MEMORANDUM

TO: Record 

FROM: Samantha Lewis, EPA 

DATE: November 29, 2005 

SUBJECT: CCH Industry Trade Group Meeting 

 EPA staff and their contractors met with representatives from industry 

trade associations on November 16, 2005 to discuss the status of the site visit and 

sampling program and the revised project scope. Appendix A contains a list of the 

attendees. This memorandum summarizes the meeting discussion points. 

EPA Update 

EPA gave a brief overview of the project schedule. EPA plans to conduct two 

sampling episodes in the spring of 2006. EPA will conduct a second round of sampling 

at up to four additional sites in the fall of 2006. EPA will conduct multi-day composite 

sampling rather than one-day grab sampling. The sites will be selected from the facilities 

that have been visited; therefore, not all sites will be selected for sampling episodes. 

EPA will select the sampling points from those discussed during the site visits; it is 

possible that not all sampling points will be selected. 

EPA would like to conduct five additional site visits in Louisiana in December. 

Trade group personnel stated that would be difficult due to holiday schedules at the 

plants, possible turnarounds, and residual staffing difficulties due to the increased need 

for staff during the hurricane recovery efforts. Since the November 16 meeting, EPA has 

decided to move the Louisiana site visits until January. 

EPA will provide the trade associations with a draft version of the industry 

questionnaire in early December. The trade associations will have two weeks to provide 

comments to EPA. EPA plans to publish the first federal register notice which will 

contain a draft questionnaire for public comment in January of 2006. EPA is still 

planning for a proposal date of March 2008. 

EPA also discussed the proposed project scope change. The project will be 

renamed Chlorine and Chlorinated Hydrocarbons (CCH). All chlorine manufacturers 

will be included in the scope. EPA will also include facilities that produce chlorinated 

hydrocarbons using direct chlorination, oxychlorination, and dehydrochlorination that are 

currently regulated under OCPSF. EPA will provide a list of the facilities that fall under 

the new scope along with the questionnaire in early December. 
Trade Association Update 

The trade associations (John Westendorf, OxyVinyls) presented areas of concern 

for the review of the vinyl chloride and chlor-alkali industry. Appendix B contains the 

handouts industry provided during the meeting. Their primary areas of concern are: 

1. Use of TWPE – The trade associations have concerns with the toxic 

weighting factors applied which EPA used to rank hazards. Appendix B 

contains TRI data showing the release of dioxins and furans in water has 

been decreasing. 

2. Small number of facilities – Only a fraction of the facilities in the industry 

group report releasing dioxin. 

3. Data collection – Data collection will be difficult due to CBI issues and 

the difficulty of obtaining representative sampling results. 

The trade associations proposed using a voluntary approach to reduce hazardous 

discharges from this manufacturing segment. A voluntary approach would reduce EPA’s 

rulemaking burden and could be implemented faster than a rulemaking approach. The 

trade associations have used voluntary approaches with EPA for other efforts (e.g., the 

PBT initiative with OPPT). EPA (Jan Goodwin) stated that EPA would be interested in 

hearing any industry suggestions but would continue with the CCH program in the 

interim. 

 Mary Bachynsky, Formosa Plastics, presented the trade associations concerns 

with collecting sampling data. The primary areas of concern are: 

1. High Variability – Difficult to obtain representative samples due to varying 

process conditions. 

2. Sample Site Locations – Certain points may be a safety risk or may impact 

production. Industry believes they already know the source of dioxin and 

therefore in-process samples are not needed. 

3. Sample Integrity – Samples will have unique collection, handling, 

preservation, and shipment issues. 

4. Analytical Methods – The trade associations would like a list of available test 

methods and accredited laboratories. Only a few laboratories can test for 

dioxin/furan. 

5. High Cost-to-Benefit Ratio – The trade associations feel that manpower 

requirements, production losses, and analysis costs should be factored into 

EPA’s sampling decision. 
EPA stated that they would work through sampling issues with the sites selected. The 

sites will receive a detailed sampling plan that will discuss the selected sampling points, 

analytes, safety issues, and any other special considerations.