MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: April 12 , 2010

SUBJECT: S ummary of March 2 and March 3, 2010 US EPA Visits to Shintech

Louisiana Facilities

1.0 Introduction

On March 2 and March 3, 2010, EPA visited the Shintech facilities in Plaquemine (3/2 and 3/3) and Addis (3/3)

, Louisiana for a meeting with plant personnel

, tour s of the p olyvinyl

c hloride (PVC) production facilities at both sites, and stack testing observation at the Plaquemine

facili ty. The visit s were conducted to support EPA’s effort to develop national hazardous air pollutant emission standards for the PVC and Copolymers Production source category.

2.0 Date and Location

March 2, 2010 and March 3, 2010

Shintech

– Plaquemine Plant 1 26270 Highway 405 River Road South Plaquemine, LA 70764

March 3, 2010

Shintech

– Addis Plant

9750 LA

- 1 South
Addis, LA 70710Memorandum

p. 2 of 9

3.0 Attendees

Name Affiliation

James S. Bell Shintech / Environmental Supervisor

David Wise Shintech / Plant Manager

Pa ul Schoppe Shintech / Assistant Supervisor SPP PVC Plant

James Miller Shintech / Production Superintendent

Shelita Williams Shintech / Environmental Technician

Sam Colon Shintech / Safety / Security

Jodi Howard US EPA Colin Hayes ERG Philip Cra wford ERG

4.0 Summary of Visit

The meeting with Shintech representatives began at approximately 8:00 A M . A summary of the meeting’s discussion follows.

The meeting began with individual introductions. EPA indicated that the group was visiting the plan t to obtain information relat ed to the production of PVC and supporting operations. A list of specific items that EPA wished to discuss was sent to the facility on February 22, 2010 as an enclosure ( Enclosure 1 ) to the letter confirming the site visit. A c op y of

the e nclosure is included in section 5.0 of this memorandum

. EPA was prepared with clarification questions on the section 114 survey response su b mitted by the Shintech facility. EPA inquired if any confidential business information (CBI) would be di scussed or transferred during the visit. Shintech requested that a Shintech employee maintain control of photographic equipment during the plant tour

. No confidential business information was discussed during the meeting.

General Discussion

Shintech prov ided an overview of the facility history and production unit information

. Aerial photos and plant plot plans were made available for viewing by EPA

. The general layout of the plant and plans for plant expansion were discussed

. EPA requested and briefly re viewed a c opy of the facilit y’s air permit

.

Addis Facility

The Addis facility is located north, approximately 8.8 mile s from the Plaquemine facility

. There are 2 PVC production units in Addis. The operational unit is to the west of LA Highway (Hwy) 1. The PVC unit to the east of LA Hwy 1 was idle before the Shintech acquisition of the facility from BCP on March 1, 2002.

Addis rece ives vinyl chloride monomer ( VCM ) feed from Dow Chemical via an underground pipeline. Dow Chemical is located across LA Hwy 1, d ue east from the Addis facility

.Memorandum

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The Addis PVC unit is almost a “carbon c opy” of the Plaquemine PVC unit

. Addis differs from the Plaquemine PVC unit in that the thermal oxidizers (TO ’s ) at Addis do not incinerate any products f rom other (non

- existent) uni ts

.

Plaquemine Facility

The Plaquemine PVC unit began operation in the fall of 2008. The new unit, currently under construction, should begin operation in the 2 nd quarter of 2011

.

The Plaquemine site stores less than 2 tons of chlorine in order to avoid triggering

additional e mergency response requirements

.

Process Description

VCM is transferred from the VCM unit to VCM spheres. Each sphere has a capacity of 1.1 million gallons.

VCM , initiators, inhibitors, and water are charged to the PVC reactors

. Pla quemine has 4 reactors running at 65

- 85% conversion

. Residual vinyl chloride monomer (RVCM) i s removed by 2 steam stripping columns. The p lant operating permit requires a RVCM level of less tha n 27 parts per million (ppm)

. Recovered VCM from the reactors a nd strippers is transferred to 2 floating roof gas holders.

Moisture is removed from the stripped slurry by processing it through 2 centrifuge units.

Residual moisture after the ce ntrifuges is approximately 20%

. Remaining moisture is

removed in fluidized b ed dryers. Moisture content after the dryers is approximately

0.08%

. Product resin is pneumatically conveyed to product silos. The product silos are outfitted with bag house fil ters for particulate matter ( PM ) control

.

Gas Holders

The facility has 2 gas h old e rs, a “ large ” and a “ small ” gas holder. The “large” unit is used to recycle VCM back to the process

. About 99.99% of VCM fed to the PVC unit is converted. The remaining 0.01% of VCM and other non

- condensable gases (NCG’s) are

transferred to the “ small ” gas holder for eve ntual incineration in the TO’s

. Following the small gas holder are two carbon adsorption units that help recover VCM. Shintech does not claim the adsorbers as “control” equipment because they can operate the facility without them. How ever, EPA stated that the adsorbers should be considered control equipment because they lower VCM emissions

.

Water Chillers

To supply chilled process water

, the PVC unit utilizes 4 water chillers. Each chiller is

rated at 1500 tons.

Thermal OxidizersMemorandum

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The Plaquemine facility shares 2 TO’s with the VCM unit. The TO’s usually run in parallel to handle surges and swings in the process. The TO’s are fitted with low

nitrogen oxide (NOx) burners. The outlets are fitted with hydrogen chloride (HCl)

scrubbers and selective catalytic (SCR) units. Three lines enter the TO units; “wet,” “dry,” and “oxy.” The PVC unit combines with other “wet” lines before entering the TO. The Plaquemine plant does not have a flare.

Boilers

Boilers are located in the utility sectio n of the plant. These boilers are shared between the ethylene dichloride (EDC), VCM, and PVC units. The facility also maintains permitted emergency boilers that are fired by diesel fuel.

Leak D etection an d R epair

Shintech follow s the H azardous Organic N at ional Emissions Standards for Hazardous Air Pollutants (HON ) leak detection and repair (LDAR) plan for both plants

. 3,000 points are monitored on a quarterly basis (every point

, every three months)

. The VCM plant contains 17,000 points. LDAR is performed b y a full tim e contractor for the VCM plant

.

The leak limit is 5 ppm above background. Plant personnel generally repair any leaks above background for saf ety and cost savings reasons

. EPA discussed the Alternative Work Practice (AW P). Shintech expressed int erest , but the

detection limit of 500 ppm is well above the 5 ppm leak limit currently in place

.

Fugitive Emissions

Shintech did not perform any emissions testing at the gas holders. Emissions are determined by using engineering calculations based on the area exposed outside of the

wa ter when the gas holder bell rises

. Emissions are controlled from reactor openings by first reducing the pressure in the reactor. Next, the reactor is purged with nitrogen (which is sent to the TO). A sample is

taken from the top and bottom of the reactor and analyzed in the lab. Snake samples are then taken from the top, mid dle, and bottom of the reactor

.

The PVC relief devices are not routed to a control device or recovery system. Shintech has not had an emergency release sin ce th e 1980’s

.

Emissions Testing

EPA inquired if any “surprises” were had by the Shintech Addis facility during review of testing results. James Bell responded no results were found out of the ordinary. The facility was still waiting for dioxin/furan resu lts

. EPA stated the concern over dioxin/furan levels due to recent law suits and media coverage of Mossville.

The plant expects to have 30 day monitoring results by March 5 th

. Submittal dates were discussed, Addis

– March 15 th , Plaquemine

– April 15 th

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EPA reiterated the ne ed to perform quality assurance (QA) on the data before submittal

. EPA inquired about P revention of Significant Deterioration ( PSD ) requirements for control equipmen t located throughout the plant

.

Wastewat er

Wastewater testing was perfor med by the EPA in 2005 at the Addis facility . The test report was “just” rece ived and no dioxins were found

.

The biological oxygen demand ( BOD ) of the Plaquemine facility is 20 % of the permit

limit. The Addis facility runs at “n on

- detect” BOD levels

.

Abou t 30% of the process water is lost to evaporative cool ing . Each process unit within the Plaquemine plant has separate water cooling units

.

Sta rtup, S hutdown, and M alfunction

No startup, shutdown, malfunction (SSM) plan is required for the PVC unit. SSM pl ans for othe r units are state requirements

. The HON rule applies fo r the VCM plant

.

EPA discussed the recent lawsuit and indicated that the startup and shutdown general provisions in Part 63 were vacated and the PVC MACT rule may include startup and

shutd own provisions specific to the source category.

Observation of Stack Testing

EPA observed stack testing at the Plaquemine facility on March 2 nd , 2010. Three locations were observed; the outlet of the “ small ” gas holder, the inlet to the TO and the exit of

the same TO. EPA returned briefly on March 3 rd , 2010 to observe additional stack testing.

EPA observed testing at the outlet of the “ small ” gas holder. In an effort to calculate the contribution of the PVC unit to the TO inlet, testing took place on th e small gas holder exit stream before combining with the main he ader run to the TO

. EPA observed the

apparatus set up as we ll as the testing equipment trailer

. EPA observed testing at the inlet of the TO

. Due to the dangers of releasing VCM to the atmosphe re, samples taken at the inlet to the TO were analyzed and then routed back to

the TO for destruction

. EPA observed the sample collection apparatus and the testing equipment trail er for the inlet to the TO

. EPA observed testing at the outlet of the same TO scrubber stack. EPA observed the stack testing equipment trailer for the outlet of the TO

. Because the stack testers did not have the correct concentration of calibration gas available, testing was delayed until Wednesday, March 3 rd

.

Shintech estimated th e total cost of stack testing for the Plaquemine f acility at approximately $300 ,000

. The largest percentage of the total c ost was Fourier transform infrared spectroscopy (FTIR) expenses

.Memorandum

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Facility Tour

On March 2 nd , 2010, EPA was given a driving tour of the entire Plaquemine facility by David Wise. A walking tour of the PVC unit was also conducted. James Bell and Shelita Williams accompanied David Wise and the EPA on the walking tour. On March 3 rd , 2010, James Bell led EPA on a driving tour of the operati onal Shintech Addis facility.

Adjournment and Action Items

Following a lunch break, a wrap

- up meeting was held at approximately 2:00 PM on March 2 nd , 2010 . G eneral discussion abou t the facility and the PVC process followed :

Shintech stated that the com munity holds trust in the company for three major r easons. First, Shintech employ s citizens of the surrounding communities. Shintech also notifies the communities of any emergency or accidental release. Lastly, Shintech makes an effort not only to submit p ermit material to local government offices, but also to major

environmental ad vocacy groups

. David Wise emphasized that Shintech is ready for the MACT to be promulgated to

remove uncertai nty in operating permit limits

.

The stat e of PVC markets was discusse d

. Currently 70% of PVC produc ed goes to

construction markets

. The domestic market is poor and d omestic producers are exporting

to countries like China and India

. PVC is a cyclic business due to the c ommodity nature of the product

. Recent earthquakes have yet to create effects on PVC markets , however; during reconstruction, the PVC indust ry will likely see improvement

. Older cities are also looking to improve or replace water and wastewater service equipment. This may also provide improvement for the PVC ma rket

.

At 3:00 PM, the stack testers had not obtained the correct calibration gas. EPA stated they may return on March 3, 2010 to observe the testing

. Shintech representatives stated that the information discussed during the meeting was not considered CBI. EPA adjourned the meeting by indicating an additional 114 letter may be sent in an effort to fill any data gaps or answer additional questions that EPA may have.Memorandum

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5.0 Attachment

Enclosure 1

“Summary of Polyvinyl Chloride Production Information of Interest”

Sent to Facility on February 22, 2010Memorandum

p. 8 of 9

Enclosure 1

Summary of Polyvinyl Chloride Production Information of Interest

To assist in the collection of information during the requested site visit, an outline of discussion topics is provided below. This ou tline is provided as a guide. Please feel free to change the order based on the availability of appropriate plant personnel and complexity of the process, its controls, and applicable regulatory requirements.

I. Polyvinyl Chloride Production Overview

a. Short history of facility

b. Overall production capacity of facility and each process unit

c. Type(s) and grade of resin(s) produced

d. Key equipment and unique characteristics of facility

e. Unique characteristics of facility and process compared to other facilities in th e industry

f. Co

- located facilities

II. Polyvinyl Chloride Production Lines

a. Description of units (e.g., types of units, capacity)

b. Description of control devices (e.g., flares, thermal oxidizers)

c. Discussion of applicable emission limits, and monitoring requiremen ts for:

i. PM

ii. SO

x iii. NO

x iv. CO

v. Other (e.g. HAP, VCM)

d. Summary of recent source test data (if applicable)

e. Summary of monitoring capital and operating costs (if available)

f. Key differences between production lines/process units (if more than one)

a. Discussion of key factors that may or may not influence emissions

III. Combustion Sources

a. Description of units (e.g., capacity, operating frequency)

b. Are units subject to NSPS or MACT? If so, which ones and when did they become subject?

c. Discussion of applicable emission limit s, and monitoring requirements for:

i. PM

ii. SO

x iii. NO

x iv. CO

v. other

d. Summary of recent source test data (if applicable)

e. Summary of monitoring capital and operating costs (if available)Memorandum

p. 9 of 9

IV. Insignificant, Unpermitted, and Uncontrolled Air Emission Sources

a. What insignif

icant, unpermitted, or uncontrolled air emission sources are at this facility?

b. What criteria pollutants and HAP are generated and/or emitted by these sources?

c. Are these emissions monitored or quantified?

d. Summary of monitoring capital and operating costs (i f available)

V. Leak Detection and Repair Program for Fugitive Equipment Leaks

a. Overview of leak detection and repair (LDAR) program

i. Is an integrated LDAR program used?

ii. If so, provide number of components, leak definitions, and monitoring frequencies used

b. Is monitoring done in

- house or by a contractor?

c. What type of monitoring method is used during LDAR surveys?

d. Are repairs performed in

- house or by a contractor?

e. Typical annual LDAR monitoring costs?

VI. Start

- up, Shutdown, and Malfunctions

a. How often do you ha ve start

- up and/or shutdown events?

b. Do you keep a log of start

- up and/or shutdown events?

c. How often do malfunction events occur at your facility?

d. What types of malfunction events occur?

e. Do you keep a log of malfunction events?

VII. Plant Tour

a. Priority items t o be observed during tour include:

i. Production Lines

ii. Control Equipment

b. Insignificant, unpermitted, and uncontrolled air emission sources