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MEMORANDUM

To: Greg Nizich, U.S. EPA, Office of Air Quality Planning and Standards

From: Colin Hayes and Jason Huckaby, Eastern Research Group, Inc.

Date: November 26, 2007

Subject: Summary of October 30, 2007 Meeting Between EPA and The Vinyl 

Institute to Discuss Remanded Polyvinyl Chloride and Copolymers 

Production (PVC) NESHAP Issues and Future Activities

On October 30, 2007, members of The Vinyl Institute (VI) met with EPA at EPA’s 

campus in Research Triangle Park, North Carolina. The attendees and affiliation are 

listed below:

Name Representing

Frank Borrelli The Vinyl Institute

Barry Christenson Occidental Chemical Corporation

Ken Atkins Georgia Gulf Corporation

Mary Bachynsky Formosa Plastics Corporation

Peter de la Cruz Keller and Heckman (Attorney representing the 

Vinyl Institute)

Greg Nizich U.S. EPA OAQPS

Ken Hustvedt U.S. EPA OAQPS

Marcia Mia U.S. EPA OGC (attended via telephone)

Jason Huckaby Eastern Research Group, Inc.

Colin Hayes Eastern Research Group, Inc.
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The meeting began at 10:00 AM EDT, broke for lunch around 11:45 AM EDT, and 

reconvened from 1:00 PM to approximately 2:40 PM EDT. The summary of the 

meeting’s discussion follows.

Opening Remarks

Frank Borrelli (VI) touched on the following topics in opening up the meeting:

Other VI members that were not present at the meeting included PolyOne, 

CertainTeed Corporation, and Westlake Chemical Corporation.

Most PVC manufacturers produce PVC homopolymers, high volume suspension 

resins, and there is some emulsion polymerization.

Two major companies engaged in co-polymer production are Dow Chemical and 

Noveon (both of these companies are not members of VI).

Colorite is another PVC manufacturer that would be affected by the PVC 

NESHAP. Colorite is not a VI member, but VI has contacts with them.

PVC is a 15-16 billion pound per year industry.

The VI has been approached by NACAA. VI wants to make sure NACAA 

understands the PVC manufacturing process. VI does not want to do something 

inconsistent with what they are doing with EPA.

VI wants to help develop a MACT that will not end up in the courts.

VI plans to meet with NACAA again after meeting with EPA.

VI wants to understand what data EPA needs and how best to get the information 

and data to EPA to support the rulemaking effort.

PVC Industry and Process Overview

Frank Borrelli and Mary Bachynsky gave a presentation on the PVC industry to provide 

background information to EPA regarding the industry, PVC resin types, and historical 

and current PVC resin manufacturing practices. Topics presented and notes on the 

presentation follow:

Dispersion resins versus suspension resins.

Review of PVC polymerization chemistry.

NESHAPS developed to control residual VCM.

Review of PVC process.

Raw materials: VCM, water, surfactants, initiators, RVCM (from overhead 

recovery).

8-12% VCM is typically unreacted.

VCM recovery: incinerators, for vent stream combustion (includes air due to 

openings).

Inert streams from reactors, initiators introduced; through to thermal oxidizers.

Homopolymer process: monomers into reactors typically 99% pure (“technical 

grade”).
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Change temperature in reactors: chain growth changes, chain growth termination, 

change molecular weight in process depending on end use requirements.

Suspension process: uses organic initiators; “grow” the polymers in organic 

phase.

Dispersion process: polymer “grows” in a water phase – micelles, use surfactants 

(emulsion chemistry).

Emulsion resins: particles size of small powdered sugar.

Suspension resins: larger particle sizes.

EPA asked whether surfactants and initiators pass through the process and are 

there HAP associated with those as they pass through the process? VI responded 

that there are some breakdown products and methanol that get attached to the 

PVC polymer chain. However, these are probably small amounts; less than 1/10 

of 1 percent.

Methyl celluloses might have methanol (a HAP) as a solvent (commonly 

used) for suspending agents. PVAs (polyvinyl alcohols) also used.

Peroxides use odorless mineral spirits, but nothing on the HAP side.

Company practices vary however.

Would probably use a few gallons of initiator in a 30,000 gallon reactor.

Once VC is formed, not many other things formed.

Low ppm level impurities in VCM (volatiles) that would carry along with 

the vinyl chloride, vast majority would go back to recovery system; 

thermal incinerator.

Realistically, nothing is 100% pure.

Once through the stripper, the slurry enters an “open” system.

Stack out of dryer, what goes out the dryer side depends on permit limits and 

depending on resin being produced.

Typical resins today, (polymer itself) down around 1 ppm RVCM (RVCM –

“after stripping loss”)

RVCM no longer regulated by NESHAP past the strippers, but state permitting 

agencies have regulations that pick up here (centrifuges, dryers, these limits vary). 

State air toxics regulations, non-attainment areas, etc. Texas, have to model 

emissions and meet ground level numbers. LA, Maryland, Texas – risk based 

standards.

There was a question by Greg Nizich regarding vinyl chloride (VC) in 

landfills and whether the VC came from PVC products in the landfills. The 

response from industry representatives was that the VC in landfills is a 

degradation product of TCE and perchloroethene (“Perc”). Industry 

representatives noted that chlorinated solvents were previously placed in 

landfills, and the VC present is not residual VC from plastics production.

Two broad classifications of PVC resins

o Suspension

o Dispersion

Resin subcategories are referred to as “grades.”
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Suspension: general purpose: flexible and rigid

o Specialty

o Copolymer

Ability to get RVCM down to a certain level depends on the type of resin being 

produced. It’s all PVC, but the resins are different and have different properties 

depending on end use. This sets the “strippability” of the resin.

1999 data: 73% general purpose, suspension resin, rigid extrusion grade (RVCM 

levels can get very low in these).

Homopolymer is vast majority of regulated production – copolymer just a small 

part.

Amount of VCM remaining in wet PVC slurry is known as “residual VCM” 

RVCM.

Steam stripping is used as primary means in industry for controlling VCM 

emissions.

Each resin type has a predictable range of RVCM level after stripping.

Dispersion resins are more difficult to strip than other PVC resins.

Many states have more stringent limits, but not based on daily limits, less frequent 

demonstration basis. This allows flexibility.

Frank: daily number is critical for the industry. For flexibility for the industry, 

daily numbers need flexibility

Many facilities have quarterly or annual limits in the permits. Daily limits may be 

no problem for facilities that made the same type of resin all the time. Other 

facilities change resin types in processing, so quarterly/annual averages allow 

flexibility for these changes depending on customer demand.

Striping is used consistently around the world.

Industry performance is improving.

What defines RVCM limits: variations in raw material purity, operating 

conditions and equipment, stripping conditions relating to product quality, 

requirement to be able to comply with a daily limit, production of different PVC 

grades.

EPA inquired as to whether there is a difference in the stripping process itself 

(e.g., the column itself, trays, steam rates, etc.) that would affect the levels of 

residual vinyl chloride? An industry representative responded that for certain 

resins, one cannot just increase the steam flow. Some resins will degrade, change 

color, etc.

VI stated that not every company can operate the same way. Each company has 

an established technology practice.

General purpose suspension resins have a higher porosity and are easier to strip. 

Emulsion resins are generally harder to strip.

VC copolymers

Most VI members do not make copolymers

Vinyl acetate (10-40%) goes into reactor (substituting VCM for VA)

Properties similar to flex PVC, floor tile, can coatings

PVDC, copolymers with VC: saran, copolymer with acrylates

Very small in comparison to total market
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Difficult to put an emulsion resin through a column, use batch stripping and 

smaller reactors

Conclusions:

BACT for PVC resin is steam stripping

Daily RVCM limits should be set high enough [to allow for differences in 

resins being produced?]

Copolymers are more difficult to strip.

This concluded the presentation by The Vinyl Institute.

VI wants to move forward with the MACT, but would like some flexibility and 

retain the ability to be competitive and satisfy a very broad marketplace.

VI asked EPA where this exercise is starting (e.g., with respect to addressing 

surrogacy issues) and reminded the group that other procedural items raised.

EPA stated its desire to be more thorough with respect to setting floors, CAA 

requires review of Part 61 NESHAPS? Issues the courts raised, “Brick” decision. 

Try to get as much info, but not duplicate information. Get info from permits, 

facilities, fill in data gaps. Want to do best analysis possible for the emission 

points...what’s the best out there, set floors. Re: timing: 

Industry asked if EPA hoping to get two birds with NESHAP review and vacatur 

of PVC standard? EPA acknowledged that is the intent.

EPA stated that it is possible that nothing will change (from the remanded PVC 

standard), EPA may just better explain its process and reasoning.

VI suggested that they perhaps needed to get copolymer producers into the 

discussion.

Industry noted that a lot of emissions that we see (reported in NEI) are 

combustion byproducts.

EPA requested a copy of the presentation given at the meeting by VI. VI agreed to that 

request.

Emissions Information and Data Needed to Address Remand

The post-lunch session was less structured than the morning presentation, and consisted 

of discussion on the emissions data that EPA currently had for affected PVC facilities, 

additional data needed to address the remand, and how best to obtain such additional 

data.

VI inquired as to whether EPA is interested in obtaining test data, calculated data, or 

something else. EPA responded that test data would be preferred.

VI noted that other HAPs besides VCM would only be present due to small amounts 

of additives to the reactors.

Regarding the presumably small amount of HAP carried through the manufacturing 

process, VI wanted to know if there was a threshold level cutoff, such as a de 

minimis level, or a certain ppm level where a compound might be classified as a 

“non-detect” or “less than X ppm.” EPA responded that there is no such level or 

guidance set for threshold or de minimis levels.
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VI reiterated that for compounds other than VC and HCl (combustion byproduct), any 

HAP will probably be present in additives, but would be present in very small 

amounts. Additionally, the additives themselves are added to reactors in very 

small amounts already. It might be difficult to quantify the levels entering the 

system at the reactors. The only source of HAP information from reactor 

additives would be MSDS sheets, but if the HAP is below a certain level, it is not 

required to be reported on the MSDS. If it is, it would be in the ppm range and 

very small.

There was some discussion of emission units and emission points in the PVC 

manufacturing process and what is currently controlled.

o VI stated that reactor opening losses (ROLs) were part of the original 

NESHAP. Added that reactors are closed systems and companies have to 

put in controls to make sure there are no uncontrolled reactions. ROLs 

probably constitute less than 1% of total VC emissions.

o Suspension resins can run several batches between reactor openings

o Reactors producing dispersion resins are typically opened between every 

batch

o VC storage spheres are pressurized and contained.

o VI: fugitive emissions are regulated and controlled, there are OSHA 

standards for worker exposures

o Vents for recovery are controlled

o VI: there is HCl control, scrubbers, also try to avoid burning VC; good 

evacuations of equipment

PVC transfers from reactors take place through a variety of methods, including 

pressure transfers and pump-outs. All transfers from reactors are closed and 

contained.

Some plants have dedicated stripping trains for a single product.

Water is used to clean reactors, organic solvents would probably not be used (e.g., 

methanol)

VI inquired as to whether process flow diagrams showing inputs, outputs, where 

everything is going in the process would be useful to EPA. EPA agreed.

Occidental Chemical inquired as to what information is still available from the last 

time around (PVC rulemaking)? ERG directed the group to the PVC docket 

available on the “regulations.gov” website, and noted that there is a lot of 

information there regarding compounding processes.

VI noted that compounding might typically be collocated with a PVC resin 

manufacturing process and this fact might cause certain compounds to show up in 

a facility’s emissions data, such as NEI data.

The attorney for VI stated that there was not much environmental group participation 

in the initial rulemaking. He added that it is hard to tell from the NEI data the 

source of compounds that may appear in the process. Need to figure out a way to 

address “what’s not there” instead of “what’s there”

VI noted that process flow sheets are very facility specific and wanted to know if 

EPA would prefer a generic process flow sheet, or several flow sheets specific to 

each facility?
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An industry representative noted that low level of HAP that would be present for 

small tanks and other equipment with vents, storage tanks, combustion emissions, 

and for natural gas combustion on a dryer. Industry questioned whether these 

types of emissions would be covered under the affected PVC source or not.

An industry representative inquired as to what fits (with respect to compounds) with 

the surrogacy issue, and how would other compounds be addressed (those for 

which, if any, VCM may not be an appropriate surrogate)? 

The attorney for VI inquired as to whether EPA currently has a guideline document or 

established procedure for determining surrogacy? EPA responded that it is 

uncertain if such specific guidance exists.

Industry representative noted that VA (vinyl alcohol) storage tanks are regulated 

under organic liquids distribution MACT. There may be regulatory overlap 

questions and issues, and multiple MACTs may apply to a particular 

plant/process. Industry also noted that some PVC plants send streams to an EDC 

plant that is covered under the HON, so a compound such as HCl would be 

covered (under HON), even though not explicitly by a PVC standard.

Industry representative asked where the circle drawn around a PVC plant for 

applicability? Some equipment, such as incinerators are not integral to the PVC 

manufacturing process. Suggested that industry could formulate a diagram 

showing what equipment connected to a PVC plant is covered by which 

regulation(s).

ERG inquired as to whether CISWI would apply. Industry responded that they did 

not think so.

Industry noted that continuous monitoring in stacks for VCM is required.

The attorney for VI noted that the discussion seemed to be heading towards industry 

providing EPA with a detailed diagram of the PVC process? EPA and industry 

representatives agreed.

Industry reps also suggested that they could provide a better description of additives 

and associated HAP entering the process with reactor additives.

EPA requested clarification that there is not other point in the PVC process where 

materials or chemicals are added other than the reactor and the compounding area 

(if present). VI confirmed that this is the case.

Industry noted that a flow diagram would probably best help EPA and that the NEI 

data would not be very useful.

The attorney for VI stated that industry and EPA may have to “cast a little broader 

mental net” to make sure everything (in the PVC process) is covered.

Industry noted that the PVC process is actually a narrower set of process/equipment 

than what the petitioners might be used to seeing.

The VI requested the list of HAP identified by petitioners. EPA agreed to get that list 

to the VI and concurrently requested a copy of the presentation made by VI at 

today’s meeting.

Industry noted that some plant data may be under a records retention policy and thus 

would either not be available or verifiable.

Industry inquired as to whether permit data be helpful. EPA did not believe that 

permit data can be used to set limits.
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VI stated that flow sheets, product specifications, perhaps some fate analysis might be 

useful.

The attorney for VI stated that VI would prefer to just work with EPA for the time 

being, then get back with NACAA.

EPA noted a footnote in the VI’s letter to EPA, dated October 12, 2007 from Peter de 

la Cruz to Greg Nizich, referencing footnote number 19 in the letter stating that 

there are/were three plants that are pursuing or have performed a MACT analysis 

under CAA Section 112(j) and wanted to know how the analysis was or is being 

performed.

Industry representative noted that they just started that 112(j) process and that they 

are not determining new emission limits, just going through the mechanism.

EPA stated that it thought this can be best controlled similar source but not 

necessarily in same industry.

VI inquired as to EPAs timing for completing the PVC rulemaking process. EPA 

stated that it would like to “rough” something out, see how it looks, then go from 

there.

VI noted that it needed to get more VI member companies involved in this process, 

and asked if it would be acceptable to get information to EPA in the next 30-60 

days. EPA agreed that timing would be acceptable.

Industry wanted to clarify that what EPA is looking for from them is a specific PVC 

process diagram. EPA agreed, and added that it would like everything labeled, 

with all of the emission points captured and what is being emitted from each point 

in the process.

VI noted that this would be an iterative process, with information reviewed by all VI 

members.

ERG asked industry representatives whether any facilities are missing from the list 

EPA provided to VI?

o Industry noted the exclusion of OxyChem, Pasadena, TX

o Also noted that the OxyChem Deer Park PVC plant sends waste to its La 

Porte EDC/VCM plant. The La Porte EDC/VCM plant should be 

combined with the Deer Park plant.

Georgia Gulf confirmed that all of their facilities were represented on the EPA list.

Formosa Plastics and Georgia Gulf noted that Geismar Vinyls is now Westlake.

The VI extended their appreciation for the time to meet with EPA.

The meeting concluded at 2:40 PM (EST).