NOTEBOOKS
Profile Of THS
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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
Organic Chemical Industry
EPA/310-R-95-012
EPA Office of Compliance Sector Notebook Project
Profile of the Organic 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 0-16-048279-8
September 1995
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Sector Notebook Project
Organic Chemical Industry
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
9:00 a.m. to 4:30 p.m., Eastern Time, 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 Irid.
*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
Organic Chemical Industry
Industry Sector Notebook Contents: Organic Chemicals
Exhibits Index iii
List of Acronyms iv
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
II. INTRODUCTION TO THE ORGANIC CHEMICALS INDUSTRY 3
A. Introduction, Background, and Scope of the Notebook 3
B. Characterization of the Organic Chemicals Industry ,. 4
1. Industry size and geographic distribution 4
2. Product Characterization 7
3. Economic trends 9
III. INDUSTRIAL PROCESS DESCRIPTION 11
A. Industrial Processes in the Organic Chemicals Industry 11
B. Raw Material Inputs and Pollution Outputs 25
C. Management of Chemicals in the Production Process 26
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 29
A. EPA Toxic Release Inventory for the Organic Chemicals Industry 32
B. Summary of Selected Chemicals Released 44
C. Other Data Sources 47
D. Comparison of Toxic Release Inventory Between Selected Industries 48
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 83
C. Pending and Proposed Regulatory Requirements 85
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VII. COMPLIANCE AND ENFORCEMENT PROFILE 87
A. Organic Chemicals Compliance History 91
B. Comparison of Enforcement Activity Between Selected Industries 93
C. Review of Major Legal Actions 98
1. Review of major cases 98
2. Supplementary Environmental Projects (SEPs) 98
VHI. COMPLIANCE ACTIVITIES AND INITIATIVES 103
A. Sector-related Environmental Programs and Activities 103
B. EPA Voluntary Programs 103
C. Trade Association/Industry Sponsored Activity 110
1, Environmental Programs 110
2. Summary of Trade Associations 112
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 117
Endnotes 127
Appendix A A-l
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Exhibits Index
Exhibit 1: Small Number of Large Facilities Account for Majority of Shipments 5
Exhibit 2: Organic Chemical Manufacturing Facilities (SIC 286) 5
Exhibit 3: Top U.S. Companies with Organic Chemical Operations 7
Exhibit 4: High Volume Organic Chemical Building Blocks 12
Exhibit 5: Organic Chemicals and Building Blocks Flow. Diagram 13
Exhibit 6: Reaction/Process Types by Chemical Category for a Sampling
of Organic Chemicals 14
Exhibit 7: Distribution of Uses for Ethylene 17
Exhibit 8: Manufacturing Processes Using Ethylene 18
Exhibit 9: Distribution of Propylene Use 19
Exhibit 10: Manufacturing Processes Using Propylene 20
Exhibit 11: Distribution of Benzene Use 21
Exhibit 12: Manufacturing Processes Using Benzene 22
Exhibit 13: Manufacturing Processes Using Vinyl Chloride . 24
Exhibit 14: Potential Releases During Organic Chemical Manufacturing 25
Exhibit 15: Source Reduction and Recycling Activity for the Organic
Chemical Industry (SIC 286) as Reported within TRI 27
Exhibit 16: 1993 Releases for Organic Chemical Manufacturing Facilities in TRI,
by Number of Facilities Reporting 34
Exhibit 17: 1993 Transfers for Organic Chemical Manufacturing Facilities in TRI,
by Number of Facilities Reporting 38
Exhibit 18: Top 10 TRI Releasing Organic Chemical Manufacturing Facilities 42
Exhibit 19: Top 10 TRI Releasing Facilities Reporting Organic Chemical
Manufacturing SIC Codes to TRI 43
Exhibit 20: Pollutant Releases (short tons/year) 48
Exhibit 21: Summary of 1993 TRI Data: Releases and Transfers by Industry 50
Exhibit 22: Toxics Release Inventory Data for Selected Industries 51
Exhibit 23: Pollution Prevention Activities Can Reduce Costs 54
Exhibit 24: Process/Product Modifications Create Pollution Prevention Opportunities 56
Exhibit 25: Modifications to Equipment Can Also Prevent Pollution 65
Exhibit 26: Five-Year Enforcement and Compliance Summary for Organic Chemicals 92
Exhibit 27: Five-Year Enforcement and Compliance Summary for Selected Industries 94
Exhibit 28: One-Year Inspection and Enforcement Summary for Selected Industries 95
Exhibit 29: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries 96
Exhibit 30: One-Year Inspection and Enforcement Summary by Statute for Selected Industries 97
Exhibit 31: FY-1993 and 1994 Supplemental Environmental Projects Overview:
Organic Chemical Manufacture 100
Exhibit 32: 33/50 Program Participants Reporting SIC 286 (Organic Chemicals) 104
September 1995
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List of Acronyms
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BEFs - 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
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 Oxides
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
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Sector Notebook Project
Organic Chemical Industry
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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Sector Notebook Project
Organic Chemical Industry
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. Many of those who reviewed this notebook are listed as contacts
in Section IX and may be sources of additional information. The individuals
and groups on this list do not necessarily concur with all statements within this
notebook.
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 if
more in-depth information is available. The contents of each profile were
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Sector Notebook Project
Organic Chemical Industry
researched from a variety of sources, and were usually condensed from more
detailed sources. This approach allowed 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 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 which
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.
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Sector Notebook Project
Organic Chemical Industry
H. INTRODUCTION TO THE ORGANIC CHEMICALS INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
organic chemical 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.
H.A. Introduction, Background, and Scope of the Notebook
The industrial organic chemical sector produces organic chemicals (those
containing carbon) used as either chemical intermediates or end-products.
This categorization corresponds to Standard Industrial Classification (SIC)
code 286 established by the Bureau of Census to track the flow of goods and
services within the economy. The 286 category includes gum and wood
chemicals (SIC 2861), cyclic organic crudes and intermediates, organic dyes
and pigments (SIC 2865), and industrial organic chemicals not elsewhere
classified (SIC 2869). By this definition, the industry does not include
plastics, drugs, soaps and detergents, agricultural chemicals or paints, and
allied products which are typical end-products manufactured from industrial
organic chemicals. In 1993, there were 987 establishments in SIC 286 of
which the largest 53 firms (by employment) accounted for more than 50
percent of the industry's value of shipments. The SIC 286 may include a small
number of integrated firms that are also engaged in petroleum refining and
manufacturing of other types of chemicals at the same site although firms
primarily engaged in manufacturing coal tar crudes or petroleum refining are
classified elsewhere.3
The industrial organic chemical market has two broadly defined categories,
commodity and specialty. Commodity chemical manufacturers compete on
price and produce large volumes of small sets of chemicals using dedicated
equipment with continuous and efficient processing. Specialty chemical
manufacturers cater to custom markets, manufacture a diverse set of
chemicals, use two or three different reaction steps to produce a product, tend
to use batch processes, compete on technological expertise and have a greater
value added to their products. Commodity chemical manufacturers have
lower labor requirements per volume and require less professional labor per
volume.
a Variations in facility counts occur across data sources due to many factors including reporting and definitional differences:
This notebook does not attempt to reconcile these differences, but rather reports the data as they are maintained by each
source.
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Sector Notebook Project
Organic Chemical Industry
The 1992 Census of Manufactures for Industrial Organic Chemicals reports
employment of 124,800 and a 1992 value of shipments of $64.6 billion. This
value of shipments does not include organic chemicals manufactured for
captive use within a facility or the value of other non-industrial organic
chemical products manufactured by the same facility. It does, however,
include intra-company transfers which are significant in this industry. By
comparison, the 1992 value of shipments for inorganic chemicals totaled
$27.3 billion with employment of 103,400 people. The 1992 value of
shipments for the entire chemical industry (SIC 28) was $292.3 billion and
employment totaled 850,000. According to Chemical and Engineering News,
the production of industrial organic chemicals has increased by three percent
per year between 1983 and 1993 while employment has fallen by one percent
per year over the same period indicating an overall increase in productivity for
the sector. The same source reports the industry employed 153,000 people
in 1993 while shipping products valued at $60.9 billion.
The Department of Commerce reported that output in the industrial organic
chemical market grew five percent between 1992 and 1993 and is expected
to continue to grow at the same rate partially on the strength of increased
demand and production of methyl tert-butyl ether, a fuel oxygenate.
H.B. Characterization of the Organic Chemicals Industry
II.B.l. Industry size and geographic distribution
Industrial organic chemical facilities have an unusual distribution when
compared to downstream manufacturing facilities. Most significantly, a small
number of very large facilities account for the majority of the industry's value
of shipments. The 1992 Census of Manufactures (Exhibit 1) showed that
only 113 of the 986 industrial organic chemical facilities (11 percent) had
more than 250 employees. However, these facilities accounted for almost 70
percent of the value of shipments for the industry; the largest 16 plants
(greater than 1,000 employees) accounted for about 25 percent of the total
value of shipments.
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Sector Notebook Project
Organic Chemical Industry
Exhibit 1 : Small Number of Large Facilities
Account for Majority of Shipments
Number of Employees
fewer than 10
10 to 49
50 to 249
250 to 499
500 to 999
1,000 or more
Total
Number of
Facilities
259
301
313
60
37
16
986
Percent of
Facilities
26%
30%
32%
6%
4%
2%
100%
Percent of
Shipment Value
1%
5%
27%
16%
26%
25%
100%
Source: 1992 Census of Manufactures
The industrial organic chemical sector is geographically diverse (Exhibit 2).
Gum and wood chemical manufacture (SIC 2861) is concentrated in Missouri,
Florida and Virginia. Cyclic crudes and intermediates (SIC 2865) and
unclassified industrial organic chemicals (SIC 2869) are concentrated in
Texas, Louisiana, New Jersey, Ohio, Illinois and West Virginia. Facility sites
are typically chosen for their access to raw materials (petroleum and coal
products for SICs 2865 and 2869 and wood for SIC 2861) and to
transportation routes. In addition, because much of the market for industrial
organic chemicals is the chemical industry, facilities tend to cluster near such
end-users.
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Exhibit 2: Organic Chemical Manufacturing Facilities (SIC 286)
(Source: U.S. EPA, Toxics Release Inventory Database, 1993)
Ward's Business Directory of U.S. Private and Public Companies, produced
by Gale Research Inc., compiles financial data on U.S. companies including
those operating within the organic chemical industry. Ward's ranks U.S.
companies, whether they are a parent company, subsidiary or division, by sales
volume within their assigned 4-digit SIC code. 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
subsidiaries and operations (not related to organic chemicals). Additional
sources of company specific financial information include Standard & Poor's
Stock Report Services, Dun & Bradstreet's Million Dollar Directory,
Moody's Manuals, and annual reports.
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Exhibit 3: Top U.S. Companies with
Organic Chemical Operations
Rank"
1
2
3
4
5
6
7
8
9
10
Companyb
Exxon Corp., Exxon Chemical Co. - S. Darien, CT
Dow Chemical USA - Midland, MI
Miles, Inc. - Pittsburgh, PA
Union Carbide Corp. - Danbury, CT
Amoco Chemical Co. - Chicago, EL
Chevron Chemical Co. - San Ramon, CA
Quantum Chemical Corp. - New York, NY
Witco Corp. - New York, NY
Ethyl Corp. - Baton Rouge, LA
Texaco Chemical Co. - Houston, TX
1993 Sales
(millions of dollars)
9,591
9,000
5,130
4,877
4,031
3,354
2,532
1,631
1,600
1,600
Note: a When Ward's Business Directory lists both a parent and subsidiary in the top ten, only
the parent company is presented above to avoid double counting. Not all sales can be
attributed to the companies' organic chemical operations.
b Companies shown listed SIC 286 as primary activity.
Source: Ward's Business Directory of U.S. Private and Public Companies - 1993.
n.B.2. Product Characterization
The two-digit SIC code 28, Chemicals arid Allied Products, includes facilities
classified as industrial organic chemical manufacturers under the three-digit
SIC code 286. This includes gum and wood chemicals, cyclic crudes and
intermediates and industrial organic chemical not elsewhere classified. The
last category is by far the largest and most diverse of the three; however, its
size distribution and industry structure are similar to those of the cyclic crudes
and intermediates because both use primarily petroleum and coal derived
feedstocks. In addition to industrial organic chemicals, seven separate types
of product establishments are identified under Chemicals and Allied Products
(SIC 28). Many of the other industry sectors within the two-digit SIC code
28, such as plastics materials and synthetics (SIC 282), are downstream users
of the products manufactured by the industrial organic chemical industry.
Others, such as the inorganic chemical sector, utilize unrelated feedstocks.
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Organic Chemical Industry
The following list includes industrial organic chemicals (italicized) as well as
other chemicals and allied product SIC codes included within SIC code 28.
SIC Industry Sector
281 Inorganic Chemicals
282 Plastics Materials and Synthetics
283 Drugs
284 Soaps, Cleaners, and Toilet Goods
285 Paints and Allied Products
SIC Industry Sector
2861 Gum and Wood Chemicals
2865 Cyclic Organic Chemicals
2869 Industrial Organic Chemicals, n.e.c.
287 Agricultural Chemicals
289 Miscellaneous Chemical Products
The industrial organic chemical industry uses feedstocks derived from
petroleum and natural gas (about 90 percent) and from recovered coal tar
condensates generated by coke production (about 10 percent). The chemical
industry produces raw materials and intermediates, as well as a wide variety
of finished products for industry, business and individual consumers. The
important classes of products within SIC code 2861 are hardwood and
softwood distillation products, wood and gum naval stores, charcoal, natural
dyestuffs, and natural tanning materials.
The important classes of products within SIC code 2865 are: (1) derivatives
of benzene, toluene, naphthalene, anthracene, pyridene, carbazole, and other
cyclic chemical products, (2) synthetic organic dyes, (3) synthetic organic
pigments, (4) cyclic (coal tar) crudes, such as light oils and light oil products;
coal tar acids; and products of medium and heavy oil such as creosote oil,
naphthalene, anthracene and their high homologues.
Important classes of chemicals produced by organic chemical industry
facilities within SIC code 2869 include: (1) non-cyclic organic chemicals such
as acetic, chloroacetic, adipic, formic, oxalic acids and their metallic salts,
chloral, formaldehyde, and methylamine; (2) solvents such as amyl, butyl and
ethyl alcohols; methanol; amyl, butyl, and ethyl acetates; ethyl ether, ethylene
glycol ether and diethylene glycol ether; acetone, carbon disulfide, and
chlorinated solvents such as carbon tetrachloride, tetrachloroethene, and
trichloroethene; (3) polyhydric alcohols such as ethylene glycol, sorbitol,
pentaerythritol, and synthetic glycerin; (4) synthetic perfumes and flavoring
materials such as coumarin, methyl salicylate, saccharin, citral, citronellal,
synthetic geraniol, ionone, terpineol, and synthetic vanillin; (5) rubber
processing chemicals such as accelerators and antioxidants, both cyclic and
acyclic; (6) plasticizers, both cyclic and acyclic, such as esters of phosphoric
acid, phthalic anhydride, adipic acid, lauric acid, oleic acid, sebacic acid, and
stearic acid; (7) synthetic tanning agents such as sulfonic acid condensates;
and (8) esters and amines of polyhydric alcohols and fatty and other acids.
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n.B.3. Economic trends
With organic chemicals as the single largest segment of chemical exports
(accounting for nearly one-half of total chemical shipments to foreign
markets), the industrial organic sector faces a market similar to the
petrochemical industry. While the U.S. production is expected to continue to
grow at two to four percent annually, there is increasing competition in the
export market despite growing demand. World petrochemical demand is
projected to increase from 320 million metric tons in 1992 to 575 million
metric tons in 2010. The share accounted for by the United States, Western
Europe and Japan is expected to drop from 71 to 63 percent. Products from
the Gulf Cooperation Council and Pacific Rim countries, including China and
Korea, will begin to compete with U.S. products in current export markets as
new facilities are brought on-line. The U.S. is expected to maintain a positive
trade balance in organic chemicals. Chemical imports of organic chemicals
(some representing intra-company transfers) have been steady over the last
five years. The reduced trade barriers due to the North American Free Trade
Agreement (NAFTA) and the Uruguay Round of the General Agreement on
Tariffs and Trade (GATT) have increased competition. Firms are adapting to
the increased competition by emphasizing specialty chemicals and higher
value-added products.
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IH. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the organic
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 by-products produced or released,
and the materials either recycled or transferred off-site. This discussion,
coupled with schematic drawings of the identified processes, provides 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.
D3.A. Industrial Processes in the Organic Chemicals Industry
Industrial Organic Chemicals - Overview
The industrial organic chemical sector includes thousands of chemicals and
hundreds of processes. In general, a set of building blocks (feedstocks) is
combined in a series of reaction steps to produce both intermediates and end-
products. The chart and flow diagram below (Exhibits 4 and 5) show the
primary organic chemical building blocks (generated principally from
petroleum refining), a key subset of the large volume secondary building
blocks and a set of large volume tertiary building blocks. The subsequent
chart (Exhibit 6) shows the reaction types used to manufacture a sample of
organic chemicals, and illustrates the large variety of processes used by the
industry.
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Exhibit 4: High Volume Organic Chemical Building Blocks
Primary Building Block
Ethylene
Propylene
Benzene
Methanol
Toluene
Xylenes
p-isomer
Butadiene
Butylene
Secondary Building Block
Ethylene dichloride
Ethylene oxide
Ethylbenzene
Propylene oxide
Acrylonitrile
Isopropyl alcohol
Ethylbenzene
Cumene
Cyclohexane
Acetic acid
Formaldehyde
Methyl t-butyl ether
Terephthalic acid
Tertiary Building Block
Vinyl chloride
Ethylene glycol
Vinyl acetate
Acetone
Styrene
Phenol
Acetone
Adipic acid
Vinyl acetate
Source: Szmant, Organic Building Blocks of the Chemical Industry
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Exhibit 5: Organic Chemicals and Building Blocks Flow Diagram
Raw Materials
Oil,
Natural Gas,
Coal
Benzene
Ethylene
Propylene
Xylene
Toluene
Butadiene
Methane
| Butylene
Outputs
Agricultural Chemicals
Food Packaging
Carpeting
Furniture
Bottles
Paints
Fiber
Resins
Pharmaceuticals
Cements
Detergents
Adheslves
Lubricants
Foam
Insulation
Dry Cleaning
Pipe & Fittings
Auto Parts
Toys
Cosmetics
Textiles
The typical chemical synthesis process involves combining multiple
feedstocks in a series of unit operations. The first unit operation is a
chemical reaction. Commodity chemicals tend to be synthesized in a
continuous reactor while specialty chemicals usually are produced in batches.
Most reactions take place at high temperatures, involve metal catalysts, and
include one or two additional reaction components. The yield of the reaction
will partially determine the kind and quantity of by-products and releases.
Many specialty chemicals require a series of two or three reaction steps.
Once the reaction is complete, the desired product must be separated from the
by-products by a second unit operation. A number of separation techniques
such as settling, distillation or refrigeration may be used. The final product
may be further processed, by spray drying or pelletizing for example, to
produce the saleable item. Frequently by-products are also sold and their
value may alter the process economics.
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Exhibit 6: Reaction/Process Types by Chemical Category for a Sampling of
Organic Chemicals
Generic Process
Alkoxylation
Condensation
Halogenation
Oxidation
Polymerization
Hydrolysis
Hydrogenation
Estcriflcation
Pyrolysis
Alkylation
Dehydrogenation
Amination (Ammonolysis)
Nitration
Sulfonation
Ammoxidation
Carbonylation
Hydrohalogenation
Dehydration
Dehydrohalogcnation
Oxyhalogenation
Catalytic Cracking
Hydrodealkylation
Phosgenation
Extraction
Distillation
Other
Hvdration
Ethers
Bis-l^-Chloroisopropyl
Ether
•
Ethylene Glycol
Monomethyl Ether
•
Halocarbcns
Epichlorohydrin
•
•
Methyl Bromide
•
1,1,1 -Trichloroethane
•
•
Hydrocarbons
m
•
•
•
Hexane
•
Isoamylene
•
•
•
&
(W
•
•
CQ
1
#
•
•
Ke-
tones
Acetone
•
•
Ni-
trile
Acetonitrile
•
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Exhibit 6 (cont.): Reaction/Process Types by Chemical Category for a Sampling of
Organic Chemicals
Generic Process
Alkoxylation
Condensation
Halogenation
Oxidation
Polymerization
Hydrolysis
Hydrogenation
Esterification
Pyrolysis
Alkylation
Dehydrogenation
Amination (Ammonolysis)
Nitration
Sulfonation
Ammoxidation
Carbonylation
Hydrohalogenation
Dehydration
Dehydrohalogenation
Oxyhalogenation
Catalytic Cracking
Hydrodealkylation
Phosgenation
Extraction
Distillation
Other
Hydration
Nitro-
Carbon
Nitrobenzene
•
Phenol
"g
f
i,
•
Salt
-2
«
1
CO
•
•
Misc.
Dichlorodiphenyl
Sulfone
•
•
Methylene Diphenyl
Diisocyanate
•
•
Acid
Sulfonic Acid
•
Alcohols
n-Butanol
•
•
1 ,6-Hexanediol
•
•
•
Alde-
hyde
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The separation technology employed depends on many factors including the
phases of the substances being separated, the number of components in the
mixture, and whether recovery of by-products is important. Numerous
techniques such as distillation, extraction, filtration, and settling can be used
singly or in combination to accomplish separations and are summarized in
publications such as Perry's Chemical Engineers' Handbook or basic texts
on chemical plant design.
Relatively few organic chemical manufacturing facilities are single
product/process plants. Additionally, many process units are designed so that
production levels of related products can be varied over wide ranges. This
flexibility is required to accommodate variations in feedstock and product
prices which can change the production rate and processes used, even on a
short-term (less than a year) basis. A 1983 survey showed that 59 percent of
industrial organic plants had more than one product or process and that seven
percent had more than 20 (USEPA Development Document for Effluent
Limitations Guidelines and Standards for the Organic Chemicals, Plastics and
Synthetic Fibers Point Source Category).
The type of reaction process used to manufacture chemicals depends on the
intended product; however, several types of reactions are common:
polymerization, oxidation, and addition. Polymerization is a chemical reaction
usually carried out with a catalyst, heat or light (often under high pressure) in
which a large number of relatively simple molecules combine to form a chain-
like macromolecule. Oxidation, in the strict sense, means combining oxygen
chemically with another substance although this name is also applied to
reactions where electrons are transferred. Addition covers a wide range of
reactions where a double or triple bond is broken and a component added to
the structure. Alkylation can be considered an addition, as can some
oxidation reactions. The following charts list the reactions used to produce
a subset of organic chemical products.
Four Specific Industrial Organic Chemicals
This profile examines the reactions of four high-volume chemicals (ethylene,
propylene, benzene and vinyl chloride) chosen to illustrate the use of typical
chemical feedstocks based on several factors, including the quantity of
chemical produced, and the health and environmental impacts of the chemical.
Ethylene, propylene, and benzene are all primary building blocks and their
reaction products are used to produce still other chemicals. Vinyl chloride is
an important tertiary building block.
The four chemicals described below illustrate several key points. First,
primary building blocks are typically used in more reactions than the building
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Ethylene
blocks further down the chain. Second, most feedstocks can participate in
more than one reaction and third, there is typically more than one reaction
route to an end-product. The end-products of all of these chemicals can be
used in numerous commercial applications; Riegel's Handbook of Industrial
Chemistry, listed in the reference section, describes many uses.
The major uses for ethylene are in the synthesis of polymers (polyethylene)
and in ethylene dichloride, a precursor to vinyl chloride. Other important
products are ethylene oxide (a precursor to ethylene glycol) and ethylbenzene
(a precursor to styrene). While ethylene itself is not generally considered a
health threat, several of its derivatives, such as ethylene oxide and vinyl
chloride, have been shown to cause cancer. The distribution of uses is shown
below.
The manufacturing processes that use ethylene as a feedstock are summarized
in the table below along with reaction conditions and components. In 1993,
18.8 million metric tons of ethylene were produced in the United States
making ethylene the fourth largest production volume organic chemical in the
United States. Ethylene dichloride, ethylbenzene, and ethylene oxide
(products of ethylene reactions) are all among the top 50 high production
volume organic chemicals in the United States (Chemical and Engineering
News).
Exhibit 7: Distribution of Uses for Ethylene
Product
Polyethylene
Ethylene dichloride
Ethylbenzene-styrene
Ethylene oxide-glycol
Ethanol
Linear olefins-alcohol
Vinyl acetate
Other
Percent of Ethylene Use
54
16
7
13
1
3
2
4
Source: Kirk-Othmer Encyclopedia of Chemical Technology
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Propylene
Over half of the U.S. propylene supplies (10.2 million metric tons produced
in 1993) are used in the production of chemicals. The primary products are
polypropylene, acrylonitrile, propylene oxide, and isopropyl alcohol. Of these,
propylene, acrylonitrile and propylene oxide are among the top fifty high-
volume chemicals produced in the United States. Acrylonitrile and propylene
oxide have both been shown to cause cancer, while propylene itself is not
generally considered a health threat. The table below shows the use
distribution of propylene.
Exhibit 9: Distribution of Propylene Use
Product
Polypropylene
Acrylonitrile
Propylene oxide
Cumene
Butyraldehydes
Oligomers
Isopropyl alcohol
Other
Percent of Propylene Use
36
16
11
9
7
6
6
9
Source: Szmant, Organic Building Blocks of the Chemical Industry
The important propylene reactions are shown below. The products of the
reactions are the feedstocks for numerous additional products.
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I Propylene
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Benzene
Benzene is an important intermediate in the manufacture of industrial
chemicals and over 5.5 million metric tons were produced in the U.S. in 1993
(Chemical and Engineering News). Over 95 percent of U.S. consumption of
benzene is for the preparation of ethylbenzene, cumene, cyclohexane,
nitrobenzene, and various chlorobenzenes as shown in the table below.
Exhibit 11: Distribution of Benzene Use
Product
Ethylbenzene
Cumene
Cyclohexane
Nitrobenzene
Chlorobenzenes
Linear detergent alkylate
Other
Percent of Benzene Use
52
22
14
5
2
2
3
Source: Kirk-Othmer Encyclopedia of Chemical Technology
The following table summarizes the primary benzene reactions. The products
are frequently feedstocks in the synthesis of additional chemicals. Benzene is
considered a human carcinogen by the Agency.
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Sector Notebook Project
Organic Chemical Industry
Vinyl Chloride
Vinyl chloride is one of the largest commodity chemicals in the U.S. with over
6.25 million metric tons produced in 1993. It is also considered a human
carcinogen by the EPA. Vinyl chloride polymers are the primary end use but
various vinyl ethers, esters, and halogen products can also be made as shown
in the table below.
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CD
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HLB. Raw Material Inputs and Pollution Outputs
Industrial organic chemical manufacturers use and generate both large
numbers and quantities of chemicals. The industry emits chemicals to all
media including air (through both fugitive and direct emissions), water (direct
discharge and runoff) and land. The types of pollutants a single facility will
release depend on the feedstocks, processes, equipment in use and
maintenance practices. These can vary from hour to hour and can also vary
with the part of the process that is underway. For example, for batch
reactions in a closed vessel, the chemicals are more likely to be emitted at the
beginning and end of a reaction step (associated with vessel loading and
product transfer operations), than during the reaction. The potential sources
of pollutant outputs by media are shown below.
Exhibit 14: Potential Releases During Organic Chemical Manufacturing
Media
Air
Liquid wastes
(Organic or
Aqueous)
Solid Wastes
Ground Water
Contamination
Potential Sources of Emissions
Point source emissions: stack, vent (e.g. laboratory hood, distillation unit,
reactor, storage tank vent), material loading/unloading operations (including
rail cars, tank trucks, and marine vessels)
Fugitive emissions: pumps, valves, flanges, sample collection, mechanical
seals, relief devices, tanks
Secondary emissions: waste and wastewater treatment units, cooling tower,
process sewer, sump, spill/leak areas
Equipment wash solvent/water, lab samples, surplus chemicals, product
washes/purifications, seal flushes, scrubber blowdown, cooling water, steam
jets, vacuum pumps, leaks, spills, spent/used solvents, housekeeping (pad
washdown), waste oils/lubricants from maintenance
Spent catalysts, spent filters, sludges, wastewater treatment biological sludge,
contaminated soil, old equipment/insulation, packaging material, reaction by-
products, spent carbon/resins, drying aids
Unlined ditches, process trenches, sumps, pumps/valves/fittings, wastewater
treatment ponds, product storage areas, tanks and tank farms, aboveground
and underground piping, loading/unloading areas/racks, manufacturing
maintenance facilities
Source: Designing Pollution Prevention into the Process- Research, Development and Engineering
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ffl.C. Management of Chemicals in the Production Process
The Pollution Prevention Act of 1990 (PPA) requires facilities to report
information about the management of TRI chemicals in waste and efforts
made to eliminate or reduce those quantities. These data have been collected
annually in Section 8 of the TRI reporting Form R beginning with the 1991
reporting year. The data summarized below cover the years 1992 through
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 remained reasonably constant 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 15 shows that the organic chemical industry managed about 6.3
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, seven 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 90 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 (three 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 15: Source Reduction and Recycling Activity for the
Organic Chemical Industry (SIC 286) as Reported within TRI
A
Year
1992
1993
1994
1995
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
6,313
6,325
6,712
6,645
c
% Released
and
Transferred1"
7%
7%
—
—
D
% Released
and
Disposed0
Off-site
3%
3%
2%
2%
On-Site
E
%
Recycled
71%
71%
71%
72%
F
% Energy
Recovery
7%
7%
8%
7%
G
% Treated
15%
15%
15%
15%
Off-Site
H
%
Recycled
2%
2%
2%
2%
I
% Energy
Recovery
1%
1%
1%
1%
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a Within this industry sector, non-production related waste < 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.
0 Percentage of production related waste released to the environment and transferred off-site for disposal.
September 1995
27
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Organic Chemical Industry
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
The following is a synopsis of current scientific toxicity and fate information
for the top chemicals (by weight) that facilities within this sector self-reported
as released to the environment based upon 1993 TRI data. Because this
section is based upon self-reported release data, it does not attempt to provide
information on management practices employed by the sector to reduce the
release of these chemicals. Information regarding pollutant release reductions
over time may be available from EPA's TRI and 33/50 programs, or directly
from the industrial trade associations that are listed in Section IX of this
document. Since these descriptions are cursory, please consult the sources
referenced below for a more detailed description of both the chemicals
described in this section and the chemicals that appear on the full list of TRI
chemicals appearing in Section IV. A.
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 through 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. 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.
TRI data provide the type, amount and media receptor of each chemical
released or transferred.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general, toxic
chemical releases have been declining. In fact, according to the 19.93 Toxic
Release Inventory Data Book, reported releases dropped by 43 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 Hotlines at 800-535-0202), or directly from the Toxic
Release Inventory System database (for user support call 202-260-1531).
September 1995
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Organic Chemical Industry
Wherever possible, the sector notebooks present TRI data as the primary
indicator of chemical release within each industrial category. TRI data
provide the type, amount and media receptor of each chemical released or
transferred. When other sources of pollutant release data have been obtained,
these data have been included to augment the TRI information.
TRI Data Limitations
The reader should keep in mind the following limitations regarding TRI data.
Within some sectors, the majority of facilities are not subject to TRI reporting
because they are not considered manufacturing industries, or because they are
below TRI reporting thresholds. Examples are the mining, dry cleaning,
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, this notebook briefly
summarizes the toxicological properties of the top five chemicals (by weight)
reported by the organic chemical 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 through 39. Facilities must submit estimates
for all chemicals that are on the EPA's defined list and are above throughput
thresholds.
September 1995
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Organic Chemical Industry
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 emissions occur through confined air
streams as found in stacks, ducts, or pipes. Fugitive emissions include losses
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 storm water 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 waste waters 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 land filled 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.
September 1995
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Organic Chemical Industry
Transfers to Energy Recovery — are wastes combusted off-site in industrial
furnaces for energy recovery. Treatment of a chemical by incineration is not
considered to be energy recovery.
Transfers to Treatment — are wastes moved off-site for either neutralization,
incineration, biological destruction, or physical separation. In some cases, the
chemicals are not destroyed but prepared for further waste management.
Transfers to Disposal — are wastes taken to another facility for disposal
generally as a release to land or as an injection underground.
IV.A. EPA Toxic Release Inventory for the Organic Chemicals Industry
According to the Toxics Release Inventory (TRI) data, 417 organic chemical
facilities released (to the air, water or land) and transferred (shipped off-site
or discharged to sewers) a total of 438 million pounds of toxic chemicals
during calendar year 1993. That represents approximately 18 percent of the
2.5 billion pounds of releases and transfers from the chemical industry as a
whole (SIC 28) and about six percent of the releases and transfers for all
manufacturers reporting to TRI that year. By comparison, the inorganic
chemical industry's releases and transfers in 1993 totaled 249.7 million
pounds, or sixty percent of the releases and transfers of the industrial organic
chemical sector.
The chemical industry's releases have been declining in recent years. Between
1988 and 1992 TRI emissions from chemical companies (all those categorized
within SIC 28, not just organic chemical manufacturers) to air, land, and
water were reduced 44 percent, which is average for all manufacturing sectors
reporting to TRI.
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. EPA's 33/50 program). In
addition, the chemical industry has focused on reducing pollutant releases.
For example, the Chemical Manufacturer's Association's (CMA's)
Responsible Care® initiative is intended to reduce or eliminate chemical
manufacturers' wastes. All 185 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 as a condition of CMA membership. Participation
involves demonstrating a commitment to the program's mandate of
continuous improvement of the environment, health, and safety. In June of
1994, the CMA approved the use of a third-party verification of management
September 1995
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Organic Chemical Industry
plans to meet these objectives. State-level toxics use reduction requirements,
public disclosure of release and transfer information contained in TRI, and
voluntary programs such as EPA's 33/50 Program have also been given as
reasons for release reductions.
Exhibit 16 presents the number and volumes of chemicals released by organic
chemical facilities. The quantity of the basic feedstocks released reflects their
volume of usage. The inorganic chemicals among the top ten released
(ammonia, nitric acid, ammonium sulfate, and sulfuric acid) are also large
volume reaction feedstocks. Inorganic chemicals contained in wastes injected
underground on-site account for 58 percent of the industry's releases;
ammonia makes up the vast majority of TRI chemicals disposed of via
underground injection. Air releases account for 40 percent (61 million
pounds), and the remaining approximately 1.5 percent (2.4 million pounds) is
discharged directly to water or land disposed.
Exhibit 17 presents the number and volumes of chemicals transferred by
organic chemical facilities. Off-site transfers account for the largest amount,
65 percent, of the organic chemical industry's total releases and transfers as
reported in TRI. Three chemicals (sulfuric acid, methanol and tert-butyl
alcohol) account for over one-half of the 287 million pounds transferred off-
site. The 49 million pounds of POTW discharges (primarily methanol and
ammonia) account for 17 percent of releases and transfers.
The frequency with which chemicals are reported by facilities within a sector
is one indication of the diversity of operations and processes. Many chemicals
are released or transferred by a small number of facilities, which indicates a
wide diversity of production processes, particularly for specialty organic
chemicals — over one half of the 204 chemicals reported are released by fewer
than 10 facilities. However, the organic chemical industry is also
characterized by one of the largest numbers of chemicals reported by any
manufacturing sector. Of the over 300 chemicals currently listed on TRI, 204
are reported as released or transferred by at least one organic chemical
facility.
September 1995
33
SIC 286
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Sector Notebook Project
Organic Chemical Industry
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Organic Chemical Industry
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Organic Chemical Industry
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Organic Chemical Industry
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Sector Notebook Project
Organic Chemical Industry
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Sector TSotebook Project
Organic Chemical Industry
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Sector Notebook Project
Organic Chemical Industry
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Sector Notebook Project
Organic Chemical Industry
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The TRI database contains a detailed compilation of self-reported, facility-
specific chemical releases. The top reporting facilities for this sector are listed
below (Exhibit 18). Facilities that have reported only the SIC codes covered
under this notebook appear on the first list. Exhibit 19 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 18: Top 10 TRI Releasing
Organic Chemical Manufacturing Facilities11
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Du Pont Victoria Plant - Victoria, TX
BP Chemicals Inc. Green Lake - Port Lavaca, TX
Zeneca Specialties Mount Pleasant Plant - Mt. Pleasant, TN
Hoechst-Celanese Chemical Group Inc. Clear Lake Plant - Pasadena, TX
Du Pont Sabine River Works - Orange, TX
Merichem Co. - Houston, TX
Hoechst-Celanese Chemical Group Inc. - Bay City, TX
Union Carbide C & P CO. Institute WV Plant Ops. - Institute, WV
Aqualon - Hopewell, VA
Aristech Chemical Corp. - Haverhill, OH
Total TRI Releases in
Pounds
22,471,672
20,650,979
13,429,259
10,354,443
9,731,302
3,832,980
3,454,971
3,082,932
3,007,010
2,858,009
Source: U.S. EPA, Toxics Release Inventory Database, 1993
Being included on this list does not mean that the release is associated with non-compliance with environmental laws.
September 1995
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Sector Notebook Project
Organic Chemical Industry
Exhibit 19: Top 10 TRI Releasing Facilities Reporting Organic Chemical
Manufacturing SIC Codes to TRP
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported in
TRI
2819,2869
2869,2819,
2841,2879
2822, 2865,
2869, 2873
2823,2821,
2869, 2824
2869, 2865,
2819
2869
2869
2821,2869,
2873
2812,2869,
2813
2813,2819,
2869, 2873
Facility
Cytec Inc. Inc. Fortier Plant - Westwego, LA
Monsanto Co. - Alvin, TX
Du Pont Beaumont Plant - Beaumont, TX
Tennessee Eastman Division - Kingsport, TN
Sterling Chemicals Inc. - Texas City, TX
Du Pont Victoria Plant - Victoria, TX
BP Chemicals Inc. Green Lake - Port Lavaca, TX
BP Chemicals - Lima, OH
Vulcan Chemicals - Cheyenne, WY
Coastal Chemicals Inc. - Cheyenne, WY
Total TRI
Releases in
Pounds
120,149,724
40,517,095
36,817,348
29,339,677
24,709,135
22,471,672
20,650,979
20,620,680
17,406,218
15,334,423
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
' Being included on this list does not mean that the release is associated with non-compliance with environmental laws.
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I V.B. Summary of Selected Chemicals Released
The brief descriptions provided below were taken from the 7993 Toxics
Release Inventory Public Data Release (EPA, 1994), the Hazardous
Substances Data Bank (HSDB), and the Integrated Risk Information System
(IRIS), both accessed via TOXNET.d
Ammonia* (CAS: 7664-41-7)
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.
TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological databases
managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and Health. For more
information on TOXNET, contact the TOXNET help line at 800-231 -3766. 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). HSDB
contains chemical-specific information on manufacturing and use, chemical and physical properties, safety and handling,
toxicity and biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards and
regulations, monitoring and analysis methods, and additional references.
c The reporting standards for ammonia were changed in 1995. Ammonium sulfate is deleted from the list and threshold and
release determinations for aqueous ammonia are limited to 10 percent of the total ammonia present in solution. This change
will reduce the amount of ammonia reported to TRI. Complete details of the revisions can be found in 40 CFR Part 372.
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Nitric Acid (CAS: 7697-37-2)
Toxicity. The toxicity of nitric acid is related to its potent corrosivity as
an acid, with ulceration of all membranes and tissues with which it comes
in contact. Concentrated nitric acid causes immediate opacification and
blindness of the cornea when it comes in contact with the eye. Inhalation
of concentrated nitric acid causes severe, sometimes fatal, corrosion of the
respiratory tract. Ingestion of nitric acid leads to gastric hemorrhaging,
nausea, and vomiting. Circulatory shock is often the immediate cause of
death due to nitric acid exposure. Damage to the respiratory system may
be delayed for months, and even years. Populations at increased risk from
nitric acid exposure include people with pre-existing skin, eye, or
cardiopulmonary disorders.
Ecologically, gaseous nitric acid is a component of acid rain. Acid rain
causes serious and cumulative damage to surface waters and aquatic and
terrestrial organisms by decreasing water and soil pH levels. Nitric acid in
rainwater acts as a topical source of nitrogen, preventing "hardening off"
of evergreen foliage and increasing frost damage to perennial plants in
temperate regions. Nitric acid also acts as an available nitrogen source in
surface water, stimulating plankton and aquatic weed growth.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Nitric acid is mainly transported in the atmosphere
as nitric acid vapors and in water as dissociated nitrate and hydrogen ions.
In soil, nitric acid reacts with minerals such as calcium and magnesium,
becoming neutralized, and at the same time decreasing soil "buffering
capacity" against changes in pH levels.
Nitric acid leaches readily to groundwater, where it decreases the pH of the
affected groundwater. In the winter, gaseous nitric acid is incorporated
into snow, causing surges of acid during spring snow melt. Forested areas
are strong sinks for nitric acid, incorporating the nitrate ions into plant
tissues.
Methanol (CAS: 67-56-1)
Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the
respiratory tract, and is toxic to humans in moderate to high doses. In the
body, methanol is converted into formaldehyde and formic acid. Methanol is
excreted as formic acid. Observed toxic effects at high dose levels generally
include central nervous system damage and blindness. Long-term exposure
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to high levels of methanol via inhalation cause liver and blood damage in
animals.
Ecologically, methanol is expected to have low toxicity to aquatic organisms.
Concentrations lethal to half the organisms of a test population are expected
to exceed one mg methanol per liter water. Methanol is not likely to persist
in water or to bioaccumulate in aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this chemical
is carcinogenic.
Environmental Fate. Liquid methanol is likely to evaporate when left
exposed. Methanol reacts in air to produce formaldehyde which contributes
to the formation of air pollutants. In the atmosphere it can react with other
atmospheric chemicals or be washed out by rain. Methanol is readily
degraded by microorganisms in soils and surface waters.
Physical Properties. Methanol is highly flammable
EtlLyleaeJ3Ly£al (CAS: 74-85-1)
Sources. Ethylene glycol is used as an antifreeze, heat, transfer agent and
solvent in industrial organic chemical facilities. The large quantity of ethylene
glycol released is due to its ubiquitous use as an antifreeze and because in
1993 it had the 29th largest chemical production volume in the United States
(Chemical and Engineering News). While the largest volume is released
through underground injection, a substantial release also occurs from air point
sources.
Toxicity. Long-term inhalation exposure to low levels of ethylene glycol may
cause throat irritation, mild headache and backache. Exposure to higher
concentrations may lead to unconsciousness. Liquid ethylene glycol is
irritating to the eyes and skin.
Toxic effects from ingestion of ethylene glycol include damage to the central
nervous system and kidneys, intoxication, conjunctivitis, nausea and vomiting,
abdominal pain, weakness, low blood oxygen, tremors, convulsions,
respiratory failure, and coma. Renal failure due to ethylene glycol poisoning
can lead to death.
Environmental Fate. Ethylene glycol readily biodegrades in water. No data
are available that report its fate in soils; however, biodegradation is probably
the dominant removal mechanism. Should ethylene glycol leach into the
groundwater, biodegradation may occur.
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Ethylene glycol in water is not expected to bioconcentrate in aquatic
organisms, adsorb to sediments or volatilize. Atmospheric ethylene glycol
degrades rapidly in the presence of hydroxyl radicals.
Acetone (CAS: 67-64-1)
Toxicity. Acetone is irritating to the eyes, nose, and throat. Symptoms of
exposure to large quantities of acetone may include headache, unsteadiness,
confusion, lassitude, drowsiness, vomiting, and respiratory depression.
Reactions of acetone (see environmental fate) in the lower atmosphere
contribute to the formation of ground-level ozone. Ozone (a major
component of urban smog) can affect the respiratory system, especially in
sensitive individuals such as asthmatics or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this chemical
is carcinogenic.
Environmental Fate. If released into water, acetone will be degraded by
microorganisms or will evaporate into the atmosphere. Degradation by
microorganisms will be the primary removal mechanism.
Acetone is highly volatile, and once it reaches the troposphere (lower
atmosphere), it will react with other gases, contributing to the formation of
ground-level ozone and other air pollutants. EPA is reevaluating acetone's
reactivity in the lower atmosphere to determine whether this contribution is
significant.
Physical Properties. Acetone is a volatile and flammable organic chemical.
IV.C. Other Data Sources
The toxic chemical release data obtained from TRI captures the vast majority
of facilities in the organic chemicals industry. It also allows for a comparison
across years and industry sectors. Reported chemicals are limited however to
the 316 reported chemicals. Most of the hydrocarbon emissions from organic
chemical facilities are not captured by TRI.1 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., total
hydrocarbons, SOX, NOX, CO, particulates, etc.) from many chemical
manufacturing sources.2
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
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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 20 summarizes annual releases of carbon monoxide (CO),
nitrogen dioxide (NOz), particulate matter of 10 microns or less (PM10), total
particulate (PT), sulfur dioxide (SO2), and volatile organic compounds
(VOCs).
Exhibit 20: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmctal 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.
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
September 1995
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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 21 is a graphical representation of a summary of the 1993 TRI data for
the organic chemical 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 22 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 organic chemical industry,
the 1993 TRI data presented here covers 417 facilities. Only those facilities
listing SIC Codes falling within SIC 286 were used.
September 1995 49 SIC 286
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Sector Notebook Project
Organic Chemical Industry
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 minimizing
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 substituting benign chemicals for toxic ones.
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 organic chemical 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 provides summary information from activities that may be, or are
being implemented by this sector. When possible, information is provided that
gives the context in which the technique can be effectively used. Please note
that the activities described in this section do not necessarily apply to all
facilities that fall within this sector. Facility-specific conditions must be
carefully considered when pollution prevention options are evaluated, and the
full impacts of the change must examine how each option affects air, land and
water pollutant releases.
The leaders in the organic chemical industry, similar to those in the chemical
industry as a whole, have been promoting pollution prevention through
various means. The most visible of these efforts is the Responsible Care®
initiative of the Chemical Manufacturer's Association (CMA). Responsible
Care is mandatory for CMA members who must commit to act as stewards for
products through use and ultimate reuse or disposal. One of the guiding
principles of this initiative is the inclusion of waste and release prevention
objectives in research and in design of new or modified facilities, processes
and products. The Synthetic Organic Chemical Manufactures Association
(SOCMA) also requires its members to implement the Responsible Care®
Guiding Principles as a condition of membership. SOCMA is instituting the
Responsible Care® management practice codes on a phased-in basis to assist
its approximately 110-non CMA members, which are primarily small and
batch chemical manufacturers, in successfully implementing their programs.
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Using pollution prevention techniques which prevent the release or generation
of pollution in the first place have several advantages over end-of-pipe waste
treatment technologies. The table below lists the direct and indirect benefits
that could result.
Exhibit 23: Pollution Prevention Activities Can Reduce Costs
Direct Benefits
Reduced waste treatment costs
Reduced capital and operating costs for waste treatment facilities
Reduced off-site treatment and disposal costs
• Reduced manufacturing costs due to improved yields
• Income or savings from sale or reuse of wastes
• Reduced environmental compliance costs (e.g., fines, shutdowns)
• Reduced or eliminated inventories or spills
• Reduced secondary emissions from waste treatment facilities
• Retained sales (production threatened by poor environmental performance or sales)
Indirect Benefits
• Reduced likelihood of future costs from:
Remediation
Legal liabilities
Complying with future regulations
Use of emission offsets (internal and external)
* Improved community relations
• Increase environmental awareness by plant personnel and management
• Reduced societal costs
Improved public health
Source: Chemical Manufacturer's Association Designing Pollution Prevention into the Process
These incentives may encourage organic chemical manufacturers to undertake
pollution prevention activities voluntarily, but a number of barriers still exist
in achieving widespread adoption of pollution prevention. The U.S. Office of
Technology Assessment has identified and characterized a number of these
barriers in its report titled Industry, Technology, and the Environment.
Pollution prevention can be carried out at any stage of the development of a
process. In general, changes made at the research and development stage will
have the greatest impact; however, changes in the process design and
operating practices can also yield significant results.
In the research and development stage, all possible reaction pathways for
producing the desired product can be examined. These can then be evaluated
in light of yield, undesirable by-products, and their health and environmental
impacts. The area of "green synthesis" is the focus of considerable research
funded jointly by the Agency and by the National Science Foundation.
Several alternative syntheses have already been developed that could reduce
wastes. For example, Joseph M. Desimone of the University of North
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Carolina, Chapel Hill, has used supercritical carbon dioxide as a medium for
carrying out dispersion polymerizations. He uses a specially engineered free-
radical initiator to start the reaction and a polymeric stabilizer to affect the
polymerization of methyl methacrylate. Because the carbon dioxide can easily
be separated from the reaction mixture, this reaction offers the possibility of
reduced hazardous waste generation, particularly of aqueous streams
contaminated with residual monomer and initiator.
Because of the large investment in current technology, and the lifetime of
capital equipment, pollution prevention at the earliest stages is unlikely unless
a company undertakes the design of a new production line or facility. There
are, however, more numerous pollution prevention opportunities that can be
realized by modifying current processes and equipment.
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Exhibit 24: Process/Product Modifications Create Pollution Prevention
Opportunities
Area
Potential Problem
Possible Approach
By-products
Co-products
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 carryover 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 insitu activation with appropriate
processing/activation facilities.
» Develop a more robust catalyst or support.
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Exhibit 24 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Catalysts (cont.)
Preparation and
Handling (cont.)
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 deactivitation
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 24 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities
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 superheat 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 24 (cont.); Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Process Conditions/
Configuration
(cont.)
Temperature (cont.)
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 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 24 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Process Conditions/
Configuration
(cont.)
Batch vs. Continuous
Operations (cont.)
Process
Operatlon'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,
absorbants, etc.) create wastes. Each
chemical (including water) employed
within the process introduces additional
potential waste sources; the composition
of 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 both 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 24 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Process Conditions/
Configuration
(cont.)
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 waste reduction 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.
• Specifying a purity greater than needed
by the process increases costs and can
result in more waste generation by the
supplier.
• 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.
• Specify a purity no greater than what the
process needs.
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Exhibit 24 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Raw Materials
(cont.)
Purity (cont.)
Vapor Pressure
Water Solubility
" 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.
•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 24 (cont.): Process/Product Modifications Create Pollution Prevention Opportunities
Area
Potential Problem
Possible Approach
Raw Materials
(cont.)
Toxicity
Regulatory
Form of Supply
Handling and
Storage
• Community and worker safety and
health concerns result from routine and
nonroutine emissions. Emissions sources
include vents, equipment leaks,
wastewater emissions, emergency
pressure relief, etc.
• Surges or higher than normal continuous
levels of toxic materials can shock or miss
wastewater biological treatment systems
resulting in possible fines and possible
toxicity in the receiving water.
• Hazardous or toxic materials are
stringently regulated. They may require
enhanced control and monitoring;
increased compliance issues and
paperwork for permits and record
keeping; stricter control for handling,
shipping, and disposal; higher sampling
and analytical costs; and increased health
and safety costs.
• Small containers increase shipping
frequency which increases chances of
material releases and waste residues from
shipping containers (including wash
waters).
• Nonretumable containers may increase
waste.
« Physical state (solid, liquid, gaseous)
may raise unique environmental, safety,
and health issues with unloading
operations and transfer to process
equipment.
• Use less toxic materials.
• Reduce exposure through equipment
design and process control. Use systems
which are passive for emergency
containment of toxic releases.
• Use less toxic material.
• Reduce spills, leaks, and upset conditions
through equipment and process control.
• Consider effect of chemicals on biological
treatment; provide unit pretreatment or
diversion capacity to remove toxicity.
• Install surge capacity for flow and
concentration equalization.
• Use materials which are less toxic or
hazardous.
• Use better equipment and process design
to minimize or control releases; in some
cases, meeting certain regulatory criteria
will exempt a system from permitting or
other regulatory requirements.
« Use bulk supply, ship by pipeline, or use
"jumbo" drums or sacks.
• 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 24 (cent.): Process/Product Modifications Create Pollution Prevention Opportunities
Area
Raw Materials (cont)
Handling and Storage
(cont.)
Waste Streams
Quantity and Quality
.
Composition
Properties
Disposal
Potential Problem
• Large inventories can lead to spills, inherent
safely 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 Manufacturer's Association. Designing Pollution Prevention into the Process, Research, Development and
Engineering,
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Exhibit 25: Modifications to Equipment Can Also Prevent Pollution
Equipment
Potential
Environment Problem
Possible Approach
Design
Related
Operational
Related
Compressors,
blowers, fans
• Shaft seal leaks, piston
rod seal leaks, and vent
streams
• Seal-less designs
(diaphragmatic, hermetic or
magnetic)
• 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
• Preventive maintenance
program
Concrete pads,
floors, sumps
1 Leaks to groundwater
1 Water stops
1 Embedded metal plates
1 Epoxy sealing
| Other impervious sealing
• Reduce unnecessary purges,
transfers, and sampling
1 Use drip pans where necessary
Controls
• Shutdowns and start-
ups generate waste and
releases
• Improve on-line controls
• On-line instrumentation
• Automatic start-up and
shutdown
• On-line vibration analysis
» Use "consensus" systems (e.g.,
shutdown trip requires 2 out of 3
affirmative responses)
» Continuous versus batch
• Optimize on-line run time
• Optimize shutdown interlock
inspection frequency
• Identify safety and environment
critical instruments and
equipment
Distillation
• Impurities remain in
process streams
1 Increase reflux ratio
1 Add section to column
1 Column intervals
1 Change feed tray
• Change column operating
conditions
- reflux ratio
- feed tray
- temperature
- pressure
-etc.
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Exhibit 25 (cont.): Modifications to Equipment Can Also Prevent Pollution
Equipment
Distillation
(cont.)
General
manufacturing
equipment
areas
Heat
exchangers
Potential
Environment Problem
• Impurities remain in
process streams (cont.)
» Large amounts of
contaminated water
condensate from stream
stripping
• Contaminated
rainwater
• Contaminated sprinkler
and fire water
• Leaks and emissions
during cleaning
« Increased waste due to
high localized
temperatures
Possible Approach
Design
Related
• Insulate to prevent heat loss
• Preheat column feed
• Increase vapor line size to lower
pressure drop
• Use reboilers or inert gas
stripping agents
• 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
• 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)
Operational
Related
• Clean column to reduce fouling
• Use higher temperature steam
• Return samples to process
• Monitor stormwater discharge
• Use drip pans for maintenance
activities
• Rinse to sump
• Reuse cleaning solutions
• 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
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Exhibit 25 (cont.): Modifications to Equipment Can Also Prevent Pollution
Equipment
Potential
Environment Problem
Possible Approach
Design
Related
Operational
Related
Heat
exchangers
(cont.)
• Increased waste due to
high localized
temperatures (cont.)
• Contaminated
materials due to tubes
leaking at tube sheets
« Furnace emissions
• 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 superheat of high-pressure
steam in place of a furnace
• 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
Piping
• Leaks to groundwater;
fugitive emissions
• Design equipment layout so,as to
minimize pipe run length
• Eliminate underground piping or
design for cathodic protection if
necessary to install piping
underground
•Welded fittings
• Reduce number of flanges and
valves :
• All welded pipe
• Secondary containment
• Spiral-wound gaskets
• Use plugs and double valves for
open end lines
• Change metallurgy
• Use lined pipe
• Monitor for corrosion and
erosion
• Paint to prevent external
corrosion
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Exhibit 25 (cont.): Modifications to Equipment Can Also Prevent Pollution
Equipment
Piping (cont.)
Pumps
Reactors
Potential
Environment Problem
• Releases when
cleaning or purging lines
« Fugitive emissions
from shaft seal leaks
» Fugitive emissions
from shaft seal leaks
« Residual "heel" of
liquid during pump
maintenance
» Injection of seal flush
fluid into process stream
« Poor conversion or
performance due to
inadequate mixing
Possible Approach
Design
Related
• Use "pigs" for cleaning
» Slope to low point drain
• Use heat tracing and insulation
to prevent freezing
• Install equalizer lines
• 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
• Use double mechanical seal with
inert barrier fluid where practical
• Static mixing
• Add baffles
" Change impellers
Operational
Related
• Flush to product storage tank
• Seal installation practices
• Monitor for leaks
« Flush casing to process sewer
for treatment
• Increase the mean time between
pump failures by:
- selecting proper seal material;
- good alignment;
- reduce pipe-induced stress
- Maintaining seal lubrication
• Add ingredients with optimum
sequence
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Exhibit 25 (cont.): Modifications to Equipment Can Also Prevent Pollution
Equipment
Reactors
(cont.)
Relief Valve
Sampling
Tanks
Potential
Environment Problem
• Poor conversion (cont.)
• Waste by-product
formation
•Leaks
• Fugitive emissions
• Discharge to
environment from over
pressure
• Frequent relief
• Waste generation due
to sampling (disposal,
containers, leaks,
fugitives, etc.)
• Tank breathing and
working losses
Possible Approach
Design
Related
• Add horsepower
• Add distributor
» Provide separate reactor for
converting recycle streams to
usable products
• Provide upstream rupture disc
• Vent to control or recovery ,
device
" Pump discharges to suction of
pump
• Thermal relief to tanks
• Avoid discharge to roof areas to
prevent contamination of rainwater
• Use pilot operated relief valve
• Increase margin between design
and operating pressure
• In-line insitu 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
Operational
Related
• Allow proper head space in
reactor to enhance vortex effect
• Optimize reaction conditions
(temperature, pressure, etc.)
• Monitor for leaks and for
control efficiency
• Monitor for leaks
• Reduce operating pressure
• Review system performance
• Reduce number and size of
samples required
• Sample at the lowest possible
temperature
• Cool before sampling
• Optimize storage conditions to
reduce losses
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Exhibit 25 (cont.): Modifications to Equipment Can Also Prevent Pollution
Equipment
Tanks (cont.)
Vacuum
Systems
Valves
Vents
Potential
Environment Problem
« Tank breathing and
working losses (cont.)
• Leak to groundwater
" Large waste heel
• Waste discharge from
jets
• Fugitive emissions
from leaks
• Release to environment
Possible Approach
Design
Related
• Floating roof
• Higher design pressure
• All aboveground (situated so
bottom can routinely be checked
for leaks)
• Secondary containment
» Improve corrosion resistance
« Design for 100% de-inventory
« Substitute mechanical vacuum
pump
» Evaluate using process fluid for
powering jet
• Bellow seals
• Reduce number where practical
• Special packing sets
* Route to control or recovery
device
Operational
Related
• Monitor for leaks and corrosion
• Recycle to process if practical
• Monitor for air leaks
• Recycle condensate to process
• Stringent adherence to packing
procedures
• Monitor performance
Source: Chemical Manufacturer's 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 choice of 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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Changes in operational practices may yield the most immediate gains with the
least investment. For example, the majority of the waste generated by the
chemical processing industry is contaminated water: Borden Chemical
Company has collected and isolated its waste water in a trench coming from
the phenol rail car unloading area and reused the water in resin batches. This
eliminated the entire waste stream with a capital investment of $3,000 and
annual savings of $1,500 a year in treatment costs. Rhone-Poulenc, in New
Brunswick, New Jersey, is now sending all quality control and raw material
samples back to be reused in the production process saving $20,000 per year
and reducing waste volume by 3,000 pounds.
Another area that can yield significant benefits is improved process control so
that less off-specification product is produced (that must be discarded) and the
process is run more optimally (fewer by-products). Exxon Chemical
Americas of Linden, New Jersey, used continuous process optimization to
reduce the generation of acid coke, a process residue, thus saving $340,000
annually in treatment costs. New in-line process controls are under
development (a fertile area of research being pursued by the Center for
Process Analytic Chemistry at the University of Washington) that may allow
better process optimization through tighter process control.
Chemical substitution, particularly of water for non-aqueous solvents, can also
prevent pollution. For example, Du Pont at the Chamber Works in New
Jersey is using a high-pressure water-jet system to clean polymer reaction
vessels. This replaces organic solvent cleaning that annually produced 40,000
pounds of solvent waste. Installing the new cleaning system cost $125,000
but it will save $270,000 annually.
Improved separations design also offers a pollution prevention opportunity
since separations account for about 20 percent of energy use in the chemical
process industry. In one case, a solvent was replaced by an excess of a
reaction component, thus eliminating the need to separate the solvent from the
waste stream while reducing separation costs.
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VL 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 regulatory agencies. EPA Hotline contacts are also
provided for each major statute.
VL A. General Description of Major Statutes
Resource Conservation And Recovery Act (RCRA)
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 (ignitibility, corrosivity, reactivity, or toxicity
and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and record keeping standards. Facilities that treat,
store, or dispose of hazardous waste must obtain a permit, either from EPA
or from a State agency which EPA has authorized to implement the permitting
program. Subtitle C permits contain general facility standards such as
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
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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
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
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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 burn fuel
containing hazardous waste must comply with strict design and
operating standards. BIF regulations (40 CFR Part 266, Subpart H)
address unit design, provide performance standards, require emissions
monitoring, and restrict the type of waste that may be burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 8:30a.m. to 7:30 p.m., ET, excluding
Federal holidays.
Comprehensive Environmental Response, Compensation, And Liability Act (CERCLA)
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 Superfund,
and created a free-standing law, SARA Title III, also known as the
Emergency Planning and Community Right-to-Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
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
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National Priorities List (NPL), which currently includes approximately 1300
sites. Both EPA and states can act at other sites; however, EPA provides
responsible parties the opportunity to conduct removal and remedial actions
and encourages community involvement throughout the Superfund response
process.
EPA'sRCRA/Superfund/UST Hotline, 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 (EPCRA)
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created EPCRA, also known as SARA Title HI, 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.
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 in SIC codes
20 through 39, which have ten or more employees, and which
manufacture, process, or use specified chemicals in amounts greater
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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 (CWA)
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the 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 and 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 which are pollutants not identified as either
conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or "point
source" discharges are from sources such as pipes and sewers. NPDES
permits, issued by either EPA or an authorized State (EPA has authorized
approximately forty States to administer the NPDES program), contain
industry-specific, technology-based and/or water quality-based limits, and
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.
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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 material storage areas at an industrial plant
(40 CFR 122.26 (b)(14)). These regulations require that facilities with the
following storm water discharges apply for an NPDES permit: (1) a discharge
associated with industrial activity; (2) a discharge from a large or medium
municipal storm sewer system; or (3) a discharge which EPA or the State
determines to contribute to a violation of a water quality standard or is a
significant contributor of pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity" means a
storm water discharge from one of 11 categories of industrial activity defined
at 40 CFR 122.26. Six of the categories are defined by SIC codes while the
other five are identified through narrative descriptions of the regulated
industrial activity. If the primary SIC code of the facility is one of those
identified in the regulations, the facility is subject to the storm water permit
application requirements. If any activity at a facility is covered by one of the
five narrative categories, storm water discharges from those areas where the
activities occur are subject to storm water discharge permit application
requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
particular facility falls within one of these categories, the regulation should be
consulted.
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.
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Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the •
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
products (except leather and tanning and finishing); SIC 323-glass products;
SIC 34-fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
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
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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 (SDWA)
The SDWA mandates that EPA establish regulations to protect human health
from contaminants in drinking water. The law authorizes EPA to develop
national drinking water standards and to create a joint Federal-State system
to ensure compliance with these standards. The SDWA also directs EPA to
protect underground sources of drinking water through the control of
underground injection of liquid wastes.
EPA has developed primary and secondary drinking water standards under its
SDWA authority. EPA and authorized states enforce the primary drinking
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.
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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 (TSCA)
TSCA granted EPA authority to create a regulatory framework to collect data
on chemicals in order to evaluate, assess, mitigate, and control risks which
may be posed by their manufacture, processing, and use. TSCA provides a
variety of control methods to prevent chemicals from posing unreasonable
risk.
TSCA standards may apply at any point during a chemical's life cycle. Under
TSCA §5, EPA has established an inventory of chemical substances. If a
chemical is not already on the inventory, and has not been excluded by TSCA,
a premanufacture notice (PMN) must be submitted to EPA prior to
manufacture or import. The PMN must identify the chemical and provide
available information on health and environmental effects. If available data
are not sufficient to evaluate the chemicals effects, EPA can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of chemicals
based upon factors such as the projected volume and use of the chemical.
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 (CAA)
The 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 50-99.
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Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur
dioxide. Geographic areas that meet NAAQSs for a given pollutant are
classified as attainment areas; those that do not meet NAAQSs are classified
as non-attainment areas. Under §110 of the CAA, each State must develop
a State Implementation Plan (SIP) to identify sources of air pollution and to
determine what reductions are required to meet Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPSs), which are nationally uniform emission standards for new stationary
sources falling within particular industrial categories. NSPSs are based on the
pollution control technology available to that category of industrial source but
allow the affected industries the flexibility to devise a cost-effective means of
reducing emissions.
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
towards controlling particular hazardous air pollutants (HAPs). Title III of
the CAAA further directed EPA to develop a list of sources that emit any of
189 HAPs, and to develop regulations for these categories of sources. To
date, EPA has listed 174 categories and developed a schedule for the
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, talcing 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
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distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000,
while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030.
EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at (800) 535-0202, answers questions about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Network Bulletin Board System (modem access (919) 541-5742)) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
VLB. Industry Specific Requirements
The organic 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 the
nation's health, safety, and environment. A summary of the major federal
regulations affecting the chemical industry follows. The Synthetic Organic
Chemical Manufacturer's Association is undertaking a year-long study to
identify the environmental regulations that apply to their members. The study
should be available in early 1996.
Federal Statutes
Toxic Substances Control Act (TSCA)
TSCA 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 organic chemical industry. TSCA §5 mandates that chemical
companies submit pre-manufacture notices that provide information on health
and environmental effects for each new product and test existing products for
these effects (40 CFR Part 720). TSCA §4 authorizes the EPA to require
testing of certain substances (40 CFR Part 790). TSCA §6 gives the EPA
authority to prohibit, limit or ban the manufacture, process and use of
chemicals (40 CFR Part 750). To date over 20,000 premanufacturing notices
have been filed.
Clean Air Act
The original CAA authorized EPA to set limits on chemical plant emissions.
Many of these new source performance standards (NSPS) apply to organic
chemical manufacturers including those for flares (40 CFR Part 60 Subpart
A), storage vessels (40 CFR Part 60 Subpart K), synthetic organic chemical
manufacturers equipment leaks (40 CFR Part 60 Subpart W), synthetic
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organic chemicals manufacturers using air oxidation processes (40 CFR Part
60 Subpart m), distillation operations (40 CFR Part 60 Subpart NNN),
reactor processes (40 CFR Part 60 Subpart RRR), and wastewater (40 CFR
Part 60 Subpart YYY).
The Clean Air Act Amendments of 1990 set control standards by industrial
sources for 41 pollutants to be met by 1995 and for 148 other pollutants to
be reached by 2003. Several provisions affect the organic chemical industry.
Under the air toxics provisions of the CAAA, more sources are covered
including small businesses. In April 1994, the EPA proposed regulations to
reduce air toxics emissions at chemical plants. The Hazardous Organic
National Emissions Standard for Hazardous Air Pollutants, also known as
HON, covers hundreds of chemical plants and thousands of chemical process
units (40 CFR Part 63 Subparts F, G, H, I, J, K). The HON also includes
innovative provisions such as emissions trading, that offer industry flexibility
in complying with the rule's emissions goals. Subsets of the industry are
regulated under other National Emission Standards for Hazardous Air
Pollutants (NESHAP). These include vinyl chloride manufacturers (40 CFR
Part 61 Subpart F), benzene emission from ethylbenzene/styrene
manufacturers (40 CFR Part 61 Subpart I), benzene equipment leaks (40 CFR
Part 61 Subpart J), emissions from storage tanks (40 CFR Part 61 Subpart
K), benzene emissions from benzene transfer operations (40 CFR Part 61
Subpart BB), and benzene waste operations (40 CFR Part 61 Subpart FF).
Another NESHAP that may affect organic chemical manufacturers is that for
treatment, storage, and disposal facilities (TSDF) (40 Part CFR 63 Subpart
AA). CAAA provisions on oxygenated additives for reformulated gasoline
have also affected the chemical industry by encouraging production of the
oxygenates methyl tert-butyl ether and ethyl tert-butyl ether.
Title V of the CAA introduces a new permit system that will require all major
sources to obtain operating permits to cover all applicable control
requirements. States were required to develop and implement the program
in 1993 and the first permits were to be issued in 1995.
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. In 1987, EPA
proposed final effluent guidelines for the organic, polymer and synthetic fiber
industry. The majority of this rule was upheld by the federal courts. A final
proposal for the remaining portions of the rule was issued in August 1993.
The implementation of the guidelines is left to the states who issue National
Pollutant Discharge Elimination System (NPDES) permits for each facility.
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The Storm Water Rule (40 CFR §122.26(b)(14) Subparts (i, ii)) requires the
capture and treatment of stormwater at facilities producing chemicals and
allied products, including industrial organic chemical manufacture. Required
treatment will remove from stormwater flows a large fraction of both
conventional pollutants, such as suspended solids and biological oxygen
demand (BOD), as well as toxic pollutants, such as certain metals and organic
compounds.
Superfund
The Comprehensive Environmental Response Compensation and Liability Act
of 1980 (CERCLA) and the Superfund Amendments and Reauthorization Act
of 1986 (SARA) provide the basic legal framework for the federal
"Superfund" program to clean up abandoned hazardous waste sites (40 CFR
Part 305). The 1986 SARA legislation extended those taxes for five years
and adopted a new broad-based corporate environmental tax. In 1990,
Congress passed a simple reauthorization that did not substantially change the
law but extended the program authority until 1994 and the taxing authority
until 1995. The chemical industry (all SIC codes) pays about $300 million a
year in Superfund chemical feedstock taxes. A comprehensive reauthorization
was considered in 1994. The industry believes several serious concerns need
to be addressed including the liability standard which threatens Potentially
Responsible Parties (PRPs) with the entire cost of clean-up at sites even
though they may be responsible for only a tiny fraction of the waste; clean-up
requirements, which are often unaffordable, unattainable, and unjustified by
the risks presented by the sites; and the punitive, adversarial nature of the
enforcement program.
Title in of the 1986 SARA amendments (also known as Emergency Response
and Community Right-to-Know Act, EPCRA) requires all manufacturing
facilities, including chemical facilities, to report annual information to the
public about stored toxic substances as well as release of these substances into
the environment (42 U.S.C. 9601). This is known as the Toxic Release
Inventory (TRI). Between 1988 and 1993 TRI emissions by chemical
companies to air, land, and water were reduced 44 percent. EPCRA also
establishes requirements for federal, state, and local governments regarding
emergency planning. In 1994, over 300 more chemicals were added to the list
of chemicals for which reporting is required.
VI.C. Pending and Proposed Regulatory Requirements
Chemical Inventory Update Rule
Every four years chemical manufacturers must report to EPA on their
manufacture, importation, and, in 1994, use of chemicals on the Toxic
Substances Control Act inventory.
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VH. COMPLIANCE AND ENFORCEMENT PROFILE
Background
To date, EPA has focused much of its attention on measuring compliance
with specific environmental statutes. This approach allows the Agency to
track compliance with the Clean Air Act, the Resource Conservation and
Recovery Act, the Clean Water Act, and other environmental statutes. Within
the last several years, the Agency has begun to supplement single-media
compliance indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track compliance with
all statutes at the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for industrial
sectors was the creation of EPA's Integrated Data for Enforcement Analysis
(IDEA) system. IDEA has the capacity to "read into" the Agency's single-
media databases, extract compliance records, and match the records to
individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation, and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within the
sector that are well defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section IT). 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 makeup.
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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 and enforcement actions, and solely reflect EPA, State, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
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/ 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 Recoveiy Information
System, Office of Solid Waste), NCDB (National Compliance Data Base,
Office of Prevention, Pesticides, and Toxic Substances), CERCLIS
(Comprehensive Environmental and Liability Information System, Superfund),
f 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 (LA, KS,
MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ED, OR, WA).
September 1995
88
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Sector Notebook Project
Organic Chemical Industry
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-inspectiqnal 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 inspectipn 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 (a facility with three enforcement actions counts as one). All
percentages that appear are referenced to the number of facilities inspected.
Total Enforcement Actions — describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes. A
facility with multiple enforcement actions is counted multiple times (a facility
with three enforcement actions counts as three).
State Lead Actions — shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use of EPA data systems by states 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.
September 1995
89
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Sector Notebook Project
Organic Chemical Industry
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.
This measure simply indicates historically how many enforcement actions can
be attributed to inspection activity. Reported inspections and enforcement
actions under the Clean Water Act (CWA), the Clean Air Act (CAA) and the
Resource Conservation and Recovery Act (RCRA) are included in this ratio.
Inspections and actions from the TSCA/FIFRA/EPCRA database are not
factored into this ratio because most of the actions taken under these
programs are not the result of facility inspections. This ratio does not account
for enforcement actions arising from non-inspection compliance monitoring
activities (e.g., self-reported water discharges) that can result in enforcement
action within the CAA, CWA, and RCRA.
Facilities with One or More Violations Identified ~ indicates the number
and percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year Noncompliance, Significant
Noncompliance (CWA); Noncompliance and Significant Noncompliance
(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High
Priority Violation (RCRA). The values presented for this column reflect the
extent of noncompliance within the measured time frame, but do not
distinguish between the severity of the noncompliance. Percentages within
this column can exceed 100 percent because facilities can be in violation
status without being inspected. Violation status may be a precursor to an
enforcement action, but does not necessarily indicate that an enforcement
action will occur.
Media Breakdown of Enforcement Actions and Inspections — four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
September 1995
90
SIC 286
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Sector Notebook Project
Organic Chemical Industry
VILA. Organic Chemicals Compliance History
Exhibit 26 provides an overview of the reported compliance and enforcement
data for the organic 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.
• About 77 percent of the organic chemical producing facilities
identified in the IDEA search were inspected in the past five years.
These facilities were inspected on average every six months.
• Those facilities with one or more enforcement actions had, on
average, over the five year period, almost five enforcement actions
brought against them.
• The complexity of reactions and diversity among and within facilities
makes it difficult to generalize about the types of compliance
problems facilities will face.
September 1995
91
SIC 286
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Sector Notebook Project
Organic Chemical Industry
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September 1995
92
SIC 286
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Sector Notebook Project
Organic Chemical Industry
V1I.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 27 and 28 allow the compliance history of the organic chemical
industry to be compared with the other industries covered by the industry
sector notebooks. Comparisons between Exhibits 27 and 28 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 organic chemical industry has a relatively high frequency of
inspections compared to the other sectors shown. On average,
organic chemical facilities were inspected every six months.
• Over the last five years, the organic chemical industry has had a
relatively high ratio of enforcement actions to inspections. This
relatively high ratio has continued in the past year.
• Of the sectors shown, the organic chemical industry has one of the
highest percentage of EPA led enforcement actions versus state led
actions.
Exhibits 29 and 30 provide a more in-depth comparison between the organic
chemical industry and other sectors by breaking out the compliance and
enforcement data by environmental statute. As in Exhibits 29 and 30, the data
cover the last five years (Exhibit 27) and the previous year (Exhibit 28) to
facilitate the identification of recent trends. A few points evident from the
data are listed below.
• Over the past five years, RCRA has accounted for the largest share of
inspections and enforcement actions at organic chemical facilities;
This trend has increased over the past year.
• The share of enforcement actions and inspections has decreased in the
past year for the Clean Water Act and FIFRA/TSCA/EPCRA/Other
and has increased for the Clean Air Act and RCRA in comparison to
the previous five years.
September 1995
93
SIC 286
-------
Sector Notebook Project
Organic Chemical Industry
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96
SIC 286
-------
Sector Notebook Project
Organic Chemical Industry
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Vn.C. Review of Major Legal Actions
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 Office of Enforcement Capacity and Outreach 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 (SEPs)
Supplemental environmental projects (SEPs) are negotiated environmental
projects such that a fraction of the costs may be applied to their fine.
Regional summaries of SEPs actions undertaken in the 1993 and 1994 federal
fiscal year were reviewed. Seventeen projects were undertaken that involved
organic chemical manufacturing facilities, as shown in the following table.
CERCLA violations engendered approximately half of all projects. Other
actions were associated withEPCRA, CAA, RCRA and TSCA violations; the
specifics of the original violations are not known.
The majority of SEPs were done in Region VI. Taken alone, Texas
accounted for approximately one-third of all projects (6 of 17). The fact that
only one fifth of all organic chemical manufactures are located in Region VI;
may suggest that negotiating SEPs is a regional priority.
One project was conducted at a facility that manufactured both inorganic and
organic chemicals. This project has been included in both industry sector
project summaries. Unlike other sectors, none of the organic chemical
manufacturing SEPs undertaken in FY-1993 and FY-1994 involved specific
manufacturing process changes. The SEPs fall into two categories:
• Non-process related projects: Eleven of the seventeen SEPs involved
projects not directly related to the organic chemical manufacturing
process or its outputs. Ten of these projects involved a contribution
to the Local Emergency Planning Committee (LEPC). Contributions
ranged from donation of equipment (e.g., computer systems and
emergency materials) to training programs for LEPC members. One
September 1995
98
SIC 286
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Sector Notebook Project
Organic Chemical Industry
project involved the replacement of QA/QC lab equipment with less
solvent-requiring alternatives. The other project involved removing
and properly disposing of 26 PCB capacitors. Cost to company
ranged from $3,000 to $257,000 for these projects.
Control and recovery technology improvement/installation: In four of
the projects, control or recovery technologies were installed or
upgraded to reduce toxic chemical production from manufacturing
processes. Cost for project implementation ranged from $125,000 to
$200,000.
September 1995
99
SIC 286
-------
Sector Notebook Project
Organic Chemical Industry
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September 1995
101
SIC 286
-------
-------
Sector Notebook Project
Organic Chemical Industry
VHI. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VDI.A. Sector-related Environmental Programs and Activities
Chemical Manufacturer's Association and EPA are discussing developing
plant level compliance guides, auditing protocols, and training materials for
new regulations.
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 32 lists those
companies participating in the 33/50 program that reported the SIC code 286
to TRI. Many of the companies shown listed multiple SIC codes and,
therefore, are likely to carry out operations in addition to organic chemical
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 286 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 organic chemicals industry as a whole used, generated or processed all
seventeen target TRI chemicals. Of the target chemicals, benzene, toluene,
xylenes and methyl isobutyl ketone are released most frequently and in similar
quantities. Significant amounts of methyl ethyl ketone are also released,
although it is only the seventh most frequently reported 33/50 chemical.
These five toxic chemicals account for about eight percent of TRI releases and
transfers from organic chemicals facilities. From Exhibit 32, 115 companies
representing 335 facilities listed under SIC 286 are currently participating in
the 33/50 program. They account for 34 percent of the 986 facilities carrying
out organic chemicals manufacturing operations (as identified by the 1992
Census of Manufacturers), 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)
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Exhibit 32: 33/50 Program Participants Reporting SIC 286
(Organic Chemicals)
Parent Company
A, W, Chesterton Company
Air Products And Chemicals
Akzo Nobel Inc.
Albcmarle Corporation
Allied-Signal Inc.
American Home Products Corp.
American Pctrofina Holding Co.
Amoco Corporation
Anstcch Chemical Corporation
Arrow Eng, Inc.
Ashlfind Oil Inc.
Atlantic Richfield Company
B F Goodrich Company-
BASF Corporation
Baxter International Inc.
Bordcn Chcm. & Plas. Ltd. Partner
Borden Inc.
BP America Inc.
Buffalo Color Corporation
CPU Holding Corporation
Capital Resin Corporation
Chcmdesign Corporation
Chemical Solvents Inc.
Chevron Corporation
Ciba-Gcigy Corporation
Citgo Petroleum Corporation
Coopers Creek Chemical
Cronipton & Knowles Corporation
Cytcc Industries
Dcgussa Corporation
Dow Chemical Company
Dow Corning Corporation
City, State
Stoneham, MA
Allentown, PA
Chicago, IL
Richmond, VA
Morristown, NJ
New York, NY
Dallas, TX
Chicago, IL
Pittsburgh, PA
Dalton, GA
Russell, KY
Los Angeles, CA
Akron, OH
Parsippany, NJ
Deerfield, IL
Columbus, OH
New York, NY
Cleveland, OH
Parsippany, NJ
Chicago, IL
Columbus, OH
Fitehburg, MA
Cleveland, OH
San Francisco, CA
Ardsley.NY
Tulsa, OK
West Conshohocken, PA
Stamford, CT
WestPaterson.NJ
RidgefieldPark.NJ
Midland, MI
Midland, MI
SIC Codes
Reported
2869,3053,3561
2873, 2869
2819,2869
2869
2819,2869
2833, 2869
2865
2865
2865
2843,2865,2869
2865
2865,2869
2869
2869,2865,2819
2869
2813,2821,2869
2869,2821
2869
2865
2869
2869,2821
2869
2869
2865
2879,2821,2865
2911,2819,2869
2865
2865
2819,2869
2819,2869,2879
2800,2819,2821
2869,2822,2821
Number of
Participating
Facilities
1
6
5
3
10
3
1
10
4
1
3
3
4
6
1
1
1
2
1
1
1
2
2
4
4
1
1
5
2
1
5
2
1993 Releases
and Transfers
Cbs)
13,250
144,876
930,189
1,005,108
2,080,501
1,210,834
747,799
4,632,163
196,400
250
723,562
2,435,248
621,207
1,157,548
42,570
12,662
1,644,614
1,597,404
10,705
7,003
62,850
47,435
955,751
2,794,502
1,875,028
1,164,354
19,690
30,239
1,074,646
676,418
2,769,363
1,134,610
% Reduction
1988 to
1993
65
50
13
51
50
50
40
50
18
50
50
2
50
50
80
***
*
24
8
50
50
*
***
50
50
20
20
50
50
***
50
16
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Exhibit 32: 33/50 Program Participants Reporting SIC 286
(Organic Chemicals)
Parent Company
DSM Finance USA Inc.
E. I. Du Pont De Nemours & Co.
Eastman Kodak Company
Elf Aquitaine Inc.
EM Industries Incorporated
Engelhard Corporation
Ethyl Corporation
Exxon Corporation
Ferro Corporation
First Mississippi Corporation
FMC Corporation
Gaf Corporation
Gencorp Inc.
General Electric Company
Georgia Gulf Corporation
Georgia-Pacific Corporation
Goodyear Tire & Rubber Co.
Henkel Corporation
f-Iercules Incorporated
HM Anglo-American Ltd.
Hoechst Celanese Corporation
Hoffman-La Roche
[CI Americas
International Paper Company
James River Corp Virginia
Johnson & Johnson
Kalama Chemical
Laidlaw Environmental Services
Laroche Holdings Inc.
Lubrizol Corp.
Lyondell Petrochemical Co.
Vlallinckrodt Group Inc.
Merck & Co. Inc.
Vtiles Inc.
City, State
Wilmington, DE
Wilmington, DE
Rochester, NY
New York, NY
Hawthorne, NY
Iselin,NJ
Richmond, VA
Irving, TX
Cleveland, OH
Jackson, MS
Chicago, IL
Wayne, NJ
Akron, OH
Fairfield, CT
Atlanta, GA
Atlanta, GA
Akron, OH
King Of Prussia, PA
Wilmington, DE
New York, NY
Somerville, NJ
Nutley, NJ
Wilmington, DE
Purchase, NY
Richmond, VA
New Brunswick, NJ
Seattle, WA
Columbia, SC
Atlanta, GA
Wickliffe, OH
Houston, TX
Saint Louis, MO
Rahway, NJ
Pittsburgh, PA
SIC Codes
Reported
2869,2873
2865,2824,2821
2869,2865
2869,2821,2819
5169,2869,2899
2816,2865,2819
2869
2869
2819,2869
2865
2879,2869,2819
2869, 2865, 2834
3764,2892,3761
2821,2812,2869
2865,2812,2819
2611,2631,2861
2865, 2869
2869
2861,2821,2869
2869
2869,2821
2869, 2879, 2844
2869, 3089
2861
2621,2611,2869
2833, 2869
2865, 2869
2819,2869
2812,2869
2869
2869,2821
2869, 2873
2833, 2869, 2879
2865
Number of
Participating
Facilities
1
16
\ 4
4
1
1
2
6
3
2
2
3
1
3
2
1
3
4
2
1
12
1
3
2
1
1
1
1
1
4
1
5
1
7
1993 Releases
and Transfers
Obs)
964,346
11,740,853
5,827,091
273,274
9,055
236,302
251,519
2,469,930
165,529
200,977
502,318
944,730
5,453,359
5,010,856
39,480
2,722,182
3,932,157
164,363
5,014,664
1,265,741
2,603,661
902,929
165,162
2,784,831
961,588
317,843
214,665
8,167
81,470
466,871
285,430
775,206
1,456,238
1,095,504
% Reduction
1988 to
1993
32
50
50
43
15
50
46
50
50
***
50
44
34
50
80
50
50
55
50
2
50
62
50
50
53
65
37
***
*
50
57
50
50
40
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Exhibit 32: 33/50 Program Participants Reporting SIC 286
(Organic Chemicals)
Pnrent Company
Millikcn & Company
Milliporc Corporation
Mobil Corporation
Monsanto Company
Moore Business Forms (Del)
Morgan Stanley Leveraged Fund
Morton International Inc.
Nalco Chemical Company
Nashua Corp.
Occidental Petroleum Corp.
Olin Corporation
PCR Group Inc.
PCL Group Inc.
Perkin-Elmcr Corporation
Philip Morris Companies Inc.
Phillips Petroleum Company
PPG Industries Inc.
Procter & Gamble Company
Quantum Chemical Corporation
Rexcne Corporation
Rhone-Poulcnc Inc.
Rohm and Haas Company
Rubicon Inc.
Sandoz Corporation
Sartomcr Company Inc.
Schcncetady Chemical Inc.
Shell Petroleum Inc.
Shepherd Chemical Co.
Standard Chlorine Chemical Co.
Stcpan Company
Sterling Chemicals Inc.
Syntex Usa Inc.
Texaco Inc.
Texas Olcfins Company
City, State
Spartanburg, SC
Bedford, MA
Fairfax, VA
Saint Louis, MO
Lake Forest, IL
New York, NY
Chicago, IL
Naperville, IL
Nashua, NH
Los Angeles, CA
Stamford, CT
Jacksonville, FL
Cincinnati, OH
Norwalk, CT
New York, NY
Bartlesville, OK
Pittsburgh, PA
Cincinnati, OH
Iselin.NJ
Dallas, TX
Monmouth Junction, NJ
Philadelphia, PA
Geismar, LA
New York, NY
Exton,PA
Schenectady, NY
Houston, TX
Cincinnati, OH
Kearny, NJ
Northfield, IL
Houston, TX
Palo Alto, CA
White Plains, NY
Houston, TX
SIC Codes
Reported
2869, 2843, 2865
2869
2911,2869
2824,2869,2821
2761,2865,2821
2869
2821,2891,2879
2869,2899,2819
2672, 3572, 3577
2869
2869,2841,2843
2869
2865, 2873, 2879
3826, 2869
2022, 2869
2869,2821
2812,2816,2869
2869
2821,2869
2821,2869
2879,2869
2869
2865, 2869, 2873
2865
2821,2869,2899
2821,2869
2869
2819,2869
2865,2819
2843,2865,2869
2869,2865,2819
2833,2048,2869
2869
2869
Number of
Participating
FaciUties
1
1
5
11
1
1
4
4
1
10
3
1
1
1
1
4
3
3
5
1
5
5
1
1
1
1
4
1
1
1
1
2
4
1
1993 Releases
and Transfers
(Ibs)
13,500
65,529
4,263,284
1,683,580
107,091
2,166,420
721,216
107,651
1,818,504
8,896,126
574,673
26,510
471,405
25,865
259,053
2,367,877
2,772,331
612,520
289,235
128,054
1,437,778
1,210,244
134,306
104,490
41,893
239,285
3,240,716
828
48,246
25,186
182,216
499,873
514,803
214
% Reduction
1988 to
1993
50
50
50
23
42
13
20
50
**
19
70
3
***
*
**
50
50
*
50
50
50
50
75
50
*
***
55
72
***
***
65
33
50
33
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Exhibit 32: 33/50 Program Participants Reporting SIC 286
(Organic Chemicals)
Parent Company
Unilever United States Inc.
Union Camp Corporation
Union Carbide Corporation
Uniroyal Chemical Corporation
United Organics Corp.
UOP
Veba Corporation
Velsicol Chemical Corporation
Vista Chemical Company
Vulcan Materials Company
Wacker Chemical Corporation
Walter Industries Inc.
Westvaco Corporation
Witco Corporation
Zeneca Holdings Inc.
City, State
New York, NY
Wayne, NJ
Danbury, CT
Middlebury, CT
Williamston,NC
Des Plaines, IL
Houston, TX
Rosemont, IL
Houston, TX
Birmingham, AL
Williamsburg, VA
Tampa, FL
New York, NY
New York, NY
Wilmington, DE
SIC Codes
Reported
2821,2891,2869
2869
2821,2869
2822, 2869, 2879
2869
2819,2869
2869, 2992
2865,2819,2869
2821,2869
2869,2812
2821,2891,2869
2869
2861
2869,2899,2841
2869,2843,2899
Number of
Participating
Facilities
3
4
7
2
1
2
3
2
3
2
1
1
2
6
5
1993 Releases
and Transfers
(Ibs)
164,034
835,696
728,129
1,970,357
14,127
14,169
24,254
224,664
106,497
679,566
772
859,751
877,866
327,611
1,609,047
% Reduction
1988 to
1993
50
50
50
20
*
50
10
50
50
85
*
***
50
50
*
* = not quantifiable against 1988 data.
** = use reduction goal only.
*** = no numerical goal.
Source: U.S. EPA, Toxics Release Inventory, 1993.
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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 mentor programs. In return for
participating, pilot participants receive public recognition and are given a
period of time to correct any violations discovered during these experimental
projects.
Forty proposals were received from companies, trade associations, and federal
facilities representing many manufacturing and service sectors. One chemical
company's proposal was accepted (Ciba Geigy of St. Gabriel, LA). Another
chemical firm (Akzo Chemicals of Edison, NJ), one pharmaceutical
manufacturer (Sch'ering Plough of Kenilworth, NJ) and one manufacturer of
agricultural chemicals (Gowan Milling of Yuma, AZ) have submitted
proposals. (Contact: Tia-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 specifc 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
at EPA's Office of Policy Analysis 202 260-4034)
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program has over 1,500 participants which include
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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
at 202-233-9178 or the Green Light/Energy Star Hotline at 202-775-6650)
WasteWi$e Program
The WasteWiSe Program was started in 1994 by EPA's Office of Solid Waste
and Emergency Response. The program is aimed at reducing municipal solid
wastes by promoting waste minimization, recycling collection, and the
manufacturing and purchase of recycled products. As of 1994, the program
had about 300 companies as members, including a number of major
corporations. Members agree to identify and implement actions to reduce
their solid wastes and must provide EPA with their waste reduction goals
along with yearly progress reports. EPA, in turn, provides technical
assistance to member companies and allows the use of the WasteWi$e logo
for promotional purposes. (Contact: Lynda Wynn 202-260-0700 or the
WasteWiSe Hotline at 800-372-9473)
Climate Wise Recognition Program
NICE3
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)
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
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energy-efficient and cost-competitive through waste minimization efforts.
Grants are used by industry to design, test, demonstrate, and assess the
feasibility of new processes and/or equipment with the potential to reduce
pollution and increase energy efficiency. The program is open to all
industries; however, priority is given to proposals from participants in the pulp
and paper, chemicals, primary metals, and petroleum and coal products
sectors. (Contact: DOE's Golden Field Office 303-275-4729)
VIII.C. Trade Association/Industry Sponsored Activity
Vm.C.1. Environmental Programs
The Global Environmental Management Initiative (GEMI) is made up of
group of leading companies dedicated to fostering environmental excellence
by business. GEMI promotes a worldwide business ethic for environmental
management and sustainable development, to improve the environmental
performance of business through example and leadership. In 1994, GEMTs
membership consisted of about 30 major corporations including Union
Carbide Corporation and Dow Chemical.
Center for Waste Reduction Technologies under the aegis of the American
Institute of Chemical Engineers sponsored research on innovative
technologies to reduce waste in the chemical processing industries. The
primary mechanism is through funding of academic research.
The National Science Foundation and the Environmental Protection Agency's
Office of Pollution Prevention and Toxics signed an agreement in January of
1994 to coordinate the two agencies' programs of basic research related to
pollution prevention. The collaboration will stress research in the use of less
toxic chemical and synthetic feedstocks, use of photochemical processes
instead of traditional ones that employ toxic reagents, use of recyclable
catalysts to reduce metal contamination, and use of natural feedstocks when
synthesizing chemicals in large quantities.
The Chemical Manufacturer's Association funds research on issues of
interest to their members particularly in support of their positions on proposed
or possible legislation. They recently funded a study to characterize the
environmental fate of organochlorine compounds.
ISO 9000 is a series of international total quality management guidelines.
After a successful independent audit of their management plans, firms are
qualified to be ISO 9000 registered. In June of 1993, the International
Standards Organization created a technical committee to work on new
standards for environmental management systems.
The Responsible Care® Initiative of the Chemical Manufacturer's
Association requires all members and partners to continuously improve their
health, safety, and environmental performance in a manner that is responsive
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to the public. Launched in 1988, the Responsible Care® concepts are now
being applied in 36 countries around the world. Responsible Care® is a
comprehensive, performance-oriented initiative composed often progressive
Guiding Principles and six board Codes of Management Practices. These
Management Practices cover all aspects of the chemical industry's operations,
from research to manufacturing, distribution, transportation, sales and
marketing, and to downstream users of chemical products. Through
Responsible Care®, CMA members and partners gain insight from the public
through, among other means, a national Public Advisory Panel and over 250
local Community Advisory Panels. This, coupled with the fact that
participation in Responsible Care® is an obligation of membership with the
Chemical Manufacturer's Association, make this performance improvement
initiative unique. The Synthetic Organic Chemical Manufacturer's
Association whose membership consists of smaller batch and custom chemical
manufacturers with typically fewer than 50 employees and less than $50
million in annual sales, encourages its members to achieve continuous
performance improvement in their health, safety, and environmental programs
through implementation of the chemical industry's Responsible Care®
initiative. SOCMA is a partner in Responsible Care®.
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Vm.C.2. Summary of Trade Associations
American Chemical Society
1155 16th Street, NW
Washington, D.C. 20036
Phone: (202) 872-8724
Fax: (202) 872-6206
Budget: $192,000,000
Staff: 1700
Members: 145,000
The American Chemical Society (ACS) has an educational and research focus.
The ACS produces approximately thirty different industry periodicals and
research journals, including Environmental Science and Technology and
Chemical Research in Toxicology. In addition to publishing, the ACS
presently conducts studies and surveys; legislation monitoring, analysis, and
reporting; and operates a variety of educational programs. The ACS library
and on-line information services are extensive. Some available on-line
services are Chemical Journals Online, containing the full text of 18 ACS
journals, 10 Royal Society of Chemistry journals, 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 Manufacturer's Association
2501 M St., NW
Washington, D.C. 20037
Phone:(202)887-1100
Fax: (202) 887-1237
Members: 185
Staff: 246
Budget: $36,000,000
A principal focus of the Chemical Manufacturer's Association (CMA) is on
regulatory issues facing chemical manufacturers at the local, state, and federal
levels. At its inception in 1872, the focus of CMA was on serving chemical
manufacturers through research. Research is still ongoing at CMA. Member
committees, task groups, and work groups routinely sponsor research and
technical data collection that is then provided to the public in support of
CMA's advocacy. Much additional research takes place through the
CHEMSTAR® program. CHEMSTAR® consists of a variety of self-funded
panels working on single-chemical research agendas. This research fits within
the overall regulatory focus of CMA; CHEMSTAR® study results are
provided to both CMA membership and regulatory agencies. Other initiatives
include the Responsible Care® program, which includes six codes of
management practices designed to go beyond simple regulatory compliance.
CAM is currently developing measurement and appropriate verification
systems for these codes. CMA also conducts workshops and technical
symposia, promotes in-plant safety, operates a chemical emergency center
(CHEMTREC®) which offers guidance in chemical emergency situations, and
operates the Chemical Referral Center which provides chemical health and
safety information to the public. Publications include the annual U.S.
Chemical Industry Statistical Handbook, containing detailed data on the
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industry; Responsible Care in Action, the 1993-94 progress report on
implementing Responsible Care®; and Preventing Pollution: A Chemical
Industry Progress Report (1988-1992), summarizing waste generation and
reduction data for the years 1988-92. CMA holds an annual meeting for its
membership in White Sulphur Springs, WV.
Ethylene Oxide Industry Council
2501 M St. NW, Ste. 330
Washington, DC 20037
Phone:(202)887-1198
The Ethylene Oxide Industry Council (EOIC), founded in 1981, is an example
of a panel group within the CHEMSTAR® program of the Chemical
Manufacturer's Association (CMA). The EOIC consists of ethylene oxide
producers and users. Ethylene oxide is used in the manufacture of antifreeze
and polyester fibers, and is widely used as a sterilizing agent. The EOIC
develops scientific, technological, and economic data on the safe use and
manufacture of ethylene oxide. Other duties include informing scientific and
governmental organizations of the industry's views and interests.
Synthetic Organic Chemicals
Manufacturer's Association
1100 New York Avenue,
Washington, D.C. 20005
Phone: (202) 414-4100
Fax: (202) 289-8584
NW
Members: 250
Staff: 50
Synthetic Organic Chemicals Manufacturer's Association (SOCMA) is the
national trade association representing the legislative, regulatory, and
commercial interests of some 250 companies that manufacture, distribute, or
market organic chemicals. Most of SOCMA's members are batch and custom
chemical manufacturers who are the highly innovative, entrepreneurial and
customer-driven sector of the U.S. chemical industry. The majority of
SOCMA's members are small businesses with annual sales of less than $50
million and fewer than 50 employees. SOCMA assists its members in
improving their environmental, safety, and health performance through
various programs focusing on continuous improvement. A bi-monthly
newsletter provides information on legislative and regulatory developments,
as well as on education and training opportunities. SOCMA holds an annual
meeting in May and also sponsors INFORMEX, the largest custom chemical
trade show in the U.S. In addition, SOCMA's Association Management
Center includes two dozen self-funded groups that focus on single chemical
issues.
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Chemical Specialties Manufacturer's
Association
1913 I St. NW
Washington, D.C. 20006
Phone:(202)872-8110
Fax:(202)872-8114
Members: 425
Staff: 31
This organization represents the manufacturers of such specialty chemical
products as pesticides, cleaners, disinfectants, sanitizers, and polishes. The
Chemical Specialties Manufacturer's Association (CSMA) was founded in
1914. Today, the CSMA works with federal and state agencies and public
representatives, to provide their membership with information on govern-
mental activities and scientific developments. Some committees include:
Government Affairs Advisory and Scientific Affairs. Publications include the
quarterly Chemical Times & Trends, the biweekly Legislative Reporter, and
compilations of laws and regulations. CSMA holds an annual December
meeting in Washington, D.C.
Halogenated Solvents Industry Alliance
1225 19th St. NW, Ste. 300
Washington, D.C. 20036
Phone: (202) 223-5890
Members: 200
Budget: $1,400,000
The goal of the Halogenated Solvents Industry Alliance (HSIA) is to develop
programs to address problems involving halogenated solvents. The group is
actively involved in legislative and regulatory issues affecting the industry,
providing industry comments and information to agencies, and representing
the industry at administrative hearings. The HSIA also sponsors working
groups on issues specific to the solvent industry. Publications include the
bimonthly newsletter Halogenated Solvents Industry Alliance, which includes
a listing of publications available from the group and the monthly newsletter
Solvents Update, which covers regulatory development and HSIA actions.
Methyl Chloride Industry Association
c/o Robert Sussman
Latham and Watkins
1001 Pennsylvania Ave. NW, Ste. 1300
Washington, D.C. 20004
Phone: (202) 637-2200
The Methyl Chloride Industry Association (MCIA) was founded in 1981 to
meet the needs of the methyl chloride manufacturing industry on the issue of
government regulation. The group participates in EPA rulemakings as an
industry representative. The MCIA has no publications or annual meetings.
September 1995
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American Institute of Chemical Engineers
1707 L Street, NW, Ste. 333
Washington, D.C. 20036
Phone: (202) 962-8690
Fax: (202) 833-3014
Members: 54,000
Staff: 103
The American Institute of Chemical Engineers (AICHE) is a professional
society of chemical engineers. AICHE develops chemical engineering
curricula and sponsors a variety of chemical study forums. AICHE is split
into twelve divisions including the Environmental, Forest Products, Fuels and
Petrochemical, and Safety and Health divisions. Approximately fourteen
publications are produced by AICHE, such as the quarterly Environmental
Progress, a periodic directory of members, and a variety of pamphlets.
AICHE holds three conferences per year in various locations.
Color Pigments Manufacturer's Association, Inc.
300 N. Washington St., Ste. 102
Alexandria, VA 22314
Phone: (703) 684-4044 Members: 50
Fax: (703) 684-1795 Staff: 5
The Color Pigments Manufacturer's Association (CPMA) represents North
American manufacturers of pigments and pigment ingredients (i.e., dyes). The
CPMA also represents the affiliates of manufacturers of those products who
happen to manufacture the product overseas. The CPMA represents its
membership before government agencies. No further information is available
at this time.
Fire Retardant Chemical Association
851 New Holland Ave., Box 3535
Lancaster, PA 17604
Phone: (717) 291-5616 Members: 42
Fax:(717)295-4538 Staff: 5
Chemical distributors/manufacturers active in promoting fire safety through
chemical technology comprise the Fire Retardant Chemical Association
(FRCA), founded in 1973. The FRCA serves as a forum for information
dissemination on new developments, new applications, and current testing
procedures for fire retardants and chemical fire safety products. Publications
include the periodic Fire Retardant Chemicals Association - Membership
Directory and the Fire Retardant Chemical Association Proceedings.
Educational conferences are held semiannually.
September 1995
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National Paint and Coatings Association
1500 Rhode Island Avenue, NW
Washington, DC 20005
Phone: (202) 462-6272
Fax: (202) 462-8549
Members: 700
Staff: 40
Founded in 1933, the National Paint and Coatings Association (NPCA)
represents manufacturers of paints and chemical coatings as well as suppliers
of paint manufacturing equipment and raw materials. NPCA is involved in
government relations programs, statistical surveys, and industry research.
Committees include Labeling, Scientific, and Government Supply. The NPCA
publishes an annual report, a periodic newsletter and trade directory, and a
variety of guides. The NPCA holds an annual meeting.
Drug, Chemical, and Allied Trades
Association
2 Roosevelt Ave., Suite 301
Syosset, NY 11791 Members: 500
Phone: 516-496-3317 Staff: 3
Fax:516-496-2231
Members: 500
Staff: 3
Budget: $500,000
Drug, Chemical, and Allied Trades Association (DCAT) is comprised of drug,
chemical, and related product (e.g., packaging, cosmetics, essential oils)
manufacturers, advertisers, brokers, and importers. The association publishes
DCAT, a monthly with coverage of federal regulations.
National Association of Chemical
Recyclers
1875 Connecticut Ave., NW
Suite 1200
Washington, DC 20009
Phone: 202-986-8150 Members: 70
Fax: 202-986-2021 Staff: 3
National Association of Chemical Recyclers (NACR) founded in 1980,
consists of recyclers of used industrial solvents. The organization promotes
"responsible and intelligent" regulation and the beneficial reuse of waste.
NACR monitors and reports on regulatory and legislative action affecting the
practice of solvent recycling. NACR also compiles industry statistics. NACR
publishes Flashpoint and a semiannual membership list. NACR holds a
semiannual conference, usually in April or October.
September 1995
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IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCEMATERIALS/BIBLIOGRAPHY
For further information on selected topics within the organic chemical industry
a list of publications and contacts are provided below:
Contacts8
Name
Walter DeRieux
Jim Gould
David Langston
Jim Seidel
Mary J. Legatski
Organization
EPA/OECA
EPA Region VI
EPA Region IV
EPA/NEIC
Synthetic Organic
Chemical
Manufacturers
Association
Telephone
(202) 564-7067
(713) 983-2153
(404) 347-7603
(303)236-5132
(202)414-4100
Subject
Regulatory requirements and
compliance assistance
Industrial processes and
regulatory requirements (CAA,
CWA)
Industrial resources and
regulatory requirements
(RCRA)
Industrial processes and
regulatory requirements
Federal environmental
requirements
CAA: Clean Air Act
CWA: Clean Water Act
OECA: Office of Enforcement and Compliance Assurance
NEIC: National Enforcement Investigations Center
RCRA: Resource Conservation and Recovery Act
General Profile
U.S. Industrial Outlook, 1994, Department of Commerce
Chemical and Engineering News, July 4, 1994 "Facts and Figures for the Chemical Industry." This
information is produced annually.
8 Many of the contacts listed above have provided valuable background information and comments during development of
this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all
statements made within this notebook.
September 1995
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United States International Trade Commission, Synthetic Organic Chemicals, United States
Production and Sales, 1992. [Published annually]
1992 Census of Manufactures, Industry Series, Industrial Organic Chemicals, Bureau of the Census.
Process Descriptions and Chemical Use Profiles
Kirk-Othmer Encyclopedia of Chemical Technology (appropriate volumes)
Ullman's Encyclopedia of Chemical Technology (appropriate volumes)
SRJ Chemical Economics Handbook (This is a proprietary data source and EPA's Regulatory Impacts
Branch has a copy)
SRI Directory of Chemical Producers
Franck, H.G. and J.W. Stadelhofer, 1987. Industrial Aromatic Chemistry, Berlin: Springer-Verlag.
Perry, Robert H. and Cecil H. Chilton, "Chemical Engineers' Handbook" New York: McGraw-Hill
Book Company.
Peters, Max S. and Klaus D. Timmerhaus, "Plant Design and Economics for Chemical Engineers,"
New York: McGraw-Hill Book Company.
Kent,J.(ed.) ReigePs Handbook of Industrial Chemistry, 1992. New York: von Nostrand Reinhold,
Ninth Edition.
Shreve, Chemical Process Industries.
Szmant, H. Harry, 1989. Organic Building Blocks of the Chemical Industry, New York: John Wiley
and Sons.
Tomes Plus Information System. Denver, CO: Micromedia, Inc. Contains information on chemical
use, production, and health effects. (303) 831-1400.
Chemical Manufacturer's Association, Undated. Designing Pollution Prevention into the Process -
Research, Development and Engineering.
U.S. Environmental Protection Agency, 1987. Development Document of Effluent Limitations
Guidelines for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category, EPA
440/1-87/009.
Wells, G. Margaret, 1991. Handbook of Petrochemicals and Processes. Aldershot, England: Gower
Publishing Company.
September 1995
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Regulatory Profile
Hazardous Waste Consultant, Volume 12, October/November 1994. RCRA Land Disposal
Restrictions: A Guide to Compliance, 1995 Edition.
Sustainable Environmental Law, Environmental Law Institute, West Publishing Co., St. Paul, Minn.,
1993.
Pollution Prevention
Breen, Joseph J., and Michael J. Dellarco. Pollution Prevention in Industrial Processes: The Role
of Process Analytical Chemistry. Washington, DC: American Chemical Society, 1992.
Chemical and Engineering News "Design for the Environment: Chemical Syntheses that Don't
Pollute" September 5, 1994. Article on the 1994 American Chemical Society symposium "Design
for the Environment: A New Paradigm for the 21 st Century."
Chemical Manufacturer's Association, "Designing Pollution Prevention into the Process: Research,
Development and Engineering," Washington, DC, 1993. [The reference section from this document
is reproduced below to provide reference to additional sources of information.]
Du Pont Corporation and U.S. Environmental Protection Agency, "Du Pont Chamber Works Waste
Minimization Proj ect" 1993.
Dorfman, M.H. et al. "Environmental Dividends: Cutting More Chemical Wastes. New York, NY:
INFORM, Inc.
Forester, William S., and John H. Skinner. Waste Minimization and Clean Technology: Waste
Management Strategies for the Future. San Diego, CA: Academic Press, 1992.
The Hazardous Waste Consultant, New York: Elsevier Science Inc. (A bimonthly journal.)
Overcash, Michael R. "Techniques for Industrial Pollution Prevention: A Compendium for
Hazardous and Non-Hazardous Waste Minimization. Chelsea, MI: Lewis Publishers, 1986.
Sawyer, Donald T., and Arthur E. Martell, Industrial Environmental Chemistry: Waste Minimization
in Industrial Processes and Remediation of Hazardous Waste. New York, NY: Plenum Press, 1992.
SOCMA Pollution Prevention Study. Prepared for SOCMA Washington, D.C. January 1993.
Profiles pollution prevention activities at four specialty chemical manufacturers.
Theodore, Louis, and Young C. McGuinn. Pollution Prevention. New York: Van Nostrand
Reinhold, 1992.
September 1995
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U.S. Congress, Office of Technology Assessment "Industry, Technology, and the Environment:
Competitive Challenges and Business Opportunities," OTA-ITE-586 (Washington, DC: U.S.
Government Printing Office, January 1994).
September 1995
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References from CMA's "Designing Pollution Prevention into the Process".
Information Sources and Agencies
Pollution Prevention Information Clearinghouse (PPIC) U.S. EPA
The International Cleaner Production Information Clearinghouse (ICPIC); United Nations
Environmental Programme (UNEP), U.S. EPA
Books, Reports and Documents
Noyes Data Corporation, "Alternative Formul'ations and Packaging to Reduce Use of
Chlorofluorocarbons," 1990, ISBNO-8155-1257-0.
Research Triangle Institute, "Alternatives for Measuring Hazardous Waste Reduction," 1991 PB91 -
.208595.
Noyes Data Corporation, "Aqueous Cleaning as an Alternative to CFC and Chlorinated Solvent-
Based Cleaning," 1991, ISBNO-8155-1285-6.
EPA, "Background Document on Clean Products Research and Implementation," 1990, EPA/600/S2-
90/048.
EPA, "Case Studies from the Pollution Prevention Information Clearinghouse: Solvent Recovery "
1989, ISM-4 (PPIC).
Government Institutes, "Case Studies in Waste Minimization," 1991, ISBNO-865 87-267-8.
United Nations Environmental Programme (UNEP), "Cleaner Production Newsletter," Industry and
Environmental Office, ICPIC-1 (PPIC).
EPA, "Degreaser System Pollution Prevention Evaluation," 1990, EPA/600/S2-90/052.
Oregon Department of Environmental Quality, "Guidelines for Waste Reduction and Recycling-
Solvents," 1989, ISM-13 (PPIC).
EPA, "Guides to Pollution Prevention: Research and Educational Institutions," 1990, ISM-19
(PPIC).
EPA, "Guides to Pollution Prevention: The Fiberglass-Reinforced and Composite Plastics Industry "
ISM-19 (PPIC).
McGraw-Hill, Inc., "Hazardous Waste Minimization," 1990, ISBNO-07-022043-3.
Lewis Publishers, "Hazardous Waste Minimization Handbook," 1989, ISBNO-87371-176-9.
September 1995
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ASTM, "Hazardous and Industrial Solid Waste Minimization Practices," 1989, ISBNO-8031-1269-6.
EPA, "Industrial Pollution Prevention for the 1990s," 1991, EPA/600/S8-91/052.
EPA, "Pollution Prevention Benefits Manual: Volume 1 (Draft), 1989, WAM-1 (PPIC).
EPA, "Pollution Prevention Fact Sheets: Chemical Production," FREG-1 (PPIC), free.
EPA, "Pollution Prevention Information Exchange System (PIES) User Guide," Version 1.1, 1989,
EPA/600/9-89/086, free.
City of Los Angeles, "Pollution Prevention Opportunities Checklist: Chemical Manufacturing,"
FCLA-1-1 (PPIC).
CMA, "Pollution Prevention Resource Manual," 1991, $75.00 (non-members), $50.00 (members,
Order no. 018031).
EPA, "Prevention Reference Manual: Chemical Specific, Volume 10: Control of Accidental Releases
of Hydrogen Cyanide," 1987, EPA/600-S 8-87/03 4j.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 11: Control of Accidental Releases
of Ammonia," 1987, EPA/600-S8-87/034k.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 12: Control of Accidental Releases
of Sulfur Dioxide," 1987, EPA/600/S8-87/0341.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 13: Control of Accidental Releases
of Methyl Isocyanate," 1987, EPA/600/S 8-87/03 4m.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 14: Control of Accidental Releases
of Phosgene," 1987, EPA/600/S8-87/034n.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 15: Control of Accidental Releases
of Sulfur Trioxide," 1987, EPA/600/S8-87/034o.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 1: Control of Accidental Releases
of Hydrogen Fluoride (SCAQMD)," 1987, EPA/600/S8-87/034a.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 2: Control of Accidental Releases
of Chlorine (SCAQMD)," 1987, EPA/600/S8-87/034b.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 3: Control of Accidental Releases
of Hydrogen Cyanide (SCAQMD)," 1987, EPA/600/S8-87/034c.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 4: Control of Accidental Releases
of Ammonia Cyanide (SCAQMD)," 1987, EPA/600/S8-87/034d.
September 1995
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EPA, "Prevention Reference Manual: Chemical Specific, Volume 7: Control of Accidental Releases
of Chloropicrin Cyanide (SCAQMD)," 1987, EPA/600/S8-87/034g.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 8: Control of Accidental Releases
of Hydrogen Fluoride," 1987, EPA/600/S8-87/034h.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 9: Control of Accidental Releases
of Chlorine," 1987, EPA/600/S8-87/034i.
EPA, "Prevention Reference Manual: Chemical Specific, Volume 6: Control of Accidental Releases
of Carbon Tetrachloride (SCAQMD)," 1.987, EPA/600/S8-87/034f.
EPA, "Prevention Reference Manual: Control Technologies. Volume 2: Post-Release Mitigation
Measures for Controlling Accidental Releases of Air Toxics," 1987, EPA/600/S8-87/039b.
EPA, "Prevention Reference Manual: Control Technologies. Volume 1: Prevention and Protection
Technologies for Controlling Accidental Releases of Air Toxics," 1987, EPA/600/S8-87/039a.
EPA, "Prevention Reference Manual: Overviews on Preventing and Controlling Accidental Releases
of Selected Toxic Chemicals," 1988, EPA/600/S8-88/074.
EPA, "Prevention Reference Manual: User's Guide, Overview for Controlling Accidental Releases
of Air Toxics," 1987, EPA/600/S8-87/028.
EPA, "Proceedings of the International Workshop on Research in Pesticide Treatment/Disposal/
Waste Minimization," 1991, EPA/600-S9-91/047.
Alaska Health Project, "Profiting from Waste Reduction in Your Small Business," 1988, free, QAM-2
(PPIC).
National Academy Press, "Reducing Hazardous Waste Generation: An Evaluation and a Call for
Action," 1985, $9.95, ISBN 0-309-03498-1.
Noyes, Data Corporation, "Solvent Waste Reduction," 1990, $45, ISBN 0-8155-1254-6.
EPA, "Solvent Waste Reduction Alternatives," 1989, EPA/625/4-89/021.
EPA, "Source Characterization and Control Technology Assessment of Methylene Choride Emissions
from Eastman Kodak Company," Rochester, NY, 1989, EPA/600-S2-043.
Government Institutes, "The Greening of American Business: Making Bottom-Line Sense of
Environmental Responsibility," 1992, $24.95, ISBN: 0-86587-295-3.
Van Nostrand Reinhold, "The Recycler's Manual for Business, Government, and the Environmental
Community," 1992, $64.95, ISBN 0-442-01190-3.
National Academy Press, "Tracking Toxic Substances at Industrial Facilities: Engineering Mass
Balance Versus Materials Accounting," 1990, ISBN 0-0309-04086-8.
September 1995
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EPA, "Waste Exchange Information Package," 1991, free, GEN-13 (PPIC).
EPA, "Waste Minimization: Environmental Quality with Economic Benefits," 1990, free, EPA/530-
SW-87-026 (also GEN-14 (PPIC)).
Government Institutes, "Waste Minimization Manual," 1987, $57.00, ISBN: 0-86587-731-9.
EPA, "Waste Minimization Opportunity Assessment Manual," 1988, EPA/625/7-88/003.
CMA, "Waste Minimization Workshop Handbook," 1987, $250.00 (non-members); $100.00
(members), Order no. 018016.
API, "Waste Minimization in the Petroleum Industry: A Compendium of Practices," 1991, $35.00,
Order no. 849-30200.
Lewis Publishers, "Waste Minimization: Implementing an Effective Program," due 1992, $59.00,
ISBN 0-87371-521-7.
Noyes Data Corporation, "Waste Oil: Reclaiming Technology, Utilization, and Disposal," 1989,
$39.00, ISBN 0-8155-1193-0.
California Department of Health Service, "Waste Reduction Fact Sheet: Pesticide Formulating
Industry," free, FCAD-7 (PPIC).
Executive Enterprises, "Waste Reduction: Policy and Practice, $39.95, ISBN 1-55840-272-1.
Journals/Newsletters
ChemEcology, Chemical Manufacturer's Association, (202) 887-1100.
Chemical Research in Toxicology, American Chemical Society, (700) 333-9511.
CMA News, Chemical Manufacturer's Association, (202) 887-1100.
Dangerous Properties of Industrial Materials Report, Van Nostrand Reinhold, (212) 254-3232.
Environmental Technology and Chemistry, Persimmon Press, Inc., (914) 524-9200.
Fundamental and Applied Toxicology, Society of Toxicology, Academic Press, Inc., (619) 230-1840.
Green Business Letter, Tilden Press Inc., (202) 332-1700.
Green Marketing Report, Business Publishers, Inc., (301) 587-6300.
Hazard Prevention, System Safety Society, Inc.
September 1995
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Hazardous Substances and Public Health, U.S. Department of Health and Human Services, Agency
for Toxic Substances and Disease Registry, (404) 639-6206.
Incorporate Environmental Reviews into Facility Design, Chemical Engineering Progress, pp. 46-52
(August 1992).
Industrial Health & Hazards Update, Merton Allen Associates, Info Team Inc., (305) 473-9560.
Journal of Environmental Pathology, Toxicology and Oncology, Blackwell Scientific Publications
Inc., (617), 225-0401.
Literature Abstracts: Health & Environment, American Petroleum Institute, (212), 366-4040.
Occupational Hazards, Penton Publishing Inc., (216) 696-7000.
Pollution Prevention Review, Executive Enterprises, (800) 332-8804.
Recycling-Reclamation Digest, ASM International, (216) 3 3 8-5151.
Responsible Care® Newsletter, Chemical Manufacturer's Association, (202) 887-1100.
Reuse-Recycle, Technomic Publishing Co., Inc., (717) 291-5609.
Toxic Substances Journal, Hemisphere Publishing Corporation.
Waste Minimization and Recycling Report, Government Institutes, Inc., (301) 921-2300.
Software/Databases
AQUIRE, Aquatic Toxicity Information Retrieval Database, NTIS, (703) 487-4650.
ATTIC, Alternative Treatment Technology Information Center Database, (301) 816-9153.
CESARS, Chemical Evaluation Search & Retrieval System, Chemical Information Systems Inc
(301)321-8440.
IRIS, Integrated Risk Information System Database (summary information related to human health
risk assessment), EPA, NTIS No. PB90-591330/CCE.
NIOSHTIC, database on bibliographic occupational safety and health, DIALOG Information
Services.
STARA, Studies on Toxicity Applicable to Risk Assessment, EPA (919) 541-3629.
SWAMI, Strategic Waste Minimization Initiative, Version 2.0, EPA, contact Doug Williams at (513)
569-7361.
September 1995
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TERRE-TOX, Terrestrial Toxicity Database (aid in evaluating pre-manufacturing notices and
research), NTIS.
TOXNET, Toxicology Data Network, National Library of Medicine.
WHWTD, Waste & Hazardous Waste Treatability Database, EPA.
September 1995
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ENDNOTES
1. Amoco - U.S. EPA Pollution Prevention Project, Yorktown, Virginia, Project Summary, January
1992.
2. Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources,
Chapter 9, Petroleum Industry. U.S. EPA, Office of Air and Radiation, Office of Air Quality
Planning and Standards, Research Triangle Park, North Carolina, U.S. Government Printing Office,
Washington, D.C., September 1985.
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$E WORLD WIDE WEB
To access this Notebook through the Enviro$en$e World Wide Web, set your World Wide
Web Browser to the following address:
http ://CS.inel.gOV/OeCa - then select "EPA Sector Notebooks"
Of after 1997, (when EPA plans to have completed a restructuring of its web site) set
your web browser to the following address:
WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
Sectors and select the appropriate sector from the menu.
The Notebook will be listed.
HOTLINE NUMBER FOR E$WWW: 208-526-6956
EPA E$WWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June 1997)
Appendix A
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United States Government
INFORMATION
PUBLICATIONS * PERIODICALS * ELECTRONIC PRODUCTS
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