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MEMORANDUM

To: Jodi Howard, U.S. EPA, OAQPS

From: Graham Gibson and Colin Hayes, ERG

Date: September 29, 2009

Subject: Summary of September 28, 2009 Meeting Between EPA and The Vinyl Institute 

and the Polyvinyl Chloride Industry to Discuss Questions on the Polyvinyl 

Chloride and Copolymers Production (PVC) Section 114 Testing and Sampling 

Requirements

On September 28, 2009, members of The Vinyl Institute (VI) and the Polyvinyl Chloride (PVC) 

industry met with EPA at EPA’s campus in Research Triangle Park, North Carolina. The 

attendees and affiliation are listed below:

Name Representing

Jennifer Gibbs U.S. EPA Region 6 (attended via telephone)

Mark Kataoka U.S. EPA, OGC (attended via telephone)

Tom Driscoll U.S. EPA, OAQPS, SPPD

Jason Dewees U.S. EPA, OAQPS, AQAD

Barry Christenson OxyChem Corporation

Mark Garza Shintech Corporation

Ken Hustvedt U.S. EPA, OAQPS

Mary Bachynsky Formosa Plastics Corporation

Jodi Howard U.S. EPA OAQPS

Richard Krock The Vinyl Institute
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Otis Sistrunk PolyOne Corporation

Kevin Bloomer Westlake Chemical Corporation

Russell Wozniak Dow Chemical Corporation

Kenny Atkins Georgia Gulf Corporation

Nate Johnson Georgia Gulf Corporation

Jim Guenthoer Golden Specialty Corporation

Gary McAlister U.S. EPA

Peter Westlin U.S. EPA

Rachel Agnew U.S. EPA

Nick Parsons U.S. EPA

Chris Farley Westlake Chemical Corporation

Karen Khonsari Westlake Chemical Corporation

JP Walker The Vinyl Institute (attended via telephone)

Allen Westlake Chemical Corporation

Karen Westlake Chemical Corporation

Bruce Certainteed Corporation

Bliss Higgins

Christy Draper

Colin Hayes Eastern Research Group, Inc.

Graham Gibson Eastern Research Group, Inc.

The meeting began at 1:00 PM. A summary of the meeting’s discussion follows.

I. Overview
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EPA provided the following remarks to open the meeting. These remarks cover broad areas of 

concerns expressed from the PVC industry.

The PVC MACT was promulgated in 2002 and vacated in 2004. Industry provided EPA 

with information in 2007 and 2008, and this rulemaking effort is an extension of that 

effort.

EPA sent a survey to the PVC industry on August 21, 2009 and has received numerous 

questions on a variety of broad topics. Those topics include:

o Industry’s request to use prior stack test data. EPA stated that if a facility has 

done emissions testing within the past year, the data should be provided to EPA 

along with a complete test report.

o Level of detection for pollutants. EPA has not and will not set a de minimis level 

for any hazardous air pollutant (HAP). A detection limit cannot be provided to 

industry by EPA before testing. If industry submits emissions test data below a 

detection limit, EPA wants a description of how that detection limit was obtained.

o Rationale for testing various points. Regulatory history leads EPA to request as 

much data as possible. One major reason the previous revisions were vacated was 

surrogacy. EPA needs to know specific process HAP emissions to aid in 

rulemaking.

o A common PVC resin sampling protocol. PVC industry stated that they want 

make sure each facility has a common understanding of what is specified in the 

test plan text.

o Ancillary test and data needs. EPA stated that there has been some movement 

with start-up/shutdown/maintenance (SSM), but is not familiar with state 

reporting requirements on the subject. EPA would like to gather any SSM data 

that is available.

EPA will review the responses to the questions provided by the PVC industry and 

provide responses no later than Friday, October 2, 2009.

II. Answers to Industry Questions

EPA compiled a list of 27 questions provided by the PVC industry. A discussion was held on 

each specific question, and EPA’s response to each question, in numeric order, is detailed below. 

EPA stated that facility-specific questions should be held off at this time.

1. EPA stated it would be best to do separate analyses on both the liquid and solid portions 

on the front half, unless the method analysis is applicable to the two different phases.

2. This question is answered in another response.

3. EPA stated that anything industry adds to their processes of which they are aware that 

may emit or decompose into HAP should be tested for. EPA stated that not every facility 

will emit the same HAP.

PVC industry asked if the working list of HAP is the list of 189 specified by the 

Clean Air Act, and not on the list provided by EPA. EPA agreed with this claim, 

stating that the list of HAP given to industry was based on information from NEI, 

industry, and VI.

EPA stated that they do not want is to have to go back and re-test something. 

Industry may submit CBI, but must be very careful when claiming something as 
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confidential. If non-CBI data is flagged as confidential, it creates unnecessary work 

for both parties.

EPA stated that if a majority of facilities show emissions of a specific HAP, the

facility/facilities that do not may be asked to further investigate why that HAP is not 

present.

4. EPA stated that for each day, the minimum requirement is one composite sample from an 

inlet and one composite post-dryer. If there are multiple resin grades, industry should 

combine the samples from each. EPA stated it would like to get a max HAP loss between 

the inlet and outlet at the facility. EPA stated that, if industry thinks multiple samples 

would show more variability, they are welcome to test individual samples.

PVC industry asked what should be done if different grades of resin are produced at 

different times of the year. The production of resin in this season may not necessarily 

represent a facility’s emissions on a yearly basis. EPA understands that industry 

cannot be forved to produce a grade of resin. EPA also states that if a facility 

produces additional emissions data in the future, the facility is welcome to submit that 

data to EPA. EPA will, in turn, attempt to use the additional data in the rulemaking 

process.

PVC industry stated that if composite sampling is the way of characterizing an entire 

plant, EPA will have problems comparing facilities on a resin basis. EPA agrees with 

industry, reiterating that only a composite is required but additional data may be 

submitted. EPA stated that any additional data submitted by industry will be 

beneficial to both parties.

PVC industry stated that the deadlines are a problem. EPA understands, stating that 

both parties need to move forward as quickly as possible. EPA stated that the 

October 9 and November 30 deadlines will not move, and it is not expected for the 

February 28 deadline to move either.

5. This question is answered in another response.

6. This question is answered in another response.

7. EPA stated that this question seems to be confusing sampling and testing, or perhaps 

combining the two. An answer was not given for this question for that reason.

8. EPA stated their intent to get as much inlet data as possible. EPA requested industry to 

submit any kind of flow monitoring data they may have (such as calibration data or 

SOPs). If the data does not meet the criteria of Subpart DD, it should not be submitted.

Some have combined inlets (with PVC and other processes); if it is at all possible, get a

mass rate from the PVC plant versus the entire (total). If there a way for industry to test 

the PVC and total and back-calculate the PVC emissions they should do so, but 

distinguish how they did so in their report.

Industry asked if a PVC and VCM plant vent to the same thermal oxidizer, how

concentrations between streams should be distinguished since concentrations will be 

virtually identical. VCM is already subject to another MACT, and so is the exhaust, 

so why does it matter what goes in if what goes out is already regulated? EPA stated 

that PVC itself is not regulated, and it is required. PVC industry asked if this would 

be a HON/MON override, to which EPA stated it could potentially be available. The 

most stringent MACT will apply to them all. PVC industry asked, if a thermal 

oxidizer has met HON/MON, data should be submitted and specify the HON/MON 

compliance? EPA reiterated they would like as much data as possible.
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PVC industry stated EPA has asked for concentration results, for every single 

parameter. EPA stated they would like concentrations (ppm) and flowrates. PVC 

industry asked why flowrates are desired when you only need concentrations. EPA 

stated that is just the way that ERG had their spreadsheet set up. EPA wants

concentration and mass rates. EPA ideally would like test reports, and EPA will do 

data conversions.

PVC industry asked if Method 320 should be used on the inlet. EPA stated it should 

be, for speciated data and total. PVC industry asked if they should identify each HAP 

in the stream, down to the detection limit. EPA stated that industry should, and that 

EPA will evaluate that detection limit.

PVC industry asked if Method 26A could be run non-isokinetic to obtain moisture. 

EPA stated this was acceptable.

PVC industry stated that if there is a water drop, only polar compounds will be in the 

water drops. Industry suggested using another method. EPA suggested single point, 

quasi-isokinetic.

PVC industry asked if Method 0031 could be moved to the outlet. EPA stated this 

was acceptable.

9. EPA stated that as long as multiple control systems are configured the same, only one 

needs to be tested.

10. This question is answered in another response.

11. (A) This question is answered in another response.

(B) This question is answered in another response.

(C) EPA approved this suggestion.

(D) EPA approved this suggestion.

12. (A) EPA will allow an alternate proposal.

(B) This question is answered in another response.

(C) EPA stated that this should be added to the facility’s test plan proposal.

(D) EPA stated that normal operation is desired, which would include all process vents 

to the thermal oxidizer operating normally.

(E) EPA stated that this is not an acceptable approach.

(F) EPA stated that this should not be an issue, and that the sampling should be done at 

the same time.

(G) EPA does not understand this very well, stating they have seen it during compliance 

inspections. EPA asked industry if these are quantifiable emissions, and if it is something 

that needs to be regulated. The EPA Region 6 representative stated that they have seen 

sources that they can’t find any way they are regulated (no requirements on emissions, 

whether on a permit or federal regulation). VCM NESHAP has been very lacking.

PVC industry asked if EPA is looking for miscellaneous protocol testing in the plants. 

EPA stated that they are not looking for miscellaneous protocol testing, but would 

like to know how industry handle off-spec resin.

PVC industry asked for clarification on off-spec resin. The EPA Region 6

representative stated it is any resin that does not come off and go through the normal 

stripping process. VCM NESHAP does not mention this type of resin anywhere.

(H) CO may be removed from consideration since there is no combustion in the PVC 

process.

13. This question is answered in another response.
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14. This question is answered in another response. EPA also stated that ethylene should be 

taken out of Table 1.3, as it is not a HAP.

15. EPA stated that the tests were originally at 8 hours and has been reduced to three fourhour tests.

16. EPA stated that in general, flowrate calculations require molecular weights. Oxygen data 

is needed to normalize industry data into a common unit of measure.

17. EPA stated that since there is no combustion in the process, there should be no concern 

with CO. EPA stated that methane may be tested using Methods 18 or 320. A constant 

methane monitor is not necessary, and all that is required is a minimum of one 24-hour 

value at the outlet. The FTR at the inlet should fulfill the methane requirement.

18. This question is answered in another response.

19. This question is answered in another response.

20. This question is answered in another response. EPA also stated that PVC industry may 

look at GD-51b to gain more information. ERG will post this document on the website.

21. EPA stated that they will take a further look at this question and provide a response in 

the future.

22. EPA stated that a mass balance on the resin may be used on the dryer, so 30-day 

monitoring is not needed.

23. PVC industry asked if periods of SSM should be included in the 30 operating days. EPA 

stated that it should be 30 days of normal operation, not including SSM.

PVC industry asked EPA do define a normal operating day, stating that the winter 

time frame is problematic for normal operation. Customer demand is low and 

facilities expect more down time this time of year.

PVC industry also noted that emissions, on a concentration basis, should not change 

based on the production rate of the facility. EPA agreed with this claim.

EPA reiterated that the questionnaire asks for annual usage and, when submitting test 

reports, industry should characterize the operating rate and notify if it is at a fraction 

of normal rate.

24. This question is answered in another response.

25. This question pertained to the survey. All survey-related questions were skipped at this 

time.

26. This question pertained to the survey. All survey-related questions were skipped at this 

time.

27. This question pertained to the survey. All survey-related questions were skipped at this 

time.

III. Closing Remarks

The PVC industry had a couple of extra questions to close out the meeting. Those questions, 

along with EPA’s response, are listed below.

PVC industry asked if the test plan approval process could impact deadlines. EPA stated 

that a large staff is available to help review the test plan submissions. EPA anticipates

that all plans will be reviewed and turned around in 4 weeks. If a plan is not approved, 

EPA will negotiate with that specific facility. Once each test plan is received, feedback 

will be shifted to a 1-on-1 basis between specific facilities and EPA.
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o PVC industry asked if a deadline could be negotiable. EPA stated that they 

cannot confirm or deny that deadlines can be negotiated.

o PVC industry stated they have calculated a compliance schedule and it was 

contingent on the EPA test plan review taking three weeks instead of four. EPA 

stated that they cannot commit to that time frame, stating that the review must be 

done correctly, which may or may not take the entire four week estimate.

o EPA asked PVC industry if they foresee enough differences between test plans 

that some may not be approved. PVC industry stated that they expect problems 

based on the complexity and number of available contractors.

PVC industry asked if clarification on testing methods could be resolved in this meeting. 

EPA responded that they will review suggestions after the meeting and have a decision 

by tomorrow.

EPA stated that PVC industry should bring any future concerns to the attention of EPA.

o PVC industry stated there are a lot of questions about the survey and wondered if 

a meeting could be scheduled to go over those questions. EPA stated that 

personal meetings are difficult, and that webinars would be easier on both parties.

o EPA stated that there will be no webinar to discuss survey questions before 

October 9.