The Vinyl Institute has tracked EDC and VCM emissions per tonne of PVC produced for many years. We provided this data to the Task Group in our original April 2, 2004 data submittal. Although the emissions factor reported by VI are slightly higher than those calculated by the Task Group, we believe this data more accurately reflects the industry’s total performance than the calculations completed by the Task Group on only three facilities. We assume that the Task Group was focusing on three facilities in an attempt to isolate their analysis to facilities that only produce EDC, VCM and PVC as discussed in the dioxin TRI question. While in one sense this is logically sound, in another it introduces another source of error. Technologies used in the manufacture of EDC and VCM as well as technologies for isolation and destruction of side products differ significantly among facilities. Reducing the number of plants has the effect of isolating a given technology rather than identifying emission factors that could be generalized. The three facilities the Task Group used may have different product mixes that can alter emission factors for their individual PVC facilities from industry averages. Also, one of the facilities selected represents an EDC/VCM plant only and the other two plants represents EDC/ VCM and PVC production. As PVC plants represents the larger portion of VCM emissions, averaging EDC/VCM/PVC with EDC/VCM only facilities would not be appropriate. As indicated below, the averaging of these facilities would be more representative for an EDC emission factor as EDC is emitted from the EDC/VCM process only and not the PVC process.

The VI has aggregated and reported on emission of EDC and VCM per unit of PVC production since TRI reporting started in 1988. This information has been provided to the USGBC Task Group in our "Performance Report for the Vinyl Industry". The VI has used publically available data from SPI and later APC for the PVC production data. As VI membership has changed over this time period, the VI has reported numbers based on total EDC and VC released to the air reported in TRI and also TRI data reported by major PVC and EDC producers that represented better than 95% of the US capacity which were members of VI at any point in time. This data has shown continuous improvement since 1988. We believe these emission factors to be more representative of the industry than the numbers calculated by the Task Group

Based on 2002 TRI EDC and VCM data reported as released to air and an reported North American production of 6451 thousand metric tons of PVC, the emission factor for EDC would be 18 g/metric tonne of PVC and the emission factor for VCM is 46 grams/metric tonne of PVC. According to this TRI data the emissions factor for VCM has been reduced by 70 percent since 1988 and the emissions factor for EDC has been reduced by 94 percent.

We understand that the Task Group might want data directly from TRI. Attached is a spreadsheet for EDC and VCM directly from TRI. Calculated emissions factors for 2003 are 39.5 grams of VCM/tonne of PVC and 14.5 grams of EDC/tonne of PVC. Spreadsheets are provided for posting.

See our response to Dioxin EF for comments on some of the shortcomings of TRI as a data source for this type of analysis.