MEMORANDUM

TO: Voluntary Program Participants 

FROM: Samantha Lewis, EPA 

 

DATE: March 16, 2007 

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to Discuss the 

Proposed Voluntary VCM Program (14 March 2007)

 EPA met with The Vinyl Institute (VI) and several member companies on Wednesday, 

March 14, 2007, to discuss the EPA’s response to VI’s February 9, 2007 letter discussing the 

proposed voluntary program as an alternative to the effluent limitations guideline (ELG) effort. 

The list of participants can be found in Attachment A and the VI’s letter is in Attachment B. 

 

The meeting followed the agenda below: 

• Introduction; 

• Discussion of proposed monitoring; 

• Next steps for the voluntary program; and, 

• Update on PVC plant information. 

The meeting is summarized below: 

Introduction

 Mr. Frank Borelli of the VI stated that the purpose of the meeting is to hear EPA’s 

thoughts on the proposed program and determine the next steps required to move forward. Ms. 

Mary Smith of EPA began the meeting by stating that EPA was pleased to see the program the VI 

proposed in their February 9, 2007 letter. Ms. Smith said that EPA would like to talk more 

specifically about the proposed monitoring. Ms. Smith stated that EPA is concerned that industry 

will be providing an average dioxin concentration across all 12 vinyl facilities. EPA wants to 

insure that the averaging will not cause ‘hotspots’ within a watershed by allowing trading of 

emissions limits between sites. The VI and member companies do not view this as a trading 

program since sites will not be buying and selling credits, but will agree to meet an average 

effluent limit. EPA also would like to evaluate additional data before determining that the 0.1 ng 

TEQ/liter limit from the European Best Available Techniques Reference document (BREF) is 

appropriate to use as the average limit. 

 Ms. Smith said EPA would like to take the approach of focusing on the monitoring 

program for the next year. EPA will review the data provided and decide the proper course of 

action after the data review. For example, EPA may find that dioxin is only a problem at certain 

facilities and could focus their efforts on permit support at those facilities rather than on 

developing a national effluent guideline. Alternatively, the data could show that there is a 

significant problem which would warrant moving forward with the ELG. The VI and member 
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companies expressed concern about moving forward with the Information Collection Request 

during the monitoring data collection and analysis period. Ms. Smith said EPA would be willing 

to put the questionnaire and any future EPA sampling on hold until the data have been evaluated. 

Ms. Smith said that EPA may collect samples at a site that was previously scheduled for sampling 

but postponed, but would not move forward with additional sites. Ms. Smith also said that EPA 

will need to brief senior management (Ephraim King, Ben Grumbles, and Marcus Peacock) on the 

proposed plan. 

Monitoring Program

 Ms. Samantha Lewis presented EPA’s suggested guidelines for monitoring at the 13 CCH 

facilities included in the voluntary program (Attachment C). One of the 13 facilities, Shintech 

Plaquemine, has not started operating; therefore, only 12 facilities will be included in the 

monitoring program. EPA would like to obtain monitoring data to characterize loadings from all 

CCH manufacturing processes at the 12 sites. This would include manufacturing of chlorine, 

other chlorinated hydrocarbons, and PVC in addition to VCM. EPA requests that facilities 

collect a minimum of three, 24-hour composite samples for each stream and analyze for dioxins 

and total suspended solids (TSS). EPA would be interested in hearing input from industry on 

whether additional points or analytes should be included in the monitoring program. EPA would 

also need corresponding flow rate information for each monitored stream, including any nonCCH wastewater. 

 Industry’s proposed monitoring program consisted of one 24-hour flow-weighted 

composite sample per process outfall per month for nine months and included dioxins, TSS, and 

turbidity. Industry suggested including low range turbidity for samples with low TSS. Turbidity 

has a lower detection limit and can analyze for solids that are not filterable. Turbidity is also 

easier to monitor since in-line turbidity monitors are available. Industry suggested data for nine 

months to account for seasonal variability while still providing EPA data within a one-year 

timeframe. Industry’s proposal included only outfall monitoring. 

Industry was concerned about EPA’s request to monitor at points other than outfalls. Ms. 

Lewis explained that EPA wants to characterize CCH loads and that some plants commingle CCH 

process wastewater with non-CCH wastewater which dilutes the stream. EPA would work with 

each facility to determine the proper locations for sampling. Facility representatives were 

concerned that this would increase their costs and was beyond the scope of their managementapproved monitoring plan. Ms. Lewis stated that for some sites, monitoring at their outfall would 

be appropriate but others would need to monitor further upstream. Ms. Lewis provided the 

following estimate of monitoring points: three facilities could monitor at their outfall; four 

facilities would need to monitor at two locations; two facilities would need to monitor at three 

locations; and three facilities would need to monitor at four or more locations. EPA would work 

with each facility to determine the proper monitoring location and develop site-specific sampling 

plans to use along with a generic sampling approach. 

Industry asked how EPA would use the different data sets since some of the streams have 

not passed through treatment. Ms. Lewis stated that EPA would use treatment data to calculate 

loads after treatment. 
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EPA and the industry members discussed the frequency of data collection and whether all 

facilities needed to submit the same number of samples. Ms. Lewis stated she would obtain input 

from EAD’s statistician and provide guidance to the facilities. 

Ms. Smith asked how the VI planned to provide the data to EPA. EPA would like to have 

the raw concentration data by facility rather than aggregated values. Frank Borrelli stated that 

industry had planned to have experts review the monitoring data and provide a summary to EPA. 

However, if the data are for upstream monitoring points, some data may be confidential business 

information (CBI). Industry members will need to discuss how to provide the data to both EPA 

and the VI while protecting CBI. 

Next Steps 

 EPA and the VI agreed to the following next steps. EPA would like to resolve all issues 

and develop the site-specific sampling plans by June/July 2007 so that monitoring can begin 

during the second half of 2007: 

• Industry members will check with their management and attorneys on the 

monitoring program revisions suggested by EPA. 

• EPA will obtain input from their statistician on the frequency of 

monitoring. 

• Industry will provide a revised letter to EPA incorporating the items 

discussed at this meeting. 

• EPA will brief senior management on the proposed program in order to 

provide a written response to industry’s proposal. 

• EPA will begin developing a generic sampling approach and site-specific 

sampling plans for the 12 facilities. 

• Industry members will check with their management and attorneys about 

the need for an official 308 request for the monitoring data. 

PVC Update

Mr. Frank Borrelli provided an update on the VI’s analysis of dioxin generation at PVC 

plants. The VI did not find dioxins at the effluent from PVC plants. Mr. Borrelli stated PVC 

operations do not have the conditions required for dioxin formation and the only possible source 

of dioxins is the thermal oxidizers used to control air emissions. The thermal oxidizers are 

regulated under the Vinyl Chloride NESHAP which requires continuous monitoring. The thermal 

oxidizers are operated a temperatures that will destroy dioxins. The HCl generated in the 

oxidizers is treated using scrubbers prior to discharge. Mr. Borrelli stated the installation of 
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thermal oxidizers and scrubbers is BAT. Mr. Borrelli provided a report of the VI’s findings to 

Ms. Mary Smith. 

 Ms. Samantha Lewis stated that EPA is interested in reviewing the report and any data the 

VI could provide. Ms. Lewis stated that although the thermal oxidizer and scrubber is BAT for 

air pollutants it may not be BAT for water discharges. EPA will need to review the data to 

determine how to proceed. 
Appendix A. List of Participants

Attachment B. Vinyl Institute Proposed Voluntary Alternative




















Attachment C. EPA Guidelines for Monitoring Program