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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
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                 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
 image: 








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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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
 image: 








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
 image: 








 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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 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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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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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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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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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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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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 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
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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).
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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.
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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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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
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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
26
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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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 Plastic Resin and Manmade Fiber
                 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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 Plastic Resin and Manmade Fiber
                  Industrial Process Description
  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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 Plastic Resin and Manmade Fiber
                 Industrial Process Description
                     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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Plastic Resin and Manmade Fiber
                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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Plastic Resin and Manmade Fiber
                Industrial Process Description
       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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 Plastic Resin and Manmade Fiber
                 Industrial Process Description
   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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Plastic Resin and Manmade Fiber
                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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 Plastic Resin and Manmade Fiber
                 Industrial Process Description
        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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Plastic Resin and Manmade Fiber
               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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 Plastic Resin and Manmade Fiber
                 Industrial Process Description
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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                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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                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
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            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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                     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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                    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
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 Plastic Resin and Manmade Fiber
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                     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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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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Plastic Resin and Manmade Fiber
                 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.
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 Plastic Resin and Manmade Fiber
                 Release and Transfer Profile
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Plastic Resin and Manmade Fiber
                 Release and Transfer Profile





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Sector Notebook Project
71
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                                                             Release and Transfer Profile
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Sector Notebook Project
                                         12
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75
September 1997
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Plastic Resin and Manmade Fiber
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Sector Notebook Project
76
September 1997
 image: 








Plastic Resin and Manmade Fiber
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 Sector Notebook Project
77
September 1997
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                                            78
                           September 1997
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79
September 1997
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80
September 1997
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81
September 1997
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                              82
September 1997
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Sector Notebook Project
83
September 1997
 image: 








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Sector Notebook Project
84
September 1997
 image: 








Plastic Resin and Manmade Fiber
                Release and Transfer Profile








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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
                 Release and Transfer Profile


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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
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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.
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90
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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.
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91
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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.
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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.
Sector Notebook Project
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 Plastic Resin and Manmade Fiber
                   Release and Transfer Profile
                     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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 Plastic Resin and Manmade Fiber
                   Release and Transfer Profile
                     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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Plastic Resin and Manmade Fiber
                 Release and Transfer Profile
                    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
                 Release and Transfer Profile
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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Plastic Resin and Manmade Fiber
                  Release and Transfer Profile
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
                 Release and Transfer Profile
       Figure 18; Summary of TRI Releases and Transfers by Industry
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Lumber and Wood Products
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Stone, Clay, and Concrete
Iron and Steel
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3731
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Motor Vehicles, Bodies,
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Plastic Resin and Manmade Fiber
                 Release and Transfer Profile












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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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 Plastic Resin and Manmade Fiber
                           Pollution Prevention
                      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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Plastic Resin and Manmade Fiber
                           Pollution Prevention
                      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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 Plastic Resin and Manmade Fiber
                           Pollution Prevention
                      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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Plastic Resin and Manmade Fiber
                           Pollution Prevention
                      •       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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 Plastic Resin and Manmade Fiber
                           Pollution Prevention
                      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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Plastic Resin and Manmade Fiber
                          Pollution Prevention
                     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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 Plastic Resin and Manmade Fiber
                          Pollution Prevention
                      •      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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Plastic Resin and Manmade Fiber
                                                         Pollution Prevention
    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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 Plastic Resin and Manmade Fiber
                                                          Pollution Prevention
      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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Plastic Resin and Manmade Fiber
                                                         Pollution Prevention
     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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 Plastic Resin and Manmade Fiber
                                                         Pollution Prevention
      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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Plastic Resin and Manmade Fiber
                                                         Pollution Prevention
     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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 Plastic Resin and Manmade Fiber
                                                          Pollution Prevention
      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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Plastic Resin and Manmade Fiber
                     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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Plastic Resin and Manmade Fiber
                      Statutes and Regulations
                     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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                                  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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Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
                     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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Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
                    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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Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
                    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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Plastic Resin and Manmade Fiber
         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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 Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
 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





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 Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
                          Compliance and Enforcement Profile
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 Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
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Plastic Resin and Manmade Fiber
         Compliance and Enforcement Profile


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Plastic Resin and Manmade Fiber
         Compliance and Enforcement Profile
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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
          Compliance and Enforcement Profile
                    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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Plastic Resin and Manmade Fiber
          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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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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Plastic Resin and Manmade Fiber
         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
 Sector Notebook Project
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Plastic Resin and Manmade Fiber
         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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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
          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$e Program was started in 1994 by EPA's Office of Solid Waste
                    and Emergency Response.  The program is aimed at reducing municipal solid
                    wastes  by promoting waste  prevention, recycling  collection  and  the
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Plastic Resin and Manmade Fiber
          Compliance Activities and Initiatives
                    manufacturing and purchase of recycled products.  As of 1997, the program
                    had about 500 companies as members, one third of whom are Fortune 1000
                    corporations.  Members agree to identify and implement actions to reduce
                    their solid wastes setting waste reduction goals and providing EPA with
                    yearly progress reports.  To member companies, EPA, in turn, provides
                    technical assistance, publications, networking opportunities, and national and
                    regional recognition.  (Contact: WasteWi$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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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
         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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 Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
           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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Plastic Resin and Manmade Fiber
          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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Plastic Resin and Manmade Fiber
                            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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 Plastic Resin and Manmade Fiber
                                   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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Plastic Resin and Manmade Fiber
                                   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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 Plastic Resin and Manmade Fiber
                                   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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Plastic Resin and Manmade Fiber
                                  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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 Plastic Resin and Manmade Fiber
                                   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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