### MEMORANDUM

TO: Record

FROM: Samantha Lewis, EPA

DATE: June 11, 2008

SUBJECT: Meeting Minutes for the EPA and Trade Group Meeting to Discuss the Proposed Voluntary VCM Program ( 23 April 2008 )

EPA participated in a meeting with The Vinyl Institute (VI) and several member companies (referred to as the Vinyl Chloride Producers, or VCP) on April 23, 2008 to discuss the sampling standard operating procedures (SOPs) developed by the VCP. The list of meeting participants can be found in Attachment A

.

Background

EPA and the VCP initially met on March 14, 2007 to discuss the VCP’s proposed voluntary monitoring program ( VMP ) for vinyl chloride manufacturers . Industry had proposed collecting dioxin a nd furan and total suspended solids (TSS) data for facilities’ final outfalls at a frequency of one sample per month for nine months. At the March 14 meeting, EPA expressed concern about the potential for dilution at the final outfall since many of the fa cilities discharge

wastewater from non

- chlorine and chlorinated hydrocarbon (CCH) manufacturing operations

. EPA prepared a generic sampling plan to describe their suggested approach for sampling and provided it to industry for discussion and comment. For facilities where CCH wastewater is commingled with non

- CCH wastewater, EPA is requesting that the facility collect a sample prior to the mixing point. EPA noted that the number of sampling points will depend on the facility’s manufacturing processes and process flow diagrams. EPA is requesting that industry collect at least four samples at each sampling point , each collected at least one month apart.

EPA developed site

- specific sampling plans for each facility in the VMP. These

site

- specific plans are confidential business information. EPA discussed the site

- specific plans with each site and developed a final plan which the sites will use as instructions for the sampling. To ensure the twelve VMP sites collect samples consistently, the VMP developed the five SOPs

listed below:

**•** VCP

- 1: Grab Sampling Guidelines;

**•** VCP

- 2: Compositing of Liquid Grab Samples;

**•** VCP

- 3: Synthetic QA/QC Sample Handling Protocol;

**•** VCP

- 4: On

- site Automatic Composite Sampling Guidelines; and

**•** VCP

- 5: Analytical QA/QC Requirements.

The purpose of this meeting was to discuss the SOPs. The VCP is currently finalizing the SOPs prior to initiating sample collection. Final copies of the SOPs will be entered into the Chlorine and Chlorinated Hydrocarbon rulemaking record.2 Discussion

Mr. Jim Williams, Dow, presented an overview of VCP’s sampling status (Attachment B). The twelve VCP facilities will be using three different laboratories. The VCP selected Environmental Standards in Valley Forge, PA to review and validate the results fr om the

laboratories. Environmental Standards will receive Level 4 reports from the laboratories for review. Each company in the VMP has already sent a QA sample to their laboratory to ensure the lab is qualified to perform the analysis.

Mr. Williams e xplained that the VCP has developed five sampling SOPs to ensure accurate, consistent results and that the SOPs will be used in conjunction with EPA’s Generic Sampling

Plan and the site

- specific sampling plans. The VCP is building a database to house the sampling data collected but they are still working through confidentiality issues and whether they can share data between companies.

1. The VCP asked if EPA would like interim reports. EPA stated they would like to be notified when sample collection begins but will only need a final report from each

company.

2. EPA and the VCP discussed each of the five SOPs. EPA did not have any major comments on the draft SOPs. The VCP will conduct sampling training for the staff collecting the samples. Some facilities w ill be using contractor staff for the sample collection. The VCP plans to add discussions of foaming issues, clean techniques, and safety issues to the existing SOPs.

3. The VCP will develop final site

- specific instructions for their sampling staff to use

a nd will include these instructions in their final data package to EPA.

4. The VCP asked about the sampling frequency. They may want to sample more frequently than once per month based on operating modes. EPA stated that individual companies can decide when it is appropriate to sample and should note the reasons for the selected dates in their final data package (e.g., differences in operating modes, production) . EPA is assuming that all sampling will be completed within 15 months of receipt of the letter t ransmitting the site

- specific plans (approximately May 2009). Most companies do not think there will be problems with meeting the schedule barring unforeseen circumstances (e.g., force majeure events).

Next Steps

1. The VCP will complete the SOPs.

2. Each c ompany in the VMP will notify EPA when sampling begins.Appendix A. List o f Participants

EPA / VCP SOP Meeting

April 23, 2008

Name Company Contact Information

Jan et Goodwin EPA 202

- 566

- 1060

Samantha Lewis EPA 202

- 566

- 1058

Ann Johnson EPA 202

- 564

- 5966 Mary Smith EPA 202

- 566

- 1000

Lem Walker EPA 202

- 566

- 1077

Todd Abel CCC 703

- 741

- 5856 Mary Bachynsky FPC USA 973

- 716

- 7342 Tom Berger Keller & Heckman 202

- 434

- 4285 David Blye

– via phone Environmental Standards 610

- 935

- 5577 Jason Campbell PPG 337

- 708

- 4450

Toni Darnall

– via phone Westlake 270

- 395

- 3571 Jeff Longsworth

– via phone Barnes & Thornburg 202

- 408

- 6918 Meg Michell Environmental Standards 610

- 935

- 5577

John Westendorf O ccidental Chemical 972

- 404

- 3229

Jim Williams Dow 304

- 737

- 3956

Lori Wei ss ERG (contractor to EPA) 703

- 633

- 1658