Memorandum
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MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford

, ERG

DATE: March 3 , 201 1

SUBJECT: S ummary of February 15 , 201 1 US EPA Community Meeting in Westlake,

LA

1.0 Introduction

On February 15 , 201 1

, EPA held a community interest meeting at the Rigmaiden Community Center in Mossville, LA to present information regarding the polyvinyl chloride and copolymers (PVC) national emission standards for hazardous air pollutan t s (NESHAP) as well as the Clean Air Act (CAA) section 114 vinyl chloride monomer (VCM) information request (ICR).

2.0 Date and Location

February 15 , 201 1

Rigmaiden Recreational Center 3825 Old Spanish Trail Westlake , LA 70 669

3.0 Attendees

Name Affiliation Darryl Malek

- Wiley Sierra Club Haywood Mortin Sierra Club MD Vincent Haks Families and Friends of Louisiana’s Incarcerated Children ( FFLIC ) / Mossville Environmental Action Now (M EAN ) Shirley Johnson FFLIC/MPACC Barbara Cahee Community Member Dorothy Felix MEAN Christina Bennett MEAN Delma Bennett MEAN Nathalie Walker Advocates for Environmental Human Rights ( AEHR ) (by telephone) Michele Roberts AEHR (by telephone)Memorandum
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Wilma Subra The Subra Company (by telephone) James Pew Earthjust ice (by telephone) Sam Coleman US EPA, Region Six (by telephone) Brenda Cook US EPA Region Six (by telephone) Jodi Howard US EPA

– Office of Air Quality Planning and Standards (OAQPS) Jason Dewees US EPA

- OAQPS Barrett Parker US EPA

- OAQPS Marcia Mia US EPA

- Office of Enforcement and Compliance Assurance Jennifer Gibbs US EPA Region Six Mark Kataoka US EPA

– Office of General Counsel Penny Lassiter US EPA

- OAQPS Philip Crawford ERG

4.0 Summary of Meeting

The meeting began at approximately 6 :00 P M with EPA introductions. EPA indicated that the EPA personnel present represented various aspects of the PVC rule.

General Discussion

EPA presented a slide show which briefly described the PVC industry and the work that has been completed related to the PVC rule. A copy of the presentation can be found in Attachment A

. The following is a brief summary of the main points covered by EPA during the slideshow.
EPA discussed PVC production in the U.S. and indicated that there is only one PVC plant in the Mossville area (Certain Teed Lake Charles).
EPA described PVC resin types and grades, as well as end uses for PVC resin.
EPA discussed ethylene dichloride (EDC ) and vinyl chloride monomer (VCM) production. EPA further indicated th at VCM and PVC are produced using two different
processes. EPA presented a PVC block flow diagram and described the PVC production process. EPA also discussed the air emissions sourc es from the PVC production process. EPA reviewed the regulatory history of PVC production. EPA specifically described the regulatory efforts that have been taking place since 2008. EPA relayed that the Agency has work ed with the PVC industry between 200 2 and 2008, but did so without making substantial progress

. EPA described the emissions testing and resin sampling conducted by facilities in response to the CAA section 114 2009 PVC information request . EPA indicated several issues with the industry’s responses to the section 114 such as missing information, varying formats of information submitted

, a supplemental Vinyl Institute (VI) data set, and the second section 114 request regarding the VI data.Memorandum
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EPA noted that vinyl chloride has been the only pol lutant regulated by 40 CFR P art 61

, subpart F. Before the required testing, EPA suspected that chlorinated dibenzodioxin and chlorinated dibenzofurans (CDD/CDF) and hydrogen chloride (HCl) were emitted from PVC manufacturing processes.
EPA listed the pro posed emission points to be regulated by the upcoming part 63 NESHAP. EPA also discussed the h azardous a ir p ollutants (HAP) emitted during PVC production . EPA indicated the Agency’s intention to apply maximum achievable control technology (MACT) emission limits, work practices, and performance standards for vinyl chloride, total organic HAP, CDD/CDF (as toxic equivalency (TEQ)), and HCl to the proposed emission points. EPA described their intention to set continuous emissions monitoring (CEMS) requiremen ts, continuous parametric monitoring requirements (CPMS), and annual source testing requirements. EPA responded to audience questions during and after the presentation. The following is a brief summary of the questions raised by audience members and res ponses given by EPA. Note that neither questions nor responses presented below are verbatim, but rather a summary of the issue discussed.
An audience member questioned if tankers were included in the storage emission point. The audience member stated th at tankers are storage vessels and they should be investigated. EPA did not provide a direct response.
An audience member asked for hard copies of presentation materials, or any type of hand out. EPA responded that they would supply a copy of the prese ntation to Loui siana Environmental Action Netwo rk (LEAN) , MEAN, and Sierra Club, as well as any email requests. An audience member asked if emissions testing data was sent directly to EPA. The audience member was concerned that testing results are potentially falsified by the facility. EPA responded that facilities are required to notify EPA 30 days prior to an emissions test to allow EPA a representative present during testing. The audience member asked if EPA took the opportunity to be present d uring testing, or if a community member was ever allowed to be present during testing. EPA responded that, to their knowledge, a community member has never been present during testing. The audience member questioned if EPA had ever asked a community memb er to be present during testing. EPA replied that a company, not the EPA, has the authority to decide if a private citizen may enter a company’s private property. EPA responded that they will discuss the issue internally. Jason Dewees indicated that

, as a former stack tester, he witnessed community members present during testing as an outreach program sponsored by the manufacturing facility (not PVC). The audience member stated that they believed a facility would falsify stack testing information if the EPA was not present for the test.

An audience member stated that they had requested “side by side” testing (a community member or a community funded stack tester collecting a sample) on numero us occasions, but to no avail.

An audience member asked if a l ive stream of emissions data from facilities is available online. EPA responded that live data streams are typically not available, however; consolidated compliance records are available upon request. Audience membersMemorandum
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expressed further concern that with available technology, one would assume streaming emissions information is possible. EPA replied that technology availability is not the issue, rather availability of funding. EPA described the electronic reporting tool ( ERT ) and indicated that the Admini strator is requesting funding for information availability. An audience member questioned EPA’s logic in setting limits for CDD/CDF emissions. The audience member stated that EPA had previously concluded that high amounts of CDD/CDF in the Mossville com munity may have been caused by the community members. The audience member asked why EPA would arrive at such a conclusion and then set emission limits for CDD/CDF. EPA responded that the CDD/CDF emissions, as indicated in the Section 114 testing requirem ents, were low. An audience member responded that previous testing (citing Lafayette) indicated high levels of CDD/CDF. EPA responded that CDD/CDF testing as a result of the 114 request will be made publically available. EPA indicated that they will for ward all of the data that was previously sent to James Pew. EPA also clarified that only one PVC facility operates in Mossville, and that the plant is classified as an area source. EPA stated they are collecting information from the two VCM manufacturing facilities in the Mossville area, PPG and Georgia Gulf.
An audience member requested EPA to clarify who performed the stack testing associated with the upcoming rulemaking. EPA responded that each facility was responsible for stack testing between Novemb er 2009 and July 2010.
An audience member questioned why EPA would conduct tests on water, soil, plants, and animals, but not on humans. EPA did not provide a direct response. An audience member asked if humans were not including in the sampling, would they (humans) be included in the rulemaking. In response, EPA d escribed the two phases of rule making, MACT and residual risk. An audience member asked why humans were considered after, not before, the MACT process.
An audience member requested that EP A provide further detail on efforts to collect information from VCM manufacturers. EPA responded that a draft section 114 information request has been sent to companies and responses are requested by July 1. EPA is requesting information from six compani es. An audience member questioned how facilities were able to maintain emissions inside fence lines. EPA indicated that the Agency is currently researching fenceline monitoring techniques and equipment

. EPA added that cost is a major factor when conside ring fenceline monitoring.
An audience member relayed their experience with emissions monitoring stations in South Africa. EPA discussed monitoring stations in LA indicating that the monitoring stations mainly collected information on criteria polluta nts, not air toxics. EPA further indicated that a toxics study was conducted in 2001 in the Iberville parish area. EPA will forward online information, if it still exists, concerning the toxics study. An audience member stated that the monitoring statio ns were set up with prejudice, expressing the opinion that only certain areas deserved clean air. EPA responded that the monitoring station locations were chosen in an effort to best capture the emission profiles from a majority of sources. EPA indicated that the monitoring station not located near anMemorandum
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emission source was used to assess the difference in ambient air outside of the dispersion area. EPA further described the toxics study.

Adjournment and Action Items

EPA adjourned the meeting at approximately 7:30 PM. EPA remained until 8:00 PM and answered additional que stions from community members. EPA stated they would perform the following follow

- up/action items:
EPA will mail a copy of the presentation to LEAN, MEAN, and Sierra Club. EPA will also email a copy of the presentation in response to any email requests.
EPA will internally discuss the issue of a community member being present during facility emissions testing.
EPA will forward, or upload to the docket, all emissions testing da ta that has been sent to James Pew.
EPA will forward, or upload to the docket online information concerning the toxics study performed by monitoring stations in LA, if the information is still available.
EPA will provide a copy of the sign in sheet and the meeting minutes.Attachment A

Attachment A EPA Presentation: “Polyvinyl Chloride and Copolymer Production (PVC) Stakeholder Meeting,” February 15

, 2011 Westlake, LA

# February 15, 2011 

# Westlake, LA

A

- 1A

- 2

###  

# 16 major and 1 area source facilities in PVC source category

◦ No small businesses

◦ Located in Delaware, Illinois, Kentucky, Louisiana (six), Missouri, Mississippi, New Jersey (two), and Texas (four)

 

# Most PVC facilities co

- located with VC and EDC production



# ◦ Some share common combustion control devices

 

# Four different types of PVC production:

◦ Bulk, dispersion, solution, and suspension

 

# Industry manufactures hundreds of different grades of PVC

◦ Production lines not necessarily dedicated to one product

◦ In producing different grades of PVC, different HAP are 

# used as additives and different HAP are produced

A

- 3Slide courtesy of Oxyvinyls

A

- 4Slide courtesy of Oxyvinyls

A

- 5A

- 6 

### Polymerization Reactor with Resin 

## VCM feed, water, additives Process vents Incinerator



### Resin

Stripper Processing

Wastewater Stripper Wastewater Stripped resin Process vent

#  

# PVC Manufacturers do not manufacture PVC products

 

# PVC Products:

◦ Vinyl Siding

◦ Plastic Toys

◦ Plastic Storage Bags

◦ PVC Pipes

◦ Medical Blood Bags

A

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- 8

###  

# October 21, 1976

- Risk

- based NESHAP for vinyl chloride (subpart F) final rule

 

# July 16, 1992

- PVC production listed as MACT category (as one source category)

◦ Does not include VCM production

 

# June 26, 2002

– PVC production listed as area source category

 

# July 10, 2002

- PVC MACT (subpart J) final rule

 

# June 18, 2004

- PVC MACT vacated

 

# January 23, 2002

– PVC area source rule (subpart DDDDD)

 

# October 22, 2008

- PVC MACT schedule petition

 

# April 15, 2011

– PVC MACT proposal (subpart HHHHHHH)

 

# January 13, 2012

– PVC MACT final (subpart HHHHHHH)

A

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###  

# Required Clean Air Act (CAA) Section 114 survey and testing to update data

◦ Source testing performed on combustion control systems for HAP/VOC and dioxin & furans

◦ PVC resin sampling conducted for HAP/VOC

◦ Problems occurred during resin sampling and analysis



# ◦ Vinyl Institute (VI) submitted supplemental resin data on behalf of industry in October 2010 without accompanying reasoning or explanations

◦ EPA requested addition information on VI in November 2010



#  Industry has complied with our latest request

A

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- 11 

###  

# Emission points prior to the base of stripper

◦ VC unloading and loading

◦ Mixing, weighing, and holding vessels

◦ Reactor opening losses

◦ Polymer stripping

 

# Emission points after the stripper 

# (resin slurry)

◦ Blend tanks

◦ Centrifuges

◦ Dryers

 

# Emission points after the stripper

◦ VC recovery (condensers)



## ◦ Control system (vent gas absorber or thermal oxidizer in series with acid scrubber)

 

# Other emission points

◦ Wastewater

◦ Equipment leaks



## ◦ Storage vessels

◦ Heat exchange systems

# Stack Testing HAP* 

# Resin Sampling HAP*

1,3 Butadiene** 2,2,4 Trimethylpentane Acetaldehyde** Chloroform Cumene Dioxin/furan Ethyl Chloride Ethylene Dichloride** Ethylene Glycol Formaldehyde** Hydrogen Chloride Methanol Methyl Chloride** Phenol Vinyl Acetate 

## Vinyl bromide** Vinyl Chloride** Vinylidene chloride 1,3 Butadiene** Acetaldehyde Cumene Ethyl Chloride Ethylene Dichloride** Formaldehyde** Hydroquinone Methanol Methyl Chloride* * Toluene Trichloroethane Vinyl Acetate Vinyl Chloride**

* Bolded HAP are in both lists. **Known or probable carcinogens.

A

- 12A

- 13

###  

# Set MACT for all sources (major and area):

◦ Process vents

◦ PVC resin sampling



# ◦ Equipment leaks

◦ Wastewater

◦ Heat exchangers

◦ Storage Vessels



# ◦ Equipment openings

 

# Set emissions limits for:

◦ Vinyl chloride

◦ Total organic HAP



# ◦ Dioxin & furans (as TEQ)

◦ Hydrogen chloride (HCl)

 

# Set monitoring requirements:

◦ Continuous emissions and parametric monitoring

◦ Annual source testing

A

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