### 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) a nd 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 th e effluent limitations guideline (ELG) effort. The list of participants can be f ound 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 th e purpose of the meeti ng 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 th at 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 ‘hotspot s’ within a watershed by allowing trading of

emissions limits between sites. The VI and me mber companies do not view this as a trading program since sites will not be buying and sellin g 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 Availa ble 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 ma y find that dioxin is only a problem at certain

facilities and could focu s their efforts on permit support at those facilities rather than on developing a national effluent guideline. Altern atively, the data could show that there is a significant problem which would warrant moving forward with the ELG. The VI and member2 companies expressed concern about moving forw ard 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 samp ling 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 a dditional 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 suggest ed guidelines for monitoring at the 13 CCH

facilities included in the voluntar y 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 mon itoring data to characterize loadings from all CCH manufacturing processes at th e 12 sites. This would include manufacturing of chlorine, other chlorinated hydrocarbons, and PVC in add ition 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 informati on 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 fo r nine months and included dioxins, TSS, and turbidity. Industry suggest ed 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 turb idity monitors are available. Industry suggested data for nine months to account for seasonal variability while still providing EPA da ta within a one-year timeframe. Industry’s proposal included only outfall monitoring.

Industry was concerned about EPA’ s request to monitor at poin ts 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 whic h 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 cost s 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 mon itor further upstream. Ms. Lewis provided the following estimate of monitoring poi nts: 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 monito r 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.3 EPA and the industry members discussed the fr equency of data collection and whether all

facilities needed to submit the same number of sa mples. Ms. Lewis stated she would obtain input from EAD’s statistician and provi de 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 expe rts review the monitoring data a nd 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 st atistician 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 dioxi ns at the effluent from PVC pl ants. 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 c ontrol air emissions. The thermal oxidizers are regulated under the Vinyl Chloride NESHAP wh ich requires continuous monitoring. The thermal oxidizers are operated a temperatures that wi ll destroy dioxins. The HCl generated in the oxidizers is treated using scrubbers prior to disc harge. Mr. Borrelli stat ed the installation of4 thermal oxidizers and scrubbers is BAT. Mr. Borre lli provided a report of the VI’s findings to Ms. Mary Smith.

Ms. Samantha Lewis stated that EPA is intere sted in reviewing the re port 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 discha rges. EPA will need to review the data to determine how to proceed.Appendix A. List of ParticipantsAttachment B. Vinyl Institute Proposed Voluntary AlternativeAttachment C. EPA Guidelines for Monitoring Program