Memorandum, August 9, 2013 Page 1 of 5



## MEMORANDUM

TO: A ndrea Siefers, US EPA/SPPD/RCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: August 9, 2013

SUBJECT: Summary of July 23, 2013 Meeting Between US EPA and The Vinyl Institute

1.0 Introduction

On July 23, 2013, a meeting by teleconference was held at the request of the Vinyl Institute (VI) and their member companies to present information to the EPA, in advance of EPA’s planned rulemaking proposal to respond to petitions for reconsideration on the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Polyvinyl Chloride and Copolymers (PVC) Production, which were promulgated on April 17, 2012.

2.0 Date and Location

July 23, 2013

U.S. Environmental Protection Agency
109 TW Alexander Drive Durham, NC 27709

3.0 Attendees

Name Affiliation

Richard Krock Vinyl Institute

Mary Bachynsky Formosa Plastics

Jean-Cyril Walker Keller & Heckman

Greg Clark Keller & Heckman

John Nickerson Axiall

Kenny Akins

Kevin Bloomer Axiall

Westlake Chemical

Allen Bodron Westlake ChemicalMemorandum, August 9, 2013 Page 2 of 5



### Al Matyger PolyOne

Andy Sheppard URS

Barry Christensen OxyChem

John Westendorf OxyVinyls

Laura Whiting OxyChem/Oxy Vinyls

Bob Elam Dow

Jodi Howard EPA

Mark Kataoka EPA (by phone)

Penny Lassiter EPA

Marcia Mia EPA (by phone)

Andrea Siefers EPA

Steffan Joshnson EPA

Colin Hayes ERG

Philip Crawford ERGMemorandum, August 9, 2013 Page 3 of 5



### 4.0 Summary of Meeting

The meeting began with introductions and an overview of the meeting structure. The VI provided an agenda, which is attached. The following are summaries of the information presented by industry.

1. Wastewater

• The VI discussed the data submitted by industry in response to the November 6, 2012 section 114 request issued by EPA. The VI described the variability of the concentrations of various organic hazardous air pollutants (HAP) in the data set. The VI indicated that the data provided by industry do not represent all of the products produced by facilities.

• The VI noted that Dow Midland does not expect any organic HAP (except vinylidene and vinyl chloride) in the wastewater at the Midland facility. The VI stated that Dow Midland manufactures one grade of resin (a polyvinylidene chloride/vinyl chloride copolymer) and contended that the Midland facility should be considered as a separate subcategory.

• The VI discussed the variability of methanol and acetaldehyde concentrations in the process wastewater. The VI stated that the presence of these compounds in the wastewater is due to the fact that the compounds are used in PVC resin recipes or are decomposition products.

• The VI recommended that EPA retain the vinyl chloride limit of 6.8 parts per million by weight (ppmw) which was promulgated on April 17, 2012. The VI recommended that EPA revert back to the originally proposed option of complying with the HON for process wastewater if the process wastewater stream
met certain flow and concentration characteristics.

2. New Source Limits

• The VI stated that the total organic HAP (TOHAP) limit for suspension resins at new sources is low and would prevent new greenfield PVC facilities from being

constructed.

• The VI argued that the TOHAP data set for the best performer represents only a limited number of PVC grades and recipes. The VI also contended that a resin stripper cannot be optimized to remove both vinyl chloride and TOHAP. The VI added that a new source would not be able to meet both the vinyl chloride and TOHAP limits under the final rule since the vinyl chloride limit was set by a facility making one particular resin grade under certain conditions, and the TOHAP limit was set by another facility, making a different subset of resin grades.

3. Combined Process Vents

• The VI presented comparisons of PVC-only, PVC-combined, HON, and MON limits for process vents.Memorandum, August 9, 2013 Page 4 of 5



### • The VI stated they were concerned with overlapping provisions for parametric monitoring of control devices for process vents.

• The VI presented a “weighted maximum achievable control technology (MACT)” process vent limit, based on the recent boiler MACT. The VI proposal would allow facilities to calculate a weighted process vent limit for PVC-combined streams based on inlet flow characteristics for each regulated stream entering the
control device.

• The VI again contended that Dow Midland should be subcategorized based on the size of the process vent and the fact that PVC makes up a small percentage of the copolymer produced by the facility. The VI also contended that EPA should not consider Dow’s data in setting the dioxin/furan floor based on the age of the data (collected in 1998).

4. Bypasses from Closed Vent Systems

• The VI described their concerns with the bypass provisions in the final rule. The VI presented a diagram of the PVC process and requested EPA define gas handling equipment up to, and including the vinyl chloride recovery system as the “recovery system.” The VI requested that EPA define the gas handling equi pment from the recovery system to the control device as the process vent system. The VI contended that the bypass and emission profile provisions not apply to the
recovery system.

5. Requirements for Emission Profiles

• The VI and EPA discussed the calculations in the final rule related to emission profiles. The VI stated they intend to provide EPA with calculations the VI believes are more appropriate than those contained in the final rule.

6. Limits for Vent Gas Absorbers

• The VI presented a mass based proposal for process vent limits. The VI suggested using the concentration based process vent limit, in combination with the average flow characteristics of the top 5 facilities to calculate a mass equivalent limit.

7. Pressure Relief Device Requirements

• The VI raised concern that the preamble to the final rule discusses a requirement to record the duration of a pressure relief event, while the rule does not contain such a requirement.

• The VI requested alternative provisions to the final rule for monitoring pressure relief devices The VI indicated they would submit proposed amendments to EPA.

8. Pressure Vessel Leaks

• The VI requested EPA allow leak detection and repair (LDAR) for pressure
vessels.

9. Area SourcesMemorandum, August 9, 2013 Page 5 of 5



### • The VI, and specifically Oxy Vinyls/OxyChem, discussed their concerns related

to area sources.

• The VI and Oxy Vinyls/OxyChem stated that they disagree with EPA’s consideration of area sources in major source floor calculations and any potential decision to apply MACT to area sources.

• The VI and Oxy Vinyls/OxyChem stated that consideration of environmental justice is not included in the Clean Air Act for setting MACT or New Source Performance Standards (NSPS), and cautioned EPA against setting a precedent by considering environmental justice in MACT or NSPS standards.

The VI indicated they would provide a follow-up letter summarizing the concerns expressed to EPA in this meeting in approximately three weeks. The EPA received this letter on August 16,

2013.Memorandum, August 9, 2013
Attachment A



### A-1 

# Attachments

A. Meeting Agenda Submitted by the Vinyl InstitutePage 1 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com July 10, 2013 Sent Electronically Via e

- mail

Ms. Andrea Siefers

, Program Manager

U.S. EPA - Office of Air Quality Planning and Standards Sector Policies and Program Divisions Refining and Chemicals Group

Mail Code: E143

- 01

Re search Triangle Park, NC 27711

RE: Revised Agenda for Vinyl Institute Meeting on Jul y 2 3 , 2013, 12:00 noon to 4:00 pm at EPA RTP, NC

Offices : National Emission Standards for Hazardous Air Pollutants for Polyvinyl Chloride and Copolymers

Production (PVC MACT) Rule

Dear Ms. Siefers :

The Vinyl Institute PVC MACT Working Group appreciates the Agency’s willingness to meet with us to discuss
our concerns, questions, additional data submissions, and information for reconsideration of certain provisions

of the above -referenced rule. We have revised the Age nda below for our discussion s to help facilitate t he flow of the discussion with some suggested timeframe s for the 4 hours allocated for this meeting

. Should you or your colleagues have any additional items that you wish add ed for our preparation, please feel free to add them

to the following topics :

1. Introductions and Opening Remarks (10 min.)

2. Petitions for Reconsideration: EPA Status Update

3. S114 Treated Process Wastewater Request: (8 0 min.)

4. New Source Limits – (3 0 min)

5. Combined Process Vents : (3 0 min)

6. Bypasses from Closed Vent Systems : (15 min.)

7. Requirements for Emission Profiles: (15 min.)

8. Limits for Vent Gas Absorbers : ( 25 min.)

9. Pressure Relief Device Requirements : (10 min.)

10. Pressure Vessel Leaks: (1 0 min.)

11. Area Sources (10 min.)

12. Other topics , ne xt steps (5 min.)

13. AdjournmentPage 2 of 2 1737 King Street, Suite 390, Alexandria, VA 22314 (571) 970

- 3392 Fax (571) 970

- 3271 www.vinylinfo.org www.vinylindesign.com At this time, I anticipate the following Working Group members to attend:

Mary Bachynsky – Formosa Plastics Barry Christensen – OxyChem

John Westendorf – OxyChem Laura Whiting - OxyChem

Tom Andersen - Shintech

Kevin Bloome r – Westlake

Allen Bodron – Westlake Al Matyger – PolyOne

Ted Nickerson – Axiall Kenny Akins - Axiall Andy Sheppard - URS

JC Walker – Keller and Heckman Greg Clark – Keller and Heckman

Richard Krock – Vinyl Institute

There are a few others that would like to attend but their schedules prevent them from doing so. Accordingly, I

have circulated the coordinates for the teleconference line you set up so they can participate by phone.

Again, the Working Group appreciate s the time and effort the Agency has put forth for this rule and your continued willingness to meet with us to ensure the amendments to final rule are fully protec tive of human health and the environment, while allowing the industry the flexibility to compete effectiv ely in the global

economy. The Working Group look s forward to our discussions with you on Tue sday, July 23 , 2011 . P lease do

not hesitate to contact me if you have any questions.

Sincerely,

Richard P. Krock

Technical Director

e- mail: rkroc k@vinylinfo.org

P hone: 571

- 970

- 3392

Cell : 571

- 216

- 4474

cc: Penny Lassiter