MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: April 12, 2010

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

Plaquemine, LA

1.0 Introduction

On March 3, 2010, US EPA visited 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 70764
Memorandum

p. 2 of 10

3.0 Attendees 

Name Affiliation 

Anthony Bonille Georgia Gulf Chemicals / 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. Brown 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 Chemicals / 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 AM. A summary of the meeting’s discussion follows.

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 to obtain information related 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 enclosure 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 taken by EPA and remove any 

CBI.

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 the presentation are listed 

below. 

General Discussion

The Plaquemine facility 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 VCM 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

1975 – 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) upgrade, controls were previously 

panel mounted and slow upgrades occurred until the entire system was replaced with 

DCS

2007 – Expansion: 5 trains, 20 reactors, 1 dryer added, the first 18 reactors are identical, 

the new train has larger reactors and condensers 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 exhibit 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). Specialty 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 in

applications such as electrical boxes. Resins produced under mid range temperatures 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 without using certain additives.

The PVC slurry is transferred to blow down tanks where most of the residual vinyl 

chloride monomer (RVCM) flashes. The GGC Plaquemine facility does not use floating 
roof tanks. All VCM recovery equipment is considered pressure vessels. VCM is 

compressed into a liquid state for recovery. 

RVCM 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 

condensable gases (NCG’s) are routed to 3 thermal oxidizer (TO) units. VCM is not 

recovered after the stripping process.

The slurry moisture content is approximately 60% by volume after stripping. The slurry 

is transferred to centrifuges to reduce the moisture content. Remaining moisture 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 upsets. 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 the 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 Plaquemine provided information on emissions from the PVC unit. 
Hazardous air pollutants (HAP’s) potentially emitted by the PVC unit include cumene, 

acetophenone, methanol, vinyl acetate, acetaldehyde, and hydroquinone. GGC 

Plaquemine presented 5 slides of emissions components for the facility. Metals, dioxin/

furans, and polychlorinated biphenyls were among the emissions presented.

Emissions from the PVC unit are capped 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. The plant stated the effectiveness of having 7 permits is expressed when 

upgrading a single unit; the need to re-permit 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 112j permit due to 

modifications made in 2007.

The facility uses a variety of control equipment to reduce emissions including stripping 

columns, condensers, cyclone separators, scrubbers, bag filters (for pneumatic 

conveying), clarifiers, and TO’s. 

Leak Detection and Repair

GGC Plaquemine stated they employ an “enhanced leak detection and repair (LDAR)” 

monitoring program as a result of a consent decree with EPA Region 6. The program 

consists of greater monitoring frequencies and lower leak detection levels. Monitoring 

frequencies for AGI and pumps are monthly. All 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 repairs 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 program, the non-Hazardous Organic 

National Emissions Standards for Hazardous Air Pollutants Maximum Achievable 

Control Technology (non-HON MACT). The non-HON MACT is similar to the HON 

rule in that it requires method 21, but it does not require connectors. Testing frequencies 

are also less stringent than 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, 

technicians, supervision, information technology (IT) support, and equipment costs.
The facility has difficult- to- monitor equipment which is checked on a yearly basis. 

There is no unsafe-to-monitor equipment in the PVC plant, but other units in the plant 

have both unsafe- and difficult-to-monitor equipment. Difficult-to-monitor equipment is 

checked mid-year and repairs are generally made at the time of testing. Associated 

connectors and fittings are also checked during the annual inspection. If the plant 

experiences 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 

delay of 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 better than the current Method 21.

Fugitive Emissions

Fugitive emissions 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 produced 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 know which components to look for. Acetophenone was found in

higher levels than expected. Dioxins were a tenth of a pictogram 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 see anything out of the ordinary.

The method for collecting resin samples during testing is outlined in the cover letter for 

the facility’s stack test report. Inlet testing to the TO was conducted on streams from the 

PVC production unit. Outlet 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 facility was 

$310,000. Aberdeen reported a similar cost. GGC estimated the total costs around 

$550,000to $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.

Timing was a limiting factor for GGC. GGC wanted to use the same contractors for 

consistency between facility tests. EPA responded that timing was limiting for the 

Agency as well, as the proposed rule is due in October, 2010.

GGC mentioned that results on a required 3% O2 dry basis were difficult to obtain.
Startup, Shutdown, and Malfunction 

GGC Plaquemine stated a startup, shutdown, and malfunction (SSM) plan was not 

required for the PVC unit. GGC indicated that due to the batch 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 rule may include startup and shutdown provisions 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. 

Adjournment and Action Items

Following the plant tour a wrap-up meeting was held with GGC representatives. 

GGC Plaquemine inquired if previous work had been “trashed” due to the recent law suit.

EPA responded that the initial process did not start well, but 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 30th, 2010.

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

removed.

The EPA stated seeing an older plant with a newer process line was beneficial.

EPA stated more meetings will occur, but at this point the Agency is still trying to 

determine the best course of action.

EPA adjourned the meeting by indicating an additional 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, 2010
Enclosure 1

Summary of Polyvinyl Chloride Production Information of Interest

To assist in the collection of information during the requested site 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 regulatory 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 characteristics 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 oxidizers)

c. Discussion of applicable emission limits, and monitoring requirements for:

i. PM 

ii. SOx

iii. NOx 

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 between 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. SOx

iii. NOx 

iv. CO 

v. other

d. Summary of recent source test data (if applicable)

e. Summary of monitoring capital and operating costs (if available)
IV. Insignificant, 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 monitored 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 number 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 monitoring 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