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<pubnumber>310R97006</pubnumber>

<title>Profile of the Plastic Resin and Man-Made Fiber Industry:  Sector Notebook</title>

<pages>192</pages>

<pubyear>1997</pubyear>

<provider>NEPIS</provider>

<access>online</access>

<operator>BO</operator>

<scandate>03/04/98</scandate>

<origin>hardcopy</origin>

<type>single page tiff</type>

<keyword>manmade fiber plastic resin notebook sector fibers september project industry polymerization epa resins process facilities polymer sic chemical chemicals tri</keyword>



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NOTEBOOKS

 image: 

















                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                WASHINGTON, D.C. 20460

                                           f 8

                                                                         THE ADMINISTRATOR



Message from the Administrator



Since EPA's founding over 25 years ago, our nation has made tremendous progress in protecting

public health and our environment while promoting economic prosperity. Businesses as large as

iron and steel plants and those as small as the dry cleaner on the corner have worked with EPA to

find ways to operate cleaner, cheaper and smarter. As a result, we no longer have rivers catching

fire. Our skies are clearer. American environmental technology and expertise are in demand

around the world.



The Clinton Administration recognizes that to continue this progress, we must move beyond the

pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the

future. Industry by industry and community by community, we must build a new generation of

environmental protection.



The Environmental Protection Agency has undertaken its Sector Notebook Project to compile,

for major industries, information about environmental problems and solutions, case studies and

tips about complying with regulations. We called on industry leaders, state regulators, and EPA

staff with many years of experience in these industries and with their unique environmental issues.

Together with an extensive series covering other industries, the notebook you hold in your hand is

the result.



These notebooks will help business managers to understand better their regulatory requirements,

and learn more about how others in their industry have achieved regulatory compliance and the

innovative methods some have found to prevent pollution in the first instance. These notebooks

will give useful information to state regulatory agencies moving toward industry-based programs.

Across EPA we will use this manual to better integrate our programs and improve our compliance

assistance efforts.



I encourage you to use this notebook to  evaluate and improve the way that we together achieve

our important environmental protection goals.  I am confident that these notebooks will help us to

move forward in ensuring that — in industry after industry, community after community —

environmental protection and economic prosperity go haj>4 in hand.

                                               Carol M. Browner,

            R«cycl*d/R«cyclabl« * Printed with Vegetable Oil Based Inks on 100% Recycled Paper (40% Postconsumer)

 image: 

















Plastic Resin and Manmade Fiber

Sector Notebook Project

                                                             EPA/310/R-97/006

         EPA Office of Compliance Sector Notebook Project:

  Profile of the Plastic Resin and Manmade Fiber Industries

                               September 1997

                              Office of Compliance

                   Office of Enforcement and Compliance Assurance

                       U.S. Environmental Protection Agency

                                401 M St., SW

                             Washington, DC 20460

                            For sale by the U.S. Government Printing Office

                     Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328

                                ISBN 0-16-049398-6

 image: 

















 Plastic Resin and Manmade Fiber

Sector Notebook Project

 This report is one in a series of volumes published by the U.S. Environmental Protection Agency

 (EPA) to provide information of general interest regarding environmental issues associated with

 specific industrial sectors. The documents were developed under contract by Abt Associates

 (Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-

 Allen & Hamilton, Inc. (McLean, VA). This publication may be purchased from the

 Superintendent of Documents, U.S. Government Printing Office.  A listing of available Sector

 Notebooks and document numbers is included at the end of this document.



 AH telephone orders should be directed to:



       Superintendent of Documents

       U.S. Government Printing Office

       Washington, DC 20402

       (202)512-1800

       FAX (202) 512-2250

       8:00 a.m. to 4:30 p.m., EST, M-F

Using the form provided at the end of this document, all mail orders should be directed to:



       U.S. Government Printing Office

       P.O. Box 371954

       Pittsburgh, PA 15250-7954

Complimentary volumes are available to certain groups or subscribers, such as public and

academic libraries, Federal, State, and local governments, and the media from EPA's National

Center for Environmental Publications and Information at (800) 490-9198. For further

information, and for answers to questions pertaining to these  documents, please refer to the

contact names and numbers provided within this volume.

Electronic versions of all Sector Notebooks are available via Internet on the Enviro$en$e World

Wide Web. Downloading procedures are described in Appendix A of this document.

Cover photograph by Steve Delaney, U.S. EPA. Photograph courtesy of Vista Chemicals,

Baltimore, Maryland. Special thanks to Dave Mahler.

Sector Notebook Project

        September 1997

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Plastic Resin and Manmade Fiber

                                                          Sector Notebook Project

                                 Sector Notebook Contacts

The Sector Notebooks were developed by the EPA's Office of Compliance. Questions relating to

the Sector Notebook Project can be directed to:



Seth Heminway, Coordinator,  Sector Notebook Project

US EPA Office of Compliance

401 M St., SW (2223-A)

Washington, DC  20460

(202) 564-7017



Questions and comments regarding the individual documents can be directed to the appropriate

specialists listed below.

Document Number

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-



EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

EPA/310-

R-95-001.

.R-95-002.

•R-95-003.

•R-95-004.

•R-95-005.

•R-95-006.

•R-95-007.

•R-95-008.

•R-95-009.

•R-95-010.

-R-95-011.

•R-95-012.

-R-95-013.

•R-95-014.

•R-95-015.

•R-95-016.

•R-95-017.

•R-95-018.



-R-97-001.

-R-97-002.

-R-97-003.

.R.97-004.

-R-97-005.

-R-97-006.

-R-97-007.

-R-97-008.

•R-97-009.

•R-97-010.

            Industry



 Dry Cleaning Industry

 Electronics and Computer Industry

 Wood Furniture and Fixtures Industry

 Inorganic Chemical Industry

 Iron and Steel Industry

 Lumber and Wood Products Industry

 Fabricated Metal Products Industry

 Metal Mining Industry

 Motor Vehicle Assembly Industry

 Nonferrous Metals Industry

 Non-Fuel, Non-Metal Mining Industry

 Organic Chemical Industry

-Petroleum Refining Industry

 Printing Industry

 Pulp and Paper Industry

 Rubber and Plastic Industry

 Stone, Clay, Glass, and Concrete Industry

 Transportation Equipment Cleaning Ind.



 Air Transportation Industry

 Ground Transportation Industry

 Water Transportation Industry

 Metal Casting Industry

 Pharmaceuticals Industry

 Plastic Resin and Manmade Fiber Ind.

 Fossil Fuel Electric Power Generation Ind.

 Shipbuilding and Repair Industry

 Textile Industry

 Sector Notebook Data Refresh, 1997

   Contact



Joyce Chandler

Steve Hoover

Bob Marshall

Walter DeRieux

Maria Malave

Seth Heminway

Scott Throwe

Jane Engert

Anthony Raia

Jane Engert

Robert Lischinsky

Walter DeRieux

Tom Ripp

Ginger Gotliffe

Maria Eisemann

Maria Malave

Scott Throwe

Virginia Lathrop

Phone (202)



  564-7073

  564-7007

  564-7021

  564-7067

  564-7027

  564-7017

  564-7013

  564-5021

  564-6045

  564-5021

  564-2628

  564-7067

  564-7003

  564-7072

  564-7016

  564-7027

  564-7013

  564-7057

Virginia Lathrop

Virginia Lathrop

Virginia Lathrop

Jane Engert

Emily Chow

Sally Sasnett

Rafael Sanchez

Anthony Raia

Belinda Breidenbach

Seth Heminway

  564-7057

  564-7057

  564-7057

  564-5021

  564-7071

  564-7074

  564-7028

  564-6045

  564-7022

  564-7017

 Sector Notebook Project

                                    111

                                                       September 1997

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Page iv intentionally left blank.

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Plastic Resin and Manmade Fiber

                    Sector Notebook Project

              PLASTIC RESIN AND MANMADE FIBER INDUSTRIES

                             (SIC 2821, 2823, and 2824)



                              TABLE OF CONTENTS

LIST OF FIGURES	vii



LIST OF TABLES	 viii



LIST OF ACRONYMS	 ix



I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1

      A. Summary of the Sector Notebook Project	1

      B. Additional Information	2



II. INTRODUCTION TO THE PLASTIC RESIN AND MANMADE FIBER INDUSTRIES . . 3

      A. History of the Plastic Resin and Manmade Fiber Industries	3

      B. Introduction, Background, and Scope of the Notebook	6

      C. Characterization of the Plastic Resin and Manmade Fiber Industries	9

             1. Product Characterization  	9

             2. Industry Characterization	13

             3. Economic Outlook	18



III. INDUSTRIAL PROCESS DESCRIPTION  	23

      A. Industrial Processes in the Plastic Resins and Manmade Fibers Industries	23

             1. Preparing Reactants 	24

             2. Polymerization	25

             3. Polymer Recovery  	36

             4. Polymer Extrusion  	37

             5. Supporting Operations	37

      B. Industrial Processes Specific to the Manmade Fiber Industry	41

             1. Polymerization	41

             2. Spinning	42

             3. Fiber Processing	47

             4. Supporting Operations	49

      C. Raw Material Inputs and Pollution Outputs in the Production Line 	50

      D. Pollution Control Systems	56

      E. Management of Chemicals in the Production Process	58



IV. CHEMICAL RELEASE AND TRANSFER PROFILE	63

      A. EPA Toxic Release Inventory for the Plastic Resin and Manmade Fiber Industries  . . 66

      B. Summary of Selected Chemicals Released	93

      C. Other Data Sources	97

      D. Comparison of Toxic Release Inventory Between Selected Industries  	99

Sector Notebook Project

v

September 1997

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Plastic Resin and Manmade Fiber

                   Sector Notebook Project

V, POLLUTION PREVENTION OPPORTUNITIES	103



VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS  	127

      A. General Description of Major Statutes	127

      B. Industry Specific Requirements	139

      C. Pending and Proposed Regulatory Requirements	144



VII, COMPLIANCE AND ENFORCEMENT PROFILE 	145

      A. Plastic Resin and Manmade Fiber Industries Compliance History	150

      B. Comparison of Enforcement Activity Between Selected Industries	152

      C. Review of Major Legal Actions	157

             1. Review of Major Cases	157

             2. Supplementary Environmental Projects (SEPs)	158



VIE. COMPLIANCE ACTIVITIES AND INITIATIVES	159

      A. Sector-Related Environmental Programs and Activities	159

      B. EPA Voluntary Programs  	159

      C. Trade Association/Industry Sponsored Activity	167

             1. Environmental Programs	167

             2. Summary of Trade Associations.	168



IX. CONTACTS/ACKNOWLEDGMENTS/REFERENCES 	173



Appendix A: Instructions for downloading this notebook	A-l

Sector Notebook Project

VI

September 1997

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Plastic Resin and Manmade Fiber

                     Sector Notebook Project

                                  LIST OF FIGURES



Figure 1: Plastic Resins: From raw material to finished product	7

Figure 2: U.S. Manmade Fiber Industry: Principal raw materials, producer types, major

       products, and principal end uses	8

Figure 3: Percentage Distribution of Plastic Resins: Sales and Captive Use, 1994	10

Figure 4: U.S. Fiber Consumption: Percentage distribution by principal fibers, 1993  	12

Figure 5: Geographic Distribution of Plastic Resin (SIC 2821) and Manmade Fiber (SIC 2823,

       2824) Manufacturing Facilities	16

Figure 6: U.S. Production of Selected Resins, in millions of pounds	18

Figure 7: Manmade Fiber Production Data for Selected Fibers 1970-1995	20

Figure 8: Gas-Phase Fluid-Bed Reactor for Production of Polyethylene	27

Figure 9: Typical Loop Reactor for Production of Polyethylene	28

Figure 10: High-Density Polyethylene Process Flow Diagram  	31

Figure 11: Fluid Reactors Used for Making Polypropylene	  32

Figure 12: Typical Process Flow Diagram for Suspension Polymerization of PVC	34

Figure 13: Typical Pneumatic Conveying System in a Pellet Blending Operation 	40

Figure 14: General Process Diagram for Melt, Dry, and Wet Spun Synthetic Fibers	43

Figure 15: Typical Process Flowchart for Synthesis of Rayon Fibers  	46

Figure 16: Potential Emissions from Plastic Resin Manufacturing Operations	52

Figure 17: VOC Emissions from Fiber Processing Operations  	54

Figure 18: Summary of TRI Releases and Transfers by Industry	100

Sector Notebook Project

vu

September 1997

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 Plastic Resin and Manmade Fiber

                      Sector Notebook Project

                                   LIST OF TABLES



 Table 1: Introduction of Selected Plastic Resins and Manmade Fibers  .	3

 Table 2: Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers  	9

 Table 3: Manmade Fibers	11

 Table 4: Size and Revenue for the Plastic Resin and Manmade Fiber Industries  	13

 Table 5: Establishment Size and Geographic Distribution of the Plastic Resin and

        Manmade Fiber Industries	14

 Table 6: Top U.S. Companies in the Plastic Resin and Manmade Fiber Industries	17

 Table 7: General Polymerization Parameters for Selected Polymers	30

 Table 8: Typical Fiber Spinning Parameters for Selected Fibers	44

 Table 9: Summary of Potential Releases Emitted During Plastic Resin and Manmade Fiber

       Manufacturing	51

 Table 10: Source Reduction and Recycling Activity for the Plastic Resin Industry	59

 Table 11: Source Reduction and Recycling Activity for the Manmade Fiber Industry	61

 Table 12: 1995 TRI Releases for Plastic Resin Manufacturing Facilities (SIC 2821)	70

 Table 13: 1995 TRI Transfers for Plastic Resin Manufacturing Facilities  	76

 Table 14: 1995 TRI Releases for Manmade Fiber Manufacturing Facilities	82

 Table 15: 1995 TRI Transfers for Manmade Fiber Manufacturing Facilities	86

 Table 16: Top 10 TRI Releasing Plastic Resin Manufacturing Facilities	91

 Table 17: Top 10 TRI Releasing Facilities Reporting Plastic Resin Manufacturing SIC

        Codes to TRI	91

 Table 18: Top 10 TRI Releasing Manmade Fiber Manufacturing Facilities	92

 Table 19: Top 10 TRI Releasing Facilities Reporting Manmade Fiber Manufacturing SIC

        Codes to TRI  	92

 Table 20: Air Pollutant Releases by Industry Sector	98

 Table 21: Toxics Release Inventory Data for Selected Industries	101

 Table 22: Process/Product Modifications Create Pollution Prevention Opportunities	Ill

 Table 23: Modifications to Equipment Can Also Prevent Pollution	120

 Table 24: Five-Year Enforcement and Compliance Summary for the Plastic Resin and Manmade

      Fiber Industries  	151

 Table 25: Five-Year Enforcement and Compliance Summary for Selected Industries	153

 Table 26: One-Year Enforcement and Compliance Summary for Selected Industries	154

 Table 27: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries  155

 Table 28: One-Year Inspection and Enforcement Summary by Statute for Selected Industries  156

 Table 29: Plastic Resin and Manmade Fiber Industries Participation in the 33/50 Program ...  160

Sector Notebook Project

Vlll

September 1997

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Plastic Resin and Manmade Fiber

                    Sector Notebook Project

                               LIST OF ACRONYMS



AFS -       AIRS Facility Subsystem (CAA database)

AIRS -      Aerometric Information Retrieval System (CAA database)

BIFs -      Boilers and Industrial Furnaces (RCRA)

BOD -      Biochemical Oxygen Demand

CAA-      Clean Air Act

CAAA-     Clean Air Act Amendments of 1990

CERCLA -  Comprehensive Environmental Response, Compensation and Liability Act

CERCLIS -  CERCLA Information System

CFCs -      Chlorofluorocarbons

CO -        Carbon Monoxide   ,

COD -      Chemical Oxygen Demand

CSI -       Common Sense Initiative

CWA -      Clean Water Act

D&B -      Dun and Bradstreet Marketing Index

ELP -       Environmental Leadership Program

EPA -      United  States Environmental Protection Agency

EPCRA -   Emergency Planning and Community Right-to-Know Act

FIFRA -     Federal Insecticide, Fungicide, and Rodenticide Act

FINDS -    Facility Indexing System

HAPs-      Hazardous Air Pollutants (CAA)

HSDB -     Hazardous Substances Data Bank

IDEA -      Integrated Data for Enforcement Analysis

LDR -      Land Disposal Restrictions (RCRA)

LEPCs -    Local Emergency Planning Committees

MACT -    Maximum Achievable Control Technology (CAA)

MCLGs -   Maximum Contaminant Level Goals

MCLs -     Maximum Contaminant Levels

MEK -      Methyl Ethyl Ketone

MSDSs -    Material Safety Data Sheets

NAAQS -   National Ambient Air Quality Standards (CAA)

NAFTA -   North American Free Trade Agreement

NAICS -    North American Industrial Classification  System

NCDB -     National Compliance Database (for TSCA, FIFRA, EPCRA)

NCP -      National Oil and Hazardous Substances Pollution Contingency Plan

NEIC -      National Enforcement Investigation Center

NESHAP -  National Emission Standards for Hazardous Air Pollutants

NO2 -       Nitrogen Dioxide

,NOV-      Notice  of Violation

NOX -       Nitrogen Oxides

NPDES -   National Pollution Discharge Elimination System (CWA)

NPL -      National Priorities List

NRC -      National Response Center

NSPS -      New Source Performance Standards (CAA)

 Sector Notebook Project

IX

September 1997

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 Plastic Resin and Manmade Fiber

Sector Notebook Project

 OAR -      Office of Air and Radiation

 OECA -     Office of Enforcement and Compliance Assurance

 OPA -      Oil Pollution Act

 OPPTS -    Office of Prevention, Pesticides, and Toxic Substances

 OSHA -     Occupational Safety and Health Administration

 OSW -      Office of Solid Waste

 OSWER -   Office of Solid Waste and Emergency Response

 OW -      Office of Water

 P2 -        Pollution Prevention

 PCS -      Permit Compliance System (CWA Database)

 POTW -     Publicly Owned Treatments Works

 RCRA -     Resource Conservation and Recovery Act

 RCRIS -    RCRA Information System

 SARA -     Superfund Amendments and Reauthorization Act

 SDWA -    Safe Drinking Water Act

 SEPs -      Supplementary Environmental Projects

 SERCs -     State Emergency Response Commissions

 SIC -       Standard Industrial Classification

 S02 -       Sulfur Dioxide

 SOX -       Sulfur Oxides

 SPI -       Society of Plastics Industry

 TOC -      Total Organic Carbon

 TRI -       Toxic Release Inventory

 TRIS -      Toxic Release Inventory System

 TCRIS -     Toxic Chemical Release Inventory System

 TSCA -     Toxic Substances Control Act

 TSS  -       Total Suspended Solids

 UIC  -       Underground Injection Control (SDWA)

 UST -      Underground Storage Tanks (RCRA)

 VOCs -     Volatile Organic Compounds

Sector Notebook Project

        September 1997

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Plastic Resin and Manmade Fiber

                     Sector Notebook Project

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT



LA. Summary of the Sector Notebook Project



                     Integrated environmental policies based upon comprehensive analysis of air,

                     water and land pollution are a logical supplement to traditional single-media

                     approaches to environmental protection.  Environmental regulatory agencies

                     are beginning to embrace comprehensive, multi-statute solutions to facility

                     permitting,  enforcement and compliance assurance, education/ outreach,

                     research, and regulatory development issues. The central concepts driving the

                     new policy direction are that pollutant releases to each environmental medium

                     (air, water and land) affect each other, and that environmental strategies must

                     actively identify and address these inter-relationships by designing policies for

                     the "whole" facility. One way to achieve a whole facility focus is to design

                     environmental policies  for  similar  industrial facilities.   By doing so,

                     environmental concerns  that are common to the manufacturing of similar

                     products can be addressed  in a comprehensive manner. Recognition of the

                     need to develop the industrial "sector-based" approach within the EPA Office

                     of Compliance led to the creation of this document.



                     The Sector Notebook Project was originally initiated by  the Office of

                     Compliance within the Office of Enforcement and Compliance Assurance

                     (OECA) to provide its staff and managers with summary information for

                     eighteen specific industrial sectors. As other EPA offices, states, the regulated

                     community, environmental  groups, and the public became interested in this

                     project, the scope of the original project was expanded to its current form.

                     The ability to design comprehensive, common sense environmental protection

                     measures for specific industries is dependent on knowledge of several inter-

                     related topics. For the purposes of this project, the key elements chosen for

                     inclusion are:  general industry information (economic and geographic); a

                     description of industrial  processes; pollution  outputs; pollution prevention

                     opportunities;  Federal  statutory  and regulatory framework;  compliance

                     history; and  a description of partnerships that have been formed between

                     regulatory agencies, the regulated community and the public.



                     For any given industry, each topic listed  above could alone be the subject of

                     a lengthy volume. However, in order to produce a manageable document, this

                     project focuses on providing summary information for each topic.  This

                     format provides the reader with a synopsis of each issue, and references where

                     more  in-depth  information is available.   Text within  each  profile  was

                     researched from a variety of sources, and was usually condensed from more

                     detailed sources pertaining to specific topics. This approach allows for a wide

                     coverage of activities that can be further explored based upon the citations

                     and references listed at the end of this profile.  As a check  on the information

                     included, each notebook went through an external review process.  The Office

                     of Compliance appreciates the efforts of all those  that participated in this

Sector Notebook Project

1

September 1997

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Plastic Resin and Manmade Fiber

Sector Notebook Project

                     process and enabled us to develop more complete, accurate and up-to-date

                     summaries. Many of those who reviewed this notebook are listed as contacts

                     in Section IX and may be sources of additional information.  The individuals

                     and groups on this list do not necessarily concur with all statements within this

                     notebook.



I.B. Additional Information

Providing Comments

                     OECA's Office of Compliance plans to periodically review and update the

                     notebooks and will make these updates available  both in hard copy and

                     electronically.  If you have any comments on the existing notebook, or if you

                     would like to provide additional information, please send a hard copy and

                     computer disk to the EPA Office of Compliance, Sector Notebook Project,

                     401 M St., SW (2223-A), Washington, DC 20460.  Comments can also be

                     uploaded to the Enviro$en$e World Wide Web for general access to all users

                     of the system. Follow instructions in Appendix A for accessing this system.

                     Once you have logged in, procedures for uploading text are available from the

                     on-line Enviro$en$e Help System.

Adapting Notebooks to Particular Needs

                     The scope of the industry sector described in this notebook approximates the

                     national occurrence of facility types within the sector.  In many instances,

                     industries within specific geographic regions or states may have unique

                     characteristics that are not fully captured in these profiles.  The Office of

                     Compliance encourages  state and local environmental  agencies and other

                     groups to supplement or re-package the information included in this notebook

                     to include more specific  industrial and regulatory information that may be

                     available.  Additionally, interested states may want to supplement  the

                     "Summary of Applicable Federal Statutes and Regulations" section with state

                     and local requirements.   Compliance or technical assistance providers may

                     also want to develop the "Pollution Prevention" section in more detail.  Please

                     contact the appropriate specialist listed on the opening page of this notebook

                     if your office is interested in assisting us in the further development of the

                     information or policies addressed within this volume.  If you are interested in

                     assisting in the development of  new notebooks for sectors not already

                     covered, please contact the Office of Compliance at 202-564-2395.

Sector Notebook Project

         September 1997

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Plastic Resin and Manmade Fiber

                                                         Introduction

II. INTRODUCTION TO THE PLASTIC RESIN AND MANMADE FIBER INDUSTRIES



                      This  section  provides background information  on the  size, geographic

                      distribution, employment, production, sales, and economic condition of the

                      plastic resin and manmade fiber industries.  Facilities described within this

                      document are described in terms of their Standard Industrial Classification

                      (SIC) codes.



H.A. History of the Plastic Resin and Manmade Fiber Industries



        The Origin of Plastic Resins



                      Plastics today are one of the  most used materials  in U.S.  industrial and

                      commercial life.  Table 1 lists selected plastic resins  and synthetic fibers by

                      year of development and their principal uses. The first plastics were invented

                      in the  1800s when people experimented to produce everyday objects out of

                      alternative materials.   The first plastic was developed in 1851 when hard

                      rubber, or ebonite, was synthesized. This was the first material that involved

                      a distinct chemical modification of a natural material.

                        Table 1: Introduction of Selected Plastic Resins and Manmade Fibers

1868

1900

190$

1927

1927

1936

1938

1939

1942



1952

19/57

1964

197G

1978

1985

                               Cellulose Nitrate

                               Viscose Rayoa

                               Phenol-Ponnaldehyde

                               Cellulose Acetate

                               Polyviayl Chloride

                               Aorylte

                               Polystyrene

                               Nylon

                               Low Density Polyethylene

                               Uosatufated Polyester

                               Polyethylene terephthahte

                               Polypropylene

                               Polyimide

                               tberrooptest&Poly<5$tef

                               Linear Low Density Bolyetl

                               Liquid Crystal Polymers

      Eyeglass frames

      Lining in clothing* curtains

      telephone Handset

      Toothbrushes, lacquer's

      WaU Covering^ pipe,-siding

      Brush Backs* display signs

      Housewares, toys '

      Fibers, films, gears

      Pegging, squeeze bottles

      Boat Huts

      Clothing, fibecSlt

      Safety Helmets

      Bearings

fcne   Extended JSlm

       Electrical/Electronic Parts

                        Source; This table has been adapted from. Pacts and Figures of the U.S. Plastics

                               , {1995 Edition.) prepared annualfy by lhe Society of the Plastics Industry,

                           , Washington DC, Please refer to that document for ^ more complete listing of

                        plastic resin development

 Sector Notebook Project

                                                       September 1997

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 Plastic Resin and Manmade Fiber

   Introduction

                      The first plastics in the U.S. were developed while John Wesley Hyatt was

                      experimenting to produce a billiard ball from materials other than ivory.  In

                      1870, John and his brother Isaiah took out a patent for a process producing

                      a horn-like material using cellulose nitrate and camphor.



                      Another important precursor to modern plastics was the development  of

                      formaldehyde  resins.  Early experiments to produce white chalkboards in

                      Germany around the turn of the 20th century led to the development  of

                      formaldehyde  resins.  These resins were first produced by reacting casein

                      (milk protein) with formaldehyde.



                      During  the  1930s, the  initial  commercial  development of today's major

                      thermoplastics took place.  These included polyvinyl chloride, low density

                      polyethylene, polystyrene, and polymethyl methacrylate. Demand for plastics

                      escalated during World War II when substitutes for scarce natural materials,

                      like rubber,  were in  high demand.   Large-scale  production  for synthetic

                      rubbers triggered extensive research into polymer chemistry and new plastic

                      materials.



                      In the 1940s-, polypropylene and high density polyethylene were developed,

                      and in 1978, linear low density polyethylene was developed.   Large-scale

                      production of these materials reduced their cost substantially, which allowed

                      these new plastics materials to compete with traditional materials like wood

                      and metal.  The introduction of alloys and blends of various polymers has

                      made it possible to  tailor properties to fit certain performance  requirements

                      that a single resin could not provide.   Demand for plastics  has steadily

                      increased, and  now plastics are accepted as basic materials along with the

                      more traditional materials in designs and engineering plans (SPI, 1995).



       Tha Origin of Manmade Fibers



                      In 1664, Robert Hooke first suggested that manmade yarn could be produced.

                      He speculated, mMicrographia, that synthetic fibers could be patterned after

                      the excretion of silk by silkworms.



                            And I have often thought, that probably there might be a way, found  out, to

                           - make an  artificial glutinous composition, much resembling, if not  full as

                            good, nay better, than the Excrement, or whatever other substances it  be out

                            of which, the Silk-worm winds and draws his clew. If such a composition

                            were found, it were certainly an easier matter to find very quick ways of

                            drawing it into small wires for use (Linton, 1966).



                     During the 19th century,  scientists were busy making precursor solutions of

                     the first manmade fibers, cellulosic fibers.  In  1840,  F.  Gottlob Keller of

                     Germany devised  a technique for making pulp for paper by squeezing

                     powdered wood taken from a grindstone.  This enabled the future production

                     of rayon and other cellulosic items. During that same year, Louis Schwabe,

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September 1997

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Plastic Resin and Manmade Fiber

  Introduction

                     an English silk manufacturer, developed the first spinnerette through which a

                     spinning solution could be extruded (Linton, 1966).



                     The first manmade fibers commercially manufactured in the U.S.  were the

                     cellulosics, led by rayon in 1910 and acetate in 1924. Cellulosic fibers are

                     manufactured by first treating cellulose with chemicals, dissolving, and then

                     regenerating the fibers. Cellulose is an abundant naturally occurring organic

                     compound which makes up a large portion of the world'.s vegetable matter.

                     Often referred to as artificial silk, rayon retained many of the same physical

                     properties  as cotton, such as high moisture absorption and subsequent

                     swelling of the fibers. While cellulose acetate was first developed as a plastic

                     in 1865, it was  not successfully spun into a fiber until the  1920s.  The first

                     U.S. acetate production took place at the Cumberland, Maryland plant of

                     British Celanese (now Hoechst Celanese).  -



                     In 1926, Du Pont Laboratories began a chemical research program that led to

                     the advent of the synthetic, or noncellulosic, fiber industry.  Unlike cellulosic

                     fibers, synthetic fibers are wholly compounded  from chemicals.   The first

                     synthetic fiber that Du Pont developed was Fiber 66. Now known  as nylon-

                     6,6, the fiber began widespread production for markets, such as nylon hosiery,

                     in 1939.  During World War II, nylon was used in producing parachutes,

                     uniforms, and a host of other military equipment.  Started primarily as a

                     hosiery yarn, the use of nylon spread after the war into other applications like

                     carpeting and woven fabrics.  •



                     Wrinkle-resistant and strong, the first polyester fiber, Terylene, was developed

                     by a British scientist group called the.Calico Printers Association.  In 1946,

                     Du Pont secured exclusive rights to produce this polyester fiber in the U.S.

                     In December 1950, Du Pont  announced  plans to build  its first plant at

                     Kinston, North Carolina at a capacity of 36 million pounds a year and a cost

                     of $40 million.   Du Pont first  unveiled the new fiber, named Dacron,  at a

                     famous press conference where it was displayed in a swimsuit that had been

                     worn  67 days continuously without ironing. After polyester fibers were first

                     produced commercially in the U.S. in 1953, the  fibers were rapidly used to

                     make men's suits, women's blouses, and men's shirts.



                     Since  then, most technological advances in manmade fibers haye occurred in

                     synthetics, which now make up almost all of the U.S. production of manmade

                     fibers. Synthetic fibers have many advantages to cellulosic fibers, such as

                     controlled shrinkage, crease retention, and wrinkle resistance. Synthetic fibers

                     have developed to seem more natural, softer, easier to care for, more lustrous,

                     and more comfortable.

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September 1997

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 Plastic Resin and Manmade Fiber

   Introduction

 1I.B. Introduction, Background, and Scope of the Notebook

                     This notebook focuses on industrial processes and  environmental issues

                     relevant to the plastic resin and manmade fiber industries. These industries

                     were chosen for this notebook because they have certain industrial processes

                     in common, such  as polymerization and extrusion. Both the plastic resin

                     industry and the manmade fiber industry use refined petroleum products and

                     synthetic organic chemicals to make selected polymers, which are large

                     molecules made up  of simple repeating chemical units. Facilities then process

                     the polymers into plastic pellets and manmade fibers. Figures 1 and 2 provide

                     an overview of the raw material inputs, products, and end uses of plastic resin

                     and manmade fiber.



                     The plastic resin industry is classified  by the Office  of Management and

                     Budget (OMB) as Plastics Materials and  Resins,  Standard  Industrial

                     Classification (SIC) code 2821.  This classification corresponds to SIC codes

                     which were established by the OMB to track the flow of goods and services

                     within the economy. SIC 2821 corresponds  to facilities that manufacture

                     manmade resin, plastic materials, and nonvulcanizable elastomer.  Table 2 lists

                     products that are classified under SIC 2821.  The manmade fiber industry'is

                     made up of two categories: Cellulosic Manmade Fibers,  SIC 2823, and

                     Organic Fibers, Noncellulosic, SIC 2824.  Cellulosic Manmade Fibers includes

                     facilities that make cellulosic fibers, like rayon and cellulose  acetate.  The

                     category, Organic  Fibers, Noncellulosic, covers facilities that make other

                     manmade fiber, including nylon  and polyester.  Manmade fiber products that

                     fall under SIC Codes 2823 and 2824 are listed in Table 3.



                     OMB is in the process of changing the SIC code system to a system based on

                     similar  production processes  called   the  North  American  Industrial

                     Classification System (NAICS). In the NAIC system, the manufacturing of

                     plastic resins, synthetic rubber, artificial and synthetic fibers and filaments are

                     all classified as NAIC 3252. Resin and  synthetic rubber manufacturing are

                     further classified as NAIC 32521, and artificial  and synthetic fibers and

                     filaments manufacturing are further classified as NAIC 32522.



                     Only the manufacturing  of plastic resin and manmade fiber is covered in this

                     notebook. Companies that perform upstream processing, such as synthesizing

                     reactants,  and companies  that perform downstream  operations, such  as

                     processing plastic resins into plastic bottles or processing manmade fibers into

                     fabric, are not covered in this notebook.  For information on companies that

                     manufacture organic chemicals (SIC 286) used  in plastic resin and manmade

                     fiber manufacture,  refer to the Organic  Chemicals Sector Notebook.  For

                     facilities that process resins into plastic products of different shapes, sizes, and

                     physical properties, refer to the Rubber and Plastics Sector Notebook. Refer

                     to the Textiles Sector Notebook for information on facilities that process

                     manmade fibers into yarn and  fabric. Note that compounding operations,

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September 1997

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Plastic Resin and Manmade Fiber

                                                            Introduction

                        where additives are incorporated into polymers,  are not covered  in  this

                        notebook.



                Figure 1:  Plastic Resins: From raw material to finished product

                                      Oil & Natural Gas

                                          Monomers

                                       Synthetic Resins

                                            SIC 2821

                                                                             Compounding

                                                                                SIC 3087

Film & Sheet

SIC 3081











Plastic Shapes

SIC 3082



Plastic Foam

SIC 3086













Laminated

Plastics

SIC 3083





Plumbing

Fixtures

SIC 3088



i









Plastics Pipe

SIC 3 084



Plastics

Products, NEC

SIC 3089







Plastics

Bottles

SIC 3085





                                        Major Markets

         Transportation

           Packaging

      Building/Construction

      Electrical/Electronic

      Furniture/Furnishings

     Consumer/Institutional

      Ind ustrial/Machi nery

             Other

            Exports

- Aerospace, Automotive, Aircraft, Marine, Railroad, Recreational



-Closures, Coatings, Containers, Flexible packaging



- Building materials, Pipe & fittings. Plumbing fixtures



• Appliance, Batteries, Business machines, Communications, Records



• Bedding, Carpets (incl. backing), House furnishings, Rigid & flexible furniture



• Cutlery, Lawn & garden, Luggage, Medical & healthcare, Toys & sporting goods



• Engine parts, Farm & constr. equip., Mach. tools. Marine supplies. Signs & displays



• Adhesives, Inks, Coatings

Source: Facts and Figures of the U.S. Plastics Industry, (1995 Edition) prepared annually by The Society of the Plastics

Industry, Inc., Washington, DC.

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                     7

September 1997

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Plastic Resin and Manmade Fiber

                                                             Introduction

  Figure 2: U.S. Manmade Fiber Industry: Principal raw materials, producer types, major

                                 products, and principal end uses

       Principal

     raw materials

   Qganic charicals:

   •Acrylonitrile

   • Gipidaetam

   •I-fcxanrthylcno-

   •Atfipieacid(AA)

   •G}x»Is(dhvlcnc,

   • TcrcpMhdie add (IPA)

   "Myvras.

   •IWjtstcr

   •K\ion

   \\bcdpiilp

                                 US. Manniade Fiber Industry

                                         SIC2823,2824

 Producer types

Ctetrical comparies



Oil exploration and

recovoy corrparaes



Rjtyirer converters

 Major products

Fibers and yams:

•Acetate

• Acrylic

•Arairid

•>fylon

•Fblyester

• RDlydefin

•Rayon

    Principal

    end uses

•Apparel

•Hbme textiles

• Carpets and rigs

• Industrial textiles

 (tires, ropes/cordage,

 automotive upholstery,

 andgeotextiles)

• Mscdlaneous consumer

 goods (craft yam,

 sevving thread,

 diapers,

 sanitary napkins,

 and tampons)

•Source: Industry and Trade Summary: Manmade Fibers, U.S. International Trade Commission, Washington, DC, 1995.

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                                                           September 1997

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Plastic Resin and Manmade Fiber

                                               Introduction

II.C. Characterization of the Plastic Resin and Manmade Fiber Industries

        II.C.l. Product Characterization

        Plastic Resins

                        The plastic resin industry produces resins which are further treated in plastics

                        processing  facilities  and  sold  largely  to  the  packaging, building  and

                        construction, and consumer markets.   Specific  product formulations and

                        manufacturing  parameters are  often  kept  as   trade  secrets  since the

                        competitiveness of many companies depends on the ability to produce resins

                        with  different physical characteristics, such  as  strength,  toughness, and

                        flexibility (Brydson, 1995).



                        Plastic resins are typically broken down into two categories: thermoplastics

                        and  thermosets.   Thermoplastic resins are resins that can be heated and

                        molded into  shapes repeatedly, while thermoset resins are resins that can be

                        heated  and molded only once.  Thermoplastic resins dominate plastic resin

                        sales and production. In 1994, thermoplastics made up about 90 percent, or

              Table 2: Plastics Materials, Synthetic Resins, and Nonvulcanizable Elastomers (as listed

              	under SIC 2821)

              acetal resins

              acetate, cellulose (plastics)

              acrylic resins

              acrylonitrile-butadiene-styrene

               resins

              alcohol resins, polyvinyl

              alkyd resins

              ally! resins

              butadiene copolymers, containing

               less than 50 percent butadiene

              carbohydrate plastics

              casein plastics

              cellulose nitrate resins

              cellulose propionate (plastics)

              coal tar resins

              condensation plastics

              coumarone-indene resins

              cresolresins

              cresol-furfural resins

              dicyandiamine resins

              diisocyanate resins

              elastomers, nonvulcanizable

               (plastics)

              epichlorohydrin bisphenol

              epichlorohydrin diphenol

              epoxy resins

ester gum

ethyl cellulose plastics

ethylene-vinyl acetate resins

fluorohydrocarbon resins

ion exchange resins

ionomer resins

isobutylene polymers

lignin plastics

melamine resins

methyl acrylate resins

methyl cellulose plastics

methyl methacrylate resins molding

 compounds, plastics

nitrocellulose plastics (pyroxylin)

nylon resins

petroleum polymer resins

phenol-furfural resins

phenolic resins

phenoxy resins

phthalic alkyd resins

phthalic anhydride resins

polyacrylonitrile resins

polyamide resins

polycarbonate resins

polyesters

polyethylene resins

polyhexamethylenediamine

  adipamide resins

polyisbutylenes

polymerization plastics, except

  fibers

polypropylene resins

polystyrene resins

polyurethane resins

polyvinyl chloride resins

polyvinyl halide resins

polyvinyl resins

protein plastics

pyroxylin

resins, synthetic

rosin modified resins

silicone fluid solution (fluid for

sonar transducers)

silicone resins

soybean plastics

styrene resins

styrene-acrylonitrile resins

tar acid resins

urea resins

vinyl resins

              Source: Standard Industrial Classification Manual, Office of Management and Budget, 1987.

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                                            September 1997

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Plastic Resin and Manmade Fiber

                                  Introduction

      Figure 3: Percentage Distribution of Plastic Resins: Sales and Captive Use, 1994

                                     Thermosets

                                        10%

                 All Other Plastics

                       12%

               LLDPE

                 8%

              Other

          Thermoplastics

              10%

               LDPE

                10%

                  Polypropylene

                      13%

                    PVC

                    14%

                            HOPE

                             15%

 Polystyrene

    8%

       .Source: SPI Committee on Resin Statistics as compiled by Association Services Group, LLC, 1995.





                     63.3 billion pounds, of plastic resin production by dry weight and accounted

                     for 82 percent, or $27.2 billion dollars of the total value of shipments for

                     plastic resin (SPI, 1995). Commercially  important thermoplastics include

                     polyethylene (all forms), polyvinyl chloride, polypropylene, and polystyrene

                     and are shown in Figure 3. These four  thermoplastics make up over  69

                     percent of plastic resin sales. These thermoplastics are considered general

                     purpose, or commodity plastics since they are usually manufactured in large

                     quantities using well established technology and are typically geared towards

                     a small number of high volume users.



                     In 1994, thermosets accounted for about 10 percent, or 7.5 billion pounds, of

                     plastic resin production  by dry weight  and 17 percent of the value  of

                     shipments for the plastic resin industry. The leading thermosets in sales were

                     phenolic resins, urea resins, and unsaturated polyester resins.  Specialty plastic

                     resins, which often include thermosets, are produced on a customized basis

                     in small production runs and typically  involve  significant  research and

                     development costs (Department of Commerce, 1994).

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Plastic Resin and Manmade Fiber

                                Introduction

      Manmade Fibers

                    Manmade fibers are produced primarily for use as raw materials for the textile

                    industry.  In 1993, about 34 percent of manmade fibers were sold to the

                    carpets and  rugs  market,  28 percent was  sold  to  the industrial  and

                    miscellaneous consumer products market, and 25 percent was sold to the

                    apparel market (International Trade Commission,  1995). The increasing use

                    of manmade fibers in a variety of markets has enabled manmade fibers to

                    account for 57% of all fibers, natural and manmade, consumed in the U.S.

                    Figure 4 illustrates manmade fiber consumption with respect to other fibers

                    and shows the leading manmade fibers.  The price and quality of manmade

                    fibers  are important determinants in the quality  and  competitiveness of

                    apparel, home textiles, and industrial and consumer products (Department of

                    Commerce, 1994;AFMA, 1997).



                    There are two main types of manmade fibers: noncellulosic (SIC 2824) and

                    cellulosic (SIC 2823). Noncellulosic, or synthetic,  fibers consist of fibers that

                    are formed by the polymerization and subsequent fiber formation of synthetic

                    organic chemicals and refined petroleum products.

Table 3: Manmade Fibers (as listed by SIC code)

Cellulosics (SIC 2823)

Acetate fibers

Cellulose acetate monofiiament, yarn, staple, or tow

Cellulose fibers, manmade

Cigarette tow, cellulosic fiber

Cuprammonium fibers

Fibers, rayon

Horsehair, artificial: rayon

Nitrocellulose fibers

Rayon primary products: fibers, straw, strips, and yarn

Rayon yarn, made in chemical plants

Regenerated cellulose fibers

Textured yarns and fibers, cellulosic: made in chemical

plants

Triacetate fibers

Viscose fibers, bands, strips, and yarn

Yarn, cellulosic: made in chemical plants

















Noncellulosics (SIC 2824)

Acrylic fibers

Acrylonitrile fibers

Anidex fibers

Casein fibers

Elastomeric fibers

Fibers, manmade: except cellulosic

Fluorocarbon fibers

Horsehair, artificial: nylon

Linear esters fibers

Modacrylic fibers

Nylon fibers and bristles ,

Olefin fibers

Organic fibers, synthetic: except cellulosic

Polyester, fibers

Polyvinyl ester fibers

Polyvinylidene chloride fibers

Protein fibers

Saran fibers

Soybean fibers (manmade textile materials)

Textured fibers and yarns, noncellulosic: made in chemical

plants

Vinyl fibers

Vinylidene chloride fibers

Zein fibers

Source: Standard Industrial Classification Manual, Office of Management and Budget, 1 987.

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 Plastic Resin and Manmade Fiber

                                  Introduction

                      In 1992, noncellulosic fibers were responsible for 88 percent, or $11.1 billion

                      dollars, of the total value of shipments for the industry. Industry statistics

                      from the Fiber Economics Bureau reported  $10.6  billion  as the value of

                      shipments for the noncellulosic fiber industry for 1996 (ATMI, 1997b). Major

                      noncellulosic fibers include nylons,  polyesters, polyolefins,  and acrylics.

                      Polyolefins  include polyethylene and polypropylene.  Figure 4 shows a

                      breakdown of U.S. fiber consumption by material.



                      Most cellulosic fibers are formed by the conversion of the cellulose into a

                      soluble  derivative, followed  by reforming as filaments.  Cellulose  is  an

                      abundant naturally occurring organic compound which makes up one-third of

                      the  world's vegetable matter.  In  some cases, the  cellulose derivative is

                      retained in the new fiber (e.g., cellulose acetate), and sometimes the cellulose

                      derivative is degraded and cellulose is regenerated (e.g., rayon). Lyocel is a

                      new class of cellulosic fibers made by direct solution of cellulose (and not a

                      derivative) in organic solvents (e.g.,  amine oxides)  and evaporation of the

                      solvent to form the new filaments. In 1992, the cellulosic fiber industry had

                      a value  of shipments of $1.7 billion according to the U.S. Department of

                      Commerce.  This is compared to $850 million for the 1996 value of shipments

                      for the cellulosic fiber industry as reported by the Fiber Economics Bureau

                      (ATMI,  1997b). Commercially important cellulosic fibers include  rayon and

                      cellulose acetate.

        Figure 4: U.S. Fiber Consumption: Percentage distribution by principal fibers, 1993

                                        Manmade

                                         fibers

                                         57%

                    All Fibers = 19.2 billion pounds

                                                                      Fbly ester

                                                                       40%

            N/lon

            28% \   mi«.  7cellulosics

                              6%

                           Acrylic

          ••"	    Rslyolefin   4%

                     22%



          Manmade Fibers = 11.0 billion pounds

Source: Industry and Trade Summary: Manmade Fibers, U.S. International Trade Commission, Washington, DC, 1995.

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12

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Plastic Resin and Manmade Fiber

                                Introduction

       ILC.2. Industry Characterization

                    Petroleum refining and synthetic organic chemical manufacturing facilities

                    produce the raw material feedstocks used to make plastic resin and manmade

                    fibers (except cellulosic fibers).  In some cases, these  facilities also make

                    plastic resins and manmade fibers.   Because of integration  between the

                    industries, the development of the petrochemical industry has contributed

                    strongly to the growth of the plastic resin and manmade fiber industries.

       Plastic Resin Industry

                    In 1992, the Department of Commerce reported 240 plastic resin companies

                    and 449 establishments in 1992.  The value of shipments for the industry was

                    $31.3 billion dollars.  The largest four companies accounted for 24 percent of

                    the value of shipments, and the largest 20 companies accounted for 63

                    percent.  Table 4 summarizes revenue and company size statistics for the

                    industry.

Table 4: Size and Revenue for the Plastic Resin and Manmade Fiber Industries

Item



Establishments (no.)

Companies (no.)a

Values of Shipments

(millions of dollars)6

Total Employees (OOO's)

Plastic Resins

(SIC 2821)

449°

240

31,303.9

60.4

Manmade Fibers

Cellulosic

(SIC 2823)

7d

5

1,748.1

11.0

Noncellulosic

(SIC 2824)

71e

42

11,113.7

44.4

Source: 1992 Census of Manufactures, Industry Series: Plastics Materials, Synthetic Rubber, and Manmade Fibers, US

Department of Commerce, Bureau of the Census, June 1995.

Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and

employment figures since 1992 are not reflected in these data.

"Defined as a business organization consisting of one establishment or more under common ownership or control.

bValue of all products and services sold by establishments in the plastics and manmade fibers industries.

cDun and Bradstreet information reports 1 553 facilities indicating SIC 282 1 as one of their top five SIC codes.

""Dun and Bradstreet information reports 29 facilities indicating SIC 2823 as one of their top five SIC codes.

cDun and Bradstreet information reports 152 facilities indicating SIC 2824 as one of their top five SIC codes.

                    Employment for the industry increased from 54,700 employees in 1982 to

                    60,400 employees in 1992.  Most  employees,  about 60  percent, are

                    considered production workers.  Although a small number of large, integrated

                    companies  dominate sales  and production, the majority of individual

                    establishments tend to be small.  About 71 percent of establishments have less

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13

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 Plastic Resin and Manmade Fiber

                                 Introduction

                     than 100 employees.  In terms of geographic distribution, four states - Texas,

                     Illinois, Michigan, and Pennsylvania - accounted for about 40 percent of

                     industry employment and 23 percent of establishments in 1992. Employment

                     and geographic distribution figures appear in Table 5.

Table 5: Establishment Size and Geographic Distribution of the Plastic Resin and

Manmade Fiber Industries

Item



% of establishments with less than

20 employees

% of establishments with less than

100 employees

Major states in which industry is

concentrated, based on employment

% of industry's employment

attributable to four major states

Plastic Resins

(SIC 2821)

24

71

TX, PA, MI, LA

40

Manmade Fibers

Cellulosic

(SIC 2823)

0

14

TN, SC, VA,AL

100

Noncellulosic

(SIC 2824)

4.2

25

SC, NC, VA, TN

77

Source: 1 993 Census of Manufactures, Industry Series: Plastics Materials, Synthetic Rubber, and Manmade Fibers, US

Department of Commerce, Bureau of the Census, June 1995.

Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and

employment figures since 1992 are not reflected in these data.

       Manmade Fibers

                     The manmade fiber industry is dominated by a small number of large plants

                     that manufacture or purchase basic organic chemicals and then synthesize

                     them into fiber-forming polymers.  These  larger fiber producers often

                     manufacture polymer for internal use and to sell to smaller firms which only

                     process purchased polymers into fibers. The dominant firms tend to fall into

                     one of the following categories: 1) large, multi-product chemical companies;

                     2)  highly integrated petrochemical companies, or 3)  widely  diversified

                     industrial firms with large chemicals- or materials-related segments (EPA,

                     1995).    Few firms  process  fibers  into end-use  consumer  products

                     (International Trade Commission, 1995).



                     In  1992, the Department of Commerce reported 5 companies involved in

                     cellulosic fiber manufacture and 42 companies involved in noncellulosic fiber

                     manufacture.  The value of shipments for the industry was $12.8 billion

                     dollars in 1992. Noncellulosic fiber manufacturing accounted for 88 percent

                     of  the value of shipments for  the industry.   Table 4 highlights industry

                     statistics, including value of shipments. Industry statistics reported by the

Sector Notebook Project

14

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Plastic Resin and Manmade Fiber

                                Introduction

                    Fiber Economics Bureau  indicated that the value of shipments for the

                    manmade fiber industry was $11.5 billion in 1996, with noncellulosic fiber

                    manufacturing accounting for 93 percent of the value of shipments for the

                    industry (ATMI, 1997b).



                    The U.S.  manmade fiber industry is highly concentrated. According to the

                    U.S. International Trade Commission, nine firms accounted for roughly 70

                    percent of U.S. production capacity in 1994, while the remaining 30 percent

                    was held by about 85 other firms.  The number of firms and level of industry

                    concentration varies by fiber type. In 1994, only two firms produced acrylic

                    and three produced rayon.  Although roughly 30 produced polyester and

                    nylon and 60 produced polyolefms, seven producers accounted for about 85

                    percent of total U.S. nylon and polyester capacity, and three accounted for

                    over one-half of polyolefin capacity. Recently, the number of polyolefin

                    producers has  increased to meet increasing demand and availability of low-

                    volume production equipment.



                    Since the mid-1980s, the manmade fiber industry has greatly consolidated and

                    reorganized.  Facilities have tried to expand and diversify by purchasing

                    existing plants,  enlarging capacity, or starting up new capacity in other parts

                    of the world. In an effort to improve profit margins and market  share, several

                    companies have sold their smaller fiber businesses in order to concentrate on

                    their strongest fiber operations (International Trade Commission, 1995).



                    While numbers of companies and establishments remained steady from 1982

                    to 1992,  employment for the industry dramatically decreased from 60,200

                    employees to 44,400 employees. Most employees, about  75 percent, are

                    considered production workers. Roughly 25 percent of establishments have

                    less than 100 employees.  Most of the manmade fiber facilities  are located in

                    the Southeast, where  the main customer,  the  textile mill industry, is

                    concentrated.  Three states -  Tennessee,  South Carolina,  and  Virginia -

                    accounted for about 62 percent of industry employment in 1992.  Table 5

                    shows employment data for the industry.  Figure 5 highlights those  states

                    which  have the largest number  of  plastic resin and manmade   fiber

                    manufacturing facilities.   Note that  industry statistics from the  Fiber

                    Economics Bureau indicated  that there were 42,000  employees for the

                    manmade fiber industry in 1996. About 39,000 employees were employed by

                    the noncellulosic fiber industry, and 3,000 employees were employed by the

                    cellulosic fiber industry (ATMI, 1997b).

Sector Notebook Project

15

September 1997

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 Plastic Resin and Manmade Fiber

                                  Introduction

  Figure 5: Geographic Distribution of Plastic Resin (SIC 2821) and Manmade Fiber (SIC

                           2823, 2824) Manufacturing Facilities

Source; 1992 Census of Manufactures, Industry Series: Plastics Materials, Synthetic Rubber, and Manmade Fibers, US Department

of Commerce. Bureau of the Census, June 1995.





       Leading Companies for (he Plastic Resin and Manmade Fiber Industries



                     Table 6 shows the top U.S. companies with plastic resin and manmade fiber

                     operations, according  to  the  1997 Dun  & Bradstreet's  Million Dollar

                     Directory. This directory compiles financial data on U.S. companies including

                     those operating within the plastic resin and manmade fiber  industries. Dun

                     and Bradstreet's ranks U.S. companies, whether they are a parent company,

                     subsidiary or division, by sales volume within their assigned 4-digit SIC code.

                     Readers should note that companies are assigned a 4-digit SIC code that most

                     closely resembles their principal industry and that sales figures include total

                     company sales, including subsidiaries and  operations not related to plastic

                     resins and manmade fibers.  Additional sources of company specific financial

                     information include Standard & Poor's Stock Report Services,  Moody's

                     Manuals, and annual reports.

Sector Notebook Project

16

September 1997

 image: 

















Plastic Resin and Manmade Fiber

                              Introduction























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 Sector Notebook Project

17

September 1997

 image: 

















 Plastic Resin and Manmade Fiber

                                                          Introduction

        II.C.3. Economic Outlook

        Plastic Resin Industry

                      The U.S. is a major exporter of plastics.  Figure 6 shows trends in U.S.

                      production of selected plastic resins for the past 25 years. Trade with Canada

                      and Mexico accounted for about one-third of total U.S. plastics exports in

                      1992.  Chronic worldwide overcapacity in plastics has continued to depress

                      and slow growth rates. Since the industry is mature, the plastic resin industry

                      was greatly affected by the depression in the global economy in the early

                      1990s.  Plant  closures and capacity  cutbacks were partly successful in

                      preventing further price  declines during  this  period  (Department  of

                      Commerce, 1994).  From 1993 to 1998, global consumption of plastic resins

                      is projected to increase 4 percent annually.

             Figure 6: U.S. Production of Selected Resins, in millions of pounds

     14000 T

  •3

                                                                           -o-LDPE/LLDPE

                                                                           -n-HDPE

                                                                           -*— Polypropylene

                                                                           — n— Polystyrene

         1970

1975

1980

                                              1985

                                     1990

                                     1995

                                       Year

KiHtrce: U.S. Tariff Commission (for 1970 data); SPI Committee on Resin Statistics as compiled by the Association Services

Group (for 1975-1995 data).

Sector Notebook Project

                       18

                                           September 1997

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Plastic Resin and Manmade Fiber

                                 Introduction

                     As the global economy rebounds from the recession of the early 1990s,

                     growth is expected to be stimulated by upswings in the packaging, building,

                     and construction markets.  This growth is expected to  occur primarily in

                     countries along the  Pacific Rim and in Latin America  as these countries

                     continue  rapid  industrialization,  increased  consumer  spending,  and

                     substitution of other materials by plastics.  Plastic resin production capacity

                     is also increasing in these regions in response to the high  demand.



                     The U.S. represents the largest single plastics market in the world, based on

                     factors  such  as large domestic  markets,  readily available  capital  and

                     technology, and relatively inexpensive raw material and energy costs. In the

                     U.S., consumption and production are not experiencing  high growth rates.

                     This is, in part, the  high level of substitution of traditional materials (like

                     wood or metal) for plastics currently in place and the fact that the commodity

                     plastics market  is  well-developed.    As a  result,  major  plastic  resin

                     manufacturers are  merging  and  swapping production  lines.   Large

                     multinational chemical companies are arranging licensing agreements as a way

                     to tap into foreign markets.  The plastic resin industry is also focusing on

                     upgrading its production to higher-value-added and  specialty resins tailored

                     for niche markets. Research on plastic resins has started to focus on refining

                     existing resins  through blends and alloys  and also improving  catalyst

                     technology to produce new grades  of polymers.   For instance, several

                     companies are planning to  produce specialty grades of polypropylene using

                     new metallocene catalysts (McGraw-Hill, 1994).



                     Advances in plastic resin properties is expected to spur growth and foster the

                     development of new end-use markets.  For instance, the cost, low weight, and

                     versatility advantages of newer plastic resins will make them more attractive

                     in the auto assembly industries. Environmental regulations and concerns have

                     an impact on many facets of the plastic resin industry.  The demand for

                     recycled and biodegradable plastic resins is expected to  continue and drive

                     development  of more  economical recycling  technologies (Department of

                     Commerce, 1994).



       Manmade Fiber Industry



                     One-half of all fibers consumed are manmade.  In 1992, global demand for

                     manmade fibers increased by 3 percent. In the past, developed countries have

                     dominated the manmade  fiber industry.   Between  1980 and  1993,  the

                     developing countries  of Asia led by China, Taiwan, and Korea have accounted

                     for most of the growth in manmade fiber production. During that period,

                     these countries increased their aggregate share of world production from 15

                     to 42 percent.  Developing countries are expected to continue increasing

                     production and capability as their consumption and  demand levels increase.

 Sector Notebook Project

19

September 1997

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 Plastic Resin and Manmade Fiber

                                  Introduction

          Figure 7: Manmade Fiber Production Data for Selected Fibers 1970-1995

    4500

        1970

                                                                            -3—Polyester



                                                                            —*— Nylon



                                                                            -— Olefin



                                                                            —~ Acrylic



                                                                            -*- Rayon



                                                                            -°— Acetate

                                                                       1995

                            Source: Fiber Economics Bureau, Inc.,  1996.

                     On the other hand, production in the U.S. has remained relatively stagnant.

                     Figure 7 shows U.S. production  trends from  1970 to 1995 for selected

                     cellulosic and noncellulosic fibers.   Figure 7  shows  that production of

                     polyester and nylon fibers was significantly greater than the production of

                     cellulosic fibers, such as acetate and rayon. Note that numbers for acetate

                     production and rayon yarn  production were not available for 1985 to the

                     present since the industries have shrunk to only a few companies.  As a result,

                     data do not appear  for acetate from 1985 to 1995, and  data for rayon

                     represent rayon yam and staple production for the period from 1970 to 1980

                     and rayon staple production only from 1985 to 1995.



                     In 1993, U.S.  manmade fiber imports rose 11 percent due to increases in

                     noncellulosic  fiber imports.  U.S.  exports decreased  1 percent in 1993.

                     Meanwhile, domestic shipments of noncellulosic fibers, such as nylon and

                     polyester,  increased  by 2  percent.  U.S. shipments of cellulosic fibers

                     increased 14 percent to $1.8 billion primarily due to growth in rayon staple

                     fiber demand  and production.  Rayon production has recently undergone

                     extensive renovation to achieve additional environmental benefits and become

Sector Notebook Project

20

September 1997

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Plastic Resin and Manmade Fiber

                                 Introduction

                    more competitive with noncellulosic fibers (U.S. Department of Commerce,

                    1994).



                    Barriers to entry into the manmade fiber industry are considerable, since

                    production is highly capital intensive and requires significant technical

                    expertise and economies of scale.  Since the mid-1980s, the manmade fiber

                    industry has undergone extensive consolidation and reorganization.  During

                    1989-1993, several fiber companies sold off smaller fiber operations in order

                    to concentrate on their strongest fiber operations, which produced higher

                    value-added products.  In addition,  large companies, which traditionally

                    produce commodity fibers, have looked to the sale of specialty fibers (e.g.

                    heat-resistant  or high-strength fibers) as a way  to increase overall profits

                    (Department of Commerce, 1994).  Back-integration of the carpet industry,

                    has resulted in the establishment of many new, small fiber producers (AFMA,

                    1997).



                    Because the manmade fiber industry is highly developed, the industry's most

                    promising growth is expected to occur through these improvements in fiber

                    characteristics.   For instance, the  U.S. Industrial Outlook states that

                    microfiber yarns and fabrics have enabled manmade fibers to compete more

                    directly with luxury fibers, such as silk and cashmere, in fashion apparel.

                    Fabrics made with these finer fibers are usually more comfortable and softer

                    than other fibers and can be used in a variety of finished apparel.  The industry

                    also predicts that lyocel, a new fiber which can be produced with particular

                    environmental benefits, will contribute to cellulosic fiber growth (Department

                    of Commerce, 1994).  In addition, the industrial and technical products

                    market is expected to continue to be dominated by manmade fibers (AFMA,

                    1997).  Geotextiles, or manmade fibers used to  reinforce civil engineering

                    projects, biological filters, and military uses are end-uses that may create more

                    opportunities for manmade fiber products.

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September 1997

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Plastic Resin and Manmade Fiber

                Industrial Process Description

ffl. INDUSTRIAL PROCESS DESCRIPTION



                     This section describes the major industrial processes used within the plastic

                     resin and manmade fiber industries, including the materials and equipment

                     used, and the processes employed. The section is designed for those interested

                     in gaining a general understanding of the industry, and for those interested in

                     the interrelationship between the industrial process and the topics described

                     in subsequent sections of this profile — pollutant outputs, pollution prevention

                     opportunities, and Federal regulations.  This section does not attempt to

                     replicate published engineering information that is available for this industry.

                     Refer to Section IX for a list of reference documents that are available.



                     This section specifically contains a description of commonly used production

                     processes, associated raw materials,  the byproducts produced or released, and

                     the materials either recycled or transferred off-site. This discussion, coupled

                     with schematic drawings  of the  identified processes,  provide a concise

                     description of where wastes may be  produced in the process.  The first

                     subsection, HI.A., discusses polymerization processes common to the plastics

                     resins and manmade fibers  industries. The following  subsection,  III.B.,

                     discusses subsequent processing steps specific to manmade fiber manufacture.

                     This section concludes with a description of the potential fate (via air, water,

                     and soil  pathways)  of process-specific waste products.



III.A. Industrial Processes in the Plastic Resins and Manmade Fibers Industries



                     The plastic resin and manmade fiber industries both use and manufacture

                     polymers. Polymers are large organic molecules (molecular weight ~104-107)

                     that consist of small repeating molecules. Polymers used in the plastic resin

                     and manmade fiber industries either occur naturally, such as cellulose, or are

                     formed  during polymerization when  bond-forming reactions cause small

                     repeating molecules to join together. Polymers are typically made from one

                     type of simple chemical unit, or monomer.  However, sometimes another

                     compound, or comonomer, is used with the monomer to make a copolymer.

                     Comonomers  can  be used  to  make  copolymers with random  chemical

                     structures, called random copolymers, or organized chemical structures, called

                     impact copolymers.



                     Polymers are central to plastic resin and manmade fiber manufacture. Many

                     grades of different polymers are produced, each with different physical

                     characteristics such as strength and ease of flow when melted. These different

                     physical  characteristics are achieved by changing operating parameters or by

                     using different polymerization  processes to change properties, such  as

                     polymer density and molecular weight. Polymers which have been  dried and

                     shaped into pellets are called plastic resins. These resins are further processed

                     at plastics processing facilities which create plastic products of different

                     shapes, sizes, and physical properties. (Refer to the EPA Rubber and Plastics

Sector Notebook Project

23

September 1997

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Plastic Resin and Manmade Fiber	Industrial Process Description



                     Sector Notebook for more information on plastics processing.) Polymers can

                     also be used to make synthetic fibers, which are commonly used to make

                     manmade textile products. Some synthetic fiber manufacturers synthesize

                     polymers on-site, while some purchase plastic resins for use in their fiber

                     operations. Fiber formation processes, including the use of natural polymers

                     to make cellulosic fibers, and particular textile fiber operations will be covered

                     later in this section.



                     There are several steps that are important to polymerization.  First, reactants

                     are purified prior to polymerization. During polymerization, catalysts, heat,

                     pressure, and reaction time are all optimized to maximize polymer conversion

                     and speed the reaction.  The polymer is often then separated from the reaction

                     mass through a series of separation and drying steps.  (Exceptions to this are

                     acrylic polymers,  (AFMA, 1997b).) Finally, the polymer is extmded and

                     pelletized for  packaging and shipment.   Various supporting steps are

                     important to note because of their potential effect on the environment.  These

                     supporting steps include unloading and storage of chemicals and equipment

                     cleaning.   Note that  methods used to recover raw materials and control

                     pollution are covered in Section m.D.  Although there are thousands of types

                     of resins  and fibers that may be produced during polymerization, the basic

                     industrial processes are similar. These processes are summarized below:



                            1) preparation of reactants

                            2) polymerization

                            3) polymer recovery

                            4) polymer extrusion

                            5) supporting operations



                     This section briefly describes the processes involved in the manufacture of

                     plastic resins and noncellulosic manmade fibers. These processes vary by

                     facility. For instance, some manufacturers purchase reactants in pure form,

                     while  others  may synthesize reactants on-site. Other facilities compound or

                     incorporate additives into the finished polymers.  Facilities that specialize

                     primarily in compounding polymers are listed under SIC Code 3087 and are

                     not covered in this notebook.



       III.A.I. Preparing Reactants



                     Many chemicals can be used to make polymers. The most important chemicals

                     are monomers, catalysts, and solvents. Monomers  are the basic building

                     blocks of polymers. They can be simple in structure (e.g. ethylene CH2CH2)

                     or complex  (e.g. ester of  a dihydric alcohol and  terephthalic  acid -

                     HOCH2CH2OCOC6H4COOH). Catalysts are chemicals used to speed up or

                     initiate the polymerization reaction.   Common catalysts include Ziegler

                     catalysts  (titanium chloride and aluminum alkyl compounds), chromium-

                     containing compounds, and organic peroxides. Details of commercially-used



Sector Notebook Project                    24                             September 1997

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Plastic Resin and Manmade Fiber

                Industrial Process Description

                     catalysts are highly  guarded secrets  since small differences in catalyst

                     preparation can lead to huge differences in polymerization costs and polymer

                     properties (Kroschwitz, 1986). Solvents are sometimes used to dissolve or

                     dilute the monomer or reactants.  The use of solvents facilitates polymer

                     transport through the plant, increases heat dissipation in the reactor, and

                     promotes  uniform  mixing  in  the  reactor.  Other chemicals  used in

                     polymerization include suspending and emulsifying agents  which disperse

                     monomer in solution.



                     Reactants, particularly monomers,  must be sufficiently pure  before they can

                     be charged to the polymerization reactor.  Trace amounts of contaminants in

                     monomer, such as water, oxygen,  and sulfur compounds in  part per million

                     quantities, can  impede polymerization and  decrease product yield.  Most

                     monomers  and solvents   can  be  purchased  in  sufficient  purity  for

                     polymerization,  however, sometimes reactants must be purified to remove

                     contaminants. Facilities may use  different purification methods, such as

                     distillation or  selective adsorption, to  increase monomer purity.   Some

                     cpmpanies manufacture monomer and other reactants at different chemical

                     facilities and transport them to plastic resin and manmade fiber facilities where

                     the  chemicals can be further processed to a sufficient purity level. For

                     example, the nylon-6 monomer,  E-caprolactam, is  often made on-site,

                     prepared, and charged to the polymerization reactors.



                     In addition to purification steps, reactants are often diluted, premixed, or

                     otherwise treated before being sent to the reactors.  The preparation and

                     charging of reactants often varies by polymerization method. For instance,

                     Ziegler-type catalysts are usually diluted with dry inert solvent and premixed

                     before injection into the polymerization reactor. For suspension and emulsion

                     polymerization, the catalyst, emulsifier,  suspending agents, modifier, and

                     activator are dissolved in water and adjusted to  the proper concentration

                     before polymerization.  In some continuous processes, two agitated make-up

                     tanks are often run in parallel so that catalysts can simultaneously be mixed

                     and charged to the polymerization vessel from one tank while a fresh solution

                     is prepared in the other.



       III.A.2. Polymerization



                     Polymerization is the major process involved in the synthesis  of plastic resins

                     and manmade fibers.  Two types of polymerization, addition polymerization

                     and  polycondensation, are  commonly used to  make  plastic  resins and

                     manmade fibers. These two methods use different chemical steps to make

                     polymers. (McKetta,   1992)  In   addition  polymerization, monomer  is

                     polymerized using a free radical catalyst  (a highly reactive molecule having

                     one or more unpaired electrons) or a coordination catalyst (e.g. Ziegler type)

                   .  to activate the monomer molecules and trigger polymerization reactions. With

                     polycondensation reactions, typically two or more reactants are first combined

 Sector Notebook Project

25

September 1997

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     in a prepolymerizer reactor to form a monomer before polymerization. During

                     polymerization, two reacting monomers are linked together in condensation

                     reactions where water molecules are split  off of the reacting monomers

                     (Lewis, 1993). In polycondensation reactions, water is typically removed by

                     vacuum to speed the reaction. Because addition polymerization processes are

                     widely used to make plastic resins and manmade fibers, this section focuses

                     primarily on addition polymerization processes.



       Continuous versus Batch Processes



                     Chemical modifiers are often injected into the reactor to  give polymers

                     specific characteristics. Temperature and pressure have a profound effect on

                     polymerization processes and may be varied in order to control conversion,

                     reaction rate  and end properties  of the  polymer  produced. Addition

                     polymerization is a highly exothermic reaction, and reactor conditions are

                     tightly monitored to control heat production and reaction stability. Continuous

                     processes are typically used for large-volume, or commodity,  polymerizations,

                     while batch or semibatch processes are used for low-volume, or specialty,

                     polymerizations. In continuous processes, the feed is continuously charged

                     into the reactor and effluent is continuously removed. In batch processes, all

                     reagents are added to the reactor and remain in the reactor for the same

                     amount of time.  In semibatch processes, some reactants are added at intervals

                     while some byproducts are removed  (Kroschwitz, 1986).



       Types of Reactors



                     Two main reactor types are used in polymerization: stirred tank reactors and

                     linear-flow reactors. Stirred-tank reactors (or autoclaves) are usually made

                     of stainless steel and range in size from 1,400-2,800 ft3 (40-80 m3), although

                     some reactors as large as 7,000 ft3  (200 ni ) are in commercial use.  The

                     reactors usually consist of a jacketed cylindrical vessel with an agitator and

                     have  highly polished  stainless steel  linings which are noncorrosive and

                     minimize polymer deposits left on walls  (Kroschwitz, 1986). Stirred-tank

                     reactors also have thick walls to withstand high pressures and support low

                     heat transfer capacity.  Temperature is controlled by heat transfer  to  the

                     jacket,  internal  cooling  coils,  water  cooled  impellers,  external  reflux

                     condensers, and external heat exchangers.  Typical temperatures range from

                     160- 570°F (70-300°C), and conversion rates ranges from a low of 2 percent

                     to 85 percent (McKetta, 1992). Due to their versatility, stirred-tank reactors

                     operated for batch processing are used to produce a large portion of polymers

                     in the United States. Often two or more reactors of similar size are used in

                     series to increase monomer to polymer conversion rates, to make maximum

                     use  of catalyst productivities, and to  reduce separation costs of removing

                     monomer from the diluent. The first reactor  is sometimes referred to as the

                     prepolymerizer since monomer conversion rates are low (McKetta, 1992).

Sector Notebook Project

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Plastic Resin and Manmade Fiber

                Industrial Process Description

                    Continuous processes are typically operated in gas-phase fluid-bed reactors

                    or linear-flow  reactors. Gas-phase fluid-bed reactors are widely used in

                    polymerizing ethylene and propylene by way of coordination catalysts. The

                    reactor is a vertical cylinder containing  a bed  of solid polymer powder

                    maintained in a fluidized state by passing a stream of reaction gas up from the

                    base of the reactor. Catalyst and monomer are added through the sides of the

                    reactor. The reaction gas is withdrawn from the top of the reactor and heat of

                    reaction is removed with a compressor and cooler before being recirculated

                    back up through the polymer powder. The solid polymer powder is removed

                    periodically as it builds up in the base of the reactor by opening a discharge

                    valve that blows the product powder into a disengaging system. (SRI, 1995)

                    Figure 8 shows a simplified diagram of a gas-phase fluid-bed reactor.



     Figure 8: Gas-Phase Fluid-Bed Reactor for Production of Polyethylene

                                               Hot Reaction Gas

                  Ethylene



                  Comonomer



                  Catalyst

                                                Cooler

                                                        Compressor

 Source: SRI International 1995.

                    Linear-flow reactors are tubular and jacketed with a heat transfer fluid, like

                    Dowtherm* or water (Kroschwitz, 1986). The tubes may be several hundred

                    meters in length, but are often coiled in helix-like structures as a way to save

                    space and avoid buildup of polymer in elbows. Typical residence time in the

Sector Notebook Project

27

September 1997

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     reactors varies from 30 to 60 seconds.  The reactors have three different

                     zones used for preheating, polymerization, and cooling.



                     Loop reactors are the most common linear-flow reactors. Loop reactors have

                     long straight lengths of tubing interjected with short bends and are typically

                     490-540 ft (150-165 m) long. The reaction slurry is circulated around the

                     loop at speeds of 10-30 ft/s (3.3-10 m/s) by axial flow pumps. The residence

                     time of the reactants in the loop reactors ranges from 45 to 60 seconds, and

                     polymerization  temperatures  range  from   390-480°F  (200-250°C).  A

                     schematic diagram of a typical loop reactor is shown in Figure 9. Polymer

                     slurries containing 20-70 percent solid  polymer particles are collected in

                     settling legs located at the base of the reactor. When two loop reactors are

                     used in  series, a portion of the slurry in  the first loop  is continuously

                     withdrawn and pumped into the second reactor, from  which polymer is

                     removed as a slurry.  Emissions and wastes generated during polymerization

                     include VOC  emissions  from leaks and spills,  solid  wastes  from off-

                     specification polymer, and spent solvent from incomplete polymerization

                     (Kroschwitz, 1986).



         Figure 9; Typical Loop Reactor for Production of Polyethylene

                  Coolant is provided

                  in jacket of loop

                  reactor

                      Ethylene.

                      comoncmer,

                      and solvent

                        Impeller.

                      Catalyst1

                                                             Settling legs

                         Optional additional

                         solvent (often not

                         used)

 Source: Encyclopedia of Chemical Processing and Design.  Volume 39. J.J. McKetta (ed), Marcel Dekker, Inc.,

 New York, 1992.

Sector Notebook Project

28

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Plastic Resin and Manmade Fiber

                Industrial Process Description

       Methods of Polymerization

                    The specific polymerization method used is key to polymer manufacturing.

                    Different polymerization conditions and processes are used to synthesize

                    different polymers and to create different grades of a given polymer (McKetta,

                    1992). Addition polymerization methods are covered primarily in this section.

                    Five general methods are used  commercially  for  polymerization:  bulk,

                    solution, suspension, emulsion, and polycondensation.  Table 7 lists typical

                    polymerization method and reactants for leading commercial plastic resins.

                    Note that distinctions between these methods are not well-defined and that

                    some companies use a combination of polymerization methods.  In addition,

                    details of specific processes are often protected by manufacturers since small

                    process variations can result in significant reductions in operating costs and

                    unique changes in polymer characteristics.

 Sector Notebook Project

29

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 Plastic Resin and Manmade Fiber

                Industrial Process Description























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Plastic Resin and Manmade Fiber

                Industrial Process Description

       Bulk Polymerization



                    In bulk polymerization, primarily monomer and a catalyst are used to make

                    polymer. Two reactor vessels are often used to complete polymer conversion

                    and recycle unreacted monomer.  Because few solvents or other chemicals are

                    used, bulk processes typically  produce purer polymers  and generate less

                    pollutants than those produced by other processes.  Separation procedures of

                    polymer and reactants are also simplified,  reducing expensive solvent recovery

                    equipment costs. Figure 10 shows a flow chart for a high density polyethylene

                    process with  simplified separation steps.   In  the figure, high density

                    polyethylene is separated from the monomer in the flash drum  and goes

                    through a series of recovery and finishing steps. The monomer is recovered

                    using a stripper and a dehydrator.  Increased conversion rates and decreased

                    recovery costs have made bulk processes increasingly favored in the industry

                    (McKetta,  1992).  Note that  bulk processes used for polycondensation

                    reactions are discussed later in this section.



          Figure 10: High-Density Polyethylene Process Flow Diagram

                    Ethylene —

           Ethylene



          Catalysts

                                                        WASH/INSPECT HC'S     LOADHC'S

                                                                             CUSTOMERS

                Source: Exxon Chemical Company's MontBelvieu Plastics Plant Brochure.

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                 Industrial Process Description

                     Bulk processes can be divided into two types based on whether or not the

                     monomer and polymer are soluble in each other. If the monomer and polymer

                     are not soluble in each other, polymer slurries are formed which consist of

                     solid polymer particles mixed with either  liquid  or  gaseous monomer.

                     Polyester and nylon are among many polymers produced in continuous-flow

                     bulk polymerization systems.



                     Gas-phase polymerization is a type of bulk polymerization, primarily used to

                     synthesize  polyethylene and  polypropylene.    Gaseous  monomer  and

                     comonomer are fed continuously into a reactor that is filled with fluidized

                     polymer particles.  Figure 11  shows a photo of two fluid reactors used for

                     making polypropylene.  In the Unipol process, up flowing monomer reacts

                     with granular polymer particles suspended in a vertical cylindrical reactor.

                     The bed  is typically 40-50 ft (12-15 m) high and 15-16 ft (4.5-5 m) in

                     diameter.  Pressures range from 265 to 310 psi (18-21  atm), and temperatures

                     range from 176 to 212°F (80-100°C).  A distributor plate is attached to the

                     bottom of the reactor to maintain uniform flow of monomer and even

                     distribution of polymer and catalyst throughout the bed.  Monomer gas is

                     cooled and partially condensed in an external cooler to remove reaction heat.

                     Only 2 percent of monomer reacts per pass, so large  volumes of gas are

                     recycled. Large polymer particles collect in the bottom of the reactor where

                     they are semicontinuously removed (McKetta, 1992).



             Figure 11: Fluid Reactors Used for Making Polypropylene

       Source: Principals of Polymer Systems, 4th Edition, Ferdinand Rodriguez, Taylor and Francis, Washington,

       DC, 1996. Reproduced with permission.  All rights reserved.

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Plastic Resin and Manmade Fiber

                Industrial Process Description

       Solution Polymerization

                     Solution polymerization is commonly used to make plastic resins and textile

                     fibers.  In solution polymerization, a solvent is mixed with monomer in the

                     reactor.  Use of solvents reduces reaction mass viscosity, improves  heat

                     transfer rates, and increases mixing efficiency during polymerization.  Choice

                     of solvent can have a large effect  on polymer properties and the rate of

                     polymerization.    Because   solution polymerization requires  additional

                     processing and recovery steps, companies typically try to optimize solvent to

                     monomer ratios to reduce polymerization costs and emissions (Kroschwitz,

                     1986).  Reactors are often operated in series for continuous operations.



                     In solution polymerization,  the polymer may be soluble or insoluble in the

                     solvent. When the polymer is insoluble in the solvent, a slurry is formed of

                     solid polymer particles dispersed in solvent. Slurry processes can be divided

                     into two categories, light slurry and heavy slurry, based on the molecular

                     weight of the solvent. Slurry processes are commonly used in the continuous

                     production of high-density polyethylene, linear low-density polyethylene, and

                     polypropylene.  Polymers are typically formed  at temperatures of 3 20-480 °F

                     (160-250°C), with a dissolved polymer content of usually 10-15 percent.

                     Loop reactors are often used, although some companies use a series of stirred

                     autoclaves as polymerization  vessels.  Typical solvents used include isobutane

                     (light slurry) and hexane (heavy slurry). Typical slurry composition by weight

                     is 30 percent particulates,  68 percent solvent,  and  2 percent monomers.

                     Reaction pressure is about 650 psi (44 atm) and reaction temperature is about

                     225°F (107°C). Typical polymer concentrations are 50-70 percent (McKetta,

                     1992).

       Suspension Polymerization

                     In suspension polymerization, agitation and suspending agents are used to

                     suspend monomer and polymer particles in water. The suspending agents also

                     maximize heat transfer,  maintain  uniform mixing,  and prevent polymer

                     clumping in the suspension. Catalysts are added to initiate the reaction and

                     typically include azo compounds, organic peroxides, or peroxydic carbonates.

                     In suspension processes, polymerization is initiated in the monomer droplets

                     and proceeds as miniature bulk reactions.  The polymer droplets, usually

                     0.006-0.20 in (0.15-5  mm) in diameter,  settle out of solution as soon as

                     agitation is stopped.  Figure 12 shows the typical flow diagram for the

                     suspension polymerization of polyvinyl chloride (PVC). Note that monomers

                     and  polymers produced  by suspension  and emulsion processes undergo

                     additional recovery steps than those produced by bulk or solution processes.

                     For example, Figure 12  shows that the polymer slurry is centrifuged and

                     separated following polymerization. Monomer undergoes additional recovery

                     and drying steps to remove water from the monomer.

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  Figure 12: Typical Process Flow Diagram for Suspension Polymerization of PVC

      Suspending

      Daonizadsnd

      Dlrihrnliaxi

        Wter

                                                                           QudeVCM

                                                                           Storagp

                                                                           Tank

                                                          Rotary Air,

                                                          2-Stag5Rash

                                                          or Cotrbination

                                                                                   To

                                                                                   •.Recovery

                                                                                   and

                                                                                   Recycle

                                      .Mast

                                       Air

                                    To PVC

                          Screerer   ^ Bagger or

                                    StorageSilo

Source: Encyclopedia of Chemical Processing and Design, Volume 40, J.J. McKetta (ed.), Marcel Dekker, Inc. New

York, 1992.

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Plastic Resin and Manmade Fiber	Industrial Process Description



                    Industrial suspension processes generally use batch reactors.   Suspension

                    polymerization processes are used for about 90 % of all PVC produced.

                    Stirred-tank reactors for PVC production range in size from 1,000-50,000

                    gallons, and reaction temperatures typically range from 110-160°F (45-70°C).

                    Note that polymers produced by suspension processes must undergo

                    additional monomer and polymer recovery steps than those produced by bulk

                    and solution processes  (Kroschwitz, 1986).



       Emulsion Polymerization



                    Emulsion polymerization is similar in method to suspension polymerization

                    but uses smaller monomer and polymer particles.  Emulsion polymerization

                    uses emulsifiers and additives to suspend monomer and polymer particles in

                    water. In emulsion polymerization, surfactant accumulates around monomer

                    particles, forming micelles that act as tiny polymerization vessels. Polymers

                    form as more monomers  react.   Agitation optimizes  reaction  rate  by

                    dispersing monomer, catalyst, and polymer and by transporting heat to the

                    reactor surface.   Emulsion processes typically produce moderately viscous

                    reaction masses. About 10% of PVC and some polystyrene are produced by

                    emulsion processes.  Emulsion polymerization methods typically produce

                    polymers that are smaller and more difficult to process than those produced

                    by suspension polymerization methods. Polymers produced by emulsion

                    processes are also  characterized by high polymer viscosity, high heat transfer

                    rates, and more difficult transport and agitation of the polymer slurry. For

                    those reasons, emulsion processes are frequently replaced with suspension

                    polymerization methods (Kroschwitz, 1986).



       Poly condensation



                    Polycondensation reactions are used to make polymers, such as polyesters,

                    polyamides (or nylons), polyurethanes, phenolics, urea resins, and epoxies.

                    Polycondensation is an equilibrium reaction that depends on temperature,

                    pressure, and the efficient removal of reactants and the catalyst (Kroschwitz,

                    1986).  Typically, two  or more reactants are first combined to form a

                    monomer. The monomer is then charged to a polymerizer where monomers

                    link together in condensation reactions.  Condensation reactions occur when

                    two molecules are linked together from the splitting of water molecules from

                    the reacting molecules. Reaction temperatures range from 446 to 545 °F (230

                    to 285 °C) for nylon-6,6 and  polyester.  These reactions are endothermic,

                    unlike addition polymerization reactions, and therefore, require the addition

                    of heat to complete polymerization (ATMI, 1997b).



                    For nylon-6,6, polycondensation of nylon salt is carried out continuously for

                    commodity  nylon production  and batchwise  for  special grade  nylon

                    production.   The reaction typically takes place  in several stages.  The first

                    stage takes  place in a tank or tubes under pressure greater than 250 psig.



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                     Water vapor is removed through a throttle valve or in a subsequent separator.

                     The last  stage  of the polycondensation occurs under atmospheric  or

                     subatmospheric pressure to further facilitate water removal. Additives are

                     often introduced during polycondensation to impart desirable properties to

                     resins and chips. Viscosity stabilizers, such as acetic acid, are sometimes used

                     to limit the  degree  of polymerization.  Reaction accelerators, such  as

                     phosphoric acid, sometimes used to speed the reaction (McKetta, 1992).



       IBI.A.3. Polymer Recovery



                     Once polymerization is  completed, a reaction mixture is produced which

                     consists of polymer, monomer, and trace amounts of catalyst.  Because

                     reaction mixture consistency varies according to which polymerization method

                     is used, different polymer separation and recovery steps are required  of

                     different polymerization methods.  To recover the polymer, the reaction

                     mixture typically goes through a series  of three separation and purification

                     steps: 1) unreacted monomer is separated from the polymer; 2) liquids and

                     solids are separated; and 3) residual water or solvents trapped in the polymer

                     are purged by drying the polymer.



                     The first step in polymer recovery is flashing, in which solvents and unreacted

                     monomers  are volatilized from the reaction mixture and drawn off for

                     recovery.  Flashing is achieved by lowering the pressure in a staged separation

                     system, which causes monomers and solvents with low boiling points  to

                     evaporate.  A large portion of monomer and solvent is removed during this

                     step. Remaining monomer in the polymer can be removed in a low-pressure

                     degasser, as in bulk polymerization processes, or by gravity, as in gas-phase

                     processes.   In  some  cases, combinations of heating,  flashing,  thin-film

                     evaporation, and vacuum stripping are used to separate residual solvent from

                     the polymer.



                     For reaction mixtures that contain heavy solvents or liquids, further steps are

                     used to separate the polymer from the reaction mixture.   Typically, the

                     mixture is centrifuged or filtered to separate the solid polymer granules from

                     the liquids. The polymer is then washed and stripped of residual solvent and

                     monomers.



                     Most polymer recovery operations include a drying step. Polymers are usually

                     solvent or water-wet and are dried after being centrifuged.  Drying removes

                     water and residual solvents from the polymers.  Flash drier-fluidized bed

                     systems with gas recycle are commonly used for polypropylene and high-

                     density polyethylene.  Combination dryers,  such as single and multistage

                     fluidized-bed systems, are also used.  In the flash dryer-fluidized bed system,

                     the  flash  dryer removes surface water  in a matter of seconds, while the

                     fluidized bed completes moisture removal by holding the polymer at drying

                     temperatures for about 30 minutes. In rotary dryers, a hot gas passes over the

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                Industrial Process Description

                     polymer  particles, transferring heat and  vaporizing  solvent  and water

                     molecules.  Rotary dryers and two-stage flash dryer-fluidized-bed systems

                     have also been used to dry the wet PVC cakes resulting from polymerization.

                     Polyester is often dried  by hot, dry air or  inert gas in tumble,  column, or

                     fluidized-bed dryers at about 180°C.   Wastes  generated from  drying

                     operations include primarily VOC emissions (Kroschwitz, 1986).



       III.A.4. Polymer Extrusion



                     Most polymers undergo further processing steps to form plastic pellets.  The

                     polymer is  usually extruded  and  pelletized before being  packaged and

                     incorporated with additives to prevent product deterioration.  After polymer

                     recovery, the polymer is fed to a screw extruder which melts the polymer.

                     The molten polymer is  then fed to a pelletizer, which may be capable of

                     producing up to 5000 pounds of pellets per hour. The pelletizer extrudes

                     molten polymer out of small orifices, forming continuous strands 0.08-0.16

                     in (2-4 mm) in diameter. These strands are cooled and then cut using either

                     a fixed or rotating knife.  The pellets are then dried to remove any dissolved

                     monomer that would exude from the pellets during storage.  Additives are

                     often added directly to the extruder, to a blender prior to the  extrusion step,

                     or later in a highly concentrated master batch. Often antioxidants are added

                     to prevent deterioration of product properties during storage, shipment, and

                     product fabrication. Other additives may be added to increase ultraviolet light

                     stability, reduce the tendency for static electrical charges, or add color and

                     pigment (McKetta, 1992).



       III.A.5. Supporting Operations



                     Various supporting steps to the manufacture of plastic resins and manmade

                     fibers  are important to note because of their effect on the environment.

                     Supporting steps include the unloading  and storage  of  chemicals and

                     equipment cleaning.  Some of these supporting processes are discussed below.

                     Note that supporting operations, such as raw material recovery and pollution

                     control, are mentioned in Section III.C.



       Equipment Cleaning



                     Cleaning of equipment,  such as reactors and storage vessels, is performed

                     periodically as routine maintenance on the plant. Polymerization reactors are

                     cleaned often to remove buildup of polymer on heat transfer  surfaces which

                     can result in contamination between batch runs of different polymers or

                     different grades of polymers.  Reactor cleaning is particularly important for

                     suspension and emulsion polymerization processes since the reaction mass is

                     very viscous. Deposits on reactors may consist of polymer gels or coagulum.

                     Spray rinse valves are often installed in the reactor top to facilitate washing

                     while the reactor is emptied. High  pressure water-jet streams and hydraulic

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                      reactor cleaners are also used to remove hard deposits. Solvents and manual

                      scraping are also sometimes used (Kroschwitz, 1986).



                      Cleaning of loading vehicles and storage vessels is performed both before and

                      after loading. Before plastic pellets can be loaded into rail hopper cars or bulk

                      trucks, the vehicles are cleaned to remove residual trapped and clinging pellets

                      as well as other contaminants that may be present.  Pellets are removed first

                      using suctioning and then using wash water.  The rinse water is collected into

                      the  facility drainage and containment system where residual pellets are

                      recaptured via a series of dams, skimmers, and surface booms.  Wastes from

                      equipment cleaning  also  include  wastewater contaminated with dilute

                      concentrations of organics, acids, and salts  (EPA, 1992).



        Unloading and Storage ofReactants



                      Unloading and storing reactants is an important step in polymerization. These

                      operations are closely monitored to avoid contamination of reactants, runaway

                      or accidental polymerization, and fugitive emissions.  To reduce fugitive

                      emissions, gaseous  compounds are often unloaded from tank  cars  by

                      pressurizing the tank car with vapors from the storage tank.  Compressor

                      valves are then reversed to remove and transfer vapor from  tank  cars to

                      storage tanks.



                      Chemicals are typically stored in large stainless steel storage tanks equipped

                      with both external and internal covers. Tank  design is mostly concerned with

                      safety,  since materials may be flammable,  toxic,  or    autocatalytically

                      polymerized.  Autocatalytic polymerization occurs when monomer starts

                      polymerizing spontaneously in the storage tank.  Monomers  are typically

                      stored in pressure vessels equipped with excess flow valves on the outlet

                      connection. These valves safeguard against complete discharge in the event

                      of pipe rupture.  In addition, monomer storage tanks are often equipped with

                      systems to avoid unwanted polymerization including systems to inject inhibitor

                      into reactors to stop polymerization and insulation and coiling coils to prevent

                      polymerization.



                      Liquids with high boiling points are  stored in vented atmospheric tanks.

                      Solvents are usually stored under a blanket of nitrogen gas to  minimize air

                      contamination.  Some catalysts, such as the Ziegler-type, are so explosive

                      when in contact with water and air that they are diluted with hydrocarbons for

                      easier handling  (Kroschwitz,  1986).   For  these safety reasons, tanks are

                     usually located outdoors and away from production facilities.  Because  of

                     stringent dust and moisture standards for  polymerization, unloading and

                     storage systems may have elaborate air conditioning and ventilation systems.

                     Emissions generated from storage operations include air emissions of VOCs

                     (EPA, 1993).

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       Conveyance

                     Charging reactants to reactors is one of the most important conveyance steps

                     in  plastic resin and manmade fiber production.   Charging reactants  and

                     polymer must be controlled carefully to avoid producing off-spec product and

                     causing polymer buildup in the pipes. Polymerization feed is automatically

                     measured and charged into the reactors.  Measuring and charging reactants

                     varies depending  on whether the process is batch or continuous  and what

                     accuracy of formulation is  required.  Batch methods use weigh  tanks,

                     volumetric charge tanks, and flow meters to feed the polymerization vessels.

                     For continuous processes, reactants are fed continuously at a specific rate into

                     the reactor.  Reactor heat-up, purge, evacuation, charge, and discharge are all

                     controlled by  automatic  control systems equipped  with temperature  and

                     pressure overrides.



                     Conveying  systems are also used to move plastic pellets  between plant

                     operations.  An example of a pneumatic conveying system in a pellet blending

                     operation is shown in Figure 13.  Pellets are conveyed using pneumatic or

                     mechanical systems to move pellets between the pelletizers and  drying systems

                     and between storage silos and shipping containers.  In pneumatic systems,

                     high-pressurized air  can  be used to transport pellets through the plant.

                     Mechanical systems  are  generally used to transport pellets  across short

                     distances using rigid driven screws to force pellets through a conduit.  Pellet

                     spills can occur during each conveyance and can be avoided by controlling the

                     rate of pellet entry and delivery from the conveying system.  Wastes generated

                     during conveying operations may include VOC emissions from  leaks and spills

                     (EPA,  1992).

       Pellet Storage

                     Plastic pellets must be stored carefully to avoid product contamination or

                     accidental spills. EPA has identified preventive measures to minimize pellet

                     loss and entry into water streams which apply to plastic resin and manmade

                     fiber plants and downstream processing plants. After polymer finishing, the

                     plastic pellets are transferred to intermediate storage vessels consisting of

                     30,000 to 100,000 pound  silos.  The pellets are then transferred to silo lots

                     where they are sampled, bagged for shipment, and transferred to downstream

                     processes for hot-melt mixing and incorporation of additives.  Pellets are

                     packaged in containers ranging from 50 pound bags to 100,000 pound railway

                     hopper cars.  Wastes from pellet storage include solid wastes or wastewater

                     containing plastic pellets (EPA, 1992; SPI, 1994).

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   Figure 13: Typical Pneumatic Conveying System in a Pellet Blending Operation

                  4

                                       Manual Feed

                                       from Bags

         Bagging

Source: U.S. EPA, Plastic Pellets in the Aquatic Environment: Sources and Recommendations, Office of Water December

1992,

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                Industrial Process Description

IH.B. Industrial Processes Specific to the Manmade Fiber Industry



                    The manufacture of manmade fibers is closely linked with the synthesis of

                    plastic resins. Fibers are the fundamental unit of textiles and fabrics and can

                    be defined as a unit of matter having a length at least 100 times its width or

                    diameter (Rodriguez, 1996). Fiber spinning processes may be similar for

                    some noncellulosic fibers and cellulosic fibers.  Manmade fibers can be

                    produced from polymers that have been continuously or batch polymerized,

                    or by dissolving cellulosic materials.  The polymer or cellulosic solution is

                    then  forced through  tiny holes of spinnerets (which function much like

                    bathroom shower heads) and  extruded into fibers (International Trade

                    Commission, 1995).  In manmade fiber  plants, polymerization of the fiber

                    polymer can occur at the same facility that produces the fiber, with continuous

                    polymerization equipment linked directly to a fiber spinning unit (EPA, 1995).

                    Subsequent processing steps typically include drawing, crimping, texturizing,

                    and twisting.  The following sections will discuss polymerization, primary

                    methods of spinning, and fiber processing steps.



       HLB.l. Polymerization



                    Many of the leading  commercial manmade  fibers, such as polyethylene

                    terephthalate (PET) and polypropylene, use polymers similar to those derived

                    from commodity plastic resins. Other manmade fibers are manufactured from

                    polymers formed using similar polymerization methods as those mentioned in

                    the preceding section.  For  instance, nylon and polyester are polymerized

                    using polycondensation or melt polymerization methods. Recall that some

                    manmade fibers  are manufactured using natural polymers, such as cellulosic

                    fibers, and do not undergo polymerization.



                    In  some plants, polymerization equipment is hooked up directly to fiber

                    spinning  equipment.    For  continuous manufacture  of polyester  fiber,

                    terephthalic acid and ethylene glycol are first passed through primary and

                    secondary esterifiers to form the monomer. The melt is then passed to low

                    and high polymerizers to  achieve higher conversion rates.   The  high

                    polymerizer is usually equipped with a high vacuum and high walls to allow

                    excess ethylene glycol to escape, promoting chain extension. The polymer is

                    then fed to several banks of direct fiber melt spinning heads or a solid polymer

                    chipping system (Kroschwitz, 1986). Wastes generated during polymerization

                    may include VOC emissions from leaks,  spills, and vents; solid wastes from

                    off-specification  polymer; and spent solvent from incomplete polymerization

                    (AFMA, 1997).

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        III.B.2. Spinning

                      Spinning, in terms of manmade fibers, refers to the overall process of polymer

                      extrusion and fiber formation. Fibers are formed by forcing a viscous fluid or

                      polymer solution through the small orifices of a spinneret and immediately

                      solidifying or precipitating the resulting filaments. Facilities typically produce

                      fibers of different thickness or denier, where denier is defined as the weight

                      in grams of 9,000 meters (9,846 yards) of filament yarn.  Fiber denier can

                      range from less than one to 3,600 denier (McKetta, 1992).



                      The three primary methods of spinning are melt, dry solvent, and wet solvent,

                      which are shown in Figure 14. A fourth and less commonly used method is

                      reaction spinning.  Table 8 lists the different types of spinning methods with

                      the fiber types and typical reactants used for each method.  The spinning

                      process used for a particular polymer is determined by the polymer's melting

                      point, melt stability, and solubility in organic and/or inorganic (salt) solvents,

                      as well as the end use of the fibers (AFMA, 1997; EPA, 1993).  Spinning

                      processes involve spinning units which are made up of meter pumps, filter

                      packs, spinnerets, and quench cells.  Meter pumps are used to transport

                      polymer through the spinning units at a constant rate.  The polymer is passed

                      through a filter and a spinneret. Note that fibers may be colored by including '

                      pigments prior to extrusion (AFMA, 1997).



                      The spinnerets are plates containing holes, of varying diameters and shapes,

                     through which molten or dissolved polymer is extruded. Pressures can reach

                      as high as 2900 psi (20 MPa). The spinnerets are usually made of stainless

                     steel or nickel alloy for melt and dry spinning processes, although for more

                     corrosive wet spinning processes they are usually made of glass or a platinum

                     alloy.   The spinneret may be a recessed flat plate  (melt spinning)  or a

                     protruding thimble shape (dry and wet spinning). The spinnerets for molten

                     polymers are relatively thick 0.1-0.4 in (3-10 mm) and have hole diameters of

                     0.007-0.030 in (175-750  |_im).  For solution polymers, the spinnerets are

                     slightly thinner with smaller hole diameters.



                     The number of holes in a spinneret ranges from a few to several thousand.

                     These holes may be divided into groups to produce, for instance,  two 30-

                     filament yarns from a 60-hole spinneret.  The exit hole is usually  circular,

                     however fibers may have lobed, dumbbell-, or dogbone-like cross-sections

                     (dry-spun fibers) or round, lobed,  serrated, or bean-shaped cross-sections

                     (wet-spun fibers). Wastes generated  during spinning operations include VOC

                     emissions and wastewater contaminated with solvents.

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               Industrial Process Description

Figure 14: General Process Diagram for Melt, Dry, and Wet Spun Synthetic Fibers

                Spinning

   Dry

   Spill n ing

               Processing

                     Source: U.S. EPA,AP-42, Office of Air and Radiation, 1993.

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Table 8: Typical Fiber Spinning Parameters for Selected Fibers

Spinning Method

Melt Spinning

Solvent Spinning

Dry solvent spinning

Wet solvent spinning

Reaction Spinning

Fiber Type

nylon-6

nylon-6,6

polyester

polyolefin

acrylic/modacrylic

cellulose acetate/

cellulose triacetate

spandex

acrylic/modacrylic

spandex

rayon (viscose process)

Solvents or Other Reactants

N/A

dimethylacetamide

acetone or chlorinated hydrocarbon

di-isocyanate, ethylenediamine, monoamine

(stabilizer)

dimethyl acetarnide

di-isocyanate, ethylenediamine, toluene

sodium hydroxide, carbon disulfide, sulfuric acid

Source: U.S. EPA,AP-42, Office of Air and Radiation, 1993; AFMA, 1997.

Types of Spinning



       Melt Spinning

                     Melt spinning processes use heat to melt polymer which can then be extruded

                     through the spinneret.  Spinning assemblies are fed by either electrically-

                     heated screw extruders, which convert powdered or chipped polymer into a

                     polymer melt,  or directly from a continuous melt polymerization process.

                     Many nylon and polyester plants use continuous melt polymerization and send

                     molten polymer  from polymerization units directly to the  spinning units.

                     During polymerization or extrusion, various additives may be incorporated to

                     impart special properties to the fibers, such as heat stability,  anti-static, and

                     eased dyeing.



                     Polymer chips or polymer melt is then passed through metering gear pumps,

                     which feed the molten polymer to a filter system at pressures of 500-1000 psi

                     (7,400-14,700 atm). The filter system screens out large solid  or gel particles

                     through a series of metal gauzes interspersed in layers of graded sand (EPA,

                     1993).  The filter  may also screen out catalyst residues or precipitated

                     additives (McKetta,  1992).  The filter may be enclosed in a Dowtherm-heated

                     manifold to maintain uniform temperature. After passing through the filter,

                     the molten polymer is fed to the spinneret (Kroschwitz, 1986).  A narrow

                     zone below the spinneret may be filled with inert gas to prevent deposits of

                     degradation products around  the holes for oxidation-sensitive polymers.

                     Extruded filaments are quenched by a cool, filtered airstream which solidifies

                     the filaments.

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Plastic Resin and Manmade Fiber

                Industrial Process Description

       Dry Spinning

                     Dry spinning is typically used for easily dissolved polymers such as cellulose

                     acetate, acrylics, and modacrylics.  In dry spinning processes, the polymer is

                     first dissolved in an organic solvent.  The solution (or spinning dope) is then

                     blended with additives, filtered, and charged to  a spin cell.  The spin cell

                     contains a feed vessel, a heat exchanger, a spinneret, and a quench cell. The

                     spin cell may be 5-10 m  (5.5-11 yards) long and 13-23 cm (5.1-9.1  in) in

                     diameter (Grayson, 1984). The solution is heated to a temperature above the

                     solvent boiling point and is then extruded through the spinneret into a zone of

                     heated gas.  The  solvent evaporates into the gas stream, leaving solidified

                     filaments. The heated gas stream is typically air although inert gas, such as

                     nitrogen and super-heated solvents, can also be used. Fibers are then passed

                     through  baths to wash residual solvent from the fibers.  To reduce costs and

                     pollution, the wash water from these baths is typically recycled. These baths

                     may be  followed  by activated carbon systems used to adsorb solvent from

                     process air (AFMA,  1997). Fibers produced by dry spinning contain less void

                     space than  those produced  by melt spinning and therefore have higher

                     densities and lower dyeability than those produced by  other  methods

                     (Kroschwitz, 1986). Of the three primary spinning methods, dry spinning

                     operations have the largest potential VOC emissions "to the air  (EPA, 1993).

       Wet Spinning

                     Wet spinning processes also use solvents, such  as dimethylacetamide or

                     aqueous inorganic salt solutions, to prepare spinning dope (AFMA, ^1997).

                     In wet spinning, the polymer is dissolved in solvent  in a solution vessel and is

                     forced through a spinneret which is submerged in a coagulation bath. As the

                     polymer solution emerges in the coagulating bath, the polymer is either

                     precipitated or chemically regenerated.  In precipitation, the fiber is formed

                     when solvent diffuses out of the thread and coagulant diffuses into the thread.

                     For some processes, a chemical reaction occurs during precipitation which

                     generates fibers. Coagulated filaments pass over a guide to godets or drive

                     rollers.  Windup speeds are about 150 m/min.   The yarn is then passed

                     through  additional  baths  for  washing  and  residual  solvent  removal

                     (Kroschwitz, 1986).

       Reaction Spinning

                     Reaction spinning methods are typically used to make spandex and rayon.

                     The process begins with the preparation  of a viscous  spinning solution

                     containing a dissolved low molecular weight polymer, such as polyester, in a

                     suitable solvent and a reactant, such as di-isocyanate. The spinning solution

                     is then forced through spinnerets into a solution containing a diamine (similar

                     to wet spinning) or is combined with a third reactant and then dry spun. The

                     primary distinguishing characteristic of reaction spinning processes is that the

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 Plastic Resin and Manmade Fiber

                                    Industrial Process Description

                     final cross-linking between the polymer molecule chains in the filament occurs

                     after the fibers have been spun. The fiber is then transported from the bath to

                     an oven, where solvent is evaporated (EPA, 1993).



                     In the U.S., most rayon is made by the viscose process.  This process is worth

                     noting because it is typically associated with a large volume of air emissions.

                     Shown  in Figure 15, the viscose process converts cellulose from one form

                     (dissolved pulp) to  another  (rayon). Although the manufacturing process

                     further purifies the cellulose, alters the physical form of the fiber, and modifies

                     the molecular orientation within the fiber and its degree of polymerization, the

                     product is essentially the same chemical  as the raw material.  Since the

                     product retains the  same chemical structure, all other chemicals used in the

                     process and all byproducts formed in the process must be removed.

 Figure 15: Typical Process Flowchart for Synthesis of Rayon Fibers Using the Viscose Process

      CELLULOSE

        S H E E T5

STEEPIN O

P R ESS IN O

                                          SHREDDING      AOINO

                                                                 XANTHATION

                     ACID BATH

                      Source: U.S. BPA,AP-42, Office of Air and Radiation, 1993.

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Plastic Resin and Manmade Fiber

                Industrial Process Description

                     The series of chemical reactions in the viscose process used to make rayon

                     consists of the following stages. First, purified cellulose pulp is steeped in a

                     solution of sodium hydroxide and water, producing an alkali cellulose slurry.

                     The excess sodium hydroxide solution is removed from the slurry, producing

                     alkali cellulose crumb. The crumb is shredded and fed into silos for aging, a

                     process which controls the degree of polymerization of the  cellulose

                     molecules. After aging, the alkali cellulose is reacted in large reactors with

                     carbon disulfide, producing sodium cellulose xanthate, which is then dissolved

                     in dilute aqueous sodium hydroxide.  That solution is known as viscose.



                     The viscose solution is then aged (ripened), during which a series of chemical

                     reactions takes place. The most important of these reactions is the splitting

                     off of carbon disulfide and the regeneration of cellulose.   These include the

                     redistribution of the carbon disulfide on the cellulose molecules and the

                     formation of small amounts of sulfur byproducts.  The viscose is filtered

                     several times and deaerated prior to spinning.  The viscose is then extruded

                     through spinnerettes,  typically containing thousands of very small holes, into

                     a spinning bath of dilute sulfuric acid, sodium sulfate, zinc sulfate, various

                     spinning aids, and water. The cellulose xanthate, in the viscose, reacts with

                     the acidic spinning bath, forming an unstable xantheic acid derivative which

                     loses carbon disulfide to yield regenerated cellulose. The carbon disulfide is

                     released from the xanthate, and the sulfur byproducts created during aging

                     react to form hydrogen sulfide.



                     After spinning  the fibers are collected together, stretched to orient the

                     cellulose molecules along the axis of the fibers, processed to remove the

                     residual chemicals from the cellulose, finished, dried, and packaged.  The

                     fibers may be cut after stretching but prior to further processing, producing

                     rayon staple (cut) fiber, or they may be processed without cutting, producing

                     rayon filament or tow (AFMA,  1997; EPA, 1993).



       ffl.B.3. Fiber Processing



                     In most cases, the extruded product from melt, dry, wet, or reaction spinning

                     is further processed  to impart particular qualities to the fibers and facilitate

                     downstream processing. Fibers can be processed as filament yarn or as staple.

                     Figure 14 illustrates general fiber processing steps.



                     After fibers have been formed, spin finish is usually applied by collecting the

                     extruded filaments on a grooved ceramic guide or rotating roller coated with

                     spin finish.  The spin finish, which includes lubricants  and finishing oils,

                     facilitates further  processing  steps  by  reducing friction and static, and

                     improving further mechanical processing (AFMA, 1997).  Mineral oils have

                     historically been used as lubricants, and organic compounds have been used

                     to reduce static. Spin finishes vary according to fiber type and are critical to

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     the processing of fibers into yarns and fabrics. Insufficient lubrication of fibers

                     can lead to strains in the fabric which may produce uneven dyeing, decreased

                     strength, or unpleasing aesthetic qualities (Grayson, 1984).

       Filament Yarn

       Staple

                     After finish is applied, a thread guide converges the individual filaments to

                     produce a continuous filament yarn that contains between 15 and 1000

                     filaments (AFMA, 1997). The spun yarn is then either immediately wound

                     onto bobbins and collected in cans or is further treated to impart special fiber

                     qualities (EPA, 1993). Filaments are typically drawn to  align and orient the

                     polymer molecules and strengthen the filament.  In melt spinning operations,

                     companies have moved towards high-speed spinning processes which combine

                     spinning and drawing operations.  Filaments may be forwarded at speeds of

                     300 to 6,000 m/min for subsequent processing. For polyester, the different

                     commercial melt-spinning processes are classified according to the degree of

                     molecular orientation in the fiber. For instance, polyester spinning processes

                     operating at speeds of 500 to 1,500 m/min give low  oriented spun yarn

                     (LOY), while processes operating at  between 4,000 and 6,000  m/min give

                     partially oriented yarn (POY) (Kroschwitz, 1986).



                     Thermoplastic fibers can be further modified by thermomechanical annealing

                     treatments, including texturing. Texturing uses curling, crimping, and tangling

                     apparatuses to give straight, rod-like filament fibers the appearance, structure,

                     and feel of natural fibers (EPA,  1995).   Filaments may be mechanically

                     distorted by compressing the fibers in a stuffing box or between rolls or by

                     false twisting, where twisting is followed by heat setting and releasing or

                     reversing the twist.  Textured yarns are either fine denier (15-200 denier) for

                     woven, knitted stretch and textured fabrics for apparel or heavy (1,000-3,600

                     denier) for carpet (McKetta, 1992). Recall that denier is the weight in grams

                     of 9,000 meters (9,846 yards) of yarn.

                     Many manmade fiber operations produce staple, or yarn that is cut into

                     specific lengths, for use by textile manufacturers.  To make staple, a tow is

                     formed by collecting thousands of continuous filaments into large rope-like

                     bundles.  These bundles are combined from all the spinning positions and

                     thrown into a large "creel can" at speeds of 1,000 to 2,000 m/min. This

                     bundle of filaments is 50,000 to 250,000 total denier, with as-spun denier

                     ranging from 2.5 to 9.0 (Dekker, 1992). The bundles are then spread out into

                     a flat band winding over the feed rolls and draw rolls of the draw machine.

                     After drawing,  the fiber may be heat set and crimped to change the tensile

                     properties.   The tow  can be shipped for further processing, or it can be

                     converted into staple-length fiber by  simply cutting it into specified lengths,

                     usually an inch to several inches long.  When manmade fibers are produced for

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                Industrial Process Description

                     blending with natural fibers, they are cut into similar lengths as the natural

                     fibers, typically  1.5-5.0 in (3.8-12.5 cm) (Kroschwitz, 1986). A baling unit

                     following the cutting machine collects and bales the cut fiber (Kent,  1992).



                     Wastes generated during fiber processing operations arise from the spin finish

                     application and drying steps (Wellman, 1997).  During processing,  fiber

                     finishes can be sources of volatile and hazardous air pollutants that may be

                     emitted into the air and into wastewater (AFMA, 1997).



       III.B.4. Supporting Operations



       Solvent Recovery



                     Solvents used in spinning processes are typically recovered by distillation.

                     Other recovery systems include gas adsorption and condensation  and are

                     specific to either fiber type or spinning method.  Dry spinning processes

                     typically use condenser or scrubbers for recovering solvent from the spin cell.

                     Distillation columns are used to recover solvent from the condenser, scrubber,

                     and wash water. Efficient solvent recovery is particularly important in dry

                     spinning  since solvent is used at three to five times the quantity of polymer.

                     Wet spinning processes typically use distillation to recover solvent from the

                     spinning  bath, drawing, and washing operations.  Scrubbers and condensers

                     are used to recover solvent emissions from the spinning cells and the dryers.

                     Carbon adsorption is used to recover emissions from storage tank vents and

                     from mixing and filtering operations (EPA, 1993). Refer to Section III. A. for

                     a more detailed discussion of pollution control equipment.

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

 III.C. Raw Material Inputs and Pollution Outputs in the Production Line



                     Raw material inputs to plastic resin and manmade fibers industries primarily

                     consist of synthetic organic chemicals, such  as  ethylene glycol  and

                     acrylonitrile, and refined petroleum products, such as ethylene. The majority

                     of these chemicals are used either as monomers or as monomer precursors.

                     Other uses are as solvents,  catalysts, and additives.  Because chemical

                     processes rarely convert  100 percent of raw materials to desired products,

                     byproducts and unreacted monomer may constitute a large part of facilities'

                     wastestreams.   Pollutant outputs generally  include VOCs, off-spec or

                     contaminated polymer, and wastewater from equipment cleaning.  Typical

                     wastestreams associated with processes involved in plastic resin and manmade

                     fiber manufacture are listed in Table 9. Wastestreams vary depending on what

                     polymer is being synthesized, what fiber spinning method is used, and whether

                     a batch or continuous process is used. Small-scale batch facilities that make

                     polymers to order often have complex and variable wastestreams (New Jersey

                     Hazardous Waste Facilities Siting Commission, 1987).

       Air Emissions

                     Over 70 percent of TRI releases for plastic resin and manmade fiber plants are

                     in the form of air emissions. Commonly released chemicals include carbon

                     disulfide, methanol and other volatile solvents and monomers.   Typical

                     chemicals released are listed in the following section on TRI releases and

                     transfers.  Air emissions from plastic resin and manmade fiber plants arise

                     from point sources and fugitive emission sources, such as valves, pumps,

                     tanks, compressors, etc. Point sources of air emissions may include monomer

                     storage and feed dissolver tanks and reactors.



                     While individual leaks are typically small, the sum of all fugitive leaks at a

                     plant can be one of its largest emission sources.  Fugitive emissions can be

                     emitted continuously  or intermittently. Continuous air emissions  may be

                     emitted from monomer recovery systems, dryer stacks and miscellaneous solid

                     handling vents, centrifuge vents, and blending operations.  Fugitive emissions

                     can also result from volatilization of monomers, solvents, and other volatile

                     organic compounds during polymerization; sublimation of solids during resin

                     production;  wastewater treatment; and volatilization  of solvents during

                     storage and  handling of resins.  These emissions are largely controlled by

                     solvent and  monomer recovery systems.  Potential VOC emission release

                     points for a  typical polymerization method are shown in Figure  16. In the

                     figure,  volatile organic compounds emitted from particular operations are

                     shown as dashed lines, and solid wastes and water wastes are shown by

                     bolded arrows.

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Plastic Resin and Manmade Fiber

               Industrial Process Description

Table 9: Summary of Potential Releases Emitted During Plastic Resin

and Manmade Fiber Manufacturing

Process

Preparing Reactants

Polymerization

Polymer Recovery

Polymer Extrusion

Equipment Cleaning

Unloading and Storage

of Reactants

Conveyance and

Pellet Storage

Spinning

Fiber Processing

Pollution Control

Systems

Air Emissions

volatilized monomer* solvents

volatilized monomer,

solvents, motion byproducts

Volatilized solvents and

uttreacted monomer

volatilized solvents and '

anreacted tnonamer ;

volatilized solvents and

uoreBeted monotner

vola^ized jaonomet and

solvents

volatilized residual monomet

or solvents from plastie

pellets

volatilized residual monomer

solvents^ additives, other

organics, volatilized fmisftes

volatilized residual monomer ;

solvents^ additive^ other

organics, volatilized finishes

volatilized solvents and

anreaeted njojiomer

Process Wastewater

little or no wastewater

produced

little or no wastewater

produced

little or no wastewater

produced

extruder quench water

reactor and floor wash water

contaminated with organics,

acids, and salts; equipment

rinse water

Rinse water from cleaning

out transport vehicles

containing solvents,

monomers, and other

reactants

little or no wastewater

produced

water contaminated with

residual monomer solvents,

additives, other organics,

finishes

water contaminated with

residual monomer, solvents,

additives, other organics

water contaminated with

residual solvents and

unreacted monomer, air

stripper water

Residual Wastes

raw material drum residuals

olf-specificatioR or

contaminated polymer,

reaction byproducts^ spent

equipment oil, spent solvent,

catalyst matrafaetote mste,

gas purification catalyst

waste

IMc or no residual waste

produced

off*spedftcBtK>n or

contaminated polymer

little or no residual waste

produced

little or no residual waste

produced

plastic pellets from leaks or

spills.

of&spefj polymer, of&speo

fiber, and residual finishes

residual monomer and

solvents; off-spec fitwrs

little or no residual waste

produced

Source: U. S, EPA, AP.-42, Office of Ait arid Radiation, 1 993 ; U.S. BPA,. Best Management Practices for

Pollution Prevention in the Textile Industry, Office of Research and Development, 1.995; SOCMA Pattntion

Prevention Study, Prepatedfbr SOCMA, Was&isgtofi, DC, 1993; Randall, P.M., "Pollution Prevention Strategies

forMiiuin&mgof Ma$trM Wastes & the Vinyl CWorid$ Monomer * Polyvbyi Chloride ladiMry," in

Environmental Progress, volume 1 3 , no. 4, November 1 994; AFMA, 1 997; Weliraan, 1 997.

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 Plastic Resin and Manmade Fiber

                  Industrial Process Description

    Figure 16: Potential Emissions from Plastic Resin Manufacturing Operations

                            Off-spec orcataniniedpjyrrer

      Manama1

      Qtolysts

        CRYER

1

DRYER



^



FEED

HN

                                                                                   AcHtives

                                           \\aercatanimledv\ilh

                                           solvKrtscrimKinias

                                                                                             . . .

                                                                                         Cortanmated

                                                                                           peUete

                                                            WASFflNSFECrFC'S

Adapted from £mw  Chemical Company's Mont Belvieu Plastics Plant Brochure; Synthetic Organic Chemical

Manufacturers Association, SOCMA Pollution Prevention Study, Prepared for SOCMA, Washington, DC, 1993; Randall,

P.M., "Pollution Prevention Strategies for Minimizing of Industrial Wastes in the Vinyl Chloride Monomer - Polyvinyl

Chloride Industry," in Environmental Progress, volume 13, no. 4, November 1994; U.S. EPA,AP-42, Office of Air and

Radiation, 1993.

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                Industrial Process Description

                     Sources of intermittent air emissions typically include unloading and charging

                     operations, reactors, safety valves, stripping towers, pumps, flanges, filters,

                     strainers,  and seals (Randall,  1994).  Fugitive emissions  can be  reduced

                     through a number of techniques, including installing leak resistant equipment

                     such as sealless pumps and bellows valves, reducing the number of tanks and

                     other potential sources, and in the case of light liquid or vapor systems,

                     implementing an ongoing leak detection and repair program (Wellman, 1997).



                     In addition to pollutants emitted during polymerization, fiber finishes are

                     sources of volatile and hazardous air pollutants emitted from manmade fiber

                     processing operations. Because melt spinning does not require the use of

                     solvents, melt spinning emits significantly less VOCs than dry or wet spinning

                     processes. Dry spinning typically emits the largest amounts of VOC per

                     pound of fiber produced of the three main spinning methods.  Dry spinning

                     can emit from 5 to 150 kg total  non-methane organic carbons (TNMOC) per

                     Mg of product, while melt spinning can emit less than 5 kg TNMOC per Mg

                     product. Wet spun fibers typically emit 5 to 20 kg TNMOC per MG product.

                     Air pollutant emissions include volatilized residual monomer, fiber lubricants,

                     organic solvents,  additives, and  other  organic compounds used in  fiber

                     processing (EPA, 1993).



                     Unrecovered solvent accounts for some of the VOC emissions from fiber

                     spinning processes, particularly for acetate production. Typically, 94 to 98

                     percent of the solvents used in fiber spinning processes is  recovered.  The

                     largest amounts of unrecovered solvent  are emitted from the fiber spinning

                     and drying steps. Other emission sources include dope preparation (dissolving

                     the polymer, blending the  spinning solution,  and filtering  the dope),  fiber

                     processing (drawing, washing, crimping), and solvent recovery.  Figure 17

                     illustrates the potential release points of VOCs in a typical fiber spinning

                     operation (EPA, 1993).  Other pollutants emitted during manufacturing

                     include air pollutants emitted during combustion. Criteria air pollutants, such

                     as SOX, NOX, CO, and CO2, are emitted from combustion equipment used to

                     heat reactors,  dryers, and other process equipment.

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 Plastic Resin and Manmade Fiber

                Industrial Process Description

            Figure 17: VOC Emissions from Fiber Processing Operations

                     MkcUp

                      Sdvot

                     Source: U.S. EPA,AP-42, Office of Air and Radiation, 1993.

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Plastic Resin and Manmade Fiber

                Industrial Process Description

       Wastewater

                     Plastic resin and manmade fiber facilities generate relatively large amounts of

                     wastewater from processes, cooling operations, utilities and maintenance, and

                     air pollution control systems. Unless  solvents are used in polymerization

                     processes, wastewater contaminants are usually restricted to off-spec polymer,

                     polymer, and raw materials (EPA,  1987).   Wastewater streams  from

                     polymerization operations typically contain dilute concentrations of organics,

                     acids, and salts. Process wastewater may be generated from water that comes

                     into direct contact with raw materials,  intermediate products,  finished

                     products, byproducts, or waste product. Process wastewater may also be

                     generated from indirect contact process water discharged from vacuum jets

                     and steam ejectors. Cooling water makes up a large portion of water used in

                     the industries  and  can  either  be generated from water that  contains

                     contaminants or from water used in noncontact processes, such as water

                     treatment wastes and boiler blowdown  (EPA,  1987).



                     Effluent containing contaminants  may  also  be discharged from batch

                     operations during equipment cleaning.  Wastes generated from  cleaning

                     operations include vessel wash waters, floor wash waters, equipment draining,

                     sump  draining,  and air stripper water effluent.  These  discharges can be

                     minimized by initiating water conservation programs and by cleaning reactors

                     using high-pressure water or process solvents which can be recycled into the

                     reactor (SOCMA, 1993).



                     Wastewater  is  also  generated  during monomer  and polymer recovery

                     processes, such as centrifuging, monomer stripping, and slurry tanks.  Process

                     sources generate liquid wastes with  relatively high  concentrations of

                     contaminants, including equipment oil, spent solvent, and raw material drum

                     residuals.  Leaks and spills also  generate waste and often occur at pumps,

                     flanges, valves,  and agitator  seals.  Loading/unloading operations and bag

                     filling operations also are common sources of leaks and spills (Randall, 1994).

                     In addition to pollutants emitted during polymerization, fiber finishes are

                     sources of volatile and hazardous pollutants found in manmade fiber plant

                     wastewater.   Spin finishes may increase biological oxygen demand (BOD)

                     and chemical oxygen demand (COD) and some may be toxic to aquatic life

                     (EPA, 1995).

       Residual Wastes

                     Residual wastes make up a significant portion of wastes from plastic resin and

                     manmade  fiber facilities.   Unless solvents are used  in  polymerization

                     processes, residual wastes are usually restricted to off-spec polymer, polymer,

                     and raw material  chemicals (EPA, 1987).  Typical  contaminants  include

                     contaminated polymer, catalyst manufacture waste, gas purification catalyst

                     waste, reaction by-products, waste oil, and general plant wastes (Clements

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     and Thompson,  1993).  Although properly run and maintained plants with

                     new technology may be capable of obtaining 95 percent or higher polymer

                     yields, off-spec and contaminated polymer is still generated and makes up a

                     sizeable  portion of the wastestream.  Unreacted  or  improperly reacted

                     polymer synthesis or regeneration residues may include monomers, oligomers,

                     metals, degradation products, solvents, and coagulants (EPA, 1995).  Other

                     sources of residual waste include cleanup absorbents,  spent activated carbon,

                     laboratory  wastes, and air pollution  control residues (SOCMA, 1993).

                     Process-related  residual waste  can be  reduced  by implementing  better

                     inventory control practices, personnel training,  and enhanced process control

                     systems. Process changes and raw material substitutions can also be used to

                     reduce residual waste pollution.



 HI.D. Pollution Control Systems



                     Recovery of raw  materials, such  as  solvents and monomers, is widely

                     practiced in the industries and is highly integrated into industrial processes as

                     a means to reduce costs  associated  with raw materials and subsequent

                     treatment of waste. During the polymer separation step, often solvent and

                     monomers are flashed from the reaction mixture. The flashed monomer and

                     solvent are then condensed into liquids using a compressor and separated

                     using vacuum distillation. Monomer and comonomer are passed through a

                     series of distillation columns to increase purity.,  These chemicals may then be

                     sent to either a monomer recovery unit or an incinerator to be burned as fuel

                     or to reduce air emissions through thermal destruction.  Wastewater can be

                     generated during monomer and  polymer recovery processes,  such  as

                     centrifuging, monomer stripping, and slurry tanks (AFMA,  1997; EPA, 1987).

                     Selected  equipment and methods  used by the industries to recover raw

                     materials and reduce air and water pollution are described below.



       Air Pollution Control Systems



                     Condensers. Condensers are widely used in the plastic  resin and manmade

                     fiber industries to recover monomers and solvents from process operations (a

                     process condenser) and as air pollution control devices to remove VOCs from

                     vented gases. Process condensers differ from condensers used as air pollution

                     control devices as the primary purpose of a process condenser is to recover

                     material as an integral part of a unit operation.  The process condenser is the

                     first condenser located after the process equipment and supports a vapor-to-

                     liquid phase change for the vapors produced in  the process equipment.

                     Examples of process  condensers  include  distillation  condensers, reflux

                     condensers, process condensers in line before the vacuum source, and process

                     condensers used in stripping or flashing operations (EPA,  1978). Vents on

                     condensers can be sources of VOC emissions.

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                Industrial Process Description

                    Adsorption.  Adsorption  is another method for removing VOCs from

                    individual process wastestreams through organic vapor recovery.   This

                    method can be used to filter out and recover solvents by passing process

                    streams through a packed column of activated carbon or any other porous

                    surface which has a microcrystalline structure.  As the gas stream passes

                    through the column, the VOCs adsorb to the column surface.  Eventually, the

                    adsorption  material  in  the column becomes  clogged  with  adsorbed

                    contaminants and must be  either regenerated or disposed (Masters,  1991;

                    EPA, 1987; CMA, 1989).



                    Scrubbers.  Scrubbers or  gas absorbers are used to remove one or more

                    constituents from a gas stream by treatment with a liquid.  When using a

                    scrubber as an air pollution control device, the solubility of the constituents

                    in the gas stream in the absorbing liquid must be determined.  The main types

                    of scrubbers are the packed tower, plate or tray tower, venturi scrubber, and

                    spray tower (EPA, 1978).



                    Combustion  or Incineration.  Another method for  controlling  VOC

                    emissions is combustion or incineration.  Although combustion systems can

                    achieve high removal efficiencies, these systems are typically more expensive

                    to install, operate, and maintain and have secondary emissions associated with

                    their operation.  Additionally, scrubbers may be required to control inorganic

                    gases produced as byproducts of combustion (EPA, 1978).



       Water Pollution Control Systems



                    Distillation. Distillation is used to separate liquids for recovery.  Two widely

                    used types of distillation are batch and continuous (or fractionation). Batch

                    distillation is used when components' vapor pressures vary widely.  In batch

                    distillation,  solvent waste is first placed inside a container where heat  is

                    applied  and  condensed  overhead  vapor  is removed  simultaneously.

                    Continuous distillation is commonly used to separate multiple fluids from a

                    wastestream and uses a column that contains multiple trays  or packing

                    materials to provide high vapor-liquid surface area. Vapors that rise to the

                    top of the heated column  are condensed and removed, while a portion  is

                    returned to the column for further  fractionation.   Lower boiling solvents

                    progressively enter the vapor, leaving a liquid with less volatile contaminants

                    at the bottom of the column (CMA,  1989).



                    Gas Stripping (Air and Steam). Stripping can be used to remove relatively

                    volatile components that are dissolved or emulsified in wastewater. This is

                    achieved through the passage of air, steam, or other gas through the liquid.

                    The  stripped  volatiles  are usually  processed  by  further recovery or

                    incineration. In air stripping processes, a liquid containing  dissolved gases

                    is brought into contact with air in a stripping tower, causing an exchange of

Sector Notebook Project

57

September 1997

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     gases between the air and the solution. If the concentrations of gases are low,

                     the gases can be emitted directly to the air.  If the concentrations are high,

                     these gases are passed to air pollution control devices.



                     In steam stripping processes, volatile components are distilled by fractionation

                     from a wastewater stream.  Steam stripping towers operate by  passing

                     preheated  wastewater  downward  through  the   distillation  column.

                     Superheated steam and organic vapors flow countercurrent to the wastewater

                     stream, rising up from the bottom of the column.  Contact between the two

                     streams progressively reduces the concentrations of VOCs in the wastewater

                     as it approaches the bottom of the column.  Reflux condensing may be used

                     to alter the composition of the vapor stream taken from the stripping column

                     (EPA,  1987).



 1II.E. Management of Chemicals in the Production Process



                     The Pollution Prevention  Act of 1990 (PPA) requires facilities to report

                     information about the management of Toxics Release  Inventory (TRI)

                     chemicals in waste and efforts made to eliminate or reduce those quantities.

                     These data have been collected annually in Section 8 of the TRI reporting

                     Form R beginning with the 1991 reporting year.  The data summarized below

                     cover the years from 1994 through 1997 and are meant to provide a basic

                     understanding of the quantities  of waste handled by the industries, the

                     methods  typically used to manage this waste, and recent trends in these

                     methods.  TRI waste management data can be used to assess trends in source

                     reduction within individual industries  and facilities,  and  for specific TRI

                     chemicals.  This information  could then be used as a tool in identifying

                     opportunities  for pollution prevention compliance assistance activities.



                     While the quantities reported for  1994 and 1995 are estimates of quantities

                     already managed, the quantities reported for 1996 and 1997 are projections

                     only. The PPA requires these projections to encourage facilities to consider

                     future waste generation and source reduction of those quantities as well as

                     movement up the waste management hierarchy.  Future-year estimates are not

                     commitments  that facilities reporting under TRI are required to meet.



                     Table 10 shows that the TRI reporting plastic resin manufacturing facilities

                     managed about 1.4 billion pounds of production related wastes (total quantity

                     of TRI chemicals in the waste from routine production operations in column

                     B) in  1995.   The yearly data  in column B indicate that plastic resin

                     manufacturing facilities  substantially lowered  the  amount of production-

                     related waste managed between 1994 and 1995. Projections for production-

                     related waste  management indicate slight increases between 1995  and 1996

                     followed by a slight decrease in 1997.  Values in column C are intended to

                     reveal the percentage of TRI chemicals that are either transferred off-site or

                     released to the environment. Column C is calculated by dividing the total TRI

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58

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Plastic Resin and Manmade Fiber

                Industrial Process Description

                    transfers and releases (reported in Sections 5 and 6 of the TRI Form R) by the

                    total  quantity of production-related waste (reported in Section 8).  The

                    percentage  of TRI  chemicals transferred  off-site or released  to the

                    environment by the plastic resin industry increased more than three fold

                    between 1994 and 1995.



                    The data indicate that about 82 percent of the TRI wastes are managed onsite

                    through recycling, energy recovery, or treatment (columns D, E, and F,

                    respectively) in 1995.  About 13 percent of the wastes were managed off-site.

                    The remaining portion of TRI chemical wastes (about 5  percent), shown in

                    column J, were released to the environment through direct discharges to air,

                    land, water, and underground injection, or were disposed off-site. The overall

                    proportions of wastes managed onsite (columns G, H,  and I) and off-site

                    (columns D, E, and F) are expected to remain relatively constant between

                    1995 and 1997.  Note that between 1994 and 1995 the proportion of waste

                    treated on-site  decreased by  12.5  percent and the proportion of waste

                    recycled on-site increased by almost  16 percent.

Table 10: Source Reduction and Recycling Activity for the Plastic Resin Industry (SIC 2821)

as Reported Within TRI

A

Year

1994

1995

1996"

1997"

B

Quantity of

Production-

Related

Waste

(10Mbs.)a

4,116

1,363

1,448

1,432

C

% Released

and

Transferred11

5.1

18.8

N/A

N/A

On-Site

D

%

Recycled

23.5

39.3

36.1

37.0

E

% Energy

Recovery

11.8

11.9

15.8

15.2

F

% Treated

43.2

30.6

27.7

28.3

Off-Site

G

%

Recycled

1.7

6.2

7.3

7.4

H

% Energy

Recovery

7.4

4.4

3.8

3.6

I

% Treated

3.7

2.6

2.1

2.0

J

% Released

and

Transferred11

8.8

5.1

7.2

6.5

Source: U.S. EPA, Toxic Release Inventory Database, 1995.

" Within this industry sector, non-production related waste < 1 % of production related wastes for 1 995.

b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related wastes.

° Percentage of production related waste released to the environment and transferred off-site for disposal.

11 Represents projected wastes for 1996 and 1997.

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 Plastic Resin and Manmade Fiber

                 Industrial Process Description

                     Table 11 shows that the TRI reporting manmade fiber manufacturing facilities

                     managed about 689 million pounds  of production related  wastes (total

                     quantity of TRI chemicals in the waste from routine production operations in

                     column  B) in 1995.  The yearly  data  in column B  indicate that fiber

                     manufacturing facilities project yearly increases in production-related waste

                     between 1994 and 1997.   Values in column C are intended to reveal the

                     percentage of TRI chemicals that are either transferred off-site or released to

                     the environment. Column C is calculated by dividing the total TRI transfers

                     and releases (reported in Sections 5 and 6 of the TRI Form R) by the total

                     quantity of production-related waste (reported in Section 8).  The percentage

                     of TRI chemicals transferred off-site or released to the environment by the

                     manmade fiber industry decreased slightly between 1994 and 1995.



                     The data indicate that about 79 percent of the TRI wastes are managed onsite

                     through recycling, energy  recovery, or treatment (columns D,  E,  and F,

                     respectively) in 1995.  About 7 percent of the wastes were managed off-site.

                     The remaining portion of TRI chemical wastes (about 14 percent), shown in

                     column J, were released to the environment through direct discharges to air,

                     land, water,  and underground injection, or were disposed off-site. The  overall

                     proportions  of wastes managed onsite (columns G, H, and I) are expected to

                     increase by 7.3 percent between 1995 and 1997.  The overall proportions of

                     wastes managed off-site (columns D, E, and F) are expected to decrease by

                     1.9 percent  between  1995 and 1997. Note that between 1995 and 1997 the

                     proportion of waste treated on-site is expected to decrease by 12.3 percent

                     and the proportion of waste recycled on-site is expected to increase by about

                     20 percent.

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Plastic Resin and Manmade Fiber

               Industrial Process Description

Table 11: Source Reduction and Recycling Activity for the Manmade Fiber Industry (SIC

2823, 2824) as Reported Within TRI

A

Year

1994

1995

1996P

1997"

B

Quantity of

Production-

Related

Waste

(10slbs.)a

634

689

814

908

C

% Released

and

Transferred13

21.0

20.8

N/A

N/A

On-Site

D

% Recycled

23.0

30.5

43.5

50.3

E

% Energy

Recovery

0.70

0.75

0.65,

0.56

F

% Treated

55.5

48.0

39.7

35.7

Off-Site

G

%

Recycled

7.6

6.2

4.8

4.3

H

% Energy

Recovery

0.50

0.23

0.13

0.13

I

% Treated

0.13

0.29

0.29

0.40

J

% Released

and

Transferred15

12.9

14.2

10.9

8.6

Source: U.S. EPA, Toxic Release Inventory Database, 1995.

a Within this industry sector, non-production related waste < 1% of production related wastes for 1 995.

b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related wastes.

0 Percentage of production related waste released to the environment and transferred off-site for disposal.

11 Represents projected wastes for 1996 and 1997.

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Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

IV. CHEMICAL RELEASE AND TRANSFER PROFILE

                    This section is designed to provide background information on the pollutant

                    releases that  are reported by this industry.  The best source of comparative

                    pollutant release information is the Toxic Release Inventory (TRI). Pursuant

                    to the Emergency Planning and Community Right-to-Know Act, TRI includes

                    self-reported facility release and transfer  data for over 600 toxic chemicals.

                    Facilities within SIC Codes 20 through 39 (manufacturing industries) that

                    have more than 10 employees, and that  are above weight-based reporting

                    thresholds are required to report TRI on-site releases and off-site transfers.

                    The information presented within the sector notebooks is derived from the

                    most recently available (1995) TRI reporting year (which includes over 600

                    chemicals), and focuses primarily on the on-site releases reported by each

                    sector.  Because TRI requires consistent  reporting regardless of sector, it is

                    an excellent tool for drawing comparisons across industries. TRI data provide

                    the type, amount and media receptor of each chemical released or transferred.



                    Although this  sector  notebook does not  present historical information

                    regarding TRI chemical releases over time, please note that in general, toxic

                    chemical releases have been declining.  In fact, according to the 1995 Toxic

                    Release Inventory Public Data Release, reported onsite releases of toxic

                    chemicals to  the environment decreased by 5 percent (85.4 million pounds)

                    between 1994 and 1995 (not including chemicals added and removed from the

                    TRI chemical list  during this period).  Reported releases  dropped by 46

                    percent between 1988 and 1995. Reported transfers of TRI chemicals to off-

                    site locations increased by 0.4 percent (11.6 million pounds) between 1994

                    and 1995.  More detailed information can be obtained from EPA's annual

                    Toxics Release Inventory Public Data  Release book (which is available

                    through the EPCRA Hotline at 800-535-0202), or directly from the Toxic

                    Release Inventory System database (for user support call 202-260-1531).



                    Wherever possible, the sector notebooks present TRI data as the primary

                    indicator  of  chemical  release within each industrial  category.  TRI  data

                    provide the type, amount and media receptor of each chemical released or

                    transferred. When other sources of pollutant release data have been obtained,

                    these data have been included to augment the TRI information.

TRI Data Limitations

                     Certain limitations exist regarding TRI data. Release and transfer reporting

                     are limited to the approximately 600 chemicals on the TRI list. Therefore, a

                     large portion of the emissions from industrial facilities are not captured by

                     TRI. Within some sectors, (e.g. dry cleaning,  printing  and transportation

                     equipment cleaning) the majority of facilities are not subject to TRI reporting

                     because they are not considered manufacturing industries, or because they are

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 Plastic Resin and Manmade Fiber

                   Release and Transfer Profile

                     below TRI reporting thresholds. For these sectors, release information from

                     other sources has been included.  In addition, many facilities report more than

                     one SIC code reflecting the multiple operations carried out onsite. Therefore,

                     reported releases and transfers may or may not all be  associated with the

                     industrial operations described in this notebook.



                     The reader should also be aware that TRI "pounds released" data  presented

                     within the notebooks is not equivalent to a "risk" ranking for each industry.

                     Weighting each pound  of release equally does not  factor in the relative

                     toxicity of each chemical that is released.  The Agency is in the process of

                     developing an approach to assign toxicological weightings to each chemical

                     released so that one can differentiate between pollutants with significant

                     differences in toxicity.  As a preliminary indicator of the environmental impact

                     of the industry's most commonly released chemicals, the notebook briefly

                     summarizes the toxicological properties of the top five chemicals (by weight)

                     reported by each industry.



 Definitions Associated With Section IV Data Tables



       General Definitions



                     SIC Code ~ the  Standard Industrial Classification  (SIC) is a  statistical

                     classification standard used for all establishment-based Federal economic

                     statistics. The SIC codes facilitate comparisons between facility and industry

                     data.



                     TRI Facilities ~ are manufacturing facilities that have 10 or more full-time

                     employees and  are  above  established  chemical throughput  thresholds.

                     Manufacturing  facilities  are defined  as  facilities in Standard Industrial

                     Classification primary codes 20-39.  Facilities must submit estimates for all

                     chemicals that are on the EPA's defined list and are above throughput

                     thresholds.



       Data Table Column Heading Definitions



                     The following definitions are based upon standard definitions developed by

                     EPA's Toxic Release Inventory Program. The categories below represent the

                     possible pollutant destinations that can be reported.



                     RELEASES  ~ are  an on-site  discharge  of a toxic chemical to  the

                     environment.  This includes emissions to the air, discharges to bodies of

                     water, releases at the facility to land, as well as contained disposal into

                     underground injection wells.

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                 Release and Transfer Profile

                    Releases  to Air (Point and Fugitive Air Emissions) — Include all air

                    emissions from industry activity.  Point emissions occur through confined air

                    streams as found in stacks, vents, ducts, or pipes. Fugitive emissions include

                    equipment leaks, evaporative losses from surface impoundments and spills,

                    and releases from building ventilation systems.



                    Releases to Water (Surface Water Discharges) ~ encompass any releases

                    going directly to streams, rivers, lakes,  oceans, or other bodies of water.

                    Releases due to runoff, including storm water runoff,  are also reportable to

                    TRI.



                    Releases  to Land ~ occur within the boundaries of the reporting facility.

                    Releases  to land include disposal  of  toxic  chemicals in landfills,  land

                    treatment/application farming, surface impoundments, and other land disposal

                    methods (such as spills, leaks, or waste piles).



                    Underground Injection -- is a contained release of a fluid into a subsurface

                    well for the purpose of waste disposal. Wastes containing TRI chemicals are

                    injected into either Class I wells or Class V wells. Class I wells are used to

                    inject liquid hazardous wastes  or  dispose  of industrial and municipal

                    wastewaters beneath the lowermost underground source of drinking water.

                    Class V wells are generally used to inject non-hazardous fluid into or above

                    an underground source of drinking water.  TRI reporting does not currently

                     distinguish between these two types of wells, although there are important

                     differences in environmental impact between these two methods of injection.



                     TRANSFERS- is a transfer of toxic chemicals in wastes to a facility that is

                     geographically or physically separate from the facility reporting under TRI.

                     Chemicals reported to TRI as transferred are sent to off-site facilities for the

                     purpose of recycling, energy recovery, treatment, or disposal. The quantities

                     reported  represent a movement of the chemical away from the reporting

                     facility. Except for off-site transfers for disposal, the  reported quantities do

                     not necessarily represent entry of the chemical into the environment.



                     Transfers to POTWs ~ are wastewaters transferred through pipes or sewers

                     to a  publicly owned treatments works (POTW).  Treatment or removal of a

                     chemical from the wastewater depends on the nature of the chemical, as well

                     as the treatment methods present at the POTW.  Not all TRI chemicals can

                     be treated or removed by a POTW. Some chemicals, such as metals, may be

                     removed, but  are not destroyed and may be disposed of in  landfills or

                     discharged to receiving waters.

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 Plastic Resin and Manmade Fiber

                   Release and Transfer Profile

                      Transfers to Recycling -- are sent off-site for the purposes of regenerating

                      or recovery by a variety of recycling methods, including solvent recovery,

                      metals recovery, and acid regeneration.  Once these chemicals have been

                      recycled, they may be returned to the originating facility or sold commercially.



                      Transfers to Energy Recovery — are wastes combusted off-site in industrial

                      furnaces for energy recovery. Treatment of a chemical by incineration is not

                      considered to be energy recovery.



                      Transfers to  Treatment ~ are wastes moved off-site to be treated through

                      a variety of methods, including  neutralization, incineration,  biological

                      destruction, or physical separation.  In some cases, the chemicals are not

                      destroyed but prepared for further waste management.



                      Transfers to Disposal ~ are wastes taken to another facility for disposal

                      generally as a release to land or as an injection underground.

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Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

IV.A. EPA Toxic Release Inventory for the Plastic Resin and Manmade Fiber Industries



                     This section summarizes  TRI  data  of plastic  resin and  manmade  fiber

                     manufacturing facilities reporting SIC  codes 2821,  2823,  or 2824 as the

                     primary SIC code for the facility.



                     According to the 1995 Toxics Release Inventory (TRI) data, 444 plastic resin

                     and manmade fiber manufacturing facilities reporting SIC 2821, 2823, or 2824

                     released (to the air, water, or land) and  transferred (shipped off-site or

                     discharged to sewers) a total of 399 million pounds of toxic chemicals during

                     calendar year 1995. This represents approximately seven percent of the 5.7

                     billion pounds of releases and transfers from all manufacturers (SICs 20-39)

                     reporting to TRI that year. The top three chemicals released by volume are

                     carbon disulfide, nitrate compounds, and ethylene. These three account for

                     about 51 percent (82 million  pounds) of the industries' total releases.

                     Ethylene glycol, used in making polyester, accounts for 45 percent  (107

                     million pounds) of the total  TRI chemicals transferred by the industries. The

                     variability in facilities' TRI  chemical profiles may be attributed to the variety

                     of processes and products in the  industries.  Note that over half of the

                     chemicals were reported by fewer than ten facilities.



Plastic Resins

       Releases

                     Table 12 presents the number and volumes of chemicals released by plastic

                     resin manufacturing facilities reporting SIC 2821 in 1995. About 410 plastic

                     resin facilities reported TRI emissions for 184 chemicals in 1995.  The total

                     volume of releases was 64.1 million pounds or 25 percent of the total volume

                     of chemicals reported to TRI by the plastic resin industry (i.e. releases and

                     transfers).  The top five chemicals released by  this  industry, in terms of

                     volumes, include: ethylene, methanol, acetonitrile, propylene, and ammonia.

                     The very volatile nature of these chemicals is apparent in the fact that about

                     74 percent (48 million pounds) of the industry's releases are to the air. About

                     49 percent (31.4 million pounds) of all the TRI  chemicals released by the

                     plastic resin industry were released to air in the form of point source

                     emissions, and 25 percent (16.3 million pounds) were released as fugitive air

                     emissions.  Roughly 21 percent (13.3 million pounds) of releases were by

                     underground injection.  The remaining five percent were released as water

                     discharges and disposals to  land.

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 Plastic Resin and Manmade Fiber

                   Release and Transfer Profile

        Transfers

Manmade Fibers

       Releases

                     Table 13 presents the number and volumes of chemicals transferred by plastic

                     resin manufacturing facilities reporting SIC 2821, in 1995.  The total volume

                     of transfers was 192 million pounds or 75 percent of the total volume of

                     chemicals reported to TRI  by the plastic resin industry  (i.e. releases and

                     transfers).   Transfers to recycling and energy recovery accounted for the

                     largest amount, 46 percent (88.5 million pounds) and 31 percent (60.2 million

                     pounds), respectively.   About  16  percent (30.5  million pounds)  was

                     transferred  off-site for treatment, with  the remaining seven percent (13.2

                     million pounds) transferred  for either disposal or POTW treatment.  Four

                     chemicals (ethylene glycol,  N-hexane, xylene (mixed isomers),  and vinyl

                     acetate) accounted for about 59 percent of the 192 million pounds of total

                     transfers for this industry.   Ethylene glycol alone accounted for about 34

                     percent (65.0 million pounds) of the total transfers and was primarily recycled.

                     Table 14 presents the number and volumes of chemicals released by manmade

                     fiber manufacturing facilities reporting SIC 2823 or 2824 in 1995.  Thirty-four

                     manmade fiber facilities reported TRI emissions for 116 chemicals in 1995.

                     The total volume of releases was 95.9 million pounds or 67 percent of the

                     total volume of TRI chemicals reported by the manmade fiber industry (i.e.

                     releases and transfers).  The top five chemicals released by this industry, in

                     terms of volumes, include: carbon disulfide, nitrate compounds, hydrochloric

                     acid, formic acid, and methanol.



                     Atypical manmade fiber facility averaged 2.8 million pounds of releases and

                     1.4 million pounds of transfers. The high release average is attributed largely

                     to the release of carbon disulfide by four facilities. Carbon disulfide, used in

                     making rayon, accounted for about 62 percent (59.5 million pounds) of TRI

                     releases for the industry.  Even eliminating carbon disulfide from the average

                     release calculation reveals that manmade fiber facilities still average about 1.1

                     million  pounds of releases per facility.   These relatively high releases and

                     transfers per facility may reflect the large volumes of material processed at a

                     relatively small number of facilities.



                     About 72 percent (69.5 million pounds) of all the chemicals released by the

                     manmade fiber industry were released  to air in the form  of point source

                     emissions, and six percent (6.3 million pounds) were released as fugitive air

                     emissions.  Roughly 19 percent (17.9 million pounds) of releases were by

                     underground injection.  The remaining three percent were released as water

                     discharges and disposals to land.

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Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

       Transfers

                    Table 15 presents  the number and volumes of chemicals transferred by

                    manmade fiber manufacturing facilities reporting SIC 2823 or 2824, in 1995.

                    The total volume of transfers off-site was 47.3 million pounds or 33 percent

                    of the total volume of chemicals reported to TRI by the manmade fiber

                    industry (i.e. releases and transfers). Transfers to recycling accounted for 90

                    percent of all transfers (42.5 million pounds).  The remaining 10 percent (4.8

                    million pounds) was transferred for disposal, treatment, energy recovery, or

                    to a POTW. Ethylene glycol accounted for about 90 percent of the industry's

                    transfers (42.5 million pounds), and was primarily recycled.

Sector Notebook Project

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 Plastic Resin and Manmade Fiber

                 Release and Transfer Profile

Sector Notebook Project

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                 Release and Transfer Profile











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Sector Notebook Project

71

September 1997

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 Plastic Resin and Manmade Fiber

                                                             Release and Transfer Profile

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76

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Sector Notebook Project

83

September 1997

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                 Release and Transfer Profile







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Sector Notebook Project

84

September 1997

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Plastic Resin and Manmade Fiber

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 Sector Notebook Project

85

September 1997

 image: 

















 Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

Sector Notebook Project

86

September 1997

 image: 

















Plastic Resin and Manmade Fiber

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Sector Notebook Project

87

September 1997

 image: 

















 Plastic Resin and Manmade Fiber

                 Release and Transfer Profile









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Sector Notebook Project

88

September 1997

 image: 

















Plastic Resin and Manmade Fiber

                Release and Transfer Profile





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 Sector Notebook Project

S9

September 1997

 image: 

















 Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

        Top 10 TRI Releasing Plastic Resin and Manmade Fiber Companies



                     The TRI database contains a detailed compilation of self-reported, facility-

                     specific chemical releases. The top reporting facilities for the plastic resin

                     manufacturing  sector and manmade fiber manufacturing sector, based on

                     pounds of TRI chemicals released, are listed in Tables 16 and 18, respectively.

                     Facilities that have reported only plastic resin SIC codes (SIC 2821) appear

                     in Table 16, and facilities that have reported only manmade fiber SIC codes

                     (SIC 2823 or 2824) appear in Table 18. Tables 17 and 19 contain additional

                     facilities that have reported plastic resin and manmade fiber SIC codes, and

                     one or more that may have also reported SIC codes that are not within the

                     scope of this notebook. Therefore, Tables 17 and  19 may include facilities

                     that conduct multiple operations ~ some that are under the scope of this

                     notebook, and some that are not.   Currently, the facility-level data do not

                     allow pollutant releases to be broken apart by industrial process.

Sector Notebook Project

90

September 1997

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Plastic Resin and Manmade Fiber

                Release and Transfer Profile

Table 16: Top 10 TRI Releasing Plastic Resin Manufacturing Facilities (SIC 2821)1

Rank

1

2

3

4

5

6

7

8

9

10

Facility

BP Chemicals Inc. - Lima, OH

Rexene Corp. - Odessa, TX

Quantum Chemical Corp. - Clinton, IA

GE Plastics Co. - Mount Vernon, IN

Du Pont - Washington, WV

Quantum Chemical Corp. - La Porte, TX

Shell Chemical Co. - Apple Grove, WV

Carolina Eastman Div. - Columbia, SC

GE Co. - Waterford, NY

Exxon Chemical Co. - Baton Rouge, LA

TOTAL

Total Releases in Pounds

13,566,795

2,558,214

2,508,685

2,344,168

2,281,027

2,225,186

1,529,579

1,487,312

1,366,735

1,365,101

31,232,802

Source: U.S. EPA, Toxics Release Inventory Database, 1995.

'Being included on this list does not mean that the releases are associated with noncompliance with environmental

laws.

Note: TRI Releases shown in this table are associated with all manufacturing activities at a facility and not just those

associated with plastic resin manufacturing activities.

Table 17: Top 10 TRI Releasing Facilities Reporting Plastic Resin Manufacturing SIC

Codes to TRI 1

Rank

1

2

3

4

5

6

7

8

9

10

SIC Codes Reported in

TRI

2821,2824,2824,2869,

2865

2821,2869

2821,2823,2869,2865,

2893

2821,2812,2813,2819,

2822, 2865

2821,2911,2869,2865

2821,2869

2821,2865,2824

2821,2611,2631 2653

2821,2869,2819

2821,2869

Facility

Monsanto Co. - Cantonment, FL

BP Chemicals Inc. - Lima, OH

Tennessee Eastman Div. - Kingsport, TN

Dow Chemical Co. - Freeport, TX

Shell Oil Co. - Deer Park, TX

Eastman Chemical Co. - Longview, TX

Du Pont - Leland, NC

Union Camp Corp. - Savannah, GA

ELF Atochem N.A. Inc. - Calvert City, KY

Celanese Eng. Resins Inc. - Bishop, TX

TOTAL

Total Releases in

Pounds

18,058,737

13,566,795

7,481,378

6,120,977

4,757,517

3,908,702

3,653,612

3,121,612

3,082,676

3,049,800

66,801,806

Source: U.S. EPA, Toxics Release Inventory Database, 1995.

'Being included on this list does not mean that the releases are associated with noncompliance with environmental

laws.

Note: TRI Releases shown in this table are associated with all manufacturing activities at a facility and not just those

associated with plastic resin manufacturing activities.

Sector Notebook Project

91

September 1997

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 Plastic Resin and Manmade Fiber

                 Release and Transfer Profile

Table 18: Top 10 TRI Releasing Manmade Fiber Manufacturing Facilities

(SIC 2823, 2824)1

Rank

I

2

3

4

5

6

7

8

9

, 10

Facility

Courtaulds Fibers Inc. - Axis, AL

Lenzing Fibers Corp. - Lowland, TN

Monsanto Co. - Cantonment, FL

Tennessee Eastman Div. - Kingsport, TN

North American Rayon Corp. - Elizabethton, TN

Monsanto Co. - Decatur, AL

Du Pont - Camden, SC

Du Pont - Seaford, DE

Hoechst Celanese Corp. - Spartanburg, SC

Hoechst Celanese Corp. - Rock Hill, SC

TOTAL

Total Releases in Pounds

34,018,200

23,231,860

18,058,737

7,481,378

2,960,770

1,580,530

1,105,503

774,488

754,912

754,174

90,720,552

Source: U.S. EPA, Toxics Release Inventory Database, 1 995.

'Being included on this list does not mean that the releases are associated with noncompliance with environmental

laws.

Note: TRI Releases shown in this table are associated with all manufacturing activities at a facility and not just those

associated with manmade fiber manufacturing activities.

Table 19: Top 10 TRI Releasing Facilities Reporting Manmade Fiber Manufacturing

SIC Codes to TRI '

Rank

1

2

3

4

5

6

7

8

9

10

SIC Codes Reported in

TRI

2823,2819

2823

2824,2869,2821,2865

2823,2821,2869,2865,

2893

2824,2865,2821

2823

2824,2821,2869

2824, 2869

2824,2821

2824,2821

Facility

Courtaulds Fibers Inc. - Axis, AL

Lenzing Fibers Corp. - Lowland, TN

Monsanto Co. - Cantonment, FL

Tennessee Eastman Div. - Kingsport, TN

Du Pont - Leland, NC

North American Rayon Corp. - Elizabethton, TN

Du Pont - Washington, WV

Monsanto Co. - Decatur, AL

Du Pont - Camden, SC

Du Pont - Seaford, DE

TOTAL

Total Releases in

Pounds

34,018,200

23,231,860

18,058,737

7,481,378

3,653,612

2,960,770

2,281,027

1,580,530

1,105,503

774,488

95,146,105

Source: U.S. EPA, Toxics Release Inventory Database, 1995.

'Efeing included on this list does not mean that the releases are associated with noncompliance with environmental

laws.

Note: TRI Releases shown in this table are associated with all manufacturing activities at a facility and not just those

associated with manmade fiber manufacturing activities.

Sector Notebook Project

92

September 1997

 image: 

















Plastic Resin and Manmade Fiber

                   Release and Transfer Profile

IV.B. Summary of Selected Chemicals Released



                      The following is a synopsis of current scientific toxicity and fate information

                      for the top chemicals (by weight) that plastic resin and manmade fiber facilities

                      released to the environment in  1995.  Ethylene  glycol is mentioned also

                      because it accounts for a large portion of the transfers for the industries.  The

                      top chemicals were selected based on TRI release data that facilities self-

                      reported. Because this section is based on self-reported release data, it does

                      not attempt to provide information on management practices employed by the

                      sector to  reduce the  release of these chemicals.  Information regarding

                      pollutant release reductions over time may be available from EPA's TRI and

                      33/50 programs, or directly from the industrial trade associations that are

                      listed in Section IX of this document.  Since these descriptions are cursory,

                      please consult the sources described  in this section, and the chemicals that

                      appear on the full list of TRI chemicals appearing in Section IV.A.



                      The  brief descriptions provided  below were taken from the 1994  Toxics

                      Release Inventory  Public Data Release  (EPA, 1995),  the Hazardous

                      Substances Data Bank (HSDB), and the Integrated Risk Information System

                      (IRIS), both accessed via TOXNET.1  The discussions of toxicity describe the

                      range of possible adverse health effects that have been found to be associated

                      with exposure to these chemicals. These adverse effects may or may not

                      occur at the levels released to the environment.  Individuals interested in a

                      more detailed picture of the chemical concentrations associated with these

                      adverse effects should consult a toxicologist or the toxicity literature for the

                      chemical to obtain more information.



              Acetonitrile (CAS: 75-05-8)



                      Sources.  Acetonitrile may be generated as a byproduct of acrylonitrile

                      manufacture and may be used as a solvent in butadiene extraction processes.



                      Toxicity.  Toxicity may be caused through ingestion, inhalation, or dermal

                      exposure.   Exposure  to acetonitrile may lead to cyanide  poisoning by

                      metabolic release of cyanide after absorption. Toxicity can be prolonged.

  TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological

databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and Health.

For more information on TOXNET, contact the TOXNET help line at 800-231-3766. Databases included in TOXNET

are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and Reproductive

Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK (Environmental Mutagen

Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS

(Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and TRI (Toxic

Chemical Release Inventory). HSDB contains chemical-specific information on manufacturing and use, chemical and

physical properties, safety and handling, toxicity and biomedical effects, pharmacology, environmental fate and exposure

potential, exposure standards and regulations, monitoring and analysis methods, and additional references.

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 Plastic Resin and Manmade Fiber

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                     Individuals exposed to slight concentrations may develop nausea, vomiting,

                     headache and lassitude.  Severely poisoned patients may develop extreme

                     weakness or lassitude, respiratory depression, shock,  coma, and seizures.

                     Pulse may become rapid, weak, and sometimes irregular. Lactic acidosis is

                     common after oral  ingestion,  as a result of the  conversion to  cyanide.

                     Chronically exposed patients may  develop  headache,  lack of appetite,

                     dizziness, weakness, and dermatitis. In one study, exposures of 40 to 160

                     ppm for four hours resulted in no symptoms or only mild symptoms.  A dose

                     of 0.006 mg of acetonitrile per kg body weight per day is expected to result

                     in no adverse effects if an individual is exposed to this dose for a lifetime.

                     This dose level was determined from a study which found decreased red blood

                     cell counts and hematocrit, and hepatic lesions in mice exposed to acetonitrile

                     for 90 days.



                     Carcinogenicity.  There is currently no long-term human or animal data to

                     suggest that this chemical is carcinogenic in humans.



                     Environmental Fate and Potential for Human Exposure.  Biodegradation

                     is likely to occur if it is released to soil.  It is also mobile in soil and may

                     evaporate from  the surface of soil.  In water, the major loss  process is

                     biodegradation.  Acetonitrile will persist in the troposphere for a long time

                     and may be transported a long distance from the source of its release. Wet

                     deposition may remove some of the atmospheric acetonitrile.



              Carbon Bisulfide (CAS: 75-15-0)



                     Sources.  Carbon disulfide is used in  a  variety of industrial applications

                     including the manufacture of regenerated cellulose rayon and cellophane, and

                     in the production of rubber.



                     Toxicity. Short-term (acute) exposure of humans to carbon disulfide can

                     cause headache, dizziness, fatigue, and irritation of eye, nose, and throat.

                     Exposure to high concentrations may result in trouble breathing or respiratory

                     failure. Contact with skin can cause severe burns.



                     Long-term (chronic) exposure to high levels in excess of regulatory standards

                     may result in peripheral nerve damage (involving the nerves that control feet,

                     legs, hands, and arms) and cardiovascular effects. A few studies contend that

                     chronic exposure may also result in potential reproductive effects.



                     Carcinogenicity.  There are no long-term human or animal data to suggest

                     that this chemical is carcinogenic in humans.



                     Environmental Fate. If released on land,  carbon disulfide will be primarily

                     lost to volatilization and it may leach into the ground where it  would be

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Plastic Resin and Manmade Fiber

                  Release and Transfer Profile

                     expected to biodegrade. The chemical will also volatilize if released to water

                     and does not adsorb to sediment. In air, carbon disulfide reacts with atomic

                     oxygen to produce hydroxyl radicals with half-lives of a few days. Carbon

                     disulfide gas is adsorbed and degraded by soil, which demonstrates that soil

                     may be a natural sink for this  chemical.  The general population may be

                     exposed to carbon disulfide primarily from ambient air as it is released not

                     only from industrial sources, but also from a wide variety of natural sources.



              Ethylene (CAS: 74-85-1)



                     Sources. Ethylene is used to make polyethylene, polypropylene, polystyrene,

                     polyester, and polyvinyl chloride resins.  Ethylene is the monomer used to

                     make high-density polyethylene, low-density polyethylene, and linear low-

                     density polyethylene.



                     Toxicity.  Ethylene has been used as an anaesthetic; the effects reported here

                     are related to its properties as  an anaesthetic.  Asphyxia may occur from

                     breathing ethylene in enclosed spaces and in cases where the atmospheric

                     oxygen has been displaced to about 15 to 16 percent or less.



                     Carcinogenicity.  According to the International Agency for Research on

                     Cancer, there is inadequate evidence in humans and animals to suggest

                     Carcinogenicity in humans.



                     Environmental Fate.  In the air,  ozone, nitrate radicals, and hydroxyl radicals

                     may degrade ethylene.  In water and soil, ethylene may be oxidized to produce

                     ethylene oxide, and the chemical may permeate soil and sediment.  The major

                     environmental fate process is volatilization.  The most probable way humans

                     are exposed  is by inhaling ethylene from contaminated air.



              Ethvlene Glvcol (CAS: 74-85-1)



                     Sources. Ethylene glycol is used to make polyethylene terephthalate (PET).

                     It is also used in the manufacture of alkyd resins and as a solvent mixture for

                     cellulose esters and ethers. Over 75 percent of ethylene glycol releases are by

                     means of point and fugitive air emissions.



                     Toxicity. Long-term inhalation exposure to low levels of ethylene glycol may

                     cause throat irritation, mild headache and backache.  Exposure to  higher

                     concentrations may lead to unconsciousness.  Liquid ethylene glycol  is

                     irritating to the eyes and skin.



                     Toxic effects from ingestion of ethylene glycol include damage to the central

                     nervous system and kidneys, intoxication, conjunctivitis, nausea and vomiting,

                     abdominal  pain,  weakness,  low  blood  oxygen, tremors,  convulsions,

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                     respiratory failure, and coma. Renal failure due to ethylene glycol poisoning

                     can lead to death.



                     Environmental Fate.  Ethylene glycol readily biodegrades in water.  No data

                     are available that report its fate in soils; however, biodegradation is probably

                     the dominant removal mechanism.   Should ethylene glycol leach into the

                     groundwater, biodegradation may occur.



                     Ethylene  glycol in water is not  expected to  bioconcentrate in aquatic

                     organisms, adsorb to sediments or volatilize.  Atmospheric ethylene glycol

                     degrades rapidly in the presence of hydroxyl radicals.



              Hydrochloric Acid (CAS: 7647-01-1)



                     Sources.    Hydrochloric acid  can be  generated  during  plastic resin

                     manufacture.



                     Toxicity.  Hydrochloric acid is primarily a concern in its aerosol form. Acid

                     aerosols have been implicated in causing and exacerbating  a variety of

                     respiratory ailments. Dermal exposure and ingestion of highly concentrated

                     hydrochloric acid  can result in corrosivity.



                     Ecologically, accidental releases of solution forms of hydrochloric acid may

                     adversely affect aquatic  life through a transient lowering of the  pH (i.e.

                     increasing the acidity)  of surface waters.



                     Carcinogenicity.  There is currently no evidence to suggest that this chemical

                     is carcinogenic.



                     Environmental Fate.  Releases of hydrochloric acid to surface waters and

                     soils will be neutralized to an extent due to the buffering capacities of both

                     systems.  The extent of these reactions will depend on the characteristics of

                     the specific environment.



                     Physical Properties. Concentrated hydrochloric acid is highly corrosive.



              Methanol (CAS: 67-56-1)



                     Sources.  Methanol can be used as a solvent  in plastic resin manufacture.

                     Methanol  is used  in some processes to make polyester,  although many

                     companies have converted to newer process methods that  do  not use

                     methanol (AFMA, 1997b).



                     Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the

                     respiratory tract, and is toxic to humans in moderate to high doses. In the

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                    body, methanol is converted into formaldehyde and formic acid. Methanol is

                    excreted as formic acid.  Observed toxic effects at high dose levels generally

                    include central nervous system damage and blindness. Long-term exposure

                    to high levels of methanol via inhalation cause liver and blood  damage in

                    animals.



                    Ecologically, methanol is expected to have low toxicity to aquatic organisms.

                    Concentrations lethal to half the organisms of a test population are expected

                    to exceed one mg methanol per liter water. Methanol is not likely to persist

                    in water or to bioaccumulate in aquatic organisms.



                    Carcinogenicity. There is currently no evidence to suggest that this chemical

                    is carcinogenic.



                    Environmental Fate.  Liquid methanol  is likely to evaporate when  left

                    exposed.  Methanol reacts in air to produce formaldehyde which contributes

                    to the formation of air pollutants. In the atmosphere it can react with other

                    atmospheric chemicals  or be washed out by rain.  Methanol  is readily

                    degraded by microorganisms in soils and surface waters.



                    Physical  Properties. Methanol is highly flammable.



IV.C. Other Data Sources



                     The toxic chemical release data obtained from TRI captures the vast majority

                     of facilities in the plastic resin and manmade fiber industries. It also allows for

                     a comparison across years  and industry sectors.  Reported chemicals  are

                     limited however to the  316 reported  chemicals. Most of the hydrocarbon

                     emissions from organic chemical facilities  are not captured by TRI. The EPA

                     Office of Air Quality Planning and Standards has compiled air pollutant

                     emission factors for determining the total air emissions of priority pollutants

                     (e.g., total hydrocarbons, SOX, NQ, CO,  particulates, etc.) from many

                     chemical  manufacturing sources.



                     The EPA Office of Air's Aerometric  Information Retrieval System (AIRS)

                     contains  a wide range  of information related to stationary  sources of air

                     pollution, including the emissions of a number of air pollutants which may be

                     of concern within a particular industry.  With the exception of volatile organic

                     compounds (VOCs), there is little overlap with the TRI  chemicals reported

                     above.  Table 20 summarizes annual releases of carbon monoxide (CO),

                     nitrogen dioxide (NOj), particulate matter of 10 microns or less (PM10), total

                     particulate (PT),  sulfur dioxide (SO2),  and volatile organic compounds

                     (VOCs).

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 Plastic Resin and Manmade Fiber

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Table 20: Air Pollutant Releases by Industry Sector (tons/year)

Industry Sector

Metal Mining

Nonmetal Mining

Lumber and Wood

Production

Furniture and Fixtures

Pulp and Paper

Printing

Inorganic Chemicals

Organic Chemicals

Petroleum Refining

Rubber and Misc. Plastics

Stone, Clay and Concrete

Iron and Steel

Nonferrous Metals

Fabricated Metals

Electronics and Computers

Motor Vehicles, Bodies,

Parts and Accessories

Dry Cleaning

Ground Transportation

Metal Casting

Pharmaceuticals

Plastic Resins and

Manmade Fibers

Textiles

Power Generation

Shipbuilding and Repair

CO

4,670

25,922

122,061

2,754

566,883

8,755

153,294

112,410

734,630

2,200

105,059

1,386,461

214,243

4,925

356

15,109

102

128,625

116,538

6,586

16,388

8,177

366,208

105

NO2

39,849

22,881

38,042

1,872

358,675

3,542

106,522

187,400

355,852

9,955

340,639

153,607

31,136

11,104

1,501

27,355

184

550,551

11,911

19,088

41,771

34,523

5,986,757

862

PM10

63,541

40,199

20,456

2,502

35,030

405

6,703

14,596

27,497

2,618

192,962

83,938

10,403

1,019

224

1,048

3

2,569

10,995

1,576

2,218

2,028

140,760

638

PT

173,566

128,661

64,650

4,827

. 111,210

1,198

34,664

16,053

36,141

5,182

662,233

87,939

24,654

2,790

385

3,699

27

5,489

20,973

4,425

7,546

9,479

464,542

943

SO2

17,690

18,000

9,401

1,538

493,313

1,684

194,153

176,115

619,775

21,720

308,534

232,347

253,538

3,169

741

20,378

155

8,417

6,513

21,311

67,546

43,050

13,827,511

3,051

voc

915

4,002

55,983

67,604

127,809

103,018

65,427

180,350

313,982

132,945

34,337

83,882

11,058

86,472

4,866

96,338

7,441

104,824

19,031

37,214

74,138

27,768

57,384

3,967

Source: U.S. EPA Office of Air and Radiation, AIRS Database, 1 997.

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IV.D. Comparison of Toxic Release Inventory Between Selected Industries



                     The following information is presented as a comparison of pollutant release

                     and transfer data across industrial categories. It is provided to give a general

                     sense as to the relative scale of releases and transfers within each  sector

                     profiled under this project. Please note that the following figure and table do

                     not contain releases and transfers for  industrial categories that are not

                     included in this project,  and  thus cannot be  used  to  draw conclusions

                     regarding the  total release and transfer amounts that are reported to TRI.

                     Similar information is available within the annual TRI Public Data Release

                     Book.



                     Figure 18 is a graphical representation of a summary of the 1995 TRI data for

                     the plastic resin and manmade fibers industries and the other sectors profiled

                     in separate notebooks. The bar graph presents the total TRI releases and total

                     transfers on the vertical axis.  The graph is based on the data shown in Table

                     21 and is meant to facilitate comparisons between the relative amounts of

                     releases, transfers, and releases per facility both within and between these

                     sectors.  The reader should note, however, that differences in the proportion

                     of facilities captured by TRI exist between industry sectors.  This can be a

                     factor of poor SIC matching and relative differences in the number of facilities

                     reporting to TRI from the various sectors.  In the case of the plastic resin and

                     manmade fiber industries, the 1995 TRI data presented here covers  469

                     facilities. Only those facilities listing SIC Codes falling within SIC 2821, 2823,

                     and 2824 were used.

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 Plastic Resin and Manmade Fiber

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       Figure 18; Summary of TRI Releases and Transfers by Industry

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Plastic Resin and Manmade Fiber

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Plastic Resin and Manmade Fiber

                         Pollution Prevention

V. POLLUTION PREVENTION OPPORTUNITIES

                     The best way to reduce pollution is to prevent it in the first place.  Some

                     companies have creatively implemented pollution prevention techniques that

                     improve efficiency and increase profits while at the same time minimizing

                     environmental impacts.  This can be done in many ways such as reducing

                     material inputs, re-engineering processes to reuse by-products, improving

                     management  practices, and  substituting benign chemicals for toxic ones.

                     Some smaller facilities are able to get below regulatory thresholds just by

                     reducing pollutant releases through aggressive pollution prevention policies.



                     The Pollution Prevention Act  of 1990  established a national policy of

                     managing waste through  source reduction, which  means  preventing the

                     generation of waste. The Pollution Prevention Act also established as national

                     policy a hierarchy of waste management options for situations in which source

                     reduction cannot  be implemented feasibly.   In the waste  management

                     hierarchy, if source reduction is not feasible the next alternative is recycling

                     of wastes, followed by energy recovery,  and waste treatment as a last

                     alternative.



                     In order to encourage these approaches, this section provides both general

                     and company-specific descriptions of some pollution prevention advances that

                     have been implemented within the plastic resin and manmade fiber industries

                     and the chemical industry as a whole. While the list is not exhaustive, it does

                     provide core information that can be used as the starting point for facilities

                     interested in starting their own pollution prevention projects.  This section

                     provides information from real activities that can, or are being implemented

                     by this sector — including a discussion of associated costs, time frames, and

                     expected rates of return.



                     This section provides summary information from activities that may be, or are

                     being implemented by this sector. When possible, information is provided that

                     gives the context in which the technique can be effectively used. Please note

                     that the activities  described in this section do not necessarily apply to all

                     facilities that fall within this sector.  Facility-specific conditions must be

                     carefully considered when pollution prevention options are evaluated, and the

                     full impacts of the change must examine how each option affects air, land and

                     water pollutant releases.



                     Substitute raw materials.  The substitution or elimination of some of the raw

                     materials used in the manufacturing of plastic resins and manmade fibers can

                     result in substantial waste reductions and cost savings. Raw materials can be

                     substituted with less water soluble materials to reduce water contamination

                     and less volatile materials to reduce fugitive emissions.  Sometimes certain

                     raw materials can be eliminated all together.  The need for raw materials that

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                      end up as wastes should be reexamined to determine if raw materials can be

                      eliminated by modifying the process and improving process control.



                      •      A specialty batch polymer plant in the Northeast avoids highly toxic and

                             hazardous substances in the facility's proprietary products and formulations.

                             The company also minimizes waste by using water-based chemistry in place

                             of organic-based chemistry wherever possible (SOCMA, 1993).



                      •      Du Pont substituted coal with butadiene in the production of nylon and

                             substituted terephthalic acid for dimethyl terephthalate in the production of

                             polyester. The substitutions eliminated generation of by-products, such as

                             liquid methanol (North Carolina Department of Environment, Health, and

                             Natural Resources, 1995).



                      •      A manmade fibers and organic chemicals manufacturer eliminated benzene

                             from its manufacturing processes.  As a result, the facility simplified its

                             compliance and recordkeeping procedures since it is no longer subject to the

                             benzene NESHAP (EPA,  1993).



                      Improve catalyst. The catalyst plays a critical role in the effectiveness of

                      chemical conversion in the reactor. Alternative catalyst chemical makeups

                      and physical characteristics can lead to  substantial improvements in the

                      effectiveness and life of a catalyst.  Different catalysts can also  eliminate

                      byproduct formation.  Using a  more active catalyst and purchasing catalysts

                      in the active form can reduce catalyst consumption and decrease emissions

                      generated during catalyst activation. Catalyst activity can also be optimized

                      by limiting catalyst residence time in the charge lines (Smith, 1964).



                      Optimize processes.  Process changes  that optimize reactions  and raw

                      materials use can reduce chemical releases.  Developing more reliable reactor

                      operations with fewer upsets can reduce air emissions and pollution from

                      unreacted reactants.  Modifications may include improved process control

                      systems, optimized use of chemicals,  or equipment modifications.  Many

                      larger facilities are using computer controlled  systems  which analyze the

                      process continuously and respond more quickly and accurately than manual

                      control systems.  These systems are often capable of automatic  startups,

                      shutdowns and product changeover which can bring the process  to stable

                      conditions quickly, minimizing the generation of off-spec wastes.  Textile fiber

                      manufacturers can optimize use of chemicals and minimize hazardous waste

                      from fiber finishes by improving control of finish add-on and selection of finish

                      components (EPA, 1995).



                      Processes  can  also  be  optimized  through  equipment  retrofits  and

                      replacements.  For instance, dedicated piping can  isolate certain types of

                      solvents from  others, avoiding offgrade product  and waste  production.

                      Equipment and process  changes can also minimize byproduct waste and

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                      improve product yield by lowering polymer conversion rate in the reactors.

                      Rationalizing the equipment used for high pressure pumping and installing

                      interlocking raw material valves to gain better recipe control can minimize

                      offgrade product (Clements and Thompson, 1993).



                      •       BP Chemicals switched from a series of programmable controllers and analog

                              controllers to a distributed control system.  The new control system has greater

                              ability to report what is occurring in the reaction tank and provides operators

                              with more opportunity to improve reaction consistency or correct  small

                              problems before they become big ones. This results in less reactor downtime

                              and off-spec product (Elley, 1991).



                      •       Du Pont's Wilmington, North Carolina polyester plant reduced its releases and

                              transfers of 33/50  chemicals by 55 percent, or more than 1 million Ib/yr

                              between 1988 and 1993.  By simplifying manufacturing processes, Du Pont

                              eliminated use of  ortho-xylene  and generation of methanol and ethylene

                              glycol by-products. This change resulted in savings of over $1 million /yr.

                              The plant also made innovative process modifications which reduced process

                              temperatures  and  VOC  emissions  (North  Carolina Department   of

                              Environment, Health, and Natural Resources, 1995).



                      •       While  increasing production in  1990 and 1991, Monsanto's  Pensacola,

                              Florida plant implemented process modifications and operational changes in

                              its nylon operations that reduced TRI releases by 74 percent and cyclohexane

                              releases by 96 percent.  The plant changed processes and reduced the amount

                              of ammonia required to neutralize nitric acid, a  by-product of  nylon

                              production.  This reduced  the amount of ammonium nitrate the company

                              disposed of in deep wells  by 18 million  pounds.  The  facility also made

                              process modifications and operational changes from 1989 to 1991 which cut

                              cyclohexane releases by 96 percent and installed a new ammonia storage tank

                              which increased safety and reduced air emissions (CMA,  1992).



                      •       Reichhold Chemicals made equipment improvements to  reduce waste from

                              product sampling.  Special canisters were permanently fixed to production

                              tanks which enabled smaller samples to be taken and later returned  to the

                              tanks.



                      •       A manmade fibers and hydrocarbon resins facility implemented four process

                              modifications to reduce waste. The plant changed to closed purge systems to

                              eliminate emissions in sampling operations, flushed pumps through equipment

                              to process vessels  to avoid discharging wastewater, optimized the wetting

                              agent amount needed for fibers to reduce oxygen demand in upstream effluent,

                              and modified procedures to require flushing of the system between product

                              grades to minimize off-grade product. These steps reduced waste generated

                              due to off-spec quality by 40 percent (Kikta, 1994).

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                      Adopt good operating practices.  Companies  can improve production

                      efficiency and  maintain low  operating costs by incorporating  pollution

                      prevention codes into their management procedures.  These codes can include

                      a written commitment by senior management to ongoing waste reduction at

                      each of the company's facilities, inclusion of pollution prevention objectives

                      in research and new facility design, or implementation of employee training

                      and incentive programs.  In addition,  establishing training programs and

                      improving recordkeeping are  other   ways that  companies  can prevent

                      pollution without  changing industrial processes.   Employee  involvement

                      groups can also be used to identify and implement waste minimization projects

                      within their operational areas, and wastes from lab, maintenance  and off-spec

                      materials can be minimized through better  housekeeping practices  and

                      personnel training (Smith, 1987), (http://es.inel.gov/techinfo/facts/cma/cma-

                      fs3.html, 7/96).



                      •      A specialty batch polymer facility established a facility-wide monetary bonus

                             program aimed at reducing waste on a monthly basis.  The company also gave

                             the reactor operator the ability  to alter production schedule and recipe

                             parameters to ensure  product quality and prevent offgrade production

                             (SOCMA, 1993).



                      •      DuPont targeted, tracked and reported tabulated wastes. Du Pont defined its

                             "tabulated waste" as RCRA-defined waste, solid waste treated or disposed of

                             on-site or off-site, waste-derived fuels, some recycled materials,  deep well

                             injection wastes, and wastewater effluents.  The company also chose an

                             environmental coordinator for each waste-generating site, established training

                             programs, and reduced waste through use of belt filters. Du Pont also saved

                             over $12.5 million by implementing a company  wide energy  efficiency

                             program.  Improvements included shutdown of spare or unneeded equipment,

                             tune-up and optimization of systems and processes, renegotiation of fuel,

                             electricity and service contracts, waste heat and condensate return, electrical

                             peak management, fuels inventory reduction, HVAC system management

                             improvements, improved steam trap maintenance program, and system or

                             process improvements (Cleenger and Hassell,1994).



                      •       At the DM Pont Kinston, North Carolina plant, lube oil waste was significantly

                             reduced through preventative maintenance programs and installation of longer-

                             life oils in certain equipment  (North Carolina Department of Environment,

                             Health, and Natural Resources, 1995).



                      Modify product.  Product modification can eliminate the use of hazardous

                      chemicals, reduce emissions from manufacturing processes, and also  decrease

                      emissions from final products. Improvements in product packaging systems

                      and materials can be used to cut back disposal of contaminated product.

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                      •       A batch specialty polymer facility has encouraged its customers to eliminate

                             the use of hazardous chemicals wherever possible in their batch specifications

                             (SOCMA, 1993).



                      •       A manmade fiber and hydrocarbon resin plant reduced product waste from

                             the mechanical failure of its sheet-forming dewatering machine. The company

                             achieved this by rectifying the inadequate design and writing better operating

                             procedures for the machine (Kikta, 1994).



                      •       PPG Industries introduced resins for industrial paints with lower VOC

                             emissions and reduced solvent waste by modifying plant  equipment and

                             processes.  Processes were modified to reformulate  resins and eliminate

                             extraneous solvents. These changes made recovery and recycle of solvent

                             easier.



                      Prevent leaks and spills. The elimination of sources of leaks and spills can

                      be a very cost effective pollution prevention opportunity. Leaks and spills can

                      be prevented by adopting a preventative maintenance program, maintaining

                      a leak detection program, and installing seamless pumps and other "leakless"

                      equipment. Vapor recovery lines can also be used to reduce monomer vapors

                      generated during polymerization and VOCs emitted during unloading of bulk

                      raw materials from tank trucks. Additionally, process water can be  used to

                      clean out unloading  vehicles and be recycled back into the processes (CMA,

                      1993).



                      •       Novacor Chemicals replaced three 100,000 gallon monomer storage tanks at

                             its Springfield, MA site and reduced VOC emissions by 8,800 Ibs/ year. The

                             new tanks are equipped with vapor recovery systems and use a nitrogen gas

                             blanket in  the  tank head space  to prevent volatilization of monomer.

                             Additionally,  the tanks  are  better equipped for fire protection and spill

                             containment (in person interview, M. Garvey, Novacor, 11/96).



                      •       At  Texas Eastman's Longview plant,  employees monitored thousands of

                             leaking valves and reduced air emissions from those valves by 99  percent,

                             through   the  development  of   new   valve   packing  materials

                             (http://es.inel.gov/studies/eastx-d.html, 7/96).



                      •       A specialty batch polymer plant initiated an intensive maintenance program

                             to improve wetting agent pump seals and installed curbs around pumps to

                             contain leaks. Refrigerant releases were also lowered by pumping equipment

                             down to very low pressure prior to maintenance (Kikta, 1994).



                      Optimize cleaning practices. Modifying equipment cleaning practices can

                      reduce wastewater discharges and reduce solvent use. Substituting cleaning

                      solvents with less toxic solvents can reduce hazardous waste generation and

                      can simplify treatment of wastewater.  Many facilities have switched from

                      using ozone-depleting chemicals to non-ozone-depleting ones.  Wastes can

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                      also be minimized by either washing out piping and transfer hoses after use or

                      by  purchasing  dedicated  hoses  for  each product loaded  into  tankers.

                      Techniques used to minimize fouling on the reactor walls include maintaining

                      a high polish on reactors, using less water-soluble and more active catalysts,

                      and using reflux condensers and water-cooled baffles.



                      •      Monsanto's Pensacola, Florida plant eliminated CFC and methyl chloroform

                             releases by substituting solvents used in its degreasing and cleaning operations

                             (CMA, 1992).  In addition, both Du Pont and Monsanto switched from

                             solvents to high-pressure water washing to clean vessels of polymer buildup.

                             This eliminated 180,000 Ibs of TRJ waste discharged annually to publicly

                             owned treatment works by  Monsanto's  Indian  Orchard   plant  in

                             Massachusetts.



                      •      Du Pont's Chambers Works plant in New Jersey reduced cleaning waste by

                             98%. The company turned to experts in waterjet engineering, used in the

                             mining industry, to design a special water lance and nozzle. This change cut

                             turnaround time and saved money (http://es.inel.gov/techinfo/facts/cma/cma-

                             fs3.html, 7/96).



               I/     Improve  inventory  management   and  storage.    Good inventory

                      management can reduce waste by preventing materials from exceeding their

                      shelf life, preventing materials from being left over or not needed,  and

                      reducing the likelihood of accidental releases of stored material.  Designating

                      a materials  storage area, limiting traffic through  the area, and giving one

                      person the responsibility to maintain  and distribute materials  can reduce

                      materials use and contamination and dispersal of materials.



                      •      At its polyethylene facility in Victoria, Australia, Commercial Polymers

                             adopted a comprehensive water conservation program.  Workers read over 20

                             water meters on a daily basis and adopted water intake minimization strategies

                             based on usage.  Water usage has been reduced by 30 percent to about 500 m3

                             per day (Clements and Thompson, 1993).



       Recycling, Recovery and Reuse



                      Although not pollution prevention as defined by the Pollution Prevention Act

                      of 1990, recovery, recycling and reuse can be effective tools for minimizing

                      pollutant  releases to the  environment. By recovering solvents  and  raw

                      materials, plastic resin and manmade fiber manufacturers can reduce pollution

                      without modifying existing processes and can reduce raw  materials costs.

                      Solvents are widely  used in  the  industries   for  activities ranging from

                      polymerization and fiber spinning to degreasing and cleaning. Raw materials

                      can  also be recycled, such as unreacted monomer,  catalyst and additives.

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                     Recover Solvents.  Capturing, purifying and recycling solvents can be an

                     effective method of reducing pollution.  Facilities can reduce TRI chemical

                     releases and save money by recycling solvents used in polymerization, fiber

                     manufacture and supporting operations. Common methods used in solvent

                     recovery are evaporation, distillation and carbon adsorption.



                     •      Hoechst installed carbon adsorption solvent recovery units to recover and

                            recycle acetone back to the acetate fiber spinning process.  Using carbon

                            adsorption, overall plant acetone recovery efficiency reaches nearly 99 percent.

                            Hoechst plans to achieve additional reductions by revamping air handling and

                            ventilation systems to improve acetone capture.



                     •      A phenol formaldehyde resin manufacturer used distillation and reuse of

                            alcohol wash liquid to reduce waste generation and off-site disposal by 67%.

                            The plant had generated 6,000 gal/yr of reactor wash solution containing 50%

                            alcohol, phenol formaldehyde resin and water. By recycling the alcohol wash

                            solution, the plant saves $15,000 annually in material and treatment costs

                            (http://es.inel.gov/studies/cs435.html, 7/96).



                     •      A specialty batch polymer plant switched to a cryogenic vapor  recovery

                            system to minimize the amount of residual solvent trapped by fibers and

                            released with downstream processing (Kikta, 1994).



                     Recover Raw  Materials.   By  capturing,  purifying and recycling  raw

                     materials,  companies can reduce pollution and raw materials costs. Many

                     companies recycle unreacted monomer back to reactor vessels. This saves

                     money by reducing monomer costs and treatment and disposal costs. Some

                     companies save money by recycling catalyst components.



                     •      Allied  Signal's  high-density polyethylene  plant  (Baton  Rouge,

                            Louisiana) implemented a chromium recovery process,  which uses an

                            ion exchange resin, to reduce the plant's hazardous catalyst waste.

                            The  company installed a chromium recovery unit  at a  cost of

                            $265,000 and saved $500,000 that year in hazardous waste disposal

                            costs.



                     •      Hoechst  Celanese  recovers Freon,  used  in  the quality  control

                            laboratories, for reuse via a glassware batch distillation system.  The

                            recovery and reuse of Freon in the laboratory has saved Celanese's

                            Greenville plant over $1,800 a year in disposal and raw material costs.

                            Contaminated  heat transfer  fluid (Dowtherm) is sent to an off-site

                            distillation facility for recovery and returned for reuse in production.

                            Recycling  of heat recovery fluid saves the  plant about $164,000 per

                            year in disposal and raw material costs.

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                      •      DuPont recycled pump out solution wastes (polymer and acid) from

                            polyarymide fiber production, saving the company disposal, treatment

                            and handling costs.



                      •      Borden Chemical Company recycled phenolic resins and modified its

                            reactor rinse procedures to reduce waste volume and toxicity. Borden

                            switched from a one-rinse system to a two-rinse system.  Previously,

                            the plant used 20,000 gallons of water to rinse the reactors. Now, the

                            reactors are first rinsed  with 500-1000 gallons of water and then

                            rinsed again.  The wastewater  from the first  rinse has  a high

                            concentration of resins, which are filtered, rinsed, and recycled back

                            into the process as raw materials.  The filtered wastewater is reused

                            for rinsing (http://es.inel.gov/studies/cs20.html, 7/96).



                      •      American Enka used an alternative two-stage precipitation process to

                            recover zinc, which is used in  the acid spinning bath process.  Zinc is

                            precipitated, treated and returned to  the spinning bath.  Zinc recycling

                            can be an economical solution that conserves limited resources and

                            reduces waste  disposal  (http://es.inel.gov/studies/hmll0053.html,

                            7/96).



       CMA 's Responsible Care® Program



                      The leaders in the plastics and manmade fibers industries, similar to those in

                      the chemical  industry as a whole, have been promoting pollution prevention

                      through various means. The most visible of these efforts is the Responsible

                      Care®  initiative  of the  Chemical  Manufacturers  Association  (CMA).

                      Responsible Care® is mandatory for CMA members who must commit to act

                      as stewards for products through use and ultimate reuse or disposal. One of

                      the guiding principles of this initiative is the inclusion of waste and release

                      prevention objectives in research and in design of new or modified facilities,

                      processes and products.



                      The following tables, Table 22 and Table 23, are adapted from the  CMA

                      "Designing Pollution Prevention into the  Process" manual.  These  tables

                      cover, in greater detail, those activities which afford the greatest opportunity

                     to utilize source reduction and/or recycle versus treatment as a way to manage

                     waste.   The  first table covers pollution prevention methods that require

                     process or product modification.  The second table describes pollution

                     prevention options that involve changes in  equipment design and operation.

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    Table 22:  Process/Product Modifications Create Pollution Prevention Opportunities

         Area

          Potential Problem

           Possible Approach

 By-products

 Co-products



 Quantity and Quality

  Uses and Outlets

• Process inefficiencies result in the

generation of undesired by-products and

co-products. Inefficiencies will require

larger volumes of raw materials and result

in additional secondary products.

Inefficiencies can also increase fugitive

emissions and wastes generated through

material handling.



• By-products and co-products are not

fully utilized, generating material or waste

that must be managed.

• Increase product yield to reduce by-

product and co-product generation and raw

material requirements.

• Identify uses and develop a sales outlet.

Collect information necessary to firm up a

purchase commitment such as minimum

quality criteria, maximum impurity levels

that can be tolerated, and performance

criteria.

 Catalysts



 Composition

 Preparation and

 Handling

• The presence of heavy metals in

catalysts can result in contaminated

process wastewater from catalyst handling

and separation. These wastes may require

special treatment and disposal procedures

or facilities.  Heavy metals can be

inhibitory or toxic to biological

wastewater treatment units. Sludge from

wastewater treatment units may be

classified as hazardous due to heavy

metals content. Heavy metals generally

exhibit low toxiciry thresholds in aquatic

environments and may bioaccumulate.



• Emissions or effluents are generated

with catalyst activation or regeneration.

                        • Catalyst attrition and carryover into

                        product requires de-ashing facilities which

                        are a likely source of wastewater and solid

                        waste.

• Catalysts comprised of noble metals,

because of their cost, are generally recycled

by both onsite and offsite reclaimers.

• Obtain catalyst in the active form.



» Provide insitu activation with appropriate

processing/activation facilities.



• Develop a more robust catalyst or support.

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      Table 22 (cont.);  Process/Product Modifications Create Pollution Prevention Opportunities

          Area

           Potential Problem

                                                                             Possible Approach

  Catalysts (cont.)



  Preparation and

  Handling (cont.)

  Effectiveness

 « Catalyst is spent and needs to be

 replaced.

                         « Pyrophoric catalyst needs to be kept

                         wet, resulting in liquid contaminated with

                         metals.



                         » Short catalyst life.

 • Catalyzed reaction has by-product

 formation, incomplete conversion and

 less-than-perfect yield.

                         « Catalyzed reaction has by-product

                         formation, incomplete conversion and

                         less-than perfect yield.

 • In situ regeneration eliminates

 unloading/loading emissions and effluents

 versus offsite regeneration or disposal.



 • Use a nonpryrophoric catalyst. Minimize

 amount of water required to handle and store

 safely.



 • Study and identify catalyst deactivation

 mechanisms.  Avoid conditions which

 promote thermal or chemical deactivation.

 By extending catalyst life, emissions and

 effluents associated with catalyst handling

 and regeneration can be reduced.



 • Reduce catalyst consumption with a more

 active form. A higher concentration of

 active ingredient or increased surface area

 can reduce catalyst loadings.



 • Use a more selective catalyst which will

 reduce the yield of undesired by-products.



 • Improve reactor mixing/contacting to

 increase catalyst effectiveness.



 • Develop a thorough understanding of

 reaction to allow optimization of reactor

 design.  Include in the optimization, catalyst

 consumption and by-product yield.	

  Intermediate

  Products



  Quantity and Quality

• Intermediate reaction products or

chemical species, including trace levels of

toxic constituents, may contribute to

process waste under both normal and

upset conditions.



• Intermediates may contain toxic

constituents or have characteristics that

are harmful to the environment.

• Modify reaction sequence to reduce

amount or change composition of

intermediates.

                                                                 • Modify reaction sequence to change

                                                                 intermediate properties.



                                                                 • Use equipment design and process control

                                                                 to reduce releases.

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     Table 22 (cont.):  Process/Product Modifications Create Pollution Prevention Opportunities

         Area

          Potential Problem

           Possible Approach

 Process Conditions/

 Configuration



 Temperature

• High heat exchange tube temperatures

cause thermal cracking/decomposition of

many chemicals.  These lower molecular

weight by-products are a source of "light

ends" and fugitive emissions. High

localized temperature gives rise to

polymerization of reactive monomers,

resulting in "heavies" or "tars." such

materials can foul heat exchange

equipment or plug fixed-bed reactors,

thereby requiring costly equipment

cleaning and production outage.

                        • Higher operating temperatures imply

                        "heat input" usually via combustion which

                        generates emissions.



                        • Heat sources such as furnaces and

                        boilers are a source of combustion

                        emissions.



                        » Vapor pressure increases with

                        increasing temperature. Loading/

                        unloading, tankage and fugitive emissions

                        generally increase with increasing vapor

                        pressure.

• Select operating temperatures at or near

ambient temperature whenever possible.



» Use lower pressure steam to lower

temperatures.



• Use intermediate exchangers to avoid

contact with furnace tubes and walls.



• Use staged heating to minimize product

degradation and unwanted side reactions.



• Use superheat of high-pressure steam in

place of furnace.



« Monitor exchanger fouling to correlate

process conditions which increase fouling,

avoid conditions which rapidly foul

exchangers.



• Use online tube cleaning technologies to

keep tube surfaces clean to increase heat

transfer.



• Use scraped wall exchangers in viscous

service.



• Use falling film reboiler, pumped

recirculation reboiler or high-flux tubes.



• Explore heat integration opportunities

(e.g., use waste heat to preheat materials and

reduce the amount of combustion required.)



• Use thermocompressor to upgrade low-

pressure steam to avoid the need for

additional boilers and furnaces.



• If possible, cool materials before sending

to storage.



» Use hot process streams to reheat feeds.

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      Table 22 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities

         Area

           Potential Problem

                                                                           Possible Approach

  Process Conditions/

  Configuration

  (cont.)



  Temperature (cont.)

  Pressure

  Coirosive

  Environment

 Batch vs. Continuous

 Operations

« Water solubility of most chemicals

increases with increasing temperature.



• Fugitive emissions from equipment.

                         • Seal leakage potential due to pressure

                         differential.



                         « Gas solubility increases with higher

                         pressures.

• Material contamination occurs from

corrosion products. Equipment failures

result in spills, leaks and increased

maintenance costs.

• Increased waste generation due to

addition of corrosion inhibitors or

neutralization.



• Vent gas lost during batch fill.

                        • Waste generated by cleaning/purging of

                        process equipment between production

                        batches.

 • Add vent condensers to recover vapors in

 storage tanks or process.



 • Add closed dome loading with vapor

 recovery condensers.



 • Use lower temperature (vacuum

 processing).



 • Equipment operating in vacuum service is

 not a source of fugitives; however, leaks into

 the process require control when  system is

 degassed.



 • Minimize operating pressure.

« Determine whether gases can be

recovered, compressed, and reused or

require controls.



• Improve metallurgy or provide coating or

lining.



• Neutralize corrosivity of materials

contacting equipment.



• Use corrosion inhibitors.



• Improve metallurgy or provide coating or

lining or operate in a less corrosive

environment.



"Equalize reactor and storage tank vent

lines.



•Recover vapors through condenser,

adsorber, etc.



• Use materials with low viscosity.

Minimize equipment roughness.

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     Table 22 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities

         Area

          Potential Problem

           Possible Approach

 Process Conditions/

 Configuration

 (cont.)



 Batch vs. Continuous

 Operations (cont.)

 Process

 Operation/Design

• Process inefficiencies lower yield and

increase emissions.



• Continuous process fugitive emissions

and waste increase over time due to

equipment failure through a lack of

maintenance between turnarounds.



• Numerous processing steps create

wastes and opportunities for errors.

                         » Nonreactant materials (solvents,

                         absorbants, etc.) create wastes. Each

                         chemical (including water) employed

                         within the process introduces additional

                         potential waste sources; the composition

                         of generated wastes also tends to become

                         more complex.



                         • High conversion with low yield results

                         in wastes.

• Optimize product manufacturing sequence

to minimize washing operations and cross-

contamination of subsequent batches.



• Sequence addition of reactants and

reagents to optimize yields and lower

emissions.



•Design facility to readily allow

maintenance so as to avoid unexpected

equipment failure and resultant release.



• Keep it simple. Make sure all operations

are necessary.  More operations and

complexity only tend to increase potential

emission and waste sources.



• Evaluate unit operation or technologies

(e.g., separation) that do not require the

addition of solvents or other nonreactant

chemicals.

                                         • Recycle operations generally improve

                                         overall use of raw materials and chemicals,

                                         thereby both increasing the yield of desired

                                         products while at the same time reducing the

                                         generation of wastes. A case-in-point is to

                                         operate at a lower conversion per reaction

                                         cycle by reducing catalyst consumption,

                                         temperature, or residence time. Many times,

                                         this can result in a higher selectivity to

                                         desired products. The net effect upon

                                         recycle of unreacted reagents is an increase

                                         in product yield, while at the same time

                                         reducing the quantities of spent catalyst and

                                         less desirable by-products.

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      Table 22 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities

          Area

           Potential Problem

                                                                             Possible Approach

  Process Conditions/

  Configuration

  (cont.)



  Process

  Opcration'Dcsign

 » Non-regenerative treatment systems

 result in increased waste versus

 regenerative systems.

 • Regenerative fixed bed treating or

 desiccant operation (e.g., aluminum oxide,

 silica, activated carbon, molecular sieves,

 etc.) will generate less quantities of solid or

 liquid waste than nonregenerative units (e.g..

 calcium chloride or activated clay). With

 regenerative units though, emissions during

 bed activation and regeneration can be

 significant. Further, side reactions  during

 activation/regeneration can give rise to

 problematic pollutants.	

  Product



  Process Chemistry

  Product Formulation

» Insufficient R&D into alternative

reaction pathways may miss pollution

opportunities such as waste reduction or

eliminating a hazardous constituent.



• Product based on end-use performance

may have undesirable environmental

impacts or use raw materials or

components that generate excessive or

hazardous wastes.

•  R&D during process conception and

laboratory studies should thoroughly

investigate alternatives in process chemistry

that affect pollution prevention.



• Reformulate products by substituting

different material or using a mixture of

individual chemicals that meet end-use

performance specifications.

  Raw Materials



  Purity

« Impurities may produce unwanted by-

products and waste.  Toxic impurities,

even in trace amounts, can make a waste

hazardous and therefore subject to strict

and costly regulation.

                         • Excessive impurities may require more

                         processing and equipment to meet product

                         specifications, increasing costs and

                         potential for fugitive emissions, leaks, and

                         spills.



                         « Specifying a purity greater than needed

                         by the process increases costs and can

                         result in more waste generation by the

                         supplier.

• Use higher purity materials.



• Purify materials before use and reuse if

practical.



• Use inhibitors to prevent side reactions.



• Achieve balance between feed purity,

processing steps, product quality and waste

generation.

                                         • .Specify a purity no greater than what the

                                         process needs.

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Plastic Resin and Manmade Fiber

                                                         Pollution Prevention

     Table 22 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities

         Area

          Potential Problem

           Possible Approach

 Raw Materials

 (cont.)



 Purity (cont.)

 Vapor Pressure

 Water Solubility

• Impurities in clean air can increase inert

purges.



• Impurities may poison catalyst

prematurely resulting in increased wastes

due to yield loss and more frequent

catalyst replacement.



• Higher vapor pressures increase fugitive

emissions in material handling and

storage.



• High vapor pressure with low odor

threshold materials can cause nuisance

odors.



• Toxic or nonbiodegradable materials

that are water soluble may affect

wastewater treatment operation,

efficiency, and cost.



• Higher solubility may increase potential

for surface and groundwater

contamination and may require more

careful spill prevention, containment, and

cleanup (SPCC) plans.



• Higher solubility may increase potential

for storm water contamination in open

areas.

                        » Process wastewater associated with

                        water washing or hydrocarbon/water

                        phase separation will be impacted by

                        containment solubility in water.

                        Appropriate wastewater treatment will be

                        impacted.

•Use pure oxygen.

                                                                 •Install guard beds to protect catalysts.

 | Use material with lower vapor pressure.

                                                                « Use materials with lower vapor pressure

                                                                and higher odor threshold.

" Use less toxic or more biodegradable

materials.

                                                                 | Use less soluble materials.

• Use less soluble materials.



« Prevent direct contact with storm water by

diking or covering areas.



• Minimize water usage.



• Reuse wash water.



• Determine optimum process conditions for

phase separation.



• Evaluate alternative separation

technologies (coalescers, membranes,

distillation, etc.)

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 Plastic Resin and Manmade Fiber

                                                          Pollution Prevention

      Table 22 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities

         Area

           Potential Problem

           Possible Approach

  Raw Materials

  (cont.)



  Toxicity

  Regulaloiy

 Form of Supply

 Handling and

 Storage

 • Community and worker safety and

 health concerns result from routine and

 nonroutine emissions. Emissions sources

 include vents, equipment leaks,

 wastewater emissions, emergency

 pressure relief, etc.

                         • Surges or higher than normal continuous

                         levels of toxic materials can shock or miss

                         wastewater biological treatment systems

                         resulting in possible fines and possible

                         toxicity in the receiving water.

« Hazardous or toxic materials are

stringently regulated. They may require

enhanced control and monitoring;

increased compliance issues and

paperwork for permits and record

keeping; stricter control for handling,

shipping, and disposal; higher sampling

and analytical costs; and increased health

and safety costs.



« Small containers increase shipping

frequency which increases chances of

material releases and waste residues from

shipping containers (including wash

waters).

• Nonreturnable containers may increase

waste.



• Physical state (solid, liquid, gaseous)

may raise unique environmental, safety,

and health issues with unloading

operations and transfer to process

equipment.

 • Use less toxic materials.



 » Reduce exposure through equipment

 design and process control. Use systems

 which are passive for emergency

 containment of toxic releases.



 • Use less toxic material.



 • Reduce spills, leaks, and upset conditions

 through equipment and process control.



 • Consider effect of chemicals on biological

 treatment; provide unit pretreatment or

 diversion capacity to remove toxicity.



 • Install surge capacity for flow and

 concentration equalization.



 • Use materials which are less toxic or

 hazardous.



 • Use better equipment and process design

 to minimize or control releases; in some

 cases, meeting certain regulatory criteria

 will exempt a system from permitting or

 other regulatory requirements.

• Use bulk supply, ship by pipeline, or use

"jumbo" drums or sacks.



• In some cases, product may be shipped out

in the same containers the material supply

was shipped in without washing.



• Use returnable shipping containers or

drums.

• Use equipment and controls appropriate to

the type of materials to control releases.

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Plastic Resin and Manmade Fiber

                        Pollution Prevention

Table 22 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities

Area

Raw Materials

(cont.)

Handling and

Storage (cont.)

Waste Streams

Quantity and Quality







Composition

Properties

Disposal

Potential Problem



• Large inventories can lead to spills,

inherent safety issues and material

expiration.



• Characteristics and sources of waste

streams are unknown.



» Wastes are generated as part of the

process.



• Hazardous or toxic constituents are

found in waste streams. Examples are:

sulfides, heavy metals, halogenated

hydrocarbons, and polynuclear aromatics.

• Environmental fate and waste properties

are not known or understood.

• Ability to treat and manage hazardous

and toxic waste unknown or limited.

Possible Approach



• Minimize inventory by utilizing just-in-

time delivery.



• Document sources and quantities of waste

streams prior to pollution prevention

assessment.

• Determine what changes in process

conditions would lower waste generation of

toxicity.

'• Determine if wastes can be recycled back

into the process.

• Evaluate whether different process

conditions, routes, or reagent chemicals

(e.g., solvent catalysts) can be substituted or

changed to reduce or eliminate hazardous or

toxic compounds.

« Evaluate waste characteristics using the

following type properties: corrosivity,

ignitability, reactivity, BTU content (energy

recovery), biodegradability, aquatic toxicity,

and bioaccumulation potential of the waste

and of its degradable products, and whether

it is a solid, liquid, or gas.

• Consider and evaluate all onsite and offsite

recycle, reuse, treatment, and disposal

options available. Determine availability of

facilities to treat or manage wastes

generated.

Source: Chemical Manufacturers Association, Designing Pollution Prevention into the Process, Research,

Development and Engineering, Washington, DC, 1993.

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 Plastic Resin and Manmade Fiber

                        Pollution Prevention

Table 23: Modifications to Equipment Can Also Prevent Pollution

Equipment

Compressors,

blowers, fans









Concivte

pads, floors,

sumps





Controls









Distillation







Potential

Environment Problem

• Shaft seal leaks, piston

rod seal leaks, and vent

streams









• Leaks to groundwater







• Shutdowns and start-

ups generate waste and

releases









• Impurities remain in

process streams







Possible Approach

Design

Related

• Seal-less designs

(diaphragmatic, hermetic or

magnetic)

» Design for low emissions

(internal balancing, double inlet,

gland eductors)

• Shaft seal designs (carbon rings,

double mechanical seals, buffered

seals)

« Double seal with barrier fluid

vented to control device

• Water stops

• Embedded metal plates

• Epoxy sealing

• Other impervious sealing

• Improve on-line controls

" On-line instrumentation

• Automatic start-up and

shutdown

• On-line vibration analysis



• Use "consensus" systems (e.g.,

shutdown trip requires 2 out of 3

affirmative responses)

• Increase reflux ratio

« Add section to column

• Column intervals

• Change feed tray

Operational

Related

• Preventive maintenance

program









• Reduce unnecessary purges,

transfers, and sampling



« Use drip pans where necessary



• Continuous versus batch

• Optimize on-line run time

• Optimize shutdown interlock

inspection frequency

• Identify safety and environment

critical instruments and

equipment



• Change column operating

conditions

- reflux ratio

- feed tray

- temperature

- pressure

- etc.

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Plastic Resin and Manmade Fiber

                       Pollution Prevention

Table 23 (cont.): Modifications to Equipment Can Also Prevent Pollution





Equipment

Distillation

(cont.)















General

manufacturing

equipment

areas































Heat

exchangers

















Potential

Environment Problem

• Impurities remain in

process streams (cont.)







• Large amounts of

contaminated water

condensate from stream

stripping

» Contaminated

rainwater











• Contaminated sprinkler

and fire water





• Leaks and emissions

during cleaning













• Increased waste due to

high localized

temperatures













Possible Approach

Design

Related

• Insulate to prevent heat loss



» Preheat column feed

• Increase vapor line size to lower

pressure drop

» Use reboilers or inert gas

stripping agents





« Provide roof over process

facilities



• Segregate process sewer from

storm sewer (diking)

• Hard-pipe process streams to

process sewer

• Seal floors



• Drain to sump

• Route to waste treatment

" Design for cleaning



• Design for minimum rinsing



• Design for minimum sludge



» Provide vapor enclosure

• Drain to process

• Use intermediate exchangers to

avoid contact with furnace tubes

and walls



• Use staged heating to minimize

product degradation and unwanted

side reactions.

(waste heat »low pressure steam

»high pressure steam)

Operational

Related

• Clean column to reduce fouling









• Use higher temperature steam







• Return samples to process





• Monitor stormwater discharge















• Use drip pans for maintenance

activities



• Rinse to sump



• Reuse cleaning solutions





• Select operating temperatures at

or near ambient temperature

when-ever possible. These are

generally most desirable from a

pollution prevention standpoint



• Use lower pressure steam to

lower temperatures



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 Plastic Resin and Manmade Fiber

                                                                Pollution Prevention

                Table 23 (cont.):  Modifications to Equipment Can Also Prevent Pollution

   Equipment

       Potential

 Environment Problem

                                                                Possible Approach

             Design

            Related

          Operational

           Related

  Heat

  exchangers

  (cont.)

« Increased waste due to

high localized

temperatures (cont.)

                 • Contaminated

                 materials due to tubes

                 leaking at tube sheets



                 « Furnace emissions

 • Use scraped wall exchangers in

 viscous service



 • Using falling film reboiler, piped

 recirculation reboiler or high-flux

 tubes



 • Use lowest pressure steam

 possible

                         • Use welded tubes or double tube

                         sheets with inert purge. Mount

                         vertically



                         • Use superheat of high-pressure

                         steam in place of a furnace	

• Monitor exchanger fouling to

correlate process conditions

which increase fouling, avoid

conditions which rapidly foul

exchangers

• Use on-line tube cleaning

techniques to keep tube surfaces

clean



• Monitor for leaks

  Piping

• Leaks to groundwater;

fugitive emissions

• Design equipment layout so as to

minimize pipe run length



• Eliminate underground piping or

design for cathodic protection if

necessary to install piping

underground



• Welded fittings



• Reduce number of flanges and

valves



• All welded pipe



• Secondary containment



• Spiral-wound gaskets



• Use plugs and double valves for

open end lines



1 Change metallurgy



1 Use lined pipe

• Monitor for corrosion and

erosion



• Paint to prevent external

corrosion

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Plastic Resin and Manmade Fiber

                        Pollution Prevention

Table 23 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment

Piping (cont.)





Pumps













Reactors



Potential

Environment Problem

• Releases when

cleaning or purging lines





• Fugitive emissions

from shaft seal leaks







• Fugitive emissions

from shaft seal leaks

• Residual "heel" of

liquid during pump

maintenance

• Injection of seal flush

fluid into process stream

« Poor conversion or

performance due to

inadequate mixing



Possible Approach

Design

Related

• Use "pigs" for cleaning

• Slope to low point drain

• Use heat tracing and insulation

to prevent freezing

• Install equalizer lines

• Mechanical seal in lieu of

packing

• Double mechanical seal with

inert barrier fluid

» Double machined seal with

barrier fluid vented to control

device

• Seal-less pump (canned motor

magnetic drive)

• Vertical pump

• Use pressure transfer to

eliminate pump

» Low point drain on pump casing

« Use double mechanical seal with

inert barrier fluid where practical

• Static mixing

• Add baffles

• Change impellers

Operational

Related

• Flush to product storage tank





• Seal installation practices

• Monitor for leaks









• Flush casing to process sewer

for treatment

• Increase the mean time between

pump failures by:

- selecting proper seal material;

- good alignment;

- reduce pipe-induced stress

- Maintaining seal lubrication



• Add ingredients with optimum

sequence



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 Plastic Resin and Manmade Fiber

                        Pollution Prevention

Table 23 (cont.): Modifications to Equipment Can Also Prevent Pollution





Equipment

Reactors

(cont.)









ReliefValve























Sampling











Tanks















Potential

Environment Problem

« Poor conversion (cont.)





• Waste by-product

formation



"Leaks

« Fugitive emissions



» Discharge to

environment from over

pressure







• Frequent relief





" Waste generation due

to sampling (disposal,

containers, leaks,

fugitives, etc.)





« Tank breathing and

working losses











Possible Approach

Design

Related

• Add horsepower



• Add distributor

• Provide separate reactor for

converting recycle streams to

usable products

« Provide upstream rupture disc

• Vent to control or recovery

device

• Pump discharges to suction of

pump



• Thermal relief to tanks

• Avoid discharge to roof areas to

prevent contamination of rainwater

« Use pilot operated relief valve

• Increase margin between design

and operating pressure

• In-line insitu analyzers



• System for return to process



• Closed loop

• Drain to sump

• Cool materials before storage



• Insulate tanks

« Vent to control device (flare,

condenser, etc.)

• Vapor balancing

« Floating roof

Operational

Related

• Allow proper head space in

reactor to enhance vortex effect



• Optimize reaction conditions

(temperature, pressure, etc.)





• Monitor for leaks and for

control efficiency

» Monitor for leaks











• Reduce operating pressure

• Review system performance



• Reduce number and size of

samples required



• Sample at the lowest possible

temperature

• Cool before sampling

• Optimize storage conditions to

reduce losses











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Plastic Resin and Manmade Fiber

                       Pollution Prevention

Table 23 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment

Tanks (cont.)

Vacuum

Systems

Valves

Vents

Potential

Environment Problem

• Tank breathing and

working losses (cont.)

• Leak to groundwater

• Large waste heel

» Waste discharge from

jets

• Fugitive emissions

from leaks

• Release to environment

Possible Approach

Design

Related

• Higher design pressure

• All aboveground (situated so

bottom can routinely be checked

for leaks)

• Secondary containment

• Improve corrosion resistance

• Design for 100% de-inventory

» Substitute mechanical vacuum

pump

• Evaluate using process fluid for

powering jet

• Bellow seals

• Reduce number where practical

• Special packing sets

• Route to control or recovery

device

Operational

Related

• Monitor for leaks and corrosion

• Recycle to process if practical

• Monitor for air leaks

• Recycle condensate to process

• Stringent adherence to packing

procedures

• Monitor performance

Source: Chemical Manufacturers Association, Designing Pollution Prevention into the Process, Research,

Development and Engineering, Washington, DC, 1993.

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Plastic Resin and Manmade Fiber

                      Statutes and Regulations

VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS



                    This section discusses the Federal regulations that may apply to this sector.

                    The purpose of this section is to highlight and briefly describe the applicable

                    Federal requirements, and to provide citations for more detailed information.

                    The three following sections are included:



                    •      Section VI. A contains a general overview of major statutes

                    •      Section VLB contains a list of regulations specific to this industry

                    •      Section VI. C contains a list of pending and proposed regulations



                    The  descriptions  within Section VI are  intended  solely  for  general

                    information.   Depending upon the nature or scope of the activities at a

                    particular facility, these summaries may or may not necessarily describe all

                    applicable environmental requirements. Moreover, they do  not constitute

                    formal interpretations or clarifications of the statutes and regulations. For

                    further information readers should consult the Code of Federal Regulations

                    and other state or local regulatory agencies. EPA Hotline contacts are also

                    provided for each major statute.

VI.A. General Description of Major Statutes



       Resource Conservation and Recovery Act



                    The Resource Conservation And Recovery Act (RCRA)  of 1976 which

                    amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and

                    hazardous (Subtitle C) waste management activities.  The  Hazardous and

                    Solid Waste Amendments (HSWA) of 1984 strengthened  RCRA's waste

                    management provisions and added Subtitle I, which governs underground

                    storage tanks (USTs).



                    Regulations promulgated pursuant to  Subtitle C of RCRA (40 CFR Parts

                    260-299) establish a "cradle-to-grave" system governing hazardous waste

                    from the point of generation to disposal.  RCRA hazardous wastes include the

                    specific materials listed  in the regulations (commercial chemical products,

                    designated with the  code "P" or "U"; hazardous wastes from  specific

                    industries/sources, designated with the code "K"; or hazardous wastes from

                    non-specific sources, designated with the code "F") or materials which exhibit

                    a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity

                    and designated with the code "D").



                    Regulated  entities  that generate hazardous waste are subject to waste

                    accumulation,  manifesting,  and record keeping  standards.  Facilities must

                    obtain a permit either from EPA or from  a State agency which EPA has

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 Plastic Resin and Manmade Fiber

                      Statutes and Regulations

                     authorized to implement the permitting program if they store hazardous

                     wastes for more than 90 days before treatment or disposal.  Facilities may

                     treat hazardous wastes stored in less-than-ninety-day tanks or containers

                     without a permit. Subtitle C permits contain general facility standards such

                     as contingency plans, emergency procedures, record keeping and reporting

                     requirements, financial assurance mechanisms, and unit-specific standards.

                     RCRA also contains provisions (40 CFR Part 264 Subpart S and §264.10) for

                     conducting  corrective actions which govern the cleanup of releases  of

                     hazardous waste or constituents from solid waste management units at

                     RCRA-regulated facilities.



                     Although RCRA is  a Federal  statute, many States implement the RCRA

                     program.  Currently, EPA has delegated its authority to implement various

                     provisions of RCRA to 47 of the  50 States and two  U.S.  territories.

                     Delegation has not been given to Alaska, Hawaii, or Iowa.



                     Most RCRA requirements are not industry specific but apply to any company

                     that generates, transports, treats, stores, or disposes of hazardous waste.

                     Here are some important RCRA regulatory requirements:



                     •      Identification of Solid and Hazardous Wastes (40 CFR Part 261)

                           lays out the  procedure every generator must follow to determine

                           whether the material in question is considered a hazardous waste,

                           solid waste, or is exempted from regulation.



                           Standards for Generators of Hazardous Waste (40 CFR Part 262)

                           establishes the responsibilities of hazardous waste generators including

                           obtaining an EPA ED number, preparing a manifest, ensuring proper

                           packaging and labeling, meeting standards for waste accumulation

                           units, and recordkeeping and reporting requirements. Generators can

                           accumulate hazardous waste for up to 90 days (or 180 days depending

                           on the amount of waste generated) without obtaining a permit.



                     •      Land  Disposal Restrictions (LDRs)  (40  CFR Part 268) are

                           regulations prohibiting  the disposal of hazardous waste  on land

                           without prior treatment.  Under the LDRs program, materials must

                           meet LDR treatment standards prior to placement in a RCRA land

                           disposal  unit (landfill, land treatment unit,  waste pile, or surface

                           impoundment). Generators of waste subject to the LDRs must provide

                           notification of such to the designated TSD facility to ensure proper

                           treatment prior to disposal.



                     •      Used Oil Management  Standards  (40  CFR Part 279) impose

                           management  requirements  affecting  the  storage, transportation,

                           burning, processing, and re-refining of the used oil. For parties that

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                     Statutes and Regulations

                           merely generate used oil, regulations establish storage standards. For

                           a party considered a used oil processor, re-refiner, burner, or marketer

                           (one who generates and-sells off-specification used oil), additional

                           tracking and paperwork requirements must be satisfied.



                    •      RCRA contains unit-specific standards for all units used to store,

                           treat, or  dispose  of hazardous  waste, including Tanks  and

                           Containers.  Tanks and containers used to store hazardous waste

                           with  a  high  volatile organic concentration must meet emission

                           standards under RCRA. Regulations (40 CFR Part 264-265, Subpart

                           CC)  require  generators  to  test  the  waste  to  determine the

                           concentration of the waste, to satisfy tank and container emissions

                           standards,  and to inspect and  monitor regulated  units.   These

                           regulations apply to all facilities that store such waste, including large

                           quantity generators accumulating waste prior to shipment off-site.



                    •      Underground Storage Tanks (USTs) containing petroleum and

                           hazardous  substances are regulated under  Subtitle I  of RCRA.

                           Subtitle I regulations (40 CFR Part 280) contain tank design and

                           release detection requirements, as well as financial responsibility and

                           corrective  action  standards for USTs.  The  UST program also

                           includes upgrade requirements for existing tanks that must be met by

                           December 22, 1998.



                    •      Boilers  and  Industrial Furnaces (BIFs) that use or burn fuel

                           containing hazardous waste must comply with design and operating

                           standards.  BIF regulations (40 CFR Part 266, Subpart H) address

                           unit  design,  provide performance  standards,  require emissions

                           monitoring, and restrict the type of waste that may be burned.



                    EPA'sRCRA, Superfund and EPCRA Hotline,  at (800) 424-9346, responds

                    to questions and distributes guidance regarding all RCRA regulations. The

                    RCRA Hotline operates weekdays from 9:00 am. to 6:00 p.m., ET, excluding

                    Federal holidays.



       Comprehensive Environmental Response, Compensation, and Liability Act



                    The Comprehensive Environmental Response,  Compensation, and Liability

                    Act (CERCLA), a 1980 law known commonly as Superfund., authorizes EPA

                    to respond to releases, or threatened releases, of hazardous substances that

                    may endanger public health, welfare, or the environment.   CERCLA also

                    enables EPA to force parties responsible for environmental contamination to

                    clean it up or to reimburse the Superfund for response costs incurred by EPA.

                    The Superfund Amendments and Reauthorization  Act (SARA) of 1986

                    revised various sections of CERCLA, extended the taxing authority for the

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 Plastic Resin and Manmade Fiber

                     Statutes and Regulations

                    Superfund, and created a free-standing law, SARA Title HI, also known as the

                    Emergency Planning and Community Right-to-Know Act (EPCRA).



                    The CERCLA hazardous substance release reporting regulations (40 CFR

                    Part 302) direct the person in charge of a facility to report to the National

                    Response Center (NRC) any environmental release of a hazardous substance

                    which equals or exceeds a reportable quantity. Reportable quantities are listed

                    in 40 CFR §302.4.  A release report may trigger a response by EPA, or by one

                    or more Federal or State emergency response authorities.



                    EPA implements hazardous substance responses according to procedures

                    outlined in the National Oil and Hazardous Substances Pollution Contingency

                    Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent

                    cleanups, known as remedial actions, and other cleanups  referred to as

                    removals. EPA generally takes remedial actions only at sites on the National

                    Priorities List  (NPL), which currently includes approximately 1300 sites.

                    Both EPA  and states can act at sites; however, EPA provides responsible

                    parties the opportunity to  conduct  removal and  remedial actions  and

                    encourages community involvement throughout the Superfund response

                    process.



                    EPA'sRCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers

                    questions and references guidance pertaining to the Superfund program.

                    The CERCLA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m.,  ET,

                    excluding Federal holidays.



       Emergency Planning And Community Right-To-Know Act  .



                    The Superfund Amendments and Reauthorization Act (SARA) of 1986

                    created  the Emergency  Planning and Community Right-to-Know  Act

                    (EPCRA, also known as SARA Title III), a statute designed to improve

                    community access to information about chemical hazards and to facilitate the

                    development of chemical  emergency response plans by  State and local

                    governments.  EPCRA required the  establishment of State emergency

                    response commissions (SERCs),  responsible  for coordinating certain

                    emergency response activities and for appointing local emergency planning

                    committees (LEPCs).



                    EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four

                    types of reporting obligations for facilities which store or manage specified

                    chemicals:



                          EPCRA §302 requires facilities to notify the SERC and LEPC of the

                          presence of any extremely hazardous substance (the list of such

                          substances is in 40 CFR Part 355, Appendices A and B) if it has such

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Plastic Resin and Manmade Fiber

                     Statutes and Regulations

                           substance in excess of the substance's threshold planning quantity, and

                           directs the facility to appoint an emergency response coordinator.



                    •      EPCRA §304 requires the facility to notify the SERC and the LEPC

                           in the event of a release equaling or exceeding the reportable quantity

                           of a CERCLA hazardous  substance  or  an EPCRA extremely

                           hazardous substance.



                    •      EPCRA §311 and §312  require a facility at which a hazardous

                           chemical, as defined by the Occupational Safety and Health Act, is

                           present in an amount exceeding a specified threshold to submit to the

                           SERC, LEPC and local fire department material safety data sheets

                           (MSDSs) or lists of MSDS's and hazardous chemical inventory forms

                           (also known as Tier I and II forms).  This information helps the local

                           government respond in the event of a spill or release of the chemical.



                    •      EPCRA §313 requires manufacturing facilities included in SIC codes

                           20 through 39,  which have ten or more employees, and which

                           manufacture, process, or use specified chemicals in amounts greater

                           than threshold quantities, to submit an annual toxic chemical release

                           report. This report, known commonly as the Form R, covers releases

                           and transfers of toxic chemicals to various facilities and environmental

                           media, and  allows EPA to compile the national Toxic Release

                           Inventory (TRI) database.



                    All information submitted pursuant to EPCRA  regulations is publicly

                    accessible, unless protected by a trade secret claim.



                    EPA'sRCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers

                    questions and distributes guidance regarding the emergency planning and

                    community  right-to-know regulations.   The  EPCRA  Hotline operates

                    "weekdays from 9:00 a.m. to 6:00 p.m., ET, excluding Federal holidays.

       Clean Water Act

                    The primary objective of the Federal Water Pollution Control Act, commonly

                    referred to as the Clean Water Act (CWA), is to restore and maintain the

                    chemical, physical, and biological integrity of the nation's surface waters.

                    Pollutants regulated under the CWA include "priority" pollutants, including

                    various toxic pollutants; "conventional"  pollutants, such as biochemical

                    oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and

                    grease, and pH; and "non-conventional" pollutants, including any pollutant not

                    identified as either conventional or priority.

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                     The CWA regulates both direct and indirect discharges.  The National

                     Pollutant Discharge Elimination  System (NPDES) program (CWA §502)

                     controls direct discharges into navigable waters. Direct discharges or "point

                     source" discharges are from sources such as pipes and sewers.  NPDES

                     permits, issued by either EPA or an authorized State (EPA has authorized 42

                     States to  administer  the NPDES  program),  contain industry-specific,

                     technology-based and/or water quality-based limits, and establish pollutant

                     monitoring requirements.  A facility that intends to discharge into the nation's

                     waters must  obtain a permit prior  to  initiating its discharge.  A permit

                     applicant must provide quantitative analytical data identifying the types of

                     pollutants present in the facility's effluent.   The permit will  then set the

                     conditions and effluent limitations on the facility discharges.



                     A NPDES permit may also include discharge limits based on Federal or State

                     water quality criteria or standards, that were designed to protect designated

                     uses of surface waters, such as supporting aquatic life or recreation. These

                     standards, unlike the technological standards, generally do not take into

                     account technological feasibility or costs. Water quality criteria and standards

                     vary from State to State, and site to site, depending on the use classification

                     of the receiving body of water.  Most States follow EPA guidelines which

                     propose aquatic life and human health criteria for many of the 126 priority

                     pollutants.



                     Storm Water Discharges



                     In 1987 the CWA was amended to require EPA to establish a program to

                     address storm water discharges.  In response, EPA promulgated the NPDES

                     storm  water permit application regulations.  These regulations require that

                     facilities  with the following storm water discharges apply for an NPDES

                     permit: (1) a discharge associated with industrial  activity; (2) a discharge

                     from a large or medium municipal storm sewer system; or (3) a discharge

                     which  EPA or the State determines to contribute to a violation of a water

                     quality standard or is a significant contributor of pollutants to waters of the

                     United States.



                     The term "storm water discharge associated with industrial activity" means a

                     storm water discharge from one of 11 categories of industrial activity defined

                     at 40 CFR 122.26. Six of the categories are defined by SIC codes while the

                     other five are identified through narrative descriptions of the regulated

                     industrial activity.  If the primary SIC code of the facility is one of those

                     identified in the regulations, the facility is subject to the storm water permit

                     application requirements.  If any activity at a facility is covered by one of the

                     five narrative categories, storm water discharges from those areas where the

                     activities occur are subject to storm water discharge  permit application

                     requirements.

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                     Those facilities/activities that are subject to storm water discharge permit

                     application requirements are identified below.  To determine whether a

                     particular facility falls within one of these categories, consult the regulation.



                     Category i: Facilities subject to storm water effluent guidelines, new source

                     performance standards, or toxic pollutant effluent standards.



                     Category ii:   Facilities classified as SIC  24-lumber and wood products

                     (except wood kitchen cabinets); SIC 26-paper and allied products (except

                     paperboard containers and products); SIC 28-chemicals and allied products

                     (except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather

                     tanning  and finishing, 32 (except 323)-stone, clay, glass, and concrete, 33-

                     primary metals, 3441-fabricated structural metal,  and 373-ship and boat

                     building and repairing.



                     Category iii:  Facilities  classified as  SIC 10-metal mining; SIC  12-coal

                     mining; SIC 13-oil and gas extraction; and  SIC 14-nonmetailic  mineral

                     mining.



                     Category iv:  Hazardous waste treatment, storage, or disposal facilities.



                     Category v: Landfills, land application sites, and open dumps that receive or

                     have received industrial wastes.



                     Category vi:  Facilities classified as SIC 5015-used motor vehicle parts; and

                     SIC 5093-automotive scrap and waste material recycling facilities.



                     Category vii:  Steam electric power generating facilities.



                     Category viii: Facilities classified as SIC 40-railroad transportation;  SIC 41-

                     local  passenger transportation; SIC 42-trucking and warehousing (except

                     public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water

                     transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk

                     storage stations and terminals.



                     Category ix:  Sewage treatment works.



                     Category x:  Construction activities except  operations  that result in the

                     disturbance of less than five acres of total land area.



                     Category xi:  Facilities classified as SIC 20-food and kindred products; SIC

                     21-tobacco products; SIC 22-textile mill products;  SIC 23-apparel related

                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture

                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted

                     paper and paperboard products;  SIC 27-printing, publishing, and  allied

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                      industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and

                      allied products;  SIC  30-rubber and plastics; SIC  31-leather and leather

                      products (except leather and tanning and finishing); SIC 3 23-glass products;

                      SIC 34-fabricated metal products (except fabricated structural metal); SIC

                      35-industrial and commercial machinery and computer equipment; SIC 36-

                      electronic  and  other  electrical  equipment  and components;  SIC 37-

                      transportation equipment (except ship and boat building and repairing); SIC

                      38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous

                      manufacturing industries; and  SIC  4221-4225-public warehousing and

                      storage.



                      Pretreatment Program



                      Another type of discharge that is regulated by the CWA is one that goes to

                      a publicly-owned treatment works (POTWs).  The national  pretreatment

                      program (CWA §307(b)) controls the indirect discharge of pollutants to

                      POTWs by "industrial users."  Facilities regulated under §307(b) must meet

                      certain pretreatment standards. The goal of the pretreatment program is to

                      protect municipal wastewater treatment plants from damage that may occur

                      when hazardous, toxic, or other wastes are discharged into a sewer system

                      and to protect the quality of sludge generated by these plants. Discharges to

                      a POTW are regulated primarily by the POTW itself, rather than the State or

                     EPA.



                     EPA has developed technology-based standards for  industrial  users  of

                     POTWs.  Different standards apply to existing and new sources within each

                     category. "Categorical" pretreatment standards applicable to an industry on

                     a nationwide basis are developed by EPA.  In addition,  another kind of

                     pretreatment standard, "local limits," are developed by the POTW in order to

                     assist the POTW in achieving the effluent limitations in its NPDES permit.



                     Regardless of whether a State is authorized to implement either the NPDES

                     or the pretreatment program, if it develops its own program, it may enforce

                     requirements more stringent than Federal standards.



                     Spill Prevention.  Control and Countermeasure Plans



                     The 1990 Oil Pollution Act requires that facilities that could reasonably be

                     expected to discharge oil in harmful quantities prepare and implement more

                     rigorous Spill Prevention Control and Countermeasure (SPCC) Plan required

                     under the CWA (40 CFR § 112.7). There are also criminal and civil penalties

                     for deliberate or negligent spills of oil.  Regulations covering response to oil

                     discharges and contingency plans (40 CFR Part 300), and Facility Response

                     Plans to oil discharges (40 CFR §112.20) and for PCB transformers and PCB-

                     containing items were revised and finalized in 1995.

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                    EPA's Office of Water, at (202) 260-5700, will direct callers with questions

                    about the  CWA to the appropriate EPA office.  EPA also maintains a

                    bibliographic  database of Office of Water publications which can  be

                    accessed through the Ground Water and Drinking Water resource center, at

                    (202) 260-7786.



       Safe Drinking Water Act



                    The  Safe  Drinking  Water Act (SDWA) mandates that EPA establish

                    regulations to protect human health from contaminants in drinking water.

                    The law authorizes EPA to develop national drinking water standards and to

                    create a joint Federal-State system to ensure compliance with these standards.

                    The SDWA also directs EPA to protect underground sources of drinking

                    water through the control of underground injection of liquid wastes.



                    EPA has developed primary and secondary drinking water standards under its

                    SDWA authority.  EPA and authorized States enforce the primary drinking

                    water standards, which are, contaminant-specific concentration limits that

                    apply to certain public drinking water supplies.   Primary drinking water

                    standards consist of maximum contaminant level goals (MCLGs), which are

                    non-enforceable health-based goals,  and maximum contaminant  levels

                    (MCLs), which are enforceable limits set as  close to MCLGs as possible,

                    considering cost and feasibility of attainment.



                    The SDWA Underground Injection Control (UIC) program (40 CFR Parts

                    144-148) is a permit program which protects underground sources of drinking

                    water by regulating five classes of injection wells.  UIC permits include

                    design, operating,  inspection,  and monitoring requirements.  Wells used to

                    inject hazardous wastes must also comply with RCRA corrective action

                    standards in order  to be granted a RCRA permit, and must meet applicable

                    RCRA land disposal restrictions standards.  The  UIC permit program is

                    primarily State-enforced, since EPA has authorized all but a few States to

                    administer the program.



                    The SDWA also provides for a Federally-implemented Sole Source Aquifer

                    program, which prohibits Federal funds from being expended on projects that

                    may contaminate the sole or principal source of drinking water for a given

                    area, and for a State-implemented Wellhead Protection program, designed to

                    protect drinking water wells and drinking water recharge areas.



                    EPA 's Safe Drinking Water Hotline, at (800) 426-4791, answers questions

                    and distributes guidance pertaining to SDWA standards.   The Hotline

                    operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.

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        Toxic Substances Control Act

                     The Toxic Substances Control Act (TSCA) granted EPA authority to create

                     a regulatory framework to collect data on chemicals in order to evaluate,

                     assess, mitigate, and control risks which may be posed by their manufacture,

                     processing, and use. TSCA provides a variety of control methods to prevent

                     chemicals from posing unreasonable risk.



                     TSCA standards may apply at any point during a chemical's life cycle.  Under

                     TSCA §5, EPA has established  an inventory of chemical substances.  If a

                     chemical is not already on the inventory, and has not been excluded by TSCA,

                     a premanufacture notice (PMN)  must  be submitted to  EPA  prior to

                     manufacture or import.  The PMN must identify the chemical and provide

                     available information on health and environmental effects. If available data

                     are  not  sufficient to evaluate  the chemicals effects, EPA can  impose

                     restrictions  pending the development  of information on  its health  and

                     environmental effects. EPA can also restrict significant new uses of chemicals

                     based upon factors such as the projected volume and use of the chemical.



                     Under TSCA §6, EPA can ban the manufacture or distribution in commerce,

                     limit the  use, require labeling, or place other restrictions on chemicals that

                     pose unreasonable risks.  Among the chemicals EPA regulates  under §6

                     authority are asbestos,  chlorofluorocarbons (CFCs), and polychlorinated

                     biphenyls (PCBs).



                     EPA's TSCA Assistance Information Service, at (202) 554-1404,  answers

                     questions and distributes guidance pertaining to Toxic Substances Control

                     Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,

                     excluding Federal holidays.

       Clean Air Act

                    The Clean Air Act (CAA) and its amendments, including the Clean Air Act

                    Amendments (CAAA) of 1990, are designed to "protect and enhance the

                    nation's air resources so as to promote the public health and welfare and the

                    productive capacity of the population." The CAA consists of six sections,

                    known as Titles, which direct EPA to establish national standards for ambient

                    air quality and for EPA and the States to implement, maintain, and enforce

                    these standards through a variety of mechanisms.  Under the CAAA, many

                    facilities will be required to obtain permits for the first time.  State and local

                    governments oversee, manage, and enforce many of the requirements of the

                    CAAA.  CAA regulations appear at 40 CFR Parts 50-99.



                    Pursuant to Title I of the CAA, EPA has established  national ambient air

                    quality standards (NAAQSs) to limit levels of "criteria pollutants," including

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                    carbon monoxide, lead, nitrogen dioxide, particulate matter, volatile organic

                    compounds (VOCs), ozone, and sulfur dioxide. Geographic areas that meet

                    NAAQSs for a given pollutant are classified as attainment areas; those that do

                    not meet NAAQSs are classified as non-attainment areas.  Under section 110

                    of the CAA, each State must develop a State Implementation Plan (SIP) to

                    identify sources of air pollution and to determine what reductions are required

                    to meet Federal air quality standards. Revised NAAQSs for particulates and

                    ozone were proposed in 1996 and may go into effect as early as late 1997.



                    Title I also authorizes EPA to establish New Source Performance Standards

                    (NSPSs), which are nationally uniform emission standards for new stationary

                    sources falling within particular industrial categories. NSPSs are based on the

                    pollution control technology available to that category of industrial source.



                    Under Title I, EPA establishes and enforces National Emission Standards for

                    Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented

                    towards controlling particular  hazardous air pollutants (HAPs).  Title  I,

                    section 112(c) of the  CAA further directed EPA to develop a list of sources

                    that emit any of 189 HAPs, and to develop regulations for these categories of

                    sources.  To date EPA has listed  174 categories and developed a schedule for

                    the  establishment  of emission standards.  The  emission standards will be

                    developed for both new and existing sources based on "maximum achievable

                    control  technology"  (MACT).   The MACT  is defined as the control

                    technology achieving the maximum degree of reduction in the emission of the

                    HAPs, taking into account cost and other factors.



                    Title II of the CAA pertains to mobile sources,  such as cars, trucks, buses,

                    and planes. Reformulated gasoline, automobile pollution control devices, and

                    vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses

                    to regulate mobile air emission sources.



                    Title IV of the CAA establishes a sulfur dioxide nitrous  oxide emissions

                    program designed to reduce the formation of acid rain. Reduction of sulfur

                    dioxide  releases will be obtained by granting  to  certain sources  limited

                    emissions allowances, which, beginning in 1995, will be set below previous

                    levels of sulfur dioxide releases.



                    Title V of the CAA of 1990 created a permit program for all "major sources"

                    (and certain other sources)  regulated under the CAA. One purpose of the

                    operating  permit  is  to include in a  single document all  air emissions

                    requirements that apply to a given facility.  States are developing the permit

                    programs in accordance with guidance and regulations from EPA. Once a

                    State program is approved by EPA, permits will  be issued and monitored by

                    that State.

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                     Title VI of the CAA is intended to protect stratospheric ozone by phasing out

                     the manufacture  of ozone-depleting  chemicals and restrict their use and

                     distribution.   Production of Class I substances, including  15  kinds  of

                     chlorofluorocarbons (CFCs) and chloroform, were phased out (except for

                     essential uses) in 1996.



                     EPA's Clean Air  Technology Center,  at (919) 541-0800, provides general

                     assistance and information on CAA standards.  The Stratospheric Ozone

                     Information Hotline, at (800) 296-1996, provides general information about

                     regulations promulgated under Title VI of the CAA, and EPA's EPCRA

                     Hotline,  at (800) 535-0202, answers questions about accidental release

                     prevention under CAA  §112(r).  In  addition, the Clean Air Technology

                     Center's website includes recent CAA  rules, EPA guidance documents, and

                     updates of EPA activities (www.epa.gov/ttn then select Directory and then

                     CATC).

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VLB. Industry Specific Requirements

                    The plastic resin and manmade fiber industries are affected by nearly all

                    federal environmental statutes.  In addition, the industries are subject to

                    numerous laws and regulations from state and local governments designed to

                    protect and improve the nation's health, safety, and environment.  A summary

                    of the major federal regulations affecting the plastic resin and manmade fiber

                    industry follows.

       Clean Air Act

                    The original CAA authorized EPA to set limits on plastic resin and manmade

                    fiber plant emissions. In its new source performance standards (NSPS) for

                    polymer manufacturing facilities (40 CFR Part 60 Subpart DDD), EPA set

                    minimum standards for the lowest achievable emissions rates  (LAER) and

                    best available control technologies (BACT). The NSPS for Polymers requires

                    air emission controls  on new and existing  facilities that  manufacture

                    polypropylene, polyethylene, polystyrene and poly(ethylene terephthalate).

                    Included are standards on controlling intermittent and continuous sources of

                    emissions from processes.  EPA also published an NSPS for synthetic fiber

                    production facilities (40  CFR Part 60  Subpart  HHH).   The  NSPS for

                    Synthetic Fibers regulates VOC emissions from facilities that use  solvents in

                    manufacturing fibers. There are additional NSPS that apply to plastic resin

                    and synthetic fiber manufacturers including those for flares (40  CFR Part 60

                    Subpart A), storage vessels (40 CFR Part 60 Subpart K), equipment leaks (40

                    CFR Part 60 Subpart VV), air oxidation processes (40 CFR Part 60 Subpart

                    III), distillation operations  (40 CFR Part 60 Subpart NNN), and reactor

                    processes (40 CFR Part 60 Subpart RRR).



                    The Clean Air Act Amendments of 1990 set National Emission Standards for

                    Hazardous Air Pollutants (NESHAP) from industrial sources for 41 pollutants

                    to  be met by  1995 and for 148 other pollutants to be reached by  2003.

                    Several provisions affect the plastic resin and manmade fiber industries.  In

                    April 1994, the EPA published Hazardous Organic National  Emissions

                    Standards for Hazardous Air Pollutants, also known as HON, in a rule  aimed

                    at reducing air toxics emissions from chemical and allied product plants. This

                    rule, which consists of four subparts, affects hundreds of plastic resin and

                    manmade fiber plants and thousands of chemical process units since potential

                    organic hazardous air pollutants are widely used as reactants.  Processes

                    covered include heat exchange systems and maintenance operations (40 CFR

                    Part 63 Subpart F); process vents, storage vessels, transfer operations, and

                    wastewater (40 CFR Part 63 Subpart G); equipment leaks (40  CFR Part 63

                    Subpart H); and equipment leaks for polycarbonate plants  (40  CFR Part 63

                    Subpart I).  Another NESHAP that may affect plastic  resin and manmade

                    fiber manufacturers is that for treatment,  storage, and disposal facilities (40

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                     Part CFR 63 Subpart AA). The HON also includes innovative provisions such

                     as emissions trading, that offer industry flexibility in complying with the rule's

                     emissions goals.



                     Subsets of the plastic resin and manmade fiber industries are regulated under

                     other NESHAPs. EPA published a final rule for epoxy resins and non-nylon

                     polyamide resins  in March  1995.   The  rule was expected  to  reduce

                     epichlorohydrin emissions from process vents and storage tank emissions.  In

                     September 1996, EPA published a final rule for Group I Polymers and Resins

                     (61  FR 46906) under 40 CFR part 63, Subpart U.  This rule focused on

                     reducing emissions from facilities that make certain elastomers used in the

                     manufacture of synthetic rubber products. The rule was expected to reduce

                     emissions of styrene, hexane, toluene, and other toxics.   Provisions on

                     pollution  prevention,  as  well as a  market-based provision on emissions

                     averaging, were also included in the rule.



                     In September 1996, EPA also published a final rule for Designated Group IV

                     Polymers and Resins (61 FR 48208) under 40 CFR part 63, Subpart JJJ.  This

                     rule was  expected to reduce emissions of air toxics from poly(ethylene

                     terephlate), nitrile, and styrene-based resins facilities.  The rule was expected

                     to reduce styrene, butadiene, and methanol emissions from storage vessels,

                     process vents, equipment leaks, and wastewater operations. A direct final

                     notice (62 FR 1869) was published on January 14, 1997, which extended the

                     heat exchange system compliance date for the Group I rule and the equipment

                     leak compliance dates for both the Group I and Group IV rules.  Other

                     NESHAPs that apply to the industry cover vinyl chloride manufacturers (40

                     CFR Part 61 Subpart F), benzene equipment leaks (40 CFR Part 61 Subpart

                     J), fugitive emissions (40 CFR Part 61 Subpart V), benzene emissions from

                     benzene storage vessels (40 CFR Part 61 Subpart Y), benzene emissions from

                     benzene transfer operations (40 CFR Part 61 Subpart BB), and benzene waste

                     operations (40 CFR Part 61  Subpart FF).

       Clean Water Act

                    The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,

                    gives EPA the authority to regulate effluents from sewage treatment works,

                    chemical plants, and other industrial sources into waters.  The act sets "best

                    available" technology standards for treatment of wastes for both direct and

                    indirect  (discharged to  a  Publicly Owned  Treatment Work  (POTW))

                    discharges.  EPA originally promulgated effluent limitations guidelines and

                    standards for the plastic resin and manmade fiber industries in two phases.

                    Phase I, covering 13 products and processes, was promulgated on April 5,

                    1974 (39 FR 12502), and Phase II, covering eight additional products and

                    processes, was promulgated on January 23, 1975 (40 FR 3716).  In 1976,

                    these regulations were challenged and eventually remanded by the federal

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                    circuit court in FMC Corp. versus Train. 539F.2d 973 (4th Cir. 1976).  As

                    a result, EPA withdrew both the Phase I and II plastic resin and manmade

                    fiber regulations on August 4, 1976 (41 FR 32587) (EPA, 1987).



                    On November 5, 1987, EPA proposed final effluent guidelines (52FR42522)

                    for the organic chemical, plastics, and synthetic fiber industries (OCPSF) (40

                    CFR Part 414).  The effluent guidelines include limits for biological oxygen

                    demand (BOD), total suspended solids (TSS), and acidity (pH). In this rule,

                    limits are specified for facilities that manufacture rayon fibers, other synthetic

                    fibers, thermoplastic resins, and thermoset resins.



                    The majority of this rule was upheld by the federal courts in 1989 when the

                    Chemical Manufacturers Association sued the EPA.  The Court left the rule

                    in effect pending  further  rulemaking but remanded three aspects of the

                    OCPSF  guidelines.  The  Court  remanded the New Source Performance

                    Standards (NSPS) and the Pretreatment Standards for New Sources  (PSNS)

                    for consideration of whether zero discharge limits were appropriate for the

                    industries; the subcategorization of the industries into two subcategories

                    imposing  differing  limitations  based on  Best  Available Technology

                    Economically Achievable (BAT);  and  limitations for BAT  Subpart J

                    pollutants that were based upon in-plant biological treatment technology.



                    The EPA decided not to revise the NSPS and PSNS standards or the BAT

                    subcategorization scheme  and promulgated two sets of amendments to the

                    rule in 1992 and 1993. On September 11, 1992, EPA promulgated a first set

                    of amendments  (57 FR 41836) to the OCPSF rule.  These amendments

                    allowed regulatory authorities to establish alternative cyanide limitations and

                    standards for cyanide resulting from complexing of cyanide at the  process

                    source  and establish alternative  metals limitations  and standards  to

                    accommodate low background levels of metals in non-"metal-bearing waste

                    streams." These amendments also allowed regulatory authorities to specify

                    the method for determining five-day biochemical oxygen demand and total

                    suspended  solids effluent  limitations for direct discharge plants (FR,

                    September 11, 1992).



                    On July 9, 1993, EPA promulgated the remaining portions of the OCPSF rule

                    in second set of amendments  (58 FR  36872) which added Subpart J

                    limitations based on  BAT and NSPS for 19  additional pollutants.  These

                    amendments also established Pretreatment Standards for Existing Sources

                    (PSES)  and PSNS for 11  of these 19 pollutants. EPA also corrected the

                    criteria for designating "metal-" and "cyanide-bearing" waste streams.  In this

                    rulemaking, phenol and 2,4-dimethylphenol pretreatment standards were not

                    promulgated since EPA concluded that they did not pass through POTWs.

                    The implementation of the guidelines is left to the states who issue NPDES

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                     permits for each facility.  The compliance date for PSES was no later than

                     July 23, 1996 (FR, July 9, 1993).



                     The Storm Water Rule (40 CFR §122.26(b)(14) Subparts (i, ii)) requires the

                     capture and treatment of stormwater at facilities producing chemicals and

                     allied  products, including plastic resin and synthetic fiber manufacture.

                     Required treatment will remove from stormwater flows a large fraction of

                     both conventional pollutants, such as suspended solids and biological oxygen

                     demand (BOD), as well as toxic pollutants, such as certain metals and organic

                     compounds.



       Resource Conservation and Recovery Act



                     Products, intermediates, and off-specification products generated at plastic

                     resin and synthetic fiber facilities that are considered hazardous wastes are

                     listed  in 40 CFR  Part 261.33(f).  Some of the handling and treatment

                     requirements for RCRA hazardous waste generators are covered under 40

                     CFR Part 262 and  include the following: determining what constitutes  a

                     RCRA hazardous waste (Subpart A); manifesting (Subpart B); packaging,

                     labeling, and accumulation time limits (Subpart C); and recordkeeping and

                     reporting (Subpart D).



                     Many plastic resin and synthetic fiber facilities store some hazardous wastes

                     at the facility for more than 90 days, and therefore, are a storage facility under

                     RCRA. Storage facilities  are required to have a RCRA treatment,  storage,

                     and disposal facility (TSDF) permit (40 CFR Part 262.34).  Some plastic resin

                     and synthetic fiber facilities are considered TSDF facilities and are subject to

                     the following regulations covered under 40 CFR Part 264: contingency plans

                     and  emergency procedures (40 CFR Part  264 Subpart D);  manifesting,

                     recordkeeping,  and reporting  (40 CFR Part  264 Subpart E); use and

                     management of containers (40 CFR Part 264 Subpart I); tank systems (40

                     CFR Part 264 Subpart J); surface impoundments (40 CFR Part 264 Subpart

                    K); land treatment  (40 CFR Part 264  Subpart M);  corrective action of

                    hazardous waste releases  (40  CFR  Part 264  Subpart S); air emissions

                    standards for process vents of processes that process or generate hazardous

                    wastes (40 CFR Part 264 Subpart AA); emissions standards for  leaks in

                    hazardous waste handling equipment (40 CFR Part 264 Subpart BB); and

                    emissions  standards for containers, tanks, and surface impoundments that

                    contain hazardous wastes (40 CFR Part 264 Subpart CC).



                    A number of RCRA wastes have been prohibited from land disposal unless

                    treated to meet specific standards under the RCRA Land Disposal Restriction

                    (LDR) program. The wastes covered by the RCRA LDRs are listed in 40

                    CFR Part 268 Subpart C and include a number of wastes commonly generated

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                     at plastic resin and synthetic fiber facilities.  Standards for the treatment and

                     storage of restricted wastes are described in Subparts D and E, respectively.



                     Many plastic resin and  synthetic  fiber facilities are also  subject to the

                     underground storage tank (UST) program (40 CFR Part 280).  The UST

                     regulations  apply to  facilities  that store either petroleum products or

                     hazardous  substances (except  hazardous  waste) identified under the

                     Comprehensive Environmental Response, Compensation, and Liability Act.

                     UST regulations address design standards, leak detection, operating practices,

                     response  to releases, financial responsibility for  releases,  and closure

                     standards.



       Toxic Substances Control Act



                     The Toxic Substances Control  Act (TSCA),  passed in 1976, gives the

                     Environmental Protection Agency comprehensive authority to regulate any

                     chemical substance whose manufacture, processing, distribution in commerce,

                     use or disposal may present an unreasonable risk of injury to human health or

                     the environment.  Four sections are of primary importance to the plastic resin

                     and manmade fiber industries.  TSCA  §5 (new chemicals) mandates that

                     plastic resin and manmade fiber companies submit pre-manufacture notices

                     that provide information on health and environmental  effects for each new

                     product and  test existing products for these  effects (40 CFR Part 720).

                     TSCA §4 (existing chemicals) authorizes the EPA to require testing of certain

                     substances (40 CFR Part 790). TSCA §6 gives the EPA authority to prohibit,

                     limit or ban the  manufacture, process and use of chemicals (40 CFR Part

                     750).  For certain chemicals, TSCA §8 also imposes record-keeping and

                     reporting requirements  including substantial risk notification; record-keeping

                     for data relative to adverse reactions; and periodic updates  to the TSCA

                     Chemical Inventory.



                     Under §5(h)(4),  which grants EPA authority to promulgate rules granting

                     exemptions  to some or all of the  premanufacture requirements for new

                     chemicals, EPA published an exemption rule in 1984 and an amendment to

                     the rule in 1995.  The amendment, entitled Premanufacture Notification

                     Exemptions  (PMN) rule,  contained a section  on polymers (40 CFR Part

                     723.250) that allowed polymers that met certain restrictions  to be exempt

                     from some of the reporting requirements for new chemicals. Two exemptions

                     {40 CFR Part 723.250(e)(l) and (e)(2)} exempt polymers based on molecular

                     weight  and  oligomer  content.   The  third  exemption (40 CFR  Part

                     723.250(e)(3)) exempts certain polyester polymers which use particular

                     monomers and reactants.



                    In addition to meeting the specific  criteria of  one of the three exemption

                    types, the new  polymer  must  also not fall into one  of the prohibited

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                      Statutes and Regulations

                                  categories. This section (40 CFRPart 723.250(d)) excludes certain polymers

                                  from reduced reporting requirements, namely:  certain cationic polymers;

                                  polymers that do not meet elemental restrictions; polymers that are reasonably

                                  predicted to decompose, degrade, or depolymerize; and polymers which are

                                  produced from monomers and/or other reactants which are not on the TSCA

                                  inventory or otherwise exempted from reporting under a §5 exemption.



              VI.C. Pending and Proposed Regulatory Requirements



                     Clean Air Act



                           NESHAPfor Formaldehyde-based Resin Manufacturers



                                  Presumptive MACT standards were published for amino, phenolic, and acetal

                                  resins in July 1996. These resins use formaldehyde as their primary building

                                  block. A NESHAP for amino and phenolic resins  is expected to be proposed

                                  in 1997 and will reduce emissions, primarily, of formaldehyde and methanol.

                                  Over 100  facilities are expected to be affected  by this rule.  EPA is also

                                  expecting to propose a NESHAP for acetal resins which will affect 3 facilities.

                                  For more information,  please contact John Schaefer at 919-541-0296.



                           NESHAPfor Polyether Polyols



                                  A proposed rule for polyether polyols is expected to be published in 1997.

                                  Roughly 50 major sources in the United States are expected to be affected by

                                  this regulation. For more information,  please contact David Svendsgaard at

                                  919-541-2380.



                           NESHAPfor Polycarbonate Resin Manufacturers



                                  This rule, scheduled to be proposed in 1997, will reduce  emissions from

                                  polycarbonate resin facilities. It is anticipated that only two major sources in

                                  the United States will be affected by this regulation.  For more information,

                                  please contact Mark Morris at 919-541-5416.



                           NESHAPfor Acrylic and Modacrylic Fiber Manufacturers



                                  EPA is working on a rule to reduce emissions from acrylic  and modacrylic

                                  fiber manufacturers. This rule is  scheduled to be proposed in  1997 and is

                                  expected to primarily reduce emissions of acrylonitrile and vinyl acetate.  Only

                                  two major sources in the United States will be affected by this regulation. For

                                  more information,  contact Leonardo Ceron at 404-562-9129.

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          Compliance and Enforcement Profile

VH. COMPLIANCE AND ENFORCEMENT PROFILE



       Background



                    Until recently, EPA has focused  much  of its attention  on measuring

                    compliance with specific environmental statutes.  This approach allows the

                    Agency  to track compliance  with the  Clean  Air Act,  the Resource

                    Conservation and Recovery  Act,  the  Clean  Water Act,  and  other

                    environmental statutes. Within the last several years, the Agency has begun

                    to  supplement single-media  compliance indicators with facility-specific,

                    multimedia indicators of compliance.  In doing so, EPA is in a better position

                    to track compliance with all statutes at the facility level, and within specific

                    industrial sectors.



                    A major step in building the capacity to compile multimedia data for industrial

                    sectors was the creation of EPA's Integrated Data for Enforcement Analysis

                    (IDEA) system. IDEA has the capacity to "read  into" the Agency's single-

                    media databases,  extract compliance records, and match the records to

                    individual  facilities.   The IDEA system  can match Air, Water, Waste,

                    Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given

                    facility, and generate a list of historical permit, inspection, and enforcement

                    activity. IDEA also has the capability to analyze data by geographic area and

                    corporate holder.  As the capacity to generate multimedia compliance data

                    improves,  EPA  will  make available  more in-depth compliance  and

                    enforcement information.  Additionally, sector-specific measures of success

                    for compliance assistance efforts are under development.



       Compliance and Enforcement Profile Description



                    Using inspection, violation and enforcement data from the IDEA system, this

                    section  provides  information  regarding  the historical  compliance  and

                    enforcement activity of this sector.  In order to mirror the facility universe

                    reported in the Toxic Chemical Profile, the data reported within this section

                    consists of records only from the TRI reporting universe.  With this decision,

                    the selection criteria are  consistent across sectors with certain  exceptions.

                    For the sectors that do not normally report to the TRI program, data have

                    been provided from EPA's Facility Indexing System (FINDS) which tracks

                    facilities in all media databases. Please note, in this section, EPA does not

                    attempt to define the actual number of facilities that fall within each sector.

                    Instead, the section portrays the records of a subset of facilities within the

                    sector that are well defined within EPA databases.



                    As a check on the relative size of the full sector  universe, most notebooks

                    contain an estimated number of facilities within the sector according to the

                    Bureau  of Census (See Section II).  With sectors dominated  by  small

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                     businesses, such as metal finishers and printers, the reporting universe within

                     the EPA databases may be small in comparison to Census data. However, the

                     group selected for inclusion in this data analysis section should be consistent

                     with this sector's general make-up.



                     Following this introduction is a list defining  each  data column presented

                     within this section.   These values  represent  a retrospective summary of

                     inspections and enforcement actions,  and reflect solely EPA, State, and local

                     compliance assurance activities that  have been entered into EPA databases.

                     To identify any changes in trends, the EPA ran two data queries,  one for the

                     past five calendar years (April 1, 1992 to March 31,  1997)  and the other for

                     the most recent twelve-month period (April 1, 1996 to March 31, 1997).  The

                     five-year analysis gives an average level of activity for that  period for

                     comparison to the more recent activity.



                     Because most inspections focus  on single-media requirements, the  data

                     queries presented in this section are taken from single media databases. These

                     databases do not provide data on whether inspections are state/local or EPA-

                     led. However, the table breaking down the universe of violations does give

                     the reader a crude measurement of the EPA's and states' efforts within each

                     media program.  The presented data illustrate the  variations across EPA

                     Regions for certain sectors.2 This variation may be attributable to state/local

                     data entry  variations,  specific geographic concentrations, proximity to

                     population  centers, sensitive ecosystems,  highly toxic chemicals  used in

                     production, or historical noncompliance. Hence, the exhibited data do not

                     rank regional performance or necessarily reflect which regions may have the

                     most compliance problems.



Compliance and Enforcement Data Definitions



       General Definitions



                     Facility Indexing System (FINDS) ~ this system assigns a common facility

                     number to  EPA single-media permit records.  The FINDS identification

                     number  allows EPA to  compile  and review all  permit, compliance,

                     enforcement and pollutant release  data for any given regulated facility.



                     Integrated Data for Enforcement Analysis (IDEA) ~ is a data  integration

                     system that can retrieve information from the major  EPA program office

                     databases. IDEA uses the FINDS identification number to link separate data

1 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA,

VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VH

(IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ED, OR,

WA),

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                    records from EPA's databases.  This allows retrieval of records from across

                    media or statutes for any given facility, thus creating a "master  list" of

                    records for that facility. Some of the data systems accessible through IDEA

                    are:  AIRS (Air Facility Indexing and Retrieval System, Office of Air and

                    Radiation), PCS  (Permit Compliance System, Office of Water),  RCRIS

                    (Resource Conservation and Recovery Information System, Office of Solid

                    Waste),  NCDB (National Compliance  Data Base, Office of Prevention,

                    Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental

                    and  Liability Information System,  Superfund), and TRIS (Toxic Release

                    Inventory System).  IDEA also contains information from outside sources

                    such as  Dun and Bradstreet and the  Occupational  Safety and  Health

                    Administration (OSHA). Most data queries displayed in notebook sections

                    IV and VII were conducted using IDEA.



       Data Table Column Heading Definitions



                    Facilities in Search ~ are based on the universe of TRI reporters within the

                    listed  SIC code range.  For  industries not covered under TRI  reporting

                    requirements (metal  mining,  nonmetallic mineral  mining,  electric power

                    generation, ground transportation, water transportation, and dry cleaning), or

                    industries in which only a very small fraction of facilities report to TRI (e.g.,

                    printing), the notebook uses the FINDS universe for executing data queries.

                    The SIC code range selected for each search is defined by each notebook's

                    selected SIC code coverage described in Section II.



                    Facilities Inspected  — indicates the  level  of EPA  and state  agency

                    inspections for the facilities in this data search.  These values show what

                    percentage of the facility universe  is inspected in  a one-year or five-year

                    period.



                    Number of Inspections  --  measures  the total  number of inspections

                    conducted in this sector.  An inspection event is  counted each  time  it is

                    entered into a single media database.



                    Average Time Between Inspections -- provides an average length of time,

                    expressed in months, between compliance inspections at a facility within the

                    defined universe.



                    Facilities with One or More Enforcement Actions  — expresses the number

                    of facilities that were the subject of at least one enforcement action within the

                    defined time period. This category  is  broken down further into federal and

                    state actions.  Data are obtained for administrative, civil/judicial, and criminal

                    enforcement actions.   Administrative  actions include Notices of Violation

                    (NOVs). A facility with multiple enforcement actions is only counted once

                    in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.

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                    Total Enforcement Actions -- describes the total number of enforcement

                    actions identified for an industrial sector across all environmental statutes. A

                    facility with multiple enforcement actions is counted multiple times, e.g., a

                    facility with 3 enforcement actions counts as 3.



                    State Lead Actions -- shows what percentage of the total  enforcement

                    actions are taken by state and local environmental agencies.  Varying levels

                    of use by  states of EPA data systems  may limit the volume of actions

                    recorded as state  enforcement activity.   Some states extensively report

                    enforcement activities into EPA data systems, while other states may use their

                    own data systems.



                    Federal Lead Actions — shows  what percentage of the total  enforcement

                    actions are taken by the United States Environmental Protection Agency.

                    This value includes referrals from state agencies. Many of these actions result

                    from coordinated or joint state/federal efforts.



                    Enforcement to Inspection Rate -- is a ratio of enforcement actions to

                    inspections, and is  presented for comparative  purposes only. This ratio is a

                    rough indicator of the relationship between inspections and enforcement. It

                    relates the number of enforcement actions and the number of inspections that

                    occurred within the one-year or  five-year period.  This ratio  includes the

                    inspections and enforcement actions reported under the Clean Water  Act

                    (CWA),  the  Clean Air  Act (CAA) and the Resource Conservation  and

                    Recovery Act (RCRA).  Inspections and actions from the TSCA/FIFRA/

                    EPCRA database are not factored  into this ratio because most of the actions

                    taken under these programs are not the result of facility inspections. Also,

                    this  ratio does not account for enforcement  actions arising from non-

                    inspection  compliance  monitoring  activities  (e.g.,   self-reported water

                    discharges) that can result in enforcement action within the CAA, CWA,  and

                    RCRA.



                    Facilities with One or More  Violations  Identified  ~ indicates  the

                    percentage of inspected  facilities  having a violation identified in one of the

                    following data  categories:  In Violation or Significant Violation Status

                    (CAA); Reportable Noncompliance, Current Year Noncompliance, Significant

                    Noncompliance (CWA); Noncompliance and Significant Noncompliance

                    (FIFRA, TSCA, and EPCRA); Unresolved  Violation and Unresolved High

                    Priority Violation (RCRA). The values presented for this column reflect the

                    extent  of noncompliance within the measured time frame,  but do  not

                    distinguish between the severity  of the noncompliance.  Violation status may

                    be a precursor to an enforcement action, but does not necessarily indicate that

                    an enforcement action will occur.

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         Compliance and Enforcement Profile

                   Media Breakdown  of Enforcement Actions and Inspections — four

                   columns identify the proportion of total inspections and enforcement actions

                   within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each

                   column is a percentage  of either the "Total Inspections," or the "Total

                   Actions" column.

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 VILA. Plastic Resin and Manmade Fiber Industries Compliance History



                     Table 24 provides an overview of the reported compliance and enforcement

                     data for the plastic resin and manmade fiber industries over the past five years

                     (April 1992 to April 1997).  These data are also broken out by EPA Region

                     thereby permitting geographical comparisons.  A few points evident from the

                     data are listed below.



                     •      The majority of plastic resin and manmade fiber facilities (about 60%)

                           and inspections over the past five years were in Regions IV, V, and

                           VI.



                     •      Regions  III and II had the second and third largest number of

                           inspections,  respectively, although they ranked fourth and fifth in

                           terms of number of facilities, respectively.



                     •      Region VI had a high ratio of enforcement actions to inspections

                           (0.25) compared to other Regions. Region VI also had the highest

                           number of enforcement actions and facilities with  enforcement

                           actions.



                     •      Region n had the second largest number of enforcement actions (52),

                           but ranks fifth in number of facilities.

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          Compliance and Enforcement Profile

VII.B. Comparison of Enforcement Activity Between Selected Industries



                     Tables 25 and 26  allow the compliance history of the plastic resin and

                     manmade fiber industries to be compared with the other industries covered by

                     the industry sector notebooks.  Comparisons between Tables 25  and 26

                     permit the identification of trends in compliance and enforcement records of

                     the industries by comparing data covering the last five years (April 1992 to

                     April 1997) to that of the past year (April 1996 to April 1997).  Some points

                     evident from the data are listed below.



                     •     The ratio of enforcement actions to inspections for plastic resin and

                           manmade fiber manufacturing facilities over the past five years (0.09)

                           was very close to the average across the industries shown (0.08).



                     •     Over the past five years, the average  number of months between

                           inspections  was relatively  low (8 months) for plastic resin and

                           manmade fiber facilities. The average across the industries shown was

                           22 months indicating that, on average, facilities in the plastic resin and

                           manmade fiber industry are inspected more frequently than facilities

                           in many other industries.



                     •     While the average enforcement to inspection rate across industries fell

                           from  0.08 over the past five years to 0.06 over the past year, the

                           enforcement to inspection rate for plastic resin and manmade fiber

                           facilities remained at 0.09.



                     •     Only  three of the industries shown (petroleum refining, lumber and

                           wood, and water transportation) had a higher percent of facilities

                           inspected with enforcement actions over the past year.



                     Tables 27  and 28 provide a more in-depth comparison between the plastic

                     resin and manmade fiber industries and other  sectors by breaking out the

                     compliance and enforcement data by environmental statute. As in Tables 25

                     and 26, the data cover the last five years (Table 27) and the last one year

                     (Table 28) to facilitate the identification of recent trends.  A few  points

                     evident from  the data are listed below.



                     •      While the percentage of RCRA  inspections  remained  the same

                           between the past five years and past year, the percent of enforcement

                           actions taken under RCRA dropped from 23 percent to 5 percent.



                     •      The Clean Air Act accounted for the largest share of enforcement

                           actions over the past five years (43 percent) and the past year (51

                           percent).

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                          Compliance and Enforcement Profile

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          Compliance and Enforcement Profile

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         Compliance and Enforcement Profile





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         Compliance and Enforcement Profile

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          Compliance and Enforcement Profile

VII.C. Review of Major Legal Actions



             Major Cases/Supplemental Environmental Projects



                    This section provides summary information about major cases that have

                    affected this  sector,  and a list of Supplemental  Environmental Projects

                    (SEPs).



       VTLC.l. Review of Major Cases



                    As indicated in EPA's Enforcement Accomplishments Report, FY1995 and

                    FY1996 publications, four significant enforcement actions were resolved

                    between 1995 and 1996 for the metal casting industry.



                    TeknorApex Company: A September 30, 1996 consent agreement and order

                    resolved TSCA violations by Teknor Apex of Pawtucket, RI.  Teknor Apex

                    had  failed to report the  identities and  volumes of  several  chemicals

                    manufactured in 1989, as required by EPA's Inventory Update rule. Teknor

                    Apex manufactures organic plasticizers, vinyl resins, garden hose, plastic

                    sheeting, and color pigments. The violations, which occurred at facilities in

                    Attleboro, MA, and in Brownsville, TN, hampered EPA's efforts to assess the

                    health and environmental risks of chemical manufacture and distribution. The

                    settlement provides for a penalty of $52,950 and implementation of SEPs

                    costing $300,000.  Four SEPs at the Attleboro facility will reduce toxic

                    emissions, reduce and improve the quality of wastewater discharges, and

                    reduce the volume of industrial wastewater processed at Teknor's on-site

                    wastewater treatment plant.



                    Union Carbide Chemicals and Plastics (South Charleston, WV): On May

                    16, 1995,  the Regional Administrator signed a consent order resolving a

                    RCRA administrative penalty action against Union Carbide Chemicals and

                    Plastics Company,  Inc. (UCC),  for violations of the BIF Rule (Boiler and

                    Industrial Furnace Rule)  at UCC's South Charleston, West Virginia, plant.

                    The complaint alleged failure to: continuously monitor and record operating

                    parameters; accurately analyze the hazardous waste fed into the boiler; and

                    properly mark equipment. Under the settlement terms UCC is required to pay

                    a $195,000 civil penalty and  comply with the requirements of the BIF Rule.



                    Formosa Plastics Co.: On May 31, 1995, a Class I CERCLA 103(a) and

                    EPCRA 304(a) consent agreement and consent order (CACO) was entered

                    with Formosa Plastics for numerous releases of vinyl chloride  from its Point

                    Comfort, Texas, facility between February 1989 and August 1992 that were

                    not reported to the National Response Center (NRC) in a timely manner

                    following the release.  Additionally, the respondent experienced a release of

                    ethylene dichloride in September 1990, and a release of hydrochloric acid in

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                    July 1991.  Formosa did not report these releases  to  the NRC,  State

                    Emergency Response Commission (SERC), and Local Emergency Planning

                    Committee (LEPC) in a  timely manner.  Formosa agreed to  pay a civil

                    penalty of $50,000 and  agreed to construct  and maintain a secondary

                    containment system which will prevent large  pressure releases of vinyl

                    chloride from the facility.  The system cost is estimated to be $1.68 million

                    with an anticipated start-up date of January 1996. Additionally, as part of a

                    SEP, Formosa agreed to  complete the following actions: (1) implement a

                    chemical safety project for the citizens of Point Comfort, Texas at a cost of

                    $10,000; (2) permit a chemical safety audit to be performed by a team led by

                    EPA personnel to review facility emergency response procedures and plans;

                    (3) develop and implement a risk management program; and (4) provide

                    funding ($35,000) to support a Region-wide LEPC conference.



       VII.C.2. Supplementary Environmental Projects (SEPs)



                    Supplemental environmental projects (SEPs) are enforcement options that

                    require the non-compliant facility to complete specific projects. Information

                    on SEP cases can be accessed via the Internet at EPA's Enviro$en$e website:

                    http://es.inel.gov/sep.

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          Compliance Activities and Initiatives

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES

                    This section highlights the activities undertaken by this industry sector and

                    public  agencies  to  voluntarily  improve  the   sector's  environmental

                    performance.  These activities include those independently initiated  by

                    industrial trade associations. In this  section, the notebook also contains a

                    listing and description of national and regional trade associations.

VTfl.A. Sector-Related Environmental Programs and Activities



                    Chemical Manufacturer's  Association and EPA  have developed training

                    modules, self-audit manuals, and compliance guides for Section 608 of the

                    Clean Air Act, which covers leak detection and repair. They are discussing

                    developing plant level compliance guides, auditing protocols, and training

                    materials for RCRA Subpart CC and other areas.



VHI.B. EPA Voluntary Programs



       33/50 Program



                    The 33/50 Program is a ground breaking program that has  focused on

                    reducing pollution from seventeen high-priority chemicals through voluntary

                    partnerships with industry.  The program's name stems from its goals: a 33%

                    reduction in toxic releases by 1992, and a 50% reduction by  1995, against a

                    baseline of 1.5 billion pounds of releases and transfers in 1988.  The results

                    have been impressive:  1,300 companies have joined the 33/50 Program

                    (representing over 6,000 facilities) and have reached the national targets a

                    year ahead of schedule. The 33% goal was reached in 1991, and the 50%

                    goal -- a reduction of 745 million pounds of toxic wastes --  was reached in

                    1994. The 33/50 Program can provide case studies on many of the corporate

                    accomplishments in reducing waste (Contact 33/50 Program  Director David

                    Sarokin - 260-6396).



                    Table 29 lists  those companies participating in  the 33/50 program that

                    reported the SIC codes 2821, 2823, or 2824 to TRI. Many of the companies

                    shown listed multiple SIC codes and, therefore, are likely to carry out

                    operations in addition to plastic resin and manmade fiber manufacturing. In

                    addition, the number of facilities within each company that are participating

                    in the 33/50 program and that report SIC 2821, 2823, or 2824 to TRI are

                    shown.  Finally, where available and quantifiable against 1988 releases and

                    transfers, each company's 33/50 goals for 1995 and the actual total releases,

                    transfers and percent reduction between 1988  and  1994 are presented.

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 Plastic Resin and Manmade Fiber

          Compliance Activities and Initiatives

Table 29: Plastic Resin and Manmade Fiber Industries Participation in the 33/50 Program

Parent Company

;;Hcadquai1ers Location)

AIR PRODUCTS AND CHEMICALS

ALLENTOWN, PA

AKZO NOBEL INC

CHICAGO, IL

ALBEMARLE CORPORATION

RICHMOND. VA

ALLIED-SIGNAL INC

vtORRISTOWN, NJ

AMERICAN PLASTIC

TECHNOLOGIES

vlIDDLEFIELD, OH

AMOCO CORPORATION

CHICAGO, IL

ARISTECH CHEMICAL

CORPORATION

'ITTSBURGH, PA

ASHLAND OIL INC

UJS8ELL.KY

ATLANTIC RICHFIELD COMPANY

,QS ANGELES, CA

3 F GOODRICH COMPANY

AKRON, OH

BASF CORPORATION

vlOUNT OLIVE, NJ

30RDEN CHEM & PLAS LTD

PARTNR

COLUMBUS, OH

iORDEN INC

NEW YORK, NY

«JLK MOLDING COMPOUNDS INC

SAINT CHARLES, IL

CAPITAL RESIN CORPORATION

COLUMBUS, OH

CARGILL DETROIT CORPORATION

CLAWSON, MI

CHEVRON CORPORATION

SAN FRANCISCO, CA

COURTAULDS FIBERS

AXIS, AL

CYTEC INDUSTRIES

WESTPATERSON.NJ

Company-

Owned

Facilities

Reporting

33/50

("Mifttnioal^

i

i

6

1

1

1

7

2

1

6

3

1

2

1

1

5

1

1

3

Company-

Wide %

Reduction

Goal1

(1988 to 1995)

50

13

51

50

50

50

18

50

2

50

50

***

*

40

50

40

50

***

50

1988TRI

Releases and

Transfers of

33/50

Chemicals

fponnHs'}

0

158,650

960,620

0

750

0

1,648,348

207,440

47,543

31,478

241,760

11,781

105

48,555

42,480

165,288

56,216

0

226,059

1994TRI

Releases and

Transfers of

33/50

Chemicals

fpmmH^

411

87,268

1,181,712

10

0

30

159,614

4,632

3,158

864

45,195

26,393

161

0

14,077

23,836

72,044

3,250

56,230

Actual %

Reduction for

Facilities

(1988-1994)

—

45

-23

—

100

—

90

98

93

97

81

-124

-53

100

67

86

-28

—

75

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         Compliance Activities and Initiatives

'arent Company

(Headquarters Location)

DOCK RESINS CORPORATION

LINDEN, NJ

DOW CHEMICAL COMPANY

MIDLAND, MI

E. I. DU PONT DE NEMOURS & CO

WILMINGTON, DE

ETHYL CORPORATION

RICHMOND, VA

EXXON CORPORATION

IRVING, TX

FINAINC

DALLAS, TX

GENERAL ELECTRIC COMPANY

FAIRFIELD, CT

GEORGIA-PACIFIC CORPORATION

ATLANTA, GA

GLASGO PLASTICS INC

SPRINGFIELD, OH

GLOBE MANUFACTURING CO

FALL RIVER, MA

GRIFFITH POLYMERS

fflLLSBORO, OR

H & N CHEMICAL CO INC

TOTOWA, NJ

HERCULES INCORPORATED

WILMINGTON, DE

HERESITE PROTECTIVE COATINGS

MANITOWOC, WI

HOECHST CELANESE

CORPORATION

CORPUS CHRISTY, TX

ILLINOIS TOOL WORKS INC

GLENVIEW, IL

INTERNATIONAL PAPER COMPANY

PURCHASE, NY

TAMES RIVER CORP VIRGINIA

RICHMOND, VA

LIBERTY POLYGLAS INC

WEST MIFFLIN, PA

LYONDELL PETROCHEMICAL CO

HOUSTON, TX

MILES INC

PITTSBURGH, PA

Company-

Owned

Facilities

Reporting

33/50

Ohemioals

i

20

2

1

3

I

6

1

1

1

1

1

3

1

21

1

3

1

1

1

20

Company-

Wide %

Reduction

Goal1

(1988 to 1995)

*#*

50

50

46

50

40

50

50

50

45

#*

*#*

50

50

50

***

50

53

*

57

37

1988TRI

Releases and

Transfers of

33/50

Chemicals

('pounds')

10,100

6,202,765

599,530

29,174

10,548

0

7,710,278

0

12,630

957,417

29,491

10,700

551,064

2,100

4,836,469

0

138,072

0

48,401

6,901

2,069,780

1994TRI

Releases and

Transfers of

33/50

Chemicals

('pounds'!

2,370

1,761,522

176,040

0

11,696

294

1,798,408

35

0

161,523

0

2,807

137,808

0

1,463,490

500

531,258

0

20,295

0

1,410,749

Actual %

Reduction for

Facilities

(1988-1994)

77

72

71

100

-11



77

—

100

83

100

74

75

100

70

—

-285

—

58

100

32

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         Compliance Activities and Initiatives

Parent Company

(Headquarters Location)

vlQBIL CORPORATION

?AIRFAX, VA

vlONSANTO COMPANY

SAINT LOUIS, MO

vIORTON INTERNATIONAL INC

CHICAGO, IL

MEWPORT ADHESIVES &

COMPOSITES

FOUNTAIN VALLEY, CA

NORTH AMERICAN PLASTICS INC.

PRAIRIE, MS

OCCIDENTAL PETROLEUM CORP

,OS ANGELES, CA

PHILLIPS PETROLEUM COMPANY

3ARTLESVILLE, OK

PLASTICS ENGINEERING COMPANY

iHEBOYGAN, WI

}PG INDUSTRIES INC

MTTSBURGH.PA

PREMIXINC

MKINGSVILLE,OH

QUANTUM CHEMICAL

CORPORATION

SELIN. NJ

RANBAR TECHNOLOGY INC

GLENSHAW, PA

iEVLIS CORPORATION

WCRON, OH

XEXENE CORPORATION

DALLAS, TX

ROGERS CORPORATION

IOGERS, CT

ROHM AND HAAS COMPANY

'HILADELPHIA, PA

SARTORIUS NORTH AMERICA INC

3RENTWOOD, NY

SOLVAY AMERICA INC

IOUSTON, TX

TEXTILE RUBBER & CHEMICAL CO

WALTON, GA

t JNION CAMP CORPORATION

WAYNE, NJ

UNION CARBIDE CORPORATION

^ANBURY. CT

Company-

Owned

Facilities

Reporting

33/50

fyhfitnicflta

i

19

1

1

2

6

1

1

2

2

7

1

1

1

5

3

1

2

1

1

2

Company-

Wide %

Reduction

Goal1

(1988 to 1995)

50

25

20

50

*

19

50

*

50

23

50

52

50

50

#**

50

50

*

*

50

54

1988TRI

Releases and

Transfers of

33/50

Chemicals

fnoiinHO

11,922

5,554,821

0

139,000

4

1,670,197

0

3,685

580,992

41,200

391,086

26,900

1,500

347,520

243,173

319,380

377,320

9,800

7,150

136,301

810,702

1994TRI

Releases and

Transfers of

33/50

Chemicals

('ponnd^

800

1,977,399

0

0

12

702,818

168

0

161,719

n 750

177,588

5,693

1,870

103,401

82,483

37,660

77,750

21,000

0

1,434

1,337

Actual %

Reduction for

Facilities

(1988-1994)

93

64

...

100

-200

58

—

100

72

98

55

79

-25

70

66

88

79

-114

100

99

100

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          Compliance Activities and Initiatives

Parent Company

(Headquarters Location)

UNOCAL CORPORATION

LOS ANGELES, CA

VALSPAR CORPORATION

MINNEAPOLIS, MN

VISTA CHEMICAL COMPANY

HOUSTON, TX

W R GRACE & CO INC

BOCA RATON, FL

ZENECA HOLDINGS INC

WILMINGTON, DE

Company-

Owned

Facilities

Reporting

33/50

P.hfimioals

i

4

5

1

1

Company-

Wide %

Reduction

Goal1

(1988 to 1995)

50

50

50

50

*

TOTAL | 209 1

1988 TRI

Releases and

Transfers of

33/50

Chemicals

fpoiinfta^

44,750

111,244

553,331

10,980

2,639

1994 TRI

Releases and

Transfers of

33/50

Chemicals

fpmirtHO

0

71,238

61,068

43,300

1,774

Actual %

Reduction for

Facilities

(1988-1994)

100

36

89

-294

33

38,468,090 1 12,688,942 1 39

Source: U.S. EPA 33/50 Program Office, 1996.

' Company- Wide Reduction Goals aggregate all company-owned facilities which may include facilities not manufacturing

elastic resins or manmade fibers.

* = Reduction goal not quantifiable against 1 988 TRI data.

** = Use reduction goal only.

***= No numeric reduction goal.

— = Actual reduction not quantifiable against 1 988 TRI data.

       Environmental Leadership Program

                    The Environmental  Leadership Program (ELP) is a national  initiative

                    developed by EPA that focuses on improving environmental performance,

                    encouraging voluntary compliance, and building working relationships with

                    stakeholders. EPA initiated a one year pilot program in 1995 by selecting 12

                    projects at industrial facilities and federal installations that demonstrate the

                    principles of the ELP program.  These principles  include:  environmental

                    management  systems,  multimedia  compliance  assurance,  third-party

                    verification  of compliance, public measures of accountability,  community

                    involvement,  and mentor programs.  In return for participating,  pilot

                    participants receive public recognition and are given a period of time to

                    correct any violations discovered during these experimental projects.



                    EPA is making plans to  launch its full-scale Environmental  Leadership

                    Program in 1997. The full-scale program will be facility-based with a 6-year

                    participation cycle. Facilities that meet certain requirements will be eligible

                    to participate, such as having a community outreach/employee involvement

                    programs and an environmental management system (EMS) in  place for 2

                    years.   (Contact:  http://es.inel.gov/elp  or  Debby  Thomas,  ELP Deputy

                    Director, at 202-564-5041)

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          Compliance Activities and Initiatives

       Project XL

                    Project XL was initiated in March 1995 as a part of President Clinton's

                    Reinventing Environmental Regulation initiative.  The projects seek to

                    achieve cost effective environmental benefits by  providing participants

                    regulatory flexibility on the condition that they produce greater environmental

                    benefits. EPA and program participants will negotiate and sign a Final Project

                    Agreement, detailing  specific environmental objectives  that the regulated

                    entity shall satisfy. EPA will provide regulatory flexibility as an incentive for

                    the participants'  superior  environmental performance.  Participants are

                    encouraged to seek stakeholder support from local governments, businesses,

                    and environmental groups.  EPA hopes to implement fifty pilot  projects in

                    four categories, including industrial facilities, communities, and government

                    facilities regulated by EPA.  Applications will be accepted on a rolling basis.

                    For additional  information  regarding XL projects, including application

                    procedures  and criteria,  see the May 23, 1995 Federal Register Notice.

                    (Contact:      Fax-on-Demand     Hotline     202-260-8590,     Web:

                    http://www.epa.gov/ProjectXL, or Christopher Knopes at EPA's Office of

                    Policy, Planning and Evaluation 202-260-9298)

       Climate Wise Program

                    Climate Wise is helping US industries turn energy efficiency and pollution

                    prevention into  a corporate asset.  Supported by the technical assistance,

                    financing  information and public recognition  that Climate Wise offers,

                    participating companies are developing  and launching  comprehensive

                    industrial  energy efficiency and pollution prevention action plans that save

                    money and protect the environment. The nearly 300 Climate Wise companies

                    expect to save more than $300 million and reduce greenhouse gas emissions

                    by  18  million metric tons of carbon dioxide equivalent by the year 2000.

                    Some  of  the actions  companies are  undertaking to achieve these results

                    include: process improvements, boiler and steam system optimization, air

                    compressor system improvements, fuel switching, and waste heat recovery

                    measures including cogeneration.  Created as part of the President's Climate

                    Change Action Plan, Climate Wise is jointly operated by the Department of

                    Energy and EPA. Under the Plan many other programs were also launched

                    or upgraded including Green Lights, WasteWiSe and DoE's Motor Challenge

                    Program.  Climate Wise provides an umbrella for these programs which

                    encourage company participation by providing information on the range of

                    partnership opportunities available. (Contact:  Pamela Herman, EPA, 202-

                    260-4407 or Jan Vernet, DoE, 202-586-4755)

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          Compliance Activities and Initiatives

Energy Star Buildings Program

                    EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program

                    designed to  improve the energy-efficiency in commercial and  industrial

                    buildings. Expanding the successful Green Lights Program, ENERGY STAR

                    Buildings was launched in 1995. This program relies on a 5-stage strategy

                    designed to maximize energy savings thereby lowering energy bills, improving

                    occupant comfort,  and preventing pollution  —  all at the same time. If

                    implemented in every commercial and industrial building in the United States,

                    ENERGY STAR Buildings could cut the nation's energy bill by up to $25 billion

                    and prevent up to 35% of carbon dioxide emissions. (This is equivalent to

                    taking 60 million cars of the road). ENERGY  STAR Buildings  participants

                    include corporations; small and medium sized businesses; local, federal and

                    state governments; non-profit groups; schools; universities; and health care

                    facilities.  EPA provides technical and non-technical  support  including

                    software,  workshops, manuals,  communication tools, and an  information

                    hotline.  EPA's Office of Air and Radiation manages the operation of the

                    ENERGY STAR Buildings Program. (Contact: Green Light/Energy Star Hotline

                    at 1-888-STAR-YES or Maria Tikoff Vargas, EPA Program Director at 202-

                    233-9178  or visit  the ENERGY  STAR  Buildings  Program  website at

                    http://www.epa.gov/appdstar/buildings/)

       Green Lights Program

                    EPA's Green Lights program was initiated in 1991 and  has the goal of

                    preventing pollution by encouraging U.S. institutions to use energy-efficient

                    lighting technologies.   The  program  saves  money for  businesses  and

                    organizations and creates a cleaner  environment by reducing pollutants

                    released into the atmosphere. The program has over 2,345 participants which

                    include major corporations, small and medium sized businesses, federal, state

                    and local governments, non-profit groups, schools, universities, and health

                    care facilities.  Each participant is required to survey their facilities  and

                    upgrade lighting wherever it is profitable. As of March 1997,  participants  had

                    lowered their electric bills by $289 million annually.  EPA provides technical

                    assistance to the participants through  a decision support software package,

                    workshops and manuals, and an information hotline.  EPA's Office of Air  and

                    Radiation is responsible for operating the Green Lights Program. (Contact:

                    Green Light/Energy Star Hotline at 1-888-STARYES or Maria Tikoff Vargar,

                    EPA Program Director, at 202-233-9178 the )

       WasteWi$e Program

                    The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste

                    and Emergency Response.  The program is aimed at reducing municipal solid

                    wastes  by promoting waste  prevention, recycling  collection  and  the

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          Compliance Activities and Initiatives

                    manufacturing and purchase of recycled products.  As of 1997, the program

                    had about 500 companies as members, one third of whom are Fortune 1000

                    corporations.  Members agree to identify and implement actions to reduce

                    their solid wastes setting waste reduction goals and providing EPA with

                    yearly progress reports.  To member companies, EPA, in turn, provides

                    technical assistance, publications, networking opportunities, and national and

                    regional recognition.  (Contact: WasteWi$e Hotline at 1-800-372-9473 or

                    Joanne Oxley, EPA Program Manager, 703 -308-0199)  '

       NICE3

                    The U.S. Department of Energy is administering a grant program called The

                    National Industrial Competitiveness through Energy, Environment, and

                    Economics (NICE3).  By providing grants of up to 45 percent of the total

                    project cost, the program encourages industry to reduce industrial waste at its

                    source and become more energy-efficient and cost-competitive through waste

                    minimization efforts.   Grants are used by industry  to design, test, and

                    demonstrate new processes and/or equipment with the potential to reduce

                    pollution and  increase energy efficiency.   The program is open to  all

                    industries; however, priority is given to proposals from participants in the

                    forest products, chemicals, petroleum refining, steel,  aluminum, metal casting

                    and glass manufacturing  sectors. (Contact: http//www. oit.doe.gov/access/

                    nice3, Chris Sifri, DOE, 303-275-4723 or Eric Hass, DOE, 303-275-4728)

       Design for the Environment (DfE)

                    DfE is working with several industries to identify cost-effective pollution

                    prevention strategies that reduce risks to workers and the environment. DfE

                    helps businesses compare and evaluate the performance,  cost, pollution

                    prevention benefits, and human health and environmental risks associated with

                    existing  and alternative technologies.  The goal of these projects is to

                    encourage businesses to consider and use cleaner products, processes, and

                    technologies.  For more information about the DfE Program, call (202) 260-

                    1678.  To obtain copies of DfE materials or for general information about

                    DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)

                    260-1023 or visit the DfE Website at http://es.inel.gov/dfe.

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          Compliance Activities and Initiatives

VIII.C. Trade Association/Industry Sponsored Activity



       VHI.C.1. Environmental Programs

                    The Global Environmental Management Initiative (GEMI) is made up of

                    a group of leading companies dedicated to fostering environmental excellence

                    by business. GEMI promotes a worldwide business ethic for environmental

                    management and sustainable development, to improve the environmental

                    performance of business through example and leadership. In 1994, GEMTs

                    membership  consisted of about 30  major  corporations including  Union

                    Carbide Corporation and Dow Chemical.



                    Center for Waste Reduction Technologies under the aegis of the American

                    Institute  of  Chemical Engineers   sponsored  research   on  innovative

                    technologies to reduce waste  in the  chemical processing industries. The

                    primary mechanism is through funding of academic research.



                    The American Plastics Council is working on a life-cycle study to examine

                    the emissions released from plastics and resins manufacturing facilities. The

                    study will compare emissions from plastics and  resins manufacturing with

                    manufacturing of other materials, such as wood products.



                    The National Science Foundation  and the Environmental Protection

                    Agency's Office of Pollution Prevention and Toxics signed an agreement in

                    January of 1994 to coordinate the two agencies' programs of basic research

                    related to pollution prevention. The collaboration will stress research in the

                    use of less toxic chemical and synthetic  feedstocks, use of photochemical

                    processes instead of traditional ones that employ toxic reagents, use of

                    recyclable catalysts  to reduce metal contamination,  and use  of natural

                    feedstocks when synthesizing chemicals in large quantities.



                    The Chemical Manufacturer's Association funds research  on issues of

                    interest to their members particularly in support of their positions on proposed

                    or possible legislation.  They recently funded a study  to characterize the

                    environmental fate of organochlorine compounds.



                    The Responsible Care® Initiative of the  Chemical  Manufacturer's

                    Association requires all members and partners to continuously improve their

                    health, safety, and environmental performance in a manner that is responsive

                    to the public. Launched in 1988, the Responsible Care® concepts are now

                    being applied in  36 countries around the world.  Responsible Care® is a

                    comprehensive, performance-oriented initiative composed often progressive

                    Guiding Principles and six board Codes of Management Practices. These

                    Management Practices cover all aspects of the chemical industry's operations,

                    from research to  manufacturing, distribution,   transportation,  sales and

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          Compliance Activities and Initiatives

                    marketing, and  to  downstream users  of chemical  products.   Through

                    Responsible Care®, CMA members and partners gain insight from the public

                    through, among other means, a national Public Advisory Panel and over 250

                    local Community Advisory Panels.   This,  coupled with the  fact that

                    participation in Responsible Care® is an obligation of membership with the

                    Chemical Manufacturer's Association, make this performance improvement

                    initiative unique. The Synthetic Organic Chemical Manufacturer's Association

                    whose  membership consists  of smaller batch  and  custom  chemical

                    manufacturers with typically fewer than 50 employees and less  than $50

                    million in annual sales, encourages its  members to  achieve  continuous

                    performance improvement in their health, safety, and environmental programs

                    through implementation of the chemical  industry's  Responsible Care®

                    initiative.  SOCMA is a partner in Responsible Care®.



                    The Society of the Plastics Industry has implemented two programs aimed

                    at reducing plastic pellet loss. In 1991,  SPFs Polymeric Materials Producers

                    Division developed and endorsed a "Pellet Retention Environmental Code."

                    Companies that sign the code commit themselves to the total containment of

                    plastic pellets throughout the  pellets'  lifespan  and to operating in  full

                    compliance with environmental laws  and regulations pertaining to  pellet

                    containment (SPI, 1994). In 1992, SPI expanded the program to include a

                    processor's pledge to uphold six principles to prevent the loss of resin pellets

                    into the environment.



                    ISO 9000 is a series of international total quality management guidelines.

                    After a successful independent audit of their management plans,  firms are

                    qualified to be ISO 9000  registered.   In June of 1993, the International

                    Standards Organization created a technical committee  to work on new

                    standards for environmental management systems.



       Vin.C.2. Summary of Trade Associations

                    American Chemical Society

                    1155 16th Street, NW

                    Washington, D.C. 20036

                    Phone: 202-872-4600

                    Fax: 202-872-4615

                  Members: 150,000 individuals

                  Staff: 1950

                  Budget: $192,000,000

                    The American Chemical Society (ACS) has an educational and research focus.

                    The ACS produces approximately thirty different industry periodicals and

                    research journals, including Environmental Science and Technology and

                    Chemical Research in Toxicology.   In addition to publishing, the ACS

                    presently conducts studies and surveys; legislation monitoring, analysis, and

                    reporting; and operates a variety of educational programs.  The ACS library

                    and on-line information services are extensive.  Some available on-line

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         Compliance Activities and Initiatives

                    services are Chemical Journals Online, containing the full text of 18 ACS

                    journals, 10 Royal Society of Chemistry journals, five polymer journals and

                    the Chemical Abstracts Service, CAS, which provides a variety of information

                    on chemical compounds. Founded in 1876, the ACS is presently comprised

                    of 184 local groups and 843 student groups nationwide.

                    American Fiber Manufacturers

                    Association, Inc.

                    1150- 17th Street, NW, Suite 310

                    Washington, DC 22036

                    Phone: 202-296-6508

                    Fax: 202-296-3052

                    E-mail: afma@aol.com

               Members: 18 companies

               Staff: 6

               Budget: $2,000,000

                    Previously known as the Man-Made Fiber Producers Association up until

                    1988, the American Fiber Manufacturers Association, Inc.  (AFMA) is a

                    domestic trade organization representing U.S. producers of more than 90

                    percent of domestic production of manufactured fibers, filaments, and yarns.

                    AFMA manages programs on government relations, international trade policy,

                    the environment, technical issues, and educational services.  Committees of

                    experts from member companies work on each of these subjects.  The group

                    publishes fact books and economic profiles, Fiber Organon, and recently

                    published an environmental life cycle study.

                    Chemical Manufacturers Association

                    1300 Wilson Boulevard

                    Arlington, VA 22209

                    Phone: 703-741-5224

                    Fax: 703-741-6224

                      Members: 185 companies

                      Staff: 246

                      Budget: $36,000,000

                    A principal focus of the Chemical Manufacturer's Association (CMA) is on

                    regulatory issues facing chemical manufacturers at the local, state, and federal

                    levels. At its inception in 1872, the focus of CMA was on serving chemical

                    manufacturers through research.  Research is still ongoing at CMA. Member

                    committees, task groups, and work groups routinely sponsor research and

                    technical data collection that is then provided to  the public in support of

                    CMA's advocacy.   Much additional research takes place through the

                    CHEMSTAR® program. CFffiMSTAR® consists of a variety of self-funded

                    panels working on single-chemical research agendas.  This research fits within

                    the overall regulatory focus of CMA; CFffiMSTAR® study results are

                    provided to both CMA membership and regulatory agencies. Other initiatives

                    include the Responsible Care® program,  which includes six codes of

                    management practices designed to go beyond simple regulatory compliance.

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          Compliance Activities and Initiatives

                     CMA is currently developing measurement  and appropriate verification

                     systems for these codes.  CMA also  conducts workshops and technical

                     symposia, promotes in-plant safety, operates a chemical emergency center

                     (CHEMTREC®) which offers guidance in chemical emergency situations, and

                     operates the Chemical Referral Center  which provides chemical health and

                     safety information to the public.  Publications include the annual U.S.

                     Chemical Industry Statistical Handbook, containing detailed data on the

                     industry; Responsible Care in Action, the 1993-94  progress report on

                     implementing Responsible Care®; and Preventing Pollution in the Chemical

                     Industry: A Progress Report (1988-1993), summarizing waste generation and

                     reduction data for the years 1988-93. CMA holds an annual meeting for its

                     membership in White Sulphur Springs, WV.

                     Polyurethane Manufacturers

                     Association

                     800 Roosevelt Road, Bldg.C, Ste. 20

                     Glen Ellyn, EL 60137-5833

                     Phone: 708-858-2670

                     Fax: 708-790-3095

                Members: 116 companies

                Staff: 4

                Budget: $500,000

                     This group includes manufacturers, suppliers, distributors and sales agents of

                     raw materials, additives, or processing equipment; processors of solid cast,

                     microcellular, RIM and thermoplastic urethane elastomers; and individuals or

                     companies providing publishing, education, research, or consulting services

                     to the industry. The association publishes the bimonthly Polytopics.

                     Society of Plastics Engineers

                     14 Fair-field Drive

                     Brookfield, CT 06804-0403

                     Phone: 203-775-0471

                     Fax: 203-775-8490

                Members: 37,000 individuals

                Staff: 38

                Budget: $6,100,000

                     Society of Plastics Engineers (SPE) is a group dedicated to promoting the

                     knowledge and education of plastics and polymers worldwide and strives to

                     be the leading technology society for the plastics industry.  SPE is made up

                     of over 37,500 members around the world involved in engineering, design,

                     production and processing, research and development, consulting, marketing

                     and sales, purchasing, education, and all levels of management. SPE publishes

                    journals, including  Plastics Engineering and  Polymer Engineering and

                     Science, and sponsors a large range of technical conferences on polymer and

                     plastics processing.

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           Compliance Activities and Initiatives

                      Society of the Plastics Industry, Inc.

                      1801 K Street, NW, Suite 600K

                      Washington, DC 20006-1301

                      Phone: 202-974-5200

                      Fax: 202-296-7005

                      Web: www.socplas.org

                 Members: 1900 companies

                 Staff: 130

                 Budget: $30,000,000

                      SPI is a principal trade association for the U.S. plastics industry.  Comprised

                      of 2,000 members, SPI has representatives from all segments of the plastics

                      industry, including materials suppliers, processors, machinery manufacturers,

                      moldmakers, distributors, and other industry-related groups and individuals.

                      SPI publishes an annual report on market trends called Facts and Figures of

                      the U.S. Plastics Industry.  In addition to its general services ~ Government

                      and Technical Affairs, Communications, Trade  Shows, Membership, and

                      Finance Administration — SPI has 28 business units as well as numerous key

                      services offering programs specifically geared to the interests of particular

                      industry segments.  These special purpose groups include the Degradable

                      Polymers  Council, which acts as  a clearinghouse for  research in the

                      degradable plastics industry, and the Polymeric Materials Producers Division.

                      which includes manufacturers  of basic  polymers or prepolymers for the

                      plastics industry.  Other industry segment groups which focus on particular

                      plastic resins include  the  Fluoropolymers Division. Naphthalate Polymers

                      Council,  the Phenolic Division, the Polyurethane Division,  the Styrene

                      Information and Research Center, and the Vinyl  Institute.  SPI also has an

                      affiliation with the American Plastics Council which includes U.S. resin and

                      monomer producers, plastics processers, and suppliers. Contact information

                      for these groups is listed below.



                      American Plastics Council, Red Cavaney, President, 202-974-5400

                      Composites Institute, Catherine Randazzo, Executive Director, 212-351-5410

                      Degradable Polymers Council, John Malloy, Director of Packaging Services,

                            202-974-5245,dpc@socplas.org

                      Fluoropolymers Division, Allen Weidman, Director, 202-974-5233

                      Naphthalate Polymers Council, John Malloy, Director of Packaging Services, 202-974-5245

                      Phenolic Division, Allen Weidman, Director, 202-974-5233

                      Polymeric Materials Producers Division, Betsy Shirley, Executive Director, 202-974-5319,

                            pmd@socplas.org

                      Polyurethane Division, Fran Lichtenberg, Executive Director, 212-351 -5242,

                      polyu@socplas.org

                      Styrene Information and Research Center, Betsy Shirley, Executive Director, 202-974-5319

                            sirc@socplas. org

                      The Vinyl Institute, Robert Burnett, Executive Director, 201-898-6633, vi@socplas.org

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          Compliance Activities and Initiatives

                    Synthetic Organic Chemicals

                    Manufacturer's Association

                    1100 New York Avenue, NW

                    Washington, D.C. 20005

                    Phone: 202-414-4100

                    Fax: 202-289-8584

               Members: 250

               Staff: 50

               Budget: $12,000,000

                    Synthetic Organic Chemicals Manufacturer's Association (SOCMA) is the

                    national trade association  representing  the  legislative, regulatory, and

                    commercial interests of some 250 companies that manufacture, distribute, or

                    market organic chemicals. Most of SOCMA's members are batch and custom

                    chemical manufacturers who are the highly innovative, entrepreneurial and

                    customer-driven  sector of the  U.S.  chemical industry.  The majority of

                    SOCMA's members are small businesses with annual sales of less than $50

                    million and fewer than 50  employees.   SOCMA assists its members in

                    improving their  environmental, safety, and health performance through

                    various programs focusing  on continuous improvement.  A bi-monthly

                    newsletter provides information on legislative and regulatory developments,

                    as well as on education and training opportunities.  SOCMA holds an annual

                    meeting in May and also sponsors INFORMEX, the largest custom chemical

                    trade show in the U.S.   In  addition, SOCMA's Association Management

                    Center includes two dozen self-funded groups that focus on single chemical

                    issues.

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                            Contacts/References

IX.  CONTACTS/ACKNOWLEDGMENTS/REFERENCES

Contacts3

                      For  further  information on selected topics within the  plastic resin and

                      manmade fiber industries,  a list of publications and contacts are provided

                      below.

Name

Sally Sasnett

Bob Rosensteel

George Jett

Bob Barker

Lucinda Schofer

David Gustafson

John Dege

Bob Lambour

Brent Smith

Jim Kachtick

Lynne Harris

Organization

EPA, Office of

Compliance

EPA, OAQPS

EPA, Office of Water

AFMA

CMA

Dow Chemical

Du Pont

Exxon

NC State

Occidental Chemical

SPI

Telephone

202-564-7074

919-541-5608

202-260-7151

202-296-6508

703-741-5231

517-636-2953

302-773-0900

713-870-6017

919-515-6548

713-215-7602

202-974-5217

Subject

Compliance assistance

Industrial processes and regulatory

requirements (CAA)

Industrial processes and effluent guidelines

Industrial processes

Industrial resources and regulatory

requirements

Regulatory requirements and polyethylene

manufacture

Regulatory requirements and synthetic fiber

manufacture

Regulatory requirements, polyethylene and

polypropylene manufacture

Manmade fibers processes and pollution

prevention methods

Regulatory requirements and PVC

manufacture

Industrial resources and regulatory

requirements

AFMA: American Fiber Manufacturers Association

CMA.: Chemical Manufacturers Association

CAA: Clean Air Act

OAQPS: Office of Air Quality Planning and Standards

SPI: Society of the Plastics Industry

 Many of the contacts listed below have provided valuable background information and comments during development

of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse

all statements made within this notebook.

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                                   References

 References

Section II - Introduction

 1) American Fiber Manufacturers Association, Inc. Comments on draft of this document, AFMA,

       1997.



 2) Brydson, J.A., Plastics Materials, 6th edition, Butterworth-Heinemann Ltd., Oxford, 1995.



 3) Linton,  G. E. Natural and Manmade Textile Fibers: Raw material to finished fabric. Duell,

       Sloan and Pearce, New York, 1966.



 4) Modern Plastics Encyclopedia,  Mid-November 1994 Issue, volume 71, no. 12, McGraw-Hill,

       Inc., New York, 1994.



 5) Society of the Plastics Industry, Inc., Facts and Figures of the U.S. Plastics Industry,  1995

       edition, SPI, Washington, DC, 1995.



 6) U.S. Department of Commerce, United States Industrial Outlook 1994, US Department of

       Commerce, Washington, DC, 1994.



 7) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention in

       the  Textile Industry, EPA, Office  of Research and Development, Washington,  DC.,

       September,  1995.



 8) U.S. International Trade Commission, Industry and Trade Summary: Manmade Fibers, US  ITC,

       Washington, DC., April,  1995, USITC Publication #2874.



 9) U.S. Office of Management and Budget, Standard Industrial Classification Manual, U.S. OMB,

       1987.



 10) Ward's Business Directory of U.S. Private and Public Companies,  Gale Research, Inc., 1996.

Section III - Industrial Process Description	



1) American Fiber Manufacturers Association, Comments on draft of this document, 1997.



2) Clements, J.W. and Thompson, J.P., Cleaner Production: An Industrial Example,  Journal of

       Cleaner Production, volume 1, no. 1, 1993.



3) Chemical Manufacturers Association, CMA  Waste Minimization Resource Manual, CMA,

       Washinton, DC, 1989.

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                                   References

4) Grayson, M. (ed.), Encyclopedia of Textiles, Fibers, and Nonwoven Fabrics, John Wiley and

       Sons, New York, 1984.



5) Kent, J.A. (ed.), Riegel's Handbook of Industrial Chemistry, Van Nostrand Reinhold, New York,

       1992.



6) Kroschwitz, J.I. (ed.), Encyclopedia of Polymer Science and Engineering, volume 12,  John Wiley

       and Sons, New York, 1986.



7) Lewis, Sr., R.J. Rowley's Condensed Chemical Dictionary, Van Nostrand Reinhold Company,

       New York, 1993.



8) Masters, G.M. Introduction to Environmental Engineering and Science. Prentice-Hall, Inc.,  New

       York, 1991.



9) McKetta, J.J. (ed.),  Encyclopedia of Chemical Processing and Design, volume 39, Marcel

       Dekker, Inc., New York,  1992.



10) New Jersey Hazardous Waste Facilities Sitings Commission, A Study of Hazardous Waste Source

       Reduction and Recycling in Four Industry Groups in New Jersey, Commissioned by  New

       Jersey Hazardous Waste Facilities Sitings Commission, Trenton, NJ, April, 1987.



11) Randall, P.M., "Pollution Prevention Strategies for Minimizing of Industrial Wastes in the Vinyl

       Chloride Monomer - Polyvinyl Chloride Industry," Environmental Progress, volume 13, no.

       4, November, 1994.



12) Rodriguez,  F., Principles of Polymer Systems, fourth edition, Taylor and Francis, Washington,

       DC., 1996.



13) Smith, W.M. (ed.), Manufacture of Plastics: Volume 1, Reinhold Publishing Corporation,  New

       York, 1964.



14) Society of the Plastics Industry, Comments on draft of this document, 1997.



15) Society of the Plastics Industry, Operation Clean Sweep: A Manual on Preventing Pellet Loss.

       SPI, Washington, DC, 1994.



16) Synthetic Organic Chemical Manufacturers Association, SOCMA Pollution Prevention Study.

       Prepared for  SOCMA, Washington, DC, January 1993.



17) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention

       in the Textile Industry, EPA, Office of Research and Development, September, 1995.



18) U.S. Environmental  Protection Agency, AP-42, EPA, Office of Air and Radiation, 1993.

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                                   References

 19) U.S. Environmental Protection Agency, Plastic Pellets in the Aquatic Environment: Sources and

       Recommendations,^?^., Office of Water, Washington, DC., December, 1992.



 20)  U.S.  Environmental Protection Agency, Development Document for Effluent Limitations

       Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers, Point

       Source Category, Volumes 1 and 2, EPA, Office of Water Regulations and Standards,

       October 1987.



 21)  U.S.  Environmental Protection Agency,  Control  of Volatile  Organic Emissions from

       Manufacture of Synthesized Pharmaceutical Products, EPA, Office of Air Quality Planning

       and Standards, 1978.



 22) U.S. International Trade Commission, Industry and Trade Summary: Manmade Fibers, USITC,

       Washington, DC., Publication # 2874, April, 1995.



 23) Wellman, Inc. Comments on draft of this document, 1997.

 Section TV - Releases and Transfers Profile	



 1) Lewis, Sr., R.J. Rowley's Condensed Chemical Dictionary, Van Nostrand Reinhold Company,

       New York, 1993.

Section V - Pollution Prevention	



1) Chemical Manufacturers Association, Desiring Pollution Prevention in to the Process: Research

       Development and Engineering, Chemical Manufacturers Association, Washington, DC, 1993.



2) Chemical Manufacturers Association, Preventing Pollution in the Chemical Industry: Five Years

       of Progress, CMA, Washington, DC, 1992.



3) Clements, J.W. and Thompson, J.P., Cleaner Production: An Industrial Example, Journal of

       Cleaner Production, volume 1, no. 1, 1993.



4) Clevenger,  L. and Hassell, J., Case Study: From Jump Start to High Gear - How Du Pont is

       Cutting Costs by Boosting Energy Efficiency, Pollution Prevention Review, Summer 1994.



5) Elley, D., DCS's On-line Information Improves resin Process Consistency, Instrumentation and

       Control Systems, volume 64, no. 11, 1991.



6) Kikta, A. J., Case Study: Using a Six-Step Organizational Framework to establish a Facility P2

       Program, Pollution Prevention Review, Spring 1994.

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                                  References

7) Manufacture of Plastics: Volume 1, W.M. Smith (ed), Reinhold Publishing Corporation, New

       York, 1964.



8) North Carolina Department of Environment, Health, and Natural Resources, Case Studies: A

       Compilation of Successful Waste Reduction Projects Implemented by North  Carolina

       Businesses and Industries,  NC DEHNR, Office of Waste Reduction, Industrial  Pollution

       Prevention Program, Raleigh, NC, December 1995.



9) Smith, G.M., IV,  Polyester Film Division's Waste Minimization/Detoxification Activities,

       Chemical  Manufacturers  Association  Waste Minimization  Workshop  Proceedings,

       Washington, DC, 1987.



10) Synthetic Organic Chemical Manufacturers Association, SOCMA Pollution Prevention Study.

       Prepared for SOCMA, Washington, DC, January 1993.



11) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention

       in the  Textile  Industry,  EPA,  Office of Research and Development, Washington, DC,

       September, 1995.



12) U.S. Environmental Protection Agency, Retrospective Analysis of Compliance Strategies and

       Pollution Prevention in the Organic Chemicals, Plastics and Synthetic Fibers Industry, EPA,

       Office of the Administrator, Washington, DC, December, 1993, (EPA Contract No. 68-C3-

       0302).



13)   Better  Housekeeping  and  Training  of  Operating   Personnel  Reduces   Liability,

       http://es.inel.gov/studies/cs382.html.



14) Monomer Storage and Handling Improvements Reduce Emissions at Novacor Chemicals, Inc.,

       http://nben.org/otacases/novacor.html.



15) New Value Packing Material Reduces Leaking Control Valves at Texas Eastman in Longview,

       http://es.inel.gov/studies/eastx-d.html.



\6)Fact   Sheet:    Source   Reduction   and   Recycling   Lead   to   P2    Efforts,

       http://es.inel.gov/techinfo/facts/cma/cma-fs3.html.



17) On-Site Recycle and Reuse of Alcohol Wash Solution, http://es.inel.gov/studies/cs435.html.



 18) Modifying Rinse Procedures for Phenolic Batch Reactors Reduced Virgin Phenolic Resin,

       http ://es. inel. gov/studies/cs20. html.



 19) Plastics Industry Emphasizes  Need for Research in Recycling of Hazardous Waste,

       http ://es.inel.gov/studies/hml 10053 .html.

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                                   References

 Section VI - Statutes and Regulations

 1) Federal Register, Vol. 57, No. 177, September 11, 1992.



 2) Federal Register, Vol. 58, No. 130, July 9, 1993.



 3) U.S. Environmental Protection Agency, Draft Polymer Exemption Guidance Manual, EPA, Office

        of Pollution Prevention and Toxics, March 29, 1995.



 4) U.S. Environmental Protection Agency, Development Document for Effluent Limitations

        Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers, Point

        Source Category, Volumes 1  and 2, EPA,  Office of Water Regulations and Standards,

        October 1987.





 Section Vm - Compliance Activities and Initiatives	



 1) Society of the Plastics Industry, Operation Clean Sweep: A Manual on Preventing Pellet Loss.

        SPI, Washington, DC, 1994.

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                               APPENDIX A

      INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK



         Electronic Access to this Notebook via the World Wide Web (WWW)

This Notebook is available on the Internet through the World Wide Web.  The Enviro$en$e

Communications Network is a free, public, interagency-supported system operated by EPA's Office

of Enforcement and Compliance Assurance and the Office of Research and Development. The

Network allows regulators, the regulated community, technical experts, and the general public to

share information regarding: pollution prevention and innovative technologies; environmental

enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of

contact for services and equipment; and other related topics. The Network welcomes receipt of

environmental messages, information, and data from any public or private person or organization.



ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB



      To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide

      Web Browser to the following address:

      http://es.epa.gov/comply/sector/index.html

      or use





      WWW.epa.gOV/OeCa -   then select the button labeled Industry and Gov't

                                    Sectors and select the appropriate sector from the

                                    menu.  The Notebook will be listed.



      Direct technical questions to the Feedback function at the bottom of the web page or to

      Shhonn Taylor at (202) 564-2502

                                  Appendix A

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