### MEMORANDUM

TO: Voluntary Program Participants

FROM: Samantha Lewis, EPA

DATE: October 31, 2006

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

Definition of Process Wastewater for the Proposed Voluntary V CM 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 defin ition 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 pr ogram 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 tha t EPA has not had an opportunity to meet internally to discuss the draft definit ion. 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 th e purpose of the call is for EPA to provide guidance on the process wastewater definition. De veloping 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 a sking if the process wastewater definition is intended to include only CCH process wastewa ter. Mr. John Westendorf of OxyChem explained that the definition includes all process wa stewater from all chemical manufacturing processes on site. Industry’s intention i s to capture all streams that a site would include in its TRI report as a dioxin source.2

Ms. Lewis asked for clarification on Number 5 in the definition, which states that process wastewater includes other site process wastewaters iden tified 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 w astewater includes evaporations cooling tower discharge at chlor-alkali plants, refers to c ontact or non-contact cooling water. Mr. Westendorf explained that Number 3 refers to contact wast ewater from caustic evaporation.

Process condensates that are recovered from caustic ev aporation 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, Ja son Campbell of PPG discussed including non-contact cooling tower blowdown for fa cilities 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 Oc tober 10 is non-contact wastewater from the utilities cooling tower. Mr. Campbell explaine d that he wanted the definition to allow flexibility for facilities to include non-contact cooling w ater that could be a potential source of dioxins. Mr. Campbell added that the non-contact cooling w ater 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 i ndustry intends to exclude non-process blowdown wastewater from the process wastewater definit ion.

Mr. Borelli concluded that industry should include some in troductory language to clarify that industry intends to include all site process wastewa ter. Ms. Goodwin added that EPA would appreciate any information industry could provide about the log ic behind selecting process

wastewater streams for the definition. Ms. Goodwin st ated that EPA is concerned that industry’s definition includes dilution sources. Industry representati ves provided the following justifications for including all site process wastewater for the definit ion of process wastewater:

• At some combined manufacturing sites, the vinyl chloride proc ess may be the largest dioxin source. However, wastewater streams ar e commingled and treated in a central system, which makes it impossible to do loa dings for individual streams. In addition, very little dioxin data are avai lable for individual streams.

• Some combined manufacturing sites may have multiple chemi cal manufacturing processes that are sources of dioxin.3

Next Steps and Further Issues

• Industry will draft an introductory paragraph and clarify th e definition of process wastewater. Industry will send the new draft to EPA for further discussion.

• EPA will review the definition and share any potential “de al-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 o f 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 HeckmanAppendix B.

Draft Definition of Process Wastewater