EPA-650/2-74-106
           OCTOBER 1974
Environmental protection Technology Series
ill!
:*:•:*:*:*:


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                               EPA-650/2-74-106
        SYSTEM  ANALYSIS
OF AIR POLLUTANT  EMISSIONS

             FROM THE

CHEMICAL/PLASTICS INDUSTRY

                   by
         Herbert Terry and Stephen Nagy
             Foster D. Snell, Inc.
                Hanover Road
         Florham Park, New Jersey 07932
            Contract No. 68-02-1068
            ROAP No. 21 AXM-060
           Program Element No. 1 ABO 15
       EPA Project Officer: Belur N. Murthy

           Control Systems Laboratory
       National Environmental Research Center
    Research Triangle Park, North Carolina 27711
                Prepared for

     OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
           WASHINGTON, D. C.  20460

                October 1974

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This report has been reviewed by the Environmental Protection
Agency and approved for publication.  Approval does not signify
that the contents necessarily reflect the views and policies of
the Agency, nor does mention of trade names or commercial
products constitute endorsement or recommendation for use.
                          11

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                                 ABSTRACT
       This system analysis of air pollution by the Chemical/Plastics Industry
(SIC 2821;  Plastic Materials and Synthetic Resins) defines producers, produc-
tion volume, forecasted growth rates, plant capacities, plant locations and the
average population density at each plant site. Major processes are described
in terms of equipment, reaction conditions, specific process chemicals used and
general air pollution controls.  A decision model, utilizing probabilities and
weighing techniques, was developed and assigned priority indices to the 14 gen-
eric groups of products in this SIC group from the viewpoint of emissions and
air pollution control. The model relates the interactions of such factors as total
population  exposed,  production volume, growth trends, emission, odor and haz-
ard potential of the most likely pollutants and identified polyurethanes, acrylics
and alkyds as the most likely candidates for in-depth study. Estimates of emissions
factors and a discussion of emission controls and their costs for these three products
is presented.  Similar information was developed for some high-volume plastic
materials:  polyethylene, polystyrene, polypropylene, nylon and poly vinyl chloride.
While a number of pollution control devices are used in this  industry, the majority
are associated with large volume resin manufacture and function primarily to  re-
cover product or heat values since in most instances the economics dictate against
installation of control devices for the sole purpose of pollution control.  Operating
costs for various controls are calculated.

      It is recommended that EPA study process modifications to reduce gaseous
air pollutant emissions from large air volume sources; evaluate the use of liquid
scrubber systems versus combustion based techniques; study air quality in the
vicinity of polyvinyl chloride plants in face of new evidence indicating that vinyl
chloride monomer may be more hazardous than hitherto believed; and refine the priority
decision model through computerization and continued updating.

       Information retrieval and analysis in this study was carried out from
March 1973 through March 1974.
                                  iii

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                        TABLE OF CONTENTS
ABSTRACT

SECTION I

SECTION II

SECTION IE

SECTION IV

SECTION V
SECTION V-A

SECTION V-B

SECTION V-C

SECTION V-D

SECTION V-E

SECTION V-F

SECTION V-G

SECTION V-H

SECTION V-I

SECTION V-J

SECTION V-K

SECTION V-L

SECTION V-M
FINDINGS AND CONCLUSIONS

RECOMMENDATIONS

INTRODUCTION

STUDY APPROACH

PROFILE OF THE CHEMICAL/PLASTICS
INDUSTRY REGARDING MARKET, PRODUCTION,
PLANT LOCATION AND POPULATION EXPOSURE
FACTORS

POLYETHYLENE AND COPOLYMERS

VINYL RESINS

STYRENE RESINS

POLYPROPYLENE

PHENOLIC AND OTHER TAR ACID RESINS

POLYESTERS

AMINO (U-F and M-F) RESINS

ALKYDS

ACRYLICS

COUMARONE-INDENE AND PETROLEUM RESINS

POLYURETHANES

CELLULOSICS

EPOXY RESINS
                                                         Page
1-1

H-l

III-l

IV-1

V-l
V-8

V-10

V-17

V-21

V-24

V-27

V-31

V-34

V-39

V-41

V-43

V-49

V-51
                              iv

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                       TABLE OF CONTENTS (continued)
SECTION V-N

SECTION V-O

SECTION VI



SECTION VI-A

SECTION VI-B

SECTION VI-C

SECTION VI-D

SECTION VI-E

SECTION VI-F

SECTION VI-G

SECTION VI-H

SECTION VI-I

SECTION VI-J

SECTION VI-K

SECTION VI-L

SECTION VI-M

SECTION VI-N

SECTION VH

SECTION VIH
POLYAMEDES

ROSIN MODIFICATIONS
Page

V-54

V-57
GENERAL PROFILE OF THE CHEMICAL/PLASTICS  VI-1
INDUSTRY REGARDING PROCESS TECHNOLOGY
AND AIR POLLUTANT EMISSIONS

POLYETHYLENE AND COPOLYMERS             VI-2

VINYL RESINS                              VI-9

STYRENE RESINS                            VI-19

POLYPROPYLENE                            VI-30

PHENOLIC AND OTHER TAR ACID RESINS        VI-33

POLYESTERS                               VI-39

AMINO (U-F and M-F) RESINS                 VI-42

ALKYDS                                    VI-48

ACRYLICS                                  VI-50

COUMARONE-INDENE AND PETROLEUM RESINS   VI- 52

POLYURETHANES                            VI-56

CELLULOSICS                               VI-61

EPOXY RESINS                              VI-66

POLYAMIDES                               VI-69

PRIORITY DECISION MODEL                   VH-1

IN-DEPTH STUDIES                          VDJ-1
SECTION VHI-A   POLYURETHANES
                                          vm-2

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                      TABLE OF CONTENTS  (continued)
SECTION Vin-B  ACRYLICS
SECTION VIH-C   ALKYDS

SECTION Vm-D


SECTION Vin-E


SECTION IX

APPENDICES

     APPENDIX 1

     APPENDIX 2


     APPENDIX 3


     APPENDIX 4
                                                        Page
                                        VIH-9
                                        vm-18
EMISSION QUANTIFICATION AND CONTROL      VIH-26
TECHNIQUES FOR SOME HIGH VOLUME PLASTICS

ECONOMICS OF TYPICAL EMISSION CONTROL    VHI-30
METHODS

REFERENCES                              IX-1
     ADDITIONAL PRODUCERS' LOCATIONS

     DEVELOPMENT OF EMISSION POTENTIAL
     INDICES

     HAZARD, ODOR AND PHYSICAL DATA ON
     PRINCIPAL POLYMER INDUSTRY CHEMICALS

     DEVELOPMENT OF HAZARD AND ODOR
     POTENTIAL INDICES
                               vi

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                         LIST OF EXHIBITS
EXHIBIT 1-1


EXHIBIT 1-2


EXHIBIT 1-3


EXHIBIT H-l

EXHIBIT V-l


EXHIBIT V-2


EXHIBIT V-3


EXHIBIT V-4


EXHIBIT V-A

EXHIBIT V-B1

EXHIBIT V-B2

EXHIBIT V-B3

EXHIBIT V-C

EXHIBIT V-D

EXHIBIT V-E

EXHIBIT V-F

EXHIBIT V-G
                                         Page

SUMMARY OF FACTORS IN THE PRIORITY       1-5
DECISION MODEL

RANKING OF PLASTICS SECTORS REGARDING    1-6
AIR POLLUTION SYSTEMS FACTORS

KEY FINDINGS FROM THE PRIORITY DECISION    1-7
MODEL

RECOMMENDED R6D PROJECT PLANS           II-4

TOTAL PLASTICS AND RESIN MATERIALS       V-3
PRODUCTION

PLASTIC AND RESIN MATERIALS PRODUCTION   V-4
1964 - 1972 and 1977

PLASTIC AND RESIN PRODUCTION RANKED IN    V-5
ORDER OF VOLUME

INDIVIDUAL RESINS AS PERCENT OF TOTAL     V-6
1972 PRODUCTION

PRODUCERS:  POLYETHYLENE                V-9

PRODUCERS:  POLYVINYL CHLORIDE           V-ll

PRODUCERS:  POLYVINYL ACETATE           V-14

PRODUCERS:  POLYVINYL ALCOHOL           V-l6

PRODUCERS:  STYRENE RESINS               V-19

PRODUCERS : POLYPROPYLENE               V-22

PRODUCERS:  PHENOLICS                    V-25

PRODUCERS:  POLYESTERS                   V-28

PRODUCERS : AMINO RESINS                 V-32
                              vii

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                         LIST OF EXHIBITS  (continued)
EXHIBIT V-H

EXHIBIT V-I

EXHIBIT V-J


EXHIBIT V-K1



EXHIBIT V-K2

EXHIBIT V-L

EXHIBIT V-M

EXHIBIT V-N

EXHIBIT V-O

EXHIBIT VI-A1


EXHIBIT VI-A2


EXHIBIT VI-A3


EXHIBIT VI-B1


EXHIBIT VI-B2


EXHIBIT VI-B3


EXHIBIT VI-B4
                                           Page

PRODUCERS: ALKYDS                        V-35

PRODUCERS: ACRYLICS                      V-40

PRODUCERS:  COUMARONE-INDENE AND         V-42
PETROLEUM RESINS

PRODUCTION OF POLYURETHANES FOR          V- 44
ADHESIVES,  COATINGS AND SEALANTS
MANUFACTURE (Resin; Compounded Basis)

PRODUCERS:  POLYURETHANES                V-46

PRODUCERS: CELLULOSICS                   V-50

PRODUCERS:  EPOXY RESINS                   V-52

PRODUCERS:  POLYAMIDE RESINS              V-55

PRODUCERS : ROSIN ESTERS AND ADDUCTS      V-58

FLOW SHEET:  LD POLYETHYLENE PRODUCTION   VI-3
(High Pressure Process)

FLOW SHEET:  HD POLYETHYLENE PRODUCTION   VI-5
(Phillips Solution and Slurry Processes)

FLOW SHEET:  HD POLYETHYLENE PRODUCTION   VI-7
(Ziegler Slurry Process)

FLOW SHEET:  POLYVINYL CHLORIDE            VI-10
PRODUCTION (Suspension Polymerization Process)
FLOW SHEET:  POLYVINYL CHLORIDE
PRODUCTION (Bulk Polymerization Process)
VI-12
FLOW SHEET:  POLYVINYL ACETATE           VI-13
PRODUCTION (Emulsion Polymerization Process)

FLOW SHEET:  POLYVINYL ACETATE           VI-14
PRODUCTION (Solution Polymerization Process)
                               Vlll

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                         LIST OF EXHIBITS (continued)
EXHIBIT VI-B5


EXHIBIT VI-B6


EXHIBIT VI-C1


EXHIBIT VI-C2



EXHIBIT VI-C3



EXHIBIT VI-C4


EXHIBIT VI-C5


EXHIBIT VI-C6

EXHIBIT VI-D


EXHIBIT VI-E1

EXHIBIT VI-E2

EXHIBIT VI-F

EXHIBIT VI-G1
FLOW SHEET:  POLYVINYL ACETATE
PRODUCTION (Bulk Polymerization Process)

FLOW SHEET:  POLYVINYL ALCOHOL
PRODUCTION
Page

VI-15


VI-17
FLOW SHEET:  CRYSTAL POLYSTYRENE         VI-20
PRODUCTION (Suspension Polymerization Process)

FLOW SHEET:  CRYSTAL POLYSTYRENE         VI-22
PRODUCTION (Continuous Solvent Polymerization
Process)

FLOW SHEET:  CRYSTAL POLYSTYRENE         VI-23
PRODUCTION (Continuous Bulk Polymerization
Process)
FLOW SHEET:  IMPACT POLYSTYRENE
PRODUCTION (Idealized Continuous Process)
VI-24
FLOW SHEET:  IMPACT POLYSTYRENE          VI-25
PRODUCTION (Suspension Polymerization Process)

FLOW SHEET:  ABS PRODUCTION              VI-27

FLOW SHEET:  POLYPROPYLENE PRODUCTION    VI-31
(Continuous Process)

FLOW SHEET:  PHENOLIC RESIN PRODUCTION    VI-34

FLOW SHEET:  PHENOLIC RESIN PRODUCTION    VI-36

FLOW SHEET:  POLYESTER RESIN PRODUCTION  VI-40

FLOW SHEET:  SOLID AMINO RESIN             VI-43
PRODUCTION
EXHIBIT VI-G2    FLOW SHEET: BUTYLATED MELAMINE RESIN    VI-45
                PRODUCTION
EXHIBIT VI-J     FLOW SHEET:  COUMARONE-INDENE AND
                HYDROCARBON RESIN PRODUCTION
                                          VI-53
                               ix

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                         LIST OF EXHIBITS  (continued)
EXHIBIT VI-K1
                                                          Page
SOME URETHANE COATING RESINS AS SUPPLIED  VI-57
BY THE PRODUCERS
EXHIBIT VI-K2    CLASSIFICATION OF URETHANE SURFACE
                COATINGS

EXHIBIT VI-L     FLOW SHEET:  THE MECHANICAL DIPPER
                PROCESS FOR NITRATING CELLULOSE

EXHIBIT VI-M     FLOW SHEET:  EPOXY RESIN PRODUCTION

EXHIBIT VI-N1    FLOW SHEET:  NYLON 6 PRODUCTION
EXHIBIT VI-N2
EXHIBIT VH-1
EXHIBIT VII-2
EXHIBIT VII-3
EXHD3IT VII-4
EXHIBIT VII-5
EXHIBIT VH-6
EXHIBIT Vn-7
EXHIBIT VD-8
EXHIBIT Vn-9
FLOW SHEET:  NYLON 66 PRODUCTION

SUMMARY OF FACTORS IN THE PRIORITY
DECISION MODEL

SELECTION OF PLASTICS SECTORS FOR
DETAILED STUDY

DEVELOPMENT OF THE PRODUCTION AND
POPULATION EXPOSURE RELATED INDEX

TOTAL POPULATION EXPOSURE MEASURE

THE POPULATION EXPOSURE POTENTIAL OF
THE AVERAGE PLANT

DECISION MATRIX FOR EMISSION POTENTIAL

TOTAL POTENTIAL EMISSION INDEX

HAZARD POTENTIAL INDEX

ODOR POTENTIAL INDEX
EXHIBIT Vin-Al   POLYURETHANE PREPOLYMER PROCESS FLOW
                SHEET

EXHIBIT VUI-A2   POLYURETHANE PREPOLYMER PROCESS FLOW
                SHEET
VI-58


VI-64


VI-67

VI-70

VI-72

VII-2


VII-3


VII-5


VH-7

VII-8


VII-11

VII-12

VII-19

VII-20

VIH-3


vm-4

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                         LIST OF EXHIBITS  (continued)
                                                          Page
EXHIBIT VIH-A3   EQUIPMENT FLOW SHEET FOR POLYURETHANE    VIII-6
                PREPOLYMER MANUFACTURE
EXHIBIT VIH-C1   ALKYD PROCESSING
VIII-20
EXHIBIT VIH-C2   SUMMARY OF EMISSIONS FROM AN ALKYD PLANT VIII-23
                PRODUCING 2.2-2.4 MILLION POUNDS OF ALKYD
                SOLIDS

EXHIBIT Vm-Dl   EMISSION CONTROLS REPORTEDLY USED BY    VHI-27
                POLYMER MANUFACTURERS

EXHIBIT VIH-D2   EMISSION FACTORS FOR SOME LARGE VOLUME   VID-29
                RESINS

EXHIBIT VIII-E1   REVIEW OF SPECIFIC PD2CES OF EQUIPMENT IN   VIH-32
                ACTUAL USE

EXHD3IT VIH-E2   CAPITAL COSTS OF BAG DUST COLLECTORS    VIH-36

EXHIBIT VIH-E3   CAPITAL COSTS OF JET SCRUBBERS           VIII-39

EXHIBIT VHI-E4   EMISSION CONTROL COSTS                   VHI-42
                              xi

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       SECTION I
FINDINGS AND CONCLUSIONS

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                                SECTION I
                       FINDINGS  AND CONCLUSIONS
      The basic function of the chemical/plastic industry (SIC 2821) is the manu-
facture of plastic materials, synthetic resins and nonvulcanizable elastomers.

1.    MARKET. PRODUCTION, PLANT LOCATION AND POPULATION  EXPOSURE
      RELATED FACTORS

      The general conclusions that follow are referenced to the information presented
in Section V, while specific findings are embodied in the Priority Decision Model
discussed under sub-section 3.

                 In the U .S., seven resin groups account for 90% of the
                 industry's production.
                 These are shown in the table below.
Resin

Polyethylene and copolymers
Vinyl resins
Styrene resins
Polypropylene
Phenolic and other tar acid  resins
Polyesters
Amino resins
                                   Percent of Production by Volume

                                              31.1%
                                              21.2
                                              18.3
                                               7.2
                                               5.8
                                               3.5
                                               3.5
Source:
Exhibit V-4
                 The growth rate of the overall industry volume will
                 be 12 - 15% through 1977 if the recent raw material
                 shortages do not persist in the long run.

                 In this study about 1,200 manufacturing operations were
                 identified. The number of plastic and resin producers
                 have increased by 700% since 1947.  The plants may
                 incorporate manufacturing of several  different plastic
                 materials and may also have diversified into the produc-
                 tion of raw materials or finished products.

                                   1-1

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                  Plants are relatively evenly distributed across the
                  country,  following the geographic pattern of the
                  national population. However, five states account
                  for about 50% of chemical/plastic operations in the
                  United States. These states are:

                        California
                        New Jersey
                        Illinois
                        Pennsylvania
                        Ohio
2.    GENERAL PROFILE REGARDING PROCESS TECHNOLOGY AND AIR
      POLLUTANT EMISSIONS

      The general conclusions that follow are referenced to the information pre-
sented in Section VI, while specific findings are embodied in the Priority Decision
Model discussed under sub-section 3.

                  The basic unit operation of the industry is poly-
                  merization.  The principal steps in process sequence
                  are listed below

                        receiving and storage of process chemicals
                         (monomers, etc.)

                        purification of monomers and solvents

                        prepolymerization

                        polymerization  (batch or continuous)

                              suspension
                              emulsion
                              bulk
                              solution

                        polymer separation (centrifugation,
                        drying, etc.)

                        compounding and final product handling
                                    1-2

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 The principal emissions produced in plastics and resin
-manufactijr,e3vary,.withiitheschemical.ispecie.s::that>ar;eiu"sed.
:!Th_e,.haizarjd/LQdqr jan^p^ysijcalf characteristics!
 chemicals show a wide variancse.. b&ypteafcemissipns
 be due to

       thej-reactantSjiCiBonomersOr
       solvents
       stabilizers
       reactipnraQtivatprs)
      icatalysts ;

 Typical normal emission iso.urcesiincludeJ

       monomer transfer*
       reactor ventingsacleaningi etc
       venting of holding tanks
      idryingi
      leaking sealscand^othere fugitivedossea

 Generally, emissions are at low heights without the
iusecpf-itall stacksLfon dilution? fForiithe^great majority of
.operatipnsjthelvolumes\ernittediare?relatively small since
materialithroug-hputs ar.e.vmodest.

Airuppllution.contr.ol-is 'generally,.characterized.as con-
.stijuting .fipaterialsir.eco^eriyi.- Eq.uipment^specifically
antendepafpr-airoppllutipnscontrolis-jmost.likely to be
found at largeriplants;n
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3.    PRIORITY DECISION MODEL

      The specific conclusions that follow are referenced to the systems analysis
factors assimilated in the Priority Decision Model presented in Section vn and
Sections V and VI discussed above.

      The Priority Decision Model was developed from standardized evaluation
and comparison of the major polymerization processes including such factors and
sub-factors as:

                  Total potential population exposed
                  Population exposure potential of the average plant
                  Plastic production volume
                  Production growth trend
                  Emission potential index
                  Hazard potential index
                  Odor potential index

      The model, depicted in Exhibits 1-1 and 1-2, was developed jointly with
EPA and features the factors discussed above. Major emphasis in this model is
directed to the hazard index.

                  The hazard potential is derived from published
                  occupational safety  and health threshold limit values
                  (TLV) of most likely air contaminants.

                  Market and production data provided the information to
                  estimate the total potential population exposed in terms
                  of each sector, taking into account the average plant, growth
                  trends and production volume .

                  Emission potentials were based  on process technology
                  assessment.

                  Odor potential was based on published odor threshold
                  data.

      Exhibit 1-3 summarizes key findings related  to the elements of the model.
                                    1-4

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                                                           EXHIBIT 1-1
                                                     Environmental Protection Agency
                                                     SUMMARY OF FACTORS IN THE
                                                     PRIORITY DECISION MODEL
Broad  Systems Analysis Factors For
Each Chemical/Plastics Industry Sector
A:
B:
C:
D:
Market and Production from
data in Section V
Emission Potential from
information in Section  VI

Hazard Potential from
information in Section  VI
Odor Potential from
information in Section VI
                                                                 Sub-Factor
                                         Sub-Factors             Weight
Aj=Total Potential        0.4
   Population Exposed
A =Population Exposure   0.2
   Potential of the
   Average Plant
A3=Plastic  Production     0.2
   Volume
A4=Production Growth    0.2
   Trend
Process Technology       1.0
Assessment

Toxicity (TLV) of         1.0
Principal Likely
Emissions

Odor Threshold of        1.0
Principal Likely
Emissions
                         Priority Decision Formula

             AC + BC + AD = R, where R is the overall  rating

      The formula has the following features:

                  The hazard factor,  C,  appears twice as a multiplicant and
                  is given significant emphasis , as required by EPA

                  The product of A x  C emphasizes situations where the hazard
                  potential is high and the potential population exposure is great

                  The product of B x  C emphasizes situations where hazard
                  potential and emission potential are high  and, therefore, the
                  relative magnitude  of potential concentrations of hazardous
                  substances at receptor locations are factored in qualitatively

                  The product of A x  D emphasizes the relative magnitude of the
                  potential nuisance to the population from  odorous substances
Source:     Snell (and EPA and Snell in development of priority decision formula)
                                   1-5

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                                                                                        EXHIBIT 1-2
                                                                                   Environmental Protection Agency
                                                                                   RANKING OF PLASTICS SECTORS
                                                                                   REGARDING AIR POLLUTION
                                                                                   SYSTEMS FACTORS
                     Selection formula:
                                       AC + BC + AD = R
                                             B
i
O9
      Plastic

Vinyl Resins
Styrene Resins
Acrylics
Alkyds
Polyurethanes
Phenolic and Other Tar
      Acid Resins
Polyethylene and
      Copolymers
Polyesters
Amino Resins
Cellulosics
Polyamides
Polypropylene
Coumarone-Indene and
      Petroleum Resins
Epoxy Resins
Production 5
Population
Exposure
Related Index
Number
10.0
8.5
8.5
8.0
8.0

Emission
Potential
Index
Number
7.0
7.4
5.0
4.8
2.6

Hazard
Index
Number
4.0(1)
2.8
4.5
6.6
9.3

Odor
Index
Number
2.3
7.4
9.0
5.0
7.7

Overall
Selection
Index
Number
91.0
107.4
137.3
124.5
160.2

Priority
Order
8
6
2
3
1
                              7.5

                              6.5
                              6.5
                              6.5
                              6.0
                              5.5
                              5.0

                              5.0
                              3.5
4.0

8.0
4.8
5.3
6.7
7.0
8.8

7.1
4.2
5.2

1.3
6.6
4.8
3.5
1.2
1.7

4.2
5.4
6.9

2.5
5.3
6.8
4.3
1.5
1.9

7.7
4.1
111.6
35.2
109.1
100.8
70.3
23.3
33.0
89.3
56.0
12
5
7
10
14
13
9
11
    U)Based on 50 ppm TLV for vinyl chloride
    Source:
           Snell

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                                                                                                                 -EXHIBIT 1-3
                                                                                                            Environmental Protection Agency
                                                                                                           KEY FINDINGS FROM THE PRIORITY
                                                                                                                  DECISION MODEL
Production and Population Exposure

       In terms of total potential population
       exposed alkyds,  polyurethanes, acrylics.
       amino resins and phenolic and other tar
       acid resins are most significant.  This is
       because there are numerous establish-
       ments engaged in the manufacture of
       these products,  and are often located in
       populated areas.

       The  population exposure potential of the
       average plant is highest for cellulosics,
       where establishments are located in high
       population density areas.  This index is
       then most significant for alkyds as well
       as coumarone-indene and petroleum resins.

       Plastic production volume is highest for
       polyethylene and copolymers. vinyl resins,
       styrene resins,  and polypropylene.   These
       account for approximately 78 percent of
       total annual production volume. The next
       four  highest volume plastics and resins are
       phenolic and other tar acid resins,  poly-
       esters, amino resins, and alkyds account-
       ing for only  approximately 16 percent.

       The  highest volume resins also exhibit
       the most significant production growth
       trend. Acrylics are also characterized by
       rapid potential growth.
Emission Potential

    The manufacture of the largest
    volume products has the highest
    emission potential both in terms
    of process complexity and possible
    emission quantity at individual plant
    sites.  These products include poly-
    ethylene and copolymers, vinyl
    resins, styrene resins and polypropylene.

    Polyurethanes production, excluding
    foam manufacture, which is not con-
    sidered part of the chemical/plastics
    industry, has the lowest emission
    potential.  Reasons include process
    simplicity and use of almost closed
    systems.
Hazard Potential

   The hazard potential of the
   principal chemical species
   in manufacture is overwhelm-
   ingly highest for polyurethanes
   because of the use of isocya-
   nates.

   The next important categories
   in this regard  are alkyds and
   polyesters.

   The hazard index assigned to
   vinyl resins is 4.0 versus 9.3
   for polyurethanes based,  in
   part, on the use of a TLV of
   50 ppm for vinyl chloride
   versus 0.02 ppm for toluene
   diisocyanate,  respectively.
   However, in the jight of
   recent evidence* Blinking
   polyvinyl chloride (PVC)
   operations to cancer deaths,
   this index may have to be
   revised upward as new ex-
   posure standards are set.
Odor Potential

.  The odor potential of
   the principal chemical
   species is overwhelm-
   ingly highest for acrylics.

.  The next important
   categories in this regard
   are coumarone-indene
   and petroleum resins,
   polyurethanes and
   styrene resins.
       Source;  Snell

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       The system-, analysis of air emission in the chemical/plastics industry
 identified polyurethanes, acrylics, and alkyds as the prime candidates for in-depth
 study. However,  it is possible that in the wake of the emerging concern with the
 hazards associated with PVC, the hazard index associated with vinyl resins will
 have to be raised from 4.0, for example, to 9.0. Then, vinyl resins will become
 of highest priority concern from a systems viewpoint of air pollution control.
 4.    IN-DEPTH STUDIES

      The specific conclusions that follow are referenced to the information presented
 in Section VIII, dealing with

                  Emissions and their controls from the manufacture of
                  polyurethanes, acrylics and alkyds as well as other
                  selected high volume resins.

                  Emission control technology and costs.

      The in-depth evaluations confirm the low emission potential index assigned
 to polyurethanes manufacture  (excluding foams). Although the hazard index is
 high, emission factors are low - of the order of 3 x 10~7 Ibs isocyanates per Ib of
 prepolymer.  Effective control technology exists and is believed to be practiced.

      Conventional scrubbing techniques can reduce appreciably the total emissions
 from acrylic facilities but not easily eliminate odor nuisance.
                  From a solution polymerization process acrylic ester
                  emissions could be of the order of 1 x 10~3 Ibs per
                  Ib of product, while this could be 3 x 10~3 for solvent.

                  From an emulsion process emission of both acrylic
                  monomers and vinyl acetate could be of the order of
                  1 x 10~3 Ibs per Ib of product, respectively.

                  From a suspension process acrylic monomers emission
                  could be of the order of 5 x 10~4 Ibs per Ib of product.

      The principal emission problem with the manufacture of alkyds is solvents.
Total emissions can be of the order of 0.01 Ibs per Ib of product.
                                       1-8

-------
      The in-depth studies also provide specific emission factor data for high
volume  resins and control cost data for representative emission control  devices.

      The table below summarizes operating  cost data for representative control
techniques.
                                                Annual Operating Cost
Emission Control Device                         Per CFM of Capacity

Bag Filters                                          $0.30 - 0.501

Compression/Refrigeration                            $3.00 - 6.00

Scrubbers                                            $0.40 - 0.601

Flares                                               $0.10 - 0.202

Regenerative Adsorption                              $2.00 - 6.003


1.    Neglecting the value of recovered product.

2.    Assumes no heating value for the stream itself, but does
      include supplying the  necessary air in case of an essen-
      tially inert gas stream.

3.    Excludes values of recovered material and assumes  a
      0.05  - 0.3% by weight concentration of absorbate.  Also
      excludes the cost of a pretreatment of the gas stream.
Source:    Section Vin
                                    1-9

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5.    OVERALL CONCLUSIONS

      The study indicates that plastics industry sources of air pollution which
require control technology development are:

            Monomer emissions, particularly of materials of hitherto
            unrecognized toxicity, e.g.,  vinyl chloride;

            Solvent emissions, both from  solution polymerization and
            alkyd manufacture.

      Currently, flaring, bag filtration and scrubbing are the most economical
techniques available for control, as compared to regenerative adsorption and
compression/refrigeration which are up to ten times as costly to operate. The
basic problem with all of these techniques, however, is that none currently ad-
dresses in a satisfactory manner the control of potentially significant absolute
quantities of air pollutants when dispersed in large volumes of vehicular air,
for example, from drying operations and general plant ventilation.  Process
development and improvements probably represent a better approach to min-
imizing emissions at low concentration in large air volumes than development
of effluent cleanup techniques specifically addressing this problem.
      The section that follows deals with recommendations.
                                   1-10

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   SECTION H
RECOMMENDATIONS

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                          SECTION II
                     RECOMMENDATIONS
      Recommendations based upon the system  analysis of air pollutant
emissions fall into two categories

                 engineering and scientific investigations

                 further system  analyses

      The discussion below details each recommendation, while Exhibit
II-l provides R&D project plans.


1.    STUDY PROCESS MODIFICATIONS TO REDUCE GASEOUS AIR
      EQLLUTANT EMISSIONS FROM LARGE AIR VOLUME SOURCES

                 Large air volume sources include dryers and
                 ventilation systems.

                 The removal of low concentration gaseous
                 emittants (mostly hydrocarbons) from dryer
                 exhausts can represent a major economic and
                 engineering undertaking because of the large
                 volumes of air utilized, if removal is to be
                 affected after drying.

                 It is recommended that various techniques of
                 stripping monomers and other potential gaseous
                 emittants be examined in-depth before the dry-
                 ing step.

                 For example, in the polyvinyl chloride industry
                 steam stripping is being studied.

                 In regard to ventilation, it is recommended that
                 combining of vents and ventilation exhausts into
                 a limited number of controlled emission points be
                 studied.
                            II-l

-------
                  Engineering studies with extensive industry con-
                  tacts and minimum dependence on literature
                  review are envisioned.
2.    EVALUATE IN-DEETH THE USE OF LIQUID SCRUBBER SYSTEMS
      FOR EMISSION CONTROL vs. COMBUSTION BASED SYSTEMS

      Combustion type pollution control systems usually require fuel
enrichment to sustain combustion. With the present and continuing energy
crisis, fuels will remain short and scrubbing will conserve this commodity.
It may also provide recycling opportunities rather than destruction of valu-
able raw materials.

                 Conduct a technical and economic evaluation of
                 various liquid (water and oil) scrubbers and packed
                 columns for removing organic contaminants from air
                 streams.

                 Compare the cost and effectiveness of scrubber sys-
                 tems with thermal decomposition methods.
3.    STUDY THE IMPACT OF AIR QUALITY IN THE VICINITY OF
      POLYVINYL CHLORIDE PLANTS

      In light of recent evidence linking poly vinyl chloride operations to
cancer deaths, measurements of atmospheric contaminants in the proximity
of producing plants should be made and used as a basis for the evaluation
of health effects on exposed populations and to set subsequent emission
standards.

                  Dispersion models of 8-10 sites under conser-
                  vative meteorological assumptions should be
                  made.

                  Ambient modeling of 8-10 residential and/or
                  residential zones near plants.
                               II-2

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4.    REFINE THE PRIORITY DECISION MODEL FOR THE CHEMICAL/PLASTICS
      INDUSTRY THROUGH COMPUTERIZATION AND CONTINUING INFORMATION
      RETRIEVAL
                 The Priority Decision Model of Section VII provides
                 a systematic framework for considering basic tech-
                 nical as well as economic factors related to air
                 pollution control at the industry level.

                 It is recommended that the model be adapted to
                 computerization.

                 It is further recommended that a continuing infor-
                 mation retrieval program be maintained focusing
                 upon

                       updating information related to the
                       economic structure of the industry
                       (production, market and population
                       exposure data, etc.)

                       continuing study of the hazard poten-
                       tial of the chemicals used

                       continuing compilation of emission
                       factors as a function of changing tech-
                       nology,  improved emission controls
                       and data availability
The next section introduces the details of the study.
                              II-3

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                                                                                                                             Exhibit II-1 (1)
                                                                                                                      Environmental Protection Agency
                                                                                                                      RECOMMENDED R&D PROJECT PLANS
        Project Name

        Control of Emissions From
        Large Air Volume Sources
r
        Evaluation of liquid Scrubber
        vs. Combustion Based
        Approaches
Project Definition

. Dryers and ventilation
   systems can represent
   large air volume sources
   with low concentrations
   of emittants
. Stripping of emittants
   before drying is to be
   studied
. Use of combined ventil-
   ation and other exhaust
   system is to be studied
   with centralized air
   pollution control
. Industry contacts are  to
   be emphasized

. Comparison of cost and
   effectiveness of scrubber
   systems versus thermal
   decomposition methods
Expected Deliverable(s)

. Conceptual design and
  cost estimates
. Recommended pilot plant
  scale work
Time Frame   Man-Years     Principle Skills Needed

    1            1          Experience in Polymer
                            Plant Design

                            Process Engineering
                            Drying
                            Ventilation
  Technical and economic       3 months  1/4
  evaluation of various liquid
  (water and oil) scrubbers for
  removing organic contaminants
  from air streams.
  Estimation of cost effectiveness
  for recovering selected materials
  for recycle purposes.
  Literature review is to be the
  study approach
                            Process Engineering
                            Air Pollution Control

-------
                                                                                                                              EXHIBIT II-l  (2)
H
en
       Project Name

       Study the Impact of Air
       Quality in the Vicinity of
       Polyvinyl Chloride Plants
       and Detailed Engineering
       Study Regarding Emissions
Priority
Project Definition
Expected Deliverable(s)
Time Frame   Man-Years    Principle Skills Needed
       Computerization of Priority
       Decision Model and Continuing
       Refinement
              .  In light of recent evidence .
                 possibly linking polyvinyl
                 operations to cancer deaths
                 in production plants, pollu-.
                 tant concentrations in the
                 atmosphere to which popu-
                 lation is exposed should be .
                 quantified and  used as a
                 basis to evaluate health
                 effects.
              .  Perform detailed engineer-
                 ing study regarding extent
                 of emission, status of con-
                 trols and possible future
                 controls.
              Same as Project Name
                               Dispersion model of 8-10
                               sites under conservative
                               meteorological assumptions
                               Ambient monitoring of 8-10
                               residential or populated
                               zones near these plants
                               Emission profiles
                               Control technology assess-
                               ment
                               Computer based model
                               Continuing information
                               retrieval regarding
                               -  hazard aspects
                               -  emission profiles
                               -  controls
                               -  industry structure
                                1 year
                                5 years    1 /3 per year
                            Meteorology
                            Air Pollution Chemistry
                            PVC Production
                            Process Engineering
                            Air Pollution Control
                             Systems Analysis
                             Computer Science
                             Engineering Knowledge of
                              Industry
                             Air Pollution Control
                              Engineering
       Source:  Snell

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  SECTION ni
INTRODUCTION

-------
                         SECTION m
                      INTRODUCTION
      The increase in public awareness of the need to prevent and control
air pollution resulted in the passage by Congress of the Clean Air Act of
1970. Under the provisions of Section 103 of the Act,  the Environmental
Protection Agency (EPA) is required to conduct and promote the coordina-
tion and acceleration of research,  investigations, experiments, training,
demonstrations, surveys. and  studies relating to the causes, effects, ex-
tent, prevention and control of air pollution.

      In pursuance of these mandates, EPA awarded Contract No. 68-02-
1068 to Foster D. Snell,  Inc. (Snell) to undertake a System  Analysis of
Air Pollutant Emissions in the Chemical/Plastics Industry. The study was
originally intended to deal with odors from the manufacture of plastic materials,
synthetic resins and non-vulcanizable elastomers (SIC 2821) .  By EPA
request, the study emphasis was shifted to general air pollutant emissions
with attention to the hazard potential of likely emittants.

      There are hundreds of products classified in SIC 2821. However,
over 97% of these can be categorized within 15 principal generic groups.

                  Polyethylene and Copolymers
                  Vinyl Resins
                  Styrene Resins
                  Polypropylene
                  Phenolic and Other Tar Acid Resins
                  Polyesters
                  Amino Resins
                  Alkyds
                  Acrylics
                  Coumarone-Indene and Petroleum Resins
                  Polyur ethanes
                  Cellulosics
                  Epoxy Resins
                  Polyamides
                  Rosin Modifications
                             III-l

-------
      In Sections  V and VI,  these are broadly defined in regard to market,
production, plant location,  process and potential emission characteristics,
etc.  Using a weighting procedure,  jointly developed with EPA, these data
are incorporated into a "priority decision model" to rank each group in
a priority order.  This system model is presented in Section VII.

      The priority plastics and resins are discussed further in Section VIII.
These include polyurethanes, acrylics and alkyds.  In depth consideration is
also given,  in that section ,  to emission characterization and controls from
the manufacture of polyvinyl chloride,  polypropylene,  polystyrene, nylon
and polyethylene.  General control technology and costs are also treated in
Section  VIII.

      Recommendations from the system  analysis appear in  Section II and
deal with both technical steps,  as well as  proposed means of developing further
characterization of emissions,  since the literature as well as the sources con-
tacted generally lacked this  type of information.
                               III-2

-------
   SECTION IV
STUDY APPROACH

-------
                            SECTION IV
                        STUDY APPROACH
      The study undertaken by Snell is titled System Analysis of Air Pollutant
Emissions from the Chemical/Plastics Industry.  • The study was originally
intended to deal with odors from the manufacture of plastic materials,
synthetic resins and non-vulcanizable elastomers.  By EPA request,
the study emphasis was shifted to general air emissions, with attention
to the hazard potential of the likely chemical species  in these emissions.

      The principal system  analysis  steps included

          •     definition of the  industry in terms of  production volumes
                and trends by  major product,  plant capacities and loca-
                tions and average population densities at each plant site
                (Section V).

          •     definition of the  major processes of the  industry in terms
                of equipment,  reaction conditions,  specific process chemi-
                cals and quantities, products, emission points, likely
                emittants  and  general controls (Section VI).

          •     development of a "priority decision model" to select
                industry sectors for further study and to segment the
                industry in a possible priority order  for further EPA
                actions; decision factors include  market and production
                configuration by major product (total potential population
                exposed, population exposure  potential of the average
                plant, plastic  production volume, production growth
                trend), emission potential of the  manufacture of each
                major product; and hazard potential as well as odor
                potential of emittants  (Section VII).

          •     in-depth study of priority sectors and description of
                general emission control methods and costs (Section
                VIII).

          •     development of research and development recommenda-
                tions (Section  II).

      These  work steps were completed during the period from  March 1973
through March 1974.
                                 IV-1

-------
      The work scope required that primary means of generating the required
information be literature review.  This was comprehensive and included a search
by EPA's Air Pollution Technical Information Center.  The list that follows pro-
vides examples of other sources searched:

             •      Chemical Abstracts,  1967 - most recent
             •      Air Pollution Abstracts, Vol. 1  - most recent
             •      Environment Information Access, Jan.  1972 - most recent
             •      Government Reports Index,
             •      Odors and Air Pollution:  A Bibliography with
                       Abstracts, EPA AP-113
             •      Environment Science  and Technology, 1969  - present
             •      Pollution Engineering,  1971 - present
             •      Archives of Environment Health, 1967 - June 1970
             •      Journal of the Air Pollution Control Association,
                       1967 - present
             •      Plastics Technology,  1969 -  present
             •      Card Catalog of the Snell collection, of the Engineering
                       Societies  Library, and of the Chemists' Club

      Either letters of inquiry were sent to or phone interviews were conducted
with a limited number (less than 10)of design engineering firms  and states with a
high concentration of plastics producers.  Through the cooperation of the Manu-
facturing Chemists Association, a symposium-sty led meeting was held with
major producers interested in polyurethanes and acrylics.   Four of these  con-
tacts submitted confidential detailed data.  Both the literature and these contacts
were useful sources of general information, but only limited data was obtained
on the quantified characterization of emissions.

      It is noted,  particularly regarding emission data in this report, that
results  are not based upon statistically sufficient surveys and serve only as
case illustrations.

      We are grateful for the technical guidance of Dr. Belur Murthy, Project
Officer. Particularly thorough inputs were provided by the  following industry
sources and their contribution is appreciated:

             •      Or. Kenneth D. Johnson of the Manufacturing
                       Chemists Association
             •      The DuPont Corporation
             •      The Union Carbide Corporation
             •      The Mobay Chemicals Corporation
             •      Rohm and Haas Company
             •      Blaw-Knox Chemical Plants, Incorporated
             •      Crawford & Russell,  Incorporated
                                  IV-2

-------
                    SECTION V

PROFILE OF THE CHEMICAL/PLASTICS INDUSTRY REGARDING MARKET,
PRODUCTION, PLANT LOCATION AND POPULATION EXPOSURE FACTORS

-------
                         SECTION V
PROFILE OF THE CHEMICAL/PLASTICS INDUSTRY REGARDING MARKET.
PRODUCTION. PLANT LOCATION AMD POPULATION EXPOSURE FACTORS

      The work of this section was completed during mid-1973.
      Plastics and resin materials can be classified broadly into two categor-
ies:  (1) thermosets and (2) thermoplastics. Thermosets are materials which
solidify or set on heating and cannot be remelted or reshaped once they have
been fully cured. Thermoplastic resins  can be softened by heat and regain
their original properties upon cooling.

      Further, these resins are divided into some 15 generic groups, within
the above two categories, members of each generic group having similar chem-
ical structure.

      There are literally hundreds of plastics and resin materials produced
in the United States. More than 97% of these can be categorized within the
15 principal generic groups. The remainder are either unique in structure
or are produced in such low volume or by only a few producers,  that they
are not reported in order to keep company production data confidential.
1.    OVER THE YEARS THE NUMBER OF COMPANIES PRODUCING
      PLASTICS AND RESIN MATERIALS HAS BEEN INCREASING

      (1)    The Number Of Producers Has Increased By About 700%
            Since 1947

            According to the 1967 Census of Manufacturers, the number of
      producers has increased from 97 in 1947 to 391 in 1963 and an estimated
      500 in 1967 and probably close to 650 in 1972.

      (2)    Producer's Specialization  Ratio Has Decreased

            The Specialization Ratio indicates the proportion of product
      shipments (both primary and secondary) of the industry represented
      by the primary products - in this case, plastics and resin materials.
      The Specialization Ratio has decreased steadily from 92% in 1947 to
      83% in 1967 indicating that producers are diversifying and possibly
      integrating either backward or forward into raw material production
      or fabricated products.
                            V-l

-------
      (3)  -  Establishment Size Has Decreased

            There were more plants employing less than 20 employees in
      1967 than in previous years. In 1947, only 36% of existing establish-
      ments had less than 20 employees. But, by 1967, 49% of the plants
      had less than this number of production workers.  Companies are,
      therefore, probably localizing production to service nearby markets.
2.    GROWTH OF SYNTHETIC RESIN PRODUCTION HAS  BEEN STEADY

      Production of synthetic resins for the period 1967-1972 and forecasted
for 1977 is shown in Exhibits V-l and V-2.

      (1)    Both Thermosets and Thermoplastics Production Have Grown

            Thermoset resin production has increased from 3.1 billion pounds
      in 1967 to 4.1 billion pounds in 1972, a compounded annual increase
      of 5.6% per year.

            Thermoplastics production increased from 10.7 billion pounds
      in 1967 to 20.4 billion pounds in 1972, a compounded annual increase
      of 13.8% per year.

      (2)    Thermoplastics Comprised  83%  Of All Synthetic Resins Produced
            In 1972

            Thermoplastics are expected to increase their share of resin
      production by 1977 and at that time account for about 85% of the total
      produced.

      (3)    Seven Resins Account For  90%  Of Production

            Exhibits V-3 and V-4 show  the resin groups ranked in order
      of descending production volume, and as can be seen, the following
      seven products make up the bulk of production .

                 A  -  Polyethylene and copolymers
                 B  -  Vinyl resins
                 C  -  Styrene resins
                 D  -  Polypropylene
                 E  -  Phenolic and other  tar acid resins
                 F  -  Polyesters
                 G  -  Amino resins
                              V-2

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                                                                                      EXHIBIT V  -  1
 i
u
                                       1967
      Alkyds                            638
      Polyesters                         513
      Epoxy Resins                      135
      Phenolic  and Other Tar Acid Resins 983
      Polyurethane                       89
      AminO Resins                      690
      Other                           	46
                         Total        3,094
                                                                         Environmental Protection Agency

                                                                      TOTAL PLASTICS AND RESIN MATERIALS
                                                                   PRODUCTION  (million pounds per year) (1,2,3,4)
                                                                           Thennosets
                                                                                   Estimated
1968
692
615
158
1,097
71
816
27
3,476
1969
674
688
166
1,181
81
816
27
3,633
1970
636
569
165
1,186
95
746
92
3.489
1971
580
730
169
1,194
79
746
92
3,590
1972
695
862
174
1.413
116
804
-
4,064
1977
750
1,900
200
2,230
177
1.100
-
6,377
      Acrylics
      Cellulosics
      Poly amides
      Coumarone-Indene and
         Petroleum Hydrocarbons
      Polyethylene and Copolymers
      Rosin Modifications
      Polypropylene
      Styrene Resins
      Vinyl Resins
      Other
                           Total
Thermoplastics
-
171
63
284
3,799
134
662
2,391
2,671
520
-
187
88
349
4,568
86
878
2,896
3,216
606
-
193
92
357
5,490
86
1,090
3,343
3,686
676
538
182
91
283
5,844
87
1,031
3,550
3,756
324
590
174
100
264
6,381
87
1.288
3,748
4,076
-
660
190
115
325
7,624
95
1,755
4,479
5,186
-
1,350
200
175
325
15,300
90
3,500
9,000
8,300
-
               10,695
12,874
15,013
15,686
 16,708
20,429
38,240
      All Resins:
Grand Total    13,789
16,350
18,646
19,175
20,298
24,493
44,617

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                                                                                EXHIBIT V-2
                                                                         Environmental, Protection Agency
                                                             PLASTIC AND RESIN MATERIALS PRODUCTION
                                                                   1964 - 1972 and 1977  (Projected)
                            • ••  • ,  i
                       ._;:_:J:      ..  iiLLti
                lift; :: 'M?r  ' •"
                                                                        ••
                                                                  ffl

                                               --.    i-
                                         ;'!  '!      :
  |
        LH  ;H:i
    L;   , :  .  ...J!.. .,:-,;
    .,.;^,-, ,..^i—L ^j—Lj 4 ... -I- -
   ..-.
-------
                                                   EXHIBIT V - 3

                                             Environmental Protection Agency

                                              PLASTIC AND RESIN PRODUCTION
                                               RANKED IN ORDER OF VOLUME
Resin

Polyethylene and Copolymers
Vinyl Resins
Styrene Resins
Polypropylene
Phenolic and  Other Tar Acid Resins
Polyesters
Amino Resins
Alkyds
Acrylics
Coumarone-Indene and
  Petroleum Resins
Cellulosics
Epoxy Resins
Polyurethanes
Polyamides (Nylon)
Rosin Modifications
Other

                       Total      19,175
Production
1970
5,844
3,756
3,550
1,031
1.186
569
746
636
538
283
182
165
95
91
87
416
(million
1971
6,381
4,076
3,748
1,288
1,194
730
804
580
590
265
174
169
79
100
87
-
pounds)
1972
7,624
5,186
4 ,'479
1,755
1,413
862
851
695
660
325
190
174
116
115
95
-
20,298
24,493
Source:  Exhibit V-l
                              V-5

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                                                EXHIBIT V  - 4

                                      Environmental Protection Agency

                                    INDIVIDUAL RESINS AS  PERCENT OF
                                        TOTAL 1972  PRODUCTION
                                            Percent of      Accumulated
Resin                                     Total Production      Percent
Polyethylene and Copolymers                    31.1              31.1
Vinyl Resins                                   21.2              52.3
Styrene Resins                                 18.3              70.6
Polypropylene                                   7.2              77.8
Phenolic and Other Tar Acid Resins              5.8              83.6
Polyesters                                       3.5              87.1
Amino Resins                                    3.5              90.6
Alkyds                                          2.8              93.4
Acrylics                                        2.7              96.1
Coumarone-Indene and                           1.3              97.4
   Petroleum Resins
CeUulosics                                      0.8              98.2
Epoxy Resins                                    0-7              98.9
Polyurethanes                                   0.5              99.4
Polyamides                                      0.5              99.9
Rosin Modifications                              0.4
Other
                                  Total        100.3*            100.3*


*Does not add to 100.0% because of rounding errors.


Source:  Exhibit V-3 and Snell estimates
                              V-6

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      (4)    Raw_"MateriaL§ujppltes Are Coming Under Pressure

            Many 'of tfre 'laxges't volume resins are based on petroleum,
      and shortages 'will 'develop rars 'evi'denced toy .the present energy
      crisis-. For %xample>, 'benzerTe is presently in 'critical -supply ;and
      it is \Ke starting 'material for .rstyrene plastics.

            le"om'petitioh for 'p'etroleum., ''as an 'energy source, vwi'H jprob.ably
      cause some •sKbftage's ca!lso.

      (:5)    fB'.y-'l97.7L:itJ8_ExRectecl -That  Production COf /fill :Plastics iWjill
            ''Reabh.i4.4 .'.6jBillib~n Pounds

            Production'wiiLprbbably increased the rate'of. 12.:7% through
      1972-1977.
3.    ADDITIONAL PLANT CAPACITIES WILL BE REQUIRED FOR ALMOST
      ALL RESINS'PRODUCED/AFTER 1974

      (1)    Most Producers Of Major Plastics Are Installing Additional
            Capacity

            Major producers of large volume resins are already installing
      additional capacity, but this will not be sufficient to meet needs much
      beyond 1977.  This assumes that feedstocks will be available.

      (2)    Present  Facilities Will Probably Be Enlarged

            The large volume resins are being made at or close to a
      source of raw materials.

            Petroleum refineries and crackers will probably remain located
      at'locations close to' ports or near pipe lines.
                               V-7

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            V-A  POLYETHYLENE AND COPOLYMERS
      Polyethylene (PE) resins are themoplastics containing, predominantly,
repeating ethylene groups.  The molecular weights of the PE resins varies over
a wide range, from wax-like materials of relatively low molecular weight
(10,000 - 25,000) to rigid and tough plastics of ultra-high molecular weight
(2,000,000 - 4,000,000) with densitites ranging from 0.91-0.93 (low to medium)
and 0.94-0.97  (high).
1.    POLYETHYLENE IS THE LARGEST PRODUCED POLYMER

      Domestic production of PE increased from 3.8 billion pounds in 1967
to 7.6 billion pounds in 1972, a compounded growth rate of 14.9% per year.
In 1972, however, production increased 19.5% over the previous year.
Yearly production for the period 1967-1972 is shown in Exhibit V-l.

            PE Consumption Will Continue  To Grow At Above Normal
            Growth Rate

            Increasing use in packaging, molding, and construction should
      provide a growth of about 15% per year over the near term.
2.    THERE ARE 18 PRODUCERS OF POLYETHYLENE

      The 18 producers operate 25 plants.  Exhibit V-A lists the locations
and plant capacities of the producers.

      (1)   PE Production Is Concentrated In Two States

            The Gulf Coast area, more specifically the states of Texas and
      Louisiana, produces over 80% of the PE at 20 plant locations.  The
      reason for this heavy concentration is that the raw material (ethylene)
      is produced in this area.  The remaining 4 plants are located rela-
      tively close to consumers.

      (2)   Plant Capacities Vary Widely

            Plant capacities range from a high of 1.2 billion pounds per
      year to as small as 100 million pounds per year or less.  The tendency
      is  to enlarge existing facilities, rather than build new grass  roots plants,
                              V-8

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                                                                   EXHIBIT V-A

                                                     Environmental Protection Agency
                                                     PRODUCERS:   POLYETHYLENE (4.5)
                                                     Estimated Capacity (1975)
Producer and Location                          .  High Density                Low Density
                                              (million pounds)           (million pounds)

Allied Chemical Corp.
  Baton Rouge,  La.                                  225
Amoco Chemicals Corp.
  Alvin, Tex.                                      100
Celanese Corp.
  Pasadena, Tex.                                    375
Chemplex Co.
  Clinton,  Iowa                                    125                       310
Cities Service Co.
  Lake Charles, La.                                                            220
The Dow Chemical Co.
  Freeport, Tex.                                    100                       300
  Plaquemine, La.                                  225                       500
E. I.  Du Pont de Nemours & Co., Inc.
  Orange, Tex.                                     200                       520
  Victoria. Tex.                                                              150
Eastman Kodak Co.
  Longview, Tex.                                                             250
Exxon Chemical Co.
  Baton Rouge,  La.                                                            400
Gulf Oil Corp.
  Orange, Tex.                                     150                       500
  Cedar Bayou, Tex.                                                           200
Monsanto Co.
  Texas City, Tex.                                  180
National Distillers and Chemical Corp.
  Deer Park,  Tex.                                                             300
  Tuscola, m.                                                                150
National Petro Chemicals Corp.
  La Porte, Tex.                                    270
Northern Petrochemical Co.
  Joliet. HI.                                                                  500
Phillips Petroleum Co.
  Pasadena. Tex.                                    250                        94
Rexene Polymers Co'.
  El Paso. Tex.                                                               310
Sinclair-Koppers Co.
  Port Arthur, Tex.                                  200                       100
Union Carbide Corp.
  Seadrift, Tex.                                    400                       750
  Texas City,' Tex.                                                            225
  Torrence, Calif.                                                            120
  Whiting, Ind.                                  	                       240
                                 Total          2,800                      6,139

                                         V-9
Total Polyethylene Capacity.-        8,939

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                      V-B VINYL RESINS
      PVC and its copolymers (vinyl chloride content varies from 85% to
97%) are the most important of the vinyl resins.  They are produced by
emulsion or suspension polymerization of vinyl chloride alone or with a
comonomer such as vinyl acetate, vinylidene chloride, etc.  They can be used
alone or as a highly plasticized  (as much as 75% plasticizer) form.

      Polyvinyl acetate (PVAc), and to a lesser extent polyvinyl alcohol
(PVA) are important resins included in the vinyl group. PVAc is made by
polymerizing vinyl acetate in a manner similar to vinyl chloride polymeriza-
tion.  PVA is made by the hydrolysis of PVAc.

      Other vinyl resins include PVC copolymers containing less than 50%
vinyl chloride, polyvinyl butyral. polyvinyl formal  and small amounts of
polyvinyl  ethers.
1.    VINYL RESINS ARE THE  SECOND LARGEST PRODUCED POLYMER
      GROUP

      Domestic production of vinyl resins for 1967-1972 increased from 2.7
billion pounds in 1967 to 5.2 billion pounds in 1972, a compounded growth rate
of 14.0% per year.  In 1972, however, production increased 27.2% over the
previous year. Yearly production for the period 1967-1972 is shown in
Exhibit V-l.

            Vinyl  Resins Will Continue To Grow At Above Normal
            Growth Rates

            Vinyl resins are finding increased usage in the construction
      industry and much of this growth will, therefore, depend upon total
      economic growth.  This anticipated growth will also depend upon resin
      supply in 1973, but with new plant constructions underway, supply to
      sustain this growth should be adequate by 1974.


2.    THERE ARE  ABOUT 22 PRODUCERS  OF FOLYVINYL CHLORIDE

      These 22 producers operate some 37 plants with a total capacity of
about 6 billion pounds per year. Exhibit V-B1 lists producers, plant locations
and company capacities by 1974.  In some instances individual plant capacities
are unavailable.
                              V-10

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                                                       EXHIBIT V-B1
Producer and Location
The B. F. Goodrich Co.
  Niagara Falls, N.Y.
  Salem County. N.J.
  Calvert City, Ky.
  Avon Lake,  O.
  Long Beach, Calif.
Continental Oil Co.
  Pawtucket, R.I.
  Assonet,  Mass.
  Oklahoma City,  Okla.      (180)
Diamond Shamrock Corp.
  Delaware City, Del.        (220)
  Deer Park, Tex.            (300)
Union Carbide Corp.
  Institute. W.Va.
  Charleston, W.Va.
  Texas City,  Tex.
Borden Inc.
  Leominster,  Mass.          (145)
  niiopolis, m.              (200)
The Firestone Tire & Rubber Co.
  Pottstown, Pa.
  Penyville,  Md.
Tenneco Inc.
         Environmental Protection Agency
         PRODUCERS:   POLYVINYL CHLORIDE

                Estimated Capacity in 1974
                     (million pounds)

                          875
                                                                                     (6)
                           (100),
                               (4)
'(4)
                           (200)$
                           (250)
 Fleming, N.J.
  Burlington, N.J.
  Pasadena, Tex.            (300)'  (by 1974)
The Goodyear Tire & Rubber Co.    _
  Plaquemine,  La.           (200X.
  Niagara Falls, N.Y.        (80)
Occidental Petroleum Corp.
  Burlington Township, N. J.
Rublntech, Inc.
  Gulf Coast
 Painesville, O.
   (former Allied)
Air Products & Chemicals, Inc.
  Calvert City, Ky.
  Pensacola, Fla.
Stauffer Chemical Co.
  Delaware City,  Del.
Ethyl Corp.
  Baton Rouge. La.
Olln Corp.
  Assonet, Mass.
Uniroyal,  Inc.
  Painesville,  O.
380



520


320



345


400


520



300


420

450



170
 50

150

150

150

130
                          V-ll

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Producer and Location
Pantasote Co.
  Pt. Pleasant, W.Va.
American Chemical Corp.
  Long Beach. Calif.
General Tire & Rubber Co.
  Ashtabula, O.
Great American Chemical Corp.
  Fitchburg, Mass.
Keysor-Century Corp.
  Saugus, Calif.
Georgia-Pacific Corp.
  Plaquemlne, La.
National Starch
  Meredosla, HI.
              EXHIBIT V-B1  (continued)

Environmental Protection Agency
PRODUCERS:  POL WIN YL CHLORIDE(6)
      Estimated Capacity In 1974
           (million pounds)
               120

               ISO

               100

                70

                50

               220

                10
                                      Total
             6.050
                         V-12

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      (1)   PVC Production Facilities Are Concentrated In The Midwest,
            Gulf Coast And On The Northeast Coast

            PVC producers have located plants either close to the market
      place or close to raw material supply.  The larger producers are also
      basic in monomer production.

      (2)   Plant Capacities Vary Over A Narrow Range

            While total company capacities vary considerably,  the average
      plant size is estimated to be about 200 million pounds per year.
3.    THERE ARE OVER 100 PRODUCERS  OF POLYVINYL ACETATE

      There are 9 relatively large producers of PVAc operating 31
plants in the U.S. with an estimated capacity of 325 million pounds per year.
In most instances individual plant capacities are unavailable.  Exhibit V-B2
lists major producers, plant locations and some company capacities.  The
many smaller producers and plant locations are listed in Appendix 1.

      (1)  PVAc Production Facilities Are Scattered Throughout The U.S.

           The preponderance of plants to make PVAc is due to its prime
      end uses — in paints and adhesives.  Many paint and adhesive manu-
      facturers make their own PVAc and these industries are located to serve
      local markets at population centers.

      (2)  Plant Capacities Are Relatively Small

           Plant capacities can vary from  about 40 million pounds per year
      to about 1 million pounds.  The larger manufacturers probably average
      15-20 million pounds per year.
4.    THERE ARE 3 PRIME PRODUCERS OF POLYVINYL ALCOHOL

      The 3 prime producers operate plants at 4 locations and will have
an operating capacity of slightly over 272 million pounds per year by the end
of 1973. Exhibit V-B3 lists producers, plant locations and capacities where
available.
                              V-13

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                                                       EXHIBIT V-B2

                                        Environmental Protection Agency
                                        PRODUCERS:   POLYVINYL ACETATE(7'8)
Producer and Location                            Capacities
                                             (million pounds)

Air Products & Chemicals, Inc.                       25
  Cleveland, O.
  Elkton, Md.
  City of Industry,  Calif.
 CalvertCity, Ky.          (20)
Borden Inc.                                         40
  Bainbridge,  N.Y.
  Compton, Calif.
  Leominster,  Mass.
 Dliopolis.  ni.
  Demopolis.  Ala.
Celanese Corp.                                     25
  Louisville, Ky.
  Belvidere, N.J.
  Newark,  N.J.
W. R. Grace & Co.                                  25
  Cambridge,  Mass.
  Owensboro,  Ky.            (10)
 Acton, Mass.
E. I. Du Pont de Nemours & Co., Inc.                  50
  Toledo. O.
  Niagara Falls. N.J.
National Starch and Chemical Corp.                  55
  Plainfield, N.J.
  Meredosia, 111.
Reichhold Chemicals, Inc.                           40
  Charlotte, N.C.
  Elizabeth, N.J.
  Morris, m.
  Kansas City, Kans.
  South San Francisco, Calif.
 Tacoma, wash.
  Jacksonville, Fla.
  Azusa, Calif.
Monsanto Co.                                      40
  Springfield,  Mass.
Union Carbide Corp.
  Institute,  W.Va.
  S. Charleston W.Va.                              25
  Gardena.  Calif.                                  	
                                  Total           325
                     (8)
Other reported producers  are listed in Appendix 1.
                          V-14

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                                               EXHIBIT V - B3

                                  Environmental Protection Agency

                                   PRODUCERS: POLYVINYL ALCOHOL
                                         Capacity  (Million  pounds)
Producers                               1972                   1973

E.I.  Du Pont de Nemours  & Co., Inc.
      Niagara Falls, N.Y.                 25
      La Porte, Texas                     -                     100

Air Products S Chemicals, Inc.
      Calvert City, Ky.                   30                      30+

Monsanto Company
      Springfield, Mass.                  12                     142+

                  Total Capacity           67                     272+
Note:  Borden.Inc. has a B million Ib/year plant on standby at
      Leominster,  Mass.
                            V-15

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           PVA Plant Capacities Vary Considerably

           Plant capacities have, in the past, been relatively small — on
      the order of 15 -25 million pounds per year. The newest plant which
      will be on stream in 1973, however, will have a rated capacity of 100
      million pounds per year.
5.    THERE ARE SEVERAL ESTABLISHMENTS PRODUCING OTHER
      VINYL RESINS

      The principal "other" vinyl resin produced is polyvinyl butyral. This
resin, and several others, is generally produced at the same locations as PVA
and/or PVAc.  Prime producers are Monsanto Co., E .1. Du Pont de Nemours
Co., Inc., and Dow Chemical Co.
                            V-16

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                    V-C  STYRENE RESINS
      Polystyrene is manufactured by polymerizing styrene monomers, then
forming pellets by an extrusion process.

      Polystyrene copolymers include aerylonitrile-butadiene- styrene (ABS),
styrene-aerylonitrile (SAN) , styrene-butadiene, styrene-divinyl benzene
and styrene-rubber.

      For reporting purposes, the U.S. Tariff Commission has divided these
resins into two categories:  (1) polystyrene and copolymers, and (2) ABS and
SAN.
1.    STYRENE RESINS ARE HIGH VOLUME PRODUCTS

      Domestic production of polystyrene resins increased from 2.4 billion
pounds per year in 1967 to 4.5 billion pounds in 1972, a compounded growth
rate of 13.4% per year. In 1972 production increased 19.5% over the previous
year. Yearly production for the period 1967-1972 is shown in Exhibit V-l.

           Polystryene Resin'Production Grew At A Faster Rate Than
           ABS-SAN Resins

           Of the total 4,479 million pounds of styrene resins produced in
      1972, 81% or 3,643 million pounds was polystyrene and its copolymers,
      the remainder being ABS and SAN resins.  Polystyrene growth in 1972
      over the preceding year was about 22%, while ABS-SAN resins grew
      9.7%.  In anticipation of these growing markets, producers are plan-
      ning major plant capacity expansions.
2.    THERE ARE SOME 21 LARGE PRODUCERS OF STYRENE RESINS

      Of these 21 producers, 4 produce both polystyrene and ABS-SAN
resins; 14 produce only polystyrene, and 3 produce only ABS-SAN resins.
These 21 producers have production facilities at some 42 locations throughout
the U.S.  Major plant locations, producers and capacities are listed in
Exhibit V-C.  Other reported producers are listed in Appendix 1.
                              V-17

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(1)   Production Facilities Are Concentrated In Two Geographic
      Regions

      While a few plants are located in California and Texas, the major-
ity of the large plants are located in the Midwest and Northeastern regions
of the U.S.  Major markets for these resins are located in these areas.

(2)   Production Facilities Tend  To Be Of Medium Size

      The majority of the plants appear to be sized at about 100 million
to 200 million pounds per year.  There are, however, a large number
of plants smaller than 50 million pounds.
                        V-18

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                                                                    EXHIBIT V-C

                                                     Environmental Protection Agency
                                                     PRODUCERS:   STYRENE RESINS <4•  u •


                                                     Estimated Capacity, 1973 (million pounds)
Producer and Location                                  ABS- SAN    Polystyrene and Copolymers

The Dow Chemical Co.                                                     980
 Joliet, m.                                              -                 x
 Torrence,  Calif.                                        20                 x
 Midland. Mich.                                       105                 x
 Ironton (Hungry Rock).  O.                                                   x
 Riverside (Pevaly). Mo.                                  -                 x
 Allyn's Point. Conn.                                    65                 x
Monsanto Co.                                                             400
 Addyston,  O.                                         270                 x
 Springfield,  Mass.                                       -                 x
 Long Beach, Calif.                                       -                 x
Foster Grant Co., inc.
 Leominster.  Mass.                                       -                155
 Peru, m.                                               -                195
Cosden Oil & Chemical Co.                                                  300
 Calumet City, m.                                                         x
 Big Spring, Tex.                                         -                 x
Sinclair-Koppers Co.
 Kobuta, Pa.                                            -                300
Union Carbide Corp.                                                        280
 Marietta, O.                                            -                 x
 Bound Brook,  N.J.                                      35                 x
Amoco Chemicals Corp.                                                    280
 Medina, O.                                                               x
 Willow Springs. 111.                                                        x
 Leominster,  Mass.                                       -                 x
 Torrence,  Calif.                                         -                 x
United States Steel Corp.
 Haverhill. O.                                           -                200
BASF Wyandotte Coip.
 Jamesburg, N.J.                                         -                130
Rexene Polymers Co.                                                        130
 Joliet. m.                                             50                 x
 Holyoke, Mass.                                         -                 x
 Ludlow, Mass.                                          -                 x
 Santa Ana, Calif.                                        -                 x
Shell Chemical Co.                                                        130
 Marietta, O.                                                              x
 -Belpre, O.                                                                x
Polysar
 Leominster.  Mass.                                       -                100
 Forest City.  N.C.                                        -                 25
Uniroyal, Inc.                                          200+
 Baton Rouge.  La.                                         x                 -
 Scotts Bluff. La.                                         x                 -
                                        V-19

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Producer and Location

The B.F.  Goodrich Co.
 Louisville, Ky.
Borg-Warner Corp.
 Ottawa, m.
 Washington, W.Va.
Diamond Plastics, Inc.
 Long Beach, Calif.
Gordon Chemical Co., Inc.
 Oxford,  Mass.
 Worcester, Mass.
Petrochemical Investment Corp.
 Houston. Tex.
The Richardson Co.
 West Haven, Conn.
U.S. Industries
A & E Plastik Pak, Inc.
 City of Industry, Calif.


 Grand Total for  Styrene Resins:
                                                                   EXHIBIT V-C   (continued)
                                                    Environmental Protection Agency
                                                    PRODUCERS:  STYRENE RESINS(4'    '   '
                                                    Estimated Capacity. 1973 (million pounds)
                                                    ABS - SAN    Polystyrene and Copolymers
                     30

                    200
                    260

                                       50
                                       40
                                        x
                                        x

                                       50

                                       35
                                       50
                                       45
             Total 1.235+

5,110+ million pounds per year
3,875
 Note:  x denotes production at this location, but capacity is not known.
 Other reported producers *8* are listed in Appendix 1.
                                        V-20

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                V-D POLYPROPYLENE
      Polypropylene resins (PF) are thermoplastic resins containing,
predominantly, repeating propylene units.  PP is produced by hetero-
geneous polymerization of propylene dissolved in hydrocarbons.  Occasion-
ally,-propylene is copolymerized with small amounts of ethylene to improve
low temperature impact properties.
1.    POLYPROPYLENE IS BECOMING A COMMERCIALLY SIGNIFICANT
     .PRODUCT

      In 1972, PP production increased 36% over the previous year and almost
doubled the average growth rate of 21% for the period of 1967-1972.  PP pro-
duction in 1972 was 1.8 million pounds as compared to 0.7 million pounds in
1967. Exhibit V-l shows yearly production volume for the period 1967-1972.

           PP Growth Will Continue At Above Normal Growth Rate

           While it is not expected that the.growth rate shown for the past
      year will continue,  industry sources believe that a 15% average growth
      rate over the near future should not be discounted.  It is also expected
      that PP copolymers will take an increasing share of the market, and may
      in time be dominant over homopolymers.
2.    NINE PRODUCERS ACCOUNT FOR THE ENTIRE PRODUCTION
      OF POLYPROPYLENE

      These 9 producers presently operate at 10 locations.  However,
one of these producers has been erecting a new plant to be on stream by
December 1974. Plant locations and production capacities are listed in
Exhibit V-D.

      (1)  The Majority Of Production Facilities Are Located On
           The Gulf Coast

           Over 70% of the production capacity is located in Louisiana
      and Texas. Three producers, one each in W. Virginia, Delaware
      and New Jersey,  account for the remainder. The major share of the
      new capacity will be coming on the Gulf and will increase this region's
      capacity to just under 75% of the total.
                              V-21

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                                                 EXHIBIT V-D

                                       Environmental Protection Agency

                                      PRODUCERS:  POLYPROPYLENE (12)
Producer

Hercules,  Inc.


Amoco Chemicals Corp.


Exxon Chemical Co.

Shell  Chemical

Rexene Polymers,Co.

Novamont  Corp.

Texas  Eastman Co.

Diamond Shamrock Corp.

Phillips Petroleum Co.


      Total

      Total Capacity by 1974
Plant Location

Lake Charles,  La.       600
Bayport, Tex.

New Castle,  Del.        250
Chocolate Bayou,Tex.    150
           Increases
Capacity     by.
Apr.'73    Dec. '74
(Million pounds/year)
Baytown, Tex.

Woodbury, N.J.

Odessa, Tex.

Neal,  W.Va.

Longview, Tex.

Deer Park,  Tex.

Pasadena, Tex.
              150
              200
              100
   300

   250

   130

   120          40

   100

    90

    85


 2,075         490

       2.565
                             V-22

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(2)   Plant Capacities Vary Over A Wide Range

      Plant size varies tremendously from the smallest with a capacity
of 85 million pounds per year to the largest with a capacity of 750 million
(when complete in 1974) . The majority, however, range from 100 to
300 million pounds per year.
                        V-23

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      V-E  PHENOLIC AND OTHER TAR ACID RESINS
      Phenolic resins are thermosetting resins formed by the reaction of
phenol with aldehydes.  The properties of the final product can be varied
widely by choice and ratio of reactants and by reaction conditions.  Phenols
can be replaced by other tar acids to produce products with different proper-
ties , but these too result in insoluble, infusible thermoset products.
1.    PHENOLIC PRODUCTION HAS INCREASED AT AN AVERAGE ANNUAL
      RATE OF 7.5% FOR THE PAST 5 YEARS
      As shown in Exhibit V-l, phenolic resin production increased from
983 million pounds in 1967 to about 1,413 million pounds in 1972, an average
compound growth rate of 7.5% per year.  This growth rate has not been con-
sistent but has steadily been increasing so that 1972 production was 18% over
the previous year.

           Overall Growth For The Next 5 Years Will Approach
           That Of The Past 5 Year Period

           The large growth exhibited by phenolics in 1972 was due
      largely to growth in the appliance market and plywood industry.
      Continued growth will depend upon the general economic climate
      of the country and supplies of wood for the plywood industry.  Growth'
      is expected to continue at the rate of 10 - 12% over the next 5 years.
2.    THERE ARE NUMEROUS PHENOLIC RESIN PRODUCERS

      The major producers operate plants at 47 locations throughout the
United States and are shown in Exhibit V-E. An additional 71 companies
operate an additional 121 plants. These producers and plant locations are
listed in Appendix 1.

      (1)    Plants Are Concentrated In Areas Of Consumer Demand

            The principal uses are molding, adhesives, thermal insulation
      and plywood. As such, plants are located near plywood producers
      (Oregon, California and the South),  molders (Midwest and East Coast)
      and adhesive producers (metropolitan or highly populated areas).
                              V-24

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Producer and Location
Ashland Oil, Inc.
 Pensacola, Fla.
 Thomasville, N.C.
 Bethel, Conn.
 Fords, N.J.
 Newark,  N.J.
 Calumet City, 111.
 Paramount, Calif.
Borden Inc.
 Compton, Calif.
 Fremont, Calif.
 Kent, Wash.
 La Grande, Ore.
 Missoula. Mont.
 Springfield, Ore.
 Berkeley, Calif.
 Sheboygan, Wise.
 Bainbiidge, N.Y.
 Diboli. Tex.
 Fayetteville,  N.C.
General Electric Co.
 Schenectady, N.Y.
 Pittsfield, Mass.
Occidental Petroleum Corp.
 Kenton, O.
 North Tonawanda, N. Y.
Monsanto Co.
 Alvin (Chocolate Bayau),

 Addyston (Port Plastics), O.

 Eugene, Ore.
 Seattle, Wash.
Capacity 1/172
 (million Ibs)

    60
                               40
                               90
                              300
                              110
                                                              EXHIBIT V-E

                                               Environmental Protection Agency
                                               PRODUCERS:   PHENOLIGS C13)
                                                Producer and Location
                                                Plastics Engineering Co.
                                                 Sheboygan, Wise.
                                                Reichhold Chemicals, Inc.
                                                 Charlotte, N.C.
                                                 Moncure, N.C.
                                                 Houston,  Tex.
                                                 Tuscaloosa, Ala.
                                                 Andovei.  Mass.     /4\
                                                 Carteret, N.J.  (20)
                                                 Elizabeth, N.J.
                                                 Niagara Falls,  N.Y.
                                                 Detroit (Ferndale), Mich.
                                                 Kansas City, Kans.
                                                 Azusa, Calif.
                                                 South San Francisco, Calif.
                                                 Tacoma, Wash.
                                                 White City, Ore.
                                                Simpson Timber Co.
                                                 Portland, Ore.
                                                Union Carbide Corp.
                                                 Texas City, Tex.
                                                 Bound Brook,  N.J.
                                                 Marietta, O.
                                                 Elk Grove, Calif.
                                                 Sacramento, Calif.
       Capacity 1/1/72
        (million Ibs)

           75

          360
                                                                               40

                                                                              190
   (4)
(25)(4)
(25)
                                                Total Capacity
        1.265
                                  (8)
Other reported Phenolic resin producers   are listed In Appendix 1.
                                         V-25

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(2)   Plant Size Varies Widely

      There are a few large plants with capacities of over 150 million
pounds per year. But judging from total company capacity, and the
number of producing locations per company, the average plant size
is probably in the order of 20 - 30 million pounds per year.  Small
plants with capacities of less than 1 million pounds are also numerous,
                         V-26

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                   V-F  POLYESTERS
      Many different resins are called polyesters, including alkyds and
unsaturated polyester resins.  This section is concerned with the unsatur-
ated polyesters.

      These unsaturated polyester resins are based on unsaturated prepoly-
mers, which are made by the esterification of dihydric alcohols (glycols)
with unsaturated and modifying dibasic acids and/or anhydrides. The un-
saturated prepolymer is dissolved in an unsaturated monomer (e.g. styrene)
with which it cross-links to form the ultimate polymer.
1.    POLYESTERS RANK SIXTH IN TOTAL VOLUME PRODUCED

      Domestic production of polyester in 1972 increased a healthy 18% over
1971,  although this growth was not as large as the increase observed in 1971.
Production has grown from 513 million pounds in 1967 to 862 million pounds
in 1972, a compounded growth rate of 10.9% per year, and is shown in Exhibit
V-l.

            Polyester Consumption Is Expected To Grow At A Higher
            Than Normal Rate

            Growth of these resins is tied closely with the construction,
      transportation and recreation industries. With the boom in the build-
      ing trade, increasing use in truck body construction, modular building
      fabrication and fiber-glass marine craft and accessories, production of
      polyesters is expected to grow at a rate of 15 - 20% for the near future
      period.
2.    THE BULK OF POLYESTER PRODUCTION IS ACCOUNTED FOR
      BY 33 COMPANIES

      These 33 companies operate at over 80 locations as shown in Exhibit V-F,
                              V-27

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                                                               EXHIBIT V - F
                                                Environmental Protection Agency
                                                PRODUCERS:  POLYESTERS t4-8,14)
Producer and Location
 Plant Capacity
(million pounds)
Allied Chemical Corp.
  Des Plaines,  111.
  Los Angeles, Calif,
  Toledo, O.
  Whippany, N.J.
  Moncuie, N.C.
Alpha Chemical Corp.
  Colliersville, Term.
  Kathleen,  Fla.
American Cyanamid Co.
  Azusa,  Calif.
  Penysville, O.
  Wallingford,  Conn.
Ashland Oil Inc.
  Los Angeles,  Calif.
  Newark, N.I.
  Pensacola, Fla.
  Valley Park,  Mo.
Atlas Chemical Industries, Inc.
  Wilmington,  Del.
Cargill, Inc.
  Lynwood. Calif.
Cook Paint & Varnish Co.
  Detroit, Mich.
  Hialeah, Fla.
  Mllpitas, Calif.
  North Kansas  City, Mo.
De Soto, Inc.
  Berkeley, Calif.
  Chicago Heights, HI.
  Garland, Tex.
Diamond Shamrock Corp.
  Oxnard,  Calif.
  Redwood City, Calif.
H. H. Robertson Co.
  Saukville,  Wise.
General Electric Co.
  Mt. Vernon,  Ind.
  Schenectady, N.Y.
P. D. George Co.
  St.  Louis, Mo.
    25
    30
    15
Producer and Location
 Plant Capacity
(million pounds)
W.  R. Grace & Co.             150
  Bartow, Fla.                   20
  Linden, N.J.                   20
  Montebello, Calif.             10
  Swanton, O.                   50
  Jacksonville, Ark.              45
Guardsman Chemical
 Coatings. Inc.
  Grand Rapids, Mich.
Inmont Corp.
  Greenville, O.
  Cincinnati, O.
  Detroit, Mich.
Interplastic Corp.
  Minneapolis, Minn.            70
  Pryor, Okla.                   30
Koppers Co., Inc.
  Bridgeville, Pa.                30
  Richmond, Calif.
Molded Fiber Glass Companies,   45
 Inc.
  Ashtabula, O.
Occidental Petroleum Corp.
  North Tonawanda,  N. Y.
  Baton Rouge, La.
Owens-Corning Fiberglas Corp.    90
  Anderson, S.C.                50
  Valpariso. Ind.                 40
PPG Industries,  Inc.
  Circleville. O.
  Houston, Tex.
  Springdale, Pa.
  Torrence, Calif.
Reichhold Chemicals, Inc.       200
  Azusa, Calif.
  Detroit, Mich.
  Elizabeth, N.J.                30+
  Grand Junction, Tenn.
  Houston, Tex.
 Jacksonville, Fla.
  South San Francisco, Calif.
  Tacoma, Wash.
                                         V-28

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                                                           EXHIBIT V  - F (continued)

                                            Environmental Protection Agency
                                            PRODUCERS:  POLYESTERS (4 •ff, 14)
Producer and Location       Plant Capacity
                         (million pounds)

Resinous Chemicals, Corp.
  Linden.  N.J.
Rohm and Haas Co.
  Knoxville, Term.
  Philadelphia, Pa.
SCM Corp.
  Chicago, m.
  Cleveland,  O.
  Huron. O.
  Reading, Pa.
  San Francisco, Calif.
Schenectady Chemicals,  Inc.
  Schenectady, N.Y.
The Sherwin-Williams Co.
  Cleveland,  O.
  Emeryville. Calif.
The Standard Oil Co. (Ohio)     42
  Hawthorne, Calif.            30
  Covington,  Ky.               12
Stepan Chemical Co.
  Anaheim, Calif.
United Merchants & Manufacturers,
 Inc.
  Langley. S.C.
VWR United Corp.
  Newark,  O.
  Portland, Ore.
  Richmond, Calif.
Westinghouse Electric Corp.
  Manor,  Pa.
WMttaker Corp.
  Lenoir,  N.C.
  Minneapolis, Minn.
  Colton,  Calif.
                                      V-29

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(1)   Five Producers Reportedly Account For 50% Of Production

      Producer, and more specifically individual plant capacities are
confidential.  Where possible we have indicated plant or producer capa-
city based on industry and literature references.  According to Chemical
Economics Handbook 1*4) f industry concentration in 1968 was approxi-
mately as follows:

      Percent of  1968 Production Accounted For By  ...

       3 largest producers                      40%
       5 largest producers                      50%
      10 largest producers                      70%
      15 largest producers                      85%
      20 largest producers                      95%

      The three largest producers are believed to be W.R. Grace 6 Co.,
PPG Industries, Inc.  and Reichhold Chemicals, Inc.

(2)   Individual Plant Capacities Are Highly Flexible

      Production economics are such that plants operate on a 24 hour
basis, processing 2 batches per day per reactor.  The smallest econom-
ically feasible batch size would be about 500 gal., while several of the
larger plants have multiple 5,000-6,000 gal. reactors.  Plant capacities
could, therefore, vary from about 1 million pounds to  over 70 million
pounds per year.

      Another consideration that must be taken into account is the
inter changeability of products produced.  For example, alkyds and
polyesters can be made in the same equipment. Comparing polyester
plant  locations with alkyd plant  locations confirms this.

(3)   Plants  Are Geographically Widely Dispersed But Tend To
      Locate  Near Populated Areas And Markets

      A rough estimate of the geographic distributions of the markets
is as follows <14):

           Midwest States                40%
            Far Western States             20%
            Southwestern States           15%
            New England and Middle       13%
             Atlantic States
            Southeastern States           12%
                        V-30

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              V-G  AMINO (U-F and M-F)  RESINS
      Amino resins are principally resins made by condensing formaldehyde
with urea or melamine. Other amino resins include:  aniline-formaldehyde,
guanamines and ethylene-urea-formaldehyde condensation products.


1.    AMINO RESIN PRODUCTION HAS  INCREASED STEADILY OVER THE
      PAST  5 YEARS

      Amino resin production has increased from 690 million pounds in 1967
to 851 million pounds in 1972. This is an average annual growth of 4.4% per
year.  Growth for 1972 was slightly better than this at 5.8%. Production for
the period 1967-1972 is shown in Exhibit V-l.

            Amino Resin Consumption Is Expected To Grow  5-6%
            Over The New Term

            Amino resin usage has benefited by the increases in bonding
      and adhesives markets, which in turn have benefited from high levels
      of activity in the building industries. Molding applications, however,
      declined somewhat.
2.    THERE ARE  82 AMINO RESIN PRODUCERS
                                                     i
      These 82 producers operating at 165 locations in the United States are
listed in Exhibit V-G.  It is interesting to note that these amino resin plants
operate at the same locations that phenolic resins are produced.  This is
typical since their major end uses compete.

           We Believe Amino Resin Production Capacity To Be
           Similar To Phenolic Resin Capacity

           In many instances,  literature refers to construction of phenolic/
      urea-formaldehyde resin plants.  Both products are produced in similar
      manners, and equipment would probably be interchangeable. Therefore,
      average plant production capacity for amino resins would probably be
      in the range  of 20-30 million pounds per year, with many small  plants
      having capacities of less than 1 million pounds per year.
                               V-31

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                                                               EXHIBIT V - G
                                                       Environmental Protection Agency
                                                       PRODUCERS:   AMINO RESINS W
Allied Chemical Corp.,  Toledo, O.
American Alkyd Industries, Carlstadt. N. J.
American Cyanamid Co., Wallingford, Conn.
                        Evandale,  O.
                        Charlotte, N.C.
                        Azusa, Calif.
Apex Chem. Co., Inc. Elizabethport, N. J.
Ashland Oil, Inc., Fords, N.J.
                 Calumet City, HI.
                 Thomasville. N.C.
                 Paramount,  Calif.
The Bendix Corp., Troy, N.Y.
Borden,  Inc., Bainbridge, N.Y.
             Compton, Calif.
             Freemont, Calif.
             Kent,  Wash.
             La Grande, Ore.
             Missoula,  Mont.
             Springfield, Ore.
             Sheboygan, Wise.
             Deboli,  Tex.
             Fayeneville,  N.C.
Brown Co., Gorham, N. H.
CPC International, Inc., Forest Park, m.
                       Charlotte,  N.C.
Cargill, Inc., Carpentersville,  m.
             Philadelphia, Pa.
             Lynwood, Calif.
Celanese Corp., Newark, N. I.
                Louisville,  Ky.
Chemical Prods. Corp.,  E. Paterson, N. J.
Clark Oil & Refining Corp.,  Blue Island, El.
                          Tewksbury. Mass.
Commercial Products Co., Hawthorne, N.J.
Cook Paint & Varnish Co., Detroit,  Mich.
                         N. Kansas City, Mo.
Dan River Mills, Inc..  Danville. Va.
De Paul Chem.  Co., Inc., Long Island City, N.Y.
De Sow. Inc.,  Chicago  Heights, HI.
               Garland, Tex.
               Berkeley, Calif.
The Duplan Corp., Brodhead, Wise.
Eastern Color &  Chem. Co..  Providence, R. I.
Emkay Chem. Co., Elizabeth.  N.J.
FMC Corp., Fredericksburg, Va.
GAF Corp., Chattanooga, Tenn.
General Electric Co., Pittsfield. Mass.
 Georgia-Pacific Corp., Coos Bay.  Ore.
                      Columbus, O.
                      Crossett, Ark.
                      Louisville. Miss.
                      Lufkin, Tex.
                      Conway, N.C.
                      Savannah,  Ga.
 Guardsman Chem. Coating Inc., Grand  Rapids, Mich.
 Gulf Oil Corp., Shawano, Wise.
               Alexandria, La.
               High Point, N.C.
               W.  Memphis, Ark.
               Lansdale. Pa.
 H & N Chem. Co.,  Totowa.  N.J.
 The Hanna Paint Mfg. Co., Inc., Columbus,  O.
 Hart Products Corp., Jersey City, N.J.
 Hercules,  Inc.. Portland, Ore.
               Eugene, Ore.
               Tacoma, Wash.
               Chicopee, Mass.
               Milwaukee, Wise.
               Savannah. Ga.
 E. F.  Houghton & Co., Philadelphia. Pa.
 Inter-Pacific Resins,  Inc., Sweet Home, Ore.
 Ironsides Resins Inc., Columbus, O.
 KoppersCo.,  Inc.,  Bridgeville, Pa.
 Lancaster Chem.  Corp., Wilmington, Del.
 Millmaster Onyx Corp., Lyndhurst, N.J.
 Minnesota Mining &  Mfg.  Co.,  Decatur, Ala.
 Mobil Oil Corp., Kankakee, 111.
 Monsanto Co., Addyston,  O.
              Alvin,  Tex.
              Everett, Mass.
              Eugene, Ore.
              Santa Clara, Calif.
              Seattle, Wash.
 National Casein Co., Chicago,  HI.
                    Tyler, Tex.
                    Riverton,  N.J.
 National Starch & Chem. Corp., Salisbury,  N.C.
 A. P.  Nonweiler Co.,  Oshkosh,  Wise.
 Onyx Oils & Resins, Inc.,  Newark,  N.J.
                        Brooker,  Fla.
Owens-Coming Fiberglas Corp., Newark. O.
PPG Industries,  Inc.. Circleville, O.
Pacific Holding Corp., Chicago, Dl.
Pioneer Plastics Corp., Auburn,  Me.
                                        V-32

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                                                              EXHIBIT V - G (continued)
                                                      Environmental Protection Agency
                                                      PRODUCERS  :  AMINO RESINS <8)
Plastics Engineering Co., Sheboygan. Wise.
Plastics Mfg. Co., Dallas,  Tex.
Quaker Chem.  Corp.,  Conshohocken, Pa.
Reichhold Chems.. Inc., Azusa, Calif.
                       S. San Francisco, Calif.
                       Tacoma, Wash.
                       White City, Ore.
                       Andover. Mass.
                       Elizabeth, N.I.
                       Niagara Falls,  N. Y.
                       Detroit, Mich.
                       Charlotte, N.C.
                       Houston, Tex.
                       Jacksonville,  Fla.
                       Tuscaloosa, Ala.
Reliance  Universal. Inc.,  Houston, Tex.
                        Louisville, Ky.
Renroh Resins,  New Bern, N. C.
Rugel Textile Corp., Ware Shoals, S. C.
Rock Hill Printing & Finishing Co., Rock Hill, S. C.
Rohm and Haas Co., Philadelphia, Pa.
SCM Corp.,  Reading,  Pa.
            Chicago,  HI.
            Cleveland, O.
            Huron, O.
            San Francisco, Calif.
Sandoz-Wander,  Inc., Hanover, N.J.
Scher Brothers  Inc., Clifton, N. J.
Scott Paper Co., Everett,  Wash.
                Chester, Pa.
                Fort Edward,  N. Y.
                Marinene. Wise.
                Mobile.  Ala.
Seydel-Woolley & Co., Atlanta,  Ga.
Skelly Oil Co., Springfield, Ore.
The Sherwin-Williams Co., Chicago,  111.
                          Cleveland, O.
                          Newark, N.J.
Sauhegan Wood Products, Inc., Wilton, N. H.
Sow-Tix  Chem. Co.,  Inc., Mount Holly,  N.C.
Southeastern Adhesives Co., Lenoir, N. C.
Standard  Oil Co. (N.J.), Odenton, Md.
Sun Chem. Corp., Chester, N. C.
                  Wood River Junction, R. I.
Sybron Corp.,  Haledon, N. J.
Synthron, Inc.,  Morganton, N. C.
               Ashton, R.I.
Synvar Corp.. Wilmington,  Del.
Taylor Corp., La Verne, Calif.
             Betzwood, Pa.
Textilana Corp., Hawthorne, N. J.
USM Corp.,  Spartanbury,  S. C.
            Centredale, R.I.
            Providence, R.I.
United-Erie, Inc.,  Erie, Pa.
United Merchants & Mfgs., Inc.,  Langley, S.C.
U. S. Oil Co., E. Providence,  R. I.
             Lumberton,  N.C.
U.S. Ply wood-Champion Papers, Inc..
             Redding. Calif.
VWR United Corp., Newark, O.
                  Portland, Ore.
                  Richmond, Ore.
Virginia Chems. Inc., Portsmouth, Va.
West Coast Adhesives Co.,  Portland, Ore.
Westinghouse Electric Corp., W. Mifflin, Pa.
Weyerhaeuser Co.,  Longview,  Wash.
                  Marshfield. Wise.
Whittaker Corp., Colton,  Calif.
Woonsocket Color & Chem.  Co.,  Woonsocket,  R. I.
Wright Chem. Corp., Acme, N. C.
                                        V-33

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                      V-H  ALKYDS
      Alkyd resins are basically polyester resins (resinous reaction products
of polybasic acids and polyhydric alcohols) but differ from other polyesters by
containing drying oils or fatty monobasic acids and diluted with a nonreactive
solvent.
1.    ALKYD RESIN PRODUCTION HAS INCREASED VERY LITTLE OVER
      THE PAST 5 YEARS

      Domestic production of alkyds in 1972 increased almost 20% over 1971,
keeping pace with increased construction activity. For the period 1967-1972
growth has averaged only 1.7% annually;  in fact, there was a steady decrease
in production during the period 1968-1971 from 692 million pounds in 1968 to
580 million pounds in 1971. Production for the period 1967-1972 is  shown in
Exhibit V-l.

            Alkyd Consumption Will Probably Not Maintain The 1972
            Growth Rate

            Alkyds are used almost exclusively in the manufacture of
      surface coatings (some is used in molding compounds). They are
      competing with latex and other water-based coatings which are gain-
      ing a larger share of the coating market.  We expect alkyd production
      will increase 1-2% per year over the next five years.
2.    OVER 100 COMPANES PRODUCE ALKYD COATING RESINS

      These 100 companies operate more than 180 plants throughout the
United States, with the heaviest geographical concentration in the Middle
Atlantic States, Great Lakes Region, Ohio River Valley and the state of
California. These four regions probably contain 75% of the plants.  Producers
are listed in Exhibit V-H.

            Plant Sizes Vary Over A Wide  Range

            Plant sizes will vary from small  "garage type" operations to
      large integrated operations.  An average small size plant might con-
      sist of a 500 gal. reactor capable of manufacturing less than 1 million
      pounds per year to a multi-reactor plant with several large 300.0 to
      5000 gal. reactors capable of producing 20-30 million pounds per year.
                               V-34

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                                                               EXHIBIT V-H
Companies and Resin Plant Locations

Adco Chemical Co.,  Newark, N. J.
Ball Chemical Co., Glenshaw,  Pa.
Barrett Varnish Co.,  Cicero,  HI.
Celanese Corp,.  Los Angeles, Calif.
                Louisville,  Ky.
                Newark, N. J.
Chemetron Corp., St. Louis, Mo.
Cook Paint & Varnish Co., Detroit, Mich.
                         Houston,  Tex.
                        Milpitas, Calif.
                         N. Kansas City, Mo.
Defiance Industries, Inc., Baltimore, Md.
The Dexter Corp., Waukegan,  Dl.
Dock Resins Corp., Linden,  N. J.
Ford Motor Co.,  Mt.  Clemens, Mich.
Foy-Johnston, Inc., Cincinnati, Ohio
P. D. George Co., St.  Louis. Mo.
Grow Chemical Corp.,  St. Louis, Mo.
Hugh J. ~ Resins Co.,  Long Beach,  Calif.
Kelly-Moore Paint Co., San Carlos,  Calif.
McCloskey Varnish Co.. Los Angeles, Calif.
                       Philadelphia, Pa.
                       Portland, Ore.
Napko Corp., Houston, Tex.
National Lead Co., Philadelphia, Pa.
                  San Francisco, Calif.
Reliance Universal, Inc., Houston, Tex.
                        Louisville, Ky.
Schenectady Chemicals, Inc.,  Schenectady,  N. Y.
The Sherwin-Williams Co., Chicago, Ql.
                          Cleveland, Ohio
                          Emeryville,  Calif.
                          Garland, Tex.
                          Los Angeles, Calif.
                          Newark. N.J.
                          Detroit, Mich.
                          Dayton, Ohio
                          Gibbsboro,  N.J.
The Valspar Corp., Rockford, DH.
Westinghouse Electric Corp., Manor, Pa.
Yenkin-Majestic Paint Corp., Columbus, Ohio
                                                Environmental Protection
                                                PRODUCERS :   ALKYDS1
Companies and Resin Plant Locations
                                  sncy
Haynie Products, Inc..  Baltimore, Md.
Hercules Inc., Burlington,  N.J.
Industrial Oil & Varnish Co., Chicago Heights, HI.
International Minerals & Chemical Corp., Bensenville, 111.
Kelly-Pickering Chemical Corp., San Carlos, Calif.
Koppers Co., Inc.,  Bridgeville, Pa.
                   Richmond, Calif.
Lanson Chemical Corp., East St. Louis, ni.
Midwest Manufacturing Corp..  Burlington, Iowa
Onyx Oils & Resins,  Inc., Brooker,  Fla.
                        Newark,  N.J.
C. J. Osbom Company,  Linden, N.J.
Polychrome Corp., Newark, N. J.
Purex Corp.. Ltd., Chicago, 111.
Reichhold Chemicals Inc., Azusa, Calif.
                         Detroit (Ferndale). Mich.
                         Elizabeth, N.J.
                         Houston, Tex.
                         Jacksonville,  Fla.
                         S.  San Francisco, Calif.
                         Tuscaloosa,  Ala.
                         Cicero, Ql.
Resinous Chemicals Corp., Linden, N.J.
Resyn Corp., Linden, N. J.
H. H.  Robertson Co.,  Saukville, Wise.
Roblen Research & Development Corp., Colton, Calif.
Rohm and Haas Co., Philadelphia,  Pa.
Shanco Plastics & Chemicals Inc., Tonawanda, N. Y.
Standard Oil Co. of Calif., Anaheim,  Calif.
American Alkyd Industries, Carlstadt, N. J.
Ashland Oil & Refining Co., Los Angeles, Calif.
                          Newark. N.J.
                          Pensacola, Fla.
                          Valley Park, Mo.
Cambridge Industries Co.,  Cambridge, Mass.
                         Watertown, Mass.
Catgill, Inc., Carpentersville. 111.
              Lynwood, Calif.
              Philadelphia, Pa.
Commercial Solvents Corp., Chicago, 111.
Degen Oil & Chemical Co., Jersey City, N.J.
                                          V-35

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                                                               EXHIBIT V-H (continued)

                                                Environmental Protection Agency
                                                PRODUCERS  :   ALKYDS*4'*5
Companies and Resin Plant Locations
Companies and Resin Plant Locations
Farac Oil & Chemical Co.,  Chicago,  ni.
Farnow, Inc.,  South Kearny, N. J.
France, Campbell & Darling Inc., Ke nil worth,  N. J.
Superior Varnish & Drier Co.,  Pennsauken,  N. J.
Synthetic Resins & Chemicals, Inc., Carpentersville, ni.
Synvar Corp.,  Wilmington,  Del.
Tenneco Inc., San Francisco,  Calif.
Union Camp Corp., Valdosta, Ga.
U. S. Coatings Co., Bronx,  N. Y.
Armstrong Paint & Varnish Works, Inc., Chicago, ni.
Beatrice Foods Co., Baltimore. Md.
Bennett's,  Salt Lake City, Utah
Brooklyn Paint & Varnish Co., Inc., Brooklyn, M. Y.
M. A. Bruder & Sons, Inc., Philadelphia, Pa.
Carpenter  Morton Co., Everett, Mass.
ConChemCo Inc.,  Baltimore,  Md.
                 Kansas City, Mo.
                 Houston, Tex.
DeSoto. Inc..  Berkeley. Calif.
              Chicago Heights, ni.
              Garland,  Tex.
Frank W. Dunne Co.. Oakland, Calif.
E. I. du Pont de Nemours & Co., Inc., Fort Madison, Iowa
                                 Parlin,  N.J.
                                 Philadelphia. Pa.
                                 S. San Francisco,
                                  Calif.
                                 Toledo, Ohio
                                 Tucker, Ga.
Enterprise  Paint Manufacturing Co., Chicago,  HI.
Fibreboard Corp., Oakland, Calif.
Frisch & Co.,  Inc., Paterson, N. J.
General Electric Co..  Chelsea. Mass.
                     Schenectady, N.Y.
Georgia-Pacific Corp.,  Sumter, S.C.
Oilman Paint & Varnish Co.. Chattanooga, Term.
Grow Chemical Corp.,  Oakland,  Calif.
                      Tampa,  Fla.
Guardsman Chemical Coatings, Inc., Grand Rapids.
                                    Mich.
                                   Louisville, Ky.
  The Hanna Paint Manufacturing Co., Inc., Columbus, Ohio
                                       Pittsburgh. Pa.
  Interchemical Corp.,  Anaheim, Calif.
                      Cincinnati,  Ohio
                      Detroit, Mich.
                      Los Angeles,  Calif.
                      Newark, N.I.
  Jewel Paint & Varnish Co.,  Chicago,  ni.
  Jones- Blair Paint Co., Inc., Dallas, Tex.
  Kohler-McLister Paint Co., Denver, Colo.
  Kyanize Paints, Inc., Everett, Mass.
  Lilly Industrial Coatings, Inc., Indianapolis, Ind.
  Maas & Waldstein Co., Newark, N. J.
  McDougall-Butler Co., Inc., Buffalo, N.Y.
  Minnesota Paints, Inc., Fort Wayne, Ind.
                       Minneapolis, Minn.
  Mobil Chemical Co., Cleveland,  Ohio (2 plants)
                      Kankakee, 111.
                      Louisville, Ky.
                      Metuchen.N.J.
                      Pittsburgh, Pa.
  Montgomery  Ward & Co.,  Inc., Chicago, HI.
                               Staten Island, N.Y.
  Benjamin Moore & Co., Cleveland, Ohio
                        Denver. Colo.
                        Los Angeles, Calif.
                        Newark, N.J.
  Morwear Paint Co., Oakland, Calif.
  A. P. Nonweiler Co., Oshkosh,  Wise.
  Norris Paint & Varnish Co., Salem, Ore.
  The O'Brien Corp., Baltimore, Md.
                    South Bend, Ind.
                    South San Francisco,  Calif.
  Perry & Derrick Co., Dayton, Ky.
  Pervo Paint Co.. Los Angeles, Calif.
  PPG Industries, Inc., Atlanta, Ga.
                     Circleville.  Ohio
                     Cleveland, Ohio
                      Houston. Tex.
                     Milwaukee,  Wise.
                     Newark, N.J.
                     Spdngdale. Pa.
                     Tonance,  Calif.
                                         V-36

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                                                           EXHIBIT V-H (continued)

                                             Environmental Protection Agency
                                             PRODUCERS :   ALKYDS(4'°)
Companies and Resin Plant Locations

Pratt & Lambert, Inc., Buffalo,  N. Y.
Red Spot Paint & Varnish Co., Inc.,  Evansville.  Ind.
Rust- Oleum Corp., Evanston.  Dl.
Sapolin Paints, Inc.,  Brooklyn,  N. Y.
SCM Corp., Chicago, 111.
           Cleveland, Ohio
           Reading, Pa.
           San Francisco, Calif.
Standard Oil Co. (New Jersey), Houston, Tex.
Steelcote Manufacturing Co., St. Louis. Mo.
Sullivan Varnish Co., Chicago.  HI.
Sun Chemical Corp.,  Northlake, HI.
Textron Inc., North Brunswick,  N. J.
Whittaker Corp., Minneapolis, Minn.
                                       V-37

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      Producers of alkyds can produce polyesters in the same equip-
ment . In many instances the economics of production of either or both
products may depend upon the ability to produce both products.
                         V-38

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                     V-I  ACRYLICS
      Acrylic resins are polymers derived from acrylate monomers.  A variety
of monomers are commercially available.  Since they can be polymerized with
each other or a wide range of nonacrylic comonomers, they offer a versatile
span of products and properties.  Among the more popular monomers used are
ethyl acrylate, methyl methacrylate. 2-ethylhexyl acrylate, butyl acrylate and
acrylic acid.
1.    A MODEST VOLUME OF ACRYLICS IS BEING PRODUCED

      Acrylic resin production in 1972 increased about 12% over 1971.  Prior
to 1970, the U.S. Tariff Commission did not report acrylic resin production.
However, based on reported demand for acrylates, production for the period
of 1967-1972 has increased from about 220 million pounds in 1967 to 590 million
pounds in 1972. a compounded annual growth rate of about 22% per year. Pro-
duction rates are shown in Exhibit V-l. Acrylate producers are shown in
Exhibit V-I.

           Acrylic Resin Demand Will Be Above  Average

           It is expected that acrylic resin demand will be above average
      over  the next 5 years and probably average 15% per year through
      1977.
2.    A MAJOR PORTION OF THE ACRYLATES PRODUCED IS USED
      CAPTIVELY

      There are  5 producers of acrylates (including acrylic acid) with
production at 7 locations as shown in Exhibit V-I.

            Probably 60-65% Of The Acrylic Resins Produced Is
            Produced By 4 Companies

            The Rohm and Haas Co. probably uses over 50% of its own
      acrylate production to produce acrylic emulsions for sale. Dow
      Chemical Co.,  Celanese Corp.  and Union Carbide Corp. uses prob-
      ably account for an additional 10%. The remainder is used by numer-
      ous producers  of emulsion polymers used for surface 'coatings,
      textiles, paper, polishes, leather and other uses as listed in Appendix
      1.
                              V-39

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                                  EXHIBIT V-I

                       Environmental Protection Agency
                                                  (15)
                         PRODUCERS:   ACRYLICS
                          Estimated Capacity  (1974)
                              (million pounds)	
Celanese Corp.                    300
      Pampa, Tex.   (180)
      Clear Lake, Tex.  (220)

Dow Badische Co.                   40
      Freeport, Tex.

The  B.F.  Goodrich  Co.              5
      Calvert City,  Ky.

Rohm 6 Haas Co.                  400
      Houston,  Tex.

Union Carbide Corp.
      Institute, W.Va.               70*
      Taft, La.                    200
Total                            1,015
*Will probably shut down  when Taft
 reaches capacity.
                  V-40

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       V-J COUMARONE-INDENE AND PETROLEUM RESINS
      Coumarone-indene and petroleum resins are thermoplastic hydrocarbon
resins prepared from by-products of large scale coking and petroleum opera-
tions .  The raw material for coumarone-indene resins is coal tar distillation;
for petroleum resins, petroleum distillates resulting from cracking operations.

1.    COUMARONE-INDENE AND  PETROLEUM RESIN PRODUCTION  IS
      RELATIVELY SMALL

      Production in 1972, for these resins, amounted to 325 million pounds.
This was a 22% increase over 1971. Production over the years has been highly
irregular.  -For the 1967-1972 period, volume has increased from 284 million
pounds to 325 million pounds as shown in Exhibit V-l. Growth is expected to
be static over the near future.

            Consumption Has Been Erratic

            Its main use (asphalt tile) is being challenged by vinyl tile.
      Increased use in rubber compounding will probably maintain its present
      volume.
2.    FIFTEEN COMPANIES PRODUCE COUMARONE-INDENE AND PETROLEUM
      RESINS

      These 15 companies produce at 20 locations as listed in Exhibit
V-J.

      (1)    We Have Not Been Able To Ascertain Plant Capacities

            By-product production is difficult to determine since production
      depends upon demand of the main product, economics of raw materials,
      and composition of the raw material. Of course, demand for the resin
      itself is also a determining factor.

      (2)    Plants Are Located At Raw Material Sources

            These plants are concentrated near  coking operations in Penn-
      sylvania and petroleum cracking operations on the Gulf Coast.
                              V-41

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                                            EXHIBIT V - J

                                    Environmental Protection Agency

                                    PRODUCERS :   COUMARONE-INDENE
                                        AND PETROLEUM RESINS (8)
DeSoto Inc.,
      Chicago, 111.
      Berkeley, Calif.
      Garland, Tex.

Monsanto  Co.,
      Sauget (E.St.Louis), 111.

Northwest Industries, Inc.
      Marshall,  HI.

PPG Industries,  Inc.,
      Milwaukee, Wise.

Neville Chemical Co.,
      Anaheim, Calif.
      Neville Island, Pa.

Alabama Binder  6  Chemical Corp.
      Tuscaloosa,  Ala.

Chemfax,  Inc.
      Gulf port, Mi s s.

Masonite Corp.,
      Gulfport, Miss.
Reichhold Chemical Inc.
      Gulfport, Miss.

Standard Oil  Co.  of N.J.,
      Baton Rouge, La.

Standard Oil  Co.  of Ind.,
      Texas City,  Tex.

Valentine Sugars,  Inc.,
      Lockport, La.

Carpenter Morton Co.,
      Everett, Mass.

Kenrich Petrochemical, Inc.
      Bayonne, N.J.

Pennsylvania  Industrial Chemical  Corp,
      Chester, Pa.
      Clairton, Pa.
      West Elizabeth, Pa.
                             V-42

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                     V-K POLYURETHANES
      The major uses of polyurethanes include flexible and rigid foams,
elastomers, adhesives, coatings and sealants. The manufacture of foams and
elastomers is not classified as "chemical/plastics" industry, SIC 2821. Plastic
foam manufacture is associated with SIC 3079,  "Miscellaneous Plastics Products"
Further, the U.S. Tariff Commission does not  note foams among "Plastic and
Resin Materials" in its reports entitled,  U.S. Production  And Sales Of
Synthetic Organic  Chemicals.  Hence, this study does not deal with polyure-
thane foams.

      Polyurethane elastomers are similarly not classified in SIC 2821 as plas-
tic materials.

1.    URETHANE RESIN PRODUCTION PERTAINING  TO ADHESIVES.
      COATINGS AND SEALANTS IS  THE AREA OF  INTEREST

      The U.S. Tariff Commission data on "Polyurethane and Diisocyanate
Resins" deals with the manufacture of adhesives, coatings  and sealants under
the broad category of "Plastic and Resin Materials" .

      Exhibit V-K1 indicates the production trends.  In our judgment, the
data is highly inaccurate.

      (1)  Growth Is  Expected  To Be At Least 10% Annually Through
           1977

           We believe this growth rate may be conservative.  Many new
      uses are being investigated, and any one of these could change total
      demand drastically.

      (2)  In The Urethane Resin  Categories Studied. Coating Resins
           Are Most Important

           These account for roughly two-thirds or more of urethane
      resins in the adhesives, coatings,  sealants and miscellaneous resins
      category.
                              V-43

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                                       EXHIBIT V-K1

                            Environmental Protection Agency
                         PRODUCTION OF POLYURETHANES FOR
                         ADHESIVES, COATINGS AND SEALANTS
                          MANUFACTURE (Resin;  Compounded Basis)
                Total               Data
              Production          Source
               (Million
                Pounds)

1967             89               1
1968             76;  (71)          1;  (16)
1969             81;  (84)          1;  (16)
1970             95              16
1971             79;  (106)         1;  (4)
1972            116               4
1975            143              16
1977            177               4
                V-44

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2.     THERE ARE OVER 100 COMPANIES  PRODUCING COATING, SEALANT
      AND ADHESIVES  RESINS

      Exhibit V-K2 defines the producers of these resins and plant locations.

      According to the Chemical Economics Handbook^)

                 There are 22 companies producing urethane coating
                 resins for sale only.  They accounted for over 50% of
                 total urethane coating resin sales on a pound basis in
                 1969.

                 There are 43 companies that produce urethane coating
                 resins for sale as well as for their own captive use.
                 Collectively, they accounted for about 30% of total ure-
                 thane coating resin sales in 1969 on a pound basis.
                 The largest producers in this list are believed to be
                 Hughson Chemical, Poly vinyl Chemicals. K.J. Quinn,
                 Trancoa (largest), and  Wilmington Chemical.

                 Many coating companies have the capability of producing
                 the urethane coating resins that go into their coatings.
                 Companies producing urethane resins primarily for
                 captive use include, E.I. Du Pont de Nemours 5 Co., Inc.;
                 Mobil Oil Corp.; Montgomery Ward Co.;  Olin Corp.;
                 PPG Industries, Inc.; SCM Corp.; The Sherwin-Williams
                 Co.

           Over 80 Producers Of Urethane  Coating Resins Represent An
           Average Plant Capacity Of Roughly One Million Pounds Of
           Resin Per Year

           In the manufacture of polyurethane coating and miscellaneous
      resins, actual plant capacities are believed to be generally close to
      the industry average.
                            V-45

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                                                     EXHIBIT V - K2

                                              Environmental Protection Agency
                                              PRODUCERS:  POLYURETHANES14'8-14*
1.     22 Companies Produce Urethane Coating Resins For Sale Only And
       Account For Over 50% Of Total Urethane Coating Resin Sales On A
       Pound Basis In 1969
Companies and Plant Locations

Ashland Oil, Inc., Los Angeles, Calif.
               Newark, N.J.
The Baker Castor Oil Co., Bayonne, N. I.
The Biggs Co.. Santa Monica, Calif.
Cargill, Inc., Carpentersville, HI.
           Lynwood, Calif.
           Philadelphia, Pa.
Commercial Solvents Corp., Carpentersville, HI.
                      Chicago, m.
Diamond Shamrock Corp., Harrison, N.J.
France, Campbell &  Darling, Inc., Kenilworth, N.J.
General Latex and Chemical Corp., Ashland, Ohio
                           Cambridge, Mass.
General Mills,  Inc.,  Kankakee, ni.
The B. F. Goodrich Co., Avon Lake, Ohio
Hugh J. — Resins Co.,  Long Beach, Calif.
Interplastic Corp., Minneapolis, Minn.
Mobay Chemical Co.  /Naftone. Inc.. New Martinsville,
Companies and Plant Locations

Northeastern Laboratories Co., Inc., Melville, N. Y.
Purex Corp.,  Ltd., Chicago, 111.
Reichhold Chemicals, Inc., Azusa,  Calif.
                      Detroit, Mich.
                      Elizabeth, N.J.
                      Houston, Tex.
                      S. San Francisco, Calif.
                      Tacoma, Wash.
H. H. Robertson Co., Am bridge, Pa.
                 Saukville, Wise.
Textron Inc.. Bellevue, Ohio
Thiokol Chemical Corp., Trenton, H J.
Union Carbide Corp., Institute,  W. Va.
Witco Chemical Corp., Chicago, m.
                   Lynwood, Calif.
                   New Castle, DeL
WyandotteChemicals Corp., Wyandctte, Mich.
W.Va.
Of the companies just listed, the largest producers  Con a total pounds
basis) are believed to be (in decreasing order of production volume)
Spencer Kellogg Division of Textron, Reichhold, Cargill, Ashland, and
Mobay.  Spencer Kellogg is the largest producer of urethane alkyds;
Reichhold is the largest producer of moisture-curing prepolymers; and
Mobay is the largest producer of phenol-blocked prepolymers and two-
package prepolymer-polyol systems. B. F. Goodrich and Spencer Kellogg
are the leading suppliers of urethane thermoplastic lacquer resins. Nopco
Chemical Division of Diamond Shamrock and Wyandotte Chemicals are the
major producers of urethane latices.
                                V-46

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                                                         EXHIBIT V-K2  (continued)

                                                  Environmental Protection Agency
                                                  PRODUCERS:  POLYURETHANES (4 •8 •
2.     43 Companies Produce Urethane Coatings Resins For Sale And Captive
       Use And Account For About 30% (by weight) Of Total Urethane Coating
       Resin Sales In 1969

Companies and Plant Locations                  Companies and Plant Locations

Allied Products Corp., Long Island City. N. Y.      The P. D. George Co., St. Louis, Mo.
John L. Armitage & Co., Newark. N. J.           The Goodyear Tire & Rubber Co., Akron,  Ohio
                      Elk Grove,  111.          Grow Chemical Corp., St. Louis, Mo.
                      Richmond,  Calif.        Hoover Ball and Bearing Co., Ann Arbor, Mich.
Ball Chemical Co., Glenshaw. Pa.               Inrilco Corp., Chicago, 111.
Bay State Chemical Co., Leominster, Mass.       Isochem  Resins Co., Lincoln, R. I.
Beatrice Foods Co., Wilmington, Mass.           Jewel Paint & Varnish Co.. Chicago, m.
Celanese Corp., Los Angeles, Calif.              Kohler- Me Lister Paint Co., Denver, Colo.
               Louisville,  Ky.                 Lord Corp.,  Saegertown.  Pa.
               Newark,  N.J.                  Lu-Sol Corp., El Monte,  Calif.
Chem Seal Corp. of America, Los Angeles. Calif.   Mr Plastics and Coatings, Inc., Maryland Heights,  Md.
Conchemco Inc., Baltimore, Md.               McCloskey Varnish Co.. Los Angeles, Calif.
                Kansas City, Mo.                                   Philadelphia,  Pa.
Continental Poly mere Corp., Santa Ana, Calif.                          Portland. Ore.
Cook Paint & Varnish Co.,  Detroit, Mich.        Midwest Mfg. Corp., Burlington, Iowa
                        Houston,  Tex.         Minnesota Mining and Mfg. Co., Decatur, Ala.
                        North Kansas City, Mo. National Lead Co., Philadelphia, Pa.
De Soto. Inc., Berkeley, Calif.                                  San Francisco, Calif.
              Chicago Heights, 111.             Occidental Petroleum Corp.. HicksviUe, N. Y.
              Garland, Tex.                   C. J. Osborn Chemicals, Inc., Pennsauken, N.J.
The Dexter Corp.,  El Monte. Calif.              Poly Resins,  Inc., Sun Valley,  Calif.
                  Olean,  N. Y.                 Prime Leather Finishes Co., Milwaukee, Wise.
                 Cleveland, Ohio              Products Research & Chemical Corp., Maiden, Mass.
                  Hayward, Calif.                                             Seabrook, N. H.
                  Los Angeles. Calif.           Schenectady  Chemicals,  Inc.,  Schenectady, N.Y.
                  Rocky Hill, Conn.            Sta-Crete, Inc., San Francisco, Calif.
                  Waukegan, m.               A. E. Staley Mfg.  Co., Marlboro, Mass.
Emerson & Cuming. Inc., Canton, Mass.         Trancoa Chemical  Corp., Reading, Mass.
The Epoxylite Corp., El Monte, Calif.           Westinghouse Electric Corp., Manor, Pa.
Farnow. Inc., South Kearny. N.J.               Wilmington Chemical Corp..  Wilmington, Del.
Furane Plastics.  Inc.,  Los Angeles, Calif.        Woburn Chemical Corp.,  Harrison,  N. J.
The largest producers of urethane coating resins in the preceding list are
believed to be Hughson Chemical, Polyvinyl Chemicals, K. J. Quinn,
Trancoa (largest), and Wilmington Chemical.
                                    V-47

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                                                       EXHIBIT V-K2 (continued)

                                                Environmental Protection Agency
                                                PRODUCERS:  POLYURETHANES (4,8,14)
 3.     Companies Producing Urethane Coating Resins Primarily For
       Captive Use

       Many coating companies have the capacity to produce the urethane
       coating resins that go into their coatings.  The extent of their
       coating-resin production depends both on the  volume of their ure-
       thane coatings sales and on the price situation in the urethane
       coating resin market.  Currently, the following  18 companies
       are known to be producing some or all of their urethane coating
       resin requirements.


 Companies and Plant Locations                       Companies and Plant Locations

 American Herberts Corp.. Woodside, N.Y.             Olin Corp., Rochester, N. Y.
 American Pipe & Construction Co., Brea. Calif.          PPG Industries, Inc., Circleville. Ohio
 Armstrong Chemcon. Inc., Chicago, m.                                Houston, Tex.
 Beatrice Foods Co., Peabody, Mass.                                    Milwaukee, Wise.
 Chemical Coatings & Engineering Co., Media, Pa.                          Springdale, Pa.
 Defiance Industries. Inc., Baltimore, Md.                               Torrance, Calif.
 E. I. Du Pont De Nemours & Co., Inc., Chicago, Ql.                         Cleveland, Ohio
                              Fort Madison, Iowa    Preservative Paint Co., Seattle, Wash.
                              Parian, N.J.         Raffi and Swanson, Inc., Wilmington, Mass.
                              Philadelphia, Pa.     SCM Corp.,  Chicago,  fll.
                              S.San Francisco, Calif.            Cleveland, Ohio
                              Toledo. Ohio                  Reading, Pa.
                              Tucker, Ga.                   San Francisco, Calif.
 Marcor, Inc., Chicago, HI.                         The Sherwin-Williams Co. .Chicago, HI.
The Master Mechanics Co.,  Cleveland, Ohio                                  Cleveland, O.
 Minnesota Paints,  Inc., Fort Wayne, Ind.                                    Emeryville, Calif.
                    Minneapolis, Minn.                                  Garland, Tex.
 Mobil Oil Corp., Cleveland,  Ohio                                         Los Angeles, Calif.
 Norris Paint & Varnish Co.. Inc.,  Salem, Ore.                                Newark, N.J.
                                  V-4B

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                   V-L  CELLULOSICS
      The cellulosic plastics of interest are the acetates and mixed esters
of cellulose and cellulose nitrate.

1.    CELLULOSICS ARE A  RELATIVELY LOW VOLUME PLASTIC

      Cellulosics are considered low volume plastics as compared to others,
and production amounted to only 190 million pounds in 1972. Production has
been somewhat irregular for  the period 1967-1972 showing an average annual
growth of 2.2% per year as shown in Exhibit V-l.

           Cellulosics Will Grow  At A Modest 2-3% Annually

      The almost 10% growth in cellulosic resin uses in 1972 will probably
      not be maintained. This growth was principally in molding and ex-
      trusion uses where the immediate advantage was in the biodegradability
      aspects of the resin. In the long run, ABS resins will probably continue
      to replace Cellulosics.
2.    THERE ARE 6 PRODUCERS OF CELLULOSICS

      The U.S. Tariff Commission (1970) reports nine producers. However,
we have been able to locate only 6 producers operating at 8 locations as
shown in Exhibit V-L.

      (1)    The Majority Of Operating Locations Are Concentrated On
            The Atlantic Coast

            Most of the plants are located in New Jersey, Maryland,
      and Massachusetss.  The largest plant, probably accounting for more
      than 50% of total production, is operated by Eastman Chemical Products,
      Inc. atKingsport, Tennessee.

      (2)    Plant Capacities Are Confidential

            Because of the large share of production accounted for by a single
      producer, plant capacities are not available.  It is believed that Eastman
      Kodak may account for over 50% of production.
                              V-49

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                       EXHIBIT V - L

            Environmental Protection  Agency

              PRODUCERS:   CELLULOSICS{8)
Celanese Corp.
      Belvidere, N.J.
      Cumberland, Md.
      Newark, N.J.

Marcor Inc.
      Linden,  N.J.

The Richardson Co.
      Kearny,  N.J.

Standard Pyroxoloid Corp.
      Leominster, Mass.

Tenneco Inc.
      Nixon, N.J.

Eastman Kodak Co.
      Kingsport, Tenn.
Other companies reported producing
cellulosics are:

Dow Chemical  Company
Hercules Inc.
Monsanto Company
Rosenberg Bros. 6 Company
Textron Inc.
      V-50

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                      V-M  EPOXY RESINS
      Epoxy resins are thermosetting resins which, in the uncured form,
contain one or more reactive epoxide or oxirane groups. These groups
serve as cross-linking points in the subsequent curing step, in which the
uncured epoxy resin is reacted with a curing agent or hardener, generally
an amine or anhydride, although other hardeners containing active or reac-
tive hydrogens are also used.

      Epoxy resins are usually based on the reaction of epichlorohydrin and
Bisphenol A.  About 90% of all unmodified epoxy resins produced are of this
type.  Other types include glycidyl compounds, epoxidized olefins, linear
aliphatic epoxides and others.

      In addition to the unmodified resins discussed briefly above, modified
epoxy resins are also produced. Modified resins are, in general, produced
by reacting unmodified epoxy resins with unsaturated fatty acids, rosin acids,
tall oil and similar materials. In many cases these modified epoxies are fur-
ther modified with melamine or urea resins.

1.    THE VOLUME OF EPOXIES PRODUCED IS SMALL

      Domestic production of epoxy resins for the 1967-1972 period increased
from 135 million pounds in 1967 to  174 million pounds in 1972, a compounded
growth rate of 5.2%. Growth in 1972 was only slightly better — 4.2%. Pro-
duction for the period 1967-1972 is shown in Exhibit V-l.

           Epoxy Resin Consumption Will Continue At About The Same
           Rate As In 1972
           These resins should be considered as specialty resins because
      of their high price, and special end uses such as encapsulating elec-
      tronic components,  high performance adhesives, filament winding of
      vessels and pipes and reinforced plastic circuit boards.  As long as
      raw material prices remain at their high levels, epoxy prices will
      remain high resulting in low volume uses.  Growth over the near term
      should be 5% per year or less.
2.    ONLY 7 COMPANIES PRODUCE UNMODIFIED EPOXIES

      These 7 producers operate plants .at 8 locations.  Exhibit V-M
lists locations and plant capacities of producers.
                              V-51

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                                   EXHIBIT V - M

                         Environmental Protection Agency

                         PRODUCERS :  EPOXY RESINS (14)
Company and Location

Celanese Corporation
  Louisville, Ky.

Ciba Corporation
  Toms River, N.J.

The Dow Chemical Company
  Freeport, Texas

Reichhold Chemicals, Inc.
  Ballard Vale, Mass.

Resyn Corporation
  'Linden, New Jersey

Shell Oil Company
  Houston, Tex.

Union Carbide Corporation
  Marietta, Ohio
  Bound Brook, N.J.

           TOTAL
Estimated Capacity,
   April 1970
(Millions of Founds
   Per Year)

      35
      60
      50
      12
      25
      88
      26
     296
                 V-52

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      (1)    About 85% Of The Production Capacity Is Located In Two
            States

            The major share of production capacity is located in Texas and
      New Jersey. The remaining capacity is located in Kentucky, Massa-
      chusetts , and Ohio.

      (2)    Production Capacity Has Generally Been Appreciably
            Larger Than Actual Production

            Most of the extra capacity is required to permit production
      changeovers for the manufacture of different types of epoxy resins.
      We estimate overall utilization to be at 70-75% of installed capacity.

            Based on plant utilization then, the largest plant would be
      producing about  64 million pounds, while the smallest would be
      producing less than 10 million pounds per year.
3.    MODIFIED EPOXIES ARE PRODUCED IN OVER 100 LOCATIONS

      The total volume of modified epoxies produced is very small — probably
less than 5% of the volume of unmodified epoxies.  The principle use for these
products is as adhesives which are packaged for retail consumer use.
                              V-53

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                   V-N POLYAMIDES
      Folyamide resins are polymers in which recurring amide groups form
an integral part of the main polymer chain. They are of two main types:
(1) nylon resins which are used to make the well-known nylon fibers and
plastics, and (2) those which are made by the condensation of polycarboxylic
acids with polyamines, and which are called non-nylon resins.

1.    THE OUTPUT OF POLYAMIDE RESINS FOR NON-FIBER USE IS LOW

      Only 115 million pounds of polyamide resins were produced in 1972
(nylon resins used to make fibers are not included).  This, however,  was an
increase of 15% over 1971 and somewhat better than the average annual growth
rate of 12.8% for the period 1967-1972.  Production for the period 1967-1972 is
shown in Exhibit V-l.

            Polyamide Consumption Will Increase At A Slower Rate

            Nylon resins must compete with other plastics, notably acetal
      and polycarbonate resins, and their use depends on cost/benefit
      performance.  Nylon resins are also relatively high priced, and
      therefore it is doubtful that large volume uses will be uncovered.

            Non-nylon resins are very seldom used alone, and can be
      used in combination with less expensive resins such as  phenolics,
      urea-formaldehydes, etc. They therefore find a greater variety of
      uses, yet must still be considered specialty resins.

            It is believed  that polyamide resins, as a whole, will probably
      grow at the rate of 8-10% per year in the foreseeable future.
2.    THERE ARE 8 PRIME PRODUCERS OF POLYAMIDE RESINS

      The prime producers of polyamide resins are those companies producing
Nylon 6 and/or 66 for fiber use. These companies producing for plastic appli-
cations have a total capacity of over 136 million pounds per year and produce
at 10 locations as listed in Exhibit V-N.

      There are considerably more producers of non-nylon polyamide resins.
Total production capacity, we believe, is less than 40 million pounds and
producers and plant locations are listed in Appendix  1.
                              V-54

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                                                EXHIBIT  V - N

                                      Environmental Protection Agency

                                       PRODUCERS:  POLYAMIDE RESINS (8)
                                                  Estimated Capacity
Nylon 66 Type                                     (million pounds)

      El Paso Natural Gas.,  Etowah,  Tenn.                 2
      Celanese Corp.  Deer Park,  Tex.                     n.a.
                     Louisville,  Ky.                      12
      Du Pont, Parkersburg, W. Va.                       70
      Monsanto Co.,  Pensacola, Fla.                        25+

Nylon 6 Type

      Allied Chemical Corp., Chesterfield,  Va.              15
      Firestone Tire  6 Rubber Co., Pottstown, Pa.            2
      Foster Grant Co., Leominster,  Mass.                 n.a.
                        Manchester, N.H.                  5+
      Custom Resins,  Henderson,  Ky.                       5
                                        Total            136+
Reported producers of non-nylon polyamide resins^  are
listed in Appendix 1.
                             V-55

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      Production Capacities Vary Widely
      Company nylon polyamide resin capacity varies from 2 million
pounds to 70 million pounds per year. These capacities are probably
quite flexible.

      Company non-nylon polyamide capacity  also varies widely.
Companies such as General Mills, Emery Industries, Stepan Chemical,
Epoxy lite'and Celanese probably have the bulk of the capacity.  Aver-
age individual capacities for these five companies is probably in the
order of 5 million pounds each.  The remaining companies share the
rest and probably average less than 0.5 million pounds each.
                         V-56

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                 V-O ROSIN MODIFICATIONS
      Rosin modifications are thermoplastic resins and are usually
prepared by esterification of rosin acids with glycerol or other alcohols.
The process not only esterifies but polymerizes the rosin acids.

1.    ROSIN ESTER  PRODUCTION HAS BEEN DECLINING

      Rosin ester production has been erratic since its high of 152 million
pounds in 1962, but is declining. In 1972 production was only 95 million pounds,
slightly higher than the 89 million pounds the previous year.  For the period
1967-1972 production declined at an average compounded annual rate of 6.5%
per year.  Exhibit V-l shows yearly production rates for this period.

            Consumption Will  Continue To Decline

            Rosin esters have few uses,  and are used in relatively small
      amounts in various formulations, particularly varnishes, lacquers
      and other coatings, to impart special properties. Many of these coat-
      ings are being replaced, and rosin esters will find fewer markets.
      We expect rosin production to decline at the rate of about 1% per year
      through 1977.
2.    THERE IS AN EXTRAORDINARILY LARGE NUMBER OF PRODUCERS
      FOR THE SMALL VOLUME OF ROSIN ESTERS AND ADDUCTS
      PRODUCED

      There are 36 companies producing 97 million pounds of rosin esters
and adducts at 71 locations as shown in Exhibit V-O.  Most of the producers
are alkyd producers and/or suppliers to the coatings industry.

           Plants Are Widely Scattered

           Rosin ester producers are usually alkyd or coatings producers.
      The latter are located near their customers.
                              V-57

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                                                                   EXHIBIT V  - O
                                                           Environmental Protection Agency
                                                           PRODUCERS :    ROSIN ESTERS
                                                           AND ADDUCTS
                                                                             (8)
Carpenter Morton Co., Everett, Mass.
Celanese Corp., Newark, N. J.
Conchemco Inc.,  Baltimore, Md.
The Dexter Corp.,  Rocky Hill,  Conn.
Eastern Color & Chem. Co.,  Providence, R. I.
Farnow, Inc., South Kearny, 'N.J.
Lawter Chems. Inc.,  South Kearny, N.J.
McCloskey Varnish Co.,  Philadelphia, Pa.
Benjamin Moore & Co.,  Newark, N. J.
The O'Brien Corp., Baltimore,  Md.
Onyx Oils & Resins, Inc., Newark,  N. J.
C. J. Osborn Chems.  Inc., Linden, N. J.
PPG Indust., Inc.,  Springdale,  Pa.
Reichhold Chems., Inc.,  Elizabeth,  N. J.
Rohm and Haas Co., Philadelphia,  Pa.
Schenectady Chems., Inc.,  Rotterdam Junction. N. Y.
                          Schenectady,  N. Y.
Shanco Plastics & Chems., Inc., Tonawanda, N.Y.
Union Carbide Corp., Bound  Brook, N. J.
Ashland Oil, Inc.,  Pensacola, Fla.
Celanese Corp., Louisville,  Ky.
Crosby Chems., Inc. ,• De Ridder, La.
                     Picayune, Miss.
De Soto, Inc., Garland,  Tex.
Dixie Pine Products Co.,  Inc.,  Hattiesburg, Miss.
Gilman Paint & Varnish Co., Chattanooga, Tenn.
Hercules, Inc., Hattiesburg)  Miss.
Monsanto Co., Baxley, Ga.
PPG Indust., Inc.,  Atlanta (East Point),  Ga.
                  Houston,  Tex.
Reichhold Chems., Inc.,  Houston, Tex.
Union Camp Corp., Savannah,  Ga.
                   Valdosta, Ga.
Valentine Sugars, Inc., Lockport, La.
Westvaco Corp.,  Charleston Heights, S. C.
Conchemco Inc., Detroit, Mich.
                Kansas City, Mo.
Cook Paint & Varnish Co., North Kansas City, Mo.
De Soto, Inc., Chicago Heights, m.
The Dexter Corp., Cleveland, Ohio
                 Waukegan, HI.
Guardsman Chem. Coatings, Inc.,
              Grand Rapids, Mich.
Internat'l Miherals&Chem. Corp., Bensenville, 111.
Midwest Mfg. Corp., Burlington,  Iowa
Benjamin Moore & Co., Cleveland,  Ohio
                      St.  Louis, Mo.
The O'Brien Corp., South Bend, Ind.
PPG Indust. Inc.. Cleveland, Ohio
                Milwaukee,  Wise.
Pacific Holding Corp., Chicago, 111.
Purex Corp., Ltd., Chicago, 111.
Reichhold Chems., Inc., Cicero,  111.
Benjamin Moore & Co., Denver, Colo.
                      Los Angeles, Calif.
Napko Corp., Emeryville, Calif.
The O'Brien Corp., South San Francisco, Calif.
PPG Indust.,  Inc., Torrance, Calif.
Preservative  Paint Co.,  Seattle, Wash.
Re'ichhold Chems., Inc., Azusa, Calif.
                       S. San Francisco,  Calif.
De Soto, Inc., Berkeley, Calif.
The Dexter Corp., Hayward, Calif.
McCloskey Varnish Co., Los Angeles, Calif.
                       Portland, Ore.
                                             V-58

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                    SECTION VI

GENERAL PROFILE OF THE CHEMICAL/PLASTICS INDUSTRY REGARDING
     PROCESS TECHNOLOGY AND AIR POLLUTANT EMMISSIONS

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                          SECTION VI

   GENERAL PROFILE OF THE  CHEMICAL/PLASTICS INDUSTRY
REGARDING PROCESS TECHNOLOGY AND AIR POLLUTANT EMISSIONS'
      This section presents our findings concerning the processing aspects of
 each of the major plastics and resins manufactured in the United States.

      The information regarding the process technology associated with the
 manufacture of each plastic was compiled from published information.  We
 believe the state-of-the-art is generally described, but particularly newer
 installations may feature appreciably different design and operating conditions
 that are proprietary and are, therefore, not described  in the literature.

      General process descriptions for the following plastic/resin groups are
 described.

             A -  Polyethylene and Copolymers
             B -  Vinyl Resins
             C -  Styrene Resins
             D -  Polypropylene
             E -  Phenolic and Other Tar Acid Resins
             F -  Polyesters
             G -  Amino Resins
             H -  Alkyds
             I  -  Acrylics
             j  -  Coumarone-Indene and Petroleum Resins
             K -  Polyurethanes
             L -  Cellulosics
             M - Epoxy Resins
             N   Polyamides
                               VI-i

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               VI-A  POLYETHYLENE AND COPOLYMERS

      There are two basic types of polyethylene (PE) resins available - high
density (HOPE) and low density (LDPE), the latter accounting for about 69%
of total PE capacity.


1.    LDPE PRODUCTION IS A HIGH TEMPERATURE,  HIGH PRESSURE
      CONTINUOUS PROCESS

            All high-pressure PE plants have similar complexities.

            All high-pressure polyethylene plants have roughly similar
      complexities in terms of gas compression and recycling systems as
      well as handling of the product. There are,  however, two major
      differences in the types of reaction vessels used which may be either
      the stirred autoclave or tubular design. A generalized flow sheet is
      shown in Exhibit VI-A 1. (lfl) The process starts with the compression
      of purified ethylene to between 1,000 and 3,500 atm. Initiators  ,
      are introduced into the compressed gas stream or into the reaction
      vessel, before which the gas may be optionally heated to 100-200°C.
      Water and solvents may also be introduced at this stage.  Following
      polymerization at conversions  of between 6 and 25% and the optional
      removal of water and solvents, the principal separation of ethylene
      from polyethylene takes place  at between 100 and 500 atm, followed
      by the final separation at much lower pressures.  Unreacted ethylene
      is recycled to the secondary compressor after cooling to provide
      correct conditions at the intake of the compressor.  At the cooling
      stage a small quantity of low-molecular-weight material may also be
      removed although this is not the purpose of return gas cooling.

            The polymer is then extruded into strands  or ribbons. chilled
      and pelletized.  PE is sold as a natural product or reprocessed with
      various pigments, stabilizers, slip agents, etc.

2.    HDPE PRODUCTION IS A RELATIVELY LOW TEMPERATURE. LOW
      PRESSURE  PROCESS WHICH CAN  BE  EITHER  CONTINUOUS  OR
      BATCH

      HDPE is manufactured  either by solution or slurry type of polymeriza-
tion (vapor phase plants are being used in some foreign operations) using
either a Phillips or Ziegler type catalyst. Based on various information sources,
the producers and plant locations by type of catalyst are listed below.
                               VI-2

-------
                                                      EXHIBIT VI-A1
                                      Environmental Protection Agency
                                                      FLOW SHEET:
                                      LD POLYETHYLENE PRODUCTION
                                           (High Pressure Process)
Pine clh|lcne
                 so-looo in/in'
Lo» pressure
500-3400 a tm
     T
      i
      t
                                                                 Prchealer
                        I	Initiator  -—'
                                      Stirred
                                     autoclave
                             Solvent
                             and water
                       Tube
                            Sewialor
                         50-1000 atm
               fielurti
                jas
               cooler
                          I
                    T
                COOlel

                                 Lo«-pressuie
                                  separator
                             T
                                                                             Water
                                                                  Reactor
|~] Decanter
                                      -*• Molten product Icr granulation and blending
                             llii;h-)ii<.—iinu jKilMjilivk-iu1 -v

-------
Manufacturer            Plant Location     Type of Catalyst System

Phillips Petroleum       Pasadena, Texas       Phillips
Celanese Corporation    Deer Park, Texas       Phillips
Union Carbide Corp.     Seadrift, Texas         Phillips
Allied Chemical          Baton Rouge, La.       Phillips
National Petro-Chem     Deer Park, Texas       Phillips
Chemplex Company      Clinton, Iowa           Phillips
Dow Chemical Company   Freeport, Texas        Ziegler
duPont                  Orange, Texas         Ziegler
                        Victoria, Texas
Monsanto                Texas City, Texas      Ziegler
Sinclair-Koppers Co.    Port Arthur, Texas     Ziegler

(1)   The Polymerization Of PE  Using  The Phillips Catalyst Can
      Be  By A Solution Or  Slurry Process

      In a typical solution process as shown in Exhibit VI-A2(19)
the catalyst, hydrocarbon solvent boiling in the range of 60 - 90°C.
and ethylene or comonomer are fed together into the reactor. Poly-
merization takes place in the reactor held at 125 - 175°C and pressures
of 20-30 atm at a residence time of 1 - 3 hours. The effluent stream
from the reactor is passed through flash or fractionation steps to
remove dissolved ethylene which is recycled to the reactor.  The
polymer-solvent solution is diluted and the catalyst removed  by fil-
tration or  centrifugation operating at 150°C and 20-30 atm pressure.
The polymer is precipitated from  solution by contacting the polymer
solution with water, or by cooling the solution by partial evaporation
of the solvent at low pressure; the solvent being recycled to the reaction
area following removal of water and polymer impurities. The polymer
is dried, extruded and palletized in conventional equipment; anti-
oxidants,  heat stabilizers and other additives may be added during
the extrusion step.

      The particle form  (PF) or slurry process is shown schematically
in Exhibit VI-A2 and consists of the following steps:  the catalyst,
ethylene and hydrocarbon diluent are fed continuously to a liquid-full
reactor at temperatures of 100-110°C ,  pressure and residence time of
20-30 atm  and 1 .- 4 hours respectively. The effluent from the reactor
is removed through a quiescent zone and the low-boiling diluent and
dissolved  ethylene flash, and are separated and recycled.  The
remaining hydrocarbon is removed from the polymer in auger-dryers
which convey the polymer to storage.
                         VI-4

-------
                                                          EXHIBIT VI-A2
                                           Environmental Protection Agency
                                                          FLOW SHEET:
                                           HD POLYETHYLENE PRODUCTION
                                           (Phillips Solution and Slurry Processes)
Solvent
               Catalyst
               storage
   Catalyst
I-   feeder
     Elhylene and
      comonomer
                                  Etlv/lcne and
                                  comonomer
                                    recycle
                                                        Solvent
                                                        recycle
                                         Catalyst
                                         discard
                                                          Finished
                                                           resin
                                                                     Bagging
                               Phillips Mllllllllll (Illll O-
         Diluent-
                        Catalyst
                        storage
                         Catalyst feeder
                           Stirred
                           reactor
                                         o
                   Ethylene and _
                    comonomer"
             Slimy imlynicfu.il ion
Diluent, elhylene
and comonomer
   recycle
                                                         Flash
                                                     V  V V V

                                                       Drier
                                                             Resin
                                                 (I'lnlliji-).
                                     VI-5

-------
      (2)   PE Polymerization Using The Ziegler Catalyst Is A Slurry
           Process

           The flow diagram for this process is very similar to the
      Phillips process and is shown in Exhibit VI-A3. (2°) The greatest
      variations plant to plant are the washing and purification sections
      and are largely dependent upon solvent and alcohol supplies.
      Reaction temperatures vary from 50 - 90°C with pressure of less
      than 5 atm and residence time from 1/4  - 2 hours. Continuous
      reaction at 30% solids is considered very good.
3.    INITIATORS  AND/OR CATALYST ARE USED FOR PE POLYMERIZATION

      (1)    LDPE Is Produced By  High Pressure Free Radical
            Polymerization

            The initiators used are usually "oxygen supplying" products
      including small amounts of oxygen, oxides of nitrogen, organic
      peroxides, and others.  Numerous initiators are available, and each
      company has its own product(s)  and this information is confidential.
      Chain modifiers are also used and include solvents, diluents, co-
      monomers , inhibitors, and others.

      (2)    HOPE  la A Catalytic Polymerization

            The Phillips process is usually based on a chromium oxide
      and silica-alumina gel,  silica gel or other substrate.

            Generally, Ziegler catalysts result from the reaction between
      compounds of transition elements in groups IV-VIII and compounds
      chosen from  the hydrides and alky Is of elements in groups I-III
      which are  capable of producing carbanions  or hydrides.  Typical
      catalysts include aluminum isopropyl or isobutyl with combinations
      of TiCl4 andV C15.
4.    THERE ARE SEVERAL POTENTIAL EMISSION SOURCES

      Emissions are present both inside and outside the plant.

      (1)    In-Plant Emissions Can Occur As A Result Of Manufacture

                  Vapors escape from valves, line and pumps.
                              VI-6

-------
                                               EXHIBIT VI-A3
                                 Environmental Protection Agency
                                               FLOW SHEET:
                                 HD POLYETHYLENE PRODUCTION
                                         (Ziegler Slurry Process)
HYDROCARBON 1
  SOLVENT  t
 TRANSITION 1
 METAL MAUDE J
  ALUfcMNUM
  ALKYL
 CATA~YST
  MODIFIER
 (OPTIONAL)
                                 DRY HYDROCARBON SOLVENT
        SEQUESTERING AGENT
   PRODUCT FINISHING
(COMPOUNDING 8 BAGGING)
SOLVENT
                  A 1} pieal Mow (hngrnin—//n-filcr puljotlijlcnc plant.
                             VI-7

-------
                 The drying equipment may be a major source.

                 Reactor and separator venting contributes sub-
                 stantially •

      (2)    Emissions Are Noticeable Outside  The Plant

                 Odorous products produced by decomposition are
                 vented to the air.

                 Because of the flammability and explosiveness of
                 ethylene, the air in the plant is ventilated by large
                 volumes of air and vented to the outside.
5.    THERE ARE THREE PRINCIPAL  EMISSIONS

            Polymerization Recipes Are Varied And Secret, But In
            General,  The Following Emissions Are Noticeable

                  Solvents in the drier area.

                  Catalyst odors.

                  Hydrocarbon decomposition odors due to
                  strenuous operating conditions.


6.    PLANT SAFETY IS DILIGENTLY PRACTICED

      Safety is practiced mainly from an explosive and fire viewpoint.
However,  the instrumentation for detecting leaks of raw materials, process
stream instrumentation,  explosion proof equipment, use of non-sparking
tools, contribute to keeping odors and emissions to a minimum.

      The exhaust systems installed in plants contribute to outside odor
problems.
                              VI-8

-------
                     VI-B  VINYL RESINS
      The most important resin of this group is that produced by polymeriz-
ing vinyl chloride alone or with another comonomer such as vinyl acetate,
vinylidene chloride, etc.  These resins are considered as poly vinyl chloride
(PVC) resins if the vinyl chloride content is over 50%.

      Two other vinyl resins are important — poly vinyl acetate (PVAc) and
polyvinyl alcohol (PVA) and will be discussed here.
1.    ALL VINYL CHLORIDE POLYMERIZATION  IS CONDUCTED AT LOW
      TEMPERATURE AND PRESSURE AS BATCH OPERATIONS

      The two most important methods of preparing PVC in the United States
are the suspension and bulk polymerization methods although some emulsion
polymerization capacity is still in operation.

      (1)    Probably  80% Or More Of The PVC Produced Is By
            Suspension Polymerization

            A schematic diagram of a typical suspension polymerization
      process is shown in Exhibit VI-B1. (21) Most reactors in use are water-
      jacketed and glass-lined ranging from 2,000 - 6,000 gallon capacity.
      The desired quantity of monomers (s) is measured in the weigh tank
      and transferred to the reactor containing the proper amount of water.
      Ratios of water to vinyl chloride range  from 1.5:1 to 4:1.  Initiators
      such as lauroyl peroxide or azobisisobutyronitrile, suspending agents
      such as polyvinyl alcohol, gelatin or methylcellulose and buffers are
      charged into the reactor.  Agitation is started and the mixture brought
      up to 45-55°C until polymerization is carried to 90% conversion.  Cooling
      water is used to remove the heat of polymerization. The mixture is then
      transferred to the dump tank, where it is stripped of unreacted monomer
      by the application of vacuum.  This monomer is recovered and recycled.
      The bulk of the water is separated in a centrifuge and the resin dried
      in a stream of hot air in a rotary drier.  The product is separated from
      the wet air stream in a cyclone separator,  from which it is screened and
      sent to storage.  The wet air stream containing the fines is passed
      through a filter.
                              VI-9

-------
                                                   EXHIBIT VI-B1
                                      Environmental Protection Agency
                                                   FLOW SHEET:
                                      POLYVINYLCHLORIDE PRODUCTION
                                        (Suspension Polymerization Process)
                           Hixovcivd vinyl clilmiclc
                                             Crude vinyl chloride       -f
                                               Storage unk    r	-fS
                                                        rvT
                                                              Rcboilcr
 JIUl
dcacralcd
 water
                                                     PVC 10 storage
     buuiililicd flow diugmm uf a Initcli-t.ypo Bi^pcnsioii-pulyiuciuuliDit plant.
                                  VI-10

-------
      (2)   The Next Most Important Polymerization Is  Bulk
            Polymerization

            A simplified flow diagram of a two-step bulk polymerization
      plant is shown in Exhibit VI-B2. ^2) Monomer is pumped into a
      prepolymerizer (a vertical stainless steel-clad vessel equipped with
      a flat-blade turbine stirrer and baffles),  and converted to polymer
      at a conversion of only 7-10% at temperatures of 40-70°C. The
      mixture from the prepolymerizer, together with an equal amount of
      fresh monomer, are transferred to the autoclave. a horizontal reactor
      equipped with slowly rotating agitator blades. Reaction time is
      5-9 hours.  Unreacted monomer is removed by vacuum and recovered
      by vapor compression and condensation in the recycle condenser.
      The resin is transferred to the resin receiver by means of an air
      eductor.

      (3)   Emulsion Polymerization Is  Also Used

            Vinyl chloride is emulsified in water using surface active
      agents. Initiator is added and the contents stirred gently at 40-55°C
      for 12-18 hours.  The resultant latex is stripped of monomer.  The
      latex is usually spray dried.
2.    POLYVINYL ACETATE (PVAc)  IS GENERALLY PRODUCED BY LOW
      TEMPERATURE BATCH POLYMERIZATION OF VINYL ACETATE

      While vinyl acetate can be produced by bulk,  solution, suspension and
emulsion polymerization techniques, we believe over 90% is produced by emul-
sion techniques as shown in the schematic in Exhibit VI-B3. <23) Exhibit VI-B4(24)
and VI-B5C25) are schematics for a solution and bulk polymerization process.
The latter two processes will not be discussed here.

     FVAc is prepared and sold as a 55% water emulsion. The average
batch size will range from 500 - 2,000 gallons.  Polymerization is conducted
at vinyl acetate/water reflux temperature of 67 - 80°C.  Copolymers can be
produced in the same equipment and fashion. Reaction time is about 5 hours.
The emulsion is then cooled to room temperature in the reactor and trans-
ferred to drums or storage vessels.
                               VI-li

-------
                                   EXHIBIT VI-B2
                     Environmental Protection Agency
                                   FLOW SHEET:
                     POLYVINYLCHLORIDE PRODUCTION
                       (Bulk Polymerization Process)
                                                  (22)

\
V
D|
•==
u<
Pn-|iUlv
T
dim
fl
Cf
Ccmd
unsci
1
«H*r
1
V*uu...
<•> VJI..K
^~\ r— -, C'jiwwi
^^ "T" Older
/— . ^^ IIIC5-.


/A Dusl
SCIIH
r>ilur
Aiiluclju1
                    To rcsiri
                    rccPiwsr
  Edjclor

ill ;i tuti—
                                                  Vent
                                         FIUIII vinyl
                                         clilundc
                                         slorjyo
                                         Uink
                                         HIH:VI lu vinyl
                                  Ojy Uill
                                       j
                                 Vinyl chlonilo
                                  lecd pump
               caitiun /VoccBsinj.
                                                   , Hydro-
                  VI-12

-------
                           EXHIBIT VI-B3
              Environmental Protection Agency
                           FLOW SHEET:
              POLYVINYL ACETATE PRODUCTION
(23)
                 (Emulsion Polymerization Process)
                                                   REACTOR
                                                   950 GAL WORK CAP
                                                   73OOAL TOTAL CAP
                                                      -OR-
                                                     ANT SIZE
                                                     REQUIRED
Polyvinyl acetate emulsion unit (Courtesy Star Tank and Filler Corp )
          VI-13

-------
                        EXHIBIT VI-B4
              Environmental Protection Agency
                        FLOW SHEET:
           POLYVINYL ACETATE PRODUCTION
               (Solution Polymerization Process)
                        i MEASURING T«N«
PRODUCT       ~_'
            3 ADJUSTING TANKS

rss for vinyl acctal.c solution polymers .
   VI-14

-------
                                        EXHIBIT VI-B5
                           Environmental Protection Agency
                                        FLOW SHEET:
                           POLYVINYL ACETATE PRODUCTION   S)
                              (Bulk Polymerization Process)
SCREEN FILTEflS
                          ENDLESS SreEL BELT WITH
                          *iR COQUliO ft>*D CUIItR
                                ftTTACHEO
      Continuous process for bulk pol3*nicrization of vinyl acetate*
                        VI-15

-------
3.    POLYVINYL ALCOHOL (PVA) IS PRODUCED BY ALCOHOLYSIS OF
      PVAc AND CAN BE CONTINUOUS OR BATCH PROCESS CONDUCTED
      AT LOW TEMPERATURE

      The PVAc used must be beads and contain less than 1% water. The
PVAc is probably made by suspension techniques.  A schematic of PVA plant
is shown in Exhibit VI-B6. <26)

      PVA is prepared in different grades and is a function of degree of
alcoholysis.  PVAc beads are dissolved in hot methanol (50-60°C). Sodium
hydroxide in methanol is added to convert the acetate to alcohol, at which
point it begins gelling.  After the gel is aged, it is ground and mixed with
additional methanol to drive the hydrolysis to the desired degree.  Excess
alcohol is removed and fed to a dryer with an inlet temperature of 140-160°C
and an exit temperature of 70-80°C. The PVA is then pulverized and bagged.
4.    EMISSION SOURCES WILL VARY DEPENDING UPON THE RESIN
      PRODUCED AND DEGREE OF PRODUCT INTEGRATION

      When several vinyl resins are produced within a single plant, emission
sources would be additive.

      (1)   There Are Several Sources Of Emissions In A PVC Plant

                 Vapors escape from reactors through vents and
                 packing on stirrers.

                 Solvent odors are prevalent in the compounding
                 and shipping area.

      (2)   Emissions From PVAc Plants Originate Mainly In The
           Manufacturing Section

                 Vapors escape from vents in the reactor, feed
                 tank and condenser.

                 The drumming section could be a minor source
                 of monomer vapor.
                              VI-16

-------
                               EXHIBIT ,VI-B 6
                   Environmental Protection Agency
                               FLOW SHEET:
                   POLYVBMYL ALCOHOL PRODUCTION (26)
                                     WATER
 LIQUID
Flow tliugram for the alcoholjsii of polyvinyl acetate.
            VI-l?

-------
      (3)   Potential Emissions Are Present Both In-Plant And Outside

                 Prime sources of emissions would be losses from
                 pumps, valves and solvent recovery systems.

                 Odors/emissions may originate in the effluent
                 from the plant.
5.     MONOMERS AND COMPOUNDING SOLVENTS  ARE THE PRINCIPAL
      EMISSIONS

      (1)   Vinyl Chloride And Ketones Are Major Emissions Of
           PVC Plants

                 PVC polymerization employs only vinyl chloride
                 and/or copolymer and water.

                 Ketones, principally Methyl Ethyl Ketone (MEK)
                 is the principal volatile solvent used - plasticizers
                 are not volatile.

      (2)   Vinyl Acetate Is The Major Emission In PVAc Production

      (3]   Methanol And Methyl Acetate Are The Principal Emissions In
           PVA Preparation

                 Methanol acts as both solvent and alcoholysis agent
                 and is present in excess of required amounts.

                 Methyl acetate is formed during the polymerization.
                             VI-18

-------
                   VI-C  STYRENE RESINS
      Polystyrene, impact polystyrene and styrene-butadiene-acrylonitrile
(ABS and styrene-acrylonitrile (SAN) copolymers make up the bulk of this
group of resins.  Polystyrene is manufactured by polymerizing styrene;
impact styrene is a blend of polystyrene with rubber; and ABS and SAN are
high tensile strength copolymers.  Polystyrene and impact styrene each
account  for about 30% of the styrene polymers; ABS , SAN and styrene-butadiene
copolymers accounting for the remainder with ABS representing about 20% of
total styrene resins. Discussion will concentrate on polystyrene,  impact
polystyrene and ABS.
1.    THE BULK CONTINUOUS AND SUSPENSION PROCESSES ARE THE
      MOST IMPORTANT METHODS FOR PRODUCING POLYSTYRENE (27)
      (CRYSTAL OR GENERAL-PURPOSE POLYSTYRENE)

      Over half of the current United States production of general-purpose
polystyrene is made by suspension polymerization, the remainder by some
variation of bulk polymerization to high conversion. (2&)

      (1)   In The Suspension Process Fpr The Manufacture Of
           General-Purpose  Polystyrene,  Water Is  The Prevalent
           Suspending Medium  And Production Is Batch-Wise

           Exhibit VI-C 1 depicts a flow scheme for manufacture of general-
      purpose polystyrene by the suspension process.  Styrene monomer is
      pumped directly into hot water containing tricalcium phosphate (TCP) ,
      suspending agents and dyes.  Typical water to monomer ratios are
      1:1 to 3:1. Plasticizers and catalysts or initiators (e.g. benzoyl peroxide
      and/or tert-butyl hydroperoxide) are added directly to the  monomer.
      A series of temperature  rises - from 90°C  to 115°C to 130°C  - over
      8 to 10 hours to complete polymerization.  The material is then flushed
      from the reactor into a mechanical separator which separates the TCP
      from the polymer beads. The beads are dried,  extruded, cooled,
      chopped and packaged.  The driers may be rotary, co-current air
      driers, counter-current steam-tube driers or rotary vacuum driers.
                              VI-19

-------
                                                     EXHIBIT VI-C1
                                        Environmental Protection Agency
                                                     FLOW SHEET:
                                        CRYSTAL POLYSTYRENE PRODUCTION^)
                                          (Suspension Polymerization Process)
 STYRENE
 STORAGE
  S-l
     METER
PUMP   S-3
                     WEIGHED CATALYST
                     ADDITION SYSTEM
                      -6
                                SUSPENSION
                                POLYMERIZATION
                                VESSEL S-7
SCALE
 S-4
                                             AIR OR MECH
                                               LIFT S-12
                                                            LUBRICATOR
                          CENTRIFUGE   DRYER
                            S-9
                                                                         CRYSTAL BEAD
                                                                             STORAGE .
                                                                              S-13
                           r
                                                      S-IO     f-1	>
                                                    m^^^
                                                                            TO TRANSPORTATION
                                                                               OR EXTRUSION
                           Flow scheme (or crystal polystyrene by suspension process.
                                   VI-20

-------
      (2)   Bulk Continuous Processes With Or Without Solvent Are
           Also Used

           Exhibits VI-C2 and VI-C3 depict bulk continuous process with
      and without solvent respectively.  In the continuous tower solvent
      process, 5-25% ethylbenzene is mixed with the monomer prior to enter-
      ing the first stage polymerizer.  Typically, the solution will pass through
      with each stage being at higher  reaction temperatures - the first is at
      110-130°C and the last stage being at 150-170°C.  The polymerization
      mass is pumped into a low-pressure, high-temperature devolatilization
      tank (225-250°C at 5-30 torr pressure) where the unreacted monomer
      and solvent is flashed off, condensed and recycled. The hot polymer
      is fed into an extruder and the polymer strands are cooled, cut and
      bagged.
2.    THE BULK CONTINUOUS AND SUSPENSION PROCESSES ARE OF
     APPROXIMATE EQUAL IMPORTANCE IN THE MANUFACTURE OF
     IMPACT  POLYSTYRENE

      (1)   In The Bulk Continuous Process For Impact Polystyrene,
           Rubber Is Dissolved In Styrene, Prepolymerized,  Run
           Into A Continuous Tower, Then Devolatilized And Often
           Extruded

           Exhibit VI-C4 depicts an idealized continuous process for the
     manufacture of impact polystyrene.  Rubber is cut, ground, weighed
     and transported to a dissolving vessel to which styrene monomer is
     metered separately; 3-10% by weight rubber is used.  The solution is
     filtered to remove gels and emulsion acids.  Polymerization is started
     in a stirred autoclave either thermally or using catalysts such as
     benzoyl nitrile or azobisisobutylnitrile.  When 35 - 40% polymer
     content is reached, the polymerization is completed in a  continuous
     tower having temperature gradients of 90°C, 130 C, 150°C and per-
     haps as high as 200°C. The product is devolatilized in a thin-film
     evaporator or a Herringbone gear devolatilizer with recycling of the
     volatiles. The product is then extruded or forced through a spinnerette
     by a gear pump and the final pellet is made and packaged.

      (2)   In The Suspension Process For Impact Polystyrene, Rubber
           Is Dissolved in Styrene, Prepolymerized, Suspended And
           Polymerized, Washed and Dried

           Exhibit VI-C5 depicts the flow scheme for impact polystyrene
     using the suspension process. The initial rubber is dissolved and
     prepolymerized in a manner similar to the bulk continuous process
     described above. When 10-20%polymer is reached, the material is
     suspended in a prepared kettle of water:TCP in about 50: 50 proportions.

                             VI-21

-------
                                              EXHIBIT VI-C2
                                 Environmental Protection Agency
                                              FLOW SHEET:
                                 CRYSTAL POLYSTYRENE PRODUCTION
                                             (28)
                                  (Continuous Solvent Polymerization Process)
               Hocoviift) iivrene and solvent
Slyrene
              Reader
               TJ
                     Rc-ocior
                            Reactor
TJ
                                   Duvola-
                                   tili/er


f

Poly-
*• siyrene
uulluis
                                         Cxiiudur   Cooler  Cutler
            Diagram of the oontimmub solvent proci-is for slyrene polyincrizat.ioii.
                             VI-22

-------
                                    EXHIBIT VI-C3
                       Environmental Protection Agency
                                    FLOW SHEET:
                       CRYSTAL POLYSTYRENE PRODUCTION
                        (Continuous Bulk Polymerization Process)
            rai POMP
fILlEP  ftOW WE«R
 e-3
                     ^lltlllllllll|—n—I
                                       ZONE I
      Continuous polystyrene process uses this polymeriza-
tion system.
                    VI-23

-------
                 EXHIBIT VI-C4
    Environmental Protection Agency
                 FLOW SHEET:
    IMPACT POLYSTYRENE PRODUCTION (29>
           (Idealized Continuous Process)



o
v=



o
=y
TOE-PCLV
VESSEL

                                     AIR FEED
                                     CONVEYOR
                        FINAL
                        POLYMERIZATION
                        VESSEL
                        OEVOLALIZING
                                            INTERNAL
                                             STORAGE
                                               WEIGH i
                                              SYSTEM
VI-24

-------
        DISSOLVING W.VK
    MEIER    1-7
I-Z  IJ
                                         EXHIBIT VI-C5
                            Environmental Protection Agency
                                         FLOW SHEET:
                            IMPACT POLYSTYRENE PRODUCTION <29)
                              (Suspension Polymerization Process)
                                                                       EXTRUDERS
             Flow scheme for impact polystyrene using the suspension process.
                      VI-25

-------
      Catalysts used include benzoyl peroxide or butyl perbenzoate.  Poly-
      merization takes between 8-10 hours with a series of temperature rises
      from 90°C to 115°C to 130°C. The material is then flushed into a
      mechanical separator which separates the 400 mesh TCP from the
      approximately 80 mesh impact polystyrene beads. The beads are
      washed, centrifuged and dried to reduce volatiles to 0.5-0.7% and
      then extruded with further reduction of volatiles to about  0.2-0.25%.
      The uncontrolled emission factor in extrusion is about 0.3-0.5% as
      volatiles.
3.    ABS  RESINS ARE GENERALLY MANUFACTURED BY EMULSION
      PROCESSES

      ABS  resins represent approximately one sixth of the production of
styrene based plastics.

      Exhibit VI-C 6 depicts the flow diagram of ABS polymerization by
batch emulsion processes. Reaction temperatures may range from 5 to
80°C • or higher in making the various ABS components. Pressures may vary
from 0.1 -  10 atm or more. Reaction time may be from  several hours to
several days. In a typical emulsion plant, polymerization takes place in a
standard jacketed 3,750 gallon reactor.  Catalysts are usually peroxides.
Carbon tetrachloride is a typical modifier.

      ABS  is generally sold in a pigmented, compounded and pelletized form.

4.    IN THE MANUFACTURE  OF STYRENE  PLASTICS. STYRENE MONOMER
      IS POTENTIALLY THE PRINCIPAL EMISSION

      Some odor is generally perceptible both inside and outside the plant.


5.    THERE ARE  MANY POTENTIAL EMISSION SOURCES

       (1)    In Continuous Processing, Polymerization And Devolatilization
            Are Potential Emission Sources

                 In polymerization, emissions are likely to occur
                  during production interruptions
                               VI-26

-------
                                                           EXHIBIT VI-C6
                                            Environmental Protection Agency
                                                           FLOW SHEET:
                                                    ABS PRODUCTION (30)
                    RUBBER
                 POLYMERIZATION
              Emulsiiter Sol'n
                Co'qlYSl Sol'n
                  Modifiers
     MONOMER
     STORAGE
       AREA
     BUTADIENE
ACftYLONITRILE
                             Shortstop
                                        Monomer Recovery
                                               r
      STrRENE
         SteomTT
REACTOR   STRIPPER


RESIN POLYMERIZATION
                       RUBBER LATEX
                          STORAGE
REACTOR


 GRAFT  POLYMERIZATION
                            Cmulsiltcr
                             " ID.
    Catalyst
     Sol-n
                       MONOMER
                         MIX
                        TANK
                                     LATEX STORAGE
                                                RESIN LATEX
                                                  STORAGE
                                                   />nl.o..dor.l
                                                             ;—~|   Anlio«iJonl
LATEX
BLEND
TANK   Flocculonl
                                                                       S  W°'*I-
                                                                  ~~-v'ii f FLOCCULATION
                                                                     " "     TANK
                                                                      I  (Resin-Rubber]
                                                                      1  V  °'6""'  I
                              REACTOR
                                            L
                                             GRAFT ABS
                                            LATEX STORAGE
                                      *___
                                    BLEND
                                    TANK
                                                                          DRY STORAGE
                                            Flow diagram—ABS manufacture.
                                                                                          BAGGER
                                                                                             WAREHOU^r
                                       VI-27

-------
                 Leaks in storage and reaction equipment are
                 maintenance related sources

                 Solvent and monomer recovery and extrusion
                 equipment are potential continuous emission
                 sources

      (2)   In Suspension Processing, Drying Is The Principal Potential
           Emission Source

                 Leaks in storage and reaction equipment are
                 maintenance related sources

                 The filling/dumping cycle in the suspension
                 polymerization vessel is a potential intermittent
                 source

                 Washing and centrifugation  are a potential source
                 of monomer emissions

                 Driers can release monomer in relatively low
                 concentrations but in large  volumes of air

                 Vented extruders are another emission source
6.     IN  THE MANUFACTURE OF STYRENE PLASTICS. STYRENE AND
      TO A LESSER EXTENT,  ACRYLONITRILE, ARE THE PRINCIPAL
      EMISSIONS

      (1)   Some Odor Is Generally Perceptible Both Inside And Outside
           The Plant

                 Styrene monomer odor can be sensed at very low
                 concentrations. The odor is rubbery and sweet.

                 Acrylonitrile odors potentially emanate from the
                 manufacture of ABS and SAN.  The odor threshold
                 of acrylonitrile is 400-500 times greater than that
                 of styrene monomer.  Acrylonitrile monomer smells
                 pungent, onion-like and is 5 times more toxic than
                 styrene.
                              VI-28

-------
           Other potential emissions to the atmosphere include

                 ethylbenzene (from continuous solution
                 processing of impact polystyrene)

                 vinyl alcohol (suspending agent)

                 rubber dust (impact polystyrene ingredient)

                 carbon tetrachloride (ABS modifier)

(2)   Both For Economic Reasons And Because Of The Odorousness
     Of Styrene, Modern Plants Manufacturing Styrene Plastics
     Feature Closed Systems

           Older manufacturing processes, such as filter
           press processes, have a more significant emission
           potential per unit of product than large, modern
           continuous plants.

           Besides utilization of closed systems and pollution
           abatement equipment, consciencious plant maintenance
           is the most important emission control means.
                        VI-29

-------
                    VI-D  POLYPROPYLENE
1.    MANUFACTURE IS CONDUCTED AT RELATIVELY LOW TEMPERATURE
      AND PRESSURE AND CAN BE EITHER A CONTINUOUS QR
      BATCH OPERATION

      Every process for producing polypropylene (PP)  involves three key
steps:  (1) polymerization, (2) purification, and (3) finishing.  A schematic
diagram for a typical PP plant is shown in Exhibit VI-D.

      (1)    Basic Equipment And Operational Steps For PP Polymerization
            Are Similar

            All streams entering the reactor (fresh and recycle diluent,
      fresh or recycle propylene, catalyst, modifiers) are individually
      metered and introduced separately into the reactor.  (If premixing
      is practiced, diluent and propylene may be added together, while
      catalyst components are introduced into lines not containing propy-
      lene) .  Catalyst and propylene concentrations, reaction temperatures
      and pressure,  and residence time are dictated by economics and
      polymer property  requirements , i.e.:  reactor temperature and
      pressure range from 40 - 95°C and below 14 atm respectively;
      the catalyst is a Ziegler type and a yield of 300-600 pounds of PP
      per pound of catalyst is considered acceptable. Propylene conver-
      sion to PP per pass is 50-70%.  The resultant PP slurry contains a
      maximum of 25% solids.

      (2)   Purification Consists Of Removing  Catalyst, Diluent And
           Amorphous  Polymer

           When polymerization is complete, the slurry is passed into
      the flash tank which is maintained at relatively low pressure. Un-
      reacted propylene along with diluent vapor (e.g. n-heptane, cyclo-
      hexane) and other volatiles are flashed off and sent either to the
      recovery section or condensers and recycled directly to the reactor.
      The  catalyst is deactivated by intimate intermixing of the slurry with
      a polar compound, i.e., alcohol or water. Inert diluents are removed
      from the solid PP by filtration or centrifugation.  The filter cake con-
      taining some volatiles and diluent is conveyed to the drying zone  for
      drying using either a rotary vacuum  drier or spray drier.
                              VI-30

-------
                                                   EXHIBIT VI-D
                                      Environmental Protection Agency
                                                   FLOW SHEET:
                                      POLYPROPVLENE PRODUCTION
                                             (Continuous Process)
Pllt*ftfp
NOPTCCM
                                      1
^*_^
si
i«EUr» **-r*~~
IW 1




DIIICMT J
T
.. OHJIXl SICrtll
"
^ •o1
/ Be
BCCTCLC ' jfUT
/uwctNsn
LiMinr 
J<             ("Hyt	   	J    I    MNlPIFUCt
 ^~—'   i	    SXHSf            ^~i*-^
            V^_^J      L J         t    (HLUfNT
VOJtXCtilltll       t\ ASH      SLWCC
                                                        T
    r~M—\
      stoadOM  I

o"
                                                                               ftffift
                                                                           OHCAMC AND
                                                                           VAT [A WASH
                        i          r
                           E>IPUOfR              »«e> COOI.INC »rn            DKfO
                      Diagram of a continuous process Tor polypropylene in.iniifncturc
                                 VI-31

-------
      (3)    PP Is Usually Compounded And Consolidated Into Pellets

            The pellets or beads from the drier section are mixed with
      various additives, melted, extruded and cut into pellets.  The num-
      ber of additives used is large and includes antioxidants, metal
      deactivators, U.V. screeners, slip agents,  antistats, fillers, plas-
      ticizers, others. The pellets are removed by mechanical or pneumatic
      conveyor to surge bins from which bagging is carried  out.
2.    THERE ARE SEVERAL POTENTIAL EMISSION SOURCES

      Potential emissions are possible both inside and outside the plant.


                  Vapors escape from compressors, pumps and vents.

                  Solvent vapors are present in the drying area.

                  The distinctive odor of catalysts is prevalent
                  outside the plant.
3.     THERE ARE THREE PRINCIPAL  EMISSIONS

      (1)    The Metallic Compounds Formed During Polymerization
            Are Odorous And Toxic

                  The odor is prevalent in the catalyst storage and
                  preparative areas.

                  Outside plant odors are noticeable.

      (2)    Solvent Or Diluent Odors Can Be Detected

                  Methanol and ethanol are detectable at 2,000 ppm
                  and 350-1,000 ppm respectively.

                  Threshold limits should be well below 500 ppm.

      (3)    Monomers Are Emitted In Greatest Volume
                               VI-32

-------
           VI-E  PHENOLIC AND OTHER TAR ACID RESINS
      Phenols react with formaldehyde to form resinous products and although
these two products are the most widely used,  other phenolic compounds and
aldehydes are used.
1.    PHENOLICS ARE  ORDINARILY MANUFACTURED BY A LOW TO MEDIUM
      TEMPERATURE BATCH OPERATION

      (1)   Regardless Of The Final Form Or The Re act ants Used In The
           Process, Equipment And Plant Layouts Are Similar

           The schematic diagram for a typical phenolic resin production
      unit is shown in Exhibit VI-E1 and equipment consists of the following:

                 Warehousing facilities and materials handling
                 equipment for resin production.

                 Jacketed acid-resistant stainless-steel kettles,
                 heated with either steam or Dowtherm, ranging
                 in size from 500 - 6,000 gallon capacity, equipped
                 with shell and tube condensers and heavy-duty
                 anchor or turbine blade agitator.

                 Weigh tanks

                 Vacuum pump

                 Compounding equipment including ribbon blender,
                 heated rolls and low speed cutters.

      (2)   Polymerization Of  Novolak  And "One-Step" Phenolic Resins
           Are Similar

           If a catalyzed mixture of phenol and formaldehyde contains one
      or more moles of formaldehyde per mole of phenol it is called a "one-step
      resin". When the catalyst is alkaline and there is less than one mole of
      formaldehyde per mole of phenol,  the initial product consists of a solution
      of a "one-step resin" in phenol. Upon heating without the loss of phenol
      it can be converted into a Novolak. A Novolak is also formed if the
      original mixture is catalyzed with an acid.
                               VI-33

-------
                                       EXHIBIT VI-E1
                         Environmental Protection Agency
                                       FLOW SHEET:
                         PHENOLIC RESIN PRODUCTION(32J
        Weigh tanks
Formaldehyde.      ^Phenol
                                     .Safety
                                     blow-off
                                         Temperature
                                           recorder
                             Resin coolers for solid one-step resins

                         j, — Resin pans or (laker for novolacs
                  fjiu of Ijjtlr.il plicnolit. rcaiu pitjilucliiMi tpiiil.
                    VI-34

-------
            Molten phenol or alternate raw materials such as resorcinol,
      meta cresol or xylenols at 60-65°C and warm 37-40% formaldehyde
      at about 40°C are charged to the kettle from the weigh tanks and
      agitation started. Catalyst is added and steam applied to raise the
      temperature until the exothermic reaction becomes strong enough to
      cause the batch to heat without further steam. In Novolak prepara-
      tion using an acid catalyst (usually sulfuric acid) mild reactions
      may be allowed to heat up to atmospheric reflux (60-85°C) while
      strongly exothermic reactions will be held to 85-90<>C by vacuum
      reflux for 3-6 hours.  In "one-step resin" preparation, steam pro-
      vides the initial heat to 60-70°C while the exotherm heat will increase
      temperature to 80-100°C at low vacuum and reflux for 1-3 hours.

            Water is then removed from the reaction mass. In Novolak
      preparation, the water is removed by slowly bringing the pot
      temperature up to 120-150°C, then applying vacuum to remove final
      traces at which time the temperature is 140-150°C and final vacuum
      up to 100 torr.  The "one-step resins" are dehydrated under
      vacuum and the temperature is not allowed to go over 100°C .

            When the desired characteristics are attained, the resins are
      discharged through a quick-opening bottom cock.  If the resin is to
      be used in solution, solvent is added while the batch is still molten
      in the kettle and while the condenser is still set for atmospheric
      reflux.  If the finished resin is solid, it is cooled in shallow pans
      or on specially cleared floor areas, or it may be fed to a flaker.
      Liquid resins are usually made-to-order for immediate shipment and
      are protected from aging by refrigeration.

            Most solid-resins are further processed and a flow diagram of
      the processing is shown in Exhibit VI-E2. Resin for molding materials
      is compounded with fillers such as wood flour. Novolak resin for
      adhesive or bonding uses is pulverized with hexamethylenetetramine.
      A small volume of special "one-step" liquid resin is manufactured for
      casting whereby the resin is transferred directly from the kettle to
      molds which are oven-cured for several days at 70-90°C .


2.     SOURCES OF EMISSIONS  OCCUR PRINCIPALLY DURING
      POLYMERIZATION AND POLYMER  PROCESSING

      (1)    The Prime Source  Of Emission Is The Production Unit

            During polymerization odors/emissions escape through the
      condenser, vacuum line, sample ports and vents. Reactions that
      become too exothermic are vented through safety blow-offs.  When
      solid resins are made, odors are prevalent after discharge from the
      reactor since the resins are cooled either in pans, plant floor space
      or flaker.
                              VI-35

-------
                                                          EXHIBIT VI-E2
                                          Environmental Protection Agency
                                                          FLOW SHEET:
                                          PHENOLIC RESIN PRODUCTION133)
               Manufacture of  phcnol-[orm:dilcli)dc muldmg and laminating  ]in»lucts.

                            KEY TO FLOW SHEETS

   /liuvj indicate operations or apparatus used during a particular stage of the process.
   Cirilrs indicate basic mad-rials wed
   nutlet! cir.li-s indicate materials \vliich nin> be used at the discretion of the manufacturer, or
to product: .special effects
   .•/rnit.'j indicate the dii 1x111111 of fluii.
   Dotted rtniiH'cliny lines imlicatc optional paths to be followed,  or supplementary processes.
Solid lines ha>c been Uicd \\hcrc  processes of  equal merit may be used.
                                  VI-36

-------
      (2)   Emissions Are Also Noted During Compounding

           Odors are noticeable during blending, crushing and mixing
      of lubricants and activators.

      (3)   Many Manufacturers Of Phenolics Produce Products Made
           From These Resins And Odors Are Common In The Molding
           And Laminating Plant

           During phenolic resin  use, heat is usually applied to cure
      the phenolic resins.
3.    THERE ARE FOUR PRINCIPAL EMISSIONS

      (1)   The Reactants Are Main Sources Of Air Pollution

                 Phenol and formaldehyde are very noticeable.

                 Phenol is considered toxic and may be absorbed
                 through the skin or inhaled.

                 Formaldehyde is an eye, skin and respiratory
                 irritant

      (2)   The Solvents Used In Making Solutions Of These Resins
           Contribute To Total Emissions

           Important solvents include:

                Cellosolve Acetate
                Butanol
                Ethanol
                Methyl Ethyl Ketone (MEK)
                C y clohexanone

      (3)   The Formaldehyde Used Is Normally Stabilized With Methanol

           About 1% methanol is used to stabilize the formaldehyde and
     this would be emitted through the condenser during polymerization.


      (4)   The Activator Used Is A Source Of  Odor

           Activators normally used include ammonia and/or hexamethyl-
     enetetramine which have sharp ammoniacal  odor.
                              VI-37

-------
4.    PHENOLIC RESIN PLANTS REPRESENT AN EMISSION PROBLEM

      While the phenolic resin industry has an excellent record of serious-
injury rates, it does have a reputation as an industry with a high odor
factor.  Phenols, for example,  are detectable as low as 5 ppm and formalde-
hyde can be detected well below 1 ppm.

      Good ventilation and other safety standards are normally practiced
within the plant so that odor/emission effects would be most pronounced
outside operating plants.
                               VI-38

-------
                   VI-F   POLYESTERS
      Polyester resins are unsaturated prepolymers made by esterifying
dihydric alcohols with unsaturated dibasic acids or anhydrides.  These
unsaturated prepolymers are dissolved in an unsaturated monomer with
which it cross-links to form the ultimate polymer.
1.    MANUFACTURE IS A HIGH TEMPERATURE BATCH OPERATION

      (1)    Manufacturing Equipment And Plant Layout Are Similar To
            That Used In Alkyd Manufacture

            The equipment layout of a typical polyester plant is shown
      in Exhibit VI-F and consists of stainless-steel reactors from
      500 -  5,000 gallons.   (Glass-lined vessels are used only
      where exceptionally  light colored resins are required or when
      halogenated starting materials are used) .  The steam condensers
      which operate at 100-110°C separate the water of reaction from  the
      process.  The thinning tank has a capacity double that of the reactor.

      (2)    The Reaction  Is An EsterificatLon Reaction

            The dibasic acids or anhydride, usually phthalic anhydride or
      isophthalic acid and maleic anhydride, fumaric acid, succinic acid
      are reacted at 190-220°C with polyhydric alcohols such as propylene
      glycol, ethylene glycol,  diethylene glycol, for 8-20 hours.  Sparging,
      during esterification, with an inert gas shortens reaction time by
      assisting in removing the water formed during condensation.

            When the esterification has progressed to the desired stage,
      the reaction mixture is cooled to 100-150°C and dropped into the
      thinning tank containing the  monomer, e.g. styrene or methyl  styrene
      and inhibitors .e.g. hydroquinone or para-tertiary butyl catechol.
      The solution is filtered and sent to storage or shipping.
2.    THERE ARE SEVERAL POTENTIAL EMISSION SOURCES

      (1)    In-Plant Emissions Occur As A Result Of Manufacture, Handling
            And  Storage

                  Vapors escape through packing on reactor and
                  thinning tank stirring equipment.
                              VI-39

-------
                                                    EXHIBIT VI-F
                                     Environmental Protection Agency
                                                    FLOW SHEET:
                                     POLYESTER RESIN PRODUCTION
Weigh
 Tank
if      From Row Material
           Inventory       Partial
                        Condenser
                                               Total
         Dowtherm
         Liquid
      To
     Storage
                                                         Vent



                                                       Scrubber


                                                     .Decanter

                                                     .Water Receiver
                                               Baffle Plates
                                                       Condenser ^   |

                                                     Motor

                                                        \
^-^.
Inert Gos "Blanket" Line _

Steam or

Filler



^




V
1
                 Srliniiiit.ic 
-------
                 Vapors escape through vents on reactor and
                 thinning tank.

                 Monomer odors/emissions are prevalent in
                 raw material storage areas, and in drumming
                 areas.

                       Solvents are usually not used.
3.    THERE ARE  TWO  PRINCIPAL EMISSIONS

      Unchanged reactants are the prime offenders.

                 Anhydrides sublime or vaporize during the
                 reaction.

                 Monomers have relatively high vapor pressures, and
                 are particularly odorous even at room temperature.
4.    MOST PLANTS FOLLOW  GOOD HEALTH AND SAFETY PRACTICES

      Reasonable precautions,  such as the use of rubber or leather gloves,
protective clothing,  eye protection and respiratory devices are employed in
handling the various ingredients.  Cleanliness and careful handling of poly-
ester ingredients are available  from raw material suppliers.
                              VI-41

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             VI-G  AMINO (U-F and M-F)  RESINS
      A large class of thermosetting resins are made by the reaction of an amine
with an aldehyde.  The only aldehyde in commercial use is formaldehyde (F),
and the most important amines are urea (u) and melamine (M).. Most important uses
include molding, adhesives, laminating, textile finishes and paper manufacture.

      Butylated melamine resins are also available and these resins are solu-
ble in paint and enamel solvents and lead to uses in surface coatings, often in
combination with alkyds.
1.    AMINO RESIN PRODUCTION IS A LOW TEMPERATURE BATCH
      OPERATION

      (1)    U-F And  M-F Resins May Vary Considerably As To
            Amine: Formaldehyde Ratio And Are Available As
            Liquids Or Solids

            U-F and M-F resins can be produced in the same equip-
      ment consisting of a nickel-clad steel reactor which is jacketed
      and equipped with fume ducts, agitator and condenser. The batch
      size can vary from 100 -  6,000 gallons.

            The reaction between amine and formaldehyde (Formalin,  37%)
      is carried part way to completion:  U-F resins are reacted at tempera-
      tures between  20-70°C for molding resins, and at reflux  for laminating
      resins; M-F  resins are usually reacted at reflux because of the low
      solubility of melamine in water. When the required degree of conden-
      sation is  reached, the resin syrup is circulated through a steel plate-
      and-frame filter press until the filtrate is water-white and clear.

            While  many applications utilize liquid resins.  there is a large
      market for solid resins - filled or unfilled resins. Schematics of a
      typical molding and spray-dried resin plant are shown  in Exhibit
      VI-Gl. The  procedure for preparing M-F resins follows.  U-F resins
      are handled  similarly.
                               VI-42

-------
                                                              EXHIBIT VI-G1
                                               Environmental Protection Agency
                                                              FLOW SHEET:
                                               SOLID AMINO RESIN PRODUCTION
                C-CLONt    Pfti't."
   !    .  "«^ <•="/'» ^' •' \:'  '  -",.'
                 ,-' . "UL.I" »U
              ; i .U'"'  !<• •..
 r   • ' ''i    ti..,' r  ' :   v,    .-f.
-i   j   ||       I-].   '   1     i ' '••5>a-J' »C'GM
                           p.'.' """  SHIP
                                          ICONTIS ;0lll BELT  'nn-^a.-j^   LJ
                                                             L-,. ..-:.••.,.!


                                            powder jilant, iVtucriciin ('y:\i\iiinid O>.
                      -  	 ,   .
                 j  MOIOIN'; tANKS     L
       .
    PUMP   FILTER PRESS
                                     Sjiray-dritxl resin plant, American Cyaiuimid Co.
                                        VI-43

-------
      In the preparation of molding powders, the resin syrup and
filler are fed to a mixing tank and held at 50°C then discharged.into
the dryer hopper then into a continuous tunnel dryer heated and/or
cooled by circulating air so that the dried product contains about 6%
volatiles. On emerging, the dryer cake is broken up by means of a
revolving blade cutter; the pieces falling directly into the hammer
mill where the resulting fine powder is caught up in a stream of con-
veying air and  charged to the ball mill along with lubricants, pig-
ments , catalyst and inhibitor.  When the ingredients are blended  to
specification, the powder is densified  by feeding it onto the preheating
rolls operating  at about 120°C where the powder is formed into a sheet
which is fed to  the cutter. The cut granules pass through the screener
and are packed.

      Spray-dried resins are prepared by introducing the resin syrup
into a spray tower  approximately 25 ft. in diameter and 24 ft. high.
Hot air is directed  downward in the form of a converging cone at the
atomizing wheel. A main fan provides the  necessary  suction to draw
approximately 40,000 cfm of air into the drying chamber and through
the dry resin collectors. The air stream leaving the drying chamber
conveys the dried resin particles to a  collection of cyclones arranged
in parallel.  Each cyclone discharges at the bottom through a venturi-
type air lock into a positive pressure, secondary air conveying system.
This secondary system discharges the resin beads into conventional
ribbon blenders by way of another cyclone collector,  and it is then
packaged. The effluent air from the secondary system is returned to
the main air stream.

(2)   Amino Resins Used In Surface  Coatings Are Basically
      Different

      These resins are usually water-insoluble, but are soluble or
dispersible in hydrocarbons and higher alcohols.  Since they are pre-
dominantly used in enamels containing alkyd resins, their  solubility
and compatibility with various solvents such as naphtha, toluene and
butanol is a prime requisite.  A manufacturing schematic is shown in
Exhibit VI-G 2.

      Condensation of urea or melamine with formaldehyde is carried
out in the same manner as described above, but not much beyond the
monomeric methylol urea or melamine  stage. A large excess of the
alcohol,  the most common being butanol, is added and the reaction mix-
ture brought to reflux until the water initially present in the formalin
and split out by condensation is partly removed and the solution clears.
                         VI-44

-------
                          EXHIBIT VI-G2
              Environmental Protection Agency
                          FLOW SHEET:
              BUTYLATED MELAMINE RESIN PRODUCTION
(36)
                                 VACUUM
                                 EJECTOR
ICquipnient for manufacturing mclamine coating resins.
           VI-45

-------
      A separator trap or weir in the reflux line allows the water to be
      drawn off while the butanol is returned to the reactor.  When the
      desired degree of esterification is reached the butanol-water is
      diverted to a separate collecting tank for subsequent recovery of
      the butanol.  Solvents such as xylene are now added to the reaction
      kettle to yield products  containing 50-60% resin in a mixture of
      butanol and xylene.

           Melamine-urea resins are available in various solvent combi-
      nations of butanol,  xylene, butyl "Cellosolve" and mineral spirits.
2.     POTENTIAL EMISSION SOURCES OCCUR IN MATERIALS HANDLING,
      POLYMERIZATION AND COMPOUNDING OPERATIONS

      (1)   Emissions Occur During Storage  And Materials Transport

                 Vents in storage tanks

                 Leakage in liquid transport piping and valves

                 Drum filling

      (2)   There Are Three Major Sources Of Emissions In Manufacturing

                 Leakage through agitator packing

                 Spills and leakage through the filter press
                 during operation and clean up

                 Condenser venting

      (3)   The Compounding Operation Probably Presents The Prime
           Source

                 Molding powder plant

                       mixing tank
                       dryer
                       preheating and densifying rolls.

                 Spray dried resin

                       cyclone collectors and exhausts
                       spray tower
                              VI-46

-------
3.    THERE ARE THREE PRINCIPAL EMISSIONS

      (1)    In Preparation Of The Basic Polymer, Formaldehyde Is
            The Prime Source Of Emissions

           The amino (amido) compounds normally used as raw
      materials have boiling points far above the reaction tempera-
      tures as shown by the following.
                  Materials For Amino Resins

Raw Material                 Melting Point °C        Boiling Point °C

Aniline                             -6.2                   184.4
Benzenesulfonamide                 156
Dicyandiamide                      207.8                     d
Melamine                           354                   sublimes
Thiourea                       180-182                       d
p-Toluenesulfonamide               137
Urea                               132.7  (d)                 d

      d = decomposes
      (2)   Alcohols Used In Alkylating U-F And M-F Resins Are
           Noticeable

           The common alcohols used in alkylation are either low
      boiling or odorous and include

                 methanol
                 butanol
                 octanoJ

      (3)   The Solvents Ordinarily Used In The Preparation Of Coating
           Or Alkylated Resins Are Evident

           The solvents used provide compatibility of the amino resins
      with alkyds and include combinations of

                 xylene
                 butanol
                 'butyl "Cellosolve"
                 mineral spirits
                              VI-47

-------
                        VI-H  ALKYDS
      Alkyds are usually made by reacting dibasic acids or anhydrides,
usually phthalic anhydride, with apolyhydric alcohol such as glycerol.
The alkyd resins can be varied and modified by the use of other anhydrides
(maleic), dibasic acids, glycols, polyols or other substances.  Regardless
of the composition of the finished resins, they are prepared by either a
solvent or fusion process described in detail in Section VIII. Quantification
of the emissions from these processes is also detailed in Section VIII.
1.    MANUFACTURE IS GENERALLY A HIGH TEMPERATURE BATCH
      OPERATION

      Processing temperatures will range between 210- 250°C, although in
a few instances temperatures slightly above or below this range may be used.
Reactor size can range from 500 gal. to 5,000 gal.  Agitation is supplied by
motor driven propellers, paddles or turbines and gas sparging.  Sparging not
only agitates the reaction mass but blankets the mass to minimize oxidative
degradation of the alkyd. When the reaction has progressed to the desired
point, the mass is cooled somewhat and dropped into a thinning tank where it
is diluted with organic solvents usually xylene and/or naphtha.


2.    THERE ARE SEVERAL POTENTIAL EMISSION SOURCES

      Emissions are present both inside and outside the plant.

      (1)   In-Plant Emissions Occur As A Result Of Manufacture And
            Handling

                  Vapors escape through packing on the stirring
                  equipment of reactors and thinning tanks

                  Solvent vapors are prevalent in the drumming area

      (2)   Vapors Escape Through Stacks And Vents

                  Solvents and raw materials are intrained with
                  the sparging gases

                  Vapors are released to the atmosphere when
                  scrubbers are vented
                               VI-48

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3.    THERE ARE THREE PRINCIPAL POTENTIAL EMISSIONS

      (1)    Reactants Escape Because Of High Temperatures Used In
            Preparation

                  Many of the ingredients used have boiling points in
                  the neighborhood of the reaction temperature. This
                  includes the anhydrides, and alcohols

                  Phthalic anhydride sublimes just below its melting
                  point and it is not uncommon to see crystals of this
                  product adhering to plant walls and ceilings

                  The characteristic odor of maleic anhydride is also
                  detectable

      (2)    Solvent Odors Are Particularly  Strong In Filling Areas

            Aromatic solvents are common,  the most common being xylene.
4.    MOST PLANTS FOLLOW  GOOD HEALTH AND SAFETY PRACTICES

      Reasonable precautions,  such as the use of rubber or leather gloves,
protective clothing,  eye protection and respiratory devices are employed in
handling the various ingredients.  Cleanliness and careful handling by the
employees are essential.  Information needed for the safe handling of alkyd
ingredients is available from alkyd raw material suppliers.
                              VI-49

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                        VI-I  ACRYLICS
      Acrylic resins are thermoplastic or thermosetting polymers or copoly-
mers of acrylic acid, methacrylic acid or esters of these acids.  These monomer
liquid esters polymerize readily in the presence of light, heat,  or catalysts.

      Because of the high emission potential and odorous/toxic nature of the
emissions, this group of resins will be discussed in detail in Section
1.    BULK, SOLUTION, EMULSION OR SUSPENSION METHODS ARE USED
      IN THE POLYMERIZATION OR CO-POLYMERIZATION OF ACRYLIC
      MONOMERS

      (1)    Emulsion Polymerization Is Widely Accepted And Is A Low
            Temperature Batch Operation

            Typically, monomers, emulsiflers and water are charged to
      a reactor.  The air is displaced by an inert gas, and the initiators,
      reducing agents and activators are added and the charge heated to
      30-50°C at which time a vigorous reaction occurs and the exotherm
      will raise the temperature to 90-95°C.  Conversion to polymer is
      almost quantitative.  The unconverted monomers are removed by
      •stripping and evaporation and the finished resin emulsion sent to
      storage.

      (2)    Suspension Polymerization Produces Dry Beads

            Polymerization of the monomer or comonomer mixture is carried
      out by charging the water, suspending agent, monomer mixture and
      initiator to a reactor similar to that used in emulsion polymerization.
      Heat the well-agitated mixture under an atmosphere of nitrogen to just
      below the reflux temperature and polymerization is complete in about
      1 hour.  The slurry is filtered or centrifuged to separate the  resin
      beads from the water and the beads washed with water and then dried
      in a circulating air oven at 80-120°C.
                               VI-50

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      (3)   Solution Polymerization Is Especially Suited To Preparation
           Of Polymers When They Are To Be Used In A Solvent

           Polymerization is carried out by slowly adding monomer and
      initiator to a solvent held at near-reflux temperature.  After all the
      monomer (s) is added, mixing is continued for an additional 4-20
      hours when polymerization is complete.  Additional solvent is then
      added and the solution sent to storage.

      (4)   In Bulk Polymerization, The Monomer Acts As The Solvent

           Commercial bulk processes for acrylic polymers are used
      primarily in the production of sheets, rods and tubes. Bulk processes
      are also used on a much smaller scale in  the preparation of dentures
      and novelty items.  The process is used primarily with methyl methac-
      rylate polymerization.

           Polymerization is a two-step operation in which the monomer is
      first partially polymerized to a syrup consistency by heating the mono-
      mer at 80-85°C for about 5 minutes.  The syrup is then poured into
      molds,  cured at 40-90°C for some time, then post-cured at 140-150°C.
2.    THERE ARE MANY POTENTIAL SOURCES OF EMISSIONS AND
      WILL VARY DEPENDING UPON THE POLYMERIZATION PROCESS

      Emissions can occur during storage, materials handling and poly-
merization operations.

                 Vents on both monomer and polymer emulsion
                 and solution storage tanks are a source of air
                 pollution.

                 Monomers and solvents used are all liquid, but
                 odorous/hazardous emissions occur as a result
                 of the line leaks and spills.

                 Polymerization equipment is vented to the atmosphere.

                 Sparging gases form aerosols with the monomers.

                 The rapid rate of polymerization and subsequent
                 heat of reaction makes it difficult to prevent vapor
                 escape  from the reactors or, for that matter,  the
                 entire polymerization system.

                 Spills from molds and during curing of the molded
                 products in bulk polymerization is a major source
                 of emissions.
                             VI-51,

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     VI-J   COUMARONE-INDENE AND PETROLEUM RESINS
      Coumarone-indene resins were first prepared as by-products in the
refining of coal-tar solvents.  More recently, resin formers containing
indene were obtained from cracked crude oils.  These latter resin formers
do not, however,  contain coumarone or its homologs.

      While coumarone-indene and petroleum (hydrocarbon) resins are
reported together by the U.S. Tariff Commission, probably no more than
15% of the total are coumarone-indene resins.
1.    PRODUCTION OF BOTH RESIN TYPES IS A LOW TEMPERATURE
      BATCH OPERATION

      The operations in the manufacture of these resins include:  blending
and purification of raw materials (feed stock); polymerization; recovery of
solvent, and finally packaging of the finished resin.  A schematic of a typical
plant is shown in Exhibit VI-J.

      (1)   Crudes May Be Blended To Average Out Variations Or They
           May Be Fractionated

           The presence of cyclopentadiene dimer is often undesirable
      and may be converted to the monomer; however, small amounts
      may be removed by treatment of the crudes with clay.

           The crudes are fractionated into specific boiling ranges to
      produce resin formers which, on polymerization, will produce
      specific softening prints.

      (2)   Polymerization Is Conducted At Low Temperature In A Solvent

           While batch polymerization is traditional because temperature
      control is easier, polymerization can be made continuous. The raw
      material is diluted to 50%, and more often 30% with an aromatic solvent.
      Catalyst is added at no higher than 35°C, usually close to 0°C , and
      the exotherm raises the temperature to 95-105°C.  Reaction is completed
      in 15-30 minutes.  Sludges formed during polymerization are removed
      by treatment with clay and filtration and acids are removed by succes-
      sive washes with alkali and then water.
                              VI-52

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                                           EXHIBIT VI-J
                               Environmental Protection Agency
                                           FLOW SHEET:
                               COUMARONE-INDENE AND HYDROCARBON
                                     RESIN PRODUCTION
                          catalyst
                    solvent
      still
                       reactor
                                                        vent
                                      wash
                                      tank
                                                 I
                                                flaker
                                                 or
                                                package
Source:  Snell
                             VI-53

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      (3)   While The Resin Is Often Finished In Batch Stills, Continuous
            Finishing Can Be Employed

            The resin is heated to about 2QO°C and flashed under vacuum.
      Steam is often injected to complete the removal of heavy oils.

      (4)   The Finished Resin Can Be Shipped Molten Or Drummed

            The softer resins (below 100 C softening point) are dropped
      into lightweight steel drums. The harder resins may also be drummed,
      but are usually flaked and bagged. Molten handling has been adopted
      by large users.

            Solutions at about 60% solids in an aromatic hydrocarbon
      thinner are also sold.
2.    EMISSIONS ARE WIDESPREAD AND OCCUR AT ALMOST ALL
      POINTS  OF HANDLING AND PROCESSING

      (1)    The Aromatic Nature Of The Raw Materials And Finished
            Products Makes Emissions Detectable At Very Low Levels

                 Vents in raw material storage  tanks, distillation
                 columns, reactor and flash evaporators are potential
                 sources of emissions.

                 Odors are prevalent in flaking areas.

                 Solvent odors are detectable in finishing and
                 shipping areas.
3.    THE VARIATION OF THE COMPOSITION OF FEED STOCK AND
      FINISHED RESIN (S)  MAKES IT DIFFICULT TO IDENTIFY
      SPECIFIC EMISSIONS

      (1)    The Coal- And Gas-Tar Fractions Used Have Wide
            Boiling Ranges

                 The resin formers found in gas-derived oils
                 contain  all the resin formers found in coal-tar
                 oils with the exception of coumarone and its
                 homologs.
                              VI-54

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           The composition of the remainder of the resin
           formers, most of which are odorous at concen-
           trations in the range of 1 - 10 ppm, include:

                 Indene
                 Cyclopentadiene (monomer and dimer)
                 Styrene
                 Methyl homologs of cyclopentadiene
                 Vinyltoluenes
                 Methylindenes
                 Methylstyrenes

(2)   Other Odor Contributing Solvents Used During Polymerization
     And Thinning Include The Following

           Xylene
           Hi-flash naphtha
           Other aromatics
                        VI-55

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                    VI-K  POLYUHETHANES
      There are over 100 producers of urethane resins used in the formulation
of coatings, adhesives and- sealants. Annual production volume is relatively
low, from 80 to over 100 million pounds of resin, with coating resins accounting
for the bulk of this.  Plant capacities are also relatively low, about one million
pounds per year, on the average.

      The manufacture of some typical urethane resins is discussed in detail
in Section vm.
1.    MANUFACTURING PROCESSES  ARE LOW TEMPERATURE BATCH
      OPERATIONS

      Urethane coating resins are prepared by reacting di- or polyisocyanates
with an intermediate containing at least two active hydrogen atoms per molecule.
Formulations are numerous and most are proprietary.  ExhibitVI-Kl lists a
few formulations that are commercially available.

      Resins are usually prepared in closed kettle reactors, blanketed with
nitrogen to keep out atmospheric moisture.  In general, the polyisocyanate is
reacted with the polyhydroxy compounds or polyamines at temperatures
ranging from ambient to about 95°C. The isocyanate content of the resulting
resin will vary from no free isocyanate to as much as 25% or more.
2.    THE  MANY URETHANE RESINS PRODUCED CAN BE CATEGORIZED
      AS NONREACTIVE  OR REACTIVE

      A simplified classification of the various types of urethane coatings is
shown in Exhibit VI-K2. (14) The ASTM designation refers to a classification
set up in 1960 by the American Society for Testing Materials, Committee D-l,
Paint. Varnish, Lacquer and Related Products. which does not include some
of the more recent resin developments.

      (1)   Nonreactive  Urethane Coating Resins Contain No Free
            Isocyanate Groups

            Nonreactive urethane surface coatings include urethane alkyds.
      lacquers, and latices. These coatings are nonreactive only in the sense
      that they contain no free isocyanate groups.  They are all one-package
      systems. The urethane alkyd cures by air oxidation and the urethane
      lacquer  and latex cure by solvent evaporation (water in the case of latex)
                              VI-56

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                                              EXHIBIT VI-Kl
                                              Environmental Protection Agency
                                              SOME URETHANE COATING RESINS
                                              AS SUPPLIED BY THE PRODUCERS
           Ur ethane alkyds:

           60% NVR (nonvolatile resins) in mineral spirits
           50% NVR in mineral spirits

           Moisture-curing prepolymers:

           60% NVR in Cellosolve acetate/xylene blend
           50% NVR in Cellosolve acetate /xylene blend
           42% NVR in Cellosolve acetate /xylene blend
           42% NVR in Cellosolve acetate/xylene blend (non-yellowing)

           Prepolymers for two-package systems:

           60% NVR in Cellosolve acetate/xylene blend
           60% NVR in Cellosolve acetate/xylene blend (non-yellowing)
           Urethane polyols  (100% NVR)

           Thermoplastic lacquer (20% NVR)
           Note: Cellosolve is a Union Carbide Corporation trade name
                 for ethylene glycol monoethyl ether.
These are shipped as drums, can or lot or truck-load quantities.
                             VI-57

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                                              EXHIBIT VI-K2
                                  Environmental Protection Agency
                                        CLASSIFICATION OF URETHANE
                                              SURFACE COATINGS (14)
      Pescription
Nonreactive
 Urethane alkyd

 Urethane lacquer


 Urethane latex
  ASTM
Designation
  Type 1
           System
One package; air oxidation

One package; solvent evapor-
 ation

One package; water evapora-
 tion
Reactive
 Moisture-curing prepolymer    Type 2
 Blocked prepolymer and polyol  Type 3
 Catalyzed prepolymer
 Prepolymer and polyol
  Type 4
  Type 5
One package; isocyanate-
 water reaction

One package; heat (to unblock) ,
 isocyanate-hydroxyl reaction

Two packages; catalyzed
 isocyanate-water or
 hydroxyl reaction

Two packages; isocyanate-
 hydroxyl reaction
                              VI-58

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      (2)   Reactive Urethane Coatings  Contain Unreacted Or Blocked
           Isocyanate Groups

           Reactive urethane surface coatings are systems that contain
      unreacted (or blocked) isocyanate groups. These coatings may be
      one-package or two-package systems.  One-package systems include
      (1) urethane prepolymers that cure by reaction of the isocyanate
      group with atmospheric moisture and (2) combinations of polyol and
      urethane prepolymer in which the isocyanate group is blocked (usu-
      ally with phenol) . When the system is heated, the phenol is released
      and the isocyanate groups in the prepolymer  react with the hydroxyl
      groups  in the polyol.  Two-package systems include (1] combinations
      of urethane prepolymer and polyol and (2)  combinations of moisture-
      curing urethane prepolymers and a small quantity of catalyst to
      accelerate curing.
3.     THERE ARE SEVERAL EMISSION SOURCES

           Emission Sources Are Present In Raw Material Handling,
           Prepolymer Manufacture And Finished Product Handling

                 Prepolymer manufacturers that are basic in
                 isocyanate manufacture will have less problem
                 in raw materials handling than small, non-basic
                 producers.

                       Basic producers will pump product directly
                       from bulk storage while small producers must
                       hand-handle drums and spillage by the latter
                       is more prevalent.

                       This same situation is true of solvent handling.

                 Displacement of moist air in reactors would cause
                 some vapors to vent.

                 Shipments of finished product are usually in small
                 lots, and the filling and shipping area would be a
                 source of vapors from

                       Solvents
                       Isocyanates
                              VI-59

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4.    MOST PLANTS FOLLOW REASONABLE SAFETY PRECAUTIONS

      Isocyanates can be handled, stored and used safely if their properties
are understood and the precautions are observed. The irritating character
of isocyanate vapors are the most objectionable feature of these compounds.

      Some of the low molecular weight isocyanates have relatively high
vapor pressures. TDI, for example, can be detected, by smell, in concen-
trations as low as 0.1 -  1 ppm. The maximum allowable concentration in the
air fpr extended  exposure is said to be 0.1 ppm.

      The main precaution taken, in plant, is proper ventilation or the use
of respirators  or gas masks.
                              VI-60

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                      VI-L  CELLULOSICS
      Cellulosic plastics are those products obtained by the esterification
of cellulose.  Cellulose itself is a stable polymer of glucose and is the pre-
ponderant and essential constituent of all vegetable tissues and fibers,
including especially cotton and wood.  Pure cellulose is now generally
obtained from treatment of wood.  In terms of production volume, cellulose
acetate and cellulose nitrate are of about equal importance.
1.    THE PRINCIPAL PROCESSING STEPS IN THE MANUFACTURE OF
      CELLULOSE ACETATE ARE PRETREATMENT OF CELLULOSE,
      ACETYLATION, HYDROLYSIS . PRECIPITATION , STABILIZATION
      AND ACETIC ACID RECOVERY

      (1)   Pretreatment Is Essentially Drying Cellulose To A Fixed
            Moisture Content In The Presence Of A Pretreating Reagent

            The cellulose is first dried to a fixed optimum moisture
      content by pretreating with acetic acid to swell the cellulose. This
      permits the acetylation reagent to diffuse into the fiber more readily.
      The time of treatment varies from 15 minutes  to several hours, de-
      pending upon the pretreating liquid and the amount used.

      (2)   The Acetylation Mixture Consists Of Acetic Anhydride, Acetic
            Acid Or Methylene Chloride And Sulfuric Acid

            The acetylation of cellulose is highly exothermic and tempera-
      ture control is very important.  In the process  in which acetic
      anhydride, acetic acid and sulfuric acid are used, two types of
      acetylators have been employed - the brine cooled, sigma-bladed
      mixer, and the cylinder mixer which rotates  on a horizontal axis.
      These reactors are large enough to acetylate 200-600 Ib of cellu-
      lose per charge.  The temperature is controlled between 5 - 45°C.

            In the methylene chloride process, much of the reaction heat
      can be dissipated in refluxing the methylene chloride, so that large
      batches can be acetylated.  Batches of up to 7,000 Ib have been
      handled by this process, although most reactors are smaller.  The
      reactors are horizontal bronze alloy or stainless-steel cylinders
      equipped with stirring blades on a horizontal axis.
                               VI-61

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(3)   The Acetylated Dope Is Hydrolyzed

      The water content of the dope is adjusted to 5-10%. The
rate of hydrolysis is controlled by the sulfuric acid/water ratio
and by the hydrolysis temperature, which is generally slightly
above room temperature.  The catalyst/water ratio must be  kept
below a certain level to avoid degradation. This can be accom-
plished by increasing the water content or decreasing the amount
of catalyst (by neutralization), depending upon how rapid a
hydrolysis is desired. The hydrolysis is then arrested by
neutralizing the sulfuric acid catalyst, usually with sodium
acetate.

      The hydrolyzers are vessels large enough to handle one
or more acetylation batches.  Some are equipped with agitators,
generally rotating blades on a vertical shaft. When the hydrolysis
is carried out without agitation. the product is precipitated in
another vessel in which the reaction mixture may be agitated.
Hydrolyzers are generally of stainless-steel, copper, bronze alloy
or glass-lined steel.

(4)   Precipitation And Purification Involves Generation Of
      Significant Volumes Of Dilute Acetic Acid

      Cellulose acetate is precipitated by diluting the dope with
water to a point somewhat short of precipitation and then mixing
with an excess of aqueous acetic acid  solution with vigorous
agitation. It is then purified by washing with water, 10% sodium
bicarbonate or magnesium ion to neutralize the sulfuric acid
catalyst, centrifuged and dried at 95°C.

      Acetic acid is a major by-product in the manufacture of
cellulose acetate and must be recovered to make the process econom-
ical.  All wash liquors containing an appreciable amount of acetic
acid are combined to give an aqueous solution containing 18-20%
acetic acid.  Glacial acetic acid is obtained by concentrating this
liquor and is returned to the process.
                         VI-62

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2.    THE USUAL TECHNIQUE FOR THE MANUFACTURE OF CELLULOSE
      NITRATE IS THE MECHANICAL-DIPPER PROCESS

      This is a batch process as shown in Exhibit VI-L.  A continuous
nitration process with countercurrent washing  of the crude, acid wet nitrate
has been developed but details of the process are not available.

      (1)    Nitration Is Accomplished With Mixed Acid

            About 30 Ib of cellulose (containing less than 1% moisture)
      is added to the dipper containing about 1,600 Ib of mixed acid
      (sulfuric acid and nitric acid).  The reaction temperature is con-
      trolled by adjusting the temperature of the acid before it is added
      to the reactor. When nitration is complete  (20-30 minutes), the
      reaction mixture is dropped into a centrifuge which removes most
      of the acid which is pumped to a tank where it is brought back to
      strength for reuse by adding concentrated  acid. The centrifuged
      cellulose nitrate is dropped through the bottom of the centrifuge and
      drowned in water.  It is  then pumped as  a water slurry  to the puri-
      fication area.

      (2)    Purification Is Accomplished By Boiling  In Dilute  Mixed
            Acid Or Water

            Purification and stabilization are carried out in batches as
      large as 12,000 Ib in tubs lined with stainless-steel. The  cellulose
      nitrate is first washed to a low level of acidity, then boiling one or
      more times in very dilute mixed acid or pure water, water-washing
      between boils. Finally,  the product is steeped or  boiled in dilute
      sodium carbonate and washed free of alkali.

      (3)    Cellulose Nitrate Is Dehydrated Before Shipment Or Storage

            It is hazardous to ship or store cellulose nitrate in the dry state
      and it is shipped either water-wet or,  more commonly, alcohol-wet.
      Alcohol-wet cellulose nitrate is often used without drying, since
      alcohol is generally part of the formulation in which cellulose nitrate
      will be used.  It is prepared by compressing the water-wet material
      into blocks at pressures  of 17 atm,  and pumping alcohol through the
      blocks at this pressure.  The compressed blocks are then  broken
      mechanically, and the alcohol-wet (about 35% alcohol) material is
      shipped in galvanized steel drums.
                              VI-63

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                                 EXHIBIT VI-L
                    Environmental Protection Agency
                                 FLOW SHEET:
                    THE MECHANICAL DIPPER PROCESS
                    FOR NITRATING CELLULOSE (37)
                               Measuring
                                 tank —I,
                                       'I
Air connection
for blowing oul
 fume ouliels
 Dipping tanks —ri!-
                                   Air conneclicn for
                                    blowing chokes
                     	
               ^                     '.^i'v^.
              Cellulose niirate header
                               nx-wsfnr iiitr:»tinn
                VI-64

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3.     ACETIC ACID AND NOX FUMES CHARACTERIZE THE PREPARATION
      OF CELLULOSE ACETATE AND NITRATE RESPECTIVELY"

      Methylene chloride vapors may also be associated with cellulose
acetate manufacture.  Sulfuric acid fumes may emanate from both acetate
and nitrate production.  Acetic acid vapors can occur in both the manu-
facture and acid recovery cycle.

      NO  fumes evolve during nitration of cellulose.  Alcohol vapors are
vented in the dehydration cycle.
                             VI-65

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                     VI-M  EPOXY RESINS
1.    MANUFACTURE IS A LOW TEMPERATURE BATCH OPERATION

      (1)    Each Producer Has Developed His Own Technique, But The
            Following General Procedure Is Applicable

            Bisphenol A, epichlorohydrin and caustic are added together
      to the reactor and heated to 50-60°C.  The exothermic heat of reac-
      tion raises the temperature and must be controlled to 90-95°C.
      Excess epichlorohydrin is removed after condensation is complete,
      by vacuum  distillation.  (Toluene may be added to facilitate removal
      of the salt formed.)  The resin is washed with warm water, filtered
      and dried at 150°C under vacuum.  A thin film evaporator may be
      used to remove last traces of solvent/water.

      (2)    Most Epoxy Resin Plants Have Similar Layouts And Equipment

            Equipment layout for a typical resin plant is shown in
      Exhibit VI-M.  This exhibit is for the manufacture of solid resins.
      A liquid resin plant would be essentially the same except there would
      be no flaking equipment. Equipment requirements include a jacketed
      steel or stainless steel reactor equipped with a reflux column, agita-
      tor and condenser, a separator tank for washing the resin, a filter,
      a finishing  kettle for  removing the last traces of solvent/water, a
      Rodney-Hunt thin film evaporator may be alternate equipment,  and a
      flaker for solid resins.

      (3)    There Are  Three Major flaw Materials  Used

            Between 80-90% of the epoxy resins produced  are made from
      Bisphenol A and epichlorohydrin.  Sodium hydroxide is the other
      major raw material used as a catalyst for the condensation and reacts
      to dehydrohalogenate the resultant bisphenol glycidyl chlorhydrin
      and is thereby removed from the reaction as salt.
                               -VI-66

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                                        EXHIBIT VI-M
                           Environmental Protection Agency
                                        FLOW SHEET:
                                  EPOXY  RESIN PRODUCTION (38)
 ^•-  ..  Ifc   I       -,1 ... -   ...       f— .   .j
 /S»iC«lO« »»*•'« \ Y      I *CT *1*1'* \ I     [ ItQOlO "till
 I  ilOn*OC   1        I  STORAGE  1 iMr.Ti^c I  S'O»*OE
 V  '    J        \	/] =«n-\>
o—J                     ^-o^^..
                      VI-67

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2.     THERE ARE SEVERAL POTENTIAL EMISSION SOURCES

      In-plant emissions occur as a result of the manufacturing process.
                 Vapors can escape through reactor packings and pumps.

                 Vapors escape by way of the vacuum pumps on
                 distillation columns.

                 There is some entrainment of epichlorohydrin in
                 wash liquors.

                 Liquid from pumps.

                 Hot resin odor on flakers.
3.     THERE ARE THREE PRINCIPAL EMISSIONS

                 Bisphenol A has a mild phenolic odor, b .p.  = 220°C
                 (4mm) minimal odor /hazard.

                 Epichlorohydrin has a boiling point of 115°C and is
                 highly volatile, unstable and narcotic with a chloroform-
                 like odor.  It is absorbed and accumulated by the body
                 and can lead to serious physiological, particularly nerve,
                 disorders.

                 Methanol has a boiling point of 64.5°C and is poisonous.
                              VI-68

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                   VI-N  POLYAMIDES
      Polyamide resins can be divided into two principal types;  (1) Nylon
type, and (2) Non-nylon type.  The former are primarily those based on
Nylon 6 and Nylon 66 and account for over 80% of polyamide resins produced.
The non-nylon resins are based primarily on dimerized polycarboxylic acids
and polyamines.
1.    POLYAMIDE RESIN PROCESSES ARE HIGH TEMPERATURE, LOW
      PRESSURE BATCH OR CONTINUOUS OPERATIONS

      (1)   Nylon 6 Involves Heating Caprolactam With A Catalyst And
           Chain Terminator

           Schematics for batch and continuous polymerizations are
      shown in Exhibit VI-N1.

           Molten caprolactam is mixed with water, catalysts, stabilizer
      and delusterant  (if fibers are to be made) and is fed into a reactor
      which is operated at about 500°F.  The mass slowly proceeds down
      the reactor which is usually divided into several zones.  The over-
      all reaction is slightly exothermic and heat exchange is provided by
      Dowtherm. The reactor effluent consists of molten polymer, monomer,
      oligomers and water.  Monomer and oligomer constitute 10-15% of the
      reactor effluent.

           There are two methods being used to purify the crude polymer
      and recover unreacted polymer.  In the first, the polymer is cast into
      ribbon form,  quenched and cut into chips. Unreacted monomer and
      some oligomer are removed from the chips by extraction with hot water.
      The water is sent to monomer  recovery where the oligomers are de-
      polymerized and the monomer is dehydrated and returned to the system,
      The chips are dried and are then ready for melting and spinning or
      bagging.

           In the second method, the molten polymer exiting from the
      reactor is sent to a vacuum distillation column where monomer, water
      and  oligomers are removed overhead.  The molten polymer can then
      be spun directly into fibers or cut into chips for bagging.
                             VI-69

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                                    EXHIBIT VI-N1
                       Environmental Protection Agency
                                    FLOW SHEET:
                              NYLON 6 PRODUCTION 139)
L1CMM
KILTER
                 Hated polymerization uf N \loix G.
                 Conlinnoiia polympnziilion of Nylon 6.
                  VI-70

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(2)   Nylon 66 Is Made By Polymerization Of Nylon Salt
      [hexamethylenediammonium adipate)

      The polymerization can be either batch or continuous. A
typical plant and schematic is shown in Exhibit VI-N2.

      Nylon monomer (nylon salt) is usually fed as a water suspen-
sion or homogeneous mixture to an evaporator where it is concentrated
to a 50-60% aqueous slurry by removal of water.  This aqueous slurry
together with additives such as  0.5% by weight acetic acid as a chain
terminator (viscosity, m. wt.  control), TiO? as a delusterant,  are
pumped to an autoclave reactor. Here temperature is increased to
260°C - 2BO°C and pressure is allowed to build to 17 atm by
controlled venting of the steam produced from  the condensation poly-
merization .  Any water remaining  after this point is reached is then
removed by lowering the pressure to atmospheric while maintaining a
constant temperature. The polymer (12,000 -  20,000 m.wt.) is a clear
melt which is removed from the  reactor under  nitrogen, cooled and
cast (palletized)  quickly as it is not stable at high temperatures.  The
solid nylon 6,6 resin is flaked or chipped and  can then go to product
storage.  These flakes can be remelted and spun into filaments or
molded to various shapes.

      Continuous Process

      A more recent development in nylon 6,6 manufacture is the
continuous process.  The chemistry of this reaction is identical to the
batch process. However, where it may take 2-4 hours to convert nylon
salt to finished polymer in  the batch process, monomer goes to polymer
in the continuous process in about 5 minutes.

      Nylon salt solution is fed  to  a thin film evaporator at about
110°C. where the bulk of the water of solution  is removed. Any addi-
tives needed are generally added after the evaporation stage and
these plus the dewatered monomer are fed to another thin film evapor-
ator held at 230°C and elevated pressure where the condensation
polymerization takes place and the water is removed as steam.  Molten
polymer goes to a "flasher" at atmospheric pressure to remove  more
water of condensation.  The polymer may be put through a finishing
step at 280°C to be sure polymerization is  complete or it may by-pass
this step.  In any  event the hot molten polymer goes directly to spin-
ning, drawing and beaming operations rather  than cooling and casting
into resin as in the batch process.
                         VI-71

-------
                                        EXHIBIT VI-N2
                            Environmental Protection Agency
                                        FLOW SHEET:
                                   NYLON 66 PRODUCTION <4t))
VENT (HjO!
                     Polymerization of Nylon 66.
                         VI-72

-------
      (3)   The Non-Nylon Polyamides Are Prepared By Condensing
           Dimerized Polycarboxylic Acids With Polyamines

           The process is a batch operation. Initial condensation is
      conducted at 100°C until all water of reaction is distilled off. In-
      crease the temperature to 150 ~ 250°C to advance the polymerization
      to desired viscosity or molecular weight.  The molten product is
      packaged in metal containers directly.

      (4)   Soluble Polyamides Which Are Copolymers Of Nylon 6,
           Nylon 66, And Nylon 610 Are Available.

           These copolymers are usually available as solutions con-
      taining water, alcohol (methanol, ethanol or isopropanol) or other
      solvents.  Solutions of 30-55% polyamides can be prepared.
2.    THERE ARE  SEVERAL POTENTIAL EMISSION SOURCES

                  The driers and surge tanks are principal sources of
                  emissions.

                  The vacuum lines are also potential sources of emissions.


3.    EMISSIONS ARE MINIMAL

      (1)    Acetic Acid Is The Main Offender In Nylon 6 Production

            This modifier could vaporize in the evaporator stage as well
      as from reactor venting.

      (2)    Hexamethylene Diamine And Acetic Acid Could Be Emitted
            In Nylon 66 Preparation

            Hexamethylene diamine (ammoniacal odor) could come from
      handling and on venting the blend tank.
                              VI-73

-------
      SECTION VH
PRIORITY DECISION MODEL

-------
                          SECTION VII
                   PRIORITY DECISION MODEL
      A decision model is a useful tool in establishing priorities among
the various sectors of the chemical/plastics industry with appropriate
weight given to each of the principal factors considered in formulating
and implementing air pollution control policy and defining the direction
of related research and development.

      The model defined in this section assimilates the systems analysis
criteria of the study in a standardized fashion to enable the determination
of priorities and the selection of candidates for detailed study.

      Exhibit VII-1 presents a summary of the required systems analysis
factors featured  in the priority decision model.  The  detailed characteriza-
tion of each broad factor appears in subsections 2,3,4 and 5.
1.    THE DECISION MODEL IDENTIFIES POLYURETHANES AND
      ACRYLICS IN THE CHEMICAL/PLASTICS INDUSTRY AS
      THE LEADING CANDIDATES FOR DETAILED STUDY

      Exhibit VII-2 presents a summary of the priority decision model.
The overall selection index number ranges from a low of 23.3 to a high of
160.2. Within this range, the 14 chemical/plastics industry sectors
studied are well differentiated.

      Polyurethanes with an overall selection index number of 160.2 and
acrylics with 137.3 are identified as candidates for detailed study.

      Subsection 2 discusses the detailed derivation of the production and
population exposure related index in the model.

      Subsection 3 discusses the detailed derivation of the total potential
emission index in the model.

      Subsection 4 describes the derivation of the hazard index, while
subsection 5 describes the odor index.
                            VII-1

-------
                                                      EXHIBIT VII-1
                                          Environmental Protection Agency
                                          SUMMARY OF FACTORS IN THE
                                          PRIORITY DECISION MODEL
 Broad Systems Analysis Factors For
 Each  Chemical/Plastics  Industry Sector
 A:
Market and Production from
data in Section V
 B:
Emission Potential from
information in Section VI

Hazard Potential from
information in Section VI
       Odor Potential from
       information in Section VI
                                                          Sub-Factor
                                   Sub-Factors              Weight
 A^Total Potential          0.4
    Population Exposed
 A2=Population Exposure     0.2
    Potential of the
    Average Plant
A3=Plastic Production       0.2
    Volume
 A4=Production Growth      0.2
    Trend
 Process Technology        1.0
 Assessment

 Toxicity (TLV)             1.0
 of Principal Likely
 Emissions

 Odor Threshold of          1.0
 Principal Likely
 Emissions
                    Priority Decision Formula

             AC + BC + AD = R, where R is the overall rating

 The formula has the following features:

             The hazard factor, C, appears twice as a multiplicant and
             is given significant emphasis, as required by EPA

             The product of A x C emphasizes situations where the hazard
             potential is high and the potential population exposure is great

             The product of B x C emphasizes situations where hazard
             potential and emission potential are high and, therefore, the
             relative magnitude of potential concentrations of hazardous
             substances at receptor locations are factored in qualitatively

             The product of A x D emphasizes the relative magnitude of the
             potential nuisance to the population from odorous substances
Source:  Snell (and EPA and Snell in development of priority decision formula)
                             VII-2

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                                                                                      EXHIBIT VH-2
                                                                                Environmental Protection Agency
                                                                                SELECTION OF PLASTICS SECTORS
                                                                                     FOR DETAILED STUDY
                  Selection formula:
G
i
co
         Plastic
                    Production 8
                    Population
                    Exposure
                    Related Index
                    Number
                                  AC  + BC + AD = R
                                               B
Emission
Potential
  Index
Number
Vinyl Resins            10.0
Styrene Resins           8.5
Acrylics                8.5
Alkyds                  8.0
Polyurethanes            8.0
Phenolic and Other Tar
    Acid Resins         7.5
Polyethylene and
  Copolymers           6.5
Polyesters               6.5
Amino Resins            6.5
Cellulosics              6.0
Polyamides              5.5
Polypropylene           5.0
Coumarone-Indene  and
  Petroleum  Resins      5.0
Epoxy Resins            3.5
   7.0
   7.4
   5.0
   4.8
   2.6

   4.0

   8.0
   4.8
   5.3
   6.7
   7.0
   8.8

   7.1
   4.2
Hazard
Index
Number
                                                               2.8
                                                               4.5
                                                               6.6
                                                               9.3

                                                               5.2

                                                               1.3
                                                               6.6
                                                               4.8
                                                               3.5
                                                               1.2
                                                               1.7

                                                               4.2
                                                               5.4
                                                                           D
Odor
Index
Number

  2.3
  7.4
  9.0
  5.0
  7.7

  6.9

  2.5
  5.3
  6.8
  4.3
  1.5
  1.9

  7.7
  4.1
Overall
Selection
Index
Number
91.0
107.4
137.3
124.5
160.2
111.6
35.2
109.1
100.8
70.3
23.3
33.0
89.3
56.0


Priority
Order
8
6
2
3
1
4
12
5
7
10
14
13
9
11
       I1)  Based on 50 ppm TLV for vinyl chloride

       Source:   Snell

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2.    THE PRODUCTION AND POPULATION EXPOSURE RELATED
      INDEX WAS DEVELOPED CONSIDERING TOTAL POTENTIAL
      POPULATION  EXPOSED. POPULATION EXPOSURE POTENTIAL
      OF  THE AVERAGE PLANT.  PLASTIC PRODUCTION VOLUME
      AND GROWTH TREND

      To develop the production and population exposure related index,
Column A  in Exhibit VII-2, a decision matrix approach was used.

      A decision matrix  can be depicted as a rectangular grid containing
values for a specific set of co-ordinates.  In this case, the vertical co-
ordinate contains the plastics under consideration, and the horizontal co-
ordinate lists the variables under consideration. This matrix is shown
in Exhibit VII-3.
      (1)    The Population Exposed To Potential Emissions From
            The Manufacture Of Each Plastic Was Estimated Using
            SMS A And State  Population Densities

            In developing a population exposure index, we considered
      the average population per square mile for the major Standard
      Metropolitan Statistical Areas (SMSA's) with which each plant
      location could be identified or the average population per square
      mile for the state with which each plant could be identified, if no
      SMSA correlation was apparent. The U.S. Department of Commerce's
      Statistical Abstract of the United States, 1972, was the source of
      these data.

            Production locations for each resin, regardless if there were
      more than one resin manufactured at this site, were located by SMSA
      and/or state using the information from Section V.  The number of
      plant locations, or establishments listed is,  therefore, significantly
      more than that given by the Bureau of Census.

            The total potential population exposed for each resin was
      estimated by the following procedure:

                  assume that the area of influence of each plant is
                  one square mile

                  correlate each plant location with an SMSA
                           VII-4

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                                                                                          EXHIBIT VH-3
                                                                              Environmental Protection  Agency
                                                                              DEVELOPMENT OF THE PRODUCTION
                                                                              AND POPULATION EXPOSURE RELATED
                                                                                           INDEX
                                                                                                1-4
a
Ol
      Plastic
                    Total
                    Potential
                    Population
                    Exposed
Polyethylene and
   Copolymers          2
Vinyl Resins            8
Styrene Resins         6
Polypropylene          2
Phenolic and  Other
   Tar Acid Resins      8
Polyesters              6
Amino Resins          8
Alkyds                10
Acrylics               8
Coumarone-Indene and
   Petroleum  Resins     4
Polyurethanes          8
Cellulosics             4
Epoxy Resins           2
Polyamides             4
Rosin Modifications      6
Population
Exposure
Potential of
the Average
 Plant
                                             1
                                             3
                                             3
                                             1

                                             2
                                             2
                                             1
                                             4
                                             3

                                             4
                                             3
                                             5
                                             2
                                             2
                                             3
  Plastic
Production
  Volume
                      5
                      4
                      3
                      2

                      1
                      1
                      1
                      1
                      1

                      1
                      1
                      1
                      1
                      1
                      1
Growth
Trend
                      5
                      5
                      5
                      5

                      4
                      4
                      3
                      1
                      5

                      1
                      4
                      2
                      2
                      4
                      1
                                                                                             Total
                                                                                             Score
Index
13
20
17
10
15
13
13
16
17
10
16
12
7
11
11
6.5
10.0
8.5
5.0
7.5
E.5
6.5
B.O
8.5
5.0
8.0
6.0
3.5
5.5
5.5
     1 - Total Score normalized on a scale of 10.  See Exhibit VE-2 for  use of index
     Source:    Snell

-------
            sum the average population per square mile for each
            plant associated with an SMSA or if a plant is not
            associated with an SMSA use the average population
            per square mile for the state in which each plant is
            located.

      Values for the total potential population exposed for each resin
are tabulated in decreasing order in Exhibit V-4, and scoring values
of 2 to 10 are based on total population exposed as follows:

            Score 2  = less than 15,000
            Score 4  = 15,000to50.000
            Score 6  = 50,001toiOO,000
            Score 8  = 100,001to200,000
            Score 10 = over 200,000
 (2)   The  Population Exposure Potential Of The Average Plant
      Indicates To What Extent Each Plastic  Producing Industry
      Is Located  In Densely Populated Areas

      The population exposure potential of the average plant in each
plastic manufacturing category is estimated by dividing the total
potential population exposed by the number of plants.  Values for
the population exposure potential of the average plant in each plastic
manufacturing category are tabulated in decreasing order in Exhibit
VII-5, and are scored from 1 to 5 as follows:

            Score 1 = less than 500
            Score 2 = 500 to 1,000
            Score 3 = 1,001 to 1,500
            Score 4 = 1,501 to 2,000
            Score 5 = over 2,000

      Plastic categories appearing at the top of the list represent
relatively urban industries in terms of plant sites while those to-
ward the bottom of the list represent relatively rural siting.
(3)   The Total Volume Of Plastic Production Is A Factor

      Broadly, the greater the volume of resin produced, the
greater the odor or hazard potential,  particularly if differences in
production volumes are large.  The percent volume production is
shown in Exhibit V-4.  These values  are scored from 1 to 5 and are
entered under Column A3, Plastic Production Volume, in Exhibit VH-3.
                      VII-6

-------
                                                    EXHIBIT VII-4
                                      Environmental Protection Agency
                                       TOTAL POPULATION EXPOSURE
                                               MEASURE
                            Number of
Resin System                  Plants

Alkyds                         173
Vinyl Resins                   153
Amino Resins                   166
Phenolic  and Other Tar
   Acid Resins                 168
Acrylics                        127
Pplyurethanes                    86
Rosin Modifications              64
Polyesters                       81
Styrene Resins                  65
Coumarone-Indene and
   Petroleum Resins              20
Cellulosics                       8
Polyamides                      24
Polyethylene and Copolymers     25
Epoxy Resins                     8
Polypropylene                    11
                                       Total Potential
                                    Population Exposed

                                      264,500
                                      171,800
                                      164,800
                                      164,600
                                      150,100
                                      122,200
                                       90.800
                                       78,200
                                       74,200

                                       30,200
                                       20,900
                                       18,700
                                       11,500
                                        7,800
                                        3,200
1,2
       Score*

        10
         8
         8

         8
         8
         8
         6
         6
         6

         4
         4
         4
         2
         2
         2
  Assuming the area of potential exposure per plant is one  square  mile

  Weighted Average Population Exposed for a given Resin System =
/   Plant \
| Location/
    PlantN
 Location/

                      /Average Population per  Square Mile\ +
                      \  associated with location i in SMSA /

                      /Average Population per Square Mile in State associated \
                      \  with j _if correlation with SMSA is not possible      /
  See Exhibit VII-3, Colume Aj for use  of scores to indicate total potential
  population  exposed.
 Source:  Information in Section V and Snell estimates
                            VH-7

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                                              EXHIBIT VII-5
                                      Environmental Protection Agency
                                   THE  POPULATION EXPOSURE POTENTIAL
                                           OF THE AVERAGE PLANT
                                              Weighted Average
                                Population Exposure
Resin System               Index Per Plant Per Square Mile    Score
Cellulosics                             2,620                    5
Alkyds                                 1,530                    4
Coumarone-Indene and
   Petroleum Resins                    1,510                    4
Polyurethanes                          1,420                    3
Rosin Modifications                     1,420                    3
Acrylics                               1,180                    3
Styrene Resins                         1,140                    3
Vinyl Resins                           1,120                    3
Phenolic and Other Tar Acid Resins        980                    2
Epoxy Resins                            970                    2
Polyesters                                965                    2
Polyamides                               980                    2
Polyethylene and Copolymers              460                    1
Polypropylene                            290                    1
Amino Resins                            100                    1
   Total  Potential Population Exposed -j-  Number  of Plants,
      shown in Exhibit VII-4
o
   See Exhibit VII-3, Column A2,  for use of scores  to indicate
      the population exposure potential of the average plant
Source:    Snell
                            VIl-8

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                 Score 1 = less than 6.2% of total production
                 Score 2 = 6.2% to less than 12.4% of total production
                 Score 3 = 12.4% to less than 18.6% of total production
                 Score 4 = 18.6% to less than 24.8% of total production
                 Score 5 = 24.8% of total production or greater
      (4)   Growth Rate And Need For  Additional Capacity Is A
           Factor Related To Future Production

           The average rate of consumption over the near future will
      determine if new capacity will be required. Exhibit V-l summarizes
      the outlook for the resins studied through 1977, assuming normal
      trends, that is,  there will be no impact upon growth from  the current
      shortages of raw materials.

           Scores from 1 to 5 were assigned as shown below and entered
      under Column A4, Growth Trend, of Exhibit VII-3.

                 Score 1 = negative growth rate or no growth
                 Score 2 = less than 5% growth rate and capacity adequate
                 Score 3 = less than 5% growth rate and new capacity
                          will be needed or 5-10% growth rate and
                          capacity adequate
                 Score 4 = 5-10% growth rate and new capacity will be
                          needed or greater than 10% growth  rate and
                          capacity adequate
                 Score 5 = greater than 10% growth rate and new capacity
                          will be needed
3.    THE EMISSION POTENTIAL INDEX WAS DEVELOPED FROM
      STANDARDIZED EVALUATION AND COMPARISON OF THE
      MAJOR POLYMERIZATION  PROCESSES

      To develop the emission potential index a decision matrix approach was
used, and is described below.

      Polymer plants operate under widely differing conditions.  It is still
possible, however, to consider certain operating functions common to all
plastic processes.  These are:

                 Receiving and storage of process chemicals

                 Purification of monomers and solvents
                            VII-9

-------
                  Prepolymerization

                  Polymerization

                  Polymer separation

                  Compounding.

      Each of the above functions will, to some degree, contribute to the
total emissions of a process.  Individually,  each can be rated on the basis
of a very high (10) to a very low (2) emission potential related to the variable
factors of process design, operating conditions and the chemistry involved.
It is also understood, that the emission contribution of each factor may be
different and must be weighed to reflect its relative importance to the total
emission potential of the process.  The sum of the values obtained (intensity
rating times percent of total contribution) will represent the best relative
estimate of the emission potential for that plastic process.  Repetition of this
analysis for all the plastic processes will produce a series of index numbers
which can be compared on the basis of seriousness of potential emissions.

      For example, the emission potential,  during storage of a liquified gas
may be very high (rating of 10); during polymerization, the emission potential
may be low  (rating of 4).  But, the relative emission contribution from storage
may only be 10% as compared to polymerization of 90%, so that the total emission
potential is the sum of (10 x 0.1) plus (4 x  0.9) or 1 plus 3.2 or a total of 4.2.

      Exhibit vn-6 shows the decision matrix used for process screening.
The vertical co-ordinate lists the factors under consideration,  and the hori-
zontal co-ordinate indicates the emission ratings assigned,  based on the oper-
ations within each phase.

      Manufacturing processes range from very complex to rather simple
procedures, and from single large operating units to small multi-batch units.
For the purpose of this evaluation,  all processes were considered in their
simplest unit operations.

      Appendix 2 presents the technical evaluation grids for each plastic
class. A summary listing of the results ranked according to total emission
potential is shown in Exhibit VII-7.
                             VII-10

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                                                                                                          EXHIBIT VII-6
                                                                                               Environmental Protection Agency
                                                                                               DECISION MATRIX FOR EMISSION
                                                                                                         POTENTIAL
^^v^^ EMISSION/ODOR
^POTENTIA L
OPERATING FUNCTION^^^^
RECEIVING, STORAGE AND
HANDLING OF PROCESS
CHEMICALS
PURIFICATION OF MONOMER
AND
SOLVENTS
PREPOLYMERIZATION
POLYMERIZATION
POLYMER SEPARATION
COMPOUNDING
VERY
HIGH
(10)
gases or
liquified gases
Venting of monomer
and solvent
purification systems

Pressure over 70
atm and above the
b.p. of ingredients
Polymer injected
into solvent or water,
filtered, dried and
extruded
Direct casting or
molded
HIGH
(8)
Liquids with high
vapor pressure
(over 25 mm Hg)
Venting of monome
purification
system

Pressure between
10-70 atm and
above the b.p. of
ingredients
Reaction mass
dried and
extruded
Partial polymer-
ization or " B"
staging
MEDIUM
(6)
Liquids with low
vapor pressure
: Venting of solvent
purification
system
Premixing of gaseou
monomers with
catalyst and pre-
>olymerization
Pressure below 10
atm and above the
b.p. of ingredients
Reaction mass
dissolved in
solvent
Mixing with
volatile solvents
and plasticizer
LOW
(4)
Solids with high
vapor pressure
(over 25 mm Hg)

Mixing of monomer
with solvent
compressing gases
Atmospheric pressure
and reflux temp.
Reaction mass
dispersed in
water
Mixing with solids
and making molding
compounds
VERY
LOW
(2)
Solids with low
vapor pressure

Mixing of monomer!
with water
melting solids
Atmospheric pressure
and below the b.p
of ingredients
Reaction mass
stored directly

Source-   Snell

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                                              EXHIBIT VII-7
                                     Environmental Protection Agency
                                      TOTAL POTENTIAL EMISSION
                                                 INDEX
                                                            6
       Plastic                                 Index Number
Polypropylene                                       8.8
Polyethylene1 and Copolymers                        8.0
Styrene  Resins                                     7.4
Coumarone-Indene and Petroleum  Resins               7.1
Vinyl3 Resins                                       7.0
Poly amides^                                         7.0
Cellulosics                                          6.7
Amino Resins                                        5.3
Acrylics5                                           5.0
Alkyds                                              4.8
Polyesters                                           4.8
Epoxy Resins                                        4.2
Phenolic  and Other Tar Acid Resins                   4.0
Polyurethanes                                       2.6
1.    70% LD and 30% HD Polyethylene
2.    76% Polystyrene and 24% ABS
3.    94% PVC, 5% PVAc and 1% PVAlc
4.    80% Nylon 66  and 20% Nylon 6
5.    50% Emulsion  and 50% Solution
6.    See Exhibit VII-2 for  use of the index
Source:    Snell, details in Appendix 2
                            VII-12

-------
 (1)   Receiving And Storage Of Process Chemicals (Monomers,
      Solvents, Catalysts) Is A Source  Of Emissions

      Emissions originating from storage facilities are dictated, to
a large extent, by the physical and chemical characteristics of the
raw materials used in the process. Most of the emissions are due
to venting of storage tanks, line and valve leaks and spillage during
handling.  Ratings in terms of potential emissions can range from
very high (10) to very low (2) as follows:

      10 -  gases or liquified gases
       8 - liquids with high vapor pressure  (greater than
          25 mmHg (25°C))
       6 - Liquids with low vapor pressure
       4 - solids with high vapor pressure (greater than
          25 mm Hg (25°O)
       2 - solids with low vapor pressure
 (2)   Purification Of Monomers And Solvents Can Be A Potential
      Source Of Emissions

      While most monomers and solvents are available commercially
in relatively pure states they may contain trace impurities which must
be removed to avoid adverse effects on the polymerization reaction, or
they may contain inhibitors which are added to prevent polymerization
in transit or storage. Whatever the source of impurity, monomers and
solvents must be properly purified when necessary.

      In many processes, monomer and solvents are removed from
the polymerization and are purified and recycled.  Purification usually
takes the route of condensation  and redistillation.  In most instances
emissions originate from condenser vents and line leakage. Ratings
in terms of potential emissions can range from very high  (10)  to medium
 (6) as follows:

      10 - Venting of solvent and monomer purification systems
       8 - Venting from monomer purification system
       6 - Venting from solvent purification system
                      VII-13

-------
(3)   Another Emission Source Is In The Preparation Or
      Prepolymerization Phase

      Chemicals and catalysts may be diluted, premixed,  aged,
ground or otherwise treated before polymerization. While some of
these processes can be carried out in separate vessels, reactors or
tanks, they may also be carried out directly in the reactor before
polymerization.  The emission potential may range from medium  (6)
to low  (2) as follows:

      6 - premixing of gaseous monomers with catalyst and
         prepolymerizing
      4 - mixing of monomers with solvent
       -  compressing gases
      2 - mixing of monomers with water
       - melting solids
       - preheating liquids

      Emissions can occur as a result of leaks and purging and
venting of prepolymerization equipment.
(4)   The Polymerization Section Is A Prime Source  Of Emissions

      There are many conditions and combinations of conditions in
which polymerization takes place. Polymerization methods include
bulk, solution,  suspension and emulsion.  Operating conditions can
range from very high temperatures and/or pressures to low pressure
and ambient or  cooler temperatures.  The polymerization can be con-
tinuous or batch or may even start as one type and end as another, i.e.,
nylon 66 polymerization starts  as a solution and at the end is essentially
a bulk polymerization.

      Nevertheless, certain generalities must be assumed in order to
evaluate the emission potentials of this phase of the process.  As would
be expected, the emission potential can range from very high (10) to
very low (2). Emissions occur through reactor venting agitator packing,
piping and valve leaks, condenser venting and/or reactor leaks.  Ratings
are as follows:

      10 - Pressure and temperature above 70 atm and the boiling
          point (at 760 mm) of the ingredients respectively
       8 - Pressure and temperatures of 10-70 atm and the boiling
          point (at 760 mm) of the ingredients respectively
       6 - Pressure and temperature below 10 atm and above the
          boiling point (at 760 mm)  of the ingredients  respectively
       4 - Atmospheric pressure and reflux temperature
       2 - Atmospheric pressure and temperature below the boiling
          point (at 760 mm) of the ingredients respectively.

                      VII-14

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(5)   Many Operations Can Be Involved In The Separation Of
      Polymers From The Reaction Mass

      This section of the total polymerization process can range from
a single  operation to a combination of operations  culminating in pro-
duction of  a solid or liquid product, the former being essentially  a
"pure polymer" and the  latter being  a polymer in a solution or emulsion
form.

            Emissions can occur in any single or combination
            of several operations.  Operations most commonly
            used include:

                  Precipitation
                  Dilution with solvent or water
                  Extrusion
                  Flaking
                  Drum  drying
                  Spray drying
                  Various materials handling operations.

            All operations contribute to total emissions  and the
            intensity range can vary from very high (10)  to very
            low (2).

            10 -  Polymerization mass injected into water or
                 solvent, filtered, washed,  dried and extruded
             8 -  Polymerization mass dried  and extruded
             6 -  Polymerization mass is dissolved in solvent
             4 -  Polymerization mass is dispersed in water or
                  solvent
             2 -  Polymerization mass packaged directly.
(6)   In Some Cases  Further  Compounding Within The Chemical/
      Plastics Industry Should Be Considered

      While the  primary function of the Chemical/Plastics Industry is
the manufacture of plastics, the market is such that many of the major
plastics must be compounded  further.  This operation can contribute
to emissions, and  can include any one or a combination of operations
including remelting,  extruding, grinding, milling, spray drying and
other drying operations.
                           VII-15

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            Emissions result from drier exhaust gases,  extruder
      exhausts. monomer or low molecular weight polymer evapor-
      ation , decomposition of the plastic during the operation, solvent
      addition or removal of residual solvent from previous operations,
      and others.  Emission potential can range from very high (10)
      to low (4).

            10 - Direct casting or molded
             8 - Partial polymerization or "B" staging
             6 - Mixing with volatile solvents and plasticizers
             4 - Mixing with solids and making molding compounds

      (7)    Assignment Of Intensity Ratings Must Be Flexible

            The intensity  ratings assigned to the various process
      factors, discussed in the previous section are based on the
      observation that there are many operations and operating con-
      ditions common to several processes.  There are,  of course, many
      others that do not fall into any of these classifications, and arbit-
      rary ratings, based on expert opinion, must be assigned to them.
      Secondly, detailed data on emission factors may shift the ratings.
4.    THE HAZARD POTENTIAL INDEX EXPRESSES THE SEVERITY
      OF THE HUMAN EXPOSURE HAZARD ASSOCIATED WITH THE
      PRINCIPAL POTENTIAL PLANT EMISSIONS

      Toxic hazard is determined from the concentration, measured in
parts of volume of a gas or vapor per million parts by volume of air, below
which ill effects are unlikely to occur to an exposed worker (during an eight-
hour working day).  This concentration is the threshold limit value (TLV)
for each chemical. The population in the vicinity of a producing plant is
potentially exposed to the emissions from this plant.  The TLV concentrations
are a useful index of the relative hazardousness of the chemicals to which
the surrounding populations could be exposed. TLV values provide a
standardized comparison base, and this data is generally available.

      The hazard index rating is based on the approach expressed in
Table G-12 (Determination of Hazard Potential)  published in the Federal
Register,  36, No. 105, page 10515, May 29,  1971. This table rates the
hazard potential on a scale from A to D, as follows:

            A - TLV at a level of 0 - 10 ppm
            B - TLV at a level of 10.1 - 100 ppm
            C - TLV at a level of 101 - 500 ppm
            D - TLV over 500 ppm
                             VD-16

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      We have refined this scale to enable sensitive differentiation between
the hazard potential of each plastic sector, and to account for the fact that
ambient concentrations are likely to be significantly lower than the work
place concentrations addressed by TLV's.  The hazard scoring used in this
study follow:

            Score 10  - TLV is 0.02 ppm or less
            Score  9 - TLV is 0.1 ppm or less but greater than 0 .02 ppm
            Score  8 - TLV is 1.0 ppm or less but greater than 0.1 ppm
            Score  7 - TLV is 2.0 ppm or less but greater than 1.0 ppm
            Score  6 - TLV is 5.0 ppm or less but greater than 2 .0 ppm
            Score  5 - TLV is 25 ppm or less but greater than 5.0 ppm
            Score  4 - TLV is 75 ppm or less but greater than 25 ppm
            Score  3 - TLV is 150 ppm or less but greater than 75 ppm
            Score  2 - TLV is 400 ppm or less but greater than 150 ppm
            Score  1 - TLV is greater than 400 ppm

      Appendix 3 identifies the most likely emittants from each process
with safety data when available.

      Determination of the hazard potential index for most probable emissions
in each plastic group is shown in Appendix 4 .  For the manufacture of each
resin the chemical species most likely to be emitted are identified. A "factor
weight" is assigned to each species reflecting its potential importance as an
emittant.  For each species identified with a given process, its factor weight
is multiplied by its hazard rating.  The products are summed  to provide a
hazard index number  for the process.

      Exhibit VII-8 summarizes hazard index number by resin category.
5.    THE ODOR POTENTIAL INDEX IS BASED ON DETECTABILITY

      There have been several attempts to describe odor sensations.  The
best known classification is that whereby odors are classified as spicy,
flowery, fruity,  resinous, foul and scorched. This classification is depen-
dent upon memory and association and few odors can be associated directly
with any of these specific adjectives.

      We, therefore, elected to use the Odor Threshold (OT). This is the
concentration at  which a trained person can first detect an odor.  We are
not considering the intensity nor the classification of odors. Ratings for
odor threshold range from 10 for products  which can be detected at very low
concentrations to 1 for products which are  noticeable only at very high con—
centrations. The odor ratings are based on the same scale as used for ex-
pressing hazard potential.
                            VII-17

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            Rating 10 - OT is 0.02 ppm or less
            Rating  9 - OT is 0.1 ppm or less but greater than 0.02 ppm
            Rating  8 - OT is 1.0 ppm or less but greater than 0.1 ppm
            Rating  7 - OT is 2.0 ppm or less but greater than 1.0 ppm
            Rating  6 - OT is 5.0 ppm or less but greater than 2.0 ppm
            Rating  5 - OT is 25 ppm or less but greater than 5.0 ppm
            Rating  4 - OT is 75 ppm or less but greater than 25 ppm
            Rating  3 - OT is 150 ppm or less but greater than 75 ppm
            Rating  2 - OT is 400 ppm or less but greater than 150 ppm
            Rating  1 - OT is greater than 400 ppm

      Appendix 3 identifies the most likely emittants from each process
with their respective odor threshold values when available.

      Determination of the potential odor index for  each plastic appears in
Appendix 4. The same methodology was used as for developing the hazard
indices, described under subsection 4 above.

      Exhibit VII-9 summarizes odor index number by resin category.
      The section that follows presents more detailed information regarding
polyurethanes, acrylics, alkyds, high volume resins and emission control
technology.
                             VH-18

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                                                   EXHIBIT VII-8
                                             Environmental Protection Agency
                                               HAZARD POTENTIAL INDEX
                                                                 6
Plastic                                        Hazard Index  Number

Polyurethanes                                        9.3
Alkyds                                              6.6
Polyesters                                           6.6
Epoxy Resins                                        5.4
Phenolic and Other Tar Acid Resins                    5.2
Amino Resins                                        4.8
Acrylics1                                            4.5
Coumarone-Indene and Petroleum Resins                4.2
Vinyl Resins                                         4.0
Cellulosics                                          3.5
Styrene Resins3                                      2.8
Polypropylene                                        1.7
Polyethylene and Copolymers                          1.3
Polyamides5                                         1.2
1.    50% Emulsion and 50% Solution
2.    94% PVC, 5% PVAc and 1% PVAlc
3.    76% Polystyrene and 24% ABS
4.    70% LD and 30% HD Polyethylene
5.    80% Nylon 66 and  20% Nylon 6
6.    See Exhibit VII-2 for use of the index
Source:     Snell, details in Appendices 3 and 4
                            VII-19

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                                                   EXHIBIT VII-9
                                             Environmental Protection Agency
                                               ODOR POTENTIAL INDEX
Plastic                                       Odor Index Number

Acrylics                                           9.0
Polyurethanes                                      7.7
Coumarone-Indene and Petroleum Resins               7.7
Styrene Resins2                                     7.4
Phenolic and Other Tar Acid Resins                   6.9
Amino Resins                                       6.8
Polyesters                                          5.3
Alkyds                                             5.0
Cellule sic s                                         4.3
Epoxy Resins                                       4.1
Polyethylenejtnd Copolymers                         2.5
Vinyl Resins                                        2.3
Polypropylene                                      1.9
Polyamides                                         1.5
1.    50% Emulsion and 50% Solution
2.    76% Polystyrene and 24% ABS
3.    80% Nylon 66 and  20% Nylon 6
4.    70% LD and 30% HD Polyethylene
5.    94% PVC, 5% PVAc and 1% PVAlc
6.    See Exhibit VII-2  for use of the index
Source:     Snell,  details in Appendices 3 and 4
                            VII-20

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    SECTION VIH
IN-DEPTH STUDIES

-------
                        SECTION VIII
                      IN-DEPTH STUDIES
      This section discusses in detail

                  The three chemical/plastics industry processes
                  identified by the priority decision model with the
                  highest priority ranking

                        polyurethanes
                        acrylics
                        alkyds

                  Emission quantification and control techniques for
                  some high volume resins

                  General control technology and costs.

      These five topics constitute the subject matter for respective chapters
in this section.
                              VIII-1

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                   VHI-A POLYURETHANES
      Polyurethanes are produced by reacting a polyisocyanate with di- or
polyfunctional hydroxyl compounds.  Of interest to this study are those poly-
urethane products falling within the category of the chemical/plastics industry,
SIC 2821. Polyurethane foams, both rigid and flexible, are outside the scope
of this study, although the manufacture of some of the intermediates used to
make foam falls within this category.
1.    POLYURETHANE RESINS FALLING IN THE CATEGORY OF
      CHEMICAL/PLASTICS INDUSTRY ARE PRINCIPALLY
      PREPOLYMERS

      Polyurethane polymers are used in a large number of applications
including surface coatings (see Exhibit VI-K2),  and intermediates in the
manufacture of foams,  adhesives, sealants and elastomers.  These polymers
are classified as either non-reactive (contain no free isocyanate groups) or
reactive  (contain unreacted or "blocked" isocyanate groups) which will react
further with active hydrogens. This latter category included the prepolymers
which are the most important products falling within the scope of this study.
2.    THE PRODUCTION PROCESSES FOR MAKING THE VARIOUS
      PREPOLYMERS ARE SIMILAR AND ARE LOW TEMPERATURE.
      BATCH PROCESSES

      Three types of bonding encountered in polyurethane prepolymer manu-
facture are (1) biuret branching, (2) allophanate branching, and (3) urethane
branching. However, from the processing standpoint, these chemical classi-
fications do not represent significantly different processes, since during
manufacture all three can (and do) occur simultaneously.

      Production is carried out as batch operations involving reactors
ranging in size from a few hundred to a few thousand gallons. Reactions are
carried out at or near atmospheric pressures under a nitrogen blanket at
temperatures ranging from 70°C - 120°C. Cycle time may vary from a few
hours to about 24 hours.  Exhibit VIII-A 1 presents a process flow sheet
characteristic of a biuret branching operation. Exhibit VIII-A2 shows a
slightly different method of preparation.
                            VIH-2

-------
                 Biuret Type Branching
                                                        EXHIBIT VIII-A 1
                                                  Environmental Protection Agency
                                                  POLYURETHANE PREPOLYMER
                                                  PROCESS FLOW SHEET
Glycol 100 parts

Water 0.4 part
  WATER ADDITION

  30 rain. 35-40°C.
TDI
 (NCO/OH ratio
  1.25/1.0)
 (NCO/H O ratio
  1.0/1/0)
                              I
EXOTHERMIC REACTION

fzSQmin.    40-100°C.
                      HEATED REACTION

                       90 min .    120°C .
                           COOLING
                            min .  80°C .
TDI
(to 9.5%NCO)
  PREPOLYMERIZATION

 60min.       80-100°C.
                              I
                   COOLING AND DRUMMING

                  £r 120 min.  to ambient
Note:  N_ blanketing in each step

Source:  Snell and confidential industry sources

                            VIII-3

-------
                                            EXHIBIT VHI-A2

                                      Environmental Protection Agency

                                      POLYURETHANE PREPOLYMER
                                      PROCESS FLOW SHEET
 Isocyanate
 (TDI - MDI)
 Polyhydroxy
 Compound
ISOCYANATE
 HEATING
                 1 Hr.
           50-70°C
REACTION
                 2-5 Hr.
           70-90°C
                       COOLING
                 IHr.
           20-25°C
                       DRUMMING
Vacuum
                                                 .N,
Cool to Maintain
                           Temperature
                           Vent to TDI
                           ^Scrubber
Source:  Snell and confidential industry sources
                            VIH-4

-------
      An equipment diagram is presented in Exhibit VIII-A3. This equip-
ment would not change radically from plant to plant, except that nitrogen
sparging throughout the reaction may be used, particularly in older plants.

      Normal operating procedure is to purge the reactor with nitrogen to
remove air and moisture. The TDI or other isocyanate is added to the reactor
and the mass heated to 50-70°C and the polyhydroxy compound added with the
temperature maintained between 70-90°C until reaction is complete.  The pre-
polymer is then cooled and drummed.

      The bulk (90%) of the prepolymers produced is based on three iso-
cyanates:  (1) toluene diisocyanate (TDI);  (2)  methylene diphenylisocyanate
(MDI) , and; (3) polymethylene polyphenylisocyanate (PMPPI) . TDI probably
accounts for 70% and MDI accounts for about 25%, but its use is growing. PMPPI
is reserved for special applications.
3.    EMISSIONS FROM POLYURETHANE PREPOLYMER MANUFACTURING
      AMOUNTS TO ABOUT 3 x 10~7 POUNDS PER POUND  OF PREPOLYMER
      PRODUCED

      A theoretical emission of TDI or MDI from a prepolymer manufacturing
plant having no emission control equipment can be estimated.  The prime
source of emission would be associated with displacement of the nitrogen in
the reactor by TDI or MDI during reactor charging.  Under the worst condi-
tion the isocyanate would be charged to the empty reactor at about 25°C. At
this temperature TDI has a vapor pressure of 0.02 mm Hg.  The equilibrium
concentration of TDI in the nitrogen atmosphere would be 200 ppm.  Then,
for a 5,000 gal reactor,  filled with 4,000 gal of TDI the vented TDI would
amount to 0.01 Ib or 3 x 10  Ibs per Ib of prepolymer produced.
      (1)   Emission Control Equipment Is Built In The Reactor Design

           As shown in Exhibit VIII-A 3, the reactor vent line is connected
      to a vacuum system equipped with a reflux condenser and a cold trap.
      The temperature of this cold trap is maintained at about -18°C by an
      ethylene glycol brine which reduces the vapor pressure of the TDI to
      about 0.006 mm Hg.  Under this condition, no measurable emission to
      the atmosphere takes place. In fact, the system is designed to prevent
      contamination of the  vacuum pump oil with TDI.
                           VHI-5

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                                                                 EXHIBIT VIII-A3
                   Conservation
                     Valve
N2
    8
r*
I   Wei
I   *•'
 Isocyanate
Weigh Tank
  000 gal
       Water
          Drain

                               Vent
Catalysts
Accelerators
Modifiers

Alcohol
  i Tank
 .DOO gal
                                5,000 gals
                                              Environmental Protection Agency

                                              EQUIPMENT FLOW SHEET FOR
                                              POLYURETHANE PREPOLYMER
                                              MANUFACTURE
Iter
\rv
t
RE A
^


,, r~"
\
C TOR
*s

x Ste
Scrub
Tow

Cold
Trap
                                                                                    -18°C
                                                                   Condenser
                                                                   Water
                                                                  Scrubbed Vent
                                                        Vent

                                                       Drum
                                                                 Spent
                                                                 Caustic
                                                                                Vac
                                                                                Pump
                                                                              Pressure
                                                                              Regulating
                                                                              Valve
                       Operating Conditions

                             Pressure = Atmospheric to 50 mm Hg.

                             Temperature = Room to 90°C

                             Cycle Time = 4-24 Hours
               Source:  Snell and confidential industry sources

                                             Vln-6

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       (2)   Isocyanate  Storage Tanks Are Equipped With Conservation
            Valves And Vented Through  Scrubbers

            TDI can be  stored in tanks of up to 80,000 gal capacity.  These
       tanks are equipped to "breathe" through the conservation valves
       which in turn are vented to antipDilution devices.

            Conservation valves are devices which minimize the "breathing"
       of tanks due to temperature variations.  They are loaded port valves
       operating at positive pressures of a few torr and negative pressures
      of few centimeters of  water.

            During bulk transfers and shipment, the atmosphere of the
       receiving vessel is connected to that of the delivery vessel, thus
       avoiding discharge to the atmosphere.

            Vent streams containing isocyanates are routed through caustic
       scrubbers having removal efficiencies of over 99.9%. The scrubbers
       are either packed with suitable material (generally polypropylene
       intalox saddles or pall rings) or venturi-type scrubbers.  Both of
      these systems are usually operated with recycle of a weak caustic
       solution (5-10%).  Emissions are monitored.

       (3)   More Elaborate Emission Control Systems Are Used Where
            Prepolymers Are Produced At Monomer Manufacturing Plants

            Where prepolymers are made at monomer production plants,
      vent streams are tied into the emission control systems  required for
      isocyanate control.

            In addition, compliance with OSHA requirements  and aware-
      ness of internal hazards involved insure a minimization of the occur-
      rence and the effects  of accidental (episodal) emissions. Availability
      of maintenance crews is also a factor in reducing the occurrence and
      effects of fugative emissions, from valves, pumps, seals, etc.


4.    THE USE OF  PREPOLYMERS OUTSIDE THE  CHEMICAL/PLASTICS
      INDUSTRY PROPER MAY  BE A MORE SIGNIFICANT  SOURCE OF '
      AIR POLLUTION

      The major share of the prepolymers produced is confined to a few
plants operated by large sophisticated producers of monomers. These
plants are well equipped with antip Dilution devices.
                            VIII-7

-------
      Industry sources are unanimous at expressing concern over the poten-
tial pollution hazard in value added operations downstream.  The final
production of consumer goods or end-use products from polyurethanes are
often carried out in comparatively small unsophisticated installations.  Of
particular significance is the area of "foamed-in-place" heat insulation.
Direct monomer handling from drums is often involved and in spite of manu-
facturer's warnings and instructions,  less than ideal usage conditions often
prevail.

      However, these industries fall outside the scope of this study but we
feel that specific investigation of this area seems warranted.  Polyurethane
foam fabricators are listed under SIC 3079.  Their  number is orders of mag-
nitude larger than those of TDI or SIC  2821 polyurethane producers.
                            Vin-8

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                        SECTION VIII-B
                           ACRYLICS
1.     EMULSION, SUSPENSION.  SOLUTION AND BULK POLYMERIZATION
      SYSTEMS ARE USED COMMERCIALLY TO PREPARE ACRYLIC RESINS
      (1)    Emulsion Polymerization Is Widely Accepted And Is A
            Low Temperature Batch Operation

            This is the most useful industrial method for the preparation of
      polymers of acrylic esters.  The principal reasons are the economy
      and safety of water as a polymerization medium,  the ease of tempera-
      ture control, the speed and completeness of reaction and the conven-
      ience of application of the polymer as an aqueous dispersion. At
      concentrations  of 30-50% the aqueous dispersions obtained by emulsion
      polymerization  have relatively low viscosities, whereas  solutions of
      polymers of equivalent molecular weight are often too  viscous to handle.

            There are two ways in which the polymerization can be conducted.
      Using the first  method (redox) , all the reactants are stirred together
      in the reactor and heated  until polymerization is complete.  This is
      practical as long as the heat of polymerization can be removed adequately
      during the reaction.  In extremely exothermic polymerizations, as with
      the lower acrylates, adequate control of the temperature by this batch
      polymerization  is extremely difficult and the operation is hazardous.
      This danger can be avoided by using the second method (reflux) in
      which only a small portion of the monomer is present initially in the
      reaction vessel, the remainder being held separately to be added grad-
      ually after polymerization has been started with the initial charge.
      The rate of addition is adjusted to permit the removal  of the heat of
      polymerization.

            In redox polymerization the reactor is first flushed with an
      inert gas  such as nitrogen or carbon dioxide to remove any oxygen
      present, and this blanket is maintained throughout the polymerization.
      With the agitator rotating, the water, emulsifiers and  monomer (s) are
      added. Then initiators (persulfates), reducing agents (bisulfite,
      thiosulfate, hydrosulfite, etc.) and activator (ferric ammonium sulfate)
      are added.  After a brief induction period, the temperature will rise
      to 85-95°C and the reaction is 99-100% complete within 15-30 minutes.
                           VIH-9

-------
It is desirable to remove unconverted monomers, and stripping is
accomplished by post-heating at temperatures and pressures con-
sistent with the stability and foaming tendency of the emulsion.  The
finished emulsion is filtered through a cheese-cloth filter bag or
basket screen.

      In the reflux method, part of the water containing emulsifiers
and initiators  (persulfates, organic hydroperoxides]  is placed in the
reactor. heated to a temperature approaching that desired for the
reaction, and monomer emulsified in another portion of the water is
fed in.  Work-up of the polymer is the same as in the redox method.

      The same equipment can be used for both redox and reflux
polymerizations.  Reactions are carried out in steam-jacketed, stain-
less steel or glass-lined kettles equipped with an agitator, such as
a three-pronged, curved impeller rotated at a peripheral speed of
150-600 ft.  per min. The  kettle has dished top and bottom heads
capable of withstanding 4  atm and is equipped with an emergency
stack,  fitted with a rupture disc, piped to a safe location.  The stack
leads to a stainless steel tube and shell condenser where condensate
may be returned to the reactor or discharged to a small receiver.
The monomer emulsion is  made up in an overhead stainless steel tank
equipped with a turbine-type agitator and a tankometer.  The emulsion
is added to the reaction kettle by gravity through a control valve.
 (2)   Suspension Polymerization Produces Dry Beads

      In suspension polymerization, the monomer or monomer mixture
is suspended in water in droplets by means of agitation. To keep the
droplets from coagulating, a protective colloid such as bentonite,
starch,  poly vinyl alcohol, etc. is added.

      The polymerization is carried out at a temperature just below
the point at which refluxing would occur.  For example, a suspension
of acrylate monomer, buffer and benzoyl peroxide catalyst is heated
at about 80°C, with vigorous agitation, until polymerization is complete.
Cool the slurry and filter through a stainless  steel screen or centrifuge,
wash the beads with water and dry in a circulating air oven at 80-12 0°C
or in a rotary vacuum drier.
                      VIH-10

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(3)   Solution Polymerization Is Especially Suited To The
      Preparation  Of Polymers Which Are To Be Used In
      A Solvent

      Although solutions could be made from bulk polymers, these
do not dissolve easily. Direct production of this type of product by
a solution polymerization process is the most convenient method.

      The equipment for solution polymerization is generally similar
to an emulsion plant.

      Polymerization is usually carried out at or near the solvent re-
flux temperature.  Most of the solvent is placed in the kettle and
heated to the desired temperature or to reflux.  Separate streams
of the monomer (s)  and the initiator dissolved in the reaction solvent
are then added over a period of 1- 4 hours, the duration of the
polymerization is usually 8 ~ 24 hours. Additional solvent is added,
if necessary , and the product sent to storage or is drummed.
(4)   In Bulk Polymerization Processes,  No Solvents Are Employed
      And  The Monomer Acts As The Solvent

      Commercial bulk processes for acrylic polymers are used
primarily in the production of sheets.  rods and tubes.  Bulk pro-
cesses are also used in a small scale in the preparation of dentures
and novelty items.  The process is used primarily with methyl raeth-
acrylate polymerization.

      Methyl methacrylate monomer catalyzed with a peroxide
catalyst —  ordinarily benzoyl peroxide — is difficult to control,
particularly where large masses are concerned.  The difficulties
involve removal of dissolved gases, adjustment for volume shrinkage,
and adequate control of the highly exothermic polymerization reaction
in the early stages especially after the material has reached the gel
stage.  These difficulties can be alleviated by using a casting syrup
or partially polymerized product rather than the  monomer.

      The casting syrup is usually prepared by  heating the monomer
with 0.02-0.1% benzoyl peroxide at 70-80°C with constant agitation
until the consistency while still hot approximates that of glycerine,
but when cooled to room temperature approximates that of molasses.
The solids  (polymer) content of this syrup is about 10%. It may be
stored at 5°C or below.
                      Vin-11

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2.
            The syrup is poured into the mold and cured at either
      atmospheric pressure or up to 10 atm and temperature cycles of
      40-110°C or 70-135°C respectively  for 45 minutes for each  1/2 inch
      of casting thickness.
MONOMERS ARE THE PRINCIPLE SPECIES EMITTED
      All commercially  available monomers have significant vapor pressures.
Since the main polymerization processes are water /monomer or monomer
only systems, their  concentrations in venting gases would be significant.

      An indication  of the magnitude of the potential emissions due to
handling of monomers alone, i.e., displacement of inert  gas  blankets in
storage and reactor  charging can be calculated as is summarized in
the following table.   The gas phase is  assumed  to be air and equivalent
concentrations would be encountered with nitrogen at atmospheric pressure.
Monomer
Ethyl Acrylate
Acrylic Acid
Butyl Acrylate
Cellosolve
 Acrylate
2-Ethylhexyl
 Acrylate
Methyl Acrylate
Methyl
 Methacrylate
            Molecular
             Weight
             100
              72
             128

             144

             185
              86

             100
 Vapor
Pressure
Equilibrium
Concentration
  in Air
                            (mmHg@ 25UC)  (% by wt)
  40
   4.0
   4.5

   0.8

   0.2
  70

  40
  16.2
   1.3
   2.6

   0.52

   0.17
  20.8

  16.2
Lb. Monomer
Emitted perLb.
Monomer Handled
2.1 x 10
-4
 -4
0.17 x 10
0.34 x 10 ~4
0.07 x 10
          -4
0.02 x 10
2.7 x 10 ~4
          -4
2.1 x 10
         -4
Source:  Snell estimates based on physical data provided in a confidential
         industry submission.
                           VIII-12

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 (1)   Except For Storage Venting. Emission Sources Are
      Generally In-Plant

      The table below summarizes significant emission sources
as a function of the polymerization processes.
      Emission Sources In Acrylic Polymerization

                                    Polymerization Process
Emission
Sources                 Bulk        Solution    Suspension  Emulsion
Monomer Handling        X             XXX
Solvent Handling                       X
Reactor                  X             XXX
Filtration                                           X
Drying                                             X
Product Handling         X             XXX
Fugitive and Accidental   X             XXX
      With comparatively high vapor pressures of the monomers,
there is considerable opportunity for escape to the atmosphere.
One industry source"' indicates that in a typical methyl meth-
acrylate plant, concentrations as high as 2.4 ppm have been en-
countered. The concentration decreased as the distance from the
plant increased, but could still be as high as 0.1 ppm 70 ft.
outside the building.

      Three companies have submitted confidential data quantifying
emissions from some of their processes.  Their data were obtained
principally by estimation (with an occasional measurement being
made] on a typical yearly production with a typical product mix and
process.  The information is not  sufficient to accurately define the
total emission, but does define the order of magnitude.

      The manufacturing processes and  emissions described below
are from well operated and maintained plants.  It is expected that
smaller plants would have emissions at least as high, if not higher
than these.
                        VIII-13

-------
 (2]    Emission From Solution Polymerization Processes Include
       Both Monomer And Solvents,  According To A Case Study
       This solution process is used in the manufacture of a
 acrylic oil additive. The plant is about 15 years old and has
 a capacity of about 30 million Ibs per year. It is a batch
 polymerization process in which monomers are polymerized
 in a hydrocarbon solvent using a peroxide catalyst and mer-
 captan type chain transfer agents. At completion of polymeriza-
 tion, the solvent is removed, and recycled, the resin is blended,
 sent to storage and, when ready for shipment, is filtered.

       Emissions are expressed in pounds of raw material per
 pound of product produced based on a typical yearly production
 with a typical product mix.  The products are solutions of acrylic
 polymer in mineral oil.  Emissions have been estimated at each
 point source.  The estimates are not sufficient to accurately
 define the total emissions but do define the order of magnitude.
 Manufacturing unit emissions under normal operating conditions
 summed are:
Source
Total non-fugitive emissions
      acrylic esters
      solvent

Chemicals receiving and storage
      heavy acrylic esters
      light acrylic esters
      solvent

Polymerization
      heavy acrylic esters
      light acrylic esters
      solvent

Polymer separation
      solvent

Fugitive emissions
Emission Factor
(lbs/lb product)
2.2 x 10
  9 x 10
.-4
 -4
  4 x 10
  2 x 10
1.4 x 10"
f5
r4
1.3xlO"5
not available
       -6
  8 x 10


7.5 x 10"4

not available
Source:  Confidential industry submission
                       Vm-14

-------
      Primary odor and emission control techniques involve good
housekeeping practices, standard operating procedures and
maintenance practices.  All process chemical storage tanks are
diked and dikes contain locked valves for spill protection and
control.  Spills average about one every five years.

(3)   According To A Case Study. Emissions From An Emulsion
      Process Are Primarily Monomer, Of The Order Of 1 x 10~a
      Lbs Acrylates/Lb Product And The Same Factor For Vinyl
      Acetate

      This emulsion process is a batch process.  The plant is
about 3 years old with a capacity of about 50 million Ibs/yr.
The process consists of emulsifying a vinyl acetate/acrylate ester
mix in water  and polymerizing with persulfate and peroxide
catalysts. Other ingredients include emulsifying agents,  pro-
tective colloids  and buffer salts.

      The emissions have been estimated based on raw material
balances across the entire system.  Estimated emissions are:
                                         _Q
      Acrylate  type monomers:        1 x 10  Ibs/lb.of product
      Vinyl acetate:                  1 x 10~  Ibs/lb of product

      The estimates include fugitive emissions but their magnitude
is not known. Spills do occur and are not included in these estimates.

      Primary odor and emission control techniques involve good
housekeeping practices, standard operating procedures and main-
tenance practices.  Devices planned for installation include
collection systems for emissions from storage and processing areas
connected to a scrubbing system based on mixtures of triethylene-
tetramine in ethylene glycol/water  solvent.  Also planned are
collection systems for transfer areas where spills have occurred
in the past.

      Another manufacturer using  the emulsion process indicates
emissions of acrylate esters from storage areas are controlled by
closed circuit loading and conservation vents.  Reactor area
emissions are controlled by a proprietary scrubbing system designed
to treat 20 SCFM gas flow rate containing 20 Ibs/hr monomer to a
level of 0.02 Ibs/hr monomer. The scrubbed gas is discharged
high enough to  prevent ground level odor.
                       VHI-15

-------
(4)   According To A Case Study, Emissions From A Suspension
      Process Are Principally Monomer, Of The Order Of 5 x 10~4
      Lbs/Lb Product

      This process in a 25 year old plant consists mainly of suspend-
ing various methacrylate and acrylate monomers in water and poly-
merizing by the aid of azo and peroxide initiators. The complete process
is not -well  defined but probably consists of filtering the suspended
polymer, and later compounding.

      Emissions for the point sources have been obtained by calcu-
lation of storage tank losses based on vapor pressures. by calculations
based on a  few atmospheric samples throughout the process, and on
estimates and observations in the cases of intermittent leaks of spills.
The estimated  emissions are:

Source                             Emission Factor
                                    (Lbs/lb of product)

Storage:
      Monomers:                          1.46x10
      Other:                              9.30xlO~7

Polymerization:
      Monomer:                           1.73xlO~4
      Other:                              6.09 x 10~6

Compounding:
      Monomer:                           9.22 x 10~
      Other:                              4.98 x 10

Waste disposal:
      Monomer:                           1.63 x 10~jj
      Other:                              5.60x 10
Source:  Confidential industry submission
      Emission control methods include:  closed liquid systems
and spill control;  condensation of vents, and;  preventative main-
tenance .
                        VHI-16

-------
3.     EFFICIENT EMISSION  CONTROL METHODS ARE AVAILABLE BUT
      ODORS WILL PROBABLY STILL BE NOTICEABLE BECAUSE OF THE
      ODOROUS NATURE OF THE MONOMERS EVEN AT EXTREMELY LOW
      CONCENTRATIONS
      The emission control methods used by the larger, more sophisticated
 producers of acrylic resins, appear to be relatively efficient. The use of
 closed liquid systems, conservation vents and nonregenerative water scrubbers
 removes over 99% of the vapors from these processes.

      The ultimate goal of most producers is to eliminate odors.  This
 may not be possible because of the  extremely low odor threshold value
 of these monomers.  For  example, ethyl acrylate is noticeable at a concen-
 tration  of 0.00024 ppm.    '  At this low  concentration, combustive materials
 in an air stream does not provide enough BTU's to maintain the temperature
 necessary for catalytic oxidation.

      One producer dilutes its plant air exhaust stream and discharges it
 high enough to  prevent ground odor.
                            VIIl-17

-------
                        SECTION VIII-C
                            ALKYDS
      Alkyds are polymers derived by condensing fatty acids or oils,
glycols and polybasic  acids.  The recipes for these  resins vary
tremendously, but can be  very broadly classified as Short Oil (contain-
ing 33 - 45% oil and 35% phthalic anhydride), Medium Oil (containing
46 - 55% oil and 30 - 35% phthalic anhydride) and Long Oil (containing
56 - 70% oil and 20 - 30% phthalic anhydride).

      Alkyds are produced by either the fusion  or solvent process.
In the fusion process  the water formed during condensation is removed
by  a  continuous purge of mist gas, while the solvent process uses-a
solvent,  such as xylene, to remove the water.   The latter usually results
in an alkyd having a  lighter color.

      There are numerous  literature references  regarding alkyd formu-
lations and manufacturing  procedures,  but no data on emissions  from
the process(s)  have been  found.   Recently,  however, emissions from
a model  paint plant have been described* 3^  and we have quantified the
emissions from a typical alkyd plant which would be part of this paint
plant.
1.    MANUFACTURE IS GENERALLY A HIGH TEMPERATURE BATCH
      OPERATION
       (1)   Most Modern Alkyd Resin Plants Have Similar Layouts
            And Equipment

            Alkyd  processing  plants consist of four  major operating areas:
       (1) raw material and solvent storage;  (2) polymerization;  (3) alkyd
      work-up including thinning  and  final product  polishing, and
       (4) finished  product storage and/or  packaging.

            Raw materials can be  stored either  inside or outside  the
      plant.   Liquids,  such as oils, alcohols, solvents,  etc.  are  usually
      stored in tanks.   Solids such  as phthalic  anhydride, pentaerythritol,
      etc. are stored in bags  usually weighing  50 Ibs each.  Large alkyd
      plants may receive molten phthalic anhydride  in bulk shipments in
      which case the product  is stored in  heated tanks.
                            Vin-18

-------
            Polymerization is carried out in jacketed resin kettles
       (reactors)  ranging in size from  500  gallons to 6,000 gallons
      capacity.   These are generally constructed from stainless steel
      alloy types 304,316,  or 347 and  equipped with an agitator
      capable of rotating at peripheral speeds of 600-600 ft.  per  min.
      Additional  agitation  is provided by means  of an inert gas sparge
      at rates of 0.005-0.04 CFM per gallon of charge.  The reactors
      can  be used as either a fusion or  solvent  reactor.   If  used as
      a solvent reactor, it is usually equipped with condensers and
      a decanter-receiver.  If used  as a fusion reactor, the  condenser
      and  decanter-receiver are omitted  or shut  off.  Reaction temper-
      atures may vary from 210 - 250°C.  An equipment flow  sheet
      for a typical alkyd manufacturing  process  is presented in
      Exhibit VIII-C1.

            All alkyds (with the exception of those used in making molding
      compounds) are diluted or thinned with solvents usually xylene or
      mineral spirits.  When the desired degree of polymerization has been
      reached, the alkyds from the  reactor are dropped into a thinning
      tank containing the  desired solvent.  The  tank is usually twice the
      capacity  of the reactor and is  equipped with a condenser and  stirrer.
      Cooling is  accomplished by circulating  cold Dowtherm or water through
      the jacket.

            The  diluted alkyd is filtered hot, usually through  a plate and
      frame filter and sent to storage or directly to drumming  facilities.
2.    THE MODEL PLANT DESCRIBED HAS A CAPACITY OF  2.2 TO 2.4
      MILLION POUNDS PER YEAR AND EMPLOYS BOTH SOLVENT AND
      FUSION PROCESS EQUIPMENT

      The model plant operates 250 days per year on a two-shift basis.
This quantity of alkyd resin solids produces about 722,000 gallons of alkyd
base paints.

      About  50,000 gallons of tankage will be required for solvents and
other raw material storage.  A minimum of one month's supply is necessary
and it is  assumed that the average alkyd prepared contains  53% oil and the
plant operates  on a  two-shift operation  (the efficiency of the second  shift
being 90%).  All alkyds  are to be diluted to 50% non-volatile solids (NVS)
with xylene.  Separate storage tanks  are available for  xylene,  oils,
glycerine and waste solvent and have the following capacities:
                             VIII-19

-------
                            EXHIBIT  Vin-Cl

                  Environmental Protection Agency

                        ALKYD PROCESSING (34)
         ln«tl Cei "Hori
        Tmnrinq TonL
           Sftoni or
          V/ottr JocV.i
          F,h.r
"•• L""» — ,1

1 >



SJ

L^ ^^i
  Hi I >•••> ,'ii •Ine-im aH|ni-il ilLnl iwoine HUH
vm-20

-------
            Volume (gal )            Contents
            25,000                  Xylene
            25,000                  Oil
             7,500                  Glycerine
             2,000                  Waste Solvent

      Phthalic anhydride is stored in 50 Ib bags, although larger
alkyd producers receive molten phthalic  anhydride and this would
require additional tankage.

      The plant is equipped with two reactors.   A small reactor of
500 gallon capacity will  be used as a fusion reactor and  can produce
about 2,375  Ibs of resin solids per batch.  A  larger  reactor having  a
capacity of 1,500  gallons can be used as both a fusion and solvent
reactor  and  can produce about 7,125 Ibs of resin  solids per batch.
Production consists of an average  of one batch in each reactor  per
24 hour day.

      Two thinning tanks  are required,  one for each  reactor.  They
should have double the capacity of the respective reactors  with which
they are associated.  Therefore, tanks should have capacities of 1,000
gallons  and  3,000 gallons.

      It is expected that 35,000-40,000 gallons  of  finished alkyd product
storage  is adequate.  Many different alkyd formulations  are made de-
pending upon  end uses and specifications and separate storage  tanks
are therefore required.  Individual tanks ranging from 1,000 gallons
to 10,000 gallons should suffice.
      (1)    Production Is Almost Equally Divided  Between Long  Oil
            And Short  Oil Alkyds

            Probably more  than 95% of alkyd production is used for
      making trade or  industrial coatings and averages about 53% oil.
      Two  formulations were used  in  calculating emissions from  an
      alkyd plant.  A short oil alkyd and long  oil alkyd  typify alkyd
      production in fusion and solvent processes respectively.   Typical
      formulations are  shown  below.

            Short  Oil   (40% oil)           Long Oil (60%  oil)
            1,000  Ibs  oil                 4,500 Ibs oil
              600  Ibs  glycerine           1,000 Ibs glycerine
              900  Ibs  phthalic            2,000 Ibs phthalic
                  anhydride                     anhydride
                            VIH-21

-------
      (2)    The Fusion Process Is Usually Carried Out At Temperatures
            Of 400-450°F

            The reactor (500  gallons) is charged with the oil and
      glycerine and blanketed with inert gas.   Agitation  is started and
      heat  is applied (435-450°F)  until alcoholysis is  complete.  This
      takes about 3  hrs.  Phthalic anhydride is added through the
      manhole  and heating is  continued for about five more hours or
      until the desired  viscosity and acid  number is reached.  Gas
      sparging exhaust rates  are  about 2 CFM during alcoholysis,
      then  at a decreasing rate  of 0.04 CFM per gallon of charge
      during the  first two hours of esterification, 0.02 CFM during the
      third hour, and 0.01 CFM for the remainder of the cook.
      (3)    The Solvent Process Is Carried Out Under Xylene Reflux
            Conditions

            Total reaction time is approximately  12  hrs.  for a long oil
      alkyd charge in the 1,500  gallon reactor.  The normal procedure
      is to charge the reactor with the oil, blanket with an inert gas,
      heat to 450-500°F, add glycerine and continue heating at this
      temperature for 4.5-5 hrs.  Cool to 390>OF. add phthalic anhydride,
      hold at 450 °F until esterification is complete  and the desired
      viscosity and acid number is reached.  The  condenser vent
      temperature is assumed to be about 100°F.
3.    TOTAL EMISSIONS FROM THE MODEL PLANT AMOUNT TO 0.008
      POUNDS PER POUND OF ALKYD SOLIDS  PRODUCED

      Total emissions for the model plant are summarized in Exhibit
VIII-C2.  Over 98% of the emissions arise from reactor venting and
fugitive sources such as filter press,  agitator  seals and  spillage.

      The emissions estimated for this model plant are in agreement
with actual emissions measured  (based on 15 resin cooks) of 0.0001
to 0.007 Ibs/lb of alkyd produced. *4^  The major component of the
emissions was xylene.

      On a pound for pound basis,  there appears to be little difference
in emissions  from  the fusion or  solvent process.
                            VIH-22

-------
                                                    EXHIBIT  VIII-C2
                                          Environmental Protection Agency

                                         SUMMARY  OF EMISSIONS FROM AN
                                         ALKYD PLANT PRODUCING 2.2  -
                                         2.4 MILLION POUNDS OF ALKYD
                                         SOLIDS U4)
                                              Pounds Emitted Per Year
Contribution

    0.4


    9.4



    1.2

    0.2


   88.8

  100.0
Source of
Emission

Raw material
storage

Reactor
Thinning

Finished Resin
Storage
Fugitive
Principle
Emission

Xylene
Mixed
organics
Xylene

Xylene
Fusion
Cook

    20
                                288
    53
Solvent
Cook

    60
 1,400

   160
Total
    80
   288
 1,400

   213
           Total
Xylene
Xylene
12
4,000
4,373
33
12.000
13,653
45
16,000
18,026
                 Pounds Emissions/Pound
                 Alkyd
                               .0074
                       .0077
                      .0076
                           VIII-23

-------
4.    MINIMAL EMISSION CONTROL IS PRACTICED IN THIS INDUSTRY

      Solvent tanks  are  normally vented to the  atmosphere.

      When phthalic anhydride is received and  stored in the molten
state, it is usually kept under a blanket of inert  gas.  Conservation
vents set at about 2-3 torr of pressure are  usually used.

      Many small producing plants heat reactors with gas burners.
This leads to local hot spots which produces  acrolein,  a  very odorous
product.  When tall oil is used,  mercaptans and other odorous sulfur
compounds are often formed.

      In addition, plants using solid phthalic anhydride usually add
this product  to the reactor  through a manhole.  During this addition,
gas sparging  is continued resulting in  particulate emissions through
the manhole and vents,  as  well as aerosol emissions containing water,
phthalic anhydride,  phthalic acid,  and esters.  The high  sparging rate
corresponds to a stream of about 60 SCFM for a typical 1,500 gallon
kettle.

      In the  solvent process, a partial reflux condenser is used to
return most of the vapors to reactor.   This is followed by the  so-called
total condenser which  condenses the  azeotrope and the continuous
decanter separates the water from the solvent.  Finally, there is a
circulating scrubber on  the vent line.  There is no concensus  as  to the
efficiency of this scrubber, but it is known that it has little  or no effect
on gaseous products.
5.    FURTHER TREATMENT OF ALKYD PRODUCTION VENT STREAMS
      MAY BE  REQUIRED

      In view of the poor performance  of scrubbing in the control of
emissions from alkyd manufacture, some other method may be required
to control, in particular, the odors emitted.

      Two methods present themselves  - carbon adsorption and com-
bustion .
                            VIII-24

-------
(1)   Carbon Adsorption Would Probably Not Be Beneficial
      For Control Of Alkyd Emissions

      A problem  associated with the emissions  from sparged
reactors  used in  alkyd production  is that highly turbulent
conditions in the reactor cause the  formation of all sorts of
aerosols.  Deposition on adsorbent  carbon would then very
severly limit the  usefulness  and life cycle of the adsorbent.
If  used downstream from an  efficient filter or precipitator,  an
activated carbon  unit could control  solvents and odors efficiently.
The  economy of this combined system is,  however,  questionable
compared to that  of combustion in terms  of both the original
cost  and the  operating  cost.
(2)   Combustion Of The Vent Gases Would  Be Beneficial But
      Additional Fuel Costs Would Be Encountered

      Combustion at 1200°F with a residence time of 2 -  3
seconds in the fire zone destroys practically all organic species.
Where a  stream containing organic materials is too dilute to
sustain its own combustion,  as would be the case for vent  gases
from alkyd production, a gross approximation of heating costs is
possible.   The energy necessary  to raise a pound  of air to 1200°F
is about  250-270 BTUs  per Ib.  Thus  a  stream  of  60 CFM of inert
gas would require a gas air mixture with a net BTU content of
about 1250 BTUs per minute.   Due to  variations in the sparging
rates,  a  total  of about 500,000 BTUs per day would be required.
This would represent about  $3 - $5 per day which is quite
acceptable.  A more complete analysis  of the incineration is given
in the review of general control methods.
                      VIII-25

-------
                       SECTION Vm-D

EMISSION QUANTIFICATION AND CONTROL TECHNIQUES FOR SOME HIGH
VOLUME PLASTICS

      Literature sources™'   •' have provided data related to quantitative
emission factors and emission control methods for several large volume resin
materials.  The emission factors, however,  are based on material balances
rather than quantitative analysis of vent or exhaust streams.  A discussion
of some emission control devices used and emission factors calculated for
some major chemical/plastic processes follows.

      Exhibit Vin-Dl summarizes the emission control devices reportedly
used by polymer manufacturers. Exhibit Vin-D2 summarizes the emissions
from some resin plants.

1.    EMISSION CONTROL DEVICES USED IN PVC PRODUCTION INCLUDE
      VENT CONDENSERS. CYCLONES AND BAG FILTERS

      Vent  condensers condense and retain most of the vinyl monomer which
would otherwise reach the  atmosphere. With these devices, hydrocarbon
emissions from the reactor area and monomer recovery units would amount
to 0.01 to 0.02 pounds per  pound of polymer produced.

      Participate control is most important during the manufacture of PVC .
Processes which generate dusts include the dryer and materials handling
(including pneumatic conveyors and loading equipment).  Cyclones are
usually used and have efficiencies of 99.9%. Bag filters will collect 100%
of the fines above approximately 50 micron particle  size and can be used
alone or as  backup for cyclones. Particulate emissions are in  the order of
0.003 pounds per pound of polymer produced.

      Cost of cyclones and bag filters is mainly dependent upon the air flow
volume. Installed costs can vary from about $20,000 to over $120,000 rated
at 1,000 - 67,000 SCFM respectively.  Operating costs also range from
0.0026 - 0.0157 cents per pound of PVC production.  In some instances
there is a net credit for recycling PVC recovered amounting to almost 0.05
cents per pound of PVC production.

      Vent  condensers recovering 9-12 pounds of monomer per hour cost
about $4,000 - $6,000, respectively. These show operating costs of 0.023
cents per pound credit to 0.003 cents per pound cost, respectively.
                            VIH-26

-------
                                                                 EXHIBIT VIII-D1
                                                          Environmental Protection Agency

EMISSION CONTROLS REPORTEDLY USED BY POLYMER MANUFACTURERS(3>45|47)
                                                         I      I      I      ?   L        ?!
                                    „.      a              g      s      i.      t   ">  a        MRI
                                    S                     2      fl)  W)   Q>      0}      3    *9   ^
                                    5      E       a      s      P" I   1      f   «-3    8   1 §
                                    "      oo      3     -^      I  o   H      2   a  g    2   2 So
                                    >s     M      .2      X      OOrl      utiOf)U(Lk
Polymer	O	no	u,	s	U U   
-------
      Fugitive emissions from pumps, compressors, storage and normal
operations amount to about 0.002 pounds of hydrocarbons per pound of
PVC produced.
2.    POLYPROPYLENE PLANT EMISSION CONTROL DEVICES WHICH MAY BE
      USED INCLUDE CYCLONES AND/OR BAG FILTERS . WATER SCRUBBERS,
      FLARES. INCINERATORS AND VENT CONDENSERS

      We judge that particulate removal costs would be of the same order of
magnitude as described above. However, reported emissions are considerably
lower and are about 0.001 pounds per pound of PP produced.

      Installed costs for flare systems can range from $37,000 to over $300,000
with operating costs ranging from 0.014 to 0.039 cents per pound of PP produc-
tion.  Hydrocarbon emissions (including fugitive emissions) would be in the
order of 0.016 pounds per pound of PP produced.
3.    VENT CONDENSERS AND CYCLONES AND/OR BAG FILTERS ARE BEING
      USED BY SOME POLYSTYRENE PRODUCERS

      These devices are used primarily for product recovery rather than
control devices.

      Hydrocarbon emissions have been estimated at 0.006 pounds per pound
of polystyrene produced with over 50% of this appearing at the reactor vent.

      Particulate emissions amount to about 0.0001 pounds per pound of PS
produced.
                            VIII-28

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                                               EXHIBIT VID-D2



                                        Environmental Protection Agency


                                         EMISSION FACTORS FOR SOME

                                         LARGE VOLUME RESINS

                                         (Lbs/Ib product)
Plastic



Poly vinyl Chloride






Nylons


Polypropylene


Polystyrene





HD Polyethylene


LD Polyethylene
Particulates/Aerosols
0.0002 - 0.004
              (45)
0.00034
       (3)
              :(45)
0.0003 - 0.005


0.00001 - 0.0002(45^
0.00001 - 0.0002
                (45)
 0.0013t3)
Hydrocarbon



0.001 - 0.02

       (3)
0.00021


0.001 - 0.02
(45)
(45)
0.0002 - 0.04(45)


0.0002 - 0.04(45)


0.00029(3)


0.085<3)


0.044(3)
                             Vin-29

-------
                       SECTION Vm-E

      ECONOMICS OF TYPICAL EMISSION CONTROL METHODS
1.    IN THE CHEMICAL/PLASTICS INDUSTRY. A GOOD DEAL OF CONTROL
      EQUIPMENT IS CONTRIBUTING TO PROFITS

      There are two fundamental types of control equipment

                 one type separates material (s) from a waste stream

                 one type destroys undesirable materials in a waste
                 stream

      Dust collectors and condensers belong in the first category. Flares
and scrubbers belong in the second. However, the heat generated by the
flares can sometimes be usefully recovered.

      Adsorbing devices, which are also useful can belong to either category
depending upon the disposition of the spent adsorbent.

      The table below presents a cursory analysis of the equipment reported
as "Emission Control Equipment" in various monomer-polymer production
plants <45> .

                                           Percent of "Profitable"
      Industry                          Emission  Control Equipment

      Styrene-Butadiene Rubber                       50%
      Polypropylene                                   20
      Polystyrene                                   100
      Polyvinyl Chloride                              50
      Nylon 6                                        40
      Vinyl Chloride Monomer                         30
      Isocyanates                                     10

      Source:   Snell estimates based on data in Reference 45.
                             VIII-30

-------
      The figures refer to the gross number of pieces of equipment reported,
regardless of type, capital or operating costs.

      It can be seen that a large proportion of such equipment falls into the
category of "profitable" equipment, showing a negative operating cost when
the value of the product recovered is taken into consideration. Examples are
cyclones and bag dust collectors.

      A relatively low proportion of "profitable" equipment is encountered in
isocyanate manufacture. In this respect it should be noted that:

                 the monomers of the isocyanate family are highly
                 noxious

                 there is a considerable amount of phosgene in the
                 atmospheric  waste streams and that a limit of 200
                 ppm has been in force  for the emission of this
                 chemical for  a number  of years.
2.    AN ECONOMIC OVERVIEW WAS DEVELOPED FOR FIVE EMISSION CONTROL
      METHODS APPLICABLE TO THE CHEMICAL/PLASTICS INDUSTRY

      Exhibit VIH-E1 shows some of the capital costs and other characteristics
of typical pieces of equipment actually in use in the polymer industry.

      (1)    The Installed Cost (C) Of A Bag Collector Is C =• 3.5 V -9,
            Where V = Thousand CFMs
            In a recent survey, unrelated to this project, we have found
      that

                 there is a keen competition between manufacturers
                 of essentially similar equipment, leading to a more
                 or less uniform pricing policy.

                 most of the installations sold until recently, were
                 based on value of recovered material.
                            VIII-31

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                                                                                      EXHIBIT Vffl-El  (1)
                                                                                            EPA
                                                                          REVIEW OF SPECIFIC PIECES OF EQUIPMENT
                                                                                      IN ACTUAL USE
G
CO
to
Polyvinyl Chloride (Suspension)
  Vent Condenser
  Dryer Bag Filter
  Silo Bag Filter
.  Bagger Bag Filter
  Bulk Loading Bag Filter
  Dryer Bag Filter
  "Day Storage" Bag Filter
  Bulk Storage Bag Filter
  Bagger Bag  Filter

  Vent Condenser

  Various Bag Filters

Capacity
Plant (tons/yr)
i)
A 50,000




B 30,000



Flow Of
Pollutants
(Ibs/hr)
12
135
4
1
3
2
0.03
0.02
0.02
Capital
Cost
(1973 $)
7,000
125,000
65,000
31,000
12,500
57,000
9,000
6,000
5,000

Efficiency
(%)
83
99.8
99.9+
99.9+
99.9+
99+
99.9+
99.9+
99.9+


Rate
12 Ib/hr
45,000 SCFM
4,500 SCFM
1,500 SCFM
3,000 SCFM
25,000 CFM
3,750 CFM
1,600 CFM
1.100 CFM
                                    45.000
  Vent Condenser
  Vent Condenser*
  Dryer Cyclone
  Dryer Bag Filter
  Dryer Bag Filter*
                                    70,000
4,500
96.3
9 Ib/hr






trace
trace
10
8
9
68.000
15,000
28.000
62,000
15.000
5.000
205.000
62.000
110,000
110,000
160,000
99.9+
99.9+
99.9+
99.9+
99.9
99.9+
99+
99+
99.9+
99.9+
99.6
27,000 CFM
5,000 CFM
9,800 CFM
38,350 CFM
5,000 CFM
1,400 CFM
trace
trace
27,000 CFM
20,000 CFM
67,000 CFM
                                                                                                 Remarks
Mikro-Pulsaire
Flex-Kleen Corp.
Mikro-Pulsaire
Mikro-Pulsaire

U.O.P.  Dust Collector
Flex-Kleen Corp.
Flex-Kleen Corp.
Flex-Kleen Corp.

Process Engineering
and Machine Co.
Flex-Kleen Corp.
Flex-Kleen Corp.
Fuller Co.
Pulverizing  Machinery
Pulverizing  Machinery
Fuller Co.
                                                                                                  Dustex
* Emulsion Process

-------
                                                                                        EXHIBIT VIH-El (2)
  Polyamides
   Nylon 6
    Reactor Vent Condenser
    Recovery Vent Condenser
                                     Capacity
                               Plant  (tons/yr)
A   119,000
t
  Pelletizer Vent Scrubber
  Depolymerizer Vent Scrubber

 Nylon 66
  Finisher Off-Gas Scrubber     A

Polypropylene
  Reclaim Vent Condenser       A

  Recovery Vent Condenser     B
  Various Bag Filters
     62,500


     60,000

    150,000



     62,500
    Flare Pit                     C
    Bag Filter
    Process Vapor Condenser  5
    K.O. Drum
    Process Vapor Condenser

    Flare System                 D    75,000
               Flow Of     Capital
               Pollutants    Cost
                (Ibs/hr)    (1973$)
                                                                     Efficiency
                                                                         (%)      Rate
-700 SCFM
n.a.
n.a.
40
344
729
n.a.
n.a.
variable

3,336
85,000
2,000
45,000
58,000
115.000
67,000
12,000
230,000
120,000
85,000
89,000
24,000
5,000
340,000
n.a.
near 100
n.a.
99.7
n.a. 120 SCFM
n.a.
near 100
143 Ib/hr
1,585 Ib/hr
8 Ib/hr
near 100

-------
                                                                                         EXHIBIT VIH-El  (3)
00
Process Vapors Scrubber
Process Fluids Incinerator
Flare System

Flare System
Handling and Storage
    Cyclone
    Screens

    Screens

Bag  Filter
   SBR Rubber (Emulsion Polymerization)
    Carbon Black Water
    Scrubber
        Flare

    Butadiene Oil Scrubber

    Carbon Black Spray Water
    Scrubber
        Flare

    Butadiene Oil Scrubber
    Carbon Black Water Scrubber

Capacity
Plant (tons/yr)
E 50,000


F 140,000





rization)
A 219,000

B 112,000
C 175,000

D 342,000
r
Flow Of
Pollutants
(Ibs/hr)
25.3
23
401
5,996
4 total
variable
variable
variable
180
1

62
715

-10
-600
Capital
Cost
(1973 $)
7,000
58,000
52,000
96,000

9,000
7,000
33,000
140,000
19,000
18,000
70,000
17,000
19,000
34,000
3,600

Efficiency
(%)
98.5
99.5+
99.5+
99.5+

n.a.

n.a.
99.3


96.5


98
95


Rate
68 Ib/hr
variable
n.a.


10,000 SCFM
3,000 SCFM
22,000 SCFM
16,000 SCFM


75 SCFM
360 SCFM
500 SCFM
8 SCFM
90 SCFM
    Design Rating 20,000 Ibs/hr
    Source:  Snell estimates based on data from Reference 45

-------
      A plot of the capital cost versus equipment capacity in terms
of CFM handled is presented in Exhibit VIII-E2. The outlying points
can be sometimes attributed to the high temperature of the stream,
requiring highly sophisticated, and therefore expensive fabric (e.g.
Du Pont "Nomex").  The plot indicates that the 1973 installed cost of
a "normal" bag dust collector, with ancillary equipment,  is given by
the formula

            C = 3450V-92

where C is the cost in $ and V the volume handled in 1000 CFM.

(2)    The Annual Continuous Operating Costs Of Bag Collectors
      Can Be Estimated At $0.30 - $0.50 Per CFM

      Assuming that on the average bag dust collectors operate at
a differential pressure of a few torr, the power requirements can
be estimated at 0.25 HP of air HP  per  1000 eft.  handled assuming a
60% efficiency.

      Thus, the energy requirement for a 50,000 CFM dust collector
is of the order of 100,000 KWH per year for a continuous operation.
With electricity at $0.02/KWH the cost of energy alone can be about
$2,000.

      Assuming an installed cost of $125,000, the annual operating
cost including 10 year depreciation can be between $15,000 - $17,000 .

      Industry figures indicate:  $23,000/year for a 45,000 CFM bag
collector and $27,000/year for a 67,000 CFM bag filter. But at the
same time, figures of $400/year have been reported for a 25,000
CFM unit and $12,000/year for a 1,500 CFM unit.

      Thus, as a first approximation, the annual continuous operating
costs for bag dust collectors could be calculated at about  $0.30 to
$0.50 per  CFM.

(3)    Where The Monomers Are Highly Volatile Compression
      And/Or Refrigerated Condensation May Be Economical

      There are two cases to be considered.  In the first  case, the
stream is essentially unreacted monomer .e.g. ethylene,  propylene
or vinyl chloride.
                       VHI-35

-------
                                                            EXHIBIT VIII-E2
                                                      Environmental Protection Agency

                                                      CAPITAL COSTS OF BAG
                                                          DUST COLLECTORS
200
100 ;
                                                                                      100
                                       Capacity(1000 CFM)
                                          VIII-36
              Source: Snell estimates based on data from Reference 45

-------
      Release to the atmosphere is undesirable for economic reasons.
In that case, the fairly elaborate equipment required to recover the
unreacted monomer should not be considered as emission control
equipment.

      In the second case, the stream is a mixture of monomer and
"uncondensable" gas, e.g. air, nitrogen, or methane. Then,
especially if the value of the product recovered is negligible compared
to the operating cost, the compression and/or refrigerated condensa-
tion may be truly considered an emission control.

      It is difficult to give equipment and operating costs in a
general fashion. As an example the refrigeration to -40°F of a
stream of nitrogen leaving a  reactor at 100°F would require about
35 BTU's per Ib. or 2,800 BTUs per 1,000 eft. Thus a stream of
10,000 CFM of N_ (or air) would require 140 tons of refrigeration.
This would necessitate a refrigeration system costing about $90,000
and an operating cost of the order of $140 per day or $46,000 per
year.(50J

(4)    Scrubbing Of Gases Is Effective In Removing Particulates
      And Some Very Soluble Vapors, Such As Acrylates - For
      Jet Scrubbing Operating Costs  Are In The Order Of $2
      Per 100 CFM Per 24 Hour Day

      Scrubbing is bringing a stream of gas in as intimate contact
as possible with a stream of liquid. The most common scrubbing
agent is water,  then various water solutions (e.g. caustic or hypo-
chlorite). Low volatility oils can be sometimes used to dissolve
hydrocarbon vapors or gases. The scrubbing stream is usually
recycled with or without intermediate treatment.

      There are two fundamental methods for scrubbing.  The
spray methods use the infringement of finely divided water counter-
currently, crosswise or co-currently with the gas stream.  A par-
ticular case is the venturi scrubber in which venturi effect is used
to provide the pressure differential necessary to move the gas stream.

      Another method is the use of packed towers (sometimes even
plate towers).  In these a stream of liquid flows by gravity counter-
currently to the gas stream over suitable packing, generally in towers
essentially similar in design to distillation towers.  These devices
are particularly successful when dissolution of a  gaseous substance
(e.g. ammonia, or HC1) is the objective.  They may be adversely
affected by high concentrations of particulates.

                        VIU-37

-------
      The capital cost of spray scrubbers varies in function of the
 capacity and the materials of construction. Exhibit VIII-E3 shows
 typical capacity cost relationships for jet scrubbers. (5)  The power
 requirements for the flow of water is said to vary from 2 - 5 HP per
 1,000 CFM of gas handled. Thus,  a daily operating cost can be about
 $2.00 per 1,000 CFM per 24*hour day.

 .(5)   Flaring, Even With Added Fuel, May Be A Costwise
      Attractive Method For Control Of Emissions,  e.g.
      Hydrocarbon Resins

      Destruction of most organic species by combustion in air is
 essentially complete atl.ZQOPF with residence time of 1 - 3 seconds.

      Again, two alternatives can be considered.  In the first alter-
 native the waste stream contains enough organic material to sustain
 its own combustion at the required temperature. In that case, the
 costs are essentially the amortization cost of the equipment. Flares
 and their auxiliaries are only nominal in costs (less than $10,000),
 but the need to provide a stack of several hundred feet of height may
 be quite  significant. For example, a capital cost of $340,000 for a
 flare system was claimed for a polypropylene installation producing
 75,000 tons per year;  the system disposed of 3,400 Ibs of pollutant
 per hour; however, due to the value of products recovered in the
 Knock Out Drums there was a negative operating cost of $100,000 per
 year.<45)

      In other installations a captial cost of about $20,000 is claimed
 for flare  systems handling 500 SCFM with a height of 150 feet.  The
 operating cost is said to be $10,600 per year.

      For a similar system on a stream of negligible heating value,
 the estimated heat requirements would be 15 x 106 BTU's per 24
 hours or 15,000 CFM of natural gas.  At a cost of $0.028 per 100 CFM
 the cost of fuel  would be about $5.00 per day or about $1,500 per
 year.(52)

 (6)   Adsorption Devices Represent Another Form Of Emission
      Control In Which Product Recovery May Be Possible, e.g.
      Alkyds

      Carbon adsorption may be used in some cases.  It usually
is limited to streams containing a significant percentage of organic
vapors and is particularly successful in solvent vapor recoveries.
The method is not known to find appreciable application in the
industry studied.
                       Vin-38

-------
                                                          EXHIBIT VIII-E 3
                                                    Environmental Protection Agency

                                                    CAPITAL COSTS OF JET SCRUBBERS
1,000
          10,000
Cubic Feet per Minute
loopoo
                                        VIII-39

-------
      Pressure drops through the system limits its applicability to
streams of moderate capacity, say less than 5,000 CFM.

      Two factors limit their usefulness to this industry:

            Thebeds are quite sensitive to solid particles
            accumulation

            Adsorbed monomers may have a tendency to
            polymerize due to the possible catalytic effect
            of the adsorption process itself.

      Two possible methods of utilization can be contemplated:

            Regeneration - It is often possible to regenerate
            the adsorbent "on site" either by pyrolysis or by
            steam stripping. In the latter case product values
            can be recovered.

            Spent adsorbent disposal -  the spent adsorbent
            could be disposed of by incineration or landfill.
            Costs for the  steam regeneration process can be
            estimated as follows: 153)

                 Capital cost for a unit handling 3,000 cfm -
                 $12,000- $13,000

                 Operating cost -  $0.25 per hour for
                 electricity,  $0.50 for water and $0.90 for
                 steam - with $250 per year for maintenance
                 for a unit recovering about 24,000 gals per
                 year of solvent.  (0.2% concentration by
                 weight)

                 Thus, a total operating cost of $13,500 per
                 year can be estimated.  This would represent
                 $4.50 per CFM capacity per year.

            It is to be noted that the utility costs would be
            somewhat proportional to the amount of solvent
            adsorbed.  Thus,  a  range of $2 to $6 per CFM per
            year  appear reasonable.
                       VIII-40

-------
            An adsorption capacity of about 8% by weight is indicated.
      This as an alternative, the carbon could be disposed of.  With a
      carbon cost of about $0.30 per lb this represents a cost of $3.75
      per lb of adsorbate. This, therefore, looks like a highly uneco-
      nomical process and should be resorted to only for extremely
      toxic substances in very diluted streams.
      As a first approximation a range of values can be assigned for the
operation of various emission control devices, discussed above, based on
their nominal capacity.

      These values are presented in Exhibit VIH-E4.
                             VIH-41

-------
                                               EXHIBIT VID-E4

                                        Environmental Protection Agency

                                         EMISSION CONTROL COSTS
      SUMMARY OF OPERATING COSTS OF VARIOUS METHODS
Bag Filters              $0.30 to 0.50 per year per CFM of capacity (*)

Compression
Refrigeration            $3.0 to 6.0 per year per CFM of capacity (*)

Scrubbers               $0.40 to 0.60 per year per CFM of capacity (*)

Flare                   $0.10 to 0.20 per year per CFM of capacity (**)

Regenerative
Adsorption              $2.0 to 6.0 per year per CFM of capacity (***)
 (*)   Neglecting the value of recovered product.

 (**)  This figure assumes no heating values for the stream itself, but
      does not include supplying the necessary air in case of an essen-
      tially inert gas stream.

 (***) Excluding value of recovered material and assuming a 0.05 to 0.3%
      by weight concentration of adsorbate.  Excluding also the cost of
      any pretreatment of the gas stream.
Source:  Snell
                             VID-42

-------
SECTION IX




REFERENCES

-------
                         SECTION IX.
                         REFERENCES
1.    United States Tariff Commission Reports: Synthetic Organic Chemicals,
      Production and Sales, 1967, 1968, 1969, 1970, 1971. Washington,
      Government Printing Office, (TC Publications,  295, 327, 412, 479,  614)

2.    Anon: Journal of Commerce: December 27,  1972

3.    Society of Plastics Industry:  Confidential Communications, November 1973

4.    Foster D. Snell, Inc.:  Confidential Files, November 1973

5.    Anon: Chemical Marketing Reporter 204: 9, December 24, 1973

6.    Macbride, Roland R.:  Will PVC's 1973 Crunch Become A Glut in 1975?
      Modern Plastics 50, No. 1:66-69, January, 1973

7.    Various Manufacturers:  Private Communications, November, 1973

8.    Chemical Information Services:  Regional Directories of Chemical
      Producers, Stanford Research Institute, MenloPark, California

9.    Anon: Polyvinyl Alcohol Behemoth of Du Pont Comes On Stream Hungry
      For Textile Size Mart.  Chemical Marketing Reporter 203: 3,12, April 2,
      1973

10.   ibid:   August, 1971

11.   Macbride, Roland R.: Still Plenty of Capacity in Polystyrene, But The
      Squeeze Is On. Modern Plastics 49, No. 8:14-15, August, 1972

12.   Anon: Tight Despite Expansion. Chemical Week 112, No. 11: 9,
      March 14,  1973

13.   Anon: Plastics World 30: 42, August, 1972

14.   Stanford Research Institute:  Chemical Economic Handbook, Stanford
      Research Institute, MenloPark, California

15.   Anon: Chemical Marketing Reporter 201: October 26, 1970
                             K-l

-------
16.    Anon:  Booming Growth Seen For Polyurethanes.  Chemical 6 Engineering
      News 50, No. 8:10-11, February 21, 1972

17.    Department of Commerce:  Statistical Abstracts of the United States, 1971:
      829-894, Department of Commerce, Washington, D.C.

18.    Repka, Jr., B.C.:  Olefin Polymers.  Kirk-Othmer Encyclopedia Of
      Chemical Technology,  2nd Edition 14: 231, 1967

19.    ibid: 252-253

20.    Smith,  W.M.: Manufacture of Plastics, Part 1:119, 1964, Reinhold
      Publishing Corp., New York

21.    Cantaw, M.J.R.: Vinyl Polymers (Chloride) Kirk-Othmer Encyclopedia
      Of Chemical Technology, 2nd Edition 21: 376, 1970
22.
23.
24.
25.
26,
27.
ibid: 372
Smith, W.M.: Manufacture of Plastics, Part I: 234,
Publishing Corp . , New York
ibid: 229
ibid: 286
ibid: 276
Bishop , R .B . : Practical Polymerization for Polystj

1964, Reinhold



rrene: 9, 1971,
      Cohners, Boston

28.   Mark, H.F. et al:  Encyclopedia of Polymer Science and Technology
      13:132, 1971. John Wiley 6 Sons, Inc., New York

29.   Bishop, R.B.:  Find Polystyrene Plant Costs, Hydrocarbon Processing
      51, No. 11:137-140, November, 1972

30.   Smith, W .M.: Manufacture of Plastics, Part I: 451,  1964, Reinhold
      Publishing Corp., New York

31.   ibid: 209

32.   Mark, H .F. et al:  Encyclopedia of Polymer Science and Technology.
      10: 50, 1971. John Wiley 8 Sons, Inc., New York

33.   Simonds, H.R. et al:  Handbook of Plastics, 2nd Edition: 700, 1949.
      D. Van Nostrand Co., Inc., New York
                             K-2

-------
34.   Mraz, R.G. and Silver, R.P.:  Alkyd Resins. Kirth-Othmer Encyclopedia
      of Chemical Technology, 2nd Edition 1: 851-882, 1963

35.   Smith, W.M.: Manufacture of Plastics, Parti: 504, 1964, Reinhold
      Publishing Corp., New York

36.   ibid: 399

37.   Klug, E .D.:  Cellulose Derivations.  Kirk-Othmer Encyclopedia of
      Chemical Technology, 2nd Edition 4: 629, 1964

38.   Smith, W.M.: Manufacture of Plastics, Part I: 504, 1964, Reinhold
      Publishing Corp., New York

39.   ibid: 520

40.   ibid:524

41.   Niehaus,  W .R.:  Safe Handling Practice for Acrylate Monomers.
      Paint and Varnish Production (PVP)  61, No. 5:41-44, 1971

42.   Toshihide, O.:  The Chemical Components  of Odor From Plastic Plants
      and Some Examples of Odor Control. Odor Research Journal, Japan 1
      (1): 46-50, 1970

43.   EPA:  Private Communications, December,  1973

44.   Anon: The Ideal Paint Plant, Manufacturing Committee, Toronto Paint
      Society

45.   EPA:  Private Communications, November, 1973

46.   Arthur D. Little: Research On Chemical Odors, Part I - Odor Thresholds
      for 53 Commercial Chemicals: 21-24, Ocotber, 1968 for Manufacturing
      Chemists Assn., Washington, D .C.

47.   Pacific Environmental Services, Inc., 2932 Wilshire Blvd., Santa Monica,
      Calif.  90403

48.   Perry, J.H. et al: Chemical Engineers'Handbook: 20-74, 1963.
      McGraw-Hill Book Company, New York

49.   ibid: 20-71

50.   ibid: 26-25,  26-29

51.   Webb: Paint Industry Magazine:  January, 1958
                             K-3

-------
52.    Anon: Confidential Communications

53.    Manzone, R .R. and Oakes,  D .W.:   Profitably Recycling Solvents From
      Process Systems.  Pollution Engineering 5, No. 10:23-24, October, 1973

54.    Rolk, R.W. et al:  Afterburner Systems Study:  Environmental
      Protection Agency Office of Air Programs. Contract EHS-D-71-3,
      August,  1972, PB 212-560

55.    Occupational Safety and Health Standards; National Concensus Standards
      and Established Federal Standards. Federal Register 36, No. 105, Part II:
      10504-10505, May 29, 1971.  Department of Labor, OSHA, Washington, D.C,

56.    Patty, F .A.:  Industrial Hygiene and Toxicology, Toxicology, Part II:
      Inter science Publishers, New York, 1966

57.    Summers, W.:  Odor Pollution of Air: 22-24, 1971.  CRC Press, Cleveland

58.    Anon: Putting the Nose To the Test, Chemical Week 112, No.  11: 35-36,
      March 14. 1973

59.    Manufacturing Chemists Assn.:  Physiological Effects. Air Pollution
      Abatement Manual: 22-26, 1951.  Manufacturing Chemists Assn.,
      Washington, D.C.

60.    Anon: Detectors, Reagents, and Accessories for MSA Universal Testing
      Kits;  Summary Data Sheets: Mine Safety Appliance Co., Pittsburgh,
      Pa.,  January, 1969

61.    Compilation of Odor and Taste Threshold Values Data:  ASTM Data
      Series DS 48:  American Society for Testing and Materials, 1973

62.    Press Release:  Public Relations,  B. F. Goodrich, Akron, O.,
      January 23, 1974

63.    Occupational Safety and Health Standards; Emergency Temporary
      Standard for Exposure to Vinyl Chloride; Federal Register 39,
      No. 67:  12342-12344, Aprils, 1974. Department of Labor, OSHA,
      Washington, D.C.
                             K-4

-------
APPENDICES

-------
          APPENDIX 1




ADDITIONAL PRODUCERS' LOCATIONS

-------
                                                               APPENDIX 1
Producer and Location

CPC International,  Inc., Charlotte, N. C.
Conchemco, Inc.,  Houston, Tex.
Dan Riber Mills, Inc., Baltimore, Md.
                     Kansas City, Mo.
                     Danville, Va.
De  Soto, Inc., Berkeley, Calif.
              Garland, Tex.
              Chicago Heights, m.
H.  B. Fuller Co.,  Atlanta, Ga.
                 St. Bernard (Cincinnati), O.
General Latex & Chem Corp., Charlotte, N. C.
                            Ashland, O.
                            Dalton, Ga.
                            Cambridge, Mass.
Jones- Blair Paint Co., Dallas, Tex.
Minnesota Mining & Mfg. Co., Decatur,  Ala.
Napko Corp., Houston, Tex.
Onyx Oils & Resins,  Inc., Brooker, Fla.
                        Newark, N.J.
Owens-Corning Fiberglas Corp., Anderson, S. C.
Philip Morris, Inc., Greenville, S. C.
                   Springdale, Conn.
Reliance Universla,  Inc., Houston, Tex.
                        Louisville, Ky.
Seydel-Woolley & Co., Atlanta, Ga.
Standard Brands, Inc., Forest Park (Atlanta), Ga.
                     Clifton, N.J.
                     Cheswold, Del.
                     Chicago, HI.
Stein, Hall & Co.. Inc., Charlotte, N. C.
                        Bridge view,  111.
                        Newark. Calif.
Amalgamated Chem. Corp.. Philadelphia,  Pa.
Colloids, Inc., Franklin,  N.J.
Defiance Indust. Inc., Baltimore, Md.
Emkay Chem. Co., Elizabeth, N. J.
Farnow, Inc., S. Kearny, N.J.
Great Northern Paint & Chem.  Corp., E. Paterson,
Gulf Oil Corp.,  Lansdale, Pa.
H & N Chemical Co., Totowa, N.J.
                                               Environmental Protection Agency
                                               PRODUCERS:  POLYVINYL ACETATE
     Producer and Location
     Hart Products Corp., Jersey City, N.J.
     McClosky Varnish Co., Philadelphia, Pa.
                          Los Angeles, Calif.
                          Portland, Ore.
     Benjamin Moore & Co., Newark, N.J.
                           St.  Louis,  Mo.
     Northeastern Labs.  Co., Inc.,  Melville, N. Y.
     The O'Brien Corp., Baltimore, Md.
                       South Bend, Ind.
     Polymeric Resins Corp., Wilmington. Mass,
     Quaker Chem. Corp., Conshohocken, Pa.
     SCM Corp., Reading, Pa.
                Chicago, ni.
                Cleveland, O.
                Huron, O.
                San Francisco, Calif.
     Scholler Bros.,  Inc., Elwood,  N.J.
     Squibb Beech-Nut, Inc.,  Canajoharie, N.Y.
     Sun Chemical Corp.,  Wood Riber Junction, R, I.
     Sybron Corp., Haledon, N. J.
    Chas. S. Tanner Co., Providence. R. I.
     U. S.  Coatings Co., Inc., Kenilworth,  N. J.
     Franklin Chem.  Co.,  Columbus, O.
     The Hanna Paint Mfg. Co.,  Inc., Columbus, O.
     The National Casein Co., Chicago, Ul.
     PPG Indust., Inc., Circleville, O.
     Pacific Holding Corp., Chicago, Dl.
     Purex Corp., Ltd.,  Kansas City, Ka.
                       Morris, 111.
                       Carson, Calif.
     The Sherwin-Williams Co.,  Chicago, 111.
     Yenkin- Majestic Paint Corp.,  Columbus, O.
     Bennett's. Salt  Lake City. Utah
     Diamond Shamrock Corp., Richmond, Calif.
     Grow Chemical Corp., Oakland, Calif.
     Kelly-~Moore Paint Co., San Carlos, Calif.
     Kohler- Me Lister Paint Co., Denver, Colo.
N.J. Norris Paint & Varnish Co.,  Salem, Ore.
     Preservative Paint Co., Seattle, Wash.
     Sinclair Paint Co., Los Angeles, Calif.
     Union Oil Co. of California, La Mirada, Calif.

-------
                                    APPENDIX 1  (continued)

                     Environmental Protection A'gency

                     PRODUCERS:   STYRENE RESINS
Producer and Location

Borden Inc..  Uliopolls. ni.
            Bainbridge, N.Y.
            Leominster, Mass.
            Compton, Calif.
            Demopolis, Ala.
S. C.  Johnson & Sons, Inc., Racine, Wise.
Morton Chem Co., Ungwood, 111.
The O'Brien Corp,, South Bend, Ind.
                 South San Francisco, Calif.
PurexCorp.. Ltd., Chicago, ni.
                 Bristol, Pa.
                 Carson,  Calif.
A. E.  Staley Manufacturing  Co., Lemont, HI.
                             Kearney, N.J.
Beatrice Foods Co., Wilmington, Mass.
Howard Industries, Inc., Hicksville, N. Y.
Pennsylvania Industrial Chem. Corp.. Clairton. Pa.
Phillip Morris, Inc.,  Springdale, Conn.
Polymeric Resins, Corp.. Wilmington, Mass.
Reichhold Chems., Inc., Elizabeth, N. J.
Scholler Bros. Inc., Elwood,  N.J.
Sybron Corp., Haledon, N. J.
Alabama Binder and Chemical Corp., Tuscaloosa,  Ala.
Southern Petrochemical Corp., Channelview, Tex.

-------
                                                              APPENDIX  1 (continued)
Producer and Location

Poly Resins, Inc..  Sun Valley. Calif.
Allied Chemical Coip., Los Angeles, Calif.
                      Capiagne. N.Y.
                      Whippany,  N.J.
                      Des Plaines, 111.
Allied Products Coip.,  Los Angeles, Calif.
                     Seattle, Wash.
                     Memphis,  Tenn.
                     Orlando, Fla.
                     Long Island City, N.Y.
                     Chicago, 111.
                     Detroit. Mich.
De Soto,  Inc., Berkeley,  Calif.
              Garland, Tex.
              Chicago Heights,  111.
The Dexter Corp.,  Hayward, Calif.
                  Rocky Hill, Conn.
                  Cleveland, O.
                  Waukegan. Ql.
Georgia Pacific Corp., Coos Bay, Ore.
                     Conway,  N. C.
                     Columbus, O.
                     Crossett,  Ark.
                      Savannah. Ga.
                      Louisville, Miss.
                      Lupkin, Tex.
Hercules Inc., Eugene,  Ore.
              Tacoma. Wash.
              Wilmington, Del.
Inmont Corp., Anaheim, Calif.
              Chicago, ni.
              Cincinnati, O.
              Grand Rapids, Mich.
              Los Angeles, Calif.
              Morganton, N.C.
              Huntington,  Ind.
              Clifton, N.J.
              Elizabeth. N.J.
              Newark,  N.J.
Environmental Protection Agency
PRODUCERS:   PHENOLICS

 Producer and Location

 PPG Industries, Inc.,  Cleveland, O.
                     Milwaukee, Wise.
                     Torrance, Calif.
                     Atlanta (East Point), Ga.
                     Houston, Tex.
                     Springdale,  Pa.
 Preservative Paint Co., Seattle,  Wash.
 Rezolin, Inc., Chatsworth, Calif.
 Taylor Corp.,  La Verne, Calif.
               Betzwood,  Pa.
 Tenneco,  Inc., San Francisco, Calif.
 U. S. Plywood, Redding,  Calif.
 VWR United Corp., Portland, Ore.
                   Richmond, Calif.
                   Newark, O.
 West Coast Adhesives, Co.,  Portland, Ore.
 Weyerhaeuser Co., Longview. Wash.
                   Marsh.fi.eld, Wise.
 Gulf Oil Corp., Alexandria,  La.
                Lansdale, Pa.
 Masordte Corp..  Gulfport, Miss.
 MMM, Decatur,  Ala.
 Napko Corp.,  Houston, Tex.
National Casein Co.,  Tyler, Tex.
                     Riverton, N.J.
                     Chicago, m.
 Onyx Oils & Resins,  Inc., Brooks, Fla.
                         Newark, N.J.
 Owens-Coming Fiberglas Corp., WaxahacMe, Tex.
                               Barrington,  N.J.
                               Kansas City, Kans.
                               Newark,  O.
 Sonoso Products Co., Hartsville. N.C.
 Union Camp Corp.,  Valdosta, Ga.
 Valentine Sugars, Inc.,  Lockport, U.
 The Bendix Corp., Troy, N.Y.
 The Budd Co., Bridgeport,  Pa.
 The Carbarundum Co., Niagara Falls, N. Y.
 Clark Oil & Refining Corp.,  Tewksbury,  Mass.

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                                                              APPENDIX 1 (continued)

                                              Environmental Protection Agency
                                              PRODUCERS:  PHENOLICS
Producer and Location
Crowley Tar Prod. Co., Inc.,  Paulsboro,  N. J.
Firestone Tire and Rubber Co., Fall River, Mass.
Kroedler, Alphonse & Co.. Lancaster, Pa.
Koppers Co., Inc., Petrolia, Pa.
Kyanize Paints, Inc., Everett,  Mass.
Lawter Chems., Inc.. South Keamy.  N.J.
Millmaster Onyx Corp., Lyndhurst, N. J.
Pennsylvania Indust. Chem. Corp., Clairton, Pa.
Pioneer Plastics Corp., Auburn, Me.
Polyrez Co., Inc., Woodbury,  N.J.
Raybestos-Manhatten Inc., Stratford,  Conn.
Resyn Corp., Linden, N. J.
Rogers Corp., Manchester, Conn.
Rohm & Haas Co., Philadelphia, Pa.
Schenectady Chems. Inc., Rotterdam Junction, N. Y.
                        Schenectady,  N.Y.
Shanco Plastics & Chem. Inc., Tonawanda, N. Y.
Standard Oil of New Jersey, Odenton, Md.
Stepan Chem.  Co., Wilmington, Mass.
Sybron Corp.,  Birmingham, N. J.
Synvar Corp.,  Wilmington, Mass.
TRW Inc., Downington, Pa.
Uniroyal Inc.,  Naugatuck, Conn.
United-Erie, Inc., Erie, Pa.
U. S. Coatings Co., Inc., Kenilworth, N. J.
Westinghouse Electric Corp., W. Mifflin (Pittsburgh), Pa.
American Cyanamid Co.,  Evendale (Cincinnati), O.
CPC International, Inc., Forest Park, 111.
Carboline Co.,  Xenia, O.
Clark Oil & Refining Corp., Blue Island, 111.
P. D. George Co., St. Louis,  Mo.
Hereseti & Chem. Co.,  Manetowoc.  Wise.
Illinois Central Indust.,  Inc.,  Troy,  Mich.
Inland Steel Co.,  Alsip, HI.
Ironsides Resins, Inc., Columbus, O.
Midwest Mfg. Corp., Burlington,  Iowa
Mobil Oil Corp., Kankakee, 111.
Plastics Engineering Co., Sheboygan, Wise.
The Richardson Co., De Kalb, 111.

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                                                          APPENDIX 1  (continued)

                                            Environmental Protection Agency

                                            PRODUCERS:   ACRYLICS

 Producers of Acrylic Coating Resins

 The following companies supply acrylic coating resins to U. S. paint
 companies.  They do not produce paint.  Companies that also produce
 paint will be listed  in a subsequent table.

Allied Chemical Corp.,  Lynwood, Calif.            Rohm and Haas Co., Bristol, Pa.
                     Toledo, Ohio                                Knoxville. Tenn.
                     Whippany, N.J.                              Louisville, Ky.
American Cyanamid Co.,  Azusa, Calif.            A. E.  Staley Mfg. Co., Cambridge,  Mass.
                       Wallingford,  Conn.                             Lemont, 111.
Archer Daniels Midland Co., Valley Park, Mo.                            Marlboro, Mass.
Ashland Oil & Refining Co.,  Fords, N. J.            Union Carbide Corp., Bound Brook, N. J.
Minnesota Mining & Manufacturing Co.,  St. Paul, Minn.                    South Charleston, W. Va.
Monsanto Co., Addyston, Ohio                    Union Oil Co.  of Calif., Charlotte, N. C.
             Santa Clara,  Calif.                                      Chicago, 111.
             Springfield, Mass.                                        Los Angeles, Calif.
National Starch and Chemical Corp., Meredosia, HI.    The Borden Chemical Co.,  Bainbridge, N.Y.
                              Piainfield, N.J.                           Compton, Calif.
Onyx Oils & Resins, Inc.,  Brooker, Fla.                                     Demopolis, Ala.
                       Newark, N.J.                                     Dliopolis, ffl.
Polyvinyl Chemicals, Inc., Wilmington, Mass.                               Leominster, Mass.
Purex Corp., Ltd., Chicago, HI.                  The Dow Chemical Co., Freeport, Tex.
                 Los Angeles, Calif.                                   Midland, Mich.
                 Philadelphia, Pa.                                    Pittsburgh, Calif.
Reichhold Chemicals, Inc., Azusa, Calif.           Freeman Chemical Corp., Ambridge, Pa.
                        Detroit,  Mich.                                 Saukville, Wise.
                        Elizabeth,  N.J.          H. B.  Fuller Co., St. Bernard, Ohio
                        Jacksonville, Fla.       The Goodyear Tire & Rubber Co., Akron, Ohio
                        S. San Francisco, Calif.   Jersey State Chemical Co., Haledon, N.J.
                                              S. C.  Johnson & Son, Inc., Waxdale, Wise.

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                                                         APPENDIX 1  (continued)

                                           Environmental Protection Agency

                                           PRODUCERS  :  ACRYLICS


 Producers of Polyacrylic Acid and Its Salts

Alco Standard Coip., Chattanooga, Tenn.         The B. F. Goodrich Co., Calvert City, Ky.
                  Philadelphia, Pa.            W. R.  Grace & Co.,  Lake Zurich, HI.
American Aniline & Extract Co., Calvert City.  Ky. Jordan Chemical Co., Folcrott, Pa.
                            Philadelphia,  Pa.  Rohm and Haas Co.,  Bristol, Pa.
Colloids, inc., Newark, N.J.                                      Knoxville, Tenn.
Diamond Shamrock Corp., Cedartown. Ga.                          Philadelphia, Pa.


 B. F. Goodrich and Rohm and Haas are the largest producers of poly-
 acrylic acid and  its salts.



 Producers of Specialty Acrylates

Aceto Chemical Co., Inc., Carlstadt, N.J.
Alcolac Chemical Corp.. Baltimore, Md.
American Aniline & Extract Co.,  Calvert City, Ky.
                             Philadelphia, Pa.
Borden Inc., Philadelphia, Pa.
Sartomer Resins,  Inc.,  Essington,  Pa.



 Producers of Polyacrylamide  Flocculants

American Cyanamid Co., Princeton, N.J.         Merck & Co., Inc.,  Ellwood City, Pa.
                      Warners,  N. J.          Nalco Chemical Co., Chicago, Ell.
                       Woodridge, N.J.        National Starch and Chemical Corp.,  Meredosia, 01.
Betz Laboratories, Inc.. Trevose.  Pa.             Standard Brands.  Inc.. Tylac Chemicals Div.,
The Dow Chemical Co.,  Midland, Mich.                                         Sayreville. N.J.
Hercules Inc., Hopewell, Va.                   Stein, Hall & Co., Inc.,  Charlotte,  N.C.

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                                                           APPENDIX 1 (continued)

                                             Environmental Protection Agency

                                             PRODUCERS :   ACRYLICS

 Producers of Acrylic Coatings and Resins

 The following companies produce acrylic coatings and supply all or part
 of their resin demand from captive resin production.
Armstong Paint & Varnish Works,  Inc.,  Chicago, ni.
Baltimore Paint & Chemical Corp., Baltimore,  Md.
Celanese Coatings Co., Detroit, Mich.
                     Newark,  N.J.
                     Riverside, Calif.
                     Belvideie, N.J.
                     Louisville, Ky.
Cook Paint & Varnish Co.,  Detroit. Mich.
                        Houston,  Tex.
De Soto Chemical Coatings, Inc., Berkeley, Calif.
                              Chicago Heights, HI.
                              Garland,  Tex.
E. I. du Pont de Nemours & Co., Inc., Belle, W. Va.
                              Chicago, ni.
                              Everett, Mass.
                              Flint, Mich.
                              Fort Madison, Iowa
                              Parlin. N.J.
                              Philadelphia. Pa.
                              S. San Francisco, Calif.
                              Toledo, Ohio
                              Tucker, Ga.
The Glidden Co., Chicago, m.
                Cleveland, Ohio
                Huron, Ohio
                Reading, Pa.
                San Francisco, Calif.
Guardsman Chem. Coatings, Inc., Grand Rapids, Mich.
Hunt Foods & Industries, Inc.,  Los Angeles. Calif.
                          Seattle, Wash.
                          S. San Francisco, Calif.
Interchemical Corp., Anaheim, Calif.
                   Detroit, Mich.
                   Cincinnati, Ohio
                   Newark, N.J.
Jones-Blair Paint Co., Inc., Dallas, Tex.
Midland Industrial Finishes Co.,  Inc.,  Waukegan.ni.
Mobil Chemical Co., Cleveland, Ohio
National Lead Co., Philadelphia, Pa.
The O' Brien Corp., South Bend, Ind.
PPG Industries,  Circleville, Ohio
              Milwaukee, Wis.
              Newark, N.J.
              Springdale,  Pa.
The Sherwin-Williams Co., Chicago,  m.
Standard T. Chemical Co., Inc.. Chicago, HI.
                             Staten Island, N. Y.

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                                 APPENDIX 1  (continued)

                   Environmental Protection Agency

                   PRODUCERS:   POLYAMIDE RESINS *8)
Producer and Location

AZ Products. Inc..  Eaton Park, Fla.
Cooper Polymers, Inc.,  Wilmington. Mass.
Emery Industries, Inc., Cincinnati, O.
The Epoxylite Corp.,  South El Monte, Calif.
                   Buffalo. N.Y.
General Mills, Inc., Kankakee,  111.
LawterChemicals,  Inc.,  South Kearny, N.J.
Mobil Oil Corp., Cicero, 111.
Reichhold Chemicals, Inc., Ballard Vale, Mass.
Stepan Chemical Co.. Millsdale, 01.
Sun Chemical Corp.,  Chester, S.C.
                   Wood River Junction. R. I.
Tenneco Chemicals, Inc., Garfield, N. J.
U. S. M. Corporation,  Middleton, Mass.

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                          APPENDIX 2
            DEVELOPMENT OF EMISSION POTENTIAL INDICES
roster 0 Snell. Inc

-------
                                                           APPENDIX  2  (continued)

                                                     Environmental Protection Agency

                                                     TECHNICAL EVALUATION GRID

                                                           Polypropylene
                             Work Sheet
A = Receiving and storage of process chemicals:
      Propylene is stored as a liquid. Diluents are stored blanketed with an
      inert gas.  Tank vents and feed lines are emission sources.  Catalysts
      are shipped either as solids or diluted with a hydrocarbon solvent -
      emissions  may occur as a result of materials handling.
B = Purification of monomers and/or solvents:
      Propylene and solvent are recovered from polymerization unit and are
      condensed and recycled to reactor.  The deactivation solvent is distilled
      and recycled.

C = Prepolymerization:

      Propylene, solvent and catalyst are premixed.  An emission source is the
      premix tank vent.

D = Polymerization:

      Polymerization conducted at under 200 psig and between 100 and 200°F.
      Solvent and propylene may be vented.

E = Polymer separation:
      Propylene and other volatiles are flashed off.  The catalyst is deactivated
      by adding water or alcohol and polymer filtered off and dried in a rotary
      or spray drier.  Emissions occur during catalyst deactivation, transport
      of polymer to and through driers.
F = Compounding:
      Polymer is compounded with the necessary additives, melted and extruded.
      Some residual solvent is emitted during melting and extrusion.
      Factor                  Intensity Rating
                                    (A)
        A                          10
        B                          10
        C                           6
        D                           8
        E                          10
        F                           6
Factor Weight
(B)
0.1
0.2
0.1
0.2
0.3
0.1
Index Number
AxB

1.0
2.0
0.6
1.6
3.0
0.6
8.8

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                                                           APPENDIX  2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                          HD Polyethylene
                             Work Sheet
A = Receiving and storage of process chemicals:

      Ethylene is stored as a liquid.  Tank vents and feed lines may be a source of
      emissions.  Cycloparaffins such as cyclohexane are liquids.

B = Purification of monomers and/or solvents:

      Ethylene and diluent/solvent are recovered, purified and recycled. Venting
      of compressors and condensers can be a source of emissions.

C = Prepolymerization:

      Ethylene and diluent/solvent are premixed.  Venting of this chamber is a
      source of emission.

D = Polymerization:

      Polymerization is conducted at 20-30 atm and 125-175°C .
E = Polymer separation:

      Monomer is flashed off and recycled.  Polymer/solvent solution contacted with
      water or cooled and polymer precipitates and is filtered. Polymer is dried.
      Conveyer systems and dryer vents are a major source of emission.
F = Compounding:

      Polymer may be remelted, additives added and extruded. Vents on extruders
      and volatilization of solvent during remelting may be a source of emission.
      Factor                 Intensity Rating        Factor Weight           AxB
                                   (A)                   (B)
        A                          10                  0.05                 0.5
        B                          10                  0.2                  2.0
        C                           4                  0.05                 0.2
        D                           8                  0.2                  1.6
        E                          10                  0.3                  3.0
        F                           6                  0.2                  1.2
                                                            Index Number   8.5

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                                                          APPENDIX 2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                          LD Polyethylene
                             Work Sheet
A = Receiving and storage of process chemicals:

      Ethylene is stored as a liquid and tank vents may be a source of emissions.
      Initiators such as organic peroxides are stored separately in relatively small
      containers.
B = Purification of monomers and/or solvents:

      Ethylene monomer is  separated from the polymer mass, purified and recycled.
      Emissions can occur from venting and leaks.

C = Prepolymerization:

      Ethylene is compressed in stages.   Emissions are possible at the compressor.


D = Polymerization:

      Ethylene is polymerized at 15,000-50,000 psi and 100-200°C. Polymerization
      is continuous and emissions can occur at vents, valves, and other leaks.

E = Polymer separation:

      Polymer is usually extruded as strands directly from the devolatilizer and
      a major source of emission is at extruder vents where the monomer still
      dissolved in the polymer is emitted.
F = Compounding:

      The polymer may be remelted,  additives added and again extruded.
      Extruder vents are a major source of emission, but not as great as  the
      previous stage.
      Factor                 Intensity Rating         Factor  Weight          AxB
                                    (A)
        A                           10
        B                            8
        C                            4
        D                           10
        E                            8
        F                            6
(B)
0.1
0.1
0.1
0.2
0.3
0.2
Index Number

1.0
0.8
0.4
2.0
2.4
1.2
7.8

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                                                          APPENDIX 2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                          Styrene Resins
                                                     (Bulk Continuous Solution
                             Work Sheet              For Crystal Polystyrene)


A = Receiving and storage of process chemicals:

      Styrene is the monomer used and ethyl benzene is the solvent.  Some emissions
      can occur as a result of styrene storage vents.

B = Purification of monomers and/or solvents:

      Monomer and ethylbenzene are recovered and recycled.


C = Prepolymerization:

      Monomer and solvent are premised.


D = Polymerization:

      Polymerization conducted in stages starting at  about 110°C  and increasing
      to 170°C.

E = Polymer separation:

      Polymer is devolatilized at 225-250°C and polymer fed to an extruder,
      cooled, cut and bagged.

F = Compounding:
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A                            6
        B                           10                  0.3                  3.0
        C                            2                   -                    -
                              2+6 = 4                  0.1                  0.4
        D
        E
        F
E                       28                  0.6                 4.8

                                                     Index Number   8.2

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                                                          APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                          Styrene Resins
                                                    (Suspension Process For
                             Work Sheet              Crystal Polystyrene)


A = Receiving and storage of process chemicals:
      Styrene is the only monomer used. Other ingredients include small amounts
      of additives, suspending agents, buffering agents and initiators.

B = Purification of monomers and/or solvents:

      None
C = Prepolymerization:
      Monomer pumped into hot water containing the additives.  Reactor venting
      is a source of emission.

D = Polymerization:
      Polymerization conducted in a stirred reactor at 190°F.  Reactor vents are
      a source of emissions.

E = Polymer separation:
      Polymer mass is washed with water,  the beads are centrifuged, dried,
      extruded and packaged.

F = Compounding:

      None
      Factor                  Intensity Rating        Factor Weight          AxB
                                   (A)                  (B)
        A                            6                   0.05                 0.3
        B                            -
        c                            2                   0.05                 0.1
        D                            2                   0.2                 0.4
        E                          10                   0.7                 7.-
        F                            ~                                       	
                                                             Index Number   7.8

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                                                           APPENDIX 2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                           Styrene Resins
                                                     (Suspension Process For
                             Work Sheet               Impact Polystyrene)


A = Receiving and storage of process chemicals:

      Rubber and styrene are raw materials.  Styrene storage tank vent is minor
      emission source.

B = Purification of monomers and/or solvents:

      None


C = Prepolymerization:

      Rubber is dissolved in styrene monomer and converted to 10-20% polymer.


D = Polymerization:

      The Rubber-styrene is suspended in water, peroxide added and polymeri-
      zation conducted at 90°-130°C.  Emissions result from reactor venting.

E = Polymer separation:

      Polymer mass is flushed into a mechanical separator, the beads are washed,
      centrifuged,  dried and extruded. Emissions result from extruder and drier
      vents.
F = Compounding:
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A                           6                   0.1                  0.6
        B                           -
        C                           6                   0.1                  0.6
        D                           8                   0.4                  3.2
        E                           8                   0.4                  3.2
        F                           -
                                                            Index Number   7.6

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                                                           APPENDIX  2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                           Styrene Resins
                                                     (Bulk Continuous Process
                             Work Sheet               por Impact PoiyStyrene)


A = Receiving and storage of process chemicals:
      Rubber and styrene are raw materials.  Styrene storage tank is a minor
      emission source.

B = Purification of monomers and/or  solvents:
      Styrene is recovered and recycled.
f. = Prepolymenzation:
      Rubber IF. dissolved in styrene monomer.


D = Polymerization:
      Polymerization conducted in a continuous tower operating in temperature
      gradients from 90°C to 150-200°C .

P = Polymer separation:

      Polymer mass is devolatilized in a thin-film evaporator or gear
        evolatilizer, extruded and packaged.

F - Compounding:
      Factor                  Intensity Rating         Factor Weight          AxB
                                   (A)                  (B)
        A                           6                    0.05                0.3
        B                           8                    0.1                 0.8
        C                           4                    0.05                0.2
        D                           6                    0.5                 3.-
        E                           8                    0.3                 2.4
        F                           -                     -                   -
                                                             Index Number   6.7

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                                                           APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                           Styrene Resins-
                                                           (ABS Process)
                             Work Sheet


A = Receiving and storage of process chemicals:

      Raw materials include styrene, butadiene and acrylonitrile with peroxides
      being used as catalysts. Emission sources are vents from storage tank.

B = Purification of monomers and/or solvents:

      Monomers are recovered and recycled.


C = Prepolymerization:
D = Polymerization:       Two separate polymerizations are conducted.

       1)    Acrylonitrile and Butadiene are emulsified in water and polymerized
            at 105°F.  Monomers are removed by stripping with steam under vacuum.
       2)    Styrene and acrylonitrile are emulsified in water and polymerized at 122°F.
E = Polymer separation:

       Both (1) and (2) above are emulsions and are stored.


F = Compounding:         (1)  and (2) above are mixed and coagulated or floculated by
       acidification, the crumb is washed with water and dried.  It is further compounded
       by feeding the dried crumb to an extruder or banbury type mixer where ABS is
       fluxed, milled and extruded.
      Factor                  Intensity Rating        Factor Weight          AxB
                                   (A)                  (B)
        A                            8                  0.05                0.4
        B                           10                  0.05                0.5
        C                            2
        D                            6                  0.7                 4.2
        E                            -
        F                            8                  0.2                 1.6
                                                             Index Number   6.7

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                                                          APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                          Coumarone-Indene And
                             Work Sheet                   Petroleum Resins


A = Receiving and storage of process chemicals:

      Coal and petroleum tar oils are the basic raw materials. Aromatic solvents
      are used extensively.

B = Purification of monomers and/or solvents:

      Tar oils are fractionated and blended. Emissions occur at condenser vents.


C = Prepolymerization:

      None


D = Polymerization:

      Polymerization begins at low temperature and the exotherm raises temperature
      to 95-lOSoC.

E = Polymer separation:

      Polymer is washed and heated to 200°C and flashed under vacuum or injected
      with steam and drummed or flaked.

F = Compounding:
      Factor                  Intensity Rating         Factor Weight          AxB
                                   (A)
        A                           6                  0.1                 0.6
        B                           8                  0.2                 i.a
        C
        D                           2                  0.2                 0.4
        E                    8+10 = 9                 0.5                 4.5
        F                      2    4                                      _
                                                            Index Number   7.1

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                                                           APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                          Vinyl Resins
                             Work Sheet                (Polyvinyl Chloride)
A = Receiving and storage of process chemicals:

      Vinyl chloride and comonomers, i.e. vinylidene chloride, vinyl acetate are
      principle monomers.  Plasticizers and ketone solvents are also used in compounding,
      Emissions can occur from storage tank vents.
B = Purification of monomers and/or solvents:

      Vinyl chloride is recovered from reactor and distilled and recycled.
C = Prepolymerization:

      Monomer and water are mixed with the initiator.


D = Polymerization:

      Polymerization conducted at 45-55°C to 90% conversion.


E = Polymer separation:

      Polymer transferred to a dump tank, monomer is removed under vacuum and
      sent to distillation unit.  Polymer separated by centrifugation and dried in a
      rotary drier.
F = Compounding:

      PVC may be dissolved in ketones or plastic!zed by mixing in heated blenders.
      Factor                  Intensity  Rating         Factor Weight           AxB
                                    (A)                  (B)
        A                          10                   0.05                0.5
        B                           8                   0.2                 1.6
        C                           2                   0.05                0.1
        D                           6                   0.3                 1.8
        E                           8                   0.3                 2.4
        F                           8                   0.1                 0.8
                                                             Index Number  7.2

                                    10

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                                                            APPENDIX  2  (continued)

                                                     Environmental Protection Agency

                                                     TECHNICAL EVALUATION GRID

                                                           Vinyl Resins
                              Work Sheet                (Polyvinyl Alcohol)
A = Receiving and storage of process chemicals:

      Polyvinyl acetate (beads) is the basic raw material.  Methanol is used in
      alcoholysis of the poly vinyl acetate.  Sodium hydroxide is the catalyst.

B = Purification of monomers and/or solvents:

      Methanol recovery.  Impurities consist of methyl acetate.


C = Prepolymerization:

      PVAc is dissolved in hot methanol (120-140°F)


D = Polymerization:

      Sodium hydroxide in methanol is added to convert the acetate to alcohol and
      gellation occurs. Additional methanol is added,  after the gel is ground, and
      alcoholysis is completed to desired degree.
E = Polymer separation:

      The slurry is sent to an expressor where liquid and solid are separated.
      The solid is dried in a rotary drier.

F = Compounding:
      Factor                  Intensity Rating         Factor  Weight          AxB
                                    (A)                   (B)
        A                           8                     -                    -
        B                           4                    0.2                 0.8
        C                           6                     -                    -
        D                           2                    0.1                 0.2
        E                           8                    0.7                 5.6
        F                           -
                                                              Index Number   6.6

                                    11

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                              Work Sheet
                                                           APPENDIX 2 (continued)

                                                     Environmental Protection Agency

                                                     TECHNICAL EVALUATION GRID
                                                           Vinyl Resins
                                                       (Polyvinyl Acetate)
A = Receiving and storage of process chemicals:

      Vinyl Acetate is the main constituent.  Many other ingredients, i.e. emulsifier,
      catalyst, protective colloids, buffers are used in minor quantities.  Emissions
      are principally vinyl acetate venting.
B = Purification of monomers and/or solvents:

      None
C = Prepolymerization:

      Vinyl acetate is mixed with water and other ingredients
      Venting of reactor is a source of emissions.

D = Polymerization:

      Polymerization conducted at 67-80°C with reflux.


E = Polymer separation:

      Emulsion is cooled and transferred to storage.


F = Compounding:
      Factor

        A
        B
        C
        D
        E
        F
Intensity Rating
      (A)
       8

       2
       4
       2
Factor Weight
    (B)
      .1

      .1
    0.7
      .1
AxB

 0.8

 0.2
 2.8
 0.2
                                                              Index Number   4.0
                                      12

-------
                                                          APPENDIX 2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                          Polyamides
                             Work Sheet                     (Nylon 6)
A = Receiving and storage of process chemicals:

      Caprolactam and acetic acid are raw materials.


B = Purification of monomers and/or solvents:

      Monomer is recovered by steam distillation of polymer at 300-400°C.


C = Prepolymerization:

      None.


D = Polymerization:

      Polymerization conducted at 255-260°C in presence of acetic acid.


E = Polymer separation:

      Polymer removed to surge tank, extruded, washed with water at 180-195°F,
      dewatered by filtering or centrifugation and dried.  Emissions through
      extruder vents, drier.
F = Compounding:
      Factor                 Intensity Rating        Factor Weight           AxB
                                   (A)                   (B)
        A                           7                    -
        B                           8                   0.6                  4.8
        C
        D                           4                   0.1                  0.4
        E                           8                   0.3                  2.4
        F                                                                   	
                                                            Index Number   7.6

                                   13

-------
                                                           APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                           Polyamides
                             Work Shea.                     
-------
                             Work Sheet
                                                           APPENDIX  2  (continued)

                                                     Environmental Protection Agency

                                                     TECHNICAL EVALUATION GRID

                                                           Cellulosics
                                                        (Cellulose Acetate)
A = Receiving and storage of process chemicals:

      Cellulose is the "monomer" used.  Major process chemicals include acetic
      acid, acetic anhydride, methylene chloride, solvents (MEK, ethanol,
      methanol, benzene)
B = Purification of monomers and/or solvents:

      Distillation of acetic acid,  methylene chloride.
C = Prepolymerization:

      Cellulose is added slowly to a mixture of acetic anhydride and glacial acetic
      acid with small amounts of sulfuric acid (7-10°C) in a mixing tank, then
      pumped to the acetylator.
D = Polymerization:

      The temperature is kept below 30°C until acetylation is complete;  then pumped
      to a hydrolyzer.  (If methylene chloride is used, acetylation is conducted at
      reflux , about 40-50°C) .
E = Polymer separation:

      The mixture is dumped into a large volume of water, centrifuged  (the acetic
      acid is recovered and reused) , washed with water, centrifuged and dried.
      Emissions occur as a result of drier vents.
F = Compounding:
      Cellulose acetate is usually compounded by either dry compounding or solution
      compounding.  In dry compounding, emissions are very small. In solvent
      compounding, however, solvent emissions are common and relatively high.
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                   (B)
        A                            8
        B                            6                  0.1                  0.6
        C                            2
        D                     2+4 = 3                 0.1                  0.3
        E                       26                  0.3                  1.8
        F                            8                  0.5                  4.-
                                                             Index Number   6.7
                                    15

-------
                                                         APPENDIX 2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                         Amino Resins

                             Work Sheet


A = Receiving and storage of process chemicals:

      Urea and melamine are solids; formaldehyde in the form of 37% solids.


B = Purification of monomers and/or solvents:

      None.


C = Prepolymerization:

      None.


D = Polymerization:

      Polymerization conducted at 75-150°F or at reflux temperature. Formaldehyde
      is probably emitted.

E = Polymer separation:

      Package directly after filtering or pass on to compounding. Formaldehyde odors
      emitted during packaging.

F = Compounding:

      Most U-F and M-F resins are compounded into molding powders.  Others are
      spray dried directly. Emissions occur in drying hoppers or in cyclone exhausts.
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A                     2 + 4   = 3                0.1                  0.3
        B                       2    -
        C                            -
        D                            4                  0.4                  1.6
        E                            2                  0.1                  0.2
        F                            8                  0.4                  3.2
                                                            Index Number   5.3

                                    16

-------
                                                           APPENDIX 2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                           Acrylics
                                                       (Emulsion Polymerization)
                             Work  Sheet                            *


A = Receiving and storage of process chemicals:

      Acrylic monomers.


B = Purification of monomers and/or solvents:

      None.


C = Prepolymerization:

      Monomer is added to the water  containing initiators and reactor purged with
      an inert gas. Emissions and aerosols can occur as result of purging.

D = Polymerization:

      There is a short induction period (30-50°C)  and a vigorous reaction occurs
      arid temperatures may approach 90-95°C. Polymerization essentially complete
      in 15 minutes.
E = Polymer separation:

      Monomers are removed by steam stripping to lower odor.  Monomers are
      usually not reused and are destroyed.  Emissions are possible during
      drumming operations or during storage.
F = Compounding:

      None.
      Factor                  Intensity Rating         Factor Weight          AxB
                             ^     (A)                  (B)
        A                            8                   .1                 0.8
        B
        C                            2
        D                            5                   .8                 4.0
        E                            6                   .1                 0.6
        F                            -                                       -
                                                            Index Number   5.4

                                   17

-------
                                                          APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                          Acrylics
                                                      (Solution Polymerization)
                             Work Sheet                          '


A = Receiving and storage of process chemicals:

      Acrylic monomers; aromatic solvents, i.e. xylene, toluene;  ketones, i.e. MIBK,
      MEK; others.

B = Purification of monomers and/or  solvents:

      None.


C = Prepolymerization:

      None/


D = Polymerization:

      Solvent is placed in the kettle and at reflux, separate streams of monomer
      and initiator are added over a period of 8 to 24 hours.  Emissions through
      condenser  venting and leakage.
E = Polymer separation:

      Polymer mix is sent to storage or drummed directly. Emissions during
      drumming.

F = Compounding:

      None.
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A                            8                  0.1                  0.8
        B                            -
        C                            -
        D                            4                  0.8                  3.2
        E                            6                  0.1                  0.6
        F                            -
                                                            Index Number   4.6

                                    18

-------
                                                           APPENDIX 2  (continued)

                                                     Environmental Protection Agency

                                                     TECHNICAL EVALUATION GRID

                                                           Alkyds
                              Work Sheet
 A = Receiving and storage of process chemicals:

      Anhydrides, fatty acids, oils,  and polyhydric alcohols are either liquids
      or solids with low vapor pressure.  Solvents, mostly aromatic, are used
      as thinners.
 B = Purification of monomers and/or solvents:

      None.
C = Prepolymerization:

      None.


D = Polymerization:

      Polymerization carried out at 210-250°C with solvent or azeotropic distillation.
      Sparge gas used to supplement agitation.  Emissions occur through  solvent
      losses in distillation, aerosol formation with sparge gas.
E = Polymer separation:

      Polymer is dropped into a thinning tank containing solvent. Addition is made
      at reflux. Solvent emissions occur during venting.

F = Compounding:

      Solvent odors prevalant in shipping area because of filling open-head drums
      and spillage.
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                   (B)                 	
        A                            3                   0.05                  .2
        B                            -
        C                            -
        D                            4                   Q.5                  2.0
        E                            6                   0.4                  2.4
        F                            4                   0.05                 Q.2
                                                             Index Number   4.8

                                    19

-------
                                                          APPENDIX '2 (continued)


                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID


                                                          Polyesters
                             Work Sheet
A = Receiving and storage of process chemicals:


      The anhydrides used are all solids.  Glycols are liquids of low vapor pressure
      and the reactive monomer or solvent is usually styrene,  a liquid of high vapor
      pressure.
B = Purification of monomers and/or solvents:

      None.
C = Prepolymerization:


      None.


D = Polymerization:


      Polymerization conducted at 190-220°C with water of reaction removed through
      a condenser.  Reaction mass is sparged during cooking to remove water. Emissions
      occur through condenser vents, reactor gaskets.
E = Polymer separation:


      Polymer mass  is cooled to 100-150°C and dropped into a thinning tank containing
      monomer. Venting results in emissions.

F = Compounding:
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A                          2                   0.1                 0.2
        B
        C

        D                          4                   0.4                 1.6
        E                          6                   0.5                 3.0
        F

                                                            Index Number  4.8

                                   20

-------
                                                          APPENDIX  2 (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID
                                                          Epoxy Resins

                             Work Sheet


A = Receiving and storage of process chemicals:

      Epichlorohydrin and Bisphenol A are the monomers. Small quantities of
      xylene or methanol are used for salting out purposes.

B = Purification of monomers and/or solvents:

      Recover epichlorohydrip.


C = Prepolymerization:

      None.


D = Polymerization:

      Polymerization conducted at epichlorohydrin b.p. 116°C .


E = Polymer separation:

      Excess epichlorohydrin removed by vacuum distillation and recycled.
      Filter, wash resin with warm water; heat resin to 100°C under vacuum
      and drum.
F = Compounding:
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                  (B)
        A
        B                            6                   0.1                  0.6
        C
        D                            4                   0.4                  1.6
        E                            4                   0.5                  2.0
        F                                                                   	
                                                            Index Number   4.2

                                   21

-------
                                                          APPENDIX  2  (continued)

                                                    Environmental Protection Agency

                                                    TECHNICAL EVALUATION GRID

                                                    Phenolic and Other Tar Acid Resins
                             Work Sheet
A = Receiving and storage of process chemicals:

      Phenol and Formalin (37% formaldehyde) are the reactive ingredients.
      Sometimes a solvent such as Butanol, Ethanol, MEK are used in making
      solution resins.
B = Purification of monomers and/or solvents:

      None.
C = Prepolymerization:

      Venting of reactor during charging.


D = Polymerization:

      Polymerization at atmospheric reflux temperature (60-85°C) ,  then temperature
      raised to 85-90oC by refluxing under pressure. Emissions of phenol, formalde-
      hyde and  methanol occur during reflux through condenser vents.
E = Polymer separation:

      Water is removed by vacuum distillation. Resin can be discharged directly into
      drums, diluted with solvent, flaked or cured in molds.

F = Compounding:

      Resins may be compounded with filler.  Some may be pulverized with
      hexamethylenetetramine.
      Factor                 Intensity Rating        Factor Weight           AxB
                                   (A)                  (B)
        A                     2 + 6 =  4
        B                       2  -
        C                          2                    0.1                  0.2
        D                          4                    0.4                  1.6
        E                     2+6 =  4                  0.4                  1.6
        F                       2 ' 6                    0.1                  0.6
                                                            Index Number   4.0

                                  22

-------
                              Work Sheet
                                                            APPENDIX  2 (continued)

                                                     Environmental Protection Agency

                                                     TECHNiqAL EVALUATION GRID

                                                            Polyurethanes
A = Receiving and storage of process chemicals:

       Diisocyanates, polyols and polyesters are major raw materials.  Solvents,
       when used, are Cellosolve esters, and aromatic solvents, i.e. xylene, or
       toluene. Nitrogen is used to blanket reaction kettles.
B = Purification of monomers and/or solvents:

       None.
C = Prepolymerization:

       None.


D = Polymerization:

       Diisocyanates are added rapidly to polyols or polyesters cold, then heated
       at 110-115°C. The reaction mass is blanketed with nitrogen.  Emissions
       result from reactor vents during reaction, and when solvents are added.
E = Polymer separation:

       Polymer mass is cooled, solvent added and stored.


F = Compounding:
      Factor                  Intensity Rating         Factor Weight           AxB
                                   (A)                   (B)
        A                            6                   0.1                  0.6
        B                            -
        C                            -
        D                            2                   0.8                  1.6
        E                            4                   0.1                  0.4
        F                            -
                                                              Index  Number   2.6

                                    23

-------
                          APPENDIX 3
             HAZARD , ODOR AND PHYSICAL DATA ON PRINCIPAL
                    POLYMER INDUSTRY CHEMICALS
Foster 0 Snell. Inc

-------
Product
       OSHA
                              (55)
                                               Other
                                                                      Odor Threshold
                                                                                                   APPENDIX 3
                                                                                            Environmental Protection Agency
                                                                                                   POLYURETHANES
                                                                                      Physical Data
                                                                            b.p.  (°C)     Vapor Pressure (mmHg(°C))
Toluene Diisocyanate .02 ppm = .14 mg/m3

4.4' - Diphenylmethane
      Diisocyanate   . 02 ppm = . 2 mg/m3
"Hexamethylene
      Diisocyanate
       n.a.
 4,4',4" - Triphenylmethane
      Triisocyanate        n.a.
 Xylene
100 ppm = 435 mg.m
Ethylene Glycol Monoethyl
      Ether        200 ppm = 740 mg/m
 Toluene
 Mineral Spirits
      200 ppm
        n.a.
 Ethyl Acetate      400 ppm = 1,400 mg/md


 Butyl Acetate       150 ppm = 710 mg/m3


 Methyl Ethyl Ketone 200 ppm = 590 mg/m3

 Methyl Isobutyl
      Ketone       100 ppm = 410 mg/m3
                              n.a.
                              n.a.
500 ppm
                                                      (56)
                                                      .4 ppm
                                                                                (56)
                                                         n.a.
                                                         n.a.
                                                         n.a.
                     20 ppm = 100 mg/m
                                                    ethereal odor
                                                                                   3  (57)
                     40 ppm = 140 mg/m
                                                                                   3  (57)
                                                                            n.a.
                                                 50 ppm = 180 mg/m
                                                                                    3  (57)
                                                         n.a.
                                                                 3  (57)
                                                 25 ppm = 80 mg/m
                                                  8 ppm = 32 mg/m3  (57)
                                                                               250.0
                                                                               n.a.
                                                                               n.a.
                                                                               n.a.
                                                                                                  139.0
                                                    134.7
                                                                                                  110.6
                                                                                                 150-210
                                                     77.0
                                                                               125.0
                                                     79.6
                                                                                                  115.8
 n.a.


 n.a.


 n.a.


10 (29)


5.3 (25)


30 (26)


 n.a.


100 (25)


15 (25)


100 (25)



7.5 (25)

-------
                                                                                                          APPENDIX 3  (continued)
                                                                                                   Environmental Protection Agency
                                                                                                             ALKYDS
     Product
                              OS HA
                                    (55)
                                         Safety
     Phthalic Anhydride   2 ppm = 12 mg/mj
     Isophthahc Anhydride       n.a.
     Maleic Anhydride    .025 ppm = 1 mg/m
to
     Fumanc Acid


     Azelaic Acid


     Succinic Acid


     Adipic Acid


     Sebacic Acid


     Xylene


     Toluene
       n.a.
       n.a.
       n.a.
       n.a.
       n.a.
                            Other
                             n.a.
               very low toxicity
               very low toxiclty
                                                             (56)
                                     (SB)
               very low toxicity (56)
               very low toxiaty
                                     (56)
               very low toxicity *   '
100 ppm = 435 mg/nr
                                                                            Odor Threshold
                                                   choking odor
                                                                                       (56)
                                          choking odor (»)
                                                         n.a.
                                                                                 n.a.
                                                                                        (56)
                                                         n.a.
                                                     odorlese
                                                             (56)
                                                         n.a.
                                                         n.a.
                                          20 ppm = 100 mg/m
                                                                 3 (57)
n.a.       200 ppm  olifactory fatigue
                                                     .17 ppm
                                                             (46)
                                                                               Physical Data
                                                                     b.p. (°C)     Vapor Pressure (mmHg(°Cl)
284.0


n.a.


202.0


200.0  sublimes


286.5


235.0


265.0


294.5


139.0


110.6
                                                                                                     n.a.
                                                                                                                             n.a.
                                                                                                                             n.a.
 n.a.


 *1


 n.a.


10 (29)


30 (26)

-------
Product
OSHA t55*
                                    Safety
Phthalic Anhydride   2 ppm = 12 mg/ra
M-aleic Anhydride     .025 ppm = 1 mg/m3
Eumaric Acid
Succimc Acid


Adipic Acid


Propylene Glycol


Ethylene Glycol


Diethylene Glycol


Neopentyl Glycol


Dipropylene Glycol


Styrene
                          n.a.
Isophthalic Anhydride       n.a.
 n.a.
 n.a.
 n.a.
 n.a.
 n.a.
 n.a.
 n.a.
 n.a.
                                    Q
Methylstyrene       100 ppm = 480 mg/m°
       Other
               very low toxicity
                       n.a.
very low toxicity (56)
very low toxidty  (56)
                none necessary
                              (56)
    100 ppm (56)


 not established (56)
                       n.a.
                none necessary
                              (56)
    100 ppm (60)
                                                                       Odor Threshold
                                             choking odor<56)
                                                   n.a.
                                                                            n.a.
choking odor  (?)


    odorless
                                                                                    (56)
                                                   n.a.
                                                   n.a.
                                               odorless
                                                       (56)
                                                   n.a.
                                                   n.a.
                                                   n.a.
    .148 ppm
                                                       (46)
                                                                                                       APPENDIX 3  (continued)
                                                                                                Environmental Protection Agency
                                                                                                       POLYESTERS
                                 ;•.    Physical Data
                           b.p.  (°C)     Vapor Pressure  CmmHg(°C))
                                                   n.a.
                                                         284.0
                                                                         202.0
                                                         200.0 sublimes
                                                                         n.a.
235.0
                                                                         265.0
                                                                         187.2
                              197.6
                                                                         245.0
                                                                         n.a.
                                                                         231.9
                                                                         145.2
                                                                         n.a.
                                                                                n.a.
                                                                                               n.a.
                                                                                                                         n.a.
                                                                                               n.a.
                                                                               .13 (25)
                                                                                               n.a.
                     4.3 (15)
                                                                               1 (17)

-------
Product
                Safety
      OSHA155)             Other
                                                                    Odor Threshold
                              APPENDIX 3  (continued)
                       Environmental Protection Agency
                              EPOXY RESINS

                                    Physical Data
                          b.p. (°C)     Vapor Pressure (mmHg(  Q)
Bisphenol A
.Sppm = 2.8 mg/nr
                                                                      odorless
                                                                               (56)
                                                                            n.a.
                                                                                                                    n.a.
Bpichlorohydrin      5 ppm = 19 mg/md
Phenol
Cresol
Butanol
Glycerol
 5 ppm = 19 mg/m
 5 ppm = 22 mg/m
100 ppm = 300 mg/m
                         n.a.
Phthalic Anhydride    2 ppm = 12 mg/m3
                                              n.a.
                                                    10 ppm
                                                                              (56)
3 ppm = 12 mg/m'
                                                                                3 (57J
                                                                       5 ppm
                                                                      25 ppm
                                                                              (56)
                                                                               (56)
                                                                         n.a.
                                                  choking odor
                                                                                (56)
116.1
182.0
195.0
117.7
290.0
284/0 sublimes
5 (25)
.35-(25)
.15 (25)
6.5 (25)
n.a.
n.a.
 Stearic Acid
                         n.a.
                                           not toxic
                                                   (56)
                                                   slight odor
                                                             (56)
                                                                                               291.0
                                                                                                                     n.a.
 Phenylene Diamine
     .1 mg/mj
                                                                          n.a.
                                                                                               287.0
                                                                                                  n.a.
 Methanol
200 ppm = 260 mg/m
                                                               5.900 ppm = 7.800 mg/m3  t57)        64.5
                                                                                                 125 (25)

-------
                                                                                                  APPENDIX 3  (continued)
                                                                                            Environmental Protection Agency
                                                                                      PHENOLIC AND OTHER TAR ACID RESINS
       Product


       Phenol


       Formaldehyde


       Meta Cresol


en      Resorcinol


       Xylenols


       Sulfuric Acid


       Ammonia


       Butanol


       Ethanol
       OSHA
                                   (55)
                                                                                                        Physical Data
   5 ppm = 19 mg/m3
        n.a.
   5 ppm = 22 mg/nr
        n.a.
  100 ppm = 435 mg/m3
       1 mg/m3
  50 ppm = 35 mg/m
  100 ppm = 300 mg/m3
1.000 ppm = 1,900 mg/m
                                                   Other
5 ppm
                               (60)
       Methyl Ethyl Ketone  200 ppm = 590 mg/m3

Odor Threshold
3 ppm = 12 mg/m3 ^ 7)





037

50
25
lPPm<46>
.19 ppm 159>
odorless (56)
200 ppm (56)
n.a.
ppm= .026 mg/m3 <57)
15 ppm ^56)
3 f*71
ppm = 9 mg/m ia/J
ppm = 80-mg/m3 (57)
b.p. (°C)
182.0
-19.5
202.7
276.0
139.0
330.0
-33.4
117.7
78.4
79.6
Vapor Pressure (mmHg(°C))
.35 (25)
10 (88J
.15 (25)
"
10 (29)
«
n.a.
6.5 (25)
50 (25)
100 (25)
                                        n
       Cyclohexanone      50 ppm = 200 mg/m0
                                                   .12 ppm
                                                           (46)
                                                                           155.6
                                                                    4.5 (25)

-------
    Product                  OSHA(55)
    -Formaldehyde             n. a.
    Aniline
 5 ppm = 19 mg/m3
os
    Benzene Sulfonamide       n. a.
    Dicy andiamide              n. a.
    Melamine                 n.a.
    Thiourea                 n.a.
    p-Toluene Sulfonamide      n.a.
    Urea
    Methanol
    Butanol
    Octanol
                              n.a.
200 ppm = 260 mg/m3
100 ppm = 300 mg/m
                             n.a.
                            Other
                          5 ppm (60)
                                                   n.a.
                            -n.a.
                         nontoxic
                                                   n.a.
                             n.a.
                                                   n.a.
                                                   n.a.
                          Odor Threshold


                           l.Oppm'46'


                           .23 ppm (59)


                              n.a.


                              n.a.


                              n.a.


                              n.a.


                              n.a.


                              n.a.
       APPENDIX 3  (continued)
Environmental Protection Agency
       AMINO RESINS

       0    Physical Data
 b.p.  ( C)     Vapor Pressure (mmHg((
   -19.5


   184.4


   n.a.


decomposes


 sublimes


   n/a.


   n.a.


   n.a.
                       5900 ppm = 7800 m g/m3 (57)     796.0
                           15 ppm
                                                                                   (56)
                                                                               n.a.
    Xylene             100 ppm = 435 mg/m3                                20  ppm = 100 mg/m3


    Butyl Cellosolve           n.a.      100 ppm eye. nose irritation (56)      mild odor (56)
10 (-88)


15 (77)


  n.a.


  n.a.


50 (315)


  n.a.


  n.a.


  n.a.
796.0
117.7
178.0
139.0
170.6
125 (25)
6.5 (25)
1
10 (29)
.88 (25)
    Mineral Spirits
       n.a.
500 ppm (56)
                                                        n.a.
  150-210
                                                                                                                           n.a.

-------
                                                                                                    APPENDIX 3  (continued)
                                                                                             Environmental Protection Agency
                                                                                                      ACRYLICS
Product
      OSHA<55)
                                   Safety
Other
Odor Threshold
          Physical Data
b.p. (°C)     Vapor Pressure (mmHg(°C))
Ethyl Acrylate       25 ppm = 100 mg/nr
2-Ethylhexyl Acrylate      n. a.
                                   o
Methyl Acrylate      10 ppm-= 35 mg/m"
Isobutyl Acrylate          n. a.
2-Cyanoethyl Acrylate      n. a.
                             n.a.
                             n.a.
                             n.a.
2- Ethoxyethyl Acrylate     n.a.
                   LC  = 500 ppm (rat)
                      50
                                                          (56)
Toluene
Xylene
                          n.a.
                  200 ppm  olifactory fatigue
                                                            (56)
100 ppm = 435 mg/nr
Ethyl acetate       400 ppm = 1.400 mg/m3


Methyl Ethyl Ketone  200 ppm = 590 mg/m3
Methyl Isobutyl
      Ketone
                                                    .00024 ppm (46)
                                                        n.a.
                                                        n.a.
                                                        n.a.
                                                        n.a.
                            n.a.
                         .17ppm<4«


                      20 ppm = 100 mg/m3 (57)
                                                        n.a.
                                                  25 ppm = 80 mg/m
                                                                 3 (57)
                   100 ppm = 400 mg/nr
                                                 ketone-hke odor
                                                                (56)
99.5
130.0
80.0
n.a.
n.a.
n.a.
110.6
139.0
77.0
79.6
30 (20)
1 (20)
68 (20)
n.a.
n.a.
n.a.
30 (26)
10 (29)
100 (25)
100 (25)
                                                  115.8
                                               7.5 (25)

-------
      Product
      OSHA
                                   (55)
                                        Safety
   Other
                                                                                                   APPENDIX 3  (continued)
                                                                                             Environmental Protection Agency
                                                                                      COUMARONE-INDENE AND PETROLEUM RESINS
Odor Threshold
         Physical Data
b.p.  (°C)     Vapor Pressure (mmHe(°C)l
oo
      Coumarone
      Indene
                               n.a.
                                                    n.a.
      Styrene
10 ppm = 200 mg/m
      Cyclopentadiene    75 ppm = 200 mg/m
       n.a.
      Methy Icy clopentadiene      n.a.
      Vinyltoluene


      Methylindene


      Methylstyrene


      Xylene


      Naphtha
100 ppm = 480 mg/m


      n.a.

                3
100 ppm = 480 mg/m


100 ppm = 435 mg/m

                3
100 ppm = 400 mg/m
100 ppm t80)
                            n.a.
   n.a.
                                                                              n.a.
                                                                              n.a.
                                                      n.a.
                                                    .148
                                                                                 (46)
                                                      n.a.
                             n.a.
                              n.a.
                              n.a.
                      20 ppm = 100 mg/m
                                     3  (57)
                              n.a.
                                                                           173.0
                                                  181.0
                                                                            41.. 0
                          145.2
                                                                            n.a.
                                                   n.a.
                                                   n.a.
                                                   n.a.
                          139.0
                                                   65.1
                                                                                                                        n.a.
                                                                                                                        n.a.
                                                                                                n.a.
                      4.3 (15)
                                                                                                n.a.
                                                                        n.a.
                                                                        n.a.
                                                                        n.a.
                       10 (29)
                                                                        n.a.

-------
                                                                                                       APPENDIX 3  (continued)
                                                                                                 Environmental Protection Agency
                                                                                                       VINYL RESINS
                                       ^^,.j                                                              Physical Data
     Product                  OSHA                 Other                  Odor Threshold           b.p.  (°C)     Vapor Pressure  (mmHg( O)



                                       i                                              (56)
     Vinyl Chloride      50 ppm = 1300 mg/m"                              slight at 4100 ppm              -13.8                2580 (20)


     Vinyl Acetate              n.a.           1C   = 400 ppm (rat) (5B)          .12 ppm <46)               73.^)                115(25)
                                              50


10    Vinylidene Chloride         n.a.                  n.a.           5000 ppm some, 1000 ppm most""      31.7                591(25)



     Methyl Ethyl Ketone                                                                    (57)
          (PVC)        200 ppm = 590 mg/m3                                 25 ppm = BO mg/md            79.5                100(25)



     Methanol (PVA)      200 ppm = 260 mg/m3                            5900 ppm = 7800 mg/m3 (           64.5                125(25)



     Methyl Acetate                      ,                                               f57i
          (PVA)        200 ppm = 610 mg/m                              200 ppm = 550 mg/m3             57.0                235(25)

-------
                                                                                               APPENDIX 3  (continued)
                                                                                        Environmental Protection Agency
                                                                                               CELLULOSICS
Product
Acetic Add
        OSHA
                              f55)
Other
                                                                     Odor Threshold
   10 ppm = 25 mg/m*
                         2.6 ppm
                                                                               (59)
Acetone          1,000 ppm = 2.4000 mg/m3                            320 ppm = 770 mg/m

                                                        « (601                  (56)
Methylene Chloride         n.a.         500 ppm = 1750 mg/m3 IOUJ


Methanol           200 ppm = 260 mg/m3
                                                                  3 (57)
b.p. (°C)
   18.1
                                                                               56.1
                                                                               40.1
                                                                    3 (57)
Ethanol
1.000 ppm = 1.900 mg/m
Ethyl Acetate       400 ppm = 1.400 mg/m3


                             .3
                         300 ppm


                  5.-900 ppm = 7.800 mg/m"  *""      64.5


                     50 ppm = 93 mg/m3   (57)        78.4


                                                  77.0
Dimethyl Phthalate


Diethyl Phthalate


Nitric Acid


Sulfuric Acid
       5 mg/m
         n.a.
                                                  50 ppm = 180 mg/m

                                                               (56)
                                                                                  3  (57)
                              n.a.
    2 ppm - 5 mg/m3


       lmg/m3
                         aromatic
                                                       aromatic
                            n.a.
                            n.a.
                                                               (56)
Physical Data
    Vapor Pressure (mmHg(°Cl)



                15 (25)


               226 (25)


               440 (25)


               125 (25)


                50 (25)


               100 (25)
  282.0
                                                 296.1
                                                  86.0
                                                  330.0
                         «1
                                                                        n.a.

-------
                                                                                                APPENDIX 3  (continued)

                                                                                         Environmental Protection Agency

                                                                                                STYRENE RESINS
Product
OSHA
                             (55)
Other
                                                                    Odor Threshold
          Physical Data

b.p. (°C1     Vapor Pressure (rnrnHgt O)
Styrene
                         n.a.
Acrylonitrile        200 ppm = 45 mg/m3




1.4-Butadlene    1.000 ppm = 2.200 mg/m3



                                   3
Ethyl Benzene       100 ppm = 435 mg/m




Vinyl Alcohol              n.a.




C arbon Tetrachloride       n.a.
                   100 ppra
                                                  (60)
                      n.a.
                   10 ppm
                         (60)
                        .148 ppm
                                             21.4 ppm
                                                     (46)
                                                                              (60.)
                                                 n.a.
                                                 n.a.
                                                 n.a.
                        BO ppm
                               (56)
                                                                                              14S.2
                                                 77.3
                                                                       -4.4
                                                                      136.2
                                                                      n.a.
   76.8
4.3 (15)




112 (25)




 n.a.




 10 (26)




 n.a.




113 (25)

-------
                                                                                                   APPENDIX 3  (continued)
                                                                                             Environmental Protection Agency
                                                                                                   POLYPROPYLENE
Product



Propylene


Ethylene


Butane-1


n-Heptane


Cyclohexane
        OSHA
        n.a.
        n.a.
        n.a.
                              (55)
                                   Safety
                                               Other
                                 Odor Threshold
       1000 ppm  (56)
lO.OOOppm - drowsiness1
 500 ppm = 2,000 mg/m
 300 ppm = 1050 mg/m
Titanium Tetrachloride      n.a.
                        not established(56J
Titanium Trichloride
         n.a.
                                                n.a.
Ethanol
Methanol
1.000 ppm = 1,900 mg/m
  200 ppm = 260 mg/m
slightly sweet smell (56)


     5000 ppm
                                         (56)          cnnn „„„,  (56)
                                      n.a
                                   300 ppm
                                                              (56)
                                                                           n.a.
                                                                           n.a.
                                      Physical Data
                            b.p. ( C)      Vapor Pressure  (mmHg(°O)
    not established (56)         slightly sweet smell (56)         -103.7
                                                                                -47.7
                                                                                 -0.5
                                                             98.4
                                                                                 BO.7
                                                                                                 136.4
                                                                                                 n.a.
                               50 ppm = 9 mg/m3 (5?)           70.4


                             5900 ppm = 7800 mg/m3 (57)        64.5
 large


 large


1823 (25)


47.7 (25)


 103 (26)


  n.a.


  n.a.


 50 (25)


 6.5 (25)

-------
CO
Product


Ethylene


Vinyl Acetate


Ethyl Acrylate


Propylene


1-Butene
                               OSHA
                               n.a.
                                    (55)
                                                                                                         APPENDIX 3  (continued)
                                                                                                  Environmental Protection Agency
                                                                                           POLYETHYLENE AND  COPOLYMERS

                                                                                                               Physical Data
   Other
                                                                       Odor Threshold
1000 ppm
                                                           (56)
slightly sweet smell
                                         (56)
                               n.a.      LC= 4,000 (rat) inhalation (56)
                                           50
                            .12 ppm
                                                                                      (46)
                         25 ppm = 100 mg/m
                           .00024 ppm
                                                                                        (46)
                               n.a.
                               n.a.
      Isobutylene                 n.a.

      Titanium Tetrachloride      n.a.
                                               not established
                                               not established
                                          not established
                                          not established
                                                             (56)
                                                             (56)
                                                             (56)
                                                        (56)
                       slightly sweet smell
                                         (56)
                       slightly sweet smell
                       slightly sweet smell
                                          (56)
                                                                                      (56)
                                n.a.
      Cycloparaffins
      Naphtha
      Light Diesel Oil
                                       300 ppm = 1050 mg/m
                                                               3 (60)
                            300 ppm
                                                                                 (60)
                   100 ppm = 400 mg/m
                                                                                  n.a.
                          n.a.
                                                      n.a.
                       800 ppm = 3300 mg/m
                                                                                          3(57)
                            b.p.  (°C)     Vapor .Pressure (mmHg( O)
                                                                                                       103.7
                                73.0
                                                                                                        99.5
                                                                                                        -47.7
                                -6.3
                                                                                                         -6.3
                                                      n.a.
                                                                                                         80.7
                                                                                                       65-120
                                                                                                        n.a.
  large


115 (25.3)


 30 (20)


   n.a.


   n.a.


   n.a.


   n.a.


   1(25)


  5 (25)


   n.a.

-------
                                                                                             APPENDIX 3  (continued)
                                                                                      Environmental Protection Agency
                                                                                             POLYAMIDES
Product
      OSHA
                             (55)
                                  Safety
Other
Odor Threshold
         Physical Data •
b.p.  (°C)     Vapor Pressure (mmHg(°C))
Caprolactam
      n.a.
                            n.a.
                                                     n.a.
                                                                          n.a.
                                                                    3 (100)
Acetic Acid
100 ppm = 25 mg/m
                       2.6ppm
                          118.1
                      15 (25)
Hexamethylene Diamine     n.a.
                                              n.a.
                                                                       n.a.
                                                                          190.0
                                                                                                                 n.a.

-------
                          APPENDIX 4
        DEVELOPMENT OF HAZARD AND ODOR POTENTIAL INDICES
rosier 0 Snell. Inc

-------
                                                         APPENDIX  4

                                                   Environmental Protection Agency

                                                   HAZARD/ODOR POTENTIAL
                                                   WORK SHEET   (By Plastic)
           Probable Emission
      Odor Potential          Hazard Potential
Factor           Index    Factor         Index
Weight   Rating  Number  Weight  Rating Number
  (A)       (B)     (AxB)     (C)     (D)    (CxD)
     Polyethylene (LD)

          Ethylene
          Catalyst
     Polyethylene (HP)

          Ethylene
          Cycloparaffin
          Catalyst


     Vinyl Resins (PVC)

          Vinyl Chloride
          Other
           . Copolymer monomers
           . Solvents
           . Catalyst

     Vinyl Resins (PVAc)
          Vinyl Acetate
    Vinyl Resins (PVAlc)

          Methanol
          Methyl Acetate
.9
.1
2
(7)
1.8
.7
2.5
.9
.1
1
(4)
.9
.4
1.3
.6
.3
.1
.8
.2
2
2
(7)
1
6
1.2
.6
.7
2.5
.8
1.2
2.0
.6
.3
.1
.8
.2
1
1
(4)
4
4
.6
.3
.4
1.3
3.2
.8
4.0
 1.0
8
8
1.0
                                           4.0
9
1

1
2

.9
.2
1.1
.9
.1

2
2

1.8
.2
2.0
Foster D Snell, Inc

-------
                                        Odor Potential
                                                         APPENDIX 4  (continued)
                             Hazard Potential
          Probable Emission
    Polystyrene (Bulk-crystal)

          Styrene
          Ethyl Benzene
    Polystyrene (Suspension-crystal)

          Styrene                  1.0


    Polystyrene (Impact)

          Styrene                  1.0


    Styrene Resins (ABS)
Factor           Index    Factor          Index
Weight   Rating  Number  Weight   Rating Number
  (A)       (B)     (AxB)      (C)     (D)    (CxD)
6
4
8
(5)
4.B
2.0
6.8
.6
.4
3
3
1.8
1.2
3.0
          Styrene
          Butadiene
          Aery Ion trile
    Polypropylene

          Propylene
          Diluent
          Methanol
          Catalyst
    Phenolic and Other Tar Acid Resins
                   8
                   8
                   8
                   8
1.0
1.0
5
3
1
1

(D
2
1
(7)

.5
.6
. .1
.7
1.9
                            .5
                            .3
                            .1
                            .1
         (1)
          2
          2
3.0
3.0
6
3
1

8
(5)
5

4.8
1.5
.5
6.8
.6
.3
.1

3
1
2

1.8
.3
.2
2.3
 .5
 .6
 .2
 .4
1-7
Formaldehyde
Phenol
Ethanol
Butanol

.6
.2
.1
.1

8
6
4
5

4.8
1.2
.4
.5
6.9
.6
,2
.1
.1

6
6
1
3

3.6
1.2
.2
.3
5.2
Foster 0 Snail. Inc.

-------
                                                              APPENDIX  4  (continued)
Odor Potential

Probable Emission

Polyesters
Phthalic Anhydride
Styrene

Amino Resins
Formaldehyde
Butanol
Xylene

Alkyds
Phthalic Anhydride
Xylene

Acrylics
Acrylates
Xylene
MEK

Factor
Weight
(A)

.9
.1


.6
.3
.1


.9
.1


.8
.1
.1


Rating
(B)

(5)
8


8
5
5


(5)
5


10
5
5

Index
Number
(AxB)

4.5
.8
5.3

4.8
1.5
.5
6.8

4.5
.5
5.0

8.0
.5
.5
9.0
Hazard Potential
Factor
Weight
(C)

.9
.1


.6
.3
.1


.9
.1


.8
.1
.1


Rating
(D)

7
3


6
3
3


7
3


5
3
2

Index
Number
(CxD)

6.3
.3
6.6

3.6
.9
.3
4.8

6.3
.3-
6.6

4.0
.3
.2
4.5
Coumarone-Indene and Petroleum Resins
Indene
Styrene
Xylene

Polyurethanes
TDI
MDI
Xylene

.6
.3
.1


.7
.2
.1

(8)
8
5


8
8
5

4.8
2.4
.5
7.7

5.6
1.6
.5
7.7
.6
.3
.1


.7
.2
.1

5
3
3


10
10
3

3.0
.9
.3
4.2

7.0
2.0
.3
9.3
Foster D. Snell. Inc

-------
                                                         APPENDIX  4  (continued)
                                       Odor Potential
          Probable Emission
Factor
Weight
  (A)
Rating
  (B)
Index
Number
 (AxB)
   Hazard Potential
Factor          Index
Weight   Rating  Number
   (C)     (D)    (CxD)
    Cellulosics
          Acetic Acid
          Methylene Chloride
          Methanol
6
3
1
6
2
1
3.6
.6
.1
.6
.3
.1
5
1
2
3.0
.3
.2
                                                     4.3
                                           3.5
    Epoxy Resins
          Bisphenol A
          Epichlorohydrin
1
8
1
5
.1
4.0
4.1
.1
.8
6
6
.6
4.8
5.4
    Polyamides
          Caprolactam
          Acetic Acid
          Hexamethylenediamine
8
1
1
(1)
6
(D
.8
.6
.1
.8
.1
.1
(D
3
(D
.8
.3
.1
                                                     1.5
                                           1.2
Foster 0. Snell. Inc.

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                                 TECHNICAL REPORT DATA
                          (Plcoie read Inunctions on the reverse before Completing)
 1. REPORT NO.
  EPA-650/2-74-106
                                 3. RECIPIENT'S ACCESSION>NO.
 4. TITLE AND SUBTITLE
 System Analysis of Air Pollutant Emissions from the
   Chemical/Plastics Industry
                                 5. REPORT DATE
                                  October 1974
                                 6. PERFORMING ORGANIZATION CODE
 7. AUTHORIS)    '                   r~
 Herbert Terry and {Stephen Nagy
                                  I. PERFORMING ORGANIZATION REPORT NO.
 9. PERFORMING OR6ANIZATION NAME AND ADDRESS
 Foster D. Snell, Inc.
 Hanover Road
 Florham Park,  NJ  07932
                                 10. PROGRAM ELEMENT NO.
                                  1AB015; ROAP 21AXM-060
                                 11. CONTRACT/GRANT NO.
                                  68-02-1068
 12. SPONSORING AGENCY NAME ANp ADDRESS
 EPA, Office of Research and Development
 NERO-RTP, Control Systems Laboratory
 Research Triangle Park, NC  27711
                                 13. TYPE OF REPORT AND PERIOD COVERED
                                  Final; 3/73-^74
                                 14. SPONSORING AGENCY CODE
 IS. SUPPLEMENTARY NOTES
 16. ABSTRACT
           The report defines chemical/plastics industry producers, production vol-
 ume, forecasted growth rates, plant capacities and locations, and average population
 densities at each plant site. It despribes major processes in terms of equipment,
 reaction conditions, specific process chemicals,  and general air pollution controls.
 A decision model was used to relate the interactions of such factors as total popula-
 tion exposed, production volume,  growth trends,  emission, odor, and hazard poten-
 tial of the most likely pollutants. The report identifies polyurethanes, acrylics, and
 alkyds as the most likely candidates for in-depth study, estimating emissions fac-
 tors and discussing emission controls and their costs. It gives similar information
 for some high-volume plastic materials: polyethylene, polystyrene, polypropylene,
 nylon, and poly vinyl chloride. Most of the pollution control devices used in the
 industry are associated with large volume resin manufacture and function  primarily
 to recover product or heat values: in most instances, economics dictate against
 installing control devices solely for pollution control. The report gives  calculated
 costs for various controls.
 7.
                              KEY WORDS AND DOCUMENT ANALYSIS
                 DESCRIPTORS
                     b.lDENTIFIERS/OPEN ENDED TERMS
                         c. COSATI Field/Group
Air Pollution
 Plastics Industry
  hemical Plants
Systems Analysis
 Production Capacity
 Populations
Polyurethane Resins
CosJ: Estimates
Acrylic Resins
Alkyd Resins
Equipment
Odors
Air Pollution Control
Stationary Sources
Chemical/Plastics Ind-
  ustry
Process Chemicals
Resin Manufacture
Hazard Potential
13B,   HA
111
07A
13 H
05E
11J
 8. DISTRIBUTION STATEMENT

 Unlimited
                     19. SECURITY CLASS (ThisReport)
                     Unclassified
                         21. NO. OR PAGES
                             293
                     20. SECURITY CLASS (Thispage)
                     Unclassified
                                              22. PRICE
EPA Form 2220-1 (9-73)

-------