MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: April 12 , 2010

SUBJECT: S ummary of March 3, 2010 US EPA Visit to Formosa Plastics Corporation,

Baton Rouge, LA

1.0 Introduction

On March 3 , 20 10

, US EPA vi sited the Formosa Plastics Corporation

, Baton Rouge , LA

facility for a meeting with plant personnel and a tour of the polyvinyl chloride ( PVC ) production

facility

. This visit was conducted to support EPA’s effort to develop national hazardous air

pollutant emission standards for the Polyvinyl Chloride P VC and Copolymers Production source

category.

2.0 Date and Location

March 3, 2010

Formosa Plastics Corporation, Louisiana

Gulf States Road

Baton Rouge, LA 70805

3.0 Attendees

Name Affiliation

Omer Wolff Formosa Plastics Corporation / E&S Manager

Scott Longon Formosa Plastics Corporation / E&S

Brandon Bencaz Formosa Plastics Corporation / E&S

Jodi Howard US EPA

Colin Hayes ERG

Philip Crawford ERGMemorandum

p. 2 of 8

4.0 Summary of Visit

The meeting began at approximately 1: 30 PM

. A summary of the meeting’s discussion

follows.

EPA began the meeting by stating the purpose for the plant visit, covering logistics for

the meeting, and giving a brief history of recent events leading to the PVC information collection

request

. EPA in dicated that the group was visiting the plant to obtain information relat ed to the

production of PVC and supporting operations. A list of specific items that EPA wished to

discuss was sent to the facility on February 22, 2010 as an enclosure (Enclosure 1) to the letter

confirming the site visit. A copy of the e nclosure is included in section 5.0 of this memorandum

. EPA inquired if any confidential business information (CBI) would be discussed or transferred

during the visit. Facility representatives agree d to review notes taken by EPA and remove any

CBI.

Presentation by Formosa

Formosa Baton Rouge facility perso nnel prepared a Microsoft Power Point presentation

following the outline of Enclosure 1. Notes and key points from th e presentation are listed

be low.

Facility History

1935

– Solvay Process Company

1965

– Allied Chemical

1978

– Imperial Chemical Industries

1981

– Formosa Plastics Corporation

1981

– Increased capacity of chlorine caustic onsite, continued operation of ethylene

dichloride (EDC) 1/ v inyl chloride monomer (VCM) 1

1985

– Cogeneration added, increased VCM 1 capacity

1990

– Cogeneration capacity increased by installing additional unit

1991

– PVC plant built, installed VCM 2 plant

1995

– 3 rd gas turbine installed

1996

- 97

– E xpanded chlorin e caustic and membrane caustic terminal

2003

– Shutdown VCM 1, shutdown chlorine caustic, PVC production increased,

installed 25 ton/day d ryer

2008

– Shutdown gas turbine 1

General DiscussionMemorandum

p. 3 of 8

The facility is cu rrently expanding the VCM unit

. Expansion was originally scheduled to

be completed by early 2009, but the 2008 recession extended the project timeline. PVC

production is expected to increase with the VCM upgrade

.

PVC demand is lower than in recent years ; however

, the expansion project was approved

wh en de mand was forecasted to increase

.

The facility is currently IS O 9000 and ISO 14001 certified

.

Two main grades of resin are produced; pipe and general purpose. The plant can

produced multiple grades simultaneously and grades can be adjusted based on cus tomer

specifications. Formosa stated the main difference in resin grades are different additive

formulations fed to the reaction.

Process Description

Feedstock is unloaded in the VCM unit. A majority of process additives are brought in

via truck

.

PVC slur ry is produced by combinin g feedstock in the PVC reactors

.

The PVC slurry is transferred to steam stripping columns in an effort to remove any

residual vinyl chloride monomer ( R VCM) from the slurry . E ach stripper utilizes an

individual condenser

. Recovered VCM is sent to a “large” gas holder. VCM that cannot

be recovered is sent to the thermal oxidizers (TO’s).

Moisture is removed from the PVC slurry in 7 steam fired drying lines with particulat e

matter (PM) control

.

Screening of the product occurs after th e dryers before bein g transferred to product silos

. Dry PVC product is transferred to product silos where it is loaded into rail cars or trucks

for shipment. The silos use b ag house filters as PM control. As a rare occurrence, the

facility will ship produc t in sup er sacks upon customer request

.

Thermal Oxidizers

All process vents from the PVC unit are routed to the TO’s

. The TO units are located in

the VCM plant. Each TO is followed by a scrubber. The TO’s are sized to handle both

the PVC and VCM plant inc ineration load. One TO is generally used as a backup.

Rules and Regulations

Vinyl production is regulated under the Hazardous Organic National Emissions Standards

for Hazardous Air Pollutants (HON) rule

. PVC production is regulated under the

National Emis sions Standards for Hazardous Air Pollutants (NESHAP)

.

The PVC unit has a Prevention of Significant Deterioration (PSD) permit. The last

expansion project resulted in PM emissions triggering a PSD.

Fugitive EmissionsMemorandum

p. 4 of 8

The PVC unit fugitive emissions source s are regulated under the Louisiana n on

– HON

Maximum Achievable Control Technology (MACT) rule . Other fugitive emission

sources follow the HO N MACT

.

The PVC unit has emissions that are characterized as “insignificant” by the state of

Louisiana

. Insignific ant sources include tanks based on size and contents. Formosa

representatives could not give specific examples of any equipment classified as an

insignificant source.

Relief devices are routed to the atmosphere. Formosa has a limited number of “internal

relief devices.”

Leak Detection and Repair

The Louisiana Non

- HON MACT is followed for leak detection and repair (LDAR) at the

facility. Equipment in heavy liquid service is monitored using audio, visual, and olfactory

(AVO’s). Method 21 is used to identif y leaks. A two person contractor team performs the

LDAR requirements for the facility.

The PVC unit contains difficult

- to

- monitor equipment. Generally, any equipment is

repa ired when a leak is discovered

. If the equipment cannot be re paired the leak is pla ced

on a delay of r epair (DOR) list. A percentage cap limits how many leaks may be placed

on the DOR list. All leaks on the list must be repaired the next time the equipment is

shutdown.

Formosa representatives were familiar with the alternative work pract ice ( AWP ) but

stated the AWP did not meet the needs of the facility. EPA provided Formosa with de tails

about the instrumentation and equipment involved with the AWP.

Startup, Shutdown, and Malfunctions

The State of L ouisiana does not require a startup, s hutdown, and malfunction ( SSM )

procedure. Formosa generally does not record any SSM outside of HON requirements.

Operati ng laws require report ing of unauthorized discharges

.

Off

- spec resin

All resin (chunks cleared from reactors, over and undersized, or o therwise off

- spec) is

sold as usable product. A specific product code is attached to the resin to indicate an “off

spec” nature

.

Emissions testing

The PVC process stream that is sent to the TO was isolated for stack testing. Formosa

stated this required s ignificant ef fort and expense to accomplish

. Testing was complete d

on the TO scrubber exit to the atmosphere

.

Samples collected for resin testing were obtained by the same manner as samples taken

for normal RVCM testing

. Samples are collected, composited, and shipped to a lab forMemorandum

p. 5 of 8

analysis. Water and slurry are analyzed separately

. Typical RVCM content in the resin is

listed on the product material safety data sheet ( MSDS )

.

Adjournment and Action Items

EPA adjourned the meeting by indicat ing an additional 114 letter may be sent in an effort

to fill any data gaps or answer additional q uestions that EPA may have. Mr. Wolff reviewed the

notes taken during the meeting and removed any CBI before the meeting was adjourned.

Facility Tour

Following the meeting, Omer Wolff led EPA on a driving tour of the facility. The group

walked down the PVC unit guided by the PVC process engineer. The group viewed the PVC

production lines and control equipment.Memorandum

p. 6 of 8

5.0 Attachments

Enclosure 1

“Summary of Polyvinyl Chloride Producti on Information of Interest”

Sent to Facility on February 22, 2010Memorandum

p. 7 of 8

Enclosure 1

Summary of Polyvinyl Chloride Production Information of Interest

To assist in the collection of information during the requested site visit, an outline of

discussion topics is provided below. This outline is provided as a guide. Please feel free to

change the order based on the availability of appropriate plant personnel and complexity of the

process, its controls, and applicable regulatory requirements.

I. Polyvinyl Chlori de Production Overview

a. Short history of facility

b. Overall production capacity of facility and each process unit

c. Type(s) and grade of resin(s) produced

d. Key equipment and unique characteristics of facility

e. Unique characteristics of facility and process compar ed to other facilities in the

industry

f. Co

- located facilities

II. Polyvinyl Chloride Production Lines

a. Description of units (e.g., types of units, capacity)

b. Description of control devices (e.g., flares, thermal oxidizers)

c. Discussion of applicable emission limit s, and monitoring requirements for:

i. PM

ii. SO

x iii. NO

x iv. CO

v. Other (e.g. HAP, VCM)

d. Summary of recent source test data (if applicable)

e. Summary of monitoring capital and operating costs (if available)

f. Key differences between production lines/process units (if more than one)

g. Discussion of key factors that may or may not influence emissions

III. Combustion Sources

a. Description of units (e.g., capacity, operating frequency)

b. Are units subject to NSPS or MACT? If so, which ones and when did they

become subject?

c. Discussion of applicable emission limits, and monitoring requirements for:

i. PM

ii. SO

x iii. NO

x iv. CO

v. other

d. Summary of recent source test data (if applicable)

e. Summary of monitoring capital and operating costs (if available)Memorandum

p. 8 of 8

IV. Insignificant, Unpermitted, and Uncontrolled Air Em ission Sources

a. What insignificant, unpermitted, or uncontrolled air emission sources are at this

facility?

b. What criteria pollutants and HAP are generated and/or emitted by these sources?

c. Are these emissions monitored or quantified?

d. Summary of monitoring ca pital and operating costs (if available)

V. Leak Detection and Repair Program for Fugitive Equipment Leaks

a. Overview of leak detection and repair (LDAR) program

i. Is an integrated LDAR program used?

ii. If so, provide number of components, leak definitions, and monitoring

frequencies used

b. Is monitoring done in

- house or by a contractor?

c. What type of monitoring method is used during LDAR surveys?

d. Are repairs performed in

- house or by a contractor?

e. Typical annual LDAR monitoring costs?

VI. Start

- up, Shutdown, and Malf unctions

a. How often do you have start

- up and/or shutdown events?

b. Do you keep a log of start

- up and/or shutdown events?

c. How often do malfunction events occur at your facility?

d. What types of malfunction events occur?

e. Do you keep a log of malfunction events?

VII. Plant Tour

a. Priority items to be observed during tour include:

i. Production Lines

ii. Control Equipment

b. Insignificant, unpermitted, and uncontrolled air emission sources