

include process and non-process wastewater. He mentioned to Mr. Westendorf that perhaps 

industry needs to clarify the definition to explain that industry intends to exclude non-process 

blowdown wastewater from the process wastewater definition. 

 Mr. Borelli concluded that industry should include some introductory language to clarify 

that industry intends to include all site process wastewater. Ms. Goodwin added that EPA would 

appreciate any information industry could provide about the logic behind selecting process 

wastewater streams for the definition. Ms. Goodwin stated that EPA is concerned that industry’s 

definition includes dilution sources. Industry representatives provided the following justifications 

for including all site process wastewater for the definition of process wastewater: 

• At some combined manufacturing sites, the vinyl chloride process may be the 

largest dioxin source. However, wastewater streams are commingled and treated 

in a central system, which makes it impossible to do loadings for individual 

streams. In addition, very little dioxin data are available for individual streams. 

• Some combined manufacturing sites may have multiple chemical manufacturing 

processes that are sources of dioxin. 
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Next Steps and Further Issues

• Industry will draft an introductory paragraph and clarify the definition of process 

wastewater. Industry will send the new draft to EPA for further discussion. 

• EPA will review the definition and share any potential “deal-breakers” for the 

voluntary proposal with industry. 

• Industry will begin drafting a discussion of the benefits of the voluntary program. 

At a minimum, the discussion will include a description of the range of facilities 

covered by the proposed voluntary program and the range of chemical processes 

other than vinyl chloride that is covered by the program. 

• Ms. Lewis stated that EPA invites facilities to share their data and baseline 

loadings with EPA. 
Appendix A. List of Participants for Teleconference 

Name Organization 

Jan Goodwin EPA/HQ/Office of Water 

Samantha Lewis EPA/HQ/Office of Water 

Josh Hall EPA/HQ/Office of Water 

Meghan Kandle ERG (Contractor to EPA) 

Frank Borelli Vinyl Institute 

Jason Campbell PPG 

Tony Jett Westlake 

James Bell Shintech 

Mary Bachynsky Formosa 

John Westendorf OxyChem 

Ken Wood DuPont 

Jim-Bob Williams Dow Chemical 

Tom Berger Keller and Heckman 
Appendix B. 

Draft Definition of Process Wastewater