To: Environmental Protection Agency 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

From: Wilma Subra 

Louisiana Environmental Action Network 

Lower Mississippi Riverkeeper 

P. O. Box 9813 

New Iberia, LA 70562 

337 367 2216 

subracom@aol.com 

Date: June 9, 2011 

Subject: Environmental Protection Agency 

Docket 10 No. EPA-HQ-OAR-2002-0037 

LEj\N 

Proposed Rule for National Emission Standards for 

Hazardous Air Pollutants for Polyvinyl Chloride and 

Copolymers Production 

On behalf of Louisiana Environmental Action Network (LEAN) 

and the Lower Mississippi Riverkeeper (LMRK), I would like to 

thank the Environmental Protection Agency for the opportunity to 

comment on the proposed rule dealing with Polyvinyl Chloride and 

Copolymer Production. As you are aware, Louisiana Environmental 

Action Network (LEAN) has been involved in the legal petition 

process dealing with the lack of emission standards for all HAPs 

emitted from PVC facilities. LEAN appreciates the EPA proposing 

emission standards for Vinyl Chloride, Hydrogen Chloride, 

Chlorinated Di-benzo Dioxins and Furans (CDDF) and Total Organic 

Air Toxins. 

POST OFFICE BOX 66323 � BATON ROUGE, LOUISIANA 70896 � (225) 928-1315 J- FAX (225) 922-9247 'Ii WWW.LEANWEB.ORG 
According to the information provided in association with the 

proposed rule, the air emissions of Vinyl Chloride will be reduced 

by 135 tons per year, Hydrogen Chloride by 33 tons per year, 

CDDF by 22 milligrams per year and Hazardous Air Pollutants by 

1,570 tons per year. While these reductions in emissions are 

appreciated, based on the impacts to environmental justice 

community members living in close proximity to the PVC production 

facilities, these reductions are not adequate. The reductions 

would account for 30% of the Vinyl chloride and 32% of the CDDF 

emissions. Such reductions would still result in the Environmental 

Justice communities continuing to be exposed to unacceptable 

levels of Vinyl Chloride and CDDFs. 

Louisiana leads the nation in PVC production facilities with 

six facilities. The PVC production facilities are located in Geismar, 

Plaquemine, Baton Rouge, Addis, and Westlake. The largest Vinyl 

Chloride emitting facility in the United States is located in Geismar, 

Louisiana (Westlake Vinyls Co.). The majority of the Polyvinyl 

Chloride facilities in the state of Louisiana are located in very 

close proximity to environmental justice communities, contrary to 

the information contained in the proposed rule. 

In Louisiana, as a result of operations of the PVC production 

facilities, Vinyl Chloride is present in the ambient air in the 

Environmental Justice communities located in proximity to the PVC 

facilities. The Vinyl Chloride fugitive emissions from the PVC 

production facilities consist of 55 to 78% of the total Vinyl 

Chloride air emissions. Even with the proposed toxic air emission 

reductions, the ambient air will continue to be contaminated with 

Vinyl Chloride and associated HAPs. 

The Vinyl Chloride emitted into the air by the six PVC facilities 

in Louisiana is more than double the Vinyl Chloride emissions 

released into the air from the four PVC facilities in Texas, which 

ranks second in the United States behind Louisiana. 

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Carcinogens 

The known human carcinogen HAPs emitted from the PVC 

production facilities include Vinyl Chloride, Benzene, 1,3-Butadiene 

and CDDF. In addition, a number of probable human carcinogenic 

compounds are also emitted from PVC production facilities. These 

include Acetaldehyde, Bis(2-ethylhexyl)phthalate, Chloroform, 

Chloroprene, Ethylene Dichloride, Ethylidene Dichloride, 

Formaldehyde, Iso-octane, Methylene Chloride, Vinyl Bromide and 

Vinylidene Chloride. As a part of this proposed rule, EPA 

established emission limits for Vinyl Chloride, CDDF, Total Organic 

HAP and Hydrogen Chloride. LEAN and LMRK support the inclusion 

of emission limits for CDDF, Total Organic HAP and Hydrogen 

Chloride in addition to Vinyl Chloride in the proposed rule. In 

addition, EPA should have established emission limits for each of 

the known and probable carcinogen HAPS emitted by the PVC 

production process. 

Wastewater 

The EPA proposed rule has requirements for wastewater 

monitoring and compliance. Vinyl Chloride is required to be tested 

at the point of generation of the wastewater and testing for HAP 

at the point of wastewater determination. The wastewater stream 

containing less than 10 ppmw Vinyl Chloride at point of generation 

and less than 1 ,000 ppmw total HAPs at the point of determination 

are not required to further reduce emissions. The EPA should 

have developed specific criteria limits for the most prevalent and 

toxic HAPs in the wastewater above which reductions are required 

rather than just the 1,000 ppmw criteria for total HAPs. 

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Accidental Releases and Upsets 

PVC production facilities have accidental releases and upset 

operational conditions which result in the release of Vinyl Chloride 

and other HAPs associated with the production process. The 

releases of HAPs frequently extent off the facility site into the 

surrounding Environmental Justice communities. The evaluation 

and control of these releases of Vinyl Chloride and associated 

HAPs are critical to protecting the health of adjacent communities. 

The record keeping and reporting requirements for discharges in 

the proposed rule must be extended to violations associated with 

bypasses, pressure vessels and closed vent systems in vacuum 

service. These records and reports are critical to determine 

emission concentrations, extent of impacts due to the emissions 

and measures taken to prevent the reoccurrence of similar types 

of events. These records are also critical to providing information 

to the fenceline communities. 

Conclusion 

Louisiana Environmental Action Network and the Lower 

Mississippi Riverkeeper encourage the Environmental Protection 

Agency to reduce the quantity of Vinyl Chloride, Hydrogen 

Chloride, CDDF and Hazardous Air Pollutants emissions by further 

tightening up the emission limits in the proposed rule. Dioxin and 

Furan releases have the potential to and have contaminated and 

bioaccumulated in the bodies of human populations in the fenceline 

communities of PVC facilities. The reduction in emissions proposed 

by the EPA will reduce the exposure of Environmental Justice 

communities, but there will still exist unacceptable levels of 

exposure to Vinyl Chloride, Dioxins and Furans, and HAPS in the air 

of these communities. Greater reductions of the toxic chemicals 

must be required. 

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