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).
Sector Notebook Project
105
September 1997
image:
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.
Sector Notebook Project
106
September 1997
image:
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
Sector Notebook Project
107
September 1997
image:
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.
Sector Notebook Project
108
September 1997
image:
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.
Sector Notebook Project
109
September 1997
image:
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.
Sector Notebook Project
110
September 1997
image:
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.
Sector Notebook Project
111
September 1997
image:
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.
Sector Notebook Project
112
September 1997
image:
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.
Sector Notebook Project
113
September 1997
image:
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.
Sector Notebook Project
114
September 1997
image:
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.
Sector Notebook Project
115
September 1997
image:
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.
Sector Notebook Project
116
September 1997
image:
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.)
Sector Notebook Project
117
September 1997
image:
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.
Sector Notebook Project
118
September 1997
image:
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.
Sector Notebook Project
119
September 1997
image:
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.
Sector Notebook Project
120
September 1997
image:
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
Sector Notebook Project
121
September 1997
image:
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
Sector Notebook Project
122
September 1997
image:
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
Sector Notebook Project
123
September 1997
image:
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
Sector Notebook Project
124
September 1997
image:
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.
Sector Notebook Project
125
September 1997
image:
Page 126 intentionally left blank.
image:
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
Sector Notebook Project
127
September 1997
image:
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
Sector Notebook Project
128
September 1997
image:
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
Sector Notebook Project
129
September 1997
image:
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
Sector Notebook Project
130
September 1997
image:
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.
Sector Notebook Project
131
September 1997
image:
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.
Sector Notebook Project
132
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
133
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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.
Sector Notebook Project
134
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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.
Sector Notebook Project
135
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
136
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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.
Sector Notebook Project
137
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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).
Sector Notebook Project
138
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
139
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
140
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
141
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
142
September 1997
image:
Plastic Resin and Manmade Fiber
Statutes and Regulations
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
Sector Notebook Project
143
September 1997
image:
r
Plastic Resin and Manmade Fiber
Statutes and Regulations
categories. This section (40 CFRPart 723.250(d)) excludes certain polymers
from reduced reporting requirements, namely: certain cationic polymers;
polymers that do not meet elemental restrictions; polymers that are reasonably
predicted to decompose, degrade, or depolymerize; and polymers which are
produced from monomers and/or other reactants which are not on the TSCA
inventory or otherwise exempted from reporting under a §5 exemption.
VI.C. Pending and Proposed Regulatory Requirements
Clean Air Act
NESHAPfor Formaldehyde-based Resin Manufacturers
Presumptive MACT standards were published for amino, phenolic, and acetal
resins in July 1996. These resins use formaldehyde as their primary building
block. A NESHAP for amino and phenolic resins is expected to be proposed
in 1997 and will reduce emissions, primarily, of formaldehyde and methanol.
Over 100 facilities are expected to be affected by this rule. EPA is also
expecting to propose a NESHAP for acetal resins which will affect 3 facilities.
For more information, please contact John Schaefer at 919-541-0296.
NESHAPfor Polyether Polyols
A proposed rule for polyether polyols is expected to be published in 1997.
Roughly 50 major sources in the United States are expected to be affected by
this regulation. For more information, please contact David Svendsgaard at
919-541-2380.
NESHAPfor Polycarbonate Resin Manufacturers
This rule, scheduled to be proposed in 1997, will reduce emissions from
polycarbonate resin facilities. It is anticipated that only two major sources in
the United States will be affected by this regulation. For more information,
please contact Mark Morris at 919-541-5416.
NESHAPfor Acrylic and Modacrylic Fiber Manufacturers
EPA is working on a rule to reduce emissions from acrylic and modacrylic
fiber manufacturers. This rule is scheduled to be proposed in 1997 and is
expected to primarily reduce emissions of acrylonitrile and vinyl acetate. Only
two major sources in the United States will be affected by this regulation. For
more information, contact Leonardo Ceron at 404-562-9129.
Sector Notebook Project
144
September 1997
image:
Plastic Resin and Manmade Fiber
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
Sector Notebook Project
145
September 1997
image:
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),
Sector Notebook Project
146
September 1997
image:
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.
Sector Notebook Project
147
September 1997
image:
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.
Sector Notebook Project
148
September 1997
image:
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.
Sector Notebook Project
149
September 1997
image:
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.
Sector Notebook Project
150
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance and Enforcement Profile
c
eg
a
'1
*
.a
•M
on
S
U
!>•*
«
g
§.2
:_
«J «
<U 3
11
n. v
S £
0 fe
U v
•sl
95 c!
"a e
S ^
0
u
<2
w
«
i
S
3
•-9
M
K
O
fc,
w
n
u
pa
g 1
^ S-S
•2 ja
ll||
£ £ <c
+* w
SS <U TJ fi
" *» « S
a « s -|
•<->
C
•"* £ c
1 1 1
a "*•
w
S fe S >»
•5 ° « S a
5 '"' 0 u .°
* "s ^ (S <j
Ed
HI!
« o -B «
•5 ^ M g
1— H
(•M W
e S
s- 2
S C
II
ZS
w *O
.2 S
3 «
i &
j-g
3 S
£.s
c
o
I
I— H
1— <
0
o
in
0
o
in
oo
"""
o
CS
p
S
<N
i— i
^.
»— i
0
2
00
in
-
en
o
en
en
i— i
HH
m
0
0
0
o
ON
ex)
0
>n
00
VO
oo
en
a
i — i
m
0
0
es
CM
00
$
CS)
CNl
00
oo
0
ON
1— 1
en
O
0
en
en
£
ON
m
— •
en
O
in
>
>n
ONI
0
ON
ON]
£
VO
r-
oo
ON)
o
ON
o
en
en
in
*
>n
0
0
N?
0
0
~
rt
oo
o
ON)
in
SO
1 — t
ON
0
0
0
0
o
§
-
1—1
ON]
ON)
~
-
^
§
r~-
0
0
0
0
0
0
o
en
^
en
i — i
0
in
a
OS
0
0
O
0
0
o
CN)
' — '
OO
^
^
m
X
o\
o
o
0\
S
0
vO
c-
ON
CNl
a
oo
o
exf
vo
cs
ON
en
j
0
Sector Notebook Project
151
September 1997
image:
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).
Sector Notebook Project
152
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance and Enforcement Profile
§
OS
00
S
!l
§
o
Ed
<".
y
e
-5
R
ini
In
ini
C
and
xtil
lnor
o
gs
hip
Sector Notebook Project
153
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance and Enforcement Profile
K
3
VO ON VO
O
JS
SS
5
O
1
W
*.l
%
£2
U
J
M
Secto
*Percent
ithout a
Sector Notebook Project
154
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance and Enforcement Profile
ll
Hl
n
1
<*,
1
c.
s
M,
ry Sect
C
C
K
U
ted
8-
Ai
Sector Notebook Project
155
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance and Enforcement Profile
"
JS
ss
s?
13 ll
*3s
s?
11
II
i
§
s
P
i
C
Ph
bri
Sector Notebook Project
156
September 1997
image:
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
Sector Notebook Project
157
September 1997
image:
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.
Sector Notebook Project
158
September 1997
image:
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.
Sector Notebook Project
159
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance Activities and Initiatives
Table 29: Plastic Resin and Manmade Fiber Industries Participation in the 33/50 Program
Parent Company
;;Hcadquai1ers Location)
AIR PRODUCTS AND CHEMICALS
ALLENTOWN, PA
AKZO NOBEL INC
CHICAGO, IL
ALBEMARLE CORPORATION
RICHMOND. VA
ALLIED-SIGNAL INC
vtORRISTOWN, NJ
AMERICAN PLASTIC
TECHNOLOGIES
vlIDDLEFIELD, OH
AMOCO CORPORATION
CHICAGO, IL
ARISTECH CHEMICAL
CORPORATION
'ITTSBURGH, PA
ASHLAND OIL INC
UJS8ELL.KY
ATLANTIC RICHFIELD COMPANY
,QS ANGELES, CA
3 F GOODRICH COMPANY
AKRON, OH
BASF CORPORATION
vlOUNT OLIVE, NJ
30RDEN CHEM & PLAS LTD
PARTNR
COLUMBUS, OH
iORDEN INC
NEW YORK, NY
«JLK MOLDING COMPOUNDS INC
SAINT CHARLES, IL
CAPITAL RESIN CORPORATION
COLUMBUS, OH
CARGILL DETROIT CORPORATION
CLAWSON, MI
CHEVRON CORPORATION
SAN FRANCISCO, CA
COURTAULDS FIBERS
AXIS, AL
CYTEC INDUSTRIES
WESTPATERSON.NJ
Company-
Owned
Facilities
Reporting
33/50
("Mifttnioal^
i
i
6
1
1
1
7
2
1
6
3
1
2
1
1
5
1
1
3
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
50
13
51
50
50
50
18
50
2
50
50
***
*
40
50
40
50
***
50
1988TRI
Releases and
Transfers of
33/50
Chemicals
fponnHs'}
0
158,650
960,620
0
750
0
1,648,348
207,440
47,543
31,478
241,760
11,781
105
48,555
42,480
165,288
56,216
0
226,059
1994TRI
Releases and
Transfers of
33/50
Chemicals
fpmmH^
411
87,268
1,181,712
10
0
30
159,614
4,632
3,158
864
45,195
26,393
161
0
14,077
23,836
72,044
3,250
56,230
Actual %
Reduction for
Facilities
(1988-1994)
—
45
-23
—
100
—
90
98
93
97
81
-124
-53
100
67
86
-28
—
75
Sector Notebook Project
160
September 1997
image:
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
161
September 1997
image:
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
Sector Notebook Project
162
September 1997
image:
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)
Sector Notebook Project
163
September 1997
image:
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)
Sector Notebook Project
164
September 1997
image:
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$e Program was started in 1994 by EPA's Office of Solid Waste
and Emergency Response. The program is aimed at reducing municipal solid
wastes by promoting waste prevention, recycling collection and the
Sector Notebook Project
165
September 1997
image:
Plastic Resin and Manmade Fiber
Compliance Activities and Initiatives
manufacturing and purchase of recycled products. As of 1997, the program
had about 500 companies as members, one third of whom are Fortune 1000
corporations. Members agree to identify and implement actions to reduce
their solid wastes setting waste reduction goals and providing EPA with
yearly progress reports. To member companies, EPA, in turn, provides
technical assistance, publications, networking opportunities, and national and
regional recognition. (Contact: WasteWi$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.
Sector Notebook Project
166
September 1997
image:
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
Sector Notebook Project
167
September 1997
image:
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
Sector Notebook Project
168
September 1997
image:
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.
Sector Notebook Project
169
September 1997
image:
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.
Sector Notebook Project
170
September 1997
image:
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
Sector Notebook Project
171
September 1997
image:
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.
Sector Notebook Project
172
September 1997
image:
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.
Sector Notebook Project
173
September 1997
image:
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.
Sector Notebook Project
174
September 1997
image:
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.
Sector Notebook Project
175
September 1997
image:
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.
Sector Notebook Project
176
September 1997
image:
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.
Sector Notebook Project
177
September 1997
image:
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.
Sector Notebook Project
178
September 1997
image:
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
image:
image: