United States :
Environmental Protection
Agency
Profile Of The%
Rubber And Plastics
NOTEBOOKS
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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 hi 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 hi 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 hi ensuring that ~ hi 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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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
EPA/310-R-95-016
EPA Office of Compliance Sector
Notebook Project
Profile of the Rubber and
Plastics 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 0-16-048283-6
SIC Code 30
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
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.
All telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202) 512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., EST, 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$ense
Bulletin Board and via Internet on the Enviro$ense World Wide Web.
Downloading procedures are described in Appendix A of this document.
Cover photograph courtesy of The Gates Rubber Company, Denver, Colorado.
September 1995
SIC Code 30
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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:
Sethi 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-
-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.
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310-
EPA/310-
EPA/310-
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 Contact
Dry Cleaning Industry
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry
Pulp and Paper Industry
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
*Air Transportation Industry
Ground Transportation Industry
*Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
*Shipbuilding and Repair Industry
Textile Industry
*Sector Notebook Data Refresh, 1997
Federal Facilities Jim Edwards
Phone (202)
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
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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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
TABLE OF CONTENTS
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project 1
LB. Additional Information 2
n. INTRODUCTION To THE RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
INDUSTRY 4
H.A. Introduction, Background, and Scope of the Notebook 4
ILB. Characterization of the Rubber and Miscellaneous Plastics
Products Industry • 5
n.B.l. Industry Size and Geographic Distribution 5
E.B.2. Product Characterization 11
H.B.3. Economic Trends 13
Ht. INDUSTRIAL PROCESS DESCRIPTION 16
m.A. Industrial Processes in the Rubber and Miscellaneous Plastics
Products Industry 16
IE.B. Raw Material Inputs and Pollution Outputs in the Production
Line 34
ULC Management of Chemicals in Wastestream 45
CHEMICAL RELEASE AND TRANSFER PROFILE 47
IV.A. EPA Toxic Release Inventory for the Rubber and Miscellaneous
Plastics Products Industry • 50
IV.
V.
VI.
IV.B.
rv.c.
Summary of Selected Chemicals Released -59
Other Data Sources 65
IV.D. Comparison of Toxic Release Inventory Between Selected
Industries 67
POLLUTION PREVENTION OPPORTUNITIES 70
V.A. Identification of Pollution Prevention Activities in Use 70
SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 80
SIC Code 30
IV
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
VI.A. General Description of Major Statutes 80
VLB. Industry Specific Regulations 92
VII. COMPLIANCE AND ENFORCEMENT PROFILE 97
VILA. The Rubber and Miscellaneous Plastics Products Industry
Compliance History 101
VII.B. Comparison of Enforcement Activity Between Selected
Industries 103
VII.C. Review of Major Legal Actions 108
VII.C.l. Review of Major Cases. 108
VII.C.2. Supplemental Environmental Projects (SEPs) 108
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES , 112
VIII.A. Sector-Related Environmental Programs and Activities 112
VIII.B. EPA Voluntary Programs 113
VIII.C. Trade Association/Industry Sponsored Activity 120
Vin.C.l. Environmental Programs 121
VIII.C.2. Summary of Trade Associations 123
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/
BIBLIOGRAPHY 128
September 1995
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
EXHIBITS INDEX
Page
Exhibit 1 Facility Size Distribution of the Plastics Products Industry 6
Exhibit 2 Geographic Distribution of the Plastics Products Industry 6
Exhibit 3 Facility Size Distribution of the Rubber Products Industry 7.
Exhibit 4 Geographic Distribution of the Rubber Products Industry 8
Exhibit 5 Facility Size Distribution of the Tire Industry 9
Exhibit 6 Geographic Distribution of the Tire Industry 10
Exhibit 7 North American Tire Sales 11
Exhibit 8 Diversity of the Plastics Products Industry 12
Exhibit 9 Diversity of the Rubber Products Industry 13
Exhibit 10 Plastics Products Manufacturing Process : 18
Exhibit 11 Injection Molding 20
Exhibit 12 Extrusion 21
Exhibit 13 Thermoforming 22
Exhibit 14 Transfer Molding 23
Exhibit 15 Encapsulation 24
Exhibit 16 Rubber Product Manufacturing Process 27
Exhibit 17 Processes Used to Manufacture Various Rubber Products 30
Exhibit 18 Tire Manufacturing Process 32
Exhibit 19 Tire Formation 33
Exhibit 20 Plastics Products Manufacturing Process Pollution Outputs 35
Exhibit 21 Rubber Products Manufacturing Process Pollution Outputs 39
Exhibit 22 Tire Manufacturing Process Pollution Outputs 44
Exhibit 23 Rubber & Misc. Plastics Source Reduction and Recycling
Activity for SIC 30 46
Exhibit 24 Top 10 TRI Releasing Rubber and Plastics Products
Manufacturing Facilities (SIC 30) 51
Exhibit 25 Top 10 TRI Releasing Rubber and Misc. Plastics Products Facilities....52
Exhibit 26 TRI Reporting Rubber and Plastics Products Manufacturing
Facilities (SIC 30) by State 52
SIC Code 30
VI
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
EXHIBITS INDEX (Cont'd)
Page
Exhibit 27 Releases for Rubber and Plastics Products Manufacturing
(SIC 30) in TRI by Number of Facilities 54,55,56
Exhibit 28 Transfers for Rubber and Plastics Products
Manufacturing (SIC 30) in TRI by Number of Facilities 56,57,58
Exhibit 29 Pollutant Releases (Short Tons/Year) 66
Exhibit 30 Summary of 1993 TRI Data: Releases and Transfers by Industry 68
Exhibit 31 Toxic Release Inventory Data for Selected Industries 69
Exhibit 32 Scrap Tire Usage 78
Exhibit 33 Five Year Enforcement and Compliance Summary for the
Rubber and Plastics Industries 102
Exhibit 34 Five Year Enforcement and Compliance Summary for Selected
Industries 104
Exhibit 35 One Year Enforcement and Compliance Summary for Selected
Industries 105
Exhibit 36 Five Year Inspection and Enforcement Summary by Statute
for Selected Industries 106
Exhibit 37 One Year Inspection and Enforcement Summary by Statute
for Selected Industries 107
Exhibit 38 Supplemental Environmental Projects ,.110
Exhibit 39 Rubber and Misc. Plastic Producers Participating in the 33/50
Program 113-117
September 1995
VI1
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
LIST OF ACRONYMS
AFS - AffiS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
CAA- Clean Air Act
CAAA - Clean Air Act Amendments of 1990
CERCLA- Comprehensive Environmental Response, Compensation and
Liability Act
CERCLIS - CERCLA Information System
CFCs - Chlorofluorocarbons
CO- Carbon Monoxide
COD Chemical Oxygen Demand
CSI- Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
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
SIC Code 30
Vlll
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
LIST OF ACRONYMS (CONT'D)
NOX - Nitrogen Oxide
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
OPA - Oil Pollution Act
OPPTS - Office of Prevention, Pesticides, and Toxic Substances
OSHA - Occupational Safety and Health Administration
OSW - Office of Solid Waste
OSWER - Office of Solid Waste and Emergency Response
OW - Office of Water
P2- Pollution Prevention
PCS - Permit Compliance System (CWA Database)
POTW - Publicly Owned Treatments Works .
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs- Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SOi- Sulfur Dioxide
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
IX
SIC Code 30
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
(SIC 30)
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air,
water, and land pollution are an inevitable and logical supplement
to traditional single-media approaches to environmental
protection. Environmental regulatory agencies are beginning to
embrace comprehensive, multi-statute solutions to facility
permitting, enforcement and compliance assurance,
education/outreach, research, and regulatory development issues.
The central concepts driving the new policy direction are that
pollutant releases to each environmental medium (air, water, and
land) affect each other, and that environmental strategies must
actively identify and address these inter-relationships by designing
policies for the "whole" facility. One way to achieve a whole facility
focus is to design environmental policies for similar industrial
facilities. By doing so, environmental concerns that are common to
the manufacturing of similar products can be addressed in a
comprehensive manner. Recognition of the need to develop the
industrial "sector-based" approach within the EPA Office of
Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of
Compliance within the Office of Enforcement and Compliance
Assurance (OECA) to provide its staff and managers with summary
information for eighteen specific industrial sectors. As other EPA
offices, States, the regulated community, environmental groups,
and the public became interested in this project, the scope of the
original project was expanded. The ability to design
comprehensive, common sense environmental protection
measures for specific industries is dependent on knowledge of
several inter-related topics. For the purposes of this project, the key
elements chosen for inclusion are: general industry information
(economic and geographic); a description of industrial processes;
pollution outputs; pollution prevention opportunities; Federal
statutory and regulatory framework; compliance history; and a
description of partnerships that have been formed between
regulatory agencies, the regulated community, and the public.
September 1995
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
I.B.
For any given industry, each topic listed above could alone be the
subject of a lengthy volume. However, in order to produce a
manageable document, this project focuses on providing summary
information for each topic. This format provides the reader with a
synopsis of each issue, and references where more in-depth
information is available. Text within each profile was researched
from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows
for a wide coverage of activities that can be further explored based
upon the citations and references listed at the end of this profile. As
a check on the information included, each notebook went through
an external review process. The Office of Compliance appreciates
the efforts of all those that participated in this process and enabled
us to develop more complete, accurate, and up-to-date summaries.
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.
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$ense Bulletin Board or the Enviro$ense 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$ense Help System.
SIC Code 30
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the
relative national occurrence of facility types that occur within each
sector. In many instances, industries within specific geographic
regions or States may have unique characteristics that are not fully
captured in these profiles. For this reason, the Office of Compliance
encourages State and local environmental agencies and other
groups to supplement or re-package the information included in
this notebook to include more specific industrial and regulatory
information that may be available. Additionally, interested States
may want to supplement the "Summary of Applicable Federal
Statutes and Regulations" section with State and local
requirements. Compliance or technical assistance providers may
also want to develop the "Pollution Prevention" section in more
detail. Please contact the appropriate specialist listed on the opening
page of this notebook if your office is interested in assisting us in the
further development of the information or policies addressed
within this volume.
If you are interested in assisting in the development of new
notebooks for sectors not covered in the original eighteen, please
contact the Office of Compliance at 202-564-2395.
September 1995
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
H. INTRODUCTION To THE RUBBER AND MISCELLANEOUS PLASTICS PRODUCTS
INDUSTRY
This section provides background information on the size,
geographic distribution, employment, production, sales, and
economic condition of the Rubber and Plastics Products industry.
The type of facilities described within the document are also
described in terms of their Standard Industrial Classification (SIC)
codes. Additionally, this section contains a list of the largest
companies in terms of sales.
II.A. Introduction, Background, and Scope of the Notebook
The rubber and miscellaneous plastics products industry, as defined
by the Standard Industrial Classification (SIC) code 30, includes
establishments that manufacture products from plastic resins,
natural and synthetic rubber, reclaimed rubber, gutta percha, balata,
and gutta siak. The production of the rubber mixture is commonly
performed in facilities manufacturing rubber products and is
covered under SIC 30; however, the production of plastic resins is
not covered under SIC 30 because the majority of plastics product
facilities manufacture products from pre-made resins purchased
from plastic resin (polymer and resin) manufacturing facilities (SIC
28).
Although this SIC code covers most rubber and plastics products,
some important rubber and plastics products are classified
elsewhere. These products include boats, which are classified under
SIC 37 (Transportation Equipment), and buttons, toys, and buckles,
which are classified under SIC 39 (Miscellaneous Manufacturing
Industries). Buttons, toys, and buckles are grouped according to the
final product rather than by process because not all of these products
are made out of rubber or plastic. The rubber and miscellaneous
plastics products industry does include tire manufacture; however,
because of the somewhat different processes involved, the
recapping and retreading of automobile tires are classified under SIC
7534 and are not discussed in this profile.
Although SIC 30 groups rubber and plastics products together under
some of the three-digit industry codes (e.g., rubber and plastic
footwear under SIC 302), the majority of economic and process
information separates plastic and rubber products. In addition,
because tire manufacture accounts for such a large portion (almost
50 percent) of all rubber product manufacture, tire process and
economic information is often discussed separately from that of
SIC Code 30
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
other rubber products. Therefore, for the purposes of this industry
profile, plastics products, rubber products, and rubber tires are often
discussed separately.
II.B. Characterization of the Rubber and Miscellaneous Plastics Products
Industry
The following sections contain information about the size and
distribution of rubber and miscellaneous plastics products facilities
as well as information about the types of products produced by these
facilities. Also included is a discussion of the current and projected
economic trends for the rubber and miscellaneous plastics products
industry.
II.B.l. Industry Size and Geographic Distribution
Variation in facility counts occur across data sources due to many
factors, including reporting and definitional differences. This
document does not attempt to reconcile these differences, but rather
reports the data as they are maintained by each source.
The Bureau of the Census estimates that in 1987, 597,900 people
were employed by the plastics products industry and 231,700 were
employed by the rubber products industry of which the tire industry
employed 65,400. The value of shipments (revenue associated with
product sales) totaled $61.6 billion in 1987 for the plastics products
industry and $24.8 billion for the rubber products industry of which
the tire industry contributed $10.5 billion. 1992 Census Data for SIC
30 was not available at the time of this printing.
Plastic
Because of the wide range of products produced, plastics products
are manufactured in all parts of the country. According to the 1987
Census of Manufacturers, the total number of plastics products
establishments (with 20 or more employees) was 5,999. Of these
facilities, approximately 72 percent have fewer than 50 employees
and only one percent have more than 500 employees (see Exhibit 1).
Although these facilities are not concentrated in any particular
region, a few States account for a large percentage of the facilities.
These States include California, Ohio, Texas, Illinois, New York,
Pennsylvania, New Jersey, and Michigan (see Exhibit 2).
September 1995
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 1
Facility Size Distribution of Plastics Products Industry
Employees per
Facility
Ito4
5 to 9
10 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
1,000 to 2,499
2,500 or more
Total
Number of Facilities
2473
1581
1991
2729
1688
1190
301
80
10
1
12,044
Percentage of
Facilities
20
13
16
23
14
10
3
1
0 (0.08)
0 (0.008)
100
Source: 1987 Bureau of me Census data.
Exhibit 2
Geographic Distribution of Plastics Products Industry
51
source: lyts/ Bureau of me census aata.
SIC Code 30
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Rubber
Like the plastic industry, the rubber industry produces a wide range
of products. Rubber product manufacturing establishments are
located all across the country. According to the 1987 Census of
Manufacturers, the total number of establishments (with 20 or more
employees) was 1,204. Of these facilities, approximately 70 percent
have fewer than 50 employees, and only three percent have more
than 500 employees (see Exhibit 3). Although these facilities are not
concentrated in any particular region, a few States account for a
large percentage of the facilities. These States include California,
Ohio, North Carolina, Indiana, Michigan, Illinois, Massachusetts,
and Texas (see Exhibit 4).
Exhibits
Facility Size Distribution of the Rubber Products Industry
Employees per
Facility
Ito4
5to9
10 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
1,000 to 2,499
Total
Number of Facilities
451 :
335
390
505 :
306
228
117
36
12
2,380
Percentage of
Facilities
19
14
16
21
13
9
5
2
1
100
Source: 1987 Bureau of the Census data.
September 1995
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 4
Geographic Distribution of the Rubber Products Industry
Tires
Source: lUa/ Bureau of me Census data.
Labor costs currently represent about 30 percent of the cost of tire
and tube production for U.S. manufacturers. To keep these labor
costs as low as possible, tire manufacturing plants are located
primarily in southern States where labor rates are lower than the
national average.
SIC Code 30
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Exhibit 5
Facility Size Distribution of the Tire Industry
Employees per
Facility
Ito4
5 to 9
10 to 19
20 to 49
50 to 99
100 to 249
250 to 499
500 to 999
1,000 to 2,499
2,500 or more
Total
Number of Facilities
31
17
18
19
8
20
13
9
23
5
163
Percentage of
Facilities
19
10
11
12
5
12
8
6
14
3
100
Source: 1987 Bureau of the Census data.
There are 47 tire manufacturing plants in the United States. These
plants are located in 20 states. States that account for a large
percentage of facilities include Alabama, Illinois and Tennessee.
September 1995
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Exhibits
Geographic Distribution of the Tire Industry
Source: 1987 Bureau of me Census data.
The two largest producers of tires, Goodyear and Michelin,
accounted for approximately 55 percent of tire production in 1992.
The five largest producers, Goodyear, Michelin,
Bridgestone/Firestone, Continental/General Tire, and Cooper,
accounted for 84 percent of production, while the eight largest
companies produced 97 percent of the domestic product (see Exhibit
7).
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Exhibit 7
North American Tire Sales
Other
16%
Goodyear
28%
Continental/
General Tire 8%
Brigestone /
Firestone 21%
Michelin/Uniroyal
Goodrich
22%
source: lire Business 1993 Annual Report
II.B.2. Product Characterization
The Bureau of the Census' SIC 30 divides the rubber and
miscellaneous plastics products into industry groups according to
the type of product manufactured. The following is a list of all the
three digit industry groups under SIC 30:
SIC 301 - Tires and Inner Tubes
SIC 302- Rubber and Plastic Footwear
SIC 305- Gaskets, Packing, and Sealing Devices and Rubber and
Plastic Hose and Belting
SIC 306 - Fabricated Rubber Products, Not Elsewhere Classified
SIC 308 - Miscellaneous Plastics products
Several of these three digit classifications group rubber and plastics
products. However, the four digit classifications clearly segregate the
two industries. The following are four digit SIC code breakdowns of
the plastic and rubber products industries. In the plastic industry,
Plastics products, Not Elsewhere Classified (NEC) (SIC 3089) account
for approximately 55 percent of all plastic product production.
Unsupported Plastic Film and Sheet (SIC 3081) account for
approximately 13 percent; Plastic Foam Products (SIC 3086) account
for approximately 11 percent; Plastic Bottles (SIC 3085) account for
approximately five percent; Plastic Pipe (SIC 3084), Unsupported
Plastic Profile Shapes (SIC 3082), and Custom Compounding of
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Purchased Plastic Resins (SIC 3087) account for approximately four
percent each; Laminated Plastic Plate, Sheet, and Profile Shapes (SIC
3083) account for approximately three percent; and Plastic Plumbing
Fixtures (SIC 3088) for approximately one percent (see Exhibit 8).
Exhibit 8
Diversity of Plastics Products Industry
Custom
Compounding Laminated
Profile Shapes
Pipe
Bottles 5%
Foam
Products
11%
Plumbing
Fixtures
13%
Film & Sheet
Source: 1987 Bureau of me Census data.
In the rubber industry, Tire and Inner Tube (SIC 3011) manufacture
accounts for approximately 42 percent of all rubber product
production. Fabricated Rubber Products Not Elsewhere Classified
(SIC 3069) account for approximately 21 percent; Molded, Extruded,
and Lathe-Cut Mechanical Rubber Goods (SIC 3061) account for
approximately 15 percent; Rubber and Plastic Hose and Belting (SIC
3052), and Gaskets, Packing, and Sealing Devices (SIC 3053) account
for approximately 10 percent; and Rubber and Plastic Footwear (SIC
3021) account for two percent (see Exhibit 9).
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Rubber and Miscellaneous Plastics Producfe
Exhibit 9
Diversity of the Rubber Products Industry
Gaskets, Packing and
Sealing Devices
Foojwear
Hoses and
Belting
10%
Mechanical
Goods
15%
Tires and
Inner Tubes
42%
21%
Fabricated Products N.E.C.
source: iy«7 Bureau of the Census data.
II.B.3. Economic Trends
Plastic
Consumption of plastics products is highest in the electronics,
health care, construction, transportation, automotive, and food
packaging industries. According to the 1994 U.S. Industrial Outlook,
shipments of miscellaneous plastics products are expected to grow
by five percent in 1994, largely as a result of stronger consumer
confidence and spending, and expected increases in demand from
the electronics and health care sectors. Highest growth is expected
to be for molded and extruded products.
In 1992, U.S. exports of plastics products (approximately $4.5 billion)
slightly exceeded imports (approximately $4.3 billion). The bulk of
U.S. imports in 1993 came from Canada, Taiwan, China, and Japan.
The value of the total trade turnover (sum of imports plus exports)
amounted to approximately 13.5 percent of total industry
shipments, domestic and foreign, in 1993. U.S. plastics products
exports compete favorably against lower cost producers in many
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Rubber
Tires
third-country markets. [Note: This data excludes the bottles and
plumbing equipment/parts sectors of the industry.]
The value of all products and services sold in the rubber products
industry is forecasted to grow three percent in 1994, largely reflecting
expected increases in the tire manufacturing sector's use of
fabricated rubber products, as well as higher consumer spending.
Higher than average growth is expected for automobiles (i.e., hoses,
belts, etc.).
Trading patterns reflect the U.S. rubber industry's position as a
moderately competitive producer; the U.S. is both a major exporter
to industrialized nations and an importer of lower-cost products
from industrializing countries. Imports continue to make inroads
in the domestic market and stand at a nearly 2:1 ratio to exports.
Two-way trade relative to total industry shipments remains stable,
at about one-fifth of total industry shipments.
The tire industry shows signs of stabilizing after undergoing a
period characterized by massive restructuring, the effects of
recession in the domestic market, and consistently high levels of
imports. With tire durability pushed to what many consider the
practical limit, industry strategy has shifted to servicing the fast-
growing emerging markets for high-performance, light truck, and
recreational vehicle (RV) tires.
The tire industry grew at an average rate of 2.5 percent until 1990, at
which point there was a slight decrease in growth. Industry
shipments reached record levels in 1994, with higher than average
growth expected for the high-performance, truck, and light truck
tires and little or no growth projected for passenger tires installed
on new cars.
Imports continued to outpace exports in the tire industry at a ratio
of nearly 2:1 in 1993. However, since 1989, a steady growth of
exports has slowly cut into this negative net trade position. The
foreign trade sector of the industry is stable, as evidenced by several
consecutive years when the ratio of combined exports and imports
to overall industry shipments remained relatively constant.
Canada is now the U.S.' largest trading partner, absorbing 40 percent
of total U.S. exports, while supplying approximately 30 percent of
imports in 1992. The two other top recipients of U.S. exports are
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Mexico and Japan, while Japan, South Korea, and Canada, produce
the majority of tires imported by the United States.
During the 1980's, corporate restructuring and mergers and
acquisitions resulted in the globalization of the tire industry.
Almost one-half of domestic production capacity is now owned by
foreign-based tire manufacturers, mainly European and Japanese.
Among the advantages realized by the surviving companies are
increased resources for research and development, and economies
of scale across procurement, manufacturing, distribution, and
service.
All four of the major tire producers in the U.S. are involved in the
production of the synthetic rubber used in tire production, and two
of these producers own and operate natural rubber plantations.
More than 80 percent of the sales revenue of the four major
producers (both foreign and domestic) is derived from tires and
related transportation products such as rubber belts and hoses.
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INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the
Rubber and Miscellaneous Plastics industry, including the materials
and equipment used, and the processes employed. The section is
designed for those interested in gaining a general understanding of
the industry, and for those interested in the inter-relationship
between the industrial process and the topics described in
subsequent sections of this profile — pollutant outputs, pollution
prevention opportunities, and Federal regulations. This section
does not attempt to replicate published engineering information
that is available for this industry. Refer to Section IX for a list of
reference documents that are available.
This section specifically contains a description of commonly used
production processes, associated raw materials, the byproducts
produced or released, and the materials either recycled or
transferred off-site. This discussion, coupled with schematic
drawings of the identified processes, provide a concise description of
where wastes may be produced in the process. This section also
describes the potential fate (air, water, land) of these waste products.
III.A. Industrial Processes in the Rubber and Miscellaneous Plastics Products
Industry
The production of plastics products, both solid and foam, is a
relatively diverse industry. Simpler processes consist of: (1)
imparting the appropriate characteristics to the plastic resin with
chemical additives; (2) converting plastic materials in the form of
pellets, granules, powders, sheets, fluids or preforms into either
intermediate or final formed plastic shapes or parts via molding
operations; and (3) finishing the product (see Exhibit 10).
There are also several methods of reacting plastic resin and catalyst
materials to form a thermoset plastic material into its final shape.
(see Exhibit 11).
Plastic
Additives are often mixed with the plastic materials to give the
final product certain characteristics (some of these additives can also
be applied to the shaped product during the finishing process).
These plastic additives and their functions, in terms of their effect
on the final product, are listed below.
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Additive Lubricants assist in easing the flow of the plastic in
the molding and extruding processes by lubricating the metal
surfaces that come into contact with the plastic.
Antioxidants inhibit the oxidation of plastic materials that
are exposed to oxygen or air at normal or high temperatures.
Antistats impart a minimal to moderate degree of electrical
conductivity to the plastic compound, preventing
electrostatic charge accumulation on the finished product.
Blowing Agents (foaming agents) produce a cellular structure
within the plastic mass and can include compressed gases
that expand upon pressure release, soluble solids that leach
out and leave pores, or liquids that change to gases and in the
process develop cells.
Colorants impart color to the plastic resin.
Flame Retardants reduce the tendency of the plastic product
to burn.
Heat Stabilizers assist in maintaining the chemical and
physical properties of the plastic by protecting it from the
effects of heat such as color changes, undesirable surface
changes, and decreases in electrical and mechanical
properties.
Impact Modifiers prevent brittleness and increase the
resistance of the plastic to cracking.
Organic Peroxides initiate or control the rate of
polymerization in thermosets and many thermoplastics.
Plasticizers increase the plastic product's flexibility and
workability.
Ultraviolet Stabilizers (UV light absorbers) absorb or screen
out ultra-violet radiation thereby preventing the premature
degradation of the plastic product.
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Exhibit 10
Plastics Products Manufacturing Process
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After adding the necessary additives to the plastic pellets, granules,
powders, etc., the plastic mixture is formed into intermediate or
final plastics products. A variety of molding processes are used to
form solid plastics products. These processes include injection
molding, reaction injection molding, extrusion, blow molding,
thermoforming, rotational molding, compression molding, transfer
molding, casting, encapsulation, and calendering. Foamed plastics
products are made using slightly different processes then those used
to make solid plastics products. The choice of which plastic forming
process to use is influenced by economic considerations, the
number and size of finished parts, the adaptability of particular
plastic to a process (various plastic will mold, process, etc.,
differently) and the complexity of the post-forming operations.
Below are brief descriptions of this most common molding and
forming processes for creating solid plastics products.
Injection Molding: In the injection molding process, plastic
granules or pellets are heated and homogenized in a cylinder until
they are fluid enough to be injected (by pressure) into a relatively
cold mold where the plastic takes the shape of the mold as it
solidifies. Advantages of this process include speed of production,
minimal post-molding requirements, and simultaneous multi-part
molding. The reciprocating screw injection machine is the
dominate technology used in injection molding. The screw acts as
both a material plasticizer and an injection ram. The buildup of
viscous plastic at the nozzle end of a cylinder forces the screw
backwards as it rotates. When an appropriate charge is
accumulated, rotation stops and the screw moves forward, thereby
becoming an injection ram, forcing the melt (liquefied plastic) into
the mold. The screw remains forward until the melt solidifies and
then returns to repeat the cycle (see Exhibit 11).
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Exhibit 11
Injection Molding
hopper slide
adapter
zone
front
zone
hopper housing
(wittf cooled)
noale
25%
25%
Source: McGraw-HillEncyclnpedia of Science and Technology.
Reaction Injection Molding: In the reaction injection molding
process, two liquid plastic components, polyols and isocyanates, are
mixed at relatively low temperatures (75 - 140 degrees F) in a
chamber and then injected into a closed mold. Reaction Injection
Molding requires far less energy than other injection molding
systems because an exothermic reaction occurs when the two liquids
are mixed. Reaction injection molding is a relatively new
processing method that is quickly becoming common in the
industry.
Extrusion: In the extrusion process, plastic pellets or granules are
fluidized, homogenized, and formed continuously as the extrusion
machine feeds them through a die (see Exhibit 12). The result is a
very long plastic shape such as a tube, pipe, sheet, or coated wire.
Extruding is often combined with post extruding processes such as
blowing, thermoforming, or punching. Extrusion molding has an
extremely high rate of output, for example, pipe can be formed at a
rate of 2000 Ib/hr (900 kg/hr).
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Exhibit 12
Extrusion
thermocouple
gear
reducer
hardened
liner
heater
bands
(barrel cooling
is often used)
screen
pack
\ breaker
plate
adapter
heater
melt
thermocouple
die
motor drive
Source: McGraw-Hill Encyclopedia of Science and Technology,
Blow Molding: Blow molding describes any forming process in
which air is used to stretch and form plastic materials. In one
method of blow molding, a tube is formed (usually by extrusion
molding) and then made into a free-blown hollow object by
injecting air or gas into the tube. Blow molding can also consist of
putting a thermoplastic material in the rough shape of the desired
finished product into a mold and then blowing air into the plastic
until it takes the shape of the mold, similar to blowing up a balloon.
Thermoforming: In the thermoforming process heat and pressure
are applied to plastic sheets which are then placed over molds and"
formed into various shapes. The pressure can be in the form of air,
compression, or a vacuum (see Exhibit 13). This process is popular
because compression is relatively inexpensive.
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Exhibit 13
Thermoforming
>
plastic sheet clamp
JH i
V
l£ 1
I mold |
formed part
seal
thin corners
and edges
Smirce: McGrmv-Hill Encyclopedia of Science and Technology.
Rotational Molding: In the rotational molding process, finely
ground plastic powders are heated in a rotating mold to the point of
either melting and/or fusion. The inner surface of the rotating
mold is then evenly coated by the melted resin. The final product is
hollow and produced scrap free.
Compression and Transfer Molding: In the compression molding
process, plastic powder or a preformed plastic part is plugged into a
mold cavity and compressed with pressure and heat until it takes
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the shape of the cavity. Transfer molding is similar, except that the
plastic is liquefied in one chamber and then injected into a closed
mold cavity by means of a hydraulically operated plunger (see
Exhibit 14). Transfer molding was developed to facilitate the
molding of intricate plastics products which contain small deep
holes or metal inserts because compression molding often ruins the
position of the pins which form the holes and the metal inserts.
Exhibit 14
Transfer Molding
Source: McGraw-Hill Encyclopedia of Science and Technology.
Casting and Encapsulation: In the casting process, liquid plastic is
poured into a mold until it hardens and takes the shape of the
mold. In the encapsulation or potting process, an object is encased
in plastic and then hardened by fusion or a chemical reaction (see
Exhibit 15).
Calendering: In the calendering process, plastic parts are squeezed
between two rolls to form a thin, continuous film.
The manufacture of foamed plastics products involves slightly
different forming processes than those described above. The three
types of foam plastic are blown, syntactic, and structural. Blown
foam is an expanded matrix, similar to a natural sponge; syntactic
foam is the encapsulation of hollow organic or inorganic micro
spheres in the plastic matrix; and structural foam is a foamed core
surrounded by a solid outer skin. All three types of foam plastic can
be produced using processes such as injection, extrusion, and
compression molding to create foam products in many of the same
shapes as solid plastics products. The difference is that creating
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foam products requires processes such as the addition of chemical
blowing agents, different mixing processes which add air to the
plastic matrix, or a unique injection molding process used to make
structural plastic.
Exhibit 15
Encapsulation
casting material
casting material
encapsulation
mold
T Jj
niii
case
Source: McGraw-Hill Encyclopedia of Science and Technology.
The following are some basic processes which occur in conjunction
with the standard molding and forming operations to produce
blown foam plastic and syntactic foam plastic:
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Gas which is under pressure is injected into the melt and
then expands during pressure relief;
A low-boiling liquid (e.g., HCFC's or hydrocarbons) is
incorporated into the plastic compound and volatilized
through the exothermic heat of reaction;
Non-chemical gas-liberating agents (adsorbed gas on finely
divided carbon) are added to the resin mix and released
during heating;
Air is dispersed by mechanical means within the polymer
(similar to whipping cream); or
The external application of heat causes the expansion of
small beads of thermoplastic resin containing a blowing
agent.
Structural foam plastic is made by injection molding liquid resins
that contain chemical blowing agents. Less mixture is injected into
the mold than is needed to mold a solid plastic part. At first the
injection pressure is very high, causing the blowing agent mixture
to solidify against the mold without undergoing expansion. As the
outer skin is formed, the pressure is reduced and the remaining
resin expands to fill the remainder of the mold. Structural foam
plastic parts have a high strength-to-weight ratio and often have
three to four times greater rigidity than solid plastic molded parts of
equal weight that are made of the same material.
After the solid or foam plastic shape is created, post forming
operations such as welding, adhesive bonding, machining, applying
of additives, and surface decorating (painting and metalizing) are
employed to finish the product.
To produce a thermoset plastic material, liquid resins are combined
with a catalyst. Resins used for thermoset plastic products include
urethane resins, epoxy resins, polyester resins, and acrylic resins.
Fillers are often added to the resin-catalyst mixture prior to molding
to increase product strength and performance and to reduce cost.
Most thermoset plastic products contain large amounts of fillers (up
to 70% by weight). Commonly used fillers include mineral fibers,
clay, glass fibers, wood fibers, and carbon black. After the thermoset
material is created, a final or intermediate product can be molded.
Various molding options may be employed to create the
intermediate or final thermoset product. These processes include
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Rubber
vacuum molding, press molding, rotational molding, hand
lamination, casting and encapsulation, spray-up lamination, resin
transfer molding, filament winding, injection molding; reaction
injection molding, and pultrusion.
Rubber product manufacture is as diverse as the number of rubber
products produced. Even with this diversity, several basic, common
processes are identifiable. This profile will focus on these basic
processes: (1) mixing; (2) milling; (3) extruding; (4) calendering;
(5) building; (6) vulcanizing; and (7) finishing (see Exhibit 16).
The rubber product manufacturing process begins with the
production of a rubber mix from polymers (i.e., raw and/or
synthetic rubber), carbon black (the primary filler used in making a
rubber mixture), oils, and miscellaneous chemicals. The
miscellaneous chemicals include processing aids, vulcanizing
agents, activators, accelerators, age resistors, fillers, softeners, and
specialty materials. The following is a list of these miscellaneous
chemicals and the functions they perform:
• Processing Aids modify the rubber during the mixing or
processing steps, or aid in a specific manner during the
extrusion, calendering, or molding operations.
• Vulcanizing Agents create cross links between polymer
chains.
• Activators, in combination with vulcanizing agents, reduce
the curing time by increasing the rate of vulcanization.
• Accelerators form chemical complexes with activators and
thus aid in obtaining the maximum benefits from the
acceleration system by increasing vulcanization rates and
improving the final product's properties.
• Age Resistors slow down the deterioration of the rubber
products that occurs through reactions with materials that
may cause rubber failure (i.e., oxygen, ozone, light, heat,
radiation, etc.).
• Fillers reinforce or modify the physical properties of the
rubber, impart certain processing properties, and reduce costs
by decreasing the quantity of more expensive materials
needed for the rubber matrix.
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Exhibit 16
Rubber Manufacturing Process
Reinforcing
Materials
Profile^
Shapes
Curing/
Vulcanizing
Cured Rubber
Product
Finishing
Final Rubber Product
Softeners either aid in mixing, promote greater elasticity,
produce tack, or extend (replace) a portion of the rubber
hydrocarbon (without a loss in physical properties).
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• Specialty Materials include retarders, colorants, blowing
agents, dusting agents, odorants, etc. Specialty materials are
used for specific purposes, and are not required in the
majority of rubber compounds.
Rubber mixes differ depending upon the desired characteristics of
the product being manufactured. Production of the rubber mixture
involves weighing and loading the appropriate ingredients into an
internal mixer known as a "Banbury" mixer which is used to
combine these ingredients. The area where the chemicals are
weighed and added to the banbury is called the compounding area.
The polymers and miscellaneous chemicals are manually
introduced into the mixer hopper, while carbon black and oils are
often injected directly into the mixing chamber from bulk storage
systems. The mixer creates a homogeneous mass of rubber using
two rotors which shear materials against the walls of the machine's
body. This mechanical action also adds considerable heat to the
rubber.
The mixed rubber mass is discharged to a mill or other piece of
equipment which forms it into a long strip or sheet. The hot, tacky
rubber then passes through a water-based "anti-tack" solution
which prevents the rubber sheets from sticking together as they cool
to ambient temperature. The rubber sheets are placed directly onto
a long conveyor belt which, through the application of cool air or
cool water, lowers the temperature of the rubber sheets. The process
of rubber mixing includes all of these steps - Banbury mixing,
milling (or other means of sheeting), anti-tack coating, and cooling.
After cooling, the sheets of rubber are sent through another mill.
These mills are used to "warm up" the rubber for further processing
on extruders and calenders. Some extruders can be "cold fed" rubber
sheets, making this milling step unnecessary.
Extruders transform the rubber into various shapes or profiles by
forcing it through dies via a rotating screw. Extruding heats the
rubber and the rubber remains hot until it enters a water bath or
spray conveyor where cooling takes place. Calenders receive hot
strips of rubber from mills and squeeze them into reinforcing fibers
or cloth-like fiber matrices, thus forming thin sheets of rubber
coated materials. Calenders are also used to produce non-
reinforced, thickness controlled sheets of rubber.
Extruded and calendered rubber components are combined (layered,
built-up) with wire, polyester, aramid, and other reinforcing
materials to produce various rubber products. Adhesives, called
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cements, are sometimes used to enhance the bonding of the various
product layers. This assembling, reinforcing, pre-curing, and
bonding process is referred to as building.
All rubber products undergo vulcanization (curing). Vulcanization
is accomplished in heated compression molds, steam heated
pressure vessels (autoclaves), hot air and microwave ovens, or
various molten and fluidized bed units. During the curing process,
the polymer chains in the rubber matrix cross-link to form a final
product of durable, elastic, thermoset rubber. Increasing the
number of cross-links in the rubber matrix gives rubber its elastic
quality. One way to visualize this is to think of a bundle of wiggling
snakes in constant motion. If the bundle is pulled at both ends and
the snakes are not entangled, then the bundle comes apart. The
more entangled the snakes are (like the rubber matrix after
vulcanization), the greater the tendency for them to bounce back to
their original shape.
Finishing operations may include grinding, printing, washing,
wiping, and buffing.
As initially indicated, due to the diversity of products and facilities,
not all of the processes shown in Exhibit 16 are necessary for every
product. For example, many plants do not mix rubber but purchase
uncured rubber from other facilities.
Exhibit 17 illustrates the processes used to manufacture the
following rubber products:
Belts - A typical belt plant will not have an extruder but will use
many layers of calendered material assembled on a lathe type
builder to produce a rubber cylinder from which individual belts
can be cut.
Hoses - A hose plant will use an extruder to produce a tube which is
reinforced with cord or wire and covered with a layer of rubber
applied by an extruder. The same extruder may be used to produce
the initial tube and then to extrude the final "cover" layer onto the
reinforced tube.
Molded Products - A molded products plant will use extruded
material to feed compression molds, or may cut strips directly from
the mixing process to feed the molds.
Roofing - Roofing manufacturers will process rubber through mills
and calenders to produce the necessary sheeting.
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Exhibit 17
Processes Used to Manufacture Various Rubber Products
I
e
Vulc
I
1
pa
Calender
I
I
I
^VNW-SS.
Vulcanize
i
I
Reinforce
T
de
Ext
(A
0)
cn
O
ffi
05
I
e
Vulca
rt
o
• i»4
•4^
u
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Tires
Sealing - Sealing, gasket like materials, will use extrusion and
continuous vulcanization in hot air ovens. -
The tire manufacturing process is similar to that of other rubber
products. The main difference between the rubber product
manufacturing process and the tire manufacturing process is that
the building process is generally more complex because there are
many rubber components.
The tire production process in its most basic form consists of: (1)
compounding and mixing elastomers, carbon blacks, pigments, and
other chemicals such as vulcanizing agents, accelerators,
plasticizers, and initiators; (2) extruding the rubber mixture between
pairs of large rollers to prepare it for the feed mill, where it is slit
into strips to take the shape of the tread and sidewall materials; (3)
processing fabrics and coating them with rubber in a calendering
operation; (4) processing bead wires and coating them with rubber
in an extruding process; (5) cutting and cooling the various extruded
and calendered outputs; (6) assembling all of the components (bead
wires, coated fabrics, treads, etc.) on a tire-building machine; (7)
lubricating the green tire (green tire spraying) (8) vulcanizing and
molding the tire with heat and pressure; and (9) finishing the
product (see Exhibit 18).
The main component of tire-building is the drum which is a
collapsible cylinder shaped like a wide drum that can be turned and
controlled by the tire builder. The building process begins when
carcass plies, also known as rubberized fabric, are placed on a drum
one at a time, after which the cemented beads (rubber coated wires)
are added and the plies are turned up around them. Narrow strips
of fabric are then cemented on for additional strength. At this stage
the belts, tread, and sidewall rubber are wrapped around the drum
over the fabric. The drum is then collapsed and the uncured (green)
tire is coated with a lubricant (green tire spray) and loaded into an
automatic tire press to be molded and cured. Prior to curing, the tire
looks like a barrel that is open at both ends. The curing process
converts the rubber, fabric, and wires into a tough, highly elastic
product while also bonding the various parts of the tire into one
single unit (see Exhibit 19). After curing, the tire is cooled by
mounting it on a rim and deflating it to reduce internal stress.
Finishing the tire involves trimming, buffing, balancing, and
quality control inspection.
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Exhibit 18
Tire Manufacturing Process
Extruding - Tread
and Sidewalls
Extruding - Bead
Wires
Cooling
Cutting
Building
i
Green Tire
Spraying
i
Vulcanizing
Finishing
Calendering -
Rubber/Fabrics
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Exhibit 19
Tire Formation
1—Bead 5—Shoulder pad
2—Bead met 6—-Bsft edge insulation
3—Cord plies 7—Nyton cap plies
4—Beits 8-—Tread elements
Source: "Tire Materials and Construction" in Automotive Envincerinv. October, 1992.
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III.B. Raw Material Inputs and Pollution Outputs in the Production Line
Plastic
There are four general types of pollution and resource material
outputs that can occur at one or more stages of the plastics product
manufacturing process. In addition, there are some plastics
products disposal concerns. Manufacturing outputs include spills,
leaks, and fugitive emissions of chemicals during the application of
additives prior to molding or during finishing; waste water
discharges during cooling and heating, cleaning, and finishing
operations; plastic pellet releases to the environment prior to
molding; and fugitive emissions from molding and extruding
machines (see Exhibit 20). Each of these is discussed below.
Chemicals
One concern during the plastic product manufacturing process is
the potential release of the additive chemicals prior to molding and
during the finishing process. Releases could be in the form of spills
during weighing, mixing, and general handling of the chemicals, in
the form of leaks from chemical containers and molding machines,
or in the form of fugitive dust emissions from open chemical
containers. It should be noted that not all plastic product
manufacturers use additives because many purchased pellets
already contain the necessary additives, making this pollution
output irrelevant for many facilities. The chemicals used in the
plastic product manufacturing process are usually added in such
small amounts that most manufacturers do not consider them to be
a problem; however, some of the additives could be toxic and
therefore even small amounts could present significant problems.
According to a National Enforcement Investigations Center (NEIC)
inspector, the plastic industry is currently looking into the
characteristics of the additives and their releases for possible
environmental or worker safety issues. The following is a list of
some of the typical chemicals used as additives in the plastics
products manufacturing process:
• Lubricants - stearic acid, waxes, fatty acid esters, and fatty acid
amines
• Antioxidants - alkylated phenols, amines, organic phosphites
and phosphates, and esters
• Antistats - quaternary ammonium compounds, anionics, and
amines
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Exhibits 20
Plastics Products Manufacturing Process Pollution Outputs
I
5!
2-S.b
« S3
•a <£ a
•s § ig
«< a
El
1
f Chemica
itives
° *g i
1?
•i-l
T3
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Blowing/foaming agents - azodicarbonamide, modified azos,
OBSH, and HTBA
Colorants - titanium dioxide, iron oxides, anthraquinones,
and carbon black
Flame Retardants - antimony trioxide, chlorinated paraffins,
and bromophenols
Heat Stabilizers - lead, barium-cadmium, tin, and calcium-
zinc
Organic Peroxides - MEK peroxide, benzoyl peroxide, alkyl
peroxide, and peresters
Plasticizers - adipates, azelates, trimellitates, and DOP/DIOP/
DIDP
Ultraviolet Stabilizers (UV light absorbers) - benzophenones,
benzotriazole, and salicylates.
Waste Water
Contaminated waste water is another concern in the plastic product
industry. EPA estimates that of the 10,260 plastic molding and
forming plants in the U.S. (this figure includes establishments with
less than 20 employees), 1,898 plants have 2,587 processes that use
water (i.e., they are wet). The 1,898 wet plants have an estimated 810
wet processes with direct discharge, 1,145 processes with indirect
discharge, and 632 wet processes with no discharge.
Water used in the plastic molding and forming processes falls into
three main categories: (1) water to cool or heat the plastics products;
(2) water to clean the surface of both the plastics products and the
equipment used in production; (3) and water to finish the plastics
products.
Cooling and heating water usually comes into contact with raw
materials or plastics products during molding and forming
operations for the purpose of heat transfer. The only pollutant
found in some waste water discharged by contact cooling and
heating in a treatable concentration is bis(2-ethylhexyl) phthalate
(BEHP) and it is toxic. Many facilities do not process materials
containing BEHP making this pollutant output irrelevant for many
manufactures.
Cleaning water includes water that is used to clean the surface of the
plastic product or the molding equipment that is or has been in
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contact with the formed plastic product. The types of pollutants
found in cleaning water in treatable concentrations are biochemical
oxygen demand (BOD5), oil and grease, total suspended solids (TSS),
chemical oxygen demand (COD), total organic carbon (TOC), total
phenols, phenol, and zinc.
Finishing water consists of water used to carry away waste plastic
material or to lubricate the product during the finishing operation.
TSS, bis(2-ethylhexyl) phthalate, di-n-butyl phthalate, and dimethyl
phthalate are the pollutants identified in finishing water in
treatable concentrations.
Of the pollutants found in all three types of process water, BODS, oil
and grease, TSS, and pH are considered conventional pollutants,
TOC and COD are considered non-conventional pollutants, and bis
(2-ethylhexyl) phthalate, di-n-butyl phthalate, dimethyl phthalate,
phenol, and zinc are considered priority toxic pollutants.
Pellet Release
The third concern in the plastic product manufacturing industry is
the release of plastic pellets into the environment. Plastic pellets
and granules used to mold intermediate and final plastics products
are often lost to floor sweepings during transport or while being
loaded into molding machines, and may end up in waste water.
Although they are inert, plastic pellets are an environmental
concern because of the harm they can cause if runoff carries them to
wetlands, estuaries, or oceans where they may be ingested by
seabirds and other marine species. EPA storm water regulations
classify plastic pellets as "significant materials," and therefore the
discovery of a single pellet in storm water runoff is subject to
Federal regulatory action.
Fugitive Emissions
Fugitive emissions from the molding processes may be an
environmental concern because of the many additives, including
cadmium and lead, which can be released during the application of
high heat and pressure. Trade association officials (i.e., American
Plastic Council and the Society of the Plastic Industry), are currently
researching the composition of these emissions and their possible
effects on worker safety and air quality.
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Disposal
Rubber
Plastics products also pose disposal concerns. Discarded plastics
products and packaging make up a growing portion of municipal
and solid waste. Because only a small percentage of plastic is
recycled (less than one percent), virtually all disposed plastics
products are put into landfills or incinerated. By the year 2000, the
amount of disposed plastic will increase by 50 percent from present
levels. Current estimates show that plastic constitutes 14 to 21
percent of the waste stream by volume and seven percent of the
waste stream by weight. Because of its resistance to degradation,
improper plastic disposal can have a particularly serious effect in
the marine environment in terms of ecological risks and aesthetics.
In terms of landfill disposal, the slow degradation of plastic is not a
significant factor in landfill capacity; research has shown that other
constituents (e.g., paper, wood, food wastes) also degrade very
slowly. However, the additives contained in plastic, such as
colorants, stabilizers, and plasticizers, may include toxic constituents
such as lead and cadmium which can leach out into the
environment as the plastic degrades. Plastic contribute 28 percent of
all cadmium found in municipal solid waste and approximately
two percent of all lead. Data are too limited to determine whether
these and other plastic additives contribute significantly to the
leachate produced in municipal solid waste landfills. Plastic that
contains heavy metal-based additives may also contribute to the
metal content of incinerator ash.
In the rubber product manufacturing industry, the primary
environmental concerns are fugitive emissions, solid wastes, waste
water, and hazardous wastes. Each of these is discussed below.
Fugitive and VOC Emissions
The compounding area, where dry chemicals are weighed and put
into containers prior to mixing, can be a source of. fugitive
emissions, and possibly spills and leaks. Because additives must be
pre-weighed, in some facilities the chemicals sit in big open bins on
the scales or waiting to get on the scales, thus increasing the
potential for significant fugitive dust emissions. Most mixing
facilities have eliminated this problem by purchasing their
chemicals in small, pre-weighed, sealed polyethylene bags. The
sealed bag is put directly into the banbury mixer thus eliminating a
formerly dusty operation. If chemicals are not in pre-weighed bags,
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Exhibit 21
Rubber Products Manufacturing Process Pollution Outputs
VQClmissionsO
x-jfeacalafee^N
V^lEntissiojttsjx
^P|«|f%
<^o.«-. t>v£2**
Raw
Materials
x^Keinforctng^N
V^Nfoterials'^X
Adhesive
Building
^^.^ »•
X!?^- ^''-Ws.'."^??^
€-^OC Btoisslaiiwy
x»;^3? V ^^.'^ i^sx ;'l2i*^^
^Reinforcing
"* Materi "
laterials
Curing/
Vulcanizing
Finishing
T
fugitive emissions are also produced as the chemicals are loaded
into the mixer. Emissions from the internal mixers are typically
controlled by baghouses. Exhausts from the collection hoods are
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ducted to the baghouses for control of particulate and possibly
particle-bound semi-volatiles and metals. The following is a list of
the major chemicals used in the rubber compounding and mixing
processes which can constitute these fugitive emissions:
• Processing Aids - zinc compounds
• Accelerators - zinc compounds, ethylene thiourea, and
diethanolamie
• Activators - nickel compounds, hydroquinone, phenol,
alphanaphthylamine, and p-phenylenediamine
• Age Restorers - selenium compounds, zinc compounds, and
lead compounds
• Initiator - benzoyl peroxide
• Accelerator Activators - zinc compounds, lead compounds,
and ammonia
• Plasticizers - dibutyl phthalate, dioctylphthalate, and
bis(2-ethylhexyl adipate)
• Miscellaneous Ingredients - titanium dioxide, cadmium
compounds, organic dyes, and antimony compounds.
VOC emissions are also an environmental concern in the rubber
product manufacturing process. A 1994 RMA Emissions Factors
study analyzed data on VOC emissions resulting from the mixing,
milling, extruding, calendering, vulcanizing, and grinding
processes. Although the findings showed extremely low VOC
emissions for each pound of rubber process, large facilities
processing great quantities of rubber face the potential of significant
VOC emissions. For example, a facility must process 100,000 pounds
of rubber to produce 10 pounds of VOCs during the mixing process.
These emissions may add up, however, at large tire facilities
producing 50,000 tires a day. The following are the finalized RMA
VOC emissions factors for the various processes:
• Mixing: 1 x 10'4 Ib VOC/lb rubber mixed (uncontrolled, i.e.,
before the control device)
• Milling: 8 x 10'5 Ib VOC/lb rubber processed
• Extruding: 1 x 10'5 Ib VOC/lb rubber processed
• Calendering: 3 x 10~5 Ib VOC/lb rubber processed
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• Vulcanizing: 4 x 1CH Ib VOC/lb rubber processed
• Grinding (during finishing): 6 x lO'3 Ib VOC/lb rubber
removed (controlled, i.e., after the control device).
The RMA VOC emissions factors have been sent to EPA for review
and possible inclusion in AP-42.
Solvent evaporation is another source of VOC emissions. Solvents
are used in various capacities during the rubber product
manufacturing process. For example, solvents are used to degrease
equipment and tools and as a type of adhesive during building.
Typically, releases of solvents occur either when the spent solvent
solutions are disposed as hazardous wastes or when degreasing
solvents are allowed to volatilize. In some facilities, mold release
compounds, sprayed onto the cavities of compression molds,
produce significant fugitive emissions. Solvents are becoming less
of an issue as water, silicon, and non-solvent based release
compounds are now common.
Solid Waste
Solid wastes are also an issue at rubber product manufacturing
facilities. Surface grinding activities that generate dust and rubber
particles are typically controlled by a primary cyclone and a
secondary baghouse or electrostatic precipitator. This baghouse-
captured particulate matter (chemicals, ground rubber, etc.) from
compounding areas, banburys, and grinders is a source of solid
waste. Used lubricating, hydraulic, and process oils are also
prevalent at most manufacturing facilities.
Scorched rubber from mixing, milling, calendering, and extruding is
a major solid waste source within the rubber product
manufacturing facilities, as is waste rubber produced during rubber
molding operations. Waste rubber can be classified into three
categories: (1) uncured rubber waste; (2) cured rubber waste; (3) off-
specification products. Currently, much of the uncured rubber
waste is recycled at the facility. Cured rubber waste is either recycled
at the facility or sold to other companies who use it to make
products such as mud flaps and playground mats. Off-specification
products can be sold to other companies who make products from
shredded or scrap rubber or it can be disposed. These practices are
discussed further in the section on pollution prevention.
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Waste Water
Waste water from cooling, heating, vulcanizing, and cleaning
operations is an environmental concern at many facilities.
Contaminants can be added to waste water in direct contact cooling
applications such as extruder cooling conveyors and from direct
contact steam used in vulcanizing operations. The residual in
adhesive dispensing containers and contaminated adhesives can
also be sources of contaminated waste water.
Zinc is of particular concern as a constituent of storm water for the
facilities involved in manufacturing and processing rubber
products. A study by the RMA identified several processes through
which zinc might be introduced into storm water. Inadequate
housekeeping is considered to be the primary source of zinc.
Inefficient, overloaded, or malfunctioning dust collectors and
baghouses are another source of zinc. Facilities that grind rubber
usually create dust. This dust, composed partially of zinc, can go
untreated (no dust collector) and be released into the atmosphere
through ventilation fans. The ventilation fans, which are typically
located in the ceilings, deposit the dust on the roof where it is
exposed to rain and hence to storm water. Some facilities use zinc
stearate slurry to prevent sticking between rubber products and
have indicated that the slurry frequently drips to the floor and
eventually drains to a storm water outlet.
Like plastic products, the leaching potential of rubber products
disposed in landfills poses a potential environmental concern. This
is a concern for rubber product manufacturing facilities which may
have to dispose of scrap rubber that they are unable to sell. The
RMA assessed the levels of chemicals, if any, leached from waste
rubber products using EPA's June 13, 1986 proposed Toxicity
Characterization Leaching Procedure (TCLP). TCLP tests were
performed on 16 types of rubber products to assess the leaching
potential of over 40 different chemicals which included volatile
organics, semi-volatile organics and metals. Results of the TCLP
study indicate that none of the rubber products tested, cured or
uncured, exceeded proposed TCLP regulatory levels. Most
compounds detected were found at trace levels (near method
detection limits) from ten to one hundred times less than proposed
TCLP regulatory limits. The TCLP regulatory levels adopted after
June 13,1986 were even less stringent than the original proposal.
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Tires
The resource material and pollution outputs from the tire
manufacturing process include all of the outputs discussed above in
the rubber product manufacturing process. There is however an
emphasis on the VOC emissions which result from cementing and
spraying operations (see Exhibit 22) and on scrap tire disposal.
VOC Emissions
Scrap Tires
VOC emissions from the rubber tire manufacturing process are
caused by solvent application to the different tire components
before, during, and after the building process (these VOC emissions
can also result from the manufacture of other rubber products that
require cementing or gluing). The principal VOC emitting
processes affected by NSPS regulations are undertread cementing
operations, sidewall cementing operations, tread end cementing
operations, bead cementing operations, green tire spraying
operations, Michelin-B operations, and Michelin-C automatic
operations. Michelin-B and -C operations are confidential and
cannot be revealed to the public. They are however known and
regulated by EPA. All cementing operations refer to the system
used to apply cement to any part of the tire. The green tire spraying
operation refers to the system used to apply a mold release agent
and lubricant to the inside and/or outside of green tires to facilitate
the curing process and to prevent rubber from sticking to the curing
press. VOC-emissions also occur in limited amounts from
operations where rubber is heated. Such operations include mixing,
milling, extruding, calendering, vulcanizing, and grinding.
Probably the biggest environmental concern with respect to rubber
tires is the disposal of scrap tires. In 1992, it was estimated that the
U.S. had approximately two billion scrap tires, with annual
additions of 200 to 250 million tires. These tires pose three
environmental threats. The first being that tire piles are a fire
hazard and burn with an intense heat which gives off dense black
smoke. These fires are extremely difficult to extinguish in part
because tire casings form natural air pockets that supply the oxygen
which feeds the flames. The second threat is that the tires trap rain
water which serves as a nesting ground for various insects such as
mosquitoes, and in areas where there are scrap tire piles there tend
to be severe insect problems. The third and most important
environmental threat associated with scrap tires is that discarded
tires are bulky, virtually indestructible, and when buried tend to
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work their way back to the surface as casings compressed by the dirt
slowly spring back into shape and "float" the tire upward. This
problem has led to either extremely high tipping fees for scrap tires
in landfills - at least twice the fee for municipal solid waste - or total
bans on whole tires in landfills. As discussed above, the RMA has
conducted testing to verify that tires are not hazardous wastes based
on TCLP analysis. The many efforts underway to address this
problem are discussed in the pollution prevention section of this
profile.
Exhibits 22
Tire Manufacturing Process Pollution Outputs
- Pollution Outputs
i I - Manufacturing Process
Chemcial additive
spills, leaks, and
gitive emissions
Chemcial additive
spills, leaks, and
itive emissio
Extruding -
Tread and
Sidewalls
Extruding -
Bead Wires
Calendering -
Rubber/Fabrics
Curing
Vulcanizing
Finishing
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ni.C. Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (EPA) requires facilities to
report information about the management of TRI chemicals in
waste and efforts made to eliminate or reduce those quantities.
These data have been collected annually in Section 8 of the TRI
reporting Form R. beginning with the 1991 reporting year. The data
summarized below cover the years 1992-1995 and is meant to
provide a basic understanding of the quantities of waste handled 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.
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 EPA 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 23 shows that the rubber and miscellaneous plastics industry
managed about .53 billion 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, 31 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 70 percent of the
industry's TRI wastes were managed on-site through recycling,
energy recovery, or treatment as shown in columns D, E and F,
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
G, H, and I, respectively. The remaining portion of the production-
related wastes (23.8 percent), shown in column J, is either released
to the environment through direct discharges to air, land, water,
and underground injection, or it is disposed off-site.
From the yearly data presented below it is apparent that the portion
of TRI wastes reported as recycled on-site has decreased and the
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portions treated or managed through energy recovery on-site have
increased between 1992 and 1995 (projected).
Exhibit 23
Rubber & Misc. Plastics
Source Reduction and Recycling Activity for SIC 30
A
Year
1992
1993
1994
1995
B
Production
Related
Waste
Volume
543
534
414
307
C
% Reported
as Released
and
Transferred
31%
31%
—
—
D
E | F
On-Site
%
Recycled
55.04%
55.91%
44.27%
27.35%
% Energy
Recovery
2.97%
2.83%
2.94%
6.02%
% Treated
11.61%
11.00%
15.49%
20.92%
G
H
I
Off-Site
%
Recycled
3.19%
5.16%
5.89%
% Energy
Recovery
1.95%
2.49%
2.66%
%
Treated
1.26%
1.74%
2.34%
J
Remaining
Releases
and
Disposal
23.87%
27.91%
34.82%
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the
pollutant releases that are reported by this industry. The best source
of comparative pollutant release information is the Toxic Release
Inventory System (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act, TRI includes self-reported facility
release and transfer data for over 600 toxic chemicals. Facilities
within SIC Codes 20-39 (manufacturing industries) that have more
than 10 employees, and that are above weight-based reporting
thresholds are required to report TRI on-site releases and off-site
transfers. The information presented within the sector notebooks is
derived from the most recently available (1993) TRI reporting year
(which then included 316 chemicals), and focuses primarily on the
on-site releases reported by each sector. Because TRI requires
consistent reporting regardless of sector, it is an excellent tool for
drawing comparisons across industries.
Although this sector notebook does not present historical
information regarding TRI chemical releases over time, please note
that in general, toxic chemical releases have been declining. In fact,
according to the 1993 Toxic Release Inventory Data Book, reported
releases dropped by 42.7% between 1988 and 1993. Although on-site
releases have decreased, the total amount of reported toxic waste
has not declined because the amount of toxic chemicals transferred
off-site has increased. Transfers have increased from 3.7 billion
pounds in 1991 to 4.7 billion pounds in 1993. Better management
practices have led to increases in off-site transfers of toxic chemicals
for recycling. More detailed information can be obtained from
EPA's annual Toxics Release Inventory Public Data Release book
(which is available through the EPCRA Hotline at 1-800-535-0202),
or directly from the Toxic Release Inventory System database (for
user support call 202-260-1531).
Wherever possible, the sector notebooks present TRI data as the
primary indicator of chemical release within each industrial
category. TRI data provide the type, amount, and media receptor of
each chemical released or transferred. When other sources of
pollutant release data have been obtained, these data have been
included to augment the TRI information.
TRI Data Limitations
The reader should keep in mind the following limitations
regarding TRI data. Within some sectors, the majority of facilities
are not subject to TRI reporting because they are not considered
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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, the notebook
briefly summarizes the toxicological properties of the top five
chemicals (by weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code — the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal
economic statistics. The SIC codes facilitate comparisons between
facility and industry data.
TRI Facilities — are manufacturing facilities that have 10 or more
full-time employees and are above established chemical throughput
thresholds. Manufacturing facilities are defined as facilities in
Standard Industrial Classification primary codes 20-39. Facilities
must submit estimates for all chemicals that are on the EPA's
defined list and are above throughput thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions
developed by EPA's Toxic Release Inventory Program. The
categories below represent the possible pollutant destinations that
can be reported.
RELEASES — are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to
bodies of water, releases at the facility to land, as well as contained
disposal into underground injection wells.
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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 stormwater runoff and non-
point losses must also be included.
Releases to Land — includes disposal of waste to on-site landfills,
waste that is land treated or incorporated into soil, surface
impoundments, spills, leaks, or waste piles. These activities must
occur within the facility's boundaries for inclusion in this category.
Underground Injection -- is a contained release of a fluid into a
subsurface well for the purpose of waste disposal.
TRANSFERS — is a transfer of toxic chemicals in wastes to a facility
that is geographically or physically separate from the facility
reporting under TRI. The quantities reported represent a
movement of the chemical away from the reporting facility. Except
for off-site transfers for disposal, these quantities do not necessarily
represent entry of the chemical into the environment.
Transfers to POTWs — are wastewaters transferred through pipes or
sewers to a publicly owned treatments works (POTW). Treatment
and chemical removal depend on the chemical's nature and
treatment methods used. Chemicals not treated or destroyed by the
POTW are generally released to surface waters or landfilled within
the sludge.
Transfers to Recycling — are sent off-site for the purposes of
regenerating or recovering still valuable materials. Once these
chemicals have been recycled, they may be returned to the
originating facility or sold commercially.
Transfers to Energy Recovery — are wastes combusted off-site in
industrial furnaces for energy recovery. Treatment of a chemical by
incineration is not considered to be energy recovery.
Transfers to Treatment — are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical
separation. In some cases, the chemicals are not destroyed but
prepared for further waste management.
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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 Rubber and Miscellaneous Plastics
Products Industry
The following section provides TRI data for those facilities
categorized under SIC 30, the rubber and miscellaneous plastics
products industry. According to the TRI data, the manufacture of
rubber and miscellaneous plastics products results primarily in the
release of solvents. The commonly released solvents include
acetone, toluene, methyl ethyl ketone, 1,1,1-trichloroethane, and
dichloromethane. According to the Toxic Release Inventory (TRI)
Public Release Data for 1993, the rubber and miscellaneous plastics
products industry released over 118 million pounds of pollutants
and transferred over 44 million pounds of pollutants. Of pollutants
released, approximately 69 percent were released as point source air
emissions, approximately 30.5 percent were released as fugitive air
emissions, approximately 0.2 percent were released to water, and
approximately 0.3 percent were disposed of on land.
The TRI database contains a detailed compilation of self-reported,
facility-specific chemical releases. The top reporting facilities for
this sector are listed below. Facilities that have reported only the
SIC codes covered under this notebook appear in Exhibit 24. Exhibit
25 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, Exhibit 25 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.
The rubber and miscellaneous plastics products industry air releases
can be traced primarily to the mixing component preparation and
building/assembly stages of the rubber manufacturing process and
to the solvent cleaning and finishing stages of the plastics products
manufacturing process. Major pollutants released to air include
toluene, dichloromethane, methylene chloride, and carbon
disulfide. Releases of pollutants to water and transfers of pollutants
to POTWs arise primarily from the cleaning and cooling of
machinery in both the rubber and plastic manufacturing processes
and from the cooling and heating of rubber during the rubber
SIC Code 30
50
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
products manufacturing process. Major pollutants released to water
include zinc compounds, sulfuric acid, and ammonia, and
ammonium sulfate. Major pollutants transferred to POTWs
include acetone, methanol, and zinc compounds, and ammonium
sulfate. Releases of pollutants to land arise from the use of various
chemicals in the rubber and plastic mixing processes. Major releases
of pollutants to land include barium compounds, antimony
compounds, zinc compounds, and styrene.
The rubber and miscellaneous plastics products industry releases
and transfers a number of metals in large quantities (i.e., transfers as
high as millions of pounds and releases as high as hundreds of
thousands of pounds). These metals include zinc compounds,
copper, lead, and lead compounds. Both zinc and lead are used in
the rubber mixing process as vulcanizing agents, accelerator
activators, and processing aids (zinc only). Lead and zinc can be
released during mixing operation as spills, leaks, and fugitive
emissions in the form of dust and particulates (which can and often
are captured by filters). Exhibit 27 and 28 present releases and
transfers for SIC 30 TRI reporting facilities.
Exhibit 24
Top 10 TRI Releasing Rubber and Plastics Products Manufacturing
Facilities (SIC 30)
Rank
1
2
3
4
5
6
7
8
9
10
Total TRI
Releases in
Pounds
5,425,721
3,603,789
2,901,978
2,586,030
2,559,756
2,129,000
1,363,500
1,359,629
1,293,243
1,265,488
Facility Name
Westinghouse Electric Corp.
Teepak Inc.
Goodyear Tire & Rubber Co.
Flexel Indiana Inc.
O'Sullivan Corp.
Viskase Corp.
Viskase Corp.
Hickory Springs Mfg. Co.
E. R. Carpenter Co. Inc.. Tupelo
Foamex L.P. Great Western Carpet Cushion
City
Hampton
Danville
Lincoln
Covington
Winchester
Loudon
Osceola
Conover
Verona
Orange
State
SC
IL
NE
IN
VA
TN
AR
NC
MS
CA
bource: US LPA, Toxics Release Inventory Database, 1993.
Note: Being included on this list does not mean that the release is associated with non-
compliance with environmental laws.
September 1995
51
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 25
Top 10 TRI Releasing Rubber and Misc. Plastics Products Facilities
SIC Codes
3083
3089
3052
3089
3081,3083
3089
2899, 3081,
2822
3089
3086
3081, 3083,
2671,2297
Total TRI
Releases in
Pounds
5,425,721
3,603,789
2,901,978
2,586,030
2,559,756
2,129,000
1,473,670
1,363,500
1,359,629
1,333,229
Facility Name
Westinghouse Electric Corp.
Teepak Inc.
Goodyear Tire & Rubber Co.
Flexel Indiana Inc.
O'Sullivan Corp.
Viskase Corp.
3M
Viskase Corp.
Hickory Spring Mfg. Co.
Foam Plant
IPC Corinth Div.
City
Hampton
Danville
Lincoln
Convington
Winchester
Loudon
Decatur
Oseola
Conover
Corinth
State
SC
IL
NE
IN
VA
TN
AL
AR
NC
MS
Source: US he A, 1 oxics Kelease inventory uataoase,
Note: Being included on this list does not mean that the release is associated with non-compliance
with environmental laws.
Exhibit 26
TRI Reporting Rubber and Plastics Products
Manufacturing Facilities (SIC 30) by State
State
AL
AR
AZ
CA
CO
CT
DE
FL
GA
IA
ID
IL
IN
KS
KY
Number of
Facilities
31
30
13
100
15
21
11
38
57
28
2
86
118
18
31
State
NC
ND
NE
NH
NJ
NM
NV
NY
OH
OK
OR
PA
PR
RI
SC
Number of
Facilities
101
2
10
11
42
3
4
33
171
13
17
76
4
9
44
SIC Code 30
52
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Producte
Exhibit 26 (cont'd)
TRI Reporting Rubber and Plastics Products
Manufacturing Facilities (SIC 30) by State
State
LA
MA
MD
ME
MI
MN
MO
MS
Number of
Facilities
6
44
9
5
81
36
41
31
State
SD
TN
TX
UT
VA
VT
WA
WI
WV
Number of
Facilities
4
74
110
6
35
4
16
53
17
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
53
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 27
Releases for Rubber and Plastics Products Manufacturing (SIC 30) in TRI, by
Number of Facilities (releases reported in pounds/year)
Chemical Name
Styrcnc
Zinc Compounds
Acetone
Toluene
Methyl Ethyl Ketone
1.1.1 -Trichloroethane
Dichloromcthanc
Di(2-Ethylhexyl) Phthalate
Vlcthylcncbis
(Phenvlisocvanate)
Antimony Compounds
Barium Compounds
Xylene (Mixed Isomers)
Lead Compounds
Toluencdiisocyanate
(Mixed Isomcrs)
Sulfuric Acid
Chromium Compounds
Methyl Isobutyl Ketone
Methanol
Glycol Ethers
Bis(2-Ethylhexyl) Adipate
Trichlorofluoromethane
Decabromodiphenyl Oxide
Hydrochloric Acid
Formaldehyde
N-Butyl Alcohol
Phenol
Methyl Mcthacrylate
Cobalt Compounds
Ethylene Glycol
Toluene-2.4-Diisocyanate
Trichlorocthylene
Butyl Benzyl Phthalate
Cadmium Compounds
Toluene-2.6-Diisocyanate
Dimethyl Phthalate
Diethanolamine
Lead
Dibutyl Phthalate
Mancancsc Compounds
Chlorine
^ Facilities
Reporting
Chemical
461
370
329
219
199
193
160
151
139
127
119
99
91
74
65
63
63
60
51
50
41
39
35
33
33
33
29
28
28
27
26
25
24
23
23
22
2C
IE
11
11
16
Fugitive
Air
4755176
44973
6479638
3785915
2793949
5374360
8144323
91271
8978
8144
72062
417496
5278
5847
1043
2258
167312
324667
95289
18402
1008351
3815
2207
32787
80646
59278
52402
453
22121
2165
738682
13603
573
312606
144S
5861
1584
272
314
281
4243$
46975
Point Air
7692418
44157
5821271
11297325
7482034
5647721
13955176
122847
10312
9895
7778
3406217
8328
15492
2590
3395
1894129
5964005
649213
72313
465928
19389
62715
1 14922
627028
662329
255715
506
402124
3405
336336
1930
525
230462
2369
10186
1496
1212
940C
1024
3425f
368792
Water
Discharges
250
14578
353
2279
0
7
450
95
0
1953
1060
10
1014
0
7005
10
0
0
5
10
0
357
0
90
0
132
0
280
2700
0
10
203
15
6037
0
5
0
12
7
ie
484
c
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
c
c
c
c
c
c
Land
Disposal
40057
93945
184
0
0
0
9753
92220
992
9810
10994
5
0
4682
0
2000
707
0
0
750
9374
0
0
250
0
0
4
2250
5
0
0
0
0
1100
0
0
0
0
5
C
25C
C
C
Total
Releases
12487901
197653
12301446
15085519
10275983
11022088
22109702
306433
20282
29802
190845
3823723
19302
21339
12643
6370
2061441
6288672
745257
100099
1474279
23561
65172
147799
707674
721743
310367
1244
426945
5570
1075028
15736
2213
549105
3818
16052
3080
1502
9721
1571
77178
415768
Release
per
Facility
27089
534
37390
68884
51638
57109
138186
2029
146
235
1604
38623
212
288
195
101
32721
104811
14613
2002
35958
604
1862
4479
21445
21871
10702
44
15248
206
41347
629
92
23874
166
730
154
83
92
4824
25986
Source: US EPA, Toxics Release Inventory Database, 1993.
SIC Code 30
54
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Exhibit 27 (cont'd)
Releases for Rubber and Plastics Products Manufacturing (SIC 30) in TRI, by
Number of Facilities (releases reported in pounds/year)
Chemical Name
Ethylbenzene
Copper Compounds
Isopropyl Alcohol
(Manufacturing)
Nickel Compounds
Phosphoric Acid
Zinc (Fume Or Dust)
Freon 113
Nitric Acid
Chromium
4,4'-Methylenebis
(2-Chloroaniline)
Antimony
Copper
Carbon Bisulfide
Barium
Dichlorodifluoromethane
Benzoyl Peroxide
Cumene Hydroperoxide
Cyclohexane
Diethyl Phthalate
Ethylene Thiourea
Nickel
4,4'-MethylenedianiIine
Manganese
Phthalic Anhydride
Propylene Oxide
Vinyl Acetate
Acrylic Acid
Acrylonitrile
Aluminum Oxide
(Fibrous Form)
Ammonium Sulfate
(Solution)
Arsenic Compounds
Chloroprene
Ethylene Oxide
1 ,2,4-Trimethylbenzene
1,4-Dioxane
Cresol (Mixed Isomers)
Maleic Anhydride
Selenium Compounds
2-Methoxyethanol
4,4'-
Isopropylidenediphenol
Asbestos (Friable)
Chloroethane
# Facilities
Reporting
Chemical
14
13
13
13
12
12
11
11
10
10
9
9
8
7
7
6
6
6
6
6
6
6
5
5
5
5
4
4
4
4
4
4
4
4
4
3
3
3
3
3
2
2
Fugitive
Air
4752
156
47381
286
5404
500
229347
1477
25
10
5
171
451497
4193
72623
252
23422
61564
11457
0
120
255
82
298
7076
8977
0
0
1005
0
5
0
14717
5757
920
5389
250
0
8152
212
0
140680
Point Air
200554
50
207141
960
1205
504
389191
1164
5
5
250
799
12136818
2007
42675
0
903
66357
23745
260
179
311
215
489
44815
6643
6506
1850
732
0
5
0
58889
40835
10341
1118
258
2
250318
45
0
201840
Water
Discharges
250
6
0
5
0
5
0
0
0
0
0
0
18273
0
0
0
0
0
18
0
0
0
0
0
0
0
1
0
159
250000
0
0
0
0
0
1
0
0
0
0
0
0
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Land
Disposal
0
0
0
0
0
4169
0
0
5
0
5
0
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
6332
0
0
0
3018
0
0
0
0
0
0
0
0
0
0
Total
Releases
205556
212
254522
1251
6609
5178
618538
2641
35
15
260
970
1260658
8
6200
115298
252
24325
127921
35220
260
304
566
297
787
51891
15620
6507
8182
1896
250000
10
3018
73606
46592
11261
6508
508
2
258470
257
0
342520
Average
Release
per
Facility
14683
16
19579
96
551
432
56231
240
4
2
29
108
1575824
886
16471
42
4054
21320
5870
43
51
94
59
157
10378
3124
1627
2046
474
62500
3
755
18402
2815
2169
169
1
86157
86
0
171260
Source: US EPA, Toxics Release Inventory Database, 1993.
September 1995
55
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 27 (cont'd)
Releases for Rubber and Plastics Products Manufacturing (SIC 30) in TRI, by
Number of Facilities (releases reported in pounds/year)
Chemical Name
Chloroform
Cobalt
Acctttldehyde
Aluminum (Fume Or
Dust)
Ammonium Nitrate
(Solution)
Butyl Acrylate
Cadmium
Chloro methane
Cumcnc
Cyanide Compounds
Uiehlorvos
M-Xylcnc
Michler's Kctone
Naphthalene
Vinylidcnc Chloride
1 ,2-biehloroetnane
1,3-Butadtcnc
Total
#/ Facilities
Reporting
Chemical
2
2
1
1
1
1
1
1
1
1
1579
Fugitive
Air
11825
0
0
0
0
0
5
95980
250
0
250
0
100
250
0
0
0
36242322
Point Air
5829
0
114
0
0
0
0
0
250
0
250
31000
1442
0
1525
250
0
81459310
Water
Discharges
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
308146
Under-
ground
Injection
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
5
Land
Disposal
0
5
0
0
0
0
0
0
0
0
250
1700
0
0
1
0
0
393773
Total
Releases
17654
5
114
0
0
0
5
95980
500
0
750
32700
1542
250
1527
250
0
118,403,556
Average
Releases per
Facility
8827
3
114
0
0
0
5
95980
500
0
750
32700
1542
250
1527
250
0
74,986
Source: US EPA, Toxics Release inventory Database,
Exhibit 28
Transfers for Rubber and Plastics Products Manufacturing (SIC 30) in TRI, by
Number of Facilities (transfers reported in pounds/year)
Chemical Name
Styrcne
Zinc Compounds
Acetone
Toluene
Methyl Ethyl Ketone
1.1.1 -Trichloroethane
Dichloromethane
Di(2-Ethylhexyl)
Phthalate
Mcthylenebis
fPhenylisocyanate)
Antimony Compounds
Barium Compounds
Xylenc (Mixed Isomers)
Lead Comoounds
Tolucnediisocyanate
(Mixed Isomers)
Sulfuric Acid
Chromium Compounds
Methyl Isobutyl Ketone
Mcthanol
GIvcol Ethers
# Facilities
Reporting
Chemical
461
370
329
219
199
193
160
151
139
127
119
99
91
74
65
63
63
60
51
POTW
Discharges
6412
48197
163425
6166
12
250
753
13806
0
2362
2021
9
1258
5
61066
293
589
174509
19935
Disposal
912615
5313559
62738
24650
9481
8081
23838
819005
50991
307512
609352
250
100404
5524
5900
88952
1005
255
68165
Recycling
86676
1330657
1021491
337563
1517588
356140
1061649
2219672
78361
61111
57595
234297
1441782
3335
123620
5735
126226
95817
73819
Treatment
84467
450403
178209
413312
454307
254839
219538
203704
25255
8576
33789
63807
22879
293268
22650
329484
41739
88988
17486
Energy
Recovery
540858
64930
1669477
2672384
3024993
380732
238847
84937
14927
7085
44543
549669
1977
417
393497
367353
47661
Total
Transfers
1631033
7208206
3106290
3455230
5007954
1000042
1544625
3341124
169534
386646
747300
848032
1568300
302549
213236
424464
563056
726922
227066
Average
Transfers
per
Facility
3538
19482
9442
15777
25166
5182
9654
22127
1220
3044
6280
8566
17234
4089
3281
6738
8937
12115
4452
Source: Us hPA, 1 oxics Release inventory uataoase,
SIC Code 30
56
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Exhibit 28 (cont'd)
Transfers for Rubber and Plastics Products Manufacturing (SIC 30) in TRI, by
Number of Facilities (transfers reported in pounds/year)
Chemical Name
Bis(2-Ethylhexyl) Adipate
Trichlorofluoromethane
Decabromodiphenyl Oxide
Hydrochloric Acid
Formaldehyde
N-Butyl Alcohol
Phenol
Methyl Methacrylate
Cobalt Compounds
Ethylene Glycol
Toluene-2,4-Diisocyanate
Trichloroethylene
Butyl Benzyl Phthalate
Cadmium Compounds
Ammonia
Toluene-2,6-Diisocyanate
Dimethyl Phthalate
Diethanolamine
Lead
Dibutyl Phthalate
Manganese Compounds
Chlorine
Tetrachloroethylene
Ethylbenzene
Copper Compounds
Isopropyl Alcohol
(Manufacturing)
Nickel Compounds
Phosphoric Acid
Zinc (Fume Or Dust)
Freon 113
Nitric Acid
Chromium
4,4'-Methylenebis
(2-Chloroaniline)
Antimony
Copper
Carbon Disulfide
Barium
Dichlorodifluoromethane
Benzoyl Peroxide
Cumene Hydroperoxide
Cyclohexane
Diethyl Phthalate
Ethylene Thiourea
Nickel
4,4'-Methylenedianiline
Manganese
Phthalic Anhydride
Propylene Oxide
# Facilities
Reporting
Chemical
50
41
39
35
33
33
33
29
28
28
27
26
25
24
23
23
22
20
18
17
17
16
16
14
13
13
13
12
12
11
11
10
10
9
9
8
7
7
6
6
6
6
6
6
6
5
5
5
POTW
Discharges
1255
250
515
14926
25727
5
59
15002
22
12047
0
10
935
36
28069
0
7893
0
67
5498
271
32800
0
251
331
0
271
0
1774
0
5
0
5
22
5
201233
0
0
0
0
250
45954
5
5
0
5
0
0
Disposal
58390
552
332723
100
9735
105
260711
33335
40697
5778
5430
4778
10043
2600
3267
12167
42354
17219
0
47972
5
22882
0
73419
41
56721
750
8063
21780
250
6018
5000
10609
250
11650
1010
10650
9634
4900
Recycling
146605
2498
6905
365
2053
2700
4146395
49588
70433
1108
3022
12397
250
1183359
12044
281
33955
505
3760
43
1610
218046
267963
7656
292083
5
69000
2054
85382
36964
Treatment
632
3277
8067
268
11194
12209
38458
7238
4385
137387
54488
36970
180
667
180
1635
497
27499
22860
5
13840
998
115960
179905
28180
17751
21
119
250
125
250
5187
22267
5585
3890
250
Energy
Recovery
108276
18920
2729
3488
101677
13963
44159
1030
1960
27640
15283
14
1590
51
1800
11000
1850
71764
42047
1589
1924
18368
630
Total
Transfers
315158
25497
350939
15294
50509
116049
313191
99734
47804
4302637
106036
140483
22284
13782
30849
12397
14635
548
1224892
93756
17776
32800
49645
73013
164768
45812
203101
28180
76803
235797
67
324803
2344
17915
313993
201733
6023
0
5000
10609
24055
148871
8654
96037
3890
46603
5530
250
Average
Transfers
per
Facility
6303
622
8998
437
1531
3517
9491
3439
1707
153666
3927
5403
891
574
1341
539
665
27
68050
5515
1046
2050
3103
5215
12674
15623
2348
6400
21436
6
32480
234
1991
34888
25217
860
0
833
1768
4009
24812
1442
16006
648
9321
1106
50
bource: Ub be A, 1 oxics Release Inventory Database, 1993
September 1995
57
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Exhibit 28 (cont'd)
Transfers for Rubber and Plastics Products
Manufacturing (SIC 30) in TRI, by Number of Facilities
(transfers reported in pounds/year)
Chemical Name
Vinyl Acetate
Acrylic Acid
Acrylonitrile
Aluminum Oxide
(Fibrous Form)
Ammonium Sulfate
(Solution)
Arsenic Compounds
Chloroprcnc
Ethylcne Oxide
1 ,2.4-Trimethylbenzene
1 ,4-Dioxane
Cresot (Mixed Isomers)
Maleic Anhydride
Selenium Compounds
2-Methoxyethanol
4,4'-
Isopropylidenediphenol
Asbestos (Friable)
Chlorocthane
Chloroform
Cobalt
Acetaldehydc
Aluminum (Fume Or
Dust)
Ammonium Nitrate
(Solution)
Butvl Acrvlate
Cadmium
Chloromcthane
Cumene
Cyanide Compounds
Dichlorvos
M-Xylcne
Michler's Ketone
Naphthalene
Vinylidene Chloride
1 .2-Dichloroethane
1,3-Butadicnc
Total
# Facilities
Reporting
Chemical
5
4
4
4
4
4
4
4
4
4
3
3
3
3
3
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1579
POTW
Discharges
0
0
0
0
2630872
5
0
750
0
113353
4
0
5
0
0
0
0
0
5
115
0
0
0
0
0
0
0
0
0
0
0
0
5410
3,647,090
Disposal
1638
0
6332
3591
5
5045
1320
1600
834
234
135704
250
1136
2863
9,704,417
Recycling
15
10161
2270
250
5
16,904,864
Treatment
6880
5
2700
0
9
169675
4,148,643
Energy
Recovery
5681
1268
2215
962
14883
600
1700
216
5
10,623,569
Total
Transfers
14199
0
7600
3591
2630872
30
5045
750
10161
117838
5986
1600
839
14883
243
135704
0
169675
5
115
500
0
600
0
0
1136
0
0
1700
216
10
0
0
8273
45,043,726
Average
Transfers
per
Facility
2840
0
1900
898
657718
8
1261
188
2540
29460
1995
533
280
4961
81
67852
0
84838
3
115
500
0
600
0
0
1136
0
0
1700
216
10
0
0
8273
28,537
Source: US he A, loxics Release inventory uataoase, ±yys
SIC Code 30
58
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Rubber and Miscellaneous Plastics Products
IV.B. Summary of the Selected Chemicals Released
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.
The brief descriptions provided below were taken from the 2993
Toxics Release Inventory Public Data Release (EPA, 1994), the
Hazardous Substances Data Bank (HSDB), and the Integrated Risk
Information System (IRIS), both accessed via TOXNET1. The
information contained below is based upon exposure assumptions
that have been conducted using standard scientific procedures. The
effects listed below must be taken in context of these exposure
assumptions that are more fully explained within the full chemical
profiles in HSDB.
1 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 1-800-231-3766. 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.
September 1995
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The top ten chemicals released by the rubber and miscellaneous
plastics products industry in 1993 were:
1,1/1-Trichloroethane
Acetone
Carbon Bisulfide
Dichloromethane
Methanol
Methyl Ethyl Ketone
Methyl Isobutyl Ketone.
Styrene
Toluene
Xylene (Mixed Isomers)
Summaries of some of the health and environmental impacts of
several of these chemicals are discussed below.
1,1.1-Trichloroethane
Toxicity. Repeated contact of 1,1,1-trichloroethane (TCE) with skin
may cause serious skin cracking and infection. Vapors cause a slight
smarting of the eyes or respiratory system if present in high
concentrations.
Exposure to high concentrations of TCE causes reversible mild liver
and kidney dysfunction, central nervous system depression, gait
disturbances, stupor, coma, respiratory depression, and even death.
Exposure to lower concentrations of TCE leads to light-headedness,
throat irritation, headache, disequilibrium, impaired coordination,
drowsiness, convulsions and mild changes in perception.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Pate. Releases of TCE to surface water or land will
almost entirely volatilize. Releases to air may be transported long
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Acetone
distances and may partially return to earth in rain. In the lower
atmosphere, TCE degrades very slowly by photo-oxidation and
slowly diffuses to the upper atmosphere where photo-degradation is
rapid.
Any TCE that does not evaporate from soils leaches to groundwater.
Degradation in soils and water is slow. TCE does not hydrolyze in
water, nor does it significantly bioconcentrate in aquatic organisms.
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 Pate. 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.
Note: Acetone was removed from the list of TRI chemicals on June
26, 1995 (60 FR 31643) and will not be reported for 1994 or
subsequent years.
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Dichlorodifluoromethane
Toxicity. Ordinary occupational and ambient exposure to
dichlorodifluoromethane (CFC-12 or Freon 12) causes neither eye
nor respiratory irritation. Short-term moderate to high inhalation
exposure to CFC-12 is linked to irregular heart beat and central
nervous system effects, such as dizziness, decreased coordination,
amnesia, apprehension, tingling, and unconsciousness. Attendant
lack of oxygen at high concentrations may also produce tremors,
convulsions, and cerebral edema. Inhalation of highly-concentrated
vapors, such as through accidental exposure to concentrated
refrigerant, can cause death through cardiovascular collapse and/or
severe damage to the respiratory tract. Long-term exposure to CFC-
12 is reported to cause heart palpitations and lightheadedness.
The most significant toxic effect associated with CFC-12 is its role as
a potent ozone-depletor. Stratospheric ozone depletion causes an
increase in the levels of ultraviolet solar radiation reaching the
earth's surface, which in turn is linked to increased incidence of
skin cancers, immune system suppression, cataracts, and
disruptions in terrestrial and aquatic ecosystems. In addition,
increased UV-B radiation is expected to increase photochemical
smog, aggravating related health problems in urban and
industrialized areas.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. All of the CFC-12 produced is eventually lost
as air emissions and builds up in the atmosphere. If released on
land, dichlorodifluoromethane leaches into the ground and
volatilizes from the soil surface. No degradative processes are
known to occur in the soil. Dichlorodifluoromethane is also stable
in water and the only removal process is volatilization.
Dichlorodifluoromethane is extremely stable in the lower
atmosphere and disperses over the globe and diffuses slowly into
the stratosphere where it is lost by photolysis. In this process,
chlorine atoms are released that degrade stratospheric ozone.
SIC Code 30
62
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Methanol
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 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 1 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.
Methvl Ethvl Ketone
Toxicity. Breathing moderate amounts of methyl ethyl ketone
(MEK) for short periods of time can cause adverse effects on the
nervous system ranging from headaches, dizziness, nausea, and
numbness in the fingers and toes to unconsciousness. Its vapors are
irritating to the skin, eyes, nose, and throat and can damage the
eyes. Repeated exposure to moderate to high amounts may cause
liver and kidney effects.
Carcinogenicity. No agreement exists over the carcinogenicity of
MEK. One source believes MEK is a possible carcinogen in humans
based on limited animal evidence. Other sources believe that there
is insufficient evidence to make any statements about possible
carcinogenicity.
September 1995
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Toluene
Environmental Fate. Most of the MEK released to the environment
will end up in the atmosphere. MEK can contribute to the
formation of air pollutants in the lower atmosphere. It can be
degraded by microorganisms living in water and soil.
Physical Properties. Methyl ethyl ketone is a flammable liquid.
Toxicity. Inhalation or ingestion of toluene can cause headaches,
confusion, weakness, and memory loss. Toluene may also affect the
way the kidneys and liver function.
Reactions of toluene (see environmental fate) in the atmosphere
contribute to the formation of ozone in the lower atmosphere.
Ozone can affect the respiratory system, especially in sensitive
individuals such as asthma or allergy sufferers.
Some studies have shown that unborn animals were harmed when
high levels of toluene were inhaled by their mothers, although the
same effects were not seen when the mothers were fed large
quantities of toluene. Note that these results may reflect similar
difficulties in humans.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases of toluene to land
and water will evaporate. Toluene may also be degraded by
microorganisms. Once volatilized, toluene in the lower
atmosphere will react with other atmospheric components
contributing to the formation of ground-level ozone and other air
pollutants.
Physical Properties. Toluene is a volatile organic chemical.
Xvlene (Mixed Isomers)
Toxicity. Xylenes are rapidly absorbed into the body after inhalation,
ingestion, or skin contact. Short-term exposure of humans to high
levels of xylenes can cause irritation of the skin, eyes, nose, and
throat, difficulty in breathing, impaired lung function, impaired
memory, and possible changes in the liver and kidneys. Both short-
and long-term exposure to high concentrations can cause effects
SIC Code 30
64
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
such as headaches, dizziness, confusion, and lack of muscle
coordination. Reactions of xylenes (see environmental fate) in the
atmosphere contribute to the formation of ozone in the lower
atmosphere. Ozone can affect the respiratory system, especially in
sensitive individuals such as asthma or allergy sufferers.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. The majority of releases to land and water
will quickly evaporate, although some degradation by
microorganisms will occur.
Xylenes are moderately mobile in soils and may leach into
groundwater, where they may persist for several years.
Xylenes are volatile organic chemicals. As such, xylenes in the
lower atmosphere will react with other atmospheric components,
contributing to the formation of ground-level ozone and other air
pollutants.
IV.C. Other Data Sources
The Aerometric Information Retrieval System (AIRS) contains a
wide range of information related to stationary sources of air
pollution, including the emissions of a number of air pollutants
which may be of concern within a particular industry. With the
exception of volatile organic compounds (VOCs), there is little
overlap with the TRI chemicals reported above. Exhibit 29
summarizes annual releases of carbon monoxide (CO), nitrogen
dioxide (NOa), particulate matter of 10 microns or less (PM10), total
particulates (FT), sulfur dioxide (SO2), and volatile organic
compounds (VOCs).
September 1995
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p
o
p
co
cs
a.
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s
cn cn
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SIC Code 30
66
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
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 table does not contain releases and transfers
for industrial categories that are not included in this project, and
thus cannot be used to draw conclusions regarding the total release
and transfer amounts that are reported to TRI. Similar information
is available within the annual TRI Public Data Release book.
Exhibit 30 is a graphical representation of a summary of the 1993
TRI data for the Rubber and Miscellaneous Plastics Products
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 31 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 Rubber
and Miscellaneous Plastics Products Industry, the 1993 TRI data
presented here covers 1,579 facilities. These facilities listed SIC 30,
the Rubber and Miscellaneous Plastics Products industry, as a
primary SIC code.
September 1995
67
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
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SIC Code 30
68
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
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o\
<--«
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
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 employing substitutes for toxic
chemicals. Some smaller facilities are able to 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
Rubber and Miscellaneous Plastics Products 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 techniques 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.
V.A.
Plastic
Identification of Pollution Prevention Activities in Use
In the plastic industry, there are substantial pollution prevention
options for most environmental concerns including chemical spills,
waste water (including solvents in waste water), plastic pellet loss,
and plastic product disposal. According to an NEIC inspector,
pollution prevention for leaks and spills of chemical additives
during compounding or finishing operations is as simple as
covering the chemical containers as often as possible and training
employees to properly handle and dispose of chemicals.
SIC Code 30
70
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Waste Water
The pollution prevention options for process waste water from the
plastic manufacturing industry are slightly more complex. As
discussed earlier, waste water can be divided into three categories:
contact cooling and heating water; cleaning water; and finishing
water. The technologies identified by EPA as appropriate for contact
cooling and heating water are good housekeeping practices and the
activated carbon process. The activated carbon process uses
activated (powered or granulated) carbon to remove soluble
organics from air and water. The organics are removed as they
became physically/chemically attached to the carbon (i.e. adsorbed to
the carbon surface). EPA analysis indicates that only one pollutant
of concern, bis(2-ethylhexyl)phthalate, is present in contact cooling
and heating water in treatable concentrations, and the only
technology identified to control bis(2-ethylhexyl)phthalate is the
activated carbon process. To maintain low concentrations of other
pollutants currently discharged in contact cooling and heating
water, EPA advises the application of good housekeeping practices.
For example, routine segregation of raw materials and lubricating
oils from the cooling and heating water will keep pollutants not
actually generated during the plastic molding and forming
operation out of the cooling and heating water.
In cleaning water, the data indicate that there are three
conventional pollutants (BODS, oil and grease, and TSS), three non
conventional (COD, TOC, and total phenols), and two priority
pollutants (phenol and zinc) present in treatable concentrations.
For the cleaning water category, EPA proposes pollution prevention
technologies based on in-process controls. One control is recycling
process water through a sedimentation tank designed to remove the
suspended solids so the process water can be reused. The other
control is end-of-pipe treatment of the discharge from the recycle
unit.
In finishing water, the data indicate that the only pollutants present
in treatable concentrations are total suspended solids (TSS) and
three phalates. The only pollution prevention technology EPA has
identified for the removal of TSS is a settling unit, and the only
technology identified for removal of phthalates present in finishing
water is an activated carbon process.
September 1995
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Pellet Release
Disposal
Rubber
The issue of plastic resin pellet loss to the environment during the
manufacturing process is being addressed by most manufacturers
through participation in "Operation Clean Sweep" (OCS). All
participating facilities take measures to ensure spill minimization,
prompt and thorough cleanup of spills, and proper pellet disposal.
Such measures include employee education, extra conscientious
sweeping efforts, enhanced pellet capture methods, and disposal
precautions. Currently, the Society of the Plastic Industry is in the
process of putting labels on all hoppers and cars used to transport
the pellets to remind employees of the importance of not spilling
the pellets.
Plastics products disposal, as discussed earlier, is a concern because
plastics make up a significant portion of the nation's waste stream.
The most common pollution prevention method currently
employed is recycling. Both single plastic resins and mixtures of
plastic resins can be recycled, but the end products from mixtures
are often lower in quality than those from just one type of resin.
Therefore, the success of plastic recycling will depend on the
development of technologies to separate mixed plastic into single
resins, and on increasing the markets for products made of mixed
plastic resins. Although recycling is the most common method of
plastic waste pollution prevention, at present, less than one percent
of all plastics products are recycled. Only a few plastic consumer
items such as soft drink bottles and milk jugs are being recycled on a
wide scale in the U.S., and the recycling of food containers and cups
is just getting started. Enhancing the degradation of plastic has been
offered as a solution to both the waste stream and marine
environmental problems; however, EPA believes source reduction
and recycling will provide the most significant results in reducing
the impact of plastic in the environment. EPA is conducting a study
of substitutes for lead- and cadmium-based additives as a possible
pollution prevention action for metal leaching at landfills and
metal releases from incinerator ash.
As discussed, pollution outputs from the rubber products industry
occur at many stages of the manufacturing process. Most facilities
are reducing these outputs by employing the many reasonable and
effective pollution prevention options that exist.
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Chemicals
The compounding and mixing area of a rubber products
manufacturing facility, where dry chemicals are weighed, put into
small containers, and loaded into the rubber mixer, can be a
significant source of particulate emissions. Some mixing facilities
have practically eliminated particulate emissions by purchasing
their chemicals in small pre-weighed, sealed polyethylene bags. The
sealed bags are put directly into the banbury mixer and the bag itself
becomes part of the rubber matrix, thus eliminating this formerly
dusty operation. For facilities not purchasing their chemicals in
pre-weighed bags, a variety of other pollution prevention options
exist. The following pollution prevention methods have been used
by various facilities:
• Careful Transportation Mechanisms - Receiving chemicals in
closed docks in sealed containers or in bulk rail or truck
shipments with a minimal history of spills. Storing chemical
piles inside the facility to ensure that any fugitive emissions
can be contained within the facility.
• Sealed Containers - Providing sealed containers for all open
materials. Sealed containers should have air space between
the chemical and the container cover to minimize "puffing"
losses when the container is opened. Similarly, placing
secondary containment mechanisms around all storage
containers provides further protection from spills and leaks.
• Automatic Dispensing - Utilizing automatic dispensing and
weighing equipment whenever possible. Automatic
dispensing minimizes waste due to spills from manual
dispensing and provides quality control.
• Reduced Toxic Chemical Usage - Reducing the use of toxic
chemicals via reformulation. For example, one
manufacturer claims to have reduced zinc waste simply by
reducing the amount of zinc added to the compound master
batch. He kept reducing the amount of zinc added until the
quality of the product suffered. The manufacturer then
assumed that the last zinc level at which no decrease in
product quality was discovered was the best "waste
minimized" operating level. Since manufacturers may use
several hundred compounding formulae on a regular basis,
formulae review may not only reduce waste production, but
also provide for increased quality control.
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Computer Inventories - Providing computer inventory
control methods to minimize the amount of stock purchased.
Spills and Sweeping Protocols - Providing protocols for
cleaning up spills and sweeping to ensure the proper
segregation of waste.
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Waste Water
Contaminated waste water is another pollution concern at many
rubber product manufacturing facilities. All but the largest rubber
product manufacturing facilities participate in waste water
pretreatment programs with local publicly-owned treatment works
(POTWs). Many plants meet pretreatment standards without
treatment of their waste water. Some facilities, however, require
solids settling, pH adjustment, or oil removal. To address the waste
water issue, many facilities have implemented water reuse and
recycling programs. Options for waste water reuse and recycling
include installing a closed-loop water cooling or heating system or a
closed-loop ethylene glycol system. Another problem is that waste
water is often contaminated by oil and grease. To prevent the
spilling and leaking of waste oil and grease which contaminates
waste water, the following pollution prevention methods have
been considered:
• Substituting lubricating grease for oil, especially for milling
equipment. Grease has been shown to reduce substantially
the amount of manifested waste.
• Performing preventive maintenance of processing, molding,
and curing equipment. Such practices can further reduce the
volume of manifested oil and grease waste by reducing waste
from worn seals and gaskets.
• Removing oil from oily waste waters prior to disposal to
reduce the volume of waste water disposal. For instance, oily
waste waters collected from equipment engine pits could be
routed through a centrally located oil/water separator prior to
discharge.
Spent Solvents
Spent solvents known to contribute to ozone depletion are another
pollution problem in rubber product manufacturing facilities. A
major initiative by the rubber products industry to eliminate ozone
depleting chemicals in 1994 and early 1995 resulted in many
innovative spent solvent pollution prevention activities. Among
the accomplishments were the replacement of solvent cleaning
applications with high pressure water systems, the use of caustic
cleaning solutions, and the substitution of old solvents with
cleaner, citrus-based solvents. Many mold release compounds,
coatings, and adhesives which formerly used ozone depleting
chemicals as carriers were reformulated to eliminate the offending
chemicals. Process changes and direct elimination of the chemicals
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Disposal
of concern were also accomplished. Most rubber products are now
free from having been manufactured with ozone depleting
chemicals.
A significant issue in the rubber product industry is the disposal of
waste rubber. To prevent the improper disposal of scrap rubber,
facilities can segregate and recycle rubber wastes. Properly
segregating waste streams may be as simple as placing a screen over
part of the molding equipment so that waste rubber stock produced
during performing operations can be segregated from the oily waste
waters and recycled back into the process. Other segregation
processes may include separating cured from uncured rubber, and
recycling the uncured portion back into the process.
Reclaiming and recycling cured, off-specification rubber is also a
waste minimization option. Reprocessing rubber involves taking
used rubber products and processing them in a manner that
produces a form of rubber filler or an ingredient that can be
incorporated into virgin rubber compounds. There are two general
methods for producing reprocessed rubber. The first is a severing of
cross-links by chemical or steam digestion to produce a product
known as reclaiming. The second is a grinding of rubber
compounds by ambient grinding, cryogenic grinding, or solution
grinding in water. These processes are also applicable to the scrap
rubber produced during finishing operations.
Scrap rubber which cannot be recycled within the manufacturing
process is being addressed by some of the following methods:
• Adding it to coal and wood waste fuels for firing process
boilers
• Making it into sheets and various shapes to use as athletic
area surfaces and other floor coverings
» Making it into sheet gasket material
• Making it into loading dock bumpers.
Recycling post-consumer and post-production scrap into products
offers great challenges. Automobile components are continuously
being designed for greater endurance (e.g., automobiles capable of
150,000 miles without maintenance or a tune up). Such
performance standards require manufacturers to use high purity
chemicals and quality, precision manufacturing processes. These
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Tires
rubber products, whether they be tires, belts, hoses, motor mounts,
gaskets, or a seals, turn out to be highly engineered entities with
strict quality standards. Introducing used, off-specification, or
unknown quality ingredients into the dynamically stressed, high
performance rubber product can be a problem. As a result, recycling
of the post-consumer and post-production waste seems, as a
necessity, to apply to the less sophisticated, non-dynamic, static
application products.
To better understand how much waste is being produced by their
facility in comparison to other facilities, many rubber product
manufacturers are monitoring waste indices, i.e., pounds of waste
per 100 pounds of product, with the goal of continuously reducing
the index. Index criteria include the following:
• Total Ibs. of non recyclable waste shipped off-site per 100 Ibs.
of product
• Total Ibs. of solid and hazardous water generated per 100 Ibs.
of product.
All of the pollution prevention options discussed in the section on
rubber product manufacture also apply to tire production. In
addition, the two pollution issues which apply specifically to the tire
industry are VOC emissions from the building and assembly process
and scrap tire disposal. In terms of pollution prevention for VOC
emissions from tire cementing and spraying operations, EPA
recommends capture and control technologies for undertread
cementing operations, tread end-cementing operations, bead
cementing operations, and green tire spraying operations where
organic solvent-based sprays are used. EPA also recommends that
green tire spraying operations consider switching to water-based
sprays (i.e., any green tire spray that contains 12 percent or less, by
weight, of VOC as sprayed) or organic solvent-based sprays.
While not technically a "pollution" output from the tire
manufacturing process. Scrap tire disposal has been a big waste
disposal issue in the U.S. Recently, legislation and initiatives have
been finding innovative ways to address this issue. The Scrap Tire
Management Council (the Council), made up of rubber industry
representatives, is leading the effort to find and expand markets for
the environmentally and economically sound uses of scrap tires.
According to the Rubber Manufacturers Association, in 1993, an
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estimated 33 percent of the 250 million tires scrapped annually were
utilized in a positive manner. This represents more than a tripling
of scrap tire use since 1990, and more than a five-fold increase since
1985. The principal use of scrap tires is as a fuel and fuel
supplement in a variety of utility and industrial applications. Other
major uses include ground rubber as an additive to asphalt paving
materials, whole and processed tire uses in civil engineering, and
utilization of cut, split, and ground tires in new products. The tires
not utilized are landfilled or stockpiled.
In 1993, 70 million tires were used in energy recovery. The capacity
to use an additional seven million tires in cement kilns was
permitted but not utilized. Asphalt paving utilized nearly five
million tires, as did civil engineering uses. The equivalent of one
million tires were used to manufacture various new products. The
Council projections indicate that by 1997, more than 328 million
tires could be utilized annually. Exhibit 32 shows the trends in the
number of scrap tires used in various capacities.
Exhibit 32
Scrap Tire Usage
SCRAP TIRE USES (Millions of Units)
Fuel
Paving
Civil Engineering
Products
Total Usage
1990
24.5
N/A
N/A
N/A
24.5
1992
57
5
5
1
68
1993
70
5
5
1
81
1997
230
80
15
3
328
Source: RMA 1993 lire Industry tacts.
The first line of defense against increasing scrap tire numbers is tire
retreading. The figures presented above do not include retreaded
tires because tire casings which are capable of being retreaded are
not, by definition, scrap tires. Only tires which can no longer be
used for their original intended purpose, even if retreaded, are
considered scrap tires. The American Retreaders Association
estimates that in 1993, nearly 32 million tires were retreaded and
returned to useful life on America's cars, trucks, airplanes, earth
movers, and industrial equipment.
The Federal government is working to identify and .implement
pollution prevention strategies to decrease the number of scrap tires
and the economic and environmental problems that accompany
scrap tire disposal. For example, in 1989 EPA promulgated
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procurement guidelines that promote the use of retread tires by
government agencies and entities funded by the government. If the
retread markets could be developed so that all passenger and light
truck tires suitable for retreading were actually retreaded,
approximately 20 million fewer new replacement tires would be
needed annually. This would reduce the number of scrap tires
generated per year by almost 10 percent.
As of January 1991, 36 States regulated scrap tires as a form of waste,
up from only one State in 1985. Twenty-four States have final
regulations in place that address storage of tires; typical provisions
include requiring permits for tire piles over a certain size and
requiring fire lanes in large tire piles. Funds may also be used to
provide grants or loans to entrepreneurs who are recycling tires or
incinerating them for energy recovery. At least four States (OR, WI,
UT, and OK) have developed rebate systems for scrap tires in which
users of scrap tires are paid rebates of one cent per pound or more
for recycling tires or burning them for energy recovery.
Other Private Sector Initiatives to Improve Environmental Performance
Many dry chemicals are purchased in sealed pre-weighed poly-logs
which can be put directly into the manufacturing process thus
eliminating fugitive emission. Fluorescent lamps and pressurized
spray cans are managed to minimize adverse impact on the
environment. Also, packaging materials are being reduced,
returnable containers are being used, and waste oil recycled.
General production improvements include the upgrading and
addition of plant ventilation systems, which provides cleaner air in
the workplace, improvement in solvent application efficiency to
decrease the amount of solvents needed, use of more efficient
coating equipment which speeds the production process, and the
refinement of preventive maintenance programs that often
virtually eliminate unplanned shutdowns which lead to waste.
Solvent use the rubber industry has been reduced through the
development of water-based adhesives and coatings, and astute raw
material substitution.
Enhanced personnel training, product substitution, and process
alternations have led to reduction in the amount of hazardous
waste generated, and recycling of paper, wood, skids, plastic shrink
wrap, cardboard, cord, wire, fabric, and white office paper have
increased. Some manufacturing plants have reduced waste water
discharges by installing closed loop water cooling systems, and other
companies removed and their underground storage tanks replaced
with above ground tanks that are easier to monitor for leaks.
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and regulations that may
apply to tihis 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 two following sections
are included.
• Section IV.A contains a general overview of major statutes
• Section IV.B contains a list of regulations specific to this
industry
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.
VI.A. General Description of Major Statutes
Resource Conservation And Recovery Act
The Resource Conservation And Recovery Act (RCRA) of 1976
which amended the Solid Waste Disposal Act, addresses solid
(Subtitle D) and hazardous (Subtitle C) waste management
activities. The Hazardous and Solid Waste Amendments (HSWA)
of 1984 strengthened RCRA's waste management provisions and
added Subtitle I, which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR
Parts 260-299) establish a "cradle-to-grave" system governing
hazardous waste from the point of generation to disposal. RCRA
hazardous wastes include the specific materials listed in the
regulations (commercial chemical products, designated with the
code "P" or "U"; hazardous wastes from specific industries/sources,
designated with the code "K"; or hazardous wastes from non-
specific sources, designated with the code "F") or materials which
exhibit a hazardous waste characteristic (ignitibility, corrosivity,
reactivity, or toxicity and designated with the code "D").
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Regulated entities that generate hazardous waste are subject to
waste accumulation, manifesting, and recordkeeping 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, recordkeeping and reporting requirements,
financial assurance mechanisms, and unit-specific standards.
RCRA also contains provisions (40 CFR Part 264 Subpart S and
§264.10) for conducting corrective actions which govern the cleanup
of releases of hazardous waste or constituents from solid waste
management units at RCRA-regulated facilities.
Although RCRA is a Federal statute, many States implement the
RCRA program. Currently, EPA has delegated its authority to
implement various provisions of RCRA to 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any
company that transports, treats, stores, or disposes of hazardous
waste. Here are some important RCRA regulatory requirements:
• Identification of Solid and Hazardous Wastes (40 CFR Part
261) lays out the procedure every generator should follow to
determine whether the material created is considered a
hazardous waste, solid waste, or is exempted from regulation.
• Standards for Generators of Hazardous Waste (40 CFR Part
262) establishes the responsibilities of hazardous waste
generators including obtaining an ID number, preparing a
manifest, ensuring proper packaging and labeling, meeting
standards for waste accumulation units, and recordkeeping
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.
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• Used Oil Management Standards (40 CFR Part 279) 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 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 8:30 a.m.
to 7:30 p.m., EST, excluding Federal holidays.
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Comprehensive Environmental Response, Compensation, And Liability Act
The Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), a 1980 law commonly known as Superfund,
authorizes EPA to respond to releases, or threatened releases, of
hazardous substances that may endanger public health, welfare, or
the environment. CERCLA also enables EPA to force parties
responsible for environmental contamination to clean it up or to
reimburse the Superfund for response costs incurred by EPA. The
Superfund Amendments and Reauthorization Act (SARA) of 1986
revised various sections of CERCLA, extended the taxing authority
for the Superfund, and created a free-standing law, SARA Title III,
also known as the Emergency Planning and Community Right-to-
Know Act (EPCRA).
The CERCLA hazardous substance release reporting regulations (40
CFR Part 302) direct the person in charge of a facility to report to the
National Response Center (NRC) any environmental release of a
hazardous substance which exceeds a reportable quantity.
Reportable quantities are defined and listed in 40 CFR § 302.4. A
release report may trigger a response by EPA, or by one or more
Federal or State emergency response authorities.
EPA implements hazardous substance responses according to
procedures outlined in the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP
includes provisions for permanent cleanups, known as remedial
actions, "and other cleanups referred to as "removals." EPA
generally takes remedial actions only at sites on the National
Priorities List (NPL), which currently includes approximately 1300
sites. Both EPA and states can act at other sites; however, EPA
provides responsible parties the opportunity to conduct removal
and remedial actions and encourages community involvement
throughout the Superfund response process.
EPA's RCRA/Superfund/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., EST, excluding Federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of
1986 created the Emergency Planning and Community Right-to-
Know Act (EPCRA, also known as SARA Title III), a statute
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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 its 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 MSDSs 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 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.
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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., EST, excluding
Federal holidays.
Clean Water Act
The primary objective of the Federal Water Pollution Control Act,
commonly referred to as the Clean Water Act (CWA), is to restore
and maintain the chemical, physical, and biological integrity of the
nation's surface waters. Pollutants regulated under the CWA
include "priority" pollutants, including various toxic pollutants;
"conventional" pollutants, such as biochemical oxygen demand
(BOD), total suspended solids (TSS), fecal coliform, oil and grease,
and pH; and "non-conventional" pollutants, including any
pollutant not identified as either conventional or priority.
The CWA regulates both direct and indirect discharges. The
National Pollutant Discharge Elimination System (NPDES)
program (CWA §402) controls direct discharges into navigable
waters. Direct discharges or "point source" discharges are from
sources such as pipes and sewers. NPDES permits, issued by either
EPA or an authorized State (EPA has presently authorized forty
States to administer the NPDES program), contain industry-specific,
technology-based and/or water quality-based limits, and establish
pollutant monitoring and reporting 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 materials storage areas at an
industrial plant (40 CFR 122.26(b)(14)). These regulations require
that facilities with the following storm water discharges apply for a
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 29-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.
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Category iv: Hazardous waste treatment, storage, or disposal
facilities.
Category v: Landfills, land application sites, and open dumps that
receive or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle
parts; and SIC 5093-automotive scrap and waste material recycling
facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation;
SIC 41-local passenger transportation; SIC 42-trucking and
warehousing (except public warehousing and storage); SIC 43-U.S.
Postal Service; SIC 44-water transportation; SIC 45-transportation by
air; and SIC 5171-petroleum bulk storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in
the disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products;
SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel
related products; SIC 2434-wood kitchen cabinets manufacturing;
SIC 25-furniture and fixtures; SIC 265-paperboard containers and
boxes; SIC 267-converted paper and paperboard products; SIC 27-
printing, publishing, and allied industries; SIC 283-drugs; SIC 285-
paints, varnishes, lacquer, enamels, and allied products; SIC 30-
rubber and plastics; SIC 31-leather and leather products (except
leather and tanning and finishing); SIC 323-glass products; SIC 34-
fabricated metal products (except fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment;
SIC 36-electronic and other electrical equipment and components;
SIC 37-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
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of pollutants to POTWs by "industrial users." Facilities regulated
under §307(b) must meet certain pretreatment standards. The goal
of the pretreatment program is to protect municipal wastewater
treatment plants from damage that may occur when hazardous,
toxic, or other wastes are discharged into a sewer system and to
protect the quality of sludge generated by these plants. Discharges to
a POTW are regulated primarily by the POTW itself, rather than the
State or EPA.
EPA has developed technology-based standards for industrial users
of POTWs. Different standards apply to existing and new sources
within each category. "Categorical" pretreatment standards
applicable to an industry on a nationwide basis are developed by
EPA. In addition, another kind of pretreatment standard, "local
limits," are developed by the POTW in order to assist the POTW in
achieving the effluent limitations in its NPDES permit.
Regardless of whether a State is authorized to implement either the
NPDES or the pretreatment program, if it develops its own
program, it may enforce requirements more stringent than Federal
standards.
EPA's Office of Water, at (202) 260-5700, will direct callers with
questions about the CWA to the appropriate EPA office. EPA also
maintains a bibliographic database of Office of Water publications
which can be accessed through the Ground Water and Drinking
Water resource center, at (202) 260-7786.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in
drinking water. The law authorizes EPA to develop national
drinking water standards and to create a joint Federal-State system
to ensure compliance with these standards. The SDWA also directs
EPA to protect underground sources of drinking water through the
control of underground injection of liquid wastes.
EPA has developed primary and secondary drinking water
standards under its SDWA authority. EPA and authorized States
enforce the primary drinking 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
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levels (MCLs), which are enforceable limits set as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SOW A Underground Injection Control (UIC) program (40 CFR
Parts 144-148) is a permit program which protects underground
sources of drinking water by regulating five classes of injection
wells. UIC permits include design, operating, inspection, and
monitoring requirements. Wells used to inject hazardous wastes
must also comply with RCRA corrective action standards in order
to be granted a RCRA permit, and must meet applicable RCRA land
disposal restrictions standards. The UIC permit program is
primarily State-enforced, since EPA has authorized all but a few
States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source
Aquifer program, which prohibits Federal funds from being
expended on projects that may contaminate the sole or principal
source of drinking water for a given area, and for a State-
implemented Wellhead Protection program, designed to protect
drinking water wells and drinking water recharge areas.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers
questions and distributes guidance pertaining to SDWA standards.
The Hotline operates from 9:00 a.m. through 5:30 p.m., EST,
excluding Federal holidays.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to
create a regulatory framework to collect data on chemicals in order
to evaluate, assess, mitigate, and control risks which may be posed
by their manufacture, processing, and use. TSCA provides a variety
of control methods to prevent chemicals from posing unreasonable
risk.
TSCA standards may apply at any point during a chemical's life
cycle. Under TSCA §5, EPA has established an inventory of
chemical substances. If a chemical is not already on the inventory,
and has not been excluded by TSCA, a premanufacture notice
(PMN) must be submitted to EPA prior to manufacture or import.
The PMN must identify the chemical and provide available
information on health and environmental effects. If available data
are not sufficient to evaluate the chemical's effects, EPA can impose
restrictions pending the development of information on its health
and environmental effects. EPA can also restrict significant new
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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., EST, excluding Federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments, including the Clean
Air Act Amendments (CAAA) of 1990, are designed to "protect and
enhance the nation's air resources so as to promote the public
health and welfare and the productive capacity of the population."
The CAA consists of six sections, known as Titles, which direct EPA
to establish national standards for ambient air quality and for EPA
and the States to implement, maintain, and enforce these standards
through a variety of mechanisms. Under the CAAA, many
facilities will be required to obtain permits for the first time. State
and local governments oversee, manage, and enforce many of the
requirements of the CAAA. CAA regulations appear at 40 CFR
Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national
ambient air quality standards (NAAQSs) to limit levels of "criteria
pollutants," including carbon monoxide, lead, nitrogen dioxide,
particulate matter, ozone, and sulfur dioxide. Geographic areas that
meet NAAQSs for a given pollutant are classified as attainment
areas; those that do not meet NAAQSs are classified as non-
attainment areas. Under §110 of the CAA, each State must develop
a State Implementation Plan (SIP) to identify sources of air
pollution and to determine what reductions are required to meet
Federal air quality standards.
Title I also authorizes EPA to establish New Source Performance
Standards (NSPSs), which are nationally uniform emission
standards for new stationary sources falling within particular
industrial categories. NSPSs are based on the pollution control
technology available to that category of industrial source but allow
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the affected industries the flexibility to devise a cost-effective means
of reducing emissions.
Under Title I, EPA establishes and enforces National Emission
Standards for Hazardous Air Pollutants (NESHAPs), nationally
uniform standards oriented towards controlling particular
hazardous air pollutants (HAPs). Title III of the CAAA further
directed EPA to develop a list of sources that emit any of 189 HAPs,
and to develop regulations for these categories of sources. To date
EPA has listed 174 categories and developed a schedule for the
establishment of emission standards. The emission standards will
be developed for both new and existing sources based on
"maximum achievable control technology" (MACT). The MACT is
defined as the control technology achieving the maximum degree
of reduction in the emission of the HAPs, taking into account cost
and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks,
buses, and planes. Reformulated gasoline, automobile pollution
control devices, and vapor recovery nozzles on gas pumps are a few
of the mechanisms EPA uses to regulate mobile air emission
sources.
Title IV establishes a sulfur dioxide emissions program designed to
reduce the formation of acid rain. Reduction of sulfur dioxide
releases will be obtained by granting to certain sources limited
emissions allowances, which, beginning in 1995, will be set below
previous levels of sulfur dioxide releases.
Title V of the CAAA of 1990 created a permit program for all "major
sources" (and certain other sources) regulated under the CAA. One
purpose of the operating permit is to include in a single document
all air emissions requirements that apply to a given facility. States
are developing the permit programs in accordance with guidance
and regulations from EPA. Once a State program is approved by
EPA, permits will be issued and monitored by that State.
Title VI is intended to protect stratospheric ozone by phasing out
the manufacture of ozone-depleting chemicals and restrict their use
and distribution. Production of Class I substances, including 15
kinds of 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
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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 Regulations
Although the rubber and plastics products manufacturing
industries are grouped together under SIC 30, current Federal
regulations separate the two industries. The environmental issues
directly addressed for rubber product manufacture are recycling
mandates, air emissions, and hazardous waste disposal. For plastic,
the only Federally-regulated issue is contaminated waste water.
Recycling requirements exist on the State and local level for plastics
products and will be expanded upon later. Based on their pollutant
outputs, both plastic and rubber products manufacturing processes
have the potential to be regulated under the Clean Water Act, the
Clean Air Act, and RCRA.
The Clean Air Act fCAA)
In addition to the applicable general requirements of the CAA,
rubber and plastics products manufacturing facilities are subject to
numerous industry-specific air regulations. Several new source
performance standards (NSPS) affect facilities in the rubber and
plastics manufacturing industries. One NSPS is 40 CFR Part 60,
Subpart BBB, "Standards of Performance for the Rubber Tire
Manufacturing Industry." This standard applies to new, modified
or reconstructed facilities which mass produce passenger car and
light-duty truck tires and similar tires with a bead diameter less
than or equal to 0.5 meters (19.7 inches) and a cross section
dimension less than 0.325 meters (12.98 inches). The emission
limits in the standard are for volatile organic compound (VOC)
emissions from undertread cementing, sidewall cementing, tread
end cementing, bead cementing and green tire spraying operations.
Another NSPS that affects certain facilities in the rubber and plastics
manufacturing industries is 40 CFR Part 60, Subpart TTT,
"Standards of Performance for Industrial Surface Coating: Surface
Costing of Plastic Parts for Business Machines." This standard
applies to new, modified, or reconstructed facilities that apply
coatings to plastic parts that will be used in the manufacture of
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business machines. The emission limits in the standards are for
VOC emissions from prime coats, color coats, texture coats, and
touch-up coats. Other NSPS standard such as NSPS ODD - For VOC
for the Polymer Manufacturing Industry, and NSPS VW - For
Polymeric Coating of Supporting Substrates Facilities, may also
apply to some facilities under SIC 30.
Under Title HI of the Clean Air Act Amendments (CAAA), the EPA
is developing many national emission standards for hazardous air
pollutants (NESHAPs). Several of these will affect certain facilities
in the rubber and plastics products manufacturing industries. These
include standards for reinforced plastics and composites, rubber tire
manufacturing, and plastic parts coating. Development of the
standard for reinforced plastics and composites started in 1995. The
development of the other two standards has not yet started.
Under Title I of the CAAA and under previous legislation, the EPA
has provided guidance and other information to State and local
agencies on reducing VOC emissions from existing sources in ozone
non-attainment areas. These documents are referred to as Control
Techniques Guidelines (CTGs) and Alternative Control Techniques
(ACTs). A CTG for rubber tire manufacturing was issued in 1978
(Control of Volatile Organic Compound Emissions from
Manufacture of Pneumatic Rubber Tires, EPA-450/2-78/030). An
ACT for coating of plastic parts was issued in 1994 (Alternative
Control Techniques Document: Surface Coating of
Automotive/Transportation and Business Machine Plastic Parts
EPA-453/R-94/017).
The Clean Water Act K7WA)
In addition to applicable general CWA requirements, rubber
product manufacturers are subject to the specific requirements
contained in 40 CFR Part 428, "EPA Effluent Guidelines and
Standards for Rubber Manufacturing." These regulations contain
pre-treatment and performance standards, and requirements for the
application of best practicable control technologies (BPT) and/or
Best Available Technologies (BAT). The regulated pollutants
include TSS, oil and grease, pH, COD, BODS, lead, and chromium.
The standards are promulgated under the authority of §§301, 304,
306, 307, 308, and 501 of the CWA and in response to the settlement
reached in Natural Resources Defense Council v. Train.
EPA promulgated regulations contained in the Federal Register,
Vol. 55 No. 222, "National Pollutants Discharge Elimination System
Permit Application Regulations for Storm Water Discharge; Final
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Rule" on November 16, 1990. These regulations require permit
applications for storm water discharges from selected municipal and
industrial point sources. The rubber manufacturing industry was
among the industries required to submit an application for storm
water discharge permits. The regulations require that a storm water
pollution prevention plan (SWPPP) be developed for each facility
covered by this regulation. The regulations state that the SWPPP
shall be prepared in accordance with good engineering practices and
in accordance with the factors outlined in 40 CFR §§125.3(d)(2) or (3)
as appropriate.
Plastics products manufacturers are subject to applicable general
CWA requirements and to the specific requirements contained in 40
CFR Part 463, "Plastic Molding and Forming Point Source Category
Effluent Limitations Guidelines; Pretreatment Standards and New
Source Performance Standards." This regulation establishes
effluent limitations guidelines and standards that limit the
discharge of pollutants into navigable waters by existing and new
sources engaged in plastic molding and forming. The regulated
pollutants include BODS, TSS, oil and grease, and pH.
Resource Conservation and Recovery Act (RCRA)
Facilities engaged in rubber product or rubber tire manufacture use
RCRA-regulated unused commercial chemical products which, if
spilled or sent for disposal, are considered hazardous waste. These
include ethylene thiourea, phenol, guanidines, and some lead,
selenium, and cadmium compounds. Because these are all
compounding agents which are added to the rubber mixture in their
original form, spills are a reasonable possibility and RCRA
requirements are likely to apply. Also, according to Toxic Release
Inventory (TRI) data, rubber and miscellaneous plastics products
manufacturing facilities use many solvents that are regulated by
RCRA. These solvents include toluene, methyl ethyl keytone, 1,1,1-
trichloroethane, acetone, methanol, xylene, methyl isobutyl
keytone, trichlorofluoromethane, freon 113, trichloroethylene, and
n-butyl alcohol.
Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA)
Facilities engaged in rubber compounding at either rubber products
or tire facilities may be required to report annually any releases to
the environment of certain chemicals regulated under §313, Title III
of the Superfund Amendments and Reauthorization Act (SARA) of
1986. If a rubber compounding facility has 10 or more full time
employees, all environmental releases of any §313-listed chemical
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or chemical category manufactured or processed by the facility in an
amount exceeding 25,000 pounds per year or otherwise used in an
amount exceeding 10,000 pounds per year must be reported. It is
important to note that approximately 35 percent of all rubber and
miscellaneous plastics products manufacturing facilities have less
than 10 employees and are not covered by EPCRA.
The Intermodal Surface Transportation Act of 1991
The purpose of the Intermodal Surface Transportation Act is to
increase the use of ground tire rubber in asphalt materials which are
purchased with Federal funds for use in highway construction and
maintenance. Ground tire rubber is produced by recycling used
automotive and truck tires that would ordinarily by disposed of by
placement in landfills or by other disposal procedures. Increased
use of tires in asphalt materials should help to remove tires from
the solid waste stream. At the same time, such use will assist in
conserving both energy and natural resources used in constructing
and maintaining pavement systems.
The Act mandates that starting in 1991, a "minimum utilization" of
five percent of all asphalt pavement financed in whole or in part by
the Federal government be asphalt rubber. This minimum is to
increase annually by five percent until 1997, when the minimum
utilization will have risen to 20 percent. More than 500 tires are
consumed to produce asphalt for a one-lane, one-mile stretch of
road. By encouraging the use of ground tire rubber, the guideline
should result in a decrease in the number of tires going to landfills
or to tire stockpiles. In addition, the increased use of rubber in
asphalt materials will result in reduced generation of solid wastes,
air pollutants, and water pollutants generated during the
production of asphalt and the aggregates used in asphalt concrete
pavements. To the extent that ground tire rubber replaces the
asphalt or the aggregate, these pollutants will be reduced.
Implementation of this Act has been delayed many times, and to
date it has not been fully implemented.
Guidance for Federal Procurement of Retread Tires
Retreading is the application of a new tread to a worn tire whose
casing is still in good condition. Currently, over 1,900 retreaders
operate in the U.S., though that number is shrinking because of
declining markets for passenger retreads. This decline is due to the
relatively low price of new tires and concerns about the safety of
retreads. Truck tires, however, are often retreaded three times
before they are discarded, and the truck tire retreading business is
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increasing. On November 17, 1989, EPA promoted the use of
retread tires by government agencies and other government-funded
entities by promulgating procurement guidelines for retread tires.
The purpose of retread guidelines is to assist procuring agencies in
complying with the requirements of §6002 of RCRA, as amended, 42
U.S.C. 6962, as that section applies to procurement of tires. By May
8, 1986, Federal agencies were required to eliminate from their
specifications any exclusion of retread tires and any requirement
that tires be manufactured from virgin materials unless there is a
technical basis for such exclusion or requirement. The current
guideline requires each procuring agency to assure that its
specifications require the use of retread tires to the maximum extent
possible without jeopardizing the intended end use of these items.
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VII.
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.
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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 the Census (See Section II). With
sectors dominated by small businesses, such as metal finishers and
printers, the reporting universe within the EPA databases may be
small in comparison to Census data. However, the group selected
for inclusion in this data analysis section should be consistent with
this sector's general make-up.
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 past five
calendar years (August 10,1990 to August 9, 1995) and the other for
the most recent twelve-month period (August 10, 1994 to August 9,
1995). The five-year analysis gives an average level of activity for
that period for comparison to the more recent activity.
Because most inspections focus on single-media requirements, the
data queries presented in this section are taken from single media
databases. These databases do not provide data on whether
inspections are State/local or EPA-led. However, the table breaking
down the universe of violations does give the reader a crude
measurement of the EPA's and States' efforts within each media
program. The presented data illustrate the variations across regions
for certain sectors.2 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.
2 EPA Regions include the following States: 1 (CT, MA, ME, RI, NH, VT); 2 (NJ, NY, PR, VI); 3
(DC, DE, MD, PA, VA, WV); 4 (AL, FL, GA, KY, MS, NC, SC, TN); 5 (EL, IN MI MN OH WI ; 6
(AR, LA, NM, OK, TX); 7 (IA, KS, MO, NE); 8 (CO, MT, ND, SD, UT, WY); 9 (AZ, CA, HI, NV,
Pacific Trust Territories); 10 (AK, ID, OR, WA).
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Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) - this system assigns a common
facility number to EPA single-media permit records. The FINDS
identification number allows EPA to compile and review all permit,
compliance, enforcement, and pollutant release data for any given
regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data
integration system that can retrieve information from the major
EPA program office databases. IDEA uses the FINDS identification
number to "glue together" separate data records from EPA's
databases. This is done to create a "master list" of data records for
any given facility. Some of the data systems accessible through
IDEA are: AIRS (Air Facility Indexing and Retrieval System, Office
of Air and Radiation), PCS (Permit Compliance System, Office of
Water), RCRIS (Resource Conservation and Recovery Information
System, Office of Solid Waste), NCDB (National Compliance Data
Base, Office of Prevention, Pesticides, and Toxic Substances),
CERCLIS (Comprehensive Environmental and Liability
Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside
sources such as Dun and Bradstreet and the Occupational Safety and
Health Administration (OSHA). Most data queries displayed in
notebook Sections IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search — are based on the universe of TRI reporters
within the listed SIC code range. For industries not covered under
TRI reporting requirements, the notebook uses the FINDS universe
for executing data queries. The SIC code range selected for each
search is defined by each notebook's selected SIC code coverage
described in Section II.
Facilities Inspected — indicates the level of EPA and State agency
facility inspections for the facilities in this data search. These values
show what percentage of the facility universe is inspected in a 12 or
60 month period. This column does not count non-inspectional
compliance activities such as the review of facility-reported
discharge reports.
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Number of Inspections - measures the total number of inspections
conducted in this sector. An inspection event is counted each time
it is entered into a single media database.
Average Time Between Inspections - provides an average length of
time, expressed in months, that a compliance inspection occurs at a
facility within the defined universe.
Facilities with One or More Enforcement Actions — expresses the
number of facilities that were party to at least one enforcement
action within the defined time period. This category is broken
down further into Federal and State actions. Data are obtained for
administrative, civil/judicial, and criminal enforcement actions.
Administrative actions include Notices of Violation (NOVs). A
facility with multiple enforcement actions is only counted once in
this column (facility with 3 enforcement actions counts as 1). 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 3 enforcement
actions counts as 3).
State Lead Actions — shows what percentage of the total
enforcement actions are taken by State and local environmental
agencies. Varying levels of use by States of EPA data systems may
limit the volume of actions accorded State enforcement activity.
Some States extensively report enforcement activities into EPA data
systems, while other States may use their own data systems.
Federal Lead Actions -- shows what percentage of the total
enforcement actions are taken by the U.S. EPA. 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. Related inspections and enforcement actions
under the Clean Water Act (PCS), the Clean Air Act (AFS) and the
Resource Conservation and Recovery Act (RCRA) are included in
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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.
VILA. The Rubber and Miscellaneous Plastics Products Industry
Compliance History
Exhibit 33 provides a Regional breakdown of the five year
enforcement and compliance activities for the rubber and
miscellaneous plastics products industry. Regions IV and V
conducted approximately-60 percent of the inspections of rubber and
miscellaneous plastics products manufacturing facilities performed
in the United States. This large percentage is due to the
concentration of rubber and miscellaneous plastics products
facilities in these areas.
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£
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SIC Code 30
102
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
VII.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 34-37 contain summaries of the one and five year
enforcement and compliance activities for the rubber and
miscellaneous plastics products industry, as well as for other
selected industries. As indicated in Exhibits 34 and 35, the rubber
and miscellaneous plastics products industry has an average
enforcement to inspection rate (12 percent) when compared to other
industries. Of the 4,044 inspections conducted at 963 rubber and
miscellaneous plastics products manufacturing facilities over a five
year period, 496, or 12 percent, resulted in enforcement actions.
Approximately 11 percent of inspections in the manufacturing
sector as a whole resulted in enforcement actions.
September 1995
103
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
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104
-------
Rubber aixd Miscellaneous Plastics Products
Sector Notebook Project
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SIC Code 30
105
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
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September 1995
106
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
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SIC Code 30
107
September 1995
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
VII.C. Review of Major Legal Actions
Vn.C.l. Review of Major Cases
This section provides summary information about major cases that
have affected this sector. As indicated in the EPA's Enforcement
Accomplishments Report, FY 1991, FY 1992, FY 1993 publications,
six significant enforcement cases were resolved between 1991 and
1993 for the rubber and plastics products manufacturing industry.
Two of these actions involved violations of CAA, and RCRA,
TSCA, CERCLA, and EPCRA accounted for one action each. Five of
these cases were brought against either rubber tire or rubber hose
manufacturing companies, and one case was brought against a
plastic product manufacturer. The cases involving the rubber
product manufacturing industry included improper disposal of
PCBs, failure to repair or replace PCB transformers, responsibility
for a Superfund site, producing mercury and benzene emissions
beyond NESHAP requirements, and failure to control VOC
emissions. The case involving the plastic product manufacturing
industry included operation of a surface impoundment and waste
pile in violation of RCRA.
Five of the six enforcement actions resulted in the assessment of a
penalty. Penalties ranged from $135,000 to $1,500,000, and in five
cases, the defendant was ordered to spend additional money to
improve the processes or technologies and to increase future
compliance. For example, in The Matter of Goodyear Tire & Rubber
Company (1991), the company paid a $135,000 penalty and spent
approximately $405,000 to remove and replace eight PCB
transformers. The average penalty per case was approximately
$500,000. Supplemental Environmental Projects (SEPs) were
required in three of the cases. In another case, B.F. Goodrich (1993)
was required to implement an environmentally beneficial project to
reduce mercury emissions beyond the NESHAP requirement, and
to conduct environmental audits at several of its facilities.
The case of U.S. et al. v. Production Plated Plastic. Inc. et al. (1992) is
considered significant by the EPA because the court held a corporate
officer and the owner of the company personally liable.
VILC2. Supplemental Environmental Projects (SEPs)
Below is 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
SIC Code 30
108
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
prevention activities that can significantly reduce the future
pollutant loadings of a facility.
In December, 1993, the Regions were asked by EPA's Office of
Enforcement and Compliance Assurance to provide information on
the number and type of SEPs entered into by the Regions. The
following chart contains a representative sample of the Regional
responses addressing the rubber and plastics products industry. The
information contained in the chart is not comprehensive and
provides only a sample of the types of SEPs developed for the rubber
and plastics products industry.
Private Sector Initiatives
Many tire and rubber product manufacturing companies participate
in a variety of Federal, State, and local voluntary initiatives
including:
• EPA's 33/50 program, a voluntary initiative to reduce toxic
waste generation from industrial sources.
• The Green lights program, an initiative encouraging
voluntary reductions in energy use through more efficient
lighting technologies.
• Energy Star Computer Program, a voluntary partnership
between EPA and the manufacturers that sell 60 percent of all
desktop computers and 80-90 percent of all laser printers in
the U.S. These companies are introducing products that
automatically "power-down" to save energy when not in use.
Concerning emissions reduction, industry-wide, many dry
chemicals are purchases in sealed pre-weighed poly-logs which can
be put directly into the manufacturing process thus eliminating
fugitive emission. Fluorescent lamps and pressurized spray cans
are managed so that they can be disposed of with no adverse impact
on the environment. Also, packaging materials are being reduced
and returnable containers are being maximized. Throughout the
rubber industry, the majority of waste oil is recycled for reuse.
General production improvements include the upgrading and
addition of plant ventilation systems, which provides cleaner air in
the workplace, improvement in solvent application efficiency to
decrease the amount of solvents needed, use of more efficient
coating equipment which speeds the production process, and the
September 1995
109
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
SIC Code 30
110
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
This page intentionally blank.
September 1995
111
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry
sector and public agencies to voluntarily improve the sector's
environmental performance. These activities include those
independently initiated by industrial trade associations. In this
section, the notebook also contains a listing and description of
national and regional trade associations.
VIII.A. Sector-Related Environmental Programs and Activities
Goodyear, the biggest tire manufacturer in the U.S., has
implemented a waste minimization and a SARA chemicals
reduction program which has proven to be quite effective. In the
mid 1980's, Goodyear set a corporate goal of 10 percent annual
reduction in solid waste disposal. In 1988, the CEO of Goodyear
established a more ambitious goal of 90 percent reduction in solid
waste disposal for North American facilities and an elimination of
all landfilling by 1994. Currently, each division of Goodyear is
setting annual reduction goals.
Many strategies have been employed to help Goodyear reach its
goals. Two internal waste minimization conferences have been
held to create a forum for the exchange and discussion of pollution
reduction ideas. Plants are now required to track various categories
of waste oil and grease, hazardous wastes (i.e., some compounding
agents), process waste, and material waste (i.e., fabrics, scrap rubber,
etc.). Monthly reports on the waste disposal tracking practices are
required for review at corporate headquarters. In addition to the
monthly reports, all Goodyear plants created flow diagrams for each
waste stream, wrote plant-specific waste reduction plans, and
selected yearly projects for waste minimization. The plants also
exchange waste minimization ideas and information on successes
and failures through corporate headquarters.
The results of these efforts have been very positive. Since 1988,
there has been an overall 67 percent reduction of waste generation
(based on 1993 data from all North American plants). At present, 35
percent of all waste is recycled at the facilities, and the pounds of
waste produced per 100 pounds of finished stock has decreased by 56
percent since 1988. 1,3 butadiene releases were reduced 64 percent by
the target date, and as of 1993 has been reduced 83 percent since 1988.
SIC Code 30
112
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Goodyear is also developing waste minimization plans for the
future. Currently, a cross-functional team from the corporate
headquarters is working on recyclable packaging for all of the raw
materials.
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 17 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 to participants who meet their 1992
goals. The list of chemicals includes 17 high-use chemicals reported
in the Toxics Release Inventory.
Exhibit 39 lists those companies participating in the 33/50 program
that reported under SIC code 30 to TRI. Many of the participating
companies listed multiple SIC codes (in no particular order), and are
therefore likely to conduct operations in addition to manufacturing
Rubber and Miscellaneous Plastic Products. The table shows the
number of facilities within each company that are participating in
the 33/50 program; each company's total 1993 releases and transfers
of 33/50 chemicals; and the percent reduction in these chemicals
since 1988.
Exhibit 39
Rubber and Misc. Plastic Product Producers Participating in the 33/50 Program
Parent Facility Name
3m Minnesota Mining & Mfg. Co
A. W. Chesterton Company
Abbott Laboratories
Aladdin Industries Inc
Albar Industries Inc
Aldan Rubber Co.
Allied-Signal Inc
Aluminum Company Of America
Parent City
St. Paul
Stoneham
North Chicago
Nashville
Lapeer
Philadelphia
Morristown
Pittsburgh
ST
MN
MA
IL
TN
MI
PA
NJ
PA
SIC Codes
3081, 3053,
3229, 3861,
2843, 2899
3053, 3561,
2869
3069, 3089
3086, 3469,
3648
3089
3069
3083
3089
# of
Participating
Facilities
8
1
2
1
1
1
2
5
1993
Releases
and
Transfers
(Ibs )
16,481,098
13,250
2,392,515
53,741
27,760
209,030
2,080,501
2,403,017
%
Reduction
1988 to
1993
70
65
20
91
55
80
50
51
September 1995
113
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 39 (cont'd)
Rubber and Misc. Plastic Product Producers Participating in the 33/50 Program
Parent Facility Name
Ameron Inc Delaware
Amsted Industries Incorporated
Apogee Plastic Tech. Inc.
Avon North America Inc
B F Goodrich Company
Baker Hughes Incorporated
Bamhardt Manufacturing Co
Baxter International Inc
Jcmis Company Inc
Bhar Incorporated
Bice Usa Inc
Blue Ridge Products Co Inc
Borden Inc
Bp America Inc
Bridgcstone/Firestone Inc
Jrown Group Inc
Cabot Corporation
Caterpillar Inc
Central Plastics Company
Chcm-Tech Rubber Inc
Chestnut Ridge Foam Inc.
Chevron Corporation
Como Plastics Corporation
Grain Industries Inc
Creative Foam Corporation
Oana Corporation
Dclbar Products Inc
Design House Inc
Dexter Corporation
Dow Chemical Company
Dow Corning Corporation
B. I. Du Pont De Nemours & Co
Eaglc-Pichcr Industries Inc
Parent City
'asadena
Chicago
Jaytona Beach
Cadillac
Akron
louston
Charlotte
Deerfield
Minneapolis
*ort Wayne
Chicago
iickory
New York
Cleveland
Akron
St Louis
3oston
Peoria
Shawnee
West Haven
Latrobe
San Francisco
Columbus
Fort Smith
Fenton
Toledo
Perkasie
Germantown
Windsor Locks
Midland
Midland
Wilmington
Cincinnati
ST
CA
1L
HL
Mi
OH
IX
NC
1L
MN
IN
1L
NC
NY
OH
OH
MO
MA
1L
OK
CT
PA
CA
IN
AR
Ml
OH
PA
Wl
cr
Ml
Ml
L>E
OH
SIC Codes
3084
3084
3087
3061
3087, 2821
3061
3086
3081, 2671,
3089
3081, 3083,
2754, 2759,
26713921
3087
3087
3086
3081, 2754,
2295
3089, 2299
3011
3069, 3079,
3086, 3089
3086
3052, 3069,
3089, 3086
3089, 3494
3069
3069
3084
3082
3086
3069
3053
3089, 3465
3089
3087
3086, 5169
282
3069
3081, 2821
2869, 308
306
# of
Participating
Facilities
1
1
1
1
10
1
1
1
3
1
1
1
2
1
5
1
2
2
1
1
1
1
1
12
2
2
1
1
2
4
2
1
6
1993
Releases
and
Transfers
(Ibs.)
184,882
1,834,493
45,921
0
621,207
193,116
629,426
42,570
936,449
755
152,253
39,369
1,644,614
1,597,404
166,052
213,505
2,407,581
870,439
43,635
561,000
22,000
2,794,502
59,657
2,700,636
331,566
1,652,123
102,983
98,256
122,127
2,769,36
1,134,61
11,740,85
227,24
%
Reduction
1988 to
1993
**
66
33
***
50
20
25
80
50
50
15
**
*
24
50
50
50
60
50
***
50
50
***
8
*
**
50
*
51
50
16
50
50
SIC Code 30
114
September 1995
-------
Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Exhibit 39 (cont'd)
Rubber and Misc. Plastic Product Producers Participating in the 33/50 Program
Parent Facility Name
Eastman Kodak Company
Ebonite International Inc
Ensign-Bickford Ind. Inc.
Federal-Mogul Corporation
Ferro Corporation
Flexcon Company Inc
Ford Motor Company
Forsch Ltd
Gates Corporation
Gencorp Inc
General Electric Company
General Motors Corporation
General Tire Inc
Georgia Gulf Corporation
Globe Manufacturing Co
Goodyear Tire & Rubber Co
Great Western Foam Pdts Corp
Great Western Foam Pdts Corp
Hartzell Manufacturing Inc
HBDIndustries Inc
Hercules Incorporated
HM Anglo-American Ltd
Home Interiors & Gifts Inc
[CI Americas
International Paper Company
Iten Industries Inc
[tt Corporation
T P Emco Inc
IMK International Inc
Jones & Vining Incorporated
Keene Corporation
Key Plastics Inc
Kimberly-Clark Corporation
Lacks Enterprises Inc
Liberty Polyglas Inc
Lord Corporation
Parent City
Rochester
Hopkinsville
Simsbury
Southfield
Cleveland
Spencer
Dearborn
Atlanta
Denver
Akron
Fairfield
Detroit
Akron
Atlanta
Fall River
Akron
Orange
Hayward
Saint Paul
Bellefontaine
Wilmington
New York
Dallas
Wilmington
Purchase
Ashtabula
New York
Ada
Fort Worth
Braintree
New York
Plymouth
rving
Grand Rapids
West Mifflin
Erie
ST
NY
KY
CT
Ml
OH
MA
Mi
GA
CO
OH
CT
Ml
OH
GA
MA
OH
CA
CA
MN
OH
DE
NY
TX
DE
NY
OH
NY
OK
TX
MA
NY
MI
TX
MI
PA
PA
SIC Codes
308
308
308
305
3087
308
3089, 3114
3089
3052
3069
3083, 3299
2821
3469, 3674
3089, 3694
3679, 3471
3011
3087
3069, 2824
3011
3086
3086
3089
3052
3089, 3764
3089, 3471,
3451, 3579
3089
3089, 2869
3083
3083
3052, 3714
3089
3069, 2822
3089
3089, 2821
3089
3086, 3842,
3949
3089, 3471
3083
3069, 3471
# of
Participating
Facilities
1
1
1
3
1
3
2
2
6
10
1
3
1
1
1
7
3
2
1
2
1
3
1
2
2
1
1
1
1
1
1
1
1
6
1
3
1993
Releases
and
Transfers
(Ibs.)
5,827,09
25,70
26,23
255,996
165,529
309,85
15,368,032
494,675
478,941
5,453,359
5r010,856
16,751,198
54,969
39,480
374,293
3,932,157
1,264,978
25,000
15,050
361,100
5,014,664
1,265,741
181,140
165,162
2,784,831
669
735,332
316,600
34,141
394,001
14,450
44,340
488,160
867,354
18,718
1,111,309
%
Reduction
1988 to
1993
50
94
***
50
50
54
15
21
***
34
50
*
***
80
45
50
*
***
85
*
50
2
83
50
50
*
7
75
50
89
**
50
50
27
*
58
September 1995
115
SIC Code 30
-------
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Exhibit 39 (cont'd)
Rubber and Misc. Plastic Product Producers Participating in the 33/50 Program
Parent Facility Name
[Louisville Tile Distributors
JMacho Products Inc
I
jMarley Usa Holding Corporation
(Masco Industries Inc
JMascotcch
Miles Inc
JMillikcn & Company
IMHIiporc Corporation
jMobil Corporation
{Molded Fiber Glass Companies
Monsanto Company
Morgan Stanley Leveraged Fund
Newell Co
Norton Company
O'Sullivan Corporation
jOberg Industries Inc
IJOecidental Petroleum Corp
||Ovvens-Illinois Inc
Parker Hannifin Corporation
jPeco Manufacturing Co. Inc.
jPermaccl
IJPhifcr Wire Products Inc
{Phillips Petroleum Company
[{Phillips Plastics Corporation
([Plymouth Rubber Company Inc
JPPG Industries Inc
IPremix Inc
IJPurethane Inc
IJRayvcn Inc
[[Reinz Wisconsin Gasket
Reynolds Metals Company
IJRogcrs Corporation
Parent City
Louisville
aim Bay
ohnson City
'aylor
'aylor
'ittsburgh
Spartanburg
Jedford
'airfax
Ashtabula
Saint Louis
"few York
'reeport
Worcester
Winchester
Freeport
^os Angeles
Toledo
Cleveland
Portland
North
Brunswick
Tuscaloosa
Bartlesville
Phillips
Canton
Pittsburgh
N Kingsville
West Branch
Saint Paul
Milwaukee
Richmond
Rogers
Philadelphia
ST
KY
L
N
Vli
Vll
'A
C
VIA
VA
OH
V1O
MY
L
VIA
VA
PA
JA
OH
JH
OR
NJ
AL
OK
Wl
VIA
PA
OH
1A
MN
Wl
VA
(Jl1
PA
SIC Codes
3088
3069, 3949,
3086
3089, 2499
3053
3069
3069
3069
3089
3081, 2673
3089
3086, 2821
3087
3089
3086
3082
3469, 3471,
3089
3081, 3087
3469, 3089
3052
3089, 3363,
3382
3069, 3089
3089, 3496
2869, 2879
3083, 2087
282
308
3069, 308
2821, 2819
2869, 308
308
3086, 371
308
305
3089, 3497
2671, 275
3061, 308
308
'articipating
Facilities
1
1
1
3
1
1
1
1
1
3
2
4
1
1
4
1
1
1
3
1
1
1
1
1
1
1
2
1
1
1
2
3
1
Releases
and
Transfers
(Ibs.)
27,000
471,824
74,713
488,484
3,163,830
1,095,504
13,500
65,529
4,263,284
86,211
1,683,580
2,166,420
324,283
40,831
2,461,791
18,435
8,896,126
412,573
244,966
16,409
485,52
24,500
2,367,877
33,11
343,00
2,772,33
497,85
213,15
14,41
16,82
2,055,29
76,99
1,210,24
Reduction
1988 to
1993
50
35
40
50
50
50
50
23
13
23
63
85
19
50
100
47
50
50
50
23
50
55
38
50
SIC Code 30
116
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Exhibit 39 (cont'd)
Rubber and Misc. Plastic Product Producers Participating in the 33/50 Proeram
Parent Facility Name
S C Johnson & Son Inc
S M R Technologies Inc
Sandoz Corporation
Seaward Intl. Inc.
Shell Petroleum Inc
Siebe Industries Inc
SKF Usa Inc
Solvay America Inc
Sonoco Products Company
Stanley Works
Stern Rubber Company
Superior Home Products
Sweetheart Holdings Inc
Tech Industries Inc
Tenneco Inc
Texas Instruments Incorporated
rherma-Tru Corp
Thyssen Holding Corporation
Trinity American Corp
Trinova Corporation
Union Carbide Corporation
United Silk Mills (Usa) Ltd
United Technologies Corp
Vernay Laboratories Inc
Vista Chemical Company
Vytech Ind. Inc.
W R Grace & Co Inc
Westinghouse Electric Corp
Wltco Corporation
Woodbridge Holdings Inc
Zeneca Holdings Inc
Parent
City
Racine •
Sharon
Center
New York
Clear Brook
Houston
Richmond
King Of
Prussia
Houston
Harts ville
New Britain
Staples
Maryville
Chicago
Woonsocket
Houston
Dallas
Sylvania
Troy
Glenola
Maumee
Danbury
New York
Hartford
Yellow
Springs
Houston
Anderson
Boca Raton
Pittsburgh
^ew York
Mississauga,
Ont., Canada
Wilmington
ST
WI
OH
NY
VA
'IX
VA
PA
IX
SC
CT
MN
IL
1L
Rl
IX
TX
OH
Ml
NC
OH
CT
NY
CT
OH
TX
SC .
FL
PA
NY
DE
SIC Codes
2821, 2842
2879, 2844
2899, 3089
3069
3087
3089
3089
3069
3053
3081
3089
3231, 3089,
2499
3061
3088
2656, 3082,
3089, 2679
3089, 3471
3353, 3081
3625, 3822,
2714, 3672,
3089
3442, 3089
3089
3086
3089
3069
3052
3089
3069
3087
3081, 2295,
2893, 3089
3089
3083, 3089,
2672
3089
3086
2295, 3087
# of
Participating
Facilities
1
1 .
. 5
1
2
4
5
1
3 '
2
1
1
1.
1
1
1
1
2
1
9
1
1
8
1
2
1
5
2
3
1
1
1993
Releases
and
Transfers
(Ibs.)
104,055
34,600
104,490
69,000
3,240,716
849,335
150,772
123,583
621,380
508,199
8,610
14,500
12,404
27,003
1,272,423
344,225
17,255
313,705
750
488,879
728,129
14,500
2,393,252
13,347
106,497
599,701
615,509
1,137,198.
327,611
45,081
1,609,047
%
Reduction
1988 to
1993
50
3.3
50
60
55
2
***
*
1
50
75
50
49
64
8
25
41
11
***
50
50
60
50
50
50
*
50
28
50
***
*
* = not quantifiable against 1988 data.
;* = use reduction goal only.
*** = no numerical goal.
September 1995
117
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Sector Notebook Project
Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national
initiative piloted by EPA and State agencies in which facilities have
volunteered to demonstrate innovative approaches to
environmental management and compliance. EPA has selected 12
pilot projects at industrial facilities and Federal installations which
will demonstrate the principles of the ELP program. These
principles include: environmental management systems,
multimedia compliance assurance, third-party verification of
compliance, public measures of accountability, community
involvement, and mentoring programs. In return for participating,
pilot participants receive public recognition and are given a period
of time to correct any violations discovered during these
experimental projects. (Contact: Tai-ming Chang, ELP Director, 202-
564-5081 or Robert Fentress, 202-564-7023)
Gillette ELP Project
The objective of the Gillette Environmental Leadership Program is
the development and implementation of a third party compliance
and management systems audit and verification process. The
project will involve the development of environmental
compliance and environmental management systems audit
protocol criteria that can be adopted and easily implemented by
other facilities to assess compliance with relevant regulations. The
three Gillette facilities that are participating are: South Boston
Manufacturing Center, blade and razor manufacturing; North
Chicago Manufacturing Center, batch chemical manufacturing; and
Santa Monica, CA, stationary products manufacturing . (Contact:
Scott Throwe, 202-564-7013).
Project XL was initiated in March 1995 as a part of President
Clinton's Reinventing Environmental Regulation initiative. The
projects seek to achieve cost effective environmental benefits by
allowing participants to replace or modify existing regulatory
requirements on the condition that they produce greater
environmental benefits. EPA and program participants will
negotiate and sign a Final Project Agreement, detailing specific
objectives that the regulated entity shall satisfy. In exchange, EPA
will allow the participant a certain degree of regulatory flexibility
and may seek changes in underlying regulations or statutes.
Participants are encouraged to seek stakeholder support from local
SIC Code 30
118
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
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, or 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 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:-Susan Bullard at 202-233-9065 or the Green
Light/Energy Star Hotline at 202-775-6650)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of
Solid Waste and Emergency Response. The program is aimed at
reducing municipal solid wastes by promoting waste minimization,
recycling collection, and the manufacturing and purchase of
recycled products. As of 1994, the program had about 300 companies
as members, including a number of major corporations. Members
agree to identify and implement actions to reduce their solid wastes
and must provide EPA with their waste reduction goals along with
yearly progress reports. EPA in turn provides technical assistance to
member companies and allows the use of the WasteWi$e logo for
promotional purposes. (Contact: Lynda Wynn, 202-260-0700 or the
WasteWi$e Hotline at 1-800-372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the
U.S. commitment to reduce greenhouse gas emissions in
accordance with the Climate Change Convention of the 1990 Earth
September 1995
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Sector Notebook Project
NICE3
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
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
In an effort to determine private sector activities, major trade
associations and corporations were contacted. There are a
significant number of activities occurring in both the rubber and
plastic industries. The Rubber Manufacturers Association (RMA)
has projects completed or underway which are looking at issues
such as storm water, emissions factors, scrap tires, and leaching
potentials of rubber products. The Society of the Plastic Industry has
started an incentive program called Operation Clean Sweep (OCS) to
help plastic product manufacturers comply with the EPA-regulated
problem of plastic pellet resin loss.
SIC Code 30
120
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Producte
VIII.C.l. Environmental Programs
Storm Water
EPA has identified storm water runoff as one of the leading causes
of the deterioration of water quality in rivers, lakes, streams,
wetlands, and estuaries. As a result, EPA promulgated regulations
on November 16, 1990, that required permit applications for storm
water discharges from, selected municipal and industrial point
sources. In 1990, the RMA sponsored a group storm water
application project which involved over 275 individual facilities.
Storm water sampling indicated that the rubber product
manufacturing facilities have minimal storm water pollution
concerns. The draft NPDES permits published in the Federal
Register on November 19, 1993 for the rubber industry reflect this
"minimal concern" by proposing the following provisions:
• No specific numerical effluent limitations are needed.
• Best management practices (BMP) are effective at reducing
pollutants.
• Quarterly visual observation of storm water discharges will
help minimize pollution.
Many States are not waiting for EPA to finalize the permitting
requirements and have requested that plants obtain local permits
with reporting and chemical analysis provisions.
Air Emissions
The RMA is also looking into air emissions. Accurate emissions
factors for hazardous air pollutants (HAPs) are required by CAA
Title V for preparation of emissions inventories in rubber
manufacturing plants. The rubber manufacturing industry is one of
the industries for which up-to-date emissions factors are not
available. The RMA has initiated an emissions sampling program,
on behalf of its members, to develop HAP emissions factors for
processes with little available air pollutant emissions data. Six
processes common to both the tire and general rubber products
industries were the subject of this project. The processes were:
mixing, milling, extruding, calendering, vulcanizing, and grinding.
Twenty-six rubber compounds/mixtures were studied in this
program. For each test, emissions rates were developed as pounds
of pollutant emitted per pound of rubber (or product) processed.
September 1995
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Sector Notebook Project
The emissions factors project is breaking new ground as this type of
testing has never been done on such a scale for the tire and rubber
industry. RMA and members of its Environment Committee have
held three meetings with EPA's air program in Research Triangle
Park. EPA officials have indicated to RMA representatives a
willingness to use the results of this project as the basis for a new
section of AP-42, EPA's compilation of air pollutant emissions
factors. EPA predicts that the new rubber industry factors could be
on EPA's Bulletin Board by the end of 1995 and that full print
publication could take place in 1996.
Scrap Tire Disposal
Scrap tire disposal is another issue being addressed by the rubber
industry. In 1990, members of the RMA created the Scrap Tire
Management Council (the Council). The Council is working to find
uses for scrap tires that are both economically and environmentally
sound. The three main themes held by the council are reuse,
recycle, or recovery. To date, improvements in finding uses for
scrap tires have been strong. In 1993, approximately 33 percent of
the 250 million scrap tires introduced that year were used in some
way. This represents a tripling of the amount of scrap tires used in
1990 and more than a five fold increase in scrap tire usage since
1985.
The RMA is also looking into the leaching potential of disposed
scrap rubber. In 1989 the RMA conducted an assessment using
EPA's proposed Toxicity Characterization leaching Procedure
(TCLP), to determine what levels of chemicals, if any, are leached
from representative RMA products. The TCLP proposes to add
chemicals to the existing list of compounds regulated under Subtitle
C of RCRA, and to introdtice new extraction methods. The results
of the TCLP analysis showed that none of the products tested, cured
or uncured, exceeded proposed TCLP regulatory levels. The RMA
also compared the effect of a modification to the TCLP recently
proposed by EPA in 1989 which would eliminate grinding prior to
leaching; in effect making TCLP tests of rubber products more
representative of disposal practices. The results from tests of
ground and unground samples were comparable.
Within the plastics products industry, the Society of the Plastic
Industry (SPI) started the incentive program Operation Clean Sweep
(OCS) to promote efforts to reduce plastic resin pellet loss. SPI
implements the program informally, by requiring all participating
facilities to encourage spill minimization, prompt and thorough
SIC Code 30
122
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
cleanup of spills, and proper pellet disposal. The participating
manufacturers sign a pledge which says they will try to prevent
pellet loss. They then draft and submit an action plan stating how
they plan to comply with the pledge. A typical action plan includes
measures such as employee education, conscientious sweeping
efforts, enhanced pellet capture methods, and disposal precautions.
In 1992, SPI held a conference as part of OCS to encourage dialog
within the industry on how to control resin pellet loss options.
Currently, SPI is in the process of putting labels on all hoppers and
cars used to transport the pellets to remind employees of the
importance of not spilling the pellets. They are also offering OCS
education videos, manuals, hats, t-shirts, and posters.
VIII.C.2. Summary of Trade Associations
Rubber Manufacturers Association (RMA)
1400 K Street, N.W.
Washington, D.C. 20005
Phone: (202)682-4800
Fax: (202)682-4854
Members: 185
Staff: 25
Budget:
Contact: Thomas E. Cole
Founded in 1900, RMA represents manufactures of tires, tubes,
mechanical and industrial products, roofing, sporting goods, and
other rubber products. RMA compiles monthly, quarterly, and
annual statistics on rubber and rubber products. Committees within
the organization include Economics and Trade, Education,
Electronic Data Processing, Energy, Environment, Government
Relations, OSHA, Public Relations, and Statistics. Divisions within
the organization include Industrial Products, Molded and Extruded
Products, Roofing Products, Sealing Products, and Sundries and
Tires.
International Tire Association (ITA)
P.O. Box 1067
Farmington, CT 06034
Phone: (203)228-4739
Fax:
Members: 1,000
Staff: 2
Budget:
Contact: Ann E. Evans
Founded in 1985, ITA is comprised of individuals working in the
tire industry. It promotes international goodwill and
communication in the industry and encourages publications. ITA
bestows membership and achievement awards and sponsors
seminars on tire industry issues. ITA also compiles statistics and
sponsors lectures on scrap tires and universal sizing of tires. ITA
publishes the Tire Advocate (quarterly).
September 1995
123
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r
Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Tire and Rim Association (TRA)
175 Montrose Avenue, West
Copley, OH 44321
Phone: (216)666-8121
Fax: (216) 666-8340
Members: 123
Staff: 3
Budget:
Contact: J.F. Pacuit
Founded in 1903, TRA includes manufacturers of tires, rims,
wheels, and related parts. TRA establishes standards (primarily
dimensional) for the interchanging of tires, rim contours, tubes,
valves, and flaps for passenger cars, motorcycles, trucks, buses,
airplanes, and for earth moving, road building, agricultural, and
industrial vehicles. TRA includes a Standards and Technical
Advisory Committee. Subcommittees include Agricultural Tire
and Rim, Aircraft Tire and Rim, Cycle Tire and Rim, Industrial Tire
and Rim, Off-the-Road Tire and Rim; Passenger Car Tire and Rim;
Truck-Bus Tire and Rim; and Tube and Valve. TRA also publishes
Engineering Design Information for Aircraft Tires and Rims
(periodic), Engineering Design Information for Ground Vehicles
Tires and Rims (quarterly), Tire and Rim Association-Aircraft Year
Book, and Tire and Rim Association Year Book.
National Tire Dealers and Retreaders
Association (NTDRA)
6333 Long Street, Suite 340
Shawnee,KS 66216
Phone: (913)268-6273
Fax: (913) 268-6388
Members: 5,000
Staff: 30
Budget:
Contact: Philip P. Friedlander
Founded in 1920, NTDRA represents independent tire dealers and
retreaders. It includes 25 State and 80 local groups. NTDRA
publishes Master Retreader (bimonthly), National Tire Dealers and
Retreaders Association-Hotline (bimonthly), National Tire Dealers
and Retreaders Association-Who's Who Membership Directory
(annual), NTDRA Dealer News (monthly), and NTDRA
Membergram (monthly).
Society of the Plastic Industry (SPI)
1275 K Street, N.W., Suite 400
Washington, D.C. 20005
Phone: (202)371-5200
Fax: (202)371-1022
Members: 2,000
Staff: 120
Budget:
Contact: Larry L. Thomas
Founded in 1937, SPI represents manufacturers and processors of
molded, extruded, fabricated, laminated, calendered, and reinforced
plastic; manufacturers of raw materials, machinery, tools, dies, and
SIC Code 30
124
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
molds; and testing laboratories. SPI supports research, proposes
standards for plastics products, compiles statistics, maintains a
speakers' bureau, organizes competitions, and bestows awards. SPI
also publishes Financial and Operating Ratios (annual); Plastic
News Briefs (monthly); Society of the Plastic Industry - Facts and
Figures (annual); Society of the Plastic Industry - Labor Survey
(annual); and Society of the Plastic Industry - Membership (annual).
Society of Plastic Engineers (SPE)
14 Fairfield Drive
Brookfield, CT 06804-0403
Phone: (203)775-0471
Fax: (203)775-8490
Members: 37,000
Staff: 35
Budget: $5,000,000
Contact: Robert D. Forger
SPE is a professional society of plastic scientists, engineers,
educators, students, and others interested in the design,
development, production, and utilization of plastic materials,
products, and equipment. SPE awards a plaque, gold medal, and
$5,000 in recognition of fundamental contributions to the
technology of polymer science and engineering, plus seven other
awards of $2,500 each for achievements in engineering and
technology, education, business management, research, production
of unique plastics products for consumer and industrial use, and
contribution to mankind in the field of plastic. SPE also conducts
seminars. Committees within SPE include Award, Credentials,
Education, Education Seminar, International Relations,
Management Involvement, New Technology, Plastic Education
Foundation, Public Interest, Technical Programs, and Technical
Volumes. Divisions include Advanced Polymer Composites,
Automotive, Blow Molding, Color and Appearance, Decorating,
Electrical and Electronics, Engineering Properties and Structure,
Extrusion, Injection Molding, Marketing, Medical Plastic, Mold
Making and Mold Design, Plastic Analysis, Plastic Recycling,
Polymodifers and Additives, Thermoforming, Thermoplastic
Materials and Foams, Thermosetting Molding, and Vinyl Plastic.
SPE also publishes the Journal of Vinyl Technology (quarterly);
Plastic Engineering (monthly); Polymer Composites (bimonthly);
Polymer Engineering and Science (semimonthly); and Preprint
Volumes and the Plastic Engineering Series (books).
Association of Rotational Molders (ARM)
435 North Michigan avenue, Suite 1717
Chicago, IL 60611-4067
Phone: (312)644-0828
Fax:
Members: 300
Staff: 3
Budget: $500,000
Contact: Charles D. Fredrick
September 1995
125
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Founded in 1976, ARM represents plastic processors who use the
rotational molding process, their suppliers, and overseas molders.
ARM's purposes are to increase awareness of roto-molding,
exchange technical information, provide education, and standardize
production guidelines. ARM conducts research seminars,
educational video, and slide programs, maintains a private library,
sponsors a product contest, and bestows awards. ARM also offers a
membership database. ARM publishes the ARM Roster (annual)
and the Roto-Molder Review (4-6/year).
National Association of Plastic Distributors
(NAPD)
6333 Long Street, Suite 340
Shawnee,KS 66216
Phone: (913)268-6273
Fax: (913)268-6388
Members: 450
Staff: 4
Budget: $825,000
Contact: Carol K. Wagner
Founded in 1955, NAPD represents distributors of plastic materials,
firms that both manufacture and distribute these materials, and
manufacturers who sell their products through plastic distributors.
The objective of NAPD is to promote proper and efficient
distributor involvement in the plastic industry. NAPD maintains
liaison with associated organizations, operates a library, bestows
awards, and compiles statistics. Publications include the Cost-of-
Doing Business Survey (annual); the Membership Directory
(annual); the NAPD Magazine (monthly); and computerized data
processing manuals, charts, and other materials.
Tube and Pipe Fabricators Association,
International (TPFA)
5411 East State Street
Rockford,IL 61108
Phone: (815)399-8700
Fax: (815)339-7279
Members: 450
Staff: 8
Budget:
Contact: JohnNandzik
Founded in 1983, TPFA represents companies that are responsible
for the fabrication of plastic tubing and piping, and suppliers of
equipment and services. TPFA provides a forum for individuals
involved in the tube and pipe fabricating industry. It encourages
discussion on problems involved in pipe manufacturing and assists
in formulating standards. TPFA's publications include
Membership Directory (annual), Technology Update (quarterly),
TPQ - The Tube and Pipe Quarterly, news releases, and voluntary
standards relevant to the pipe producing industry.
SIC Code 30
126
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Plastic Pipe and Fittings Association (PPFA)
Building C, Suite 20
800 Roosevelt Road
GlenEllyn,IL 60137
Phone: (708)858-6540
Fax:
Members: 48
Staff: .4
Budget:
Contact: Richard W. Church
Founded in 1978, PPFA represents raw material suppliers and
processors of plastic pipe and fittings. PPFA's objectives are to
provide a forum for exchange of information and ideas; to see that
existing code approvals for use of plastic pipe and fittings are
retained; to obtain additional code approvals and develop new
markets for products; to provide leadership and continuity for the
industry; and to seek liaison and involvement with other
organizations within the industry.
September 1995
127
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
General Profile
Industry and Trade Summary - Pneumatic Tires and Tubes, U.S. International
Trade Commission, Washington, D.C., February 1994.
Natural Rubber, Senior Policy Paper, Theodore J. Goering, The World Bank,
Washington, D.C., 1982.
Tire Business - 1993 Annual Report, Tire Business, Akron, OH.
U.S. Industrial Outlook 1994, Department of Commerce.
1987 Census of Manufacturers: Rubber and Plastics products, Bureau of the
Census, 1987.
Process Descriptions
The Chemical Process Industries, First ed., R. Norris Shreve, McGraw-Hill Book
Company, Inc., New York, NY, 1945.
Assessment of Industrial Hazardous Waste Practices - Rubber and Plastic
Industry, Foster D. Snell for the U.S. EPA, Cleveland, OH, 1975.
Foam Processing, Modern Plastic, October 1991.
The Identification of Effluents from Rubber Vulcanization, Stephen M.
Rappaport, University of North Carolina, Chapel Hill, Presented at the
Conference on Environmental Aspects of Chemical Use in Rubber Processing,
Akron, OH, 1975.
McGraw-Hill Encyclopedia of Science & Technology, 6th Edition, McGraw-Hill
Book Company, New York, NY, 1992.
Tire Materials and Construction, Kevin Jost, Automotive Engineering, October
1992.
Regulatory Profile
Federal Register: Standards of Performance for New Stationary Sources; Rubber
Tire Manufacturing Industry; Final Rule. 52 FR 34868, September 15,1987.
SIC Code 30
128
September 1995
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Sector Notebook Project
Rubber and Miscellaneous Plastics Products
Federal Register: Plastic Molding and Forming Point Source Category Effluent
Limitations Guidelines; Pretreatment Standards and New Source Performance
Standards; Final Regulation. 49 FR 49026, December 17,1984.
The Society of the Plastic Industry Issues, Volume V, No. 1-8, The Society of the
Plastic Industry, Washington, D.C., 1994.
Pollution Prevention
Environmental Fact Sheet - Plastic: The Facts About Production, Use, and
Disposal, U.S. EPA, Office of Solid Waste and Emergency Response, February
1990.
Environmental Fact Sheet - Plastic: The Facts on Source Reduction, U.S. EPA,
Office of Solid Waste and Emergency Response, February 1990.
Environmental Fact Sheet - The Facts on Degradable Plastic, U.S. EPA, Office of
Solid Waste and Emergency Response, February 1990.
Environmental Fact Sheet - The Facts on Recycling Plastic, U.S. EPA, Office of
Solid Waste and Emergency Response, February 1990.
Operation Clean Sweep, Only You Can Stop Resin Pellet Loss!, The Society of the
Plastic Industry, Washington, D.C.
Recent Experience in Encouraging the Use of Pollution Prevention in
Enforcement Settlements, Monica M Becker and Nicholas A Ashford,
Massachusetts Institute of Technology, Center for Technology, Policy, and
Industrial Development, Cambridge, MA, May 1992.
Scrap Tires: Alternative and Markets in the United States, Goodyear Tire and
Rubber Company, Akron, OH.
Scrap Tires for Fuel, an Energy Alternative, A.L. Eastman, Goodyear Tire and
Rubber Company, Presented at the Akron Rubber Fall Technical Symposium,
October 1991.
Scrap Tires - Understanding the Challenge, Goodyear Tire and Rubber Company,
Akron, OH, 1990.
A Study of the Use of Recycled Paving Material, Report to Congress, U.S.
Department of Transportation, Federal Highway Administration and U.S. EPA,
June 1993. (FHWA-RD-93-147; EPA 530/R-93/013).
September 1995
129
SIC Code 30
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Rubber and Miscellaneous Plastics Products
Sector Notebook Project
Summary of Markets for Scrap Tires, U.S. EPA, Office of Solid Waste and
Emergency Response, October 1991.
Title ffl Section 313, Release Reporting Guidance, Estimating Chemical Releases
From Rubber Production and Compounding, U.S. EPA, Office of Pesticides and
Toxic Substances, March 1992. (EPA 560/4-88/004q)
Waste Minimization Strategies for the Fabricated Rubber Products Industry,
Christopher Bozzini, Thomas O'Regan, Patrick Sheehan, and Catherine Walsh,
Prepared for the U.S. EPA, August 1992.
Contacts *
Organization
Telephone
David Chapman
Pat Toner
Maureen Healy
Greg Kennedy
Bob Larch
Hope Pillsbury
Sergio Saio
Judy Sophianopoulas
Steven Teslik
Dale Louda
Ernie Karger
Dave Salman
Goodyear Tire Company
Society of the Plastic Industry
Society of the Plastic Industry.
Tire Business (magazine)
Ohio EPA, Solid Waste
EPA, Solid Waste
NEIC
EPA, Region IV
American Plastic Council
Rubber Manufacturers Association
The Gates Rubber Company
EPA, Office of Air Quality Planning
and Standards
(216) 796-2121
(202) 371-5202
(202) 371-5200
(216) 836-9186
(614) 644-2734
(202) 260-2797
(303) 236-5124
(404) 347-7603
(202) 371-5357
(202) 682-4839
(303) 744-4935
(919) 541-0859
* Many of the contacts listed above have provided valuable background information and comments
during the development of this document. EPA appreciates this support and acknowledges that the
individuals listed do not necessarily endorse all statements made within this notebook.
SIC Code 30
130
September 1995
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APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
Web Browser to the following address:
http ://CS.inel.gOV/OeCa - then select "EPA Sector Notebooks"
Of after 1997, (when EPA plans to have completed a restructuring of its web site) set
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WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
Sectors and select the appropriate sector from the menu.
The Notebook will be listed.
HOTLINE NUMBER FOR E|WWW: 208-526-6956
EPA E$WWW MANAGERS: Louis Paley 202-564-2613
Myles Morse 202-260-3151
(This page updated June, 1997)
Appendix A
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