MEMORANDUM

To: Jodi Howard, U.S. EPA, Office of Air Quality Planning and Standards

From: Colin Hayes, Roy Oommen, and Philip Crawford, Eastern Research Group, Inc.

Date: August 25, 2010

Subject: Summary of August 24, 2010 Meeting Between EPA and the Vinyl Institute

(VI) to Discuss Items Proposed in VI Letter Dated August 16th, 2010 

On August 24, 2010, members of Vinyl Institute (VI) and representatives of PVC 

manufacturing companies met with EPA at Research Triangle Park (RTP). The attendees 

and affiliation are listed below:

Name Representing

Barry Christenson Occidental Chemical Corporation

Kenny Akins Georgia Gulf Corporation

Mary Bachynsky Formosa Plastics Corporation

Kevin Bloomer Westlake Chemical Corporation 

Mark Garza Shintech Incorporated

Otis Sistrunk PolyOne Corporation 

John Westendorf Occidental Chemical Corporation

David Wise Shintech Incorporated

Greg Bocchi Vinyl Institute 

Nate Johnson Georgia Gulf Corporation

Allen Bodron Westlake Chemical Corporation

Richard Krock Vinyl Institute

Bob Elam Dow Chemical 

Peter de la Cruz Keller and Heckman (Attorney representing VI)

Gary McAlister U.S. EPA OAQPS

Mark Kataoka U.S. EPA OGC

Jodi Howard U.S. EPA OAQPS

Ken Hustvedt U.S. EPA OAQPS
Peter Westlin U.S. EPA OAQPS

Robin Segall U.S. EPA OAQPS

Jennifer Gibbs U.S. EPA Region 6

Nick Parsons U.S. EPA OAQPS

Philip Crawford Eastern Research Group, Inc.

Roy Oommen Eastern Research Group, Inc.

Colin Hayes Eastern Research Group, Inc.

The meeting began at 2:00 PM (EST). A summary of the meeting’s discussion follows.

Industry Submitted Data Inconsistencies

 The VI began the meeting with an introduction stating the intent of VI was to 

cooperate in the MACT rule making and provide additional information to EPA. VI 

indicated that they are not officially representing Dow Chemical and Certain Teed, 

but have included Georgia Gulf Corporation. 

Resin Sampling Data and Methods

 VI first addressed inconsistencies in resin sampling data. Before publication of the 

EPA PVC 114 Survey Database, VI requested Keller and Heckman (KH) to create a 

database using the industry data submitted to EPA. KH noted several inconsistencies:

Resin sampling data was submitted to EPA by facilities in pounds (lbs) per lbs 

of dry resin production (lbs/lbs of dry resin). Some companies calculated lbs 

of dry resin for their entire facility, while others only calculated resin 

production for the line from which the resin sample was obtained. 

During resin analysis, a number of labs used a procedure which corrects for 

water content in the resin sample. When facilities received the corrected 

results, unnecessary and incorrect moisture correction was again applied to the 

results. VI stated that the confusion was the result of inconsistent test methods 

specified by EPA.

Facilities were inconsistent in the way percent solids were reported. 

 In an effort to standardize the data set, VI has created a Microsoft (MS) Excel 

workbook containing industry data in a consistent format. VI presented the data set 

for suspension and dispersion resin data. VI further categorized the data by assigning 

resin grade indications to the data points, based on resin inherent viscosity. The data 

set also includes detection indicators (PQL, MDL, DL, ND). VI stated that work was 

still being done to verify all of the indicators. EPA inquired when the data set would 

be finished. VI responded two to four weeks. EPA requested to receive the data set in 

stages and VI agreed. VI also indicated that the database does not contain Dow or 

Certain Teed data; however, if received, the VI would include the missing data. 
 EPA inquired what percentage of the data included in VI’s MS Excel workbook was 

currently denoted as ND. VI ran a filter of the data and indicated approximately 20% 

of the data was above detection limit. 

 VI discussed the inconsistent vinyl chloride monomer (VCM) test results obtained 

using Method 8260 and Method 107. Method 107 yields higher VCM extraction 

while 8260 extracts significantly less VCM from the sample matrix. VI is currently 

attempting to produce a method with improved recovery and determine a factor to 

correct the results of 8260. VI has hired Environmental Chemistry of Houston Texas 

to assist in researching the methods. EPA Region Six confirmed that Method 107 

yielded a higher extraction of VCM during the resin sampling. 

 EPA and VI briefly discussed how facilities normally test for residual VCM in the 

resin slurry and how facilities/labs performed testing for the ICR requirement. VI 

indicated that results for the ICR testing may have differed due to the increased 

sample settling time as a result of shipping the sample offsite. 

 VI stated that when slurry is sampled, the matrix is initially well mixed, but after a 

short period of time the resin particles settle to the bottom of the matrix. VI stated that 

negligible amounts of VCM are contained in the water portion; therefore labs will 

“pour-off” the water portion and deposit the remaining “wet cake” onto an absorbing 

substrate (e.g., paper towel). The wet cake is then analyzed and the results are 

corrected for the water portion remaining in the wet cake. 

Emissions Testing Data

 VI raised inconsistencies surrounding emissions testing of thermal oxidizer and vent 

gas adsorption (VGA) units. VI inquired how EPA intended to address the data 

inconsistency in setting the MACT floor. EPA responded that the Agency is still 

investigating the data. VI specifically mentioned PolyOne and the VGA technology 

used at the Pedricktown and Henry facilities. A PolyOne representative stated that the 

VGA is online approximately 95% of the time and a thermal oxidizer is used when 

the VGA is offline as the result of a malfunction or scheduled maintenance. 

General

 VI presented a graph on analytes reported by industry. VI discussed how variability 

and potential “outlier” data may result from differing detection limits. 

Non-Detect Data Submitted by Industry 

 VI asked how EPA intends to handle non-detect (ND) data in the MACT floor 

analysis. EPA discussed how labs use different methods to determine detection limits. 

EPA stated that the Agency has requested labs to report those detection limits in place 

of ND values. EPA proceeded to explain how recent proposed rulemakings have used 

ND values to account for variability in setting emissions limits. 

Process and Chemistry Variability
 VI emphasized process variability due to chemistry variations between manufactures 

and within facilities to meet a wide variety of customer specifications. VI stated that 

although facilities submitted 30 days of resin sampling data, a certain grade of resin 

may have only been made once during the thirty day period. VI believes that 

addressing chemistry variability will be a significant challenge for EPA and proposed 

to meet again with EPA in approximately three weeks to further discuss the issue. 

EPA requested an earlier meeting. VI indicated a webinar or teleconference is 

possible. EPA asked if variability was more significant in the slurry or in incinerator 

emissions. VI responded that slurry exhibits increased variability over incinerator 

emissions. VI asked how EPA intended to handle variability but EPA indicated they 

were undecided. 

Discussion of Non-representative Data Set 

 VI discussed the overall data set submitted to EPA and uncharacteristic 

manufacturing period during which the data were obtained. VI commented that resin 

sampling and emissions testing data was obtained during winter months when PVC 

production is seasonally low. VI also mentioned in addition, current and recent 

economic conditions have also decreased PVC production. VI inquired how EPA 

plans to account for increased future production in the proposed rulemaking. VI 

suggests submitted previous years of Method 107 data. EPA asked when additional 

data would be available. VI responded that they were waiting on the Method 8260 / 

Method 107 research to be completed. EPA stated VI may submit additional data 

after the proposal. VI and EPA discussed if language related to “alternate test method 

approval by the administrator” will be included in the preamble. 

Items Related to Proposed Rulemaking 

 EPA discussed the option of regulating emission points downstream of the stripper 

instead of requiring compliance by VCM content in the stripped resin slurry. VI 

responded that those particular emission points are difficult to control due to the high 

moisture content, high volume, and low volatile organic compound concentration of 

the streams. EPA requested more information from VI and industry regarding these 

emission points, specifically the technical reasons why control in not feasible. 

 VI asked EPA if the Agency intended to regulate Hazardous Air Pollutants (HAPs) as 

a whole or by individual compounds. EPA responded they were undecided. 

 EPA inquired about PVC facilities co-located with VCM facilities and why those 

PVC facilities decided to comply with subpart UU ( 40 CFR Part 63 Subpart UU –

National Emission Standards for Equipment Leaks Control Level 2 Standards). VI 

responded that certain facilities comply with UU as part of a consent decree. In other 

cases facilities are complying with subpart UU as a PVC de facto MACT. VI also 

indicated that facilities try to limit the number of Leak Detection and Repair (LDAR) 

programs they must implement. For example, Louisiana facilities will comply with 

the most stringent LDAR program for co-located facilities as part of an option offered 

by EPA Region Six. 

Remaining Data Gaps
 VI inquired if any other specific data gaps existed and for which of those gaps VI 

should focus effort on filling. ERG indicated that the wastewater and miscellaneous 

emissions sections of the surveys. ERG will provide a more detail list of missing 

information to EPA in the near future. 

 VI offered to present and additional PVC seminar “PVC 101” to EPA at a later date. 

The meeting adjourned at approximately 3:30 PM.