### 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 me t with representatives from industry trade associations to discuss August site visi ts at four plants in Houston Appendix A

contains a list of the attendees. This me morandum 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 manu facturing 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 vi nyl chloride and chlor-alkali (VCCA) process lines and wastewater treatment, EPA request ed a tour of any additional chlorine-using process lines on site. EPA would also lik e to view potential sampling points for collecting source water samples.

EPA will not be permitted to bring a digita l 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 requireme nts for site visits. Clothing should consist of long sleeve shirts a nd pants. Shoes must be steel-toed boots. The companieswill 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 presen tation covered the following topics:

− Description of differences between di aphragm, membrane, and mercury cell processes, including puri ty of caustic product and brine recycling;

− Sources of process wastewater;

− Variability in brine preparation proce ss 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 descri bed the processing step s 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/Diaphr agm 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 presen tation covered the following topics:

− Description of chemical reac tions, reactor types, and r eactor conditions for direct chlorination, oxychlorination, EDC cracking, and VCM polymerization;

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

− Discussion of dioxin formation and carry- over into wastewater in fixed- and fluidized-bed oxychlor ination reactors;

− Description of processing steps in ED C, VCM, and PVC manufacturing processes and sources of process wastewater; and− Description of incinerators and wastes generated.

Following the presentation, EPA asked fo r clarification of which wastewaters were sampled during the VI sampling program . All water samples were of treated wastewater. VI has never sampled water fr om the PVC process prior to treatment. Conclusions made regarding pot ential for dioxin formation we re based on a review of the process. Industry offered to send copi es 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 recove rs 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 s hould 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 li st 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 pr ovide 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 appr oved QAPP from another rulemaking to show Industry the type of information that is in cluded 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 ma y be more efficient if the facilities collect and preserve the samples for EPA. I ndustry 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 asso ciations 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 questi onnaire for industry revi ew during the fourthquarter of 2005, grab sampling may occur dur ing the first quarter of 2006, followed by multi-day sampling in the third quarter.

Impacts on 2006 ELG Plans

EPA explained that the facilities th at are included in the VCCA scope are excluded from the OCPSF and Inorganic Ca tegory Reviews for the 2005 Preliminary Plan. Industry may provide any additiona l comments on the 2004 review of VCCA

facilities to EPA.

# Appendix A

# Appendix BAppendix B

Site Visit Checklist for VCCA Facilities

The following list of questions is to be us ed as a guide during site visits to obtain information that will expand the technical profile of the industry, identify and characterize process and trea tment 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., hour s/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 ch emicals for each of the past five

years. II-8. List of permitted outfalls discha rging VCCA wastewater, discharge volume, and percent of wastew ater 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 thr ough 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 proces s require air pollution control? Are any WAPC devices used to control emissions?

III-12. Are any P2 or in-process treatment t echnologies used in the chlor-alkali process line?

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

EDC and EDC/VCM:

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

− Stand-alone direct chlori nation 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 prio r 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 chlo rination treated prior to commingling with crude EDC from oxychlorination?

III-18. Describe any treatment (including co oling) that the crude EDC from oxychlorination receives prior to co mmingling with EDC from direct

chlorination?

III-19. Describe the EDC pur ification process.

III-20. What percentage of the EDC product is used to produce VCM? Do any other processes use th e EDC product on site?

III-21. Describe the EDC cracking furnace.

III-22. Describe the VCM pur ification process

III-23. Describe the HCl recovery process.

III-24. Is VCM product used to manufact ure PVC on site, used for other processes on site, transporte d 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 wast e incinerator HCl absorption columns

neutralized? Describe ne utralization systems.

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

III-30. What is the source of the VCM f eed? Is VCM treated prior to polymerization?

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

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

III-33. Describe the PVC dewatering step.

III-34. Describe the VCM recovery process.

III-35. What wastewater streams are ge nerated from each manufacturing operation?

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

WAPC devices used to control emissions?

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

line?

III-38. What listed hazardous wastes are ge nerated? 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 charact erize process water from VCCA operations, wastewater from ot her chlorine-using product lines, wastewater treatment influent, a nd wastewater treatment effluent.

V-3. What is the discharge frequenc y/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 sample s 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 sampli ng 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