MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Colin Hayes, ERG

DATE: April 12, 2010

SUBJECT: Summary of September 1, 2009 Meeting and Visit to OxyVinyls, Pasadena, 

TX

1.0 Introduction

On September 1, 2009, EPA visited the OxyVinyls Pasadena, TX facility for a meeting 

with plant personnel and a tour of the PVC production facility. This meeting was conducted to 

support EPA‟s effort to develop national hazardous air pollutant emission standards for the 

Polyvinyl Chloride (PVC) and Copolymers Production source category.

2.0 Date and Location

September 1, 2009

8:30 AM

OxyVinyls, LLC

Pasadena, TX

3.0 Attendees

Jodi Howard US EPA

KC Hustvedt US EPA

Jason Dewees US EPA

Colin Hayes ERG

Barry Christiansen Manager of Air Quality, OxyVinyls

Karenanne Stegmann Plant Manager, OxyVinyls

Mike Moran Tech Manager, OxyVinyls

Ray Givonetti Director-Env, OxyVinyls

Al Collins Sr. Dir. Reg. Affairs, OxyVinyls

Mark Woodall Env. Mgr., OxyVinyls

Steve Kemp VP-HES&S, OxyVinyls
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4.0 Summary of Meeting

Following a safety orientation and general introductions, EPA gave an overview of the 

Clean Air Act (CAA) mandate and the general rulemaking process. There was a general 

discussion about the schedule for promulgation of the rule for the PVC source category. The 

following items were discussed:

Under the CAA, since there are less than 30 sources in the PVC source category, 

EPA has to set the floor based on the top 5 performers.

OxyVinyls asked if that top 5 is on a facility basis or a company basis.

EPA stated that the rule making process has not been ideal, and asked in the 

future, what would an ideal information collection process look like?

OxyVinyls then gave a presentation on their PVC process. All of the information 

presented was claimed to be confidential business information (CBI). Following the 

presentation, the following topics were discussed:

EPA asked about how the facility handles “off-spec” resin. OxyVinyls responded 

that there are four sources for „off-spec” resin: (1) the dryer area (oversize from 

screens, collected in 1000 lb Gaylord boxes, used as a filler in rugged products, 

excess heat history, off-color); (2) maintenance cleanouts (up and downstream 

from stripper, “reactor-chunk” material, this material is sold, processed, ground 

and sold to offsite customers); (3) resin carry-over into recovery process during 

off-gassing; reclaim resin; and (4) dry material sweeps. OxyVinyls added that 

they have MSDS for all of these products and that they are legitimate products.

EPA asked if there was any way to recover VCM from materials that hasn‟t 

reached the stripper. Oxy responded there is no way for “reactor chunks”, but yes 

for other streams. Oxy added that other customers take that material and process 

it further. This material is not a large percentage of business.

OxyVinyls noted that water from the centrifuge goes through the steam stripper. 

The reactors are washed and rinsed and have a proprietary reactor coating 

technology. Resin water and centrifuge water goes to ponds and biological 

treatment systems. Less than 200 ppb (hazardous waste regulation).

EPA asked about start-up, shutdown, and malfunction provisions (SSM).

OxyVinyls noted that low-pressure slurry tanks are equalized with gas holders. 

There is a cryogenic recovery process for VCM prior to the thermal oxidizer

(TO). There is a dedicated gas chromatograph (GC) at the scrubber outlet. 

Monitoring is performed at the inlet and outlet of the TO.

There are 7 GC‟s and 105 monitoring points. The plant follows NESHAP area 

monitoring.
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For LDAR, there are 60,000 components. Pumps, compressors, etc. are 

monitored quarterly; connectors are monitored annually. The plant uses a 500 

ppm leak definition and a 200 valve random survey.

Following the presentation and discussion, there was a walking tour of the PVC process 

followed by a break for lunch. Following the lunch break, the following topics were discussed.

OxyVinyls asked if EPA plans to conduct a webinar related to testing.

EPA noted that it has not received many comments on the survey itself. 

OxyVinyls noted it may have some comments to come at a later date.

There was general discussion regarding required testing and the overall schedule.

OxyVinyls asked how long EPA would take to look over the sampling and testing 

plan. EPA responded it would likely take about 2 weeks to a month to review.

OxyVinyls asked about how many people were involved in the rulemaking 

process.

EPA discussed concerns over CBI being submitted by facilities.

There were some questions from OxyVinyls regarding the final date for rule 

promulgation.

EPA asked OxyVinyls if the Agency narrowed the data request, would it be 

missing anything important. EPA added that 2008 data is a minimum, but the 

industry is free to submit anything beyond that if it felt that the data is necessary 

for representativeness.

Discussion on Resin Sampling

There was some discussion on the scope of the resin sampling program. 

OxyVinyls asked if EPA was looking for normal operations, worst case, etc. and 

that the facilities need additional guidance from EPA in order to design an 

acceptable sampling plan. OxyVinyls stated that it has narrowed its potential 

sampling points down a couple of process lines.

EPA asked what OxyVinyls thought might be average HAP values in resin and 

how those levels might vary over a certain averaging times. OxyVinyls asked if 

EPA was open to talking about averaging and EPA acknowledged that it was, and 

added that enforcement likes shorter averaging times.

OxyVinyls added that it has a lot of VCM data and it is getting more data on other 

HAP. OxyVinyls stated that it is looking at about 500 samples of resin that have 

to be taken and a separate analysis needs to be performed for each HAP. 

OxyVinyls added that they currently only analyze for VCM and other HAP 

concentrations will/may be much lower than the VCM concentrations.
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OxyVinyls noted that only a few labs can analyze for acetaldehyde and added that 

other companies may run into similar issues with the availability of testing and 

lab resources.

OxyVinyls noted that some process equipment may not be running during the 

testing window.

OxyVinyls noted that there are some specialty resins—those that may have higher 

HAP content but may only be produced a couple of times per year. Longer 

averaging periods may take care of those if data from producing those resins are 

not accounted for in setting limits.

There was some discussion on raw materials and how some plants choose certain 

raw materials over others. EPA noted that speciated HAP and knowing what 

those are will be important down the road, i.e., for residual risk. EPA added that 

it would be good to make the Agency aware of unique process/product data so 

that companies do not limit themselves.

For other HAP, OxyVinyls asked EPA how the Agency intends to ensure a level 

playing field. EPA noted that it looked at the NEI to help determine the list of 

HAP.

OxyVinyls noted that EPA needs to strive for rapid approval of the sampling 

plans. EPA asked that the plans be submitted as soon as possible. EPA added 

that they will not have time to meet with industry to review plans prior to being 

submitted.

Discussion on Thermal Oxidizer Testing

EPA asked if there would be a problem with entrained water droplets; and if not, 

it may be possible to move some of the test methods up to scrubber outlet. HCl 

removal across the scrubber is important.

There was additional general discussion on test methods.

OxyVinyls noted that the inlet to the TO is a pressurized line and that no inlet 

methods are isokinetic (Method 26 is an option).

EPA noted it would like everything run at the same time, but if this is not possible

then the Agency can work with them.

OxyVinyls noted that with 2 TOs, it can only force flow through one, but if the 

Agency wants testing at maximum conditions, they may not want to do that. The 

company can run both, but both are sized to run individually. OxyVinyls noted 

that it could run the test with cryo system down; that would give max 

concentration to the TOs, but it is not normal to have cryo system down.

Miscellaneous Topics
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EPA noted that it may possibly try to develop emission factors for the industry. 

As data is collected, EPA will update a database. Tom Driscoll wants to work 

with industry.

EPA added that for emission sources raised as areas of concern by Region 6, such 

as gas holders, off-spec piles, etc., EPA is open to suggestions from industry on 

those sources.

OxyVinyls inquired as to EPA‟s approach with respect to wastewater. EPA 

responded that it would likely consider requiring an enclosed trench to 

biotreatment; activated sludge; and steam strippers. This would be similar to 

what is required in other rules. OxyVinyls noted that the wastewater system starts 

at outlet of steam stripper.

30 day CEMS not required on the dryers.

OxyVinyls noted that its Pedricktown facility is a minor source and shares the site 

with PolyOne. OxyVinyls asked how EPA intends to treat minor sources. EPA

noted that it was not aware of any minor sources.

The meeting concluded at approximately 2:00 PM.