Economic Impact Analysis
For the Proposed Cyanide
Manufacturing NESHAP
Prepared by:
Eric L. Crump, P.E.
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Innovative Strategies and Economics Group
MD-15, Research Triangle Park, NC 27711
EPA-452/D-00-004
May 2000
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CONTENTS
1. OVERVIEW 1
2. INDUSTRY PROFILE 1
What are cyanide chemicals? 1
How is sodium cyanide (NaCN) made? 1
How is hydrogen cyanide (HCN) made? 1
What are the end uses for cyanide? 2
What companies/facilities make cyanide? 3
What are the production costs for cyanide manufacturing? 4
What are the pricing trends for sodium cyanide? 5
What are the pricing trends for hydrogen cyanide? 5
How much cyanide is imported to/exported from the United States? 5
Are there consumer substitutes for cyanide? 6
What is the anticipated growth for the cyanide industry over the next few years? 6
3. HAP EMISSIONS AND PROPOSED CONTROLS 7
What HAP are emitted from cyanide manufacturing facilities? 7
What are the sources of HAP emissions in cyanide manufacturing facilities? 7
What level of control does the proposed rule specify for affected facilities? 7
4. COSTS AND IMPACTS 8
What costs will this proposed regulation impose on the cyanide chemicals manufacturing source
category? 8
What is the anticipated impact of control costs on the industry? 12
Are any small businesses significantly impacted by this NESHAP? 13
REFERENCES 14
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LIST OF TABLES
Table 1 - Hydrogen Cyanide (HCN) Uses and Estimated Consumption 2
Table 2 - Sodium Cyanide (NaCN) Uses and Estimated Consumption 3
Table 3 - Cyanide Manufacturing Facilities and Estimated Production Capacity 4
Table 4 - MACT Floor for Cyanide Chemicals Manufacturing Facilities 8
Table 5 - Model Plant Characteristics for Cyanide Chemicals Manufacturing NESHAP 9
Table 6 - Annual Costs for Cyanide Chemicals Manufacturing NESHAP 10
Table 7 - Annual Costs for Cyanide Model Plants 11
Table 8 - Screening Analysis for Firms Affected by the Proposed Rule 12
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1. OVERVIEW
The EPA is proposing national emission standards for hazardous air pollutants (NESHAP) that will
affect major sources of hazardous air pollutant (HAP) emissions in covered under the cyanide
chemicals manufacturing source category. Cyanides manufacturing is classified under Standard
Industrial Classification (SIC) code 2819 and North American Industrial Classification System
(NAICS) code 325188.
This analysis provides a brief economic profile of the cyanide chemicals manufacturing industry, an
overview of the HAP emissions and proposed NESHAP, and a screening analysis of the impact the
proposed NESHAP will have on firms in the cyanide chemicals manufacturing source category.
2. INDUSTRY PROFILE
What are cyanide chemicals?
This standard focuses on the production of sodium cyanide (NaCN) and hydrogen cyanide (HCN).
NaCN is a white, cubic crystalline solid. Odorless when dry, it gives off the smell of bitter almonds
when damp. It is used in extracting gold and silver from ore, electroplating, case hardening of metals,
chelating agents production, hydrocyanic acid production, and dye and pigment manufacturing. It is
typically shipped off-site for use by other manufacturing industries.
HCN is a highly toxic, colorless liquid with the odor of bitter almonds. It is mostly used to make
adiponitrile (used to produce nylon 66), and acetone cyanohydrin (used to produe methyl
methacrylate), and other chemicals. Because it is highly toxic, it is usually manufactured on-site by
manufacturers of these chemicals (Brown).
How is sodium cyanide (NaCN) made?
NaCN is produced when hydrocyanic acid is neutralized with aqueous sodium hydroxide,
producing a slurry. The slurry is crystallized, and the NaCN solids are separated, dried, and prepared
for shipping (Brown).
How is hydrogen cyanide (HCN) made?
HCN is mostly made using the Andrussow process, where ammonia, air, and natural gas are
reacted over a platinum/rhodium catalyst at high heat (Brown). The Blausaure Methane Anlage is also
used; it differs from the Andrussow process in that air is not fed into the reactor (Johnson, July 1996).
HCN is also made as a byproduct of the Sohio process, used to make acrylonitrile. In this
process, propylene, anhydrous ammonia, and air are combined in a reactor to produce acrylonitrile,
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HCN and acetonitrile. The separate products are then distilled, separated, and purified (Johnson, July 1996).
What are the end uses for cyanide?
Tables 1 and 2 below provide a breakdown of the end uses of HCN and NaCN. Over 90% of
NaCN is used in extracting gold from ore. Small quantities are also used in electroplating, and chemical
synthesis (Chemical Market Reporter 6/28/99). HCN is mostly used as a raw material in the
production of fibers, plastics, polymers, resins, and coatings. Nearly 90% of HCN is used as a raw
material for adiponitrile (used in producing nylon 66 for fiber and plastic production), acetone
cyanohydrin production (to produce methyl methacrylate for acrylic plastics and resins, protective
coatings, plastic additives, and emulsion polymers), and NaCN production.
Table 1 - Hydrogen Cyanide (HCN) Uses and Estimated Consumption
Use Estimated consumption, Percent of total estimated
1998 (Million Ibs/yr) consumption
Adiponitrile production (used in making
nylon 66 for fiber and plastic production) 590 41
Acetone cyanohydrin production (for
methyl methacrylate, used to make acrylic
plastics and resins, protective coatings, 461 32
plastic additives, and emulsion polymers)
Sodium cyanide production 202 14
Other 187 13
Total 1,440 100
Source: Chemical Market Reporter, 11/23/98
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Table 2 - Sodium Cyanide (NaCN) Uses and Estimated
Use
Gold extraction
Electroplating, chemical, synthesis, and other
uses
Total
Estimated consumption
(Million Ibs/yr)
130
10
140
Consumption
Percent of total estimated
consumption
93
7
100
References: Johnson (June 1996)
What companies/facilities make cyanide?
The EPA has identified 16 domestic cyanide manufacturing facilities, owned and operated by 12
companies. Twelve of these facilities are located in the southern U.S.; eight are located in Texas. All
16 firms produce HCN; 5 of the 16 firms produce sodium cyanide as well. Table 3 lists the companies
and facilities that manufacture sodium cyanide and hydrogen cyanide, the production processes, and the
production capacity for each facility.
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Table 3 - Cyanide Manufacturing Facilities and Estimated Production Capacity
Company
BP Chemicals
Cyanco*
Cytec
Degussa
Dow Chemical
Du Pont
FMC Corp.
Monsanto
Novartis Crop
Protection, Inc.
Rhone-Poulenc
Rohm & Haas
Sterling Chemicals
Production Totals
Location
Lima, OH
Port Lavaca, TX
Winnemucca, NV
Westwego, LA
Theodore, AL
Freeport, TX
Beaumont, TX
Memphis, TN
Orange, TX
Victoria, TX
Green River, WY
Alvin, TX
St. Gabriel, LA
Institute, WV
Deer Park, TX
Texas City, TX
Employment
96,650
25,100*
5,000
25,000
39,000
97,000
17,000
32,000
100,000
65,0000
20,000
1,180
HCN Production
Process
Sohio
Sohio
Andrussow
Sohio
BMA
Andrussow
Sohio
Andrussow
Andrussow
Andrussow
Andrussow
Sohio
Andrussow
Andrussow
Andrussow
Sohio
HCN
Production
Capacity
(tons/year)
40
72
24
65-80
53
20
55-90
200
320
400
33
55-100
100
15
200
75
1727-1823
NaCN
Production
Capacity
(tons/year)
43
60
200
60
80
442
* - joint venture of Mining Services International and Degussa. Employment figures represent combined
employment of both parent corporations.
Source: Brown
What are the production costs for cyanide manufacturing?
Scant information on HCN and NCN production costs is available. The U.S. Census Bureau's
1997 Economic Census includes cyanide manufacturing operations with other chemical production
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facilities in NAICS 325188 under the category "All Other Basic Inorganic Chemical Manufacturing."
The Census Bureau's "Annual Report on Inorganic Chemicals - 1997" appears to subclassify HCN
under "inorganic acids, except nitric, phosphoric and sulfuric" (product code 2819451), and provides
production quantities and values for HCN, but no specific production costs for HCN. No apparent
breakout of NCN costs is provided.
What are the pricing trends for sodium cyanide?
Information on pricing for sodium cyanide over the past decade is limited, and can only be pieced
together from several sources. The information suggests a wide fluctuation in prices over the last
decade. In the mid-1989, NaCN prices rose to the 85-90 cent per pound range, but fell to 80-85 cent
per pound range in 1990. Prices in 1992 reportedly ranged from 79 to 85 cents per pound.
(Chemical Marketing Reporter, 12/7/92). This price trend continued through the first part of 1993, but
fell to the low 50s in the latter part of that year. In early 1994, prices were reported to be 60 cents per
pound. (Chemical Marketing Reporter, 1/10/94). DuPont estimated that 450,000 metric tons of
NaCN were consumed worldwide in 1994. If, as SRI suggests, this reflects a global value of $675
million using late 1995 market prices, this would mean a rough mid-1990's price of 68 cents per pound
of NaCN. DeGussa was reported in August 1996 to have raised the base price for NaCN to
$1650/tonne CFR main port, or around 74 cents per pound. (European Chemical News).
While no current pricing information on NaCN is available, gold prices have been falling since the
mid-1990s. Demand for NaCN was reportedly 3-4% lower in 1999 than in 1996. Despite price
decreases (of unreported magnitude), demand is expected to stay flat in the near future. (Chemical
Market Reporter, 2/15/99)
What are the pricing trends for hydrogen cyanide?
Prices for liquid HCN in tanks appear to have held fairly steady in the years 1990-1996 at around
60 cents per pound. Since very little HCN produced is sold, published prices may not fully represent
transaction values. (Johnson, July 1996; Chemical Marketing Reporter, 1/10/94). List prices for HCN
have not been published since the mid-1990s. However, average sale values from Bureau of the
Census reports indicate prices ranging from 25 to 31 cents per pound over the years 1990-1995.
Projected average HCN sales values for 1996 and 1998 were 32 and 33 cents per pound, respectively
(Chemical Products Synopsis, November 1996).
How much cyanide is imported to/exported from the United States?
HCN is not believed to be imported to, or exported from the United States, since most of the
product is consumed at its production site.
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According to the U.S. Census Bureau, 7.1 million pounds of NaCN was imported into the United
States in 1995, an increase from 5.7 million pounds the previous year. NaCN imports peaked in 1988
at 63.4 million pounds, and declined steadily until 1995. Most imports have come from Germany and
the United Kingdom. No more recent data is available.
In 1995, the United States exported 179 million pounds of NaCN to other countries. Exports fell
from 143 million pounds in 1990 to 104 million pounds in 1991, but steadily increased over the next
four years. Canada was the leading recipient of U.S. exports in 1995 with nearly 40 million tons,
followed by Bolivia (23 million tons) and Ghana (22.5 million tons) (Johnson, June 1996).
Are there consumer substitutes for cyanide?
HCN is primarily used to make intermediates for other products - adiponitrile and acetone
cyanohydrin (which in itself is an intermediate for methyl methacrylate). While adiponitrile is the
dominant intermediate for nylon-6,6, it can also be made from adipic acid, butadiene, or acrylonitrile
(Chemical Week Buyers Guide). As for methyl methacrylate, methods exist to produce it using C-3
and C-4 hydrocarbons instead of acetpme cyanohydrine (Chemical Market Reporter, 11/23/98).
Thiosulfate is considered a promising substitute for NaCN in removing gold from certain ores,
because it poses less environmental risk, and could be comparable in cost to NaCN (American Metal
Market). While thiosulfate has been shown to work on low grade carbanaceous ores, more research is
needed to determine how it would be used on a large mining scale. (Chemical Marketing Reporter,
12/5/94).
What is the anticipated growth for the cyanide industry over the next few years?
For NaCN, demand is reportedly 3 to 4% lower than in 1996, and is expected to stay flat for the
next several years. The price of gold has fallen over the past few years, resulting in reduced demand
for NaCN. At least one major joint venture to increase plant capacity has been put on hold, as a result
(Chemical Market Reporter, 2/15/99).
For HCN, overall demand is expected to grow at around 2% per year through the year 2002. This
growth mirrors the projected growth for adiponitrile (a result of increasing demand for nylon-6,6),
plastics, and resins over the next decade (Chemical Market Reporter, 11/23/98).
Based on 1997 U.S. production amounts (3,650 million Ibs) and reported capacity (approximately
4,000 million Ibs), it appears reasonable that the projected growth over the next few years could be
absorbed by existing facilities without need for expansion or new facilities.
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3. HAP EMISSIONS AND PROPOSED CONTROLS
What HAP are emitted from cyanide manufacturing facilities?
In the production of HCN, the main HAP of concern is the product itself - HCN. In addition,
some facilities report emissions of acetonitrile and acrylonitrile. Similarly, for NaCN production,
NaCN and HCN are the major HAP emitted (Brown).
What are the sources of HAP emissions in cyanide manufacturing facilities?
Data obtained by the EPA, indicate that process vents account for the majority of HAP emissions
from cyanide manufacturing. Other sources of emissions include storage vessels and transfer
operations. In addition, equipment leaks and wastewater (and, in the case of NaCN, solids handling
operations) are sources of fugitive emissions (Brown).
What level of control does the proposed rule specify for affected facilities?
The proposed MACT floor levels of control for identified HAP emission points at cyanide
manufacturing facilities are shown in Table 4. For the most part, MACT floor levels of control for
existing and new sources are identical, with the exception of some sodium cyanide process vents at the
dry end of the process.
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Table 4 - MACT Floor for Cyanide Chemicals Manufacturing Facilities
Emission Source Type
Storage Vessels
Equipment Leaks
Transfer Operations
Wastewater
Process Vents
Andrussow or
BMA
Sodium Cyanide
-Wet End
Sodium Cyanide
- Dry End
Sohio
Existing Source MACT Floor
98% emission reduction (by weight)
through use of flare or other control
device
Leak dectection and repair
complying with 40 CFR part 60,
subpart VV
98% emission reduction (by weight)
through use of flare or other control
device
Biotreatment
Overall emission reduction of 99.9%
(by weight) during normal
operations
Use of flare during startup,
shutdown, and malfunction
Overall emission reduction of 98%
(by weight)
Overall emission reduction of 91%
(by weight)
Overall emission reduction of 98%
(by weight)
New Source MACT Floor
98% emission reduction (by weight)
through use of flare or other control
device
Leak dectection and repair
complying with 40 CFR part 60,
subpart VV
98% emission reduction (by weight)
through use of flare or other control
device
Biotreatment
Overall emission reduction of 99.9%
(by weight) during normal
operations
Use of flare during startup,
shutdown, and malfunction
Overall emission reduction of 98%
(by weight)
Overall emission reduction of 98.9%
(by weight)
Overall emission reduction of 98%
(by weight)
4. COSTS AND IMPACTS
What costs will this proposed regulation impose on the cyanide chemicals manufacturing
source category?
To estimate impacts and costs of the proposed NESHAP, EPA developed eight model plants to
represent the cyanide chemicals manufacturing industry. Table 5 summarizes the control technologies
required by each model plant to meet the proposed MACT floor. Based on the criteria established in
the proposed NESHAP, EPA believes that 14 facilities will need to add control equipment in order to
comply with the proposed rule. The EPA estimates the total annual cost for these facilities combined
to be approximately $2.4 million per year. Table 6 below provides a breakdown of this total annual
cost, including capital recovery, labor, maintenance, energy, and administrative costs. Table 7 below
provides a breakdown of the estimated annual costs for each model plant.
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Table 5 - Model Plant Characteristics for Cyanide Chemicals Manufacturing NESHAP
Model
Plant
1
2
3
4
5
6
7
8
Manufacturing
Process
Andrussow/BMA
Andrussow/BMA
Andrussow/BMA
Andrussow/BMA
NaCN
NaCN
Sohio
Sohio
Controls Required to Meet the MACT Floor by Emission Source Type
Process
Vents
None
Thermal
Incinerator
None
None
None
Flare
None
Flare
Storage
Vessels
None
Thermal
Incinerator
None
None
None
None
None
None
Equipment Leaks
None
None
Modify existing
LDAR program to
comply with MACT
Implement LDAR
program to comply
with MACT
None
None
None
Modify existing
LDAR program
Transfer
Operations
None
None
None
None
None
None
None
None
Wastewater
None
None
None
None
None
None
None
None
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Table
6 - Annual Costs for Cyanide Chemicals
NESHAP
Cost component
Fixed Control Costs Annualized Capital
Overhead
Property taxes
Insurance
Administrative fees/charges
Variable Control Raw materials (process)
Costs
Raw materials (maintenance)
Energy /utilities
Labor
Replacement parts
Monitoring/Recordkeeping Costs
Total Annual Costs
Manufacturing
Amount ($)
153,528
134,735
13,612
13,612
27,225
8
100,524
844,049
261,778
20,008
813,140
2,382,219
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Table 7 - Annual Costs for Cyanide Model Plants
Cost Component
Fixed Control
Costs
Variable Control
Costs
Annualized
Capital
Overhead
Allocation
Property Tax
Insurance
Administrative
Fees
Raw Materials
(Process)
Raw Materials
(Maintenance)
Energy/Utilities
Labor
Replacement
Parts
Monitoring/Recordkeeping
Total
Model Plant Costs ($)
1
Andrussow/
BMA
(2 facilities)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
56,414
56,414
2
Andrussow/
BMA
(1 facility)
12,024
9,366
845
845
1,689
n/a
7,805
30,792
7,805
n/a
58,462
129,633
3
Andrussow/
BMA
(4 facilities)
18,077
13,559
1,666
1,666
3,332
n/a
9,438
n/a
33,897
3,240
59,076
143,951
4
Andrussow/
BMA
(2 facilities)
19,718
13,559
1,666
1,666
3,332
n/a
9,438
n/a
33,897
3,240
59,076
145,592
5*
NaCN
(2 facilities)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
6*
NaCN
(1 facility)
5,368
11,303
489
489
978
8
9,419
761
9,419
n/a
n/a
38,234
7
Sohio
(3 facilities)
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
n/a
56,414
56,414
8
Sohio
(2 facilities)
12,196
16,356
1,141
1,141
2,283
n/a
13,336
406,248
20,586
324
59,076
532,689
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*Only 14 facilities are considered major sources, but three of them are HCN facilities colocated with NCN facilities - hence the total
number of 17 plants cited above. Model plant 5 is colocated with model plant 8; its MRR costs are included under model plant 8.
Model plant 6 is colocated with model plant 2; its MRR costs are included under model plant 2.
What is the anticipated impact of control costs on the industry?
To assess the impact of the impact the proposed NESHAP would have on the industry, EPA
performed a "sales test" as a initial impacts screening for affected firms in the industry. Under this
analysis, EPA looked at the annualized cost of compliance with the rule as a percentage of annual sales.
Using this approach, if a firm has a cost-to-sales ratio of 1% or less, it is presumed that the regulation
has no significant economic impact, it may experience some degree of significant impact.
The EPA was able to identify sales information for all of the firms subject to the proposed rule, and
assigned a model plant to each facility, based on the type of process used. The results of this screening
are shown in table 8 below. Because Cyanco and Monsanto are not considered major sources of
HAP emissions, they would not be affected by the proposed rule, and were not included in this
screening analysis.
Table 8 - Screening Analysis for Firms Affected by the Proposed Rule
Company (& number
of facilities affected
by rule, if more than
one)
BP Chemicals (2
facilities)
Cytec
Degussa
Dow Chemical
Du Pont (4 facilities)
FMC Corp.
Novartis
Rhone-Poulenc
Rohm & Haas
Sterling Chemicals
Production
Process
Sohio
Sohio
BMA and NaCN
Andrussow
Sohio (1 facility),
Andrussow (2
facilities),
Andrussow and
NaCN (1 facility)
Andrussow and
NaCN
Andrussow
Andrussow
Andrussow
Sohio and NaCN
Model Plants
Assigned to
Company
7,7
7
4,5
1,3,4,6,8
3
3
3
2
5,8
Annualized
cost of control,
including MTRR
($000)
$113
56
146
56
881
144
144
144
130
533
Parent
Company Total
Sales for 1998
($000)*
$83,732,000
1,444,500
14,856,600
18,441,000
24,767,000
1,909,100
23,102,000
13,200,000
6,448,000
822,590
Cost-
to-Sales
Ratio
(%)
xO.OOl
xO.OOl
<0.001
<0.001
xO.OOl
xO.OOl
<0.001
<0.001
xO.OOl
xO.OOl
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* - All sales data compiled from company annual reports, except for Sterling Chemical sales figures, which were
found in its 10-K report to the SEC.
As shown in the preceeding table, no firm has a cost-to-sales ratio that exceeds 1%. The firm with
the highest cost-to-sales ratio is Sterling Chemical, with a ratio of over six-hundredths of a percent.
Based on this screening analysis, EPA therefore concludes that the proposed cyanide chemicals
manufacturing NESHAP will cause no significant impact on any of the sources affected by the rule.
Are any small businesses significantly impacted by this NESHAP?
No. The Regulatory Flexibility Act (RFA), as amended by the Small Business Regulatory
Enforcement Fairness Act (SBREFA) of 1996, requires Federal regulatory agencies to determine
whether a proposed or final regulation will have a significant impact on a substantial number of small
entities. For SIC 2819, a small entity is defined by the Small Business Administration as a firm with
500 or fewer employees (a small entity cut-off for NAICS 325188 will not be available before October
1, 2000). This cut-off is made based on parent company employment. At this time, no parent
company included in the cyanide chemical manufacturing source category has been identified as having
500 or fewer employees. Therefore, the EPA does not believe that the proposed carbon black
NESFLAP will have a significant impact on a substantial number of small entities.
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5. REFERENCES
American Metal Market. Thiosulfate May Replace Cyanide in Leaching. Vol. 107, No. 40,
March 2, 1999.
BP-Amoco. 1998 annual report, downloaded from the corporate web site December 14, 1999.
Brown, Heather P., and McGeough, U. G. of EC/R, Incorporated. Memorandum (draft) to
Keith Barnett, EPA/OAQPS/ESD/OCG, September 23, 1999. Cyanide Chemicals
Manufacturing Source Category Description.
Chemical Market Reporter. Chemical Profile: Hydrogen Cyanide. November 23, 1998.
Chemical Market Reporter. Sodium Cyanide Market Stabilizes Despite a Recent Drop in Pricing.
Vol. 255, No. 7, February 15, 1999.
Chemical Market Reporter. Weak Gold Market Pressures the Sodium Cyanide Industry. Volume
255, No. 26, June 28, 1999.
Chemical Marketing Reporter. Sodium Cyanide Gains Needed Margin Boost. Vol. 243, No. 23,
December 5, 1994.
Chemical Marketing Reporter. HCN Targets Profitable Uses Despite Rising NaCN Prices.
January 10, 1994.
Chemical Marketing Reporter. Cyanide Makers Attempt to Improve Weak Prices.
December 7, 1992.
Chemical Products Synopsis: Hydrogen Cyanide. Mannsville Chemical Products Corporation,
November 1996.
Chemical Week Buyers Guide and Industry Almanac. Adipic Acid/Adiponitrile. November 1999.
Cytec. Five-Year Summary, 1994-1998, downloaded from the corporate web site
December 16, 1999.
DeGussa-Huls Group. Annual report 1998/1999, downloaded from the corporate web site
March 13, 2000. Sales data listed for the year designated as "1997/1998" was used. Euros
converted to U.S. dollars using the 9/30/98 exchange rate of 1.17871 dollars per euro.
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Dow Chemical Company. 1998 annual report 1998, downloaded from the corporate web site
March 13, 2000.
DuPont. 1998 annual report, downloaded from the corporate web site December 14, 1999.
European Chemical News. Mining Chemicals: Gold Price Threat to Sodium Cyandide. Volume
67, No. 1765, May 19, 1997.
FMC Corporation. 1998 annual report, downloaded from the corporate web site
March 13, 2000.
Hoover's Online. 1998 sales information on Mining Services International Corporation
downloaded from web site January 12, 2000.
Johnson, William K., and A. Leder. CEH Data Summary: Sodium Cyanide. Chemical Economics
Handbook, SRI International. June 1996.
Johnson, William K., with A. Leder and S. Yoshikawa. CEH Product Review: Hydrogen
Cyanide. Chemical Economics Handbook, SRI International. July 1996.
Novartis. Five Year Summary of Financial Date 1994-1998, downloaded from the corporate web
site December 14, 1999. Swiss francs converted to U.S. dollars using the 12/31/98 exchange
rate of 0.728717 dollars per franc.
Rohm and Haas Company. 1998 Annual Report, downloaded from the corporate web site
December 14, 1999.
Rhone-Poulenc. 1998 sales figures downloaded from the corporate web site December 14, 1999.
Sterling Chemicals. 10-K report, submitted December 17, 1998 to the Securities Exchange
Commission. Downloaded from the EDGAR website January 12, 2000.
U.S. Census Bureau. All Other Basic Inorganic Chemical Manufacturing. 1997 Economic
Census, Manufacturing Industry Series (EC97M-3295), October 1999.
U.S. Census Bureau. Annual Report on Inorganic Chemicals - 1997. Current Industrial Reports
Series (MA28A(97)), September 29, 1998.
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