United .States :>,,-^"*;
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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
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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
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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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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
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Inorganic Chemicals
Exhibits Index
Exhibit 1: Inorganic Chemicals Industry Dominated by a Large Number of Small Facilities 6
Exhibit 2: Inorganic Chemicals Facilities Distribution .6
Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast, Southeast, Northwest,
and Great Lakes Region 8
Exhibit 4: Top U.S. Companies with Inorganic Chemical Manufacturing Operations 9
Exhibit 5: Chlorine Electrolysis Cells 15
Exhibit 6: Main Characteristics of the Different Electrolysis Processes 16
Exhibit 7: Mercury Electrolysis Cell and Flow Diagram 17
Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram 19
Exhibit 9: Typical Membrane Electrolysis Cell 21
Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry
(SIC 281) as Reported within TRI 30
Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
by Number of Facilities Reporting 36
Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI,
by Number of Facilities Reporting 39
Exhibit 13: Top 10 TRI Releasing Inorganic Chemicals Facilities 42
Exhibit 14: Top 10 TRI Releasing Facilities Reporting Inorganic Chemical SIC Codes to TRI ... 43
Exhibit 15: Pollutant Releases (short tons/year) 48
Exhibit 16: Summary of 1993 TRI Data: Releases and Transfers by Industry 51
Exhibit 17: Toxics Release Inventory Data for Selected Industries 52
Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities 57
Exhibit 19: Modifications to Equipment Can Also Prevent Pollution . 66
Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic
Chemicals Manufacturing 94
Exhibit 21: Five-Year Enforcement and Compliance Summary for Selected Industries 96
Exhibit 22: One-Year Inspection and Enforcement Summary for Selected Industries 97
Exhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 98
Exhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected Industries . . 99
Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview:
Inorganic Chemical Manufacture 102
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals) 104
Exhibit 27: Contacts for State and Local Pollution Prevention Programs 109
September 1995
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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
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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
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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
September 1995
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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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Inorganic Chemicals
Exhibit 1: Inorganic Chemicals Industry Dominated
by a Large Number of Small Facilities
Employees
per Facility
1-9
10-19
20-49
50-249
250-999
1,000->2,500
Total
Inorganic Chemicals
Number
of Facilities
682
212
253
221
51
10
1,429
Percentage
of Facilities
48%
15%
18%
15%
3%
1%
100%
Chlor-alkali
Number of
Facilities
12
6
3
23
6
1
51
Percentage
of Facilities
24%
12%
6%
44%
12%
2%
100%
Source: Bureau of the Census, 1992 Census of Manufacturers.
Inorganic chemical facilities are typically located near consumers and to a
lesser extent raw materials. The largest use of inorganic chemicals is in
industrial processes for the manufacture of chemicals and nonchemical
products; therefore, facilities are concentrated in the heavy industrial regions
along the Gulf Coast, both east and west coasts, and the Great Lakes region.
Since a large portion of inorganic chemicals produced are used by the
organic chemicals manufacturing industry, the geographical distribution of
inorganic facilities is very similar to that of organic chemicals facilities
(Exhibit 2).
September 1995
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Inorganic Chemicals
Exhibit 2: Inorganic Chemicals Facilities Distribution
0 100 200 300 400
(Source: U.S. EPA Toxic Release Inventory Database, 1993)
Chlor-alkali Sector
The alkali and chlorine industry, however, consists of a relatively small
number of medium to large facilities. The Bureau of the Census identified 34
companies operating 51 facilities within the SIC 2812 in 1992. According to
The Chlorine Institute (an industry trade group), there were 25 companies
operating 52 chlorine production plants in 1989. The Bureau of Census
employment data for 1992 indicated that about 60 percent of those employed
in the chlor-alkali industry worked at facilities with over 50 employees
(Exhibit I).7'8
The distribution of the chlor-alkali sector differs from that of the inorganic
chemicals industry as a whole. Since chlorine and caustic soda are co-
products produced in almost equal amounts, the distribution of the caustic
soda manufacturing industry is essentially the same as the chlorine
manufacturing industry. Chlorine is difficult to store and transport
economically; therefore, chlorine and caustic soda are produced near the
September 1995
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Inorganic Chemicals
chlorine consumers which are primarily chemical manufacturers and pulping
operations. Consequently, chlor-alkali facilities are concentrated near the
chemical industries along the Gulf Coast, followed by the Great Lakes region
as shown in the table below. Other important areas are in the vicinity of the
pulp mills of the Southeast and Northwest (Exhibit 3). In 1989, almost half
of the chlorine plants in the U.S. (72 percent of domestic chlorine production)
were located along the Gulf Coast. Two states, Louisiana and Texas,
accounted for two-thirds of the domestic chlorine production.9
Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast,
Southeast, Northwest, and Great Lakes Region
State
Louisiana
Texas
New York
Alabama
Washington
West Virginia
Georgia
Tennessee
Other States (14)
U.S. Total
Number of
Chlorine Plants
9
5
4
5
4
2
3
1
19
52
Annual Capacity
(thousand tons
per year)
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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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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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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Inorganic Chemicals
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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Inorganic Chemicals
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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Inorganic Chemicals
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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Inorganic Chemicals
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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Inorganic Chemicals
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.
September 1995
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Inorganic Chemicals
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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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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Inorganic Chemicals
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Inorganic Chemicals
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Sector Notebook Project
Inorganic Chemicals
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September 1995
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SIC 281
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Sector Notebook Project
Inorganic Chemicals
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September 1995
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SIC 281
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Inorganic Chemicals
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September 1995
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Sector Notebook Project
Inorganic Chemicals
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September 1995
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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.
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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).
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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
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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
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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.
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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.
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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).
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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.
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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
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Inorganic Chemicals
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September 1995
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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
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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
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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,
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reverse osmosis, and improved distillation, evaporation, and dewatering can
often be added to existing treatment systems. Wastewater streams containing
acids or metals can be concentrated enough to be sold commercially as a
product by slightly altering the manufacturing process, adding processing
steps, and segregating wastewater streams. Furthermore, many wastewater
streams can be reused within the same or different processes, significantly
reducing discharges to the wastewater treatment system. An ion exchange
system installed in a mercury cell chlor-alkali plant reduced mercury by 99
percent in the facility's effluent. An inorganic chemicals plant making
photochemistry solution generated a wastewater containing silver.
Electrolytic cells were installed that recovered 98 percent of the silver and an
evaporator was added that concentrated the remaining liquid for disposal
resulting in a 90 percent reduction in waste volume.
Prevent leaks and spills. The elimination of sources of leaks and spills can
be a very cost effective pollution prevention opportunity. Leaks and spills
can be prevented by installing seamless pumps and other "leakless"
components, maintaining a preventative maintenance program, and
maintaining a leak detection program.
Improve inventory management and storage. Good inventory
management can reduce the generation of wastes by preventing materials
from exceeding their shelf life, preventing materials from being left over or
not needed, and reducing the likelihood of accidental releases of stored
material. Designating a materials storage area, limiting traffic through the
area, and giving one person the responsibility to maintain and distribute
materials can reduce materials use, and the contamination and dispersal of
materials.
Exhibit 18 summarizes the above pollution prevention opportunities and
provides additional examples provided by the Chemical Manufacturers
Association.
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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.
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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.
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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.
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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.
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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.
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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.
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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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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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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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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
September 1995
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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
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).
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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).
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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.
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VILA. Inorganic Chemical Industry Compliance History
Exhibit 20 provides an overview of the reported compliance and enforcement
data for the inorganic chemical industry over the past five years (August
1990 to August 1995). These data are also broken out by EPA Region
thereby permitting geographical comparisons. A few points evident from the
data are listed below.
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.
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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
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Inorganic Chemicals
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September 1995
SIC 281
-------
Sector Notebook Project
Inorganic Chemicals
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Sector Notebook Project
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-------
Sector Notebook Project
Inorganic Chemicals
VII.C. Review of Major Legal Actions
Major Cases/Supplemental Environmental Projects
This section provides summary information about major cases that have
affected this sector, and a list of Supplementary Environmental Projects
(SEPs). SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
VII.C.1. Review of Major Cases
Historically, OECA's Enforcement Capacity and Outreach Office does not
regularly compile information related to major cases and pending litigation
within an industry sector. The staff are willing to pass along such
information to Agency staff as requests are made. In addition, summaries of
completed enforcement actions are published each fiscal year in the
Enforcement Accomplishments Report. To date, these summaries are not
organized by industry sector. (Contact: Office of Enforcement Capacity and
Outreach 202-260-4140)
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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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
103
SIC 281
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Sector Notebook Project
Inorganic Chemicals
Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)
Parent Company
3M MINNESOTA MINING & 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
104
SIC 281
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Sector Notebook Project
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
105
SIC 281
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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
September 1995
106
SIC 281
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Sector Notebook Project
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)
September 1995
107
SIC 281
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Sector Notebook Project
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.
September 1995
108
SIC 281
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Sector Notebook Project
Inorganic Chemicals
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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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.
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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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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.
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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
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Chlorine and Its Derivatives: A World Survey of Supply, Demand, and Trade to 1992, Tecnon
Consulting Group, London, 1988.
North American Chlor-Alkali Industry Plants and Production Data Book, Pamphlet 10, The
Chlorine Institute, Washington, D.C., January, 1989.
Process Descriptions and Chemical Use Profiles
Riegel's Handbook of Industrial Chemistry, 9th ed., Kent, James A., Ph.D., editor, Van Nostrand
Reinhold, New York, 1993.
Kirk-Othmer Encyclopedia of Chemical Technology, Fourth edition, volume 1, John Wiley and
Sons, New York, 1994.
Buchner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry, VCH Publishers, New York,
1989.
Multi-media Assessment of the Inorganic Chemicals Industry, Chapter 12-Salt Derivatives, Prepared
for U.S. EPA Industrial Environmental Research Laboratory by Verser, Inc., Springfield, Virginia,
1980.
Recommendations To Chlor-alkali Manufacturing Facilities for the Prevention of Chlorine
Releases, The Chlorine Institute, First Edition, October, 1990.
Assessment of Solid Waste Management Problems and Practices in the Inorganic Chemicals
Industry, Final Report, Versar, Inc. for U.S. Environmental Protection Agency, Industrial
Environmental Research Laboratory, Cincinnati, Ohio, April 1979.
Chlorine, Its Manufacture, Properties, and Uses, J.S. Sconce, Reinhold Publishing Corp., New
York, 1962.
Electrolytic Manufacture of Chemicals from Salt, D.W.F. Hardie and W.W. Smith, The Chlorine
Institute, New York, 1975.
Modern Chlor-Alkali Technology, Vol. 4, N.M. Prout and J.S. Moorhouse, eds., Elsevier Applied
Science, 1990.
Regulatory Profile
Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St. Paul, Minn.,
1993.
Development Document for Effluent Limitations Guidelines and New Source Performance Standards
for the Major Inorganic Products Segment of the Inorganic Chemicals Point Source Category, U.S.
Environmental Protection Agency, Washington, D.C., March 1974. Report No. EPA-440/l-74-007a.
September 1995
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ENDNOTES
1. U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.
2. U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers,
Industrial Inorganic Chemicals. April 1995.
3. U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.
4. U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers,
Industrial Inorganic Chemicals. April 1995.
5. 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
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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
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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
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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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