Memorandum, December 9, 2013 

Page 1 of 5 

MEMORANDUM 

TO: Andrea Siefers, US EPA/SPPD/RCG 

 

FROM: Philip Crawford and Colin Hayes, ERG 

DATE: December 9, 2013 

SUBJECT: Summary of May 22, 2013 Meeting Between US EPA and The Vinyl Institute 

1.0 Introduction 

On May 22, 2013, a teleconference meeting was held at the request of the Vinyl Institute 

(VI) and their member companies (henceforth, “the industry) to present information to the EPA 

and its contractor, ERG, in advance of EPA’s planned proposal to respond to petitions for 

reconsideration that EPA granted on the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) for Polyvinyl Chloride and Copolymers (PVC) Production, which were 

promulgated on April 17, 2012. 

2.0 Date and Location

May 22, 2013 

Teleconference 

U.S. Environmental Protection Agency 

109 TW Alexander Drive 

Durham, NC 27709 

3.0 Attendees 

Name Affiliation 

Richard Krock Vinyl Institute 

Mary Bachynsky Formosa Plastics 

Jean-Cyril Walker Keller & Heckman 

Greg Clark Keller & Heckman 

Ted Nickerson Axiall 

Dave Goldsmith Axiall 
Memorandum, December 9, 2013 

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Kevin Bloomer Westlake Chemical 

Allen Bodron Westlake Chemical 

Otis Sistrunk PolyOne 

Mark Pettigrew PolyOne 

Andy Sheppard URS 

Barry Christensen OxyChem 

John Westendorf OxyChem 

Laura Whiting OxyChem 

David Wise Shintech 

Tom Anderson Shintech 

James Bell Shintech 

Bob Elam Dow 

Mark Kataoka EPA 

Penny Lassiter EPA 

Andrea Siefers EPA 

Steff Joshnson EPA 

Colin Hayes ERG 

Ashley Wong ERG 

Philip Crawford ERG 
Memorandum, December 9, 2013 

Page 3 of 5

4.0 Summary of Meeting 

The VI provided an agenda ahead of the meeting, which is attached. 

The following are summaries of the information presented by the industry. 

1. Area Sources - Generally available control technology (GACT) limits 

• The industry representatives noted that hydrogen chloride (HCl) measurement 

data for OxyVinyls Deer Park facility were not included in EPA’s process vent 

MACT floor calculations. The industry representatives elaborated that EPA had 

approved the submission of HCl data collected by Deer Park prior to the August 

2009 Section 114, and that the Deer Park facility had included the HCl 

measurement data in their Section 114 response. 

• The industry representatives pointed out that several of the finalized GACT limits 

are more stringent than the Part 61 NESHAP for PVC facilities. They described 

the history of allowing reduced monitoring, recordkeeping, and reporting 

requirements for area sources, and they requested that the EPA consider 

proposing such reduced requirements for PVC area sources. 

2. Limits for Vent Gas Absorbers

• The industry representatives discussed challenges regarding the application of the 

process vent emission standards to vent gas absorption (VGA) units. They 

reiterated their comments from their June 18th, 2012 petition for reconsideration, 

noting that VGAs are fundamentally different and that oxygen correction is not 

applicable to non-combustion control devices. They requested the EPA to 

consider the possibility of alternative emission limits (e.g., mass or percent 

reduction based standards) for VGAs. 

3. Bypasses from Closed Vent Systems 

• The industry representatives presented the points set forth in their June 18, 2012 

petition regarding bypasses from closed vent systems. 

4. Pressure Relief Device Requirements 

• The industry presented issues raised in their petition regarding monitoring of 

pressure relief devices (PRDs). 

5. Leak Detection and Repair for Pressure Vessels

• The industry representatives requested that EPA consider proposing to include a 

definition for “potential leak interface,” and suggested using the definition from 

40 CFR Part 63 subpart UU. 

• The industry representatives also requested that the EPA consider proposing that 

leaks from a pressure vessel be subject to the same LDAR requirements as other 

equipment, which provide facilities with an opportunity to repair detected leaks 

rather than a leak resulting in an immediate violation of the standards. 

6. Vapor Balancing
Memorandum, December 9, 2013 

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• The industry representatives went over issues raised in their petition regarding the 

omission of vapor balancing from the final rule. 

7. Combined Process Vents

• The industry representatives reiterated comments from their June 18, 2012 

petition regarding emission limits for combined process vents, including 

applicability of the limits and process vent requirements to other source category 

processes and the determination of the most stringent standard where multiple 

standards apply to a single emission point. 

• The industry representatives presented an approach to “apportion” standards for 

combined process vents. 

8. Requirements for Emission Profiles

• The industry representatives reiterated their comments regarding emission profiles 

from their June 18, 2012 petition for reconsideration. They noted that they agree 

with the intent of the emission profile requirements as described in the preamble 

to the final rule, but stated that the rule does not reflect the discussion of the 

emission profile provisions in the preamble. 

• As stated in their petition, the industry representatives requested that EPA clarify 

in the proposal the extent of the emission profiles and at what particular point in 

the process vent systems they are required. The industry representatives explained 

how emission profiles could be skewed or not applicable given the vinyl chloride 

recovery systems at most manufacturing facilities. 

9. Discussion of VI Clarification Letter

• The industry representatives walked through issues raised in their letter to EPA, 

dated April 5, 2013 “Re: Clarification on Certain Provisions in the National 

Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and 

Copolymers Production (‘PVC MACT’)”. 

• The industry representatives stated that stripped resin is stored in feed tanks that 

are vented to the atmosphere but that these tanks are not considered to be in HAP 

service. 

10. Wastewater Section 114 Survey Request

• The industry representatives indicated they were in the process of reviewing the 

data submitted to EPA in response to the November 6, 2012 wastewater Section 

114 survey request. 

• The industry representatives requested another meeting with EPA to discuss the 

results of the testing conducted in response to the November 6, 2012 Section 114 

survey. 

• The industry representatives discussed the general variability of the measurement 

data collected, noting that subsets of certain HAP are present for some facilities 

and not others due to recipe requirements for particular types and grades of resins. 
Memorandum, December 9, 2013 

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11. Miscellaneous Topics

• The industry representatives expressed concern with the new source emission 

limits in the final rule, noting in general that adequate variability may not have 

been incorporated for the best performers identified by EPA. 

• The industry representatives restated from their petition that that they support 

subcategorization for resin limits, the definition of “affected source,” the use of 

the upper prediction limit in MACT floor limit calculations, the use of total 

organic HAP (TOHAP) and not including beyond the floor technology in the final 

rule provisions. 

• The industry representatives noted that an extension of the compliance date may 

be needed if the EPA changes limits in the standard as part of reconsideration.

 
Memorandum, December 9, 2013 

Attachment A 

A-1 

Attachments 

A. Meeting Agenda Submitted by the Vinyl Institute 
 

Page 1 of 2

1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

A-2 

May 22, 2013 Sent Electronically Via e-mail 

Ms. Andrea Siefers 

Program Manager 

U.S. EPA - Office of Air Quality Planning and Standards 

Sector Policies and Program Divisions 

Refining and Chemicals Group 

Mail Code: E143-01 

Research Triangle Park, NC 27711 

RE: Agenda for Vinyl Institute Meeting on May 22, 2013 (1:00 to 4:00 pm): National Emission Standards for 

Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers Production (PVC MACT) Rule 

Dear Ms. Siefers: 

The Vinyl Institute PVC MACT Working Group appreciates the Agency’s willingness to meet with us to discuss 

our concerns, questions, additional data submissions, and need for clarification of certain provisions of the 

above-referenced final rule. We have prepared a brief Agenda for our discussions which should facilitate the 

flow of the discussion with some suggested timeframes for the meeting. Should you or your colleagues have 

any additional items that you wish added for our preparation, please feel free to add them to the following 

topics: 

1. Introductions and Opening Remarks (10 min.) 

2. Petitions for Reconsideration: EPA Status Update 

a. Area Sources (15 min.) 

b. Limits for Vent Gas Absorbers (20 min.) 

c. Bypasses from Closed Vent Systems (10 min.) 

d. Pressure Relief Device Requirements (20 min.) 

e. LDAR for Pressure Vessels (10 min.) 

f. Vapor Balancing (5 min.) 

g. Combined Process Vents (20 min) 

i. Status of EDC/VCM rulemaking 

h. Requirements for Emission Profiles (5 min.) 

3. Addressing clarifications (30 min.) 

4. S114 Treated Process Wastewater Request (30 min.) 

5. Other topics, next steps (5 min.) 

6. Adjournment
 

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1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970-3392 Fax (571) 970-3271 

www.vinylinfo.org www.vinylindesign.com

A-3 

At this time, I anticipate the following Working Group members to attend: 

Mary Bachynsky – Formosa Plastics 

Barry Christensen – OxyChem 

John Westendorf – OxyChem 

David Wise – Shintech 

Tom Andersen - Shintech 

Kevin Bloomer – Westlake 

Allen Bodron – Westlake 

Otis Sistrunk – PolyOne 

Ted Nickerson – Axiall 

Andy Sheppard - URS 

JC Walker – Keller and Heckman 

Greg Clark – Keller and Heckman 

Richard Krock – Vinyl Institute 

Tentative attendees include: 

Laura Whiting - OxyChem 

There are a few others that would like to attend but their schedules prevent them from doing so. Accordingly, I 

have circulated the coordinates for the teleconference line you set up so they can participate by phone. 

Again, the Working Group appreciates the time and effort the Agency has put forth for this rule and your 

continued willingness to meet with us to ensure the amendments to final rule are fully protective of human 

health and the environment, while allowing the industry the flexibility to compete effectively in the global 

economy. The Working Group looks forward to our discussions with you on Wednesday, May 22, 2011 at 1:00 

pm. Please do not hesitate to contact me if you have any questions. 

Sincerely, 

Richard P. Krock 

Technical Director 

e-mail: rkrock@vinylinfo.org

Phone: 571-970-3392 

Cell: 571-216-4474 

cc: Penny Lassiter