Sector Notebook Project	Inorganic Chemicals

This report is one in a series of volumes published by the U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors.  The documents were developed under contract by Abt Associates
(Cambridge, MA), and Booz-Allen & Hamilton,  Inc. (McLean, VA).  This publication may be
purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included on the following page.
All telephone orders should be directed to:

       Superintendent of Documents
       U.S. Government Printing Office
       Washington, DC 20402
       (202)512-1800
       FAX (202) 512-2250
       8:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, local, and foreign governments, and the media. For further
information, and for answers to questions pertaining to these documents,  please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available free of charge at the following web
address: www.epa.gov/oeca/sector. Direct technical questions to the "Feedback" button at the
bottom of the web page.
September 1995                                                                 SIC 281

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Sector Notebook Project	Inorganic Chemicals

Cover photograph by Steve Delaney, EPA.  Photograph courtesy of Vista Chemicals, Baltimore,
Maryland. Special thanks to Dave Mahler.
September 1995                                                              SIC 281

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Sector Notebook Project	Inorganic Chemicals

                                                 EPA/310-R-95-004
                 EPA Office of Compliance Sector Notebook Project

                     Profile of the Inorganic Chemical Industry
                                 September 1995
                               Office of Compliance
                    Office of Enforcement and Compliance Assurance
                        U.S. Environmental Protection Agency
                            401 M St., SW (MC 2221-A)
                              Washington, DC 20460
                             Sector Notebook Contacts
September 1995                                                            SIC 281

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Sector Notebook Project
                                                     Inorganic Chemicals
The Sector Notebooks were developed by the EPA's Office of Compliance.  Questions relating to
the Sector Notebook Project can be directed to:

Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
401 M St., SW (2223-A)
Washington, DC 20460
(202) 564-7017

Questions and comments regarding the individual documents can be directed to the appropriate
specialists listed below.
Document Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/310-R-97-007.
EPA/310-R-97-008.
EPA/310-R-97-009.
EPA/310-R-97-010.
EPA/310-R-98-001.
EPA/310-R-98-002.

EPA/310-R-98-003.
EPA/310-R-98-004.
             Industry
Dry Cleaning Industry
Electronics and Computer Industry*
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry*
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry*
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry*
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
Air Transportation Industry
Ground Transportation Industry
Water Transportation Industry
Metal Casting Industry
Pharmaceuticals Industry
Plastic Resin  and Man-made Fiber Ind.
Fossil Fuel Electric Power Generation Ind.
Shipbuilding  and Repair Industry
Textile Industry
Sector Notebook Data Refresh-1997
Aerospace Industry
Agricultural Chemical, Pesticide, and
Fertilizer Industry
Agricultural Crop Production Industry
Agricultural Livestock Production hid.
   Contact
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Jane Engert
Anthony Raia
Jane Engert
Rob Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Anthony Raia
Belinda Breidenbach
Seth Heminway
Anthony Raia
Shruti Sanghavi

Ginah Mortensen
Ginah Mortensen
 Phone (202)
   564-7073
   564-7007
   564-7021
   564-7067
   564-7027
   564-7017
   564-7013
   564-5021
   564-6045
   564-5021
   564-2628
   564-7067
   564-7003
   564-7072
   564-7017
   564-7027
   564-7013
   564-7057
   564-7057
   564-7057
   564-7057
   564-5021
   564-7071
   564-7074
   564-7028
   564-6045
   564-7022
   564-7017
   564-6045
   564-4158

(913)551-7864
(913)551-7864
September 1995
                                                                   SIC 281

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Sector Notebook Project	Inorganic Chemicals

EPA/310-R-98-005.       Oil and Gas Exploration and Production       Dan Chadwick        564-7054
                       Industry
EPA/310-R-98-008.       Local Government Operations               John Dombrowski     564-7036
* Spanish Translations Available
September 1995                                                                       SIC 281

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Sector Notebook Project	Inorganic Chemicals
        Industry Sector Notebook Contents: Inorganic Chemicals Manufacturing


Exhibits Index	  iii

List of Acronyms	v

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT	1
   A. Summary of the Sector Notebook Project	1
   B. Additional Information 	2

II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY	3
   A. Introduction, Background, and Scope of the Notebook	3
   B. Characterization of the Inorganic Chemical Industry  	4
       1. Product Characterization	4
       2. Industry Size and Geographic Distribution	5
       3. Economic Trends	10

III. INDUSTRIAL PROCESS DESCRIPTION	13
   A. Industrial Processes in the Inorganic Chemical Industry	13
       1. Mercury Cell  	16
       2. Diaphragm Cell  	18
       3. Membrane Cell	20
       4. Auxiliary Processes 	22
   B. Raw Material Inputs and Pollution Outputs in the Production Line  	24
       1. Mercury Cell  	25
       2. Diaphragm Cell  	25
       3. Membrane Cell	26
       4. Auxiliary Processes 	27
   C. Management of Chemicals In Wastestream	29

IV. CHEMICAL RELEASE AND TRANSFER PROFILE	31
   A. EPA Toxic Release Inventory for the Inorganic Chemical Industry  	34
   B. Summary of Selected Chemicals Released	43
   C. Other Data Sources	48
   D. Comparison of Toxic Release Inventory Between Selected Industries	50
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Sector Notebook Project	Inorganic Chemicals
V. POLLUTION PREVENTION OPPORTUNITIES	53

VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS  	73
   A. General Description of Major Statutes	73
   B. Industry Specific Requirements	84
   C. Pending and Proposed Regulatory Requirements	87

VII. COMPLIANCE AND ENFORCEMENT HISTORY	89
   A. Inorganic Chemical Industry Compliance History  	93
   B. Comparison of Enforcement Activity Between Selected Industries 	95
   C. Review of Major Legal Actions	100
      1. Review of Major Cases  	100
      2. Supplementary Environmental Projects	100

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES	103
   A. Sector-related Environmental Programs and Activities  	103
   B. EPA Voluntary Programs 	103
   C. Trade Association/Industry Sponsored Activity	108
      1. Environmental Programs 	108
      2. Summary of Trade Associations	Ill

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY  113

ENDNOTES	115
September 1995                          ii                               SIC 281

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Sector Notebook Project
                                                                     Inorganic Chemicals
                                      Exhibits Index

Exhibit 1:  Inorganic Chemicals Industry Dominated by a Large Number of Small Facilities  	6
Exhibit 2:  Inorganic Chemicals Facilities Distribution	6
Exhibit 3:  Chlorine Capacity Located Primarily Along Gulf Coast, Southeast, Northwest,
           and Great Lakes Region	8
Exhibit 4:  Top U.S. Companies with Inorganic Chemical Manufacturing Operations  	9
Exhibit 5:  Chlorine Electrolysis Cells	15
Exhibit 6:  Main Characteristics of the Different Electrolysis Processes  	16
Exhibit 7:  Mercury Electrolysis Cell and Flow Diagram	17
Exhibit 8:  Typical Diaphragm Electrolysis Cell and Flow Diagram	19
Exhibit 9:  Typical Membrane Electrolysis Cell	21
Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry
           (SIC 281) as Reported within TRI 	30
Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
           by Number of Facilities Reporting	36
Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
           by Number of Facilities Reporting	39
Exhibit 13: Top 10 TRI  Releasing Inorganic Chemicals Facilities	42
Exhibit 14: Top 10 TRI  Releasing Facilities Reporting Inorganic Chemical SIC Codes to TRI ...  43
Exhibit 15: Pollutant Releases (short tons/year)	48
Exhibit 16: Summary of 1993 TRI Data: Releases and Transfers by Industry	51
Exhibit 17: Toxics Release Inventory Data for Selected Industries	52
Exhibit 18: Process/Product  Modifications Create Pollution Prevention Opportunities	57
Exhibit 19: Modifications to Equipment Can Also Prevent Pollution  	66
Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic
           Chemicals Manufacturing	94
Exhibit 21: Five-Year Enforcement and Compliance Summary for Selected Industries	96
Exhibit 22: One-Year Inspection and Enforcement Summary for Selected Industries 	97
Exhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries . .  98
Exhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected Industries . .  99
Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview:
           Inorganic Chemical Manufacture  	  102
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)	  104
Exhibit 27: Contacts for State and Local Pollution Prevention Programs 	  109
September 1995

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Sector Notebook Project
                       Inorganic Chemicals
                                 List of Acronyms

AFS -        AIRS Facility Subsystem (CAA database)
AIRS -       Aerometric Information Retrieval System (CAA database)
BIFs -        Boilers and Industrial Furnaces (RCRA)
BOD -        Biochemical Oxygen Demand
CAA -        Clean Air Act
CAAA -      Clean Air Act Amendments of 1990
CERCLA -    Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS -   CERCLA Information System
CFCs -       Chlorofluorocarbons
CO -         Carbon Monoxide
COD -        Chemical Oxygen Demand
CSI -         Common Sense Initiative
CWA -       Clean Water Act
D&B -        Dun and Bradstreet Marketing Index
DSA -        Dimensionality stable
ELP -        Environmental Leadership Program
EPA -        United States Environmental Protection Agency
EPCRA -     Emergency Planning and Community Right-to-Know Act
FIFRA -      Federal Insecticide, Fungicide, and Rodenticide Act
FINDS -      Facility Indexing System
HAPs -       Hazardous Air Pollutants (CAA)
HSDB -      Hazardous Substances Data Bank
IDEA -       Integrated Data for Enforcement Analysis
LDR -        Land Disposal Restrictions (RCRA)
LEPCs -      Local Emergency Planning Committees
MACT -      Maximum Achievable Control Technology (CAA)
MCLGs -     Maximum Contaminant Level Goals
MCLs -       Maximum Contaminant Levels
MEK -       Methyl Ethyl Ketone
MSDSs -      Material Safety Data Sheets
NAAQS -     National Ambient Air Quality Standards (CAA)
NAFTA -     North American Free Trade Agreement
NCDB -      National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP -        National Oil and Hazardous Substances Pollution Contingency Plan
NEIC -       National Enforcement Investigation Center
NESHAP -    National Emission Standards for Hazardous Air Pollutants
NO2 -         Nitrogen Dioxide
NOV -        Notice of Violation
NOX -        Nitrogen Oxide
September 1995
IV
                                   SIC 281

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Sector Notebook Project
Inorganic Chemicals
NPDES -     National Pollution Discharge Elimination System (CWA)
NPL -        National Priorities List
NRC -        National Response Center
NSPS -       New Source Performance Standards (CAA)
OAR -        Office of Air and Radiation
OECA -      Office of Enforcement and Compliance Assurance
OPA -        Oil Pollution Act
OPPTS -      Office of Prevention, Pesticides, and Toxic Substances
OSHA -      Occupational Safety and Health Administration
OSW -       Office of Solid Waste
OSWER -    Office of Solid Waste and Emergency Response
OW-        Office of Water
P2 -          Pollution Prevention
PCS  -        Permit Compliance System (CWA Database)
POTW -      Publicly Owned Treatments Works
RCRA -      Resource Conservation and Recovery Act
RCRIS -      RCRA Information System
SARA -      Superfund Amendments and Reauthorization Act
SDWA -      Safe Drinking Water Act
SEPs -        Supplementary Environmental Projects
SERCs -      State Emergency Response Commissions
SIC -        Standard Industrial Classification
SO2 -        Sulfur Dioxide
SOX -        Sulfur Oxides
TOC -        Total Organic Carbon
TRI -        Toxic Release Inventory
TRIS -        Toxic Release Inventory System
TCRIS -      Toxic Chemical Release Inventory System
TSCA -      Toxic Substances Control Act
TSS -        Total Suspended Solids
UIC -        Underground Injection Control (SDWA)
UST -        Underground Storage Tanks (RCRA)
VOCs -       Volatile Organic Compounds
September 1995
            SIC 281

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Sector Notebook Project	Inorganic Chemicals

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA. Summary of the Sector Notebook Project

                     Environmental policies based upon comprehensive analysis of air, water and
                     land pollution are an inevitable and logical supplement to traditional single-
                     media approaches to environmental protection.  Environmental regulatory
                     agencies are beginning to embrace comprehensive, multi-statute solutions to
                     facility  permitting,  enforcement  and compliance assurance,  education/
                     outreach, research, and regulatory development issues. The central concepts
                     driving  the  new policy direction are  that  pollutant releases to   each
                     environmental medium (air, water and land) affect each other, and that
                     environmental strategies must actively identify and address  these  inter-
                     relationships by  designing policies for the "whole"  facility.  One way to
                     achieve a whole facility focus is to design environmental policies for similar
                     industrial facilities. By doing so, environmental concerns that are common to
                     the manufacturing of similar products can be addressed in a comprehensive
                     manner. Recognition of the need to develop the industrial "sector-based"
                     approach within the EPA Office of Compliance led to the creation of this
                     document.

                     The Sector Notebook Project was initiated by the Office of Compliance within
                     the Office of Enforcement and Compliance Assurance (OECA) to provide its
                     staff and managers with summary information for eighteen specific industrial
                     sectors.   As other  EPA  offices,   states,  the  regulated  community,
                     environmental groups, and the public became interested in this project, the
                     scope  of  the original project was expanded.   The ability  to design
                     comprehensive, common sense environmental protection measures for specific
                     industries is dependent on knowledge of several inter-related topics.  For the
                     purposes of this project, the key elements chosen for inclusion are: general
                     industry information (economic and geographic); a description of industrial
                     processes; pollution outputs; pollution prevention opportunities;  Federal
                     statutory and regulatory framework; compliance history;  and a description of
                     partnerships that have been formed between regulatory agencies, the regulated
                     community and the public.

                     For any given industry, each topic listed above could alone be the subject of
                     a lengthy volume. However, in order to produce a manageable document, this
                     project focuses on providing summary information for each topic.   This
                     format provides the reader with a synopsis of each issue, and references where
                     more  in-depth information  is available.   Text within each  profile was
                     researched from a variety of sources, and was usually condensed from more
                     detailed sources pertaining to specific topics. This approach allows for a wide
                     coverage of activities that can be further explored based upon the citations
September 1995                             1                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals

                     and references listed at the end of this profile. As a check on the information
                     included, each notebook went through an external review process. The Office
                     of Compliance appreciates the efforts of all those that participated in this
                     process and enabled us to develop more complete, accurate and up-to-date
                     summaries.

I.B. Additional Information

Providing Comments

                     OECA's Office of Compliance plans to periodically review and update the
                     notebooks  and will make these updates available both in hard copy and
                     electronically.  If you have any comments on the existing notebook, or if you
                     would  like to provide additional information, please send a hard copy and
                     computer disk to the EPA Office of Compliance, Sector Notebook Project,
                     401 M St., SW (2223-A), Washington, DC 20460.  Comments can also be
                     uploaded to the Enviro$en$e Bulletin Board or the Enviro$en$e World Wide
                     Web for general  access to all users of the  system.  Follow instructions  in
                     Appendix A for  accessing these data systems.  Once you have logged in,
                     procedures for uploading text are available from the on-line Enviro$en$e Help
                     System.

Adapting Notebooks to Particular Needs

                     The scope of the  existing notebooks reflect an approximation of the relative
                     national occurrence of facility types that occur within each sector.  In many
                     instances,  industries within specific geographic regions or states may have
                     unique characteristics that are not fully captured in these profiles. For this
                     reason, the Office of Compliance encourages state and local environmental
                     agencies and other groups to  supplement  or  re-package the information
                     included in this notebook to include more specific industrial and regulatory
                     information that may be available.  Additionally, interested states may want
                     to supplement the  "Summary of Applicable Federal Statutes and Regulations"
                     section with state and local requirements.  Compliance or technical assistance
                     providers may also want to develop the "Pollution Prevention" section in more
                     detail. Please contact the appropriate specialist listed on the opening page  of
                     this notebook if your office is  interested  in assisting us in the further
                     development of the information or policies addressed within this volume.

                     If you  are interested in assisting in the development of new notebooks for
                     sectors not covered in the original eighteen, please contact the Office  of
                     Compliance at 202-564-2395.
September 1995                             2                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals

II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY

                     This section  provides  background  information  on the size,  geographic
                     distribution, employment, production, sales, and economic condition of the
                     inorganic chemicals industry.  The type of facilities  described within the
                     document are  also  described  in  terms  of their  Standard  Industrial
                     Classification (SIC) codes.  Additionally, this section contains a list of the
                     largest companies in terms of sales.

II.A. Introduction, Background, and Scope of the Notebook

                     The inorganic chemical industry manufactures over 300 different chemicals
                     accounting for about 10 percent of the total value of chemical shipments in the
                     U.S.1  This industry categorization  corresponds to Standard Industrial
                     Classification (SIC) code 281 Industrial Inorganic Chemicals established by
                     the Bureau of Census to track the flow of goods and services within the
                     economy.  The 281  category  includes alkalies and chlorine (SIC 2812),
                     industrial gases (SIC 2813) (e.g., hydrogen, helium, oxygen, nitrogen, etc.),
                     inorganic pigments (SIC 2816), and  industrial inorganic chemicals,  not
                     elsewhere classified (SIC 2819).  Approximately two-thirds of the value of
                     shipments for the inorganic chemical industry, including over 200 different
                     chemicals, are classified under industrial inorganic chemicals, not elsewhere
                     classified (SIC 2819). The industry does not include those establishments
                     primarily manufacturing organic chemicals, agricultural  pesticides, drugs,
                     soaps, or cosmetics.  However, the 281  industry group does include  a
                     significant number of integrated  firms that are engaged in the manufacture of
                     other types of chemicals at the  same site. Conversely, many manufacturing
                     facilities not categorized under SIC 281, especially organic chemicals facilities
                     (SIC 286), fertilizer plants (SIC 287), pulp and paper mills (SIC 26), and iron
                     and steel mills  (SIC 331),  produce and use  inorganic chemicals  in their
                     processes at the same facility.2 For example, a significant number of inorganic
                     chemical manufacturing processes  are part  of very large chemical
                     manufacturing or  pulp manufacturing  facilities, making characterization
                     strictly by SIC code difficult.

                     Whenever possible, this notebook describes the entire inorganic chemical
                     industry. In many cases, however, specific details relating to some of the
                     topics covered by the notebook (facility size,  economic trends, geographic
                     distribution, pollutant releases, pollution prevention issues, and applicable
                     regulations) vary depending on the type of inorganic chemical manufacturing
                     process.  The large number of different industrial processes used in the
                     inorganics industry could not all be covered in this notebook.  As a result,
                     most sections of this notebook describe the entire inorganic chemical industry
                     as  a whole. These sections are  usually augmented with information specific
September 1995                             3                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals

                     to the largest single industrial process within the industry: chlorine and caustic
                     soda production (SIC 2812).  Section III, Industrial Process Description,
                     rather than attempting to describe every inorganic chemical manufacturing
                     process, deals solely with the production of chlorine and caustic soda.

II.B. Characterization of the Inorganic Chemical Industry

       II.B.1. Product Characterization

       Inorganic Chemicals Industry

                     The inorganic chemical industry manufactures chemicals which are often of
                     a mineral origin, but not of a basic carbon molecular. Inorganic chemicals are
                     used at some stage in the manufacture of a great variety of other products.
                     The industry's products are used as basic chemicals for industrial processes
                     (i.e., acids, alkalies, salts, oxidizing agents, industrial gases, and halogens);
                     chemical products to be used in manufacturing products (i.e., pigments, dry
                     colors, and alkali metals); and finished products for ultimate consumption
                     (i.e., mineral fertilizers, glass, and construction materials).  The largest use of
                     inorganic chemicals is as processing aids in the manufacture of chemical and
                     nonchemical products.  Consequently, inorganic chemicals often do not
                     appear in the final products.3

       Chlor-alkali Sector

                     The  chlor-alkali industry produces mainly chlorine,  caustic soda (sodium
                     hydroxide), soda ash (sodium carbonate), sodium bicarbonate,  potassium
                     hydroxide, and potassium carbonate.  In 1992, chlorine  and caustic soda
                     production accounted for about 80 percent of the chlor-alkali industry's value
                     of shipments and, in terms of weight, were the  eighth and ninth largest
                     chemicals produced in the U.S., respectively.  Chlorine and caustic soda are
                     co-products produced in  about equal amounts primarily  through  the
                     electrolysis of salt (brine).4

                     The  majority of domestic chlorine production (70 percent) is used in  the
                     manufacturing of organic chemicals  including: vinyl chloride  monomer,
                     ethylene dichloride, glycerine, glycols, chlorinated solvents, and chlorinated
                     methanes.  Vinyl chloride, which is  used in the production of polyvinyl
                     chloride (PVC) and many other organic chemicals,  accounts for about 38
                     percent of the  total  domestic chlorine  production.   The pulp  and paper
                     industry consumes approximately 15 percent of U.S. chlorine production, and
                     about eight percent is used in the manufacturing of other inorganic  chemicals.
                     Other major uses are disinfection treatment of water, and the production of
September 1995                             4                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals

                     hypochlorites. More than two-thirds of all chlorine is consumed in the same
                     manufacturing plant in the production of chemical intermediates.5

                     The largest  users of caustic soda are the organic chemicals industry (30
                     percent) and the inorganic chemicals industry (20 percent).  The primary uses
                     of caustic soda  are in industrial processes,  neutralization,  and off-gas
                     scrubbing; as a catalyst; and in the production of alumina, propylene oxide,
                     polycarbonate resin, epoxies, synthetic fibers, soaps, detergents, rayon, and
                     cellophane.  The pulp  and paper industry uses  about 20 percent of total
                     domestic caustic  soda production for pulping wood chips, and  other
                     processes. Caustic soda is also used in the production of soaps and cleaning
                     products, and in the petroleum and natural gas extraction industry as a drilling
                     fluid.6

       II.B.2. Industry Size and Geographic Distribution

       Inorganic Chemical Industry

                     The inorganic chemical industry is characterized by a relatively large number
                     of small facilities.  The  Bureau of the Census  identified  665 companies
                     operating 1,429 facilities within SIC 281  in 1992.a Most of these facilities
                     were classified under  SIC  2819  —  industrial  inorganic  chemicals,  not
                     elsewhere classified — which are typically smaller facilities producing specialty
                     inorganic chemicals.  The  Bureau of Census employment data  for 1992
                     (Exhibit 1) indicated that about 63 percent of inorganic chemical facilities
                     employed fewer than 20  people.  A significant portion of inorganic chemicals
                     are produced and used within the same plant in the manufacturing of organic
                     chemicals. The number of these facilities and the number of people employed
                     in the inorganic chemical production portion of the industrial processes is not
                     included in this data.
a Variation in facility counts occur across data sources due to many factors including, reporting and definition
differences. This notebook does not attempt to reconcile these differences, but rather reports the data as they are
maintained by each source.
September 1995                              5                                      SIC 281

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Sector Notebook Project
Inorganic Chemicals
Exhibit 1: Inorganic Chemicals Industry Dominated
by a Large Number of Small Facilities

Employees
per Facility
1-9
10-19
20-49
50-249
250-999
1,000->2,500
Total
Inorganic Chemicals
Number
of Facilities
682
212
253
221
51
10
1,429
Percentage
of Facilities
48%
15%
18%
15%
3%
1%
100%
Chlor-alkali
Number of
Facilities
12
6
3
23
6
1
51
Percentage
of Facilities
24%
12%
6%
44%
12%
2%
100%
Source: Bureau of the Census, 1992 Census of Manufacturers.
                     Inorganic chemical facilities are typically located near consumers and to a
                     lesser extent raw materials.  The largest use of inorganic  chemicals is in
                     industrial  processes for the  manufacture of chemicals  and nonchemical
                     products; therefore, facilities are concentrated in the heavy industrial regions
                     along the Gulf Coast, both east and west coasts, and the Great Lakes region.
                     Since a large portion of inorganic chemicals produced are used by the organic
                     chemicals manufacturing industry, the geographical distribution of inorganic
                     facilities is very similar to that of organic chemicals facilities (Exhibit 2).
September 1995
             SIC 281

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Sector Notebook Project
Inorganic Chemicals
                   Exhibit 2: Inorganic Chemicals Facilities Distribution
                                                    0 100 200 300 400
(Source: U.S. EPA Toxic Release Inventory Database, 1993)

Chlor-alkali Sector
                     The  alkali and chlorine industry, however,  consists of a relatively small
                     number of medium to large facilities. The Bureau of the Census identified 34
                     companies operating 51 facilities within the SIC 2812 in 1992. According to
                     The Chlorine Institute (an industry trade group), there were 25 companies
                     operating 52 chlorine production plants in 1989.  The Bureau of Census
                     employment data for 1992 indicated that about 60 percent of those employed
                     in  the chlor-alkali industry worked at facilities with over 50 employees
                     (Exhibit I).7'8

                     The distribution of the chlor-alkali sector differs from that of the inorganic
                     chemicals industry as a whole.  Since chlorine and caustic soda are co-
                     products produced in almost equal amounts, the distribution of the caustic
                     soda manufacturing  industry  is essentially the  same  as the  chlorine
                     manufacturing  industry.   Chlorine  is  difficult  to store and  transport
                     economically; therefore, chlorine and caustic soda  are produced near the
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Inorganic Chemicals
                    chlorine consumers which are primarily chemical manufacturers and pulping
                    operations.  Consequently, chlor-alkali facilities are concentrated near the
                    chemical industries along the Gulf Coast, followed by the Great Lakes region
                    as shown in the table below. Other important areas are in the vicinity of the
                    pulp mills of the Southeast and Northwest (Exhibit 3). In 1989, almost half
                    of the chlorine plants in the U.S. (72 percent of domestic chlorine production)
                    were located  along the Gulf Coast.  Two  states, Louisiana and  Texas,
                    accounted for two-thirds of the domestic chlorine production.9
Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast,
Southeast, Northwest, and Great Lakes Region
State
Louisiana
Texas
New York
Alabama
Washington
West Virginia
Georgia
Tennessee
Other States (14)
U.S. Total
Number of
Chlorine Plants
9
5
4
5
4
2
3
1
19
52
Annual Capacity
(thousand tons
per year)
4,068
3,314
652
592
503
392
246
230
1,139
11,136
Percent of
Total U.S.
Operating
Capacity
37%
30%
6%
5%
5%
3%
2%
2%
10%
100%
Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed. Vol. 1, 1993.
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Inorganic Chemicals
                     Ward's Business Directory of U.S. Private Companies, produced by Gale
                     Research Inc., compiles financial data on U.S. companies including those
                     operating within the inorganic chemicals manufacturing industry.  Ward's
                     ranks U.S. companies, whether they are a parent company, subsidiary or
                     division, by sales volume within the 4-digit SIC codes that they have been
                     assigned  as their primary  activity.   Exhibit 4 lists the  top ten inorganic
                     chemical manufacturing companies in the U.S. Readers should note that: 1)
                     Companies are assigned a 4-digit SIC that most closely resembles their
                     principal industry; and 2) Sales figures include total company sales, including
                     sales derived from subsidiaries and operations not related to the manufacture
                     of inorganic chemicals. Additional sources of company  specific financial
                     information include Standard &  Poor's Stock Report Services,  Dunn &
                     Bradstreet's Million Dollar Directory, Moody's Manuals, and annual reports.
Exhibit 4: Top U.S. Companies with
Inorganic Chemical Manufacturing Operations
Ranka
1
2
3
4
5
6
7
8
9
10
Company13
Dow Chemical Co. - Midland, Ml
Hanson Industries, Inc. - Iselin, NJ
WR Grace and Co. - Boca Raton, FL
Occidental Chemical Corp. - Dallas, TX
BOC Group, Inc. - Murray Hill, NJ
FMC Corp. - Chicago, 1L
Eastman Kadak Co. - Kingsport, TN
Air Products and Chemicals, Inc. - Allentown, PA
ARCO Chemical Co. - Newtown Square, PA
Ethyl Corp. - Richmond, VA
1993 Sales
(millions of dollars)
18,800
6,092
6,049
4,600
4,500
3,899
3,740
2,931
2,837
2,575
Note: a When Ward's Business Directory listed both a parent and subsidiary in the top ten,
only the parent company is presented above to avoid double counting sales volumes.
Not all sales can be attributed to the companies' inorganic chemical manufacturing
operations.
b Companies shown listed SICs 2812, 2813, 2816 and 2819 as primary activities.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
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       II.B.3. Economic Trends

       Inorganic Chemicals Industry

                    The Bureau of the Census estimated that there were 1,429 facilities in the
                    inorganic chemical industry in 1992. The industry employed 103,000 people
                    and  had a total value of shipments of $27.4 billion. The total value of
                    shipments for the inorganic chemicals industry increased about one percent
                    per year between 1992 and 1994.  These values do not include inorganic
                    chemicals manufactured for captive use within a facility nor the value of other
                    non-industrial inorganic chemical products manufactured by the same facility.
                    It does, however, include intra-company transfers which are significant in this
                    industry.  The inorganic chemical industry's growth rate  is expected to
                    continue to increase with the growth of the economy.  The U.S. is a net
                    exporter of inorganic chemicals with most exports shipped to the European
                    Community (EC) followed by Canada and Mexico.  This positive trade
                    balance increased significantly in 1993 to $1.7 billion and is expected to
                    continue as  the European economy improves.  By comparison, the 1992
                    Census of Manufactures for Industrial Organic Chemicals reports  a 1992
                    value of shipments  for organic chemicals  of $64.5  billion and  a  total
                    employment of 125,100 people. The 1992 value of shipments for the entire
                    chemical industry (SIC 28) totaled $292.3 billion with an employment of
                    850,000 people.10

                    Because inorganic chemicals are used in the manufacturing  of many products,
                    the industry tends to grow at the same rate as overall industrial production.
                    In the late 1980s, the industry experienced high growth rates and, in the early
                    1990s, the industry saw little real growth in output, as a reflection of the U.S.
                    economy's recession.  The industry has historically had low profit margins
                    which,  in recent years, have  decreased further with increasing pollution
                    abatement costs.11

       Chlor-alkali Sector

                    The Bureau of the Census data for  1992 shows that there were 51 facilities
                    within the  inorganic  chemicals  industry that manufactured  alkalies and
                    chlorine. These chlor-alkali facilities employed 8,000 people and had a total
                    value of shipments of $2.8 billion. This was an increase of 1.7 percent from
                    1991. The chlor-alkali industry as a whole is expected to grow at its past rate
                    of 1.5  times gross domestic  product  (GDP) growth  through the  1990s.
                    Because chlorine and caustic soda are electrolysis co-products, the production
                    of one product can depend on the demand of the other product. The market
                    pull has switched several times between caustic soda and chlorine in the past
                    few  decades.   Presently, chlorine demand is  controlling production;
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                    consequently, there is a current excess availability of caustic soda in the U.S.
                    This excess material is typically exported to fill a significant demand outside
                    the U.S.   The consumption of caustic soda  is growing faster than the
                    consumption of chlorine, however, and domestic caustic soda demand is
                    expected to control production in the coming years.12

                    After reaching record high levels in the late  1970s,  chlorine production
                    declined in the early 1980s due in part to the economic recession between
                    1980 and 1982. Chlorine production increased slowly through the 1980s and,
                    as of 1992, had not reached the record high levels and growth rates of the
                    1970s.  This is due in part to the relative  maturity of the chlorine usage
                    industries and more recent environmental pressures  aimed at curtailing
                    chlorine use.  Regulatory restrictions on the production or disposal of some
                    products which require  large amounts of chlorine to manufacture  (i.e.,
                    chlorofluorocarbons, PVC, and chlorinated solvents) have adversely affected
                    the market.   Chlorine's  commercial appeal has  been further  reduced by
                    initiatives such as the International Joint Commission of Great Lakes Water
                    Quality (a  Canada-U.S. environmental oversight group) and a number of
                    environmental groups which call for a gradual phaseout or an immediate ban
                    of chlorine and chlorinated compounds as industrial feedstocks.13

                    The production of caustic soda is very dependent on the short term and long
                    term chlorine demand and production because chlorine cannot be stored
                    economically. Increased demand  for chlorine must be  met immediately by
                    increased chlorine production  via electrolysis of brine and, consequently,
                    caustic soda production. Domestic and export demand for caustic soda was
                    very strong in the 1980s with the pick up of the world  economy and an
                    increase  in pulp  and paper production.  In the late  1980s, there was  a
                    worldwide shortage of caustic soda due to increased demand and lower U.S.
                    chlorine production. The demand for caustic soda is expected to continue to
                    grow in the coming years; however, there are a number of uncertainties that
                    may limit the growth rate.  Some industries have begun  switching from caustic
                    soda to soda ash where possible to avoid caustic soda shortages. Soda ash,
                    which  is extremely plentiful in the U.S., is obtained almost entirely  from
                    natural sources of trona ore.  Demand for caustic soda may also decrease as
                    pulp mills  increase their reclamation of caustic  soda  from spent pulping
                    liquor.14
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III. INDUSTRIAL PROCESS DESCRIPTION

                     This section describes the major industrial processes within the inorganic
                     chemical industry, including the  materials and  equipment used, and the
                     processes employed.  The section is designed for those interested in gaining
                     a general understanding of the industry, and for those interested in the inter-
                     relationship  between the industrial process and the  topics  described  in
                     subsequent sections of this profile — pollutant outputs, pollution prevention
                     opportunities, and Federal regulations. This  section does not  attempt  to
                     replicate published engineering information that  is available for this industry.
                     Refer to Section IX for a list of reference documents that are available.

                     This section specifically contains a description of commonly used production
                     processes, associated raw materials, the byproducts produced or released, and
                     the materials either recycled or transferred off-site.  This discussion, coupled
                     with schematic drawings of the  identified processes, provide a concise
                     description of where wastes may be produced  in the process.  This section
                     also describes the potential fate (via air, water, and soil pathways) of these
                     waste products.

III.A. Industrial Processes in the Inorganic Chemical Industry

                     Chlorine and caustic soda are co-products of electrolysis of saturated aqueous
                     solutions of  sodium chloride, NaCl  (salt water or brine).   In addition,
                     relatively small amounts (by weight) of hydrogen gas are produced in the
                     process. The overall chemical reaction is as follows:

                                   2 NaCl + 2 H2O D  2 NaOH + C12 + H2

                     Energy, in the form of direct current (d-c) electricity, is supplied to drive the
                     reaction. The amount of electrical  energy required depends on the design  of
                     the  electrolytic cell, the  voltage used, and the  concentration of brine used.
                     For each ton of chlorine produced, 1.1 tons of sodium hydroxide and 28
                     kilograms of hydrogen are produced.

                     Three types of electrolysis processes are used for  the manufacture of chlorine,
                     caustic soda, and hydrogen from brine:

                     D      Mercury Cell Process
                     D      Diaphragm Cell Process
                     D      Membrane Cell Process

                     Virtually all chlorine produced in the U.S. is manufactured by one of these
                     three electrolysis processes.  Each electrolytic cell consists of an anode and
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                    cathode  in contact with the brine solution.  Exhibit 5 shows  the  basic
                    elements, inputs and  outputs  of each type of electrolytic cell.   The
                    distinguishing feature of each cell type is the method employed to separate
                    and  prevent  the mixing of the  chlorine  gas  and  sodium hydroxide.
                    Consequently, each process produces a different purity of chlorine gas  and a
                    different concentration of caustic soda. Exhibit 6 is a summary of the major
                    differences between each cell type.  In 1988, diaphragm cells accounted for
                    76 percent of all domestic chlorine production, followed by mercury cells with
                    17 percent, and membrane cells with five percent. The industry is moving
                    away from mercury and diaphragm cells and is moving towards the use of
                    membrane cells. Membrane cells are a relatively recent development which
                    have fewer adverse effects on the environment and produce a higher quality
                    product at a lower cost than the other methods.15'16
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                        Inorganic Chemicals
                           Exhibit 5: Chlorine Electrolysis Cells
                                 HllMtu
                                 vfvin^v     _





                            —— —
                                                      Hweury
                                                      Call
                           CfHMH
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                         Inorganic Chemicals
              (Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.)
Exhibit 6: Main Characteristics of the Different Electrolysis Processes
Component
Cathode
Diaphragm/
Membrane
Anode
Cathode
Product
Decomposer/
Evaporator
Product
Electricity
Consumption
Mercury Cell
Mercury flowing
over steel
None
Titanium with RuO2
or TiO2 coating
(DSA anode)
Sodium amalgam
50% NaOH and H2
from decomposer
3,300 kWh per ton
C12
Diaphragm Cell
Steel or steel coated
with activated nickel
Asbestos or polymer
modified asbestos
Titanium with RuO2
or TiO2 coating
(DSA anode)
10- 12% NaOH with
15-17% NaCl and
H2
50% NaOH with 1%
NaCl and solid salt
from evaporator
2,750 kWh per ton
C12
Membrane Cell
Steel or nickel with a
nickel based catalytic
coating
Ion-exchange
membrane
Titanium with RuO2
or TiO2 coating
(DSA anode)
30-33% NaOH and
H2
50% NaOH with
very little salt
2,1 00-2,450 kWh per
ton NaOH
Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.
       III.A.1. Mercury Cell
                     The mercury cell process consists of slightly inclined steel troughs through
                     which a thin  layer of mercury  (about three mm) flows over the bottom
                     (Exhibit 7). The cells are operated at 75 to 85 DC and atmospheric pressure.
                     The mercury  layer serves as the cathode for the process and the saturated
                     brine solution (25.5 percent NaCl by weight) flows through the troughs above
                     the mercury. The anodes are usually incorporated into the cell covers and are
                     suspended horizontally in the brine solution.  The height of the anodes within
                     the brine is adjusted to the optimal height either manually or through an
                     automatic computer controlled system.17

                     Electrolytic cell anodes were made of graphite until the late 1960s  when
                     anodes of titanium coated with ruthenium oxide (RuO2) and titanium  oxide
                     (TiO2) were  developed.   The  RuO2  and TiO2  anodes, termed  DSA
                     (dimensionally stable) anodes, are more stable than the graphite anodes (i.e.,
                     they do not need to be replaced as frequently) and are more energy efficient.18
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                          Inorganic Chemicals
                           Exhibit 7: Mercury Electrolysis Cell and Flow Diagram
                   puntbrta
                                                                        > dtplatod bfln*

                                       thkdn*
              (Source: Industrial Inorganic Chemistry, Biichner, et al., 1989.)
                     The chlorine gas is produced at the anodes where it moves upward through
                     gas extraction slits in the cell covers.   Sodium ions are absorbed by the
                     mercury  layer and the resulting sodium and mercury mixture, called the
                     amalgam, is processed in "decomposer" cells to generate sodium hydroxide
                     and reusable mercury.   The amalgam entering  the decomposer cell has a
                     sodium concentration of approximately 0.2 to 0.5  percent by weight. The
                     decomposer consists of a short-circuited electrical cell where graphite serves
                     as the anode and the amalgam serves as the cathode.  The amalgam and water
                     flowing through the  cell come into direct contact with the  graphite.  The
                     hydrolysis of the water on the graphite in the presence of the amalgam results
                     in  a  strong exothermic reaction generating mercury to  be reused in the
                     electrolytic cell, a 50  percent caustic  soda solution, and  hydrogen gas.
                     Mercury  cells are operated to maintain a 21 to 22 percent by weight NaCl
                     concentration in the depleted brine leaving the cell.  The dissolved chlorine is
                     removed from the depleted brine solution, which is then resaturated with solid
                     salt and purified for further use. Some facilities purge small amounts of brine
                     solution and use new brine as make-up in order to prevent the build up of
                     sulfate impurities in the brine.19'20
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                     The mercury process has the advantage over diaphragm and membrane cells
                     in that it produces a pure chlorine gas with no oxygen, and a pure 50 percent
                     caustic soda solution without having to further concentrate a more dilute
                     solution. However, mercury cells operate at a higher voltage than diaphragm
                     and membrane cells and, therefore, use more energy.   The process also
                     requires a very pure brine  solution with  little or no metal contaminants.
                     Furthermore,  elaborate precautions must  be taken to avoid releases  of
                     mercury to the environment.

       III.A.2. Diaphragm Cell

                     In the diaphragm cell process, multiple cells consisting of DS A anode plates
                     and cathodes  are mounted vertically and parallel to each other (Exhibit 8).
                     Each cell consists of one anode and cathode pair. The cathodes are typically
                     flat hollow  steel mesh or perforated steel structures covered with asbestos
                     fibers, which  serve as the diaphragm. The asbestos fiber structure of the
                     diaphragm prevents the mixing of hydrogen and chlorine by allowing liquid to
                     pass through to the cathode, but not fine bubbles of chlorine gas formed at the
                     anodes.  The diaphragm  also hinders the  back-diffusion to  the anode  of
                     hydroxide (OH") ions formed at the cathode.  The cells are operated at 90 to
                     95 DC and  atmospheric pressure.  Brine flows continuously into the anode
                     chamber and, subsequently, through the diaphragm  to the cathode. As in the
                     mercury cell process, chlorine gas is formed at the anodes; however, in the
                     diaphragm  process, caustic soda solution and hydrogen gas are formed
                     directly at the cathode. The chlorine gas is drawn off from above the anodes
                     for further processing.  The hydrogen gas is drawn off separately from the
                     cathode chambers.21'22

                     Two  basic types of diaphragm cells are in use today.  The first, monopolar
                     cells, have an electrode arrangement in which the anodes and cathodes are
                     arranged in parallel. As a result of this configuration, all cells have the same
                     voltage of about three to four volts; up to 200 cells can be constructed in one
                     circuit. The second basic type of diaphragm cell is the bipolar cell, in which
                     the anode of one cell is directly connected to the cathode of the next cell unit.
                     This type of arrangement minimizes voltage loss between cells; however, since
                     the total voltage across the entire set of cells is the sum of the individual cell
                     voltages, the  number of cells per unit is limited.  To compensate for the
                     reduced anode and cathode surface area in the bipolar configuration, bipolar
                     units  tend to be much larger than monopolar units.  Production of chlorine
                     and caustic soda by the diaphragm process is split approximately equally
                     between monopolar and bipolar systems.23
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                          Inorganic Chemicals
                            Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram
                                                         CHLORINE
                      •"*£_,_,  I
                       i envnlMl*
                      1   i     i
                                             Equcr
          «* N*OH +1% Ntd
                         +  v
                                                  liquor
                                                          ilLFV
                                                              liquor
               (Source: Industrial Inorganic Chemistry, Biichner, et al., 1989)

                     Diaphragm cells are operated such that about 50 percent of the input NaCl is
                     decomposed resulting in an effluent mixture of brine and caustic soda solution
                     containing eight to 12 percent NaOH and 12 to 18 percent NaCl by weight.
                     This solution is evaporated to 50 percent NaOH by weight at which point all
                     of the salt, except a residual 1.0 to 1.5 percent by weight, precipitates out.
                     The salt generated is very pure and is typically used to make more brine.
                     Because the brine and caustic soda solution are mixed in a single effluent, a
                     fresh brine solution (no recycled brine) is constantly entering the system. The
                     diaphragm cell process does not, therefore, require a brine purge to prevent
                     sulfate build up, or treatment to remove entrained chlorine gas,  as in the
                     mercury cell process.24

                     Diaphragms are constructed of asbestos because of its  chemical and physical
                     stability and because it is a relatively inexpensive and abundant material.
                     Beginning in the early 1970s, asbestos diaphragms began to be replaced by
                     diaphragms  containing  75  percent  asbestos  and  25  percent fibrous
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                    polytetrafluoroethylene (PTFE). These diaphragms, trade named Modified
                    Diaphragms,  are more stable and operate  more efficiently than the  fully
                    asbestos diaphragms.   Modified  Diaphragms are  the  most  common
                    diaphragms currently in use.25

                    Diaphragm cells have the advantage of operating at a lower voltage than
                    mercury cells and, therefore, use less electricity.   In addition, the brine
                    entering a diaphragm cell can be less pure than that required by mercury and
                    membrane cells.  The chlorine gas produced by the diaphragm process,
                    however, is not pure and must be processed to remove oxygen, water, salt,
                    and  sodium hydroxide.  Another disadvantage of the process is that the
                    caustic soda produced contains chlorides and requires evaporation to bring it
                    to a usable concentration.26

       III.A.3. Membrane Cell

                    In the  membrane cell process, the  anode and cathode are separated  by a
                    water-impermeable ion-conducting membrane (Exhibit 9).  Brine solution
                    flows through the anode compartment where chlorine gas is generated.  The
                    sodium ions migrate through the membrane to the cathode compartment
                    which  contains flowing caustic soda solution. Water is hydrolyzed at the
                    cathode, releasing hydrogen gas and hydroxide (OH") ions. The sodium and
                    hydroxide ions combine to produce caustic soda which is typically brought to
                    a concentration of 32 to 35 percent by recirculating the solution before it is
                    discharged from the cell. The membrane prevents the migration of chloride
                    ions  from the anode compartment to the cathode compartment; therefore, the
                    caustic soda solution produced does not contain salt as in the diaphragm cell
                    process. Depleted brine is  discharged from the anode compartment and
                    resaturated with salt.27

                    The cathode material used in membrane cells is either stainless steel or nickel.
                    The  cathodes  are often coated with  a catalyst that is more stable than the
                    substrate and that increases surface area and electrical conductivity. Coating
                    materials include Ni-S, Ni-Al, and Ni-NiO mixtures, as well as mixtures of
                    nickel and platinum group metals. Anodes are typically of the DSA type.28

                    The  most critical components of the membrane cells are the membranes
                    themselves.   The membranes must remain stable while being  exposed to
                    chlorine on one side and a strong caustic solution on the other.  Furthermore,
                    the membranes must have low electrical resistance, and allow the transport of
                    sodium  ions  and  not chloride ions  and  reinforcing  fabric,  and a
                    perfluorocarboxlate polymer all bonded together.
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                          Inorganic Chemicals
                            Exhibit 9: Typical Membrane Electrolysis Cell
         (Source: Industrial Inorganic Chemistry, Biichner, et al., 1989.)

                    Membrane cells can be configured either as monopolar or bipolar. As in the
                    case of the diaphragm cell process, the bipolar cells have less voltage loss
                    between the cells than the monopolar  cells; however, the number of cells
                    connected together in the same circuit is limited.29

                    Membrane cells have the advantages of producing a very pure caustic soda
                    solution  and of using less electricity than  the mercury and  diaphragm
                    processes.  In addition, the membrane process does not use highly toxic
                    materials such as mercury and asbestos. Disadvantages of the membrane
                    process are that  the chlorine gas produced must be processed to remove
                    oxygen and water vapor, and the caustic soda produced must be evaporated
                    to increase the concentration.  Furthermore, the brine entering a membrane
                    cell must be of a very high purity, which  often requires costly additional
                    purification steps prior to electrolysis.30
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       III.A.4. Auxiliary Processes

       Brine Purification

                     Approximately 70 percent of the salt used in chlorine gas production is
                     extracted  from natural  salt deposits; the  remainder is  evaporated from
                     seawater. Salt from natural deposits is either mined in solid form or is leached
                     from the  subsurface.  Leaching involves the injection of freshwater into
                     subterranean salt deposits and pumping out brine solution.  Brine production
                     from seawater typically occurs by solar evaporation in a series of ponds to
                     concentrate the seawater, precipitate out impurities, and precipitate out solid
                     sodium chloride.  Regardless of the method used to obtain the salt, it will
                     contain impurities that must be removed before being used in the electrolysis
                     process.  Impurities primarily consist of calcium, magnesium, barium, iron,
                     aluminum, sulfates, and trace metals. Impurities can significantly reduce the
                     efficiency of the  electrolytic  cells, by precipitating  out and subsequently
                     blocking a diaphragm or damaging a membrane  depending on the process
                     used.   Certain trace metals,  such  as vanadium, reduce the efficiency of
                     mercury cells and cause the production of potentially dangerous amounts of
                     hydrogen gas. Removal of impurities accounts for a significant portion of the
                     overall costs of chlor-alkali production, especially in the membrane process.


                     In addition to the dissolved natural impurities,  chlorine must be removed from
                     the recycled brine  solutions  used in mercury  and  membrane  processes.
                     Dissolved chlorine gas entering the anode chamber in the brine solution will
                     react with hydroxide  ions formed at the cathode to form  chlorate which
                     reduces product yields.  In addition, chlorine gas in the brine solution will
                     cause corrosion of pipes, pumps, and containers during further processing of
                     the brine.  In a typical chlorine plant, HC1 is added to the brine solution
                     leaving the cells to liberate the chlorine gas. A vacuum is applied to the
                     solution to collect the chlorine gas for further treatment. To further reduce
                     the chlorine  levels, sodium sulfite or another reducing agent is added to
                     remove the final traces of chlorine. Dechlorinated brine is then resaturated
                     with solid salt before further treating to remove impurities.32

                     Depending on the amount of impurities in the  salt and the electrolysis process
                     utilized, different purification steps will be required.  Brine solution is typically
                     heated before treatment  to improve reaction times and precipitation of
                     impurities.   Calcium carbonate impurities are  precipitated out through
                     treatment with sodium  carbonate; magnesium,  iron,  and  aluminum  are
                     precipitated out through treatment with sodium hydroxide; and sulfates are
                     precipitated out through the addition of calcium chloride or barium carbonate.
                     Most  trace  metals are  also  precipitated  out through  these  processes.
                     Flocculants  are sometimes added to  the clarifying  equipment to  improve
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                     settling.   The  sludges generated in this process  are washed to  recover
                     entrained sodium chloride.  Following the clarification steps, the brine solution
                     is typically passed through sand filters followed by polishing filters.  The brine
                     passing through these steps will contain less than four parts per million (ppm)
                     calcium  and 0.5 ppm magnesium which is sufficient purification for the
                     diaphragm and mercury cell processes.  For brine to be used in the membrane
                     process, however, requires a combined calcium and magnesium content of less
                     than 20 parts per billion (ppb).  Brine for the membrane process is,  therefore,
                     passed through ion exchange columns to  further remove impurities.33

       Chlorine Processing

                     The chlorine gas produced by electrolytic processes is saturated with water
                     vapor. Chlorine gas from the  diaphragm process also contains liquid droplets
                     of sodium hydroxide and salt solution.  The first steps in processing the
                     chlorine to a usable product consists of cooling the chlorine to less than ten
                     degrees centigrade and then passing it  through  demisters  or electrostatic
                     precipitators to remove water and solids. Next the chlorine is passed through
                     packed towers with concentrated sulfuric acid flowing countercurrently.  The
                     water vapor is absorbed by the sulfuric acid and the dry chlorine gas is then
                     passed through demisters to remove sulfuric acid mist. If the chlorine is to be
                     liquefied, liquid chlorine is then added to the gas to further purify the chlorine
                     and to prechill it prior to compression. Prechilling is primarily carried out to
                     prevent the temperature from reaching the  chlorine-steel ignition point during
                     compression.34

                     Chlorine gas is either used in gaseous form within the facility, transferred to
                     customers via pipeline, or liquefied for storage or transport. Liquid chlorine
                     is of a higher purity than gaseous chlorine and is either used within the facility
                     or is transferred via rail tank car, tank truck,  or tank barge. The demand for
                     liquid chlorine has increased in recent years and, in 1987, accounted for about
                     81 percent of chlorine produced in the U.S.35

                     Chlorine liquefaction processes typically liquefy only about 90-95 percent of
                     the chlorine. This gas and the chlorine gas  left inside tank truck tanks, rail car
                     tanks,  or barges after removal of liquid chlorine  is impure and must be
                     recovered in a chlorine recovery unit. The gas is compressed and cooled
                     using cold water followed by Freon.  The chilled  gas is  fed up  through a
                     packed column in which carbon tetrachloride flows downward absorbing the
                     chlorine.  The chlorine-rich carbon tetrachloride is fed to a chlorine  stripper
                     in which the chlorine and carbon tetrachloride separate as they are heated.
                     The chlorine gas is cooled and scrubbed of carbon tetrachloride using liquid
                     chlorine  and the resulting pure chlorine  is sent to the chlorine liquefaction
                     system.36
       Caustic Soda Processing


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                     Caustic  soda solution generated from  chlor-aikali processes is typically
                     processed to remove impurities and to concentrate it to either a 50 percent or
                     73 percent water-based solution or to anhydrous caustic soda.  The caustic
                     soda from the mercury and membrane processes is relatively pure. Product
                     from the mercury process requires only filtration to remove mercury droplets.
                     The evaporators  used to concentrate  the  caustic  soda  solution in  the
                     diaphragm process are typically multi-stage forced circulation evaporators.
                     The evaporators have  salt  settling systems  to remove precipitated salt.
                     Sodium borohydride is often added to reduce corrosion of the equipment.
                     Evaporators for the membrane process are usually much simpler than those
                     for the diaphragm process because the salt concentration in the membrane cell
                     caustic solution is very low.37

       Hydrogen Processing

                     The hydrogen produced in  all  of the electrolytic processes contains small
                     amounts of water vapor, sodium hydroxide, and salt which is removed
                     through cooling. The hydrogen produced during the mercury cell process also
                     contains small amounts of mercury which must be removed by cooling  the
                     hydrogen gas to condense the mercury and treating with activated carbon.38

III.B. Raw Material Inputs and Pollution Outputs  in the Production Line

                     Inputs and pollutant outputs of the chlor-alkali industry are relatively small
                     both in  number and volume in comparison to the chemical manufacturing
                     industry as  a whole.  The inputs are primarily salt and water as feedstocks;
                     acids and chemical precipitants  used to remove impurities in the input brine
                     or output chlorine and caustic soda; and freon  used for liquefying and
                     purifying the chlorine gas produced.   The major pollutant outputs from all
                     three electrolytic processes are chlorine gas emissions (both fugitive and point
                     source);  spent acids; freon (both fugitive and point  source); impurities
                     removed from the input salt  or brine; and pollutants originating  from
                     electrolytic cell materials and other system parts.

                     Pollutant outputs have decreased in recent years as the industry moves away
                     from the mercury and diaphragm cell processes to  the more efficient (in terms
                     of material  and energy inputs  and  outputs) membrane cell process.  In
                     addition, improved cell part materials have been developed, such as DSA
                     anodes and Modified Diaphragms, which are more  stable and create less
                     undesirable  byproducts.

                     Inputs and  pollutant outputs from  the  auxiliary processes such  as brine
                     purification, chlorine processing, caustic soda processing, and hydrogen
                     processing are described in Section III.B.4.
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       III.B.1. Mercury Cell

                     Wastewater streams from mercury cell facilities arise from the chlorine drying
                     process, brine purge, and miscellaneous sources. Small amounts of mercury
                     are found in the brine purge and miscellaneous sources which include floor
                     sumps and cell wash water.   Before treatment, mercury concentrations
                     (principally in the form of mercuric chloride, HgCl42") typically range from 0
                     to 20 ppm.  Thereby segregating most mercury bearing wastewater streams
                     from non-mercury bearing wastewater streams. Prior to treatment, sodium
                     hydrosulfide is used to precipitate mercuric sulfide. The mercuric  sulfide is
                     removed through filtration before the water is discharged.39

                     Air emissions consist of mercury vapor and chlorine gas released in relatively
                     small amounts as fugitive emissions from the cells; and in the tail gases of the
                     chlorine  processing,  caustic soda processing, and hydrogen processing.
                     Process tail gases are wet scrubbed with caustic soda or soda ash solutions to
                     remove chlorine and mercury vapor. Residual chlorine emissions in  tail gases
                     after treatment are less than one kg per 1,000 kg of chlorine produced and
                     mercury emissions are negligible.  The tail gas scrubber  water is  typically
                     reused as brine make-up water.40

                     Solid wastes containing mercury include:  solids generated during brine
                     purification;  spent graphite from decomposer cells; spent caustic  filtration
                     cartridges from the filtration of caustic soda solution;  spilled mercury from
                     facility sumps; and mercury cell "butters," which are semisolid amalgams of
                     mercury with barium or iron formed when an excess of barium is used during
                     salt purification.  Most mercury bearing solid wastes are shipped off-site to
                     outside reclaimers who recover the mercury.  The remaining wastes are
                     disposed  of in secure landfills using  either chemical or physical methods to
                     recover maximum feasible amount of mercury.41

       III.B.2. Diaphragm Cell

                     Wastewater  streams  from the diaphragm cell process originate  from the
                     barometric condenser during caustic soda evaporation, chlorine drying, and
                     from purification of salt recovered from the evaporators. These wastewaters
                     and their  treatment are described below in Section III.B.4. The use of lead
                     and graphite anodes and asbestos diaphragms generates lead, asbestos, and
                     chlorinated hydrocarbons in the caustic soda and chlorine processing waste
                     streams.   Lead salts and chlorinated  hydrocarbons are generated from
                     corrosion of the anodes, and asbestos particles are formed by the degradation
                     of the diaphragm with use.  Over  the past twenty  years,  all but a  few
                     diaphragm cell facilities have switched from the use of  lead and graphite
                     anodes with asbestos diaphragms to DSA anodes and Modified Diaphragms
                     which resist corrosion and degradation.  The lead, asbestos, and chlorinated


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                     hydrocarbon contaminants are, therefore, no longer discharged in significant
                     amounts from most diaphragm cell chlor-alkali facilities.  Those facilities that
                     discharged caustic processing wastewater streams to on-site lagoons may,
                     however, still have significant levels of these contaminants on-site.42

                     Chlorine is released in relatively small amounts as fugitive emissions from the
                     cells and in the process tail gases. Process tail gases are wet scrubbed with
                     soda ash or caustic soda solutions to remove  chlorine.  Residual chlorine
                     emissions  in tail  gases after treatment are negligible.  The  spent caustic
                     solution is neutralized prior to discharge.43

                     Solid wastes generated in the diaphragm process consist primarily of solids
                     generated during brine purification and scrapped cell parts including, cell
                     covers, piping and used diaphragms.  Discarded cell parts are either landfilled
                     on-site, as is typically the case for spent diaphragms, or shipped off-site for
                     disposal. Used cathodes and DSA anodes are shipped off-site for recovery of
                     their titanium content.44

       III.B.3. Membrane Cell

                     Wastewater from the diaphragm cell process originates from the barometric
                     condenser during  caustic soda evaporation, chlorine drying, and wash water
                     from the ion exchange resin used to purify the brine solution.  The  ion
                     exchange wash water consists of dilute hydrochloric acid with small amounts
                     of dissolved calcium, magnesium, and aluminum chloride. The wastewater is
                     combined with the other process  wastewaters and treated by neutralization.45

                     Chlorine is released in relatively small amounts as fugitive emissions from the
                     cells and in the process tail gases. Process tail gases are wet scrubbed with
                     soda ash or caustic soda solutions to remove  chlorine.  Residual chlorine
                     emissions  in tail  gases after treatment are negligible.  The  spent caustic
                     solution is neutralized prior to discharge.46

                     Solid waste generated in the diaphragm process consists primarily of solids
                     generated during brine  purification  and used  cell parts  which include
                     membranes, cathodes and DSA anodes.  The used membranes are typically
                     returned to the supplier and the  used cathodes and DSA anodes are shipped
                     off-site for recovery of their titanium content.47

       III.B.4. Auxiliary Processes

       Brine Purification

                     Brine solutions are typically treated with a number of chemicals to remove
                     impurities prior to input to the electrolytic cells. In the case of mercury and


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                     membrane cell  systems, the brine is first acidified with HC1 to remove
                     dissolved chlorine. Next, sodium hydroxide and sodium carbonate are added
                     to  precipitate  calcium and  magnesium  ions  as  calcium carbonate and
                     magnesium hydroxide.  Barium carbonate is then added to remove sulfates
                     which precipitate out as barium sulfate.  The precipitants are removed from
                     the brine solution by  settling  and filtration.  Pollutant outputs from this
                     process include fugitive chlorine emissions and brine muds.48

                     Brine muds are one of the largest waste streams of the chlor-alkali industry.
                     On average,  about 30 kilograms (kg) of brine mud are generated for every
                     1,000 kg of chlorine produced. The volume of mud will vary, however,
                     depending on the purity of the salt used. Some facilities use pre-purified (i.e.,
                     chemical grade) evaporated salts which will produce  only 0.7 to 6.0 kg of
                     brine mud per 1,000 kg of chlorine produced. Brine mud typically contains
                     magnesium hydroxide, calcium carbonate, and, in most cases, barium sulfate.
                     Mercury cell brine muds usually  contain mercury either  in the elemental form
                     or as the complex ion, mercuric chloride (HgQ42~).  Mercury- containing brine
                     muds are typically disposed of in a RCRA Subtitle C landfill after treatment
                     with sodium  sulfide which converts the mercury to an insoluble sulfide.49

                     Brine muds are usually segregated from other process wastes and stored in
                     lagoons on-site. When the lagoons become filled, the brine mud is either
                     dredged and landfilled off-site, or drained and covered over. Some plants that
                     use brine solution leached from subterranean deposits inject brine muds into
                     the salt cavities that are no longer being  used.50

       Chlorine Processing

                     The chlorine  gas recovered from electrolytic cells is cooled to remove water
                     vapor.  The condensed water is usually recycled as brine make-up although
                     some  facilities  combine this waste stream with other waterborne waste
                     streams prior to treatment.  The remaining water vapor is  removed by
                     scrubbing the chlorine gas with  concentrated sulfuric acid. The chlorine gas
                     is then compressed and cooled to form liquid chlorine. Between six kg and
                     35  kg of 79  percent sulfuric acid wastewater is generated per 1,000 kg of
                     chlorine produced. The majority of the spent sulfuric acid waste is shipped
                     off-site for refortiflcation to concentrated sulfuric acid  or for use in other
                     processes. The remainder is used to control effluent pH and/or is discharged
                     to water or land disposed.51

                     The process  of purifying and liquefying impure chlorine gas  involves the
                     absorption of the chlorine in a stream of carbon tetrachloride.  The chlorine
                     is  subsequently removed in  a stripping process in  which the carbon
                     tetrachloride is either recovered and reused, or is  vented to the atmosphere.52
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       Caustic Soda Processing

                     Caustic  soda solution generated from  chlor-alkali processes  is typically
                     processed to remove  impurities and,  in the case of the diaphragm and
                     membrane processes, is concentrated to either a 50 percent or 73 percent
                     water-based solution or to anhydrous caustic soda.  About five tons of water
                     must be evaporated per ton of 50 percent caustic soda solution produced.
                     The water vapor from the evaporators is condensed in barometric condensers
                     and, in the case of the diaphragm process, will primarily contain about 15
                     percent caustic soda solution and high concentrations of salt.  If sodium
                     sulfate is not removed during the brine purification process, salt recovered
                     from the  evaporators is often recrystallized to avoid sulfate buildup in the
                     brine.  If the salt is recrystallized, the wastewater  from sodium hydroxide
                     processing will also contain sodium sulfates.  Significant levels of copper may
                     also be present in the wastewater due to  corrosion of pipes and  other
                     equipment. Wastewater from the membrane process contains caustic soda
                     solution and virtually no salt or sodium sulfates.53

                     Caustic soda processing wastewater is typically neutralized with hydrochloric
                     acid, lagooned, and then discharged directly to a  receiving water or land
                     disposed.  The caustic soda generated from the mercury process only requires
                     filtration to remove mercury droplets which are typically recovered for reuse.

       Hydrogen Processing

                     The hydrogen produced in all of the electrolytic processes contains  small
                     amounts  of water  vapor,  sodium hydroxide,  and salt which  is removed
                     through cooling.  Condensed salt water and sodium hydroxide solution is
                     either recycled as  brine make-up or treated with  other waterborne waste
                     streams. The hydrogen produced during the mercury cell process, however,
                     also contains small amounts of mercury which must be removed prior to
                     liquefaction. Most  of the entrained mercury is extracted by cooling the gas.
                     The condensed mercury is then returned  to the electrolytic cells.   Some
                     facilities further purify the  hydrogen gas of mercury using activated carbon
                     treatment. Spent activated carbon is typically shipped off-site as a hazardous
                     waste.54

III.C. Management of Chemicals In Wastestream

                     The Pollution Prevention Act of 1990  (PPA) requires facilities to  report
                     information about the management of TRI chemicals in waste and efforts
                     made to eliminate or reduce those quantities.  These data have been collected
                     annually in Section 8 of the TRI reporting Form R beginning with the 1991
                     reporting year.  The data summarized below cover the years 1992-1995 and
                     is meant to provide a basic understanding of the quantities of waste handled


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                     by the industry, the methods typically used to manage this waste, and recent
                     trends in these methods.  TRI waste management data can be used to assess
                     trends in source reduction within individual industries and facilities,  and for
                     specific TRI chemicals.  This information could then be used as a tool in
                     identifying  opportunities  for pollution prevention compliance  assistance
                     activities.

                     From the yearly data presented below it is apparent that the portion of TRI
                     wastes reported as recycled on-site has increased and the portions treated or
                     managed through treatment on-site have decreased between 1992 and  1995
                     (projected).  While the quantities reported for 1992 and 1993  are estimates of
                     quantities already managed, the quantities reported for 1994 and 1995 are
                     projections only.  The PPA requires these projections to encourage facilities
                     to consider future waste generation and source reduction of those quantities
                     as  well as  movement up the waste management hierarchy.  Future-year
                     estimates are not commitments that facilities reporting under TRI are required
                     to meet.

                     Exhibit 10  shows that the inorganic chemicals industry managed about 1.7
                     trillion pounds of production-related waste (total quantity of TRI chemicals
                     in  the  waste from routine production operations) in  1993 (column B).
                     Column C reveals that of this production-related waste, 15 percent was either
                     transferred off-site or released to the environment. Column C is calculated by
                     dividing the  total TRI  transfers and releases by the total quantity  of
                     production-related waste. In other words, about 85 percent of the industry's
                     TRI wastes were managed on-site through  recycling, energy recovery, or
                     treatment as shown in columns E, F and G, respectively.   The majority of
                     waste that is released or transferred off-site can be divided into portions that
                     are recycled off-site, recovered for energy off-site, or treated off-site as shown
                     in columns H, I and J, respectively. The remaining portion of the production
                     related wastes (11 percent), shown in column D, is either released to the
                     environment through direct  discharges to air, land, water, and underground
                     injection, or it is disposed off-site.
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Sector Notebook Project
                       Inorganic Chemicals
Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry (SIC
281) as Reported within TRI
A
Year
1992
1993
1994
1995
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
1,642
1,712
1,759
1,732
C
% Released
and
Transferred13
16%
15%
...
—
D
% Released
and
Disposed0
Off-site
12%
11%
11%
10%
On-Site
E
%
Recycled
42%
45%
47%
48%
F
% Energy
Recovery
0%
0%
<1%
0%
G
%
Treated
42%
40%
39%
40%
Off-Site
H
%
Recycled
<1%
<1%
<1%
<1%
I
% Energy
Recovery
<1%
<1%
<1%
<1%
J
%
Treated
3%
3%
3%
3%
a Within this industry sector, non-production related waste is < 1% of production related wastes for 1993.
b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related
wastes.
c Percentage of production related waste released to the environment and transferred off-site for disposal.
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE

                     This section is designed to provide background information on the pollutant
                     releases that are reported by this industry. The best source of comparative
                     pollutant release information is the Toxic Release Inventory System (TRI).
                     Pursuant to the Emergency Planning and Community Right-to-Know Act,
                     TRI includes self-reported facility release and transfer data for over 600 toxic
                     chemicals.  Facilities within SIC Codes 20-39 (manufacturing industries) that
                     have more than 10 employees, and that are above weight-based reporting
                     thresholds are required to report TRI on-site releases and off-site transfers.
                     TRI is not specific to the chemical industry. The information presented within
                     the sector notebooks is derived from the most recently available (1993) TRI
                     reporting year (which then included 316  chemicals), and focuses primarily on
                     the on-site releases reported by each sector.  Because TRI requires consistent
                     reporting regardless of sector, it is an excellent tool for drawing comparisons
                     across industries.

                     Although  this sector notebook  does  not present historical information
                     regarding TRI chemical releases, please note that in general, toxic chemical
                     releases across all industries have been declining. In fact, according to the
                     1993 Toxic Release Inventory Data Book, reported releases dropped by 42.7
                     percent between 1988 and 1993. Although on-site releases have decreased,
                     the total amount of reported toxic waste has not declined because the amount
                     of toxic chemicals transferred off-site has increased.  Transfers have increased
                     from 3.7 billion pounds in 1991 to 4.7 billion pounds in  1993.  Better
                     management practices have led to increases in  off-site transfers  of toxic
                     chemicals for recycling.  More detailed information  can be obtained from
                     EPA's annual Toxics Release Inventory Public Data Release book (which is
                     available through the EPCRA Hotline at 800-535-0202), or directly from the
                     Toxic Release Inventory System database (for user support  call 202-260-
                     1531).

                     Wherever possible, the sector notebooks present TRI data as the primary
                     indicator of chemical release within each industrial category.  TRI data
                     provide the type, amount and media receptor of each chemical released or
                     transferred.  When other sources  of pollutant release data have been obtained,
                     these data have been included to augment the TRI information.
TRI Data Limitations
                     The reader should keep in mind the following limitations regarding TRI data.
                     Within some sectors, the majority of facilities are not subject to TRI reporting
                     because they are not considered manufacturing industries, or because they are
                     below TRI reporting thresholds.  Examples are the mining, dry cleaning,
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                     printing, and transportation equipment cleaning sectors. For these sectors,
                     release information from other sources has been included.

                     The reader should also be aware that TRI "pounds released" data presented
                     within the notebooks is not equivalent to a "risk" ranking for each industry.
                     Weighting each pound of release equally does not factor  in the relative
                     toxicity of each chemical that is released. The Agency is in the process of
                     developing an approach to assign toxicological weightings to each chemical
                     released so that one can differentiate between pollutants with significant
                     differences in toxicity. As a preliminary indicator of the environmental impact
                     of the industry's most commonly released chemicals, the notebook briefly
                     summarizes the toxicological properties of the top chemicals (by weight)
                     reported by each industry.

Definitions Associated With Section IV Data Tables

                     General Definitions

                     SIC Code — is the Standard Industrial Classification (SIC) is  a statistical
                     classification standard used for all establishment-based Federal economic
                     statistics.  The SIC codes facilitate comparisons between facility and industry
                     data.

                     TRI Facilities — are manufacturing facilities that have 10 or more full-time
                     employees  and are above  established chemical throughput  thresholds.
                     Manufacturing facilities are defined  as facilities  in  Standard Industrial
                     Classification primary codes  20-39. Facilities must submit estimates for all
                     chemicals that are on the EPA's defined list and are above  throughput
                     thresholds.

                     Data Table Column Heading Definitions

                     The following  definitions are based upon standard definitions developed by
                     EPA's Toxic Release Inventory Program. The categories below represent the
                     possible pollutant destinations that can be reported.

                     RELEASES  —  are an  on-site discharge  of  a toxic  chemical to  the
                     environment.   This  includes  emissions to the air, discharges to bodies of
                     water,  releases at the facility  to land,  as well as contained disposal into
                     underground injection wells.

                     Releases to Air (Point and Fugitive Air  Emissions) —  include all  air
                     emissions from industry activity. Point emission occur through confined air
                     streams as found in stacks, ducts, or pipes. Fugitive emissions include losses
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                     from equipment leaks, or evaporative losses from impoundments, spills, or
                     leaks.

                     Releases to Water (Surface Water Discharges) - encompass any releases
                     going directly to streams, rivers, lakes, oceans, or other bodies of water. Any
                     estimates for stormwater runoff and non-point losses must also be included.

                     Releases to Land — includes disposal of toxic chemicals in waste to on-site
                     landfills, land treated or incorporation into soil, surface impoundments, spills,
                     leaks, or waste piles.   These activities must occur within the facility's
                     boundaries for inclusion in this category.

                     Underground Injection — is a contained release of a fluid into a subsurface
                     well  for the purpose of waste disposal.

                     TRANSFERS — is a transfer of toxic chemicals in wastes to a facility that is
                     geographically or physically separate from the  facility reporting under TRI.
                     The quantities reported represent a movement of the chemical away from the
                     reporting facility.  Except for off-site transfers  for disposal, these quantities
                     do not necessarily represent entry of the chemical into the environment.

                     Transfers to POTWs — are wastewaters transferred through pipes or sewers
                     to  a publicly owned treatments works (POTW).  Treatment and chemical
                     removal depend  on the  chemical's nature  and treatment methods used.
                     Chemicals not treated or destroyed by the POTW are generally released to
                     surface waters or landfilled within the sludge.

                     Transfers to Recycling — are sent off-site for the purposes of regenerating
                     or  recovering still valuable materials.  Once these  chemicals have been
                     recycled, they may be returned to the originating facility or sold commercially.

                     Transfers to Energy Recovery — are wastes combusted off-site in industrial
                     furnaces for energy recovery.  Treatment of a chemical by incineration is not
                     considered to be energy recovery.

                     Transfers to Treatment — are wastes moved off-site for either neutralization,
                     incineration, biological destruction, or physical separation. In some cases, the
                     chemicals are not destroyed but prepared for further waste management.

                     Transfers to Disposal - are wastes taken to  another  facility for disposal
                     generally as a release to land or as an injection underground.

IV.A. EPA Toxic Release Inventory for the Inorganic Chemical Industry
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                     The 1993 TRI data presented in Exhibits 11 and 12 for inorganic chemicals
                     manufacturing covers 555 facilities. These facilities listed SIC 281 (industrial
                     inorganic chemicals) as a primary SIC code. The Bureau of Census identified
                     1,429 facilities manufacturing inorganic chemicals. More than half of these
                     facilities, however, have fewer than 20 employees, many of which are likely
                     to be below the TRI reporting thresholds of employment (TRI reporting
                     threshold is greater than 10 employees) and/or chemical use and, therefore,
                     are not required to report to TRI.

                     According to TRI  data, in 1993  the inorganic  chemical industry released
                     (discharged to the air, water,  or land without treatment) and transferred
                     (shipped off-site) a total of 250 million pounds of 112 different chemical toxic
                     chemicals. This represents about 10 percent of the TRI releases and transfers
                     of the chemical  manufacturing  industry and about three percent of the total
                     releases and transfers of all manufacturers that year.  In  comparison, the
                     organic chemical industry (SIC 286) produced 438 million pounds that year,
                     almost twice that of the inorganic chemical industry.55

                     The chemical industry's releases have been declining in recent years.  Between
                     1988 and 1993 TRI emissions from chemical companies (all those categorized
                     within SIC 28, not just inorganic chemical manufacturers) to air, land, and
                     water were reduced 44 percent, which is slightly above the average for all
                     manufacturing sectors reporting to TRI.56

                     Because the chemical industry  (SIC 28) has historically  released more TRI
                     chemicals  than  any other  industry,  the EPA has  worked to  improve
                     environmental performance within this  sector.  This has been done through a
                     combination of enforcement  actions, regulatory requirements, pollution
                     prevention projects, and voluntary programs  (e.g. 33/50).  In addition, the
                     chemical industry has focused on  reducing pollutant releases. For example,
                     the  Chemical Manufacturers   Association's  (CMA's)  Responsible Care
                     initiative is intended to reduce or eximinate chemical manufacturers' waste.
                     All 184 members of the CMA, firms  that account for the majority of U.S.
                     chemical  industry sales and earnings,  are required to participate  in the
                     program.    Participation involves  demonstrating a  commitment  to the
                     program's mandate of continuous improvement  in environment, health, and
                     safety.  In June of  1994, the CMA approved the  use  of a third-party
                     verification of management plans  to meet these objectives.

                     Exhibits 11 and 12 present the number and volumes of chemicals released and
                     transferred by inorganic chemical facilities, respectively. The frequency with
                     which chemicals  are reported by facilities within  a sector is one indication of
                     the diversity of operations and processes. Many of the  TRI chemicals are
                     released or transferred by only a small number of facilities which indicates a
                     wide diversity of production processes, particularly for specialty inorganics -


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                     over 70 percent of the 110 chemicals reported are released or transferred by
                     fewer than 10 facilities.

                     The inorganic chemical industry releases 69 percent of its total TRI poundage
                     to the water (including 67 percent to underground injection and two percent
                     to surface waters), 14 percent to the air, and  17 percent to  the land.  This
                     release profile differs from other TRI industries which average approximately
                     30 percent to the water, 59 percent to air, and 10 percent to land. Examining
                     the inorganic  chemical industry's TRI reported toxic chemical releases
                     highlights the likely origins of the large water releases for the industry (Exhibit
                     11).

                     As presented in Exhibit 11, on-site underground injection of essentially one
                     chemical, hydrochloric acid, accounts for the largest portion, 55 percent, of
                     the inorganic chemical industry's total  releases and transfers as reported in
                     TRI.   Only five facilities of the 555 identified facilities reported releasing
                     hydrochloric  acid through underground injection.   Two of these facilities
                     accounted for over 85 percent of the total hydrochloric acid injected to the
                     subsurface, or 42 percent of the inorganic chemical industry's total releases
                     and transfers.   Land disposal accounted  for the next largest amount, 17
                     percent, of the industry's total releases. The largest single chemical  released
                     to the air  by the inorganic chemical industry, carbonyl sulfide, is only emitted
                     by eleven facilities manufacturing certain inorganic pigments.

                     Discharges to POTWs  accounted for 43  percent  of the industry's total
                     transfers of TRI chemicals. Ammonia, hydrochloric acid, and sulfuric acid
                     account  for over 66 percent of the 70 million pounds transferred off-site.
                     Finally, approximately 22 million pounds, accounting for 31 percent of the
                     total, are transferred  off-site for treatment (Exhibit 12).
September 1995                             35                                     SIC 281

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Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting

                                         (Releases reported in pounds/year)
# REPORTING
CHEMICAL NAME CHEMICAL
SULFURIC ACID
HYDROCHLORIC ACID
AMMONIA
CHLORINE
PHOSPHORIC ACID
NITRIC ACID
ACETONE
ZINC COMPOUNDS
CHROMIUM COMPOUNDS
COPPER COMPOUNDS
NICKEL COMPOUNDS
METHANOL
BARIUM COMPOUNDS
DICHLORODIFLUOROMETHANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
HYDROGEN FLUORIDE
COBALT COMPOUNDS
ETHYLENE GLYCOL
TOLUENE
ANTIMONY COMPOUNDS
XYLENE (MIXED ISOMERS)
PHOSPHORUS (YELLOW OR
PROPYLENE
AMMONIUM NITRATE
AMMONIUM SULFATE
CARBONYL SULFIDE
GLYCOL ETHERS
TITANIUM TETRACHLORIDE
ETHYLENE OXIDE
COPPER
MOLYBDENUM TRIOXIDE
FORMALDEHYDE
ZINC (FUME OR DUST)
ARSENIC COMPOUNDS
MERCURY
1,1,1 -TRICHLOROETHANE
ASBESTOS (FRIABLE)
CARBON TETRACHLORIDE
CHROMIUM
DICHLOROTETRAFLUOROETHANE
ETHYLENE
METHYL ETHYL KETONE
NAPHTHALENE
CADMIUM COMPOUNDS
DICHLOROMETHANE
DIETHANOLAMINE
ACETONITRILE
311
167
152
121
72
71
54
53
41
33
29
28
27
26
26
26
24
21
20
20
16
16
14
14
13
11
11
11
11
10
9
9
8
8
7
7
7
6
6
6
6
6
6
6
5
5
5
4
FUGITIVE
AIR
47,743
29,428
1,984,440
52,954
4,673
13,211
40,304
39,171
4,294
2,317
1,253
105,224
2,279
741,761
1,370
124,003
93,040
1,001
543
84,679
2,010
9,608
1,200
14,451
697
1,613
380
4,028
7,900
428
523
1,155
493
255
260
5,903
1,200
0
25,632
260
709,950
527
10,205
819
431
53,174
3,325
2,085
POINT WATER UNDERGROUND
AIR DISCHARGES INJECTION
538,584
1,420,262
2,726,774
3,017,393
417,181
56,538
19,261
72,705
13,008
15,238
20,000
878,239
8,176
54,302
12,730
146,393
84,932
2,018
765
11,313
11,439
7,998
4,137
2,215
8,858
4,935
9,676,486
40,640
4,492
19,890
1,250
12,291
11,703
6,476
264
1,597
505
1
259,791
520
5
5,287
2,601
33,652
4,237
9,322
750
1,696
7,482
3,748
1,885,475
6,105
500
250
0
104,180
33,935
1,827
8,872
77,887
5,629
0
287
87,548
5
996
505
0
273
0
5
0
496,400
0
0
0
0
0
83
3,749
0
0
391
215
0
0
0
86
0
0
0
741
21
0
0
0
5
120,745,708
0
0
5
5
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
LAND
DISPOSAL
29,520
213,351
1,162,987
0
0
0
0
86,384
19,036,934
428
34,289
0
353,000
0
58,053
7,672,768
10
33,460
702
4
1
52
323,749
0
599,028
0
0
0
0
0
0
500
0
0
504
1,519
0
0
2
267,786
0
0
41
5
124
0
0
0
TOTAL AVG. RELEASES
RELEASES PER FACILITY
623,334
122,677,352
7,759,676
3,076,452
422,359
70,004
59,565
302,440
19,088,171
19,810
64,419
1,061,350
369,084
796,063
72,440
8,030,712
177,987
37,475
2,515
95,996
13,723
17,658
329,091
16,666
1,104,983
6,548
9,676,866
44,668
12,392
20,318
1,856
17,700
12,196
6,731
1,419
9,234
1,705
1
285,425
268,652
709,955
5,814
12,847
35,217
4,813
62,496
4,075
3,781
2,004
734,595
51,051
25,425
5,866
986
1,103
5,706
465,565
600
2,221
37,905
13,670
30,618
2,786
308,874
7,416
1,785
126
4,800
858
1,104
23,507
1,190
84,999
595
879,715
4,061
1,127
2,032
206
1,967
1,525
841
203
1,319
244
0
47,571
44,775
118,326
969
2,141
5,870
963
12,499
815
945
C/5
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                                                                                                                       3T

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Exhibit 11 (cont.): 1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting

                                        (Releases reported in pounds/year)
# REPORTING FUGITIVE
CHEMICAL NAME CHEMICAL AIR
CARBON BISULFIDE
CHLOROFORM
CYANIDE COMPOUNDS
NICKEL
PHTHALIC ANHYDRIDE
SELENIUM COMPOUNDS
TRICHLOROFLUOROMETHANE
1 ,2,4-TRIMETHYLBENZENE
ALUMINUM (FUME OR DUST)
BENZENE
ETHYLBENZENE
FREON113
HYDRAZINE
MANGANESE
MONOCHLOROPENTAFLUOROEHTANE
TRICHLOROETHYLENE
ACETALDEHYDE
ACRYLONITRILE
CHLORINE DIOXIDE
COBALT
CRESOL (MIXED ISOMERS)
CYCLOHEXANE
HYDROQUINONE
LEAD
METHYL ISOBUTYL KETONE
METHYL TERT-BUTYL ETHER
PHENOL
SILVER COMPOUNDS
TETRACHLOROETHYLENE
ACRYLIC ACID
ARSENIC
BARIUM
BROMOTRIFLUOROMETHANE
CAPTAN
CHLOROBENZENE
CHLOROETHANE
CHLOROMETHANE
CREOSOTE
CUMENE
DI(2-ETHYLHEXYL) PHTHALATE
DIBUTYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFATE
ETHYL ACRYLATE
HYDROGEN CYANIDE
ISOPROPYL ALCOHOL
MALEIC ANHYDRIDE
MERCURY COMPOUNDS
4
4
4
4
4
4
4
4
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2



















70,006
13,282
5
38
250
10
307,250
1,110
42
505
505
30,954
330
250
402,000
255
6
255
86
13
276
255
0
76
250
790
264
0
400
250
5
0
34,000
5
250
522
501
250
750
250
250
10
0
250
0
250
250
250
POINT WATER UNDERGROUND
AIR DISCHARGES INJECTION
4,334
27,017
5
880
250
270
1,205
1,290
660
5
250
67
0
316
7,721
35,305
3,100
5
176
251
510
5
0
0
303
5
145
5
305
5
0
0
0
0
5
0
0
5
750
5
5
0
0
5
30
250
5
250
250
360
0
5
0
87
0
250
0
0
0
0
33
34
0
5
0
0
0
0
0
0
0
9
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
LAND
DISPOSAL
0
0
0
250
0
0
0
5
0
0
0
0
0
1,180,335
0
0
0
0
0
5
0
0
0
8,500
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
TOTAL AVG. RELEASES
RELEASES PER FACILITY
74,590
40,659
10
1,173
500
367
308,455
2,655
702
510
755
31,021
363
1,180,935
409,721
35,565
3,106
260
262
269
786
260
0
8,585
553
795
409
5
705
255
5
0
34,000
5
255
522
501
255
1,500
255
255
10
0
255
30
500
255
500
18,648
10,165
3
293
125
92
77,114
664
234
170
252
10,340
121
393,645
136,574
11,855
1,553
130
131
135
393
130
0
4,293
277
398
205
3
353
255
5
0
34,000
5
255
522
501
255
1,500
255
255
10
0
255
30
500
255
500
C/5
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Exhibit 11 (cont.): 1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting

                                        (Releases reported in pounds/year)
# REPORTING FUGITIVE
CHEMICAL NAME CHEMICAL AIR
METHYL METHACRYLATE
N-BUTYL ALCOHOL
0-XYLENE
P-XYLENE
PERACETIC ACID
POLYCHLORINATED BIPHENYLS
SELENIUM
SILVER
STYRENE
THIOUREA
VINYL ACETATE
VINYL CHLORIDE
1 , 1 ,2-TRICHLOROETHANE
1 ,2-DICHLOROETHANE
1 ,2,4-TRICHLOROBENZENE
1,4-DIOXANE
TOTAL
250
250
5
5
10
0
5
750
250
0
5
0
250
5
5
1 5
555 5,366,356
POINT WATER UNDERGROUND
AIR DISCHARGES INJECTION
5
250
0
0
2,100
0
250
250
250
0
0
0
5
0
0
0
19,737,660
0
0
0
0
42
0
0
0
0
0
0
0
0
0
0
0
2,728,270
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
120,745,733
LAND
DISPOSAL
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
31,064,296
TOTAL AVG. RELEASES
RELEASES PER FACILITY
255
500
5
5
2,152
0
255
1,000
500
0
5
0
255
5
5
5
179,642,315
255
500
5
5
2,152
0
255
1,000
500
0
5
0
255
5
5
5
323,680
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                                                                                                                         3T

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Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting


                                           (Transfers reported in pounds/year)
# REPORTING POTW
CHEMICAL NAME CHEMICAL DISCHARGES
SULFURIC ACID
HYDROCHLORIC ACID
AMMONIA
CHLORINE
PHOSPHORIC ACID
NITRIC ACID
ACETONE
ZINC COMPOUNDS
CHROMIUM COMPOUNDS
COPPER COMPOUNDS
NICKEL COMPOUNDS
METHANOL
BARIUM COMPOUNDS
DICHLORODIFLUOROMETHANE
LEAD COMPOUNDS
MANGANESE COMPOUNDS
HYDROGEN FLUORIDE
COBALT COMPOUNDS
ETHYLENE GLYCOL
TOLUENE
ANTIMONY COMPOUNDS
XYLENE (MIXED ISOMERS)
PHOSPHORUS (YELLOW OR
PROPYLENE
AMMONIUM NITRATE
AMMONIUM SULFATE
CARBONYL SULFIDE
GLYCOL ETHERS
TITANIUM TETRACHLORIDE
ETHYLENE OXIDE
COPPER
MOLYBDENUM TRIOXIDE
FORMALDEHYDE
ZINC (FUME OR DUST)
ARSENIC COMPOUNDS
MERCURY
1,1,1 -TRICHLOROETHANE
ASBESTOS (FRIABLE)
CARBON TETRACHLORIDE
CHROMIUM
DICHLOROTETRAFLUOROETHA
ETHYLENE
METHYL ETHYL KETONE
NAPHTHALENE
CADMIUM COMPOUNDS
DICHLOROMETHANE
DIETHANOLAMINE
ACETONITRILE
311
167
152
121
72
71
54
53
41
33
29
28
27
26
26
26
24
21
20
20
16
16
14
14
13
11
11
11
11
10
9
9
8
8
7
7
7
6
6
6
6
6
6
6
5
5
5
4
11,146
528
22,101,429
5
3,913
10
1,655
7,382
4,078
4,228
9,840
16,209
5,080
0
1,301
1,446
185
3,996
3,951
1,375
3,735
0
0
0
1,923,495
6,506,733
0
628
0
0
46
7,652
255
250
5
0
0
0
0
0
0
0
0
0
35
0
450
0
ENERGY
DISPOSAL RECYCLING TREATMENT RECOVERY
250,434
4,598,609
371,669
610
2,130
250
23
509,395
121,569
321,517
86,370
4,000
370,288
0
89,660
1,694,840
230,250
13,580
0
203
52,815
73
1
0
160
8,247
0
506
16
0
938,477
52,424
250
1,710
59,900
3,486
0
33,070
1,400
48,930
0
0
92
48
585
0
0
0
1,025,242
0
528,230
0
23,218
0
15,726
159,713
47,843
576,642
278,630
291,354
0
20,600
1,153,211
7,300
77,587
8,050
30,912
25,347
16,000
250
0
0
603,440
0
0
0
0
0
0
61,220
0
250
250
5,222
250
0
0
2,763
0
0
0
0
5
5,147
0
0
6,820,665
10,423,062
65,300
270
132,065
438,614
11,249
30,265
51,452
7,733
106,692
175
123,560
16
1,087,669
2,206,411
38,700
10,598
2,248
32,384
7,171
5,127
26,000
0
0
6,092
0
37,387
489
0
55,261
0
362
0
904
1,010
5
0
34,107
37,765
0
0
443
880
4,061
5
0
5
0
0
0
0
0
0
84,368
0
0
0
0
1,802,765
0
0
0
0
0
0
13,852
217,979
0
188,093
0
0
0
0
0
13,405
86
0
0
0
0
0
0
0
0
0
0
0
0
0
33,567
250
0
0
0
22,239
TOTAL AVG. TRANSFERS
TRANSFERS PER FACILITY
8,107,487
15,022,199
23,066,628
885
161,326
438,874
113,021
706,755
224,942
910,120
481,532
2,114,503
498,928
20,616
2,331,841
3,909,997
346,722
36,224
50,963
277,288
79,721
193,543
26,001
0
2,527,095
6,521,072
0
51,926
591
0
993,784
121,296
867
2,210
61,059
9,718
255
33,070
35,507
89,458
0
0
34,102
1,178
4,686
5,152
450
22,244
26,069
89,953
151,754
7
2,241
6,181
2,093
13,335
5,486
27,579
16,605
75,518
18,479
793
89,686
150,385
14,447
1,725
2,548
13,864
4,983
12,096
1,857
0
194,392
592,825
0
4,721
54
0
110,420
13,477
108
276
8,723
1,388
36
5,512
5,918
14,910
0
0
5,684
196
937
1,030
90
5,561
C/5
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                                                                                                                          3.


                                                                                                                          a:
                                                                                                                          3T

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Exhibit 12 (cont.): 1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting

                                         (Transfers reported in pounds/year)
# REPORTING POTW ENERGY TOTAL AVG. TRANSFERS
CHEMICAL NAME CHEMICAL DISCHARGES DISPOSAL RECYCLING TREATMENT RECOVERY TRANSFERS PER FACILITY
CARBON BISULFIDE
CHLOROFORM
CYANIDE COMPOUNDS
NICKEL
PHTHALIC ANHYDRIDE
SELENIUM COMPOUNDS
TRICHLOROFLUOROMETHANE
1 ,2,4-TRIMETHYLBENZENE
ALUMINUM (FUME OR DUST)
BENZENE
ETHYLBENZENE
FREON 113
HYDRAZINE
MANGANESE
MONOCHLOROPENTAFLUOROE
TRICHLOROETHYLENE
ACETALDEHYDE
ACRYLONITRILE
CHLORINE DIOXIDE
COBALT
CRESOL (MIXED ISOMERS)
CYCLOHEXANE
HYDROQUINONE
LEAD
METHYL ISOBUTYL KETONE
METHYL TERT-BUTYL ETHER
PHENOL
SILVER COMPOUNDS
TETRACHLOROETHYLENE
ACRYLIC ACID
ARSENIC
BARIUM
BROMOTRIFLUOROMETHANE
CAPTAN
CHLOROBENZENE
CHLOROETHANE
CHLOROMETHANE
CREOSOTE
CUMENE
DI(2-ETHYLHEXYL)
DIBUTYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFATE
ETHYL ACRYLATE
HYDROGEN CYANIDE
ISOPROPYL ALCOHOL
MALEIC ANHYDRIDE
MERCURY COMPOUNDS
4
4
4
4
4
4
4
4
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
250
0
1
97
5
2
0
0
0
0
0
0
0
0
0
0
0
0
130
4
0
0
500
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
10
7,700
0
505
0
27
0
0
0
0
0
0
0
183,412
0
0
0
0
0
5
0
0
0
750
0
0
0
5
0
0
0
26,217
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,525
0
0
0
23,670
0
0
3,100
0
0
0
0
0
0
0
0
0
0
0
0
2,300
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
72,311
4
0
5
295
1,705
1,854
0
5
5
1,500
0
0
0
1,305
0
5
0
0
5
5
0
66
5
5
5
0
5
5
70,761
0
0
0
5
0
0
5
1,000
5
5
0
0
5
0
5
5
5
500
0
0
0
2,412
0
0
3,188
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
820
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
760
80,011
5
24,272
2,422
324
4,805
5,042
0
5
5
1,500
0
183,412
0
1,305
0
5
130
2,309
5
5
500
816
825
5
5
10
5
5
70,761
26,217
0
0
5
0
0
5
1,000
5
5
0
0
5
0
5
5
1,535
190
20,003
1
6,068
606
81
1,201
1,261
0
2
2
500
0
61,137
0
435
0
3
65
1,155
3
3
250
408
413
3
3
5
3
5
70,761
26,217
0
0
5
0
0
5
1,000
5
5
0
0
5
0
5
5
1,535
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Exhibit 12 (cont.): 1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting
                                         (Transfers reported in pounds/year)
*
CHEMICAL NAME
METHYL METHACRYLATE
N-BUTYL ALCOHOL
0-XYLENE
P-XYLENE
PERACETIC ACID
POLYCHLORINATED
SELENIUM
SILVER
STYRENE
THIOUREA
VINYL ACETATE
VINYL CHLORIDE
1 , 1 ,2-TRICHLOROETHANE
1 ,2-DICHLOROETHANE
1 ,2,4-TRICHLOROBENZENE
1,4-DIOXANE
TOTAL
REPORTING POTW
CHEMICAL DISCHARGES
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
555 30,622,040
DISPOSAL I
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
10,087,743
RECYCLING r
0
0
0
0
0
0
0
1,011
0
0
0
0
0
0
0
0
4,994,483
rREATMENT
5
5
0
0
110
0
1,450
0
5
0
0
0
5
0
0
0
21,958,678
ENERGY
RECOVERY
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,383,524
TOTAL AV(
TRANSFERS I
5
5
0
0
110
0
1,450
1,011
5
0
0
0
5
0
0
0
70,046,468
3. TRANSFERS
>ER FACILITY
5
5
0
0
110
0
1,450
1,011
5
0
0
0
5
0
0
0
126,210
                                                                                                                             o
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Sector Notebook Project
                           Inorganic Chemicals
                     The TRI database contains a detailed compilation of self-reported, facility-
                     specific chemical releases. The top reporting facilities for this sector are listed
                     below. Facilities that have reported only the SIC codes covered under this
                     notebook appear on the first list. The second list contains additional facilities
                     that have reported the SIC code covered within this report, and one or more
                     SIC codes that are not within the scope of this notebook.  Therefore, the
                     second list includes facilities that conduct multiple operations — some that are
                     under the scope of this notebook, and some that are not.  Currently, the
                     facility-level data do not  allow  pollutant releases to be broken apart by
                     industrial process.
Exhibit 13: Top 10 TRI Releasing
Inorganic Chemicals Facilitiesb
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Du Pont Delisle Plant - Pass Christian, MS
Du Pont Johnsonville Plant - New Johnsonville, TN
Cabot Corp. Cab-O-Sil Div. - Tuscola, IL
American Chrome & Chemicals Inc. - Corpus Christi, TX
Occidental Chemical Corp. - Castle Hayne, NC
Chemetals Inc. - New Johnsonville, TN
Kaiser Aluminum & Chemical Corp. - Mulberry, FL
Kerr-McGee Chemical Corp. - Henderson, NV
SCM Chemicals Americas Plant II - Ashtabula, OH
Louisiana Pigment Co. L.P. - Westlake, LA
Total TRI
Releases
in Pounds
58,875,734
51,215,700
13,926,440
12,113,360
6,705,795
5,684,893
4,876,348
2,333,175
2,238,400
1,465,753
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
 Being included on this list does not mean that the release is associated with non-compliance with environmental laws.
September 1995
42
SIC 281

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Sector Notebook Project
                          Inorganic Chemicals
Exhibit 14: Top 10 TRI Releasing Facilities Reporting
Inorganic Chemical SIC Codes to TRP
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported in TRI
2819,2873,2874
2819,2869
2819,2874
2816
2816
2819,2823
2819,2869,2841,
2879
2819,2869,2865
2819,2873,2874
2812,2813,2869
Facility
IMC-Agrico Co., Faustina Plant - Saint James, LA
Cytec Industries, Inc., Fortier Plant - Westwego, LA
IMC-Agrico Co., Uncle Sam Plant - Uncle Sam, LA
Du Pont Delisle Plant - Pass Christian, MS
Du Pont Johnsonville Plant - New Johnsonville, TN
Courtaulds Fibers, Inc. - Axis, AL
Monsanto Co. - Alvin, TX
Sterling Chemicals, Inc. - Texas City, TX
Arcadian Fertilizer L.P. - Geismar, LA
Vulcan Chemicals - Wichita, KS
Total TRI
Releases in
Pounds
127,912,967
120,149,724
61,807,180
58,875,734
51,215,700
42,658,865
40,517,095
24,709,135
22,672,961
17,406,218
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
IV.B. Summary of Selected Chemicals Released
                     The brief descriptions provided below were taken from the 1993 Toxics
                     Release Inventory Public Data Release (EPA, 1994), and the Hazardous
                     Substances  Data Bank (HSDB), accessed via TOXNET.  TOXNET is a
                     computer system run by the National Library of Medicine.  It includes a
                     number of toxicological databases managed by EPA, the National Cancer
                     Institute, and the National  Institute for Occupational Safety and Health.d
                     HSDB  contains chemical-specific information on  manufacturing and use,
                     chemical and physical properties, safety and handling, toxicity and biomedical
                     effects, pharmacology, environmental fate and exposure potential, exposure
                     standards and regulations, monitoring and analysis methods, and additional
c Being included on this list does not mean that the release is associated with non-compliance with environmental laws.

d Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EMICBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB
(Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of
Chemical Substances), and TRI (Toxic Chemical Release Inventory).
September 1995
43
SIC 281

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Sector Notebook Project	Inorganic Chemicals

                    references.   The information contained below  is  based upon  exposure
                    assumptions that have been conducted using standard scientific procedures.
                    The effects  listed  below must be taken  in  context of these  exposure
                    assumptions that are more fully explained within the full chemical profiles in
                    HSDB. For more information on TOXNET, contact the TOXNET help line
                    at 800-231-3766.

                    Hydrochloric Acid  (CAS: 7647-01-1)

                    Sources. Hydrochloric acid is one of the highest volume chemicals produced
                    by the  inorganic chemical industry. Some of its more common uses are as a
                    pickling liquor and metal cleaner in the iron and steel industry, as an activator
                    of petroleum wells, as a boiler scale remover, and as  a neutralizer of caustic
                    waste  streams. The largest release of hydrochloric acid by the inorganic
                    chemical  industry  is  in  the form  of underground injection  of  spent
                    hydrochloric acid  used  to  manufacture  chlorosulfonic acid and  other
                    products.57

                    Toxicity. Hydrochloric acid is primarily a concern in its aerosol form. Acid
                    aerosols have been implicated in causing and exacerbating a variety of
                    respiratory ailments. Dermal exposure and ingestion of highly concentrated
                    hydrochloric  acid can result in corrosivity.

                    Ecologically, accidental releases of solution forms of hydrochloric  acid may
                    adversely affect aquatic life by including a transient lowering of the pH (i.e.,
                    increasing the acidity) of surface waters.

                    Carcinogenicity. There is currently no evidence to suggest that this  chemical
                    is carcinogenic.

                    Environmental Fate.  Releases of hydrochloric acid to surface waters and
                    soils will be neutralized to an extent due to the buffering capacities of both
                    systems. The extent of these reactions will depend on the characteristics of
                    the specific environment.

                    Physical Properties. Concentrated hydrochloric acid is highly corrosive.

                    Chromium and Chromium Compounds (CAS: 7440-47-3; 20-06-4)

                    Sources.  Chrome pigments, chromates, chromic acid, chromium salts, and
                    other inorganic chromium compounds are some of the larger volume products
                    of the inorganic chemicals industry. Chrome is used as a plating element for
                    metal and plastics to prevent corrosion, and as a constituent of certain steels
                    and inorganic pigments. Most chromium wastes released to the environment
September 1995                             44                                    SIC 281

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Sector Notebook Project	Inorganic Chemicals

                    by the inorganic chemicals industry are land disposed in the form of chromium
                    containing sludges.

                    Toxicity. Although the naturally-occurring form of chromium metal has very
                    low toxicity, chromium from industrial emissions is highly toxic due to strong
                    oxidation characteristics and cell membrane permeability.  The majority of the
                    effects  detailed below are based on Chromium VI (an  isomer that is more
                    toxic than Cr III). Exposure to chromium metal and insoluble chromium salts
                    affects  the respiratory system.  Inhalation  exposure to chromium  and
                    chromium salts may cause severe irritation of the upper respiratory tract and
                    scarring of lung tissue.  Dermal exposure to chromium  and chromium salts
                    can also cause sensitive dermatitis and skin ulcers.

                    Ecologically, although chromium is present in small quantities in all  soils and
                    plants, it is toxic to plants at higher soil concentrations (i.e., 0.2 to 0.4 percent
                    in soil).

                    Carcinogenicity.  Different sources disagree on  the carcinogenicity of
                    chromium.  Although an increased incidence in lung cancer among workers
                    in the chromate-producing industry has been  reported, data are inadequate to
                    confirm that  chromium is a human carcinogen.   Other sources  consider
                    chromium VI to be a known human carcinogen based on inhalation exposure.

                    Environmental Fate.  Chromium is a non-volatile metal with very  low
                    solubility in water.  If applied to land, most chromium remains in the upper
                    five centimeters of soil.  Most chromium  in surface waters is present in
                    particulate form as  sediment. Airborne chromium  particles are  relatively
                    unreactive and are removed from the air through wet and dry deposition.  The
                    precipitated chromium from the air enters surface water or soil. Chromium
                    bioaccumulates  in plants  and animals, with an observed  bioaccumulation
                    factor of 1,000,000 in snails.

                    Carbonyl Sulfide (CAS: 463-58-1)

                    Sources. Carbonyl sulfide is the largest volume chemical released to the air
                    by the inorganic chemicals industry.  Carbonyl sulfide is primarily generated
                    by a relatively  small number of facilities hydrolyzing ammonium or potassium
                    thiocyanate during the manufacturing of inorganic pigments and dyes.58

                    Toxicity.  Exposure to  low to moderate concentrations of carbonyl sulfide
                    causes eye and skin irritation and adverse central nervous system effects such
                    as giddiness, headache, vertigo, amnesia, confusion, and unconsciousness. If
                    ingested, gastrointestinal effects include profuse salivation, nausea, vomiting
                    and diarrhea. Moderate carbonyl sulfide poisoning also causes rapid breathing
                    and heartbeat, sweating, weakness, and muscle cramps. Exposure to very


September 1995                            45                                    SIC 281

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Sector Notebook Project	Inorganic Chemicals

                    high  concentrations  of  carbonyl  sulfide   causes   sudden  collapse,
                    unconsciousness, and death from sudden respiratory paralysis.  Recovery from
                    sublethal exposure is slow, but generally complete. Degradation products of
                    carbonyl sulfide (especially hydrogen sulfide) can result in toxic symptoms and
                    death.

                    Carcinogenicity. There is currently no evidence to suggest that this chemical
                    is carcinogenic.

                    Environmental Fate.  If released to soil or surface waters, carbonyl sulfide
                    will rapidly volatilize. It is not expected to adsorb to soil sediments or organic
                    matter nor is it expected to bioconcentrate in fish and aquatic organisms.
                    Carbonyl sulfide is hydrolyzed in water to carbon dioxide and hydrogen
                    sulfide.  Carbonyl sulfide is expected to have a long residence time in the
                    atmosphere.  Atmospheric removal of carbonyl sulfide may occur by slow
                    reactions with other gases, and may also occur through adsorption by plants
                    and soil microbes.

                    Manganese and Manganese Compounds (CAS: 7439-96-5;  20-12-2)

                    Sources. Manganese  is both a product and chemical  intermediate  of the
                    inorganic chemical industry.  Manganese is used as a purifying  and scavenging
                    agent in metal production, as an intermediate in aluminum production and as
                    a constituent of non-ferrous  alloys to improve  corrosion resistance and
                    hardness.59

                    Toxicity. There is currently no evidence that human exposure to manganese
                    at levels commonly observed in ambient atmosphere results in adverse health
                    effects.   However,  recent  EPA  review  of  the  fuel  additive  MMT
                    (methylcyclopentadienyl manganese tricarbonyl) concluded that use of MMT
                    in gasoline could lead to ambient exposures to manganese at a level sufficient
                    to cause adverse neurological effects in humans.

                    Chronic manganese poisoning bears some similarity to chronic  lead poisoning.
                    Occurring via inhalation of manganese dust or fumes, it primarily involves the
                    central  nervous system.   Early symptoms   include  languor,  speech
                    disturbances, sleepiness, and cramping  and weakness in legs.  A stolid mask-
                    like appearance of face, emotional disturbances such as absolute detachment
                    broken by  uncontrollable  laughter,  euphoria, and a spastic gait with a
                    tendency to fall while walking are seen in more advanced cases.  Chronic
                    manganese  poisoning  is reversible if treated early and exposure stopped.
                    Populations at greatest risk of manganese toxicity are the very young and
                    those with iron deficiencies.
September 1995                            46                                    SIC 281

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Sector Notebook Project	Inorganic Chemicals

                     Ecologically, although manganese is an essential nutrient for both plants and
                     animals, in excessive concentrations manganese inhibits plant growth.

                     Carcinogenicity. There is currently no evidence to suggest that this chemical
                     is carcinogenic.

                     Environmental Fate.  Manganese is an essential nutrient for plants and
                     animals. As such, manganese accumulates in the top layers of soil or surface
                     water sediments and cycles between the soil and living organisms. It occurs
                     mainly as a solid  under environmental conditions,  though may also be
                     transported in the atmosphere as a vapor or dust

                     Ammonia (CAS: 7664-41-7)

                     Sources. Ammonia is used in many chemical manufacturing processes and is
                     the building block for all synthetic nitrogen products.  Its prevalence and its
                     volatile and water soluble characteristics allow it to be readily released to the
                     air and water. In the inorganic chemical manufacturing industry, ammonia can
                     be either a feedstock or a by-product. Some of the more common inorganic
                     chemical industry  processes using or  producing ammonia include the
                     manufacturing of: ammonium chloride,  ammonium hydroxide, ammonium
                     thiosulfate, ammonium nitrate, hydrazine, and hydrogen cyanide.

                     Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and
                     upper respiratory system. Ecologically, ammonia is a source of nitrogen (an
                     essential element for aquatic plant growth), and may therefore contribute to
                     eutrophication of standing or slow-moving surface water, particularly in
                     nitrogen-limited waters such  as the Chesapeake Bay. In addition,  aqueous
                     ammonia is moderately toxic  to aquatic organisms.

                     Carcinogenicity. There is currently no evidence to suggest that this chemical
                     is carcinogenic.

                     Environmental  Fate.    Ammonia combines with  sulfate ions in the
                     atmosphere and is washed out by rainfall, resulting in rapid return of ammonia
                     to the  soil and surface waters.  Ammonia is  a central compound in the
                     environmental cycling of nitrogen. Ammonia in lakes, rivers, and streams is
                     converted to nitrate.

                     Physical Properties. Ammonia is  a corrosive and severely irritating  gas with
                     a pungent odor.

IV.C. Other Data Sources
September 1995                            47                                    SIC 281

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Sector Notebook Project	Inorganic Chemicals

                    In addition to chemicals covered under TPJ,  many other chemicals are
                    released.  For example, the EPA Office of Air Quality Planning and Standards
                    has compiled air pollutant emission  factors for determining the  total air
                    emissions of priority pollutants (e.g., VOCs, SOX, NOX, CO, particulates) from
                    many chemical industry sources.

                    The EPA Office of Air's Aerometric Information Retrieval System (AIRS)
                    contains a  wide range of information related to stationary sources of air
                    pollution, including the emissions of a number of air pollutants which may be
                    of concern within a particular industry. With the exception of volatile organic
                    compounds (VOCs), there is little overlap with  the TRI chemicals  reported
                    above.  Exhibit 15 summarizes  annual releases  of carbon monoxide (CO),
                    nitrogen dioxide (NO2), particulate matter of 10 microns or less (PM10), total
                    particulate  (PT),  sulfur dioxide (SO2) and volatile organic compounds
                    (VOCs).
September 1995                             48                                   SIC 281

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Sector Notebook Project
                       Inorganic Chemicals
Exhibit 15: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood
Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc.
Plastics
Stone, Clay and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office
Equipment
Electronics and Other
Electrical Equipment and
Components
Motor Vehicles, Bodies,
Parts and Accessories
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO 2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
SO 2
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
49
SIC 281

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Sector Notebook Project	Inorganic Chemicals

IV.D. Comparison of Toxic Release Inventory Between Selected Industries

                     The following information is presented as a comparison of pollutant release
                     and transfer data across industrial categories. It is provided to give a general
                     sense as to  the relative scale of releases and transfers within each sector
                     profiled under this project. Please note that the following figure and table do
                     not contain releases and transfers for industrial categories that  are  not
                     included in this  project, and thus cannot be  used to  draw conclusions
                     regarding the total release  and transfer amounts that are reported to TRI.
                     Similar information is available within the annual TRI Public Data Release
                     Book.

                     Exhibit 16 is a graphical representation of a summary of the 1993 TRI data for
                     the inorganic chemicals industry and the other  sectors profiled in separate
                     notebooks. The bar graph presents the total TRI releases and total transfers
                     on the left axis and the triangle points show the average releases per facility
                     on the right axis. Industry sectors are presented in the order of increasing
                     total TRI releases. The graph is based on the data shown in Exhibit 17 and
                     is meant to facilitate comparisons between the relative amounts of releases,
                     transfers, and releases per facility both within and between these sectors. The
                     reader should note, however, that differences in the proportion of facilities
                     captured by TRI exist between industry sectors.  This can be a factor of poor
                     SIC matching and relative differences in the number of facilities reporting to
                     TRI from the various sectors. In the case of the inorganic chemicals, the 1993
                     TRI data presented here covers 555 facilities. These facilities listed SIC 2812-
                     2819 (inorganic chemicals) as a primary SIC code.
September 1995                             50                                     SIC 281

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Sector Notebook Project
                     Inorganic Chemicals
               Exhibit  16: Summary of  1993 TRI  Data:
                     Releases and Transfers by Industry
Total Pounds (millions)
"•fin
600 -
500 -
400 -
300 -
200 -
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Total Releases | | Total



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-800,000 £
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-600,000 fe
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00
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00
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331 286 281
30 26 333,334
Transfers V Avg. Releases/Facility

SIC
Range
36
24
32
27
25
Industry Sector
Electronic Equipment and
Components
Lumber and Wood Products
Stone, Clay, and Concrete
Printing
Wood Furniture and Fixtures
SIC
Range
2911
34
371
331
30
Industry Sector
Petroleum Refining
Fabricated Metals
Motor Vehicles, Bodies,
Parts, and Accessories
Iron and Steel
Rubber and Misc. Plastics
SIC
Range
286
26
281
333,334

Industry Sector
Organic Chemical Mfg.
Pulp and Paper
Inorganic Chemical Mfg.
Nonferrous Metals

September 1995
51
SIC 281

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Exhibit 17: Toxics Release Inventory Data for Selected Industries
Industry Sector
Stone, Clay, and Concrete
Lumber and Wood Products
Furniture and Fixtures
Printing
Electronic Equip, and
Components
Rubber and Misc. Plastics
Motor Vehicles, Bodies,
Parts, and Accessories
Pulp and Paper
Inorganic Chem. Mfg.
Petroleum Refining
Fabricated Metals
Iron and Steel
Nonferrous Metals
Organic Chemical Mfg.
Metal Mining
Nonmetal Mining
Dry Cleaning
SIC
Range
32
24
25
2711-2789
36
30
371
2611-2631
2812-2819
2911
34
331
333,334
2861-2869
10
14
7216
#TR1
Facilities
634
491
313
318
406
1,579
609
309
555
156
2,363
381
208
417
1993 TR1 Releases
Total
Releases
(million Ibs.)
26.6
8.4
42.2
36.5
6.7
118.4
79.3
169.7
179.6
64.3
72
85.8
182.5
151.6
Average
Releases
per Facility
(pounds)
42,000
17,000
135,000
115,000
17,000
75,000
130,000
549,000
324,000
412,000
30,000
225,000
877,000
364,000
1993 TR1 Transfers
Total
Transfers
(million Ibs.)
2.2
3.5
4.2
10.2
47.1
45
145.5
48.4
70
417.5
195.7
609.5
98.2
286.7
Average
Transfers
per Facility
(pounds)
4,000
7,000
13,000
32,000
116,000
29,000
239,000
157,000
126,000
2,676,000
83,000
1,600,000
472,000
688,000
Total Releases
+ Transfers
(million Ibs.)
28.8
11.9
46.4
46.7
53.7
163.4
224.8
218.1
249.7
481.9
267.7
695.3
280.7
438.4
Average Releases
+ Transfers per
Facility (pounds)
46,000
24,000
148,000
147,000
133,000
104,000
369,000
706,000
450,000
3,088,000
123,000
1,825,000
1,349,000
1,052,000
Industry sector not subject to TR1 reporting.
Industry sector not subject to TR1 reporting.
Industry sector not subject to TR1 reporting.
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
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Sector Notebook Project	Inorganic Chemicals
V. POLLUTION PREVENTION OPPORTUNITIES

                     The best way to reduce pollution is to prevent it in the first place.  Some
                     companies have creatively implemented pollution prevention techniques that
                     improve  efficiency and increase profits while at  the same time minimize
                     environmental impacts. This can be done in many ways such as reducing
                     material inputs, re-engineering processes to reuse by-products, improving
                     management practices, and employing substitute toxic  chemicals.  Some
                     smaller facilities are able to actually get below regulatory thresholds just by
                     reducing pollutant releases through aggressive pollution prevention policies.

                     In order to encourage these approaches, this section provides both general
                     and company-specific descriptions of some pollution prevention advances that
                     have been implemented within the inorganic chemical manufacturing industry.
                     While the list is not exhaustive, it does provide core information that can be
                     used as the starting point for facilities interested in beginning their own
                     pollution  prevention  projects.    When  possible, this  section provides
                     information from real activities that can, or are being implemented by this
                     sector — including a discussion of associated costs, time frames, and expected
                     rates of return. This section also provides the context (in terms of type of
                     industry  and/or type of process affected) in which the pollution prevention
                     technique can effectively be used.

                     There have been numerous cases have where the chemical industry has
                     simultaneously reduced pollutant outputs  and operating costs through
                     pollution prevention techniques.  In the inorganic  chemicals manufacturing
                     sector, however, economically viable pollution prevention opportunities are
                     not as easily identified as in other sectors. The relatively small size and limited
                     resources of a typical inorganic chemical facility limits the number of feasible
                     pollution prevention options.  The limited resources available to the industry
                     eliminates many pollution prevention options that require significant capital
                     expenditures such as process modifications and process redesign.  In addition,
                     the inorganic chemicals industry's products are primarily commodity chemicals
                     for which the manufacturing processes have been developed over many years.
                     Commodity chemical manufacturers redesign their processes infrequently so
                     that redesign of the reaction process or equipment is unlikely in the short
                     term.  In addition, the industry's process equipment has been amortized over
                     long periods of time making cost-effective process equipment improvements
                     scarce. As a result, pollution prevention in the inorganic  chemicals industry
                     is  somewhat restricted to the  less costly options, such as minor process
                     modifications, operational changes, raw material substitutions, and recycling.

                     Pollution prevention in the chemical industry in process specific. As such it
                     is  difficult to  generalize about the relative merits of  different pollution
                     prevention strategies.   The age and size of the facility, and the type and
September 1995                             53                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals
                     number of its processes will determine the most effective pollution prevention
                     strategy. Brief descriptions of some of the more widespread, general pollution
                     prevention techniques found to be effective at inorganic chemicals facilities
                     are provided below. Many of these pollution prevention opportunities can be
                     applied  to the petrochemical industry as a whole due to the many similar
                     processes found throughout the industry. It should be noted that many of the
                     ideas identified below as pollution prevention opportunities, aimed at reducing
                     wastes and reducing materials use, have been carried out by the chemicals
                     manufacturing industry for many years as  the primary means of improving
                     process efficiencies and increasing profits.

                     In  chlor-alkali  production,  pollution  prevention  options have  been
                     demonstrated  for both  the mercury  cell  and diaphragm  cell  processes;
                     however, the best opportunity to reduce pollutant outputs, conserve  energy,
                     and reduce costs in the chlor-alkali industry are in the conversion to the
                     membrane cell process. In terms of energy  consumption, the membrane cell
                     process uses only about 77 percent of that of the mercury cell process and
                     about 90 percent of that of the diaphragm  cell process. The membrane cell
                     process also generates significantly less airborne  and waterborne pollutants
                     and solid wastes (see Section III.B. - Raw  Material Inputs and Pollution
                     Outputs).

                     Substitute raw materials.  The substitution or elimination of some of the raw
                     materials used in the manufacturing of inorganic  chemicals can result in
                     substantial waste reductions and cost savings.  Because impurities in the feed
                     stream can be a major  contributor to waste generation, one of the most
                     common substitutions is to use a higher  purity feedstock. This  can be
                     accomplished either by working with suppliers to get a higher quality feed or
                     by installing purification equipment.  Raw  materials can also be substituted
                     with less toxic and less water soluble materials to reduce water contamination,
                     and with less  volatile materials to reduce  fugitive emissions.  Sometimes
                     certain raw materials can be eliminated all together.  The need for raw
                     materials that  end up as wastes should be  reexamined to determine if raw
                     materials can be eliminated by modifying the process and improving  control.

                     Improve reactor efficiencies.  Since the  chemical products are primarily
                     created inside the process reactor, it can be the primary source for waste (off-
                     spec) materials. One of the most important parameters dictating the reactor
                     efficiency is the quality of mixing.  A number of techniques can be  used to
                     improve mixing,  such as installing baffles in the reactor, a higher rpm motor
                     for the agitator, a  different mixing blade design, multiple impellers, and pump
                     recirculation. The method used to introduce  feed to the reactor can also have
                     an effect on the quality of mixing. A feed distributor can be added to equalize
                     residence time through the reactor, and feed streams can be added at a point
September 1995                             54                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals
                     in time closer to the ideal reactant concentration.  This will avoid secondary
                     reactions which form unwanted by-products.

                     Improve catalyst. The catalyst plays a critical role in the effectiveness of
                     chemical conversion  in the reactor.  Alternative  chemical makeups and
                     physical  characteristics  can  lead  to substantial improvements  in the
                     effectiveness and life of a catalyst. Different catalysts  can also eliminate by-
                     product formation.  Noble metal catalysts can replace heavy metal catalysts
                     to eliminate wastewater contaminated with heavy metals. The consumption
                     of catalysts can be reduced by using a more active  form and emissions and
                     effluents generated during catalyst activation can be eliminated by obtaining
                     the catalyst in the active form.

                     Optimize processes.  Process changes  that optimize reactions and raw
                     materials use can reduce waste generation and releases.  Many larger facilities
                     are using computer controlled systems which analyze the process continuously
                     and respond more quickly and accurately than manual control systems.  These
                     systems  are  often capable  of  automatic startups, shutdowns, and product
                     changeover  which can bring  the  process to stable conditions  quickly,
                     minimizing the generation of off-spec wastes.  Other process optimization
                     techniques include: equalizing the reactor and storage  tank vent lines during
                     batch filling to minimize vent gas losses; sequencing the addition of reactants
                     and reagents to optimize  yields and lower emissions;  and optimizing
                     sequences to minimize  washing operations  and  cross-contamination of
                     subsequent batches.

                     Reduce heat exchanger wastes  and inefficiencies.  Heat exchangers are
                     often  the  source  of  significant off-spec product  wastes  generated  by
                     overheating the product closest to the tube walls. The best way to reduce off-
                     spec product from overheating is  by reducing the heat exchanger tube wall
                     temperature.  This can be accomplished through a number of techniques
                     which do not reduce the overall heat transferred such as: reducing the tube
                     wall  temperature  and increasing the effective  surface area of the heat
                     exchanger; using staged heating by first heating  with waste heat, then low
                     pressure steam, followed by superheated high pressure steam; monitor and
                     prevent fouling of the heat exchanger tubes so that lower temperature heat
                     sources can be used; using noncorroding tubes which will foul less quickly
                     than tubes that corrode.

                     Improve wastewater treatment and recycling.  A large portion  of the
                     inorganic chemical industry's pollutants leave the  facilities as wastewater or
                     wastewater treatment system sludge. Improved treatment and minimization
                     of wastewater are effective pollution prevention opportunities that often do
                     not  require  significant  changes to  the  industrial  processes.    Modern
                     wastewater treatment technologies such as ion exchange, electrolytic cells,
September 1995                            55                                     SIC 281

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Sector Notebook Project	Inorganic Chemicals
                     reverse osmosis, and improved distillation, evaporation, and dewatering can
                     often be added to existing treatment systems.  Wastewater streams containing
                     acids or metals can be concentrated enough to be sold commercially as a
                     product by slightly altering the manufacturing process, adding processing
                     steps, and segregating wastewater streams.  Furthermore, many wastewater
                     streams can be reused within the same or different processes,  significantly
                     reducing discharges to the wastewater treatment system. An ion exchange
                     system installed in a mercury cell chlor-alkali plant reduced mercury by  99
                     percent in the facility's effluent.  An  inorganic chemicals plant making
                     photochemistry  solution  generated  a  wastewater   containing  silver.
                     Electrolytic cells were installed that recovered 98 percent of the silver and  an
                     evaporator was added that concentrated the remaining liquid for disposal
                     resulting in a 90 percent reduction in waste volume.

                     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 installing seamless pumps and other "leakless" components,
                     maintaining a preventative maintenance program, and maintaining a leak
                     detection program.

                     Improve  inventory   management  and  storage.    Good  inventory
                     management can reduce the generation of wastes 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 the contamination and dispersal of materials.

                     Exhibit 18  summarizes the above  pollution prevention opportunities and
                     provides additional examples provided by the  Chemical  Manufacturers
                     Association.
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Sector Notebook Project
                                                     Inorganic Chemicals
    Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities
            Area
          Potential Problem
         Possible Approach
  Byproducts
  Coproducts

  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 toxicity thresholds
in aquatic environments and may
bioaccumulate.

• Emissions or effluents are generated
with catalyst activation or regeneration.
                             • Catalyst attrition and carry over
                              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 in situ activation with
appropriate processing/activation
facilities.

• Develop a more robust catalyst or
support.
September 1995
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Sector Notebook Project
                                                     Inorganic Chemicals
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
          Potential Problem
         Possible Approach
  Catalysts (cont'd)

  Preparation and Handling
  (cont')
  Ejfectiveness
• 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.
• hi 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.
September 1995
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Sector Notebook Project
                                                    Inorganic Chemicals
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            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 a super heat 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.
September 1995
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Sector Notebook Project
                       Inorganic Chemicals
Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
Area
Process Conditions/
Configuration (cont'd)
Temperature (cont'd)





Pressure








Corrosive Environment










Batch vs. Continuous
Operations





Potential Problem






• 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.
Possible Approach


• 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.
• 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.

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
September 1995
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Sector Notebook Project
                       Inorganic Chemicals
Area
Process Conditions/
Configuration (cont'd)
Batch vs. Continuous
Operations (cont'd)









Process Operation/Design



























Potential Problem






• 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,
absorbents, etc.) create wastes. Each
chemical (including water) employed
within the process introduces additional
potential waste sources; the composition
generated wastes also tends to become
more complex.
• High conversion with low yield results
in wastes.














Possible Approach


• 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 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.
Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
Area
Potential Problem
Possible Approach
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                                                     Inorganic Chemicals
  Process Conditions/
  Configuration (cont'd)

  Process Operation/Design
• 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 reducing waste 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.
• 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.
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
          Potential Problem
         Possible Approach
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                                                      Inorganic Chemicals
  Raw Materials (cont'd)

  Purity (cont 'd)
  Vapor Pressure
  Water Solubility
• Specifying a purity greater than needed
by the process increases costs and can
generate more waste generation by the
supplier.

• 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.
• Specify a purity no greater than what
the process needs.
                                                                      •Use pure oxygen.
                                                                      1 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.
                                                                       1 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.)
September 1995
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Sector Notebook Project
                                                     Inorganic Chemicals
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
          Potential Problem
         Possible Approach
  Raw Materials (cont'd)

  Toxicity
  Regulatory
  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.

• hi 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.
September 1995
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                       Inorganic Chemicals
Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
Area
Raw Materials (cont'd)
Handling and Storage
(cont'd)

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.
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                       Inorganic Chemicals
Exhibit 19: Modifications to Equipment Can Also Prevent Pollution


Equipment
Compressors,
blowers, fans









Concrete pads,
floors, sumps




Controls











Distillation







Potential
Environment Problem
• Shaft seal leaks
Piston rod seal leaks
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
magnetics)
• 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
two out of three affirmative
responses)
• Increase reflux ratio

• Add section to column

• Column intervals

• Change feed tray
Operational
Related
• Preventive maintenance
program









• Reduce unnecessary
purges, transfers, and
sampling

• Use drip pans where
necessary
• Continuous versus batch

• Optimize on-line run time
• Optimize shutdown
interlock inspection
frequency
• Identify safety and
environment critical
instruments and equipment



• Change column operating
conditions
- reflux ratio
- feed tray
- temperature
- pressure
- etc.
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                                                           Inorganic Chemicals
        Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution
    Equipment
        Potential
  Environment Problem
                                                                Possible Approach
          Design
         Related
      Operational
        Related
 Distillation
 (cont'd)
• Impurities remain in
process streams (cont'd)
                   • Large amounts of
                   contaminated water
                   condensage from stream
                   stripping	
• Insulate to prevent heat loss

• Preheat column feed

• Increase vapor line size to
lower pressure drop

• Use reboilers or inert gas
stripping agents
• Clean column to reduce
fouling
                                                       • Use higher temperature
                                                       steam
 General
 manufacturing
 equipment areas
  Contaminated rainwater
                   • Contaminated sprinkler
                   and fire water
                   • Leaks and emissions
                   during cleaning
• 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
  Return samples to process
                                                                          • Monitor stormwater
                                                                          discharge
                                                       • Use drip pans for
                                                       maintenance activities

                                                       • Rinse to sump

                                                       • Reuse cleaning solutions
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        Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution
    Equipment
        Potential
  Environment Problem
                                                                 Possible Approach
          Design
          Related
       Operational
         Related
 Heat exchangers
• Increased waste due to
high localized temperatures
                    • Contaminated materials
                    due to tubes leaking at tube
                    sheets

                    • Furnace emissions
 Piping
 1 Leaks to groundwater
  Fugitive emissions
• 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)
                                               • 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 super heat of high-
pressure steam in place of a
furnace

• Design equipment layout so
as to minimize pipe run
length

• Eliminate underground
piping or design for cathodic
protection  if necessary to
install piping underground

• Use welded fittings

• Reduce number of flanges
and valves
• 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

• 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
• Monitor for corrosion and
erosion
                                                                            • Paint to prevent external
                                                                            corrosion
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                                                           Inorganic Chemicals
        Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution
    Equipment
        Potential
  Environment Problem
                                                                Possible Approach
          Design
         Related
     Operational
       Related
 Piping (cont'd)
• Leaks to groundwater
Fugitive emissions (cont'd)
                    • Releases when cleaning
                    or purging lines
• Use all welded pipe

• Use secondary containment

• Use spiral-wound gaskets

• Use plugs and double
valves for open end lines

• Change metallurgy

• Use lined pipe

• Use "pigs" for cleaning

• Slope to low point drain

• Use heat tracing and
insulation to prevent freezing

• Install equalizer lines	
                                                       • Flush to product storage
                                                       tank
 Pumps
• Fugitive emissions from
shaft seal leaks
                    • Fugitive emissions from
                    shaft seal leaks

                    • Residual "heel" of liquid
                    during pump maintenance
• 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
Seal installation practices

Monitor for leaks
                                                       • Flush casing to process
                                                       sewer for treatment
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                       Inorganic Chemicals
Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution


Equipment
Pumps (cont'd)








Reactors









Relief Valve














Potential
Environment Problem
• Injection of seal flush
fluid into process stream







• Poor conversion or
performance due to
inadequate mixing




• Waste by-product
formation

• Leaks

• Fugitive emissions

• Discharge to environment
from over pressure




• Frequent relief



Possible Approach
Design
Related
• Use double mechanical seal
with inert barrier fluid where
practical






• Static mixing

• Add baffles
• Change impellers
• 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
Operational
Related
• Increase the mean time
between pump failures by:
- selecting proper seal
material;
- aligning well;
- reducing pipe-induced
stress;
- maintaining seal
lubrication
• Add ingredients with
optimum sequence


• 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
Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution
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                                                             Inorganic Chemicals
    Equipment
        Potential
  Environment Problem
                                                                 Possible Approach
          Design
          Related
       Operational
         Related
 Sampling
• Waste generation due to
sampling (disposal,
containers, leaks, fugitives,
etc.)
  On line in situ analyzers

  System for return to process

  Closed loop

  Drain to sump
• Reduce number and size
of samples required

• Sample at the lowest
possible temperature

• Cool before sampling
 Tanks
• Tank breathing and
working losses
                      Leak to groundwater
                      Large waste heel
• Cool materials before
storage
• Insulate tanks

• Vent to control device
(flare, condenser, etc.)

• Vapor balancing

• Floating roof

• Floating roof

• Higher design pressure

• All aboveground (situated
so bottom can routinely be
checked for leads)

• Secondary containment

• Improve corrosion
resistance

• Design for 100 percent de-
inventory
• Optimize storage
conditions to reduce losses
                                                        • Monitor for leaks and
                                                        corrosion
                                                        • Recycle to process if
                                                        practical
 Vacuum Systems
 1 Waste discharge from jets
• Substitute mechanical
vacuum pump

• Evaluate using process fluid
for powering jet
  Monitor for air leaks
                                                                            • Recycle condensate to
                                                                            process
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                          Inorganic Chemicals
Exhibit 19 (cont): Modifications to Equipment Can Also Prevent Pollution
Equipment
Valves
Vents
Potential
Environment Problem
• Fugitive emissions from
leaks
• Release to environment
Possible Approach
Design
Related
• Bellow seals
• Reduce number where
practical
• Special packing sets
• Route to control or recovery
device
Operational
Related
• Stringent adherence to
packing procedures
• Monitor performance
Source: Chemical Manufacturers Association. Designing Pollution Prevention into the Process, Research, Development and
Engineering.
                     It is critical to emphasize that pollution prevention in the chemical industry is
                     process specific and oftentimes constrained by site-specific considerations.
                     As  such, it is  difficult to generalize about the relative merits of different
                     pollution prevention strategies.  The age, size, and purpose of the plant will
                     influence the most effective pollution  prevention strategy.   Commodity
                     chemical manufacturers redesign their processes infrequently so that redesign
                     of the  reaction process or equipment is unlikely in the short term.  Here,
                     operational changes are the most feasible response.  Specialty chemical
                     manufacturers are making  a greater variety of chemicals and have more
                     process and design flexibility. Incorporating changes at the earlier research
                     and development phases may be possible for them.
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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.

                    D     Section VI.A. contains a general overview of major statutes
                    D     Section VLB. contains a list of regulations specific to this industry
                    D     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 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 that treat,
                    store, or dispose of hazardous waste must obtain a permit, either from EPA
                    or from a State agency which EPA has authorized to implement the permitting
                    program.  Subtitle C  permits contain general facility standards such as

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                    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 46 of the 50 States.

                    Most RCRA requirements are not industry specific but apply to any company
                    that transports, treats, stores, or disposes of hazardous waste.  Here are some
                    important RCRA regulatory requirements:

                    D      Identification of Solid and Hazardous Wastes (40  CFR Part 261)
                           lays out the procedure every generator should  follow to determine
                           whether the material created is considered a  hazardous waste, solid
                           waste, or is exempted from regulation.

                    D      Standards for Generators of Hazardous Waste (40  CFR Part 262)
                           establishes the responsibilities of hazardous waste  generators including
                           obtaining  an  ID  number,  preparing a manifest, ensuring proper
                           packaging and labeling, meeting standards for waste accumulation
                           units, and record keeping 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.

                    D      Land Disposal Restrictions (LDRs) are regulations  prohibiting the
                           disposal of hazardous waste on land without prior treatment.  Under
                           the LDRs (40 CFR 268), materials must meet land disposal restriction
                           (LDR)  treatment  standards prior  to placement  in  a RCRA  land
                           disposal unit  (landfill,  land treatment unit,  waste pile, or surface
                           impoundment).  Wastes  subject  to the LDRs include  solvents,
                           electroplating wastes, heavy metals, and acids.  Generators of waste
                           subject  to the  LDRs must  provide  notification of such to the
                           designated TSD facility to ensure proper treatment prior to disposal.

                    D      Used Oil storage and disposal regulations (40 CFR Part 279) do not
                           define Used Oil  Management Standards impose management
                           requirements   affecting the  storage,   transportation,  burning,
                           processing, and re-refining of the used oil.  For parties that merely
                           generate used oil, regulations establish storage standards.  For a party
                           considered a  used  oil marketer  (one who  generates and  sells
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                           off-specification used oil directly to a used oil burner), additional
                           tracking and paperwork requirements must be satisfied.

                    D      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 who store such waste, including generators operating under
                           the 90-day accumulation rule.

                    D      Underground Storage Tanks  (USTs) containing petroleum and
                           hazardous substance 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
                           establishes increasingly  stringent  standards,  including upgrade
                           requirements for existing tanks, that must be met by 1998.

                    D      Boilers and Industrial  Furnaces (BIFs) that use or burn fuel
                           containing hazardous waste must  comply with strict 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's  RCRA/Superfund/UST Hotline,  at (800) 424-9346, responds  to
                    questions and distributes guidance regarding all RCRA regulations. The
                    RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 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 commonly known 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
                    Superfund, and created a free-standing law, SARA Title III, 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

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                    Response Center (NRC) any environmental release of a hazardous substance
                    which exceeds a reportable quantity. Reportable quantities are defined and
                    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 other 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/USTHotline, at (800) 424-9346, answers questions
                    and references guidance pertaining to the Superfund program. The CERCLA
                    Hotline operates weekdays from  8:30 a.m. to  7:30 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:

                    D      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
                           substance in excess of the substance's threshold planning quantity, and
                           directs the facility to appoint an emergency response coordinator.

                    D      EPCRA §304 requires the facility to notify the SERC and the LEPC
                           in the event of a release exceeding the  reportable quantity of a
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                         Inorganic Chemicals
                           CERCLA hazardous substance or an EPCRA extremely hazardous
                           substance.

                    D      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.

                    D      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, commonly known 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's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
                    guidance regarding the emergency planning and community right-to-know
                    regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
                    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.

                    The  CWA regulates both direct and indirect discharges.  The National
                    Pollutant Discharge Elimination System (NPDES) program (CWA §402)
                    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
                    approximately forty States to administer the NPDES program), contain
                    industry-specific, technology-based and/or water quality-based limits, and
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                     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 forth the conditions and effluent limitations under which a facility
                     may make a discharge.

                     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.  Storm water discharge associated
                     with industrial activity means the discharge from any conveyance which is
                     used for collecting and conveying storm water and which is directly related to
                     manufacturing, processing, or raw materials storage areas at an industrial
                     plant (40 CFR 122.26(b)(14)). 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.
                     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, the regulation should be
                     consulted.

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                     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.

                     Category iii:   Facilities classified  as SIC 10-metal mining;  SIC 12-coal
                     mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic 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
                     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 323-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-
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                    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.

                    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

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                    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.

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.
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                    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 through 99.

                    Pursuant to Title I of the CAA, EPA has established national ambient air
                    quality standards (NAAQSs) to limit levels of "criteria pollutants," including
                    carbon monoxide, lead, nitrogen dioxide, particulate matter, 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 §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.

                    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 but
                    allow the affected industries the flexibility to devise a cost-effective means of
                    reducing emissions.

                    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 III of
                    the CAAA 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
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                    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 establishes a sulfur dioxide 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 CAAA 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.

                    Title VI 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), will be phased out entirely by the year 2000,
                    while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030.

                    EPA's Control 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 Technology  Transfer
                    Network Bulletin  Board System (modem access (919) 541-5742)) includes
                    recent CAA rules, EPA guidance documents, and updates of EPA activities.

VLB. Industry Specific Requirements

                    The inorganic chemical industry is affected by nearly all federal environmental
                    statutes. In addition, the industry is subject to numerous laws and regulations
                    from state and local governments designed to protect and improve health,
                    safety, and the environment.  A  summary  of the major federal regulations
                    affecting the chemical industry follows.

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Federal Statutes
Toxic Substances Control Act
Clean Air 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 health or the
                    environment.  Three sections are of primary importance  to the inorganic
                    chemical industry. Section 5 mandates that chemical companies submit to
                    EPA pre-manufacture notices  that provide information  on health and
                    environmental effects for each new product and test existing products for
                    these effects. To date, over 20,000 premanufacturing notices have been filed.
                    Section 4 authorizes the EPA to require testing of certain substances.  Section
                    6 gives the EPA authority to  prohibit, limit, or ban the manufacture, process,
                    and use of chemicals.  Under Section 6 of TSCA, EPA has banned most uses
                    of asbestos.  In 1990, however, the chlor-alkali industry was able to show that
                    it did not have difficulty meeting the required exposure limits for asbestos
                    fibers, and the use of asbestos as a diaphragm material was exempted from the
                    TSCA ban.
                    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 inorganic chemical industry.   The EPA will
                    promulgate maximum achievable control technology (MACT) standards and
                    Lowest Achievable Emission  Rates will be  required in NAAQS non-
                    attainment areas  (Iliam Rosario, U.S. EPA, OAQPS, WAM for Chlorine
                    Production NESHAP (919)-541-5308).  An information collection request
                    survey was sent out to the chlor-alkali industry in 1992.  The data obtained
                    from the survey will be analyzed and, based on the results, EPA will propose
                    MACT standards (or EPA may propose that no new standards are necessary)
                    for the chlor-alkali industry by 1997. For  any subject facility, a six year
                    extension of MACT requirements is available if they can demonstrate early
                    emission reductions.

                    The Clean Air Act Amendments of 1990 contain provisions to phase out the
                    use of ozone depleting chemicals such as chlorofluorocarbons, halons, carbon
                    tetrachloride, and methyl chloroform, as required by the Montreal Protocol
                    on Substances that Deplete the Ozone Layer. The chlor-alkali industry has
                    been and will continue to be significantly affected by these provisions due to
                    decreases in the demand for chlorine as a feedstock in manufacturing these
                    chemicals. In addition, many of these chemicals are used extensively by the
                    industry to process chlorine.
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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 (to a Publicly Owned  Treatment Works) discharges.  Effluent
                     guidelines  for the chlor-alkali industry were last updated in 1984 (40 CFR
                     Section 415). EPA is currently conducting a study to  assess the need for new
                     effluent guidelines.  (Contact: George Zipf, U.S. EPA, Office of Water, 202-
                     260-2275)

                     Restrictions on dioxin emissions in the wastewater from pulp mills are having
                     significant effects on the chlor-alkali industry. Dioxins are  formed during the
                     chlorine bleaching process  and are subsequently  released to rivers and
                     streams.  Many mills are switching from chlorine  to alternative bleaching
                     agents in response to the effluent restrictions. Pulp mills accounted for about
                     15 percent of the chlorine demand in the U.S. in  1982  and 11 percent in 1992.
                     The demand  for chlorine for pulp bleaching is expected  to continue to
                     decrease through the 1990s.

Resource Conservation and Recovery Act

                     The Resource Conservation and Recovery Act (RCRA)  of 1976 gives the
                     EPA authority  to establish a list  of solid and hazardous wastes,  and to
                     establish standards and regulations for handling and disposing of these wastes.
                     New wastes specific to the inorganic chemical industry have not been added
                     to the RCRA list since the original waste listings in 1980.  EPA is currently
                     under a consent order, however, to propose new hazardous waste listings for
                     the industry by March 1997, and to finalize by March 1998.  (Contact: Rick
                     Brandes, U.S. EPA, Office  of Solid Waste, 202-260-4770) The Act also
                     requires companies to establish programs to reduce  the volume and toxicity
                     of hazardous wastes. It was last amended in 1984 when Congress mandated
                     some  70  new programs for the hazardous waste (Subtitle C) program.
                     Included were tighter standards for handling and  disposing of hazardous
                     wastes, land  disposal  prohibitions,  corrective  action  (or remediation)
                     regulations, and regulations for underground  storage tanks. The inorganic
                     chemical industry is strongly affected by the RCRA regulations because of the
                     disposal costs for hazardous waste  and the record keeping requirements.

Occupational Safety and Health Act

                     The Occupational Safety and Health Act gave the Department of Labor the
                     authority  to set comprehensive workplace  safety and health standards
                     including permissible exposures to chemical in the workplace and authority to
                     conduct inspections and issue citations for violations of safety and health

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                     regulations.   The  chemical industry  is  subject to hazard identification
                     standards established by OSHA, which require extensive documentation of
                     chemicals  in trade  and in the workplace and mandate  warning labels on
                     containers.  The industry is also subject to OSHA's Hazard Communication
                     Standard and various state and local laws, which give workers the right to
                     know about hazardous chemicals in the workplace.

Hazardous Materials Transportation Act

                     The Hazardous Materials Transportation Act (HMTA) gives the Department
                     of Transportation authority to regulate the movement of hazardous materials.
                     Chemical manufacturers must comply with regulations governing shipment
                     preparation, including packaging,  labeling and shipping papers; handling,
                     loading and unloading; routing emergency and security planning; incident
                     notifications; and liability insurance.  The chemical manufacturers must also
                     comply  with operating  requirements  for  vehicle, vessel, and carrier
                     transportation of hazardous materials by road,  rail, air, and  sea.   The
                     chemicals covered by the HMTA span a broad list of substances, including
                     hazardous wastes normally regulated by RCRA and hazardous materials that
                     DOT designates as hazardous for the purposes of transportation that may not
                     be considered hazardous under RCRA. These regulations especially apply to
                     chlorine gas which can cause significant risk during transport.

Pollution Prevention Act

                     The Pollution Prevention Act makes it a national policy of the United States
                     to reduce or eliminate the generation of waste at the source whenever feasible.
                     The EPA is directed to undertake a multi-media program of information
                     collection, technology transfer, and financial assistance to enable the states to
                     implement this policy and to promote the use of source reduction techniques.
                     The reorganization of the Office of Compliance by industry sector is part of
                     EPA's response to this act.

State Statutes

Toxics Use Reduction Act, Massachusetts

                     The Massachusetts Toxics Use Reduction Act affects those facilities that use,
                     manufacture, or process more than a specified amount of substances that are
                     on the Massachusetts toxic or hazardous substances list.  Facilities must
                     submit annual reports on the amounts of substances used, manufactured, or
                     processed and must pay annual fees based on these amounts. In addition,
                     facilities must prepare toxics use reduction plans which show in-plant changes
                     in production processes  or raw materials that would reduce,  avoid, or
                     eliminate the use or generation of toxic or hazardous substances.   The
                     Massachusetts toxic or hazardous  substance list initially consists of those

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                    substances listed under §313 of EPCRA and will eventually include those
                    substances listed under CERCLA. New Jersey has recently passed a similar
                    act.

VI.C. Pending and Proposed Regulatory Requirements

Resource Conservation and Recovery Act (RCRA)

                    The Resource Conservation and Recovery Act (RCRA) listed waste streams
                    specific to the inorganic chemical industry have not been updated since the
                    original RCRA hazardous wastes list developed in 1980. EPA is under a
                    court-ordered deadline to propose and finalize additional waste listings for the
                    industry by March 1997 and March 1988, respectively. The Office of Solid
                    Waste will begin assessing the need for new listings by early 1996. (Contact:
                    Rick Brandes, U.S. EPA, Office of Solid Waste, 202-260-4770)
Clean Air Act
                    The new NESHAP standards  for the  inorganic chemical industry are
                    scheduled to be promulgated by EPA by 1997. (Contact: Iliam Rosario, U.S.
                    EPA, OAQPS, WAM for Chlorine Production NESHAP, 919-541-5308) The
                    standards required will, in most cases, be in the form of MACT standards.
                    Lowest Achievable  Emission Rates will  be required  in  NAAQS  non-
                    attainment areas.  An information collection request survey was sent out to
                    the chlor-alkali industry in 1992. The data obtained will be analyzed and used
                    to assess the need for NESHAP standards in the chlor-alkali  industry.

                    The chlor-alkali industry will continue to be  affected by the provisions to
                    phase out the use of ozone depleting chemicals as required by the Montreal
                    Protocol on Substances that Deplete the Ozone Layer.  The demand for
                    chlorine as a feedstock in manufacturing these chemicals, which accounted for
                    about 15 percent of total domestic demand in 1990, will continue to decline
                    through the 1990s. In addition, costs of purifying and liquefying chlorine gas
                    may increase as the cost of carbon tetrachloride and refrigerants increases, and
                    as alternative processes are introduced.
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
                     To date, 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.
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
                     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.
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                    Following this introduction is a list defining each data column presented
                    within this section.   These values represent a retrospective  summary of
                    inspections or enforcement actions, and solely reflect EPA, state, and local
                    compliance assurance activity 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 (August 10,1990 to August 9, 1995) and the  other for the
                    most recent twelve-month period (August 10, 1994 to August 9, 1995).  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 regions for
                    certain sectors.6 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 "glue together"
                    separate data records from EPA's databases. This is done to create a "master
                    list" of data records for  any given 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,
c 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); VII
(IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR,
WA).	

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                    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, 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 facility
                    inspections for the facilities in this data search.  These values show what
                    percentage of the facility universe is inspected in a 12 or 60 month period.
                    This column does not count non-inspectional compliance activities such as the
                    review of facility-reported discharge reports.

                    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, that a compliance inspection occurs at a facility within
                    the defined universe.

                    Facilities with One or More Enforcement Actions — expresses the number
                    of facilities that were party to 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  (facility with three  enforcement actions counts as one).  All
                    percentages that appear are referenced to the number of facilities inspected.

                    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 (a facility
                    with three enforcement actions counts as three).
                    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
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                    accorded  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 — expresses how often enforcement actions
                    result  from inspections.  This value  is a ratio of enforcement actions to
                    inspections, and is presented for comparative purposes only.  This measure is
                    a rough indicator of the relationship between inspections and enforcement.
                    Reported inspections and enforcement actions under the Clean Water Act
                    (PCS), the Clean Air Act (AFS) and the Resource Conservation and Recovery
                    Act  (RCRA)  are included in this ratio.  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. 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 number
                    and 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.  Percentages within
                    this  column may exceed 100 percent because  facilities  can be  in violation
                    status without being inspected. Violation status may be a  precursor to  an
                    enforcement action, but does not necessarily indicate that  an enforcement
                    action will occur.

                    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. Inorganic Chemical Industry Compliance History

                    Exhibit 20 provides an overview of the reported compliance and enforcement
                    data for the inorganic chemical industry over the past five years (August 1990
                    to August 1995).  These data are also broken out by EPA Region thereby
                    permitting geographical comparisons.  A few points evident from the data are
                    listed below.
                    D      Slightly more  than half of the TRI reporting  inorganic chemical
                           facilities in the EPA databases were inspected over the five year
                           period resulting in an average of 11 months between inspections of
                           these facilities.

                    D      On average,  the states carried out three times the number of
                           inspections as the Regions;  however, the percentage of state led
                           actions varied across the Regions from 44 percent to 96 percent.

                    D      The enforcement to inspection rate varied significantly from Region
                           to Region. Region IX had the highest enforcement to inspection rate
                           as well as the highest percentage of state led actions.
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GO
CD
Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic Chemicals Manufacturing
A
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
TOTAL
B
Facilities
in Search
10
46
60
105
108
93
19
17
70
20
548
C
Facilities
Inspected
5
29
41
54
62
40
12
9
35
11
298
D
Number of
Inspections
16
354
544
916
469
401
62
38
171
63
3,034
E
Average
Months
Between
Inspections
38
8
7
7
14
14
18
27
25
19
11
F
Facilities with 1
or More
Enforcement
Actions
0
12
12
21
11
24
2
4
9
4
99
G
Total
Enforcement
Actions
0
29
38
113
42
106
9
5
53
7
402
H
Percent
State Lead
Actions
-
72%
89%
89%
45%
61%
44%
80%
96%
86%
76%
I
Percent
Federal
Lead Actions
-
28%
11%
11%
55%
39%
56%
20%
4%
14%
24%
J
Enforcement
to Inspection
Rate
-
0.08
0.07
0.12
0.09
0.26
0.15
0.13
0.31
0.11
0.13
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Sector Notebook Project	Inorganic Chemicals
VII.B. Comparison of Enforcement Activity Between Selected Industries

                     Exhibits 21 and 22 allow the compliance history of the inorganic chemical
                     manufacturing sector to be compared to the other industries covered by the
                     industry sector notebooks. Comparisons between Exhibits 21 and 22 permit
                     the identification of trends in compliance and enforcement records of the
                     industry by comparing data covering the last five years to that of the past year.
                     Some points evident from the data are listed below.

                     D      The inorganic chemicals industry has a relatively low frequency of
                            inspections compared to most  of  the other sectors shown.  On
                            average, the number of months between inspections at inorganic
                            chemicals  facilities has been  only about twice  that of  organic
                            chemicals facilities.

                     D      Over the past five years the inorganic chemical industry has had a ratio
                            of enforcement actions to inspections lower than most of the  other
                            sectors listed including the organic chemicals sector. This difference
                            has continued over the past year.

                     D      Enforcement actions are brought against only about 10 percent of the
                            facilities with violations; lower than most other sectors listed.

                     Exhibits 23 and 24 provide a more in-depth comparison between the inorganic
                     chemicals industry and other sectors by breaking out the compliance and
                     enforcement data by environmental statute.  As in the previous Exhibits (21
                     and 22), the data cover the  last five years (Exhibit 23) and the last one year
                     (Exhibit 24) to facilitate the identification of recent trends.  A few points
                     evident from the data are listed below.

                     D      Inspections of inorganic chemical facilities are split relatively evenly
                            between Clean Air Act, Clean Water Act, and RCRA, although RCRA
                            accounts for a significantly larger portion of the total actions brought
                            against the inorganic chemicals industry over the past five years.

                     D      Significantly more Clean Water Act inspections are carried out at
                            inorganic chemicals facilities in comparison to the organic chemicals
                            industry, although the Clean Water Act accounts for a smaller portion
                            of the  total actions brought against inorganic chemicals facilities.

                     D      Over  the  past  year RCRA inspections  have  accounted for  a
                            significantly smaller portion of the enforcement  actions  brought
                            against the  industry and the  Clean Air Act has taken a far greater
                            share.
September 1995                            94                                    SIC 281

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Exhibit 21: Five- Year Enforcement and Compliance Summary for Selected Industries
A
Industry Sector
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
Metal Mining
Non-Metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Fabricated Metal
Nonferrous Metal
Electronics
Automobiles
B
Facilities
in Search
306
4,106
548
412
156
374
933
873
1,143
464
293
1,665
468
2,346
844
405
598
c
Facilities
Inspected
265
1,035
298
316
145
275
245
339
631
301
213
739
268
1,340
474
222
390
D
Number of
Inspections
3,766
4,723
3,034
3,864
3,257
3,555
633
1,519
3,422
1,891
1,534
3,386
2,475
5,509
3,097
777
2,216
E
Average
Months
Between
Inspections
5
52
11
6
3
6
88
34
20
15
11
30
11
26
16
31
16
F
Facilities with
1 or More
Enforcement
Actions
115
176
99
152
110
115
29
67
84
78
34
146
73
280
145
68
81
G
Total
Enforcement
Actions
502
514
402
726
797
499
103
155
192
232
91
391
301
840
470
212
240
H
Percent
State Lead
Actions
78%
85%
76%
66%
66%
72%
99%
47%
76%
79%
91%
78%
70%
80%
76%
79%
80%
I
Percent
Federal
Lead
Actions
22%
15%
24%
34%
34%
28%
1%
53%
24%
21%
9%
22%
30%
20%
24%
21%
20%
J
Enforcement
to
Inspection
Rate
0.13
0.11
0.13
0.19
0.25
0.14
0.16
0.10
0.06
0.12
0.06
0.12
0.12
0.15
0.15
0.27
0.11
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Exhibit 22: One- Year Inspection and Enforcement Summary for Selected Industries
A
Industry Sector
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics
Automobiles
B
Facilities in
Search
306
4,106
548
412
156
374
933
873
1,143
464
293
1,665
468
844
2,346
405
598
C
Facilities
Inspected
189
397
158
195
109
167
80
114
253
142
160
271
146
202
477
60
169
D
Number of
Inspections
576
676
427
545
437
488
111
194
425
268
113
435
330
402
746
87
284
E
Facilities with 1 or
More Violations
Number
162
251
167
197
109
165
21
82
75
109
66
289
116
282
525
80
162
Percent*
86%
63%
106%
101%
100%
99%
26%
72%
30%
77%
41%
107%
79%
104%
110%
133%
96%
F
Facilities with 1 or more
Enforcement Actions
Number
28
25
19
39
39
20
5
16
28
18
3
19
20
22
46
8
14
Percent*
15%
6%
12%
20%
36%
12%
6%
14%
11%
13%
2%
7%
14%
11%
10%
13%
8%
G
Total
Enforcement
Actions
88
72
49
118
114
46
11
24
54
42
5
59
66
72
114
21
28
H
Enforcement to
Inspection Rate
0.15
0.11
0.12
0.22
0.26
0.09
0.10
0.13
0.13
0.58
0.55
0.14
0.20
0.18
0.15
0.24
0.10
* Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and actions can occur without a facility inspection.
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Exhibit 23: Five- Year Inspection and Enforcement Summary by Statute for Selected Industries
Industry Sector
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics
Automobiles
Facilities
Inspected
265
1,035
298
316
145
275
245
339
631
301
293
739
268
474
1,340
222
390
Total
Inspections
3,766
4,723
3,034
3,864
3,237
3,555
633
1,519
3,422
1,891
1,534
3,386
2,475
3,097
5,509
777
2,216
Total
Enforcement
Actions
502
514
402
726
797
499
103
155
192
232
91
391
301
470
840
212
240
Clean Air Act
% of Total
Inspections
51%
49%
29%
33%
44%
32%
15%
35%
65%
31%
52%
39%
45%
36%
25%
16%
35%
%of
Total
Actions
48%
31%
26%
30%
32%
20%
1%
17%
46%
21%
27%
15%
39%
22%
11%
2%
15%
Clean Water Act
% of Total
Inspections
38%
6%
29%
16%
19%
30%
3%
57%
31%
8%
1%
13%
15%
22%
15%
14%
9%
%of
Total
Actions
30%
3%
17%
21%
12%
18%
4%
60%
24%
7%
1%
7%
5%
13%
6%
3%
4%
Resource
Conservation and
Recovery Act
% of Total
Inspections
9%
43%
39%
46%
35%
37%
83%
6%
3%
59%
45%
44%
39%
38%
56%
66%
54%
%of
Total
Actions
18%
62%
53%
44%
52%
58%
93%
14%
27%
67%
64%
68%
51%
54%
76%
90%
75%
FIFRA/TSCA/
EPCRA/Other
% of Total
Inspections
2%
2%
3%
5%
2%
2%
0%
1%
0%
2%
1%
3%
2%
4%
4%
3%
2%
% of Total
Actions
3%
4%
4%
5%
5%
5%
1%
9%
4%
5%
8%
10%
5%
10%
7%
5%
6%
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Exhibit 24: One- Year Inspection and Enforcement Summary by Statute for Selected Industries
Industry Sector
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Iron and Steel
Dry Cleaning
Metal Mining
Non-metallic Mineral
Mining
Lumber and Wood
Furniture
Rubber and Plastic
Stone, Clay, and Glass
Nonferrous Metals
Fabricated Metal
Electronics
Automobiles
Facilities
Inspected
189
397
158
195
109
167
80
114
253
142
293
271
146
202
477
60
169
Total
Inspections
576
676
427
545
437
488
111
194
425
268
160
435
330
402
746
87
284
Total
Enforcement
Actions
88
72
49
118
114
46
11
24
54
42
5
59
66
72
114
21
28
Clean Air Act
% of Total
Inspections
56%
50%
26%
36%
50%
29%
21%
47%
69%
29%
58%
39%
45%
33%
25%
17%
34%
%of
Total
Actions
69%
27%
38%
34%
31%
18%
4%
42%
58%
20%
67%
14%
52%
24%
14%
2%
16%
Clean Water Act
% of Total
Inspections
35%
5%
29%
13%
19%
35%
1%
43%
26%
8%
1%
14%
18%
21%
14%
14%
10%
%of
Total
Actions
21%
3%
21%
16%
16%
26%
22%
34%
16%
13%
10%
4%
8%
3%
8%
7%
9%
Resource
Conservation and
Recovery Act
% of Total
Inspections
10%
44%
45%
50%
30%
36%
78%
10%
5%
63%
41%
46%
38%
44%
61%
69%
56%
%of
Total
Actions
7%
66%
36%
49%
47%
50%
67%
6%
16%
61%
10%
71%
37%
69%
77%
87%
69%
FIFRA/TSCA/
EPCRA/Other
% of Total
Inspections
0%
0%
0%
1%
1%
0%
0%
0%
0%
0%
0%
1%
0%
1%
0%
0%
1%
%of
Total
Actions
3%
4%
6%
1%
6%
6%
7%
19%
11%
6%
13%
11%
3%
4%
2%
4%
6%
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Sector Notebook Project	Inorganic Chemicals
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 Supplementary Environmental Projects
                    (SEPs). SEPs are compliance agreements that reduce a facility's stipulated
                    penalty in return for an environmental project that exceeds the value of the
                    reduction. Often, these projects fund pollution prevention activities that can
                    significantly reduce the future pollutant loadings of a facility.

       VII.C. 1. Review of Major Cases

                    Historically, OECA's Enforcement Capacity and Outreach Office does not
                    regularly compile information related to major cases and pending litigation
                    within an industry sector. The staff are willing to pass along such information
                    to Agency staff as requests are made.  In addition, summaries of completed
                    enforcement actions are published each fiscal year in the Enforcement
                    Accomplishments Report.  To date, these summaries are not organized by
                    industry sector. (Contact: Office of Enforcement Capacity and Outreach 202-
                    260-4140)

       VII.C.2. Supplementary Environmental Projects

                    Supplemental environmental projects (SEPs) are an enforcement option that
                    requires the non-compliant facility to complete specific projects.  Regional
                    summaries of SEPs undertaken in the 1993 and 1994 federal fiscal years were
                    reviewed.   Five  SEPs were undertaken that involved inorganic chemical
                    manufacturing facilities, as shown in Exhibit 25.

                    CERCLA violations engendered three out of the five SEPs identified; the
                    fourth and fifth were due to a CAA violation and a TSCA violation.  Due to
                    regional reporting methods, the specifics of the original violations are not
                    known and, for one SEP, details of the actual project were not available.

                    One of the five projects was conducted at a facility that manufactures both
                    inorganic and organic chemicals.  This project has been included in both
                    industry sector project summaries. The FY 1993 and 1994 SEPs for inorganic
                    chemical manufacturers fall into four categories: process related projects;
                    control and recovery technology inprovement or installation; leak prevention;
                    and donations to the community.
September 1995                            99                                    SIC 281

-------
Sector Notebook Project	Inorganic Chemicals
                    •Process related projects
                           A Region IV project carried out in 1993 entailed specific process
                           changes intended to reduce chlorinated wastes  at the facility.  In
                           conjunction with other non-process components of the project, the
                           implementation cost was $93,000.

                    •Control and recovery technology improvement/installation
                           A Louisiana facility, the combined organic and  inorganic  chemical
                           manufacturer, implemented a SEP to reduce emissions from returned
                           gas canisters.  The  SEP involved the installation of  recovery
                           technologies to reduce emissions of residual CFC and HCFC from the
                           used canisters. The cost to the company was $158,400.

                    •Leak prevention
                           A Region IV facility constructed retaining walls around underground
                           storage  tanks  to  prevent  hazardous leachate from  reaching
                           groundwater.  The cost to the company was $46,200.

                    •Donations to Community
                           Following a CERCLA violation, a facility in Texas donated emergency
                           and  computer  equipment  to  the  Local  Emergency   Planning
                           Commission (LEPC)  which could be used in the planning and
                           responding to potential chemical emergencies. The facility also agreed
                           to participate in LEPC activities and to provide technical assistance.
September 1995                            100                                   SIC 281

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Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview: Inorganic Chemical Manufacture
General Information
FY
93
93
93
93
94
Docket
#



6-93-16
—
Company
Name
LaRoche
Chemicals,
Inc.
Coastal
Chemicals
Scholle
Corp.
ALCOA
Anzon, Inc.
State/
Region
LA
Reg. 4
Reg. 4
TX
Reg.III
Violation Information
Type
CAA
CERCLA
103/EPCRA
304
CERCLA,
EPCRA
CERCLA
103(a)
TSCA
Initial
Penalty
$88,360
$90,000
$40,000
$25,000
N/A
Final
Penalty
$25,000
$2,000
$10,000
$3,000
N/A
SEP
Credit




N/A
SEP Cost
to
Company
$158,400
$93,000
$46,200
$10,000
$198,000
Pollutant Reduction
Pollutant of
Concern
CFC/HCFC
chlorinated
waste


—
Pollutant
Reduction




—
Supplemental Environmental Projects
Description
Company purchased, installed, and
operated equipment for recovery of
residual CFCs and HCFCs in used gas
cylinders returned by customers
Altered process to reduce chlorinated
wastes, provided computer and Cameo
training for county EMA, donated funds
to LEPC for hazards analysis, and held
response exercises at plant
Constructed retaining walls around
underground storage tanks to prevent
hazardous material leachate from
reaching groundwater
Donated emergency and/or computer
equipment to LEPC for response/planninj
for chemical emergencies, agreed to
participate in LEPC activities and to
provide technical assistance
N/A
"Facilities identified as combined inorganic and organic chemical manufacturers
Violation Information Terms
Initial penalty: Initial proposed cash penalty for violation
Final penalty: Total penalty after SEP negotiation
SEP credit: Cash credit given for SEP so that, Final penalty - SEP credit = Final cash penalty
SEP cost to company: Actual cost to company of SEP implementation
NOTE: Due to differences in terminology and level of detail between regional SEP information, in some cases the figure listed as Final penalty may be the Final cash penalty after deduc
for SEP credit
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Sector Notebook Project
                         Inorganic Chemicals
VIII. COMPLIANCE ASSURANCE 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.

VIII.A. Sector-related Environmental Programs and Activities

                    None identified.

VIII.B. EPA Voluntary Programs

33/50 Program

                    The "33/50  Program" is EPA's voluntary program to reduce toxic chemical
                    releases and transfers of seventeen chemicals from manufacturing facilities.
                    Participating companies pledge to reduce their toxic chemical releases and
                    transfers by 33 percent as of 1992 and by 50 percent as of 1995 from the  1988
                    baseline year. Certificates of Appreciation have been given out to participants
                    meeting their 1992 goals.  The list of chemicals includes seventeen high-use
                    chemicals reported in the Toxics Release Inventory.  Exhibit 26 lists those
                    companies participating in the 33/50 program that reported the SIC code 281
                    to TRI.   Many of the  companies shown listed multiple SIC codes and,
                    therefore, are likely to carry out operations in addition to inorganic chemicals
                    manufacturing. The SIC codes reported by each company are listed in no
                    particular order. In addition,  the number of facilities within each company
                    that are participating in the 33/50 program and that report SIC 281 to TRI is
                    shown. Finally, each company's total 1993 releases and transfers of 33/50
                    chemicals and the percent reduction in these  chemicals  since  1988 are
                    presented.

                    The inorganic chemicals industry as a whole used, generated or processed
                    almost all of the seventeen target TRI chemicals.  Of the target chemicals,
                    chromium and chromium compounds, lead and lead compounds, and nickel
                    and nickel compounds are released and transferred most frequently and in
                    similar quantities. These three toxic chemicals account for about nine percent
                    of TRI releases and transfers from inorganic chemical facilities.  Seventy-five
                    companies,  representing  168 facilities,  listed under  SIC 281 (inorganic
                    chemicals) are currently participating in the 33/50 program.  This accounts for
                    30 percent  of the facilities reporting to SIC code  281 to TRI  which is
                    significantly higher  than the average  for  all industries of  14 percent
                    participation.  (Contact: Mike Burns, 202-260-6394 or the 33/50 Program,
                    202-260-6907)
September 1995
102
SIC 281

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Sector Notebook Project
                       Inorganic Chemicals
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)
Parent Company
3M MINNESOTA MINING & MFC CO.
AIR PRODUCTS AND CHEMICALS
AKZO NOBEL INC.
ALBEMARLE CORP.
ALLIED-SIGNAL INC.
ASHLAND OIL INC.
B F GOODRICH COMPANY
BASF CORP.
BENJAMIN MOORE & CO.
BORDEN CHEM & PLAS LTD PARTNR
CABOT CORP.
CALGON CARBON CORP.
CIBA-GEIGY CORP.
CITGO PETROLEUM CORP.
CONKLIN COMPANY INC.
CORNING INC.
CRITERION CATALYST LTD PARTNR
CYTEC INDUSTRIES
DEGUSSA CORP.
DOW CHEMICAL COMPANY
E. I. DU PONT DE NEMOURS & CO.
EAGLE CHEMICALS INC.
EAGLE-PICHER INDUSTRIES INC.
ELF AQUITAINE INC.
ENGELHARD CORP.
ETHYL CORP.
FERRO CORP.
FMC CORP.
GENERAL ELECTRIC COMPANY
GEORGIA GULF CORP.
GEORGIA-PACIFIC CORP.
HANLIN GROUP INC.
HM ANGLO-AMERICAN LTD.
HOECHST CELANESE CORP.
INTERNATIONAL PAPER COMPANY
[SK AMERICAS INC.
KEMIRA HOLDINGS INC.
KERR-MCGEE CORP.
LAIDLAW ENVIRONMENTAL
SERVICES
LAROCHE HOLDINGS INC.
MALLINCKRODT GROUP INC.
City, State
ST. PAUL, MN
ALLENTOWN, PA
CHICAGO, IL
RICHMOND, VA
MORRISTOWN, NJ
RUSSELL, KY
AKRON, OH
PARSIPPANY, NJ
MONTVALE, NJ
COLUMBUS, OH
BOSTON, MA
PITTSBURGH, PA
ARDSLEY, NY
TULSA, OK
SHAKOPEE, MN
CORNING, NY
HOUSTON, TX
WEST PATERSON, NJ
RIDGEFIELD PARK,
NJ
MIDLAND, MI
WILMINGTON, DE
HAMILTON, OH
CINCINNATI, OH
NEW YORK, NY
ISELIN, NJ
RICHMOND, VA
CLEVELAND, OH
CHICAGO, IL
FAIRFIELD, CT
ATLANTA, GA
ATLANTA, GA
EDISON, NJ
NEW YORK, NY
SOMERVILLE, NJ
PURCHASE, NY
SAN FRANCISCO, CA
SAVANNAH, GA
OKLAHOMA CITY,
OK
COLUMBIA, SC
ATLANTA, GA
SAINT LOUIS, MO
SIC Codes
Reported
2821, 2816,2899
2819,2869
2819,2869
2869,2819
2819,2869
2819
2812,2821,2869
2869,2865,2819
2851,2812,
2813,2821,2869
3339,2819
2819
2819,2865,2869
2911,2819,2869
2819,2952,2992
3339,2819
28190
2819,2869
2819,2869,2879
2800,2819,2821
2816
2899,2819,2841
2816
2812
3714,2819
2869,2819,
2819,2869
2812,2819
2821,2812,2869
2865,2812,2819
2611,2621,2812
2812,2819
2816
2819,2869,2873
28190
2879,2819
2816,2819
2819
2819,2869
2812,2869
2869,2833,2819
#of
Participat-
ing
Facilities
1
5
1
1
4
1
1
1
7
1
2
1
2
1
1
1
3
2
1
4
9
1
1
7
6
1
5
4
2
1
1
3
4
1
1
2
1
3
1
1
3
1993 Releases
and Transfers
(Ibs.)
16,481,098
144,876
930,189
1,005,108
2,080,501
723,562
621,207
1,157,548
20,635
12,662
2,407,581
14,845
1,875,028
1,164,354
2,977
1,521,528
3,716
1,074,646
676,418
2,769,363
11,740,853
500
227,242
273,274
236,302
251,519
165,529
502,318
5,010,856
39,480
2,722,182
6,174
1,265,741
2,603,661
2,784,831
300,088
394,070
374,098
8,167
81,470
775,206
% Reduction
1988 to 1993
70
50
13
51
50
50
50
50
*
***
50
50
50
20
*
14
*
50
***
50
50
33
50
43
50
46
50
50
50
80
50
75
2
50
50
50
*
35
***
*
50
September 1995
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Sector Notebook Project
                       Inorganic Chemicals
Parent Company
MAYO CHEMICAL CO. INC.
MILES INC.
MOBIL CORP.
MONSANTO COMPANY
MORTON INTERNATIONAL INC.
NALCO CHEMICAL COMPANY
OCCIDENTAL PETROLEUM CORP.
OLIN CORP.
PHILLIPS PETROLEUM COMPANY
PPG INDUSTRIES INC.
PQ CORP.
PROCTER & GAMBLE COMPANY
RHONE-POULENC INC.
ROHM AND HAAS COMPANY
SHELL PETROLEUM INC.
SHEPHERD CHEMICAL CO.
SHERWIN-WILLIAMS COMPANY
STANDARD CHLORINE CHEM. CO.
STAR ENTERPRISE
STERLING CHEMICALS INC.
SUD-CHEMIE NORTH AMERICA DE
TEXACO INC.
TEXAS INSTRUMENTS INC.
UNILEVER UNITED STATES INC.
UNIROYAL CHEMICAL CORP.
UNOCAL CORP.
UOP
US DEPARTMENT OF ENERGY
VELSICOL CHEMICAL CORP.
VISTA CHEMICAL COMPANY
VULCAN MATERIALS COMPANY
W R GRACE & CO INC.
WEYERHAEUSER COMPANY
WITCO CORP.
City, State
SMYRNA, GA
PITTSBURGH, PA
FAIRFAX, VA
SAINT LOUIS, MO
CHICAGO, IL
NAPERVILLE, IL
LOS ANGELES, CA
STAMFORD, CT
BARTLESVILLE, OK
PITTSBURGH, PA
VALLEY FORGE, PA
CINCINNATI, OH
MONMOUTH
JUNCTION, NJ
PHILADELPHIA, PA
HOUSTON, TX
CINCINNATI, OH
CLEVELAND, OH
KEARNY, NJ
HOUSTON, TX
HOUSTON, TX
LOUISVILLE, KY
WHITE PLAINS, NY
DALLAS, TX
NEW YORK, NY
MIDDLEBURY, CT
LOS ANGELES, CA
DBS PLATNES, IL
WASHINGTON, DC
ROSEMONT, IL
HOUSTON, TX
BIRMINGHAM, AL
BOCA RATON, FL
TACOMA, WA
NEW YORK, NY
SIC Codes
Reported
2819
2819
2869,2819,2821
2865,2869,2819
2819,2869
2899,2819,2843
2812,2819
2819
2911,2819
2812,2816,2869
2819
28190
2821,2819,2841
2819,2869
2869,2819
2819,2869
2816,2851
2865,2819
2911,2819,4463
2869,2865,2819
2819
2869,2865,2819
3674,3812,2819
2819
2821,2879,2813
2819
2819,2869
2819
2865,2819,2869
2869,2865,2819
2869,2812
2819
2621,2611,2812
2819,2869
#of
Participat-
ing
Facilities
2
3
1
3
1
2
8
4
2
3
3
1
6
1
1
1
1
1
1
1
2
1
2
1
1
1
2
4
1
2
2
2
1
1
1993 Releases
and Transfers
(Ibs.)
15
1,095,504
4,263,284
1,683,580
721,216
107,651
8,896,126
574,673
2,367,877
2,772,331
19
612,520
1,437,778
1,210,244
3,240,716
828
1,352,412
48,246
601,640
182,216
196,438
514,803
344,225
164,034
1,970,357
238,520
14,169
148,198
224,664
106,497
679,566
615,509
1,006,356
327,611
% Reduction
1988 to 1993
67
40
50
23
20
50
19
70
50
50
50
*
50
50
55
72
50
***
50
65
16
50
25
50
20
50
50
50
50
50
85
50
*
50
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Source: U.S. EPA, Toxic Release Inventory, 1993.
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Environmental Leadership Program

                     The Environmental Leadership Program (ELP) is a national initiative piloted
                     by EPA and state agencies in which facilities have volunteered to demonstrate
                     innovative approaches to environmental management and compliance. EPA
                     has selected 12 pilot projects at industrial facilities and federal installations
                     which will 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 mentoring programs. In return
                     for participating, pilot participants receive public recognition and are given a
                     period  of time to correct violations discovered during these experimental
                     projects. Forty proposals were received from companies, trade associations,
                     and federal facilities representing many manufacturing and service sectors.
                     Two chemical companies (Ciba Geigy of St. Gabriel, LA and Akzo Chemicals
                     of Edison, NJ), one pharmaceutical  manufacturer (Schering Plough  of
                     Kenilworth, NJ), and one manufacturer of agricultural chemicals (Gowan
                     Milling of Yuma, AZ) submitted proposals.  (Contact: Tai-ming Chang, ELP
                     Director, 202-564-5081 or Robert Fentress 202-564-7023)
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 allowing participants  to
                     replace or modify existing regulatory requirements on the condition that they
                     produce greater environmental benefits.  EPA and program participants will
                     negotiate and sign a final Project Agreement, detailing specific objectives that
                     the regulated entity shall satisfy. In exchange, EPA will allow the participant
                     a certain degree of regulatory flexibility and may seek changes in underlying
                     regulations or  statutes.  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 facilities,
                     sectors,   communities,  and  government  agencies  regulated  by  EPA.
                     Applications will be accepted on a rolling basis and projects will move to
                     implementation within  six  months  of their  selection.   For  additional
                     information regarding XL Projects, including  application procedures and
                     criteria, see the May 23,1995 Federal Register Notice. (Contact: Jon Kessler,
                     Office of Policy Analysis, 202-260-4034)

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 has over 1,500 participants which include
                     major corporations; small and medium sized businesses; federal, state and

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                    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. EPA provides technical assistance to the
                    participants through a decision support software package, workshops and
                    manuals, and a financing registry.  EPA's Office of Air and Radiation is
                    responsible for operating the Green Lights Program. (Contact: Maria Tikoff
                    202-233-9178 or the Green Light/Energy Star Hotline, 202-775-6650)
WasteWi$e Program
                    The WasteWiSe 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 minimization,  recycling collection, and  the
                    manufacturing and purchase of recycled products.  As of 1994, the program
                    had  about 300  companies as members, including a number of  major
                    corporations. Members agree to identify and implement actions to reduce
                    their solid wastes and must provide EPA with their waste reduction goals
                    along with yearly progress reports.  EPA, in  turn,  provides technical
                    assistance to member companies and allows the  use of the WasteWiSe logo
                    for promotional  purposes.  (Contact:  Lynda Wynn 202-260-0700 or  the
                    WasteWiSe Hotline, 800-372-9473)
Climate Wise Recognition Program
                    The Climate Change Action Plan was initiated  in response to the U.S.
                    commitment to reduce greenhouse gas emissions in accordance with the
                    Climate Change Convention of the 1990 Earth Summit.  As part of the
                    Climate Change Action Plan, the Climate Wise Recognition Program is a
                    partnership initiative run jointly by EPA and the Department of Energy.  The
                    program is designed to reduce greenhouse gas emissions by encouraging
                    reductions across all sectors of the economy, encouraging participation in the
                    full range of Climate Change Action Plan initiatives, and fostering innovation.
                    Participants in the program are required to identify and commit to actions that
                    reduce greenhouse gas emissions.  The program, in turn, gives organizations
                    early recognition for  their  reduction  commitments; provides  technical
                    assistance through consulting services, workshops, and guides; and provides
                    access to the program's centralized information system. At EPA, the program
                    is operated by the Air and Energy Policy Division within the Office of Policy
                    Planning and Evaluation.  (Contact: Pamela Herman 202-260-4407)
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NICE3

                    The U.S. Department of Energy and EPA's Office of Pollution Prevention are
                    jointly  administering a  grant  program  called  The National Industrial
                    Competitiveness through Energy, Environment, and Economics (NICE3). By
                    providing grants of up to 50 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, demonstrate, and assess the
                    feasibility of 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 pulp
                    and paper, chemicals, primary metals, and petroleum and coal products
                    sectors. (Contact: DOE's Golden Field Office, 303-275-4729)

VIII.C. Trade Association/Industry Sponsored Activity

       VIII.C.l. Environmental Programs

       Global Environmental Management Initiative

                    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, GEMI's
                    membership consisted of about 30 major corporations including Amoco
                    Corporation.

       National Pollution Prevention Roundtable

                    The  National  Pollution  Prevention Roundtable published  The Pollution
                    Prevention Yellow  Pages in September 1994.   It is a compilation of
                    information collected from mail and telephone surveys of state and local
                    government pollution prevention programs. (Contact: Natalie Roy 202-543-
                    7272) The following state programs listed themselves as having expertise in
                    pollution prevention related to inorganic chemical manufacture and use.  The
                    contacts listed below (Exhibit 27) are also likely to be aware of various state-
                    and local-level initiatives affecting the inorganic chemical industry.
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Exhibit 27: Contacts for State and Local Pollution Prevention Programs
State
Alabama
California
Colorado
Illinois
Indiana
Iowa
Kentucky
Massachusetts
Michigan
New Mexico
North Dakota
Ohio
Pennsylvania
Rhode Island
South
Carolina
Texas
Vermont
Washington
Wisconsin
Wyoming
Program
AL Dept. of Env. Protection, Ombudsman and
Small Business Assistance Program
AL WRATT Foundation
CA State Dept. of Toxic Substances Control
County Sanitation Districts of LA
Region Vlll HW Minimization Program
1L HW Research and Information Center
IN Dept. of Env. Mgmt.
1A Dept. of Natural Resources
KY Partners, State Waste Reduction Center
Toxics Use Reduction Institute
University of Detroit Mercy
Waste Management Education and Research
Consortium
Energy and Env. Research Center
Institute of Advanced Manufacturing Sciences
Center for Hazardous Materials Research
RI Center for P2, UR1
Clemson University
TX Natural Resource Conservation Commission
Retired Engineers and Professionals Program
WA State Dept. of Ecology
Wl Dept. of Natural Resources,
Small Business Assistance Program
WY Dept. of Env. Quality
Contact
Blake Roper,
Michael Sherman
Roy Nicholson
David Harley, Kim
Wilhelm, Kathy
Barwick
Michelle Mische
Marie Zanowich
David Thomas
Tom Neltner
Larry Gibson
Joyce St. Clair
Janet Clark
Daniel Klempner
Ron Bhada
Gerald Groenewold
Harry Stone, Sally
Clement
Roger Price, Steven
Ostheim
Stanley Barnett
Eric Snider
Andrew Neblett
Muriel Durgin
Peggy Morgan
Robert Baggot
Charles Raffelson
Telephone
(800) 533-2336
(205)271-7861
(205) 386-3633
(916)322-3670
(310)699-7411
(303) 294-1065
(217)333-8940
(317)232-8172
(515)281-8941
(502) 852-7260
(508) 934-3346
(313)993-3385
(505)646-1510
(701) 777-5000
(513)948-2050
(412) 826-5320
(401) 792-2443
(803) 656-0985
(512)239-3100
(802) 879-4703
(206) 407-6705
(608)267-3136
(307)777-7391
      Center for Waste Reduction Technologies
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                    Center for Waste Reduction Technologies, under the aegis of the American
                    Institute of Chemical Engineers, sponsors research on innovative technologies
                    to reduce waste in the chemical  processing  industries.   The primary
                    mechanism is through funding of academic research.

       National Science Foundation and the Office of Pollution Prevention and Toxics

                    The National Science Foundation and EPA'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.

       Chemical Manufacturers Association

                    The  Chemical Manufacturers 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.

       Responsible Care Program

                    The Responsible Care Program of the Chemical Manufacturers Association
                    requires members to pledge commitment to  six codes  that identify 106
                    management practices that companies  must carry out in the areas of
                    community awareness and emergency response, pollution prevention, process
                    safety, distribution, employee health and safety, and product stewardship.
       ISO 9000
                    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 begin work on new
                    standards for environmental management systems.  The new standards are
                    called ISO 14000 and are expected to be issued in 1996.
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                         Inorganic Chemicals
       VII.C.2. Summary of Trade Associations

Chemical Industry	
                    American Chemical Society
                    1155 16th Street, NW
                    Washington, D.C. 20036
                    Phone: (202) 872-8724
                    Fax: (202) 872-6206
                   Members: 145,000
                   Staff: 1700
                   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
                    services are Chemical Journals Online, containing the full text of 18 ACS
                    journals, 10 Royal Society of Chemistry journals, and 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.
                    Chemical Manufacturers Association
                    2501 MSt.,NW
                    Washington, D.C. 20037
                    Phone:(202)887-1164
                    Fax: (202) 887-1237
                    Members: 185
                    Staff: 246
                    Budget: $36,000,000
                    Contact: Joseph Mayhew
                    Presently, the principle focus of the Chemical Manufacturers Association
                    (CMA) is on regulatory issues facing chemical manufacturers at the local,
                    state, and federal level. At its inception in 1872, the focus of the CMA was
                    on serving chemical manufacturers through research. Research is still ongoing
                    at the CMA, however, as the CHEMSTAR program illustrates. CHEMSTAR
                    consists of a variety of self-funded panels working on single-chemical research
                    agendas. This research fits in with the overall regulatory focus of the CMA;
                    CHEMSTAR study results are provided  to both CMA membership and
                    regulatory agencies. Other initiatives include the "responsible care"  program.
                    Membership in the CMA is contingent upon enrollment in the "responsible
                    care" program, which includes six codes of management practice (including
                    pollution prevention) that  attempt to  "go beyond  simple regulatory
                    compliance." The 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: ChemEcology, a  10-
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Sector Notebook Project	Inorganic Chemicals
                    issue-per-year newsletter covering environmental, pollution-control, worker-
                    safety, and federal and state regulatory actions, and the CMA Directory, a
                    listing of the CMA membership. The CMA holds an annual meeting in White
                    Sulphur Springs, WV.

Chlor-alkali Industry	

                    The Chlorine Institute, Inc.
                    2001 L Street, N.W.
                    Suite 506
                    Washington, D.C. 20036                    Members: 200
                    Phone: (202) 223-2790                      Budget: $ 1,500,000
                    Fax: (202) 223-7225                        Contact: Gary Trojak

                    The Chlorine Institute, Inc. was established in 1924 and represents companies
                    in the U.S.,  Canada, and other countries that produce, distribute, and use
                    chlorine, sodium and potassium hydroxides, and sodium hypochlorite; and that
                    distribute and use hydrogen chloride. The Institute is a non-profit scientific
                    and technical organization which serves as a safety, health, and environmental
                    protection center for the industry.
                    Chlorine Chemistry Council
                    2501 M Street, N.W.                      Members: 30
                    Washington, D.C. 20037                   Staff: 24
                    Phone: (202) 887-1100                    Budget: $14,000,000
                    Fax: (202) 887-6925                       Contact: Kip Howlett Jr.

                    The Chlorine Chemistry Council (CCC), established  in 1993, is a business
                    council of the Chemical Manufacturers Association (CMA) and is made up of
                    producers  and users  of chlorine and chlorine-related  products.  With
                    involvement from all stakeholders, the CCC works to promote science-based
                    public policy regarding chlorine chemistry and is committed to develop and
                    produce only those chemicals that can be manufactured, transported, used,
                    and disposed of safely.  CCC facilitates risk-benefit analyses and product
                    stewardship through the collection, development, and use of scientific data on
                    health, safety,  and  environmental  issues.  CCC hopes to heighten public
                    awareness of chlorine chemistry and its many societal benefits by collaborating
                    with  the  public   health  and   scientific community  in  assessing  and
                    communicating chlorine-related human health and environmental issues.
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                           Inorganic Chemicals
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY

                      For further information on selected topics within the inorganic chemicals
                      industry a list of contacts and publications are provided below:

Contactsf
Name
Walter DeRieux
Sergio Siao
lliam Rosario
George Zipf
Rick Brandes
Ed Burks
Jim Gold
Organization
EPA/OECA
EPA/NE1C
EPA/OAQPS
EPA/OW
EPA/OSWER
EPA/Region IV
EPA/Region VI
Telephone
(202) 564-7067
(303) 236-3636
(919)541-5308
(202) 260-2275
(202) 260-4770
(404) 347-5205
(713)983-2153
Subject
Regulatory requirements and compliance
assistance
Industrial processes and regulatory
requirements
Regulatory requirements (Air), Chlorine
NESHAPs
Regulatory requirements (Water)
Regulatory requirements (Solid waste)
Inspections, regulatory requirements
(RCRA)
Inspections and regulatory requirements
(Water, AIR and TSCA)
OECA: Office of Enforcement and Compliance Assistance
NEIC: National Enforcement Investigations Center
OAQPS: Office of Air Quality Planning and Standards
OW: Office of Water
OSWER: Office of Solid Waste and Emergency Response
General Profile
U.S. Industrial Outlook 1994, Department of Commerce

1987 Census of Manufacturers, Industry Series, Industrial Inorganic Chemicals, Bureau of the
Census [Published every five years the next version will be available in September of 1994]

1992 Census of Manufacturers, Preliminary Report Industry Series, Industrial Inorganic Chemicals,
Bureau of the Census [Data will be superseded by a more comprehensive report in September of
1994]
f Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements make within this notebook.
September 1995
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 Chlorine and Its Derivatives: A  World Survey of Supply, Demand, and Trade to 1992, Tecnon
 Consulting Group, London, 1988.

 North American Chlor-Alkali Industry Plants and Production Data Book, Pamphlet 10, The Chlorine
 Institute, Washington, D.C., January, 1989.

 Process Descriptions and Chemical Use Profiles	

 Riegel's Handbook of Industrial Chemistry, 9th ed., Kent, James A., Ph.D., editor, Van Nostrand
 Reinhold, New York, 1993.

 Kirk-Othmer Encyclopedia of Chemical Technology, Fourth edition, volume 1, John Wiley and Sons,
 New York, 1994.

 Buchner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry, VCH Publishers, New York,
 1989.

 Multi-media Assessment of the Inorganic Chemicals Industry, Chapter 12-Salt Derivatives, Prepared
 for U.S. EPA Industrial Environmental Research Laboratory by Verser, Inc., Springfield, Virginia,
 1980.

 Recommendations To Chlor-alkali Manufacturing Facilities for the Prevention  of  Chlorine
 Releases, The Chlorine Institute, First Edition, October, 1990.

 Assessment of Solid  Waste Management Problems and Practices in the Inorganic Chemicals
 Industry,  Final  Report, Versar,  Inc.  for U.S. Environmental  Protection  Agency,  Industrial
 Environmental Research Laboratory, Cincinnati, Ohio, April 1979.

 Chlorine, Its Manufacture, Properties, and Uses, J.S. Sconce, Reinhold Publishing Corp., New York,
 1962.

 Electrolytic Manufacture of Chemicals from Salt, D.W.F. Hardie and W.W. Smith, The Chlorine
 Institute, New York, 1975.

 Modern Chlor-Alkali Technology, Vol. 4, N.M. Prout and J.S. Moorhouse, eds., Elsevier Applied
 Science,  1990.

 Regulatory Profile	

 Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St. Paul, Minn.,
 1993.

 Development Document for Effluent Limitations Guidelines and New Source Performance Standards
for the Major Inorganic Products Segment of the Inorganic Chemicals Point Source Category, U.S.
 Environmental Protection Agency, Washington, D.C., March 1974. Report No. EPA-440/l-74-007a.
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                                     ENDNOTES

1.  U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.

2.  U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers,
Industrial Inorganic Chemicals. April 1995.

3.  U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.

4.  U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers,
Industrial Inorganic Chemicals. April 1995.

5.  Buchner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

6.  Ibid.

7.  U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers,
Industrial Inorganic Chemicals. April 1995.

8.  Charles River Associates. Chlorine Chemistry Plays a Vital Role in the U.S. Economy.
Washington, D.C.: The Chlorine Institute, 1993.

9.  Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

10. U.S. Department of Commerce.  U.S. Industrial Outlook 1994.  January 1994.

11. Ibid.

12. Ibid.

13. Ibid.

14. Ibid.

15. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

16. Buchner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

17. Ibid.

18. Ibid.

19. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.
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20. Biichner, Schliebs, Winter, Biichel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

21. Ibid.

22. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

23. Ibid.

24. Ibid.

25. Ibid.

26. Biichner, Schliebs, Winter, Biichel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

27. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

28. Ibid.

29. Ibid.

30. Biichner, Schliebs, Winter, Biichel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

31. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

32. Ibid.

33. Ibid.

34. Ibid.

35. Ibid.

36. Ibid.

37. Ibid.

38. Ibid.

39. Versar, Inc. Multi-Media Assessment of the Inorganic Chemicals Industry. Ch. 12.
Cincinnati, Ohio: U.S. EPA Industrial Environmental Research Laboratory, August, 1980.

40. Versar, Inc. Multi-Media Assessment of the Inorganic Chemicals Industry. Ch. 12.
Cincinnati, Ohio: U.S. EPA Industrial Environmental Research Laboratory, August, 1980.

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41. Ibid.

42. Ibid.

43. Ibid.

44. Ibid.

45. Ibid.

46. Ibid.

47. Ibid.

48. Ibid.

49. Ibid.

50. Ibid.

51. Ibid.

52. Ibid.

53. Ibid.

54. Ibid.

55. U.S. EPA Office of Pollution Prevention and Toxics. 1993 Toxics Release Inventory Public
Data Release. May 1994.

56. Ibid.

57. Kent, James A. Ph.D., editor. Riegel's Handbook of Industrial Chemistry, 9th ed. New York:
Van Nostrand Reinhold, 1993.

58. Ibid.

59. Ibid.
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