c/EPA
United States
Environmental Protection
Agency
Chemical Manufacturing Industry Practices
and Environmental Characterization
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Table of Contents
Index of Tables and Figures v
1. Introduction 1
1.1 Wastes 3
1.2 Sectors and their Subsectors 6
2. 325 - Chemical Manufacturing 7
2.1 3251 - Basic Chemical Manufacturing 8
2.1.1 325110 - Petrochemical Manufacturing 8
2.1.2 325120 - Industrial Gas Manufacturing 9
2.1.3 325130 - Synthetic Dye and Pigment Manufacturing 10
2.1.4 325180 - Other Basic Inorganic Chemical Manufacturing 10
2.1.5 325193 - Ethyl Alcohol Manufacturing 11
2.1.6 325194 - Cyclic Crude, Intermediate, and Gum and Wood Chemical Manufacturing 11
2.1.7 325199 - All Other Basic Organic Chemical Manufacturing 12
2.2 3252 - Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments Manufacturing 13
2.2.1 325211 - Plastics Material and Resin Manufacturing 14
2.2.2 325212 - Synthetic Rubber Manufacturing 15
2.2.3 325220 - Artificial and Synthetic Fibers and Filaments Manufacturing 17
2.3 3253 - Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing 18
2.3.1 325311 - Nitrogenous Fertilizer Manufacturing 21
2.3.2 325312 - Phosphatic Fertilizer Manufacturing 21
2.3.3 325314 - Fertilizer (Mixing Only) Manufacturing 21
2.3.4 325320 - Pesticide and Other Agricultural Chemical Manufacturing 22
2.4 3254 - Pharmaceutical and Medicine Manufacturing 23
2.4.1 325411 - Medicinal and Botanical Manufacturing 27
2.4.2 325412 - Pharmaceutical Preparation Manufacturing 28
2.4.3 325413 - In-Vitro Diagnostic Substance Manufacturing 28
2.4.5 325414 - Biological Product (except Diagnostic) Manufacturing 28
2.5 3255 - Paint, Coating, and Adhesive Manufacturing 28
2.5.1 325510 - Paint and Coating Manufacturing 29
2.5.2 325520 - Adhesive Manufacturing 30
2.6 3256 - Soap, Cleaning Compound, and Toilet Preparation Manufacturing 31
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2.6.1 325611 - Soap and Other Detergent Manufacturing 31
2.6.2 325612 - Polish and Other Sanitation Good Manufacturing 32
2.6.3 325613 - Surface Active Agent Manufacturing 32
2.6.4 325620 - Toilet Preparation Manufacturing 33
2.7 3259 - Other Chemical Product and Preparation Manufacturing 33
2.7.1 325910 - Printing Ink Manufacturing 34
2.7.2 325920 - Explosives Manufacturing 35
2.7.3 325991 - Custom Compounding of Purchased Resins 36
2.7.4 325992 - Photographic Film, Paper, Plate, and Chemical Manufacturing 36
2.7.5 325998 - All Other Miscellaneous Chemical Product and Preparation Manufacturing 36
3. Chemical Manufacturing Accidents 38
3.1 AB Specialty Silicones 39
3.2 KMCO Crosby 39
3.3 Kuraray America 39
3.4 Arkema 39
3.5 MGPI Processing 39
3.6 Airgas 40
3.7 DuPont LaPorte 40
3.8 William Olefins 40
3.9 US Ink 41
3.10 Carbide Industries 41
3.11 DuPont Buffalo 41
3.12 DuPont Belle 41
3.13 Goodyear Tire and Rubber 42
3.14 Bayer CropScience 42
3.15 INDSPEC Chemical 42
3.16 T2 Laboratories 42
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Index of Tables and Figures
Table 1 Chemical Manufacturing Top 3 TRI "Releases to Land" by Subsector 2
Figure 1 Schematic diagram of a typical chemical manufacturing process 3
Table 2 Typical Chemical Manufacturing Operations: Materials Used and generated Hazardous Wastes. 5
Figure 2 On-site Land Releases from Basic Chemical Manufacturing 8
Table 3 Potential releases during Organic Chemical Manufacturing 13
Figure 3 On-site Land Releases from Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and
Filaments Manufacturing 14
Figure 4: Rubber Products Manufacturing Process Pollution Outputs 16
Table 4 Summary of Potential releases during Plastic Resin and Manmade Fiber Manufacturing 18
Figure 5 On-site Land Releases from Pesticide, Fertilizer and Other Agricultural Chemical Manufacturing
19
Table 5 Summary of Potential Pollution Outputs for Agricultural Chemicals 20
Table 6 Fertilizer Materials used in Bulk Blends 22
Table 7 Examples of Pharmaceutical Products by Bulk Manufacturing Process 23
Figure 6: Simplified Process Flow Diagram for Chemical Synthesis 24
Figure 7: Simplified Process Flow Diagram for Natural Extraction 25
Figure 8: Simplified Process Flow Diagram for the Fermentation Process 26
Figure 9 On-site Land Releases from Pharmaceutical and Medicine Manufacturing 27
Figure 10 On-site Land Releases from Paint, Coating and Adhesive Manufacturing 29
Figure 11 On-site Land Releases from Soap, Cleaning Compound, and Toilet Preparation Manufacturing
31
Figure 12 On-site Land Releases from Other Chemical Product and Preparation Manufacturing 33
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1. Introduction
Operational and decommissioning practices in industrial sectors and their associated firms can
ultimately affect the ability of individual firms to responsibly minimize their impact on human health and
the environment. To consider the potential for releases as part of its decision making, EPA prepared this
a high-level review of industry practices and the environmental profile of the Chemical Manufacturing
industry, which includes a summary of relevant operational and decommissioning materials and wastes.
This document endeavors to review how current Chemical Manufacturing Industry practices have
affected the non-permitted releases of hazardous substances into the environment. It also discusses
how the nature and frequency of releases and other impacts may have changed over time. As
documented in the 2010 Advance Notice of Potential Rulemaking (ANPRM),1 facilities in the Chemical
Manufacturing Industry generate significant quantities of hazardous wastes, which may increase the risk
of releases of hazardous substances.
Chemical Manufacturing facilities transform raw materials (e.g., oil, natural gas, water, minerals, metals)
into tens of thousands of different products, including pigments, synthetic fibers, bulk chemicals,
plastics, pharmaceuticals, and consumer goods, as well as produce inputs to agriculture, manufacturing,
and construction industries. Commodity manufacturers create products in large quantities under
continuous processing conditions, generally in large volumes in response to homogenous specifications.
The small number of shutdowns affects the potential to adjust such as equipment retrofits and
upgrades. Specialty-batch manufacturers develop products for focused markets, making complex
products in small quantities that are then processed into higher value-added products.2 These
manufacturers change their process lines several times per year, providing more opportunities for
environmental improvements but also making environmental compliance more complicated.
Operation of any chemical manufacturing facility requires use of a variety of nonhazardous materials,
including paper, cardboard, wood, aluminum, containers, packaging materials, office waste, food,
municipal trash, and wastes from equipment assembly and maintenance crews. Potentially hazardous
materials are also frequently used. These materials can include a large variety of chemicals and
compounds.
The many different processes used in the chemical manufacturing industry result in many specific
wastes. Typical wastes from chemical manufacturing facilities can include, for example, spent solvents,
distillation bottoms and side-cuts, off-specification and unused chemicals, wastewater, wastewater
treatment sludge, emission control sludges, filter cake, spent catalysts, byproducts, reactor cleanout
wastes and container residues. Chemical facilities typically handle large volumes of chemicals using
above and below ground bulk storage tanks, transfer equipment, process piping and raw material/final
product storage areas. Some materials or wastes may be found on site in surface impoundments, bulk
storage tanks, waste piles and disposal pits. All these areas may contribute to soil, building and
groundwater contamination.3 Decommissioning wastes can include all the chemicals and substances
1 https://wvyyy.federalregister.gov/documents/2010/01/06/E9-31399/identification-of-additionaj-cjasses-of-
facilities-for-development-of-financial-respoiisibility
2 EPA Sustainable Industry Principle Findings: the U.S. Specialty-Batch Chemical Industry, Feb 2000
3 EPA Brownfields Technical Resources: Industrial & Analytical Profiles: Abandoned Chemical Facilities
SATA0301341BFcleanup9/97 of Sep 1997
Chemical Manufacturing Industry Practices and Environmental Characterization -
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listed above, as well as contaminated soil and building materials, sludges, neutralization liquids and
cleaning solvents. Air emissions and any associated human health and environmental impacts are not
considered in this document, as they rarely lead to the CERCLA and RCRA removal and clean up liabilities
relevant to CERCLA 108(b) potential requirements.
Of the national 2017 EPA Toxic Release Inventory (TRI) reported releases, over 50% of the total releases
from the Chemical Manufacturing industry are to land.4 There are a number of factors to consider when
using TRI data.5 The reader should be aware that TRI "pounds released" data presented here is not
equivalent to a "risk" ranking. Weighting each pound of release equally does not factor in the relative
toxicity of each chemical that is released. The largest overall releases to land from this industry listed in
declining order by weight are manganese and manganese compounds, nitrates, ammonia, formaldehyde
and formic acid, although Table 1 below shows the variation between sectors and subsectors. Other
substances beyond those listed here may also have been used in operations or released from facilities in
the industry.
Industry
Sector
Chemical
Manufacture
Basic
Chemical
Manufacture
Resin,
Synthetic
Rubber, and
Artificial and
Synthetic
Fibers and
Filaments
Manufacture
Pesticide,
Fertilizer and
Other
Agricultural
Chemical
Manufacture
Pharmaceutical
and Medicine
Manufacture
Paint, Coating
and Adhesive
Manufacture
Soap,
Cleaning
Compound
and Toilet
Preparation
Manufacture
Other Chemical
Product and
Preparation
Manufacture
NAICS
325
3251
3252
3253
3254
3255
3256
3259
Largest
Chemical
releases to
land
Manganese &
manganese
compounds
Manganese &
manganese
compounds
Nitrate
compounds
Formaldehyde
N,N-
dimethylforma
mide
Glycol ethers
Methanol
Acetonitrile
Second
largest
chemical
release to
land
Nitrate
compounds
Ammonia
Formic acid
Barium &
barium
compounds
Methanol
3-iodo-2-
propynyl
butylcarbamate
Napthalene
Ammonia
Third
largest
chemical
release to
land
Ammonia
Chromium &
chromium
compounds
N-methyl 2-
pyrrolidone
Formic acid
Nitrate
compounds
Zinc & zinc
compounds
N-methyl 2-
pyrrolidone
Cyanide
compounds
Table 1 Chemical Manufacturing Top 3 TRI "Releases to Land" by Subsector
Industry practices in certain subsectors,, All Other Basic Organic Chemical Manufacturing (325199),
Other Basic Inorganic Chemical Manufacturing (325180), Cyclic Crude, Intermediate, and Gum and
Wood Chemical Manufacturing (325194) and Synthetic Dye and Pigment Manufacturing (325130), of the
Chemical Manufacturing industry use more hazardous substances and generate larger volumes of
hazardous waste.6 Several subsectors use less hazardous substances and generate lower amounts of
hazardous wastes, including Custom Compounding of Purchased Resins (325991), Printing Ink
4 EPA 2017 TRI sector report for Chemical Manufacturing accessed at
https://www.epa.gov/sites/production/files/2019-02/documents/industrv sectors.pdf
5 EPA Factors to Consider When Using Toxics Release Inventory Data of Mar 2019 accessed at
https://www.epa.gov/sites/production/files/2019-03/documents/factors to consider march 2019.pdf
6 2017 325 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Manufacturing (325910), Polish and other Sanitation Good Manufacturing (325612), Phosphatic
Fertilizer Manufacturing (325312), and Ethyl Alcohol Manufacturing (325193).7
1.1 Wastes
Hazardous wastes generated by the Chemical Manufacturing industry are diverse. Volume, types, and
toxicity varies widely from one sector to another, and between subsectors within a sector. Table 2 below
provides a high-level overview of the types of operations, materials and associated wastes. EPA has also
added hazardous waste listings for several different wastes from the inorganic chemicals industry.8
Other wastes beyond those listed here may also have been generated from facilities in the industry. Air
emissions and any associated human health and environmental impacts are not considered in this
document, as they rarely lead to the CERCLA and RCRA removal and clean up liabilities relevant to
CERCLA 108(b) potential requirements. Additional information on processes and releases for portions of
this industry is also available in the EPA Sector Profile Reports - EPA/310-R-95-004 Profile of the
Inorganic Chemical Industry, EPA/310-R-02-001 Profile of the Organic Chemical Industry, 2nd Edition,
EPA/310-R-95-016 Profile of the Rubber and Plastic Industry, EPA/310-R-97-005 Profile of the
Pharmaceuticals Industry, EPA/310-R-97-006. Profile of the Plastic Resin and Man-made Fiber Industry,
EPA/310-R-97-010 Sector Notebook Data Refresh-1997, and EPA/310-R-00-003 Profile of the
Agricultural Chemical, Pesticide and Fertilizer Industry. For illustration purposes, Figure 1 below provides
a high-level schematic of a typical chemical manufacturing process.9
Figure 1 Schematic diagram of a typical chemical manufacturing process
1 2017 325 Land Smallest Subsectors TRI
8 Economic Analysis for Listing of Inorganic Chemicals, Oct 2001
9 Industrial Environmental Performance Metrics: Challenges and Opportunities, Chapter 5, the Chemical Industry,
National Academies Press, 1999
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Waste from the Chemical Manufacturing Industry arises at each step of the production cycle. This
characterization review concerns only the operation and decommissioning steps of direct relevance to
the Chemical Manufacturing Industry. Operation of any facility in this industry requires use of a variety
of nonhazardous materials, including paper, cardboard, wood, aluminum, containers, packaging
materials, office waste, municipal trash etc. Potentially hazardous materials are also frequently used, as
shown in Table 2.10 Process fluids can be either hazardous or non-hazardous, and can include
wastewater, spent solvents, chemical cleaning rinses, cooling water, wash and makeup water, sump and
floor discharges, chemical water seperator fluids, boiler blowdown, and water from surface
impoundments. A study11 of hazardous waste in the California chemical industry found that most of the
waste, almost 40%, was generated by cleaning activities (washing out bottles, glassware, tanks,
containers, reactor vessel and other production equipment, and flushing lines). Another 20% was
generated by plant washdown. Production of off-specification materials and by-products accounted for
14%, while distilation and reclamation activities accounted for 13%. Much smaller amounts were
generated by onsite treatment of residuals and wastes, use of personal protective equipment, settling of
sludges, housekeeping actitis, abrasive blasting of equipment and use of filter materials. Spent
materials, empty containers and waste fuel oil also contributed to the waste streams. Other materials
beyond those listed here may be used in the operation of Chemical Manufacturing Industry facilities.
For Chemical Manufacturing industry facilities, decommissioning will likely occur soon after the end of a
plant's operating life. Decommissioning wastes will generally be those associated with demolition and
can include all the chemicals and substances listed below, as well as contaminated soil and building
materials, sludges, neutralization liquids and cleaning solvents. Some may pose special residual hazards.
Where onsite landfills and surface impoundments are used during operation, compliant and protective
closure can be complex and challenging.
10 EPA Industry Overview Fact Sheets - Chemical Manufacturers EPA 530-SW-027h, Printing and Allied Industries
EPA/530-SW-90-027g, Formulators EPA 530-SW-027p, and Cleaning Agents EPA 530-SW-027q
11 Hazardous Waste Source Reduction Assessment of Selected Sectors on the California Chemical Industry, May
2004
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Process or
operation
Materials Used
General Types of Waste Generated
Pigment
Manufacturing
Acids/alkalies, heavy metals
(catalysts and salts), solvents,
petroleum distillates
Acid/alkaline wastes, Heavy metal wastes (dust and
sludge), Heavy metal wastes (solutions,) Solvent
wastes, Toxic organic liquids, Toxic wastewaters and
sludges
Pesticide
Formulators and
Manufacturing
Pesticides, carriers, dispensing
agents, solvents, organic chemicals,
heavy metals
Pesticide wastes, Empty containers, Rinsewater,
Solvent wastes, Toxic wastes
Synthetic Fiber
Manufacturing:
Cellulosic Fibers
Cellulose acetate/rayon pigments,
solvents, bleaches, lubricants, dyeing
assistants, stabilizers, delustrants,
brighteners
Toxic heavy metal wastes, Toxic wastewaters and
sludges, Other toxic wastes, Solvent wastes, Reactive
wastes
Synthetic Fiber
Manufacturing:
Non-Cellulosic
(acrylic, nylon,
polyester)
Pigments, solvents, bleaches,
lubricants, dyeing assistants,
stabilizers, delustrants, brighteners,
ploymeric materials
Still bottoms, Solvent wastes, Reactive wastes, Toxic
heavy metal wastes, Toxic wastewaters and sludges,
Other toxic wastes
Rubber
Manufacturing
Monomers, solvents, paints, catalysts
Toxic heavy metal wastes, Toxic or ignitable paint
wastes, Toxic wastewaters and sludges, Other toxic
wastes, Solvent wastes, Waste rubber solids
Other Chemical
Manufacturing
Solvents, chemicals, catalysts,
acids/alkalies
Acid/alkaline wastes, Toxic heavy metal wastes (dust
and sludge) Ignitable wastes, Reactive wastes
(other), Solvent wastes, Spent catalysts, Emission
control dusts and sludges
Printing Ink
Formulation
Coloring materials, resins, varnishes,
solvents, driers, antioxidants,
thickeners, gellants, waxes,
defoamers, wetting agents,
surfactants
Acid/alkaline wastes, Toxic heavy metal wastes (dust
and sludge), Ink sludges with chromium or lead,
Other toxic wastes
Cleaning Agent
Manufacturing
Solvents, heavy metals, pesticides,
organic chemicals, metals, strong
acids and bases
Solvent wastes, Toxic wastes, Pesticide wastes,
Ignitable wastes, Toxic heavy metal sludges and
dusts, Acid/alkaline wastes
Pharmaceutical
Formulation
Solvents, resins, lubricants, gelatins
Solvent wastes, Ignitable wastes, Toxic wastewaters
and wastewater treatment sludges
Paint and Coatings
Formulation
Paints, solvents, heavy metals,
acids/alkalies, driers, plastic resins,
plasticizers
Acid/alkaline wastes, Toxic heavy metal wastes (dust
and sludge), Other toxic wastes, Paint wastes,
Solvent wastes, Spoiled batches
Chemical Product
Formulation not
Classified
Elsewhere
Solvents, chemicals, catalysts,
acids/alkalies, heavy metals
Acid/alkaline wastes, Toxic heavy metal wastes (dust
and sludge), Other toxic wastes, Ignitable wastes,
Reactive wastes, Solvent wastes, Spent catalysts,
Emission control dusts and sludges
Table 2 Typical Chemical Manufacturing Operations: Materials Used and generated Hazardous Wastes
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1.2 Sectors and their Subsectors
The North American Industry Classification System (NAICS) Industry Code 325 - Chemical Manufacturing
- is "based on the transformation of organic and inorganic raw materials by a chemical process and the
formulation of products. This Sector distinguishes the production of basic chemicals that comprise the
first industry group from the production of intermediate and end products produced by further
processing of basic chemicals that make up the remaining industry groups." Within this classification the
following sectors and subsectors are listed as:
Industry 325: Chemical Manufacturing
Sector 3251: Basic Chemical Manufacturing
325110 Petrochemical Manufacturing
325120 Industrial Gas Manufacturing
325130 Synthetic Dye and Pigment Manufacturing
325180 Other Basic Inorganic Chemical Manufacturing
325193 Ethyl Alcohol Manufacturing
325194 Cyclic Crude, Intermediate, and Gum and Wood Chemical Manufacturing
325199 All Other Basic Organic Chemical Manufacturing
Sector 3252: Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments
Manufacturing
325211 Plastics Material and Resin Manufacturing
325212 Synthetic Rubber Manufacturing
325220 Artificial and Synthetic Fibers and Filaments Manufacturing
Sector 3253: Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing
325311 Nitrogenous Fertilizer Manufacturing
325312 Phosphatic Fertilizer Manufacturing
325314 Fertilizer (Mixing Only) Manufacturing
325320 Pesticide and Other Agricultural Chemical Manufacturing
Sector 3254: Pharmaceutical and Medicine Manufacturing
325411 Medicinal and Botanical Manufacturing
325412 Pharmaceutical Preparation Manufacturing
325413 In-Vitro Diagnostic Substance Manufacturing
325414 Biological Product (except Diagnostic) Manufacturing
Sector 3255: Paint, Coating, and Adhesive Manufacturing
325510 Paint and Coating Manufacturing
325520 Adhesive Manufacturing
Sector 3256: Soap, Cleaning Compound, and Toilet Preparation Manufacturing
325611 Soap and Other Detergent Manufacturing
325612 Polish and Other Sanitation Good Manufacturing
325613 Surface Active Agent Manufacturing
325620 Toilet Preparation Manufacturing
Sector 3259: Other Chemical Product and Preparation Manufacturing
325910 Printing Ink Manufacturing
325920 Explosives Manufacturing
325991 Custom Compounding of Purchased Resins
325992 Photographic Film, Paper, Plate, and Chemical Manufacturing
325998 All Other Miscellaneous Chemical Product and Preparation Manufacturing
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Each of the sections that follow describes operating and Chemical Manufacturing industry sector and
subsector waste management methods in the United States and provides a brief overview description of
how they are implemented. Unique characteristics within the sectors and subsectors are covered below.
2. 325 - Chemical Manufacturing
In 2017, chemical manufacturers reported to EPA's National RCRA Hazardous Waste Biennial Report (BR)
the generation of 21.7 million tons of hazardous waste, accounting for 62% of the hazardous waste
generated nationally. This represents a 5% growth since 2015.12
Most of the national 2017 EPA Toxic Release Inventory (TRI) reported chemical releases originated from
the Chemical Manufacturing industry (51%). From 2007 to 2017 total releases by the Chemical
Manufacturing industry decreased by less than 1%13. Distribution of releases changed during this time
period with reduced releases to air and increased disposal to land. This change has been driven largely
by decreased air releases of common chemicals including methanol, carbonyl sulfide, and hydrochloric
acid, and increased land disposal of many metal compounds such as barium compounds and zinc
compounds. The top fifteen released chemicals and compounds from the Chemical Manufacturing
industry are ammonia, nitrates, manganese, methanol, formaldehyde, zinc, formic acid, acetonitrile,
ethylene, chromium, barium, nitric acid, carbonyl sulfide, vanadium, and n-methyl-2-pyrridone. Other
materials beyond those listed here may be used in the operation of chemical manufacturing facilities.
Water use in the Chemical Manufacturing industry varies widely, depending on the products
manufactured and production processes used. The primary uses of water are for non-contact cooling,
steam applications, and product processing. The production of various chemicals requires different
amounts of water. For example, producing silicon-based chemicals requires large quantities of water,
yet the top manufactured chemicals by volume (including nitrogen, ethylene, ammonia, phosphoric
acid, propylene, and polyethylene) require far less water during production. In general, the substances
tracked by TRI are found in the raw materials or fuels used in Chemical Manufacturing processes, and as
intermediates. They can also be byproducts, products from side reactions, or internal end products.
Over 50% of the total releases from the Chemical Manufacturing industry are to land.14 The largest
overall releases to land listed in declining order by weight are manganese and manganese compounds,
nitrates, ammonia, formaldehyde and formic acid, although there is substantial variation between
sectors.15 For example, chromium and chromium compounds are the third largest for the Basic Chemical
Manufacturing sector (NAICS 3251), n-methyl 2-pyrrolidone is the third largest for the Resin, Synthetic
Rubber, and Artificial and Synthetic Fibers and Filaments Manufacturing sector (NAICS 3252), barium
and barium compounds are the third largest for the Pesticide, Fertilizer and Other Agricultural Chemical
Manufacturing sector (NAICS 3253), N,N-dimethylformamide is the largest for the Pharmaceutical and
12 2017 BR Detailed NAICS Results for National (NAICS 325)
13 2017 TRI including 325 Industry Sectors report of Mar 2019
14 EPA 2017 TRI sector report for Chemical Manufacturing accessed at
httpsi//www,epa,gov/sites/production/files/2019~02/documents/industry sectors.pdf
15 2017 325 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Medicine Manufacturing sector (NAICS 3254), glycol ethers are the largest for the Paint, Coating and
Adhesive Manufacturing sector (NAICS 3255), napthalene is the second largest for the Soap, Cleaning
Compound and Toilet Preparation Manufacturing sector (NAICS 3256), and acetonitrile is the largest for
the Other Chemical Product and Preparation Manufacturing sector (NAICS 3259). Other substances
beyond those listed here may also have been used in operations or released from facilities in the
industry.
2.1 3251 - Basic Chemical Manufacturing.
This sector comprises establishments primarily engaged in manufacturing chemicals using basic
processes, such as thermal cracking and distillation. Chemicals manufactured in this industry group are
usually separate chemical elements or separate chemically-defined compounds.
Within this sector, on-site land disposal in 2017 was over 158 million pounds.16 The largest weight
substances released to land listed in declining order by weight are manganese and manganese
compounds, ammonia, chromium and chromium compounds, and acetonitrile and methanol, as shown
on Figure 2. When evaluated by subsector, 48% of the on-site land waste is from All Other Basic Organic
Chemical Manufacturing (325199) and 30% is from Synthetic Dye and Pigment Manufacturing (325130).
The national 2017 EPA RCRA BR identified over 20.4 million tons of hazardous waste generated by this
sector.17
On-site Land Disposal by Chemical, 2017
1S8.470.70S lb
Chemical
MANUANtSt AND MANGA...
Others
34 4S
ZINC AND ZINC COMP.
NITRATE COMPOUNDS
VANADIUM AND VANADIUM...
NITRIC ACID
AMMONIA
CHROMIUM AND CHROMIUM..
ACETONITRILE
Figure 2 On-site Land Releases from Basic Chemical Manufacturing
2.1.1 325110 - Petrochemical Manufacturing
This subsector comprises establishments primarily engaged in (1) manufacturing acyclic (i.e., aliphatic)
hydrocarbons such as ethylene, propylene, and butylene made from refined petroleum or liquid
hydrocarbons and/or (2) manufacturing cyclic aromatic hydrocarbons such as benzene, toluene, styrene,
xylene, ethyl benzene, and cumene made from refined petroleum or liquid hydrocarbons.
16 2017 3251 Land TRI
17 2017 BR Detailed NAICS Results for National (NAICS 3251)
Chemical Manufacturing Industry Practices and Environmental Characterization -
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The two most common petrochemical classes are olefins (including ethylene and propylene) and
aromatics (including benzene, toluene and xylene isomers). Oil refineries produce olefins and aromatics
by fluid catalytic cracking of petroleum fractions. Chemical plants produce olefins by steam cracking of
natural gas liquids like ethane and propane. Aromatics are produced by catalytic reforming of naphtha.
Olefins and aromatics are the building-blocks for a wide range of materials such as solvents, detergents,
and adhesives. Olefins are the basis for polymers and oligomers used in plastics, resins, fibers,
elastomers, lubricants, and gels.
Like commodity chemicals, petrochemicals are made on a very large scale. Petrochemical manufacturing
units differ from commodity chemical plants in that they often produce several related products. The
large-scale petrochemical manufacturing locations are more likely to have clusters of manufacturing
units that share utilities and large-scale infrastructure such as power stations, storage tanks, port
facilities, road and rail terminals. The 2017 TRI reported18 over 4.1 million pounds (a 40% reduction from
2016) of chemicals disposed on-site, primarily methanol through underground injection in Texas. The
national 2017 EPA RCRA BR identified over 958 thousand tons of hazardous waste generated by this
subsector.19
2.1.2 325120 - Industrial Gas Manufacturing
This subsector comprises establishments primarily engaged in manufacturing industrial organic and
inorganic gases in compressed, liquid, and solid forms. Industrial gas producers use advanced
technologies to supply gases like oxygen, nitrogen, helium, acetylene and hydrogen. Many of these
gases are used in manufacturing, health care, transportation and other essential industries. While the
industrial gas industry uses natural gas, the industrial gases industry is not a producer or distributor of
natural gas.20 Air separation plants refine air in a separation process and so allow the bulk production of
nitrogen and argon in addition to oxygen - these three are often also produced as cryogenic liquid. The
other principal production technology in the industry is reforming. Steam reforming is a chemical
process used to convert natural gas and steam into a syngas containing hydrogen and carbon monoxide
with carbon dioxide as a byproduct.
In addition to the major gases produced by air separation and syngas reforming, the industry provides
many other gases. Some gases are simply byproducts from other industries and others are sometimes
bought from other larger chemical producers, refined and repackaged; although a few have their own
production processes. The 2017 TRI reported21 over 14,000 pounds (a 50% reduction from 2016) of
chemicals disposed on-site, primarily arsenic and chromium. The national 2017 EPA RCRA BR identified
over 18,000 tons of hazardous waste generated by this subsector.
18 2017 325110 Land TRI
19 2017 BR Detailed NAICS Results for National (NAICS 3251)
20 American Chemistry Council Industrial Gases, July 2016
21 2017 325120 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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2.1.3 325130 - Synthetic Dye and Pigment Manufacturing
This subsector comprises establishments primarily engaged in manufacturing synthetic organic and
inorganic dyes and pigments, such as lakes and toners (except electrostatic and photographic). Dyes are
coloring materials that are applied as a solution and cling to whatever they are applied to (e.g., textiles,
hair, wood, food) and can be used for decorative, aesthetic, identification and artistic purposes.
Fluorescent brightening dyes improve the appearance of textiles and paper. Contrast agents and
fluorescent dyes make selected cells and organs stand out for biological and medical imaging. Dye-based
lasers are not only powerful, but they also emit laser light over a range of wavelengths, producing
"tunable" laser beams for manufacturing, medical applications, astronomical research, and
spectroscopy.
Pigments are used for artists' paints, car finishes, and light-reflecting signs. They are insoluble materials
that must be mixed with binders or vehicles to attach them to a substrate. Pigments are often derived
from minerals, but they can also be made synthetically. Pigments are used in paints, inks, plastics,
fabrics, cosmetics, and food. They are often better than dyes at keeping their color for many centuries
and for withstanding high heat, intense light, and exposure to weather or chemical agents.22
Over 48 million pounds of material reported to the 2017 TRI was disposed on-site at Synthetic Dye and
Pigment chemical manufacturing facilities, with over 70% of this disposition by weight resulting from the
manganese and manganese compounds, and over 15% from chromium and chromium compounds.
Industry practices in certain sectors generate larger volumes of hazardous waste. The national 2017 EPA
RCRA BR identified over 2.1 million tons of hazardous waste generated by this subsector, one of the
largest in this sector.
2.1.4 325180 - Other Basic Inorganic Chemical Manufacturing
This subsector comprises establishments primarily engaged in manufacturing basic inorganic chemicals
(except industrial gases and synthetic dyes and pigments). This includes alkalies, aluminum compounds,
carbides (e.g., baron, calcium, silicon, tungsten), carbon black, chlorine, hydrochloric acid, potassium,
inorganic compounds, radioactive isotopes, sulfides, sulfites and sulfuric acid manufacturing.
Over 14 million pounds of material reported to the 2017 TRI was disposed on-site at Other Basic
Inorganic chemical manufacturing facilities, with over 28% of this disposition by weight resulting from
the manganese and manganese compounds, over 24% from zinc and zinc compounds, over 10% from
vanadium and vanadium compounds, and over 8% from chromium and chromium compounds23.
Industry practices in certain subsectors generate larger volumes of hazardous waste. The national 2017
EPA RCRA BR identified over 3.9 million tons of hazardous waste generated by this subsector, one of the
largest in this sector.24
Solid wastes generated during inorganic chemical manufacturing containing mercury include: solids
generated during brine purification; spent graphite from decomposer cells; spent caustic filtration
22 American Chemistry Society, Dyes, Pigments and Inks
23 2017 325180 Land TRI
24 2017 BR Detailed NAICS Results for National (NAICS 3251)
10
Chemical Manufacturing Industry Practices and Environmental Characterization -
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cartridges from the filtration of caustic soda solution; spilled mercury from facility sumps; and mercury
cell "butters," which are semisolid amalgams of mercury with barium or iron formed when an excess of
barium is used during salt purification. Most mercury bearing solid wastes are shipped off-site to outside
reclaimers who recover the mercury. The remaining wastes are disposed of in secure landfills using
either chemical or physical methods to recover maximum feasible amount of mercury.
Solid wastes generated in the diaphragm process consist primarily of solids generated during brine
purification and scrapped cell parts including, cell covers, piping and used diaphragms. Discarded cell
parts are either landfilled on-site, as is typically the case for spent diaphragms, or shipped off-site for
disposal. Used cathodes and DSA anodes are shipped off-site for recovery of their titanium content.44
Solid waste generated in the diaphragm process consists primarily of solids generated during brine
purification and used cell parts which include membranes, cathodes and DSA anodes. The used
membranes are typically returned to the supplier and the used cathodes and DSA anodes are shipped
off-site for recovery of their titanium content.
Brine muds are one of the largest waste streams of the chlor-alkali industry. On average, about 30
kilograms (kg) of brine mud are generated for every 1,000 kg of chlorine produced. The volume of mud
will vary, however, depending on the purity of the salt used. Some facilities use pre-purified (i.e.,
chemical grade) evaporated salts which will produce only 0.7 to 6.0 kg of brine mud per 1,000 kg of
chlorine produced. Brine mud typically contains magnesium hydroxide, calcium carbonate, and, in most
cases, barium sulfate. Mercury cell brine muds usually contain mercury either in the elemental form or
as the complex ion, mercuric chloride (HgCI42-). Mercury- containing brine muds are typically disposed
of in a RCRA Subtitle C landfill after treatment with sodium sulfide which converts the mercury to an
insoluble sulfide. Brine muds are usually segregated from other process wastes and stored in lagoons
on-site. When the lagoons become filled, the brine mud is either dredged and landfilled off-site, or
drained and covered over. Some plants that use brine solution leached from subterranean deposits
inject brine muds into the salt cavities that are no longer being used.25
2.1.5 325193 - Ethyl Alcohol Manufacturing
This subsector comprises establishments primarily engaged in manufacturing non-potable ethyl alcohol.
Only 1.5 million pounds of material reported to the 2017 TRI was disposed on-site at ethyl alcohol
manufacturing facilities. Industry practices in certain subsectors generate smaller amounts of hazardous
wastes. The national 2017 EPA RCRA BR identified less than 900 tons of hazardous waste generated by
this subsector.
2.1.6 325194 - Cyclic Crude, Intermediate, and Gum and Wood Chemical Manufacturing
This subsector comprises establishments primarily engaged in one or more of the following: (1) distilling
wood or gum into products, such as tall oil and wood distillates; (2) distilling coal tars; (3) manufacturing
wood or gum chemicals, such as naval stores, natural tanning materials, charcoal briquettes, and
charcoal (except activated); and (4) manufacturing cyclic crudes or cyclic intermediates (i.e.,
hydrocarbons, except aromatic petrochemicals) from refined petroleum or natural gas.
25 Profile of the Inorganic Chemicals Manufacturing Sector 310-R-95-004 of Sep 1995
Chemical Manufacturing Industry Practices and Environmental Characterization -
11
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Over 14 million pounds of material (a more that 58% increase from 2016) reported to the 2017 TRI was
disposed on-site by facilities in this subsector, with over 15% of this disposition by weight resulting from
aniline, over 18% from methanol and ammonia combined, over 14% from nitrate compounds, over 11%
from sodium nitrate, and over 10% from picric acid.26 Industry practices in certain subsectors generate
larger volumes of hazardous waste. The national 2017 EPA RCRA BR identified over 3.3 million tons of
hazardous waste generated by this subsector.
2.1.7 325199 - All Other Basic Organic Chemical Manufacturing
This subsector comprises establishments primarily engaged in manufacturing basic organic chemical
products (except aromatic petrochemicals, industrial gases, synthetic organic dyes and pigments, gum
and wood chemicals, cyclic crudes and intermediates, and ethyl alcohol). This includes biodiesel fuels
not made in petroleum refineries and not blended with petroleum, calcium organic compounds, carbon
organic compounds, enzyme proteins (i.e., basic synthetic chemicals) (except pharmaceutical use), fatty
acids (e.g., margaric, oleic, stearic), organo-inorganic compounds, plasticizers (i.e., basic synthetic
chemicals), silicone (except resins), and synthetic sweeteners.
Over 249 million pounds of material reported to the TRI in 2017 was disposed on-site at chemical
manufacturing facilities, with over 30% of this disposition by weight resulting from the All Other Basic
Chemicals subsector. Over 75 million pounds of material reported to the 2017 TRI was disposed on-site
by facilities in this subsector, with over 23% of this disposition by weight resulting from ammonia, over
11% from acetonitrile, over 9% from nitric acid, over 6% from methanol, almost 5% from acrylonitrile,
and over 4% each from nitrate and cyanide compounds.27 Industry practices in certain sectors of the
Chemical Manufacturing industry generate larger volumes of hazardous waste. The national 2017 EPA
RCRA BR identified over 9.9 million tons of hazardous waste generated by this subsector, the largest for
the entire Chemical Manufacturing industry.28
Details on industrial processes in the Organic Chemicals subsector are available in the Profile of the
Organic Chemical Industry29. Section III of this profile specifically contains a description of commonly
used production processes, associated raw materials, the by-products produced or released, and the
materials either recycled or transferred off-site. This discussion, coupled with schematic drawings of the
identified processes, provides a concise description of where wastes may be produced in the process. It
also describes the potential fate (via air, water, and soil pathways) of these waste products.
Organic chemical manufacturers use and generate both large numbers and quantities of chemicals. The
industry releases chemicals to all media including air (through both fugitive and direct emissions), water
(direct discharge and runoff) and land. The types of pollutants a single facility will release depend on the
feedstocks, processes, equipment in use and maintenance practices. These can vary from hour to hour
and can also vary with the part of the process that is underway. For example, for batch reactions in a
closed vessel, the chemicals are more likely to be emitted at the beginning and end of a reaction step
26 2017 325194 Land TRI
27 2017 325199 Land TRI
28 2017 BR Detailed NAICS Results for National (NAICS 3251)
29 Profile of the Organic Chemical Industry, 2nd Edition 310-R-02-001 of Nov 2002
Chemical Manufacturing Industry Practices and Environmental Characterization -
12
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(associated with vessel loading and product transfer operations), than during the reaction. The potential
sources of pollutant outputs by media are shown below in Table 3.
Media
Potential Sources of Emissions
Air
Point source emissions: stack, vent (e.g. laboratory hood, distillation unit,
reactor, storage tank vent), material loading/unloading operations (including
rail cars, tank trucks, and marine vessels)
Fugitive emissions: pumps, valves, flanges, sample collection, mechanical
seals, relief devices, tanks
Secondary emissions: waste and wastewater treatment units, cooling tower,
process sewer, sump, spill/leak areas
Liquid wastes
(Organic or
Aqueous)
Equipment wash solvent/water, lab samples, surplus chemicals, product
washes/purifications, seal flushes, scrubber blowdown, cooling water, steam
jets, vacuum pumps, leaks, spills, spent/used solvents, housekeeping (pad
washdown), waste oils/lubricants from maintenance
Solid Wastes
Spent catalysts, spent filters, sludges, wastewater treatment biological sludge,
contaminated soil, old equipment/insulation, packaging material, reaction by-
products, spent carbon/resins, drying aids
Ground Water
Contamination
Unlined ditches, process trenches, sumps, pumps/valves/llttings, wastewater
treatment ponds, product storage areas, tallies and tank farms, aboveground
and underground piping, loading/unloading areas/racks, manufacturing
maintenance facilities
Source: Chemical Manufacturers Association, 1993.
Table 3 Potential releases during Organic Chemical Manufacturing
2.2 3252 - Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments
Manufacturing
This sector comprises establishments primarily engaged in one of the following: (1) manufacturing
synthetic resins, plastics materials, and non-vulcanizable elastomers and mixing and blending resins on a
custom basis; (2) manufacturing non-customized synthetic resins; (3) manufacturing synthetic rubber;
(4) manufacturing cellulosic (e.g., rayon, acetate) and non-cellulosic (e.g., nylon, polyolefin, polyester)
fibers and filaments in the form of monofilament, filament yarn, staple, or tow; or (5) manufacturing
and texturizing cellulosic and non-cellulosic fibers and filaments.
Within this sector, on-site land disposal in 2017 was over 34 million pounds.30 The largest weight
substances released to land by this sector listed in declining order by weight are nitrate compounds and
formic acid, as shown on Figure 3. When evaluated by subsector within this sector, 99% of the on-site
land waste is from Plastics Material and Resin Manufacturing (325211) and less than 1% is from
Synthetic Rubber Manufacturing (325212).
30 2017 3252 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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On-site Land Disposal by Chemical, 2017
34,229,963 lb
Chemical
NI-BUTYL ALCOHOL
AMMONIA \
MtlHANOL
N-METHYL-2-PYRROLI...
FORMIC ACID
66.9%
NITRATE COMPOUNDS
Figure 3 On-site Land Releases from Resin, Synthetic Rubber, and Artificial and Synthetic Fibers and Filaments Manufacturing
Residual wastes make up a significant portion of wastes from plastic resin (325211) and manmade fiber
(325220) facilities. Unless solvents are used in polymerization processes, residual wastes are usually
restricted to off-spec polymer, polymer, and raw material chemicals. Typical contaminants include
contaminated polymer, catalyst manufacture waste, gas purification catalyst waste, reaction by-
products, waste oil, and general plant wastes. Although properly run and maintained plants with new
technology may be capable of obtaining 95 percent or higher polymer yields, off-spec and contaminated
polymer is still generated and makes up a sizeable portion of the waste stream. Unreacted or improperly
reacted polymer synthesis or regeneration residues may include monomers, oligomers, metals,
degradation products, solvents, and coagulants. Other sources of residual waste include cleanup
absorbents, spent activated carbon, laboratory wastes, and air pollution control residues. Additional
information on pollution outputs from this subsector are available in Table 4 below, Section III.C of the
1997 1st edition of the EPA Sector Profile,31 and section III.B of the 2005 2nd edition of the EPA Sector
Profile.32
2.2.1 325211 - Plastics Material and Resin Manufacturing
This subsector comprises establishments primarily engaged in (1) manufacturing resins, plastics
materials, and non-vulcanizable thermoplastic elastomers and mixing and blending resins on a custom
basis and/or (2) manufacturing non-customized synthetic resins. Specific product formulations and
manufacturing parameters are often kept as trade secrets since the competitiveness of many companies
depends on the ability to produce resins with different physical characteristics, such as strength,
toughness, and flexibility.
31 EPA Profile of the Plastic Resin and Manmade Fiber Industries, 310-R-97-006 of Sep 1997
32 EPA Profile of the Rubber and Plastics Industry, 2nd Edition, 310-R-05-003 of Feb 2005
14
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Over 249 million pounds of material reported to the TRI in 2017 was disposed on-site to land at chemical
manufacturing facilities, with over 13% of this disposition by weight resulting from the Plastics Material
and Resin Manufacturing sector.33 More than 59% of releases from this subsector are to land (more than
15 million pounds), primarily nitrate compounds and formic acid.34 Industry practices in certain sectors
of the Chemical Manufacturing industry generate larger volumes of hazardous waste. The national 2017
EPA RCRA BR identified over 471 thousand tons of hazardous waste generated by this subsector.35
Details on industrial processes in the Plastics Material and Resin Manufacturing subsector are available
in the Profile of the Plastic Resin and Manmade Fiber Industries.36 Section III.A of this profile specifically
contains a description of commonly used industrial processes, associated raw materials, the by-products
produced or released, and the materials either recycled or transferred off-site. This discussion, coupled
with schematic drawings of the identified processes, provides a concise description of where wastes
may be produced in the process. It also describes the potential fate (via air, water, and soil pathways) of
these waste products. The potential sources of pollutant outputs by media are shown above in Table 4.
2.2.2 325212 - Synthetic Rubber Manufacturing
This subsector comprises establishments primarily engaged in manufacturing synthetic rubber. Less than
1% of releases from this subsector are to land (less than 15 thousand pounds), primarily l,4-dichloro-2-
butene, chloroprene, and toluene.37
Details on industrial processes in the Synthetic Rubber Manufacturing subsector are available in the
Profile of the Rubber and Miscellaneous Plastics Products Industries.38 Section 111. A. 2 of this profile
specifically contains a description of commonly used industrial processes, associated raw materials, the
by-products produced or released, and the materials either recycled or transferred off-site. This
discussion, coupled with schematic drawings of the identified processes, provides a concise description
of where wastes may be produced in the process. It also describes the potential fate (via air, water, and
soil pathways) of these waste products. The potential sources of pollutant outputs by media are shown
Section III.B.2 of this profile and below in Figure 4. Additional information on emissions from rubber
manufacturing processes can also be found in the AP-42 Emissions factors draft Final report.39
33 2017 325 Land TRI
34 2017 325211 Land TRI
35 2017 BR Detailed NAICS Results for National (NAICS 3252)
36 EPA Profile of the Plastic Resin and Manmade Fiber Industries, 310-R-97-006 of Sep 1997
37 2017 325212 Land TRI
38 EPA Profile of the Rubber and Miscellaneous Plastics Products Industries, 310-R-05-003 of Feb 2005
39 Emission Factor Documentation for AP-42, Section 4.12 Manufacture of Rubber Products of Nov 2008
Chemical Manufacturing Industry Practices and Environmental Characterization -
15
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Figure 4: Rubber Products Manufacturing Process Pollution Outputs
The national 2017 EPA RCRA BR identified over 34 thousand tons of hazardous waste generated by this
subsector.40
40 2017 BR Detailed NAICS Results for National (NAICS 3252)
Chemical Manufacturing Industry Practices and Environmental Characterization -
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2.2.3 325220 - Artificial and Synthetic Fibers and Filaments Manufacturing
This subsector comprises establishments primarily engaged in (1) manufacturing cellulosic (e.g., rayon,
acetate) and noncellulosic (e.g., nylon, polyolefin, polyester) fibers and filaments in the form of
monofilament, filament yarn, staple, or tow or (2) manufacturing and texturizing cellulosic and
noncellulosic fibers and filaments. Noncellulosic, or synthetic, fibers consist of fibers that are formed by
the polymerization and subsequent fiber formation of synthetic organic chemicals and refined
petroleum products.
Details on industrial processes in the Artificial and Synthetic Fibers and Filaments Manufacturing
subsector are available in the Profile of the Plastic Resin and Manmade Fiber Industries.41 Section III.B of
this profile specifically contains a description of commonly used industrial processes, associated raw
materials, the by-products produced or released, and the materials either recycled or transferred off-
site. This discussion, coupled with schematic drawings of the identified processes, provides a concise
description of where wastes may be produced in the process. It also describes the potential fate (via air,
water, and soil pathways) of these waste products. Some of this pollution output (spinning, fiber
processing) information is included in Table 4 below. Less than 1% of releases from this subsector are to
land (less than 210 pounds), primarily polycyclic aromatic compounds.42 The national 2017 EPA RCRA BR
identified over 2,200 tons of hazardous waste generated by this subsector.43
41 EPA Profile of the Plastic Resin and Manmade Fiber Industries, 310-R-97-006 of Sep 1997
42 2017 325220 Land TRI
43 2017 BR Detailed NAICS Results for National (NAICS 3252)
Chemical Manufacturing Industry Practices and Environmental Characterization -
17
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Process
Air Emissions
Process Wastewater
Residual Wastes
Preparing Reactants
volatilized monomer,
solvents
little or no wastewater
produced
raw material drum
residuals
Polymerization
volatilized monomer,
solvents, reaction
byproducts
little or no wastewater
produced
off-specification or
contaminated polymer,
reaction byproducts, spent
equipment oil. spent
solvent, catalyst
manufacture waste, gas
purification catalyst waste
Polymer Recovery
volatilized solvents and
unreacted monomer
little or no wastewater
produced
little or no residual waste
produced
Polymer Extrusion
volatilized solvents and
unreacted monomer
extruder quench water
off-specification or
contaminated polymer
Equipment Cleaning
volatilized solvents and
unreacted monomer
reactor and floor wash water
contaminated with organics,
acids, and salts; equipment
rinse water
little or no residual waste
produced
Unloading and Storage
of Reactants
volatilized monomer and
solvents
Rinse water from cleaning
out transport vehicles
containing solvents,
monomers, and other
reactants
little or no residual waste
produced
Conveyance and
Pellet Storage
volatilized residual
monomer or solvents from
plastic pellets
little or no wastewater
produced
plastic pellets from leaks
or spills
Spinning
volatilized residual
monomer
solvents, additives, other
organics, volatilized finishes
water contaminated with
residual monomer solvents,
additives, other organics,
finishes
off-spec polymer, off-spec
fiber, and residual finishes
Fiber Processing
volatilized residual
monomer
solvents, additives, other
organics. volatilized finishes
water contaminated with
residual monomer, solvents,
additives, other organics
residual monomer and
solvents; off-spec fibers
Pollution Control
Systems
volatilized solvents and
unreacted monomer
water contaminated with
residual solvents and
unreacted monomer; air
stripper water
little or no residual waste
produced
Source: U.S. EPA. AP-42, Office of Air and Radiation, 1993; U.S. EPA, Best Management Practices for
Pollution Pre\'erttion in the Textile Industry, Office of Research and Development. 1995; SOCMA Pollution
Prevention Study, Prepared fen- SOCMA. Washington, DC, 1993; Randall. P.M., "Pollution Prevention
Strategies for Minimizing of Industrial Wastes in the Vinyl Chloride Monomer - Polyvinyl Chloride
Industry," in Environmental Progress, volume 13. no. 4, November 1994; AFMA, 1997: Wellinan, 1997.
Table 4 Summary of Potential releases during Plastic Resin and Manmade Fiber Manufacturing
2.3 3253 - Pesticide, Fertilizer, and Other Agricultural Chemical Manufacturing
This sector comprises establishments primarily engaged in one or more of the following: (1)
manufacturing nitrogenous or phosphatic fertilizer materials; (2) manufacturing fertilizers from sewage
or animal waste; (3) manufacturing nitrogenous or phosphatic materials and mixing with other
ingredients into fertilizers; (4) mixing ingredients made elsewhere into fertilizers; and (5) formulating
and preparing pesticides and other agricultural chemicals.
Chemical Manufacturing Industry Practices and Environmental Characterization -
18
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Within this sector, on-site land disposal in 2017 was over 45 million pounds. The largest substances
released to land by this sector listed in declining order by weight are formaldehyde, barium and barium
compounds, formic acid, nitrate compounds, ammonia and hydrogen fluoride, as shown on Figure 5,
When evaluated by subsectors within this sector, 43% of the on-site land waste is from Pesticide and
Other Agricultural Chemical Manufacturing (325320), 36% from Nitrogenous Fertilizer Manufacturing
(325311) and 20% from Phosphatic Fertilizer Manufacturing (325312),44
On-site Land Disposal by Chemical, 2017
45,296,4291b
Chemical
Others
METHANOL
CHROMIUM AND CHROMI...
ZINC AND ZINC COMPO...
HYDROGEN FLUORIDE
AMMONIA
NITRATE COMPOUNDS
25.255
FORMALDEHYDE
BARIUM AND BARIUM C...
FORMIC ACID
Figure 5 On-site Land Releases from Pesticide, Fertilizer and Other Agricultural Chemical Manufacturing
Table 5 below summarizes potential pollution outputs for the Agricultural Chemical sector. For the
fertilizer subsectors, sources of residual solid wastes include off-specification product, spills, dust
collected in emission control systems, spent catalysts, spent containers, wastewater treatment sludges
spent filters, and phosphogypsum (containing arsenic, nickel, cadmium, lead, aluminum, fluoride and
radium). Spent catalysts can contain oxides of hexavalent chromium, zinc, iron and nickel. Wastewaters
are generated in any fertilizer production facility by production processes (condensate stripping,
neutralization, nitrification, evaporation, cooling), leaks, spills, cleaning, maintenance and laboratory
tests. Cleaning of pollution control and cooling systems also produces process wastewater. Cooling
water may contain arsenic, cadmium, uranium, vanadium, radium, ammonia, sulfate, chloride,
phosphate, chromate and dissolved solids. A detailed review of wastes and emissions in this subsector
can be found in Section III.E of the EPA Profile of the Agricultural Chemical, Pesticide, and Fertilizer
44 2017 3253 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Industry.45 The national 2017 EPA RCRA BR identified over 295 thousand tons of hazardous waste
generated by this sector.46
Process
Air Emissions
Process Wastewater
Residual Waste
Nitric Acid
Absorption Tower
NO. NO;. HNOjin
tailgas
NA
Spent tower
materials, trays
Solution
Formulation and
Granulation
MI,. HNO,
particulates
Condensed steam with
NH4NO;, and NH_,
NA
Solids Formation
Particulates. NO,.
SiF4. hf
NA
Dusts
Regeneration of
Desulfurization
and Filter Beds
Hydrocarbons. CO.
NH3. CO,
C ondensed steam. NH-.
CO,
Spent bed material
Screening
Dust
NA
Mixed undersized
captured dusts, used
screens
Wet Process
Phosphoric Acid
Production
SiF+. HF
Pond water
Gypsum
Unloading of
materials into
blending tanks
Dust particulates
released in transfer
NA
Leftover raw material
containers
Open processing
and storage
equipment
VOC's
NA
NA
Equipment and
facility cleaning
NA
Wasliwater. waste
solvent
Waste sands and
clays, used inopv
squeegees etc.
Laboratory
procedures
VOC\ and dusts
released
Wasliwater. lab testing
water
Off-spec product
used for
testing analysis
Spills and runoff
Dust/particulates
released by spill
Contaminated
rainfall runoff
Contaminated solid
product
Pollution control
systems
NA
Contaminated scrubber
water
Spent filter material
S orrt c (TiuJe to Pollution Prevention, The Pesticide Formulating Jm/rsrrr, Center for
Ein i, oo^ietrn' Reseat ch Inton»i
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2.3.1 325311 - Nitrogenous Fertilizer Manufacturing
This sector comprises establishments primarily engaged in one or more of the following: (1)
manufacturing nitrogenous fertilizer materials and mixing ingredients into fertilizers; (2) manufacturing
fertilizers from sewage or animal waste; and (3) manufacturing nitrogenous materials and mixing them
into fertilizers. Releases from this subsector to land (more than 16 million pounds), are primarily barium
and barium compounds, and nitrate compounds.47 The major nitrogenous fertilizers include synthetic
ammonia, ammonium nitrate and urea. The various industrial processes used to manufacture these
products are described in Section III.A of the EPA Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry,48 as well as the production process for nitric acid, an important intermediate in
nitrogenous fertilizer production. The national 2017 EPA RCRA BR identified over 2,600 tons of
hazardous waste generated by this sub sector.49
2.3.2 325312 - Phosphatic Fertilizer Manufacturing
This Subsector comprises establishments primarily engaged in (1) manufacturing phosphatic fertilizer
materials or (2) manufacturing phosphatic materials and mixing them into fertilizers. The primary
products of this subsector are phosphoric acid, ammonium phosphate, and superphosphates.
Phosphoric acid is sold as is or used as an intermediate in producing other phosphatic fertilizers.
Releases from this subsector to land (more than 9 million pounds), are primarily hydrogen fluoride, zinc
and zinc compounds, chromium and chromium compounds, lead and lead compounds, and vanadium
and vanadium compounds.50
Industry practices in certain subsectors generate smaller amounts of hazardous wastes, including
Phosphatic Fertilizer Manufacturing (325312). The national 2017 EPA RCRA BR identified less than 1,200
tons of hazardous waste generated by this subsector51, the smallest for this sector. A detailed review of
processes in this subsector can be found in Section III.B of the EPA Profile of the Agricultural Chemical,
Pesticide, and Fertilizer Industry.52
2.3.3 325314 - Fertilizer (Mixing Only) Manufacturing
This subsector comprises establishments primarily engaged in mixing ingredients made elsewhere into
fertilizers. This subsector only purchases fertilizer materials in bulk from fertilizer manufacturing
facilities and mixes them to sell as a fertilizer formulation. The most common materials used for bulk
blending as of 1990 are shown in Table 6 below. Additional materials may also be added to the blends,
such as micronutrients and pesticides. Releases from this subsector to land (more than 16 thousand
pounds), are primarily nitrate compounds, manganese and manganese compounds.53 A detailed review
of processes in this subsector can be found in Section III.C of the EPA Profile of the Agricultural
47 2017 325311 Land TRI
48 Sector Profile EPA 310-R-00-003 of September 2000
49 2017 BR Detailed NAICS Results for National (NAICS 3253)
50 2017 325312 Land TRI
51 2017 BR Detailed NAICS Results for National (NAICS 3253)
52 Sector Profile EPA 310-R-00-003 of September 2000
53 2017 325314 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Chemical, Pesticide, and Fertilizer Industry.54 The national 2017 EPA RCRA BR identified more than 3,300
tons of hazardous waste generated by this subsector. 55
Typical Grade
n-p2o5-k2o
Percent of
fertilizer plants
using this
material
Ammonium nitrate
31-0-0
41%
Urea
46-0-0
66%
Ammonium sulfate
21-0-0
22%
Diammonium phosphate (DAP)
18-46-0
95%
Monoammonium phosphate (MAP)
11-52-0
11%
Triple Superphosphate
0-46-0
78%
Normal superphosphate
0-20-0
4%
Potassium chloride
0-0-60
94%
Source: "Retail Marketing of Fertilizers in the United States," by Hargett, Norman
and Ralph Pay, 1980.
Table 6 Fertilizer Materials used in Bulk Blends
2.3.4 325320 - Pesticide and Other Agricultural Chemical Manufacturing
This subsector comprises establishments primarily engaged in the formulation and preparation of
agricultural and household pest control chemicals (except fertilizers). This includes a variety of pesticide
products, including herbicides, insecticides, and fungicides. These facilities typically have physical
divisions between formulating and any packaging operations, and between dry and liquid operations. A
detailed review of liquid, dry and pressurized gas formulation processes in this subsector can be found in
the EPA Pollution Prevention Guidance Manual for the Pesticide Formulating, Packaging, and
Repackaging Industry56 and Section III.D of the EPA Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry.57 Releases from this subsector to land (more than 19 million pounds), are primarily
formaldehyde and formic acid.58
Residual solid wastes in this subsector include containers and container liners potentially contaminated
with pesticides, as well as off-spec product, dust collected from emissions control equipment, and
product spills. Contaminated laboratory equipment and protective workers clothing are other potential
wastes. Decontamination of pesticide blending mills may generate sand or clay contaminated with
pesticides. The national 2017 EPA RCRA BR identified over 73 thousand tons of hazardous waste
generated by this subsector.59 Wastewaters from this subsector typically contains pesticides, solvents
and wetting agents. Further details are shown in Table 6 above.
54 Sector Profile EPA 310-R-00-003 of September 2000
55 2017 BR Detailed NAICS Results for National (NAICS 3253)
56 Final report EPA-821-B-98-017 of June 1998
57 Sector Profile EPA 310-R-00-003 of September 2000
58 2017 325320 Land TRI
59 2017 BR Detailed NAICS Results for National (NAICS 3253)
Chemical Manufacturing Industry Practices and Environmental Characterization -
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2.4 3254 - Pharmaceutical and Medicine Manufacturing
Most of the equipment and the general processes used in formulating pharmaceutical preparations are
common to many other products. However, some aspects of the processing are unusual. Most products
are prepared in relatively small batches, and different products can be processed in the same
equipment. This leads to an unusual amount of cleaning of equipment prior to changing from one
product to another. Many of the process operations are conducted in separate rooms to prevent any
cross contamination of products. Quality control is more important in the formulation of pharmaceutical
preparations than it is in most other industries. Finally, inventory control is very important at all stages
of production, packaging, labeling, storage, and shipment.60 The production of pharmaceutical products
can be broken down into three main stages: 1) research and development; 2) the conversion of organic
and natural substances into bulk pharmaceutical substances or ingredients through fermentation,
extraction, and/or chemical synthesis as shown on Table 7 below; and 3) the formulation of the final
pharmaceutical product. Each step in the manufacturing process, and the identity and quality of each
ingredient used in the process, must be specified approved by the US Food and Drug Administration
(FDA).
Chemical Synthesis
Natural Product Extraction
Fermentation
Antibiotics
Antihistamines
Cardiovascular Agents
Central Nervous System (CMS)
Stimulants
CNS Depressants
Hormones
Vitamins
Antineoplastic Agents
Enzymes and Digestive Aids
CNS Depressants
Hematological Agents
Insulin
Vaccines
Antibiotics
Antineoplastic Agents
Therapeutic Nutrients
Vitamins
Steroids
Table 7 Examples of Pharmaceutical Products by Bulk Manufacturing Process
Chemical synthesis - The manufacture of pharmaceutical compounds using chemical synthesis involves
a complex series of processes including many intermediate stages and chemical reactions performed in
a step-by-step fashion. Depending on the process, the operator (or a programmed computer) adds
reagents, increases or decreases the flow rate of chilled water or steam, and starts and stops pumps to
draw the reactor contents into another vessel. At other stages in the process, solutions may be pumped
through filters or centrifuges, recycled within the process, or pumped to recycling or disposal facilities.
Co-products, such as salts, may be sold for reuse. Spent acids, metals, and catalysts may be recovered
and reused onsite or sold for reuse. It is impossible to provide a single process flow diagram for this
sector since each bulk pharmaceutical substance is different in its manufacture and several
intermediates may be produced in a step-wise fashion prior to the manufacture of the final active
ingredient. However, an example chemical synthesis process has been provided as Figure 6 to show the
equipment used and where wastes or emissions might be generated.
60 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Source: Adapted from Economic Impact and Regulatory Flexibility' Analysis of Proposed Effluent Guidelines for the
Pharmaceutical Manufacturing Industry, 1995.
Figure 6: Simplified Process Flow Diagram for Chemical Synthesis
Natural Product Extraction - Natural product extraction, as the name suggests, involves isolating an
active ingredient from natural sources, such as plants, roots, parasitic fungi or animal glands. This
process is often used to produce allergy relief medicines, insulin, morphine, anti-cancer drugs, or other
pharmaceuticals with unique properties. Blood fractionation, used to produce plasma, is also part of the
natural product extraction process. A simplified diagram of natural product extraction processes and its
associated wastes is shown in Figure 7.
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Source: Adapted from Economic Impact and Regulatory Flexibility; Analysis of Proposed Effluent Guidelines for the Pharmaceutical
Manufacturing Industry, 1995.
Figure 7: Simplified Process Flow Diagram for Natural Extraction
Active ingredients are recovered by precipitation, purification and solvent extraction methods. In
precipitation, solubility is changed by pH adjustment, salt formation, or addition of an anti-solvent.
Solvents are used as extractive agents to remove the active ingredient from the raw materials, such as
plant and animal tissues. Solvents are also used to remove fats and oils, which may contaminate the
product. Such solvents remove the fats and oils, without damaging the essential active ingredient(s)
found in the raw materials. Ammonia is also used in the extraction stages as a method of controlling the
pH when extracting from animal and plant sources. Ammonium salts are used as buffering chemicals,
and aqueous or anhydrous ammonia is used as an alkalizing agent. The high degree of solubility of
ammonium salts prevents unwanted precipitation. Also, ammonium salts have the advantage of not
reacting with animal and/or plant tissues.
Fermentation - Most steroids, antibiotics, and certain food additives (such as vitamins) are commonly
known pharmaceuticals which are produced by fermentation. In fermentation, microorganisms (e.g.,
bacteria, yeast or fungi) are typically inoculated in a liquid broth supplemented with nutrients that are
acclimated to an environment (e.g., temperature, pH, oxygen), conducive to rapid growth). These
microorganisms produce the desired product (e.g., antibiotic, steroid, vitamin, etc.) as a by-product of
normal metabolism. Fermentation involves three main steps: 1) inoculum and seed preparation, 2)
fermentation, and 3) product recovery. A diagram of a fermentation process and the wastes produced in
this process is shown in Figure 8.
Chemical Manufacturing Industry Practices and Environmental Characterization -
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Gas
^ (NO:CO-( sulfur)
Active
Ingredient
To Compounding &
Formulation
Source: Adapted from Economic Impact and Regulatory> Flexibility Analysis of Proposed Effluent Guidelines for the
Pharmaceutical Manufacturing Industry, 1995.
Figure 8: Simplified Process Flow Diagram for the Fermentation Process
Both nonhazardous and hazardous wastes are generated during pharmaceutical manufacturing. These
wastes can include off-spec or obsolete raw materials or products, spent solvents, reaction residues,
used filter media, still bottoms, used chemical reagents, dusts from filtration or air pollution control
equipment, raw material packaging wastes, laboratory wastes, spills, as well as wastes generated during
packaging of the formulated product.
The most significant waste streams are probably the aqueous wastes generated in cleaning equipment.
These wastes contain many types of biological agents. Dusting occurs in many of the process steps. Since
both air temperature and humidity must be controlled, and dust must be kept away from both workers
and other products, an elaborate air-filtration system is required, or a great deal of outside air must be
conditioned. The dust is ultimately an air contaminant, water contaminant, or solid waste. When non-
aqueous solvents are used, small amounts may be air contaminants or water contaminants from the
cleaning operations. Shipping containers in which ingredients or preformed packaging units are received
contribute to solid waste. Breakage may also contribute to solid waste.61 Filter cakes and spent raw
materials (plants, roots, animal tissues etc.) from fermentation and natural product extraction are two
61 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
26
Chemical Manufacturing Industry Practices and Environmental Characterization -
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of the largest sources of residual wastes52 in the pharmaceutical sector. Other wastes include reaction
residues and filtrates from chemical synthesis processes. These wastes may be stripped of any solvents
which remain in them, and then disposed as either hazardous or nonhazardous wastes. Typically, solid
wastes are shipped off-site for disposal or incineration.
Within this sector, on-site land disposal in 2017 was over 117 thousand pounds63. The largest substances
released to land by this sector listed in declining order by weight are N, N-dimethylformamide,
methanol, nitrate compounds, phenol, ammonia and dichloromethane, as shown on Figure 9. When
evaluated by subsectors within this sector, 85% of the on-site land waste is from Pharmaceutical
Preparation Manufacturing (325412), and 13% is from Medicinal and Botanical Manufacturing (325411).
The national 2017 EPA RCRA BR identified over 200,000 tons of hazardous waste generated by this
sector.64
On-site Land Disposal by Chemical, 2017
117,9901b
Chemical
N,N-DIMETHYLFORM.„
Figure 9 On-site Land Releases from Pharmaceutical and Medicine Manufacturing
2.4.1 325411 - Medicinal and Botanical Manufacturing
This Subsector comprises establishments primarily engaged in (1) manufacturing uncompounded
medicinal chemicals and their derivatives (i.e., generally for use by pharmaceutical preparation
manufacturers) and/or (2) grading, grinding, and milling uncompounded botanicals. Only 2% of releases
from this subsector are to land (less than 17 thousand pounds), primarily nitrate compounds and
ammonia.65 The national 2017 EPA RCRA BR identified over 94,000 tons of hazardous waste generated
by this subsector.66
62 EPA Profile of the Pharmaceutical Manufacturing Industry Sep 1997, 310/R-97-005
63 2017 3254 Land TRI
64 2017 BR Detailed NAICS Results for National (NAICS 3254)
65 2017 325411 Land TRI
66 2017 BR Detailed NAICS Results for National (NAICS 3254)
METHANOL
NITRATE COMPOUNDS
MANGANESE AND MANGANESE C...
DICHLOROMETHANE
AMMONIA
PHENOL
Chemical Manufacturing Industry Practices and Environmental Characterization -
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2.4.2 325412 - Pharmaceutical Preparation Manufacturing
This Subsector comprises establishments primarily engaged in manufacturing in-vivo diagnostic
substances and pharmaceutical preparations (except biological) intended for internal and external
consumption in dose forms, such as ampoules, tablets, capsules, vials, ointments, powders, solutions,
and suspensions. Less than 2% of releases from this subsector are to land (less than 101 thousand
pounds), primarily n,n-dimethylformamide and methanol.67 The national 2017 EPA RCRA BR identified
over 98,000 tons of hazardous waste generated by this subsector.68
2.4.3 325413 - In-Vitro Diagnostic Substance Manufacturing
This Subsector comprises establishments primarily engaged in manufacturing in-vitro (i.e., not taken
internally) diagnostic substances, such as chemical, biological, or radioactive substances. The substances
are used for diagnostic tests that are performed in test tubes, petri dishes, machines, and other
diagnostic test-type devices. Less than 3% of releases from this subsector are to land (less than 800
pounds), primarily methanol and dichloromethane.69 The national 2017 EPA RCRA BR identified over
2,300 tons of hazardous waste generated by this subsector.70
2.4.5 325414 - Biological Product (except Diagnostic) Manufacturing
This Subsector comprises establishments primarily engaged in manufacturing vaccines, toxoids, blood
fractions, and culture media of plant or animal origin (except diagnostic). No measurable releases from
this subsector are to land. The national 2017 EPA RCRA BR identified over 6,200 tons of hazardous waste
generated by this subsector.71
2.5 3255 - Paint; Coating, and Adhesive Manufacturing
This sector comprises establishments primarily engaged in one or more of the following: (1) mixing
pigments, solvents, and binders into paints and other coatings; (2) manufacturing allied paint products;
and (3) manufacturing adhesives, glues, and caulking compounds.
Within this sector, on-site land disposal in 2017 was over one thousand pounds. The largest substances
released to land by this sector listed in declining order by weight are certain glycol ethers, 3-iodo-2-
propynyl butylcarbamate, zinc and zinc compounds, ethylene glycol and l-(3-cholroallyl)-3,5,7-triaza-l-
azoniaadamantane chloride,72 as shown on Figure 10. When evaluated by subsectors within this sector,
99% of the on-site land waste is from Paint and Coating Manufacturing (325510), and 1% is from
Adhesive Manufacturing (325520). The national 2017 EPA RCRA BR identified over 104 thousand tons of
hazardous waste generated by this sector73.
67 2017 325412 Land TRI
68 2017 BR Detailed NAICS Results for National (NAICS 3254)
69 2017 325413 Land TRI
70 2017 BR Detailed NAICS Results for National (NAICS 3254)
71 2017 BR Detailed NAICS Results for National (NAICS 3254)
72 2017 3255 Land TRI
73 2017 BR Detailed NAICS Results for National (NAICS 3255)
Chemical Manufacturing Industry Practices and Environmental Characterization -
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On-site Land Disposal by Chemical, 2017
1.3781b
Chemical
H3-CHLOROALLYD-3,5,7-TRIAZ.-
13.41
ETHYLENE GLYCOL , CERTAIN GLYCOL ETHE...
ZINC AND ZINC COM POU...
3-JODO-2-PROPYNYL BUTYL CARBAMATE
Figure 10 On-site Land Releases from Paint, Coating and Adhesive Manufacturing
2.5.1 325510 - Paint and Coating Manufacturing
This sector comprises establishments primarily engaged in (1) mixing pigments, solvents, and binders
into paints and other coatings, such as stains, varnishes, lacquers, enamels, shellacs, and water-repellent
coatings for concrete and masonry, and/or (2) manufacturing allied paint products, such as putties, paint
and varnish removers, paint brush cleaners, and frit (ground glass or glaze). The Paint & Coatings sub
sector manufactures a variety of products that preserve, protect, and beautify the objects to which they
are applied. The main types of Paint & Coatings products include: architectural coatings—interior and
exterior paints, primers, sealers, and varnishes; industrial coatings—factory-applied to manufactured
goods during production; special-purpose coatings—aerosol paints, marine paints, high-performance
coatings, and automotive refinish paints; and allied paint products—putties, paint and varnish removers,
paint thinners, pigment dispersions, paint brush cleaners, and frit (ground glass or glaze).
The manufacture of paint involves the dispersion of a colored oil or pigment in a vehicle, usually an oil or
resin, followed by the addition of an organic solvent for viscosity adjustment. Only the physical
processes of weighing, mixing, grinding, tinting, thinning, and packaging take place. These processes
take place in large mixing tanks at approximately room temperature, no chemical reactions are involved.
The primary factors affecting emissions from paint manufacture are care in handling dry pigments, types
of solvents used, and mixing temperature. The manufacture of varnish also involves the mixing and
blending of various ingredients to produce a wide range of products. In this case, chemical reactions are
initiated by heating. Varnish is cooked in either open or enclosed gas-fired kettles for periods of 4 to 16
hours at temperatures of 93 to 340°C (200 to 650°F)74. Less than 1% of releases from this subsector are
to land (less than 1400 pounds), primarily certain glycol ethers, 3-iodo-2-propynyl butylcarbamate, and
zinc and zinc compounds.75
74 AP-42, Organic Chemical Process Industry, Chapter 6.4 Paint and Varnish of May 1983 accessed at
https://www3.epa.gov/ttn/chief/ap42/ch06/index.html
75 2017 325510 TRI Land
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Although lead was banned from consumer paints in the U.S. in 1978, it may still be used in some
industrial paints and coatings. Lead use by the Paint and Coating Manufacturing sector (32551) has
greatly declined over several decades, with continuing reductions in recent years. From 2007 to 2017
releases of lead and lead compounds have decreased by 18 thousand pounds (81%). This decline in lead
releases reflects efforts by several companies that have voluntarily stopped using lead or have begun
phasing it out. In 2017, 59% of all lead releases in the Paint, Coating and Adhesive Manufacturing sector
(3255) were from facilities owned by a single firm. That firm is planning to phase out lead from its
industrial paints by 2020.76
Total releases of xylene (mixed isomers), toluene, methanol, n-butyl alcohol, and 1,2,4-
trimethylbenzene have dropped by 842 thousand pounds (37%) since 2007. This is largely due to a
reduction in air releases in this sector, which decreased 42% since 2007. Wastes in this subsector can be
generated from process-related functions or from other activities, such as operation of pollution control
devices or remediation of past contamination77. The national 2017 EPA RCRA BR identified over 76
thousand tons of hazardous waste generated by this subsector.78
2.5.2 325520 - Adhesive Manufacturing
This subsector comprises establishments primarily engaged in manufacturing adhesives, glues, and
caulking compounds. Less than 1% of 2017 releases from this subsector are to land (less than 10
pounds), primarily lithium carbonate.79 Wastes from natural-base adhesives processing presents the
possibility of generating volatile material during the digestion steps. Usually there is solid waste
(unextractable portion of bones, hides, etc.). These are usually processed further into by-products such
as fertilizer. Cleanup of processing equipment may result in waterborne waste. Often the raw materials
for synthetic resin and rubber-based adhesives are manufactured at a site other than the adhesive
formulation installation. In this case the manufacturing process consists essentially of dissolution and
blending ingredients and packaging the resultant mixture. There may be volatile components of the
resins and the volatile organic solvents used present possible emissions to be controlled. If fillers such as
clay are used, particulate emissions may be a problem. Liquid waste may be generated in clean-up
operations. Wastewaters from synthetic resin and rubber-based products contain high dissolved solids,
heavy metals, total suspended solids, and hexane extractables. Specific statements for the industry are
difficult because of the very wide range of chemical compounds used as base materials and additives.
Some manufacturers produce a wide range of products while others produce only one type with
possibly several grades.80 The national 2017 EPA RCRA BR identified over 27 thousand tons of hazardous
waste generated by this subsector.81
76 TRI National Analysis 2017: Paint and Coating Manufacturing
77 2008 EPA Sector Performance Report, Paint and Coatings
78 2017 BR Detailed NAICS Results for National (NAICS 3255)
79 2017 325520 Land TRI
80 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
81 2017 BR Detailed NAICS Results for National (NAICS 3255)
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2.6 3256 - Soap, Cleaning Compound, and Toilet Preparation Manufacturing
This sector comprises establishments primarily engaged in (1) manufacturing and packaging soaps,
detergents, polishes, surface active agents, textile and leather finishing agents, and other sanitation
goods or (2) preparing, blending, compounding, and packaging toilet preparations.
Within this sector, on-site land disposal in 2017 was over 57 thousand pounds.82 The largest substances
released to land by this sector listed in declining order by weight are methanol, naphthalene, and n-
methyl-2-pyrrolidone, as shown on Figure 11. When evaluated by subsectors within this sector, 78% of
the on-site land waste is from Surface Active Agent Manufacturing (325613), and 21% is from Soap and
Other Detergent Manufacturing (325611). The national 2017 EPA RCRA BR identified over 20 thousand
tons of hazardous waste generated by this sector. 83
On-site Land Disposal by Chemical. 2617
57,668 lb
Chemical
ACRYLIC ACID
1,2,4-TRIMETHYLBENZENE
CERTAIN GLYCOL ETHE... Jk L METHANOL
N-M ETHYL-2-PYRROLI...
NAPHTHALENE
Figure 11 On-site Land Releases from Soap, Cleaning Compound, and Toilet Preparation Manufacturing
2.6.1 325611 - Soap and Other Detergent Manufacturing
This subsector comprises establishments primarily engaged in manufacturing and packaging soaps and
other detergents, such as laundry and dishwashing detergents; toothpaste gels and tooth powders; and
natural glycerin. Within this subsector, on-site land disposal in 2017 was over 12 thousand pounds. The
largest substance released to land by this subsector is n-methyl-2-pyrrolidone, more than 99% by
weight.84
All chemical processes and some of the other operations involved in making soap, production of fatty
acids, and the purification of glycerine have odors as a common air pollution problem. Blending, mixing,
drying, packaging, and other physical operations are subject to the air-pollution problems of dust
emissions. Process water is used to clean up the various pieces of equipment, therefore the wastewater
82 2017 3256 Land TRI
83 2017 BR Detailed NAICS Results for National (NAICS 3256)
84 2017 325611 Land TRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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will be mainly soap85. Most of the soap wastes would be recycled. Solid waste also results from the
packaging operations.86
For both soap and detergent processes, fabric filters are generally used to manage dust emissions and
recover raw materials. The dust emissions principally consist of detergent compounds, although some of
the particles are uncombined phosphates, sulfates and other mineral compounds. Secondary collection
equipment is used to collect fine particulates that escape from primary devices. For example, cyclonic
impingement scrubbers are often followed by mist eliminators, and dry cyclones are followed by fabric
filters or scrubber/electrostatic precipitator units. Several types of scrubbers can be used following the
cyclone collectors.87 The national 2017 EPA RCRA BR identified over 7,700 tons of hazardous waste
generated by this subsector.
2.6.2 325612 - Polish and Other Sanitation Good Manufacturing
This subsector comprises establishments primarily engaged in manufacturing and packaging polishes
and specialty cleaning preparations. Within this subsector, on-site land disposal in 2017 was over 70
pounds,88 one of the smallest in this industry. Most of the products of this subsector are prepared as
solutions, emulsions, or pastes, although some are prepared in solid form. Blending and mixing are
common operations.
Some particulate matter may also be evolved in the milling operations. Water pollution should not arise
from the actual process operations, although cleanup of spills and cleaning of equipment would
contribute to water pollution. Solid wastes would include the containers in which starting materials
were received.89 The national 2017 EPA RCRA BR identified over 1,200 tons of hazardous waste
generated by this subsector.
2.6.3 325613 - Surface Active Agent Manufacturing
This subsector comprises establishments primarily engaged in (1) manufacturing bulk surface active
agents for use as wetting agents, emulsifiers, and penetrants and/or (2) manufacturing textile and
leather finishing agents used to reduce tension or speed the drying process. "Surfactant" is a contraction
of the three words "Surface Active Agents." Surfactants are materials that lower the surface tension (or
interfacial tension) between two liquids or between a liquid and a solid. Within this subsector, on-site
land disposal in 2017 was over 43 thousand pounds. The largest substance released to land by this
subsector is methanol, followed by napthalene.90 Surfactants are routinely deposited in numerous ways
on land and into water systems, whether as part of an intended process or as industrial and household
waste. Anionic surfactants can be found in soils as the result of sludge application, wastewater
irrigation, and remediation processes. The national 2017 EPA RCRA BR identified over 8,500 tons of
hazardous waste generated by this subsector.
85 Soap and Detergent Manufacturing Point Source Development of Apr 1974
86 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
87 AP-42, Organic Chemical Process Industry, Chapter 6.8 Soap and Detergents of July 1993
88 2017 325612 LandTRI
89 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
90 2017 325613 LandTRI
Chemical Manufacturing Industry Practices and Environmental Characterization -
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2.6.4 325620 - Toilet Preparation Manufacturing
This subsector comprises establishments primarily engaged in preparing, blending, compounding, and
packaging toilet preparations, such as perfumes, shaving preparations, hair preparations, face creams,
lotions (including sunscreens), and other cosmetic preparations.
Within this subsector, there is no record of any on-site land disposal in 2017. Water, alcohol and
solvents are used for cleaning the process kettles. The wastewater includes diluted products. The
national 2017 EPA RCRA BR identified over 3,000 tons of hazardous waste generated by this subsector.91
2.7 3259 - Other Chemical Product and Preparation Manufacturing
This sector comprises establishments primarily engaged in manufacturing chemical products (except
basic chemicals; resins, synthetic rubber, cellulosic and noncellulosic fibers and filaments; pesticides,
fertilizers, and other agricultural chemicals; pharmaceuticals and medicines; paints, coatings, and
adhesives; soaps and cleaning compounds; and toilet preparations).
Within this sector, on-site land disposal in 2017 was over 10 million pounds.92 The largest weight
substances released to land by this sector listed in declining order are acetonitrile, ammonia, cyanide
compounds, methanol, acrylonitrile, acrylamide, and acetamide, as shown on Figure 12. The national
2017 EPA RCRA BR identified over 150 thousand tons of hazardous waste generated by this sector.93
When evaluated by subsectors within this sector, 97% of the TRI on-site land waste is from All Other
Miscellaneous Chemical Product and Preparation Manufacturing (325998), and 2% is from Explosives
Manufacturing (325920).
On-site Land Disposal by Chemical. 2017
10.987.277 !b
NITRATE COMPOUNDS
ACETAMIDE 1
CY ANIDE COMPOUNDS
Figure 12 On-site Land Releases from Other Chemical Product and Preparation Manufacturing
91 2017 BR Detailed NAICS Results for National (NAICS 3256)
92 2017 3259 Land TRI
93 2017 BR Detailed NAICS Results for National (NAICS 3259)
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2.7.1 325910 - Printing Ink Manufacturing
This subsector comprises establishments primarily engaged in manufacturing printing and inkjet inks
and inkjet cartridges. Within this subsector, there is no TRI record of any on-site land disposal in 2017.
Inks are liquids or pastes that contain dyes or pigments, and they are used for writing pens, printing, and
tattoos. Anti-counterfeiting inks, including gel inks, some fountain pen inks, and inks used for paper
currency, react with the cellulose in paper to produce a permanent color change. Although they are not
strictly inks, liquids used for inkjet technologies like micro circuitry fabrication and 3D printing benefit
from much of the same research used to develop more conventional inks: consistency and flow
properties, electrostatic properties, adhesion to a substrate, resistance to bleeding and spreading,
solvent compatibility properties, and resolution and stability of the resulting patterns or 3D structures.
There are four major classes of printing ink: letterpress and lithographic inks, commonly called oil or
paste inks; and flexographic and rotogravure inks, which are referred to as solvent inks. These inks vary
considerably in physical appearance, composition, method of application, and drying mechanism.
Flexographic and rotogravure inks have many elements in common with the paste inks but differ in that
they are of very low viscosity, and they almost always dry by evaporation of highly volatile solvents.
There are three general processes in the manufacture of printing inks: (1) cooking the vehicle and
adding dyes, (2) grinding of a pigment into the vehicle using a roller mill, and (3) replacing water in the
wet pigment pulp by an ink vehicle (commonly known as the flushing process). The ink "varnish" or
vehicle is generally cooked in large kettles at 200 to 600°F (93 to 315°C) for an average of 8 to 12 hours
in much the same way that regular varnish is made. Mixing of the pigment and vehicle is done in dough
mixers or in large agitated tanks. Grinding is most often carried out in 3-roller or 5-roller horizontal or
vertical mills.94
Wastes from Printing Ink Manufacturing occur in every media. Solvent vapor emissions occur in almost
every phase of manufacturing and in numerous locations throughout individual plants. The loading or
unloading of pigments and other dry solid into grinding and dispersion equipment results in dust
emission into the surrounding plant areas. The only process wastewater from ink formulation is the
water used for tub washing. Sometimes this water is recycled, and the sludge is transported to
landfills.95 Waste ink and ink sludges might contain solvent and heavy metals. Oil-based or paste inks are
generally composed of colorant or pigments (carbon black, inorganic or organic), varnish, (drying oils,
alkyd, resin-phenolic, resin-ester), drier (cobalt, manganese, or zirconium fatty acid compounds), and
sometimes an extender, solvents and modifiers (waxes, petroleum solvents and magnesia). Fluid inks
contain a vehicle made of resin and solvent or oil, and additives such as waxes, drier and wetting agents.
While not all waste inks and ink sludges are hazardous, those containing solvents or heavy metals
generally are.96 Industry practices in certain subsectors generate smaller amounts of hazardous wastes.
The national 2017 EPA RCRA BR identified less than 1,300 tons of hazardous waste generated by this
subsector.97
94 AP-42, Chapter 6.7, Printing Ink of May 1983
95 EPA Potential Environmental Impact of Compounding and Fabricating Industries, 600-2-77-160 of Aug 1977
96 Printing and Allied Industries fact sheet 530-SW-90-027G of 1990
97 2017 BR Detailed NAICS Results for National (NAICS 3259)
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2.7.2 325920 - Explosives Manufacturing
This subsector comprises establishments primarily engaged in manufacturing explosives. An explosive is
a material that, under the influence of thermal or mechanical shock, decomposes rapidly and
spontaneously with the evolution of large amounts of heat and gas. There are two major categories,
high explosives and low explosives. High explosives are further divided into initiating, or primary, high
explosives and secondary high explosives. Initiating high explosives are very sensitive and are generally
used in small quantities in detonators and percussion caps to set off larger quantities of secondary high
explosives. Secondary high explosives, chiefly nitrates, nitro compounds, and nitramines, are much less
sensitive to mechanical or thermal shock, but they explode with great violence when set off by an
initiating explosive. The chief secondary high explosives manufactured for commercial and military use
are ammonium nitrate blasting agents and 2,4,6,-trinitrotoluene (TNT). Low explosives, such as black
powder and nitrocellulose, undergo relatively slow auto combustion when set off and evolve large
volumes of gas in a definite and controllable manner. Many different types of explosives are
manufactured.98 Within this subsector, on-site land disposal in 2017 was over 270 thousand pounds. The
largest weight substances released to land by this sector are nitrate compounds, over 98% of the total."
Wastes from explosive manufacturing processes are classified as hazardous wastes and originate from
the manufacture of basic explosives, from explosives formulation, and from loading, assembly, and
packing operations. The waste water treatment sludges from processing of explosives are listed as
hazardous wastes based only on reactivity. Waste water treatment may involve filtering through
activated charcoal, photolytic degradation, and biodegradation. Waste waters generated from the
manufacturing areas are generally piped to an industrial water treatment plant on site. Following
neutralization and nutrient addition, sludge is aerobically digested and dewatered. Some explosive
chemicals are not listed on the TRI database, because they are not chemicals for which companies are
required to report discharges to environmental media.
The solid wastes associated with TNT manufacturing are scrap TNT and settled TNT sludges collected in
sumps in the TNT wash and recovery houses. The major solid waste from the production of
nitrocellulose is contaminated nitrocellulose, 1-2% of the production. Waste waters and associated
drainage and handling facilities are also sources of potential land contamination. In manufacturing RDX,
wastewaters typically contain methyl nitrate, nitromethane, methyl acetate, propyl formate, propyl
acetate and other esters and alcohol. Wastes are also generated from spillage of ingredients and final
products, off-specifications materials, and general equipment clean up.100 Primary contaminants at
some explosive manufacturing facilities have included lead, mercury, arsenic in soil and groundwater
and trichloroethene (TCE) and perchloroethylene (PCE) in groundwater. The national 2017 EPA RCRA BR
identified more than 18,000 tons of hazardous waste generated by this subsector.101
98 AP-42, Ch 6.3, Explosives of May 1983
99 2017 325290 TRI Land
100 Assessment of Industrial Hazardous Waste Practices: Organic Chemicals, Pesticides and Explosives Industries.
EPA SW118C of 1976
101 2017 BR Detailed NAICS Results for National (NAICS 3259)
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2.7.3 325991 - Custom Compounding of Purchased Resins
This subsector comprises establishments primarily engaged in (1) custom mixing and blending plastics
resins made elsewhere or (2) reformulating plastics resins from recycled plastics products. Within this
subsector, on-site land disposal in 2017 was under 3000 pounds.102 The largest weight substances
released to land by this subsector listed in declining order are antimony and antimony compounds, zinc
and zinc compounds, lead and lead compounds, and ethylbenzene. Industry practices in certain
subsectors generate smaller amounts of hazardous wastes. The national 2017 EPA RCRA BR103 identified
less than 1,300 tons of hazardous waste generated by this subsector, the smallest for this sector.
2.7.4 325992 - Photographic Film, Paper, Plate, and Chemical Manufacturing
This subsector comprises establishments primarily engaged in manufacturing sensitized film, sensitized
paper, sensitized cloth, sensitized plates, toners (i.e., for photocopiers, laser printers, and similar
electrostatic printing devices), toner cartridges, and photographic chemicals. Within this subsector, on-
site land disposal in 2017 was less than 100 pounds.104 The only substance released to land by this
subsector are silver and silver compounds. The national 2017 EPA RCRA BR identified more than 8,900
tons of hazardous waste generated by this subsector105.
2.7.5 325998 - All Other Miscellaneous Chemical Product and Preparation Manufacturing
This Subsector comprises establishments primarily engaged in manufacturing chemical products (except
basic chemicals, resins, and synthetic rubber; cellulosic and noncellulosic fibers and filaments;
pesticides, fertilizers, and other agricultural chemicals; pharmaceuticals and medicines; paints, coatings
and adhesives; soaps, cleaning compounds, and toilet preparations; printing inks; explosives; custom
compounding of purchased resins; and photographic films, papers, plates, and chemicals). Examples
included within this subsector are manufacturing of activated carbon and charcoal, antifreeze
preparations, electronic cigarette vapor refills, industrial salt, lighter fluids (e.g., charcoal, cigarette),
matches and matchbooks, pyrotechnics (e.g., flares, flashlight bombs, signals), sugar substitutes (i.e.,
synthetic sweeteners blended with other ingredients) made from purchased synthetic sweeteners,
swimming pool chemical preparations, and writing inks.
In manufacturing of activated carbon and charcoal, there are five types of products and byproducts from
charcoal manufacturing: charcoal, non-condensible gases (carbon monoxide [CO], carbon dioxide [CO ],
methane, and ethane), pyroacids (primarily acetic acid and methanol), tars and heavy oils, and water.
Except for charcoal, all these materials are emitted with the kiln exhaust.106
Antifreeze is used as freeze protection and as a heat transfer medium for motor vehicles, heavy
equipment and buildings. The most common type is made of ethylene glycol107, a material that is toxic
to humans and animals.
102 2017 325991 Land TRI
103 2017 BR Detailed NAICS Results for National (NAICS 3259)
104 2017 325992 Land TRI
105 2017 BR Detailed NAICS Results for National (NAICS 3259)
106 AP-42, Ch 10.7: Charcoal, of Sep 1995
107 Ethylene Glycol fact sheet
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Electronic cigarette vapor refills can include the chemicals propylene glycol, glycerol, nicotine,
formaldehyde, acetaldehyde, acrolein, toluene, nickel, flavorings and lead. Scientific information on the
environmental impacts of e-cigarette manufacturing and disposal is very limited. The environmental
impacts of e-cigarette manufacturing will depend upon factory size and the nicotine extracting method
used.108 Disposing of raw material (i.e., nicotine), off-spec e-liquids, container residues, and spill residues
by manufacturers requires handling as a hazardous waste.109
Industrial salt production ponds generally take salt water in by pumps and/or inlets, concentrate the
water into brines by solar evaporation in sequential basins, and use small rectangular crystallizers to
crystallize the salt. Associated residual bitterns are generally wasted or recycled back into the
production process.
Lighter fluids (e.g., charcoal, cigarette) are one consumer product historically composed entirely of
volatile constituents.110 Charcoal lighter fluid has generally been produced from petroleum. The
manufacturing of charcoal lighter fluid uses a light refined isoparaffinic hydrocarbon, a light grade of
kerosene. This substance is a clear liquid that has been highly refined to include a phase of naphtha.111
Manufacturing of matches and matchbooks is regulated by the Consumer Product Safety Act.112 Modern
matches are made with the following chemicals: ammonium phosphate and paraffin wax for wood
treatment, antimony trisulfide and potassium chlorate for the match head, animal glue for binding
ingredients, zinc oxide for coloring of the match head, sulfur, rosin, small amount of paraffin wax and
phosphorus sesquisulfide for the base of the match, water-soluble dye for coloring of the base, striking
surface with red phosphorus, powdered glass, and an adhesive (gum arabic or urea formaldehyde) for
match boxes and match books.
Management of waste pyrotechnic fireworks has received focused attention from EPA, including a
detailed memo113 and brochure114 on safe handling and treatment.
Sugar substitutes (i.e., synthetic sweeteners blended with other ingredients) are made from purchased
synthetic sweeteners. They are food additives that provide a sweet taste like that of sugar while
containing significantly less food energy than sugar-based sweeteners. Artificial sweeteners may be
derived through manufacturing of plant extracts or processed by chemical synthesis. In Dec 2010, EPA
removed saccharin from its list of hazardous substances.115
108 Chang H, Research gaps related to the environmental impacts of electronic cigarettes Tobacco Control
2014;23:ii54-ii58. accessed at httpi//dx,doi,org/10,1136/tobaccocontrol-2013-051480
109 EPA OSWER Memo of 8 May 2015, HW status of e-cigarettes.
110 EPA Estimation of Emissions from Charcoal Lighter Fluid, 600-2-90-003 of Jan 1990
111 "Barbecue charcoal lighter fluid..." accessed at https://escogoxom/charcoal-jjghter-fjuid/
112 Title 16, Chapter II, Subchapter B - Consumer Product Safety Act, Part 1202 - Safety Standard for Matchbooks
113 Memorandum on the Safe Handling, Storage and Treatment of Waste Fireworks
114 Brochure on the Safe Handling and Treatment of Waste Fireworks
115 EPA Removes Saccharin from Hazardous Substances Listing, Release Date: 12/14/2010 accessed at
https://archive.epa.gov/epapages/newsroom archive/newsreleases/ea895aIlea50a56d852577f9005e2690.html
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Swimming pool chemical preparations may become a hazard when they become wetted or when they
are improperly mixed, such as with other chemicals or reactive materials. A partial listing of pool
chemical materials includes chlorinated isocyanurate, lithium hypochlorite, sodium bicarbonate,
potassium monopersulfate, hydrogen peroxide, sodium hypochlorite, calcium hypochlorite, and certain
ammonium, brominated, copper and silver compounds, and muriatic acid. Pool chemicals involved in
fire or toxic vapor releases are likely to include those that add chlorine or a chlorine ion to the pool
water for bacterial control. Chemicals that release chlorine are among the group of chemicals that are
classified as oxidizers. These pool oxidizer chemicals include calcium hypochlorite, sodium hypochlorite,
and chlorinated isocyanurate.116
The manufacturing of writing inks can result in several waste streams.117 Water-based ink waste consists
largely of material from flushing of ink pumps and from off-specification materials being scrapped. There
are also residues from laboratory testing. The component of environmental concern in this waste is
chromium, although other heavy metals used in ink formulation may also be present. Flammable waste
ink is like the water-based stream described above except that it includes organic solvents. The major
component of environmental concern is acetone and related organic solvents. Ink spill solid wastes
consist primarily of residues from cleanup of manufacturing equipment and ink dispersing equipment as
well as some off-specification product. It also contains residues from spills including adsorbent
materials. The major components of environmental concern are heavy metals, particularly chromium.
Solvent-based ink spills solids waste is similar except that it adds solvent-based inks.
Within this subsector, on-site land disposal in 2017 was over 10 million pounds.118 The largest weight
substances released to land by this subsector listed in declining order are acetonitrile, ammonia, cyanide
compounds, methanol, acrylonitrile, acrylamide, and acetamide. The national 2017 EPA RCRA BR
identified more than 119 thousand tons of hazardous waste generated by this subsector,119 the largest
for this sector.
3. Chemical Manufacturing Accidents
Chemical spills contaminate soil and water and may cause devastating explosions and fires. Chemical
Manufacturing accidents are not generally common but occur more frequently at some sites. The
consequences and associated releases can be significant. For example, chemical manufacturing facilities
are more likely to have used Aqueous Film Forming Foam (AFFF) to suppress fire risks. This material is a
major source of Per- and Polyfluoroalkyl Substances (PFAS),120 which can lead to adverse human health
effects.121
The U.S. Chemical Safety Board (CSB) conducts root cause investigations of chemical accidents at fixed
industrial facilities. Root causes are usually deficiencies in safety management systems but can be any
116 EPA Safe Storage and Handling of Swimming Pool Chemicals of Mar 2001
117 Waste Reduction for... Manufacturer of Writing Instruments of Oct 1992.
118 2017 325998 Land TRI
119 2017 BR Detailed NAICS Results for National (NAICS 3259)
120 Interstate Technology & Regulatory Council (ITRC) PFAS Nuts and Bolts Presentation of 14 Aug 2019.
121 EPA Basic Information on PFAS accessed at httpsi//www.epa.gov/pfas/basic-information-pfas
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factor that would have prevented the accident if that factor had not occurred. Other accident causes
often involve equipment failures, human errors, unforeseen chemical reactions or other hazards. The
CSB agency does not issue fines or citations, but does make recommendations to plants, regulatory
agencies, industry organizations, and labor groups. The CSB investigated or reported on the following
incidents at Chemical Manufacturing facilities:
3.1 AB Specialty Silicones. On 3 May 2019 a massive explosion and fire occurred at the AB Specialty
Silicones facility in Waukegan, IL, killing four workers and causing extensive damage to nearby
businesses.122
3.2 KMCO Crosby. On 2 Apr 2019 a fire and explosion at the KMCO Crosby TX custom chemical
processing and specialty chemical manufacturing facility caused one fatality and multiple injuries.123
3.3 Kuraray America. An explosion at Kuraray America on 19 May 2018 injured 21 workers at the
EVAL facility in Pasadena, Texas. The facility manufactures ethylene vinyl-alcohol copolymers, sold as
EVAL. During pre-startup pressure-testing activities of a chemical reactor, an abnormal high-pressure
condition occurred and over 2,000 pounds of ethylene were released to the atmosphere from a
pressure relief valve. The ethylene vapors ignited, resulting in worker injuries. Some workers suffered
burns or were injured by jumping from heights or falling while running to escape the fire. Twenty-one
injured workers were transported to off-site medical facilities for treatment. Kuraray America is a Tokyo-
based specialty chemical manufacturer.124
3.4 Arkema. On 29 Aug 2017 flooding from Hurricane Harvey disabled the refrigeration system at the
Arkema plant in Crosby, TX, which manufactures organic peroxides. The following day people within a
1.5 mile radius were evacuated. As the trailers increased in temperature the peroxides spontaneously
combusted on August 31. Officials ignited the remaining trailers, on Sunday, September 3, 2017. Over
the course of the three fires, in excess of 350,000 pounds of organic peroxide combusted. As a result,
more than 200 residents living within 1.5 miles of the facility evacuated and could not return home for a
week. The evacuation zone was lifted on 4 Sep 2017.125
3.5 MGPI Processing. On 21 Oct 2016 a chemical release occurred at the MGPI Processing plant in
Atchison, Kansas. MGPI Processing produces distilled spirits and specialty wheat proteins and starches.
The release occurred when a chemical delivery truck, owned and operated by Harcros Chemicals, was
inadvertently connected to a tank containing incompatible material. The mixture of the two chemicals,
sulfuric acid and sodium hypochlorite (better known in its less concentrated form as bleach), produced a
cloud containing chlorine and other compounds. The plume generated by the chemical reaction led to a
122 US Chemical Safety Board Investigation accessed at httpsi//www.csb.gov/ab-specialty-silicones-llc/
123 US Chemical Safety Board Investigation accessed at httpsi//www.csb.gov/kmco-llc-fatal-fire-and-explosion-/
124 US Chemical Safety Board Investigation accessed at httpsi//www.csb.gov/kuraray-america/
125 US Chemical Safety Board Report accessed at httpsi//www.csb.gov/arkema-inc-chemical-plant-fire-/
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shelter-in-place order for thousands of residents. At least 120 employees and members of the public
sought medical attention.126
3.6 Airgas. On 28 Aug 2016 a nitrous oxide explosion occurred at the Airgas manufacturing facility in
Cantonment, Florida. The blast killed the only Airgas employee working at the facility that day and
heavily damaged the plant, halting its manufacturing of nitrous oxide indefinitely. The Airgas
Cantonment facility is one of four manufacturing plants in the United States producing nitrous oxide for
industrial facilities, hospitals, and universities. On the day of the explosion, the Airgas operator likely
began the transfer process. Under normal operating conditions, nitrous oxide is stable and can be safely
handled; however, under certain conditions it can decompose explosively. CSB investigators127 found
that a pump used to transfer nitrous oxide into a trailer heated the gas above its safe operating limit and
triggered a violent decomposition reaction. The explosion scattered large metal fragments for hundreds
of feet.
3.7 DuPont La Porte. On 15 Nov 2014 at the DuPont La Porte, Texas Chemical facility, an accident
killed four workers and injured a fifth when methyl mercaptan, a toxic chemical used in the company's
insecticide and fungicide manufacturing process, was released128. Nearly 24,000 pounds of deadly
methyl mercaptan escaped through two valves in a poorly ventilated manufacturing building at DuPont's
La Porte facility. For several days leading to the incident, operations personnel attempted to clear
blocked piping outside of the manufacturing building. In response to what personnel believed was a
routine, unrelated pressure problem, two workers went to drain liquid from piping inside the
manufacturing building. Unfortunately, the pressure problem was related to the clearing activities.
Liquid methyl mercaptan drained from the piping, filling the manufacturing building with toxic vapor.
Although one of the workers made a distress call, both died, unable to escape from the building. Four
additional operators responded to the distress call and entered the manufacturing building. Two of
those workers succumbed to the toxic vapor, while two others survived. The CSB report stated
"although this facility has since been closed, the incident offers important lessons for the chemical
industry, relating to the following areas: - Emergency Response: The emergency response efforts at the
La Porte facility were disorganized and placed operators, emergency responders, and potentially the
public at risk. Chemical plants need a robust emergency response program to mitigate emergencies and
protect the health of workers, emergency responders, and the public."
3.8 William Olefins. On 13 Jun 2013 a fi re and explosion occurred which fatally injured two workers
at the William Olefins, Inc., plant located in Geismar, Louisiana. The facility produces ethylene and
propylene for the petrochemical industry. The incident occurred during nonroutine operational activities
that introduced heat to a type of heat exchanger called a "reboiler" which was offline, creating an
overpressure event while the vessel was isolated from its pressure relief device. The introduced heat
increased the temperature of the liquid propane mixture confined within the reboiler shell, resulting in a
dramatic pressure rise within the vessel due to liquid thermal expansion. The reboiler shell
126 US Chemical Safety Board Report accessed at https://www.csb.gov/mgpi-processing-inc-toxic-chemicaj-rejease-
L
127 US Chemical Safety Board Report accessed at https://www.csb.gov/airgas-facility-fatal-explosion-/
128 US Chemical Safety Board Report accessed at https://www.csb.g0v/assets/l/6/dupont laporte final report,pdf
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catastrophically ruptured, causing a boiling liquid expanding vapor explosion and fire. A Williams
operator working near the propylene fractionator at the time of the explosion died at the scene. The
operations supervisor succumbed to severe burn injuries the next day. The explosion and fire also
injured Williams employees and contractors who were working on a Williams facility expansion
project—167 personnel reported injuries.14 The fire lasted approximately 3.5 hours, and Williams
reported releasing over 30,000 pounds of flammable hydrocarbons during the incident.15 The plant
remained down for 18 months and restarted in January 2015.129
3.9 US Ink. On 9 Oct 2012 a combustible dust explosion and fire occurred at US Ink in East Rutherford,
NJ. The flash fire that burned seven workers, one seriously, resulted from the accumulation of
combustible dust inside a poorly designed dust collection system that had been put into operation only
four days before the accident130. U.S. Ink manufactures black and color-based inks at seven U.S.
locations including East Rutherford. A key step in the ink production process is mixing fine particulate
solids, such as pigments and binders, with liquid oils in agitated tanks.
3.10 Carbide Industries. On 21 Mar 2011 during calcium carbide production at the Carbide Industries
plant in Louisville, KY, an electric arc furnace exploded, ejecting solid and powdered debris, flammable
gases, and molten calcium carbide at temperatures near 3800°F (2100°C). Two workers died and two
others were injured131. Carbide Industries, LLC produces calcium carbide for the iron and steel industry
and to acetylene producers.
3.11 DuPont Buffalo. On 9 Nov 2010 two contractors were performing welding atop a 10,000 gallon
slurry tank at the E. I. DuPont De Nemours Co. Buffalo, NY facility when hot sparks ignited flammable
vapors inside the tank, causing an explosion that killed one contractor and seriously injured another.132
3.12 DuPont Belle. On 23 Jan 2010 there was a release of highly toxic phosgene, exposing a veteran
operator at the DuPont facility in Belle, West Virginia and resulting in his death one day later. DuPont
officials told the CSB that a braided steel hose connected to a one-ton capacity phosgene tank suddenly
ruptured, releasing phosgene into the air. An operator who was exposed to the chemical was
transported to the hospital, where he died the following day. The phosgene release followed two other
accidents at the same plant in the same week, including an ongoing release of chloromethane from the
plant's F3455 unit, which went undetected for several days, and a release from a spent sulfuric acid
unit133. The CSB is also investigating a November 2010 accident at the Dupont facility outside Buffalo,
NY, that fatally injured one worker.
129 US Chemical Safety Board Report accessed at httpsi//www.csb.gov/williams-olefins-plant-explosion-and-fire-/
130 US Chemical Safety Board Report accessed at https://wwwxsb.gov/us-ink-fjre/
131 US Chemical Safety Board Report accessed at https://wwwxsb.gov/carbide-industries-fire-explosion/
132 US Chemical Safety Board Report accessed at https://wwwxsb.gov/e-i-dupont-de-nemours-co-fatal-hotwork-
explosjon/
133 US Chemical Safety Board Report accessed at https://wwwxsb.gov/dupont-corporation-toxic-chemical-
releases/
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3.13 Goodyear Tire and Rubber. On 11 Jun 2008 one worker at the Goodyear Tire and Rubber plant
in Houston was killed and approximately seven others were injured. An overpressure in a heat
exchanger led to a violent rupture of the exchanger, hurtling debris that struck and killed a Goodyear
employee walking through the area. The heat exchanger contained pressurized anhydrous ammonia, a
colorless, toxic chemical, used as a coolant in the production of synthetic rubber; five workers were
exposed to ammonia released by the rupture.134
3.14 Bayer CropScience. On 28 Aug 2008 two workers were killed and eight others injured when a
waste tank containing the pesticide methomyl violently exploded, damaging a process unit at the Bayer
CropScience chemical plant in Institute, West Virginia. A runaway chemical reaction occurred inside a
4,500 gallon pressure vessel known as a residue treater, causing the vessel to explode violently in the
methomyl unit. Highly flammable solvent sprayed from the vessel and immediately ignited, causing an
intense fire that burned for more than 4 hours. The fire was contained inside the Methomyl-Larvin
insecticide unit by the Bayer CropScience fire brigade with mutual aid assistance from local volunteer
and municipal fire departments. The Kanawha-Putnam County Emergency Management Director
advised more than 40,000 residents, including the resident students at the West Virginia State
University adjacent to the facility, to shelter-in-place for more than three hours as a precaution. The fire
and drifting smoke forced the state police and local law enforcement authorities to close roads near the
facility and the interstate highway, which disrupted traffic for hours.135
3.15 INDSPEC Chemical. On 11 Oct 2008 a transfer operation overflowed an oleum process tank,
filling a vent system and releasing the oleum into a storage building at INDSPEC Chemical Corporation in
Petrolia, PA. Oleum, also known as fuming sulfuric acid, was released when a tank transfer operation
was left unattended during weekend operations and an oleum storage tank overflowed. The oleum
formed a toxic sulfur trioxide gas, which mixed with moisture in the air to form a dense, corrosive,
sulfuric acid cloud that threatened the neighboring towns. Plant personnel evacuated the facility, while
emergency responders evacuated about 2,500 residents from the towns of Petrolia, Bruin, and Fairview.
Owned by the Occidental Petroleum Corporation and located approximately 50 miles northeast of
Pittsburgh, the INDSPEC facility produces resorcinol, a chemical used for making tires and other
products.136
3.16 T2 Laboratories. On 19 Dec 2007 a powerful explosion and subsequent chemical fire killed four
employees and destroyed T2 Laboratories, Inc., a chemical manufacturer in Jacksonville, Florida. It
injured 32, including four employees and 28 members of the public who were working in surrounding
businesses. Debris from the reactor was found up to one mile away, and the explosion damaged
buildings within one quarter mile of the facility. The event occurred during the production of a gasoline
additive called methylcyclopentadienyl manganese tricarbonyl.137
134 US Chemical Safety Board Report accessed at httpsi//www.csb.gov/goodyear-heat-exchanger-rupture/
135 US Chemical Safety Board Report accessed at https://www.csb.gov/baver-cropscience-pestjcjde-yyaste-tank-
explosjon/
136 US Chemical Safety Board Report accessed at https://www.csb.gov/indspec-chemical-corporation-oleum-
release/
137 US Chemical Safety Board Report accessed at https://www.csb.gov/t2-laboratories-inc-reactive-chemical-
explosion/
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