United S
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Internet Address (URL) •http://www.epa.gov
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For more information, please contact
U.S. Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Office of Compliance
Chemical, Commercial Services, and Municipal Division
Chemical Industry Branch
(202) 564-2310
The Chemical Industry Branch is grateful for the assistance of the Enforcement
Planning, Targeting, and Data Division within the Office of Compliance, U.S.
Environmental Protection Agency (EPA), and peer reviews provided by the
various EPA regional and program offices, as well as external peer reviews
provided by:
Louisiana Department of Environmental Quality
Michigan Department of Environmental Quality
Missouri Department of Natural Resources
New York Department of Environmental Conservation
Pennsylvania Department of Environmental Protection
Wisconsin Department of Natural Resources
Chemical Manufacturers Association
Disclaimer: This document has been reviewed in accordance with U.S. Environmental Protection Agency administrative
review policy and approved for publication. Mention of trade names or commercial products does not constitute endorse-
ment or recommendation of their use.
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CONTENTS
PAGE
EXECUTIVE SUMMARY
ES.A. Section 2 - Overview of the Chemical Industry ES-4
ES.B. Section 3 - Trends in Releases and Transfers Reported
by the Industry to the Toxics Release Inventory (TRI) ES-5
ES.C. Section 4 - Trends in Compliance
Monitoring Activities and Violations ES-6
ES.D. Section 5 - Promoting Environmental Performance Through
Compliance Promotion, Enforcement, and Compliance Assurance ES-6
ES.E. Future Directions ES-7
I. INTRODUCTION
1 .A. U.S. Environmental Protection Agency's (EPA)
Approach to Compliance Assurance 3
l.B. Role of the Chemical Industry Branch in EPA's Compliance
Assurance Program 4
l.C. Joint Initiatives of EPA and the Chemical Industry 4
l.D. Purpose of the Report 5
I.E. Scope of the Report 5
I.F. Methodology and Data Limitations 5
l.G. Organization of the Report : 6
2. INDUSTRY OVERVIEW
2.A. Industry Background 9
2.B. Number of Chemical Facilities 14
2.C. Chemical Facilities and Low-Income
and Minority Communities 16
2.D. Facility Employment 17
3. TRI DATA
3.A. Chemical Industry Trends (1990 to 1994) 22
3.B. TRI Data for All Industries (1994) 23
3.C. TRI Data for the Chemical Industry (1994) 25
3.D. National Trends for All Industries (1990 to 1994) 26
3.E. National Trends for the Chemical Industry (1990 to 1994) 26
3.F. Five Chemicals Released in the Greatest Quantities
by the Chemical Industry (1990 to 1994) 27
4. COMPLIANCE MONITORING ACTIVITIES AND VIOLATION
TRENDS BY ENVIRONMENTAL STATUTE
4.A. Definition of Terms: Compliance Monitoring and Violations 34
4.B. Chemical Industry Sector Multi-Media Compliance Trends : 35
4.C. Clean Water Act (CWA) ! : 35
4.D. Clean Air Act (CAA) 36
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Contents
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
........ * .....
I- ..... 1
I ........... •< .......... !
4.E. Resource Conservation and Recovery Act (RCRA) 37
4.F. Toxic Substances Control Act (TSCA) 38
4.G. Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) 39
4.H. Emergency Planning and Community Right-to-Know Act (EPCRA) 40
5. PROMOTING ENVIRONMENTAL PERFORMANCE
THROUGH COMPLIANCE PROMOTION,
ENFORCEMENT, AND COMPLIANCE ASSURANCE
5.A. Definition of Enforcement Actions 43
5.B. Chemical Industry Sector Multi-Media Enforcement Trends 44
5.C. Clean Water Act (CWA). 45
5.D. Clean Air Act (CAA) 45
5.E. Resource Conservation and Recovery Act (RCRA) 46
5.F. Toxic Substances Control Act (TSCA) 46
5.G. Compliance Assurance 46
5.H. New Incentive Policies 51
5.1. Supplemental Environmental Projects (SEP) , 51
5.J. Pollution Prevention Program 52
5.K. Environmental Leadership Program 52
5.L. Success Stories 52
5.M. Trade Associations/Industry Sponsored Activities 58
6. FUTURE DIRECTIONS
ENDNOTES
APPENDIX A — ACRONYMS . A-1
APPENDIX B — GLOSSARY OF KEY TERMS B-1
APPENDIX C — ENVIRONMENTAL STATUTES
AND REGULATIONS C-l
APPENDIX D — LOCATIONS OF CHEMICAL FACILITIES D-1
APPENDIX E — TRI RELEASES AND TRANSFERS
BY FOUR-DIGIT SIC CODE E-1
APPENDIX F — COMPLIANCE MONITORING ACTIVITIES
SUMMARY BY FOUR-DIGIT SIC CODE F-l
FIGURES
ES-1. Chemical Facilities in the United States, 1994 ES-5
1-1. Utilizing the Mix 3
1-2. Organizational Chart 4
2-1. Leading Exports in the World Manufacturers Market, 1993 10
2-2. Composition of World Goods Trade, 1994 10
2-3. Chemicals Traded on the Manufacturers Market, 1994 10
2-4. Chemicals Traded on the World Goods Market, 1994 10
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SIC 2800
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2-5. Chemical Industry World Trade Growth, 1993 11
2-6. Composition of World Chemical Exports, 1993 11
2-7. EPA Regions , 14
2-8. Number of Chemical Facilities by EPA Region, 1995 14
2-9. Percentage of Chemical Facilities by EPA Region, 1995 14
2-10. National Summary of Chemical Facilities by
Primary Standard Industrial Classification (SIC) Code, 1995 15
2-11. National Summary of Chemical Facilities by
Number of Employees, 1995 16
2-12. Number of Chemical Industry Employees by
EPA Region, 1995 16
2-13. Percentage of Chemical Industry Employees by EPA Region, 1995 17
2-14. Average Population per Square Mile by EPA Region, 1995 17
3-1. Total Release Trends, 1990 to 1994 22
3-2. Carcinogenic Release Trends for Chemical Industry, 1990 to 1994 22
3-3. Transfer Trends for Chemical Industry, 1990 to 1994 22
3-4. Distribution of TRI Releases for All Industries, 1994 23
3-5. Distribution of TRI Transfers for All Industries, 1994 23
3-6. Industry Categories that Reported the Largest
Quantities of On-Site TRI Releases for All Industries, 1994 24
3-7. Industry Categories that Reported the Largest
Quantities of TRI Transfers, 1994 24
3-8. Industry Categories that Reported the Largest
Quantities of Releases of Carcinogens, 1994 24
3-9. Total TRI Releases for Chemical Industry, 1994 25
3-10. Total Air Emissions for Chemical Industry, 1994 25
3-11. Surface-Water Discharges for Chemical Industry, 1994 26
3-12. Underground Injection Releases for Chemical Industry, 1994 26
3-13. Releases to Land for Chemical Industry, 1994 26
4-1. Compliance Monitoring Activities Trends
by Three-Digit SIC Code, 1990 to 1994 34
4-2. Violation Trends by Three-Digit SIC Code,
1990 to 1994 1 35
4-3. CWA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994 35
4-4. CAA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994 36
4-5. RCRA Compliance Monitoring Activities and
Violation Trends, 1990 to 1994 37
4-6. TSCA Compliance Monitoring Activities and
Violation Trends, 1990 to 1994 38
4-7. FIFRA Compliance Monitoring Activities and
Violation Trends, 1990 to 1994 39
4-8. EPCRA Compliance Monitoring Activities and
Violation Trends, 1990 to 1994 40
5-1. Enforcement Actions by Industry Sector,
1990 to 1994 44
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Contents
iii
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
5-2. CWA Enforcement Actions, 1990 to 1994 45
5-3. CAA Enforcement Actions, 1990 to 1994 45
5-4. RCRA Enforcement Actions, 1990 to 1994 46
5-5. TSCA Enforcement Actions, 1990 to 1994 '.... ;, 46
TABLES
ES-1. Comparison of National and Chemical Industry
TRI Trends, 1990 to 1994 ES-5
ES-2. Comparison of Compliance Monitoring Activities and
Violations, 1990 and 1994 (all statutes)., ES-6
2-1. Major Chemical Industry Sectors ... 9
2-2. Specific Chemical Industry Sectors 9
2-3. State and Regional Information, 1995 18
3-1. Total Quantities of TRI Releases for All Industries, 1994 23
3-2. Total Quantities of TRI Transfers for All Industries, 1994 24
3-3. Total Quantities of TRI Releases, 1994 , 25
3-4. TRI Trends for All Industries, 1990 to 1994 ,.' 27
3-5. TRI Trends for All Industries, Summary of 1990 to 1994 27
3-6. TRI Trends for Chemical Industry, Summary of 1990 to 1994 27
3-7. Top Five Chemicals Released in the Greatest Quantities
by the Chemical Industry, 1990 to 1994 28
3-8. Top Five Carcinogenic Chemicals Released in the Greatest
Quantities by the Chemical Industry, 1990 to 1994 29
3-9. Top Five Chemicals Transferred in the Greatest Quantities by the
Chemical Industry, 1990 to 1994 30
4-1. CWA Data, 1990 to 1994 35
4-2. CAA Data, 1990 to 1994 , 36
4-3. RCRA Data, 1990 to 1994 37
4-4. TSCA Data, 1990 to 1994 38
4-5. FIFRA Data, 1990 to 1994 39
4-6. EPCRA Data, 1990 to 1994 40
5-1. Ratio of Enforcement Actions to Compliance Monitoring
Activities, 1990 to 1994 44
5-2. CWA Data, 1990 to 1994 45
5-3. CAA Data, 1990 to 1994 45
5-4. RCRA Data, 1990 to 1994 46
5-5. TSCA Data, 1990 to 1994 46
5-6. Hotline Assistance 48
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October 1997
SIC 2300
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SUMMARY
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EXECUTIVE SUMMARY
Chemical Industry
Environmental
Baseline Report
1990 to 1994
The U.S. Environmental Protection Agency (EPA) developed this report as a baseline
against which to measure compliance trends among the various subsectors of the
chemical manufacturing industry. Through an analysis of data related
to economics, demographics, the Toxics Release Inventory (TRI), compliance
monitoring actions, and violations and enforcement actions, the baseline report provides
an overview of the U.S. chemical industry sector as a whole (Standard Industrial
Classification [SIC] codes in the 2800 series) and its subsector components (SICs 281
to 289). It is intended for use by regulators, states, industry, and the public as a general
profile of the chemical industry and its environmental performance from 1990
to 1994. The baseline report provides information that may serve as a catalyst for the
development of innovative compliance initiatives and similar profiles for this and other
sectors on a state or regional basis.
Data presented in this report also may be of use to EPA in evaluating environmental
performance and identifying specific segments of the industry that might benefit from
tighter enforcement and expanded compliance monitoring. It may be possible, through
a comparison of environmental performance, risk-based criteria, and other factors, to
select certain industrial sectors for special assistance and outreach efforts, maximize
efficiency in the use of resources for traditional enforcement activities, and fashion
custom compliance assistance programs to meet the unique needs of specific industry
groups. Through such activities, the agency can promote efforts to achieve
and maintain compliance, and industry can attain a higher level of environmental
performance.
By presenting a national environmental compliance history for the first half of the decade
(1990 through 1994), the baseline report provides information that begins to establish
relative trends among the various four-digit SIC codes that make up the chemical
industry. In addition, the number of facilities and chemicals included in TRI is to be
expanded. When the report was drafted, complete data were available for all portions of
the report, up to and including 1994. During summer 1997, TRI data for 1995 were
released. Since the peer review process for this report started before the release of the
1995 TRI data, the baseline report does not include data for that year.
The baseline report is useful to help quantify historical compliance trends for the
industry, as well as to focus future compliance efforts. The baseline report also can
allow for enhanced sector-based compliance monitoring and will facilitate strategic
planning for the various sectors. This strategic planning allows for in-depth analyses
of compliance for the industry. The U.S. Environmental Protection Agency (EPA)/
Chemical Manufacturers Association (CMA) Root-Cause Analysis Project and sector-
based EPA headquarters/regional office Memoranda of Agreement (MOA) are examples
of such analyses.
In addition, the baseline report serves as a framework for implementing the Operating
Principles for an Integrated EPA Enforcement and Compliance Assurance Program,
published by the Office of Enforcement and Compliance Assurance (OECA) as an
interim draft in November 1996.
Some of the areas in which the baseline report fulfills the objectives stated in OECA's
operating principles are:
• It provides information on enforcement and compliance monitoring activities.
• 'It evaluates industry environmental performance through multi-year trend
analysis.
Executive Summary
ES-3
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
• It provides information in the form of outreach to the public and the regulated
community regarding environmental performance.
The information in the report is presented in four major areas: 1) an overview of the chemical
industry, including the number, sizes, and types of chemical facilities located in the U.S.;
2) a summary of trends in releases and transfers reported to the TRI; 3) trends in compliance
monitoring activities and violations, by statute and by SIC code, over time; and 4) trends in
enforcement actions and descriptions of innovative approaches to enforcement that have been
used to boost compliance.
SUMMARY OF FINDINGS
ES.A. Section 2 - Overview of the Chemical Industry
Section 2 of this report provides background information about the chemical industry.
The chemical industry, which falls in the 2800 SIC code series, has eight industry groups:
281 - inorganic chemicals
282 - plastic materials and synthetics
283 - drugs
284 - soaps, cleaners, and toilet goods
285 - paints and allied products •
286 - organic chemicals
287 - agricultural chemicals
289 - miscellaneous chemical products
Figure ES-1 shows the locations of chemical manufacturing facilities in the U.S.
This section briefly defines the chemical industry's role in U.S. and world economies as a
leading employer, producer, and exporter of goods. Section n also identifies the number,
types, sizes, and geographical distribution of chemical facilities located in the U.S. and
provides an overview of the major environmental statutes,that affect the chemical industry.
Findings
Data presented in this section indicate that:
• The U.S. chemical industry is the largest producer of chemicals in the world, with
approximately 2,800 affiliates abroad.
• The U.S. chemical industry is a leader in U.S. and world markets and is the largest
U.S. export sector, providing one of every 10 dollars of U.S. export of goods. The
U.S. chemical industry is surpassed in total world export of goods only by the
automotive sector.
• Between 1981 and 1993, world trade in chemicals increased from $124 billion to
$309 billion, or 149 percent. World production of chemicals rose only 67.3 percent
in that period.
• Since 1984, the U.S. chemical industry has maintained a trade surplus totaling
about $140 billion—$15 billion in 1993 alone.
• According to 1995 records provided by Dun and Bradstreet Information Services, Inc.,
20,676 facilities declare that chemical processing is one of their top five operations.
• Of the 10 EPA regions in the U.S., EPA Region 5 (Minnesota, Wisconsin, Illinois,
Indiana, Michigan, and Ohio) is the location of the largest number of chemical
facilities (21 percent of total), as well as the largest number of industry employees
(25 percent of total).
ES-4
October 1997
SSC2800
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure ES-1.
Chemical Facilities in the United States, 1994'
3*7^7—
*•*». •**( \ *i
I •tJm »L-«J!55!._Jrr»
r---? r\5.«
5. - - Li. *«* li.
Chemical Facilities
• The chemical industry is characterized by a predominance of small facilities; more " _ _j
than 50 percent have fewer than 10 employees.
• Locations of chemical facilities generally are chosen because they offer access to
raw materials, transportation routes, and markets.
ES.B. Section 3 - Trends in Releases and Transfers
Reported by the Industry to the Toxics Release
Inventory (TRI)
Section 3 of this report provides information about trends, both overall and for the
chemical industry, associated with releases and transfers of listed chemicals as
reported to the TRI, as mandated under the Superfund Amendments and
Reauthorization Act (SARA) Title III,
known as the Emergency Planning and Table ES-1,
Community Right-to-Know Act (EPCRA).
Findings
• As depicted in Table ES-1, the
chemical industry has followed
the national trends that demon-
strate a reduction in the release of
chemicals and carcinogenic
chemicals over time (although to
a lesser extent), notwithstanding
an increase in production. "•' Please see Endnotes Section.
r . Trend reported is from 1991 to 1994 because of significant changes in the reporting requirements
Moreover, the chemical industry for TRI transfers.
TRI Category
Chemicals released
Carcinogenic chemicals
released
Chemicals transferred*
National Trend
All Industries
52.1 percent decrease
16.9 percent decrease
4. 1 percent increase
Chemical Inc
43.5 percent de
15.9 percent de
13.5 percent de
Executive Summary
ES-5
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
it' ui
|ll
I
I
reduced the quantity of chemicals transferred over time, while the national
statistic for all industries showed a slight increase.
• In 1994, the chemical industry reported the largest quantities of carcinogens
released, the largest quantities of total pounds released, and the largest quanti-
ties transferred each year, compared with all other industries that reported.
ES.C. Section 4 - Trends in Compliance Monitoring
Activities and Violations
Section 4 of this report provides information about trends in compliance monitoring
activities and violations for the chemical industry. Using data obtained from the EPA
Integrated Data for Enforcement Analysis (IDEA) database, the report presents summa-
ries of compliance monitoring activities conducted and violations identified at chemical
facilities from 1990 through 1994. Raw numbers of violations were counted, but no
attempt was made to characterize the magnitude of the violations.
Findings
• Nationwide, from 1990 through 1994, EPA and states conducted 48,037
compliance monitoring activities, identified 17,807 violations, and initiated
10,360 enforcement actions at chemical facilities.
• As Table ES-2 shows, the number of violations identified under all programs
increased 37.6 percent between 1990 and 1994. Compliance monitoring
activities decreased by 4.5 percent during the same time period. For specific
changes in each of the industry groups in the 2800 SIC code series, please see
Appendix F.
ES.D. Section 5 - Promoting Environmental
Performance Through Compliance Promotion,
Enforcement, and Compliance Assurance
Section 5 describes EPA's response to noncompliance, either through enforcement
actions or through certain programs that EPA developed to assist in improving the
compliance status of the regulated community. This section also provides some
success stories about cases in which the chemical industry has participated in
innovative approaches to ensure compliance.
Table ES-2.
Comparison of Compliance Monitoring Activities and Violations,
--:". ,.?»^««&I*$4|»ft»f«^^
Category
Compliance
Monitoring
Activities
Violations
1 990 1 994 1 990 to 1 994
Annual Average
9,842 9,401 9,606
2,539 3,494 3,561
1990 to 1994
Percent Change
4.5 percent decrease
37.6 percent increase
ES-6
October 1997
sir oann
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Chemical Industry
Ncrfroncvf
Environmental
Baseline Report
1990 to 1994
In addition to the use of traditional compliance tools, EPA has developed incentives,
assistance programs, and strategies to help ensure compliance. A strategic combination
of traditional enforcement actions and other, more innovative activities allows EPA to
best apportion and leverage its resources and promote the highest possible level of
compliance with environmental requirements. The success stories illustrate ways in
which EPA and the chemical industry have worked together to attain compliance in the
following areas:
• Compliance assistance tools
• New incentive policies
• Supplemental environmental projects (SEP)
• Pollution prevention programs
• Environmental Leadership Program (ELP)
ES.E. Future Directions
This report provides information that can serve as a reference point for the following
compliance monitoring and enforcement activities:
• Cooperative efforts and partnerships between EPA and the chemical industry
continue to demonstrate the importance of compliance with environmental
regulations.
• New agency initiatives to ensure compliance are moving beyond the traditional
unilateral approach to enforcement to approaches that consider members of the
chemical industry equal partners in the search for environmental excellence.
Examples of such initiatives include the EPA/CMA Root-Cause Analysis
Project, the Community-Based Environmental Protection (CBEP) initiative,
and the development of additional compliance assistance tools.
• Promoting responsible management practices will require that components
of traditional enforcement activity remain essential program activities.
• Baseline information presented in this report will provide a basis to chart
progress and help to refine the focus of innovative approaches to compliance
in the future.
Executive Summary
ES-7
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CHEMICAL INDUSTRY ENVIRONMENTAL
BASELINE REPORT 1990 TO 1994
1. INTRODUCTION
This section provides background on the U.S. Environmental Protection Agency's (EPA)
approach to compliance activities, the role of the Chemical Industry Branch (CIB) of the
Office of Enforcement and Compliance Assurance (OECA) at EPA; current joint initia-
tives of EPA and the chemical industry; and descriptions of the purpose, scope, methodol-
ogy used, data limitations, and organization of this report. All information for which
references are provided is noted with a superscript letter; those references are provided in
the endnotes.
1 .A. EPA's Approach to Compliance Assurance
For nearly 25 years, EPA relied on the use of enforcement authorities to ensure compli-
ance with environmental statutes and regulations. However, while maintaining its
enforcement efforts, EPA has developed new elements of its approach to compliance
assurance. This new approach has five distinct elements11:
1 A broader mission: Fostering environmental accountability, that is, account-
ability for environmental results, rather than merely the fulfillment of regulatory
obligations.
2 A set of new relationships: Developing partnerships with industry, states, and the
public to ensure compliance and promote operating principles that go beyond
compliance.
3 A shift in strategic assumptions: Recognizing constraints on resources and
placing greater emphasis on setting priorities, directing government resources
toward problems of greatest concern, and focusing on multi-media, sector, and
geographic issues.
ll A more diverse mix of tactics: Using various techniques promoting compli-
ance, recognizing excellence, and informing the public about companies'
environmental performance. ^
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
COMPLIANCE ASSISTANCE
:*Cotnpiiance'Assistance Centers
'''Policies and Environmental.!^,-"'•
EnvrrorimentalA'-"1'-'-'^"^'-
§ A more sophisticated method
of measuring effectiveness:
Developing measures that
reflect the levels of compliance
of various sectors and charac-
terizing the environmental
improvements and benefits
that result from compliance.
EPA reorganized its enforcement program
in June 1994, when it consolidated the
Agency's five enforcement and compliance
programs into OECA. EPA has worked with various stakeholders
to implement its new agenda and has demonstrated progress in using
the mix of approaches to obtain regulatory compliance (see Figure
1-1). For example, EPA has developed and is implementing the Self-
Disclosure Incentives Program Policy and the Policy on Compliance
Incentives for Small Business. EPA also has established compliance
assistance service centers for specific industries.
COMPLIANCE MONITORING
Inspection Guidance
Figure 1 -1.
Utilizing the Mix.
ENFORCEMENT ACTIONS
Civil and Judicial Referrajs "'""^
Administrative Actions*^
_ Injunctive Relief«i <>,».i
' Criminal Sanctions " s'rt '
Civil Penalties and Supplemental
Environmental Projects (SEPs)-'
INCENTIVE PROGRAMS
Project Excellence In Leadership (XL)
Environmental Leadership
Program (ELP)" * •
Common Sense Initiative (CSt)
REGULATORY COMPLIANCE
Introduction
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 1 -2.
Organizational Chart.
Office of Enforcement and
1 .B. Role of the Chemical Industry Branch in EPA's
Compliance Assurance Program
The GIB is located in OECA, under the Office of Compliance, within the Chemical,
Commercial'Services, and Municipal Division of EPA (see Figure 1-2).
The GIB assists OECA in developing and implementing a national, sector-based, multi-
media program of compliance activities for the chemical industry in the 2800 series of
the Standard Industrial Classification (SIC) system. To obtain a clearer picture of the
compliance issues and problems confronting the chemical industry, as
well as to obtain a better understanding of its own strengths and of
potential areas for improvement, CIB periodically assesses the perfor-
mance of chemical facilities with respect to environmental statutes and
programs.
f
Environmental requirements that may affect the chemical industry range
from federal statutes and their implementing regulations to state and local
laws and ordinances. Such legislation includes the Resource Conserva-
tion and Recovery Act (RCRA); the Clean Water Act (CWA); the Clean
Air Act (CAA); the Safe Drinking Water Act (SDWA); the Toxic Sub-
stances Control Act (TSCA); the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA); and the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA). EPA, in
Conjunction with the states, has oversight responsibility for facilities'
environmental compliance. To fulfill the Agency's oversight responsibility, CIB and
other offices of OECA conduct a broad range of activities, including:
• Development of policy and guidance
• Support for regional programs
• Support for interagency agreements (LAG)
• Support for national programs and dissemination of information
• Technical assistance and capacity building
Through EPA's network of regional offices and through state agencies, staff of the
CIB and OECA monitor and respond to detected noncompliance.
1 .C. Joint Initiatives of EPA and the Chemical Industry
The chemical industry is participating in several EPA initiatives, such as the Environmen-
tal Leadership Program, and Project XL. EPA currently is working closely with the
CMA and its member companies to implement the EPA/CMA Root-Cause Analysis
Project. The ultimate goals of the project are to:
• Verify currently available information and analyze compliance and enforce-
ment trends from 1990 to 1995 for certain CMA member facilities
• Identify fundamental causes of violations
• Develop innovative prevention-oriented compliance management options to
eliminate or reduce noncompliance.
The purpose for performing the EPA/CMA Root-Cause Analysis Project is to identify
the underlying reasons for noncompliance and to use that information to assist in not
only correcting the problem but also preventing repeat violations.
October 1997
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Chemical Industry
1 .D. Purpose of the Report
The purpose of this report is to provide a general profile of the chemical industry.
Because this is a baseline report, it establishes a point of reference for profiling the
chemical industry. The report will be used as a benchmark to be compared with the
future activities and accomplishments of the industry and EPA. The report also is
intended to identify areas in which additional research could further focus CIB's compli-
ance activities.
CIB's efforts include developing and providing information that assists the general public,
regulators, and the industry in becoming more knowledgeable about EPA's responses to
the environmental status of the chemical industry at large. This report, which is a central
element of that understanding, is intended to assist in building effective partnerships with
stakeholders to jointly develop solutions to compliance issues.
I.E. Scope of the Report
This report provides an overview of compliance trends and status by analyzing compli-
ance and enforcement trends and environmental loadings from 1990 to 1994 for the 2800
SIC code series.
The report analyzes trends in environmental protection activities at chemical facilities
and displays the following information by fiscal year (October 1 to September 30) by
EPA region for all 2800 SIC code series:
• Number and location of facilities
• Number of employees
• Chemical emissions levels (TRI data)
• Frequency and types of compliance monitoring actions, violations,
and enforcement actions, by statute
This report makes no attempt to assess the effectiveness or accomplishments of EPA and
state programs or the overall effects on human health or the environment that result from
activities of EPA or the chemical industry. Because this report focuses on the entire
chemical industry, data are presented in the aggregate, rather than by individual facility
or corporation. Raw numbers of violations were counted, but no attempt was made to
characterize the magnitude of the violations.
This report also is consistent with the operating principles established to integrate EPA and
state enforcement and compliance assurance efforts. Specifically, these principles obligate
EPA to be accountable to the public and to report the enforcement and compliance rates for
each industry to assess industry performance. In addition, EPA will report the enforcement.
and compliance rates to measure the environmental effects and results of these activities.
1 .F. Methodology and Data Limitations
To establish the baseline, a relational database was used. The database was constructed
from readily available data, such as data from Dun and Bradstreet Information Services,
Inc. (D&B), information about environmental loadings from TRI reports provided to EPA
by facilities, and environmental compliance histories from EPA's multi-media Integrated
Data for Enforcement Analysis (IDEA) system, which includes data that reflect state and
federal activities.
Environmental
Baseline Report
1990 to 1994
1
Introduction
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Chemical Industry
National
Environmental
Baseline Report
199O to 1994
The baseline was established by conducting a series of queries. Three general areas
were examined:
1 Establishing the size (both total number and sizes of individual facilities) and
geographic location of the industry;
2 Gathering general information on chemical releases and transfers; and
3 Developing a compliance history for each environmental statute.
The baseline was constructed by conducting a review of the 2800 SIC code'series by
numbers of TRI releases and transfers reported and compliance monitoring activities,
violations, and enforcement actions. The data were broken down further by number of
employees per facility.
Industry overview data were drawn from a variety of sources. The demographic information
presented in the report was drawn largely from information provided by the Bureau of the
Census, U.S. Department of Commerce. Demographic information presented herein
includes population and number of facilities, by state. The baseline uses Census data (for
employment and economics) and not Bureau of Labor statistics because Census data more
closely represents chemical manufacturing facilities which are the focus of the report (not
corporate entities).
It bears mentioning that this report may have been affected by the quantity and quality
of data available for use in preparing it. CIB has made no effort to modify raw data for
quality assurance and quality control (QA/QC) or to normalize the data sets. EPA
currently is conducting efforts to improve the quality of its existing data. Future
baseline reports should benefit from those efforts. (See Section 4, Compliance Monitor-
ing Activities and Violation Trends by Environmental Statute.)
In preparing this report, CIB consulted relevant EPA offices to ensure that the type of
compliance data presented herein and the format in which they are presented are
consistent with those used by the respective EPA programs.
1 .G. Organization of the Report
The report has the following sections:
Section 1: Introduction
Section 2: Industry overview
Section 3: Toxics Release Inventory (TRI) data
Section 4: Compliance monitoring activities and violation trends by
environmental statute
Section 5: Promoting environmental performance through compliance
promotion, enforcement, and compliance assurance
Section 6: Future directions
Endnofes: Description of data sources used
Appendices: Appendices that present supplemental information, including
a list of acronyms; a glossary of key terms used; summaries of
some of the federal environmental statutes and regulations that
affect this industry sector; location of facilities; TRI data; and
compliance data.
October 1997
cir
-------
INDUSTRY
OVERVIEW
»$&,/$&&'' .'£&$£ * ' £%•,&,
-------
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
2. INDUSTRY OVERVIEW
P^^^^^^^^^^^K^«^^^^^^^^gp^
This section provides general demographic and economic information
, / , . . . f , , ,. , .,-.,.. _,
about the chemical industry, the number of chemical facilities, and .
Table 2-1.
emplovment at individual facilities. SIC Industry Sector _
__ i i . n i i 281 Inorganic Chemicals
2.A. Industry Background „„„ _ . „ . , ^ 0 u .
„,,-„. ,. -j i_ • rj • *• r.uL-i 282 Plastic Materials and Synthetics
The following subsections provide a brief description of the chemical
industry, including a discussion of the Standard Industrial Classification 2^3 Drugs
(SIC) code system; types of facilities that make up the chemical 284 Soaps, Cleaners, and Toilet Goods
industry; products produced; the role of the chemical industry in the 285 Paints and Allied Products
U.S. and world economies; the environmental regulatory context within jsg Organic Chemicals
which the chemical industry operates; distribution of facilities, as it is
related to minority communities; and industry employment. 287 Agricultural Chemicals
289 Miscellaneous Chemical Products
2. A.I. SIC Code Classification. For purposes of the analysis in
this report, the chemical industry is described by SIC code. The Bureau of the
Census uses the SIC code system to track the movement of goods and services
w/itriiti 'trip TT ^ Ai^nnrvnrv Thf* r*h/atnii"'£i1 itiHncf"t*v ffillc intn tlif* ^ITf1 Tmnot* ornun
W .11111 11 ' II1C LJ.O. C^UllUlllj'. 1 11C dltxilllVCU lllUUaliy lo.Ha 1111U 11 1C OJA*' HldJUl glUUfJ
28, which is divided into the eight industry groups listed in Table 2-1.
Effective January 1, 1997, the SIC system changed to the North American
Industry Classification System (NAICS) (see 61 Federal Register 57006,
November 5, 1996). Data in the IDEA system for the trend period were not
gathered according to the NAICS code because the IDEA database uses the SIC
system for those years. For more information regarding NAICS, please visit the
U.S. Bureau of Census website at http://www.census.gov/epcd/www/.
2.A.2. Types of Facilities That Make Up the Chemical Industry.
The chemical industry is unique in that it encompasses numerous industries that
use widely varying processes. Therefore, the eight categories listed above are
subdivided further into 29 specific industry sectors at the four-digit level
(see Table 2-2).
For this report, industry sectors will be referred to by their specific sector names
and corresponding SIC codes. Database information is sorted by SIC code to •
allow consistent comparisons of data.
2.A.3. Chemical Industry Processes and Products. The discipline of
chemistry is divided into two branches: organic and inorganic chemistry.
Organic chemistry focuses on compounds of carbon which typically are derived
from petroleum and natural gas sources. Inorganic chemistry covers all sub-
stances that are not compounds of carbon (with a few exceptions) and includes
metals, salt, and other minerals.
Organic chemical production involves processing raw carbon-based materials
into primary outputs or building blocks, including ethylene, propylene, benzene,
methanol, toluene, xylenes, butadiene, and'butylene. Chemicals are added in
subsequent phases to create the final products, such as foams, resins, cements,
adhesives, lubricants, floor coverings, paints, airplane parts, pharmaceuticals,
tires, cosmetics, detergents, and soaps.d Inorganic chemical production uses the
earth's natural resources to produce a wide array of goods. One of these
processes involves breaking down salt (sodium chloride) into its principal
components, sodium (Na) and chlorine (Cl), which are used in a variety of
chemical processes; for example, chlorine is used to bleach items, such as cloth
and paper, and is added to drinking water for purification.d
bsie
281 2812
2813
2816
2819
- 282 2821
4
," 2822
2823
; , 2824
283 2833
2834
2835
2836
284 " 2841
• i 2842
2843
2844
285 2851
286 2861
2865
"2869
287 2873
2874
2875
2879
289 2891
2892
2893
2895
I 2899
Table 2-2.
Industry Sector
Alkalies
Gases
Pigments
Inorganics
„ Plastics ,
Rubber
- Cellulosics
Organic Fiber
Medicinal
Pharmaceuticals
Diagnostic Substances
Biologic
Soaps
- Polishes
Surfactants
Cosmetics
Paints
Gums
Cyclic Crude
Organics
Nitrogenous Fertilizer
Phosphatic Fertilizer
Mixed Fertilizer
Pesticides
Adhesives
"" Explosives
Inks
Carbon Black
Chemical Preparation^
industry Overview
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 2-1.
Leading Exports in the World Manufacturers
Market, 1993.d
1JSO
use
u»
JJM
lisa
SIM
uo
10
^ \
» Only road vehicles trade is I:
larger than world trade in L
chemicals. ) \
The chemical industry produces more than 70,000 finished products from raw materi-
als. Very few goods and services are produced without'involving the chemical
industry in at least one phase of the production process. Products made by the
chemical industry include textiles, medicines, dyes and paints, and automobile parts.
In addition, products of the chemical industry are crucial to the agricultural, con-
struction, manufacturing, medical, and service industries.11
2.A.4. Role of the Chemical Industry in the U.S. and World Economies.
The chemical industry is a leader in world export markets, surpassed only by the
automotive industry (see Figure 2-1). The U.S. chemical industry is the leading sector
in U.S. goods exports; in 1994, chemical manufacturers
accounted for 10 cents of every dollar in exports and 1.9
percent of the national gross domestic product (GDP) and
employed approximately one million people. Cumulative
exports from 1970 to 1989 totaled $66 billion and $223
billion in the following five years, from 1990 to 1994.
Since 1984, the U.S. chemical industry has maintained a
trade surplus totaling about $140 billion—$17 billion in
1993 alone. However, although the U.S. chemical industry
is the largest producer in the world, Germany is the leading
exporter of chemicals.0 U.S. chemical manufacturers have
approximately 2,800 affiliates abroad, while foreign
chemical manufacturers have 1,700 affiliates in the U.S.
Read Chemical* Industrial Computers Clothing Other Iron and
V.hkWi Machltery Trans. Steel
Equipment
Figure 2-2.
Composition of World Goods Trade, 1994.e
Other
21.4%
Manufactured
Goods 78.6%
The majority of items on the world trade market are manufactured goods.
Figure 2-3.
Chemicals Traded on the Manufacturers
Market, 1994.«
Most items traded on the world market are manufactured
products; that sector has shown consistent growth in
exports. In 1981, manufactured goods accounted for 60.9
percent of world exports of goods. By 1994, the percentage
of manufactured goods in world exports had risen to 78.6
percent (see Figure 2-2).° Chemicals account for about 11.7
percent of all manufactured products traded and 9.2 percent
of all goods traded on the world market (see Figures 2-3 and
2-4). Major growth is expected in the Asian and Pacific
Rim markets, with some growth expected for agricultural
products in Latin America. World chemical trade has grown
more rapidly than world chemical production. Between
1981 and 1993, world trade in chemicals increased from
Figure 2-4.
Chemicals Traded on the World
Goods Market, 1994.e
Chemicals 11.7%
Other/"
Products
88.3%
Chemicals 9.2%
Other
' 90.8%
Chemicals acciiuntfor 11.7% of all goods traded on the
manufacturers market.
Chemicals account for 9.2% of all goods traded on the
world market.
10
October 1997
SIC 2800
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Chemical Industry
Maffonaf
Environmental
Baseline Report
1990 to 1994
$124 billion dollars to $309 billion dollars, or 149.2 percent (see Figure 2-5). However,
world production of chemicals increased 67.3 percent in that same period.6
Figure 2-6 depicts the composition of world
chemical industry exports by sector. In 1993,
organic and inorganic chemicals accounted for
nearly one-third of the world chemical trade. Over
time, the sectors that have the highest growth rates
in the world market include inks, medicinals,
Pharmaceuticals, cosmetics, soaps, and plastics.
Current trends indicate an oversupply in the next
decade and perhaps beyond. As developing
countries enter the market, the number of producers
will increase, thereby increasing competition. Rates
of return therefore could decline, and U.S.
production could decrease, compared with total
world production.8
Another important trend in the chemical industry is
the rising cost of pollution abatement. In 1993, cost
of pollution abatement totaled $5.4 billion, or 3.3
cents per dollar of sales (capital expenditures and
operating costs). That number is up from 1.9 cents
per dollar of sales in 1984. In addition, one-sixth of all new capital expenditures is
allocated to pollution abatement measures, exceeding the investment in plant and
equipment needed to start up new manufacturing operations.
(These figures do not include other costs of pollution abatement,
such as the cost of process modification and site remediation, and
instead focus on end-of-pipe costs.)
Figure 2-5.
Chemical Industry World Trade Growth, 1993.*
* Between 1981 and 1993, world trade in
chemicals increased from $124 billion
dollars to $309 billion dollars, or 149.2
percent.
Figure 2-6.
Composition of World Chemical
Exports, 1993.e
To obtain additional general information on the chemical
industry, refer to such resources as:
• Profile of the Organic Chemical Industry.
EPA, OECA. September 1995.
• Profile of the Inorganic Chemical Industry.
EPA, OECA. September 1995.
• U.S. Chemical Industry Statistical Handbook.
CMA. 1994.
• The U.S. Chemical Industry Performance in 1994
and Outlook. CMA. February 1995.
2.A.5. Legal and Regulatory Environment. Many
compliance assurance and enforcement actions are carried out by
states. EPA and the states are partners in enforcing environmental
statutes and regulations.
[ • Organic and inorganic chemicals
accounted for nearly one-third of world
chemical trade.
J
Chemical Sector
Although the programs described below are federal programs, most federal environmen-
tal programs are implemented and enforced by the states: States usually have the option
to develop environmental programs and implement them, once EPA has approved them.
Although the states have primary responsibility for implementing these programs once
they have been approved, state programs are subject to EPA oversight. States also may
Industry Overview
11
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Chemical Industry
National
Environmental
Baseline Report
199O to 1994
. 1*1
«*i I
,*i
develop their own programs that may establish more stringent requirements than those
established under federal law. In general, chemical facilities must comply with environ-
mental regulations under both federal and state programs.
The chemical industry has been and continues to be one of the most stringently regu-
lated industries in the U.S. The industry is regulated under a variety of federal, state,
and local environmental statutes and regulations. This section provides a broad over-
view of the environmental regulations and their enabling legislation that affect the
chemical industry. A more detailed description may be found in Appendix C. The
major applicable federal environmental statutes are:
• The Resource Conservation and Recovery Act (RCRA)
• The Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA)
• SARA Title IE, the Emergency Planning and Community
Right-to-Know Act (EPCRA)
• The Clean Air Act (CAA)
• The Clean Water Act (CWA)
• The Safe Drinking Water Act (SDWA)
• The Toxic Substances Control Act (TSCA)
• The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
RCRA
Under RCRA, three major regulatory programs affect the chemical industry: one
developed under the authority of Subtitle C for hazardous waste management, the
second developed under the authority of Subtitle D for solid waste management, and
the third developed under Subtitle I for the storage of regulated substances in under-
ground storage tanks (UST). The hazardous waste management program requires
the industry to characterize the wastes that it generates and establishes management
standards for the treatment, storage, and disposal of hazardous wastes. When contamina-
tion from hazardous waste elevates the risk to human health or the environment, the
corrective action program requires facilities to-clean up contaminants and mitigate risks.
Subtitle D sets forth guidelines for the management of municipal and industrial solid
waste. It also provides that states may develop and implement their own regulatory
programs for solid waste management, including landfills. The UST program establishes
design and operating requirements for the underground storage of petroleum products
and certain hazardous substances.
CERCLA
CERCLA affects the day-to-day operations of chemical facilities through its require-
ments for reporting releases of hazardous substances and extremely hazardous substances
above those threshold quantities established under the legislation. CERCLA also
imposes liability on those facilities for releas.es of hazardous substances into the environ-
ment. CERCLA provides EPA with the authority to: (1) require facilities to remediate
releases of hazardous substances, or (2) conduct the cleanup and seek reimbursement
from responsible parties to recover the costs of cleanup. CERCLA has a significant
effect on chemical facilities because the liability is strict, joint, and several - that is,
a facility can be held liable for the cost of cleanup at a site, regardless of its relative
contribution to the overall problem.
12
October 1997
Si€ 2800
-------
EPCRA
EPCRA establishes a program that requires chemical facilities to prepare reports that
document: (1) the quantities of chemicals they are storing, and (2) the quantities of
chemicals they are transferring or releasing into the environment. Under EPCRA,
facilities are required to report certain transfers and releases to the environment of
extremely hazardous substances. Facilities that store more than specified threshold
amounts of hazardous chemicals must report to local authorities information about the
quantities of those chemicals in storage; that information is used in preparing regional
emergency response plans. Finally, certain chemical facilities that have 10 or more
employees must estimate transfers and releases of about 600 toxic chemicals to the air
and water and in solid wastes and complete and submit forms that document those
transfers and releases.
CAA
The CAA requires that chemical facilities obtain preconstruction and operating permits,
primarily for major stationary sources of air pollutants. Regulations under the Clean Air
Act Amendments of 1990 require certain facilities to submit permit applications and
obtain permits under Title V of that legislation. Such permits establish permit conditions
designed to control both point-source and fugitive emissions of hazardous air pollutants.
Finally, the act subjects many facilities to industry-specific emissions standards and
requires many chemical facilities to evaluate air pollution control alternatives and select
and install the best available air pollution control equipment.
CWA
The CWA establishes two programs that regulate discharges of pollutants to the surface
water and groundwater of the U.S. First, facilities are required to prepare permit applica-
tions and obtain permits to control point-source discharges of toxic pollutants and
stormwater runoff. The permits require facilities to monitor discharges and prepare and
submit reports that document the results of monitoring. Regulations under the act also
establish industry-specific discharge limits for certain chemical facilities. Second,
chemical facilities are subject to effluent limits for wastewater that is being discharged to
publicly-owned treatment works (POTW), including prohibition of discharges that will
adversely affect the operation of the POTW.
SDWA
The SDWA sets forth provisions designed to protect the nation's public drinking-water
supplies. Most important to certain members of the chemical industry, the act, which was
reauthorized in 1996, requires facilities to submit permit applications and obtain permits to
control the underground injection of contaminants. The permits establish general condi-
tions governing design, operation, and monitoring, as well as chemical-specific discharge
limits.
TSCA
Two major environmental programs control the manufacture, distribution, and use of
chemicals. TSCA includes provisions that require chemical facilities to submit informa-
tion to EPA about new and existing chemicals so that EPA can determine whether those
chemicals are safe for distribution and use in commerce. TSCA also includes provisions
that regulate the management and disposal of certain chemicals, such as polychlorinated
biphenyls (PCB) and asbestos.
FIFRA
FIFRA regulates the manufacture, distribution, and use of pesticides. The original FIFRA,
passed in 1947, monitored the use and sale of pesticides in the U.S., and was under the
purview of the U.S. Department of Agriculture. The Federal Environmental Pesticide
Control Act (FEPCA), passed in 1972, mandated that EPA regulate the use and sale of
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Industry Overview
13
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 2-7.
EPA Regions.
Figure 2-8.
Number of Chemical Facilities by EPA Region, 1995.'
4,500
4,000
* EPA Region 5 has the largest number
of chemical facilities.
EPA Region
Figure 2-9.
Percentage of Chemical Facilities by EPA Region, 1995.'
pesticides to protect human health and preserve the environment.
Specifically, EPA is authorized to: (1) strengthen the registration
process by shifting the burden of proof to the chemical manufacturer,
(2) enforce compliance with requirements governing against banned
and unregistered products, and (3) promulgate the regulatory frame-
work that had been missing from FIFRA.
2.B. Number of Chemical Facilities
The following sections provide information about the distribution of
chemical facilities throughout the U.S. and by EPA region, as well as
the number of facilities in each industry sector or SIC code.
2.B.I. Distribution of Chemical Facilities Throughout
the U.S. Locations of facilities generally are chosen because they
offer access to: (1) raw materials, (2) transportation routes, and (3)
end users and consumers. Therefore, most wood and gum chemical
facilities are located in Florida, Missouri, and Virginia. Facilities
that produce cyclic crudes and intermediates, as
well as unclassified organic chemicals, typically
are located in Illinois, Louisiana, New Jersey,
Ohio, Texas, and West Virginia.15 Inorganic
chemical facilities are concentrated in the heavily
industrialized regions of the Great Lakes and the
Gulf Coast.0
According to 1995 records provided by Dun and
Bradstreet Information Services, Inc.,1 which
sorts data according to facilities' top five SIC
codes, 20,676 facilities declare that chemical
processing is one of their primary operations.
Figure 2-7 shows the location of EPA regions in
the U.S. Figure 2-8 shows the number of such
chemical facilities in each EPA region. Figure 2-
9 shows the percentage of chemical facilities by
EPA region.
Region 5, with the largest number of facilities
nationwide, has 4,212 facilities, or 21 percent of
all facilities. Regions 4 and 9 follow, with 3,368
and 3,215 facilities, or 16 percent respectively.
The regions that have the smallest number of
facilities are 7, 10, and 8, with 963, 647, and 629
facilities, or 5 percent, 3 percent, and 3 percent,
respectively.
According to 1995 records of the Bureau of the
Census, which sorts data according to each
facility's primary SIC code, 12,001 facilities
declared that chemical processing is their primary
operation.
More than half of all chemical facilities in the U.S. are located in EPA
Regions 4, 5. and 9.
14
October 1997
SIC 2800
-------
Figure 2-10.
National Summary of Chemical
Facilities by Primary SIC Code, 1995.'
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
•a
3
u
to
fc-
a
Chemical Preparation (2899)
Cosmetics (2844) ||g~
Pharmaceuticals (2834)
Polishes (2842)
Inorganics (2819)
Plastics (2821)
Paints (2851)
Organlcs (2869)
Adheslves (2891)
Gases (2813)
Soaps (2841)
~ Pesticides (2879)
D
C Mixed Fertilizer (2875)
o
^ Inks (2893)
S Medicinal (2833)
g Nitrogenous Fertilizer (2873) eg
i, —tm
_ Biologic (2836)
2 Cyclic Crude (2865)
{• Dlagnos tic S ubs tances (2835)
4)
£ S urfactant(2843)
jjj Explosives (2892)
" Organic Fiber (2824)
Q. Rubber (2822)
l~ Phosphatic Fertilizer (2874)
Pigments (2816)
Alkalies (2812)
Gums (2861)
Cellulosic(2823)
Carbon Black (2895)
e largest number of facilities are
gaged in chemical preparation.
500
1000 1500
Number of Facilities
2000
2.B.2. Numbers of Facilities in Each SIC Code. Another important element of
information about the chemical industry is the distribution of facilities among the various
SIC codes or industry sectors. As Figure 2-10 shows, the largest number of facilities are
engaged in:
Chemical preparation (SIC 2899)
Cosmetics (SIC 2844)
Pharmaceuticals (SIC 2834)
• Polishes (SIC 2842)
Together, these four sectors account for 39 percent of all chemical facilities in the nation.
Industry sectors in which the smallest number of facilities nationwide (fewer than 100
facilities per sector) are engaged include:
• Gums (SIC 2861)
• Cellulosics (SIC 2823)
• Carbon black (SIC 2895)
Industry Overview
15
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 2-11.
National Summary of Chemical Facilities
by Number of Employees, 1995.'
ieto4» 50 to 100 101 to 500
Number of Employees per Facility
Figure 2-12.
Number of Chemical Industry Employees by
EPA Region, 1995."
2.C. Chemical Facilities
and Low-Income and
Minority Communities
Over the past decade, attention to the effects of
environmental pollution on particular segments
of U.S. society has increased steadily. At issue
specifically is the potential that disproportion-
ately high adverse effects on human health and
the environment from pollution may be borne
by minority populations and low-income
populations. This concern has sparked a
movement to ensure environmental justice for
all segments of our society.
On February 11, 1994, President Clinton issued
Executive Order 12898, Federal Actions to
Address Environmental Justice in Minority
Populations and Low-Income Populations,
which focused the attention of federal agencies
on the environmental and human health
conditions of minority communities and low-
income communities. The Executive Order
directed federal agencies to develop environ-
mental justice strategies by February 11,1995
that identify and address disproportionately
high exposure and adverse effects on human
health or the environment that their programs,
policies, and activities impose on minority
populations and low-income populations.
Early in her tenure as Administrator of EPA,
Carol Browner identified the pursuit of
environmental justice as a priority of the
agency. OECA is dedicated to resolving issues
related to environmental justice. To that end,
OECA is interested in determining whether
chemical facilities are concentrated dispropor-
tionately in areas in which low-income
populations and minority populations reside.
Appendix D identifies counties that have primarily low-income populations and minor-
ity populations, as well as the number of chemical facilities in each such county. The
designation of low-income or minority population is not established by statistical
definition but by a decision based on language developed by the Interagency Working
Group on Environmental Justice. For this report, the terms are defined as follows:
• Low-income counties: Counties in which the average income is less than
$15,000 per year
• Minority counties: Counties having a nonwhite population equal to or greater
than 25 percent
350,000-
200,000-
•f. 150,000-
•s
J 100,000
50,000
103,!
(fl
•/-•
31,833
It
!»
i
'!
i
!r
'
rai
147,114
e
0,052
123
! :
-
21,637
*"••
\
,i,
4- EPA Region 5 has the greatest number Y
of chemical industry employees. f"
-I
|
108,130 J
jfm I
t,"'
j
I
78,525 "
j&tm *
37,152 «| II
r^a II
'-I lidja *1 8'915
- "' .Pi; fTP. "P fTP./
4 5 6 7 8 9 10
EPA Region
16
October 1997
SIC 2800
-------
5 400-
As can be seen from the maps in Appendix D, some
facilities are located in minority or low-income counties
while some are not. Data at this level of detail does not
lend itself to making any specific conclusions.
In response to Executive Order 12898 and EPA's commit-
ment to environmental justice, the Chemical Manufactur-
ers Association (CMA) through their Responsible Care®
Initiative developed "A Plant Managers Introduction to
Environmental Justice," dated 1995. This document
establishes a framework for facility-based activities to
proactively address environmental justice issues. In this
document, the hallmarks of a strong community outreach
program are presented and draw upon CMA's Community
Outreach Manual and Community Awareness and
Emergency Response (CAER) Core Resource Guide. The
CAER Core Resource Guide is a part of CMA's Respon-
sible Care® Initiative (see Responsible Care® Initiative,
Page 58).
2.D. Facility Employment
The chemical industry is characterized by a predominance
of small facilities, generally having fewer than 10
employees.b'c Facility employment numbers are important
to note, because facilities that have fewer than 10 employ-
ees are not required to report releases of toxic chemicals
under the reporting requirements for the TRI. Based on
available employment data, Figure 2-11 shows more than
56 percent of all facilities have fewer than 10 employees.
Therefore, fewer than 44 percent of facilities report
releases and transfers of toxic chemicals. This trend is
consistent among the EPA regions.
According to 1995 records of the Bureau of the Censusg,
the number of chemical industry employees is greatest in
EPA Region 5, where there are approximately 220,000
employees, or 25 percent of all chemical industry
employees in the nation (see Table 2-3 and Figures 2-12
and 2-13). EPA Regions 2 and 4 follow, with 163,501
and 147,116 employees, or 18 and 17 percent, respectively, of all chemical industry
employees in the nation. The EPA regions in which the fewest number of chemical
industry employees are located are 10, 8, and 1, with 8,915, 13,212, and 31,633
employees, or 1 percent, 1 percent, and 4 percent of all chemical industry employees
in the nation, respectively. This trend is consistent with the trend in number of facilities
per region.
As a comparison of Figures 2-8, 2-9, 2-12, 2-13, and 2-14 shows, there is no correla-
tion between the number of facilities or employees in an EPA region and the EPA
region's population per square mile. Region 5, in which the largest number of facilities
and employees are found, has the fourth highest population density among the regions.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 2-13.
Percentage of Chemical Industry Employees
by EPA Region, 1995.'
43 percent of all chemical industry employees are located in, EPA
Regions 2 and 5.
Figure 2-14.
Average Population per Square Mile
by EPA Region, 1995.'
No positive correlation exists between
the number of chemical facilities and
population density on an EPA Region basis. I
EPA Region
Industry Overview
17
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 2-3.
EPA Region
Region 1
Region 2
Region 3
Region 4
Region 5
State Number
of
Facilities
Connecticut
Maine
Massachusetts
New Hampshire
Rhode Island
Vermont
Region 1 Totals
New Jersey
New York
Puerto Rico
Region 2 Totals
Delaware
Maryland
Pennsylvania
Virginia
Washington, DC
West Virginia
Region 3 Totals
Alabama
Florida
Georgia
Kentucky
Mississippi
North Carolina
South Carolina
Tennessee
Region 4 Totals
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin .
Region 5 Totals
282
64
472
87
88
40
1,033
1,300
1,261
59
2,620
119
224
925
130
22
94
1,514
199
1,049
641
209
129
510
281
350
3,368
1,210
410
769
422
1,030
371
4,212
Population
per
Sq Mile
678.4
39.8
767.6
123.7
370.3
60.8
1042
381
*
340.8
489.2
265.1
156.3
9882.6
74.5
79.6
239.6
111.9
92.8
54.9
136.1
115.8
118.3
205.6
154.6
163.6
55.0
264.9
90.1
Chemical
Industry
Employees
12,353
834
14,004
1,716
1,633
1,093
31,633
92,520
70,981
*
163,501
15,021
7,231
38,469
3,999
83
15,249
80,052
5,113
22,585
20,986
11,326
4,487
34,648
12,513
35,458
147,116
69,383
25,430
45,574
12,106
61,923
7,221
221,637
EPA Region State
Region 6 Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Region 6 Totals
Region 7 Iowa
Kansas
Missouri
Nebraska
Region 7 Totals
Region 8 Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Region 8 Totals
Region 9 Arizona
California
Hawaii
Nevada
Region 9 Totals
Region 10 Alaska
Idaho
Oregon
Washington
Region 10 Total
Number
of
Facilities
169
336
89
195,
1,686 ,
2,475
205
183
485
90
963
279
55
31
39
187
38
629
294
2,763
44
114
3,215
11
76
230
330
x 647
Grand Total 20,676
Population
per
Sq Mile
45.1
96.9
12.5
45.8
64.9
49.7
30.3
74.3
20.5
31.8
5.5
9.3
9.2
21.0
4.7
32.3
190.8
172.5
10.9
1.0
12.2
29.6
73.1
Chemical
Industry
Employees
4,285
16,519
1,681
4,555
81,090
108,130
5,547
4,310
24,898
2,397
37,152
3,172
404
230
342
6,801
2,263
13,212
6,271
70,620
527
1,107
78,525
361
1,247
2,561
4,746
8,915
889,873
* Information not available
In contrast, Region 1, in which only 4 percent of employees and 5 percent of facilities
are located, has the third highest population density. Chemical facilities, therefore, are
not necessarily located in densely populated areas. However, there are pockets of
facilities in areas of high population density, such as those in the Port of New York and
New Jersey; Gary, Indiana; and Chicago, Illinois areas. Those areas are the exception,
rather than the norm.
18
October 1997
SIC 2800
-------
TRI DATA
-------
-------
3. TRI DATA
Reporting under the Toxics Release Inventory (TRI) is mandated under the Emergency
Planning and Community Right-to-Know Act (EPCRA), Title HI of the Superfund Amend-
ments and Reau.thorization Act (SARA) of 1986. Manufacturing facilities that have the
equivalent of 10 or more full-time employees arid manufacture, process, or otherwise use
listed chemicals in quantities that meet the established thresholds must report their releases
and transfers. Manufacturing facilities are defined as facilities in SIC major groups 20
through 39, which include, among others, chemicals, petroleum refining, primary metals,
fabricated metals, paper, plastics, and transportation equipment. Facilities that manufacture
or process more than 25,000 pounds or otherwise use more than 10,000 pounds of any listed
chemical during the calendar year must submit to EPA a Form R for each listed chemical.
Reports for each calendar year are due to EPA by July 1 of the following year.h
EPA has created a database to track national trends in releases and transfers, known as the
Toxics Release Inventory System (TRIS). The database contains information about
releases, transfers, and waste management activities. The database tracks information about
the amounts of chemicals released to the environment, transferred, or otherwise managed
either on site or off site. The TRI database primarily reflects lawful, permitted releases and
transfers. Broad categories tracked in the TRI database are: (1) facility identification, (2)
substance identification, (3) environmental releases of TRI chemicals, (4) waste treatment,
(5) transfer of waste off site, and (6) source reduction and recycling. The inventory
contains data dating from 1987; however, 1988 is considered the inventory's baseline year,
because of concerns about the quality of the data submitted by industry during the first year
such submittals were required. Transfers for treatment and disposal have been reported
since 1987. Transfers for recycling and energy recovery have been reported since 1991.
Beginning with reporting year 1994, federal facilities are required to report to TRI. For
reporting purposes, TRI designates 118 chemicals as carcinogens on the basis of criteria
set forth in the Occupational Safety and Health Administration's (OSHA) Hazard
Communication Standards.- Some of those chemicals, such as benzene and asbestos, are
known to cause cancer in humans. Others are suspected to cause cancer in humans
because they have been shown to cause cancer in laboratory animals. For more
information regarding chemicals tracked in TRI, please visit EPA's website at
http://www.epa.gov/opptintr/chemfact/or the Agency for Toxic Substances and Disease
Registry website at http://atsdrl.atsdr.cdc.gov:8080/toxfaq.html.
A final rule adding 286 chemicals to the TRI was published on November 30,1994. The
first reports that included those chemicals were due August 1,1996. Other industry groups
were added in 1997. Currently under consideration is the future expansion of the reporting
requirements to include accounting for use of materials.
It is important to note the following data limitations:
• TRI data should be adjusted for production to obtain a more accurate accounting of
industry activities.
• The congressional Office of Technology Assessment estimates that releases reported
to TRI represent only five percent of all chemical releases.
• Changes in reporting thresholds and TRI obligations occurred throughout the baseline
period.
• The database contains information about only a portion of the toxic chemicals released
nationwide, because facilities that have fewer than 10 full-time employees and that do
not meet or exceed threshold amounts established for the various chemicals are not
required to file TRI reports. ,
• Facilities not included in SIC major groups 20 to 39 were not required to report to TRI.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
TRI Data
21
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
fi'il!
Figure 3-1.
Total Release Trends, 1990 to 1994.
300,000,000
ieo.ooo.ooo
120,000,000-
10.000,000
40,000,000
Industry Sector
Not all toxic chemicals are listed under the TRI.
The TRI requires the reporting of estimated data and does not mandate that facilities
monitor their releases.
TRI data reflect releases and transfers of chemicals, not exposure of the public
to those chemicals.
Since 1987, EPA has deleted a number of chemicals from the TRI reporting list,
added other chemicals, and modified the reporting requirements for still others.
EPA does not have a national database that tracks indirect discharges to surface
water. That information exists at the local level only. Therefore, data on
surface water discharges includes only direct discharges.
Data were extracted from the EPA TRI Public Data Releases for all TRI
industry trends.
Data were extracted from the EPA TRI Data CD-ROM, 1990 to 1994, for all
industries that reported under 2800 SIC code.
The following sections describe trends from 1990 to 1994,
including national trends for all industries and trends within
the chemical industry. National trends for all industries are
provided to aid the reader in placing the chemical industry
in the context of all releases and transfers of toxic chemi-
cals reported nationwide under the TRI.
3.A. Chemical Industry Trends
(1990 to 1994)
Figure 3-1 shows the trend in total releases for each of the
chemical industry sectors from 1990 to 1994. There was a
steady decline in total releases reportable under TRI during
this period, except for slight increases in some sectors for
the period between 1990 and 1991, attributable at least in
part, to expansion of reporting requirements for the chemical
industry. However, the data from 1991 to 1994 show an
overall decrease of 43.5 percent in total releases reportable
under TRI. During that time, production increased by 8.6
percent.11
Figure 3-2.
Carcinogenic Release Trends
for Chemical Industry, 1990 to 1994.
Industry Sector
Figure 3-3.
Transfer Trends
for Chemical Industry, 1990 to 1994.
Industry Sector
22
October 1997
SIC 2800
-------
Point Source Air
50.8%
Figure 3-2 shows the trend in releases of carcinogenic chemicals
for each of the chemical industry sectors from 1990 to 1994.
There was a steady decline in such releases, except for a slight
increase in 1994 in some sectors, again a circumstance that may
be attributable to a change in reporting requirements for the
chemical industry. However, an overall decrease of 15.9 percent
in total releases of carcinogens reportable to TRI occurred from
1990 to 1994.
Figure 3-3 shows the trend in total transfers for each of the
chemical industry sectors from 1990 to 1994. There was a
steady decline in total transfers of chemicals reportable under
TRI in most sectors, during that period, except for the period
between 1990 and 1991, a circumstance that can be attributed
to changes in requirements for reporting of transfers for
recycling and energy recovery. However, an overall decrease
of 13.5 percent in total transfers reportable to TRI occurred
from 1991 to 1994.
A comparison among the chemical industry sectors shows
that, in 1990, the organic chemical sector reported the
greatest number of transfers reportable to TRI, followed by
the inorganic chemical, drug, plastic material, and synthetic
sectors, respectively. The organic chemical sector reported
the largest quantity of toxic chemicals released, followed by
inorganic chemicals, agricultural chemicals, and plastic
materials and synthetics, respectively. Releases of carcino-
genic chemicals were highest for the organic chemicals and plastic materials and
synthetics sectors.
In 1991 and 1992, the organic chemicals sector again reported the largest number of
transfers reportable to TRI, followed by the plastic materials and synthetics sector. The
inorganic chemicals sector reported the largest quantity of toxic chemicals released,
followed by the organic chemicals and agricultural chemicals sector, respectively.
Releases of carcinogenic chemicals decreased from the levels reported in 1990, but the
same sectors reported the largest quantities of carcinogenic chemicals released.
In 1993 and 1994, the organic chemical sector led the other sectors in the transfer of
TRI chemicals, followed by the plastic materials and synthetics sector. The inorganic
chemicals sector reported the greatest number of pounds released, followed by the
organic chemicals and agricultural sectors, respectively. Releases of carcinogenic
chemicals decreased from the levels reported in 1990, but the same sectors reported the
largest quantities of carcinogenic chemicals released.
3.B. TRI Data for All Industries (1994)
In 1994, 22,744 facilities filed 75,332 TRI reporting forms, or an
average of 3.3 forms per facility. The facilities reported releas-
ing approximately 2.26 billion pounds of listed chemicals into
the environment.11 Table 3-1 and Figure 3-4 show the total
releases to various media.
Facilities sent almost 3.8 billion pounds of listed chemicals to off-
site locations for treatment, disposal, energy recovery, or recycling
in 1994. Table 3-2 and Figure 3-5 show the total transfers by
source.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 3-4.
Distribution of TRI Releases for All Industries, 1994.h
.Surface Water
2.9%
On-Site Land
Releases
12.9%
Half of all 1994 TRI releases were those to air from point sources.
Figure 3-5.
Distribution of TRI Transfers for All Industries, 1994.h
Over 64 percent of all 1994 TRI transfers were attributed to recycling.
— «£.
71
Table 3-1 .h
Source
Pounds
Percent
Fugitive Air 407,515,304 18.0
Point Source Air 1,148,492,781 50.8
Surface Water 66,083,288 2.9
Underground Injection 348,968,226 15.4
On-Site Land Releases 289,151,126 12.9
TRI Data
23
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 3-6.
Industry Categories that Reported the Largest
Quantities of On-Site TRI Releases
for All Industries, 1994.''
• The chemical industry had the largest
quantity of 1994 TRI releases.
Paper
Table 3-2.h
Source
Pounds
Percent
Recycling
Energy Recovery
Treatment
POTVVs
Disposal
Other
2,456,120,948
464,206,483
318,810,333
254,688,836
297,600,462
3,602,423
64.7
12.2
8.4
6.7
7.8
0.2
Figure 3-7.
Industry Categories that Reported
the Largest Quantities of TRI
Transfers, 1994.h
^ The chemical industry
reported the largest
quantity of 1994 TRI
transfers.
Figure 3-6 shows the industry categories that reported the
largest quantities of on-site TRI releases in 1994. The
chemical industry had the largest quantity of releases (942
million pounds), followed by the primary metals (313
million pounds) and paper (246 million pounds) industries.
It is important to note that, while the 50 facilities reporting
the largest total amounts of listed TRI chemicals released
represent just 0.2 percent of all facilities reporting to the
TRI, they accounted for 26.1 percent of all releases
reported to TRI in 1994. The facilities submitted an
average of 14.9 reports each. More than one-half (31) of
those facilities were chemical facilities.11
Figure 3-7 shows the industry categories in which facilities
reported the largest quantities of transfers of TRI chemi-
cals. The chemical industry reported the largest quantities
transferred (1,920 million pounds), followed by the
primary metals (1,142 million pounds) and electrical
equipment (392.2 million pounds) industries. However,
most of the transfers reported by primary metals and
electrical equipment industries were transfers to recycling
(79.4 percent and 90.9 percent, respectively). In contrast,
only 15.6 percent of the chemical industry's transfers were
to recycling, although the chemical industry accounted for
75.3 percent of all transfers to energy recovery.
Figure 3-8 shows the industry categories in which facilities
reported the largest quantities of releases of carcinogenic
chemicals as identified under TRI reporting requirements.
The chemical industry reported the largest quantity of
releases (54.8 million pounds), followed by the plastics
industry (43.5 million pounds), and paper (18.2 million
pounds).
Figure 3-8.
Industry Categories that Reported
the Largest Quantities of Releases
of Carcinogens, 1994.h
.tg^^^f^
XA- Mft
4 The chemical industry
had the largest quantity
of 1994 TRI
carcinogenic releases
Paper
24
October 1997
SIC 2800
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 3-3.
SIC
Code
281
282
283
284
285
286
287
289
*
if
J^lpjll*; ,n . . » ^Jf|lf!f , _,
Industry
Inorganic Chemicals
Plastic Materials
and Synthetics
Drugs
Soaps, Cleaners,
and Toilet Goods
Paints and
Allied Products
Organic Chemicals
Agricultural
Chemicals
Miscellaneous
Chemicals
Multiple SIC
with 2800
TOTAL
Number
of
Facilities
366
323
175
233
536
384
163
527
1,024
3,731
•srlsf^rt
*f"*SKr^ri
Number
of
Forms
1,377
1,956
601
1,070
3,123
3,111
1,039
2,245
8,396
puO%*44iy
!?•>. , ^ ~3r ,, -.
Total Air
Emissions
(Pounds)
21,534,987
57,534,842
10,966,354
1,735,522
9,828,250
50,841,160
57,536,662
25,897,822
232,011,012
22,918 467,886,611
Surface Water
Discharges
^(Pounds)
1,215,939
935,114
912,144
2,737
3,828
1,009,047
5,576,521
243,027
32,682,782
42,581,139
iiF1 * «
Underground Releases
Injection to Land
(Pounds) (Pounds)
72,349,069
84,050
6,826,250
15,431
0
52,661,370
2,391,288
0
201,036,145
335,363,603
17,467,785
65,397
175,154
35,514
13,909
1,149,816
21,218,843
255,621
55,852,811
96,234,850
•#"
Total
Releases
O'ounds'l^
112,567,780
58,619,403
18,879,902
1,789,204
9,845,987
105,661,393
86,723,314
26,396,470
521,582,750
942,066,203
* Facilities have been assigned to the "multiple" category according to all the SIC codes they reported. Forms and amounts in pounds have been assigned to single-
category SIC codes if only one SIC code was reported for a particular chemical form from the facility.
3.C. TRI Data for the Chemical
Industry (1994)
In 1994, facilities in the chemical industry submitted 22,918
TRI forms, or 30.4 percent of all forms submitted to the TRI,
filing an average of 6.2 forms per facility (see Table 3-3).
Chemical facilities reported an average of 255,372 pounds
released, second only to primary metals. The chemical
industry accounted for almost all reported underground
injection of waste (96.0 percent) and a majority of surface-
water discharges (64.4 percent).
Table 3-3 and Figure 3-9 break down the total quantity of
TRI releases for the chemical industry. The inorganic
chemicals segment of the industry reported the largest
quantity of releases (27 percent), followed by the organic
chemicals (25 percent) and agricultural chemicals (21
percent) segments.
Figure 3-10 shows the breakdown of air emissions for the
chemical industry. The plastic materials and synthetics
segments of the industry reported the largest quantity of air
releases (25 percent), followed by the agricultural chemicals
(24 percent) and organic chemicals (22 percent) segments.
Figure 3-11 breaks down the total surface-water discharges for
the chemical industry. The agricultural chemicals segment of
the industry reported the largest quantity of surface-water
Figure 3-9.
Total TRI Releases for Chemical Industry, 1994.h
Miscellaneous
Chemical Products
6.3%
Agricultural Chemicals
20.6%
Organic Chemicals
25.1%
Paints and Allied
Products
2.3%
26.8%
Plastic Materials
and Synthetics
13%
Soaps, Cleaners and
Toilet Goods
0.4%
The inorganic chemicals segment reported the largest quantity of releases.
Figure 3-10.
Total Air Emissions for Chemical Industry, 1994.h
MtacoNarteous
Chemical Products
11.0V.
Agricultural Chomteato
24.4%
Ptatfc Materials
and Synthetics
25,2%
Paints and AlHed
Products
4.2%
Soaps, Cleaners, w
ToHet Goods
0.6%
The plastics and synthetics segment reported the largest quantity of air releases.
TRI Data
25
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
discharges (56 percent), followed by the inorganic chemicals (12 percent) and the plastic
materials and synthetics (11 percent) segments.
Figure 3-12 breaks down the total releases by underground injection for the. chemical
industry. The inorganic chemicals segment of the industry reported the largest quantity
of underground injection releases (66 percent), followed by the organic chemicals (29
percent) and drug (4 percent) segments.
Figure 3-13 breaks down the total releases to land for the chemical industry. The
agricultural chemicals segment of the industry reported the largest quantity of releases
Flaure 3-11 to 'anc* ^ percent), followed by the inorganic chemicals (43
Surface-Water Discharges percent) and organic chemicals (3 percent) segments.
for Chemical Industry, 1994.h
Cnwnfeil Product*
23%
Inorganic Charrlcala
12.4%
Pbsllc Material*
and Synttwl)c»
10.5%
Druga
a.7%
[Paints and Aflad
Producla
0.0%
Soapa, Ctvanefs and
To«>l Gooda
Organic Ctiamlcalo n o%
Tlte agricultural chemicals segment reported the largest surface-
water discharges,
Figure 3-12.
Underground Infection Releases
for Chemical Industry, 1994.h
AericuhJral Cnamteala
1.2%
Inorganic Owmlcala
66.2%
Ptutlc Malarial.
•ndSynthxfca
0.0%
The inorganic chemicals segment reported the largest quantity
of underground injection releases.
Figure 3-13.
Releases to Land for
Chemical Industry, 1994.h
Chenfcal Products
Inorganic Cberrteal
43,3%
Drugs
Flaatlc Material. "% Soar* d.an.r*
andlynlhitlc. and TOIal Cood.
°-<% 0.1%
The agricultural chemicals segment reported the largest quantity of
releases to land,
~26
3.D. National Trends for All
Industries (1990 to 1994)
The number of all facilities reporting to TRI increased slightly
between 1990 and 1991, but the general trend is a steady
decline in the number of facilities reporting to TRI (see Table
3-4). Following that trend, the number of TRI reports
submitted declined gradually from 1990 to 1994.
Reported releases of listed chemicals decreased by 500
million pounds between 1993 and 1994. That figure repre-
sents a decline of nearly 18 percent. Reports of releases of
listed chemicals decreased by 13 percent between 1992 and
1993, at more than double the rate of decline between 1991
and 1992. The quantity of TRI chemicals released decreased
from 3.6 billion pounds in 1990 to 2.3 billion pounds in
1994, a decrease of 36.1 percent.
Amounts of carcinogenic chemicals released dropped from
236 million pounds in 1990 to 177 million pounds in 1994, a
25 percent decrease. The quantity of TRI chemicals trans-
ferred increased from 3.9 billion pounds in 1991 to 4.8
billion pounds in 1993. The increase of 23 percent is
primarily the result of increased transfers for recycling.
Reports of TRI chemicals transferred show a decrease
between 1993 and 1994, from 4.8 billion pounds, to 3.8
billion pounds, a 21 percent decrease. Table 3-5 summa-
rizes national TRI trends for all industries.
3.E. National Trends for the
Chemical Industry (1990 to 1994)
Throughout the period from 1990 to 1994, the chemical
industry as a whole generally reported the largest quantities of
carcinogens released, followed by the plastics products (SIC
3000) and transportation equipment (SIC 3700) industries.
The chemical industry consistently has reported the largest
quantities of total pounds released, followed by the primary
metals and paper industries. In addition, the chemical
industry has reported the largest quantities transferred,
followed by the primary metals and paper industries.
October 1997
SIC 2800
-------
Year
1990
1991
1992
1993
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 3-4.
1994
Number of Facilities Reporting to TRI 23,638 23,719 23,630 23,321 22,744
Number of Forms Submitted to TRI 83,387 82,293 81,016 79,987 75,332
Average Number of Forms per Facility 3.5 3.5 3.4 3.4 3.3
Total Pounds Released 3.6 billion 3.4 billion 3.2 billion 2.8 billion 2.3 billion
Total Pounds of Carcinogens Released 236 million1 212 million 197 million 180 million 177 million
Total Pounds Transferred 1.3 billion2 3.9 billion 4.4 billion 4.8 billion 3.8 billion
1 Does not include releases to land.
2 Transfers include only those to POTWs and off-site locations. Transfers to energy recovery and recycling were not reported.
It is important to note that, for the 1990 to 1994 period, the chemical industry as a
whole reported more than half the total quantity of production-related waste reported by
all industries and more than four times the amount reported by the second-ranked
industry, primary metals. Table 3-6 summarizes national TRI trends for the chemical
industry.
3.F. Five Chemicals Released in the Greatest
Quantities by the Chemical Industry
(1990 to 1994)
From 1990 to 1993, ammonia was the TRI chemical released into the environment in the
largest quantity (see Table 3-7). However, the amount reported decreased steadily from
approximately 404.6 million pounds in 1990 to 126.7 million pounds in 1994. Those
figures represent a decrease of 277.9 million pounds, or 68.7 percent. The TRI chemicals
released in the second, third, fourth, and fifth largest quantities show a generally down-
ward trend in the releases of phosphoric acid, sulfuric acid, and methanol. The reporting
requirements for ammonia and sulfuric acid were revised during that period.
Releases of carcinogenic chemicals from 1990 to 1994 are shown in Table 3-8. Styrene
is the TRI carcinogenic chemical released to the environment in the largest quantity,
followed by acetonitrile, and formaldehyde.
The TRI chemicals transferred in the largest quantities from 1990 to 1994 are not the
same chemicals from one year to the next (see Table 3-9). However, the TRI chemical
transferred in the greatest quantity shows a trend towards accounting for more than half
of all TRI transfers.
In 1990, the top five chemicals released accounted for 56.8 percent of all chemicals
released. This percentage rose to 59.6 and 63.3 percent in 1991 and 1992, respectively.
In 1993, it decreased to 60.9 percent and then to 53.2 percent in 1994.
Table 3-5.
TRI Category
Trend
Chemicals released
Carcinogenic chemicals
released
Chemicals transferred
36.1 percent decrease
25 percent decrease
292 percent increase
TRICategory__
Table 3-6.
Trend
Chemicals released
Carcinogenic chemicals
released
Chemicals transferred
43.5 percent decrease
15.9 percent decrease
13.5 percent decrease
TRi Data
27
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 3-7.
Top Five Chemicals Released! in the Greatest
Quantities by the Chemical Industry, 1 990 to 1 994.h
Rank
First
Second
Third
Fourth
Fifth
Year
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
Chemical
Ammonia
Ammonia
Ammonia
Ammonia
Hydrochloric acid
Hydrochloric acid
Hydrochloric acid
Hydrochloric acid
Phosphoric acid
Ammonia
Phosphoric acid
Phosphoric acid
Phosphoric acid
Hydrochloric acid
Phosphoric acid
Sulfuric acid
Sulfuric acid
Sulfuric acid
Sulfuric acid
Methanol
Methanol
Methanol
Methanol
Carbon Bisulfide
Carbon Disulfide
Amount
404,608,062
366,126,752
365,374,868
255,719,521
150,824,955
188,082,470
216,287,343
217,970,514
211,252,927
126,778,226
136,784,943
161,636,911
205,183,078
151,586,039
77,649,114
121,472,207
122,521,308
122,423,015
124,690,389
74,561,119
96,488,265
95,135,510
97,452,887
81,284,733
71,795,989
Percentage
24.2
22.7
22.9
18.9
16.0
11.3
13.4
13.7
15.6
13.5
8.2
10.0
12.9
11.2
8.2
7.3
7.6
7.7
9.2
7.9
5.8
5.9
6.1
6.0
7.6
,,]*:;:,
28
October 1997
SIC 2800
-------
Table 3-8.
Top Five
Quanl
Rank
First
Second
Third
Fourth
Fifth
Carcinogenic Chemicals Re
ities by the Chemical Indu:
Year
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
1990
1991
1992
1993
1994
Chemical
Styrene
Styrene
Styrene
Acetonitrile
Acetonitrile
Formaldehyde
Acetonitrile
Acetonitrile
Styrene
Styrene
Acetonitrile
Diethyl Sulfate
Formaldehyde
1,3-Butadiene
1,3-Butadiene
Diaminotoluene
(Mixed Isomers)
Formaldehyde
Di(2-Ethylyexyl)
Diethyl Sulfate
Diethyl Sulfate
Asbestos (Friable)
Di(2-Ethylyexyl)
Phthalate
1,3-Butadiene
Di(2-Ethylyexyl)
Phthalate (DEHP)
Di(2-Ethylyexyl)
Phthalate (DEHP)
.! ' • ,-' "--^^^ISIHI
Amount
14,371,179
21,573,455
23,853,716
23,349,289
22,581,548
7,558,513
20,246,192
19,791,225
16,457,053
18,850,062
3,953,185
14,276,861
5,867,222
15,167,497
15,801,079
2,416,480
6,329,773
5,778,997
10,744,465
12,368,251
2,084,026
5,708,647
4,965,581
5,357,730
5,728,831
SGfelLtiSli
[g*4^ II iff
Percentage
37.1
21.6
28.1
22,5
20.6
19.5
20.3
23.3
15.9
17.2
10.2
14.3
6.9
14.6
14.4
6.2
6.3
6.8
10.4
11.3
5.4
5.7
5.9
5.2
5.23.5
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
TRI Data
29
-------
ri Industry
National
Envir*itM«ttt«l
Bas«IIiMi ••perl
1990 to 1994
Table 3-9.
Rank
Year Chemical
Amount Percentage
First
1990
1991
1992
1993
1994
Methanol
Sulfuric acid
Sulfuric acid
Sulfuric acid
Methanol
153,139,319
352,611,719
369,047,778
360,165,712
267,397,243
Second
1990
1991
1992
1993
1994
Ammonia
Methanol
Methanol
Methanol
Ethylene Glycol
71,660,866
278,678,189
284,529,890
268,881,669
237,064,296
Third
1990 Hydrochloric acid 70,729,618
1991 Ethylene Glycol 196,755,104
1992 Ethylene Glycol 215,926,458
1993 Ethylene Glycol 209,156,217
1994 Toluene ^J^Z^dEZ,,
Fourth 199° Toluene 46,593,137
1991 Xylene (Mixed Isomers) 166,345,343
1992 Toluene 169,273,165
1993 Toluene 182,327,913
1994 Xylene (Mixed Isomers) 160,010,711
Fifth
19.0
15.9
16.4
16.4
13.9
8.9
12.6
12.6
12.3
12.3
'8.8
8.9
9.6
9.5
9.1
ssssmss
5.8
7.5
7.5
8.3
8.3
1990 Sulfuric acid 43,583,277 5.4
1991 Toluene 164,122,956 7.4
1992 Xylene (Mixed Isomers) 129,305,610 5.7
1993 Xylene (Mixed Isomers) 140,004,661 6.4
1994 Hydrochloric acid 85,067,427 4.4
I.
30
October 1997
SIC 2800
-------
COMPLIANCE
MONITORING
ACTIVITIES
VIOLATION
TRENDS BY
ENVIRONMENTAL
STATUTE
-------
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
4. Compliance Monitoring Activities and Violation
Trends by Environmental Statute
This section provides information about compliance monitoring activities and violation
trends for the chemical industry under the CWA, CAA, RCRA, TSCA, FEFRA, and
EPCRA. This baseline report focuses on the period from 1990 to 1994, at the conclu- ,
sion of which OECA was established and EPA adopted a sector-based approach to
compliance and enforcement. The data presented below have been compiled from
the EPA IDEA database. The following limitations associated with IDEA data are
pertinent to this report:
• The standard method of retrieving data on chemical facilities is to sort the data
by 2800 SIC code series. However, only one-third of all facility records have
SIC codes. Therefore, to retrieve all records related to chemical facilities, a
modified method was used that consisted of: (1) running an initial sort, using
SIC codes; (2) searching records, using key words, such as "chemical"; and
(3) pulling records of known chemical facilities by facility or company name.
Therefore, IDEA data queries do not capture all of the data elements in each
program.
• The IDEA database retrieves and unites information from numerous databases,
including the RCRA Information System (RCRIS), the CERCLA Information
System (CERCLIS), the National Compliance Database (NCDB), the
Aerometric Information Retrieval System (AIRS), and the Permit Compliance
System (PCS). The IDEA database reflects the current data quality and
quantity of those agency systems. Data gaps within the IDEA database are
difficult to quantify and are beyond the scope of this report.
• The IDEA database does not capture differences in programmatic activities (for
example, compliance monitoring activities performed under TSCA differ from
those performed under the CAA). All statutory programs were subject to
changes during reauthorization and subsequent rulemaking efforts. Regions
and states vary somewhat in how they implement programs.
It is important to note the following:
• The data on compliance monitoring activities and violations are sorted by
fiscal, not calendar, year. Therefore, each year starts on October 1 and ends on
the following September 30.
• There is no correction in the data for repeated compliance monitoring activities
at a single facility or multiple violations at a single facility.
• The report does not distinguish among the magnitude of violations; it merely
presents the raw numbers of violations, which may be misleading to the reader.
• It has been assumed that there has been no significant increase or decrease over
time in the number of chemical facilities regulated under each of the statutes
listed above or in the number of applicable compliance obligations. It should
be recognized that none of these factors was static during the trend period and
that those factors might have had an effect on' a change in the number of
violations.
• Databases for tracking compliance with several environmental statutes lack
complete data on compliance monitoring activities-and violations.
To facilitate accurate comparison, the following subsections present numbers of
compliance monitoring activities and trends in violations by environmental statute.
Comparisons among environmental statutes have not been made because of differences
Compliance Monitoring Activities and Violation
Trends By Environmental Statute
33
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
in inception dates of the statutes and database tracking methods. The tables in Appendix
• F are intended to give the reader an overview of enforcement and compliance history by
four-digit SIC code. Chemical facilities that have been identified, but for which no four-
digit SIC code is recorded in the database, are excluded from Appendix F but are
included in the overall industry analysis presented in sections IV and V of this report.
Further, Appendix F does hot include every compliance monitoring activity-for
example, it does not track review of self-monitoring reporting. The totals of compliance
monitoring activities and violations shown in Section IV on a three-digit SIC code
therefore are higher than the totals shown in Appendix F for specific statutes in
individual years. However, the relative differences among the three-digit SIC codes
reported in Section IV are approximately the same as the relative differences among
four-digit SIC codes, as shown in Appendix F.
4.A. Definition of Terms:
Compliance Monitoring and Violations
The following subsections provide brief definitions of the terms "compliance monitor-
ing" and "violation" as well as the method used to present the data.
4.A.1. Compliance Monitoring. EPA and states (under cooperative agreements
or their delegated programs) perform compliance monitoring activities to determine
whether facilities are in compliance with regulatory requirements. Compliance
monitoring can take any of several forms, which include a simple review of records on
site, review of self-monitoring reports, compliance monitoring of operations and
equipment, sampling of waste or environmental media, or compliance monitoring to
determine progress in correcting deficiencies or performing corrective action. Com-
pliance monitoring is performed under a variety of regulations and statutory authori-
ties, including the CWA, CAA, RCRA, TSCA, FIFRA, and EPCRA. The following
subsections provide data on the number of compliance monitoring activities for the
five-year period from 1990 through 1994 and the change in the number of compliance
monitoring activities during that time period.
Figure 4-1.
Compliance Monitoring Activities Trends
by Three-Digit SIC Code, 1990 to 1994.'
1200
1000-
800-
600-
400-
200-
CtWfpfcab
PtatUc Matttlats
•fid Synthetics
Drugs
Soap, Cleaners. Paints and
and Toilet Allied Products
Goods
Industry Sector
Organic
Chemicals
Agricultural
Chemicals
Miscellaneous
Chemical
Products
IV.A.2. Violations. Violations
are identified when compliance
monitoring is conducted by a
regulator or identified by self-
reporting under a Discharge
Monitoring Report (DMR) for the
CWA, for example. Numbers
reported include violations of
orders administered under a statute,
as well as violations of laws or
regulations. All violations are
included in the report, not just those
above a certain threshold. The
report does not distinguish among
the magnitude of violations, for
instance, a record-keeping violation
versus a toxic spill. The following
subsections provide data on the
number of violations for the five-
year period from 1990 to 1994 and
the change in the number of
violations over that time period.
34
October 1997
SIC 2800
-------
4.B. Chemical
Industry Sector
Multi-Media
Compliance
Trends
From 1990 to 1994, the inorganic
chemicals sector was subjected to
compliance monitoring activities
more often than any other chemical
industry sector (see Figure
4-1), followed by the organic
chemicals and plastic materials and
synthetics sectors. During that
period, compliance monitoring
activities of the inorganic chemicals
sector identified the largest number
of violations (see Figure 4-2);
however, the second and third
largest number of violations occurred in the miscellaneous
chemical products and the paints and allied products
sectors, respectively.
The number of compliance monitoring activities per-
formed and violations identified at chemical facilities
based on applicable statutes and regulations showed a
decreasing trend in many sectors from 1990 to 1994,
following the national trend towards decreases in the
number of compliance monitoring activities.
4.C. Clean Water Act (CWA)
Table 4-1 presents compliance monitoring activities and
violations for 1990 to 1994. Over that period, 9,466
compliance monitoring activities were performed under
the CWA, with 1,371 violations
identified. The average numbers
of compliance monitoring activi-
ties and violations annually over
the five-year period are 1,893 and
274, respectively.
Compliance Monitoring
Activities
As shown in Figure 4-3, the
number of compliance monitoring
activities per year between 1990
and 1994 has decreased slightly.
Although there was a 7.7 percent
decrease in compliance monitoring
activities from 1990 to 1994, the
average annual decrease is only 1.5
percent.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 4-2.
Violation Trends by Three-Digit SIC Code, 1990 to 1994.'
Plastic Materials
and Synthetics
Soap, Cleaners. Paints and Alliad Organic
and Toilet Goods Products Chemicals
Industry Sector
Agricultural Miscellaneous
Chemicals Chemical
Products
Table 4-1.
f,,7ft?T*r~' i
Compliance
Monitoring Violations
Activities
1990
1991
1992
1993
1994
Total
i Average
1,953
1,976
1,903
1,831
1,803
9,466
1,893
193
277
371
278
252
1,371
274
Figure 4-3.
CWA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994.*
Compliance Monitoring Activities and Violation
Trends By Environmental Statute
35
-------
Chemical Industry
National
Environmental
Baseline Report
199O to 1994
Table 4-2.
Violations
The number of violations varied more than the number of compliance monitoring activi-
ties during the same time period, with an increase of 30.6 percent, or an average yearly
increase of 6.1 percent. However, from 1992 to 1994, the number of violations identi-
fied annually declined each year.
4.D. Clean Air Act (CAA)
Table 4-2 presents compliance monitoring
numbers for 1990 to 1994 for the CAA. Over
that period, 15,948 compliance monitoring
activities were performed under the CAA,
identifying 981 violations. The average
numbers of compliance monitoring activities
and violations annually over the five-year
period are 3,190 and 196, respectively.
Compliance
Monitoring Violations
Activities
1990
1991
1992
1993
1994
Total
Average
3,141
3,086
3,233
3,182
3,306
15,948
3,190
154
196
187
187
257
981
196
Compliance Monitoring Activities
As shown in Figure 4-4, the number of
compliance monitoring activities per year
between 1990 and 1994 varied slightly.
Although there was a slight increase, 5.3
percent, in compliance monitoring activities
from 1990 to 1994, the average annual
increase is only 1.05 percent.
Violations
The number of violations varied more than the number of compliance monitoring
activities conducted during the same time period, with an increase of 66.9 percent
between 1990 and 1994.
Figure 4-4.
CAA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994J
36
October 1997
SIC 2800
-------
4.E. Resource Conservation and Recovery Act (RCRA)
Table 4-3 presents numbers of compliance monitoring activities and violations under
RCRA for 1990 to 1994. Over that period, 19,962 compliance monitoring activities
were performed under RCRA, with 14,705 violations identified. The average annual
numbers of compliance monitoring activities and violations over the five-year period are
3,992 compliance monitoring activities and 2,941 violations.
Compliance Monitoring Activities
As shown in Figure 4-5, the number of
compliance monitoring activities per year
between 1990 and 1994 has remained rela-
tively constant. Although there was a de-
crease of 7.1 percent in compliance monitor-
ing activities from 1990 to 1994, the average
annual decrease is only 1.4 percent.
Violations
The number of violations varied more than the
number of compliance monitoring activities
during the same time period, with an increase of
41.9 percent, or an average annual increase of
8.4 percent. As in the case of the CWA, viola-
tions decreased annually from 1992 to 1994.
Table 4-3.
Compliance
Monitoring Violations
Activities
1990
1991
1992
1993
1994
Total
Average
4,160
4,245
3,893
3,801
3,863
19,962
3,992
'2,032
2,744
3,726
3,319
2,884
14,705
2,941
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Figure 4-5.
RCRA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994.'
Compliance Monitoring
Activities
Compliance Monitoring Activities and Violation
Trends By Environmental Statute
37
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
I <
4.F. Toxic Substances Control Act (TSCA)
Table 4-4 presents numbers of compliance monitoring activities and violations under
TSCA for 1990 to 1994. Over that period, 1,552 compliance monitoring activities, were
performed under TSCA, with 326 violations identified. The average annual numbers of
compliance monitoring activities and violations over the five-year period are 310
compliance monitoring activities and 65 violations.
Table 4-4.
Compliance
Monitoring
Activities
1990 332
1991 360
1992 328
1993 272
1994 260
Total 1,552
Average 310
Violations
56
71
71
84
44
326
65
Compliance Monitoring Activities
As shown in Figure 4-6, the number of
compliance monitoring,activities between
1990 and 1994 has decreased by 21.7 percent,
or an annual decrease of 4.3 percent.
Violations
The number of violations increased 50 percent
from 1990 to 1993 and decreased 48 percent
between 1993 and 1994. The net result is a
21.4 percent decrease in violations between
1990 and 1994.
Figure 4-6.
TSCA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994.'
. N ,
B Compliance Monitoring \
Activities I _ __„
m Violations J
38
October 1997
SIC
-------
Table 4-5.
4.G. Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA)
Table 4-5 presents numbers of compliance monitoring activities and violations for the
period from 1990 to 1994. Over that period, 547 compliance monitoring activities were
performed under FIFRA, with 318 violations identified. The average numbers of
compliance monitoring activities per year over
the five-year period are 109 compliance
monitoring activities and 64 violations.
Compliance Monitoring Activities
As shown in Figure 4-7, the number of
compliance monitoring activities between
1990 and 1994 decreased 48.9 percent between
1990 to 1994, or an average annual decrease of
9.8 percent.
Violations
During the same time period, the number of
violations also decreased 44.7 percent, or an
average yearly decrease of 8.9 percent.
Compliance
Monitoring Violations
Activities j
1990
1991
1992
1993
1994
Total
Average
135
142
115
86
69
547
109
76 J
78
61
61
42
318
64
Chemical Industry
ffafionaf
Environmental
Baseline Report
1990 to 1994
Figure 4-7.
FIFRA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994.'
g"W*&. -^ •-*""• ••-•'^
.^. —;-;_ —/ | Compliance Monitoring
»» :^y _,f Activities
%- 'if :| 3 Violations
'^•'•Mfi :P^ V ^
Compliance Monitoring Activities and Violation
Trends By Environmental Statute
39
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
t
Compliance
Monitoring Violations
Activities
4.H. Emergency Planning and Community
Right-to-Know Act (EPCRA)
Table 4-6 Table 4-6 presents numbers of compliance
monitoring activities for the period from 1990
to 1994. Over that period, 562 compliance
monitoring activities were performed and 106
violations were identified under EPCRA. The
average number of compliance monitoring
activities per year over the five-year period is
112, and the average number of violations
identified per year is 21.
Compliance Monitoring Activities
As shown in Figure 4-8, the number of compli-
ance monitoring activities per year between
1990 and 1994 has decreased 17.3 percent, or an
average annual decrease of 3.5 percent.
1990
1991
1992
1993
1994
Total
Average
121
98
123
120
100
562
112
28
27
17
19
15
106
21
Violations
During the same time period, the number of
violations decreased 46.4 percent, or an
average annual decrease of 9.3 percent.
Figure 4-8.
EPCRA Compliance Monitoring Activities
and Violation Trends, 1990 to 1994.'
Compliance Monitoring
Activities
40
October 1997
SIC 2800
-------
•»-«*«&•.-
PROMOTING
ENVIRONMENTAL
PERFORMANCE
THROUGH
COMPLIANCE
PROMOTION,
ENFORCEMENT, AND
COMPLIANCE
ASSURANCE
-------
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
5. Promoting Environmental Performance Through
Compliance Promotion, Enforcement, and
Compliance Assurance
Traditional administrative and judicial enforcement actions, brought at both the state and the
federal levels, allow authorities to take immediate action when noncompliance is detected,
impose penalties when appropriate, and prevent noncompliance, thereby fostering competi-
tive advantages. The continued use of traditional types of enforcement actions, however, also
has limitations that can be alleviated by the development of other incentives, assistance
programs, and strategies to help ensure compliance. A strategic combination of traditional
enforcement actions and other, more innovative compliance-related activities allows EPA to
best apportion its resources and to achieve the highest possible level of compliance with
environmental requirements. OECA was established to perform both traditional enforcement
activities and compliance assistance functions.
Although EPA will continue pursuing traditional enforcement actions, EPA also actively
seeks to introduce and develop nontraditional compliance initiatives. Such initiatives can be .
used to create opportunities for industry and regulators to work together to find innovative
and equitable solutions to difficult environmental issues, provide significant benefits in
protecting the environment (especially through pollution prevention), deliver the information
and tools industry needs to prevent instances of noncompliance, and assist EPA and states in
training their personnel. Innovative initiatives that OECA has developed or participated in to
assist in improving the compliance status of the regulated community include:
• Compliance assistance
- Compliance assistance centers
- Sector-specific compliance assistance
• New incentive policies
- Environmental audit policy
- Small business incentives policy
• Supplemental environmental projects (SEP)
• Pollution prevention (P2) program
• Environmental Leadership Program (ELP)
This section describes trends in traditional enforcement approaches under each of the
initiatives listed above and presents some examples of success stories that illustrate how the
chemical industry has participated in innovative approaches to compliance.
5.A. Definition of Enforcement Actions
The following subsections define the term "enforcement actions;" describe the relationships
among compliance monitoring activities, violations, and enforcement actions; and summarize
trends in enforcement by environmental statute. Because the IDEA database is a compila-
tion of program databases related to individual statutes, it may or may not capture the data
for all facilities. The body of the report therefore does not present data on EPCRA and
FIFRA enforcement actions. However, Appendix F does provide data for EPCRA and FIFRA.
5.A.1. Enforcement Actions. An enforcement action is an administrative, civil, or
criminal proceeding carried out by EPA or its delegated representatives in response to a state
of noncompliance with regulatory requirements. Formal enforcement actions can be taken
against facilities at which one or more violations have been identified. Enforcement actions
may be taken for repeated or continuing violations or for only one occurrence, depending on
the circumstances to which the enforcement response policy is applied. The following
subsections provide data on the number of enforcement actions for the five-year period from
1990 to 1994 and the change in the number of enforcement actions over that time period.
' Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
43
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 5-1.
1990 1991 1992 1993 1994 Average
281 Inorganics 20 20
282 Plastics 23 20
283 Drugs 18 24
284 Soaps 30 26
285 Paints 32 36
286 Organics 27 30
287 Agricultural 20 23
289 Miscellaneous 33 27
i,> iiilll '.
*n
5.A.2. Relationship Between Compliance
Monitoring Activities, Violations, and
Enforcement Actions. There have been efforts
in the past to determine compliance levels by '
examining various elements of compliance.'.
Following is a brief discussion' of possible method-
ologies. Trends for conducting such examinations
can be measured by analyzing the number of
compliance monitoring activities and violations.
The first measure is the ratio of enforcement
actions compared with the number of compliance
monitoring activities. Table 5-1 shows the results
of a comparison of enforcement actions and
compliance monitoring activities. This ratio
expresses how often enforcement actions result
from compliance monitoring activities. This value
is a ratio of enforcement actions to compliance
monitoring activities, and is presented for compara-
tive purposes only. This ratio is a rough indicator
of the relationship between compliance monitoring activities and enforcement actions.
This measure simply indicates historically how many enforcement actions can be
attributed to compliance monitoring activities across the eight three-digit SIC codes
during 1990 to 1994. From 1990 to 1994, this ratio increased by 50 percent in the drugs
sector, remained constant in the plastics sector, and declined in all other sectors from 9 to
33 percent. Also of note during this 5 year time period, the number of violations per
enforcement action doubled.
5.B. Chemical Industry Sector Multi-Media
Enforcement Trends
From 1990 to 1994, the inorganic chemicals sector experienced the largest number of
enforcement actions, followed by the organic chemicals and the miscellaneous chemical
products sectors (see Figure 5-1).
23
20
23
21
35
25
17
20
18
19
28
17
41
18
20
21
16
23
27
22
24
18
18
21
19
21
24
23
34
24
20
24
Figure 5-1.
Enforcement Actions by Industry Sector, 1990 to 1994.'
E3
a
O
•1
8
g
8
9
9
0
1
2
3
4
*V> ;«*
-------
5.C. Clean Water Act (CWA)
Table 5-2 presents the numbers of enforcement actions for 1990 to 1994. Over that
period, 1,070 enforcement actions were taken under the CWA. The average number of
enforcement actions per year over that period is 214. Although the number of enforce-
ment actions decreased between 1991 and 1993, the number of such actions actually
increased over the full five-year period from 1990 to 1994 (see Figure 5-2).
5.D. Clean Air Act (CAA)
Table 5-3 presents the number of enforcement actions for the period from 1990 to 1994.
Over that period, 1,380 enforcement actions were taken. The average number of
enforcement actions per year over that five-year period is 276. The number of enforce-
ment actions consistently decreased from 1991 to 1994 (see Figure 5-3).
Chemical Industry
National
Environmental
Baseline Report
199O to 1994
*3tf* '/A
••» *7*:v&
Year
1990
1991
1992
1993
1994
Total
Average
Table 5-2.
Number of
Enforcement
Actions
Table 5-3.
186
253
230
174
227
1,070
214
Year
1990
1991
1992
1993
1994
Total
Average
Number of
Enforcement
Actions
282
302
298
266
232
1,380
276
Figure 5-2.
CWA Enforcement Actions, 1990 to 1994.'
300-1
1990 1991 1992 1993 1994
Year
Figure 5-3.
CAA Enforcement Actions, 1990 to 1994.J
1990 1991 1992 1993 1994
Year
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assyrarsce
45
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 5-4.
Year
1990
1991
1992
1993
1994
Total
Average
Number of
Enforcement
Actions
1,932
1,605
1,364
1,419
1,249
7,569
1,514
Table 5-5.
mpff«i»«BifWHk=:i"«
Year
1990
1991
1992
1993
1994
Total
Average
Number of
Enforcement
Actions
125
129
115
104
65
538
108
Figure 5-4.
RCRA Enforcement Actions/1990 to 1994.'
Figure 5-5.
TSCA Enforcement Actions, 1990 to 1994.'
140
120
100
80-
40
20
125
I
5.E. Resource Conservation and Recovery Act
(RCRA)
Table 5-4 presents the numbers of enforcement actions for the period from 1990
to 1994. During that period, 7,569 enforcement actions were taken. The average
number of enforcement actions taken per year over the five-year period is 1,514.
The number of enforcement actions generally decreased over the five-year period
(see Figure 5-4).
5.F. Toxic Substances Control Act (TSCA)
Table 5-5 presents the number of enforcement actions for the period from 1990 to
1994. Over that period, 538 enforcement actions have been taken under TSCA.
The number of enforcement actions consistently decreased from 1991 to 1994 and
the average number of enforcement actions taken per year over the five-year period
is 108 (see Figure 5-5).
5.G. Compliance Assurance
Compliance information and assistance are provided to the regulated community to
help that community understand and fully comply with the requirements of various
environmental laws. Compliance assis-
tance activities, which take place at both
state and federal levels, are targeted
primarily at small businesses that make up
most of the facilities governed by environ-
mental regulations. Many of EPA's
compliance assistance activities involve
partnerships with states and industry
associations. The participation of states
and industry partners in the development
of such compliance assistance programs
has enabled EPA to tailor its assistance to
those areas in which it can provide the
most benefits and to benefit itself from the
products of those programs.
104
J J J
1990
1991
1992
Year
1993
1994
46
October 1997
SIC 2800
-------
EPA offers three distinct types of compliance assistance: 1) compliance assistance
centers, 2) sector-specific compliance assistance, and 3) hotline assistance.
1 Compliance assistance centers - In 1995 and 1996, EPA, in partnership with
industry, academic institutions, environmental groups, and other federal and state
agencies, established five national compliance assistance centers. The centers, which
are located throughout the country, were established specifically to serve the follow-
ing industrial sectors: printing, agriculture, metal finishing, and auto repair. Those
industrial sectors were targeted for special assistance in part because they are heavily
populated with small businesses and are subject to substantial regulation. The
ultimate goal of the centers is to improve small businesses' understanding of environ-
mental requirements that affect them and to encourage them to take the next steps to
improve compliance. The five centers are:
• Chemical Manufacturers Compliance Assistance Center (CMCAC)
• The Printers' National Compliance Assistance Center
• Agricultural Services Compliance Assistance Center
• National Metal Finishers Resource Center
GREENLINK™ (Automotive Service and Repair Compliance
Assistance Center)
CMCAC is responsible for disseminating compliance assistance tools quickly and
widely, while minimizing their cost. The center is a PC-based information clearing-
house for plain-English guides and user-friendly materials that promote compliance.
The center is in the final implementation phase and will be operational in FY 1998.
OECA is also planning to open a transportation center, printed wire board manufactur-
ing center, and a local government compliance assistance centers.
2 Sector-specific compliance assistance - In recognition of the unique needs of
certain industries, EPA has established custom compliance assistance programs to reach
out to specific industry sectors. Such programs heighten awareness of the environmen-
tal regulations that apply to certain types of industrial operations and provide informa-
tion about pollution prevention opportunities that may be available. Of greatest rel-
evance to the chemical industry are the compliance assistance tools that the industry and
EPA have developed collabpratively for several new rules. Other industry sectors and
other groups to which EPA has offered specific assistance include:
• Wood finishers
• Dry cleaners
• Auto services industry
• Printing facilities
• Metal finishing manufacturers
• Public water supply systems
2 Hotline assistance - Under a variety of programs, EPA has established a
network of telephone and electronic hotlines to help the regulated community and the
public achieve compliance. The hotlines (see Table 5-6) are intended to answer indi-
vidual questions about regulatory compliance in a timely and efficient manner. EPA's
main home page on the World Wide Web provides electronic access to much of the
same information about compliance assistance. The home page can be found at
http://www.epa.gov.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
47
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
i i
Table 5-6.
noTimc iv QIH 6
Acid Rain Hotline
Air RISC Hotline
Asbestos and Lead Program Hotline
Asbestos Ombudsman Clearinghouse/Hotline
Automotive Imports Automated Faxback
System
CleanLAN/ WasteLAN Hotline
Comprehensive Environmental Response,
Compensation, and Liability Information
System (CERCLIS) Helpline
Control Technology Center (CTC)
Customer Call Center/National Computer
Center
Data Processing Support Services National
Computer Center
EMF (Electromagnetic Field) Infoline
Emergency Response Section Notification
Line
Environmental Financial Information
Network (EFIN)
Environmental Justice Information Line
EPA Action Line Region 7
EPA Human Resources Hotline
Ethics Program Advice
Facility Index System (FINDS)
Green Lights and Energy Star Programs
Greenlink
Hazardous Waste Ombudsman
Indoor Air Quality Information Clearinghouse
Information Clearinghouse for Information
and Environmental Factors (CHIEF)
Integrated Data for Enforcement Analysis
(IDEA) System
Method Information Communications
Exchange (MICE)
Phone Number
(202) 233-9620
(919) 541-0888
(301) 530-5603 *
(800) 462-6706 **
(703) 305-5938 *
(800) 368-5888 **
(202) 233-9660
(703) 908-2066
(703) 908-2066
(919) 541-0800
(919) 541-7862 From all government
locations and Research Triangle Park
local calling area
(800) 334-2405 From all non-
government locations outside
Research Triangle Park local area
(919) 541-2385 From all government
locations and Research Triangle Park
local calling area i
(800) 363-2383 **
(415) 744-2000 (For states or territories
of AZ, CA, HI, NV, AS, and GU)
(202) 260-0420
(800) 962-6215**
(913) 551-7122 From all local calls
in Kansas City calling area
(800) 223-0425 From all locations
outside Kansas City (including IA,
MO, NE, and KS)
(202) 260-8836
(202) 260-4550
(703) 908-2493
(202) 775-6650
(202) 564-7032
(202) 260-9361 *
(800) 262-7937 **
(202) 484-1307 *
(800)438-4318 **
(919) 541-5285
(202) 564-2475 *
(703)821-4690
48
* From all government locations and the Washington, DC metropolitan local calling area
** From all nongovernment locations outside Washington, DC metropolitan local calling area
" ~ October 1997
SJC2300
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Table 5-6 (continued)
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Hotline Name
Mobile Sources Region 1
Air Quality Information for New England
EPA Small Business Ombudsman Office
National Lead Information Center Hotline
National Metal Finishing Resource Center
National Pesticides Telecommunications
Network (NPTN)
National Radon Hotline
National Response Center- U.S. Coast Guard
National Small Flows Clearinghouse
Office of Inspector General Whistle-Blower
Hotline
Oil and Hazardous Material Spills
. Office of Environmental Justice (OEJ)
Pay-As- You-Throw Helpline
Permit Compliance System (PCS) Hotline
Pollution Prevention Information Clearing-
house (PPIC) Envirosense
Public Information Center (PIC)
Radon and Indoor Air Helpline
Radon-Fix-It-Line
RCRA/Superfund and. EPCR A Hotline
Region 1 (888) EPA-Tips.
Region 1 General Information
Region 1 Small Parties Hotline
Region 1 Superfund Small Parties Hotline
Region 2 Emergency Notification Spill
• Reporting Hotline
Region 2 Potentially Responsible Party
Hotline
Region 2 Superfund Hazardous Waste Hotline
Region 2 Superfund Investigators Hotline
Region 2 Superfund Ombudsman
Region 3 Customer Service Hotline
Region 4 Helpline
'^ttt^&fttJSii^a**, ^^SSSKi&^iisS'-*" **?*< * "" «. (P^*^^^1"^'^
urcsr $&> w>:y« ^--*«* •«
Phone Number
(617) 565-9145 From all govern-
ment locations and the Massachu-
setts local calling area
(800) 368-5888 From all non-
government locations outside
Massachusetts (including CT, ME,
NH, RI, and VT)
(800) 532-3394 **
(202) 564-7013
(800) 858-7378 **
(800) 767-7236 **
(800) 424-8802 **
(800) 624-8301 **
(202) 260-4977
- (800)424-8802**
(202) 260-6359 *
(800) 962-6215 **
(888) 372-7298
(202) 564-5036
(202) 260-1023
(202) 260-9388
(800) 557-2366 **
(202) 233-9454
(800) 424-9346 **
(888) 372-8477
(617) 565-3420
(800) 762-5727
(800) 762-5727 From all non-
government locations in the New
England calling area
(908) 548-8730
(212) 637-4290 From all govern-
ment locations and New York local
calling area
(800) 245-2738 All nongovernment
locations outside the New York
calling area
(800) 346-5009
(800) 245-2738
(888) 283-7626
(800) 483-2474
(800) 241-1754
* From all government locations and the Washington, DC metropolitan local calling area
** From all nongovernment locations outside Washington, DC metropolitan local calling area
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
49
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Table 5-6 (continued).
hllflli^^ • ~~':™ •--''-"• - '•''*•••?£
\ Hotline Name
Region 4 ERRB Community Hotline
(Removal)
Region 4 Job Information Line
Region 4 South Superfund Community
Relations Toil-Free Number
Region 5 Hotline
Region 6 Public Information
Region 7 Action Line
Region 7 Spill Emergency Line
Region 8 Environmental Information Service
Center (EISC)
Region 9 Asbestos Line
Region 9 Emergency Resource Center
Notification Line
Region 9 Lead Information Line
Region 9 Public Information Center
Region 9 RCRA Hotline/Information Line
Region 9 Stratospheric Ozone Information
Hotline
Resource Conservation and Recovery Act/
Underground Storage Tanks (RCRA/UST),
Superfund, and Emergency Planning and
Community Right-to-Know-Act (EPCRA)
Hotline
Risk Communication Information Line
Safe Drinking Water Hotline
Small Business Ombudsman Clearinghouse/
Hotline ,
Storage and Retrieval of U.S. Waterways
Parametric Data (STORET)
Stratospheric Protection Division Ozone
Information Hotline
Superfund DeMinimis
Region 9 Superfund/Resource Conservation
and Recovery Act (RCRA) Community
Relations Office Information Line
Region 1 Superfund Small-Parties Hotline
Transportation Partners Hotlines
TSCA Assistance Information Service
Phpne Number
(404) 562-8724
(404) 562-9945
(800) 435-9234
(312) 353-9798
(800) 887-6063
(800) 223-0425
(913) 281-0991
(800) 227-8917 All non-
government locations outside the
Colorado local calling area
(415)744-1122
(415) 744-2000
(415)744-1124
(415) 744-1505
(415) 744-2074
(415)711-1141
(703) 412-9810 *
(800)424-9346**
(202) 260-5606
(703) 285-1093 *
(800) 426-4791 **
(800) 368-5888 **
(202) 260-8161 *
(800) 424-9067 **
(800) 296-1996 **
(202) 564-4292
(415) 744-2423
(800) 231-3075 ** (including area
codes 415, 707, 512 and Northern
portion only of 408)
(617) 565-3464 From all govern-
ment locations and nongovernment
locations outside the New England
area (800) 762-5727 From all
nongovernment locations in New
England area
(202) 260-3729
(202) 554-1404
50
* From all government locations and the Washington, DC metropolitan local calling area
** From all nongovernment locations outside Washington, DC metropolitan local calling area
October 1997
SIC 2800
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Table 5-6 (continued).
Hotline Name
Phone Number
Waste Isolation Pilot Plant (WIPP)
Information Line and Yucca Mountain
Information Line
# Information line no longer active
WASJEWISE Helpline
(800) EPA-WISE **
Wetlands Information Hotline
(800) 832-7828 **
** From all nongovernment locations outside Washington, DC metropolitan local calling area
5.H. New Incentive Policies
EPA has two major compliance incentive policies that have application in the chemical
industry:
Environmental audit policy - On December 22, 1995, EPA issued the Voluntary
Environmental Self-Policing and Self-Disclosure Policy, which offers new
incentives for companies to evaluate their own operations for compliance and
voluntarily disclose and correct any violations. The policy provides incentives,
such as reduced penalties for noncompliance, for companies that meet established
conditions for finding, disclosing, and addressing violations. It does not apply to
parties engaging in recurring violations or in violations that result in serious harm
or imminent and substantial endangerment, nor does it apply to criminal conduct
by individuals. In addition, while the punitive component of the penalty may be
reduced, EPA will continue to recover from companies any significant economic
advantage the companies may have gained through noncompliance.
Small business incentives policy - On June 3, 1996, EPA announced the imple-
mentation of the new Policy on Compliance Incentives for Small Businesses. The
policy is intended to promote environmental compliance among small businesses
by providing incentives for participation in compliance assistance programs, for
auditing and disclosure of violations, and for prompt correction of violations.
Under the policy, EPA will eliminate or reduce civil penalties in cases in which
small businesses have made good-faith efforts to comply with applicable environ-
mental requirements by obtaining compliance assistance or auditing and disclos-
ing violations. The policy does not apply if a violation is caused by criminal
conduct or has caused serious harm or imminent and substantial endangerment of
public health or the environment.
5.1. Supplemental Environmental Projects (SEP)
EPA uses SEPs to gain significant environmental benefits in conjunction with the
settlement of enforcement cases. Usually, SEPs are those projects that are undertaken
voluntarily by members of the regulated community in conjunction with case settlements
to provide some level of environmental benefit, in addition to returning to compliance.
In exchange for performing the SEP, the facility is granted relief equaling some fraction
of the total value of the stipulated penalty. Once applied predominantly in cases of
violations of-reporting requirements, SEPs are becoming a more versatile tool. SEPs now
are used frequently to negotiate settlements for violations under the CAA, CWA, RCRA,
and other regulatory programs.
Chemical Industry
National
Environmenfaf
Baseline Report
1990 fie 1994
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
51
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
i.f$»
5.J. Pollution Prevention Program
OECA has issued a policy statement that encourages compliance and enforcement
programs to use the settlement process to identify and implement pollution prevention
activities that are consistent with the agency's overall approach to enforcement. By
incorporating elements of pollution prevention into its traditional enforcement efforts,
EPA encourages companies to conduct projects that benefit both industry and the
environment, as well as promote improved environmental performance. For example,
EPA may use the conditions of the settlement to specify the use of pollution prevention
methods to redress the original violation and achieve compliance. EPA also may reduce
penalties when industries agree to conduct pollution prevention activities that are
considered SEPs.
5.K. Environmental Leadership Program
The ELP is a national program that was pilot-tested by EPA and the states in 1995 and 1996.
Under the program, facilities volunteered to demonstrate innovative approaches to environ-
mental management and compliance. The ELP is intended to recognize and reward compa-
nies that develop and implement comprehensive environmental management systems that
result in significant environmental improvements and outstanding compliance records.
ELP pilot projects focused on such issues as development of innovative environmental
management systems, creation of mentoring programs, testing of third-party auditing and
self-certification protocols, and enhancement of community involvement policies.
5.L. Success Stories
Not all innovative compliance-related activities EPA has undertaken have direct applica-
tion to the chemical industry. EPA, however, continues to work to build better relation-
ships with chemical manufacturers and to jointly develop the tools needed to maximize
compliance in the industry. Although there are many success stories at the state and
regional levels that are not discussed in this report, the following success stories illustrate
how EPA and the chemical industry have worked to attain compliance through the
development and implementation of innovative approaches to enforcement in the
following areas:
• Compliance assistance tools
SEPs
• Pollution prevention program
• Environmental audit policy
ELP
52
October 1997
SIC 2800
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Program Description
The Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA)
requires all federal agencies to prepare "small entity compliance assistance guides"
for rules that trigger a regulatory flexibility analysis. Such guides are to explain the
actions an entity must take to come into compliance and are to be written in plain
language likely to be understood by personnel of small entities. Agencies are
encouraged to cooperate with associations of small entities in developing and
distributing guides.
EPA's Approach
When OECA was reorganized two years before SBREFA was enacted, EPA recog-
nized that an important part of compliance assistance would be "plain English guides"
to compliance with selected rules. The agency also identified the value of promoting
self-auditing for compliance and improving compliance training. Finally, OECA saw
the benefits to all concerned of genuine partnerships between EPA and industry in
developing and disseminating guides and audit training materials.
Chemical Industry Approach
CMA and Synthetic Organic Chemical Manufacturers Association (SOCMA)
independently have recognized the value to their membership of producing compli-
ance assistance tools that draw on their members' collective expertise and that
minimize redundancy. CMA's membership identified key needs for compliance
assistance guides, self-audit check lists and training materials. In 1994, CMA
proposed to EPA that the two organizations cooperate with each other and with other
interested groups in developing effective compliance assistance tools. This coopera-
tive effort has produced valuable sets of tools for several new rules:
EPA and CMA jointly developed a compliance guide, a self-audit check list,
and a training module for 1995 rules governing repair of industrial process
refrigeration leaks. Those publications marked the first time that OECA and
industry had jointly produced a compliance tool for a new rule. Plant
refrigeration technicians and the EPA rule writer participated in the process,
and the tools ultimately were issued as EPA guidance. OECA Assistant
Administrator Steve Herman called them "an excellent example of how
government and industry can work together to protect the health of the
American public and the environment." EPA and CMA have distributed more
than 800 of these tools, and EPA has used the self-audit check list as its own
inspection check list.
CMA and the American Petroleum Institute (API) jointly developed a
compliance guideline for EPA's risk management program rule, which then
was revised to reflect the comments of the Agency's Chemical Emergency
Preparedness and Prevention Office, which noted that, "it provides practical
advice and insights for clearer understanding of the rules' requirements."
CMA and SOCMA jointly prepared a compliance assistance tool and a
training module for the RCRA subpart CC rule that addresses air emission of
violate organic compounds in tanks, containers, surface impoundments, and
landfills. The Agency is how reviewing the rule. Agency contractors
currently are using the training module to train regional and state personnel,
as well as members of the public.
CMA is currently developing compliance assistance tools for the Hazardous
Organic NESHAP and the off-site waste and recovery operations rule for
review by EPA.
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
53
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
ft!1*' v
tf
lilnlll Hill
mm
I
WMMKatfi]
Program Description
SEPs are projects voluntarily undertaken by members of the regulated community in
conjunction with settlements for regulatory violations. Such projects often prove to be
valuable tools for negotiating settlements with the regulated community and provide more
tangible benefits to the environment than could be achieved through the payment of fines
alone. In exchange for performance of a SEP, a facility is granted relief equaling some
fraction of the total stipulated penalty assessed for the violation.
EPA's Approach
Because SEPs can provide substantial benefits to the environment, EPA has allowed an
increasing number of companies to conduct SEPs as part of settlements for regulatory
violations. In 1995, EPA negotiated with numerous companies the conduct of almost 350
SEPs, valued at $103 million. More than one-half of all SEPs negotiated in 1995 were
categorized as pollution prevention or pollution reduction initiatives. Environmental
benefits anticipated from the use of SEPs include: 1) reduction of 637,000 pounds of
nonhalogenated organics, including toluene and xylene; 2) reduction of 483,000 pounds
of halogenated organics, including solvents; 3) reduction of 4,000 tons per year of sulfur
dioxide emissions; and 4) reduction of 104,000 pounds per year of volatile organic
compounds. EPA continues to provide to industry many different types of assistance to
prevent noncompliance. When it is necessary to correct existing violations, however, EPA
expects the increased use of SEPs to facilitate the negotiation of more equitable settlements
with the regulated community, encourage industry to conduct projects that are truly
beneficial to the environment, and provide a punitive element that motivates companies
to avoid future violations.
Chemical Industry Approach
Because SEPs frequently benefit facilities by improving the efficiency and cost-effective-
ness of industrial operations, many members of the chemical industry have welcomed the
opportunity to conduct SEPs as part of settlements with EPA. A few examples of settle-
ments with members of the chemical industry that include SEPs are:
Under a settlement with EPA Region 2, Eastman Kodak Corporation agreed to
conduct several projects at its facility in Rochester, New York. The projects involved
elimination of the use of CFCs from large process refrigeration units and several —
chemical substitutions designed to reduce the volume or toxicity of raw materials
and emissions. The combined projects are expected to reduce the aggregate volume
of pollutants released by the facility by 2.3 million pounds by the year 2001. In
consideration of those SEPs, EPA reduced the civil penalty assessed against Kodak
by $3 million.
In a settlement with EPA, Anzon, Inc. agreed to pay a civil penalty of $57,000 for
certain inventory violations, $43,620 of which may be remitted by EPA upon
completion of SEPs to be performed at the company's facilities in Philadelphia,
Pennsylvania and Laredo, Texas. The Philadelphia project involves the early
removal and disposal of four transformers that contain PCBs. The Laredo project
requires the installation of controls that will enable the facility to capture an
increased volume of antimony oxide emitted from the facility.
In a settlement with EPA Region 6, E.I. Du Pont De Nemours and Company
agreed to pay a civil penalty and conduct a pollution prevention SEP worth an
estimated $3.2 million. The SEP requires the replacement of steam-powered
vacuum jets in adiponitrile process units with mechanical vacuum pumps. The
steam, contaminated with waste materials from the adiponitrile process, previously
was condensed as water and became a waste stream. Replacing the pumps will
eliminate that waste stream and effectively save the costs of handling, treating, and
disposing of the waste.
54
October 1997
SIC 2800
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,-
Program Description
Congress passed the Pollution Prevention Act of 1990 to move government and industry
toward strategies for environmental protection that emphasize the prevention of pollution,
rather than the more traditional methods of controlling and cleaning up waste once it has
been generated. While the traditional "end-of-pipe" approach has done much to clean up
and protect the environment, it has become increasingly clear that to truly solve environmen-
tal problems, generation of pollution must be reduced.
EPA's Approach
EPA has promoted the use of pollution prevention as a means of protecting the environment
and helping industry minimize the costs of managing waste. As one of many efforts to
promote that initiative, EPA may reduce penalties when industries that have not met
regulatory requirements agree to conduct pollution prevention activities. In addition, much
of the compliance assistance that EPA offers to industry involves the provision of informa-
tion about implementing pollution prevention and waste minimization activities and training
in those areas.
Chemical Industry Approach
With the support of EPA, the chemical industry has undertaken significant efforts to reduce
generation of waste and emissions of pollution and encourage sound waste management
practices. In fact, members of CMA and SOCMA adhere to a formal Pollution Prevention
Code-part of the Responsible Care® Initiative-that sets forth three far-reaching goals: 1)
long-term reduction in the amount of pollution released to the air, water, and land; 2)
continuous reductions in the amount of waste generated at facilities; and 3) responsible
management of any remaining wastes and releases. The code establishes a comprehensive
set of guiding principles and an ethical framework for industry operations. The following
examples illustrate how some manufacturers have incorporated the concepts of pollution
prevention into their day-to-day operations:
A new dewatering system installed at Occidental Chemical Corporation's Dela-
ware City, Delaware plant removes solids from tank car wash water for reuse. The
system reduces discharges of water from the plant by 5 million gallons per year and
wastewater treatment sludge by 70 tons per year.
Recently, Amoco Chemical Company's Marietta, Ohio plant received the
Governor's Award for Outstanding Achievements in Pollution Prevention. The plant
reduced air emissions by 38 percent during a two-week period, cut solid and
hazardous waste by nearly 45 percent, and halved the amount of wastewater it treats
and discharges each day.
At its Baltimore, Maryland facility, Reichhold Chemicals reduced waste from
product sampling by designing and installing special canisters that are attached to the
production tanks. The canisters capture a product sample from which a smaller test
sample is drawn. The remaining product sample is returned to the tank. Using
smaller samples cuts waste by 95 percent.
Chemical Industry
Nafienaf
Environmental
Baseline Report
1990 to 1994
Promoting Environmental Performance Through Compliance
Promotion, Enforcement, and Compliance Assurance
55
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
'II *sM
Program Description
Given the size and scope of the chemical industry nationwide; the variety of environmental
media affected by the industry's operations; and the finite resources available at the federal,
state, and local levels to conduct enforcement actions, responsible members of the regulated
community should become more involved in voluntarily finding, disclosing, and correcting
instances of noncompliance at their own operations. By empowering responsible companies
to police their own operations, environmental regulators can: 1) involve companies actively
in the compliance assurance process, 2) build trust and establish better relationships with
such companies, and 3) reallocate limited resources to address other high-priority enforce-
ment needs.
EPA's Approach
EPA issued the Voluntary Environmental Self-Policing and Self-Disclosure Policy, which
offers dramatic new incentives for companies that evaluate their own operations for
compliance and voluntarily disclose and correct violations. The policy provides incentives,
such as reduced penalties and reduced criminal liability, for companies that meet established
conditions for finding, disclosing, and addressing violations. It does not apply to parties
engaging in recurring violations, or in violations that involve criminal conduct or result in
serious harm or imminent and substantial endangerment. Further, while the "punitive"
component of penalties may be reduced, EPA will continue to recover from companies any
economic advantage the companies may have gained from noncompliance.
Chemical Industry Approach
Recognizing the many advantages of voluntary disclosure as a means of negotiating more
equitable settlements for certain environmental violations, members of the chemical industry
voluntarily have disclosed noncompliance to EPA, both before and after EPA announced its
new self-policing initiative. A few examples of the ways in which EPA and chemical
companies are working together to use voluntary disclosure to improve the regulatory
compliance process are:
Polaroid Corporation notified EPA in October 1994 that an internal audit had
revealed the manufacture and use of a new chemical for several years without
compliance with requirements for premanufacture notice under TSCA. Polaroid
paid a penalty of $80,000, reduced from $160,000 in light of the prompt and
voluntary disclosure of the violations.
After a voluntary disclosure made by Eastman Kodak Company on July 1, 1993,
EPA charged the company with one count of unauthorized disposal of PCBs.
Because the violation had been disclosed voluntarily, the penalty that Kodak was
required to pay to EPA was reduced to $13,750, pursuant to the 1986 audit policy
then in effect.
After a voluntary disclosure made by Ciba-Geigy Corporation, Ciba-Geigy was
required to pay to EPA a penalty of $182,550 for violations of sections 5, 8, and 13
of TSCA. When determining the amount of the penalty, EPA considered Ciba-
Geigy's voluntary disclosure of those violations a mitigating circumstance.
EPA settled two enforcement actions brought against Glidden Company for
importing and distributing an unregistered pesticide. The enforcement actions,
which cited violations under both TSCA and FIFRA, came about as a result of a
series of disclosures made by Glidden to EPA regarding violations of sections 5, 8,
12, and 13 of TSCA. Because the violations were disclosed voluntarily, Glidden
paid a reduced penalty of $290,100.
56
October 1997
SIC 2800
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Program Description
The Environmental Leadership Program (ELP) is a national program currently being pilot-
tested by EPA and the states, under which certain facilities have been selected to demonstrate
innovative approaches to environmental management and compliance. The ELP recognizes
and rewards companies that develop and implement comprehensive environmental manage-
ment systems that result in significant environmental improvements and outstanding
compliance records. ELP projects focus on such issues as development of innovative
environmental management systems, creation of monitoring programs, testing of third-party
auditing and self-certification protocols, and enhancement of community involvement
policies.
EPA's Approach
On April 7, 1995, EPA announced that it had selected 12 facilities to participate in the ELP.
The 12 facilities (10 private-sector firms and 2 federal facilities) were selected from a field of
more than 40 applicants. EPA selected Ciba-Geigy Corporation's plant in St. Gabriel,
Louisiana as one of the 12 facilities that would participate in the pioneering effort. The ELP
affords EPA a unique opportunity to establish meaningful partnerships with members of the
chemical industry and to help showcase innovative approaches to protecting the environ-
ment.
Chemical Industry Approach
Ciba-Geigy was selected for the program in part because of an innovative waste minimiza-
tion project undertaken by its St. Gabriel facility to reuse calcium carbonate waste as a lime
substitute for farming. Excessive acidity poses major problems to farmers in Louisiana. It .
binds nutrients in the soil, making fertilizers less efficient, and limits crop production. Soil
pH levels can be raised with the application of lime but, at $20 to $30 per ton, lime can be a
costly remedy. Ciba-Geigy's project involves strengthening and purifying calcium carbon-
ate so that it can be used as a lime substitute to raise the pH level of soil and improve crop
yields in Louisiana. Calcium carbonate solids are produced when waste hydrochloric acid, a
by-product of the production of herbicides at the St. Gabriel facility, is neutralized with lime.
For many years, the solids — approximately 3,721 tons per year — were disposed of in an
industrial waste landfill, consuming large quantities of the state's limited landfill capacity.
To address this concern, Ciba-Geigy modified its filtration process to dewater the calcium
carbonate solids, strengthening and purifying them for reuse. From 1989 to 1990, 2,900
tons of calcium carbonate were donated to 15 farmers, saving them approximately
$75,000 in the cost of lime and significantly improving crop yields. In 1991, Ciba-
Geigy received the state's first beneficial reuse permit from the Louisiana Department
of Environmental Quality (DEQ). Ciba-Geigy's project represents a win-win situation
for all involved — Ciba-Geigy, local farmers, and the environmental community. The
project has three distinct benefits:
Ciba-Geigy saves more than $595,000 per year in disposal costs, with an investment
of $115,000 per year for program implementation.
Approximately 14,882 tons of calcium carbonate were distributed to farmers from
1989 to 1993, saving more than $417,000 in the'cost of lime and improving crop
yields substantially.
Limited landfill capacity in Louisiana is preserved. Through active participation in
the ELP, Ciba-Geigy works in partnership with EPA and state staff to help demon-
strate and promote the use of such innovative reuse technologies to other members
of the chemical industry and to assist in the development of other innovative systems
that promote responsible environmental management.
Chemical Industry
National
Environmental
Basdlim* Report
1993 to 1994
Promoting Environmental Performance Through Compliance
Promotion,, Enforcement, and Compliance Assurance
57
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
5.M. Trade Associations/Industry Sponsored Activities
The Global Environmental Management Initiative (GEM!) 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 Union Carbide Corporation and Dow Chemical.
The 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.
The National Science Foundation and the EPA's Office of Pollution Prevention and
Toxics signed an agreement in January of 1994 to coordinate the two agencies' pro-
grams 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 synthesiz-
ing chemicals in large quantities.
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.
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 1993, the International Standards Organization created a
technical committee to work on new standards for environmental management systems.
The Responsible Care® Initiative of the Chemical Manufacturers Association requires
all members and partners to continuously improve their health, safety, and environmen-
tal performance in a manner that is responsive to the public. The concepts of the
program, launched in 1988, are now being applied in countries around the world. The
program is a comprehensive, performance-oriented initiative composed of 10 progres-
sive guiding principles and six codes of management practices. The management
practices cover all aspects of the chemical products. Pollution prevention is addressed
by the Pollution Prevention Code, which requires companies to make a clear commit-
ment to ongoing reductions, at each of a company's facilities, in releases to the air,
water, or land and in the generation of wastes. The program also requires a commitment
to compliance with applicable regulatory requirements and requires further that mem-
bers of CMA audit or review their regulatory compliance.
Through the program, CMA members and partners gain insight from the public through,
among other means, a national public advisory panel and more than 250 local commu- ,
nity advisory panels. Participation in the program is an obligation of membership in
the CMA.
The Synthetic Organic Chemical Manufacturers Association (SOCMA), whose member-
ship consists of small-batch and custom chemical manufacturers that typically have
fewer than 50 employees and less than $50 million in annual sales, encourages its
members to achieve continuous improvement in the performance of their health, safety,
and environmental programs through implementation of the chemical industry's
Responsible Care® Initiative. SOCMA is a partner in that program.
58
October 1997
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its*.. ,»_»*.
FUTURI
DIRECTIONS
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6. FUTURE DIRECTIONS
While the use of traditional enforcement actions undeniably remains an essential compo-
nent of its contemporary compliance strategy, EPA now believes that other, more innova-
tive activities and programs also must be introduced if we are to achieve the highest
possible level of compliance with environmental requirements. The challenge at hand is
great. EPA, however, remains confident in and committed to its efforts to continue to
reach out to members of the chemical industry to promote responsible management
practices and move forward into a new era of environmental compliance.
Recognizing that a unilateral approach to enforcement no longer may be the most effective
strategy for ensuring compliance with environmental regulations, EPA has taken action to
develop new programs that encourage companies to engage in environmental audits or
conduct other proactive environmental management efforts. By introducing nontraditional
compliance initiatives that foster environmental accountability and promote responsible
management practices, EPA has provided unique opportunities for the chemical industry
to reach new heights in environmental management and performance.
By preparing this baseline report, which provides an overview of compliance trends and
a profile of the chemical industry, EPA has taken an important step toward defining
future objectives. A variety of approaches are being developed to address enforcement
and compliance issues and the identification of opportunities to build innovative
partnerships with industry and the public. Future baseline reports will permit EPA to
assess progress and will help stimulate the development of additional compliance
initiatives. Through an ongoing analysis of the chemical industry, EPA will continue to
refine its efforts to work together with industry to achieve its primary goal — environ-
mental protection through compliance with the law.
Because EPA is accountable to its constituents, the amount and types of compliance
activities and the industry's compliance level must be reported, in addition to reporting
of EPA program activities. Through a more comprehensive and sophisticated reporting
system, EPA will strive to measure and report the effectiveness and successes of
innovative approaches to enforcement and compliance. In that way, EPA can fulfill its
mission to the public by addressing environmental problems in the broadest sense,
working in partnership with industry, integrating innovative and traditional approaches
to enforcement, and reporting the results of compliance and enforcement activities to
measure success. ,
EPA's future directions include:
• Establishing the Chemical Industry Compliance Assistance Center
• Expanding its participation in, development of, or review of industry compli-
ance assistance tools
• Tailoring compliance assistance and enforcement activities so that they will
have the greatest effect
• Supporting regional compliance activities through the MOA process
• Providing compliance data to support the EPA/CMA Root-Cause Analysis
Project and similar projects
• Providing compliance data for analysis of the chemical sector
• Providing benchmarks for measuring success
• Providing a platform for future QA/QC initiatives and sustained public access
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Future Directions
61
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S™££f'" ^®s^&^^'f^5Jjjjjj;
%C!?»^^:
ENDNOTES
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ENDNOTES
Chemical Industry
National
Environmental
Baseline Report
1990fo 1994
€1 U.S. Environmental Protection Agency (EPA). 1995. Enforcement In Transi-
tion. The Environmental Forum. December.
EPA. 1995. Profile of the Organic Chemical Industry. EPA, Office of En-
forcement and Compliance Assurance. September.
€ EPA. 1995. Profile of the Inorganic Chemical Industry. EPA, Office of
Enforcement and Compliance Assurance. September.
€1 Chemical Manufacturers Association (CMA). 1996. U.S. Chemical Industry
Statistical Handbook.
© CMA. 1995. The U.S. Chemical Industry Performance in 1994 and Outlook.
February.
* Dun and Bradstreet Information Services, Inc. 1994. Database of Information
on U.S. Companies.
Q Bureau of the Census, U.S. Department of Commerce. 1995. Database of
Information on U.S. Companies.
O EPA. 1995. Toxics Release Inventory (TRI): Database on TRI Releases and
Transfers. (CD-ROM)
I EPA. Toxics Release Inventory: Public Data Release, for each year from 1990
through 1994.
J EPA. 1995. Integrated Data for Enforcement Analysis (IDEA) Database.
August.
Endnoies
65
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APPENDICES
A-G
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Chemical Industry
APPENDIX A—ACRONYMS
Environmental
Baseline Report
1990 to 1994
AIRS Aerometric Information Retrieval System
API American Petroleum Institute
ARAR Applicable or Relevant and Appropriate Requirements
CAA Clean Air Act
CBEP Community Based Environmental Protection
CERCLA Comprehensive Environmental Response, Compensation, and
Liability Act
CERCLIS CERCLA Information System
CFC Chlorofluorocarbons
CFR Code of Federal Regulations
CIS Chemical Industry Branch
CMA Chemical Manufacturers Association
CMCAC Chemical Manufacturers Compliance Assistance Center
CWA Clean Water Act
DOC Department of Commerce
DMR Discharge Monitoring Report
ELP Environmental Leadership Program
,EPA U.S. Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FEPCA Federal Environmental Pesticide Control Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facilities'Index System
GDP Gross Domestic Product
HAP Hazardous Air Pollutants
HSWA Hazardous and Solid Waste Amendments
IDEA Integrated Data for Enforcement Analysis
LDR Land Disposal Restrictions
LEPC Local Emergency Planning Committee
MACT Maximum Available Control Technology
MCL Maximum Contaminant Level
MCLG Maximum Contaminant Level Goal
NAICS North American Industry Classification System
NCDB National Compliance Database
NCP National Oil and Hazardous Substances Pollution
Contingency Plan
NESHAP National Emissions Standards for Hazardous Air Pollutants
NPDES National Pollutant Discharge Elimination System
NSPS New Source Performance Standards
OECA Office of Enforcement and Compliance Assurance
OSHA Occupational Safety and Health Act
PA/SI Preliminary Assessment and Site Inspection
PCB Polychlorinated Biphenyl
PCS Permit Compliance System
PMN Premanufacture Notice
POTW Publicly-Owned Treatment Works
RCRA Resource Conservation and Recovery Act
RCRIS RCRA Information System
SARA Superfund Amendments and Reauthorization Act
SEP Supplemental Environmental Projects
SIC Standard Industrial Classification
fej
APPENDIX A— Acronyms
A-1
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SDWA Safe Drinking Water Act
SOCMA Synthetic Organic Chemical Manufacturers Association
TSCA Toxic Substances Control Act
TRI Toxics Release Inventory
TSDF Treatment, Storage, and Disposal Facility
UIC Underground Injection Control
UST Underground Storage Tank
liil Man!
P '• ' ''
|
i
I
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APPENDIX B — GLOSSARY OF KEY TERMS
Air Release: Releases to air are reported as either stack or fugitive emissions.
Stack emissions are releases to air that occur through confined air streams, such
as stacks, vents, ducts, or pipes. Fugitive emissions are any releases to air that
are not released through a confined air stream, such as equipment leaks,
evaporative losses from surface impoundments and spills, and releases from the
ventilation systems of buildings.
CERCLA Information System (CERCLIS): CERCLIS is an information system
for tracking and retrieving data relevant to the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) program (for example,
the number of hazardous waste sites in each EPA region).
Chemical Industry Branch (CIB): The GIB is an entity within EPA that is located
in the Office of Enforcement and Compliance Assurance (OECA), Office of
Compliance, in the Chemical, Commercial Services, and Municipal Division.
The CIB develops and implements a national sector-based, multimedia program
of compliance activities for the chemical industry, classified in the 2800 series
of the Standard Industrial Classification (SIC) code system.
Chemical Industry: The chemical industry, classified in the 2800 series of the SIC
code, includes facilities that manufacture predominantly: (1) inorganic
chemicals; (2) plastic materials and synthetics; (3) drugs; (4) soaps, cleaners,
and toilet goods; (5) paints and allied products; (6) organic chemicals; (7)
agricultural chemicals; and (8) miscellaneous chemical products.
Inorganic Chemical Industry: This industry segment uses the earth's natural
resources to produce a wide array of goods. The industry's primary focus is
breaking down salt (NaCl) into its principal components, sodium (Na) and
chlorine (Cl), which are used in a variety of chemical processes.
Integrated Data for Enforcement Analysis (IDEA): IDEA is a data integration
system that can retrieve information from all major EPA program office databases.
IDEA uses the Facilities Index System (FINDS) identification number to unite
various records from EPA's databases to create a master list of records for any
. given facility. Some of the data systems accessible through IDEA are: AIRS
(Aerometric Information 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 Compli-
ance Database, Office of Pollution Prevention, Pesticides, and Toxic Substances),
CERCLIS (Comprehensive Environmental Response, Compensation, and
Liability Information System), and TRIS (Toxics Release Inventory System).
IDEA also contains information from such outside sources as Dun and
Bradstreet Information Services, Inc. and the Occupational Safety and Health
Administration.
Land Release: Under Toxics Release Inventory (TRI), releases to land are those
that occur within the boundaries of the reporting facility. Releases to land
include disposal of toxic chemicals in landfills (in which wastes are buried),
land treatment and farming applications (in which a waste containing a listed
chemical is applied to or incorporated into soil), surface impoundments (which
are uncovered holding areas used to volatilize or settle waste materials), other
land disposal methods (such waste piles), and certain other events (such as
spills or leaks).
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
APPENDIX B — Glossary of Key Terms
B-1
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Chemical Industry
National
Environmental
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1990 to 1994
Off-Site Transfer: Under TRI, an off-site transfer is a shipment of a listed chemi-
cal in waste to a facility that is geographically or physically separate from the
facility reporting to TRI. Such transfers represent a movement of the chemical
away from the reporting facility.
Organic Chemical Industry: This chemical industry segment processes raw
materials that have a carbon structure into primary products or building blocks,
including ethylene, propylene, benzene, methanol, toluene, xylenes, butadiene,
and butylene. Chemicals are added in subsequent phases to create the end
product.
Other Off-Site Transfers: Under TRI in this report, "other off-site transfers" are
transfers that were reported without an appropriate waste management activity
code and that therefore could not be assigned to a transfer category.
Release: Under TRI, a release is a discharge of a listed chemical to the environ-
ment. Releases include emissions to the air, discharges to bodies of water,
releases to land from a facility (such as a landfill or surface impoundment),
and contained disposal into underground injection wells.
RCRA Information System (RCRIS): RCRIS is a database that tracks informa-
tion relevant to the RCRA program (for example, number of regulated facili-
ties, inspections conducted, violations found, and enforcement actions taken at
each facility).
Standard Industrial Classification (SIC) Code: The SIC code system is a statisti-
cal classification standard used prior to 1996 for all establishment-based federal
economic statistics.
Stipulated Penalty: This is a fixed sum of money that a defendant agrees to pay
for violating the terms of a judicial consent decree.
Surface-Water Release: Under the TRI, releases to surface water include dis-
charges to streams, rivers, lakes, oceans, and other bodies of water. They
include releases from contained sources, such as industrial process outflow
pipes or open trenches. Releases from runoff, including stormwater runoff,
also are reportable under TRI.
Toxics Release Inventory (TRI) Facilities: TRI facilities are those manufacturing
facilities that have 10 or more full-time employees and whose operations create
transfers and releases of listed chemicals that exceed established thresholds on
chemical throughput. Such facilities must submit estimates of quantities
released or transferred for all chemicals that are on EPA's defined list that the
facility uses in quantities that exceed a specific threshold quantity.
Transfer: Under TRI, a transfer occurs when a listed waste is removed to a facility
that is geographically or physically separate from the facility that is required to
report under the TRI. Transfers include wastes sent to publicly-owned treat-
ment works (POTW), sent off-site for recycling, combusted off-site for energy
recovery, moved off-site for treatment, or taken to another facility for disposal.
Transfer to a Publicly-Owned Treatment Works (POTW): Under TRI, reported
information includes wastewaters that are transferred through pipes or sewers
to a POTW. A POTW is a wastewater treatment facility (sewage treatment
plant) that is owned by a state or municipality.
B-2
October 1997
SIC 2800
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Chemical Industry
AtotiamrJ
Environmental
Baseline Report
1990 to 1994
Transfer Off Site for Recycling: Under TRI, a transfer off site for recycling is the
shipment of listed chemicals off site for recycling. The chemicals are subjected
to solvent recovery, metals recovery, acid regeneration, or other processes.
Once recycling has been accomplished, the chemicals may be returned to the
originating facility or sold for further processing or use.
Transfer Off Site for Energy Recovery: Under TRI, such a transfer involves
listed chemicals that are sent off site for energy recovery and are combusted off
site in industrial furnaces (including kilns) or boilers that generate heat or
energy for use at the off-site location. Treatment of a chemical by incineration
is not considered energy recovery.
Transfer Off Site for Treatment: Under TRI, reported information includes listed
chemicals that are sent off site and treated by such processes as biological
treatment, neutralization, incineration, or physical separation. The methods
achieve various degrees of destruction of the toxic chemical. In some cases
(such as stabilization or solidification), the chemical is not destroyed but is
prepared for further waste management, such as contained disposal.
Transfer Off Site for Disposal: Under TRI, listed chemicals sent off site to a
facility for disposal usually are released to land or injected underground at
the off -site location.
Underground Injection: Underground injection is a contained release of a fluid.
into a subsurface well for waste disposal. Most underground injection
reported to TRI involves injection of waste into Class I or Class V wells.
Class I wells are used to inject liquid hazardous wastes or industrial and
municipal wastewaters beneath the lowermost underground source of drink-
ing water. Class V wells usually are used to inject nonhazardous fluids into
or above an underground source of drinking water. Beginning with 1996 data,
reporting to TRI will distinguish between the two types of wells because they
differ significantly in environmental effects.
APPENDIX B — Glossary of Key Terms
B-3
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
-•is
What \e an On-6ite
According to EPA's 1991 Toxic Release Inventory Public Data
of a toxic chemical to the environment. This includes releases to
site discharge
land."
2, A release is any discharge into any surface water
body, including process outfalls, releases from
on-sltc wastewater treatmentsystems, and any
stormwater runoff which is contaminated with
the listed chemicals, The specific water body into
which the discharge is made must be named.
5. A release Is the disposal of TRI chemicals by
means of deepwell Injeottone.
A release is any discharge into the all4
whether it is a fugitive or a stack emission.
. Fugitive emissions include leaks from valves
and pump seals; evaporative losses from
surface impoundments; and releases other
than through stacks, vents, ducts,
confined air streams.
4. A release is any discharge to jand made on-site.
; ." this includes surface impoundments, .landfills,
and land .treatment. : ' . '. . ; '.
* Copied from the Louisiana Toxics Release Inventory 1993
B-4
October 1997
SIC 2800
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
IB m OffrStta
w EPA'» 1391 TOKM; Rs easus lownfexy
P*ts Relfi&ss, an 6*fH5ite Trawrfw i& a
bows shswitciif in <*#6fr} te-
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xiV" -w j
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.-;.^M
* Copied from the Louisiana Toxics Release Inventory 1993
APPENDIX B — Glossary of Key Terms
B-5
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
fe j
Rec:
Off-Site Transfers of TRI Toxic Chemical
' -'•... .••,.'":„,_'..'_•_
, Treatment and Disposal
I
I TRI Chemicals
Transferred Off-Site for Recycling: Energy
Recovery: Treatment and/or Pteposal
'-Site
Dsepwell
Injection
Products of
Recycling/
Treatment/
Energy
Reovery
• •MMMHIBl
Pteposal 1.,,
. . Releassstottie ..•/•
Environment Resulting from
Recycllna/Treatinent/
Energy Recovery
Products Resulting from
Returned for Re-Use in Prodiction
ery
* Copied from the Louisiana Toxics Release Inventory 1993
B-6
October 1997
SIC 2800
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APPENDIX C — ENVIRONMENTAL STATUTES
AND REGULATIONS
This appendix provides a brief overview of some of the federal environmental statutes
that apply to the U.S. chemical industry. It is important to note that a single acronym is
used in this document to refer to the entire legislative history of a statute. For example,
the Resource Conservation and Recovery Act (RCRA) was enacted in 1976 and amended
in 1980 and again in 1984. Although RCRA amended the Solid Waste Disposal Act of
1965, RCRA and all its current amendments are included in the acronym RCRA, as it is
used in this document. No attempt has been made to comprehensively review all the
statutes, their amendments, or regulations promulgated under their authorities because
that is beyond the scope of the current effort.
RESOURCE CONSERVATION AND RECOVERY ACT (RCRA)
The Resource Conservation and Recovery Act (RCRA) was enacted in 1976 to address
problems in the U.S. related to management of solid and hazardous wastes. RCRA,
which actually amended the Solid Waste Disposal Act of 1965, was amended in 1984
with the passage of the Hazardous and Solid Waste Amendments (HSWA). For the sake
of convenience, the term RCRA will be considered here to encompass all related legisla-
tion and amendments not mentioned herein. Two major subtitles of RCRA affect the
operations of the chemical manufacturing industry: Subtitle C, which regulates hazard-
ous waste management, and Subtitle I, which regulates underground storage tanks.
Regulations promulgated under subtitle C of RCRA address the identification, genera-
tion, transportation, treatment, storage, and disposal of hazardous wastes. The regula-
tions are found in 40 Code of Federal Regulations (CFR) part 124 and parts 260 to 279.
Under RCRA, persons who generate secondary materials must determine whether those
materials are defined as solid wastes and as hazardous wastes. Solid wastes are hazard-
ous wastes if they are listed specifically by EPA as hazardous, or if they exhibit charac-
teristics of a hazardous waste: toxicity, ignitability, corrosivity, or reactivity.
RCRA establishes management standards for hazardous wastes that are specific to the
type of activity being performed. Generators of hazardous waste may accumulate such
wastes on site, usually for a period of 90 days or less, only in containers, tanks, and
containment buildings. While waste is on site, the generator is subject to general and
unit-specific accumulation standards. The generator also must complete a hazardous
waste manifest before waste is offered for transportation off site and must comply with
the land disposal restrictions (LDR) program.
A chemical manufacturer that engages in treatment, long-term storage, or disposal of
hazardous waste (treatment, storage, and disposal facilities [TSDF]) must obtain a
permit or authorization under interim status for those activities. Chemical manufactur-
ers that are TSDFs are subject to several requirements, including general standards for
facilities, such as those requiring waste analysis, training of personnel, preparedness and
prevention planning, and contingency planning. TSDFs also are subject to unit-specific
requirements for the types of activities being performed (for example, operation of a
landfill or an incinerator), corrective action for cleanup of releases of hazardous wastes
or hazardous constituents, financial assurance for closure'and corrective action, closure,
and compliance with the LDRs.
Many chemical manufacturing facilities also are subject to the regulations in 40 CFR
part 280 promulgated under RCRA subtitle I, the underground storage tank (UST)
program. The UST regulations apply to entities that store "regulated substances" —
either petroleum products or hazardous substances (except hazardous waste) identified
under the Comprehensive Environmental Response, Compensation, and Liability Act
Chemical Industry
National
Environmental
Baseline Report
199Oto 1994
APPENDIX C — Environmental
Statutes and Regulations
C-l
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
mis
If II
If,, :,•:;;£
(CERCLA). UST regulations address design standards, leak detection, operating
practices, response to releases, and financial responsibility for releases and impose •
closure standards.
Requirements under RCRA typically are implemented by the states. Under RCRA, a
state may apply for authorization to administer and enforce the hazardous waste and
UST programs, if the state can demonstrate through submittal of an application to EPA
that its requirements are substantially equivalent to federal requirements. States also
may establish requirements that are more stringent or broader in scope than the federal
requirements. Although a state agency may obtain regulatory authorization, EPA retains
authority for oversight of all activities.
Compliance monitoring under RCRA includes a combination of reporting requirements
and field inspections to identify violations. Field inspections are conducted under the
authority of section 3007 of RCRA. Such inspections include compliance evaluation
inspections, case development inspections, compliance sampling evaluations, ground-
water monitoring evaluations, and operation and maintenance inspections conducted by
inspectors from EPA regional offices and states. Under RCRA, compliance monitoring
activities at chemical facilities consist of both field inspections and record reviews. The
inspections focus on compliance with requirements under the RCRA program, as well
as corrective action requirements under the terms of an order or permit.
COMPREHENSIVE ENVIRONMENTAL RESPONSE,
COMPENSATION, AND LIABILITY ACT (CERCLA)
The Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA) was passed in 1980 and amended by the Superfund Amendments and
Reauthorization Act (SARA) of 1986 to address threats to human health or the
environment created by uncontrolled hazardous waste disposal sites. For the sake of
convenience, the term CERCLA will be considered here to encompass all related
legislation and amendments not mentioned herein. CERCLA generally does not impose
requirements governing the day-to-day operations of chemical manufacturing facilities;
rather, it imposes liability for the costs of investigation and cleanup of releases of
hazardous substances. The liability provisions apply to potentially responsible parties
(PRP) that: (1) generate hazardous substances that are sent to a site at which a hazardous
substance has been released or at which there is a threat of release, (2) transport wastes to
such a site, or (3) own or operate a site at which a hazardous substance has been released
or at which there is a threat of release of such a substance. Under CERCLA, liability is
strict, joint, and several: a single PRP can be held liable for the entire cost of cleanup,
regardless of its contribution to the release.
Cleanups under CERCLA are implemented in accordance with regulations under the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR part
300). The NCP provides for two types of response actions: removal actions and
remedial actions. Removal actions are taken to address a release or threatened release
of hazardous substances that poses an immediate threat to human health or the environ-
ment. Removal actions usually are short in duration. Remedial responses are long-term
actions that are taken to reduce the risks to human health or the environment posed by
a release or threatened release. A site under consideration for a response action first
undergoes a preliminary assessment and a site inspection (PA/SI). If the results of the
PA/SI indicate that it may be necessary to address a threat to human health or the
environment through a long-term remedial response, the site is evaluated under the
Hazard Ranking System (HRS) for placement on the National Priorities List (NPL).
Once the site has been listed on the NPL, a remedial investigation and a feasibility study
(RI/FS) are performed to determine the nature and magnitude of any releases at the site
C-2
October 1997
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
and to identify a remedy, if needed, to address such releases. Finally, a remedial design
(RD) is prepared and a remedial action (RA) conducted to implement the selected
remedy.
Cleanups conducted under CERCLA generally must meet applicable or relevant and
appropriate requirements under federal and state laws (for example, RCRA and the
Clean Water Act [CWA] and their state analogues). Although no permits are required
for actions conducted at a site that is undergoing cleanup, all substantive requirements
(such as design and operating standards for an on-site incinerator) must be met. Clean-
ups are conducted in one of two ways: (1) by PRPs under the terms of an order or
decree from EPA or a state, or (2) by EPA or the state, with the government later seeking
reimbursement from the PRPs to recover the costs of cleanup.
Since CERCLA does not govern the day-to-day operations of facilities, compliance
inspections typically are not associated with CERCLA. However, EPA and states
monitor cleanups conducted by PRPs under CERCLA through oversight inspections
conducted under the authority of CERCLA. The inspections are designed to evaluate
a PRP's compliance with the provisions of an approved work plan or comparable
document that outlines the required RI/FS, RD, or RA.
EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-
KNOW ACT (EPCRA)
The Emergency Planning and Community Right-to-Know Act (EPCRA), also known as
Title III of SARA, was passed in 1986 to require certain facilities to divulge information'
about the amounts of hazardous substances they store and release. Regulations written
under the law are found in 40 CFR parts 350-399. For the sake of convenience, EPCRA
will be considered here to encompass all related legislation and amendments not men-
tioned herein. Three major provisions of EPCRA apply to the chemical manufacturing
industry: (1) requirements for reporting of most releases, (2) emergency planning
provisions, and (3) the Toxics Release Inventory (TRI) program.
Under EPCRA regulations at 40 CFR part 355, facilities are required to report releases
of extremely hazardous substances in amounts greater than reportable quantities specific
to each substance. The provisions governing reporting of releases are similar to those
set forth under CERCLA, which requires reporting of releases of those substances
identified under CERCLA as hazardous.
The emergency planning provisions of the law require that facilities report to the local
emergency planning committee the quantities stored at those facilities of: (1) hazardous
chemicals (as defined by the Occupational Safety and Health Administration) for which
the preparation of Material Safety Data Sheets (MSDS) is required, and (2) extremely
hazardous substances. Under the program, facilities that store hazardous chemicals in
amounts in excess of threshold quantities specific to each chemical each year must
submit to the local emergency planning committee (LEPC) MSDSs or chemical inven-
tory forms. Local response authorities use the information in developing community-
wide emergency response plans.
Reporting information to TRI is a requirement under EPCRA that applies strictly to
chemical manufacturing facilities that have 10 or more employees. Facilities that
manufacture, process, or otherwise use more than a specified quantity of any of more
than 600 listed chemicals must estimate releases of each of those chemicals. The
information must be entered on a form (Form R); the form requires that the affected
facility estimate releases of listed chemicals to air and water and in solid wastes that
leave the facility. Form R must be submitted to EPA once a year for each chemical,
and the data are compiled once every two years.
APPENDIX C — Environmental
Statutes and Regulations
C-3
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Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
;, j
** 1
|:::,:, ,:::,,
I I
Section 325 of EPCRA provides for administrative and civil penalties. However,
because many substances regulated under EPCRA also are regulated under TSCA,
compliance with EPCRA regulations may be monitored through the use of enforcement
authorities under TSCA- For example, violations of EPCRA requirements can be
identified while conducting inspections at facilities under the inspection authorities set
forth in section 11 of TSCA. Because states are not authorized under TSCA to conduct
such compliance monitoring activities, personnel in EPA regional offices usually do so.
CLEAN AIR ACT (CAA)
The Clean Air Act (CAA) was passed and later amended by the Clean Air Act Amend-
ments (CAAA) of 1990, with the goal of protecting and enhancing the nation's air
resources. Regulations in 40 CFR parts 1-99 were promulgated under this law and
amendments. Under the law, each state must develop an implementation plan to identify
sources of air pollution and implement measures to meet federal air quality standards.
States historically have required sources of air pollutants to obtain preconstruction and
operating permits. The three other major provisions of the CAA that apply to the
chemical manufacturing industry are: (1) the new source performance standards (NSPS),
(2) the national emissions standards for hazardous air pollutants (NESHAPS), and (3) the
permit program under Title V of the act.
The NSPS and NESHAPS both establish specific emissions standards that are based
on the use of available air pollution control technologies. The NSPS establish uniform
emissions standards for new stationary sources that fall within particular categories of
industrial sources. NSPS are based on the performance of the best available control
technology for each category of industrial source, but allow affected industries to
develop alternative, equivalent means of controlling emissions that are cost-effective.
NESHAPS are standards that apply to emissions of hazardous air pollutants (HAP) for
various categories of industrial sources and require the use of the maximum available
control technology (MACT). The MACT is defined as the control technology that
achieves the maximum degree of reduction in the emissions of HAPs, in light of cost
and other considerations. The MACT source category descriptions do not match SIC
codes for most source categories. Source Classification Codes (SCC) developed by the
EPA Office of Air Quality Planning, and Standards (OAQPS) that are used to describe
operations of a facility that produce air emissions have been assigned to all MACT
source categories.
OAQPS compiles the National Toxics Inventory (NTI). The NTI compiles inventory
data on emissions from major, area, and mobile sources for the 188 HAPs. Emissions in
NTI are generated from MACT data, state and local HAP inventory data, TRI data, and
emissions factors and activity data. Nationally, mobile sources account for approxi-
mately 40 percent of the emissions in the NTI, area sources for 35 percent, and major
sources for 25 percent. TRI data account for approximately 50 percent of the major
emissions in NTI.
The Title V permit program, mandated by the CAAA of 1990, requires all major sources
of air pollutants to submit a permit application and obtain a permit to control emissions.
Major sources are defined as sources that emit more than specified threshold amounts
of HAPs or other designated air pollutants, such as volatile organic compounds or
particulate matter. Before the inception of the Title V program, the states required
various preconstruction, operating, and other permits for sources of air pollutants.
Title V permits are .designed to address all sources of emissions from an affected major
source, including fugitive emissions, under a single, consolidated permit. Under the
program, states obtain authorization to implement the program; once authorized, the
C-4
October 1997
SIC 2800
-------
states then review and issue permits. Although Title V permits are intended to supersede
permits issued under state authority only, facilities that are not subject to Title V still are
required to obtain such permits.
EPA and the states determine compliance with the provisions of the CAA largely
through inspections conducted under section 114(a) of the CAA or analogous state
authorities. Inspectors from EPA regional offices and, less frequently, states conduct
inspections of stationary sources, such as those associated with chemical industry
facilities. The compliance inspections focus on recordkeeping and other compliance
activities, such as continuous emissions monitoring, associated with the requirements
of the CAA.
CLEAN WATER ACT (CWA)
The Federal Water Pollution Control Act (more commonly known as the CWA) was
enacted in 1972 to protect the navigable waterways of the U.S. Regulations promulgated
under this legislation are found in 40 CFR parts 100-129 and parts 400-503. For the sake
of convenience, the term CWA will be considered here to encompass all related legislation
and amendments not mentioned herein. The major provisions of the CWA that apply to the
chemical manufacturing industry are the National Pollutant Discharge Elimination System
(NPDES) permit program and pretreatment requirements for discharges to a publicly-
owned treatment works (POTW).
The NPDES permitting program requires each facility that discharges to a surface water •
body to prepare and submit a permit application that covers point-source discharges (for
example, from a pipe) to surface water. NPDES permits require that facilities conduct
monitoring for priority pollutants, which include various toxic pollutants, and for conven-
tional and nonconventional pollutants. Conventional pollutants include indicators of
activities that may compromise the chemical, physical, and biological characteristics of
surface water, including fecal coliform bacteria, total suspended solids, and oil and grease.
Nonconventional pollutants include any other pollutants deemed pertinent by EPA or a
state that are not priority or conventional pollutants. In addition to the NPDES permit .
program for point-source discharges to surface water, EPA has established similar pro-
grams for nonpoint-source discharges from storm water runoff or discharges that may
affect groundwater. Although the NPDES permitting program is a federal program, most
states have obtained authorization to implement and enforce the program.
The CWA also established a pretreatment program that regulates indirect discharges to
POTWs by "industrial users." The purpose of the program is to prevent discharges that
will have adverse effects on the operation of POTWs, that is, to ensure that POTWs can
treat incoming wastewaters adequately to meet their discharge limits under NPDES
permits. Under the pretreatment program, EPA has established general pretreatment
standards (for example, the discharge of hazardous waste is prohibited) and industry-
specific discharge limits. Finally, the pretreatment program includes local discharge
limits established by the POTW.
EPA and state personnel monitor compliance through field inspections and through
analysis of the results of self-monitoring conducted by regulated facilities. Field
inspections conducted under the authority of section 308(a) of the CWA include
compliance inspections conducted primarily by inspectors representing states or, less
frequently, EPA regional offices. Under the CWA, compliance monitoring activities at
chemical facilities consist of field inspections and record reviews. The inspections focus
on compliance with the requirements of NPDES permits, but also may include an
evaluation of pretreatment discharges to POTWs.
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
APPENDIX C — Environmental
Statutes and Regulations
C-5
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
;..;
h'
C-6
SAFE DRINKING WATER ACT (SDWA)
The Safe Drinking Water Act (SDWA) was passed in 1974 to protect the nation's drinking
water supplies and was reauthorized most recently in 1996. For the sake of convenience,
the term SDWA will be considered here to encompass all related legislation and afriend-
ments not mentioned herein. Regulations promulgated under this law are found in 40
CFR parts 130-149. The law establishes two programs that affect the chemical manufac-
turing industry: the national drinking water standards and the underground injection
control (UIC) program.
EPA established the national drinking water standards as chemical-specific concentration
limits for groundwater or surface water that is to be used as a source of drinking water for
a public water supply. EPA has established maximum contaminant level goals (MCLG)
for a number of organic and inorganic chemicals. MCLGs are health-based limits on
concentrations that are not enforceable. For regulatory purposes, EPA has established
maximum contaminant levels (MCL), which are enforceable limits set as close to the
MCLGs as possible, considering cost and feasibility of attainment. The significance of
MCLs and MCLGs to the chemical manufacturing industry is that they often are used as
cleanup levels for remedial actions performed under CERCLA, RCRA, or state authorities.
The UIC program encompasses regulations, established under 40 CFR parts 144 through
148, that require facilities to obtain permits for subsurface discharges through under-
ground injection wells. The program requires that facilities develop and submit permit
applications and obtain permits that specify design, operating, inspection, and monitor-
ing requirements for underground injection wells. The permit program is implemented
initially by EPA, with the states able to apply for and obtain authorization to implement
their own programs.
Under the SDWA, compliance monitoring is performed through a combination of self-
monitoring and inspections conducted by EPA regional and state personnel. Under the
SDWA, regulated facilities are required to conduct self-monitoring at frequencies
ranging from daily to annual, and report the results of that monitoring, often monthly,
to EPA or the state. Facilities usually submit such monitoring results to the state, since
most states have primary responsibility for the regulations issued under the act. State
(and occasionally EPA) personnel also conduct inspections under the authority of
section SOOj-4 of the SDWA. Those inspections typically focus on whether the facility
is using required treatment techniques but may include sampling of water supplies.
Usually, such sampling is focused on biological indicators, in consideration of the
biological agent's potential acute effects on human health.
TOXIC SUBSTANCES CONTROL ACT (TSCA)
The Toxic Substances Control Act (TSCA) was enacted in 1976; its primary purpose is
to regulate the manufacture, import, processing in commerce, and use of chemicals in the
U.S. For the sake of convenience, the term TSCA will be considered here to encompass
all related legislation and amendments not mentioned herein. These regulations are
found in 40 CFR parts 700-789. Under TSCA, EPA collects data to determine whether
new and existing chemicals are safe for distribution and use. Drawing on the information
it collects, EPA has established an inventory of chemicals that are approved without
restriction for use or import.
One of the major provisions of TSCA that affects the chemical manufacturing industry
is the requirement for premanufacture notice (PMN). Chemical manufacturing facilities
must submit a PMN before manufacturing any chemical that is not in the existing chemi-
cal inventory or that has not been excluded by EPA from the listing requirement. The
PMN must identify the chemical and provide available information on health and environ-
mental effects. If EPA deems the information insufficient, EPA may place restrictions,
such as labeling requirements, on use of the chemical until sufficient data are available.
"~ October 1997
SiC 2800
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Chemical Industry
ffafionaf
Environmental
Baseline Report
1990 to 1994
EPA may ban the manufacture or distribution in commerce of existing chemicals if they
pose unreasonable risks. EPA may limit the use of such chemicals and require labeling
or place other restrictions on chemicals, such as those that currently apply to asbestos,
chlorofluorocarbons, and polychlorinated biphenyls (PCB). For example, regulations
under 40 CFR part 761 set forth management standards for storage, marking and
labeling requirements, and regulations that specify required treatment technologies for
the disposal of materials that contain PCBs. -
Under TSCA, compliance monitoring activities at chemical facilities encompass field
inspections for the most part conducted by EPA regional offices. The inspections focus
on reporting and recordkeeping requirements under TSCA sections 5 and 8. However,
most PCB and asbestos inspections are conducted by the states under grants from EPA.
FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE
ACT (FIFRA)
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), which was enacted in
1947, authorized the U.S. Department of Agriculture to monitor the use and sale of
pesticides in the U.S. The law was concerned primarily with efficacy and the registering
and labeling of pesticides. The Federal Environmental Pesticide Control Act (FEPCA) of
1972 mandated that EPA regulate the use and sale of pesticides to protect human health
and preserve the environment. Specifically, EPA is authorized to: (1) strengthen the
registration process by shifting the burden of proof to the chemical manufacturer, (2)
enforce compliance against banned and unregistered products, and (3) promulgate the
regulatory framework that had been missing from FIFRA. For the sake of convenience,
the term FIFRA will be considered here to encompass all related legislation and amend-
ments not mentioned herein. Regulations under these laws and their numerous amend-
ments are found in 40 CFR parts 150-189.
FIFRA provides EPA with the authority to oversee the sale and use of pesticides and
other products intended to kill or control living organisms, such as insects, weeds, and
rodents. Under FIFRA, EPA requires that pesticides be registered and, through the
registration process, collects data to be used in evaluating the risks posed by pesticides.
As necessary, EPA may suspend, ban, or restrict the use of pesticides that pose a threat
to human health or the environment. Under FIFRA, a chemical manufacturer that
wishes to sell or distribute a pesticide must submit test data, information about proposed
uses, and suggested labeling in support of the application for registration. Once a
product has been registered, producers must report annual production of the product.
The act also grants EPA inspection authority and enables the agency to take enforcement
action against facilities that are not in compliance with applicable regulations.
Section 9 of FIFRA authorizes representatives of EPA or duly designated states to
inspect facilities, subject to the provisions of the law. The inspections usually are
conducted by the states, either in states that have been delegated authority by EPA,
or states that have entered into cooperative enforcement agreements with EPA.
The inspections focus on pesticide applicators.
APPENDIX C
Statutes and
Environmental
C-7
-------
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
APPENDIX D — LOCATION OF CHEMICAL FACILITIES
c
JC
5
£
°5
£
o
(W
* EPA Office of Environmental Justice Database, 1994.
APPENDIX D — Chemical Facilities
D-1
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Chemical Facilities in Low-Income Counties*
.ill
I '•* I
* EPA Office of Environmental Justice Database, 1994.
D-2
October 1997
SIC 2800
-------
Chemical Facilities in Minority Counties*
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
* EPA Office of Environmental Justice Database, 1994.
APPENDIX D — Chemical Facilities
D-3
-------
-------
APPENDIX E — TRI RELEASES AND
TRANSFERS BY FOUR-DIGIT SIC
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Summary of Total TRI Releases, 1990 to 1994
Year
1990
1991
1992
1993
1994
Fugitive Air,(Pounds)
210,819,863
198,163,102
167,018,774
159,683,683
128,787,598
Point Source'Air (Pounds)
510,632,159
449,890,383
424,494,685
337,140,924
339,099,013
Wafer: (Pounds)
135,601,832
190,970,875
226,779,186
234,877,413
42,581,139
•Underground lniection;(Rounds)
689,183,214
655,110,548
684,646,025
536,444,507
335,363,603
land Disposal (Pounds)
121,655,176
107,440,474
88,447,993
84,052,350
96,234,850
total Releases'. (Pounds)
1,667,892,244
1,601,575,382
1,591,386,663
1,352,198,877
942,066,203
Summary of Total Carcinogenic Releases, 1990 to 1994
Year
1990
1991
1992
1993
1994
Fugitive Air; (Pounds):
9,761,363
8,277,786
8,282,614
7,587,899
7,371,994
'Point SourcftAir (Rounds)
16,626,780
13,674,746
11,637,133
9,463,537
9,998,971
Water; (Pounds)
1,068,640
711,656
697,158
770,118
670,101
Underground injection (Pounds)
37,131,546
34,082,426
33,446,210
31,411,350
35,990,037
i':Land Disposal (Pounds)
623,367
545,827
368,657
881,268
804,774
Total Releases (Pounds)
65,211,696
57,292,441
54,431,772
50,114,172
54,835,877
Summary of Total TRI Transfers, 1990 to 1994
•t" ;:•.
iYiar
1990
1991
1992
1993
1994
POTW'(Rounds)
288,415,312
227,725,275
218,494,790
181,377,222
148,808,996
Bother Transfers' (Pounds)
258,623,644
995,491,849
1,017,294,638
1,005,198,647
885,589,514
Disposal (Pounds)
73,940,671
52,583,314
47,521.490
42,031,991
38.728,766
Energy Recowry (Pounds)
766,886
326,071,090
352,025,459
366,953,724
357,897,675
diner (Pounds)
2,588,666
2,505,857
1,390,758
135,211
475,471
Recycling (Pounds)
2,351,777
422,043,659
441,879,758
429,500,308
299,568,131
Treatment (Pounds)
178,975.644
192,287,929
174,477,173
166,577,413
188,919,471
Total Transfers (Pounds)
805,662,600
2,218,708,973
2,253,084,066
2,191,774,516
1,919,988,024
!:*•
* EPA 1990-1994 Toxics Release Inventory (TRI) Database on TRI Releases and Transfers
APPENDIX i — TR! Releoses and
Transfers by Four-Digit SIC Code
E-1
-------
Chemical Industry
National
Environmental.
Baseline Report
1990 to 1994
1990 - Total Releases
SIC Code
2800
Total 280
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2831
2833
2834
2835
2836
2839
Total 283
2840
2841
2842
2843
2844 .
Total 284
2850
2851
Total 285
2860
2861
2864
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2890
2891
2892
2893
2895
2899
Total 289
Multiple SIC with 2800 *
TOTAL
Fugitive Air
(Pounds)
90,645
90,645
88,342
471,487
18,235
522,180
3,658,753
4,758,997
14,382,284
6,032,509
2,355,480
296,599
23,066,872
49,323
7,293
4,286,614
5,191,393
7,398
8,577
3,802
9,554,400
3,005
416,451
310,360
1,020,926
52,605
1,803,347
4,550
6,862,514
6,867,064
27,666
71,568
3,400
2,507,622
26,483,815
29,094,071
4,518,398
603,661
66,429
1,072,121
6,260,609
7,179
1,401,852
1,220,118
1,004,869
33,521
1,579,026
5,246,565
124,077,293
210,819,863
Point Source
Air (Pounds)
557,228
557,228
486,291
789,612
7,677
21,349,448
16,575,943
39,208,971
22,651,210
8,279,179
6,814,916
1,197,316
38,942,621
321,870
505
5,392,662
15,725,170
17,380
289,431
19,556
21,766,574
2,260
839,184
142,407
915,349
154,681
2,053,881
1,000
12,219,239
12,220,239
113,866
343,947
525
5,919,423
39,674,073
46,051,834
86,585,314
3,675,373
2,212,619
2,008,184
94,481,490
4,029
1,677702
1,906,468
1,132,874
14,199,854
2,511,706
21,432,633
233,916,688
510,632,159
Water (Pounds)
41,306
41,306
7,812
37,760
0
140,425
2,577,643
2,763,640
908,547
49,011
138,031
82,426
1,178,015
4,025
0
3,645,232
744,056
10
0
0
4,393,323
10
545
7,136
3,677
275
11,643
0
5,541
5,541
45,589
2,193
0
207,809
4,409,364
4,664,955
6,991,908
837,368
3,250
• 224,149
8,056,675
25
6,689
73,274
500
10
12,654
93,152
114,393,582
135,601,832
Underground
Injection
(Pounds)
0
0
0
15
0
83,000,000
12,477,398
95,477,413
50
0
0
163,715
163,765
0
5
15
6,962,036
0
0
0
6,962,056
0
5
40
18,820
0
18,865
0
6,477
6,477
0
0
0
3,283,935
108,404,087
111,688,022
5,020,050
0
0
1,232,254
6,252,304
0
15
5
0
0
105
125
468,614,187
689,183,214
Land Disposal
(Pounds)
10,600
10,600
4,674
11,322
0
234,969
30,342,351
30,593,316
44,469
36,918
283,750
7,962
373,099
0
20
268,103
7,199
0
0
5
275,327
10
994
26,805
17,689
6
45,504
0
97,505
97,505
0
591
0
684,572
983,219
1,668,382
939,782
16,915,549
458,447
84,593
18,398,371
0
2,515
153,507
843
818,164
7,800
982,829
69,210,243
121,655,176
Total Releases
in 1990
(Pounds)
699,779
699,779
587,119
1,310,196
25,912
105,247,022
65,632,088
172,802,337
37,986,560
14,397,617
9,592,177
1,748,018
63,724,372
375,218
7,823
13,592,626
28,629,854
24,788
298,008
23,363
42,951,680
5,285
1,257,179
486,748
1,976,461
207,567
3,933,240
5,550
19,191,276
19,196,826
187,121
418,299
3,925
12,603,361
179,954,558
193,167,264
104,055,452
22,031,951
2,740,745
4,621,301
133,449,449
11,233
3,088,773
3,353,372
2,139,086
15,051,549
4,111,291
27,755,304
1,010,211,993
1,667,892,244
t,
H:
* Facilities have been assigned to the "multiple" category according to all the SIC codes they reported.
Forms-and amounts in pounds have been assigned to single-category SIC codes if only one SIC code was
reported for a particular chemical form from the facility.
E-2
October 1997
SIC 2800
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1991 - Total Releases
SIC Code
2800
Total 280
2810
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2831
2833
2834
2835
2836
Total 283
2840
2841
2842
2843
2844
Total 284
2850
2851
2859
Total 285
2860
2861
2864
2865
2869
Total 286
2871
2873
2874
2875
2879
Total 287
2890
2891
2892
2893
2895
2899
Total 289
Multiple SIC with 2800
TOTAL
Fugitive Air
(Pounds)
137,837
137,837
5
179,673
1,396,128
36,892
1,566,068
3,595,171
6,773,937
12,948,735
6,720,498
43,560
204,056
19,916,849
20,915
10,056
3,379,794
4,135,902
5,843
8,290
7,560,800
5
79,063
297,228
454,861
50,971
882,128
3,600
6,587,331
250
6,591,181
49,995
39,160
1,995
2,109,539
22,754,286
24,954,975
31,093
5,250,237
2,898,146
68,164
535,158
8,782,798
4,815
947,027
1,211,281
653,043
16,070
2,941,528
5,773,764
116,788,833
198,163,102
Point Source Mr
(Pounds)
473,077
473,077
250
444,634
729,072
3,250
19,369,531
14,374,103
34,920,840
17,501,180
8,908,229
3,313,730
1,158,423
30,881,562
18,010
10,095
3,962,116
15,471,856
12,790
209,452
19,684,319
5
697,807
175,928
847,524
113,389
1,834,653
450
7,144,921
0
7,145,371
134,015
66,921
600
7,166,509
36,725,032
44,093,077
0
68,966,971
5,274,052
1,954,549
1,163,257
77,358,829
4,020
1,615,400
1,683,336
829,126
13,835,953
1,882,776
19,850,611
213,648,044
449,890,383
Water (Pounds)
28,708
28,708
0
2,621
35,005
0
224,166
2,656,924
2,918,716
669,052
36,007
137,600
68,683
911,342
0
0
3,576,151
963,160
0
0
4,539,311
0
255
4,519
1,420
63
6,257
0
5,714
0
5,714
28,474
1,258
0
1,554,965
4,130,454
5,715,151
0
8,040,992
763,659
1,015
105,600
8,911,266
0
1,774
72,913
408
255
50,736
126,086
167,808,324
190,970,875
Underground
Injection
(Pounds)
0
0
0
0
1
0
93,000,000
20,459,620
113,459,621
250
22,000,000
0
305,585
22,305,835
0
0
0
5,615,735
0
0
5,615,735
0
0
0
19,473
0
19,473
0
2
0
2
0
0
0
3,720,102
97,033,953
100,754,055
0
2,930,171
0
0
878,563
3,808,734
0
0
0
0
0
0
0
409,147,093
655,110,548
Land Disposal
(Pounds)
0
0
960
3,452
10,204
0
303,865
27,241,763
27,560,244
68,306
25,045
111,500
8,679
213,530
0
0
255,652
1,478
0
5
257,135
0
260
2,306
521
1,530
4,617
0
26,726
0
26,726
0
0
0
518,886
817,826
1,336,712
0
2,094,530
28,504,741
1,452
28,760
30,629,483
500
3,814
130,517
133
306,092
101,304
542,360
46,869,667
107,440,474
Total Releases
in 1991
(Pounds)
639,622
639,622
1,215
630,380
2,170,410
40,142
114,463,630
68,327,581
185,633,358
31,187,523
37,689,779
3,606,390
1,745,426
74,229,118
38,925
20,151
11,173,713
26,188,131
18,633
217,747
37,657,300
10
777,385
479,981
1,323,799
165,953
2,747,128
4,050
13,764,694
250
13,768,994
212,484
107,339
2,595
15,070,001
161,461,551
176,853,970
31,093
87,282,901
37,440,598
2,025,180
2,711,338
129,491,110
9,335
2,568,015
3,098,047
1,482,710
14,158,370
4,976,344
26,292,821
954,261,961
1,601,575,382
APPENDIX i — TRI Reieases and
Transfers by Four-Digit SIC Code
E-3
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1992 - Total Releases
Fugr
SIC Code (Po
2800
2803
Total 280
2812
live Air Point Source Water
unds) Air (Pounds) (Pounds)
Underground
Injection
(Pounds)
95,830! 506,984! 28,769 0
0; 400i Oj 0
95,830| 507,384 28,769
0
134,749! 479,095! 3,294i 0
2813 1,068,843 . 802,029 18,427 0
2815
2816
12,392 255 0 0
1,444,35i; 15,113,409 286,918, 99,000,000
2819 ! 2,346,995! 14,357,847 2,645,525 25,858,280
Total 281 I
5,007,330 30,752,635 1 2,954,164
124,858,280
Land Disposal
(Pounds)
0
6
0
Total Releases
in 1992
(Pounds)
631,583
I 400
631,983
54,150| 671,288
14,000 1 . 1,903,299
0 " 12,647
193,931 116,038,609
17,366,4891 62,575,136
17, 628,570 1 181,200,979
2821 I 10,238,611; 14,992,043; 599,108! 0 226,361! 26,056,123
2822 I 4,113,729' 7,160,521 ! 33,927 Oj 31,002 11,339,179
2823 \
2824
2829
Total 282 1(
2830 :
2831 l_
2833
1,642,515 22,510,260[ 158,500 Oi 100l 24,311,375
iS.iis1 178,798! 5r 6
0* 67,950 0 0
5,141,688 44,909,572 791,540| 0
23,605; 17,025 0 0
____271L_ J-9§Zt '. M .....P.
1,723,617!"""" ——j^: - "-^^ggj "" o
2834 ! 2,086,210i 11,294,923! 361,030 5,725,395
2835 ;
2836 '
Total 283 :
2841
2842
2843
2844 '
Total 284
2850
0 '__.325jf86
290,900! 35&850
548,363| 62,391,163
Oi 40,630
6
134,899
24,773
5,234! io,117l 5 0 0
5,708: 266,659! 61 . 6
J.844,646| 17,347,496 . 3,220,659| 5,725,395
45,284 464,283i 1,005[ 0
139,700; 169,1921 5,131 0
740,402: 698,587 260 21,962
54,705: 50,837 26! 0
980,091 1,382,8991 6,422| 21,962
0
159,672
510
2,261
•539
5
3,315
3,300; 250 Oi OI 0
;;3,269
__ZlM^915
19,492,331
15,356
' — J367
30,297,868
511,082
316,284
1,461,750
105,573
2,394,689
3,550
2851 • 6,978,976 5,514,856 5,391! 198! ' 6,203| 12,505,624
2856
2857
Total 285 (
2861
2863
2864 ;
2,600 3,500! 5! 0
250 o! 0 0
;,985,876J 5,51 9,356 1 5,396
..JiOjSSe 69,986! 1,257
250 5 0
630: 150 0
2865 2,789,527. 8,061,275 2,540,582
2869 22,911,390' 31,547,174 1,074,338
Total 286 2£
2871
198
0
6
0
.3,328,401
86,800,110
i,752,333| 39,678,590 3,616,177| 90,128,511
5
0
6,208
1,500
0
0
776,704
707,868
1.486.072
.6,110
••' • 250
12,517,034
'123,279
l_ ' '• " 255
• 780
17,496,489
143,040,880
160.661.683
33,645 0! 0! 0! 0| 33,645
2873 i 4,551,914 55,460,310 7,530,825! 2,333,034! 1,237,308! 71,113,391
2874 (
2875 t
2879 !
Total 287 . £
2881
Total 288
2890 !
2891 ! 1
2892
2893
2895 !
2899 2
Total 289 t
Multiple SIC with 2800 97
TOTAL 167
,114,034 5,326,300! 14,323,877
66,084 1,682,084! 2,263
324,854! 1,510,737! 55,586
i,090,531 1 63,979,431 1 21,912,551
16,715! 49,180; 512
16,715 49,180 512
1,005! 1,005 0
,000,083[ 1,649,426 276
0
0
726,"3i 6
3,053,344
0
0
0
0
25,573,902( 46,338,113
3,069
• 69,620
1,753,500
2,681,107
26,883,899| 121,919,756
OI 66,407
0 66,407
1,500 3,510
1,920
670,820t 1,893,470! 204,626 0 69,009
472,771; 798,507 143 0 250
13,107! 20,680,154 255 250
>,482,780 1,674,021 7,302
1,640,566 26,096,583 212,602
',463,168 194,271,559 194,030,394
018,774 424,494,685 226,779,186
0
250
460,858,085
684,646,025
0
41^350
114,029
41,617,865
88,447,993
2,651,705
2,837,925
___JJi[7J!J571
20,093,766
4,205,453
31,064,030
988,241,071
1,591,386,663
E-4
October 1997
SIC 2800
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1993 - Total Releases
SIC Code
2810
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2833
2834
2835
2836
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2861
2864
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2889
Total 288
2891
2892
2893
2895
2899
Total 289
Multiple SIC with 2800
TOTAL
Fugitive Air
(Pounds)
250
111,412
1,101,709
250
1,041,302
2,952,647
5,207,570
8,572,467
4,692,470
2,042,515
622,330
15,929,782
722,709
2,027,235
4,927
8,526
2,763,397
45,692
197,953
331,773
' 39,955
615,373
6,176,453
6,176,453
51,592
150
1,497,256
23,275,356
24,824,354
3,906,227
484,466
67,997
259,324
4,718,014
1,910
1,910
825,006
1,006,802
283,825
3,312
1,943,148
4,062,093
95,384,737
159,683,683
Point Source
Air (Pounds)
250
401,909
371,321
0
10,365,044
8,184,751
19,323,275
14,198,390
3,513,034
23,859,760
307,545
41,878,729
1,971,226
6,663,842
12,738
237,961
8,885,767
224,045
158,725
703,102
44,740
1,130,612
5,045,801
5,045,801
184,616
0
4,291,295
27,837,384
32,313,295
43,913,903
4,360,336
1,312,554
849,112
50,435,905
24
24
1,555,058
519,262
633,075
18,403,046
1,503,669
22,614,110
155,513,406
337,140,924
Water (Pounds)
0
3,378
22,168
. 0
471,846
2,050,444
2,547,836
708,085
41,244
141,900
53,900
945,129
153,891
416,919
0
0
570,810
250
7,633
0
21
7,904
10,601
10,601
755
0
278,384
1,347,705
1,626,844
6,411,935
435,778
3,785
28,971
6,880,469
0
0
24
276,479
124
255
10,561
287,443
222,000,377
234,877,413
Underground
Injection
(Pounds)
0
0
0
0
105,000,000
17,045,733
122,045,733
0
0
0
238,020
238,020
0
3,521,999
0
0
3,521,999
0
0
18,378
0
18,378
0
0
0
0
3,774,950
81,428,835
85,203,785
1,942,860
0
0
800,632
2,743,492
0
0
0
0
0
250
0
250
322,672,850
536,444,507
Land Disposal
(Pounds)
0
4,883
447
0
1,188,049
16,957,677
18,151,056
563,473
36,490
30
14,304
614,297
17,948
120,416
0
0
138,364
760
1,770
29
1
2,560
26,089
26,089
0
0
654,720
500,968
1,155,688
131,327
18,300,315
4,505
401,686
18,837,833
0
0
41,550
17,487
250
0
11,954
71,241
45,055,222
Total Releases in
1993 (Pounds)
500
521,582
1,495,645
250
118,066,241
47,191,252
167,275,470
24,042,415
8,283,238
26,044,205
1,236,099
59,605.957
2,865,774
12,750,411
17,665
246,487
15,880,337
270,747
366,081
1,053,282
84,717
1,774,827
11,258,944
11,258.944
236,963
150
10,496,605
134,390,248
145,123,966
56,306,252
23,580,895
1,388,841
2,339,725
83,615,713
1,934
1.934
2,421,638
1,820,030
917,274
18,406,863
3,469,332
27,035,137
840,626.592
84,052,350 1,352,198,877
APPENDIX i — Till Releases and
Transfers by Four-Digit SIC Code
E-5
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1994 - Total Releases
SIC Code
2812
2813
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2831
2833
2834
2835
2836
Total 283
2841
2842
2843
2844
Total 284
2850
2851
2859
Total 285
2860
2861
2863
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2890
2891
2892
2893
2895
2899
Total 289
Multiple SIC with 2800
TOTAL
Fugitive Air
(Pounds)
87,784
603,521
1,273,758
2,536,197
4,501,260
9,095,159
4,295,357
2,042,515
402,516
15.835,547
750
688,590
1,180,844
4,433
31,909
1,906,526
48,034
89,925
616,316
29,249
783,524
750
6,089,063
250
6,090,063
15
8,899
5
1,340,990
19,845,942
21,195,851
4,006,831
726,442
155,286
242,427
5,130,986
330
598,525
105,393
258,434
3,639
1,390,532
2,356,853
70,986,988
128,787,598
Point Source
Air (Pounds)
337,718
808,137
8,439,962
7,447,910
17,033,727
15,685,373
3,364,459
22,424,260
225,203
41,699,295
6,850
1,599,848
7,437,326
12,320
3,484
9,059,828
206,094
159,322
580,985
5,597
951,998
2,550
3,735,387
250
3,738,187
750
17,146
5
4,357,686
25,269,722
29,645,309
44,444,498
5,619,743
1,128,094
1,213,341
52,405,676
5,150
971,967
57,825
699,640
20,413,961
1,392,426
23,540,969
161,024,024
339,099,013
Water
(Pounds)
1,901
25,755
581,143
607,140
1,215,939
688,594
84,544
149,950
12,026
935,114
5
224,733
687,406
0
0
912,144
0
2,282
205
250
2,737
0
3,828
0
3,828
0
1,005
0
289,833
718,209
1,009,047
4,310,700
1,199,931
2,765
63,125
5,576,521
0
785
193,689
121
1,010
47,422
243,027
32,682,782
42,581,139
Underground
Injection
(Pounds)
0
0
57,000,500
15,348,569
72,349,069
0
0
0
84,050
84,050
0
0
6,826,250
0
0
6,826,250
0
0
15,431
0
15,431
0
0
0
0
0
0
0
4,215,300
48,446,070
52,661,370
1,803,927
0
0
587,361
2,391,288
0
0
0
0
0
0
0
201,036,145
335,363,603
Land
Disposal
(Pounds)
193
0
2,580,160
14,887,432
17,467,785
28,598
35,570
16
1,213
65,397
0
160
174,994
0
0
175,154
10
1,508
33,996
0
35,514
0
13,909
0
13,909
0
0
0
212,881
936,935
1,149,816
44,748
21,166,341
4,539
3,215
21,218,843
0
600
166,826
250
0
87,945
255,621
55,852,811
96,234,850
Total
Releases in
1994 (Pounds)
427,596
1,437,413
69,875,523
40,827,248
112,567,780
25,497,724
7,779,930
24,616,741
725,008
58,619,403
7,605
2,513,331
16,306,820
16,753
35,393
18,879,902
254,138
253,037
1,246,933
35,096
1,789,204
3,300
9,842,187
500
9,845,987
765
27,050
10
10,416,690
95,216,878
105,661,393
54,610,704
28,712,457
1,290,684
2,109,469
86,723,314
5,480
1,571,877
523,733
958,445
20,418,610
2,918,325
26,396,470
521,582,750
942,066,203
E-6
October 1997
SIC 2800
-------
Chemical Industry
National
EnWronmenfaf
Baseline Repert
1990 to 1994
1990 - Carcinogenic Releases
SIC Code
2800
Total 280
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2833
2834
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2860
2861
2864
2865
2869
Total 286
2873
2875
2879
Total 287
2890
2891
2892
2893
2899
Total 289
Multiple SIC with 2800
TOTAL
Fugitive Air
(Pounds)
3,945
3,945
335
484
250
1,535
9,328
11,932
1,700,091
1,284,415
18,817
60,684
3,064,007
250
69,353
125,115
194,718
2,910
2,110
41,934
15,629
62,583
146,225
146.225
470
1,070
1,800
387,705
2,462,050
2,853.095
2,025
255
8,537
10,817
500
8,728
0
7,387
90,066
106,681
3,307,360
9,761,363
Point Source
Air (Pounds}
3,888
3,888
15,552
3,442
250
1,250
211,594
232,088
3,872,303
2,024,480
32,566
58,242
5,987,591
750
291,456
442,606
734,812
2,759
1,294
37,034
250
41,337
71,563
71,563
628
1,957
100
509,820
1,509,006
2.021,511
3,804
8,005
102,013
113,822
500
141,449
0
16,118
69,465
227,532
7,192,636
16,626,780
Water
(Pounds)
84
84
1,060
3,480
0
0
1,147
5,687
326,053
29,497
2,223
12,921
370,694
0
27,955
265
28,220
0
0
0
0
0
15
15
39
250
0
2,791
189,265
192,345
15
0
585
600
0
0
0
0
278
278
470,717
1,068,640
Underground
Injection
(Pounds)
0
0
0
0
0
0
5
5
15
0
0
43,070
43,085
0
0
288,662
288,662
0
5
0
0
5
5
5
0
0
0
0
7,778,745
7,778,745
0
0
5
5
0
0
0
0
20
20
29,021,014
37,131,546
Land Disposal
(Pounds)
10,600
10,600
0
0
0
0
14,770
14,770
11,145
25,279
0
5
36,429
0
255
21
276
0
20
0
0
20
275
275
0
0
0
9,623
48,302
57,925
2,265
0
85
2,350
0
450
5
0
80
535
500,187
623,367
Total
Carcinogenic
Release in
1990 (Pounds)
18,517
18,517
16,947
7,406
500
2,785
236,844
264,482
5,909,607
3,363,671
53,606
174,922
9,501,806
1,000
389,019
856,669
1,246,688
5,669
3,429
78,968
15,879
103,945
218,083
218,083
1,137
3,277
1,900
909,939
11,987,368
12,903,621
8,109
8,260
111,225
127,594
1,000
150,627
5
23,505
159,909
335,046
40,491,914
65,211,696
APPENDIX E — TRI Releases and
Transfers by Four-Digit SIC Code
E-7
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1991- Carcinogenic Releases
I:
'
""'"' : I
SIC Code
2800
Total 280
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2831
2833
2834
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2860
2861
2864
2865
2869
Total 286
2873
2875
2879
Total 287
2890
2891
2892
2893
2899
Total 289
Multiple StC with 2800
TOTAL
Fugitive Air
(Pounds)
455
455
75
360
10
255
9,704
10,404
1,414,745
933,482
1,540
35,565
2,385,332
2,200
170,760
30,556
203,516
3,337
1,565
34,853
15,864
55,619
117,598
117,598
470
546
1,970
171,146
1,552,971
1,727,103
1,496
250
8,630
10,376
250
16,508
0
2,116
90,251
109,125
3,658,258
8,277,786
Point Source
Air (Pounds)
4,655
4,655
5
1,550
0
255
175,391
177,201
2,849,777
1,925,000
5,480
69,510
4,849,767
9,500
167,309]
204,336
381,145
2,446
1,520
48,394
0
52,360
86,774
86,774
718
1,803
0
535,080
1,083,489
1,621,090
4,718
23,000
39,365
67,083
500
12,837
5
9,741
83,861
106,944
6,327,727
13,674,746
Water
(Pounds)
23
23
770
0
0
0
328
1,098
316,796
17,445
0
15,096
349,337
0
23,350
. ,255
23,605
0
0
0
0
0
0
0
44
251
0
3,172
39,215
42,682
1,375
0
250
1,625
0
0
0
0
15
15
293,271
711,656
Underground
Injection
(Pounds)
0
0
0
0
0
0
0
0
0
0
0
207,685
207,685
0
0
162,500
162,500
0
0
0
0
0
0
0
0
0
0
8,100
5,524,580
5,532,680
1,183
0
0
1,183
0
0
0
0
0
0
28,178,378
34,082,426
Land Disposal
(Pounds)
0
0
0
0
0
0
0
0
16,253
16,388
0
0
32,641
0
5
2
7
0
0
0
5
5
255
255
0
0
0
13,531
17,210
30,741
16
0
15
31
0
200
0
0
21
221
481,926
545,827
Total
Carcinogenic
Release in
1991 (Pounds)
5,133
5,133
850
1,910
10
510
185,423
188,703
4,597,571
2,892,315
7,020
327,856
7,824,762
11,700
361,424
397,649
770,773
5,783
3,085
83,247
15,869
107,984
204,627
204,627
1,232
2,600
1,970
731,029
8,217,465
8,954,296
8,788
23,250
48,260
80,298
750
29,545
5
11,857
174,148
216,305
38,939,560
57,292,441
E-8
October 1997
SIC 2800
-------
Chemical Industry
1992 - Carcinogenic Releases
Environmental
Baseline Report
1990 to 1994
SIC Code
2800
2803
Total 280
2812
2813
2815
2816
2819
Total 281
2821
2822
2824
Total 282
2833
2834
2835
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2861
2864
2865
2869
Total 286
2873
2875
2879
Total 287
2881
Total 288
2890
2891
2892
2893
2899
Total 289
Multiple SIC with 2800
TOTAL
Fugitive Air
(Pounds)
406
0
406
80
800
5
0
3,639
4,524
1,302,878
976,523
3,500
2,282,901
200,495
28,624
0
229,119
2,663
1,431
23,172
15,391
42,657
469,507
469,507
545
325
207,709
1,408,246
1,616,825
1,350
250
4,862
6,462
15,000
15,000
250
8,990
5
2,100
62,749
74,094
3,541,119
8,282,614
Point Source
Air (Pounds)
3,455
400
3,855
5
1,259
0
7
165,559
166,830
2,372,657
1,762,944
170
4,135,771
59,639
122,558
5
182,202
1,516
303
37,280
0
39,099
105,817
105,817
15,161
0
396,990
937,252
1,349,403
4,105
24,250
12,475
40,830
44,600
44,600
250
14,015
0
1,000
66,948
82,213
5,486,513
11,637,133
Water
(Pounds)
44
0
44
92
0
0
500
173
765
253,261
14,299
0
267,560
6,600
10
0
6,610
0
0
0
0
0
5
5
5
0
3,716
42,372
46,093
25
0
167
192
250
250
0
0
0
0
20
20
375,619
697,158
Underground
Injection
(Pounds)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
217,000
0
217,000
0
0
0
0
0
0
0
0
0
7,500
4,608,499
4,615,999
176
0
0
176
0
0
0
0
0
0
0
0
28,613,035
33,446,210
Land Disposal
(Pounds)
0
0
0
0
0
0
0
10,001
10,001
546
18,272
0
18,818
5
0
0
5
0
0
3
0
3
0
0
0
0
12,117
10,651
22,768
19,005
0
10
19,015
0
0
250
200
0
.0
457
907
297,140
368,657
Total
Carcinogenic
Release in
1992 (Pounds)
3,905
400
4,305
177
2,059
5
507
179,372
182,120
3,929,342
2,772,038
3,670
6,705,050
266,739
368,192
5
634,936
4,179
1,734
60,455
15,391
81,759
575,329
575,329
15,711
325
628,032
7,007,020
7,651,088
24,661
24,500
17,514
66,675
59,850
59,850
750
23,205
5
3,100
130,174
157,234
38,313,426
54,431,772
,l£ >'
v,.f^f,, 1,
;„ s • -•'.' -*fe
- -
APPENDIX I — TRI Releases and
Transfers by Four-Digit SIC Code
E-9
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1993 - Carcinogenic Releases
SIC Code
2812
2813
2819
Total 281
2821
2822
2824
Total 282
2833
2834
2835
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2861
2864
2865
2869
Total 286
2873
2875
2879
Total 287
2891
2893
2899
Total 289
Multiple SIC with 2800
Total
Fugitive Air
(Pounds)
80
784
3,131
3,995
1,036,471
1,093,809
55,725
2,186,005
18,490
30,633
0
49,123
3,065
946
38,433
30,343
72,787
116,139
116,139
615
150
117,540
1,513,476
1,631,781
1,610
250
5,223
7,083
6,968
250
62,229
69,447
3,451,539
7,587,899
Point Source
Air (Pounds)
5
2,020
32,679
34,704
2,298,073
1,426,243
69,895
3,794,211
5,681
98,251
5
103,937
1,105
1,043
62,974
0
65,122
65,900
65,900
13,231
0
382,126
886,142
1,281,499
3,495
9,900
13,826
27,221
18,104
450
77,676
96,230
3,994,713
9,463,537
Water
(Pounds)
33
0
14
47
242,534
21,860
18,000
282,394
680
5
0
685
0
0
0
0
0
0
0
5
0
441
210,903
211,349
35
0
80
115
0
0
25
25
275,503
770,118
Underground
Injection
(Pounds)
0
0
0
0
0
0
• 127,385
127,385
0
77,005
0
77,005
0
0
0
0
0
0
0
0
0
8,000
5,724,020
5,732,020
339
0
0
339
0
0
0
0
25,474,601
31,411,350
Land Disposal
(Pounds)
0
0
9,760
9,760
236,727
26,295
0
263,022
0
0
0
0
0
0
3
0
3
0
0
0
0
983
11,817
12,800
105
0
10
115
450
0
0
450
595,118
881,268
Tofal
Carcinogenic
Release In
1993 (Pounds)
118
2,804
45,584
48.506
3,813,805
2,568,207
. 271,005
6,653,017
24,851
205,894
5
230,750
4,170
1,989
101,410
30,343
137,912
182,039
182,039
13,851
150
509,090
8,346,358
8,869,449
5,584
10,150
19,139
34,873
25,522
700
139,930
166,152
. 33,791,474
"50,114,172
E-10
October 1997
'•'• SIC.2800
-------
1994 - Carcinogenic Releases
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Of !
sic code
2812
2813
2816
2819
Total 281
2821
2822
2824
Total 282
2831
2833
2834
2835
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2861
2865
2869
Total 286
2873
2875
2879
Total 287
2891
2893.
2899
Total 289
Multiple SIC with 2800
Total
Fugitive Air
(Pounds)
68
1,111
0
1,990
3,169
945,017
608,476
40,568
1,594,061
250
20,465
36,368
250
57,333
2,925
770
53,226
22,890
79,811
496,390
496,390
625
124,863
1,212,723
1,338,211
1,053
250
5,372
6,675
7,829
260
61,840
69,929
3,726,415
7,371,994
Point Source
fit (Pounds)
250
2,415
16
25,652
28,333
2,402,097
1,183,327
67,530
3,652,954
4,400
10,609
109,654
255
124,918
967
1,545
26,981
0
29,493
134,886
134,886
2,800
453,365
802,022
1,258,187
12,045
3,614
10,903
26,562
16,719
111
48,426
65,256
4,678,382
9,998,971
Water
(Pounds)
0
0
86
182
268
220,945
66j390
4,900
292,235
0
0
5
0
5
0
0
29
0
29
0
0
5
897
26,575
27,477
20
0
136
156
0
0
64
64
349,867
670,101
Underground
Injection
(Pounds)
0
0
0
0
0
0
0
68,255
68,255
0
0
221,000
0
221,000
0
0
0
0
0
Land Disposal
(Pounds)
0
0
280,000
10,000
290,000
4,088
'27,645
, 0
31,733
0
0
1,850
• o
1,850
- . o
0
33,737
0
33,737
o| o
Total
Carcinogenic
Release in
1994 (Pounds)
318
3,526
280,102
37,824
321,770
3,572,147
1,885,838
181,253
5,639,238
4,650
31,074
368,877
505
405,106
3,892
2,315
113,973
22,890
143,070
631,276
0| 0| 631,276
0
8,000
7,404,036
0
2,126
80,345
7,412,036| 82,471
1,030
0
0
1,030
0
0
0
:.- 5
' 0
15
20
200
0
0
OJ 200
28,287,716
35,990,037
364,763
804,774
3,430
589,251
9,525,701
10,118,382
14,153
3,864
16,426
34;443
•"24,748
371
110,330
135,449
37,407,143
54,835,877
APPENDIX £ — TRI Releases and
Transfers by Four-Digit SIC Code
E-11
-------
Chemical Industry
National
Environmental
Baseline Report
199O to 1994
1990 - Total Transfers
•fe
II Jl
SIC Code
2800
Tot 81280
2812
2213
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2831
2833
2834
2835
2838
2839
Total 283
2840
2841
2842
2843
2844
Total 284
2851
2959
Total 285
2860
2861
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2882
Total 288
2890
2891
2892
2893
2895
2898
2899
Total 289
MuHiofo SIC with 2800
TOTAL
POTW (Pounds)
0
0
0
1,025
506
27,277,910
19,090,081
46.369.522
6,973,069
138.757
0
5,697
7,117,523
157,706
41,245
6,760.418
8,090.983
449,122
1,078,686
0
16,578,160
1,760
7,962,763
270,696
2,368,783
461,776
11,065.778
903,983
5
903.988
0
11,393
31,094,446
46,852,968
77,958.807
572,113
435
5,353
123,551
701,452
0
0
4,039
139,880
2,071
12,061
0
250
2,777,701
2,936.002
124,784,080
288,415,312
Other Transfers
(Pounds)
94,986
94,986
72,297
3,642,966
5,826
7,700,717
23,749,616
35,171,422
19,978,835
525,907
567,342
124,449
21.196.533
317,835
250
16,758,354
9,210,834
30,455
3,120
11,332
26.332,180
0
788,851
87.042
238.386
153,000
1,267,279
17,984,964
0
17.984,964
45,180
81,614
7,618,040
44,832,919
Sa577.753
855,654
248,695
488,824
, 5,359,750
6,952,923
104
104
7,777
3,292,371
3,087,028
779,193
8,733
0
3,471,791
10,646.893
86.398,607
258,623,644
Disposal
(Pounds)
681
681
10,351
3,347,606
1,350
7,548,109
12,961,783
23.869,199
3,483,565
159,046
340,000
44,995
4.027.608
233,870
250
1,184,199
274,460
21,100
0
10
1,713,889
0
726,157
11,681
149,714
25,867
913,419
4,140,943
0
4.140.943
730
77,781
2,860,310
10,457,632
13.396.453
851,804
206,151
486,820
305,623
1.850,398
104
104
0
306,918
2.544,743
131,481
7,964
0
2,838,033
5.829.139
18.198.840
73,940,671
Energy
Recovery
(Pounds)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
500
0
0
0
500
0
0
0
0
0
0
396,103
0
396.103
0
0
88.000
0
88.000
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
282.283
766,886
Other
(Pounds)
0
0
250
50
0
47,686
430
48.416
40,810
0
0
0
40.810
0
0
1,783,096
2,345
0
0
0
1,785,441
0
0
760
500
3,682
4.942
163,716
0
163.716
0
0
4,874
308,935
313,809
0
0
0
1,295
1.295
0
0
, 0
19,336
0
580
0
0
4,115
24.031
206.206
2,588,666
Recycling
(Pounds)
0
0
0
0
0
0
0
0
243,429
0
0
0
243,429
0
0
0
0
0
0
0
0
0
0
0
0
0
0
288,000
0
288,000
0
0
0
79,200
79,200
0
0
0
0
• 0
0
0
0
0
0
0
0
0
0
0
1,741.148
2,351,777
Treatment
(Pounds)
94,305
94,305
61,696
295,310
4,476
104,922
10,787,403
11,253,807
16,211,031
366,861
227,342
79,454
16,884,688
83,965
0
13,791,059
8.933,529
9,355
3,120
11,322
22.832.350
0
62,694
74,601
88,172
123,451
348,918
12,996,202
0
12,996,202
' 44,450
3,833
4,664,856
33,987,152
38,700,291
'3,850
42,544
2,004
5,052,832
5.101,230
0
0
7,777
2,966,117
542,285
647,132
769
0
629,643
4,793.723
65,970.130
178,975,644
Total Transfers
in 1990
(Rounds)
189,972
189.972
144,594
7,286.957
12.158
42.679.344
66,589,313
116.712.366
46,930.739
1,190.571
1.134.684
254,595
49.510.589
793,376
41.745
40,277,126
26,512,651
510,032
1,084,926
22664
69.242.520
1,760
9,540.465
.444,780
2,845,555
767,776
13.600.336
36,873.911
K
36.873.916
90,360
174,621
46,330.526
136,518,806
183.114.313
2,283.421
497.825
983,001
10,843,051
14.607.298
208
208
19.593
6,724,622
6,176.127
1,570.447
17,466
250
9,721,283
24,229.788
297.581.294
805,662,600
E-12
October 1997
SIC 2800
-------
1991 - Total Transfers
Chemical Industry
National
Environmental
Baseline Report
1999 to 1994
SIC Coda
2800
Total 280
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2831
2833
2834
2835
2836
Total 283
2840
2841
2842
2843
2844
Total 284
2851
2859
Total 285
2860
2861
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2890
2891
2892
2893
2895
2898
2899
Total 289
Multiple SIC with 2800
TOTAL
POTW(PounW
0
0
: 1.650
757
'0
17.082.270
13.645.631
.30.730.308
5,855.093
369.857
549
22.090
6.2471589
201.804
.750
8.146.630
9.955.024
195.675
881.151
19.381.034
1.250
7.046.804
245.709
1.960.253
269.764
9.523.780
1.343.002
5
1.343.007
0
8.375
23.683.990
39,604.489
63296854
1.704.368
318
2,000
75.212
1.781.898
1.265
68.626
2.084
9.395
0
250
2.534.038
2.615658
92.805.147
227,725,275
Other Transfers
(Pounds)
173.620
173.620
61,295
3.526,168
19,802
9,414,895
47.772,620
60.794.780
90.340,807
6.592.857
242,200
591,771
97.767,635
2.343,955
118,059
26.761,133
49.617,114
68,672
126,857
79.035.790
0
21.487,098
382,107
1.867,661
. 520,272
24.257,138
83.424,022
0
83.424.022
361,255
5,822
18.811,822
204.606,109
223.785,008
1.081,180
70.765
290,183
13.871,625
15.313,753
13.088
6.249.433
8.703,776
1.951.402
8,830
0
41.305,220
58.231 749
352.708,354
995,491,849
Disposal
(Pounds)
130.005
130.005
13,646
3,228,182
0
2,813,097
16,685,131
22.740.056
1,332,765
217,902
80,000
66,068
1.696,735
0
0
1.090.542
233.861
6.750
0
1.331.153
"0
500,836
23,921
28,242
31,092
584.091
• • 512,547
0
512,547
482
500
1.289.700
9.903,411
11.194,093
411.498
3.005
246,533
478,700
1.139,736
0
176,297
306,602
21.969
8,830
0
753.909
1.267.607
11.987.291
52,583,314
Energy
Racovety
(Pounds)
0
0
0
3.830
0
3.720
11.647.701
11.655.251
18,163,159
964.792
0
133.880
19.261.831
2,342.950
16,770
6,391.634
27,301.254
37.019
76,527
. 36.166.154
0
' 114.923
' 95.426
495.642
218,734
924.725
48.681.174
0
48.681J74
0
150
5.790.757
69,703.194
75,494.101
0
0
0
753.315
753.315
0
4,020.215
0
609.368
0
0
38.614.550
43.244.133
89.890.406
326,071,090
'Other .
(founds) .
0
0
0
9.700
0
0
478,302
488.002
43,539
0
0
0
43.539
0
0
25
250
0
0
275
0
3.940
250
0
1,000
5.190
747.770
0
747.770
0
0
1.669
1,107,910
1.109,579
0
0
0
2.307
Z307
0
0
0
5.230
0
0
12.643
17.873
91.322
2,505,857
Recycling
{Pounds)
0
0
1.360
96.603
19.802
800,334
3,896,520
4.814.619
61,440,974
4.835.942
162.200
0
66.439.116
0
101.129
3.765.932
13,985,165
0
1.900
17.854.126
0
20,824.428
140.741
495.132
63,100
21.523.401
24.745.762
0
24.745.762
0
0
6.956.470
80,685.792
87.642.262
663.062
0
34.980
7.828.906
8,526.948
0
870.797
7,990,969
957.133
0
0
597.436
10.416.335
180.081.090
422,043,659
Treatment
(Pounds)
43.615
43.615
46,289
187,853
0
5,797,744
15.064,966
21,096.852
9.360,370
574,221
0
391,823
10.326,414
1,005
160
15.513,000
8.096,584
24,903
48,430
23.684.082
0
42,971
121,769
848.645
206,346
1.219,731
8.736,769
0
8.736.769
360,773
5,172
4.773,226
43,205,802
48,344,973
6,620
67,760
8,670
4,808,397
4,891.447
13,088
1.182,124
406.205
357,702
0
0
1.326,682
3.285.801
70.658,245
192,287,929
Total Transfers
in 1991
(Pounds)
347,240
347.240
124,240
7,053.093
39.604
35,912,060
109,190,871
152,319.868
186,536,707
13,555.571
484,949
1,205,632
201,782.859
4,889,714
236.868
61,668.896
109,189,252
333,019
1,134,865
177,452.614
1.250
50,021,000
1,009.923
5,695.575
1,310,308
58,038,056
168,191,046
5
168,191.051
722,510
20,019
61,307.634
448,816,707
510,866,870
3.866.728
141.848
582,366
27,818,462
32,409,404
27,441
12,567.492
17,409,636
3,912.199
17.660
250
85,144,478
119,079.156
798,221.855
2,218,708,973
APPENDIX E — TRI Releases and
Transfers by Four-Digit SIC Code
E-13
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1992 - Total Transfers
SIC Code
2800
Total 280
2812
2S13
2315
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2830
2831
2833
2834
2835
2836
Tola! 283
2841
2842
2843
2844
Total 234
28S
2850
28S1
2856
2857
Total 285
2881
2863
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2881
Total 288
2890
2891
2892
2893
2895
2898
2899
Total 289
MuHlpte SIC with 2800
TOTAL
POTW (Pounds)
0
0
0
7.798
0
16.287,071
14.492,881
30.787,750
3.546.010
303,327
1.000
27,911
3,878,248
237.890
263
8,222,313
6.975,384
30,357
1,165.603
16,631,810
6.793,438
207,739
2.045.522
409.758
9.456,457
0
0
1.043,924
0
0
1,043,924
6,266
250
23.643,627
34,744.899
58.395,042
175,069
224
500
120.270
296,063
0
0
750
61.551
1,894
25,521
0
250
1,256,321
1.346,287
96.659,209
218,494,790
Other Transfers
(Pounds)
115.940
115.940
39.090
5,843.534
34.050
12.738.884
32,951,415
51,606.973
106.183.079
8.590.110
1.340.000
47.432
116,160.621
2,708.571
82.003
30,482,425
60,561.902
74.165
84.751
93,993,817
16,672,770
137.124
4,716.783
282,337
21,809,014
1.500
35.750
84.613.734
245
3.034
84,654.263
161.515
0
19,416,755
189,572,106
209,150.376
1,050,941
5.243
70.645
11,021,007
12,147,836
54.026
54.026
33.500
7,699,581
8,621.605
2.438.069
109
0
8.395,943
27,188,807
400,412.965
1,017,294,638
Disposal
(Pounds)
96.005
96.005
7.642
5,555,106
0
1,158.817
9,201.042
15,922,607
1,254.621
115.184
1,340.000
1,826
Z71 1.631
0
0
1,391.871
283,684
1.200
0
1,676.755
347,108
12.505
2,245.494
34,008
2,639,115
0
750
562,726
220
0
563,696
500
0
2,554,493
7,580,747
10,135,740
484.902
5.243
68.545
653.049
1,211,739
136
136
1,300
473.681
130.729
16.285
109
0
603.462
1,225.566
11,338.500
47,521,490
Energy
Recovery
(Pounds)
0
0
0
1
0
5,994
8.314,857
8.320,852
32.930.568
1,317,193
0
8,620
34.256,381
2.664,420
0
9,796,501
31,713.284
41,612
66,811
44.282,628
115,407
40.720
296.321
116,846
569,294
1.500
35.000
52,761,405
25
3,034
52,800,964
147,839
0
7,521,286
83,487,877
91,157,002
0
0
0
2,263,096
2,263,096
8,060
8.060
0
4.904,449
0
765,866
0
0
4,423,573
10,093,888
108,273,294
352,025,459
Other
(Pounds)
0
0
22
17.500
0
0
0
17,522
51,367
700
0
0
52,067
0
0
0
11,975
0
0
11,975
0
0
0
6.300
6,300
0
0
189,096
0
0
189,096
0
0
168
33,533
33,701
0
0
0
0
0
0
0
0
43,909
0
89,220
0
0
1,968
135,097
945,000
1,390,758
Recycling
(Pounds)
0
0
2,163
66.455
34.050
800,163
3,646,321
4,549,152
63,381,177
6.469.385
0
34,000
69,884.562
2.100
82,003
2,713.524
10,917,770
0
1,800
13,717,197
16,180,492
42.320
1,973.225
36,010
18,232,047
0
0
24,802,838
0
0
24,802,838
5,005
0
7,027.564
79,382,596
86.415.165
566.039
0
0
6,713.648
7,279.687
0
0
0
950,092
8,196,422
1,021.411
0
0
634.232
10,802,157
206,196,953
441,879,758
Treatment
(Pounds)
19,935
19.935
29,263
204.472
0
10.773.910
11,789,195
22,796,840
8,565,346
687.648
0
2,986
9.255,980
42,051
0
16.580,529
17.635,189
31,353
16,140
34,305,262
29,763
41,579
201,743
89,173
362.258
0
0
6.297.669
0
0
6.297,669
8,171
0
2,313,244
19.087.353
21.408.768
0
0
2,100
1,391,214
1,393.314
45,830
45,830
32.200
1,327,450
294.454
545.287
0
0
2.732,708
4.932,099
73.659.218
174,477,173
Total Transfers
In 1992 (Pounds)
231.880
231.880
78,180
11.694.866
68.100
41,764,839
80,395,711
134.001,696
215.912,168
17.483.547
2,681,000
122,775
236,199,490
5,655,032
164,269
69.187.163
128.099.188
178,687
1,335,105
204,619,444
40.138.978
481,987
11.479,088
974,432
53.074,485
3.000
71,500
170.271.392
490
6,068
170.352,450
329,296
250
62.477.137
413,889,111
476.695.794
2,276.951
10,710
141.790
22.162.284
24.591.735
108,052
108,052
67.750
15,460,713
17,245,104
4.901.659
218
250
18,048,207
55,723,901
897,485,139
2,253,084,066
E-14
October 1997
SIC 2800
-------
1993 - Total Transfers
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Cede
2810
2812
2813
2815
2816
2819
Total 281
2821
2822
2823
2824
Total 282
2833
2834
2835
2836
Total 283
2841
2842
2843
2844
Total 284
2851
Total 285
2861
2865
2869
Total 286
2873
2874
2875
2879
Total 287
2889
Total 288
2891
2892
2893
2899
Total 289
Multiple SIC with 2800
Total
POTW (Pounds)
760
10
62.080
0
15.811.677
13,727,333
29.601.850
5.288.055
130,980
1,000
21,780
5.441.815
7,830.442
4,096,943
39,469
41,341
12.008.195
6,749,981
6.362,147
2.109.476
298.141
15.519.725
1.063.119
1.063.119
14,421
21.951.067
27,069.173
49 034 661
109,604
193
1,025
103,788
214.610
0
0
59,998
39
28.872
993,532
1,082.441
67,410,806
181,377,222
Other Transfers
(Pounds)
0
15.450
5,141,656
1,210
11,423,044
22,553,205
39.134.565
88,481,239
15,444,119
1.615,500
73.094
105.613.952
19,399,133
47,213,877
158,829
114.112
66.885.951
14,428.630
290.181
4,590,059
636,592
19.945.462
83,225,269
83,225.269
3,911
18,588,434
207,730,990
226.323.335
1,422,088
1,760
238,364
12.304.741
13.966,953
7,600
7,600
7.658.327
2,372,711
2,146,483
7,729,945
19,907,466
430,188.094
1,005,198,647
Disposal
(Pounds)
0
'2,648
4,825,713
0
252,809
4.320,498
9.401.668
991,191
79,311
1,615,500
17,743
2.703.745
456.108
111,945
0
660
568,713
233,061
51,702
881,664
66,546
1.232.973
794.399
794.399
0
2.464.785
9.350,285
11.815.080
68,041
1.760
236.689
648.235
954,725
0
0
562,544
156,081
15.587
403,773
1,137,985
13,422,703
42,031,991
Energy Recovery
(Pounds)
0
0
0
0
48.625
2.265.472
2.314.097
32,938,218
1,018,008
0
40,435
33.996,661
9,571,713
15,803,627
32,165
99,046
25.506.551
30,000
66,772
420.614
227,775
745,161
53,064,463
53.064.463
462
5.186,539
85,504,191
90.691.192
0
0
755
493.095
493,850
7.600
7.600
4,741,886
0
812.665
4.628,572
10,183.123
149.951.026
366,953,724
Other
.(Pounds)
0
0
0
0
0
0
0
37.567
0
0
0
37.567
0
250
0
0
250
0
0
0
0
0
10.102
10.102
0
0
250
250
0
0
0
0
0
0
0
1,505
0
83.000
0
84,505
2,537
135,211
Recycling
(Pounds)
0
0
164,825
1,210
621,743
4.182,093
4.969.871
46.694,694
13.827,280
0
14,000
60.535.974
3.080.334
12.609,333
97,672
13.994
1S.801.333
14,142,743
22,796
3.188,807
9.942
17.364.288
22,869,050
22,869,050
0
9,087,464
93.678,975
102.766.439
1.343,797
0
0
7.856,177
9.199,974
0
0
868,121
1.923,384
927.289
521,176
4.239,970
191.753,409
429,500,308
Treatment
(Pounds)
0
12.602
151.118
0
10,499,867
11,785,142
22,448.929
7,819,569
519,520
0
916
8.340,005
6.290,978
18,688,722
28,992
412
25.009.104
22.826
148,911
98,974
332.329
603.040
6.487,255
6.487.255
3.449
1,849.646
19,197.279
21.050.374
10.250
0
920
3,307,234
3.318.404
0
0
1,484,27!
293,246
307,942
2,176,424
4,261,883
75,058,419
166,577,413
Total Transfers In
•1993 (Pounds)
750
30.910
10,345.392
2,420
38.657.765
58.833,743
107.870.980
182.250.533
31,019,218
3,232.000
167,968
216.669.719
46.628.708
98,524,697
357,127
269,565
145.780.097
35,607,221
6.942.509
11,289.594
1.571.325
55.410,649
167.513.657
167,513.657
22.243
59.127.935
442,531.153
501.681.331
2,953.780
3.713
477.753
24.713.270
28,148,516
15,200
15.200
15.376.652
4,745,461
4,321,838
16,453,422
40.897.373
927,786,994
2,191,774,516
APPENDIX E — Tffl Releases and
Transfers fey Four-Digit SIC Code
E-15
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
1994 - Total Transfers
SIC Code
2812
2813
2815
2816
2819
Total 281
2821
£822
2823
2824
TOUJ282
2831
2833
2834
2835
2836
Tot«l 283
2841
2842
2843
2844
Totil 284
2850
2851
Tola] 285
2860
2861
2863
2865
2869
Total 28S
2873
2874
2875
2879
Total 287
2890
2891
2892
2893
2895
2899
Tola! 289
Multiple SIC with 2800
Total
POTW
(Pounds)
0
39,499
1.189
16,011,554
9,368,128
25.420,370
6.661,083
88,106
1.000
370
6,750,559
0
6.864,334
4.388,542
53,279
26,537
11,332,692
3,850,289
987,028
1,092,678
139,790
6.069,785
0
1,529,544
1,529,544
0
0
1,369
15.695.496
21.080.523
36.777,388
121.011
180
1,005
52,683
174,879
0
83,640
1,000
87,477
20
995.107
1,107,244
59,646,535
148,808,996
Other Transfers
(Pounds)
14,154
1.315,702
450
7,121,252
13,891,012
22,342,570
97,950,469
16,844,823
1,407,400
38,678
116,241,370
137,300
19,139,995
61,321,598
110,323
2,950
80,712,166
537,086
229,736
2,956,538
59,552
3.782,912
112,364
63,703,724
63,816,088
3,974
8,000
0
15,923,420
174,620,821
190,556,215
1,247,870
515
10,043
7,981,381
9.239.809
474
8,291,727
666,103
2,358,546
2,510
6.644,322
17,963,682
380,934,702
885,589,514
Disposal
(Pounds)
389
1.090,225
200
2,209,274
3.556,653
6,856,741
1.012.962
149,936
1,407,400
6,754
Z577.052
137,300
36,280
366,194
0
0
539.774
161.112
16,237
19,730
34,045
231.124
260
683.172
683,432
949
0
0
1.091.760
7.580,224
8,672,933
103,519
515
7,103
385,717
496,854
0
388,446
8,581
31.564
1.510
1,133.398
1,563,499
17,107,357
38,728,766
Energy Recovery
(Pounds)
0
30,000
0
1,118
153,678
184,796
32,024,637
1,120,442
0
2,932
33.148.011
0
9.665.984
36,683,534
18,640
0
46,368,158
15,845
104,898
485,340
7,306
613,389
112,104
40,227,877
40,339,981
2,507
0
0
8,127,957
86,248,022
94.378.486
50
0
0
1,756,262
1.756,312
474
4,244,858
0
699,484
1,000
3^6,116
8,271,932
132,836,610
357,897,675
Other
(Pounds)
0
0
0
0
0
0
. 47,288
0
0
0
47.288
0
0
250
0
0
250
0
0
0
0
0
0
2,042
2.042
0
0
0
0
423,109
423,109
0
0
0
0
0
0
0
0
0
0
0
0
2,782
475,471
Recycling
(Pounds)
0
23,72-f
0
422,958
4,784,368
5.231.050
57;059,915
13,596,548
0
0
- 70.656.463
0
• 2.048.469
11.774.033
56,878
250
13,879,630
291,787
15,500
2,375,552
•• 52
2,682,891
0
17,046,801
17.046.801
0
0
0
4.637,942
20,885,686
25.523.628
1.049.401
- 0
0
4,000,280
5.049.681
• o
1,529,568
304.497
1,292,328
0
627,135
3.753,528
155.744.459
299,568,131
Treatment
(Pounds)
13,765
171,753
250
4.487.902
5,396,313
10.069.983
7,805,667
1.977.897
0
28.992
9.812,556
0
7.389,262
12.497.587
34,805
2,700
19.924.354
68,342
93,101
75,916
18,149
255,508
0
5,743,832
5.743.832
518
8,000
0
2,065.761
59.483,780
'61,558,059
94,900
0
2,940
1,839,122
1,936,962
0
2,128,855
353,025
335,170
0
1.557,673
4,374,723
75,243,494
188,919,471
Total Transfers
tnl994
(Pounds)
28,308
2,670.903
2.089
30,254,058
37.150,152
70,105,510
. 202,562,021
33,777,752
: 2.815.800
77,726
239.233.299
274,600
45,144,324
127,031,738
273,925
32,437
172.757.024
4,924,461
1,446,500
7.005,754
258,894
13.635.609
224,728
128,936,992
129,161,720
7.948
16,000
1.369
47,542,336
370,322,165
417,889,818
2,616,751
1,210
21,091
16,015,445
18.654.497
948
16,667,094
1,333,206
4,744,569
5,040
14,283,751
37,034,608
821.515.939
1,919,988,024
E-16
October 1997
SIC 2800
-------
APPENDIX F — COMPLIANCE MONITORING
ACTIVITIES SUMMARY BY 4-DIGIT SIC CODE**
Summary of Compliance Monitoring Activities,
1990 to 1994
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
Total
Year
1990
856
26
45
601
1,322
116
2,966
1991
856
35
62
620
1,403
119
3,095
1992
829
37
33
610
1,230
101
2,840
1993
882
46
37
544
1,227
114
2,850
1994| Total
863
15
26
548
1,239
76
2,767
4,286
159
203
2,923
6,421
526
14,518
Summary of Violations
1990 to 1994
Statute
iilt
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
Total
Year
1990
35
8
31
61
687
19
841
1991
47
11
32
115
919
26
1,150
1992
40
11
47
141
1,318
26
1,583
1993
45
5
30
79
1,267
25
1,451
1994
41
6
29
79
1,005
20
Total
208
41
169
475
5,196
116
1,1 80| 6,205
Summary of Enforcement Actions
1990 to 1994
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
Total
Year
1990
88
8
28
54
562
12
752
1991
93
9
29
101
536
13
781
1992
96
7
42
86
446
20
697
1993
72
5
25
88
460
20
670
1994
72
4
21
78
390
16
581
Total
421
33
145
407
2,394
81
3,481
* EPA IDEA Database
* The tables in Appendix F are intended to give the reader an overview of enforcement
and compliance history by four-digit SIC code. Chemical facilities that have been
identified, but for which no four-digit SIC code is recorded in the database, are
excluded from this section but are included in the overall industry analysis found in
Sections 4 and 5 of this report. Further, Appendix F does not include every
compliance monitoring activity-for example, it does not track review of self-
monitoring reporting. The IDEA database does not capture differences in
programmatic activities (for example, compliance monitoring activities performed
under TSCA differ from those performed under CAA). Also regions and states vary
somewhat in how they implement programs.
Chemical Industry
National
Environmental
Baseline Report
1990 lo 1994
^3
f v -*~
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-1
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Compliance Monitoring Activities Summary - 281
SIC Code
2812
Subtotal
2813
Subtotal
2816
Subtotal
2819
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 281
Year
1990
41
0
1
30
36
8
116
5
2
0
11
15
0
33
6
0
0
23
8
0
37
204
0
3
150
278
25
660
846
1991
40
1
4
21
35
3
104
5
1
0
9
18
4
37
13
1
0
13
5
2
34
159
6
1
156
308
33
663
838
1992
40
2
1
27
41
11
122
6
3
1
14
14
0
38
16
0
0
16
6
6
44
168
3
0
137
253
15
576
780
1993
43
0
0
19
44
2
108
6
1
0
11
15
0
33
9
0
0
11
1
0
21
177
7
1
133
245
13
576
738
1994
35
0
0
18
37
3
93
5
0
0
10
12
0
27
19
1
0
18
4
0
42
179
3
2
136
228
8
556
718
Total
199
3
6
115
193
27
543
27
7
1
55
74
4
168
63
2
0
81
24
8
178
887
19
7
712
1,312
94
3,031
3,920
F-2
October 1997
SIC 2800
-------
Compliance Monitoring Activities Summary - 282
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2821
Subtotal
2822
Subtotal
2823
Subtotal
2824
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 282
Year
1990
81
0
0
74
89
6
250
17
0
0
11
30
2
60
5
0
0
10
5
0
20
14
0
1
17
17
2
51
381
1991
75
3
0
90
89
11
268
22
0
0
9
35
0
66
5
0
0
9
2
0
16
32
0
1
16
17
2
68
418
1992
67
0
1
77
94
1
240
16
1
0
11
20
1
49
12
0
0
6
6
0
24
20
0
1
17
12
0
50
363
1993] 1994| Total
79
3
0
62
87
18
249
16
1
0
11
23
5
56
10
1
0
9
8
0
28
28
1
0
14
14
0
57
390
68
0
0
72
83
7
230
20
0
0
15
20
0
55
5
0
0
6
6
0
17
30
0
1
12
11
2
56
358
370
6
1
375
442
43
1,237
91
2
0
57
128
8
286
37
1
0
40
27
0
105
124
1
4
76
71
6
282
1,910
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-3
-------
Chemical Industry
National
Environmental
Baseline Report
199O to 1994
Compliance Monitoring Activities Summary - 283
SIC Code
2833
Subtotal
2834
Subtotal
2835
Subtotal
2836
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 283
Year
1990
7
1
3
17
34
3
65
55
3
1
40
67
3
169
0
1
0
1
1
0
3
4
1
1
0
3
0
9
246
1991
22
1
1
13
25
0
1992
8
0
1
12
24
1
62 1 46
44
1
1
48
77
0
171
0
0
0
0
2
0
2
2
0
0
0
3
0
5
240
44
4
0
47
55
7
157
0
0
0
2
5
0
7
2
0
0
0
2
0
1993
12
1
0
12
27
0
52
40
5
0
43
71
4
163
0
0
0
1
3
0
4
3
0
1
0
4
0
4| 8
214| 227
1994
13
0
1
13
24
3
54
50
1
1
44
77
6
179
0
0
0
2
0
0
2
2
0
0
0
8
0
2
237
Total
62
3
6
67
134
7
279
233
14
3
222
347
20
839
0
1
0
6
11
0
18
13
1
2
0
20
0
36
1,172
F-4
October 1997
SIC 2800
-------
Compliance Monitoring Activities Summary - 284
Chemical Industry
National
Environmental
Baseline Report
1990 to 1094
SIC Code
2841
Subtotal
2842
Subtotal
2843
Subtotal
2844
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 284
Year
1990
20
0
1
5
18
0
44
11
5
8
4
28
7
63
0
0
0
3
3
0
6
11
2
0
15
21
1
50
163
1991
26
3
4
12
17
6
68
10
3
23
3
27
5
71
1
2
0
3
4
0
10
8
0
1
10
15
1
35
184
1992
21
1
2
6
17
1
48
5
2
. 10
5
28
2
52
0
1
0
4
2
0
7
4
0
0
15
13
0
32
139
1993) 1994| Total
14
1
2
8
17
6
48
14
4
18
3
15
6
60
0
1
0
4
2
0
7
4
1
0
8
13
0
26
141
17
1
0
2
16
2
38
7
0
9
4
25
2
47
2
0
0
4
5
0
11
6
0
0
8
31
0
45
141
98
6
9
33
85
15
246
47
14
68
19
123
22
293
3
4
0
18
16
0
41
33
3
1
56
93
2
188
768
Compliance Monitoring Activities Summary - 285
SIC Code
2851
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 285
Year
1990
58
2
11
8
161
15
255
1991
57
7
2
6
180
17
269
1992
58
6
0
9
157
11
241
1993| 1994| Total
48
7
1
9
147
17
47
1
2
9
140
10
229 | 209
268
23
16
41
785
70
1,203
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-5
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Compliance Monitoring Activities Summary - 286
I; , ,,,n
SIC Code
2861
Subtotal
2865
Subtotal
2869
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 286
Year
1990
7
0
0
6
15
2
30
34
1
0
20
25
4
84
115
2
0
77
206
19
419
533
1991
6
0
0
6
10
0
22
34
1
0
16
32
0
83
111
1
4
84
241
16
457
562
1992
21
2
0
8
19
3
53
35
2
0
17
33
5
92
90
2
1
91
213
12
409
554
1993
30
0
0
7
10
1
48
35
1
0
13
40
0
89
121
2
0
76
228
16
443
580
1994
18
0
0
6
12
0
36
26
0
0
16
28
11
81
113
3
0
62
253
10
441
558
Total
82
2
0
33
66
6
189
164
5
0
82
158
20
429
550
10
5
390
1,141
73
2,169
2,787
F-6
October 1997
SIC 2800
-------
Compliance Monitoring Activities Summary - 287
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2873
Subtotal
2874
Subtotal
2875
Subtotal
2879
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 287
Year
1990
20
0
0
13
9
1,
43
19
0
0
4
7
0
30
6
0
0
1
0
0
7
22
1
12
6
47
3
91
171
1991
32
0
0
19
9
2
62
16
0
0
6
6
0
28
8
0
1
0
1
0
10
25
1
16
9
50
1
102
1992
30
1
0
14
11
0
56
32
1
0
4
5
0
42
4
0
0
1
1
0
6
19
0
8
10
43
4
84
202| 188
1993
31
2
0
14
11
1
59
25
1
0
8
12
0
46
6
0
1
1
1
0
9
18
2
9
15
42
4
90
204
1994
29
0
0
15
14
0
58
24
0
0
7
5
0
36
7
0
4
1
1
0
13
24
0
3
11
46
1
85
192
Total
142
3
0
75
54
4
278
116
2
0
29
35
0
182
31
0
6
4
4
0
45
108
4
48
51
228
13
452
957
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-7
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Compliance Monitoring Activities Summary - 289
SIC Code
2891
Subtotal
2892
Subtotal
2893
Subtotal
2895
Subtotal
2899
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 289
Year
1990
16
2
0
0
30
6
54
10
0
0
8
• 18
0
36
6
1
0
0
39
0
46
13
0
0
1
1
0
15
49
3
3
46
111
9
221
1991
18
0
0
6
22
1
47
6
0
0
5
18
0
29
5
1
0
1
36
0
43
12
0
0
0
1
0
13
62
2
3
50
118
15
250
372| 382
1992
17
2
1
10
13
1
44
11
0
0
4
14
0
29
5
0
0
1
22
0
28
17
0
0
0
1
0
18
61
4
6
45
101
20
237
356
1993
20
1
0
7
18
8
54
5
1
0
5
12
4
27
3
1
0
3
18
1
26
15
0
= 0
0
0
0
,15
64
1
4
37
99
8
213
335
1994
23
, 2
0
8
26
5
64
5
0
0
6
10
0
21
: 3
0
0
1
20
0
24
: 16
1
0
0
0
3
20
70
2
3
42
97
3
217
346
Total
94
7
1
31
109
21
263
37
1
0
28
72
4
142
22
3
0
6
135
1
167
73
1
0
1
3
3
81
306
12
19
220
526
55
1,138
1,791
F-8
October 1997
SIC 2800
-------
Violations Summary - 281
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2812
Subtotal
2813
Subtotal
2816
Subtotal
2819
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 281
Year
1990
3
0
0
2
20
2
27
0
0
0
0
3
1
4
0
0
0
0
3
0
3
6
0
4
12
162
4
188
222
1991
4
0
0
0
19
2
25
1
0
0
2
4
0
7
4
0
0
1
2
0
7
4
0
1
44
216
2
267
306
1992
2
0
1
2
23
0
28
0
5
1
6
25
0
37
2
0
0
4
0
0
6
7
0
1
48
253
7
316
387
1993
2
0
0
5
16
0
23
0
0
1
3
9
0
13
1
0
0
2
0
0
3
10
0
2
21
185
5
223
262
1994J Total
1
0
0
4
22
0
27
0
0
0
2
2
1
5
5
0
0
0
0
0
5
10
0
2
26
145
2
185
222
12
0
1
13
100
4
130
1
5
2
13
43
2
66
12
0
0
7
5
0
24
37
0
10
151
961
20
1,179
1,399
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-9
-------
Chemical Industry
National
Environmental
Baseline Report
199Oto 1994
Violations Summary - 282
SIC Code
2821
Subtotal
2822
Subtotal
2823
Subtotal
2824
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 282
Year
1990
2
1
0
11
67
1
82
1
0
0
0
g
0
10
0
0
0
0
0
0
0
0
0
1
0
3
0
4
96
1991
2
0
0
14
69
0
85
2
0
0
0
52
0
54
0
0
0
0
0
0
0
0
0
2
1
1
0
4
143
1992
4
0
1
17
120
0
142
0
0
0
0
42
0
42
3
0
0
0
3
0
6
0
0
0
1
0
0
1
191
1993
8
0
0
5
139
3
155
1
1
0
0
51
3
56
0
0
0
0
11
0
11
1
0
1
1
3
1
7
229
1994
3
0
0
4
140
3
150
1
0
0
. 0
15
0
16
1
0
0
0
7
0
8
0
•: 0
0
0
2
0
2
176
Total
t9
1
1
51
535
7
614
5
1
0
0
169
3
178
4
0
0
0
21
0
25
1
0
4
3
9
1
18
835
F-10
October 1997
SIC 2800
-------
Violations Summary - 283
Chemical Industry
National
Environmental
Baseline Report
199Oto 1994
SIC Code
2833
Subtotal
2834
Subtotal
2835
Subtotal
2836
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 283
Year
1990
0
0
0
0
6
0
6
4
0
1
5
20
0
30
0
0
0
0
0
0
0
0
0
0
0
0
0
0
36
1991
0
0
0
2
41
0
43
2
1
0
7
19
0
29
0
1
0
2
2
0
5
0
0
0
0
2
0
2
79
1992
2
0
0
2
21
0
25
1
0
0
7
34
1
43
0
0
0
1
2
0
3
0
0
1
0
1
0
2
73
1993
0
0
0
1
40
0
41
0
1
0
5
41
1
48
0
0
0
1
1
0
2
0
0
1
0
1
0
2
93
1994| Total
5
0
0
0
47
0
52
1
3
0
3
94
4
105
0
0
0
1
0
0
1
0
0
0
0
2
0
2
160
7
0
0
5
155
0
167
8
5
1
27
208
6
255
0
1
0
5
5
0
11
0
0
2
0
6
0
8
441
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-11
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Violations Summary - 284
SIC Code
2841
Subtotal
2842
Subtotal
2843
Subtotal
2844
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 284
Year
1990
2
0
0
0
6
0
8
0
1
10
0
15
0
26
0
0
0
1
0
0
1
1
0
1
3
5
0
10
45
1991
0
0
3
0
9
0
12
0
1
12
0
4
4
21
0
0
0
0
4
0
4
0
0
0
4
8
0
12
49
1992
0
1
4
0
9
1
15
0
2
3
0
18
2
25
0
0
0
0
0
0
0
0
0
0
2
5
0
7
47
1993
0
0
0
1
2
1
4
1
0
6
0
26
0
33
0
0
0
0
0
0
0
1
0
0
4
23
0
28
65
1994
0
2
1
2
2
•/,-• 2
9
0
1
11
0
33
2
47
0
0
0
0
1
0
1
0
: "0
0
3
13
0
16
73
Total
2
3
8
3
28
4
48
1
5
42
0
96
8
152
0
0
0
1
5
0
6
2
0
1
16
54
0
73
279
Violations Summary - 285
SIC Code
2851
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 285
Year
1990
4
5
6
1
95
1
1991
5
2
4
0
132
0
112| 143
1992
5
1
1
12
222
4
245
1993
4
1
11
1
275
4
296
1994
1
0
2
4
178
1
186
Total
19
9
24
18
902
10
982
F-12
October 1997
SIC 2800
-------
Violations Summary - 286
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2861
Subtotal
2865
Subtotal
2869
Subtotal
Statute ,
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 286
Year
1990
0
0
0
0
4
0
4
0
0
1
12
19
4
36
6
1
2
13
104
4
130
170
1991
4
0
0
0
7
1
12
2
2
0
6
27
6
43
7
1
1
18
117
6
150
205
1992
0
0
1
0
15
0
16
0
0
0
6
36
1
43
7
0
2
15
143
5
172
231
1993
1
0
0
0
12
0
13
0
0
0
1
37
0
38
11
2
1
7
94
3
118
169
1994| Total
0
0
0
0
10
0
10
1
0
2
4
39
0
46
6
0
1
12
59
3
81
137
5
0
1
0
48
1
55
3
2
3
29
158
11
206
37
4
7
65
517
21
651
912
U
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-13
-------
Chemical Industry
National
Environmental
Baiolino Roport
1990 to 1994
Violations Summary - 287
|M||» I
,,4
SIC Code
2873
Subtotal
2874
Subtotal
2875
Subtotal
2879
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 287
Year
1990
0
0
0
0
3
0
3
1
0
0
0
5
0
6
0
0
0
0
0
0
0
1
0
3
0
29
0
33
42
1991
1
0
0
0
6
0
7
3
0
0
2
2
0
1992
0
0
0
1
20
0
21
2
0
0
1
1
0
7| 4
1
0
0
0
1
0
2
2
2
7
4
47
2
64
0
0
0
0
1
0
1
3
1
31
5
24
0
64
80 1 90
1993
1
0
0
0
13
0
14
0
0
0
10
15
0
25
0
0
0
0
1
0
1
3
0
5
6
37
0
51
91
1994
0
0
0
0
10
0
10
0
0
0
3
1
0
4
0
0
2
0
1
0
3
1
0
8
6
34
1
50
67
Total
2
0
0
1
52
0
55
6
0
0
16
24
0
46
1
0
2
0
4
0
7
10
3
54
21
171
3
262
370
F-14
October 1997
SIC 2800
-------
Violations Summary - 289
Chemical Industry
Notional
Environmental
Bwteline Report
1990 to 1994
SIC Code
2891
Subtotal
2892
Subtotal
2893
Subtotal
2895
Subtotal
2899
Subtotal
Statute
i
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 289
Year
1990
1
0
1
0
13
0
15
1
0
0
0
6
0
7
0
0
0
0
25
2
27
1
0
0
0
0
0
1
1
0
1
1
65
0
68
118
1991
1
0
0
3
13
0
17
0
0
0
1
14
0
15
0
1
0
0
21
0
22
2
0
0
0
0
0
2
1
0
2
4
80
3
90
146
1992
0
0
0
7
9
0
16
1
0
0
2
20
0
23
0
1
0
0
19
0
20
0
0
0
0
2
0
2
0
0
0
2
250
5
257
318
1993
0
0
1
4
14
0
19
0
0
0
0
14
1
15
0
0
0
0
25
0
25
0
0
0
0
0
1
1
0
0
1
1
182
2
186
246
1994
0
0
0
, 3
27
0
30
0
0
0
2
21
0
23
0
0
0
0
10
0
10
0
0
0
0
0
0
0
5
0
0
0
90
1
96
159
Total
2
0
2
17
76
0
97
2
0
0
5
75
1
83
0
2
0
0
100
2
104
3
0
0
0
2
1
6
7
0
4
8
667
11
697
890
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SSC Code
F-15
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Enforcement Actions Summary - 281
SIC Code
2812
Subtotal
2813
Subtotal
2816
Subtotal
2819
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 281
Year
1990
8
0
0
1
9
1
19
1
0
0
1
7
1
10
0
0
0
1
2
0
3
13
0
4
16
116
2
151
183
1991
0
0
0
3
17
1
21
1
0
0
3
3
0
7
1
0
0
2
2
0
5
9
,0
1
26
97
2
135
168
1992
9
0
1
1
19
0
30
0
2
1
5
4
0
12
0
0
0
2
3
1
6
21
0
1
17
84
5
128
176
1993
1
0
0
2
17
0
20
0
0
1
1
11
0
13
0
0
0
1
0
0
1
16
0
2
7
73
4
102
136
1994
2
0
0
5
10
0
17
0
0
0
3
3
1
6
0
0
0
0
2
0
2
7
0
2
17
70
2
98
123
Total
20
0
1
12
72
2
107
2
2
2
13
28
2
49
1
0
0
6
9
1
17
66
0
10
83
440
15
614
787
F-16
October 1997
SIC 2800
-------
Enforcement Actions Summary - 282
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2821
Subtotal
2822
Subtotal
2823
Subtotal
2824
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 282
Year
1990
3
1
0
8
43
1
56
7
0
0
3
15
0
25
1
0
0
0
1
0
2
0
0
1
0
2
0
3
86
1991
8
0
0
16
35
0
59
1
0
0
3
10
0
14
0
0
0
0
0
0
0
0
0
1
0
4
0
5
78
1992
10
0
1
15
• 30
0
56
0
0
0
0
5
0
5
3
0
0
1
1
0
5
0
0
0
0
0
0
0
66
1993
10
0
0
8
29
2
49
0
1
0
2
8
1
12
2
0
0
1
4
0
7
0
0
1
1
3
1
6
74
1994| Total
7
0
0
8
43
2
60
2
0
0
4
4
0
10
3
0
0
1
1
0
5
0
0
0
0
2
0
2
77
38
1
1
55
180
5
280
10
1
0
12
42
1
66
9
0
0
3
7
0
19
0
0
3
1
11
1
16
381
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-17
-------
Chemical Industry
National
Environmental
Baseline Report
199O to 1994
Enforcement Actions Summary - 283
iiljfli
j:Jf.-iST
; w.
it -
SE' ." In I"™"!
SIC Code
2833
Subtotal
2834
Subtotal
2835
Subtotal
2836
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 283
Year
1990
0
0
0
1
8
0
9
7
0
1
3
20
0
31
0
0
0
0
0
> 1
1
0
0
0
0
3
0
3
1991
1
0
0
0
8
0
9
15
1
0
9
20
0
45
0
1
0
1
1
0
3
0
0
0
0
3
0
3
44| 60
1992
2
0
0
0
7
0
9
15
0
0
7
15
1
38
0
0
0
1
1
0
2
0
0
1
0
1
1
3
52
1993
1
0
0
0
13
0
14
10
1
0
3
29
1
44
0
0
0
0
1
0
1
0
0
1
0
2
1
4
63
1994
4
0
0
1
6
0
11
14
1
0
13
24
2
54
0
0
0
1
0
0
1
0
0
0
0
2
0
2
Total
8
0
0
2
42
0
52
61
3
1
35
108
4
212
0
1
0
3
3
1
8
0
0
2
0
11
2
15
68| 287
F-18
October 1997
SIC 2800
-------
Enforcement Actions Summary - 284
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
2841
Subtotal
2842
Subtotal
2843
Subtotal
2844
Subtotal
Statute
*
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 284
Year
1990
1
0
o
0
8
0
9
0
1
10
0
14
0
25
0
0
0
0
2
0
2
0
0
1
4
13
1
19
,1991
1
0
3
0
6
0
10
1
1
12
0
10
1
25
0
0
0
0
2
0
2
0
0
0
3
12
0
15
55| 52
1992
1
1
4
0
4
1
11
0
1
3
0
11
2
17
0
0
0
0
1
0
1
0
0
0
2
6
0
8
37
1993
0
0
0
0
4
1
5
0
0
6
0
8
0
14
0
0
0
0
0
0
0
0
0
0
1
4
0
5
24
1994J Total
0
2
1
0
1
2
6
0
1
7
1
13
2
24
0
0
0
0
1
0
1
0
0
0
0
12
0
12
43
3
3
8
0
23
4
41
1
4
38
1
56
5
105
0
0
0
0
6
0
6
0
0
1
10
47
1
59
211
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-19
-------
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
Enforcement Actions Summary - 285
SIC Code
2851
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 285
Year
1990
2
5
4
1
71
1
84
1991
3
2
4
0
86
0
95
1992
4
1
1
1
76
2
85
1993
3
1
7
0
86
4
101
1994
0
0
2
1
45
1
49
Total
12
9
18
3
364
8
414
Enforcement Actions Summary - 286
SIC Code
2861
Subtotal
2865
Subtotal
2869
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 286
Year
1990
5
0
0
1
6
0
12
7
0
1
2
7
1
18
22
1
2
8
82
3
118
148
1991
3
0
0
1
7
1
12
4
1
0
3
12
1
21
31
1
1
17
87
4
141
174
1992
0
0
1
0
5
0
6
6
0
0
6
16
1
29
19
0
2
13
68
4
106
141
1993
2
0
0
0
6
0
8
1
0
0
3
14
0
18
12
2
1
6
61
3
85
111
1994
0
0
0
0
5
0
5
2
0
1
3
11
0
17
23
0
1
10
39
2
75
97
Total
10
0
1
2
29
1
43
20
1
2
17
60
3
103
107
4
7
54
337
16
525
671
F-20
October 1997
SIC 2800
-------
Enforcement Actions Summary -287
Chemical Industry
National
Environmental
Baseline Report
1990 to 1994
SIC Code
-
2873
Subtotal
2874
Subtotal
2875
Subtotal
2879
Subtotal
Statute
CAA .
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 287
Year
1990
3
0
0
0
6
• • 0
9
3
0
0
0
0
0
3
1
0
0
0
o
0
1
" • "I
0
2
0
19
0
22
35
1991
0
0
0
4
7
0
11
0
0
0
1
1
0
2
1
0
0
0
1
0
2
4
1
5
3
26
1
40
55
1992
0
0
0
1
, 4
0
5
0
0
0
2
1
0
3
0
0
0
0
1
0
1
4
1
26
2
22
0
55
64
1993
0
0
0
1
10
0
11
0
0
0
1
. 2
0
3
0
0
0
0
0
0
0
8
0
4
2
20
0
34
48
1994) Total
0
0
0
1
6
0
7
0
0
0
0
4
0
4
0
0
2
0
0
1
3
5
0
5
2
19
1
32
46
3
0
0
7
33
0
43
3
0
0
4
8
0
15
2
0
2
0
2
1
7
22
2
42
9
106
2
183
248
APPENDIX F — Compliance Monitoring
Activities Summary by Four-Digit SIC Code
F-21
-------
Chemical Industry
National
Environmental
Baseline Report
1990lo1994
Enforcement Actions Summary - 289
li ,£=
f- ...... - ..... :
SIC Code
2891
Subtotal
2892
Subtotal
2893
Subtotal
2895
Subtotal
2899
Subtotal
Statute
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
CAA
EPCRA
FIFRA
CWA
RCRA
TSCA
TOTAL 289
Year
1990
0
0
1
0
16
0
17
1
0
0
0
10
0
11
0
0
0
0
23
2
25
0
0
0
1
2
0
3
2
0
1
3
57
0
63
1991
1
0
0
0
7
0
8
0
0
0
1
10
0
11
0
1
0
0
18
0
19
2
0
0
0
0
0
2
6
0
2
5
46
2
61
119J 101
1992
0
0
0
0
7
0
7
0
0
0
0
8
0
8
0
1
0
0
8
0
9
0
0
0
0
1
0
1
2
0
0
3
37
4
46
71
1993
0
0
1
1
6
0
8
0
0
0
4
0
1
5
0
0
0
0
9
0
9
0
0
0
0
1
1
2
6
0
1
3
41
1
52
76
1994
0
0
0
2
9
0
11
0
0
0
0
4
0
4
0
0
0
1
8
0
9
0
0
0
0
0
0
0
3
0
0
4
46
1
54
78
Total
1
0
2
3
45
0
51
1
0
0
5
32
1
39
0
2
0
1
66
2
71
2
0
0
1
4
1
8
19
0
4
18
227
8
276
445
F-22
*U.S. GOVERNMENT PRINTING OFFICE: 1 997-61 6-11 8/90439
October 1997
SSC 2800
------- |