MEMORANDUM

TO: Jodi Howard, US EPA/SPPD/CCG

FROM: Philip Crawford and Colin Hayes, ERG

DATE: April 12, 2010

SUBJECT: Summary 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, tours of the polyvinyl 

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

facility. The visits 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 70710
Memorandum

p. 2 of 9

3.0 Attendees 

Name Affiliation 

James S. Bell Shintech / Environmental Supervisor

David Wise Shintech / Plant Manager

Paul 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 Crawford ERG

4.0 Summary of Visit 

The meeting with Shintech representatives began at approximately 8:00 AM. A

summary of the meeting’s discussion follows.

The meeting began with individual introductions. EPA indicated that the group was 

visiting the plant to obtain information related 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 copy of 

the enclosure is included in section 5.0 of this memorandum. EPA was prepared with 

clarification questions on the section 114 survey response submitted by the Shintech facility.

EPA inquired if any confidential business information (CBI) would be discussed 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 provided 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 reviewed a copy of the facility’s air permit.

Addis Facility

The Addis facility is located north, approximately 8.8 miles 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 receives vinyl chloride monomer (VCM) feed from Dow Chemical via an 

underground pipeline. Dow Chemical is located across LA Hwy 1, due east from the 

Addis facility.
Memorandum

p. 3 of 9

The Addis PVC unit is almost a “carbon copy” 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 from other (non-existent) units.

Plaquemine Facility 

The Plaquemine PVC unit began operation in the fall of 2008. The new unit, currently 

under construction, should begin operation in the 2nd quarter of 2011.

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

additional emergency 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. Plaquemine has 4 

reactors running at 65-85% conversion.

Residual vinyl chloride monomer (RVCM) is removed by 2 steam stripping columns.

The plant operating permit requires a RVCM level of less than 27 parts per million 

(ppm). Recovered VCM from the reactors and 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 centrifuges is approximately 20%. Remaining moisture is 

removed in fluidized bed 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 filters for particulate matter (PM) control.

Gas Holders

The facility has 2 gas holders, 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 eventual 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. However, 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 Oxidizers
Memorandum

p. 4 of 9

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 lownitrogen 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 section 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 Detection and Repair

Shintech follows the Hazardous Organic National 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 by a full time contractor for the 

VCM plant.

The leak limit is 5 ppm above background. Plant personnel generally repair any leaks

above background for safety and cost savings reasons.

EPA discussed the Alternative Work Practice (AWP). Shintech expressed interest, 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 

water 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, middle, 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 since the 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 results. 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 5th. Submittal dates were 

discussed, Addis – March 15th, Plaquemine – April 15th.
Memorandum

p. 5 of 9

EPA reiterated the need to perform quality assurance (QA) on the data before submittal.

EPA inquired about Prevention of Significant Deterioration (PSD) requirements for 

control equipment located throughout the plant.

Wastewater

Wastewater testing was performed by the EPA in 2005 at the Addis facility. The test 

report was “just” received 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 “non-detect” BOD levels.

About 30% of the process water is lost to evaporative cooling. Each process unit within 

the Plaquemine plant has separate water cooling units.

Startup, Shutdown, and Malfunction

No startup, shutdown, malfunction (SSM) plan is required for the PVC unit. SSM plans 

for other units are state requirements.

The HON rule applies for 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 

shutdown provisions specific to the source category.

Observation of Stack Testing

EPA observed stack testing at the Plaquemine facility on March 2nd, 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 3rd, 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 the small gas holder 

exit stream before combining with the main header run to the TO. EPA observed the 

apparatus set up as well as the testing equipment trailer.

EPA observed testing at the inlet of the TO. Due to the dangers of releasing VCM to the 

atmosphere, 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 trailer 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 3rd.

Shintech estimated the total cost of stack testing for the Plaquemine facility at 

approximately $300,000. The largest percentage of the total cost was Fourier transform 

infrared spectroscopy (FTIR) expenses.
Memorandum

p. 6 of 9

Facility Tour

On March 2nd, 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 3rd, 2010, James 

Bell led EPA on a driving tour of the operational Shintech Addis facility. 

Adjournment and Action Items

Following a lunch break, a wrap-up meeting was held at approximately 2:00 PM on 

March 2nd, 2010. General discussion about the facility and the PVC process followed:

Shintech stated that the community holds trust in the company for three major reasons. 

First, Shintech employs 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 permit material to local government offices, but also to major 

environmental advocacy groups.

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

remove uncertainty in operating permit limits.

The state of PVC markets was discussed. Currently 70% of PVC produced goes to 

construction markets. The domestic market is poor and domestic producers are exporting 

to countries like China and India. PVC is a cyclic business due to the commodity nature 

of the product. Recent earthquakes have yet to create effects on PVC markets, however;

during reconstruction, the PVC industry 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 market.

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

p. 7 of 9

5.0 Attachment

Enclosure 1

“Summary of Polyvinyl Chloride Production Information of Interest”

Sent to Facility on February 22, 2010
Memorandum

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 outline 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 the 

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 requirements for:

i. PM 

ii. SOx

iii. NOx 

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 limits, and monitoring requirements for:

i. PM 

ii. SOx

iii. NOx 

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 insignificant, 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 (if 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 have 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 to be observed during tour include:

i. Production Lines

ii. Control Equipment

b. Insignificant, unpermitted, and uncontrolled air emission sources