Memorandum

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MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford, ERG

DATE: March 3, 2011

SUBJECT: Summary of February 15, 2011 US EPA Community Meeting in Westlake, 

LA

1.0 Introduction

On February 15, 2011, 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 pollutants (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, 2011

Rigmaiden Recreational Center

3825 Old Spanish Trail

Westlake, LA 70669

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 (MEAN)

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)
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Wilma Subra The Subra Company (by telephone)

James Pew Earthjustice (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 PM 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 that 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 sources from the PVC production process. 

EPA reviewed the regulatory history of PVC production. EPA specifically described the 

regulatory efforts that have been taking place since2008. EPA relayed that the Agency

has worked with the PVC industry between 2002 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. 
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EPA noted that vinyl chloride has been the only pollutant regulated by 40 CFR Part 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 proposed emission points to be regulated by the upcoming part 63 

NESHAP. EPA also discussed the hazardous air pollutants (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) requirements, 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 responses 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 that 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 presentation to Louisiana 

Environmental Action Network (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 during 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 member 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 numerous occasions, 

but to no avail.

An audience member asked if a live 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 members 
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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 Administrator 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 community 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 requirements, 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 forward 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 November 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 described the two phases of rulemaking, 

MACT and residual risk. An audience member asked why humans were considered 

after, not before, the MACT process. 

An audience member requested that EPA 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 companies. 

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 considering

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 pollutants, 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 stations 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 an 
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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 questions 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 data 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-1
A-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-3
Slide courtesy of Oxyvinyls

A-4
Slide courtesy of Oxyvinyls

A-5
A-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

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A-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-9
 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

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A

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 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.

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 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

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