Final Generic Sampling Plan 

for Determining Baseline Loads for 

Proposed VCM Voluntary Program 

Prepared for:

U.S. Environmental Protection Agency

Engineering and Analysis Division 

Office of Water 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Prepared by: 

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151 

October 19, 2007 

EPA Contract No. 68-C-02-095 

Work Assignment 5-18 
i

TABLE OF CONTENTS 

Page 

1.0 INTRODUCTION .....................................................................................................1-1 

1.1 Background..............................................................................................1-1 

1.2 Objectives and Scope...............................................................................1-4 

1.3 Facilities Included in Sampling Program.................................................1-5 

2.0 OVERVIEW OF CCH MANUFACTURING PROCESSES AND WASTEWATER TREATMENT

..............................................................................................................................2-1 

3.0 SAMPLING APPROACH...........................................................................................3-1 

3.1 Sampling Point Selection.........................................................................3-1 

3.2 Analytical Method Requirements ............................................................3-2 

3.3 Sample Collection Methodology .............................................................3-3 

3.4 Quality Assurance/Quality Control..........................................................3-4 

3.5 Field Measurements...............................................................................3-10 

3.6 Engineering Data Collection..................................................................3-10 

3.7 Sample Shipment ...................................................................................3-11 

4.0 SAMPLING ACTIVITIES ..........................................................................................4-1 

4.1 Sampling Preparation...............................................................................4-1 

4.2 Field Sampling Activities ........................................................................4-1 

4.3 Analysis of Results ..................................................................................4-2 

4.4 Final Data Package ..................................................................................4-2 

4.5 Site-Specific Logistics .............................................................................4-3 

5.0 REFERENCES .........................................................................................................5-1 

Appendix A LIST OF DIOXIN AND FURAN ANALYTES
ii

LIST OF TABLES 

Page 

Table 1-1. U.S. Industry Coverage of Participating Sites........................................................... 1-3 

Table 3-1. Guidelines for Selecting Sampling Points............................................................... 3-12 

Table 3-1A. Analytes to be Collected by Sampling Point for Stand-Alone CCH Facility 

(Example)........................................................................................................... 3-12 

Table 3-1B. Analytes to be Collected by Sampling Point for Integrated Facility (Example) .. 3-13 

Table 3-2. CCH Sampling Screen Analytes and Method Requirements.................................. 3-13 

Table 3-3. Sampling Point Field Measurements....................................................................... 3-13 
iii

LIST OF FIGURES 

Page 

Figure 2-1. Process Flow Diagram for Stand-Alone CCH Facility............................................ 2-2 

Figure 2-2. Process Flow Diagram for Integrated CCH Facility................................................ 2-3 

Figure 3-1. Sample Preservation Log Sheet ............................................................................. 3-14 

Figure 3-2. Example Field Sampling Log Sheet....................................................................... 3-15 

Figure 3-3. Example Engineering Data Sheet........................................................................... 3-16 
1-1

1.0 INTRODUCTION

 Under the direction of the Engineering and Analysis Division (EAD) of the U.S. 

Environmental Protection Agency (EPA), 12 U.S. manufacturing facilities of vinyl chloride 

monomer (VCM) are conducting a sampling program to characterize process wastewaters 

generated by chlorine and chlorinated hydrocarbon (CCH) manufacturing operations, including 

the characterization of total site outfall discharges. The primary use for the data from this 

sampling effort is for EPA to estimate baseline loads for 17 dioxin and furan congeners 

(hereinafter “dioxin”) and total suspended solids from CCH process wastewater at these 12 

facilities. The data from this sampling effort will also be used to calculate separate loading 

contributions from the different CCH process types (e.g. PVC, chlor-alkali), when possible, and 

to further assess the need for regulation of each CCH process type. Finally, the data will also be 

used to estimate total manufacturing site dioxin discharges. 

 EPA is interested in characterizing process wastewater streams prior to 

commingling with non-CCH wastewater. For stand-alone CCH facilities that do not operate 

non-CCH manufacturing processes, facilities will collect samples from the effluent from 

wastewater treatment. For integrated facilities, facilities will collect wastewater samples for each 

CCH process type prior to entering the combined wastewater treatment system. With these goals 

in mind, EPA will select the sampling points for each facility with input from facility personnel. 

This generic version of the sampling plan provides project background, scope and objectives, as 

well as general sampling procedures and methods to be followed during all sampling episodes. 

Once EPA develops site-specific sampling plans for each of the 12 facilities, the site-specific 

plan will serve as a detailed guide to facility personnel (including facility contractors, if utilized) 

conducting the sampling and analysis activities. 

1.1 Background

 The 1972 Clean Water Act directs EPA to develop national technology-based 

regulations placing limits on the pollutants that are discharged by categories of industry to 

surface waters (termed “effluent guidelines”) or to sewage treatment plants1

 (termed 

 
1-2

“pretreatment standards”). The Act also directs EPA to develop national technology-based 

regulations (termed “new source performance standards”) for new industrial facilities that are 

discharging nontrivial amounts of toxic or non-conventional pollutants. 

 EPA’s Office of Water has begun an effort to determine if revised regulations are 

required for facilities manufacturing chlorine and chlorinated hydrocarbons (including polyvinyl 

chloride (PVC)), under the authority of Section 308 of the Clean Water Act (Federal Water 

Pollution Control Act, 33 U.S.C. Section 1318). EPA refers to the manufacturers of chlorine and 

chlorinated hydrocarbons as the Chlorine and Chlorinated Hydrocarbon (CCH) manufacturing 

segments. Wastewater from chlorine manufacturing via the chlor-alkali process is regulated by 

the Inorganic Chemicals Manufacturing Point Source Category (40 CFR Part 415). Wastewater 

from chlorinated hydrocarbon manufacturing is regulated under the Organic Chemicals, Plastics, 

and Synthetic Fibers (OCPSF) Point Source Category (40 CFR Part 414). 

 In February 2007, several member companies of the Vinyl Institute (VI) and the 

American Chemistry Council (ACC) (referred to as the Vinyl Chloride Producers, or “VCP”) 

proposed a voluntary dioxin control program for vinyl chloride facilities (1). The proposed 

voluntary program included all 13 (consisting of 12 existing and 1 future) U.S. VCM 

manufacturing sites. According to the VCP, the 12 existing sites account for 97 percent of 

ethylene dichloride (EDC) manufactured in the U.S and represented 97 percent of the dioxin 

loadings into wastewater identified in Table 6-43 of EPA’s Technical Support Document for the 

2004 Effluent Guidelines Program Plan (see Table 1-1).2

 The proposed program focused on 

vinyl chloride manufacturing sites because of industry knowledge, based primarily on the Vinyl 

Institute Dioxin Characterization study, that the oxyhydrochlorination (OHC) process and the 

thermal oxidation of chlorinated hydrocarbons are potential dioxin sources in the CCH 

manufacturing segments.3

 

 The VCP initially investigated voluntary programs that would focus only on the 

wastewater streams from the OHC process at these facilities. However, the VCP determined that 

 

2

 U.S. EPA. 2004. Technical Support Document for the 2004 Effluent Guidelines Program Plan. (August). EPA821-R-04-014. 

3

 Vinyl Institute. 2002. The Vinyl Institute Dioxin Characterization Program Final Report. (July 1). 
1-3

it was not practical to isolate OHC wastewater streams at all facilities, and, thus, decided that the 

program should include wastewater streams from all site operations so that dioxin sources other 

than CCH manufacturing (e.g., combustion) would be included. The VCP therefore proposed a 

program that would include discharges from chlor-alkali operations at these sites (60 percent of 

U.S. chlor-alkali production according to industry), as well as discharges from other on-site CCH 

and non-CCH manufacturing processes. Chemical Market Associates, Inc. provided the U.S. 

industry capacity information for VCM and PVC.4 

Table 1-1. U.S. Industry Coverage of Participating Sites 

Metric 

Percent 

Coverage Source 

U.S. VCM manufacturing capacity 100 CMAI, 2006 

U.S. EDC OHC manufacturing capacity 97 CMAI, 2006 

D/F wastewater loading (TRI, TM17, CY2000) for sites listed in 

Table 6-43 of EPA’s 2004 Section 304(m) plan Technical Support 

Document 

97 Vinyl Institute, EPA 

304(m) plan Technical 

Support Document 

U.S. chlor-alkali manufacturing capacity (2005) ~60 Chlorine Institute, Vinyl 

Institute 

U.S. PVC manufacturing capacity (which the VCP believes is a 

negligible contributor to overall CCH D/F loadings) 

~25 Vinyl Institute 

U.S. high-volume chlorinated hydrocarbon solvent manufacturing 

capacity known by the participating companies to exist 

~60 Halogenated Solvents 

Industry Alliance; Vinyl 

Institute 

 Because it directly addressed dioxin in wastewater from EDC/VCM facilities, the 

VCP selected the European Commission Integrated Pollution Prevention and Control (IPPC) 

Reference Document on Best Available Techniques (BAT) in the Large Volume Organic 

Chemical Industry (2) as the basis for the voluntary program. The IPPC document identifies a 

BAT maximum concentration of 0.1 nanogram per liter, international toxic equivalent basis 

(ng/L I-TEQ) for dioxin congeners in treated EDC/VCM wastewater. Under the voluntary 

program, the VCP proposed to first analytically calculate a quantitative baseline of dioxin 

surface wastewater discharges from participating VCP sites through monitoring/reporting of 

dioxin on both an international toxic equivalent (I-TEQ) and “TM-17” basis. The VCP sites then 

proposed to achieve, as an initial target, maximum dioxin mass discharges equivalent to process 

wastewater flow multiplied by 0.1 ng/L TEQ, on a collective, 12-facility basis. For the sum of 

 

4

 http://www.cmaiglobal.com/ 
1-4

discharges from the 12 EDC/VCM facilities, the maximum daily discharge was thus proposed to 

be no more than 42 milligrams of dioxin per day (I-TEQ). 

1.2 Objectives and Scope

 This sampling program is intended to provide EPA with information to allow 

determination of the current estimated dioxin discharges from treatment of CCH wastewater. 

When CCH wastewater is sampled prior to existing wastewater treatment, the estimated dioxin 

discharges will be modeled using percent removal information from similar wastewater 

treatment systems. The modeling accuracy will be limited by the amount and type of dioxin 

removal data EPA has or obtains during the time period of the sampling program. This 

information will allow EPA to further evaluate the appropriateness of the industry proposed 

maximum target of 42 mg/day I-TEQ and could lead EPA to conclude that other dioxin control 

targets/options may be more appropriate, including revision of one or more Effluent Limitations 

Guidelines (ELGs) for the CCH manufacturing segment. 

 Under this industry monitoring program, 12 VCM-manufacturing facilities will 

collect and analyze samples to characterize average and maximum dioxin discharges from CCH 

manufacturing sites. For stand-alone CCH facilities that do not operate non-CCH manufacturing 

processes, facilities will collect samples from the effluent from wastewater treatment and, as 

agreed by EPA and the site, and consistent with the purposes of this program, other site outfalls 

that contain treated or untreated wastewaters. For integrated facilities at which CCH process 

wastewater is significantly diluted with other non-CCH wastewaters before treatment, facilities 

will sample streams representing all CCH processes prior to entering the combined wastewater 

treatment system and may composite wastewater streams from each CCH process type in a flowweighted manner for analysis. EPA will use the above sampling data, along with information 

collected under its own sampling effort for treatment performance, as well as relevant 

performance data from other sources, to estimate baseline annual and daily maximum dioxin 

discharge loads related to CCH process wastewater at the 12 facilities. When possible, flowweighted composite samples from all relevant site outfalls will also be collected to estimate total 

site annual and maximum discharges of dioxin. When more than one outfall exists at a facility, a 

facility may decide to flow-weight composite multiple facility outfalls into a single sample. EPA 
1-5

will use the industry dioxin monitoring data to further evaluate industry’s proposed voluntary 

program for VCM facilities, as well as other options for proceeding with dioxin discharge 

controls. 

 Sampling episodes will consist of at least four 24-hour composite samples, each 

collected at least one month apart. Section 3.0 contains additional information about the 

sampling procedures. 

1.3 Facilities Included in Sampling Program

 Industry’s proposed voluntary program includes the following 13 facilities: 

• Dow, Freeport, TX; 

• Dow, Plaquemine, LA; 

• Formosa, Baton Rouge, LA 

• Formosa, Point Comfort, TX; 

• Georgia Gulf, Lake Charles, LA; 

• Georgia Gulf, Plaquemine, LA; 

• OxyVinyls, Deer Park, TX; 

• OxyChem/OxyVinyls, Ingleside, TX; 

• OxyVinyls, La Porte, TX; 

• Shintech, Plaquemine, LA5; 

• PPG, Lake Charles, LA; 

• Westlake, Calvert City, KY; and 

• Westlake, Geismar, LA. 

 

5

 The Shintech Plaquemine, LA facility is scheduled to begin manufacturing operations in 2007, and is the only 

known U.S. VCM manufacturing facility not included in this program at this time. 
2-1

2.0 OVERVIEW OF CCH MANUFACTURING PROCESSES AND WASTEWATER 

TREATMENT

 For the site-specific sampling plans, this section will include an overview of the 

CCH manufacturing processes at each facility and the configuration of site outfalls. Sections 

will include descriptions of the manufacturing process and wastewater streams for: 

• Chlor-alkali manufacturing; 

• EDC/VCM manufacturing; 

• Other chlorinated hydrocarbon manufacturing using direct chlorination, 

oxychlorination, dehydrochlorination, or hydrochlorination; 

• PVC manufacturing; and 

• Wastewater outfalls for all site manufacturing activities. 

 This section will also describe the wastewater treatment operations for CCH 

process wastewater at each facility. EPA will note any non-CCH process wastewater streams 

that enter combined wastewater treatment systems. Block diagrams will be provided for the 

CCH manufacturing processes and wastewater treatment system, including locations of sampling 

points and those for all relevant site outfalls. Figure 2-1 shows an example diagram for the 

wastewater treatment system at a stand-alone CCH facility. Figure 2-2 shows an example 

diagram for a wastewater treatment system at an integrated facility. The recommended sampling 

points are noted on each example diagram. The site-specific plans will show the sampling points 

proposed by EPA for each facility and the samples that can be composited for dioxin analysis. 

EPA will discuss and agree upon the proposed sampling points with each facility prior to 

finalizing the site-specific plans. 
2-2 

Figure 2-1. Process Flow Diagram for Stand-Alone CCH Facility 

EDC/VCM plant Wastewater Stripper

PVC plant

Wastewater

Stripper

PrimaryClarifier

Biological Treatment

Final Equalization/

Neutralization

Equalization

Tank

VCM Recovery Wastewater

Centrifuge Wastewater

Nonprocess stormwater

Quench Andwash tank wastewater

Caustic Scrubber Blowdown

Outfall 001

Sampling Point

EDC/VCM plant Wastewater Stripper

PVC plant

Wastewater

Stripper

PrimaryClarifier

Biological Treatment

Final Equalization/

Neutralization

Equalization

Tank

VCM Recovery Wastewater

Centrifuge Wastewater

Nonprocess stormwater

Quench Andwash tank wastewater

Caustic Scrubber Blowdown

Outfall 001

Sampling Point
2-3 

Figure 2-2. Process Flow Diagram for Integrated CCH Facility

EDC/VCM plant Wastewater Stripper

PVC plant

Wastewater

Stripper

PrimaryClarifier

Biological Treatment

Final Equalization/

Neutralization

Equalization

Tank

Incin

Scr

VCM Recovery Wastewater

Centrifuge Wastewater

Nonprocess stormwater

Quench Andwash tank wastewater

Caustic Scrubber Blowdown

Outfall 001

Sampling Point

Methano

EDC/VCM plant Wastewater Stripper

PVC plant

Wastewater

Stripper

PrimaryClarifier

Biological Treatment

Final Equalization/

Neutralization

Equalization

Tank

Incin

Scr

VCM Recovery Wastewater

Centrifuge Wastewater

Nonprocess stormwater

Quench Andwash tank wastewater

Caustic Scrubber Blowdown

Outfall 001

Sampling Point

Methano
3-1

3.0 SAMPLING APPROACH

 This section will provide sampling procedures, methods, and logistics to be 

followed during each of the multi-day sampling events at the 12 VCM facilities included in the 

proposed voluntary program. Specifically, this section will contain information regarding 

selection of sampling points, sampling methodologies, analytes, and sampling frequency and 

duration for each facility. All tables and figures appear at the end of this section. 

3.1 Sampling Point Selection

 Twelve VCM-manufacturing facilities plan to collect samples to assist EPA in 

characterizing the discharges of total suspended solids (TSS) and dioxin from CCH processes 

and from the sampled site. At least four sampling episodes will be conducted at each facility, 

consisting of 24-hour sample composite collection periods spaced at least one month apart, or as 

needed to capture all relevant site operating modes. Facilities should consider various operating 

modes in selecting the number and frequency of sampling episodes to ensure that a typical (or 

representative) annual average dioxin discharge can be estimated. For this sampling effort, 

sampling points for CCH process wastewater streams prior to commingling with wastewater 

from non-CCH processes will be included where necessary. For facilities with CCH-dedicated 

wastewater treatment systems, the effluent from wastewater treatment will suffice. For 

integrated facilities that operate combined wastewater treatment systems, sampling points to 

characterize the influent to wastewater treatment from each CCH process at the facility will be 

necessary. In addition, samples of all relevant outfalls from the entire site will be identified. 

Facilities will collect at least four samples for all sampling points specified by EPA and agreed to 

by each facility in the site-specific sampling plans. Note that some facilities may not sample for 

TSS in some samples taken prior to wastewater treatment. Facilities are also encouraged to 

measure turbidity in outfall and final treatment system samples for potential correlation with 

dioxin levels. Details on how turbidity is measured should be provided to EPA by each facility. 

 Table 3-1 presents the guidelines for selection of sampling points for various 

wastewater treatment and flow scenarios at CCH facilities. Tables 3-1A and 3-1B are examples 

of the sample collection tables that EPA will provide in the site-specific sampling plans. The 
3-2

tables describe the number of 24-hour composite samples to be collected, including quality 

assessment samples. Table 3-1A shows an example sample collection table for a wastewater 

treatment system at a stand-alone CCH facility (see Figure 2-1). Table 3-1B shows an example 

sample collection table for a wastewater treatment system at an integrated facility (see Figure 

2-2). 

3.2 Analytical Method Requirements

 Analytes that are included in this sampling effort include TSS and dioxin. 

Appendix A lists the individual congeners for the dioxin and furan analysis. Table 3-2 lists the 

sample container, sample volume, and preservation requirements for Total Suspended Solids 

(TSS) and EPA Method 1613B (dioxin). TSS will be measured using Standard Method 2540D, 

which is the approved method referenced in 40 CFR 136. 

 Facility or contractor personnel will add chemical preservatives to samples 

according to method-specified protocols, either upon sample collection (i.e., grab samples) or 

following preparation of sample fractions from the composite sample. In addition, facilities will 

communicate with their laboratories to ensure that proper preservation protocols are followed in 

the field. The type and amount of preservation used will be recorded on sample preservation log 

sheets (Figure 3-1). Preservation will be discontinued if the preservative added reaches 10 

percent of the sample volume and the required pH is not achieved. Facilities will send copies of 

the completed preservation log sheets to EPA as part of the final data package (see Section 4.4). 

 TSS and 1613B methods require that samples be maintained at a temperature of 

≤6o

C. To ensure adequate cooling of samples, facility personnel will either place all samples on 

ice or store in a refrigerator promptly upon collection. In addition, the samples will be packed in 

a manner to ensure that samples maintain a temperature of ≤6°C until they arrive at the 

designated analytical laboratories. Facilities will communicate with their laboratories to ensure 

that proper packing and shipping procedures are followed in the field. 

 The analysis should follow method 1613B. The laboratory must ensure a proper 

separation of all target analytes from co-eluting and interfering non-2378-PCDD/F-congeners 
3-3

which could cause significantly biased data. A second GC column (confirmation column) will be 

used to confirm target analytes. Since the participating facilities will use various laboratories, the 

VCP will review initial results and verify comparability of results across all laboratories in the 

program. 

3.3 Sample Collection Methodology

 To characterize the CCH wastewater streams at the 12 facilities, facility personnel 

may use varying methods of sample collection depending on the location of the sampling point 

and the nature of the sample flow and composition at each sampling point. Sampling points will 

fall under one of three categories: 

• Automatic composites: Facilities may collect flow-weighted composites 

using automatic compositors for continuous streams that are located in 

plant areas that the facility has deemed safe for operating an automatic 

compositor. If facility is unable to set up an automatic compositor for 

collecting flow-weighted composite, then time-weighted composites may 

be collected. 

• Manual composites: Facilities may collect manual composites for 

continuous streams for sampling points where it is not possible or 

recommended to sample using an automatic compositor. The absence of a 

flow signal from an appropriate flow meter may necessitate using the 

manual composite method. 

• Intermittent streams: Prior to sampling, the facility will provide 

information on the frequency and duration of flow, and coordinate with 

EPA to determine the appropriate collection frequency. 

The remainder of this subsection describes sample collection techniques. 

 For all sampling locations, facility personnel will conduct the sampling episode 

using the site-specific sampling plan provided by EPA. Facility personnel will evaluate the 

specific hazards at each sampling point and determine the appropriate personal protective 

equipment required. 
3-4

• Automatic Composites: Facility personnel will collect one automatic 

composite sample for each sampling point. Wherever possible, facilities 

will set up automatic compositors to collect flow-weighted composites. If 

flow-weighted composites are not possible, then facilities may collect 

time-weighted automatic composites. The compositor will be 

programmed to collect enough wastewater over the 24-hour period to 

provide adequate sample volume for analysis of TSS and dioxin 

(approximately three to four liters). At the end of the 24-hour period, 

facility personnel will divide the composite volume into one 100mL or 1-

L plastic jar for TSS testing and two 1-L amber glass jars for dioxin 

analysis. Samplers will then preserve these fractions following the 

guidelines in Table 3-2. The mixing of the composite sample before 

division into the sub-samples is a crucial step to achieve representative 

samples for the analysis. 

 

• Manual Composites: Facility personnel will collect one manual 

composite sample for each sampling point. Each composite will comprise 

six 500mL sample aliquots that will be collected approximately four hours 

apart. The composite container will contain enough sample volume for 

analysis of TSS and dioxin (approximately three to four liters). At the end 

of the 24-hour period, facility personnel will divide the composite volume 

into one 100 mL or 1-L plastic jar for TSS and two 1-L amber glass jars 

for dioxin analysis. Samplers will then preserve these fractions following 

the guidelines in Table 3-2. The mixing of the composite sample before 

division into the sub-samples is a crucial step to achieve representative 

samples for the analysis. 

Facilities may opt to collect samples for dioxin as lab-composited grabs. 

For lab-composited grabs, facility personnel will fill six 500mL amber 

glass jars over the 24-hour collection period (i.e. one 500mL jar every four 

hours). Facility personnel will preserve the contents of each 500mL jar 

immediately following sample collection. The six sample jars will remain 

unopened until receipt at the analytical laboratory. The laboratory will 

then composite the six 500mL samples for one analysis for the 24-hour 

compositing period. Facilities should communicate with their analytical 

laboratories to determine the preferred method of compositing. The 

mixing of the composite sample before division into the sub-samples is a 

crucial step to achieve representative samples for the analysis. 

3.4 Quality Assurance/Quality Control

 Facilities will provide information to EPA regarding any company-specific 

quality assurance/quality control (QA/QC) procedures that will be followed during the sampling 

episode. The following is a discussion of the quality elements to be included in the sampling: 
3-5

• Sampling Process Design. Facilities will follow the sampling procedures 

described in the site-specific sampling plan. Based on site-specific 

conditions, facilities may modify the sampling methodology of the sitespecific sampling plan. For example, hazardous conditions created by 

volatile chemicals at CCH facilities may complicate sampling. All 

deviations from the site-specific sampling plan will be discussed with the 

EPA contact in a timely manner. Facilities will document all deviations in 

the samplers’ field notes, which will be provided to EPA in the final data 

package (see Section 4.4). 

• Sampling Methods. The site-specific sampling plan will describe the 

specific field sampling methodology for each sampling point in detail. 

Facilities will ensure that samplers have received adequate training to 

conduct the sampling activities described in the site-specific plan. 

Training may include health and safety training, as well as training for 

proper handling, collection, mixing, and division of samples. 

This sampling program is intended to characterize wastewater generation 

and treatment during normal, representative facility operations. If a nonroutine process event occurs during sampling, facility personnel will 

record the times and dates that the events occur for future reference during 

the data analysis phase. Facility personnel will record information 

regarding the non-routine process event in the field notes (see Section 

3.5). In the event of an non-routine process event (i.e., outside the 

facility’s normal range of operations), facility personnel should discard the 

sample volume collected during the non-routine process event. Sample 

collection should not recommence until normal operations resume. 

Facility personnel will conduct all sampling activities in a manner to 

minimize potential contamination and cross-contamination of samples. If 

samples are collected with an automatic compositor or with a peristaltic 

pump, facility personnel will install new tubing for each sampling point at 

the beginning of the collection period. Facility personnel will use noncontaminating pH indicator paper or a pH probe during field tests and 

preservation. A 1-liter glass jar will be filled during collection of each 

grab sample set for field measurements to ensure that thermometers and 

test kits do not contaminate the samples (see Section 3.5). 

Facility personnel who collect samples will wear proper new gloves at 

each sampling point to avoid exposure to pollutants and other chemical, 

physical, and biological hazards, and to prevent cross-contamination of 

samples. Samplers should use a new pair of gloves at each sampling point 

each time they collect a grab or composite sample. Samplers should use 

care not to touch the insides of bottles or lids/caps during sampling. 

• Typical field sampling equipment that may be used for the sampling 

program includes: precleaned sample bottles and composite jars for 

chemical analyses, pH indicator paper, pH probes, thermometers, chlorine 
3-6

test kits, and sampling collection devices such as an automatic sampler. 

Table 3-2 provides information for the proper size and type of bottle to use 

for each sample. An automatic sampler is a pumping device that collects 

sample through FEP, Teflon, or other tubing at preset frequencies and 

durations and discharges collected sample into a sample container. EPA 

and facility personnel will together determine the specific field sampling 

devices to use for each sampling location based on the specific sampling 

location logistics and EPA will describe these devices in the site-specific 

sampling plans. 

• Sampling Frequency. Facilities will collect a minimum of four samples 

with at least one month between samples to provide EPA with variation in 

process conditions. Facilities may choose to collect more than four 

samples, or may need to collect additional samples to cover all significant 

operating modes. The goal is for the average sample results to be 

representative of normal operations over a typical 12-month period and is 

the best engineering estimate that can be reasonably obtained of an annual 

average dioxin loading from CCH manufacturing to surface waters. For a 

facility with CCH manufacturing units that are operated in only two 

modes (e.g., operating at normal production rates, or not operating), the 

best engineering estimate may be as simple as a statistical average of four 

samples spaced out over time. For a more complex facility, sampling may 

have to be planned to capture dioxin loadings under each significant 

operating mode. For example, if the EDC/VCM plant is normally down or 

running at reduced rates, while another CCH process runs at full rates, 

then it may be best engineering judgment to schedule a sample during 

each mode of operation and then weight the resulting annual dioxin 

loading for the approximate time the facility was operating in each mode. 

The technical staff at each facility will assess typical operations for each 

facility prior to initiating sample collection to determine the most 

representative set of samples needed to fully characterize discharges from 

CCH operations on site. For complex operating modes, as many as 9 

samples (or more) may need to be collected to provide enough data to 

establish a typical annual dioxin loading using best engineering judgment. 

Facilities may chose to stagger sampling between locations to account for 

hydraulic residence time through treatment systems. To assist EPA in 

evaluating variability, the facility should provide: 

— Its rationale for collecting number and frequency of samples. 

— All of the data collected during the study, because subsets are 

unlikely to represent the full range of measured values and 

associated variability. If a facility is concerned that some data are 

not representative, the facility should still provide the data, and 

note its concerns, and identify any unusual condition. 
3-7

• Sampling Handling and Custody. Facilities will be responsible for 

developing a method to track samples from sample collection through 

creation of sub-samples, shipping, analysis at the laboratory, and receipt of 

analytical results. This includes identification of samples through sample 

ID numbers, labeling of sample bottles, organization of samples, and 

tracking of sample shipments. 

• Analytical Methods. Table 3-2 at the end of this section lists the 

analytical methods that will be used to characterize CCH waste stream 

samples. All analytical methods are publicly available. Table 3-2 lists the 

typical volume of sample to be collected, typical container type, and 

typical preservation. EPA will use this information in combination with 

the site-specific sample conditions to specify the proper bottle type and 

preservation methods in each site-specific sampling plan. Facility 

personnel will use the sampling equipment and preservation methods 

described in the site-specific plan. In addition, facilities will provide 

information to EPA on the procedures for laboratory and data quality 

review in the final data package (see Section 4.4). As proposed by the 

VCP, both level 2 and level 4 data packages will be provided for each 

sample analyzed for dioxin (Industry plans to better define what is meant 

by Level 2 and 4 packages). 

• Quality Control. EPA will require facilities to collect field quality 

control samples for this sampling effort. Facility personnel will follow all 

required QC measures for Standard Method 2540D (TSS) and EPA 

Method 1613B (dioxin). At least one field duplicate and one equipment 

field blank (as described below) will be collected for analysis at each 

sampled site. Tables 3-1A and 3-1B show the number of QC volumes to 

be collected and specify the sampling points for which the QC volumes 

will be collected. EPA will coordinate with facilities to determine the 

appropriate sampling locations for QC for each site-specific plan. Facility 

personnel should coordinate with their analytical laboratory to determine 

whether additional QC volumes are needed. 

— Equipment Field Blanks. The facility will collect equipment 

field blanks for any special equipment used during the sample 

collection, such as cooling coils, ISCO composite samplers, tubing, 

funnels, etc. The equipment field blank evaluates any 

contamination of the sample from either the equipment used or 

ambient conditions. To collect equipment field blanks if no special 

equipment is used, the facility will pour HPLC grade water directly 

into sample bottles or composite containers at the sample point 

location. If special equipment is used, the facility will pass HPLC 

grade water through all equipment used and into sample bottles at 

the sample point location. Multiple equipment field blanks may be 

required if different sampling techniques are used or if ambient 

conditions are expected to vary from sample point to sample point. 
3-8

The site-specific sampling plans will list the equipment field 

blanks to be collected at each site. 

Purpose: To monitor any contamination from sampling 

techniques (equipment used or ambient conditions). 

— Field Duplicates. Each site-specific sampling plan will specify a 

sampling point for duplicate sampling. EPA will assist the facility 

in selecting the duplicate point. At the duplicate sampling point, 

the facility will fill up twice the number of sampling containers per 

analysis type (using one composite for the original sample and a 

separate composite for the duplicate). 

Purpose: To evaluate total measurement precision and cover 

all the sources of data variability, including sample 

collection, handling, preparation, and analysis. 

• Instrument/Equipment Testing, Inspection, and Maintenance. Facility 

personnel will inspect the sampling devices prior to use to ensure that they 

are working properly. Facility personnel will conduct any required 

maintenance for the sampling equipment including equipment cleaning. 

• Instrument/Equipment Calibration and Frequency. Whenever 

appropriate, facility personnel will use disposable equipment to reduce the 

potential for contamination. If the facility uses non-disposable sampling 

equipment, it will be cleaned and decontaminated prior to subsequent 

sampling. Field sampling equipment and decontamination procedures will 

be consistent with cleaning procedures described in the analytical 

methods. Facility personnel will be responsible for ensuring that all 

equipment is maintained in good working condition and that 

decontamination procedures are properly followed. Any variations from 

the guidelines will be fully documented in field logs. 

Facility personnel will clean the automatic sampling machines prior to use 

for the sampling episode and install new tubing on the sampling pump. 

Each automatic sampling machine will be dedicated to a specific sampling 

point for the entire sampling episode. 

Facility personnel will be responsible for maintaining and repairing the 

test meters used for field measurements to ensure proper operation. 

Samplers will follow applicable test kit calibration procedures specified by 

the manufacturer for any meters used. 

• Inspection/Acceptance of Supplies and Consumables. Critical supplies 

and consumables for this sampling effort include those that come in 

contact with samples. These include sample bottles, preservation 

chemicals, blank water, and sampling equipment. Facility personnel will 
3-9

be responsible for purchasing required materials and inspecting materials 

upon receipt to ensure they are usable for this project (e.g., looking for 

breakage, evidence of tampering, or contamination). 

Where practical, facility personnel will use new sampling equipment 

materials, such as gloves or tubing for automatic samplers that will be 

dedicated to a single sampling point for the each 24-hour collection 

period. If decontamination of non-disposable equipment is needed, 

facility personnel will describe the decontamination procedures in the field 

notes (see Section 3.5). 

• Non-direct Measurements. This sampling program will be augmented 

and complemented by the following types of data generated and provided 

by the CCH facility: 

— Process flow diagrams, 

— Daily chemical production, and 

— Daily flow rate through the treatment plant. 

Loading values consist of both a dioxin concentration and a wastewater 

flow, thus, flow meters should be checked for calibration during this 

project. Best engineering estimates of flow are needed in many cases, 

especially when sampling locations where no flow meters exist, e.g., at 

upstream raw wastewater locations. Procedures to obtain best engineering 

estimates for flows should be part of the planning process early in the 

project, and be detailed in the site-specific sampling plan. 

In addition, facilities will provide relevant information on treatment 

techniques specific to the particular CCH stream being sampled. EPA and 

the facility will develop a checklist of limited engineering data to be 

collected during each sampling episode, which will be included in the sitespecific sampling plan (see Section 3.6). 

• Project Data Management. Field documentation tools for this project 

will include preservation log sheets, field log sheets, and engineering data 

sheets completed by facility personnel. The facility will review all field 

documentation and ensure that all records are legible and complete, and 

retain copies of the documents until the sampling episode is complete. At 

the end of the sampling episode, facilities will provide all documentation 

to EPA as part of the final data package (see Section 4.4). EPA will retain 

as CBI all sample collection data for this sampling program, including 

site-specific sampling plans, field sampling log sheets, engineering data 

sheets, and preservation log sheets, as requested. 
3-10

3.5 Field Measurements

 During each 24-hour collection period, facility personnel will fill a 1-liter glass jar 

for field measurements. For manual composite sampling points that require sample collection 

every four hours, facility personnel will collect the field measurement sample at the same time as 

collecting one of the manual composite samples. Field measurements include temperature, pH, 

and total residual chlorine. Facilities may also provide turbidity measurements on outfall and 

final treated effluent samples. Temperature and pH will be measured in the 1-liter glass jar 

immediately upon collection; total residual chlorine may be taken shortly thereafter, upon return 

to the sample staging area. Facility personnel will note the type of equipment used for field 

measurements on field sampling log sheets (Figure 3-2). Table 3-3 summarizes the field 

measurements, measurement procedure, and the measurement frequency. 

 The field sampling log sheets (Figure 3-2) will be completed at each sampling 

point for each 24-hour sampling period. This sheet will record the sampling methodology, 

names of the samplers, sample collection times, wastewater flow rate at the time of sample 

collection, field measurements, and any notes and observations. Facilities will send copies of the 

completed field sampling log sheets to EPA as part of the final data package (see Section 4.4). 

3.6 Engineering Data Collection

 The goal of Engineering Data Collection is to support the determination that the 

CCH manufacturing units are operating in a normal mode during the 24-hour compositing period 

for each sampling event and to document the operational criteria of the CCH operations that may 

affect the wastewater characteristics of each facility. This typically consists of the following 

type of information: 

1. Daily production rate for the CCH process(es) as percent of nameplate 

capacity. 

2. Operating mode, including units that are down which may impact D/F 

loading results. 

3. Status of, and feed rates for, combustion units generating scrubber 

wastewater. 
3-11

4. WWTP units operating and not operating (stand-alone facilities). 

5. Any non-routine process event or maintenance events/conditions that may 

impact D/F loading results. 

6. Composition of each sample point (i.e. % of each process water type 

making up the sample point). 

7. Any of the above factors which have changed significantly in the 3-day 

period prior to sampling. 

 Engineering data collection at each facility will be site-specific and will be 

developed by EPA with facility staff to ensure capture of all major variables that could impact 

dioxin results. Figure 3-3 shows example engineering data sheets for chlor-alkali, EDC, PVC, 

incinerators, and wastewater treatment. EPA will tailor the data sheets in Figure 3-3 for each 

site-specific plan. Depending on the CCH manufacturing operations and the locations of the 

site-specific sampling points, EPA may not request all information shown in Figure 3-3. EPA 

may request detailed wastewater treatment system operating information for an integrated 

facility that operates a combined wastewater treatment system in order to be able to have enough 

information to model subsequent pollutant removals. Facilities will send copies of the completed 

engineering data sheets to EPA as part of the final data package (see Section 4.4). 

3.7 Sample Shipment

 Facilities should coordinate with their analytical laboratories and Department of 

Transportation (DOT) personnel to ensure that proper packing and shipping procedures are 

followed in the field. Facility personnel will identify samples that are hazardous and require 

shipment as dangerous goods. Facility personnel will follow all DOT and IATA guidelines 

when shipping these samples. 
3-12

Table 3-1. Guidelines for Selecting Sampling Points 

Scenario Monitoring Location 

1. Wastewater treatment plant treats wastewater for 

CCH processes only. (see Table 3-1A) 

Effluent from wastewater treatment. 

2. Wastewater treatment plant treats wastewater for 

CCH processes and non-CCH processes. (see 

Table 3-1B) 

Influent to wastewater treatment from all CCH process 

wastewater streams prior to commingling with nonCCH process wastewater. Individual sampling 

locations could include: 

− Process wastewater stripper effluent; 

− Absorber discharge (other than WAPC); 

− WAPC streams; 

− Dryer effluent; 

− Product wash; or 

− Process wastewater collection sump. 

Samples can be flow-proportionally composited for 

dioxin analysis if they enter treatment at the same 

location and from same CCH process type. 

3. Site has separate outfalls for different CCH 

processes. All relevant site outfalls to be 

monitored for total site discharge estimation. 

Monitor each outfall separately. 

4. Site transfers discharges of CCH wastewater to 

another facility for treatment. 

Monitor stream prior to discharge to neighboring 

facility and after any pretreatment, if applicable. 

Table 3-1A. Analytes to be Collected by Sampling Point for Stand-Alone CCH Facility 

(Example) 

Sampling Point 

Number 

(Type) Sampling Point Name TSS 

Dioxins and 

Furans 

SP-1 (AC) Effluent from wastewater treatment 4 +1 QC 4 

SP-2 (AC) Final Outfall(s) 4 (minimum) 4 (minimum) 

SP-3 (AC) Field Duplicate 1 1 

SP-4 (G) Equipment field blank 1 1 

Total Number of Samples 10 +1 QC 10 

Type: AC-Automatic composite (24 hours); G- One time grab; MC- Manual composite (6x per day) 

QC – Includes extra sample volume required to analyze matrix spikes and laboratory duplicates (see Table 3-2). 
3-13

Table 3-1B. Analytes to be Collected by Sampling Point for Integrated Facility (Example) 

Sampling Point 

Number 

(Type) Sampling Point Name 

TSS Dioxins and 

Furans 

SP-1 (MC) Centrifuge wastewater 4 4 

SP-2 (MC) PVC plant wastewater stripper 4+1QC 4 

SP-3 (MC) EDC/VCM plant wastewater stripper 4+1QC 4 

SP-4 (AC) Caustic scrubber blowdown 4 4 

SP-5 (AC) Final Outfall 4 4 

SP-6 (AC) Field Duplicate 1 1 

SP-7 (G) Equipment field blank 1 1 

Total Number of Samples (can be flow-proportionally composited for 

dioxin analysis if they enter treatment at same location and from 

same CCH process type)

22 +2QC 22 

Type: AC-Automatic composite (24 hours); G- One time grab; MC- Manual composite (6x per day) 

QC – Includes extra sample volume required to analyze matrix spikes and laboratory duplicates (see Table 3-2). 

Table 3-2. CCH Sampling Screen Analytes and Method Requirements 

Method 

Number Parameter Procedure Sample Container

Additional 

QC 

Containers On-Site Preservation (a) 

SM 2540D TSS Gravimetric 1 100 mL plastic 

jar 

None Cool to ≤6oC 

EPA 1613B Dioxins and 

Furans 

HRGC/MS 2 1-L amber glass 

bottles with PTFElined cap 

None Store in the dark, 

Cool to ≤6o

C, 

If pH>9 H2SO4 to pH 7-9, 

If total Cl2 ≥ 0.1mg/L, add 

80mg Na2S2O3 per 1L H2O

HRGC/MS: High resolution gas chromatography with mass spectrometry. 

Table 3-3. Sampling Point Field Measurements 

Field Measurements Tool Used Frequency 

Temperature Thermometer Once every day 

pH pH Probe or pH paper Once every day 

Total Chlorine Colorimetric test kit Once every day 
3-14

Sampling Episode 

Preservation Chemicals – List Strength of Solution from Bottle 

H2SO4____________________ Na2S2O3____________________ 

Sample 

Number Analysis Date Chemical Initial pH Final pH 

Number of 

Drops 

 

Figure 3-1. Sample Preservation Log Sheet 
3-15

Sampling Episode: Sampling Point:______________ Sample ID Numbers:___________ 

Automatic Composite  Manual Composite  Grab 

Time of Compositing period, if applicable: 

 Start Time  AM  PM Start Date______________ 

 End Time  AM  PM End Date ______________ 

Equipment Used for Sample Collection: 

Samplers’ Names: 

Equipment Used for Field Measurements: 

Aliquot Time 

Wastewater Stream 

Flow rate (gpm) 

Flow Meter (M) or 

Best Estimate (E) 

Temp 

C pH 

Total Residual 

Chlorine (mg/L) Amount (L) 

1 

2 

3 

4 

5 

6 

Composite 

Notes: (include any other observations for each aliquot) 

Grab 1: 

Grab 2: 

Grab 3: 

Grab 4: 

Grab 5: 

Grab 6: 

Figure 3-2. Example Field Sampling Log Sheet 
3-16

Engineering Sheet Sampling Episode ______ 

Chlor-Alkali Plant 

Date: 

Average daily chlorine production (note units): _________ 

Flow Information for pH Tank (treatment system for chlor-alkali wastewater) 

Wastewater Stream 

Average Daily 

Flowrate 

(note units) 

Range of Flowrates for 

Sampling Day 

(note units) 

Basis for Flow Value 

(Flow meter or Best 

Estimate) 

Sulfate Purge 

Cooling Tower Blowdown 

Other: 

Effluent from pH tank 

List chemical additions to pH tank: 

Additional Information: (Include any observations, non-routine process events, or deviations from the 

sampling plan) 

Figure 3-3. Example Engineering Data Sheet 
3-17

Engineering Sheet Sampling Episode ______ 

EDC Plant Wastewater Stripper 

Date: 

EDC Production Information 

Direct Oxychlorination Reactor 

Chlorination 

Reactor Reactor 1 Reactor 2 

EDC Production (average daily, note units) 

Daily Reactor Temperature Range (note units) 

Flow Information for EDC Wastewater Stripper 

Process Unit/Wastewater 

Stream 

Average Daily 

Flowrate 

(note units) 

Range of Flowrates 

for Sampling Day 

(note units) 

Basis for Flow Value 

(Flow meter or Best 

Estimate) 

Direct chlorination 

Oxychlorination Reactor 1 

Oxychlorination Reactor 2 

Process Area Stormwater 

Other: 

Effluent from wastewater stripper 

Additional Information: (Include any observations, non-routine process events, or deviations from the 

sampling plan) 

Figure 3-3. (Continued)
3-18

Engineering Sheet Sampling Episode ______

Incinerator Caustic Scrubber 

Date: 

Incinerator Feed Streams (including percentages of each): (example: vent gases from EDC plant) 

Incinerator/Scrubber Information 

Parameter Flow Rate 

Basis for Flow or Feed Rate 

(Flow meter or Best Estimate) 

Incinerator Feed Rate 

Flowrate of caustic scrubber blowdown 

Additional Information: (Include any observations, non-routine process events, or deviations from the 

sampling plan) 

Figure 3-3. (Continued)
3-19

Engineering Sheet Sampling Episode ______

PVC Plant 

Date: 

Production Information for PVC Reactors 

Reactor 

1 

Reactor 

2 

Reactor 

3

Reactor 

4

Reactor 

5

Reactor 

6

Production (average daily, note 

units) 

 

Average daily reactor temperature, 

note units 

Flow Information for PVC Process 

Process Unit/Wastewater 

Stream 

Average Daily 

Flowrate 

(note units) 

Range of Flowrates 

for Sampling Day 

(note units) 

Basis for Flow Value 

(Flow meter or Best 

Estimate) 

Centrifuge Water 

Wastewater Stripper 

Reactor Wash Water 

Total WW flow 

Other: 

Additional Information: (Include any observations, non-routine process events, or deviations from the 

sampling plan) 

Figure 3-3. (Continued)
3-20

Engineering Sheet Sampling Episode ______

Combined Wastewater Treatment System 

Date: 

Flow Information for Combined Wastewater Treatment System 

Process Unit/Wastewater 

Stream 

Average Daily 

Flowrate 

(note units) 

Range of Flowrates for 

Sampling Day 

(note units) 

Basis for Flow Value 

(Flow meter or Best 

Estimate) 

Influents to Wastewater Treatment 

EDC Wastewater Stripper 

Incinerator Caustic Scrubber 

Non CCH Process 1 

Non CCH Process 2 

Other: ______________ 

Effluent from Wastewater 

Treatment 

 

Figure 3-3. (Continued) 
3-21

Engineering Sheet Sampling Episode ______ 

General Wastewater Treatment System Information (Specify units for all parameters) 

 

Biological Treatment Units 

Design capacity flowrate: 

Unit liquid depth: 

Volume of aeration zone: 

Air/oxygen flow to unit: 

Sludge retention time: 

MLSS concentration range: 

Design loading to treatment system (BOD or COD lbs/day): 

F/M ratio: 

Operating temperature: 

Return activated sludge concentration: 

Return activated sludge flow: 

MLSS removal rate: 

MLSS percent solids: 

Clarifiers 

Design capacity flowrate: 

Residence time: 

Overflow rate (gpm): 

Target pH: 

Sludge removal rate: 

Percent solids of sludge: 

Equalization Tanks 

Design capacity flowrate: 

Residence time: 

Overflow rate (gpm): 

Target pH: 

Sludge removal rate: 

Percent solids of sludge: 

Filters 

Design capacity flowrate: 

Operating pressure: 

Cross-sectional flow rate: 

Method of regeneration (if applicable): 

Frequency of regeneration/backwash: 

Figure 3-3. (Continued) 
4-1

4.0 SAMPLING ACTIVITIES

 This section discusses the sampling preparation activities, sampling activities, 

analysis of results, and information to be included in the final data package to EPA. 

4.1 Sampling Preparation

 For sample collection at the 12 VCM facilities, the sampling team will consist 

entirely of facility personnel. EPA and ERG will not be present for the collection of the samples, 

unless they wish to be observers. Facility personnel will be responsible for all health and safety 

(H&S), sample collection, preservation, and shipping activities on site. 

 Prior to the sampling episode, EPA will provide a Site-Specific Sampling Plan to 

facility personnel. Facility personnel will review the sampling plan and conduct a pre-sampling 

teleconference with EPA to review the sampling activities outlined in the plan. 

4.2 Field Sampling Activities

 During sampling, facility personnel will: 

• Collect and preserve all sampling bottles according to Section 3.0 of the 

site-specific sampling plan; 

• Cool samples to a temperature ≤6C prior to packing; 

• Seal sample fractions and place them in shipping containers with ice for 

shipment; and 

• Complete preservation log sheets, field log sheets, and engineering data 

sheets and send to EPA with the final data package (see Section 4.4). 
4-2

4.3 Analysis of Results

 Facility personnel will be responsible for coordinating with analytical laboratories 

and overseeing the analysis of the results of the sampling episode. Facilities will compile the 

analytical results for each sampling day and provide a summary electronic spreadsheet to EPA 

containing the following information: 

• Dates of sample collection; 

• Sampling point identifier; 

• Analytical method used; 

• Concentrations for TSS (mg/L) and for individual congeners of dioxins 

and furans in aqueous concentration units (e.g., pg/L); 

• Concentrations units; 

• Dilution factors for analysis; and 

• Detection limits. 

 

All dioxin analyses will be reported down to the laboratory and sample specific detection limits. 

Values between the detection limit and the ML (minimum level) will be flagged as being outside 

the validated range of the method. 

 The electronic spreadsheet will be sent to EPA as part of the final data package 

(see Section 4.4). In addition, facilities will keep copies of the Level 2 and Level 4 (dioxin only) 

data packages from the analytical laboratories. 

4.4 Final Data Package

 No later than three months after the completion of the last sampling episode, 

facilities will send a final data package to EPA. EPA expects that facilities will complete the 

sampling episodes within twelve months of receiving the final site-specific sampling plan. The 

package will contain: 
4-3

• An electronic spreadsheet showing the analytical results for all samples; 

• Completed field log sheets; 

• Completed preservation log sheets; and 

• Completed engineering data sheets. 

4.5 Site-Specific Logistics

 Below is a list of industry, company, EPA, and ERG contacts. 

Industry Contacts 

Frank Borrelli 

Vinyl Institute 

(703) 741-5668 

Frank_Borrelli@americanchemistry.com

Company Contacts 

[To be determined in Site-Specific Sampling Plans] 

EPA Contacts 

Samantha Lewis 

 Engineering and Analysis Division 

 U.S. Environmental Protection Agency 

 Ariel Rios Building 

 1200 Pennsylvania Avenue, NW (4303T) 

 Room 6233F 

 Washington, D.C. 20460 

 (202) 566-1058 

Paul Shriner 

Engineering and Analysis Division 

U.S. Environmental Protection Agency 

Ariel Rios Building 

1200 Pennsylvania Avenue, NW (4303T) 

Room 6233L 

Washington, D.C. 20460 

(202) 566-1076 
4-4

ERG Contacts 

Lori Weiss 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

(703) 633-1658 

Meghan Camp 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151 

(703) 633-1684 
5-1

5.0 REFERENCES

1. Vinyl Institute, U.S. “Vinyl Chloride Producers” (“VCP”) Proposed Voluntary 

Alternative to Dioxin/Furan (D/F) ELG for CCH Manufacturing Sites; EPA-HQOW-2005-0012, February 9, 2007 

2. European Commission, Integrated Pollution Prevention and Control (IPCC), 

Reference Document on Best Available Techniques in the Large Volume Organic 

Chemical Industry, February 2003, http://eippcb.jrc.es/pages/FActivities.htm. 
Appendix A 

LIST OF DIOXIN AND FURAN ANALYTES 
A-1

Table A-1 

List of Constituents for Analysis - 

Dioxin and Furan Analytes 

CAS 

Number Common Name Technique Method

1746016 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

40321764 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

39227286 1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

57653857 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

19408743 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

35822469 1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

3268879 OCTACHLORODIBENZO-P-DIOXIN HRGCMS 1613B 

51207319 2,3,7,8-TETRACHLORODIBENZOFURAN HRGCMS 1613B 

57117416 1,2,3,7,8-PENTACHLORODIBENZOFURAN HRGCMS 1613B 

57117314 2,3,4,7,8-PENTACHLORODIBENZOFURAN HRGCMS 1613B 

70648269 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN HRGCMS 1613B 

57117449 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN HRGCMS 1613B 

60851345 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN HRGCMS 1613B 

72918219 1,2,3,7,8,9-HEXACHLORODIBENZOFURAN HRGCMS 1613B 

67562394 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN HRGCMS 1613B 

55673897 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN HRGCMS 1613B 

39001020 OCTACHLORODIBENZOFURAN HRGCMS 1613B 

17 DIOXIN ANALYTES