MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: April 12 , 2010

SUBJECT: S ummary March 3, 2010 US EPA visit to Georgia Gulf Chemicals & Vinyls,

Plaquemine, LA

1.0 Introduction

On March 3 , 20 10

, US EPA vis ited the Georgia Gulf Chemicals Plaquemine , 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 PVC and Copolymers Production source category.

2.0 Date and Location

March 3, 2010

Georgia Gulf Chemicals & Vinyls, LLC 26100 Louisiana Highway 405 Plaquemine, LA 70764Memorandum

p. 2 of 10

3.0 Attendees

Name Affiliation Anthony Bonille Georgia Gulf Ch emicals / PVC Production Engineer

Nate Johnson Georgia Gulf Chemicals / EHS&S Superintendent (Aberdeen) Anthony Fugarino Georgia Gulf Chemicals / Environmental Engineer Danny Cedotal Georgia Gulf Chemicals / PVC Production Manager

Daniel J. Bro wn Georgia Gulf Chemicals / Atl Corporate Council

Dave Goldsmith Georgia Gulf Chemicals / Principal Engineer,

Environmental Services Wayne Cooper Georgia Gulf Chemicals / Principal Engineer, VCM

Production Charles Freeburgh Georgia Gulf Chemica ls / General Manager of Operations

Jodi Howard US EPA Colin Hayes ERG Philip Crawford ERG

4.0 Summary of Visit

The meeting with Georgia Gulf Chemicals (GGC) representatives began at approximately

8:00 A M . A summary of the meeting’s discussion foll ows.

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 issuance of the section 114

survey. EPA indicated that the group was visiting the plant t o 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 agreed to review notes t aken by EPA and remove any

CB I.

Presentation by GGC Plaquemine

The GGC Plaquemine facility personnel prepared a Microsoft Power Point presentation following the outline of Enclosure 1. Notes and key points from th e presentation are listed

below.

General Discussion

The Plaquemine f

acility nameplate capacity is 1.65 billion pounds (lbs.) of PVC per year.The facility operates 5 production units including chemicals, cogeneration,

caustic/chlorine, and PVC. The chemicals division produces vinyl chloride monomer (VCM).

A majority of VC M produced is used in their onsite PVC production operations . If Excess VCM is produced, it can be loaded into railcars; this usually does not occur.

Plant History

19 75

– Facility startup: 3 trains, 9 reactors, internal stripping and open charging

1979

– Expansion: 3 trains, 12 reactors, stripping columns added, closed charging

1989

– Expansion: 3 trains, 14 reactors, dryers added

1994

– Expansion: 4 trains, 18 reactors, 2 dryers added, 3 silos added

2003

– Upgrade: distributed control system (DCS) upgra de, controls were previously panel mounted and slow upgrades occurred until the entire system was replace d with

DCS

2007

– Expansion: 5 trains, 20 reactors, 1 dryer added, the first 18 reactors are identical, the new train has larger reactors and condenser s for more effective cooling and quicker

batch reaction time

Resin Grades

13 different grades of PVC resin are produced at GGC Plaquemine. The facility produces 7 low molecular weight (MW) grades, 1 mid MW grade, and 5 high MW grades. Different grades exh ibit characteristics that define the end product. Reaction temperature during production is the main difference between resins grades.

Low weight grades are made on trains 1 and 2. Pipe grades are made on trains 2, 3, 4, and 5 (60% of production). Specialt y grades are produced on trains 2, 3, and 4. Train 4 is generally dedicated to specialty grades.

Resins produced under low temperature conditions are rigid and are commonly used i n applications such as electrical boxes. Resins produced under mid range temp eratures are general purpose and used in applications such as PVC piping. Resins produced under high temperature conditions are used in flexible applications.

EPA discussed concerns of different resin grades and different emissions levels. GGC

stated that rigid applications produce a small pore resin particle which is more difficult to strip.

Process Description

VCM and water are charged to the reactor

. Some of the reactors are rated for higher pressures. This allows GGC to produce particular grades w ithou t using certain additives

. The PVC slurry is transferred to blow down tanks w h ere mo st of the residual vinyl chloride monomer (RVCM) flashes

. The GGC Plaquemine facility does not use floatingroof tanks. All VCM recovery equipment is considered pressure ve ssels. VCM is

compressed into a liquid state for recovery.

R VCM is removed from the PVC slurry in steam stripping columns. All of the dump and blend tanks after the stripping columns are atmospheric

. After recovering VCM, non

condensa ble gases (NCG’s) are routed to 3 thermal oxidizer (TO) units

. VCM is not recovered after the stripping process.

The slurry moisture content is approximatel y 60% by volume after stripping

. The slurry

is trans ferred to centrifuges to reduce the moisture content . Remaining mois ture content after the centrifuges is approximately 25% by volume. The Plaquemine facility uses flash dryers (steam coil air heaters) and fluidized bed dryers for final moisture content

removal

. Over 99% of product produced is shipped by railcar

.

Thermal Oxidizers

The TO units are located in the VCM plant. Two of the units are dedicated to the destruction of products from the VCM and PVC units. The units incorporate waste heat

boilers. One of these units generally operates in standby to handle process ups ets. The third TO is an industrial furnace which destroys heavy end products from the VCM unit.

The TO units have 3 inlets; “ wet, ” “ dry, ” and “ oxy. ” Firebox temperatures are approximately 2200 degrees Fahrenheit (°F).

Flue gas from the TO units is routed to scrubbers . The scrubbers contain a hydrogen chloride (HCl) recirculation section and a caustic recirculation section for HCl removal.

A permit for the incineration section of the plant covers all 3 TO’s. GGC Plaquemine

stated that HCl emissions do not approach permitted level. In 2008

, the plant emitted 28

tons of HCl.

The largest capital cost for th e TO’s is the continuous emissions monitoring system ( CEMS ) analyzer ($175 thousand ). Maintenance costs total approximately $1.14 million

per year.

Water and Waste Water

Process water is sent to clarifiers and used as cooling water across the site. The plant uses well water and discharges to the river that is located to the north and east of the plant

. Storm water drains to the water treatment system and is then discharged to the river.

Emergency Power Generation

The facility operates emergency power generation units. The power produced by these

units is generally used by agitators to aid in the restart of plant equipment

.

Facility Emissions

GGC Plaquemi ne provided information on emissions from the PVC unit.Hazardous air pollutants (HAP ’ s) potentially emitted by the PVC unit include c umene
,

acetophenon e , methanol, vinyl acetate, acetaldehyde, and hydroquinone. GGC Plaquemine present ed 5 slides of emissi ons components for the facility. Metals, dioxin / furans, and polychlorinated biphenyls were among the emissions presented

. Emissions from the PVC unit are capp ed at the following (tons/year) :

 Particulate Matter (PM)

– 1054.8

 Volatile Organic Carbons ( VOC )

– 49.15

 Methanol

– 12.95

 Vinyl Chloride (VC)

– 10.73

 Phenol

– 1.36

 Chloroform

– 0.2

The GGC Plaquemine facility holds a different permit for each production unit and has 7 permits total. T he plant stated the effectiveness of having 7 permits is expressed when upgrading a single unit; the need to re

- pe rmit the entire facility is nonexistent

. The plant

holds Prevention of Significant Deterioration (PSD) and nitrogen oxide (NOx) permits

. The PVC unit does not have a NOx permit. The plant does not have a 112 j permit due to
modifications made in 2007

. The facility uses a variety of contro l equipment to reduce emissions including stripping columns, condensers, cyclone separators, scrubber s , bag filters (for pneumatic conveying), clarifiers, and TO’s.

Leak Dete ction and Repair

GGC Pla quemine stated they employ an “e nhanced leak detection and repair (LDAR) ”

monitori ng program as a result of a consent decree with EPA Region 6

. The program

consists of greater monitoring frequenc ies a nd lower leak detection levels

. Monitoring frequencie s for AGI and pumps are monthly. A ll other equipment is monitored on a quarterly basis

. Equipment counts in the LDAR program were presented.

The “Enhanced LDAR” program is performed by GGC Plaquemine employees using Method 21. If repai rs can be made easily they are completed by the monitoring personnel, if not, the repairs are handed over to operations. If operations cannot complete the repairs, maintenance personnel or contractors will be assigned the work.

Louisiana DEQ constitutes a fugitive emissions p rogram, the n on

- Hazardous Organic

National Emissions Standards for Hazardous Air Pollutants Maximum Achievable Control Technology (non

- HON MACT)

. The n on

- HON MACT is similar to the HON rule in that it requires method 21, but it does not require connector s . Testing frequencies are also less stringent th an the HON rule. During a permit modification the facility asked

to transfer to the HON

- LDAR

. The facility LDAR program costs approximately $155 thousand per year including repair,

technic ians, supervision, information technology ( IT ) support, and equipment costs.The facility has difficult

- to

- monitor equipment which is checked on a yearly basis

.

T here is no unsafe

- to

- monitor equipment in the PVC plant, but other units in the plant

have b oth unsafe

- and difficult

- to

- monitor equipment

. Difficult

- to

- monitor equipment is

checked mid

- year and repairs are general ly made at the time of testing

. Associated connectors and fittings are also check ed during the annual inspection

. If the plant experie nces a leak which would require a facility wide shutdown for repair by in

- house maintenance, contractors with advanced repair techniques are consulted to determine if the repair can be completed while the facility is on

- line. GGC Plaquemine states that a

d elay o f repair is a rare occurrence and they currently have no backlog

. GGC Plaquemine has investigated the Alternative Work Practice (AWP) and stated the AWP did not meet facility needs any bet ter than the current Method 21

.

Fugitive Emissions

Fugitive e missions sources include operation ’ s activities , filter cleaning, slurry sampling, dryer sampling, screener cleaning, and equipment preparation for maintenance. Maintenance activities that produce fugitive emissions include painting, instrumentation work, shop work on equipment, and testing emergency cooling tower equipment.

Fugitive emissions are also produce d from reactor openings. Older PVC trains are opened every 4 to 5 months. The newest train is opened about once a year. Trains are not opened

more or less frequently based on product grades.

Emissions Testing as a Result of the 114 Survey

A survey of raw materials was completed before emissions testing was conducted so plant personnel would kn ow which components to look for

. Acetophenone was found in higher levels than expected

. Dioxins were a tenth of a pictogr am per dry standard cubic meter (DSCM) lower than 10 years ago

. During stack testing at the Aberdeen facility, the stack testers stated they didn’t se e anything out of the ordinary

.

The metho d for collecting resin samples during testing is outlined in the cover lett er for the facility ’s stack test report

. Inlet testing to the TO wa s conducted on streams from the PVC production unit. O utlet testing included both the PVC and VCM production units

. GGC Plaquemine outlined the costs for testing as a result of the 114 survey. Lab and testing services were about $250 ,000 . Instrumentation totaled approximately $30 ,000

. Personnel costs were about $30 ,000 . The total cost to date for the Plaquemine facili ty was $310 ,000 . Aberdeen reported a similar cost. GGC estimated the total costs around $550 ,000 to $600 ,000 for the company. EPA acknowledged that testing costs may have been high, but emphasized the importance of obtaining quality data and fulfilling all requirements the first time.

Timin g was a limiting factor for GGC

. GGC wanted to use the same contractors for

con sistency between facility tests. EPA responded that timing was limit ing for the

A gency as well, as the propos ed rule is due in October, 2010

.

G GC mentioned that results on a required 3% O 2 dry basis were difficult to obtain

.Startup, Shutdown, and Malfunction

GGC Plaquemine stated a startup, shutdown, and malfunction ( SSM ) plan wa s not required for the PVC unit. GGC indicated that due to the ba tch nature of PVC production, emissions are generally not affected by most startup and shutdown scenarios

. EPA

indicated that the startup and shutdown general provisions in Part 63 were vacated and

the PVC MACT r ule may include startup and shutdown provis ions specific to the source

category

.

Facility Tour

Danny Cedotal and Dave Goldsmith provided EPA a driving and walking tour of the Plaquemine facility and the PVC unit. Anthony Bonille accompanied the group for the walking tour of the PVC facility.

Ad journment and Action Items

Following the plant to ur a wrap

- up meeting was held with GGC representatives.

GGC Plaquemine inquired if previous work had been “tras hed” due to th e recent law suit. EPA responded that the initial process did not start well, bu t the situation was improving

. GGC Aberdeen asked for a more specific date for the MACT proposal deadline. EPA

indicated the court

- ordered deadline of October 30 th , 2010

. GGC Plaquemine agreed to provide EPA with a copy of the presented material; all CBI

removed

.

The EPA stated seeing an older plan t with a new er process line was beneficial

. EPA stated more meetings wil l occur, but at this point the A gency is still trying to

deter mine the best course of action

.

EPA adjourned the meeting by indicating an ad ditional 114 letter may be sent in an effort to fill any data gaps or answer additional questions that EPA may have. Mr. Cedotal reviewed the notes taken during the meeting and removed any CBI before the meeting was adjourned.5.0 Attachment

Enclosure 1 “Summary of Polyvinyl Chloride Production Information of Interest”

Sent to Facility on February 22, 2010Enclosure 1

Summary of Polyvinyl Chloride Production Information of Interest

To assist in the collection of information during the requested s ite 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 r egulatory requirements.

I. Polyvinyl Chloride 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 char acteristics of facility and process compared 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 oxidizer s)

c. Discussion of applicable emission limits, 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 betwe en 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)IV. Insignifi cant, Unpermitted, and Uncontrolled Air Emission 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 monitor ed or quantified?

d. Summary of monitoring capital 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 nu mber 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 monit oring costs?

VI. Start

- up, Shutdown, and Malfunctions

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