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Part CFR 63 Subpart AA). The HON also includes innovative provisions such
as emissions trading, that offer industry flexibility in complying with the rule's
emissions goals.
Subsets of the plastic resin and manmade fiber industries are regulated under
other NESHAPs. EPA published a final rule for epoxy resins and 
non-nylon
polyamide resins in March 1995. The rule was expected to reduce
epichlorohydrin emissions from process vents and storage tank emissions. In
September 1996, EPA published a final rule for Group I Polymers and Resins
(61 FR 46906) under 40 CFR part 63, Subpart U. This rule focused on
reducing emissions from facilities that make certain elastomers used in the
manufacture of synthetic rubber products. The rule was expected to reduce
emissions of styrene, hexane, toluene, and other toxics. Provisions on
pollution prevention, as well as a market-based provision on emissions
averaging, were also included in the rule.
In September 1996, EPA also published a final rule for Designated Group IV
Polymers and Resins (61 FR 48208) under 40 CFR part 63, Subpart JJJ. This
rule was expected to reduce emissions of air toxics from poly(ethylene
terephlate), nitrile, and styrene-based resins facilities. The rule was expected
to reduce styrene, butadiene, and methanol emissions from storage vessels,
process vents, equipment leaks, and wastewater operations. A direct final
notice (62 FR 1869) was published on January 14, 1997, which extended the
heat exchange system compliance date for the Group I rule and the equipment
leak compliance dates for both the Group I and Group IV rules. Other
NESHAPs that apply to the industry cover vinyl chloride manufacturers (40
CFR Part 61 Subpart F), benzene equipment leaks (40 CFR Part 61 Subpart
J), fugitive emissions (40 CFR Part 61 Subpart V), benzene emissions from
benzene storage vessels (40 CFR Part 61 Subpart Y), benzene emissions from
benzene transfer operations (40 CFR Part 61 Subpart BB), and benzene waste
operations (40 CFR Part 61 Subpart FF).
Clean Water Act
The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,
gives EPA the authority to regulate effluents from sewage treatment works,
chemical plants, and other industrial sources into waters. The act sets "best
available" technology standards for treatment of wastes for both direct and
indirect (discharged to a Publicly Owned Treatment Work (POTW))
discharges. EPA originally promulgated effluent limitations guidelines and
standards for the plastic resin and manmade fiber industries in two phases.
Phase I, covering 13 products and processes, was promulgated on April 5,
1974 (39 FR 12502), and Phase II, covering eight additional products and
processes, was promulgated on January 23, 1975 (40 FR 3716). In 1976,
these regulations were challenged and eventually remanded by the federal
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circuit court in FMC Corp. versus Train. 539F.2d 973 (4th Cir. 1976). As
a result, EPA withdrew both the Phase I and II plastic resin and manmade
fiber regulations on August 4, 1976 (41 FR 32587) (EPA, 1987).
On November 5, 1987, EPA proposed final effluent guidelines (52FR42522)
for the organic chemical, plastics, and synthetic fiber industries (OCPSF) (40
CFR Part 414). The effluent guidelines include limits for biological oxygen
demand (BOD), total suspended solids (TSS), and acidity (pH). In this rule,
limits are specified for facilities that manufacture rayon fibers, other synthetic
fibers, thermoplastic resins, and thermoset resins.
The majority of this rule was upheld by the federal courts in 1989 when the
Chemical Manufacturers Association sued the EPA. The Court left the rule
in effect pending further rulemaking but remanded three aspects of the
OCPSF guidelines. The Court remanded the New Source Performance
Standards (NSPS) and the Pretreatment Standards for New Sources (PSNS)
for consideration of whether zero discharge limits were appropriate for the
industries; the subcategorization of the industries into two subcategories
imposing differing limitations based on Best Available Technology
Economically Achievable (BAT); and limitations for BAT Subpart J
pollutants that were based upon in-plant biological treatment technology.
The EPA decided not to revise the NSPS and PSNS standards or the BAT
subcategorization scheme and promulgated two sets of amendments to the
rule in 1992 and 1993. On September 11, 1992, EPA promulgated a first set
of amendments (57 FR 41836) to the OCPSF rule. These amendments
allowed regulatory authorities to establish alternative cyanide limitations and
standards for cyanide resulting from complexing of cyanide at the process
source and establish alternative metals limitations and standards to
accommodate low background levels of metals in non-"metal-bearing waste
streams." These amendments also allowed regulatory authorities to specify
the method for determining five-day biochemical oxygen demand and total
suspended solids effluent limitations for direct discharge plants (FR,
September 11, 1992).
On July 9, 1993, EPA promulgated the remaining portions of the OCPSF rule
in second set of amendments (58 FR 36872) which added Subpart J
limitations based on BAT and NSPS for 19 additional pollutants. These
amendments also established Pretreatment Standards for Existing Sources
(PSES) and PSNS for 11 of these 19 pollutants. EPA also corrected the
criteria for designating "metal-" and "cyanide-bearing" waste streams. In this
rulemaking, phenol and 2,4-dimethylphenol pretreatment standards were not
promulgated since EPA concluded that they did not pass through POTWs.
The implementation of the guidelines is left to the states who issue NPDES
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permits for each facility. The compliance date for PSES was no later than
July 23, 1996 (FR, July 9, 1993).
The Storm Water Rule (40 CFR §122.26(b)(14) Subparts (i, ii)) requires the
capture and treatment of stormwater at facilities producing chemicals and
allied products, including plastic resin and synthetic fiber manufacture.
Required treatment will remove from stormwater flows a large fraction of
both conventional pollutants, such as suspended solids and biological oxygen
demand (BOD), as well as toxic pollutants, such as certain metals and organic
compounds.
Resource Conservation and Recovery Act
Products, intermediates, and off-specification products generated at plastic
resin and synthetic fiber facilities that are considered hazardous wastes are
listed in 40 CFR Part 261.33(f). Some of the handling and treatment
requirements for RCRA hazardous waste generators are covered under 40
CFR Part 262 and include the following: determining what constitutes a
RCRA hazardous waste (Subpart A); manifesting (Subpart B); packaging,
labeling, and accumulation time limits (Subpart C); and recordkeeping and
reporting (Subpart D).
Many plastic resin and synthetic fiber facilities store some hazardous wastes
at the facility for more than 90 days, and therefore, are a storage facility under
RCRA. Storage facilities are required to have a RCRA treatment, storage,
and disposal facility (TSDF) permit (40 CFR Part 262.34). Some plastic resin
and synthetic fiber facilities are considered TSDF facilities and are subject to
the following regulations covered under 40 CFR Part 264: contingency plans
and emergency procedures (40 CFR Part 264 Subpart D); manifesting,
recordkeeping, and reporting (40 CFR Part 264 Subpart E); use and
management of containers (40 CFR Part 264 Subpart I); tank systems (40
CFR Part 264 Subpart J); surface impoundments (40 CFR Part 264 Subpart
K); land treatment (40 CFR Part 264 Subpart M); corrective action of
hazardous waste releases (40 CFR Part 264 Subpart S); air emissions
standards for process vents of processes that process or generate hazardous
wastes (40 CFR Part 264 Subpart AA); emissions standards for leaks in
hazardous waste handling equipment (40 CFR Part 264 Subpart BB); and
emissions standards for containers, tanks, and surface impoundments that
contain hazardous wastes (40 CFR Part 264 Subpart CC).
A number of RCRA wastes have been prohibited from land disposal unless
treated to meet specific standards under the RCRA Land Disposal Restriction
(LDR) program. The wastes covered by the RCRA LDRs are listed in 40
CFR Part 268 Subpart C and include a number of wastes commonly generated
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at plastic resin and synthetic fiber facilities. Standards for the treatment and
storage of restricted wastes are described in Subparts D and E, respectively.
Many plastic resin and synthetic fiber facilities are also subject to the
underground storage tank (UST) program (40 CFR Part 280). The UST
regulations apply to facilities that store either petroleum products or
hazardous substances (except hazardous waste) identified under the
Comprehensive Environmental Response, Compensation, and Liability Act.
UST regulations address design standards, leak detection, operating practices,
response to releases, financial responsibility for releases, and closure
standards.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA), passed in 1976, gives the
Environmental Protection Agency comprehensive authority to regulate any
chemical substance whose manufacture, processing, distribution in commerce,
use or disposal may present an unreasonable risk of injury to human health or
the environment. Four sections are of primary importance to the plastic resin
and manmade fiber industries. TSCA §5 (new chemicals) mandates that
plastic resin and manmade fiber companies submit pre-manufacture notices
that provide information on health and environmental effects for each new
product and test existing products for these effects (40 CFR Part 720).
TSCA §4 (existing chemicals) authorizes the EPA to require testing of certain
substances (40 CFR Part 790). TSCA §6 gives the EPA authority to prohibit,
limit or ban the manufacture, process and use of chemicals (40 CFR Part
750). For certain chemicals, TSCA §8 also imposes record-keeping and
reporting requirements including substantial risk notification; record-keeping
for data relative to adverse reactions; and periodic updates to the TSCA
Chemical Inventory.
Under §5(h)(4), which grants EPA authority to promulgate rules granting
exemptions to some or all of the premanufacture requirements for new
chemicals, EPA published an exemption rule in 1984 and an amendment to
the rule in 1995. The amendment, entitled Premanufacture Notification
Exemptions (PMN) rule, contained a section on polymers (40 CFR Part
723.250) that allowed polymers that met certain restrictions to be exempt
from some of the reporting requirements for new chemicals. Two exemptions
{40 CFR Part 723.250(e)(l) and (e)(2)} exempt polymers based on molecular
weight and oligomer content. The third exemption (40 CFR Part
723.250(e)(3)) exempts certain polyester polymers which use particular
monomers and reactants.
In addition to meeting the specific criteria of one of the three exemption
types, the new polymer must also not fall into one of the prohibited
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categories. This section (40 CFRPart 723.250(d)) excludes certain polymers
from reduced reporting requirements, namely: certain cationic polymers;
polymers that do not meet elemental restrictions; polymers that are reasonably
predicted to decompose, degrade, or depolymerize; and polymers which are
produced from monomers and/or other reactants which are not on the TSCA
inventory or otherwise exempted from reporting under a §5 exemption.
VI.C. Pending and Proposed Regulatory Requirements
Clean Air Act
NESHAPfor Formaldehyde-based Resin Manufacturers
Presumptive MACT standards were published for amino, phenolic, and acetal
resins in July 1996. These resins use formaldehyde as their primary building
block. A NESHAP for amino and phenolic resins is expected to be proposed
in 1997 and will reduce emissions, primarily, of formaldehyde and methanol.
Over 100 facilities are expected to be affected by this rule. EPA is also
expecting to propose a NESHAP for acetal resins which will affect 3 facilities.
For more information, please contact John Schaefer at 919-541-0296.
NESHAPfor Polyether Polyols
A proposed rule for polyether polyols is expected to be published in 1997.
Roughly 50 major sources in the United States are expected to be affected by
this regulation. For more information, please contact David Svendsgaard at
919-541-2380.
NESHAPfor Polycarbonate Resin Manufacturers
This rule, scheduled to be proposed in 1997, will reduce emissions from
polycarbonate resin facilities. It is anticipated that only two major sources in
the United States will be affected by this regulation. For more information,
please contact Mark Morris at 919-541-5416.
NESHAPfor Acrylic and Modacrylic Fiber Manufacturers
EPA is working on a rule to reduce emissions from acrylic and modacrylic
fiber manufacturers. This rule is scheduled to be proposed in 1997 and is
expected to primarily reduce emissions of acrylonitrile and vinyl acetate. Only
two major sources in the United States will be affected by this regulation. For
more information, contact Leonardo Ceron at 404-562-9129.
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VH. COMPLIANCE AND ENFORCEMENT PROFILE
Background
Until recently, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach allows the
Agency to track compliance with the Clean Air Act, the Resource
Conservation and Recovery Act, the Clean Water Act, and other
environmental statutes. Within the last several years, the Agency has begun
to supplement single-media compliance indicators with facility-specific,
multimedia indicators of compliance. In doing so, EPA is in a better position
to track compliance with all statutes at the facility level, and within specific
industrial sectors.
A major step in building the capacity to compile multimedia data for industrial
sectors was the creation of EPA's Integrated Data for Enforcement Analysis
(IDEA) system. IDEA has the capacity to "read into" the Agency's single-
media databases, extract compliance records, and match the records to
individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within the
sector that are well defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section II). With sectors dominated by small
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businesses, such as metal finishers and printers, the reporting universe within
the EPA databases may be small in comparison to Census data. However, the
group selected for inclusion in this data analysis section should be consistent
with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections and enforcement actions, and reflect solely EPA, State, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (April 1, 1992 to March 31, 1997) and the other for
the most recent twelve-month period (April 1, 1996 to March 31, 1997). The
five-year analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases. These
databases do not provide data on whether inspections are state/local or EPA-
led. However, the table breaking down the universe of violations does give
the reader a crude measurement of the EPA's and states' efforts within each
media program. The presented data illustrate the variations across EPA
Regions for certain sectors.2 This variation may be attributable to state/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used in
production, or historical noncompliance. Hence, the exhibited data do not
rank regional performance or necessarily reflect which regions may have the
most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) ~ this system assigns a common facility
number to EPA single-media permit records. The FINDS identification
number allows EPA to compile and review all permit, compliance,
enforcement and pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) ~ is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FINDS identification number to link separate data
1 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA,
VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VH
(IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ED, OR,
WA),
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records from EPA's databases. This allows retrieval of records from across
media or statutes for any given facility, thus creating a "master list" of
records for that facility. Some of the data systems accessible through IDEA
are: AIRS (Air Facility Indexing and Retrieval System, Office of Air and
Radiation), PCS (Permit Compliance System, Office of Water), RCRIS
(Resource Conservation and Recovery Information System, Office of Solid
Waste), NCDB (National Compliance Data Base, Office of Prevention,
Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental
and Liability Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside sources
such as Dun and Bradstreet and the Occupational Safety and Health
Administration (OSHA). Most data queries displayed in notebook sections
IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search ~ are based on the universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements (metal mining, nonmetallic mineral mining, electric power
generation, ground transportation, water transportation, and dry cleaning), or
industries in which only a very small fraction of facilities report to TRI (e.g.,
printing), the notebook uses the FINDS universe for executing data queries.
The SIC code range selected for each search is defined by each notebook's
selected SIC code coverage described in Section II.
Facilities Inspected — indicates the level of EPA and state agency
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a one-year or five-year
period.
Number of Inspections -- measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections -- provides an average length of time,
expressed in months, between compliance inspections at a facility within the
defined universe.
Facilities with One or More Enforcement Actions — expresses the number
of facilities that were the subject of at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and criminal
enforcement actions. Administrative actions include Notices of Violation
(NOVs). A facility with multiple enforcement actions is only counted once
in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.
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Total Enforcement Actions -- describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes. A
facility with multiple enforcement actions is counted multiple times, e.g., a
facility with 3 enforcement actions counts as 3.
State Lead Actions -- shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use by states of EPA data systems may limit the volume of actions
recorded as state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use their
own data systems.
Federal Lead Actions — shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions result
from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate -- is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. This ratio is a
rough indicator of the relationship between inspections and enforcement. It
relates the number of enforcement actions and the number of inspections that
occurred within the one-year or five-year period. This ratio includes the
inspections and enforcement actions reported under the Clean Water Act
(CWA), the Clean Air Act (CAA) and the Resource Conservation and
Recovery Act (RCRA). Inspections and actions from the TSCA/FIFRA/
EPCRA database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections. Also,
this ratio does not account for enforcement actions arising from non-
inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA, CWA, and
RCRA.
Facilities with One or More Violations Identified ~ indicates the
percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year Noncompliance, Significant
Noncompliance (CWA); Noncompliance and Significant Noncompliance
(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
Priority Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Violation status may
be a precursor to an enforcement action, but does not necessarily indicate that
an enforcement action will occur.
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Media Breakdown of Enforcement Actions and Inspections — four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
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VILA. Plastic Resin and Manmade Fiber Industries Compliance History
Table 24 provides an overview of the reported compliance and enforcement
data for the plastic resin and manmade fiber industries over the past five years
(April 1992 to April 1997). These data are also broken out by EPA Region
thereby permitting geographical comparisons. A few points evident from the
data are listed below.
• The majority of plastic resin and manmade fiber facilities (about 60%)
and inspections over the past five years were in Regions IV, V, and
VI.
• Regions III and II had the second and third largest number of
inspections, respectively, although they ranked fourth and fifth in
terms of number of facilities, respectively.
• Region VI had a high ratio of enforcement actions to inspections
(0.25) compared to other Regions. Region VI also had the highest
number of enforcement actions and facilities with enforcement
actions.
• Region n had the second largest number of enforcement actions (52),
but ranks fifth in number of facilities.
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VII.B. Comparison of Enforcement Activity Between Selected Industries
Tables 25 and 26 allow the compliance history of the plastic resin and
manmade fiber industries to be compared with the other industries covered by
the industry sector notebooks. Comparisons between Tables 25 and 26
permit the identification of trends in compliance and enforcement records of
the industries by comparing data covering the last five years (April 1992 to
April 1997) to that of the past year (April 1996 to April 1997). Some points
evident from the data are listed below.
• The ratio of enforcement actions to inspections for plastic resin and
manmade fiber manufacturing facilities over the past five years (0.09)
was very close to the average across the industries shown (0.08).
• Over the past five years, the average number of months between
inspections was relatively low (8 months) for plastic resin and
manmade fiber facilities. The average across the industries shown was
22 months indicating that, on average, facilities in the plastic resin and
manmade fiber industry are inspected more frequently than facilities
in many other industries.
• While the average enforcement to inspection rate across industries fell
from 0.08 over the past five years to 0.06 over the past year, the
enforcement to inspection rate for plastic resin and manmade fiber
facilities remained at 0.09.
• Only three of the industries shown (petroleum refining, lumber and
wood, and water transportation) had a higher percent of facilities
inspected with enforcement actions over the past year.
Tables 27 and 28 provide a more in-depth comparison between the plastic
resin and manmade fiber industries and other sectors by breaking out the
compliance and enforcement data by environmental statute. As in Tables 25
and 26, the data cover the last five years (Table 27) and the last one year
(Table 28) to facilitate the identification of recent trends. A few points
evident from the data are listed below.
• While the percentage of RCRA inspections remained the same
between the past five years and past year, the percent of enforcement
actions taken under RCRA dropped from 23 percent to 5 percent.
• The Clean Air Act accounted for the largest share of enforcement
actions over the past five years (43 percent) and the past year (51
percent).
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VII.C. Review of Major Legal Actions
Major Cases/Supplemental Environmental Projects
This section provides summary information about major cases that have
affected this sector, and a list of Supplemental Environmental Projects
(SEPs).
VTLC.l. Review of Major Cases
As indicated in EPA's Enforcement Accomplishments Report, FY1995 and
FY1996 publications, four significant enforcement actions were resolved
between 1995 and 1996 for the metal casting industry.
TeknorApex Company: A September 30, 1996 consent agreement and order
resolved TSCA violations by Teknor Apex of Pawtucket, RI. Teknor Apex
had failed to report the identities and volumes of several chemicals
manufactured in 1989, as required by EPA's Inventory Update rule. Teknor
Apex manufactures organic plasticizers, vinyl resins, garden hose, plastic
sheeting, and color pigments. The violations, which occurred at facilities in
Attleboro, MA, and in Brownsville, TN, hampered EPA's efforts to assess the
health and environmental risks of chemical manufacture and distribution. The
settlement provides for a penalty of $52,950 and implementation of SEPs
costing $300,000. Four SEPs at the Attleboro facility will reduce toxic
emissions, reduce and improve the quality of wastewater discharges, and
reduce the volume of industrial wastewater processed at Teknor's on-site
wastewater treatment plant.
Union Carbide Chemicals and Plastics (South Charleston, WV): On May
16, 1995, the Regional Administrator signed a consent order resolving a
RCRA administrative penalty action against Union Carbide Chemicals and
Plastics Company, Inc. (UCC), for violations of the BIF Rule (Boiler and
Industrial Furnace Rule) at UCC's South Charleston, West Virginia, plant.
The complaint alleged failure to: continuously monitor and record operating
parameters; accurately analyze the hazardous waste fed into the boiler; and
properly mark equipment. Under the settlement terms UCC is required to pay
a $195,000 civil penalty and comply with the requirements of the BIF Rule.
Formosa Plastics Co.: On May 31, 1995, a Class I CERCLA 103(a) and
EPCRA 304(a) consent agreement and consent order (CACO) was entered
with Formosa Plastics for numerous releases of vinyl chloride from its Point
Comfort, Texas, facility between February 1989 and August 1992 that were
not reported to the National Response Center (NRC) in a timely manner
following the release. Additionally, the respondent experienced a release of
ethylene dichloride in September 1990, and a release of hydrochloric acid in
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July 1991. Formosa did not report these releases to the NRC, State
Emergency Response Commission (SERC), and Local Emergency Planning
Committee (LEPC) in a timely manner. Formosa agreed to pay a civil
penalty of $50,000 and agreed to construct and maintain a secondary
containment system which will prevent large pressure releases of vinyl
chloride from the facility. The system cost is estimated to be $1.68 million
with an anticipated start-up date of January 1996. Additionally, as part of a
SEP, Formosa agreed to complete the following actions: (1) implement a
chemical safety project for the citizens of Point Comfort, Texas at a cost of
$10,000; (2) permit a chemical safety audit to be performed by a team led by
EPA personnel to review facility emergency response procedures and plans;
(3) develop and implement a risk management program; and (4) provide
funding ($35,000) to support a Region-wide LEPC conference.
VII.C.2. Supplementary Environmental Projects (SEPs)
Supplemental environmental projects (SEPs) are enforcement options that
require the non-compliant facility to complete specific projects. Information
on SEP cases can be accessed via the Internet at EPA's Enviro$en$e website:
http://es.inel.gov/sep.
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VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VTfl.A. Sector-Related Environmental Programs and Activities
Chemical Manufacturer's Association and EPA have developed training
modules, self-audit manuals, and compliance guides for Section 608 of the
Clean Air Act, which covers leak detection and repair. They are discussing
developing plant level compliance guides, auditing protocols, and training
materials for RCRA Subpart CC and other areas.
VHI.B. EPA Voluntary Programs
33/50 Program
The 33/50 Program is a ground breaking program that has focused on
reducing pollution from seventeen high-priority chemicals through voluntary
partnerships with industry. The program's name stems from its goals: a 33%
reduction in toxic releases by 1992, and a 50% reduction by 1995, against a
baseline of 1.5 billion pounds of releases and transfers in 1988. The results
have been impressive: 1,300 companies have joined the 33/50 Program
(representing over 6,000 facilities) and have reached the national targets a
year ahead of schedule. The 33% goal was reached in 1991, and the 50%
goal -- a reduction of 745 million pounds of toxic wastes -- was reached in
1994. The 33/50 Program can provide case studies on many of the corporate
accomplishments in reducing waste (Contact 33/50 Program Director David
Sarokin - 260-6396).
Table 29 lists those companies participating in the 33/50 program that
reported the SIC codes 2821, 2823, or 2824 to TRI. Many of the companies
shown listed multiple SIC codes and, therefore, are likely to carry out
operations in addition to plastic resin and manmade fiber manufacturing. In
addition, the number of facilities within each company that are participating
in the 33/50 program and that report SIC 2821, 2823, or 2824 to TRI are
shown. Finally, where available and quantifiable against 1988 releases and
transfers, each company's 33/50 goals for 1995 and the actual total releases,
transfers and percent reduction between 1988 and 1994 are presented.
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Table 29: Plastic Resin and Manmade Fiber Industries Participation in the 33/50 Program
Parent Company
;;Hcadquai1ers Location)
AIR PRODUCTS AND CHEMICALS
ALLENTOWN, PA
AKZO NOBEL INC
CHICAGO, IL
ALBEMARLE CORPORATION
RICHMOND. VA
ALLIED-SIGNAL INC
vtORRISTOWN, NJ
AMERICAN PLASTIC
TECHNOLOGIES
vlIDDLEFIELD, OH
AMOCO CORPORATION
CHICAGO, IL
ARISTECH CHEMICAL
CORPORATION
'ITTSBURGH, PA
ASHLAND OIL INC
UJS8ELL.KY
ATLANTIC RICHFIELD COMPANY
,QS ANGELES, CA
3 F GOODRICH COMPANY
AKRON, OH
BASF CORPORATION
vlOUNT OLIVE, NJ
30RDEN CHEM & PLAS LTD
PARTNR
COLUMBUS, OH
iORDEN INC
NEW YORK, NY
«JLK MOLDING COMPOUNDS INC
SAINT CHARLES, IL
CAPITAL RESIN CORPORATION
COLUMBUS, OH
CARGILL DETROIT CORPORATION
CLAWSON, MI
CHEVRON CORPORATION
SAN FRANCISCO, CA
COURTAULDS FIBERS
AXIS, AL
CYTEC INDUSTRIES
WESTPATERSON.NJ
Company-
Owned
Facilities
Reporting
33/50
("Mifttnioal^
i
i
6
1
1
1
7
2
1
6
3
1
2
1
1
5
1
1
3
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
50
13
51
50
50
50
18
50
2
50
50
***
*
40
50
40
50
***
50
1988TRI
Releases and
Transfers of
33/50
Chemicals
fponnHs'}
0
158,650
960,620
0
750
0
1,648,348
207,440
47,543
31,478
241,760
11,781
105
48,555
42,480
165,288
56,216
0
226,059
1994TRI
Releases and
Transfers of
33/50
Chemicals
fpmmH^
411
87,268
1,181,712
10
0
30
159,614
4,632
3,158
864
45,195
26,393
161
0
14,077
23,836
72,044
3,250
56,230
Actual %
Reduction for
Facilities
(1988-1994)
—
45
-23
—
100
—
90
98
93
97
81
-124
-53
100
67
86
-28
—
75
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'arent Company
(Headquarters Location)
DOCK RESINS CORPORATION
LINDEN, NJ
DOW CHEMICAL COMPANY
MIDLAND, MI
E. I. DU PONT DE NEMOURS & CO
WILMINGTON, DE
ETHYL CORPORATION
RICHMOND, VA
EXXON CORPORATION
IRVING, TX
FINAINC
DALLAS, TX
GENERAL ELECTRIC COMPANY
FAIRFIELD, CT
GEORGIA-PACIFIC CORPORATION
ATLANTA, GA
GLASGO PLASTICS INC
SPRINGFIELD, OH
GLOBE MANUFACTURING CO
FALL RIVER, MA
GRIFFITH POLYMERS
fflLLSBORO, OR
H & N CHEMICAL CO INC
TOTOWA, NJ
HERCULES INCORPORATED
WILMINGTON, DE
HERESITE PROTECTIVE COATINGS
MANITOWOC, WI
HOECHST CELANESE
CORPORATION
CORPUS CHRISTY, TX
ILLINOIS TOOL WORKS INC
GLENVIEW, IL
INTERNATIONAL PAPER COMPANY
PURCHASE, NY
TAMES RIVER CORP VIRGINIA
RICHMOND, VA
LIBERTY POLYGLAS INC
WEST MIFFLIN, PA
LYONDELL PETROCHEMICAL CO
HOUSTON, TX
MILES INC
PITTSBURGH, PA
Company-
Owned
Facilities
Reporting
33/50
Ohemioals
i
20
2
1
3
I
6
1
1
1
1
1
3
1
21
1
3
1
1
1
20
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
*#*
50
50
46
50
40
50
50
50
45
#*
*#*
50
50
50
***
50
53
*
57
37
1988TRI
Releases and
Transfers of
33/50
Chemicals
('pounds')
10,100
6,202,765
599,530
29,174
10,548
0
7,710,278
0
12,630
957,417
29,491
10,700
551,064
2,100
4,836,469
0
138,072
0
48,401
6,901
2,069,780
1994TRI
Releases and
Transfers of
33/50
Chemicals
('pounds'!
2,370
1,761,522
176,040
0
11,696
294
1,798,408
35
0
161,523
0
2,807
137,808
0
1,463,490
500
531,258
0
20,295
0
1,410,749
Actual %
Reduction for
Facilities
(1988-1994)
77
72
71
100
-11
77
—
100
83
100
74
75
100
70
—
-285
—
58
100
32
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Parent Company
(Headquarters Location)
vlQBIL CORPORATION
?AIRFAX, VA
vlONSANTO COMPANY
SAINT LOUIS, MO
vIORTON INTERNATIONAL INC
CHICAGO, IL
MEWPORT ADHESIVES &
COMPOSITES
FOUNTAIN VALLEY, CA
NORTH AMERICAN PLASTICS INC.
PRAIRIE, MS
OCCIDENTAL PETROLEUM CORP
,OS ANGELES, CA
PHILLIPS PETROLEUM COMPANY
3ARTLESVILLE, OK
PLASTICS ENGINEERING COMPANY
iHEBOYGAN, WI
}PG INDUSTRIES INC
MTTSBURGH.PA
PREMIXINC
MKINGSVILLE,OH
QUANTUM CHEMICAL
CORPORATION
SELIN. NJ
RANBAR TECHNOLOGY INC
GLENSHAW, PA
iEVLIS CORPORATION
WCRON, OH
XEXENE CORPORATION
DALLAS, TX
ROGERS CORPORATION
IOGERS, CT
ROHM AND HAAS COMPANY
'HILADELPHIA, PA
SARTORIUS NORTH AMERICA INC
3RENTWOOD, NY
SOLVAY AMERICA INC
IOUSTON, TX
TEXTILE RUBBER & CHEMICAL CO
WALTON, GA
t JNION CAMP CORPORATION
WAYNE, NJ
UNION CARBIDE CORPORATION
^ANBURY. CT
Company-
Owned
Facilities
Reporting
33/50
fyhfitnicflta
i
19
1
1
2
6
1
1
2
2
7
1
1
1
5
3
1
2
1
1
2
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
50
25
20
50
*
19
50
*
50
23
50
52
50
50
#**
50
50
*
*
50
54
1988TRI
Releases and
Transfers of
33/50
Chemicals
fnoiinHO
11,922
5,554,821
0
139,000
4
1,670,197
0
3,685
580,992
41,200
391,086
26,900
1,500
347,520
243,173
319,380
377,320
9,800
7,150
136,301
810,702
1994TRI
Releases and
Transfers of
33/50
Chemicals
('ponnd^
800
1,977,399
0
0
12
702,818
168
0
161,719
n 750
177,588
5,693
1,870
103,401
82,483
37,660
77,750
21,000
0
1,434
1,337
Actual %
Reduction for
Facilities
(1988-1994)
93
64
...
100
-200
58
—
100
72
98
55
79
-25
70
66
88
79
-114
100
99
100
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Parent Company
(Headquarters Location)
UNOCAL CORPORATION
LOS ANGELES, CA
VALSPAR CORPORATION
MINNEAPOLIS, MN
VISTA CHEMICAL COMPANY
HOUSTON, TX
W R GRACE & CO INC
BOCA RATON, FL
ZENECA HOLDINGS INC
WILMINGTON, DE
Company-
Owned
Facilities
Reporting
33/50
P.hfimioals
i
4
5
1
1
Company-
Wide %
Reduction
Goal1
(1988 to 1995)
50
50
50
50
*
TOTAL | 209 1
1988 TRI
Releases and
Transfers of
33/50
Chemicals
fpoiinfta^
44,750
111,244
553,331
10,980
2,639
1994 TRI
Releases and
Transfers of
33/50
Chemicals
fpmirtHO
0
71,238
61,068
43,300
1,774
Actual %
Reduction for
Facilities
(1988-1994)
100
36
89
-294
33
38,468,090 1 12,688,942 1 39
Source: U.S. EPA 33/50 Program Office, 1996.
' Company- Wide Reduction Goals aggregate all company-owned facilities which may include facilities not manufacturing
elastic resins or manmade fibers.
* = Reduction goal not quantifiable against 1 988 TRI data.
** = Use reduction goal only.
***= No numeric reduction goal.
— = Actual reduction not quantifiable against 1 988 TRI data.
Environmental Leadership Program
The Environmental Leadership Program (ELP) is a national initiative
developed by EPA that focuses on improving environmental performance,
encouraging voluntary compliance, and building working relationships with
stakeholders. EPA initiated a one year pilot program in 1995 by selecting 12
projects at industrial facilities and federal installations that demonstrate the
principles of the ELP program. These principles include: environmental
management systems, multimedia compliance assurance, third-party
verification of compliance, public measures of accountability, community
involvement, and mentor programs. In return for participating, pilot
participants receive public recognition and are given a period of time to
correct any violations discovered during these experimental projects.
EPA is making plans to launch its full-scale Environmental Leadership
Program in 1997. The full-scale program will be facility-based with a 6-year
participation cycle. Facilities that meet certain requirements will be eligible
to participate, such as having a community outreach/employee involvement
programs and an environmental management system (EMS) in place for 2
years. (Contact: http://es.inel.gov/elp or Debby Thomas, ELP Deputy
Director, at 202-564-5041)
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Project XL
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by providing participants
regulatory flexibility on the condition that they produce greater environmental
benefits. EPA and program participants will negotiate and sign a Final Project
Agreement, detailing specific environmental objectives that the regulated
entity shall satisfy. EPA will provide regulatory flexibility as an incentive for
the participants' superior environmental performance. Participants are
encouraged to seek stakeholder support from local governments, businesses,
and environmental groups. EPA hopes to implement fifty pilot projects in
four categories, including industrial facilities, communities, and government
facilities regulated by EPA. Applications will be accepted on a rolling basis.
For additional information regarding XL projects, including application
procedures and criteria, see the May 23, 1995 Federal Register Notice.
(Contact: Fax-on-Demand Hotline 202-260-8590, Web:
http://www.epa.gov/ProjectXL, or Christopher Knopes at EPA's Office of
Policy, Planning and Evaluation 202-260-9298)
Climate Wise Program
Climate Wise is helping US industries turn energy efficiency and pollution
prevention into a corporate asset. Supported by the technical assistance,
financing information and public recognition that Climate Wise offers,
participating companies are developing and launching comprehensive
industrial energy efficiency and pollution prevention action plans that save
money and protect the environment. The nearly 300 Climate Wise companies
expect to save more than $300 million and reduce greenhouse gas emissions
by 18 million metric tons of carbon dioxide equivalent by the year 2000.
Some of the actions companies are undertaking to achieve these results
include: process improvements, boiler and steam system optimization, air
compressor system improvements, fuel switching, and waste heat recovery
measures including cogeneration. Created as part of the President's Climate
Change Action Plan, Climate Wise is jointly operated by the Department of
Energy and EPA. Under the Plan many other programs were also launched
or upgraded including Green Lights, WasteWiSe and DoE's Motor Challenge
Program. Climate Wise provides an umbrella for these programs which
encourage company participation by providing information on the range of
partnership opportunities available. (Contact: Pamela Herman, EPA, 202-
260-4407 or Jan Vernet, DoE, 202-586-4755)
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Energy Star Buildings Program
EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
designed to improve the energy-efficiency in commercial and industrial
buildings. Expanding the successful Green Lights Program, ENERGY STAR
Buildings was launched in 1995. This program relies on a 5-stage strategy
designed to maximize energy savings thereby lowering energy bills, improving
occupant comfort, and preventing pollution — all at the same time. If
implemented in every commercial and industrial building in the United States,
ENERGY STAR Buildings could cut the nation's energy bill by up to $25 billion
and prevent up to 35% of carbon dioxide emissions. (This is equivalent to
taking 60 million cars of the road). ENERGY STAR Buildings participants
include corporations; small and medium sized businesses; local, federal and
state governments; non-profit groups; schools; universities; and health care
facilities. EPA provides technical and non-technical support including
software, workshops, manuals, communication tools, and an information
hotline. EPA's Office of Air and Radiation manages the operation of the
ENERGY STAR Buildings Program. (Contact: Green Light/Energy Star Hotline
at 1-888-STAR-YES or Maria Tikoff Vargas, EPA Program Director at 202-
233-9178 or visit the ENERGY STAR Buildings Program website at
http://www.epa.gov/appdstar/buildings/)
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program saves money for businesses and
organizations and creates a cleaner environment by reducing pollutants
released into the atmosphere. The program has over 2,345 participants which
include major corporations, small and medium sized businesses, federal, state
and local governments, non-profit groups, schools, universities, and health
care facilities. Each participant is required to survey their facilities and
upgrade lighting wherever it is profitable. As of March 1997, participants had
lowered their electric bills by $289 million annually. EPA provides technical
assistance to the participants through a decision support software package,
workshops and manuals, and an information hotline. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program. (Contact:
Green Light/Energy Star Hotline at 1-888-STARYES or Maria Tikoff Vargar,
EPA Program Director, at 202-233-9178 the )
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste
and Emergency Response. The program is aimed at reducing municipal solid
wastes by promoting waste prevention, recycling collection and the
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manufacturing and purchase of recycled products. As of 1997, the program
had about 500 companies as members, one third of whom are Fortune 1000
corporations. Members agree to identify and implement actions to reduce
their solid wastes setting waste reduction goals and providing EPA with
yearly progress reports. To member companies, EPA, in turn, provides
technical assistance, publications, networking opportunities, and national and
regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473 or
Joanne Oxley, EPA Program Manager, 703 -308-0199) '
NICE3
The U.S. Department of Energy is administering a grant program called The
National Industrial Competitiveness through Energy, Environment, and
Economics (NICE3). By providing grants of up to 45 percent of the total
project cost, the program encourages industry to reduce industrial waste at its
source and become more energy-efficient and cost-competitive through waste
minimization efforts. Grants are used by industry to design, test, and
demonstrate new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in the
forest products, chemicals, petroleum refining, steel, aluminum, metal casting
and glass manufacturing sectors. (Contact: http//www. oit.doe.gov/access/
nice3, Chris Sifri, DOE, 303-275-4723 or Eric Hass, DOE, 303-275-4728)
Design for the Environment (DfE)
DfE is working with several industries to identify cost-effective pollution
prevention strategies that reduce risks to workers and the environment. DfE
helps businesses compare and evaluate the performance, cost, pollution
prevention benefits, and human health and environmental risks associated with
existing and alternative technologies. The goal of these projects is to
encourage businesses to consider and use cleaner products, processes, and
technologies. For more information about the DfE Program, call (202) 260-
1678. To obtain copies of DfE materials or for general information about
DfE, contact EPA's Pollution Prevention Information Clearinghouse at (202)
260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
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VIII.C. Trade Association/Industry Sponsored Activity
VHI.C.1. Environmental Programs
The Global Environmental Management Initiative (GEMI) is made up of
a group of leading companies dedicated to fostering environmental excellence
by business. GEMI promotes a worldwide business ethic for environmental
management and sustainable development, to improve the environmental
performance of business through example and leadership. In 1994, GEMTs
membership consisted of about 30 major corporations including Union
Carbide Corporation and Dow Chemical.
Center for Waste Reduction Technologies under the aegis of the American
Institute of Chemical Engineers sponsored research on innovative
technologies to reduce waste in the chemical processing industries. The
primary mechanism is through funding of academic research.
The American Plastics Council is working on a life-cycle study to examine
the emissions released from plastics and resins manufacturing facilities. The
study will compare emissions from plastics and resins manufacturing with
manufacturing of other materials, such as wood products.
The National Science Foundation and the Environmental Protection
Agency's Office of Pollution Prevention and Toxics signed an agreement in
January of 1994 to coordinate the two agencies' programs of basic research
related to pollution prevention. The collaboration will stress research in the
use of less toxic chemical and synthetic feedstocks, use of photochemical
processes instead of traditional ones that employ toxic reagents, use of
recyclable catalysts to reduce metal contamination, and use of natural
feedstocks when synthesizing chemicals in large quantities.
The Chemical Manufacturer's Association funds research on issues of
interest to their members particularly in support of their positions on proposed
or possible legislation. They recently funded a study to characterize the
environmental fate of organochlorine compounds.
The Responsible Care® Initiative of the Chemical Manufacturer's
Association requires all members and partners to continuously improve their
health, safety, and environmental performance in a manner that is responsive
to the public. Launched in 1988, the Responsible Care® concepts are now
being applied in 36 countries around the world. Responsible Care® is a
comprehensive, performance-oriented initiative composed often progressive
Guiding Principles and six board Codes of Management Practices. These
Management Practices cover all aspects of the chemical industry's operations,
from research to manufacturing, distribution, transportation, sales and
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marketing, and to downstream users of chemical products. Through
Responsible Care®, CMA members and partners gain insight from the public
through, among other means, a national Public Advisory Panel and over 250
local Community Advisory Panels. This, coupled with the fact that
participation in Responsible Care® is an obligation of membership with the
Chemical Manufacturer's Association, make this performance improvement
initiative unique. The Synthetic Organic Chemical Manufacturer's Association
whose membership consists of smaller batch and custom chemical
manufacturers with typically fewer than 50 employees and less than $50
million in annual sales, encourages its members to achieve continuous
performance improvement in their health, safety, and environmental programs
through implementation of the chemical industry's Responsible Care®
initiative. SOCMA is a partner in Responsible Care®.
The Society of the Plastics Industry has implemented two programs aimed
at reducing plastic pellet loss. In 1991, SPFs Polymeric Materials Producers
Division developed and endorsed a "Pellet Retention Environmental Code."
Companies that sign the code commit themselves to the total containment of
plastic pellets throughout the pellets' lifespan and to operating in full
compliance with environmental laws and regulations pertaining to pellet
containment (SPI, 1994). In 1992, SPI expanded the program to include a
processor's pledge to uphold six principles to prevent the loss of resin pellets
into the environment.
ISO 9000 is a series of international total quality management guidelines.
After a successful independent audit of their management plans, firms are
qualified to be ISO 9000 registered. In June of 1993, the International
Standards Organization created a technical committee to work on new
standards for environmental management systems.
Vin.C.2. Summary of Trade Associations
American Chemical Society
1155 16th Street, NW
Washington, D.C. 20036
Phone: 202-872-4600
Fax: 202-872-4615
Members: 150,000 individuals
Staff: 1950
Budget: $192,000,000
The American Chemical Society (ACS) has an educational and research focus.
The ACS produces approximately thirty different industry periodicals and
research journals, including Environmental Science and Technology and
Chemical Research in Toxicology. In addition to publishing, the ACS
presently conducts studies and surveys; legislation monitoring, analysis, and
reporting; and operates a variety of educational programs. The ACS library
and on-line information services are extensive. Some available on-line
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services are Chemical Journals Online, containing the full text of 18 ACS
journals, 10 Royal Society of Chemistry journals, five polymer journals and
the Chemical Abstracts Service, CAS, which provides a variety of information
on chemical compounds. Founded in 1876, the ACS is presently comprised
of 184 local groups and 843 student groups nationwide.
American Fiber Manufacturers
Association, Inc.
1150- 17th Street, NW, Suite 310
Washington, DC 22036
Phone: 202-296-6508
Fax: 202-296-3052
E-mail: afma@aol.com
Members: 18 companies
Staff: 6
Budget: $2,000,000
Previously known as the Man-Made Fiber Producers Association up until
1988, the American Fiber Manufacturers Association, Inc. (AFMA) is a
domestic trade organization representing U.S. producers of more than 90
percent of domestic production of manufactured fibers, filaments, and yarns.
AFMA manages programs on government relations, international trade policy,
the environment, technical issues, and educational services. Committees of
experts from member companies work on each of these subjects. The group
publishes fact books and economic profiles, Fiber Organon, and recently
published an environmental life cycle study.
Chemical Manufacturers Association
1300 Wilson Boulevard
Arlington, VA 22209
Phone: 703-741-5224
Fax: 703-741-6224
Members: 185 companies
Staff: 246
Budget: $36,000,000
A principal focus of the Chemical Manufacturer's Association (CMA) is on
regulatory issues facing chemical manufacturers at the local, state, and federal
levels. At its inception in 1872, the focus of CMA was on serving chemical
manufacturers through research. Research is still ongoing at CMA. Member
committees, task groups, and work groups routinely sponsor research and
technical data collection that is then provided to the public in support of
CMA's advocacy. Much additional research takes place through the
CHEMSTAR® program. CFffiMSTAR® consists of a variety of self-funded
panels working on single-chemical research agendas. This research fits within
the overall regulatory focus of CMA; CFffiMSTAR® study results are
provided to both CMA membership and regulatory agencies. Other initiatives
include the Responsible Care® program, which includes six codes of
management practices designed to go beyond simple regulatory compliance.
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CMA is currently developing measurement and appropriate verification
systems for these codes. CMA also conducts workshops and technical
symposia, promotes in-plant safety, operates a chemical emergency center
(CHEMTREC®) which offers guidance in chemical emergency situations, and
operates the Chemical Referral Center which provides chemical health and
safety information to the public. Publications include the annual U.S.
Chemical Industry Statistical Handbook, containing detailed data on the
industry; Responsible Care in Action, the 1993-94 progress report on
implementing Responsible Care®; and Preventing Pollution in the Chemical
Industry: A Progress Report (1988-1993), summarizing waste generation and
reduction data for the years 1988-93. CMA holds an annual meeting for its
membership in White Sulphur Springs, WV.
Polyurethane Manufacturers
Association
800 Roosevelt Road, Bldg.C, Ste. 20
Glen Ellyn, EL 60137-5833
Phone: 708-858-2670
Fax: 708-790-3095
Members: 116 companies
Staff: 4
Budget: $500,000
This group includes manufacturers, suppliers, distributors and sales agents of
raw materials, additives, or processing equipment; processors of solid cast,
microcellular, RIM and thermoplastic urethane elastomers; and individuals or
companies providing publishing, education, research, or consulting services
to the industry. The association publishes the bimonthly Polytopics.
Society of Plastics Engineers
14 Fair-field Drive
Brookfield, CT 06804-0403
Phone: 203-775-0471
Fax: 203-775-8490
Members: 37,000 individuals
Staff: 38
Budget: $6,100,000
Society of Plastics Engineers (SPE) is a group dedicated to promoting the
knowledge and education of plastics and polymers worldwide and strives to
be the leading technology society for the plastics industry. SPE is made up
of over 37,500 members around the world involved in engineering, design,
production and processing, research and development, consulting, marketing
and sales, purchasing, education, and all levels of management. SPE publishes
journals, including Plastics Engineering and Polymer Engineering and
Science, and sponsors a large range of technical conferences on polymer and
plastics processing.
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Society of the Plastics Industry, Inc.
1801 K Street, NW, Suite 600K
Washington, DC 20006-1301
Phone: 202-974-5200
Fax: 202-296-7005
Web: www.socplas.org
Members: 1900 companies
Staff: 130
Budget: $30,000,000
SPI is a principal trade association for the U.S. plastics industry. Comprised
of 2,000 members, SPI has representatives from all segments of the plastics
industry, including materials suppliers, processors, machinery manufacturers,
moldmakers, distributors, and other industry-related groups and individuals.
SPI publishes an annual report on market trends called Facts and Figures of
the U.S. Plastics Industry. In addition to its general services ~ Government
and Technical Affairs, Communications, Trade Shows, Membership, and
Finance Administration — SPI has 28 business units as well as numerous key
services offering programs specifically geared to the interests of particular
industry segments. These special purpose groups include the Degradable
Polymers Council, which acts as a clearinghouse for research in the
degradable plastics industry, and the Polymeric Materials Producers Division.
which includes manufacturers of basic polymers or prepolymers for the
plastics industry. Other industry segment groups which focus on particular
plastic resins include the Fluoropolymers Division. Naphthalate Polymers
Council, the Phenolic Division, the Polyurethane Division, the Styrene
Information and Research Center, and the Vinyl Institute. SPI also has an
affiliation with the American Plastics Council which includes U.S. resin and
monomer producers, plastics processers, and suppliers. Contact information
for these groups is listed below.
American Plastics Council, Red Cavaney, President, 202-974-5400
Composites Institute, Catherine Randazzo, Executive Director, 212-351-5410
Degradable Polymers Council, John Malloy, Director of Packaging Services,
202-974-5245,dpc@socplas.org
Fluoropolymers Division, Allen Weidman, Director, 202-974-5233
Naphthalate Polymers Council, John Malloy, Director of Packaging Services, 202-974-5245
Phenolic Division, Allen Weidman, Director, 202-974-5233
Polymeric Materials Producers Division, Betsy Shirley, Executive Director, 202-974-5319,
pmd@socplas.org
Polyurethane Division, Fran Lichtenberg, Executive Director, 212-351 -5242,
polyu@socplas.org
Styrene Information and Research Center, Betsy Shirley, Executive Director, 202-974-5319
sirc@socplas. org
The Vinyl Institute, Robert Burnett, Executive Director, 201-898-6633, vi@socplas.org
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Synthetic Organic Chemicals
Manufacturer's Association
1100 New York Avenue, NW
Washington, D.C. 20005
Phone: 202-414-4100
Fax: 202-289-8584
Members: 250
Staff: 50
Budget: $12,000,000
Synthetic Organic Chemicals Manufacturer's Association (SOCMA) is the
national trade association representing the legislative, regulatory, and
commercial interests of some 250 companies that manufacture, distribute, or
market organic chemicals. Most of SOCMA's members are batch and custom
chemical manufacturers who are the highly innovative, entrepreneurial and
customer-driven sector of the U.S. chemical industry. The majority of
SOCMA's members are small businesses with annual sales of less than $50
million and fewer than 50 employees. SOCMA assists its members in
improving their environmental, safety, and health performance through
various programs focusing on continuous improvement. A bi-monthly
newsletter provides information on legislative and regulatory developments,
as well as on education and training opportunities. SOCMA holds an annual
meeting in May and also sponsors INFORMEX, the largest custom chemical
trade show in the U.S. In addition, SOCMA's Association Management
Center includes two dozen self-funded groups that focus on single chemical
issues.
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Contacts/References
IX. CONTACTS/ACKNOWLEDGMENTS/REFERENCES
Contacts3
For further information on selected topics within the plastic resin and
manmade fiber industries, a list of publications and contacts are provided
below.
Name
Sally Sasnett
Bob Rosensteel
George Jett
Bob Barker
Lucinda Schofer
David Gustafson
John Dege
Bob Lambour
Brent Smith
Jim Kachtick
Lynne Harris
Organization
EPA, Office of
Compliance
EPA, OAQPS
EPA, Office of Water
AFMA
CMA
Dow Chemical
Du Pont
Exxon
NC State
Occidental Chemical
SPI
Telephone
202-564-7074
919-541-5608
202-260-7151
202-296-6508
703-741-5231
517-636-2953
302-773-0900
713-870-6017
919-515-6548
713-215-7602
202-974-5217
Subject
Compliance assistance
Industrial processes and regulatory
requirements (CAA)
Industrial processes and effluent guidelines
Industrial processes
Industrial resources and regulatory
requirements
Regulatory requirements and polyethylene
manufacture
Regulatory requirements and synthetic fiber
manufacture
Regulatory requirements, polyethylene and
polypropylene manufacture
Manmade fibers processes and pollution
prevention methods
Regulatory requirements and PVC
manufacture
Industrial resources and regulatory
requirements
AFMA: American Fiber Manufacturers Association
CMA.: Chemical Manufacturers Association
CAA: Clean Air Act
OAQPS: Office of Air Quality Planning and Standards
SPI: Society of the Plastics Industry
Many of the contacts listed below have provided valuable background information and comments during development
of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse
all statements made within this notebook.
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References
References
Section II - Introduction
1) American Fiber Manufacturers Association, Inc. Comments on draft of this document, AFMA,
1997.
2) Brydson, J.A., Plastics Materials, 6th edition, Butterworth-Heinemann Ltd., Oxford, 1995.
3) Linton, G. E. Natural and Manmade Textile Fibers: Raw material to finished fabric. Duell,
Sloan and Pearce, New York, 1966.
4) Modern Plastics Encyclopedia, Mid-November 1994 Issue, volume 71, no. 12, McGraw-Hill,
Inc., New York, 1994.
5) Society of the Plastics Industry, Inc., Facts and Figures of the U.S. Plastics Industry, 1995
edition, SPI, Washington, DC, 1995.
6) U.S. Department of Commerce, United States Industrial Outlook 1994, US Department of
Commerce, Washington, DC, 1994.
7) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention in
the Textile Industry, EPA, Office of Research and Development, Washington, DC.,
September, 1995.
8) U.S. International Trade Commission, Industry and Trade Summary: Manmade Fibers, US ITC,
Washington, DC., April, 1995, USITC Publication #2874.
9) U.S. Office of Management and Budget, Standard Industrial Classification Manual, U.S. OMB,
1987.
10) Ward's Business Directory of U.S. Private and Public Companies, Gale Research, Inc., 1996.
Section III - Industrial Process Description
1) American Fiber Manufacturers Association, Comments on draft of this document, 1997.
2) Clements, J.W. and Thompson, J.P., Cleaner Production: An Industrial Example, Journal of
Cleaner Production, volume 1, no. 1, 1993.
3) Chemical Manufacturers Association, CMA Waste Minimization Resource Manual, CMA,
Washinton, DC, 1989.
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References
4) Grayson, M. (ed.), Encyclopedia of Textiles, Fibers, and Nonwoven Fabrics, John Wiley and
Sons, New York, 1984.
5) Kent, J.A. (ed.), Riegel's Handbook of Industrial Chemistry, Van Nostrand Reinhold, New York,
1992.
6) Kroschwitz, J.I. (ed.), Encyclopedia of Polymer Science and Engineering, volume 12, John Wiley
and Sons, New York, 1986.
7) Lewis, Sr., R.J. Rowley's Condensed Chemical Dictionary, Van Nostrand Reinhold Company,
New York, 1993.
8) Masters, G.M. Introduction to Environmental Engineering and Science. Prentice-Hall, Inc., New
York, 1991.
9) McKetta, J.J. (ed.), Encyclopedia of Chemical Processing and Design, volume 39, Marcel
Dekker, Inc., New York, 1992.
10) New Jersey Hazardous Waste Facilities Sitings Commission, A Study of Hazardous Waste Source
Reduction and Recycling in Four Industry Groups in New Jersey, Commissioned by New
Jersey Hazardous Waste Facilities Sitings Commission, Trenton, NJ, April, 1987.
11) Randall, P.M., "Pollution Prevention Strategies for Minimizing of Industrial Wastes in the Vinyl
Chloride Monomer - Polyvinyl Chloride Industry," Environmental Progress, volume 13, no.
4, November, 1994.
12) Rodriguez, F., Principles of Polymer Systems, fourth edition, Taylor and Francis, Washington,
DC., 1996.
13) Smith, W.M. (ed.), Manufacture of Plastics: Volume 1, Reinhold Publishing Corporation, New
York, 1964.
14) Society of the Plastics Industry, Comments on draft of this document, 1997.
15) Society of the Plastics Industry, Operation Clean Sweep: A Manual on Preventing Pellet Loss.
SPI, Washington, DC, 1994.
16) Synthetic Organic Chemical Manufacturers Association, SOCMA Pollution Prevention Study.
Prepared for SOCMA, Washington, DC, January 1993.
17) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention
in the Textile Industry, EPA, Office of Research and Development, September, 1995.
18) U.S. Environmental Protection Agency, AP-42, EPA, Office of Air and Radiation, 1993.
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References
19) U.S. Environmental Protection Agency, Plastic Pellets in the Aquatic Environment: Sources and
Recommendations,^?^., Office of Water, Washington, DC., December, 1992.
20) U.S. Environmental Protection Agency, Development Document for Effluent Limitations
Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers, Point
Source Category, Volumes 1 and 2, EPA, Office of Water Regulations and Standards,
October 1987.
21) U.S. Environmental Protection Agency, Control of Volatile Organic Emissions from
Manufacture of Synthesized Pharmaceutical Products, EPA, Office of Air Quality Planning
and Standards, 1978.
22) U.S. International Trade Commission, Industry and Trade Summary: Manmade Fibers, USITC,
Washington, DC., Publication # 2874, April, 1995.
23) Wellman, Inc. Comments on draft of this document, 1997.
Section TV - Releases and Transfers Profile
1) Lewis, Sr., R.J. Rowley's Condensed Chemical Dictionary, Van Nostrand Reinhold Company,
New York, 1993.
Section V - Pollution Prevention
1) Chemical Manufacturers Association, Desiring Pollution Prevention in to the Process: Research
Development and Engineering, Chemical Manufacturers Association, Washington, DC, 1993.
2) Chemical Manufacturers Association, Preventing Pollution in the Chemical Industry: Five Years
of Progress, CMA, Washington, DC, 1992.
3) Clements, J.W. and Thompson, J.P., Cleaner Production: An Industrial Example, Journal of
Cleaner Production, volume 1, no. 1, 1993.
4) Clevenger, L. and Hassell, J., Case Study: From Jump Start to High Gear - How Du Pont is
Cutting Costs by Boosting Energy Efficiency, Pollution Prevention Review, Summer 1994.
5) Elley, D., DCS's On-line Information Improves resin Process Consistency, Instrumentation and
Control Systems, volume 64, no. 11, 1991.
6) Kikta, A. J., Case Study: Using a Six-Step Organizational Framework to establish a Facility P2
Program, Pollution Prevention Review, Spring 1994.
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References
7) Manufacture of Plastics: Volume 1, W.M. Smith (ed), Reinhold Publishing Corporation, New
York, 1964.
8) North Carolina Department of Environment, Health, and Natural Resources, Case Studies: A
Compilation of Successful Waste Reduction Projects Implemented by North Carolina
Businesses and Industries, NC DEHNR, Office of Waste Reduction, Industrial Pollution
Prevention Program, Raleigh, NC, December 1995.
9) Smith, G.M., IV, Polyester Film Division's Waste Minimization/Detoxification Activities,
Chemical Manufacturers Association Waste Minimization Workshop Proceedings,
Washington, DC, 1987.
10) Synthetic Organic Chemical Manufacturers Association, SOCMA Pollution Prevention Study.
Prepared for SOCMA, Washington, DC, January 1993.
11) U.S. Environmental Protection Agency, Best Management Practices for Pollution Prevention
in the Textile Industry, EPA, Office of Research and Development, Washington, DC,
September, 1995.
12) U.S. Environmental Protection Agency, Retrospective Analysis of Compliance Strategies and
Pollution Prevention in the Organic Chemicals, Plastics and Synthetic Fibers Industry, EPA,
Office of the Administrator, Washington, DC, December, 1993, (EPA Contract No. 68-C3-
0302).
13) Better Housekeeping and Training of Operating Personnel Reduces Liability,
http://es.inel.gov/studies/cs382.html.
14) Monomer Storage and Handling Improvements Reduce Emissions at Novacor Chemicals, Inc.,
http://nben.org/otacases/novacor.html.
15) New Value Packing Material Reduces Leaking Control Valves at Texas Eastman in Longview,
http://es.inel.gov/studies/eastx-d.html.
\6)Fact Sheet: Source Reduction and Recycling Lead to P2 Efforts,
http://es.inel.gov/techinfo/facts/cma/cma-fs3.html.
17) On-Site Recycle and Reuse of Alcohol Wash Solution, http://es.inel.gov/studies/cs435.html.
18) Modifying Rinse Procedures for Phenolic Batch Reactors Reduced Virgin Phenolic Resin,
http ://es. inel. gov/studies/cs20. html.
19) Plastics Industry Emphasizes Need for Research in Recycling of Hazardous Waste,
http ://es.inel.gov/studies/hml 10053 .html.
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References
Section VI - Statutes and Regulations
1) Federal Register, Vol. 57, No. 177, September 11, 1992.
2) Federal Register, Vol. 58, No. 130, July 9, 1993.
3) U.S. Environmental Protection Agency, Draft Polymer Exemption Guidance Manual, EPA, Office
of Pollution Prevention and Toxics, March 29, 1995.
4) U.S. Environmental Protection Agency, Development Document for Effluent Limitations
Guidelines and Standards for the Organic Chemicals, Plastics, and Synthetic Fibers, Point
Source Category, Volumes 1 and 2, EPA, Office of Water Regulations and Standards,
October 1987.
Section Vm - Compliance Activities and Initiatives
1) Society of the Plastics Industry, Operation Clean Sweep: A Manual on Preventing Pellet Loss.
SPI, Washington, DC, 1994.
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APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
Web Browser to the following address:
http://es.epa.gov/comply/sector/index.html
or use
WWW.epa.gOV/OeCa - then select the button labeled Industry and Gov't
Sectors and select the appropriate sector from the
menu. The Notebook will be listed.
Direct technical questions to the Feedback function at the bottom of the web page or to
Shhonn Taylor at (202) 564-2502
Appendix A
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