MEMORANDUM

TO: Samantha Lewis, EPA 

 Paul Shriner, EPA 

FROM: Lori Weiss, ERG 

 Meghan Kandle, ERG 

DATE: August 24, 2005 

SUBJECT: VCCA Industry Trade Group Meeting 

 EPA staff and their contractors met with representatives from industry 

trade associations to discuss August site visits at four plants in Houston Appendix A 

contains a list of the attendees. This memorandum summarizes the meeting discussion 

points. 

Schedule for Site Visits 

EPA gave a brief overview of the schedule for site visits: 

− Monday, August 29 – Formosa Plastics, Point Comfort, TX. 

− Tuesday, August 30 – Oxyvinyls LaPorte, TX: This site visit was scheduled for 

a tour of the EDC/VCM manufacturing plant. EPA requested an additional tour 

of the Battleground Chlor-alkali plant on this day. 

− Wednesday, August 31 – Dow, Freeport, TX: This site visit will include a tour 

of chlor-alkali processes in Plant A, EDC/VCM processes in the Oyster Creek 

Plant, and the wastewater treatment system in Plant B. 

− Thursday, September 1 – Oxyvinyls Pasadena, TX. 

 In addition to the tour of relevant vinyl chloride and chlor-alkali (VCCA) process 

lines and wastewater treatment, EPA requested a tour of any additional chlorine-using 

process lines on site. EPA would also like to view potential sampling points for 

collecting source water samples. 

 EPA will not be permitted to bring a digital camera to the site visits. Facilities 

will take pictures of potential sampling points using their own digital cameras. The plant 

manager will review photos before sending them to EPA. 

 EPA asked industry about PPE requirements for site visits. Clothing should 

consist of long sleeve shirts and pants. Shoes must be steel-toed boots. The companies 
will check with each site regarding contact lenses. EPA asked each site to provide the 

following items prior to the week of the site visits: 

− List of PPE requirements; 

− Directions to facility; 

− Facility contact phone number; and 

− Process flow diagrams of facility. 

EPA provided industry with a list of questions to be covered during site visits (Appendix 

B). 

Review of Chlor-Alkali and EDC/VCM/PVC Processes 

 Art Dungan of the Chlorine Institute provided an overview of the chlor-alkali 

manufacturing process. The presentation covered the following topics: 

− Description of differences between diaphragm, membrane, and mercury cell 

processes, including purity of caustic product and brine recycling; 

− Sources of process wastewater; 

− Variability in brine preparation process due to purity of the salt feed and 

specifications on brine purity for different cell types; and 

− Use of titanium anodes instead of graphite electrodes. 

 Industry provided a handout that described the processing steps and included two 

process flow diagrams from the OCPSF section of the 2004 TSD (Appendix C). John 

Westendorf of Occidental Chemical Corp provided comments on the process flow 

diagrams. Specifically, the Membrane/Diaphragm Cell Diagram (Figure 6-6) should be 

two separate PFDs due to differences in the processes and waste streams produced. 

 Frank Borelli of the Vinyl Institute (VI) presented an overview of the 

EDC/VCM/PVC processes. The presentation covered the following topics: 

− Description of chemical reactions, reactor types, and reactor conditions for direct 

chlorination, oxychlorination, EDC cracking, and VCM polymerization; 

− Conclusions from the VI report regarding dioxin formation during each reaction; 

− Discussion of dioxin formation and carry-over into wastewater in fixed- and 

fluidized-bed oxychlorination reactors; 

− Description of processing steps in EDC, VCM, and PVC manufacturing processes 

and sources of process wastewater; and 
− Description of incinerators and wastes generated. 

 Following the presentation, EPA asked for clarification of which wastewaters 

were sampled during the VI sampling program. All water samples were of treated 

wastewater. VI has never sampled water from the PVC process prior to treatment. 

Conclusions made regarding potential for dioxin formation were based on a review of the 

process. Industry offered to send copies of the presentation slides to EPA. 

 EPA also asked about other methods of manufacturing chlorine. Industry knew of 

a US Magnesium plant in Utah that recovers chlorine as a by-product of magnesium 

production and a DuPont plant in Niagara Falls that uses the sodium process. Industry 

stated that these facilities should be included in the survey. 

EPA Information Summary/Information Needs for Each Site 

 EPA provided a spreadsheet indicating what information has been collected and 

reviewed on the four Houston sites. Industry provided a list of documents/data sources 

that EPA should review. These items can be found in Appendix D. The trade 

associations will provide their comments on the draft Dioxin Inventory to EPA. 

 EPA requested that the trade associations review the list of VCCA facilities to 

ensure that it is complete and provide any updates regarding facility closures or changes 

of ownership. 

 Industry also expressed an interest in reviewing the underlying TRI and PCS data 

EPA has reviewed. Industry will provide comments on any data errors. 

Sampling and Analytical Plans 

 Industry requested that EPA provide a preliminary list of analytes for the 

sampling program. EPA will provide a list to the trade associations. Industry also 

requested an opportunity to review the QAPP and Sampling Plan prior to each sampling 

episode. EPA offered to provide an approved QAPP from another rulemaking to show 

Industry the type of information that is included in the QAPP. Site-specific Sampling 

Plans will be provided to facilities at least 30 days prior to sampling. 

 EPA mentioned that the sampling program may be more efficient if the facilities 

collect and preserve the samples for EPA. Industry indicated that some facilities may be 

interested in this approach. Decisions will be site-specific. 

Schedule of Events Following Visits 

 EPA will continue to work with industry in finalizing the schedule for grab and 

multi-day sampling episodes. The trade associations would also like to review the 

industry questionnaire. EPA will keep industry informed of the overall project schedule. 

EPA tentatively plans to have a draft questionnaire for industry review during the fourth 
quarter of 2005, grab sampling may occur during the first quarter of 2006, followed by 

multi-day sampling in the third quarter. 

Impacts on 2006 ELG Plans 

 EPA explained that the facilities that are included in the VCCA scope are 

excluded from the OCPSF and Inorganic Category Reviews for the 2005 Preliminary 

Plan. Industry may provide any additional comments on the 2004 review of VCCA 

facilities to EPA. 

 
Appendix A 



Appendix B 
Appendix B 

Site Visit Checklist for VCCA Facilities 

 The following list of questions is to be used as a guide during site visits to obtain 

information that will expand the technical profile of the industry, identify and 

characterize process and treatment technologies, and identify sample points and other 

pertinent information should the facility be selected for future sampling. 

I. INTRODUCTION/PURPOSE OF SITE VISIT

I-1. Introduction to VCCA component of regulatory development effort. 

I-2. Purpose of site visits. 

I-3. Prepare attendance list. 

I-4. Discuss CBI considerations (including photos). 

II. GENERAL FACILITY INFORMATION 

II-1. Site name, location, parent company. 

II-2. Facility contact, name, title, telephone number. 

II-3. Facility age and size (e.g., number of employees). 

II-4. Operating information (e.g., hours/day, days/week, shifts). 

II-5. Chemicals manufactured. 

II-6. Number of production plants/process or product lines. 

II-7. Production volume of relevant VCCA chemicals for each of the past five 

years. 

II-8. List of permitted outfalls discharging VCCA wastewater, discharge 

volume, and percent of wastewater from VCCA operations. 

II-9. Process flow diagrams. 

III. PROCESS SPECIFIC INFORMATION 

Chlor-alkali: 

III-1. How many chlor-alkali units are onsite? 

III-2. What type of cell does each unit use (i.e. mercury, membrane, or 

diaphragm)? 

III-3. What types of cathodes and anodes are used? 

III-4. What raw materials are used and what is the source of the raw materials? 

III-5. Describe the brine recovery system. 

III-6. Describe the chlorine gas cooling stage. What type of condenser is used? 

Are chlorine condensates discharged or recycled through brine recovery? 

III-7. Is the chlorine product sold or used for other processes on site? 

III-8. Describe any by-product recovery including caustic purification and 

hydrogen gas purification. 
III-9. Are by-products from the chlor-alkali process used in other processes on 

site? 

III-10. Describe all wastewater streams from the chlor-alkali process line and the 

destination of each stream. 

III-11. What steps in the chlor-alkali process require air pollution control? Are 

any WAPC devices used to control emissions? 

III-12. Are any P2 or in-process treatment technologies used in the chlor-alkali 

process line? 

III-13. What listed hazardous wastes are generated? How are these handled? 

EDC and EDC/VCM: 

III-14. How many of the following process lines are operated onsite: 

− Stand-alone direct chlorination to produce EDC? 

− Direct chlorination/oxychlorination balanced process to produce EDC 

and VCM? 

III-15. What raw materials are used and what is the source of the raw materials? 

Are any raw materials treated prior to direct- or oxychlorination? 

III-16. Describe the direct chlorination and oxychlorination reactor(s). If multiple 

reactors are used, are they operated in series or in parallel? What type of 

bed (fluidized or fixed) does each oxychlorination reactor use? 

III-17. Is the crude EDC from direct chlorination treated prior to commingling 

with crude EDC from oxychlorination? 

III-18. Describe any treatment (including cooling) that the crude EDC from 

oxychlorination receives prior to commingling with EDC from direct 

chlorination? 

III-19. Describe the EDC purification process. 

III-20. What percentage of the EDC product is used to produce VCM? Do any 

other processes use the EDC product on site? 

III-21. Describe the EDC cracking furnace. 

III-22. Describe the VCM purification process 

III-23. Describe the HCl recovery process. 

III-24. Is VCM product used to manufacture PVC on site, used for other 

processes on site, transported to another site, or sold? 

III-25. Describe all wastewater streams generated during EDC/VCM production 

and the destination of each stream. 

III-26. What steps in the EDC/VCM process require air pollution control? Are 

any WAPC devices used to control emissions? 

III-27. Are any P2 or in-process treatment technologies used in the EDC/VCM 

process line? 

III-28. Are vent gases from hazardous waste incinerator HCl absorption columns 

neutralized? Describe neutralization systems. 

III-29. What listed hazardous wastes are generated? How are these handled? 
PVC: 

III-30. What is the source of the VCM feed? Is VCM treated prior to 

polymerization? 

III-31. What type of polymerization reactor do you operate? 

III-32. Describe the PVC purification process. Are steam strippers used? 

III-33. Describe the PVC dewatering step. 

III-34. Describe the VCM recovery process. 

III-35. What wastewater streams are generated from each manufacturing 

operation? 

III-36. What steps in the PVC process require air pollution control? Are any 

WAPC devices used to control emissions? 

III-37. Are any P2 or in-process treatment technologies used in the PVC process 

line? 

III-38. What listed hazardous wastes are generated? How are these handled? 

IV. WASTEWATER TREATMENT

IV-1. Describe wastewater treatment system. 

IV-2. Is VCCA wastewater commingled with other streams prior to treatment? 

IV-3. Are any technologies used to remove dioxin from wastewater? Are these 

technologies applied before or after commingling with other wastewater? 

Are they before or after wastewater treatment? 

V. GATHER INFORMATION FOR POTENTIAL SAMPLING 

V-1. What streams are currently monitored?

V-2. What streams can be sampled at each site? Which streams cannot be 

sampled? EPA would like to characterize process water from VCCA 

operations, wastewater from other chlorine-using product lines, 

wastewater treatment influent, and wastewater treatment effluent.

V-3. What is the discharge frequency/duration for each stream?

V-4. What are the site-specific health and safety requirements? What type of 

PPE is required?

V-5. Can EPA personnel collect the samples or will facility personnel be 

required for the sample collection?

V-6. Are there sample-point specific health and safety concerns?

V-7. Are there any sample-point specific considerations (e.g. use of cooling 

coils for hot streams)?

V-8. What are the conditions at each sampling point (e.g. temperature, pH, flow 

rate)?

V-9. Can composite samples be taken?

V-10. Is there space available for use as a sample staging area? 
Appendix C 




Appendix D