United States
Environmental Protection
Office of Pollution Prevention
Washington, DC 20460
August 1990
TRI Rele

Recovery; CMA's
'Responsible ^
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Editor's Corner

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A. Henry Schilling, Director,
Office of Pollution Prevention
More and more, companies are realizing the
need to develop and implement pollution pre-
vention initiatives. One incentive is the bottom
line. Not only can pollution prevention measures
save many companies money through more ef-
ficient useof resources, butenvironmentallysound
practices can position companies to capture a
larger market share in an environmentally-con-
scious marketplace.
Beyond this incentive is a longer-range vision
of corporate citizenship. Pollution prevention
represents a challenge for industry to take up the
mantle of leadership and innovation. Many in-
dustry executives recognize this challenge and
have begun to act on it — sending the message
that industry can be part of the solution, not just
part of the problem.
As this message spreads, a new and special
environmental leadership role is emerging for
trade associations. Historically, the agendas of
many industrial trade associations have been
driven by the needs and concerns of their least
environmentally aware members. Some associa-
tions have seen their mission as one of protecting
their members from government intervention
while insulating them from the repercussions of
continued on page 4
Largest TRI Releasers Report on
Waste Reduction Plans
EPA's recent publication of the 1988 Toxic
Release Inventory (TRI) data led us to wonder
how facilities at the top of the list were reacting.
Pollution Prevention News contacted the 10 fa-
cilities reported to have the largest on-site releases
of TRI chemicals excluding off-site transfers to
other facilities. (Note that including off-site trans-
fers would produce a somewhat different list of
top facilities.) The firms contacted are listed on
page 2. We asked for their reactions and whether
any changes were planned or underway at their
The responses indicate quite clearly that TRI
has made companies think seriously about their
releases. In some cases, TRI appears to have
contributed to substantial changes in plant opera-
tions. Managers at several facilities reported on
specific goals or actions to reduce the generation
of toxic wastes, or to recycle and reuse wastes in
commercial applications.
In other cases, however, responses were more
vague. Some companies appear to be focused on
pollution control instead of pollution prevent ion, on
release reduction (that may merely shift wastes
from one medium to another) rather than on waste
reduction. One lasting message is the continuing
need for EPA to help channel industry's efforts
into appropriate long-term responses that em-
phasize genuine preventive measures.
Below we summarize the responses received
from the facilities. (Note that EPA is not endors-
ing any particular company's approach.)
Reducing Air Pollution
MagCorp, the new parent company of Amax
Magnesium, reported that a recently installed
chlorine conversion burner would reduce the
facility's air em issions by about 40 million pounds,
to be reflected in 1990 and 1991 figures. With the
burner, one of the facilities' two major chlorine
emission sources will be eliminated, a corporate
spokesman said.
Inland Steel Co. called attention to its pro-
cantinued on page 2
Printed on Recycled Paper

Pollution Prevention News - 2
1 K| Ke
August 1990
grams to reduce volatile organic compounds
by 90 percent at its Indiana Harbor Works
Plant 2 Coke Plant. VOC's, including air toxics
such as benzene, are considered primary con-
tributors to the summer ozone pollution
problem in the East Chicago, Indiana area.
"Engineering and equipment procurement
are now in progress on a major process modi-
fication to convert the coke plant's by-products
final cooler from an open to a closed system,"
the company stated. "Installationofadditional
emission controls and new process technology
at the Indiana Harbor Works, the nation's
largest steel plant (in terms of facilities and
employees), will substantially help to further
reduce air pollution in Northwest Indiana."
The modified facility is scheduled to be in
operation in 1990, and another program to
eliminate vapor emissions is due to be com-
pleted by the end of 1991.
Moving Away from Deepwells
Six facilities made the TRI "top ten" list
because they dispose of large quantities of
toxic wastes by means of underground injec-
tion. Wastes are placed in underground for-
mations through injection wells several
thousand feet deep.
Last year, Shell Oil Co. closed the injection
wells it had been using to dispose of hydro-
chloric acid (HC1) and began using a new
process to convert HQ to calcium chloride, a
marketable product. Largely as a result, the
Norco plant has reduced its SARA Title III
emissions to air, land and water by more than
97 percent since 1987.
"Further reductions will be achieved upon
completion of a $55 million biological treat-
ment facility... expected to be in operation by
the fall," according to Shell.
Several companies characterized under-
ground injection as environmentally safe.
Nonetheless they seem to be moving away
from it.
A Vulcan Chemicals spokesman said: "We
hope to eliminate the practice of disposing of
hazardous waste in our deepwells within the
next 10 years, and we expect a steady reduc-
tion until then. In 1990 to date, we are show-
ing approximately a 30 percent reduction in
HC1 wastes from 1988 because we began us-
ing HQ in the manufacture of methyl chlor-
ide. We are exploring the possibility of using
HQ to make other useful products."
Du Pont's Beaumont Works manager
noted that his company also "recognizes the
"Top 10" On-Site Releasers
1988 Releases
(Millions of Pounds)
American Cyan am id
Co., Westwego, LA
Shell CHI Co.,	158.6
Norco, LA
Amax Magnesium	109.7
Rowlegy Plant,
Tooele, UT
DuPont Beaumont	109.7
Works, Beaumont, TX
Monsanto Co.,	103.3
Alvin, TX
Vulcan Chemicals,	92
Wichita, KS
BP Chemicals Green	78.2
Lake, Port Lavaca, TX
Agrico Chemical Co.,	63.3
Uncle Sam, LA
Agrico Chemical Co.,	61.7
Donaldsonville, LA
Inland Steel Co.,	59.8
East Chicago, DM
Major Chemicals
Sulfuric acid,
ammonium sulfate,
Hydrochloric acid
Chlorine, hydrochloric
Ammonium sulfate
Ammonium sulfate
Hydrochloric acid,
sulfuric acid
Ammonium sulfate,
acrylic acid
Phosphoric acid,
sulfuric acid
Phosphoric acid,
Manganese com-
pounds, hydrochloric
acid, zinc compounds
Type of
injection (99%)
injection (99%)
Air (100%)
injection (99%)
injection (99%)
injection (99%)
injection (99%)
discharge (99%)
discharge (77%)
Air (23%)
Land (84%)
public concern about deepwell injection and,
for that reason, has set a goal of elimi nating all
toxic discharges to the ground, or verifying
that they have been rendered nonhazardous,
by the year 2000."
Four major acrylonitrile producers on the
list — BP Chemicals Green Lake, Monsanto
Co., Du Pont Beaumont Works, and Ameri-
can Cyanamid — pointed out that ammo-
nium sulfate, the primary chemical released
from their plants, is commonly used as a
fertilizer and is under consideration by EPA
for delisting.
Spokesmen for both American Cyanamid
and BP Chemicals referred to their companies'
continuing programs to reduce the quantities
of waste generated. The BP Chemicals plant
manager noted: "Our Research and Devel-
opment program focuses on developing
cleaner, more efficient processes for making
our chemicals such as new, advanced catalysts
which have increased yields and decreased
waste products."
Monsanto mentioned its corporate com-
mitment to reduce air emissions by 90 percent
by the end of1992. The company's spokesman
said that Monsanto Chemical Company, an
operating unit, has an additional commit-
ment to reduce its most hazardous waste by
70 percent by the end of 1995.
Finally, two Agrico Chemical Co. facilities
made the TRI top ten list because of surface
water discharges, principally of phosphates
and sulfates. Agrico's spokesman noted that
these wastes are not carcinogens or mutagens,
and "they are not toxic to humans in concen-
trations normally encountered in the envi-
ronment as a result of Agrico's discharges."
"Agrico is committed to an ongoing pro-
gram to reduce all waste . . . including a
program to reduce the amount of gypsum (a
by-product of phosphoric acid manufac-
turing) and more reuse of process and other

3 - Pollution Prevention News
Investment Recovery Cleans
Corporate Attics
"Where's my best market for a Ball Mill?"
"Who purchases spent glycol?"
The companies asking these questions
are involved in a new recycling/reuse pro-
cess called investment recovery, aimed at
both saving money and helping the environ-
ment. The idea, perfectly simple on the face
of it, is for companies going out of business,
moving, or discarding assets for any reason,
to sell or exchange these assets, thereby pro-
longing their useful life while still recovering
some of their investment.
The Investment Recovery Association
(IRA) is the central resource for the indus-
trial recycling of equipment, products, by-
products, and waste. Comprised of approxi-
mately 200 companies, since 1979 this non-
profit association has served as a conduit of
information and networking.
In this relatively new field of industrial
recycling, member companies rely on other
members to share recycling methods and
remedies based on their own experiences.
The IRA publishes a directory of its member
companies and their disposal techniques. In
addition, through seminars and other pro-
motional programs, the association interests
other companies in starting investment re-
covery programs and in participating effec-
tively in the investment recovery network.
Turning Waste Into Dollars
The financial benefits of implementing an
investment recovery program can be sub-
stantial. William Yerkey, President of the
Investment Recovery Association, estimates
that his recovery department at Union Car-
bide brings in a million dollars for every
thirty thousand it spends. According to the
IRA, among 12 large companies with annual
sales of $4-7 billion, the average 1988 return
for sales and avoided costs from investment
recovery was $7.4 million. Among 14 small
companies with less than 1 billion in sales,
the average return was $1.2 million. Bud
Shaver, investment recovery officer for 3M,
notes that investment recovery at his com-
pany in 1988 "generated $34.5 million in
sales, up from $10 million five years ago."
A wide range of materials can be recov-
ered. Myrene Lang, an investment recovery
manager with Hitachi Data Systems, said:
"We recover everything from integrated
circuits to precious metals to shelving,
forklifts, pallets, room dividers, heavy
Large compressors await removal and refurbishing
for reuse on a new capital project.
equipment, mainframe computers, and so
forth." Machinery, minerals, fibers, paper,
pipe, and chemicals are increasingly being
exchanged and resold. The result is less
waste, conservation of valuable resources,
and reduced burden on landfills.
Investment recovery is not restricted to
IRA members. Any interested company can
initiate its own recovery program, setting up
an in-house investment recovery department.
Some large companies, such as Phillips and
3M, have warehouses for their used assets
which are offered for public auction twice
yearly. Other companies publish and dis-
tribute catalogs of items available for ex-
change. Union Carbide, for example, mails
its catalogs to 10,000 companies.
In large companies, very often the most
efficient solution is an exchange of material
between divisions. Duplication in buying is
a common problem in any large organization.
"Typically a corporation's left hand could be
shopping for a brand new packaging machine
or raw material, while its right hand is junking
... a perfectly good asset at another plant,"
notes Paul Wengert of Phillips Petroleum
which has established an investment recov-
ery department. "Now ... before any divi-
sion buys new, they check our in-house
surplus catalog."
Is this the waveof the future? Says Shaver,
"companies that do not have professional,
successful recovery organizations cannot
remain competitive because they're throw-
ing away money."
For more information on the Investment
Recovery Association, contact A.P. Wherry
and Associates, 30200 Detroit Road, Cleve-
land, Ohio 44145-1967. Tel: 216-899-0010.
CMA Firms
"Responsible Care'
This spring, the Chemical Manufacturers
Association (CMA) publicly announced an
initiative that its members adopted in Sep-
tember 1988. Called "Responsible Care," the
initiative signifies CMA members' public
commitment to improve performance in
health, safety, and environmental protection.
The CMA's 185 members represent more
than 90 percent of basic industrial chemical
production in the United States.
By participating in Responsible Care,
companies agree to follow ten guiding prin-
ciples intended to foster responsible man-
agement of chemicals. The principles in-
clude commitments to respond to commu-
nity concerns; to develop chemicals that can
be safely handled by producers, transport-
ers, and users; and to support research into
environmental effects.
Results of an opinion poll, conducted by
CM A in September 1989, reaffirm industry's
need to perform better. The public ranked
the chemical industry next to last in
favorability among ten major industries,
just above the tobacco industry. According
to CMA, the membership "concluded that
the chemical industry doesn't just have a
public relations problem; it has a perfor-
mance problem."
Waste Reduction Code
As part of the new program, CMA has
developed a Waste and Release Reduction
Code of Management Practices "to achieve
ongoing reductions in the amount of all
contaminants and pollutants released to the
air, water, and land from member company
The code requires CMA members to set
up waste and release reduction programs
with the commitment of senior manage-
"We have a stewardship responsibility
for chemicals throughout their lifecycle,
from their development to their disposal,"
former CMA Board Chairman Robert D.
Kennedy said in announcing the program.
He said that all CMA member companies
are required to adhere to the principles of
Responsible Care, and are asked to submit
written evaluations of their performance in
adhering to each code. For more informa-
tion contact CMA at (202) 887-1100.

Pollution Prevention News - 4
' i ¦ ¦ ¦ ' . :: ' ^ '
Pollution Prevention Through
Facilities Planning
National Roundtable for State
Waste Reduction Programs
Sept. 6-7
Minneapolis, MN
A1 Innes
Annual Regional Solid Waste
Governmental Refuse Collection
& Disposal Assn.
Oct. 2-4/Virginia Beach, VA
Nov. 6-8/Orlando, FL
Brad Roberge
Haztech International '90
Institute for International
Oct. 2-4
Pittsburgh, PA
Neal Schwartz
Waste Minimization Seminar
Du Pont Company
Oct. 9-10
San Antonio, TX
Seminar Group
Hazwaste Expo Chicago '90
National Association of
Hazardous Waste Generators
Oct. 15-18
Rosemont, IL
Robert McCarty
7th Annual New Jersey
Environmental Exposition
Environmental Expo Advisory
Oct. 15-17
Edison, N]
Linda Siecke
Hazardous Waste Pollution
Prevention Strategies
Hazardous Waste Treatment
Oct. 25-26
Washington, DC
Jacqueline Scott
Enviro Expo
Anchor Resources, Inc.
Oct. 30-31
Beaumont, TX
Jimmie Douglas
Investment Recovery
Investment Recovery
Oct. 30-Nov. 1
Williamsburg, VA
Jeff Wherry

environmentally questionable practices.
These roles and responsibilities are
changing. Trade associations need to move
from a reactive stance to a proactive stance,
from protecting their members to leading
them, from thwarting change to encouraging
it. For example, the Azo-dye manufacturers
are developing an industry-wide pollution
prevention initiative. The Responsible Care
program of the Chemical Manufacturers As-
sociation (described inside) is another example
and we are hopeful that the program will
induce real improvements in its member
companies as it is implemented. We encour-
age other trade associations to "take the ball
and run with it," leading the way in words
and actions towards a healthier environment
and sustainable economic growth.
United States Environmental
Protection Agency (PM-219)
Washington, DC 20460
Official Business
Penalty for Private Use $300