Memorandum, August 9, 2013 

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MEMORANDUM 

TO: Andrea 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 Chemical 
Memorandum, August 9, 2013 

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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 ERG 
Memorandum, August 9, 2013 

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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 

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• 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 equipment 

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 Sources
Memorandum, August 9, 2013 

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• 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 Institute 
 

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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

Research Triangle Park, NC 27711

RE: Revised Agenda for Vinyl Institute Meeting on July 23, 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 Agenda below for our discussions to help facilitate the flow 

of the discussion with some suggested timeframes for the 4 hours allocated for this meeting. Should you or 

your colleagues have any additional items that you wish added 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: (80 min.) 

4. New Source Limits – (30 min)

5. Combined Process Vents: (30 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: (10 min.)

11. Area Sources (10 min.)

12. Other topics, next steps (5 min.)

13. Adjournment 
 

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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 Bloomer – 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 appreciates 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 protective of human

health and the environment, while allowing the industry the flexibility to compete effectively in the global 

economy. The Working Group looks forward to our discussions with you on Tuesday, July 23, 2011. Please do 

not hesitate to contact me if you have any questions.

Sincerely, 

Richard P. Krock

Technical Director

e-mail: rkrock@vinylinfo.org

Phone: 571-970-3392

Cell: 571-216-4474

cc: Penny Lassiter