1

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 Questio ns on the Polyvinyl Chloride and Copolymers Production (PVC) Section 114 Test ing 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 Trian gle 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 Dew ees U.S. EPA

, OAQPS, AQAD

Bar r y 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 Institute2

Otis Sistrunk Po lyOne 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

Pet er 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 follo ws.

I. Overview3

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 200 7 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 t est 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 haza rdous 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 va rious 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 protoc ol. 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), bu t 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 facili ty

- 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 portion s on the front half, unless the me thod analysis is applicable to the two different phases.

2. This question is answe red 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 worki ng 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 as4 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 e ach 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 sample s would show more variability, they are welc ome 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

represe nt 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 E PA. 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 wit h 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 unders tands, 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 r esponse. 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 mu ch inlet data as possible. EPA requested industry to

s ubmit 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 (w ith 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

- calc ulate the PVC emissions they should do so, but distinguish how they di d 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 t he 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 ava ilable. The most stringent MACT will apply to them all. PVC industry asked, if a thermal

oxidizer has met HON/MON, data should be submit ted and speci fy the HON/MON compliance? EPA reiterated they would like as much data as possible.5 PVC i ndustry stated EPA ha s asked for concentration resu lts, for every single parameter. EPA stated they would like concentrations (ppm) and flowrate s

. PVC

i ndustry ask ed why flowrates are desired when you only need concentrations. EPA

stated that is just the way that ERG had their spreadsheet set up. EPA want s concentration and mass rate s. EPA ideally would like test reports, and EPA will do

data conversions.

PVC i nd ustry 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 stre am, 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 mois ture. 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 po int, quasi

- isokinetic.

PVC i ndustry asked if Method 0031 could be moved to the outlet . EPA stated this was acceptable

. 9. EPA stated that a s long as multiple control systems are configured the sam e, 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 n ormal 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 R egion 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). VC M NESHAP ha s 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 as ked 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 menti on this type of resin anywhere. (H) CO may be removed from consi deration since there is no combustion in the PVC

process. 13. This question is answered in another response.6

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 o riginally at 8 h ours and has been reduced to three four

hour 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 s ince there is no combustion in the process, there should be no concern

with CO. EPA stated that m ethane 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 a t GD

- 51b to gain more information. ERG will post this document on the websit e. 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 mor e 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 su rvey. 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 p lan approval process could impact deadlines. EPA stated

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

. EPA anticipate s 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.7 o PVC industry asked if a deadline could be negotiable. EPA stated that they cannot confirm or deny that deadline s 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 b e 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 an d 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 s hould 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 w ebinars would be easier on both parties.

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

October 9.