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 Produ ction 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 Wood all Env. Mgr., OxyVinyls Steve Kemp VP

- HES&S, OxyVinylsMemorandum

p. 2 of 5

4.0 Summary of Meeting

Followin g a s afety orientation and general i ntroductions , EPA gave an over view 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 l ess 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 tha t 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 fr om 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, process ed

, 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 pe rcentage of business.

OxyVinyls noted that water from the c entrifuge goes through the steam stripper

. The reactors are washed and rinse d and have a proprietary reactor coating technology

. Resin water and c entrifuge water goes to ponds and biological

tre atment 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 holder s

. There is a c ryogenic recovery process for VCM prior to the thermal oxidizer (TO). There is a d edicated 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

.Memorandum

p. 3 of 5

For LDAR, there are 60,000 comp onents. 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 w alking tour of the PVC process followed by a break for lunch. Following the lunch break, the following topics were discussed.

OxyV inyls asked if EPA plans to conduct a webinar related to testing

. EPA noted that it has not received many comments on the su rvey 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 wo uld take to look over the sampl ing and testing plan. EPA resp onded 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 i s free to submit anything beyond that if it felt that the d ata 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. OxyV inyls 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 level s might vary over a certain averaging time s. OxyVinyls asked if EPA was open to talking about averagin g 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 get ting more data on other

HAP

. Oxy Vinyls 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 cu rrently only analyze for VCM and o ther HAP

concen trations will/may be much lower than the VCM concentrations.Memorandum

p. 4 of 5

Oxy Vinyls noted that only a few labs can analy ze for acetaldehyde and added that other companies may run into similar issues with the availability of testing and

lab resources

. Oxy Vinyls noted th at 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 pe r year. Longer averaging perio ds may take care of thos e if data from produc ing those resins are not accounted for in setting limits.

There was som e discussion on raw materials and how s ome 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 u nique process/product data so that companies do not limit themselves.

For other HAP, Oxy Vinyls asked EPA how the Agency intends to ensure a lev el 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 wi ll not have time to meet with industry to review plans prior to being

submitted.

Discussion on Thermal Oxidizer T esting

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 u p to scrubber outlet

. HCl removal across the scrubber is important

. There was additional general discussion on test methods

. Oxy Vinyls noted that the inlet t o the TO is a pressurized line and that no inlet methods are isokinetic (M ethod 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 w ith 2 TOs, it can only force flow through one, but if the Agency wants testing at max imum cond ition s
, they may no t want to do that. The

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

that it could r un the test with cryo system down; that would give max concentration to the TOs, but it is not normal to have cryo system down

.

Miscellan eous TopicsMemorandum

p. 5 of 5

EPA noted that it may p ossibly 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 Re gion 6, such

as gas holders, off

- spec piles, etc., EPA is open to suggestions from industry on

those sources

. Oxy Vinyls inquired as to EPA‟s approach with respect to wastewater. EPA responded that it would likely consider requiring an e nclosed trench to

b i otreatment; activated sludge; and steam stripper s . This would be similar to what is required i n other rules. OxyVinyls noted that the wastewater system starts at outlet of steam stripper

. 30 day CEMS not required on the dryers

. Oxy Vinyls noted that its Pedricktown facility is a minor source and shares the site with PolyOne. Oxy Vinyls 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.