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                                                    i*..in-	i •: " ii"'ii 'i''i ''

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                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460
                                                                         THE ADMINISTRATOR
Message from the Administrator

Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.

The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.

Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.

These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.

I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
                                                Carol M. Brown-
           Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)

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

                       Profile of the Inorganic Chemical Industry




                                    September 1995
                                  Office of Compliance
                     Office of Enforcement and Compliance Assurance
                          U.S. Environmental Protection Agency
                              401 M St., SW (MC 2221-A)
                                 Washington, DC 20460
                               For sale by the U.S. Government Printing Office
                       Superintendent of Documents, Mail Stop: SSOP, Washington', DC 20402-9328
                                    ISBN 0-16-048271-2
September 1995
            SIC 281

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

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

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA  15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and
academic libraries, Federal, State, local, and foreign governments, and the media. For further
information, and for answers to questions pertaining to these documents, please refer to the
contact names and numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin
Board and via the Internet on the Enviro$en$e World Wide Web.  Downloading procedures are
described in Appendix A of this document.
Cover photograph by Steve Delaney, EPA. Photograph courtesy of Vista Chemicals, Baltimore,
Maryland. Special thanks to Dave Mahler.
September 1995
            SIC 281

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                                     Sector Notebook Contacts

The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:

         Seth Heminway, Sector Notebook Project Coordinator
         US EPA, Office of Compliance
         401MSt, SW(2223-A)
         Washington, DC 20460
         (202) 564-7017 fax (202) 564-0050
         E-mail: heminway.seth@epamail.epa.gov

Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-

EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
•R-95-008.
•R-95-009.
-R-95-010.
•R-95-011.
-R-95-012.
•R-95-013.
•R-95-014.
•R-95-015.
R-95-016.
•R-95-017.
R-95-018.

R-97-001.
R-97-002.
R-97-003.
R-97-004.
R-97-005.
R-97-006.
R-97-007.
R-97-008.
R-97-009.
R-97-010.
EPA/310-B-96-003.
    Industry

 Dry Cleaning Industry
 Electronics and Computer Industry
 Wood Furniture and Fixtures Industry
 Inorganic Chemical Industry
 Iron and Steel Industry
 Lumber and Wood Products Industry
 Fabricated Metal Products Industry
 Metal Mining Industry
 Motor Vehicle Assembly Industry
 Nonferrous Metals Industry
 Non-Fuel, Non-Metal Mining Industry
 Organic Chemical Industry
 Petroleum Refining Industry
 Printing Industry
 Pulp and Paper Industry
 Rubber and Plastic Industry
 Stone, Clay, Glass, and Concrete Industry
 Transportation Equipment Cleaning Ind.

*Air Transportation Industry
 Ground Transportation Industry
* Water Transportation Industry
 Metal Casting Industry
 Pharmaceutical Industry
 Plastic Resin and Man-made Fiber Ind.
 *Fossil Fuel Electric Power Generation Ind.
 *Shipbuilding and Repair Industry
 Textile Industry
 * Sector Notebook Data Refresh, 1997

 Federal Facilities
Contact

Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop

Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway

Jim Edwards
Phone (202)

564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057

564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017

564-2461
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting

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Sector Notebook Project
Inorganic Chemicals
        Industry Sector Notebook Contents: Inorganic Chemicals Manufacturing
Exhibits Index	 iii

List of Acronyms	v

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

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

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

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

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

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

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

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY .113

ENDNOTES  	115

APPENDIX A  	  A-l
September 1995
11
                                SIC 281

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  Sector Notebook Project
                         Inorganic Chemicals
                                      Exhibits Index

Exhibit 1:   Inorganic Chemicals Industry Dominated by a Large Number of Small Facilities  	6
Exhibit 2:   Inorganic Chemicals Facilities Distribution	.6
Exhibit 3:   Chlorine Capacity Located Primarily Along Gulf Coast, Southeast, Northwest,
           and Great Lakes Region	8
Exhibit 4:   Top U.S. Companies with Inorganic Chemical Manufacturing Operations  	9
Exhibit 5:   Chlorine Electrolysis Cells	 15
Exhibit 6:   Main Characteristics of the Different Electrolysis Processes  	 16
Exhibit 7:   Mercury Electrolysis Cell and Flow Diagram	 17
Exhibit 8:   Typical Diaphragm Electrolysis Cell and Flow Diagram	19
Exhibit 9:   Typical Membrane Electrolysis Cell	21
Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry
           (SIC 281) as Reported within TRI  	30
Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
           by Number of Facilities Reporting	36
Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
           by Number of Facilities Reporting	39
Exhibit 13: Top 10 TRI Releasing Inorganic Chemicals Facilities	42
Exhibit 14: Top 10 TRI Releasing Facilities Reporting Inorganic Chemical  SIC Codes to TRI ... 43
Exhibit 15: Pollutant Releases (short tons/year)	48
Exhibit 16: Summary of 1993 TRI Data: Releases and  Transfers by Industry	51
Exhibit 17: Toxics Release Inventory Data for Selected Industries	52
Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities	57
Exhibit 19: Modifications to Equipment Can Also Prevent Pollution  .	66
Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic
           Chemicals Manufacturing	94
Exhibit 21: Five-Year Enforcement and Compliance Summary for Selected Industries	96
Exhibit 22: One-Year Inspection and Enforcement Summary for Selected Industries 	97
Exhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 98
Exhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 99
Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview:
           Inorganic Chemical Manufacture  	 102
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)	 104
Exhibit 27: Contacts for State and Local Pollution Prevention Programs	 109
 September 1995
111
SIC 281

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Sector Notebook Project
                      Inorganic Chemicals
                                List of Acronyms

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

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

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Sector Notebook Project
Inorganic Chemicals
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

LA. Summary of the Sector Notebook Project

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

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

                    For any given industry, each topic listed above could alone be the subject of
                    a lengthy volume. However, in order to produce a manageable document,
                    this project focuses on providing summary information for each topic. This
                    format provides the  reader with a synopsis of each issue, and references
                    where more in-depth information is available. Text within each profile was
                    researched from a variety of sources, and was usually condensed from more
                    detailed sources pertaining to specific topics. This approach allows for a
                    wide  coverage of activities that can be further explored  based  upon the
                    citations and references listed at the end of this profile.  As a check on the
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Sector Notebook Project
Inorganic Chemicals
                    information included,  each notebook went through an external  review
                    process. The Office of Compliance appreciates the efforts of all those that
                    participated in this process and enabled us to develop more complete,
                    accurate and up-to-date summaries.

I.B. Additional Information
Providing Comments
                    OECA's Office of Compliance plans to periodically review and update the
                    notebooks and will make these updates available both in hard copy and
                    electronically. If you have any comments on the existing notebook, or if you
                    would like to provide additional information, please send a hard copy and
                    computer disk to the EPA Office of Compliance, Sector Notebook Project,
                    401 M St., SW (2223-A), Washington, DC 20460. Comments can also be
                    uploaded to the Enviro$en$e Bulletin Board or the Enviro$en$e World Wide
                    Web for general access to all users of the system.  Follow instructions in
                    Appendix A for accessing these data systems.  Once you have logged  in,
                    procedures for uploading text are available from the on-line Enviro$en$e
                    Help System.
Adapting Notebooks to Particular Needs
                    The scope of the existing notebooks reflect an approximation of the relative
                    national occurrence of facility types that occur within each sector.  In many
                    instances, industries within specific geographic regions or states may have
                    unique characteristics that are not fully captured in these profiles.  For this
                    reason, the Office of Compliance encourages state and local environmental
                    agencies and other groups to  supplement or re-package  the  information
                    included in this notebook to include more specific industrial and regulatory
                    information that may be available. Additionally, interested states may want
                    to  supplement  the  "Summary  of  Applicable Federal  Statutes  and
                    Regulations" section  with state and local requirements.  Compliance or
                    technical assistance providers may also want to develop the "Pollution
                    Prevention" section in more detail. Please contact the appropriate specialist
                    listed on the opening page of this notebook if your office is interested in
                    assisting us  in  the further  development of the information or policies
                    addressed within this volume.

                    If you are interested in assisting in the development of new notebooks for
                    sectors not covered in the original eighteen, please contact the Office of
                    Compliance at 202-564-2395.
September 1995
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Sector Notebook Project
Inorganic Chemicals
II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY

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

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

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

                     Whenever possible, this notebook describes the entire inorganic chemical
                     industry.  In many cases, however, specific details relating to some of the
                     topics covered by the notebook (facility size, economic trends, geographic
                     distribution, pollutant releases, pollution prevention issues, and applicable
                     regulations) vary depending on the type of inorganic chemical manufacturing
                     process.  The large number of different industrial processes used in the
                     inorganics industry could not all be covered in this notebook. As a result,
                     most sections of this notebook  describe the  entire inorganic  chemical
                     industry as a whole. These sections are usually augmented with information
                     specific to the largest single industrial process within the industry: chlorine
September 1995
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Sector Notebook Project
Inorganic Chemicals
                     and caustic soda production (SIC 2812).  Section III, Industrial Process
                     Description, rather than attempting to describe every inorganic chemical
                     manufacturing process, deals solely with the production of chlorine and
                     caustic soda.

II.B. Characterization of the Inorganic Chemical Industry

       II.B.l. Product Characterization

       Inorganic Chemicals Industry

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

       Chlor-alkali Sector

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

                     The majority of domestic chlorine production (70 percent) is used in the
                     manufacturing of organic  chemicals including: vinyl chloride monomer,
                     ethylene dichloride, glycerine, glycols, chlorinated solvents, and chlorinated
                     methanes.  Vinyl chloride, which is used in the production of polyvinyl
                     chloride (PVC) and many other organic chemicals, accounts for about 38
                     percent of the total domestic chlorine production.  The pulp and paper
                     industry consumes approximately 15 percent of U.S. chlorine production, and
                     about  eight percent is used in the manufacturing of other  inorganic
                     chemicals. Other major uses are disinfection treatment  of water, and the
                     production of hypochlorites.   More than  two-thirds of all chlorine is
September 1995
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Sector Notebook Project
Inorganic Chemicals
                     consumed in the same manufacturing plant in the production of chemical
                     intermediates.5

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

       II.B.2. Industry Size and Geographic Distribution

       Inorganic Chemical Industry

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

Employees
per Facility
1-9
10-19
20-49
50-249
250-999
1,000->2,500
Total
Inorganic Chemicals
Number
of Facilities
682
212
253
221
51
10
1,429
Percentage
of Facilities
48%
15%
18%
15%
3%
1%
100%
Chlor-alkali
Number of
Facilities
12
6
3
23
6
1
51
Percentage
of Facilities
24%
12%
6%
44%
12%
2%
100%
Source: Bureau of the Census, 1992 Census of Manufacturers.
                     Inorganic chemical facilities are typically located near consumers and to a
                     lesser extent raw materials.  The largest use of inorganic chemicals is in
                     industrial processes for the manufacture of chemicals and nonchemical
                     products; therefore, facilities are concentrated in the heavy industrial regions
                     along the Gulf Coast, both east and west coasts, and the Great Lakes region.
                     Since a large portion of inorganic chemicals produced are used by  the
                     organic chemicals manufacturing industry, the geographical  distribution of
                     inorganic facilities is  very similar to  that of organic chemicals facilities
                     (Exhibit 2).
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                   Exhibit 2: Inorganic Chemicals Facilities Distribution
                                                    0 100 200 300 400
(Source: U.S. EPA Toxic Release Inventory Database, 1993)

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

                     The distribution of the chlor-alkali sector differs from that of the inorganic
                     chemicals industry as a whole.  Since chlorine  and caustic soda are co-
                     products produced in almost equal amounts, the  distribution of the caustic
                     soda manufacturing industry is essentially the same  as  the  chlorine
                     manufacturing  industry.   Chlorine  is  difficult  to  store  and transport
                     economically; therefore, chlorine and caustic soda are produced near the
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                    chlorine consumers which are primarily chemical manufacturers and pulping
                    operations.  Consequently, chlor-alkali facilities are concentrated near the
                    chemical industries along the Gulf Coast, followed by the Great Lakes region
                    as shown in the table below. Other important areas are in the vicinity of the
                    pulp mills of the Southeast and Northwest (Exhibit 3). In 1989, almost half
                    of the chlorine plants in the U.S. (72 percent of domestic chlorine production)
                    were located  along the Gulf Coast.   Two states,  Louisiana and Texas,
                    accounted for two-thirds of the domestic chlorine production.9
Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast,
Southeast, Northwest, and Great Lakes Region
State
Louisiana
Texas
New York
Alabama
Washington
West Virginia
Georgia
Tennessee
Other States (14)
U.S. Total
Number of
Chlorine Plants
9
5
4
5
4
2
3
1
19
52
Annual Capacity
(thousand tons
per year)
44068
3,314
652
592
503
392
246
230
1,139
11,136
Percent of
Total U.S.
Operating
Capacity
37%
30%
6%
5%
5%
3%
2%
2%
10%
100%
Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed. Vol. 1, 1993.
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                     Ward's Business Directory of U.S. Private Companies, produced by Gale
                     Research Inc., compiles financial data on U.S. companies including those
                     operating within the inorganic chemicals manufacturing industry.  Ward's
                     ranks U.S. companies, whether they are a parent company, subsidiary or
                     division, by sales volume within the 4-digit SIC codes that they have been
                     assigned as their primary activity.  Exhibit 4 lists the top ten inorganic
                     chemical manufacturing companies in the U.S. Readers should note that: 1)
                     Companies are  assigned a 4-digit SIC that most closely resembles their
                     principal  industry; and  2)  Sales figures  include  total  company sales,
                     including sales derived from subsidiaries and operations not related to the
                     manufacture of inorganic chemicals. Additional sources of company specific
                     financial information include Standard & Poor's Stock Report Services, Dunn
                     & Bradstreet's Million Dollar  Directory, Moody's Manuals, and annual
                     reports.
Exhibit 4: Top U.S. Companies with
Inorganic Chemical Manufacturing Operations
Rank*
1
2
3
4
5
6
7
8
9
10
Company6
Dow Chemical Co. - Midland, MI
Hanson Industries, Inc. - Iselin, NJ
WR Grace and Co. - Boca Raton, FL
Occidental Chemical Corp. - Dallas, TX
BOC Group, Inc. - Murray Hill, NJ
FMC Corp. - Chicago, IL
Eastman Kadak Co. - Kingsport, TN
Air Products and Chemicals, Inc. - Allentown, PA
ARCO Chemical Co. - Newtown Square, PA
Ethyl Corp. - Richmond, VA
1993 Sales
(millions of dollars)
18,800
6,092
6,049
4,600
4,500
3,899
3,740
2,931
2,837
2,575
Note: a When Ward's Business Directory listed both a parent and subsidiary in the top ten,
only the parent company is presented above to avoid double counting sales volumes.
Not all sales can be attributed to the companies' inorganic chemical manufacturing
operations.
b Companies shown listed SICs 2812, 2813, 2816 and 2819 as primary activities.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
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       H.B.3. Economic Trends
       Inorganic Chemicals Industry
                    The Bureau of the Census estimated that there were 1,429 facilities in the
                    inorganic chemical industry in 1992. The industry employed 103,000 people
                    and had a total value of shipments of $27.4 billion. The total value of
                    shipments for the inorganic chemicals industry increased about one percent
                    per year between 1992 and 1994.  These values do not include inorganic
                    chemicals manufactured for captive use within a facility nor the value of
                    other non-industrial inorganic chemical products manufactured by the same
                    facility.   It does, however,  include intra-company  transfers  which are
                    significant in this industry. The inorganic chemical industry's growth rate is
                    expected to continue to increase with the growth of the economy. The U.S.
                    is a net exporter of inorganic chemicals with most  exports shipped to the
                    European Community (EC) followed by Canada and Mexico. This positive
                    trade balance increased significantly in 1993 to $1.7 billion and is expected
                    to continue as the European economy improves.  By comparison, the 1992
                    Census of Manufactures  for Industrial  Organic Chemicals reports a 1992
                    value  of shipments  for  organic chemicals of $64.5  billion and a total
                    employment of 125,100 people. The 1992 value of shipments for the entire
                    chemical industry (SIC 28) totaled $292.3 billion with an employment of
                    850,000 people.10

                    Because inorganic chemicals are used in the manufacturing of many
                    products, the industry tends to grow at the same rate as overall industrial
                    production, hi the late 1980s, the industry experienced high growth rates
                    and, in the early 1990s, the industry saw little real growth in output, as a
                    reflection of the U.S. economy's recession. The industry has historically had
                    low profit margins which, in recent years, have decreased further with
                    increasing pollution abatement costs.11
       Chlor-alkali Sector
                    The Bureau of the Census data for 1992 shows that there were 51 facilities
                    within the inorganic chemicals industry that manufactured alkalies and
                    chlorine. These chlor-alkali facilities employed 8,000 people and had a total
                    value of shipments of $2.8 billion. This was an increase of 1.7 percent from
                    1991. The chlor-alkali industry as a whole is expected to grow at its past rate
                    of 1.5 times gross  domestic product (GDP) growth through the 1990s.
                    Because chlorine  and caustic soda are  electrolysis co-products, the
                    production of one product can depend on the demand of the other product.
                    The market pull has switched  several  times between caustic soda and
                    chlorine in the past  few decades. Presently, chlorine demand is controlling
                    production; consequently, there is a current  excess availability of caustic
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                    soda in the U.S. This excess material is typically exported to fill a significant
                    demand outside the U.S. The consumption of caustic soda is growing faster
                    than the consumption of chlorine,  however, and domestic  caustic  soda
                    demand is expected to control production in the coming years.12

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

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

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

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

III.A. Industrial Processes in the Inorganic Chemical Industry

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

                                  2 NaCl + 2 H2O -> 2 NaOH + C12 + H2

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

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

                     •      Mercury Cell Process
                     •      Diaphragm Cell Process
                     •      Membrane Cell Process

                     Virtually all chlorine produced in the U.S. is manufactured by one of these
                     three electrolysis processes. Each electrolytic cell consists of an anode and
                     cathode  in contact with the brine solution.  Exhibit 5 shows the basic
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                    elements,  inputs  and outputs of each type  of electrolytic cell.  The
                    distinguishing feature of each cell type is the method employed to separate
                    and  prevent  the  mixing  of the  chlorine  gas  and sodium hydroxide.
                    Consequently, each process produces a different purity of chlorine gas and
                    a different concentration of caustic soda.  Exhibit 6 is a summary of the
                    major  differences between  each  cell type.   In 1988, diaphragm cells
                    accounted for 76 percent of all domestic chlorine production, followed by
                    mercury cells with 17 percent, and membrane cells with five percent. The
                    industry is moving away from mercury and diaphragm cells and is moving
                    towards the use of membrane cells. Membrane cells are a relatively recent
                    development which have fewer adverse effects on the environment and
                    produce a higher quality product at a lower cost than the other methods.15'16
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                          Inorganic Chemicals
                             Exhibit 5: Chlorine Electrolysis Cells
Saturated
brine
Depleted
brine
Mercury in
Saturated
brine
Saturated
brine
Depleted
brine
Chlorine
1 Anode (+) 1 |
1. • « 4 j
I 	 | 	 I 	 It 	 i 	 I 	 Ut — I — i — .1
Ions (Na +)
III Cathode (-)
Na-Hg amalgam
Mercury
Cell
	 T | 	 ^ Amalgam
	 to decomposer
Chlorine Hydrogen

— ^==— ions(Na+)| ~
I i
1
unionae Hydroxyl I
ions (CI -) ions (OH -)|
Anode Brine Cathode
W * (-) ,
Diaphragm
Cell

' Dilute caustic soda
Diaphragm and sodjum chloride
Chlorine Hydrogen
T t Water
-plL, - Sodium rHi_
: _~ 	 — ions (Na '{ _~
c •
Chloride >
ions (CI -) OH -
Anode * ~* •*"" Cathode
. +) H .
Ion-exchange membrane ca|
Membrane
Cell
ncentrated
jstic soda
              (Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.)
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Exhibit 6: Main Characteristics of the Different Electrolysis Processes
Component
Cathode
Diaphragm/
Membrane
Anode
Cathode
Product
Decomposer/
Evaporator
Product
Electricity
Consumption
Mercury Cell
Mercury flowing
over steel
None
Titanium with RuO2
or TiO2 coating
(DSA anode)
Sodium amalgam
50% NaOH and H2
from decomposer
3, 3 00 kWh per ton
C12
Diaphragm Cell
Steel or steel coated
with activated nickel
Asbestos or polymer
modified asbestos
Titanium with RuO2
or TiO2 coating
(DSA anode)
10-12% NaOH with
15-17%NaCland
H2
50% NaOH with 1%
NaCl and solid salt
from evaporator
2,750 kWh per ton
C12
Membrane Cell
Steel or nickel with a
nickel based
catalytic coating
Ion-exchange
membrane
Titanium with RuO2
or TiO2 coating
(DSA anode)
30-33% NaOH and
H2
50% NaOH with
very little salt
2,1 00-2,450 kWh per
ton NaOH
Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.
       IILA.1. Mercury Cell
                    The mercury cell process consists of slightly inclined steel troughs through
                    which a thin layer of mercury (about three  mm) flows over the bottom
                    (Exhibit 7).  The cells are operated at 75 to 85  °C and atmospheric pressure.
                    The mercury layer serves as the cathode for  the process and the saturated
                    brine solution (25.5 percent NaCl by weight) flows through the troughs
                    above the mercury. The anodes are usually incorporated into the cell covers
                    and are suspended horizontally in the brine solution.   The height of the
                    anodes within the brine is adjusted to the optimal height either manually or
                    through an automatic computer controlled system.17

                    Electrolytic cell anodes were made of graphite until the late 1960s when
                    anodes of titanium coated with ruthenium oxide (RuOz) and titanium oxide
                    (TiOi)  were developed.   The RuO2  and  TiO2  anodes,  termed DSA
                    (dimensionally stable) anodes, are more stable than the graphite anodes (i.e.,
                    they do not need to be  replaced as frequently)  and are more energy
                    efficient.18
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                           Exhibit 7: Mercury Electrolysis Cell and Flow Diagram
                   pure brine
                  anode
                              depleted brine
                                                             graphite contact
                       NaCI
                            chemii
                                icals
                                        chlorine
NaCI
solu-
tion
-n
-
brine
purificat-
ion
»-
i
1
electrolysis ;
•f Hg
precipitated sludge
P

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

       III.A.2. Diaphragm Cell

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

                    Two basic types of diaphragm cells are in use today.  The first, monopolar
                    cells, have an electrode arrangement in which the anodes and cathodes are
                    arranged in parallel. As a result of this configuration, all cells have the same
                    voltage of about three to four volts; up to 200 cells can be constructed in one
                    circuit. The second basic type of diaphragm cell is the bipolar cell, in which
                    the anode of one cell is directly connected to the cathode of the next cell unit.
                    This type of arrangement minimizes voltage loss between cells; however,
                    since the total voltage across the entire set of cells is the sum of the
                    individual cell voltages, the number  of cells per unit is  limited.   To
                    compensate for the reduced anode and cathode surface area in the bipolar
                    configuration, bipolar units tend to be much larger than monopolar units.
                    Production of chlorine and caustic soda by the diaphragm process is split
                    approximately equally between monopolar and bipolar systems.23
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                           Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram
                                        NaCI pure brine
                                                          CHLORINE
                                                                            NaOH
                                                                            NaCI
                     NaCI
                     solution
i                        chemicals
                          I
                    precipitation sludge
                                        recovered salt
              (Source: Industrial Inorganic Chemistry, Buchner, et al., 1989)

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

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

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

       III.A.3. Membrane Cell

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

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

                    The  most critical components of the  membrane cells are the membranes
                    themselves.  The membranes must remain stable while being exposed to
                    chlorine on one side and a strong caustic solution on the other. Furthermore,
                    the membranes must have low electrical resistance, and allow the transport
                    of sodium ions  and not chloride ions  and  reinforcing fabric,  and a
                    perfluorocarboxlate polymer all bonded together.
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                             Exhibit 9: Typical Membrane Electrolysis Cell
                                                                          H20
         (Source: Industrial Inorganic Chemistry, Bilchner, et al, 1989.)

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

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

       Brine Purification
                     Approximately 70 percent of the salt used in chlorine gas production is
                     extracted from natural salt  deposits; the remainder is evaporated from
                     seawater.  Salt from natural deposits is either mined in solid form or is
                     leached from the subsurface. Leaching involves the injection of freshwater
                     into subterranean salt deposits and  pumping out  brine solution.  Brine
                     production from seawater typically occurs by solar evaporation in a series of
                     ponds to concentrate the seawater, precipitate out impurities, and precipitate
                     out solid sodium chloride. Regardless of the method used to obtain the salt,
                     it will contain impurities that must be removed  before being used in the
                     electrolysis process.  Impurities primarily consist of calcium, magnesium,
                     barium, iron,  aluminum, sulfates,  and trace metals.  Impurities  can
                     significantly reduce the efficiency of the electrolytic cells, by precipitating
                     out and subsequently blocking a diaphragm or damaging a membrane
                     depending on the process used.  Certain trace metals, such as vanadium,
                     reduce the efficiency of mercury cells and cause the production of potentially
                     dangerous amounts of hydrogen gas.  Removal of impurities accounts for a
                     significant portion of the overall costs of chlor-alkali production, especially
                     in the membrane process.31

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

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

       Chlorine Processing

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

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

                     Chlorine liquefaction processes typically liquefy only about 90-95 percent
                     of the chlorine. This gas and the chlorine gas left inside tank truck tanks, rail
                     car tanks, or barges after removal of liquid chlorine is impure and must be
                     recovered in a chlorine recovery unit. The gas is compressed and cooled
                     using cold water followed by Freon.  The chilled gas is fed  up through a
                     packed column in which carbon tetrachloride flows downward absorbing the
                     chlorine. The chlorine-rich carbon tetrachloride is fed to a chlorine stripper
                     in which the chlorine and carbon tetrachloride separate as they are heated.
                     The chlorine gas is cooled and scrubbed of carbon tetrachloride using liquid
                     chlorine and the resulting pure chlorine is sent to the chlorine liquefaction
                     system.
                           36
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       Caustic Soda Processing
                    Caustic soda solution generated from chlor-alkali processes is typically
                    processed to remove impurities and to concentrate it to either a 50 percent or
                    73 percent water-based solution or to anhydrous caustic soda.  The caustic
                    soda from the mercury and membrane processes is relatively pure. Product
                    from the mercury process requires only filtration to remove mercury droplets.
                    The evaporators used to concentrate the  caustic soda  solution in the
                    diaphragm process are typically multi-stage forced circulation evaporators.
                    The evaporators have salt settling  systems to remove precipitated salt.
                    Sodium borohydride is often added  to reduce corrosion of the equipment.
                    Evaporators for the membrane process are usually much simpler than those
                    for the diaphragm process because the salt concentration in the membrane
                    cell caustic solution is very low.37

       Hydrogen Processing

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

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

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

                    Pollutant outputs have decreased in recent years as the industry moves away
                    from  the mercury and diaphragm cell processes to the more efficient (in
                    terms of material and energy inputs and outputs) membrane cell process. In
                    addition, improved cell part materials have  been developed, such as DSA
                    anodes and Modified Diaphragms, which are more stable and create less
                    undesirable byproducts.
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                     Inputs and pollutant outputs from the auxiliary processes such as brine
                     purification,  chlorine processing,  caustic soda processing, and hydrogen
                     processing are described in Section III.B.4.

       HI.B.1. Mercury Cell

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

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

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

       III.B.2. Diaphragm Cell

                     Wastewater streams from the diaphragm cell process originate from the
                     barometric condenser during caustic soda evaporation, chlorine drying, and
                     from purification of salt recovered from the evaporators.  These wastewaters
                     and their treatment are described below in Section III.B.4.  The use of lead
                     and graphite anodes and asbestos diaphragms generates lead, asbestos, and
                     chlorinated hydrocarbons in the caustic soda and chlorine processing waste
                     streams.   Lead salts and  chlorinated hydrocarbons are generated from
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                     corrosion of the anodes, and asbestos particles are formed by the degradation
                     of the diaphragm with use.   Over the past  twenty years, all but a few
                     diaphragm cell facilities have switched from the use of lead  and graphite
                     anodes with asbestos diaphragms to DSA anodes and Modified Diaphragms
                     which resist corrosion and degradation. The lead, asbestos, and chlorinated
                     hydrocarbon contaminants are, therefore, no longer discharged in significant
                     amounts from most diaphragm cell chlor-alkali facilities.  Those facilities
                     that discharged caustic processing wastewater streams to on-site lagoons
                     may, however, still have significant levels of these contaminants on-site.42

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

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

       IH.B.3. Membrane Cell

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

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

                     Solid waste generated in the diaphragm process consists primarily of solids
                     generated during  brine purification and used cell parts  which include
                     membranes, cathodes and DSA anodes.  The used membranes are typically
                     returned to the supplier and the used cathodes and DSA  anodes are shipped
                     off-site for recovery of their titanium content.47
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       III.B.4. Auxiliary Processes

       Brine Purification
                     Brine solutions are typically treated with a number of chemicals to remove
                     impurities prior to input to the electrolytic cells. In the case of mercury and
                     membrane cell systems, the brine is first acidified with HC1 to remove
                     dissolved chlorine. Next, sodium hydroxide and sodium carbonate are added
                     to  precipitate calcium  and magnesium  ions  as  calcium carbonate and
                     magnesium hydroxide. Barium carbonate is then added to remove sulfates
                     which precipitate out as barium sulfate. The precipitants are removed from
                     the brine solution by settling  and filtration.  Pollutant outputs from this
                     process include fugitive chlorine emissions and brine muds.48

                     Brine muds are one of the largest waste streams of the chlor-alkali industry.
                     On average, about 30 kilograms (kg) of brine mud are generated for every
                     1,000 kg of chlorine produced.  The volume of mud will vary, however,
                     depending on the purity  of the salt used.  Some facilities use pre-purified
                     (i.e., chemical grade) evaporated salts which will produce only 0.7 to 6.0 kg
                     of  brine mud per 1,000 kg of chlorine  produced.  Brine mud  typically
                     contains magnesium hydroxide, calcium carbonate, and,  in most cases,
                     barium sulfate. Mercury cell brine muds  usually contain mercury either in
                     the elemental form or as the  complex ion, mercuric chloride  (HgCl42~).
                     Mercury- containing brine muds are typically disposed of in a RCRA Subtitle
                     C landfill after treatment with sodium sulfide which converts the mercury to
                     an  insoluble sulfide.49

                     Brine muds are usually segregated from other process wastes and stored in
                     lagoons on-site.  When the lagoons become filled, the brine mud is either
                     dredged and landfilled  off-site, or drained and covered over.  Some plants
                     that use brine solution leached from subterranean deposits inject brine muds
                     into the salt cavities that are no longer being used.50
       Chlorine Processing
                    The chlorine gas recovered from electrolytic cells is cooled to remove water
                    vapor. The condensed water is usually recycled as brine make-up although
                    some facilities combine this waste stream with other waterborne waste
                    streams prior to treatment.   The remaining water vapor is removed by
                    scrubbing the chlorine gas with concentrated sulfuric acid. The chlorine gas
                    is then compressed and cooled to form liquid chlorine. Between six kg and
                    35 kg of 79 percent sulfuric acid wastewater is generated per 1,000 kg of
                    chlorine produced. The majority of the spent sulfuric acid waste is shipped
                    off-site for refortification to concentrated sulfuric acid or for use in other
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                     processes. The remainder is used to control effluent pH and/or is discharged
                     to water or land disposed.51

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

       Caustic Soda Processing

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

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

       Hydrogen Processing

                     The hydrogen produced in all of the electrolytic processes contains small
                     amounts of water vapor, sodium hydroxide,  and salt which is removed
                     through cooling.  Condensed salt water and sodium hydroxide solution is
                     either recycled as brine make-up or treated with other waterborne waste
                     streams.  The hydrogen produced during the mercury cell process, however,
                     also contains small amounts of mercury which  must be removed prior to
                     liquefaction. Most of the entrained mercury is extracted by cooling the gas.
                     The condensed mercury is then  returned to the electrolytic  cells.  Some
                     facilities further purify the hydrogen gas of mercury using activated carbon
                     treatment. Spent activated carbon is typically shipped off-site as a hazardous
                     waste.54
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 III.C. Management of Chemicals In Wastestream
                     The Pollution Prevention Act of 1990 (PPA) requires facilities to report
                     information about the management of TPJ chemicals in waste and efforts
                     made to eliminate or reduce those quantities. These data have been collected
                     annually in Section 8 of the TPJ reporting Form R beginning with the 1991
                     reporting year. The data summarized below cover the years 1992-1995 and
                     is meant to provide a basic understanding of the quantities of waste handled
                     by the industry, the methods typically used to manage this waste, and recent
                     trends in these methods. TRI waste management data can be used to assess
                     trends in source reduction within individual industries and facilities, and for
                     specific TRI chemicals.  This information could then be used as a tool in
                     identifying opportunities for pollution prevention compliance assistance
                     activities.

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

                     Exhibit 10 shows that the inorganic chemicals industry managed about 1.7
                     trillion pounds of production-related waste (total quantity of TRI chemicals
                     in  the waste  from routine production operations)  in 1993  (column B).
                     Column C reveals that of this production-related waste, 15 percent was either
                     transferred off-site or released to the environment. Column C is calculated
                     by dividing the total TRI transfers and releases by the total quantity of
                     production-related waste. In other words, about 85 percent of the industry's
                     TRI wastes were managed on-site through recycling, energy recovery, or
                     treatment as shown in columns E, F and G, respectively.  The majority of
                     waste that is released or transferred off-site can be divided into portions that
                     are recycled off-site, recovered  for energy off-site, or treated off-site as
                     shown in columns H, I and J, respectively. The remaining portion of the
                     production related wastes (11  percent), shown in column D, is either released
                     to  the environment  through direct discharges to air, land, water, and
                     underground injection, or it is disposed off-site.
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Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry
(SIC 281) as Reported within TRI
A
Year
1992
1993
1994
1995
B
Quantity of
Production-
Related
Waste
(106 Ibs.)*
1,642
1,712
1,759
1,732
C
% Released
and
Transferred1"
16%
15%
—
—
D
% Released
and
Disposed0
Off-site
12%
11%
11%
10%
On-Site
E
%
Recycled
42%
45%
47%
48%
F
% Energy
Recovery
0%
0%
<1%
0%
G
%
Treated
42%
40%
39%
40%
Off-Site
H
%
Recycled
<1%
<1%
<1%
<1%
I
% Energy
Recovery
<1%
<1%
<1%
<1%
J
%
Treatec
3%
3%
3%
3%
" Within this industry sector, non-production related waste is < 1% of production related wastes for 1993.
b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related
wastes.
c Percentage of production related waste released to the environment and transferred off-site for disposal.
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TV. CHEMICAL RELEASE AND TRANSFER PROFILE
                     This section is designed to provide background information on the pollutant
                     releases that are reported by this industry. The best source of comparative
                     pollutant release information is the Toxic Release Inventory System (TRI).
                     Pursuant to the Emergency Planning and Community Right-to-Know Act,
                     TRI includes self-reported facility release and transfer data for over 600 toxic
                     chemicals. Facilities within SIC Codes 20-39 (manufacturing industries) that
                     have more than 10 employees, and that are above  weight-based reporting
                     thresholds are required to report TRI on-site releases and off-site transfers.
                     TRI is not specific to the chemical industry.  The information presented
                     within the sector notebooks is derived from the most recently available
                     (1993) TRI reporting year (which then included 316 chemicals), and focuses
                     primarily on the on-site releases reported by each sector.   Because TRI
                     requires consistent reporting regardless of sector, it is an excellent tool for
                     drawing comparisons across industries.

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

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

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

Definitions Associated With Section IV Data Tables

                    General Definitions

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

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

                    Data Table Column Heading Definitions

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

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

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

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

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

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

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

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

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

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

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

                     Transfers to Disposal -- are wastes taken to another facility for disposal
                     generally as a release  to land or as an injection underground.
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IV.A. EPA Toxic Release Inventory for the Inorganic Chemical Industry

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

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

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

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

                    Exhibits 11 and  12 present the number and volumes of chemicals released
                    and transferred by inorganic chemical facilities, respectively. The frequency
                    with which chemicals are reported by facilities  within a  sector is  one
                    indication of the diversity of operations and processes. Many of the TRI
September 1995
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 Sector Notebook Project
                           Inorganic Chemicals
                      chemicals are released or transferred by only a small number of facilities
                      which indicates a wide diversity of production processes, particularly for
                      specialty inorganics -- over 70 percent of the  110 chemicals reported are
                      released or transferred by fewer than 10 facilities.

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

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

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

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             Sector Notebook Project
                                       Inorganic Chemicals
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-------
Sector Notebook Project
                                                 Inorganic Chemicals
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September 1995
                              37
                                                          SIC 281

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Sector Notebook Project
                                 Inorganic Chemicals
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September 1995
           38
SIC 281

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Sector Notebook Project
                      Inorganic Chemicals

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September 1995
39
SIC 281

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Sector Notebook Project
                                                       Inorganic Chemicals
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September 1995
                                40
SIC 281

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Sector Notebook Project
                                         Inorganic Chemicals
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September 1995
                  41
SIC 281

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Sector Notebook Project
                          Inorganic Chemicals
                     The TRI database contains a detailed compilation of self-reported, facility-
                     specific chemical releases.  The top reporting facilities for this sector are
                     listed below. Facilities that have reported only the SIC codes covered under
                     this notebook appear on the first list. The second list contains additional
                     facilities that have reported the SIC code covered within this report, and one
                     or more SIC codes that are not within the scope of this notebook. Therefore,
                     the second list includes facilities that conduct multiple operations ~ some
                     that are under the scope of this notebook, and some that are not.  Currently,
                     the facility-level data do not allow pollutant releases to be broken apart by
                     industrial process.
Exhibit 13: Top 10 TRI Releasing
Inorganic Chemicals Facilities5
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Du Pont Delisle Plant - Pass Christian, MS
Du Pont Johnsonville Plant - New Johnsonville, TN
Cabot Corp. Cab-O-Sil Div. - Tuscola, IL
American Chrome & Chemicals Inc. - Corpus Christi, TX
Occidental Chemical Corp. - Castle Hayne, NC
Chemetals Inc. - New Johnsonville, TN
Kaiser Aluminum & Chemical Corp. - Mulberry, FL
Kerr-McGee Chemical Corp. - Henderson, NV
SCM Chemicals Americas Plant II - Ashtabula, OH
Louisiana Pigment Co. L.P. - Westlake, LA
Total TRI
Releases
in Pounds
58,875,734
51,215,700
13,926,440
12,113,360
6,705,795
5,684,893
4,876,348
2,333,175
2,238,400
1,465,753
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
b Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
September 1995
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                          Inorganic Chemicals
Exhibit 14: Top 10 TRI Releasing Facilities Reporting
Inorganic Chemical SIC Codes to TRT
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported in TRI
2819,2873,2874
2819, 2869
2819, 2874
2816
2816
2819,2823
2819,2869,2841,
2879
2819, 2869, 2865
2819,2873,2874
2812,2813,2869
Facility
IMC-Agrico Co., Faustina Plant - Saint James, LA
Cytec Industries, Inc., Fortier Plant - Westwego, LA
IMC-Agrico Co., Uncle Sam Plant - Uncle Sam, LA
Du Pont Delisle Plant - Pass Christian, MS
Du Pont Johnsonville Plant - New Johnsonville, TN
Courtaulds Fibers, Inc. - Axis, AL
Monsanto Co. - Alvin, TX
Sterling Chemicals, Inc. - Texas City, TX
Arcadian Fertilizer L.P. - Geismar, LA
Vulcan Chemicals - Wichita, KS
Total TRI
Releases in
Pounds
127,912,967
120,149,724
61,807,180
58,875,734
51,215,700
42,658,865
40,517,095
24,709,135
22,672,961
17,406,218.
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
IV.B. Summary of Selected Chemicals Released
                     The brief descriptions provided below were taken from the 1993  Toxics
                     Release Inventory Public Data Release (EPA, 1994), and the Hazardous
                     Substances Data Bank (HSDB), accessed via TOXNET.  TOXNET is a
                     computer system run by the National Library of Medicine.  It includes a
                     number of toxicological databases managed by EPA, the National Cancer
                     Institute, and the National Institute for Occupational Safety and Health-.d
                     HSDB contains  chemical-specific  information on manufacturing and use,
                     chemical  and physical  properties,  safety and handling,  toxicity and
                     biomedical  effects,  pharmacology,  environmental  fate  and  exposure
c Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.

d Databases included in TOXNET are:  CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EMICBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB
(Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects
of Chemical Substances), and TRI (Toxic Chemical Release Inventory).
September 1995
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                         Inorganic Chemicals
                    potential, exposure standards and regulations, monitoring and  analysis
                    methods, and additional references.  The information contained below is
                    based upon exposure assumptions that have been conducted using standard
                    scientific procedures.  The effects listed below must be taken in context of
                    these exposure assumptions that are  more fully explained within the full
                    chemical profiles in HSDB.  For more information on TOXNET, contact the
                    TOXNET help line at 800-231-3766.

                    Hydrochloric Acid (CAS: 7647-01-1)

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

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

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

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

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

                    Physical Properties.  Concentrated hydrochloric acid is highly corrosive.

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

                    Sources. Chrome pigments, chromates, chromic acid, chromium salts, and
                    other  inorganic chromium compounds are  some  of the larger volume
                    products of the inorganic chemicals industry.  Chrome is used as a plating
                    element for metal and plastics to prevent corrosion, and as a constituent of
                    certain steels and inorganic pigments.  Most chromium wastes released to the
September 1995
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                         Inorganic Chemicals
                    environment by the inorganic chemicals industry are land disposed in the
                    form of chromium containing sludges.

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

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

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

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

                    Carbonvl Suffide (CAS: 463-58-1)

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

                    Toxicity.  Exposure to low to moderate concentrations of carbonyl sulfide
                    causes eye and skin irritation and adverse central nervous system effects such
                    as giddiness, headache, vertigo, amnesia, confusion,  and unconsciousness.
                    If ingested, gastrointestinal effects  include profuse salivation,  nausea,
                    vomiting and diarrhea.  Moderate carbonyl sulfide poisoning  also causes
September 1995
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                         Inorganic Chemicals
                    rapid breathing  and heartbeat,  sweating, weakness, and muscle cramps.
                    Exposure to very high concentrations of carbonyl sulfide causes sudden
                    collapse, unconsciousness, and death from sudden respiratory  paralysis.
                    Recovery from sublethal  exposure is slow,  but generally complete.
                    Degradation products of carbonyl sulfide (especially hydrogen sulfide) can
                    result in toxic symptoms and death.

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

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

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

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

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

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

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

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

                     Ammonia (CAS: 7664-41-7)

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

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

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

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

                     Physical Properties. Ammonia is a corrosive and severely irritating gas
                     with a pungent odor.
September 1995
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                        Inorganic Chemicals
I V.C. Other Data Sources
                    In addition to chemicals covered under TRI, many other chemicals are
                    released.  For example, the  EPA Office  of Air Quality Planning and
                    Standards has compiled air pollutant emission factors for determining the
                    total air emissions  of priority pollutants  (e.g., VOCs,  SOX, NQ, CO,
                    particulates) from many chemical industry sources.

                    The EPA Office of Air's Aerometric Information Retrieval System (AIRS)
                    contains a wide range  of information related to stationary sources of air
                    pollution, including the emissions of a number of air pollutants which may
                    be of concern within a particular industry.  With the exception of volatile
                    organic compounds (VOCs), there is little overlap with the TRI chemicals
                    reported above. Exhibit 15 summarizes annual releases of carbon monoxide
                    (CO), nitrogen dioxide (NO2), particulate  matter of 10  microns or less
                    (PM10), total particulate (PT), sulfur dioxide (SO2) and volatile organic
                    compounds (VOCs).
September 1995
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                       Inorganic Chemicals
Exhibit 15: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood
Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc.
Plastics
Stone, Clay and
Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office
Equipment
Electronics and Other
Electrical Equipment
and Components
Motor Vehicles, Bodies,
Parts and Accessories
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35,579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
SO2
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,310
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
September 1995
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                         Inorganic Chemicals
IV.D. Comparison of Toxic Release Inventory Between Selected Industries

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

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

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 Sector Notebook Project
                        Inorganic Chemicals
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                       Inorganic Chemicals
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September 1995
52
SIC 281

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

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

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

                     Pollution prevention in the chemical industry in process specific. As such it
                     is difficult to generalize about the relative merits of different pollution
September 1995
53
SIC 281

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

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

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

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

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

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

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

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

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

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

                    Prevent leaks and spills. The elimination of sources of leaks and spills can
                    be a very cost effective pollution prevention opportunity.  Leaks and spills
                    can be prevented  by installing seamless  pumps  and other "leakless"
                    components,  maintaining  a preventative  maintenance  program,  and
                    maintaining a leak detection program.

                    Improve   inventory management  and  storage.    Good  inventory
                    management can reduce the generation of wastes by preventing materials
                    from exceeding their shelf life, preventing materials from being left over or
                    not needed, and reducing the likelihood of accidental releases of stored
                    material.  Designating a materials storage area, limiting traffic through the
                    area, and giving one person  the responsibility to maintain and distribute
                    materials can reduce materials use, and the contamination and dispersal of
                    materials.

                    Exhibit 18 summarizes the above pollution prevention opportunities and
                    provides additional examples provided by the  Chemical Manufacturers
                    Association.
September 1995
56
SIC 281

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Sector Notebook Project
                                                    Inorganic Chemicals
    Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities
            Area
         Potential Problem
         Possible Approach
  Byproducts
  Coproducts

  Quantity and Quality
  Uses and Outlets
• Process inefficiencies result in the
generation of undesired by-products
and co-products. Inefficiencies will
require larger volumes of raw materials
and result in additional secondary
products. Inefficiencies can also
increase fugitive emissions and wastes
generated through material handling.

• By-products and co-products are not
fully utilized, generating material or
waste that must be managed.
• Increase product yield to reduce by-
product and co-product generation and
raw material requirements.
• Identify uses and develop a sales
outlet. Collect information necessary
to firm up a purchase commitment
such as minimum quality criteria,
maximum impurity levels that can be
tolerated, and performance criteria.
  Catalysts

  Composition
  Preparation and Handling
• The presence of heavy metals in
catalysts can result in contaminated
process wastewater from catalyst
handling and separation. These wastes
may require special treatment and
disposal procedures or facilities.
Heavy metals can be inhibitory or toxic
to biological wastewater treatment
units. Sludge from wastewater
treatment units may be classified as
hazardous due to heavy metals content.
Heavy metals generally exhibit low
toxicity thresholds in aquatic
environments and may bioaccumulate.

• Emissions or effluents are generated
with catalyst activation or regeneration.
                             » Catalyst attrition and carry over
                              into product requires de-ashing
                              facilities which are a likely source of
                             wastewater and solid waste.
• Catalysts comprised of noble metals,
because of their cost, are generally
recycled by both onsite and offsite
reclaimers.
• Obtain catalyst in the active form.

• Provide in situ activation with
appropriate processing/activation
facilities.

• Develop a more robust catalyst or
support.
September 1995
                      57
                            SIC 281

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Sector Notebook Project
                                                    Inorganic Chemicals
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
         Potential Problem
         Possible Approach
  Catalysts (cont'd)

  Preparation and Handling
  (conf)
  Effectiveness
» Catalyst is spent and needs to be
replaced.
                             • Pyrophoric catalyst needs to be kept
                             wet, resulting in liquid contaminated
                             with metals.  ,

                             • Short catalyst life.
• Catalyzed reaction has by-product
formation, incomplete conversion and
less-than-perfect yield.
                             « Catalyzed reaction has by-product
                             formation, incomplete conversion and
                             less-than perfect yield.
• In situ regeneration eliminates
unloading/loading emissions and
effluents versus offsite regeneration or
disposal.

• Use a nonpryrophoric catalyst.
Minimize amount of water required to
handle and store safely.

• Study and identify catalyst
deactivation mechanisms. Avoid
conditions which promote thermal or
chemical deactivation. By extending
catalyst life, emissions and effluents
associated with catalyst handling and
regeneration can be reduced.

• Reduce catalyst consumption with a
more active form. A higher
concentration of active ingredient or
increased surface area can reduce
catalyst loadings.

• Use a more selective catalyst which
will reduce the yield of undesired by-
products.

• Improve reactor mixing/contacting to
increase catalyst effectiveness.

• Develop a thorough understanding of
reaction to allow optimization of
reactor design. Include in the
optimization, catalyst consumption and
by-product yield.
  Intermediate Products
  Quantity and Quality
• Intermediate reaction products or
chemical species, including trace levels
of toxic constituents, may contribute to
process waste under both normal and
upset conditions.

» Intermediates may contain toxic
constituents or have characteristics that
are harmful to the environment.
• Modify reaction sequence to reduce
amount or change composition of
intermediates.
                                                                   • Modify reaction sequence to change
                                                                   intermediate properties.
                                                                   • Use equipment design and process
                                                                   control to reduce releases.
September 1995
                      58
                            SIC 281

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

   Temperature
• High heat exchange tube
temperatures cause thermal
cracking/decomposition of many
chemicals. These lower molecular
weight by-products are a source of
"light ends" and fugitive emissions.
High localized temperature gives rise to
polymerization of reactive monomers,
resulting in "heavies" or "tars."  such
materials can foul heat exchange
equipment or plug fixed-bed reactors,
thereby requiring costly equipment
cleaning and production outage.
                             • Higher operating temperatures imply
                             "heat input" usually via combustion
                             which generates emissions.
                             • Heat sources such as furnaces and
                             boilers are a source of combustion
                             emissions.

                             • Vapor pressure increases with
                             increasing temperature. Loading/
                             unloading, tankage and fugitive
                             emissions generally increase with
                             increasing vapor pressure.
 • Select operating temperatures at or
 near ambient temperature whenever
 possible.

 • Use lower pressure steam to lower
 temperatures.

 • Use intermediate exchangers to
 avoid contact with furnace tubes and
 walls.

 • Use staged heating to minimize
 product degradation and unwanted side
 reactions.

 • Use a super heat of high-pressure
 steam in place of furnace.

 • Monitor exchanger fouling to
 correlate process conditions which
 increase fouling, avoid conditions
 which rapidly foul exchangers.

 » Use online tube cleaning
 technologies to keep tube surfaces
 clean to increase heat transfer.

 • Use scraped wall exchangers in
 viscous service.

 • Use falling film reboiler, pumped
 recirculation reboiler or high-flux
 tubes.

 • Explore heat integration
 opportunities (e.g., use waste heat to
 preheat materials and reduce the
 amount of combustion required.)

 • Use thermocompressor to upgrade
 low-pressure steam to avoid the need
 for additional boilers and furnaces.

 • If possible, cool materials before
sending to storage.

 • Use hot process streams to reheat
feeds.
September 1995
                     59
                            SIC 281

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

  Temperature (cont'd)
  Pressure
  Corrosive Environment
   Batch vs. Continuous
   Operations
• Water solubility of most chemicals
increases with increasing temperature.

» Fugitive emissions from equipment.
» Seal leakage potential due to pressure
differential.

• Gas solubility increases with higher
pressures.


• Material contamination occurs from
corrosion products. Equipment failures
result in spills, leaks, and increased
maintenance costs.
• Increased waste generation due to
addition of corrosion inhibitors or
neutralization.

• Vent gas lost during batch fill.
                             • Waste generated by cleaning/purging
                             of process equipment between
                             production batches.
• Add vent condensers to recover
vapors in storage tanks or process.

• Add closed dome loading with vapor
recovery condensers.

• Use lower temperature (vacuum
processing).

• Equipment operating in vacuum
service is not a source of fugitives;
however, leaks into the process require
control when system is degassed.

• Minimize operating pressure.
• Determine whether gases can be
recovered, compressed, and reused or
require controls.

• Improve metallurgy or provide
coating or lining.

• Neutralize corrosivity of materials
contacting equipment.

• Use corrosion inhibitors.

• Improve metallurgy or provide
coating or lining.

• Improve metallurgy or provide
coating or lining or operate in a less
corrosive environment.

•Equalize reactor and storage tank
vent lines.

"Recover vapors through condenser,
adsorber, etc.

• Use materials with low viscosity.
Minimize equipment roughness.
 September 1995
                      60
                            SIC 281

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

  Batch vs. Continuous
  Operations (cont'd)
  Process Operation/Design
                             » Process inefficiencies lower yield and
                             increase emissions.
• Continuous process fugitive
emissions and waste increase over time
due to equipment failure through a lack
of maintenance between turnarounds.

• Numerous processing steps create
wastes and opportunities for errors.
                             • Nonreactant materials (solvents,
                             absorbents, etc.) create wastes. Each
                             chemical (including water) employed
                             within the process introduces additional
                             potential waste sources; the
                             composition generated wastes also
                             tends to become more complex.

                             • High conversion with low yield
                             results in wastes.
• Optimize product manufacturing
sequence to minimize washing
operations and cross-contamination of
subsequent batches.

• Sequence addition of reactants and
reagents to optimize yields and lower
emissions.

•Design facility to readily allow
maintenance so as to avoid unexpected
equipment failure and resultant
release.

• Keep it simple. Make sure all
operations are necessary. More
operations and complexity only tend to
increase potential emission and waste
sources.

• Evaluate unit operation or
technologies (e.g., separation) that do
not require the addition of solvents or
other nonreactant chemicals.
                                      • Recycle operations generally
                                      improve overall use of raw materials
                                      and chemicals, thereby increasing the
                                      yield of desired products while at the
                                      same time reducing the generation of
                                      wastes. A case-in-point is to operate at
                                      a lower conversion per reaction cycle
                                      by reducing catalyst consumption,
                                      temperature, or residence time. Many
                                      times, this can result in a higher
                                      selectivity to desired products. The
                                      net effect upon recycle of unreacted
                                      reagents is an increase in product
                                      yield, while at the same time reducing
                                      the quantities of spent catalyst and less
                                      desirable by-products.
September 1995
                     61
                            SIC 281

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

  Process Operation/Design
• Non-regenerative treatment systems
result in increased waste versus
regenerative systems.
• Regenerative fixed bed treating or
desiccant operation (e.g., aluminum
oxide, silica, activated carbon,
molecular sieves, etc.) will generate
less quantities of solid or liquid waste
than nonregenerative units (e.g.,
calcium chloride or activated clay).
With regenerative units though,
emissions during bed activation and
regeneration can be significant.
Further, side reactions during
activation/regeneration can give rise to
problematic pollutants.
  Product

  Process Chemistry
  Product Formulation
» Insufficient R&D into alternative
reaction pathways may miss pollution
opportunities such as reducing waste or
eliminating a hazardous constituent.
• Product based on end-use
performance may have undesirable
environmental impacts or use raw
materials or components that generate
excessive or hazardous wastes.
• R&D during process conception and
laboratory studies should thoroughly
investigate alternatives in process
chemistry that affect pollution
prevention.

• Reformulate products by substituting
different material or using a mixture of
individual chemicals that meet end-use
performance specifications.
  Raw Materials

  Purity
• Impurities may produce unwanted by-
products and waste. Toxic impurities,
even in trace amounts, can make a
waste hazardous and therefore subject
to strict and costly regulation.
                             • Excessive impurities may require
                             more processing and equipment to meet
                             product specifications, increasing costs
                             and potential for fugitive emissions,
                             leaks, and spills.
• Use higher purity materials.

• Purify materials before use and reuse
if practical.

• Use inhibitors to prevent side
reactions.

• Achieve balance between feed
purity, processing steps, product
quality, and waste generation.
 September 1995
                      62
                             SIC 281

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Sector Notebook Project
                                                    Inorganic Chemicals
     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
         Potential Problem
                                                                            Possible Approach
  Raw Materials (cont'd)

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

• Impurities in clean air can increase
inert purges.

• Impurities may poison catalyst
prematurely resulting in increased
wastes due to yield loss and more
frequent catalyst replacement.

• Higher vapor pressures increase
fugitive emissions in material handling
and storage.

• High vapor pressure with low odor
threshold materials can cause nuisance
odors.

• Toxic or nonbiodegradable materials
that are water soluble may affect
wastewater treatment operation,
efficiency, and cost.

• Higher solubility may increase
potential for surface and groundwater
contamination and may require more
careful spill prevention, containment,
and cleanup (SPCC) plans.

• Higher solubility may increase
potential for storm water contamination
in open areas.
                             • Process wastewater associated with
                             water washing or hydrocarbon/water
                             phase separation will be impacted by
                             containment solubility in water.
                             Appropriate wastewater treatment will
                             be impacted.
• Specify a purity no greater than what
the process needs.
                                                                   •Use pure oxygen.
                                                                    •Install guard beds to protect catalysts.
• Use material with lower vapor
pressure.
                                                                   • Use materials with lower vapor
                                                                   pressure and higher odor threshold.
• Use less toxic or more biodegradable
materials.
                                                                     Use less soluble materials.
• Use less soluble materials.

• Prevent direct contact with storm
water by diking or covering areas.

• Minimize water usage.

• Reuse wash water.

• Determine optimum process
conditions for phase separation.

• Evaluate alternative separation
technologies (coalescers, membranes,
distillation, etc.)
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     Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
            Area
         Potential Problem
         Possible Approach
  Raw Materials (cont'd)

  Toxicily
  Regulatory
  Form of Supply
  Handling and Storage
« Community and worker safety and
health concerns result from routine and
nonroutine emissions. Emissions
sources include vents, equipment leaks,
wastewater emissions, emergency
pressure relief, etc.
                             • Surges or higher than normal
                             continuous levels of toxic materials can
                             shock or miss wastewater biological
                             treatment systems resulting in possible
                             fines and possible toxicity in the
                             receiving water.
» Hazardous or toxic materials are
stringently regulated. They may
require enhanced control and
monitoring; increased compliance
issues and paperwork for permits and
record keeping; stricter control for
handling, shipping, and disposal; higher
sampling and analytical costs; and
increased health and safety costs.

• Small containers increase shipping
frequency which increases chances of
material releases and waste residues
from shipping containers (including
wash waters).
" Nonreturnable containers may
increase waste.

• Physical state (solid, liquid, gaseous)
may raise unique environmental, safely,
and health issues with unloading
operations and transfer to process
equipment.
• Use less toxic materials.

• Reduce exposure through equipment
design and process control. Use
systems which are passive for
emergency containment of toxic
releases.

• Use less toxic material.

» Reduce spills, leaks, and upset
conditions through equipment and
process control.

• Consider effect of chemicals on
biological treatment; provide unit
pretreatment or diversion capacity to
remove toxicity.

• Install surge capacity for flow and
concentration equalization.

• Use materials which are less toxic or
hazardous.

• Use better equipment and process
design to minimize or control releases;
in some cases, meeting certain
regulatory criteria will exempt a
system from permitting or other
regulatory requirements.

• Use bulk supply, ship by pipeline, or
use "jumbo" drums or sacks.

• In some cases, product may be
shipped out in the same containers the
material supply was shipped in without
washing.

• Use returnable shipping containers
or drums.

• Use equipment and controls
appropriate to the type of materials to
control releases.
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Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.
Area
Raw Materials (cont'd)
Handling and Storage
(cont'd)
Waste Streams
Quantity and Quality


Composition

Properties
Disposal
Potential Problem

• Large inventories can lead to spills,
inherent safety issues and material
expiration.

• Characteristics and sources of waste
streams are unknown.
• Wastes are generated as part of the
process.

• Hazardous or toxic constituents are
found in waste streams. Examples are:
sulfides, heavy metals, halogenated
hydrocarbons, and polynuclear
aromatics.

• Environmental fate and waste
properties are not known or understood.
• Ability to treat and manage hazardous
and toxic waste unknown or limited.
Possible Approach

• Minimize inventory by utilizing just-
in-time delivery.

• Document sources and quantities of
waste streams prior to pollution
prevention assessment.
• Determine what changes in process
conditions would lower waste
generation of toxicity.
• Determine if wastes can be recycled
back into the process.
• Evaluate whether different process
conditions, routes, or reagent
chemicals (e.g., solvent catalysts) can
be substituted or changed to reduce or
eliminate hazardous or toxic
compounds.
• Evaluate waste characteristics using
the following type properties:
corrosivity, ignitability, reactivity,
BTU content (energy recovery),
biodegradability, aquatic toxicity, and
bioaccumulation potential of the waste
and of its degradable products, and
whether it is a solid, liquid, or gas.
• Consider and evaluate all onsite and
offsite recycle, reuse, treatment, and
disposal options available. Determine
availability of facilities to treat or
manage wastes generated.
Source: Chemical Manufacturers Association. Designing Pollution Prevention into the Process, Research, Development and
Engineering.
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                       Inorganic Chemicals
Exhibit 19: Modifications to Equipment Can Also Prevent Pollution


Equipment
Compressors,
blowers, fans









Concrete pads,
floors, sumps




Controls













Distillation







Potential
Environment Problem
• Shaft seal leaks
Piston rod seal leaks
Vent streams








• Leaks to groundwater





• Shutdowns and Start-ups
generate waste and
releases











» Impurities remain in
process streams





Possible Approach
Design
Related
• Seal-less designs
(diaphragmatic, hermetic or
magnetics)
• Design for low emissions
(internal balancing, double
inlet, gland eductors)
• Shaft seal designs (carbon
rings, double mechanical
seals, buffered seals)
• Double seal with barrier
fluid vented to control device
« Water stops

• Embedded metal plates
• Epoxy sealing

• Other impervious sealing
• Improve on-line controls

• On-line instrumentation

• Automatic start-up and
shutdown


• On-line vibration analysis

• Use "consensus" systems
(e.g., shutdown trip requires
two out of three affirmative
responses)
• Increase reflux ratio

• Add section to column

• Column intervals

• Change feed tray
Operational
Related
• Preventive maintenance
program









• Reduce unnecessary
purges, transfers, and
sampling

• Use drip pans where
necessary
• Continuous versus batch

• Optimize on-line run
time

• Optimize shutdown
interlock inspection
frequency

• Identify safety and
environment critical
instruments and equipment


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

• Preheat column feed

• Increase vapor line size to
lower pressure drop

• Use reboilers or inert gas
stripping agents
• Clean column to reduce
fouling
                                                      • Use higher temperature
                                                      steam
 General
 manufacturing
 equipment areas
 | Contaminated rainwater
                   • Contaminated sprinkler
                   and fire water
                   • Leaks and emissions
                   during cleaning
• Provide roof over process
facilities

» Segregate process sewer
from storm sewer (diking)

» Hard-pipe process streams
to process sewer

• Seal floors

• Drain to sump

• Route to waste treatment

• Design for cleaning

• Design for minimum
rinsing

• Design for minimum
sludge

• Provide vapor enclosure

» Drain to process
                                                      • Return samples to
                                                      process
                                                                         • Monitor stormwater
                                                                         discharge
                                                     • Use drip pans for
                                                     maintenance activities

                                                     • Rinse to sump

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

                    » Furnace emissions
 Piping
 i Leaks to groundwater
  Fugitive emissions
• Use intermediate
exchangers to avoid contact
with furnace tubes and walls

 • Use staged heating to
minimize product
degradation and unwanted
side reactions.
(waste heat »low pressure
steam »high pressure
steam)

• Use scraped wall
exchangers in viscous
service

• Using falling film reboiler,
piped recirculation reboiler
or high-flux tubes

• Use lowest pressure steam
possible
• Use welded tubes or
double tube sheets with inert
purge. Mount vertically

• Use super heat of high-
pressure steam in place of a
furnace

• Design equipment layout
so as to minimize pipe run
length

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

• Use welded fittings

• Reduce number of flanges
and valves
• Select operating
temperatures at or near
ambient temperature when-
ever possible. These are
generally most desirable
from a pollution prevention
standpoint

• Use lower pressure steam
to lower temperatures
                                                       • Monitor exchanger
                                                       fouling to correlate process
                                                       conditions which increase
                                                       fouling, avoid conditions
                                                       which rapidly foul
                                                       exchangers

                                                       • Use on-line tube cleaning
                                                       techniques to keep tube
                                                       surfaces clean

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

• Use secondary
containment

• Use spiral-wound gaskets

» Use plugs and double
valves for open end lines

• Change metallurgy

• Use lined pipe

• Use "pigs" for cleaning

• Slope to low point drain

• Use heat tracing and
insulation to prevent freezing

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

                   « Residual "heel" of liquid
                   during pump maintenance
• Mechanical seal in lieu of
packing

» Double mechanical seal
with inert barrier fluid

• Double machined seal with
barrier fluid vented to
control device

• Seal-less pump (canned
motor magnetic drive)

• Vertical pump

• Use pressure transfer to
eliminate pump

• Low point drain on pump
casing
Seal installation practices

Monitor for leaks
                                                      • Flush casing to process
                                                      sewer for treatment
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        Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution
    Equipment
        Potential
 Environment Problem
                                                               Possible Approach
          Design
         Related
                                                                                Operational
                                                                                  Related
 Pumps (cont'd)
 Reactors
» Injection of seal flush
fluid into process stream
• Use double mechanical
seal with inert barrier fluid
where practical
• Poor conversion or
performance due to
inadequate mixing
                    » Waste by-product
                    formation
• Static mixing

• Add baffles

• Change impellers

• Add horsepower

• Add distributor

• Provide separate reactor
for converting recycle
streams to usable products
• Increase the mean time
between pump failures by:
- selecting proper seal
material;
- aligning well;
- reducing pipe-induced
 stress;
- maintaining seal
lubrication
• Add ingredients with
optimum sequence
                                                       • Allow proper head space
                                                       in reactor to enhance
                                                       vortex effect

                                                       • Optimize reaction
                                                       conditions (temperature,
                                                       pressure, etc.)
 Relief Valve
• Leaks
                     Fugitive emissions
                    • Discharge to
                    environment from over
                    pressure
                     Frequent relief
• Provide upstream rupture
disc

• Vent to control or recovery
device

• Pump discharges to suction
of pump

• Thermal relief to tanks

• Avoid discharge to roof
areas to prevent
contamination of rainwater

• Use pilot operated relief
valve

• Increase margin between
design and operating
pressure
                                                       • Monitor for leaks and for
                                                       control efficiency

                                                       • Monitor for leaks
                                                       » Reduce operating
                                                       pressure

                                                       • Review system
                                                       performance
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Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution


Equipment
Sampling







Tanks
















Vacuum Systems




Potential
Environment Problem
• Waste generation due to
sampling (disposal,
containers, leaks,
fugitives, etc.)




• Tank breathing and
working losses







• Leak to groundwater





• Large waste heel

• Waste discharge from
jets


Possible Approach
Design
Related
• On line in situ analyzers

• System for return to
process

» Closed loop

• Drain to sump
• Cool materials before
storage
• Insulate tanks
• Vent to control device
(flare, condenser, etc.)
• Vapor balancing
• Floating roof
• Floating roof
• Higher design pressure
• All aboveground (situated
so bottom can routinely be
checked for leads)
• Secondary containment
• Improve corrosion
resistance
• Design for 100 percent de-
inventory
• Substitute mechanical
vacuum pump
• Evaluate using process
fluid for powering jet
Operational
Related
• Reduce number and size
of samples required

• Sample at the lowest
possible temperature

• Cool before sampling

• Optimize storage
conditions to reduce losses







• Monitor for leaks and
corrosion




• Recycle to process if
practical
• Monitor for air leaks

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

                    This section discusses the Federal regulations that may apply to this sector.
                    The purpose of this section is to highlight, and briefly describe the applicable
                    Federal requirements, and to provide citations for more detailed information.
                    The three following sections are included.

                    •       Section VI. A. contains a general overview of major statutes
                    •       Section VLB. contains a list of regulations specific to this industry
                    •       Section VI.C. contains a list of pending and proposed regulations

                    The descriptions  within Section VI  are intended solely for  general
                    information.   Depending upon the nature or scope of the activities at a
                    particular facility, these summaries may or may not necessarily describe all
                    applicable environmental requirements.  Moreover, they  do not constitute
                    formal interpretations or clarifications of the statutes and regulations.  For
                    further information, readers should consult the Code of Federal Regulations
                    and other state or local agencies. EPA Hotline contacts are also provided for
                    each major statute.

VI.A. General Description of Major Statutes

Resource Conservation And Recovery Act

                    The Resource Conservation And Recovery Act (RCRA) of 1976 which
                    amended the Solid Waste Disposal Act, addresses solid  (Subtitle D)  and
                    hazardous (Subtitle C) waste  management activities.  The Hazardous  and
                    Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's waste
                    management provisions and added Subtitle I, which governs underground
                    storage tanks (USTs).

                    Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
                    260-299) establish a "cradle-to-grave" system governing  hazardous waste
                    from the point of generation to disposal.  RCRA hazardous wastes include
                    the specific materials listed in  the regulations  (commercial chemical
                    products,  designated with the code "P" or "U"; hazardous wastes from
                    specific industries/sources,  designated with the code "K";  or hazardous
                    wastes from non-specific sources, designated with the code  "F") or materials
                    which exhibit a hazardous waste characteristic (ignitability, corrosivity,
                    reactivity, or toxicity and designated with the. code "D").

                    Regulated entities that generate  hazardous waste are subject to waste
                    accumulation,  manifesting,  and record keeping standards.  Facilities that
                    treat, store, or dispose of hazardous waste must obtain a permit, either from
                    EPA or from a State agency which EPA has authorized to implement the
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                    permitting program.  Subtitle C permits contain general facility standards
                    such as contingency plans,  emergency procedures,  record keeping  and
                    reporting requirements, financial assurance mechanisms, and unit-specific
                    standards. RCRA also contains provisions (40 CFR Part 264 Subpart S and
                    §264.10) for conducting corrective actions which govern the cleanup of
                    releases of hazardous waste or constituents from solid waste management
                    units at RCRA-regulated facilities.

                    Although RCRA is a Federal statute, many States implement the RCRA
                    program. Currently, EPA has delegated its authority to implement various
                    provisions of RCRA to 46 of the 50 States.

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

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

                           Standards for Generators of Hazardous Waste (40 CFR Part 262)
                           establishes  the  responsibilities of  hazardous waste  generators
                           including obtaining an ID number, preparing a manifest, ensuring
                           proper packaging  and  labeling,  meeting  standards  for  waste
                           accumulation units, and record keeping and reporting requirements.
                           Generators can accumulate hazardous waste for up to 90 days (or 180
                           days depending on the amount of waste generated) without obtaining
                           a permit.

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

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

                    •      Tanks and Containers used to store hazardous waste with a high
                           volatile organic concentration must meet emission standards under
                           RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require
                           generators to test the waste to determine the concentration of the
                           waste,  to satisfy tank and container emissions standards,  and to
                           inspect and monitor regulated units.  These regulations apply to all
                           facilities who store such waste, including generators operating under
                           the 90-day accumulation rule.

                    •      Underground Storage Tanks (USTs)  containing petroleum and
                           hazardous substance are  regulated under  Subtitle  I of RCRA.
                           Subtitle I regulations (40 CFR Part 280) contain tank design and
                           release detection requirements, as well as financial responsibility and
                           corrective action standards for USTs.  The UST program  also
                           establishes  increasingly  stringent standards,  including upgrade
                           requirements for existing tanks, that must be met by 1998.

                    •      Boilers and Industrial Furnaces (BIFs)  that use  or bum fuel
                           containing hazardous waste must comply with strict design and
                           operating standards.  BIF regulations (40 CFR Part 266, Subpart H)
                           address unit  design,  provide performance  standards,  require
                           emissions monitoring,  and restrict the type of waste  that may be
                           burned.

                    EPA's  RCRA/Superfund/UST Hotline, at (800) 424-9346,   responds  to
                    questions and distributes guidance regarding all RCRA regulations.  The
                    RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
                    Federal holidays.

Comprehensive Environmental Response, Compensation, And Liability Act

                    The Comprehensive Environmental Response, Compensation, and Liability
                    Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
                    to respond to releases, or threatened releases, of hazardous substances that
                    may endanger  public health, welfare, or the environment. CERCLA also
                    enables EPA to force parties responsible for environmental contamination to
                    clean it up or to reimburse the Superfund for response costs incurred by EPA.
                    The Superfund Amendments and Reauthorization  Act (SARA) of 1986
                    revised various sections of CERCLA, extended the taxing authority for the
                    Superfund, and created a free-standing law, SARA Title III, also known as
                    the Emergency Planning and Community Right-to-Know Act (EPCRA).
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                    The CERCLA hazardous substance release reporting regulations (40 CFR
                    Part 302) direct the person in charge of a facility to report to the National
                    Response Center (NRC) any environmental release of a hazardous substance
                    which exceeds a reportable quantity.  Reportable quantities are defined and
                    listed in 40 CFR §302.4.  A release report may trigger a response by EPA, or
                    by one or more Federal or State emergency response authorities.

                    EPA implements hazardous substance responses according to procedures
                    outlined  in  the National  Oil  and  Hazardous  Substances  Pollution
                    Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions
                    for permanent  cleanups, known  as remedial actions, and other cleanups
                    referred to as "removals." EPA generally takes remedial actions only at sites
                    on the National Priorities List (NPL), which currently includes approximately
                    1300 sites.   Both EPA  and  states can act at other sites; however, EPA
                    provides responsible parties the opportunity to conduct removal and remedial
                    actions and encourages community involvement throughout the Superfund
                    response process.

                    EPA's RCRA/Superfund/USTHotline, at (800) 424-9346, answers questions
                    and references guidance pertaining to the Superfund program. The CERCLA
                    Hotline  operates -weekdays from 8:30 a.m. to  7:30 p.m.,  ET,  excluding
                    Federal  holidays.

Emergency Planning And Community Right-To-Know Act

                    The Superfund Amendments and Reauthorization Act (SARA) of 1986
                    created  the  Emergency Planning and  Community Right-to-Know  Act
                    (EPCRA, also  known as SARA  Title III), a statute designed to improve
                    community access to information about chemical hazards and to facilitate the
                    development of chemical emergency response plans by  State and local
                    governments.  EPCRA required the establishment of State emergency
                    response commissions  (SERCs), responsible  for coordinating certain
                    emergency response activities and for appointing local emergency planning
                    committees (LEPCs).

                    EPCRA  and the EPCRA regulations (40 CFR Parts 350-372) establish four
                    types of reporting obligations for  facilities which store or manage specified
                    chemicals:

                          EPCRA §302 requires facilities to notify the SERC and LEPC of the
                          presence of any "extremely hazardous substance" (the list of such
                          substances is in 40 CFR Part 355, Appendices A and B) if it has such
                          substance in excess of the substance's threshold planning quantity,
                          and directs the facility to appoint an emergency response coordinator.
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                           EPCRA §304 requires the facility to notify the SERC and the LEPC
                           in the event  of a release  exceeding the reportable quantity of a
                           CERCLA hazardous substance or an EPCRA extremely hazardous
                           substance.

                    •      EPCRA §311 and §312 require a facility at which a hazardous
                           chemical, as defined by the Occupational Safety and Health Act, is
                           present in an amount exceeding a specified threshold to submit to the
                           SERC, LEPC and local fire department material safety data sheets
                           (MSDSs) or lists of MSDS's and hazardous chemical inventory forms
                           (also known as Tier I and II forms).  This information helps the local
                           government respond in the event of a spill or release of the chemical.

                    •      EPCRA §313 requires manufacturing facilities included hi SIC codes
                           20 through 39, which have ten or more  employees,  and which
                           manufacture, process, or use specified chemicals in amounts greater
                           than threshold quantities, to submit an annual toxic chemical release
                           report. This report, commonly known as the Form R, covers releases
                           and  transfers  of  toxic  chemicals  to  various facilities  and
                           environmental media, and allows EPA to compile the national Toxic
                           Release Inventory (TRI) database.

                    All information submitted pursuant to EPCRA regulations  is publicly
                    accessible, unless protected by a trade secret claim.

                    EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
                    guidance regarding the emergency planning and community right-to-know
                    regulations.  The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
                    p.m., ET, excluding Federal holidays.
Clean Water Act
                    The primary objective of the Federal Water Pollution Control Act, commonly
                    referred to as the Clean Water Act (CWA), is to restore and maintain the
                    chemical, physical, and biological integrity of the nation's surface waters.
                    Pollutants regulated under the CWA include "priority" pollutants, including
                    various toxic pollutants;  "conventional" pollutants, such as biochemical
                    oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and
                    grease, and pH; and "non-conventional" pollutants, including any pollutant
                    not identified as either conventional or priority.

                    The CWA regulates  both direct and indirect discharges.  The National
                    Pollutant Discharge Elimination System (NPDES) program (CWA §402)
                    controls direct discharges into navigable waters. Direct discharges or "point
                    source" discharges are from sources such as pipes and sewers.  NPDES
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                     permits, issued by either EPA or an authorized State (EPA has authorized
                     approximately forty States to administer the NPDES program), contain
                     industry-specific, technology-based and/or water quality-based limits, and
                     establish pollutant monitoring requirements.   A facility that intends to
                     discharge into the nation's waters must obtain a permit prior to initiating its
                     discharge.  A permit applicant must provide quantitative analytical data
                     identifying the types of pollutants present in the facility's effluent.  The
                     permit will then set forth the conditions and effluent limitations under which
                     a facility may make a discharge.

                     A NPDES permit may also include discharge limits based on Federal or State
                     water quality criteria or standards, that were designed to protect designated
                     uses of surface waters, such as supporting aquatic life or recreation.  These
                     standards, unlike the technological standards,  generally do not take into
                     account technological  feasibility  or costs.   Water  quality criteria and
                     standards  vary from State to State, and site to site, depending on the use
                     classification of the receiving body of water. Most  States follow EPA
                     guidelines which propose aquatic life  and human health criteria for many of
                     the 126 priority pollutants.

                     Storm Water Discharges

                     In 1987 the CWA was amended to require EPA to  establish a program to
                     address storm water discharges. In response, EPA promulgated the NPDES
                     storm water permit application regulations.  Storm water discharge associated
                     with industrial activity means the discharge from any conveyance which is
                     used for collecting and conveying storm water and which is directly related
                     to manufacturing, processing, or raw materials storage areas at an industrial
                     plant (40 CFR 122.26(b)(14)). These regulations require that facilities with
                     the following storm water discharges apply for an NPDES permit:  (1) a
                     discharge associated with industrial activity; (2) a discharge from a large or
                     medium municipal storm sewer system; or (3) a discharge which EPA or the
                     State determines to contribute to a violation of a water quality standard or is
                     a significant contributor of pollutants to waters of the United States.

                     The term "storm water discharge associated with industrial activity"  means
                     a storm water discharge from one of 11 categories of industrial activity
                     defined at 40 CFR 122.26. Six of the categories are defined by SIC codes
                     while the other five are identified through narrative  descriptions  of the
                     regulated industrial activity. If the primary SIC code of the facility is one of
                     those identified in the regulations, the facility is subject to the storm water
                     permit application requirements.  If any activity at a facility is covered by
                     one of the five narrative categories, storm water discharges from those areas
                     where the activities occur are subject to storm water  discharge  permit
                     application requirements.
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                     Those facilities/activities that are subject to storm water discharge permit
                     application requirements are identified below.  To determine whether a
                     particular facility falls within one of these categories, the regulation should
                     be consulted.

                     Category i:  Facilities subject to storm water effluent guidelines, new source
                     performance standards, or toxic pollutant effluent standards.

                     Category ii:  Facilities classified as SIC  24-lumber and wood products
                     (except wood kitchen cabinets); SIC 26-paper and allied products (except
                     paperboard containers and products); SIC 28-chemicals and allied products
                     (except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
                     tanning and finishing.

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

                     Category iv: Hazardous waste treatment, storage, or disposal facilities.

                     Category v:  Landfills, land application sites, and open dumps that receive
                     or have received industrial wastes.

                     Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
                     SIC 5093-automotive scrap and waste material recycling facilities.

                     Category vii:  Steam electric power generating facilities.

                     Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
                     local passenger transportation; SIC 42-trucking  and warehousing (except
                     public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
                     transportation; SIC 45-transportation by air; and  SIC 5171-petroleum bulk
                     storage stations and terminals.

                     Category ix: Sewage treatment works.

                     Category x:  Construction activities except operations that result in the
                     disturbance of less than five acres of total land area.

                     Category xi:  Facilities classified as SIC 20-food and kindred products; SIC
                     21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
                     products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
                     and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
                     paper and paperboard products; SIC 27-printing, publishing,  and allied
                     industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
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                    allied products;  SIC 30-rubber and plastics;  SIC 31-leather and leather
                    products (except leather and tanning and finishing); SIC 323-glass products;
                    SIC 34-fabricated metal products (except fabricated structural metal); SIC
                    35-industrial and commercial .machinery and computer equipment; SIC 36-
                    electronic  and other electrical  equipment  and  components;  SIC 37-
                    transportation equipment (except ship and boat building and repairing); SIC
                    38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
                    manufacturing  industries; and  SIC 4221-4225-public warehousing and
                    storage.

                    Pretreatment Program

                    Another type of discharge that is regulated by the CWA is one that goes to
                    a publicly-owned treatment works (POTWs). The national pretreatment
                    program (CWA §307(b)) controls the indirect discharge of pollutants to
                    POTWs by "industrial users."  Facilities regulated under §307(b) must meet
                    certain pretreatment standards. The goal of the pretreatment program is to
                    protect municipal wastewater treatment plants from damage that may occur
                    when hazardous, toxic, or other wastes are discharged into a sewer system
                    and to protect the quality of sludge generated by these plants.  Discharges to
                    a POTW are regulated primarily by the POTW itself, rather than the State or
                    EPA.

                    EPA  has developed technology-based standards  for industrial users  of
                    POTWs. Different standards apply to existing and new sources  within each
                    category.  "Categorical" pretreatment standards applicable to an industry on
                    a nationwide basis are developed by  EPA.  In addition, another kind of
                    pretreatment standard, "local limits," are developed by the POTW in order
                    to assist the POTW in achieving the effluent limitations in its NPDES permit.

                    Regardless of whether a State is authorized to implement either  the NPDES
                    or the pretreatment program, if it develops its own program, it may enforce
                    requirements more stringent than Federal standards.

                    EPA's Office of Water, at (202) 260-5700, will direct callers with questions
                    about the  CWA to the appropriate EPA office.   EPA also maintains  a
                    bibliographic database  of Office  of Water publications  which can  be
                    accessed through the Ground Water and Drinking Water resource center, at
                    (202) 260-7786.
Safe Drinking Water Act
                     The Safe  Drinking Water Act (SDWA) mandates that EPA establish
                     regulations to protect human health from contaminants in drinking water.
                     The law authorizes EPA to develop national drinking water standards and to
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                    create a joint  Federal-State system to ensure  compliance with  these
                    standards. The SDWA also directs EPA to protect underground sources of
                    drinking water through the control of underground injection of liquid wastes.

                    EPA has developed primary and secondary drinking water standards under
                    its  SDWA authority.  EPA and authorized States enforce the primary
                    drinking water standards,  which are, contaminant-specific concentration
                    limits that apply to certain public drinking water supplies. Primary drinking
                    water standards consist of maximum contaminant level goals (MCLGs),
                    which are non-enforceable health-based goals, and maximum contaminant
                    levels (MCLs), which are enforceable limits set as close to MCLGs as
                    possible, considering cost and feasibility of attainment.

                    The SDWA Underground  Injection Control (UIC) program (40 CFR Parts
                    144-148)  is a  permit  program which  protects underground sources of
                    drinking water by regulating five classes of injection wells.  UIC permits
                    include  design,  operating, inspection, and monitoring requirements.  Wells
                    used to  inject hazardous wastes must also comply with RCRA corrective
                    action standards in order to be granted a RCRA permit, and must meet
                    applicable RCRA land disposal restrictions standards.  The  UIC permit
                    program is primarily State-enforced, since EPA has authorized all but a few
                    States to administer the program.

                    The SDWA also provides for a Federally-implemented Sole Source Aquifer
                    program, which prohibits Federal funds from being expended on projects that
                    may contaminate the  sole or principal source of drinking water for a given
                    area, and for a State-implemented Wellhead Protection program, designed to
                    protect drinking water wells and drinking water recharge areas.

                    EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
                    and distributes guidance pertaining  to SDWA standards.   The Hotline
                    operates from 9:00a.m. through 5:30 p.m., ET, excluding Federal holidays.

Toxic Substances Control Act

                    The Toxic Substances Control Act (TSCA) granted EPA authority to create
                    a regulatory framework to  collect data on chemicals in order to evaluate,
                    assess, mitigate, and control risks which may be posed by their manufacture,
                    processing, and use. TSCA provides a variety of control methods to prevent
                    chemicals from posing unreasonable risk.

                    TSCA standards may apply at any point during a  chemical's life cycle.
                    Under TSCA §5, EPA has established an inventory of chemical substances.
                    If a chemical is not already on the inventory,  and has not been excluded by
                    TSCA, a premanufacture notice (PMN) must be submitted to EPA prior to
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                    manufacture or import. The PMN must identify the chemical and provide
                    available information on health and environmental effects. If available data
                    are not sufficient to  evaluate the chemicals  effects, EPA  can impose
                    restrictions pending the  development of information on its health and
                    environmental  effects.  EPA can also  restrict significant new uses of
                    chemicals based upon factors such as the projected volume and use of the
                    chemical.

                    Under TSCA §6, EPA can ban the manufacture or distribution in commerce,
                    limit the use, require labeling, or place other restrictions on chemicals that
                    pose unreasonable risks.  Among the chemicals EPA regulates under §6
                    authority are asbestos, chlorofluorocarbons (CFCs),  and polychlorinated
                    biphenyls (PCBs).

                    EPA's TSCA Assistance Information Service, at (202) 554-1404, answers
                    questions and distributes guidance pertaining to Toxic Substances Control
                    Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET,
                    excluding Federal holidays.
 Clean Air Act
                    The Clean Air Act (CAA) and its amendments, including the Clean Air Act
                    Amendments (CAAA) of 1990, are designed to "protect and enhance the
                    nation's air resources so as to promote the public health and welfare and the
                    productive capacity of the population."  The CAA consists of six sections,
                    known as Titles, which direct EPA to establish national standards for ambient
                    air quality and for EPA and the States to implement, maintain, and enforce
                    these standards through a variety of mechanisms.  Under the CAAA, many
                    facilities will be required to obtain permits for the first time. State and local
                    governments oversee, manage, and enforce many of the requirements of the
                    CAAA.  CAA regulations appear at 40 CFR Parts 50 through 99.

                    Pursuant to  Title I of the CAA, EPA has established national ambient air
                    quality standards (NAAQSs) to limit levels of "criteria pollutants," including
                    carbon  monoxide, lead, nitrogen dioxide,  particulate matter, ozone, and
                    sulfur dioxide.  Geographic areas that meet NAAQSs for a given pollutant
                    are classified as  attainment areas; those that do not meet NAAQSs are
                    classified as non-attainment areas. Under §110 of the CAA, each State must
                    develop a State Implementation Plan (SIP) to identify sources of air pollution
                    and to determine what reductions are required to meet Federal air quality
                    standards.

                    Title I also authorizes EPA to establish New Source Performance Standards
                    (NSPSs), which are nationally uniform emission standards for new stationary
                    sources falling within particular industrial categories. NSPSs are based on
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                     the pollution control technology available to that category of industrial
                     source but  allow the affected industries the  flexibility to devise  a
                     cost-effective means of reducing emissions.

                     Under Title I, EPA establishes and enforces National Emission Standards for
                     Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
                     towards controlling particular hazardous air pollutants (HAPs). Title III of
                     the CAAA further directed EPA to develop a list of sources that emit any of
                     189 HAPs, and to develop regulations for these categories of sources. To
                     date EPA has listed 174  categories and developed a schedule for the
                     establishment of emission standards.  The  emission standards  will be
                     developed for both new and existing sources based on "maximum achievable
                     control technology"  (MACT).  The MACT is  defined as the control
                     technology achieving the maximum degree of reduction in the emission of
                     the HAPs, taking into account cost and other factors.

                     Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
                     and planes.  Reformulated  gasoline, automobile pollution control devices,
                     and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
                     uses to regulate mobile air emission sources.

                     Title IV establishes a sulfur dioxide emissions program designed to reduce
                     the formation of acid rain.  Reduction of sulfur dioxide releases will be
                     obtained by granting to certain sources limited emissions allowances, which,
                     beginning in 1995, will be set below previous levels of  sulfur  dioxide
                     releases.

                     Title V of the CAAA of 1990 created a permit  program  for all "major
                     sources" (and certain other sources) regulated under the CAA. One purpose
                     of the operating permit is to include in a single document all air emissions
                     requirements that apply to a given facility. States are developing the permit
                     programs in accordance with guidance and regulations from EPA.  Once a
                     State program is approved by EPA, permits will be issued and monitored by
                     that State.

                     Title VI  is intended  to protect stratospheric ozone by phasing out the
                     manufacture  of ozone-depleting chemicals and  restrict  their use  and
                     distribution.   Production of Class I  substances,  including 15 kinds of
                     chlorofiuorocarbons (CFCs), will be phased out entirely by the year 2000,
                     while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030.

                     EPA's Control Technology Center, at (919) 541-0800, provides general
                     assistance and information on CAA standards.  The Stratospheric Ozone
                     Information Hotline, at (800) 296-1996, provides general information about
                     regulations promulgated under Title  VI of the CAA, and EPA's EPCRA
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                    Hotline, at (800)  535-0202,  answers questions about accidental release
                    prevention  under CAA §112(r).   In addition,  the  Technology Transfer
                    Network Bulletin Board System (modem access (919) 541-5742)) includes
                    recent CAA rules, EPA guidance documents, and updates of EPA activities.

VLB. Industry' Specific Requirements

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

Federal Statutes

Toxic Substances Control Act

                    The Toxic Substances Control  Act (TSCA), passed in  1976, gives the
                    Environmental Protection Agency comprehensive authority to regulate any
                    chemical  substance whose  manufacture,  processing,  distribution  in
                    commerce, use, or disposal may present an unreasonable risk of injury to
                    health or the environment.  Three sections are of primary importance to the
                    inorganic chemical industry.  Section 5 mandates that chemical companies
                    submit to EPA pre-manufacture notices that provide information on health
                    and environmental effects for each new product and test existing products for
                    these effects.  To date, over 20,000 premanufacturing notices have been filed.
                    Section 4 authorizes the EPA to require testing of certain substances. Section
                    6 gives the EPA authority to prohibit, limit, or ban the manufacture, process,
                    and use of chemicals. Under Section 6 of TSCA, EPA has banned most uses
                    of asbestos. In 1990, however, the chlor-alkali industry was able to show
                    that it did not have difficulty meeting the required exposure limits for
                    asbestos fibers, and the use of asbestos  as a diaphragm material was
                    exempted from the TSCA ban.
Clean Air Act
                    The Clean Air Act Amendments of 1990 set National Emission Standards for
                    Hazardous Air  Pollutants (NESHAP)  from industrial  sources for 41
                    pollutants to be met by 1995 and for 148 other pollutants to be reached by
                    2003.  Several provisions affect the inorganic chemical industry. The EPA
                    will promulgate maximum achievable control technology (MACT) standards
                    and Lowest Achievable Emission Rates will be required in NAAQS non-
                    attainment areas (Iliam  Rosario,  U.S.  EPA, OAQPS, WAM for  Chlorine
                    Production NESHAP (919)-541-5308). An information collection request
                    survey was sent out to the chlor-alkali industry in 1992. The data obtained
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                     from the survey will be analyzed and, based on the results, EPA will propose
                     MACT standards (or EPA may propose that no new standards are necessary)
                     for the chlor-alkali industry by 1997.  For any subject facility, a six year
                     extension of MACT requirements is available if they can demonstrate early
                     emission reductions.

                     The Clean Air Act Amendments of 1990 contain provisions to phase out the
                     use of ozone depleting chemicals such as chlorofluorocarbons, halons, carbon
                     tetrachloride,  and methyl chloroform, as required by the Montreal Protocol
                     on Substances that Deplete the Ozone Layer.  The chlor-alkali industry has
                     been and will  continue to be significantly affected by these provisions due to
                     decreases in the demand for chlorine as a feedstock in manufacturing these
                     chemicals. In addition, many of these chemicals are used extensively by the
                     industry to process chlorine.
Clean Water Act
                     The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,
                     gives EPA the authority to regulate effluents from sewage treatment works,
                     chemical plants, and other industrial sources into waters. The act sets "best
                     available technology" standards for treatment of wastes for both direct and
                     indirect (to a Publicly Owned  Treatment Works) discharges.  Effluent
                     guidelines for the chlor-alkali industry were last updated in 1984 (40 CFR
                     Section 415). EPA is currently conducting a study to assess the need for new
                     effluent guidelines.  (Contact: George Zipf, U.S. EPA, Office of Water, 202-
                     260-2275)

                     Restrictions on  dioxin  emissions in the wastewater from  pulp mills are
                     having significant effects on the chlor-alkali industry.  Dioxins are formed
                     during the chlorine bleaching process and are subsequently released to rivers
                     and streams. Many mills are switching from chlorine to alternative bleaching
                     agents in response to the effluent restrictions. Pulp mills accounted for about
                     15 percent of the chlorine demand in the U.S.  in 1982 and 11 percent in
                     1992.  The demand for chlorine for pulp bleaching is expected to continue to
                     decrease through the 1990s.
Resource Conservation and Recovery Act
                    The Resource Conservation and Recovery Act (RCRA) of 1976 gives the
                    EPA authority to  establish a list of solid and hazardous wastes, and to
                    establish standards and regulations for handling and disposing of these
                    wastes. New wastes specific to the inorganic chemical industry have not
                    been added to the RCRA list since the original waste listings in 1980. EPA
                    is currently under a consent order, however, to propose new hazardous waste
                    listings for the industry by March 1997, and to finalize by  March  1998.
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                    (Contact: Rick Brandes, U.S. EPA, Office of Solid Waste, 202-260-4770)
                    The Act also requires companies to establish programs to reduce the volume
                    and toxicity  of hazardous  wastes.  It was last amended in  1984 when
                    Congress mandated some 70 new programs for the hazardous waste (Subtitle
                    C) program.  Included were tighter standards for handling and disposing of
                    hazardous  wastes,  land  disposal  prohibitions,  corrective  action  (or
                    remediation) regulations, and regulations for underground storage tanks. The
                    inorganic chemical industry is strongly affected by the RCRA regulations
                    because  of the disposal costs for hazardous waste and the record keeping
                    requirements.

Occupational Safety and Health Act

                    The Occupational Safety and Health Act gave the Department of Labor the
                    authority to  set  comprehensive workplace safety and  health  standards
                    including permissible exposures to chemical in the workplace and authority
                    to conduct Inspections and issue citations for violations of safety and health
                    regulations.   The chemical industry  is subject  to  hazard  identification
                    standards established by OSHA, which require extensive documentation of
                    chemicals in trade and in the workplace and mandate warning labels  on
                    containers. The industry is also subject to OSHA's Hazard Communication
                    Standard and various state and local laws, which give workers the right to
                    know about hazardous chemicals in the workplace.

Hazardous Materials Transportation Act

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

Pollution Prevention Act

                    The Pollution Prevention Act makes it a national policy of the United States
                    to  reduce  or eliminate the generation of waste at  the  source  whenever
                    feasible.  The EPA is directed to undertake  a multi-media program of
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                     information collection, technology transfer, and financial assistance to enable
                     the states to implement this policy and to promote the use of source reduction
                     techniques. The reorganization of the Office of Compliance by industry
                     sector is part of EPA's response to this act.
 State Statutes
 Toxics Use Reduction Act, Massachusetts
                    The Massachusetts Toxics Use Reduction Act affects those facilities that use,
                    manufacture, or process more than a specified amount of substances that are
                    on the Massachusetts toxic or hazardous substances list.  Facilities must
                    submit annual reports on the amounts of substances used, manufactured, or
                    processed and must pay annual fees based on these amounts.  In addition,
                    facilities must prepare  toxics use reduction plans which show in-plant
                    changes in production processes or raw materials that would reduce, avoid,
                    or eliminate the use or generation of toxic or hazardous substances.  The
                    Massachusetts toxic or hazardous substance list initially consists of those
                    substances listed under §313 of EPCRA and will eventually include those
                    substances listed under CERCLA. New Jersey has recently passed a similar
                    act.
VI.C. Pending and Proposed Regulatory Requirements

Resource Conservation and Recovery Act (RCRA)
Clean Air Act
                    The Resource Conservation and Recovery Act (RCRA) listed waste streams
                    specific to the inorganic chemical industry have not been updated since the
                    original RCRA hazardous wastes list developed in 1980. EPA is under a
                    court-ordered deadline to propose and finalize additional waste listings for
                    the industry by March 1997 and March 1988, respectively.  The Office  of
                    Solid Waste will begin assessing the need for new listings by early 1996.
                    (Contact: Rick Brandes, U.S. EPA, Office of Solid Waste, 202-260-4770)
                    The new NESHAP  standards for the inorganic  chemical industry are
                    scheduled to be promulgated by EPA by 1997.  (Contact: Iliam Rosario, U.S.
                    EPA, OAQPS, WAM for Chlorine Production NESHAP, 919-541-5308)
                    The standards required will, in  most cases, be in the form of MACT
                    standards. Lowest Achievable Emission Rates will  be required in NAAQS
                    non-attainment areas.  An information collection request survey was sent out
                    to the chlor-alkali industry in 1992. The data obtained will be analyzed and
                    used to assess the need for NESHAP standards in the chlor-alkali industry.
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                    The chlor-alkali industry will continue to be affected by the provisions to
                    phase out the use of ozone depleting chemicals as required by the Montreal
                    Protocol on Substances that Deplete the Ozone Layer.  The demand for
                    chlorine as a feedstock in manufacturing these chemicals, which accounted
                    for about 15 percent of total domestic demand in  1990, will continue to
                    decline through the 1990s. In addition, costs of purifying and liquefying
                    chlorine gas may increase as the cost of carbon tetrachloride and refrigerants
                    increases, and as alternative processes are introduced.
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
                     To date, EPA has focused much of its attention on measuring compliance
                     with specific environmental statutes.  This approach allows the Agency to
                     track compliance with the Clean Air Act, the Resource Conservation and
                     Recovery Act, the Clean Water Act, and  other environmental  statutes.
                     Within the last several years, the Agency has begun to supplement single-
                     media compliance indicators with facility-specific, multimedia indicators of
                     compliance, hi doing so, EPA is in a better position to track compliance with
                     all statutes at the facility level, and within specific industrial sectors.

                     A  major step  in building the capacity to  compile multimedia  data for
                     industrial sectors was the creation of EPA's Integrated Data for Enforcement
                     Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
                     single-media databases, extract compliance records, and match the records
                     to individual facilities.  The IDEA system can match Air, Water, Waste,
                     Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
                     facility, and generate a list of historical permit, inspection, and enforcement
                     activity. IDEA also has the capability to analyze data by geographic area and
                     corporate holder.
Compliance and Enforcement Profile Description
                     Using inspection, violation, and enforcement data from the IDEA system,
                     this section provides information regarding the historical compliance and
                     enforcement activity of this sector.  In order to mirror the facility universe
                     reported in the Toxic Chemical Profile, the data reported within this section
                     consists of records only from the TRI reporting universe. With this decision,
                     the selection criteria are  consistent  across sectors with certain exceptions.
                     For the sectors that do not normally report to the TRI program, data have
                     been provided from EPA's Facility Indexing System (FINDS) which tracks
                     facilities in all media databases. Please note, in this section, EPA does not
                     attempt to define the actual number of facilities that fall within each sector.
                     Instead, the section portrays the records of a subset  of facilities within the
                     sector that are well defined within EPA databases.

                     As a check on the relative size  of the  full sector universe, most notebooks
                     contain an estimated number of facilities within the sector according to the
                     Bureau of Census  (See  Section II).  With sectors dominated by small
                     businesses, such as metal  finishers and printers, the reporting universe within
                     the EPA databases may be small in  comparison to Census data.  However,
                     the group  selected  for inclusion in this data analysis section should be
                     consistent with this sector's general make-up.
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                    Following this introduction is a list defining each data column presented
                    within this section.  These values represent a retrospective summary of
                    inspections or enforcement actions, and solely reflect EPA, state, and local
                    compliance assurance activity that have been entered into EPA databases.
                    To identify any changes in trends, the EPA ran two data queries, one for the
                    past five calendar years (August 10, 1990 to August 9, 1995) and the other
                    for the most recent twelve-month period (August 10, 1994 to August 9,
                    1995).  The five-year analysis gives an  average level of activity  for that
                    period for comparison to the more recent activity.

                    Because most inspections focus on single-media requirements, the data
                    queries presented in this section are taken from single media databases.
                    These databases do not provide data on whether inspections are state/local
                    or EPA-led. However, the table breaking down the universe of violations
                    does give the reader a crude measurement  of the EPA's and states' efforts
                    within each media program.  The presented data illustrate the  variations
                    across regions for certain sectors.6  This variation may be attributable to
                    state/local  data entry variations,  specific  geographic  concentrations,
                    proximity to population centers, sensitive ecosystems, highly toxic chemicals
                    used in production, or historical noncompliance. Hence, the exhibited data
                    do not rank regional performance or necessarily reflect which regions may
                    have the most compliance problems.

Compliance and Enforcement Data Definitions

General Definitions

                    Facility Indexing System (FINDS) — this system assigns a common facility
                    number to  EPA single-media permit records.  The FINDS identification
                    number  allows  EPA to compile and  review all  permit, compliance,
                    enforcement and pollutant release data for any given regulated facility.

                    Integrated Data for Enforcement Analysis (IDEA) ~ is a data integration
                    system that can retrieve information from  the major EPA program office
                    databases.  IDEA uses the FINDS identification number to "glue together"
                    separate data records from EPA's databases.  This is done to create a "master
                    list" of data records  for any given facility.  Some of the data  systems
                    accessible through IDEA are: AIRS (Air Facility Indexing and Retrieval
                    System,  Office of Air and Radiation), PCS (Permit Compliance  System,
                    Office of Water), RCRIS (Resource Conservation and Recovery Information
e EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT);II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX);
VII (IA, KS, MO, NE); VIII (CO, MT, ND,  SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK,
ID, OR, WA).
September 1995
90
SIC 281

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 Sector Notebook Project
                          Inorganic Chemicals
                     System, Office of Solid Waste), NCDB (National Compliance Data Base,
                     Office  of  Prevention, Pesticides, and Toxic  Substances),  CERCLIS
                     (Comprehensive   Environmental  and  Liability  Information  System,
                     Superfund),  and  TRIS (Toxic Release Inventory System).   IDEA also
                     contains information from outside sources such as Dun and Bradstreet and
                     the Occupational Safety and Health Administration (OSHA).  Most data
                     queries displayed in notebook sections IV and VII were conducted using
                     IDEA.

 Data Table Column Heading Definitions

                     Facilities in Search - are based on the universe of TRI reporters within the
                     listed SIC code range. For industries not covered under TRI reporting
                     requirements, the notebook uses the FINDS universe for executing data
                     queries. The SIC code range selected for each search is defined by each
                     notebook's selected SIC code coverage described in Section II.

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

                     Number  of Inspections  -  measures the  total number of inspections
                     conducted in this sector.  An inspection event is counted each time it is
                     entered into a single media database.

                     Average Time Between Inspections - provides an average length of time,
                     expressed in months, that a compliance inspection occurs at a facility within
                     the defined universe.

                     Facilities with One or More Enforcement Actions - expresses the number
                     of facilities that were party to at least one enforcement action within the
                     defined time period.  This category is broken down further into federal and
                     state  actions.  Data are obtained for administrative, civil/judicial, and
                     criminal enforcement actions.  Administrative actions include Notices of
                     Violation (NOVs).  A  facility with multiple enforcement actions is only
                     counted once in this column (facility with three enforcement actions counts
                     as one).  All percentages that appear are referenced to the number of facilities
                     inspected.

                     Total Enforcement Actions ~ describes the total number of enforcement
                     actions identified for an industrial sector across all environmental statutes.
                     A facility with multiple enforcement actions is counted multiple times (a
                     facility with three enforcement actions counts as three).
September 1995
91
SIC 281

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Sector Notebook Project
                        Inorganic Chemicals
                    State Lead Actions ~ shows what percentage of the total enforcement
                    actions are taken by state and local environmental agencies.  Varying levels
                    of use by states of EPA  data systems may limit the volume of actions
                    accorded state  enforcement activity.   Some  states  extensively report
                    enforcement activities into EPA data systems, while other  states may use
                    their own data systems.

                    Federal Lead Actions --  shows what percentage of the total enforcement
                    actions are taken by the United  States Environmental  Protection Agency.
                    This value includes referrals from state agencies.  Many of these actions
                    result from coordinated or joint state/federal efforts.

                    Enforcement to Inspection Rate ~ expresses how often enforcement
                    actions result from inspections. This value is a ratio of enforcement actions
                    to inspections, and is presented for comparative purposes only. This measure
                    is a rough Indicator of the relationship between inspections and enforcement.
                    Reported inspections and  enforcement actions under the Clean Water Act
                    (PCS), the Clean Air Act (AFS) and the Resource Conservation  and
                    Recovery Act (RCRA) are included in this ratio.  Inspections and actions
                    from the TSCA/FIFRA/EPCRA database are not factored into this ratio
                    because most of the actions taken under these programs are not the result of
                    facility inspections.   This ratio does not account for enforcement actions
                    arising from  non-inspection compliance monitoring activities (e.g., self-
                    reported  water discharges) that can result in enforcement action within the
                    CAA, CWA and RCRA.

                    Facilities with One or More Violations Identified -- indicates the number
                    and percentage of inspected facilities having a violation identified in one of
                    the folio whig data categories: In Violation or Significant Violation Status
                    (CAA);  Reportable  Noncompliance,  Current  Year  Noncompliance,
                    Significant  Noncompliance (CWA); Noncompliance  and  Significant
                    Noncompliance (FIFRA, TSCA, and EPCRA);  Unresolved Violation and
                    Unresolved High Priority Violation (RCRA). The values presented for this
                    column reflect the extent of noncompliance within the measured time frame,
                    but  do  not  distinguish  between the  severity of the noncompliance.
                    Percentages within this column may exceed 100 percent because facilities
                    can be in violation status without being inspected. Violation status may be
                    a precursor to an enforcement action, but does not necessarily indicate that
                    an enforcement action will occur.

                    Media Breakdown of Enforcement Actions and Inspections  —  four
                    columns  identify the proportion of total inspections and enforcement actions
                    within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases.  Each
                    column is a percentage of either the "Total Inspections," or the  "Total
                    Actions" column.
 September 1995
92
SIC 281

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

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

                            The enforcement to inspection rate varied significantly from Region
                            to Region.  Region DC had the highest enforcement to inspection rate
                            as well as the highest percentage of state led actions.
September 1995
93
SIC 281

-------
Sector Notebook Project
                      Inorganic Chemicals





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94
SIC 281

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Sector Notebook Project
                          Inorganic Chemicals
 VII.B. Comparison of Enforcement Activity Between Selected Industries

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

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

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

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

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

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

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

                     •      Over the past year RCRA  inspections  have  accounted for a
                           significantly smaller portion of the enforcement actions brought
                           against the industry and the Clean Air Act has taken a far greater
                           share.
September 1995
95
SIC 281

-------
Sector Notebook Project
                      Inorganic Chemicals





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Sector Notebook Project
Inorganic Chemicals



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           SIC 281

-------
Sector Notebook Project
Inorganic Chemicals

















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Sector Notebook Project
                       Inorganic Chemicals















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                         Inorganic Chemicals
VII.C. Review of Major Legal Actions

Major Cases/Supplemental Environmental Projects
                    This section provides summary information about major cases that have
                    affected this sector, and a list of Supplementary Environmental Projects
                    (SEPs). SEPs are compliance agreements that reduce a facility's stipulated
                    penalty in return for an environmental project that exceeds the value of the
                    reduction. Often, these projects fund pollution prevention activities that can
                    significantly reduce the future pollutant loadings of a facility.

       VII.C.1. Review of Major Cases

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

       VH.C.2. Supplementary Environmental Projects

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

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

                    One of the five projects was conducted at a facility that manufactures both
                    inorganic and organic chemicals.   This project has been included in both
                    industry sector project summaries.  The  FY  1993 and  1994 SEPs for
                    inorganic chemical manufacturers fall into four categories: process related
                    projects; control and recovery technology inprovement or installation; leak
                    prevention; and donations to the community.
 September 1995
100
SIC 281

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

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

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

                     •Donations to Community
                           Following  a  CERCLA  violation,  a facility  in Texas  donated
                           emergency  and computer  equipment  to the Local  Emergency
                           Planning Commission (LEPC) which could be used in the planning
                           and responding to potential chemical emergencies. The facility also
                           agreed to participate in LEPC activities and to provide  technical
                           assistance.
September 1995
101
SIC 281

-------
Sector Notebook Project
                      Inorganic Chemicals

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i 1 •" 1 ^ I
^a>° 8 « J
13 ^ 4-! S 3s*
1 ^'1 § ^' 'i
S (§ CO CO ^ ^
 September 1995
102
SIC 281

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Sector Notebook Project
                          Inorganic Chemicals
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

                     This section highlights the activities undertaken by this industry sector and
                     public  agencies to  voluntarily  improve  the sector's  environmental
                     performance.   These activities include those  independently initiated by
                     industrial trade associations.  In this section, the notebook also contains a
                     listing and description of national and regional trade associations.

VIII.A. Sector-related Environmental Programs and Activities

                     None identified.

VIII.B. EPA Voluntary Programs

33/50 Program

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

                     The inorganic chemicals industry as a whole used, generated or processed
                     almost all of the seventeen target TRI chemicals. Of the target chemicals,
                     chromium and chromium compounds, lead and lead compounds, and nickel
                     and nickel compounds are released and  transferred most frequently and in
                     similar quantities. These three toxic chemicals account for about nine percent
                     of TRI releases and transfers from inorganic chemical facilities. Seventy-five
                     companies, representing 168 facilities, listed under SIC  281 (inorganic
                     chemicals) are currently participating in the 33/50 program. This accounts
                     for 30 percent of the facilities reporting to  SIC code 281 to TRI which is
                     significantly higher  than the average  for all industries  of 14 percent
                     participation. (Contact: Mike Burns, 202-260-6394 or the  33/50 Program
                     202-260-6907)
September 1995
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                      Inorganic Chemicals
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)
Parent Company
3M MINNESOTA MINING & MFG CO.
AIR PRODUCTS AND CHEMICALS
AKZO NOBEL INC.
ALBEMARLE CORP.
ALLIED-SIGNALING.
ASHLAND OIL INC.
B F GOODRICH COMPANY
BASF CORP.
BENJAMIN MOORE & CO.
BORDEN CHEM & PLAS LTD PARTNR
CABOT CORP.
CALGON CARBON CORP.
CIBA-GEIGY CORP.
CITGO PETROLEUM CORP.
CONKLIN COMPANY INC.
CORNING INC.
CRITERION CATALYST LTD PARTNR
CYTEC INDUSTRIES
DEGUSSA CORP.
DOW CHEMICAL COMPANY
E 1. DU PONT DE NEMOURS & CO.
OAGLE CHEMICALS INC.
EAGLE-PICHER INDUSTRIES INC.
ELFAQUITA1NEINC.
ENGELHARD CORP.
ETHYL CORP.
FERRO CORP.
FMCCORP.
GENERAL ELECTRIC COMPANY
GEORGIA GULF CORP.
GEORGIA-PACIFIC CORP.
HANLIN GROUP INC.
IIM ANGLO-AMERICAN LTD.
HOECHST CELANESE CORP.
INTERNATIONAL PAPER COMPANY
ISK AMERICAS INC.
KEMIRA HOLDINGS INC.
KERR-MCGEECORP.
LAIDLAW ENVIRONMENTAL
SERVICES
LAROCHE HOLDINGS INC.
City, State
ST. PAUL, MN
ALLENTOWN, PA
CHICAGO, IL
RICHMOND, VA
MORRISTOWN, NJ
RUSSELL, KY
AKRON, OH
PARSIPPANY, NJ
MONTVALE, NJ
COLUMBUS, OH
BOSTON, MA
PITTSBURGH, PA
ARDSLEY, NY
TULSA, OK
SHAKOPEE, MN
CORNING, NY
HOUSTON, TX
WEST PATERSON, NJ
RIDGEFIELD PARK,
NJ
MIDLAND, MI
WILMINGTON, DE
HAMILTON, OH
CINCINNATI, OH
NEW YORK, NY
ISELIN,NJ
RICHMOND, VA
CLEVELAND, OH
CHICAGO, IL
FAIRFIELD, CT
ATLANTA, GA
ATLANTA, GA
EDISON, NJ
NEW YORK, NY
SOMERVILLE, NJ
PURCHASE, NY
SAN FRANCISCO, CA
SAVANNAH, GA
OKLAHOMA CITY.
OK
COLUMBIA, SC
ATLANTA, GA
SIC Codes
Reported
2821, 2816,2899
2819, 2869
2819, 2869
2869, 2819
2819, 2869
2819
2812, 2821, 2869
2869, 2865, 2819
2851,2812,
2813,2821,2869
3339,2819
2819
2819, 2865, 2869
2911,2819,2869
2819, 2952, 2992
3339,2819
28190
2819,2869
2819, 2869, 2879
2800, 2819, 2821
2816
2899, 2819, 2841
2816
2812
3714,2819
2869, 2819,
2819, 2869
2812,2819
2821, 2812, 2869
2865,2812,2819
2611,2621,2812
2812,2819
2816
2819, 2869, 2873
28190
2879, 2819
2816,2819
2819
2819,2869
2812, 2869
#of
Participat-
ing
Facilities
1
5
1
1
4
1
1
1
7
1
2
1
2
1
1
1
3
2
1
4
9
1
1
7
6
1
5
4
2
1
1
3
4
1
1
2
1
3
1
1
1993 Releases
and
Transfers
(Ibs.)
16,481,098
144,876
930,189
1,005,108
2,080,501
723,562
621,207
1,157,548
20,635
12,662
2,407,581
14,845
1,875,028
1,164,354
2,977
1,521,528
3,716
1,074,646
676,418
2,769,363
11,740,853
500
227,242
273,274
236,302
251,519
165,529
502,318
5,010,856
39,480
2,722,182
6,174
1,265,741
2,603,661
2,784,83 1
300,088
394,070
374,098
8,167
81,470
% Reduction
1988 to 1993
70
50
13
51
50
50
50
50
*
***
50
50
50
20
*
14
*
50
***
50
50
33
50
43
50
46
50
50
50
80
50
75
2
50
50
50
*
35
***
*
September 1995
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                       Inorganic Chemicals
Parent Company
MALLINCKRODT GROUP INC.
MAYO CHEMICAL CO. INC.
MILES INC.
MOBIL CORP.
MONSANTO COMPANY
MORTON INTERNATIONAL INC.
NALCO CHEMICAL COMPANY
OCCIDENTAL PETROLEUM CORP.
OLIN CORP.
PHILLIPS PETROLEUM COMPANY
PPG INDUSTRIES INC.
PQ CORP.
PROCTER & GAMBLE COMPANY
RHONE-POULENC INC.
ROHM AND HAAS COMPANY
SHELL PETROLEUM INC.
SHEPHERD CHEMICAL CO.
SHERWIN-WILLIAMS COMPANY
STANDARD CHLORINE CHEM. CO.
STAR ENTERPRISE
STERLING CHEMICALS INC.
SUD-CHEMIE NORTH AMERICA DE
TEXACO INC.
TEXAS INSTRUMENTS INC.
UNILEVER UNITED STATES INC.
UNIROYAL CHEMICAL CORP.
UNOCAL CORP.
UOP
US DEPARTMENT OF ENERGY
VELSICOL CHEMICAL CORP.
VISTA CHEMICAL COMPANY
VULCAN MATERIALS COMPANY
W R GRACE & CO INC.
WEYERHAEUSER COMPANY
WITCO CORP.
City, State
SAINT LOUIS, MO
SMYRNA, GA
PITTSBURGH, PA
FAIRFAX, VA
SAINT LOUIS, MO
CHICAGO, IL
NAPERVILLE, IL
LOS ANGELES, CA
STAMFORD, CT
BARTLESVILLE, OK
PITTSBURGH, PA
VALLEY FORGE, PA
CINCINNATI, OH
MONMOUTH
JUNCTION, NJ
PHILADELPHIA, PA
HOUSTON, TX
CINCINNATI, OH
CLEVELAND, OH
KEARNY, NJ
HOUSTON, TX
HOUSTON, TX
LOUISVILLE, KY
WHITE PLAINS, NY
DALLAS, TX
NEW YORK, NY
MIDDLEBURY, CT
LOS ANGELES, CA
DBS PLAINES, IL
WASHINGTON, DC
ROSEMONT, IL
HOUSTON, TX
BIRMINGHAM, AL
BOCA RATON, FL
TACOMA, WA
NEW YORK, NY
SIC Codes
Reported
2869,2833,2819
2819
2819
2869,2819,2821
2865, 2869, 2819
2819, 2869
2899,2819,2843
2812,2819
2819
2911,2819
2812, 2816, 2869
2819
28190
2821,2819,2841
2819,2869
2869,2819
2819,2869
2816,2851
2865,2819
2911,2819,4463
2869, 2865, 2819
2819
2869,2865,2819
3674,3812,2819
2819
2821, 2879, 2813
2819
2819,2869
2819
2865, 2819, 2869
2869, 2865, 2819
2869, 2812
2819
2621,2611,2812
2819,2869
#of
Participat-
ing
Facilities
3
2
3
1
3
1
2
8
4
2
3
3
1
6
1
1
1
1
1
1
1
2
1
2
1
1
1
2
4
1
2
2
2
1
1
1993 Releases
and
Transfers
(Ibs.)
775,206
15
1,095,504
4,263,284
1,683,580
721,216
107,651
8,896,126
574,673
2,367,877
2,772,33 1
19
612,520
1,437,778
1,210,244
3,240,716
828
1,352,412
48,246
601,640
182,216
196,438
514,803
344,225
164,034
1,970,357
238,520
14,169
148,198
224,664
106,497
679,566
615,509
1,006,356
327,611
% Reduction
1988 to 1993
50
67
40
50
23
20
50
19
70
50
50
50
*
50
50
55
72
50
***
50
65
16
50
25
50
20
50
50
50
50
50
85
50
*
50
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Source: U.S. EPA, Toxic Release Inventory, 1993.
September 1995
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                         Inorganic Chemicals
Environmental Leadership Program
Project XL
                    The Environmental Leadership Program (ELP) is a national initiative piloted
                    by EPA  and  state agencies in which facilities  have volunteered to
                    demonstrate  innovative  approaches to  environmental management and
                    compliance.  EPA has selected 12 pilot projects at industrial facilities and
                    federal installations which  will demonstrate the principles of the ELP
                    program.  These principles include: environmental management systems,
                    multimedia compliance assurance, third-party verification of compliance,
                    public measures of accountability, community involvement, and mentoring
                    programs. In return  for participating,  pilot participants receive  public
                    recognition and are given a period of time to correct violations discovered
                    during these experimental projects.  Forty  proposals were received from
                    companies, trade  associations, and federal facilities representing many
                    manufacturing and service sectors.  Two chemical companies (Ciba Geigy
                    of St. Gabriel, LA and Akzo Chemicals of Edison, NJ), one pharmaceutical
                    manufacturer (Schering Plough of Kenilworth, NJ), and one manufacturer of
                    agricultural chemicals (Gowan Milling of Yuma, AZ) submitted proposals.
                    (Contact:  Tai-ming Chang, ELP Director, 202-564-5081 or Robert Fentress
                    202-564-7023)
                     Project XL was initiated in March 1995 as a part of President Clinton's
                     Reinventing Environmental Regulation initiative.   The projects  seek to
                     achieve cost effective environmental benefits by allowing participants to
                     replace or modify existing regulatory requirements on the condition that they
                     produce greater environmental benefits.  EPA and program participants will
                     negotiate and sign a final Project Agreement, detailing specific objectives
                     that the  regulated entity shall satisfy.  In exchange, EPA will allow the
                     participant a certain degree of regulatory flexibility and may seek changes in
                     underlying  regulations or statutes.  Participants are encouraged  to  seek
                     stakeholder support from local governments, businesses, and environmental
                     groups.  EPA hopes to implement fifty pilot projects in four categories
                     including facilities, sectors, communities, and government agencies regulated
                     by EPA.  Applications will be accepted on a rolling basis and projects will
                     move to implementation within six months of their selection.  For additional
                     information regarding XL Projects, including application procedures  and
                     criteria,  see the May 23, 1995 Federal Register Notice.  (Contact:  Jon
                     Kessler, Office of Policy Analysis, 202-260-4034)
Green Lights Program
                     EPA's Green Lights program was initiated in 1991 and has the goal of
                     preventing pollution by encouraging U.S. institutions to use energy-efficient
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                          Inorganic Chemicals
                     lighting technologies.   The program has over 1,500 participants which
                     include major corporations; small and medium sized businesses; federal, state
                     and local governments; non-profit groups; schools; universities; and health
                     care facilities.  Each participant is required to survey their facilities and
                     upgrade lighting wherever it is profitable. EPA provides technical assistance
                     to the participants through a decision support software package, workshops
                     and manuals, and a financing registry.  EPA's Office of Air and Radiation is
                     responsible for operating the Green Lights Program. (Contact: Maria Tikoff
                     202-233-9178 or the Green Light/Energy Star Hotline, 202-775-6650)
 WasteWiSe Program
                     The WasteWi$e Program was started in 1994 by EPA's Office of Solid
                     Waste and  Emergency Response.  The program is aimed at reducing
                     municipal  solid  wastes by  promoting  waste minimization, recycling
                     collection, and the manufacturing and purchase of recycled products.  As of
                     1994, the program had about 300 companies as members, including a number
                     of major corporations. Members agree to identify and implement actions to
                     reduce their solid wastes and must provide EPA with their waste reduction
                     goals along with yearly progress reports.  EPA, in turn, provides technical
                     assistance to member companies and allows the use of the Waste Wi$e logo
                     for promotional purposes.  (Contact: Lynda Wynn 202-260-0700 or the
                     WasteWi$e Hotline, 800-372-9473)
Climate Wise Recognition Program
                    The Climate Change Action Plan was initiated  in response to the U.S.
                    commitment to reduce greenhouse gas emissions in accordance with the
                    Climate Change Convention of the 1990 Earth Summit.  As part of the
                    Climate Change Action Plan, the Climate Wise Recognition Program is a
                    partnership initiative run jointly by EPA and the Department of Energy.  The
                    program is designed to reduce greenhouse gas emissions  by encouraging
                    reductions across all sectors of the economy, encouraging participation in the
                    full  range of Climate  Change  Action  Plan initiatives, and  fostering
                    innovation. Participants in the program are required to identify and commit
                    to actions that reduce greenhouse gas emissions. The program, in turn, gives
                    organizations early recognition for their reduction commitments; provides
                    technical assistance through consulting services, workshops,  and guides; and
                    provides access to the program's centralized information system.  At EPA,
                    the program is operated by the Air and Energy Policy Division within the
                    Office of Policy Planning and Evaluation. (Contact: Pamela Herman 202-
                    260-4407)
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                         Inorganic Chemicals
NICE3
                    The U.S. Department of Energy and EPA's Office of Pollution Prevention
                    are jointly administering a grant program called The National Industrial
                    Competitiveness through Energy, Environment, and Economics (NICE3). By
                    providing grants of up to 50 percent of the total project cost, the program
                    encourages industry to reduce industrial waste at its source and become more
                    energy-efficient and cost-competitive through waste minimization efforts.
                    Grants are used by industry to design, test, demonstrate,  and assess the
                    feasibility of new processes and/or equipment with the potential to reduce
                    pollution and  increase energy efficiency.  The program  is open  to all
                    industries; however, priority is given to proposals from participants in the
                    pulp and paper, chemicals, primary metals, and petroleum and coal products
                    sectors. (Contact: DOE's Golden Field Office, 303-275-4729)
VIH.C. Trade Association/Industry Sponsored Activity

       VIII.C.l. Environmental Programs

       Global Environmental Management Initiative
                    The Global Environmental Management Initiative (GEMI) is made up of a
                    group of leading companies dedicated to fostering environmental excellence
                    by business. GEMI promotes a worldwide business ethic for environmental
                    management and sustainable development to improve the environmental
                    performance of business through example and leadership.  In 1994, GEMFs
                    membership consisted of about 30 major corporations including Amoco
                    Corporation.
       National Pollution Prevention Roundtable
                    The National  Pollution Prevention Roundtable  published The  Pollution
                    Prevention Yellow Pages in September  1994.   It is a compilation of
                    information collected from mail and telephone surveys of state and local
                    government pollution prevention programs. (Contact: Natalie Roy 202-543-
                    7272)  The following state programs listed themselves as having expertise in
                    pollution prevention related to inorganic chemical manufacture and use. The
                    contacts listed below (Exhibit 27) are also likely to be aware of various state-
                    and local-level initiatives affecting the inorganic chemical industry.
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Exhibit 27: Contacts for State and Local Pollution Prevention Programs
State
Alabama
California
Colorado
Illinois
Indiana
Iowa
Kentucky
Massachusetts
Michigan
New Mexico
North Dakota
Ohio
Pennsylvania
Rhode Island
South
Carolina
Texas
Vermont
Washington
Wisconsin
Wyoming
Program
AL Dept. of Env. Protection, Ombudsman and
Small Business Assistance Program
AL WRATT Foundation
CA State Dept. of Toxic Substances Control
County Sanitation Districts of LA
Region VIII HW Minimization Program
IL HW Research and Information Center
IN Dept. of Env. Mgmt.
I A Dept. of Natural Resources
KY Partners, State Waste Reduction Center
Toxics Use Reduction Institute
University of Detroit Mercy
Waste Management Education and Research
Consortium
Energy and Env. Research Center
Institute of Advanced Manufacturing Sciences
Center for Hazardous Materials Research
RI Center for P2, URI
Clemson University
TX Natural Resource Conservation Commission
Retired Engineers and Professionals Program
WA State Dept. of Ecology
WI Dept. of Natural Resources,
Small Business Assistance Program
WY Dept. of Env. Quality
Contact
Blake Roper,
Michael Sherman
Roy Nicholson
David Harley, Kim
Wilhelm, Kathy
Barwick
Michelle Mische
Marie Zanowich
David Thomas
Tom Neltner
Larry Gibson
Joyce St. Clair
Janet Clark
Daniel Klempner
Ron Bhada
Gerald
Groenewold
Harry Stone, Sally
Clement
Roger Price,
Steven Ostheim
Stanley Barnett
Eric Snider
Andrew Neblett
Muriel Durgin
Peggy Morgan
Robert Baggot
Charles Raffelson
Telephone
(800) 533-2336
(205) 271-7861
(205) 386-3633
(916) 322-3670
(310)699-7411
(303) 294-1065
(217)333-8940
(317)232-8172
(515)281-8941
(502) 852-7260
(508) 934-3346
(313)993-3385
(505)646-1510
(701)777-5000
(513)948-2050
(412) 826-5320
(401) 792-2443
(803) 656-0985
(512)239-3100
(802) 879-4703
(206) 407-6705
(608)267-3136
(307) 777-7391
September 1995
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                        Inorganic Chemicals
       Center for Waste Reduction Technologies

                    Center for Waste Reduction Technologies, under the aegis of the American
                    Institute  of  Chemical Engineers,  sponsors  research  on  innovative
                    technologies to reduce waste in the chemical processing industries.  The
                    primary mechanism is through funding of academic research.

       National Science Foundation and the Office of Pollution Prevention and Toxics

                    The National Science Foundation and EPA's Office of Pollution Prevention
                    and Toxics signed an agreement in January of 1994 to coordinate the two
                    agencies' programs of basic research related to pollution prevention.  The
                    collaboration will stress research in the use of less toxic chemical and
                    synthetic feedstocks, use of photochemical processes instead of traditional
                    ones that employ toxic reagents, use of recyclable catalysts to reduce metal
                    contamination, and use of natural feedstocks when synthesizing chemicals
                    in large quantities.

       Chemical Manufacturers Association

                    The Chemical Manufacturers Association funds research on issues of
                    interest to their members  particularly  in support  of their positions on
                    proposed or  possible legislation.   They  recently funded a study to
                    characterize the environmental fate of organochlorine compounds.

       Responsible Care  Program

                    The Responsible Care Program of the Chemical Manufacturers Association
                    requires  members to pledge commitment to six codes that identify 106
                    management practices that companies must carry out in the areas of
                    community awareness and emergency response, pollution prevention, process
                    safety, distribution, employee health and safety, and product stewardship.
       ISO 9000
                     ISO 9000 is a series of international total quality management guidelines.
                     After a successful independent audit of their management plans, firms are
                     qualified to be ISO 9000 registered.  In June of 1993, the International
                     Standards Organization created a technical committee to begin work on new
                     standards for environmental management systems.  The new standards are
                     called ISO 14000 and are expected to be issued in 1996.
 September 1995
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                          Inorganic Chemicals
       VII.C.2. Summary of Trade Associations

 Chemical Industry
                    American Chemical Society
                    1155 16th Street, NW
                    Washington, D.C. 20036
                    Phone: (202) 872-8724
                    Fax: (202) 872-6206
                   Members: 145,000
                   Staff: 1700
                   Budget: $192,000,000
                    The American Chemical Society (ACS) has an educational and research
                    focus.  The ACS produces approximately thirty different industry periodicals
                    and research journals, including Environmental Science and Technology and
                    Chemical Research in Toxicology.  In addition to publishing, the ACS
                    presently conducts studies and surveys; legislation monitoring, analysis, and
                    reporting; and operates a variety of educational programs. The ACS library
                    and on-line information services are extensive.  Some available on-line
                    services are ChemicalJournals Online, containing the full text of 18 ACS
                    journals,  10 Royal Society of Chemistry journals, and five polymer journals,
                    and the Chemical Abstracts Service (CAS), which provides a variety of
                    information on chemical compounds. Founded in 1876, the ACS is presently
                    comprised of 184 local groups and 843 student groups nationwide.
                    Chemical Manufacturers Association
                    2501 M St., NW
                    Washington, D.C. 20037
                    Phone:(202)887-1164
                    Fax: (202) 887-1237
                    Members: 185
                    Staff: 246
                    Budget: $36,000,000
                    Contact: Joseph Mayhew
                    Presently, the principle focus of the Chemical Manufacturers Association
                    (CMA) is on regulatory issues facing chemical manufacturers at the local,
                    state, and federal level. At its inception in 1872, the focus of the CMA was
                    on serving  chemical manufacturers through  research.  Research  is still
                    ongoing at  the CMA, however, as the CHEMSTAR program illustrates.
                    CHEMSTAR consists of a variety of self-funded panels working on single-
                    chemical research agendas.  This research fits in with the overall regulatory
                    focus of the CMA; CHEMSTAR study results are provided to both CMA
                    membership and  regulatory  agencies.    Other initiatives  include the
                    "responsible care" program. Membership in the CMA is contingent upon
                    enrollment in the "responsible  care" program,  which includes six codes of
                    management practice (including pollution prevention) that  attempt to "go
                    beyond simple regulatory compliance."  The CMA also conducts workshops
                    and technical symposia, promotes in-plant safety, operates a chemical
                    emergency  center  (CHEMTREC) which offers  guidance in chemical
                    emergency  situations,  and  operates the  Chemical Referral Center which
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                         Inorganic Chemicals
                    provides chemical health and safety information to the public. Publications
                    include:   ChemEcology,   a   10-issue-per-year   newsletter   covering
                    environmental, pollution-control, worker-safety,  and federal  and state
                    regulatory  actions, and the CMA Directory,  a  listing  of the CMA
                    membership. The CMA holds an annual meeting in White Sulphur Springs,
                    WV.
Chlor-alkali Industry
                    The Chlorine Institute, Inc.
                    2001 L Street, N.W.
                    Suite 506
                    Washington, D.C. 20036
                    Phone: (202) 223-2790
                    Fax: (202) 223-7225
                    Members: 200
                    Budget: $1,500,000
                    Contact: Gary Trojak
                    The Chlorine  Institute,  Inc.  was  established  in 1924  and  represents
                    companies in the U.S., Canada, and other countries that produce, distribute,
                    and use  chlorine,  sodium  and  potassium  hydroxides,  and  sodium
                    hypochlorite; and that distribute and use hydrogen chloride. The Institute is
                    a non-profit scientific and technical organization which serves as a safety,
                    health, and environmental protection center for the industry.
                    Chlorine Chemistry Council
                    2501 M Street, N.W.
                    Washington, D.C. 20037
                    Phone:(202)887-1100
                    Fax: (202) 887-6925
                   Members: 30
                   Staff: 24
                   Budget: $14,000,000
                   Contact: Kip Hewlett Jr.
                    The Chlorine Chemistry Council (CCC), established in 1993, is a business
                    council of the Chemical Manufacturers Association (CMA) and is made up
                    of producers and users of chlorine and chlorine-related products.  With
                    involvement from all stakeholders, the CCC works to promote science-based
                    public policy regarding chlorine chemistry and is committed to develop and
                    produce only those chemicals that can be manufactured, transported, used,
                    and disposed of safely.  CCC facilitates risk-benefit analyses and product
                    stewardship through the collection, development,  and use of scientific data
                    on health, safety, and environmental issues. CCC hopes to heighten public
                    awareness of  chlorine  chemistry  and  its many  societal  benefits by
                    collaborating with the public health and scientific community in assessing
                    and communicating chlorine-related human health  and environmental issues.
September 1995
112
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 Sector Notebook Project
                           Inorganic Chemicals
 IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY

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

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

1992 Census of Manufacturers, Preliminary Report Industry Series, Industrial Inorganic Chemicals,
Bureau of the Census [Data will be superseded by a more comprehensive report in September of
1994]
f Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements make within this notebook.
September 1995
113
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Sector Notebook Project
                        Inorganic Chemicals
Chlorine and Its Derivatives: A World Survey of Supply, Demand, and Trade to 1992, Tecnon
Consulting Group, London, 1988.

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

Process Descriptions and Chemical Use Profiles	

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

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

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

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

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

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

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

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

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

Regulatory Profile	

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

Development Document for Effluent Limitations Guidelines and New Source Performance Standards
for the Major Inorganic Products Segment of the Inorganic Chemicals Point Source Category, U.S.
Environmental Protection Agency, Washington, D.C., March 1974. Report No. EPA-440/l-74-007a.
September 1995
114
SIC 281

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 Sector Notebook Project
                          Inorganic Chemicals
                                     ENDNOTES

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

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

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

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

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

 6. Ibid.

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

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

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

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

 11. Ibid.

 12. Ibid.

 13. Ibid.

 14. Ibid.

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

 16. Biichner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry. New York- VCH
Publishers, 1989.

 17. Ibid.

 18. Ibid.
September 1995
115
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Sector Notebook Project
                        Inorganic Chemicals
19. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and
Sons, 1994.

20. Btichner, Schliebs, Winter, Biichel. Industrial Inorganic Chemistry. New York: VCH
Publishers, 1989.

21. Ibid.

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

23. Ibid.

24. Ibid.

25. Ibid.

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

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

28. Ibid.

29. Ibid.

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

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

32. Ibid.

33. Ibid.

34. Ibid.

35. Ibid.

36. Ibid.

37. Ibid.

38. Ibid.
 September 1995
116
SIC 281

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

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

 41.  Ibid.

 42.  Ibid.

 43.  Ibid.

 44.  Ibid.

 45.  Ibid.

 46.  Ibid.

 47.  Ibid.

 48.  Ibid.

 49.  Ibid.

 50.  Ibid.

 51.  Ibid.

 52.  Ibid.

 53.  Ibid.

 54.  Ibid.

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

 56. Ibid.

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

 58. Ibid.

 59. Ibid.
September 1995
117
SIC 281

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                                APPENDIX A
       INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK

          Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web.  The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics.  The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.

ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB

      To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
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      Or after 1997, (when EPA plans to have completed a restructuring of its web site) set
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      WWW.epa.gOV/OeCa -  then select the button labeled Gov't and Business
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      HOTLINE NUMBER FOR E|WWW:  208-526-6956

      EPA E$WWW MANAGERS: Louis Paley 202-564-2613
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(This page updated June 1997)
Appendix A

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