Chemical Industry Releases

Organic Chemical Industry
Sector Notebook Project EPA/310-R-02-001
EPA Office of Compliance Sector Notebook Project
Profile of the Organic Chemical Industry 2nd Edition
November 2002
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (MC 2224-A)
Washington, DC 20460
Sector Notebook Project
This report is one in a series of volumes published by the U.S. Environmental Protection Agency (EPA) to provide information of general interest regarding environmental issues associated with specific industrial sectors. The documents were developed under contract by Abt Associates (Cambridge, MA), GeoLogics Corporation (Alexandria, VA), Science Applications International Corporation (McLean, VA), and Booz-Allen & Hamilton, Inc. (McLean, VA). A listing of available Sector Notebooks is included on the following page. Obtaining copies: Electronic versions of all sector notebooks are available on the EPAs website at: www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/. Purchase printed bound copies from the Government Printing Office (GPO) by consulting the order form at the back of this document or order via the Internet by visiting the U.S. Government Online Bookstore at: http://bookstore.gpo.gov/. Search using the exact title of the document Profile of the XXXX Industry or simply Sector Notebook. When ordering, use the GPO document number found in the order form at the back of this document. A limited number of complimentary volumes are available to certain groups or subscribers, including public and academic libraries; federal, state, tribal, and local governments; and the media from EPAs National Service Center for Environmental Publications at (800) 490-9198 or www.epa.gov/ncepihom. When ordering, use the EPA publication number found on the following page. The Sector Notebooks were developed by the EPAs Office of Compliance. Direct general questions about the Sector Notebook Project to: Coordinator, Sector Notebook Project US EPA Office of Compliance 1200 Pennsylvania Ave., NW (2224-A) Washington, DC 20460 (202) 564-2310 For further information, and for answers to questions pertaining to these documents, please refer to the contacts listed on the following page.
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AVAILABLE SECTOR NOTEBOOKS

Questions and comments regarding the individual documents should be directed to Compliance Assistance and Sector Programs Division at 202 564-2310 unless otherwise noted below. See the Notebook web page at: http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/ for the most recent titles and links to refreshed data.
EPA Publication Number

EPA/310-R-95-001. EPA/310-R-95-002. EPA/310-R-95-003. EPA/310-R-95-004. EPA/310-R-95-005. EPA/310-R-95-006. EPA/310-R-95-007. EPA/310-R-95-008. EPA/310-R-95-009. EPA/310-R-95-010. EPA/310-R-95-011. EPA/310-R-02-001. EPA/310-R-95-013. EPA/310-R-95-014. EPA/310-R-02-002. EPA/310-R-95-016. EPA/310-R-95-017. EPA/310-R-95-018. EPA/310-R-97-001. EPA/310-R-97-002. EPA/310-R-97-003. EPA/310-R-97-004. EPA/310-R-97-005. EPA/310-R-97-006. EPA/310-R-97-007. EPA/310-R-97-008. EPA/310-R-97-009. EPA/310-R-97-010. EPA/310-R-98-001. EPA/310-R-00-001. EPA/310-R-00-002. EPA/310-R-00-003. EPA/310-R-00-004. EPA/310-R-99-001.
Industry
Profile of the Dry Cleaning Industry
Profile of the Electronics and Computer Industry*
Profile of the Wood Furniture and Fixtures Industry
Profile of the Inorganic Chemical Industry*
Profile of the Iron and Steel Industry
Profile of the Lumber and Wood Products Industry
Profile of the Fabricated Metal Products Industry*
Profile of the Metal Mining Industry
Profile of the Motor Vehicle Assembly Industry
Profile of the Nonferrous Metals Industry
Profile of the Non-Fuel, Non-Metal Mining Industry
Profile of the Organic Chemical Industry, 2nd Edition*
Profile of the Petroleum Refining Industry
Profile of the Printing Industry
Profile of the Pulp and Paper Industry, 2nd Edition
Profile of the Rubber and Plastic Industry
Profile of the Stone, Clay, Glass, and Concrete Ind.
Profile of the Transportation Equipment Cleaning Ind.
Profile of the Air Transportation Industry
Profile of the Ground Transportation Industry
Profile of the Water Transportation Industry
Profile of the Metal Casting Industry
Profile of the Pharmaceuticals Industry
Profile of the Plastic Resin and Man-made Fiber Ind.
Profile of the Fossil Fuel Electric Power Generation Industry
Profile of the Shipbuilding and Repair Industry
Profile of the Textile Industry
Sector Notebook Data Refresh-1997 **
Profile of the Aerospace Industry
Profile of the Agricultural Crop Production Industry
Contact: Ag Center, (888) 663-2155
Profile of the Agricultural Livestock Production Industry
Contact: Ag Center, (888) 663-2155
Profile of the Agricultural Chemical, Pesticide and Fertilizer Industry
Contact: Agriculture Division, 202 564-2320
Profile of the Oil and Gas Extraction Industry
Government Series Profile of Local Government Operations
* Spanish translations available of 1st Editions in electronic format only. ** This document revises compliance, enforcement, and toxic release inventory data for all previously published
profiles. Visit the Sector Notebook web page to access the most current data.
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DISCLAIMER
This Sector Notebook was created for employees of the U.S. Environmental Protection Agency (EPA) and the general public for informational purposes only. This document has been extensively reviewed by experts from both inside and outside the EPA, but its contents do not necessarily reflect the views or policies of EPA or any other organization mentioned within. Mention of trade names or commercial products or events does not constitute endorsement or recommendation for use. In addition, these documents are not intended and cannot be relied upon to create any rights, substantive or procedural, enforceable by any party in litigation with the United States.
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Organic Chemical Industry (SIC 2861, 2865, and 2869) TABLE OF CONTENTS
LIST OF ACRONYMS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viii
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT . . . . . . . . . . . . . . . . . . . 1
A. Summary of the Sector Notebook Project . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
B. Additional Information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
INTRODUCTION TO THE ORGANIC CHEMICALS INDUSTRY . . . . . . . . . . . . . . . 3
A. Introduction, Background, and Scope of the Notebook . . . . . . . . . . . . . . . . . . . . . . . . 3
B. Characterization of the Organic Chemicals Industry . . . . . . . . . . . . . . . . . . . . . . . . . . 5
1. Product Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
2. Industry Size and Geographic Distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
3. Economic Trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
INDUSTRIAL PROCESS DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
A. Industrial Processes in the Organic Chemicals Industry . . . . . . . . . . . . . . . . . . . . . . 11
1. Chemical Manufacturing Processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
2. Common Chemical Reactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3. Common Organic Chemical Production Chains . . . . . . . . . . . . . . . . . . . . . . . 15
B. Raw Material Inputs and Pollution Outputs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE . . . . . . 24
A. EPA Toxic Release Inventory for the Organic Chemicals Industry . . . . . . . . . . . . . 27
B. Summary of Selected Chemicals Released . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40
C. Other Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
D. Comparison of Toxic Release Inventory Between Selected Industries . . . . . . . . . . . 45
POLLUTION PREVENTION OPPORTUNITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 49
SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS . . . . 68
A. General Description of Major Statutes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68
B. Industry Specific Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84
C. Pending and Proposed Regulatory Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . 94
II.
III.
IV.
V. VI.
VII. COMPLIANCE AND ENFORCEMENT PROFILE . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

A. Organic Chemicals Compliance History . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 101
B. Comparison of Enforcement Activity Between Selected Industries . . . . . . . . . . . . 103
C. Review of Major Legal Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
1. Review of Major Cases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 108
2. Supplementary Environmental Projects (SEPs) . . . . . . . . . . . . . . . . . . . . . . 111
Sector Notebook Project v November 2002
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . 117

A. Sector-related Environmental Programs and Activities . . . . . . . . . . . . . . . . . . . . . . 117
B. EPA Voluntary Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 119
C. Trade Association/Industry Sponsored Activity . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
1. Environmental Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
2. Summary of Trade Associations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 127
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 133
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LIST OF FIGURES
Figure 1: Annual Volume and Value of Common Organic Chemicals . . . . . . . . . . . . . . . . . . . . . 7
Figure 2: Geographic Distribution of U.S. Organic Chemical Manufacturing Facilities . . . . . . . 8
Figure 3: Organic Chemicals and Building Blocks Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . 15
Figure 4: Ethylene Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
Figure 5: Propylene Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
Figure 6: Benzene Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Figure 7: 2000 Summary of TRI Releases and Transfers by Industry . . . . . . . . . . . . . . . . . . . . 47
LIST OF TABLES
Table 1: Structure of the Chemical Industry (SIC 28) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
Table 2: SIC and NAICS Codes for the Organic Chemicals Industry . . . . . . . . . . . . . . . . . . . . . . 4
Table 3: Summary of Major Organic Chemical Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
Table 4: Facility Size Distribution of Organic Chemical Facilities . . . . . . . . . . . . . . . . . . . . . . . 8
Table 5: Top 20 U.S. Chemical Producers in 2001 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
Table 6: Distribution of Uses for Ethylene . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Table 7: Distribution of Propylene Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
Table 8: Distribution of Benzene Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
Table 9: Potential Releases During Organic Chemical Manufacturing . . . . . . . . . . . . . . . . . . . . 23
Table 10: 2000 TRI Releases for Organic Chemical Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . 29
Table 11: 2000 TRI Transfers for Organic Chemical Facilities . . . . . . . . . . . . . . . . . . . . . . . . . 35
Table 12: Ten Largest Volume TRI Releasing Facilities in the Organic Chemicals Industry . . 40
Table 13: Air Pollutant Releases by Industry Sector (tons/year) . . . . . . . . . . . . . . . . . . . . . . . . 45
Table 14: Toxics Release Inventory Data for Selected Industries . . . . . . . . . . . . . . . . . . . . . . . . 48
Table 15: Pollution Prevention Activities Can Reduce Costs . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
Table 16: Process/Product Modifications Create Pollution Prevention Opportunities . . . . . . . . 52
Table 17: Modifications to Equipment Can Also Prevent Pollution . . . . . . . . . . . . . . . . . . . . . . 61
Table 18: Five-Year Enforcement and Compliance Summary for the Organic Chemicals
Industry, by Region . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 102
Table 19: Five-Year Enforcement and Compliance Summary for Selected Industries . . . . . . 104
Table 20: Two-Year Enforcement and Compliance Summary for Selected Industries . . . . . . . 105
Table 21: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries106
Table 22: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries 107
Table 23: FY 1995-1999 Supplemental Environmental Projects Overview . . . . . . . . . . . . . . . 113
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LIST OF ACRONYMS
AFS AIRS AOR BAT BCT BIFs BMP BOD BPT CAA CAAA CERCLA CERCLIS CFCs CFR CGP CO CO2 COD CSI CWA CZMA D&B DOC DPCC EIS EPA EPCRA ESA FIFRA FINDS FR FRP HAPs HSDB HSWA IDEA LDR LEPCs MACT MCLGs MCLs MEK AIRS Facility Subsystem (CAA database)
Aerometric Information Retrieval System (CAA database)
Area of Review (SDWA)
Best Available Technology Economically Achievable
Best Conventional Pollutant Control Technology
Boilers and Industrial Furnaces (RCRA)
Best Management Practice
Biochemical Oxygen Demand
Best Practicable Technology Currently Available
Clean Air Act
Clean Air Act Amendments of 1990
Comprehensive Environmental Response, Compensation and Liability Act
CERCLA Information System
Chlorofluorocarbons
Code of Federal Regulations
Construction General Permit (CWA)
Carbon Monoxide
Carbon Dioxide
Chemical Oxygen Demand
Common Sense Initiative
Clean Water Act
Coastal Zone Management Act
Dun and Bradstreet Marketing Index
United States Department of Commerce
Discharge Prevention, Containment and Countermeasures
Environmental Impact Statement
United States Environmental Protection Agency
Emergency Planning and Community Right-to-Know Act
Endangered Species Act
Federal Insecticide, Fungicide, and Rodenticide Act
Facility Indexing System
Federal Register
Facility Response Plan
Hazardous Air Pollutants (CAA)
Hazardous Substances Data Bank
Hazardous and Solid Waste Amendments
Integrated Data for Enforcement Analysis
Land Disposal Restrictions (RCRA)
Local Emergency Planning Committees
Maximum Achievable Control Technology (CAA)
Maximum Contaminant Level Goals
Maximum Contaminant Levels
Methyl Ethyl Ketone
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Organic Chemical Industry MSDSs MSGP NAAQS NAFTA NAICS NCDB NCP NEC NEIC NEPA NESHAP NICE3 NO2 NOI NOT NOV NOx NPDES NPL NRC NSPS OAQPS OAR OECA OMB OPA OPPTS OSHA OSW OSWER OW P2 PCS PM10 PMN POTW PSD PT RCRA RCRIS RQ SARA SDWA SEPs SERCs SIC
Material Safety Data Sheets

Multi-Sector General Permit (CWA)
National Ambient Air Quality Standards (CAA)
North American Free Trade Agreement
North Americal Industrial Classification System
National Compliance Database (for TSCA, FIFRA, EPCRA)
National Oil and Hazardous Substances Pollution Contingency Plan
Not Elsewhere Classified
National Enforcement Investigations Center
National Environmental Policy Act
National Emission Standards for Hazardous Air Pollutants
National Industrial Competitiveness Through Energy, Environment and Economics
Nitrogen Dioxide
Notice of Intent
Notice of Termination
Notice of Violation
Nitrogen Oxides
National Pollution Discharge Elimination System (CWA)
National Priorities List
National Response Center
New Source Performance Standards (CAA)
Office of Air Quality Planning and Standards
Office of Air and Radiation
Office of Enforcement and Compliance Assurance
Office of Management and Budget
Oil Pollution Act
Office of Prevention, Pesticides, and Toxic Substances
Occupational Safety and Health Administration
Office of Solid Waste
Office of Solid Waste and Emergency Response
Office of Water
Pollution Prevention
Permit Compliance System (CWA Database)
Particulate Matter of 10 microns or less
Premanufacture Notice
Publicly Owned Treatments Works
Prevention of Significant Deterioration (CAA)
Total Particulates
Resource Conservation and Recovery Act
RCRA Information System
Reportable Quantity (CERCLA)
Superfund Amendments and Reauthorization Act
Safe Drinking Water Act
Supplementary Environmental Projects
State Emergency Response Commissions
Standard Industrial Classification
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Organic Chemical Industry SIP SO2 SOx SOCMI SPCC STEP SWPPP TOC TRI TRIS TCRIS TSCA TSD TSP TSS UIC USDW UST VOCs State Implementation Plan
Sulfur Dioxide
Sulfur Oxides
Synthetic Organic Chemical Manufacturing Industry
Spill Prevention Control and Countermeasures
Strategies for Todays Environmental Partnership
Storm Water Pollution Prevention Plan (CWA)
Total Organic Carbon
Toxic Release Inventory
Toxic Release Inventory System
Toxic Chemical Release Inventory System
Toxic Substances Control Act
Treatment Storage and Disposal
Total Suspended Particulates
Total Suspended Solids
Underground Injection Control (SDWA)
Underground Sources of Drinking Water (SDWA)
Underground Storage Tanks (RCRA)
Volatile Organic Compounds
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Organic Chemical Industry I.
INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. Summary of the Sector Notebook Project Environmental policies based upon comprehensive analysis of air, water and land pollution (such as economic sector, and community-based approaches) are an important supplement to traditional single-media approaches to environmental protection. Environmental regulatory agencies are beginning to embrace comprehensive, multi-statute solutions to facility permitting, compliance assurance, education/outreach, research, and regulatory development issues. The central concepts driving the new policy direction are that pollutant releases to each environmental medium (air, water and land) affect each other, and that environmental strategies must actively identify and address these interrelationships by designing policies for the whole facility. One way to achieve a whole facility focus is to design environmental policies for similar industrial facilities. By doing so, environmental concerns that are common to the manufacturing of similar products can be addressed in a comprehensive manner. Recognition of the need to develop the industrial sector-based approach within the EPA Office of Compliance led to the creation of this document. The Sector Notebook Project was initiated by the Office of Compliance within the Office of Enforcement and Compliance Assurance (OECA) to provide its staff and managers with summary information for eighteen specific industrial sectors. As other EPA offices, states, the regulated community, environmental groups, and the public became interested in this project, the scope of the original project was expanded. The ability to design comprehensive, common sense environmental protection measures for specific industries is dependent on knowledge of several interrelated topics. For the purposes of this project, the key elements chosen for inclusion are: general industry information (economic and geographic); a description of industrial processes; pollution outputs; pollution prevention opportunities; federal statutory and regulatory framework; compliance history; and a description of partnerships that have been formed between regulatory agencies, the regulated community and the public. For any given industry, each topic listed above could alone be the subject of a lengthy volume. However, in order to produce a manageable document, this project focuses on providing summary information for each topic. This format provides the reader with a synopsis of each issue, and references where more in-depth information is available. Text within each profile was researched from a variety of sources, and was usually condensed from more detailed sources pertaining to specific topics. This approach allows for a wide coverage of activities that can be further explored based upon the references listed at the end of this profile. As a check on the information Sector Notebook Project 1 November 2002
included, each notebook went through an external document review process. The Office of Compliance appreciates the efforts of all those that participated in this process and enabled us to develop more complete, accurate and up-todate summaries. Many of those who reviewed this notebook are listed as contacts in Section IX and may be sources of additional information. The individuals and groups on this list do not necessarily concur with all statements within this notebook. I.B. Additional Information Providing Comments OECAs Office of Compliance plans to periodically review and update the notebooks and will make these updates available both in hard copy and electronically. If you have any comments on the existing notebook, or if you would like to provide additional information, please send a hard copy and computer disk to the EPA Office of Compliance, Sector Notebook Project (2224-A), 1200 Pennsylvania Ave., NW, Washington, DC 20460. Comments can also be sent via the Sector Notebooks web page at: http://www.epa.gov/compliance/resources/publications/assistance/sectors/ notebooks/. If you are interested in assisting in the development of new Notebooks, or if you have recommendations on which sectors should have a Notebook, please contact the Office of Compliance at 202-564-2310. Adapting Notebooks to Particular Needs The scope of the industry sector described in this notebook approximates the national occurrence of facility types within the sector. In many instances, industries within specific geographic regions or states may have unique characteristics that are not fully captured in these profiles. The Office of Compliance encourages state and local environmental agencies and other groups to supplement or re-package the information included in this notebook to include more specific industrial and regulatory information that may be available. Additionally, interested states may want to supplement the Summary of Applicable Federal Statutes and Regulations section with state and local requirements. Compliance or technical assistance providers may also want to develop the Pollution Prevention section in more detail.
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Organic Chemical Industry II.
Introduction, Background, and Scope
INTRODUCTION TO THE ORGANIC CHEMICALS INDUSTRY This section provides background information on the size, geographic distribution, employment, production, sales, and economic condition of the organic chemical industry. The type of facilities described within the document are also described in terms of their Standard Industrial Classification (SIC) codes.
II.A. Introduction, Background, and Scope of the Notebook The chemical manufacturing industry (SIC 28) produces an enormous number of materials. EPA estimates that there are 15,000 chemicals manufactured in the U.S. in quantities greater than 10,000 pounds (EPA, 2002). The organic chemicals industry, which manufactures carboncontaining chemicals, accounts for much of this diversity. The general structure of the chemical industry is displayed in Table 1. The organic and inorganic chemicals industries obtain raw materials (from petroleum and mined products, respectively) and convert them to intermediate materials or basic finished chemicals. The remaining industries in SIC 28 convert intermediate materials into a spectrum of specialized finished products. Table 1: Structure of the Chemical Industry (SIC 28) SIC Code 281 282 283 284 285 286 287 289 Industry Sector Inorganic chemicals Plastics materials and synthetics Drugs Soaps, cleaners, and toilet goods Paints and allied products Organic chemicals Agricultural chemicals Miscellaneous chemical products
This sector notebook addresses the organic chemicals industry (SIC 286). The industry is divided into three categories: gum and wood chemicals, cyclic organic crudes & intermediates, and industrial organic chemicals not elsewhere classified.
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Gum and wood chemicals (SIC 2861) are materials that are distilled or otherwise separated from wood. The most common products of the industry are charcoal, tall oil, rosin, turpentine, pine tar, acetic acid, and methanol. Because the products are wood-based, many of the major producers are in the pulp and paper industry (Kline & Co., 1999). Cyclic organic crudes and intermediates (SIC 2865) are materials processed from petroleum, natural gas, and coal. Important products include benzene, toluene, xylene, and naphthalene. Typically these products are consumed by downstream industries included in Table 1. Manufacturers of synthetic dyes and organic pigments also are included in this SIC code (U.S. Department of Labor, 2001). Industrial organic chemicals, not elsewhere classified (SIC 2869) is by far the largest and most diverse component of the organic chemicals industry. Its products may be either intermediates or end products. SIC codes were established by the Office of Management and Budget (OMB) to track the flow of goods and services within the economy. OMB has changed the SIC code system to a system based on similar production processes called the North American Industrial Classification System (NAICS). Because most of the data presented in this notebook apply to the organic chemicals industry as defined by its SIC codes, this notebook continues to use the SIC system to define this sector. Table 2 presents the SIC codes for the organic chemistry industry and the corresponding NAICS codes. Table 2: SIC and NAICS Codes for the Organic Chemicals Industry
1987 SIC 2861 2865 SIC Description Gum & wood chemicals Cyclic crudes & intermediate 1997 NAICS 325191 325110 325132 325192 2869 Industrial organic chemicals, not elsewhere classified 325110 325120 325188 325193 325199
Source: U.S. Census Bureau, 2000.
NAICS Description Gum & wood chemical mfg Petrochemical mfg (part) Synthetic organic dye & pigment mfg Cyclic crude & intermediate mfg Petrochemical mfg (part) Industrial gas mfg (part) All other basic inorganic chemical mfg (part) Ethyl alcohol mfg All other basic organic chemical mfg (part)
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II.B. Characterization of the Organic Chemicals Industry II.B.1. Product Characterization The chemical industry produces many materials that are essential to the economy and to modern life: plastics, pharmaceuticals, and agricultural chemicals are some examples. Although these end products have very different characteristics, they are created from a relatively small number of raw materials. The organic chemicals industry, as described in this notebook, converts these raw materials into intermediate materials that are necessary to create desired end products. The industrial organic chemical market has two broadly defined categories: commodity and specialty. Commodity chemical manufacturers compete on price and produce large volumes of small sets of chemicals using dedicated equipment with continuous and efficient processing. Specialty chemical manufacturers cater to custom markets, manufacture a diverse set of chemicals, use two or three different reaction steps to produce a product, tend to use batch processes, compete on technological expertise and have a greater value added to their products. Commodity chemical manufacturers have lower labor requirements per volume and require less professional labor per volume. Common inputs, or feedstocks, for the industry are supplied by petroleum refiners: ethylene, propylene, benzene, methanol, toluene, xylene, butadiene, and butylene (Szmant, 1989). As noted previously, other feedstocks come from coal, natural gas, and wood. By using several processes outlined in Section III, a range of chemicals are produced from these feedstocks. Table 3 presents common categories of products and their typical end uses.
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Table 3: Summary of Major Organic Chemical Products Category Aliphatic and other acyclic organic chemicals Solvents Example Chemicals Ethylene, butylene, and formaldehyde Butyl alcohol, ethyl acetate, ethylene glycol ether, perchloroethylene Ethylene glycol, sorbitol, synthetic glycerin Saccharin, citronellal, synthetic vanillin Thiuram, hexamethylene tetramine Phosphoric acid, phthalic anhydride, and stearic acid Naphthalene sulfonic acid condensates Tear gas, phosgene Allyl alcohol, diallyl maleate Example End Uses Polyethylene plastic, plywood Degreasers, dry cleaning fluid Antifreeze, soaps Food flavoring, cleaning product scents Tires, adhesives
Polyhydric alcohols Synthetic perfume and flavoring materials Rubber processing chemicals
Plasticizers Synthetic tanning agents Chemical warfare gases Esters and/or amines of polyhydric alcohols and fatty and other acids Cyclic crudes and intermediates Cyclic dyes and organic pigments Natural gum and wood chemicals
Rain coats, inflatable toys Leather coats and shoes Military and law enforcement Paints, electrical coatings
Benzene, toluene, mixed xylenes, naphthalene Nitro dyes, organic paint pigments Methanol, acetic acid, rosin
Eyeglasses, foams Fabric and plastic coloring Latex, adhesives
Sources: U.S. Department of Labor, 2001; American Chemistry Council, 2001.
On a volume basis, intermediate chemicals (chemicals that are subsequently processed into final products) represent the majority of the production in the organic chemicals industry. Figure 1 presents the annual production rate in 1998 of the ten most-produced intermediate chemicals in the U.S. The value of these shipments also are presented. These selected chemicals account for roughly 60% of the production volume of intermediates. Sector Notebook Project 6 November 2002
Figure 1: Annual Volume and Value of Common Organic Chemicals

25 5
20
15
10

Ethylene dichloride

MTBE

Vinyl chloride

Methanol (synthetic)

Styrene
Billion pounds

Dimethyl terephthalate
Billion Dollars

Formaldehyde
Pounds Value ($)

Ethylene oxide

Cumene

Ethylene glycol
Source: American Chemistry Council and Kline & Company, 1999.
II.B.2. Industry Size and Geographic Distribution The organic chemicals industry accounted for approximately $80 billion in shipments in 2000, one fifth of the output of the entire chemical industry (U.S. Department of Commerce, 2000). As noted in Table 4, some facilities are quite large (greater than 500 employees). These facilities primarily produce bulk commodity chemicals such as those shown above in Figure 1. The industry is also characterized by a relatively high proportion of small facilities. These facilities predominantly manufacture specialty chemicals.
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Table 4: Facility Size Distribution of Organic Chemical Facilities Distribution of Facilities According to Number of Employees (% of Total in Parentheses) 1-19 20-99 100-499 >499 Employees Employees Employees Employees 52 (74%) 75 (38%) 10 (14%) 67 (34%) 8 (11%) 51 (26%) 0 (0%) 6 (3%) 44 (6%) Total Facilities 70 (100%) 199 (100%) 743 (100%)
Industry
Gum and wood chemicals (SIC 2861) Cyclic crudes and intermediates (SIC 2865) Industrial organic chemicals, not elsewhere classified (SIC 2869)
268 (36%) 254 (34%) 177 (24%)
Source: U.S. Department of Commerce, 1998.
Organic chemicals facilities generally are located in four areas of the United States. Gum and wood chemical production is found primarily in the southeast, near wood and pulp production facilities. Other organic chemicals facilities are predominantly located near the Gulf of Mexico, where many petroleum-based feedstocks are produced, and near downstream industrial users in the Northeast and Midwest. Figure 2: Geographic Distribution of U.S. Organic Chemical Manufacturing Facilities
There are no organic chemical facilities in Alaska or Hawaii. Source: U.S. EPA, Toxics Release Inventory Database, 1999.
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Organic Chemical Industry II.B.3. Economic Trends
The United States has the largest organic chemicals industry in the world and is a net exporter of organic chemicals. However, many of the chemicals produced by the industry are commodities. As a result, the industry faces significant competition due to increased capacity in Asia, the Middle East, and Latin America. Difficulties between 1998 and 2001 included reduced shipments to Asia because of its slowed economy, worldwide overcapacity, and higher raw material and fuel costs due to high oil prices (U.S. Department of Commerce, 2000). Several trends are occurring within the industry to account for these and other changes. A considerable amount of consolidation is occurring. Across the chemical industry as a whole, there was approximately $45 billion in mergers and acquisitions in 1999 (U.S. Department of Commerce, 2000). Furthermore, many chemical companies are repositioning themselves in fundamental ways. Companies such as ICI, Clariant, and Ciba now focus on specialty chemicals. Others, including Exxon, BP, and Shell, now produce basic chemicals almost exclusively. Finally, some former chemical companies, such as Monsanto, Hoechst, and Novartis, exited the organic chemicals industry to specialize in life sciences (Speed, 2001). Table 5 lists the top 10 companies in the United States in 2001 according to their sales of chemicals. In the longer term, anticipated sustained growth in downstream industries such as agricultural chemicals (fertilizers and pesticides) and pharmaceuticals are expected to provide growth opportunities for the organic chemicals industry (Speed, 2001).
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Table 5: Top 20 U.S. Chemical Producers in 2001 Rank 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

a
Company Dow Chemical DuPont ExxonMobil Huntsman Corp. General Electric BASF Chevron Phillips PPG Industries Equistar Chemicals Shell Oil Air Products Eastman Chemical BP Praxair Rohm and Haas Atofina Monsanto Honeywell Lyondell Chemical Nova Chemicals
2001 Chemical Salesa (millions of dollars) 27,805 26,787 15,943 8,500 7,069 6,852 6,010 5,933 5,909 5,524 5,467 5,384 5,300 5,158 4,917 4,380 3,755 3,313 3,226 3,194
Represents sales from chemical segment of each company; organic chemicals may
only be a portion of these sales.
Source: Annual Survey: Top 75 Chemical Producers. Chemical & Engineering
News, Volume 80, Number 19 (May 13, 2002); 21-25.
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Organic Chemical Industry III. INDUSTRIAL PROCESS DESCRIPTION
Industrial Process Description
This section describes the major industrial processes within the organic chemical industry, including the materials and equipment used, and the processes employed. The section is designed for those interested in gaining a general understanding of the industry, and for those interested in the interrelationship between the industrial process and the topics described in subsequent sections of this profile -- pollutant outputs, pollution prevention opportunities, and Federal regulations. This section does not attempt to replicate published engineering information that is available for this industry. Refer to Section IX for a list of reference documents that are available. This section specifically contains a description of commonly used production processes, associated raw materials, the 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. This section also describes the potential fate (via air, water, and soil pathways) of these waste products. III.A. Industrial Processes in the Organic Chemicals Industry Although the organic chemicals industry manufactures thousands of chemicals, there are basic principles that are common to most production processes. This section provides a brief overview of the processes, describes common chemical reactions, and discusses four chemicals that are particularly important building blocks for organic chemical products. III.A.1. Chemical Manufacturing Processes As described in Section II, the organic chemicals industry requires raw materials from upstream industries, such as petroleum refining, and sells its products either as finished materials or as intermediates for further processing by other manufacturers. Assuming that raw materials are received in sufficient purity, the two major steps in chemical manufacturing are 1) the chemical reaction and 2) the purification of reaction products. Chemical Reaction Processes The primary types of chemical reactions are batch and continuous. In batch reactions, the reactant chemicals are added to the reaction vessel at the same time and the products are emptied completely when the reaction is completed. The reactors are made of stainless steel or glass-lined carbon steel and range in size from 50 to several thousand gallons (U.S. EPA, 1993). Batch reactors, also called stirred tank reactors or autoclaves, have an Sector Notebook Project 11 November 2002
agitator mechanism to mix the reactants, an insulating jacket, and the appropriate pipes and valves to control the reaction conditions (U.S. EPA, 1993; Kroschwitz, 1986). Batch processes generally are used for smaller scale and experimental processes. One advantage is that batch equipment can be adapted to multiple uses an important issue for facilities producing many specialty chemicals. Also, these processes are easier to operate, maintain, and repair. In general, facilities producing less than four million pounds of a particular product per year use a batch process (Hocking, 1998). An important subcategory of the batch process is toll manufacturing. Many organic chemicals require multi-step manufacturing processes. These steps often call for precise operating conditions, which in turn demand specialized equipment and trained employees. In a tolling operation, a company outsources one or more steps in the manufacturing process to a contractor, who then sends the product to yet another contractor to complete the production process. Toll manufacturing is highly useful from an engineering standpoint, but this arrangement can also be used for economic reasons to utilize excess production capacity. Continuous processes occur either in a tank (a continuous stirred tank reactor) or in a pipe (a pipe reactor). In this case, the reactants are added and products are removed at a constant rate from the reactor, so that the volume of reacting material in the vessel remains constant. A continuous stirred tank reactor is similar to the batch reactor described above. A pipe reactor typically is a piece of tubing arranged in a coil or helix shape that is jacketed in a heat transfer fluid. Reactants enter one end of the pipe, and the materials mix under the turbulent flow and react as they pass through the system. Pipe reactors are well suited for reactants that do not mix well, because the turbulence in the pipes causes all materials to mix thoroughly (Hocking, 1998). Continuous processes require a substantial amount of automation and capital expenditures, and the equipment generally must be dedicated to a single product. As a result, this type of process is used primarily for large scale operations, such as those producing greater than 20 million pounds per year of a particular chemical (Hocking, 1998). For facilities producing between 4 and 20 million pounds of a chemical per year, the choice of a batch or continuous process depends on the particular chemical and other site-specific considerations. In some cases, a hybrid reaction process, called a semi-batch reactor, is needed. This is commonly used when the reaction is very fast and potentially dangerous. One reactant is placed in the vessel at the beginning of the
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reaction (like in a batch process) and the other reactant(s) is added gradually (Hocking, 1998). Product Separation Reaction products rarely are obtained in a pure form from a reaction. Often there are byproducts and unreacted inputs. Therefore, the desired product must be isolated and purified in order to be used by customers or downstream manufacturers. Common separation methods include filtration, distillation, and extraction. Depending on the particular mixture and the desired purity, multiple separation methods can be used. Filtration Filtration is a process that separates solids from liquids. A slurry, or mixture of liquid and suspended particles, is passed through a porous barrier (filter) that traps the solids and allows the liquid to pass through. The liquid typically is passed through the filter via gravity. An alternative form of filtration is centrifugation, in which the slurry is placed in a porous basket that is spun rapidly. The outward force pushes the liquid through the filter or mesh on the sides of the basket where the fluid is reclaimed. Distillation Distillation is a process that separates liquids that have differing boiling points. A mixture of liquids is heated to the boiling point of the most volatile compound (i.e., the compound with the lowest boiling point). That compound becomes gaseous and then is condensed back to a liquid form in an attached vessel. Additional compounds can be isolated from the mixture by increasing the temperature incrementally to the appropriate boiling point. It should be noted that materials existing as gases at room temperature can be separated via distillation when they are refrigerated to a liquid form and slowly warmed to their boiling points. Extraction Organic compounds each have different solubility rates in fluids such as water or organic solvents. In an extraction, a mixture is placed in a fluid in which the desired product is insoluble but the undesired materials are soluble. The result is that the desired material is in a separate phase from the solvent and contaminants and can be removed (Buonicore and Davis, 1992). III.A.2. Common Chemical Reactions The following section presents some of the chemical reactions that are used to produce the most significant products of the organic chemicals industry, such as those listed in Figure 1 in Section II. There are illustrations of each type of reaction. Note that the illustrations follow the chemistry standard practice of implying that a carbon atom is found wherever lines meet. Sector Notebook Project 13 November 2002
Details of the reactions were obtained form Organic Chemistry by Vollhardt and Schore, and the equation illustrations were obtained from the internet site http://products.cambridgesoft.com/ChemFinder.cfm. Halogenation Halogenation is a process of adding a halogen atom on an organic compound. (Halogen is the collective name for fluorine, chlorine, bromine, and iodine.) This is an important step in making chlorinated solvents such as ethylene dichloride. The following equation shows a simplified version of the halogenation of ethylene to form ethylene dichloride. This particular reaction generally is conducted with an iron chloride catalyst. (A catalyst is material that facilitates a reaction but is not actually consumed in the process).
>
Pyrolysis Pyrolysis is a process of breaking down a large compound into smaller components by heating it (in the absence of oxygen) and exposing it to a catalyst. This process is also referred to as cracking. Vinyl chloride is produced in this way by pyrolizing ethylene dichloride. Because pyrolysis can result in a variety of products, the catalyst and temperature must be carefully selected and controlled in order to maximize the yield of the desired product. The following equation shows the formation of vinyl chloride in the presence of heat and a catalyst. >
Oxidation In the context of organic chemistry, oxidation generally means the addition of an electron-donating atom (such as oxygen) and/or the removal of hydrogen to a compound. For example, formaldehyde is formed by removing two hydrogen atoms from methanol, as shown in the following equation. Oxygen and a metal catalyst, such as silver, typically are used in the reaction.
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> 2
+2
Hydrolysis Hydrolysis involves the addition or substitution of water (H2O) into a compound. This process is used in the manufacturing of ethylene glycol, the main component of antifreeze. The following equation shows how ethylene oxide is hydrolized to form ethylene glycol.
+2
>
III.A.3. Common Organic Chemical Production Chains Most of the products of the organic chemicals industry are derived from just a handful of feedstocks, or raw materials. Figure 3 demonstrates this conceptually; a small number of chemicals derived from materials such as fossil fuels are then processed into the wide range of intermediate and finished products used in the economy. Figure 3: Organic Chemicals and Building Blocks Flow Diagram
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The rest of this section presents the reactions of three high-volume chemicals (ethylene, propylene, and benzene) chosen to illustrate the use of typical chemical feedstocks. The three chemicals are all primary building blocks and their reaction products are used to produce still other chemicals. The flowcharts below (Figures 4-6) illustrate some of the common intermediates and final products associated with each chemical. The chemicals described below illustrate several key points. First, primary building blocks are typically used in more reactions than the building blocks further down the chain. Second, most feedstocks can participate in more than one reaction and third, there is typically more than one reaction route to an end-product. The end-products of all of these chemicals can be used in numerous commercial applications; Riegels Handbook of Industrial Chemistry, listed in the reference section, describes many uses. Ethylene The major uses for ethylene are in the synthesis of polymers (polyethylene) and in ethylene dichloride, a precursor to vinyl chloride. Other important products are ethylene oxide (a precursor to ethylene glycol) and ethylbenzene (a precursor to styrene). While ethylene itself is not generally considered a health threat, several of its derivatives, such as ethylene oxide and vinyl chloride, have been shown to cause cancer. The distribution of uses is shown in Table 6. The manufacturing processes that use ethylene as a feedstock are summarized in the table below along with reaction conditions and components. Ethylene dichloride, ethylbenzene, and ethylene oxide (products of ethylene reactions) are all among the top 50 high production volume organic chemicals in the United States (Chemical and Engineering News). Table 6: Distribution of Uses for Ethylene Product Polyethylene Ethylene dichloride Ethylene oxide-glycol Ethylbenzene-styrene Linear olefins-alcohol Vinyl acetate Ethanol Other
Source: Kirk-Othmer Encyclopedia of Chemical Technology.
Percent of Ethylene Use 54 16 13 7 3 2 1 4
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Figure 4 presents a flowchart of the intermediates produced from ethylene and examples of the major finished products. Many of the products are plastics derived from polyethylene.
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Organic Chemical Industry Figure 4: Ethylene Products
Low Density Polyethylene & Linear Low Density Polyethylene
Food Packaging, Film, Trash Bags, Diapers, Toys, Housewares
High Density Polyethylene
Housewares, Crates, Drums, Food Containers, Bottles
Ethylene Dichloride
Vinyl Chloride
PVC
Siding, Window Frames, Swimming Pool Liners, Pipes
Ethylene Oxide Crude Oil/ Natural Gas
Ethylene Glycol
Automotive Antifreeze
Ethylene Pantyhose, Carpets, Clothing
Fibers
Polyester Resin Miscellaneous
Bottles Film
Polystyrene Resins Ethylbenzene Styrene Styrene Acrylonitrile Resins Styrene Butadiene Rubber
Insulation, Cups, Models
Instrument Lenses, Housewares
Linear Alcohols
Detergents
Tires, Footwear, Sealants
Vinyl Acetate
Adhesives, Coatings, Textile/Paper Finishing, Flooring
Styrene Butadiene Latex
Carpet Backing, Paper Coatings
Miscellaneous
Miscellaneous
Source: American Chemistry Council, 2001.
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Organic Chemical Industry Propylene
Over half of the U.S. propylene supplies are used in the production of chemicals. The primary products are polypropylene, acrylonitrile, propylene oxide, and isopropyl alcohol. Of these, propylene, acrylonitrile and propylene oxide are among the top fifty high-volume chemicals produced in the United States. Acrylonitrile and propylene oxide have both been shown to cause cancer, while propylene itself is not generally considered a health threat. Table 7 shows the use distribution of propylene. Table 7: Distribution of Propylene Use Product Polypropylene Acrylonitrile Propylene oxide Cumene Butyraldehydes Oligomers Isopropyl alcohol Other
Source: Szmant.
Percent of Propylene Use 36 16 11 9 7 6 6 9
Figure 5 shows the major intermediates and finished products associated with propylene.
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Organic Chemical Industry Figure 5: Propylene Products
Propylene Oxide
Propylene Glycol
Polyesters
Auto Patch Compounds, Furniture Parts, Boats, Fibers
Polyols
Polyurethane
Foams, Coatings, Lacquers
Resins Polypropylene Fibers
Auto Steering Wheels, Knobs, Auto Grills, Pipe, Film, Shirt Package, Strapping, Rope & Twine
Indoor/Outdoor Carpets, Matting
Crude Oil
Propylene
Isopropyl Alcohol
Acetone
Methyl Methacrylate
Solvents, Coatings, Cosmetics, Health Care
Plastics, Signs, Plexiglass, Paints, TailLight Lenses, Lighting Panels
Oxoalcohols
Plasticizers
PVC Plastics
Rain Coats, Inflatable Toys
Solvents Acrylonitrile Polyacrylonitrile
Coatings
Acrylic Fiber
Carpets, Sweaters, Draperies, Dresses, Coats
Modacrylic Fiber
Acrylic Resins
Lenses, Light Fixtures, Coatings, Domestics
Synthetic Furs, Coatings Cumene ABS Resins Telephones, Auto Parts, Bath Tubs Phenol Acrylic Acid, Acrylates Miscellaneous Phenolic Resins, Nylon Fibers, Solvents
Super Absorbent Polymers, Coatings, Adhesives, Detergents
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Organic Chemical Industry Benzene
Benzene is an important intermediate in the manufacture of industrial chemicals. Over 95 percent of U.S. consumption of benzene is for the preparation of ethylbenzene, cumene, cyclohexane, nitrobenzene, and various chlorobenzenes as shown in Table 8. Benzene is considered a human carcinogen by EPA. Table 8: Distribution of Benzene Use Product Ethylbenzene Cumene Cyclohexane Nitrobenzene Chlorobenzenes Linear detergent alkylate Other
Source: Kirk-Othmer Encyclopedia of Chemical Technology.
Percent of Benzene Use 52 22 14 5 2 2 3
Figure 6 summarizes the primary benzene intermediates and products.
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Organic Chemical Industry Figure 6: Benzene Products
Polystyrene Resins Styrene Acrylonitrile Resins Styrene Butadiene Rubber
Insulation, Cups, Models
Instrument Lenses, Housewares
Ethylebenzene
Styrene
Tires, Footwear, Sealants
Styrene Butadiene Latex
Carpet Backing, Paper Coatings
Miscellaneous Crude Oil Football Helmets, Eyeglasses, Computers
Acetone
Polycarbonate Resins Epoxy Resins Miscellaneous
Benzene
Cumene Bisphenol A
Protective Coatings, Adhesives
Ethylene Cracker
Phenol Phenolic Resins
Plywood, Coatings, Housings Adipic Acid
Cyclohexane
Nylon Fibers & Resins Miscellaneous
Caprolactam Isocyanates Miscellaneous Rubber Chemicals Aniline Pesticides Nylon Fibers & Resins
Dyes Miscellaneous Chlorobenzenes Miscellaneous Pesticides, Dyes
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Organic Chemical Industry III.B. Raw Material Inputs and Pollution Outputs
Industrial 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 (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 9. Table 9: Potential Releases During Organic Chemical Manufacturing Media
Air
Potential Sources of Emissions

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) Solid Wastes
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 Spent catalysts, spent filters, sludges, wastewater treatment biological sludge, contaminated soil, old equipment/insulation, packaging material, reaction byproducts, spent carbon/resins, drying aids Unlined ditches, process trenches, sumps, pumps/valves/fittings, wastewater treatment ponds, product storage areas, tanks and tank farms, aboveground and underground piping, loading/unloading areas/racks, manufacturing maintenance facilities
Ground Water Contamination
Source: Chemical Manufacturers Association, 1993.
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Organic Chemical Industry IV.
Chemical Releases and Transfers
CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE This section is designed to provide background information on the pollutant releases that are reported by this industry in correlation with other industries. The best source of comparative pollutant release and other waste management information is the Toxic Release Inventory (TRI). Pursuant to the Emergency Planning and Community Right-to-Know Act, TRI includes self-reported facility release and other waste management data for over 650 toxic chemicals and chemical categories. Facilities within SIC Codes 10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4939 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4953 (limited to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in solvents recovery services on a contract or fee basis) have more than 10 employees, and that manufactures, processes or otherwise uses listed chemical in quantities greater than the established threshold in the course of a calendar year are required to report to TRI annually release and other waste management quantities (on- and off-site). The information presented within the sector notebooks is derived from the most recently available (2000) TRI reporting year (which includes over 650 chemicals and chemical categories), and focuses primarily on the on-site releases reported by each sector. Because TRI requires consistent reporting regardless of sector, it is an excellent tool for drawing comparisons across industries. TRI data provide the type, amount and media receptor of each chemical released or otherwise managed as waste. Although this sector notebook does not present historical information regarding TRI chemical releases over time, please note that in general, toxic chemical releases have been declining. In fact, according to the 2000 Toxic Release Inventory Public Data Release, reported on-site and off-site releases of toxic chemicals to the environment from original TRI reporting industries (SIC codes 20-39) decreased by more than 8 percent (644 million pounds) between 1999 and 2000 (not including chemicals added and removed from the TRI chemical list during this period). Reported on-site releases dropped by almost 57 percent between 1988 and 2000. Reported transfers of TRI chemicals to off-site locations for disposal increased by almost 7 percent (28 million pounds) between 1988 and 2000. More detailed information can be obtained from EPA's annual Toxics Release Inventory Public Data Release Report (which is available through the EPCRA Call Center at 800-424-9346), or directly from the Internet at www.epa.gov/tri. Wherever possible, the sector notebooks present TRI data as the primary indicator of chemical release within each industrial category. TRI data
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provide the type, amount and media receptor of each chemical released or otherwise managed as waste. When other sources of pollutant release data have been obtained, these data have been included to augment the TRI information. TRI Data Limitations Certain limitations exist regarding TRI data. Within some sectors, (e.g., printing and transportation equipment cleaning) the majority of facilities are not subject to TRI reporting either because they do not fall under covered SIC codes, or because they are below the TRI reporting threshold amounts. However, EPA lowered threshold amounts for persistent bioaccumulative toxic (PBT) chemicals starting reporting year 2000. For these sectors, release information from other sources has been included. In addition, many facilities report to TRI under more than one SIC code, reflecting the multiple operations carried out onsite whether or not the operations are the facilities primary area of business as reported to the U.S. Census Bureau. Reported chemicals are limited to the approximately 650 TRI chemicals and chemical categories. A portion of the emissions from organic chemicals facilities, therefore, are not captured by TRI. Also, reported releases and other waste management quantities may or may not all be associated with the industrial operations described in this notebook. The reader should also be aware that TRI pounds released data presented within the notebooks is not equivalent to a risk ranking for each industry. Weighting each pound of release equally does not factor in the relative toxicity of each chemical that is released. The Agency is in the process of developing an approach to assign toxicological weightings and population exposure levels to each chemical released so that one can differentiate between pollutants with significant differences in toxicity. This project, the Risk Screening Environmental Indicators Model, can be found at http://www.epa.gov/opptintr/rsei/. As a preliminary indication of the environmental impact of the industry's most commonly released chemicals, this notebook briefly summarizes the toxicological properties of the top five chemicals (by weight) reported by the organic chemical industry. Definitions Associated with Section IV Data Tables General Definitions SIC Code -- is the Standard Industrial Classification (SIC) is a statistical classification standard used for all establishment-based Federal economic statistics. The SIC codes facilitate comparisons between facility and industry data. Sector Notebook Project 25 November 2002
TRI Facilities -- are facilities that are within specified SIC codes that have 10 or more full-time employees and are above established threshold amounts for manufacture or process or otherwise use activities in the course of a calendar year. These facilities are in standard industrial classification codes 10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4931 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4939 (limited to facilities that combust coal and/or oil for the purpose of generating electricity for distribution in commerce), 4953 (limited to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in solvents recovery services on a contract or fee basis), and federal facilities. Facilities must submit release and other waste management estimates for all chemicals that are on the EPA's defined list and are above manufacturing or processing or otherwise use thresholds. Data Table Column Heading Definitions The following definitions are based upon standard definitions developed by EPAs Toxic Release Inventory Program. The categories below represent the possible pollutant destinations that can be reported. ON-SITE RELEASES -- are an on-site discharge of a toxic chemical to the environment. This includes emissions to the air, discharges to bodies of water, releases at the facility to land, as well as contained disposal into underground injection wells. Releases to Air (Point and Fugitive Air Emissions) -- Include all air emissions from industry activity. Point emissions occur through confined air streams as found in stacks, ducts, or pipes. Fugitive emissions include losses from equipment leaks, or evaporative losses from impoundments, spills, or leaks. Releases to Water (Surface Water Discharges) -- encompass any releases going directly to streams, rivers, lakes, oceans, or other bodies of water. Any estimates for storm water runoff and non-point losses must also be included. Releases to Land -- includes disposal of toxic chemicals in waste to on-site landfills, land treated or incorporation into soil, surface impoundments, spills, leaks, or waste piles. These activities must occur within the facility's boundaries for inclusion in this category. Underground Injection -- is a contained release of a fluid into a subsurface well for the purpose of waste disposal.
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TRANSFERS -- is a transfer of toxic chemicals in wastes to a facility that is geographically or physically separate from the facility reporting under TRI. The quantities reported represent a movement of the chemical away from the reporting facility. Except for off-site transfers for disposal, these quantities do not necessarily represent entry of the chemical into the environment. Transfers to POTWs -- are waste waters transferred through pipes or sewers to a publicly owned treatments works (POTW). Treatment and chemical removal depend on the chemical's nature and treatment methods used. Chemicals not treated or destroyed by the POTW are generally released to surface waters or land filled within the sludge. Metals and metal compounds transferred to POTWs are considered as released to surface water. Transfers to Recycling -- are sent off-site for the purposes of regenerating or recovering still valuable materials. Once these chemicals have been recycled, they may be returned to the originating facility or sold commercially. Transfers to Energy Recovery -- are wastes combusted off-site in industrial furnaces for energy recovery. Treatment of a chemical by incineration is not considered to be energy recovery. Transfers to Treatment -- are wastes moved off-site for either neutralization, incineration, biological destruction, or physical separation. In some cases, the chemicals are not destroyed but prepared for further waste management. Transfers to Disposal -- are wastes taken to another facility for disposal generally as a release to land or as an injection underground. IV.A. EPA Toxic Release Inventory for the Organic Chemicals Industry According to the Toxics Release Inventory (TRI) data, 467 organic chemical facilities released (to the air, water or land) and transferred (shipped off-site or discharged to sewers) a total of 594 million pounds of toxic chemicals during calendar year 2000. That represents approximately 5.5 percent of the releases and transfers for all facilities reporting to TRI that year. Because the chemical industry (SIC 28) has historically released more TRI chemicals than any other manufacturing industry, the EPA has worked to improve environmental performance within this sector. This has been done through a combination of enforcement actions, regulatory requirements, pollution prevention projects, and voluntary programs. In addition, the chemical industry has focused on reducing pollutant releases. For example, the American Chemistry Councils Responsible Care initiative is intended Sector Notebook Project 27 November 2002
to reduce or eliminate chemical manufacturers wastes. All members of the Council, firms that account for the majority of U.S. chemical industry sales and earnings, are required to participate in the program as a condition of Council membership. Participation involves demonstrating a commitment to the programs mandate of continuous improvement of the environment, health, and safety. State-level toxics use reduction requirements, public disclosure of release and transfer information contained in TRI, and voluntary programs such as EPAs 33/50 Program during the 1990's have also been given as reasons for release reductions. Table 10 presents the number and volumes of chemicals released by organic chemical facilities. The quantity of the basic feedstocks released reflects their volume of usage. The top inorganic chemicals released (ammonia, chlorine, nitric acid, and hydrochloric acid) are also large volume reaction feedstocks. Forty three percent of releases occurred via on-site underground injection. Air releases accounted for another 38 percent (83 million pounds), 18 percent (39 million pounds) was released to water, and the remaining one percent (2.1 million pounds) was disposed of on land. Table 11 presents the number and volumes of chemicals transferred off-site by organic chemical facilities. Off-site transfers account for the largest amount, 63 percent, of the organic chemical industry's total releases and transfers as reported in TRI. One chemical, methanol, accounted for 24 percent of the 374 million pounds transferred by facilities in the industry. Approximately 14 percent of transfers are sent to recycling facilities. The frequency with which chemicals are reported by facilities within a sector is one indication of the diversity of operations and processes. Many chemicals are released or transferred by a small number of facilities, which indicates a wide diversity of production processes, particularly for specialty organic chemicals. Almost two-thirds of the 302 chemicals reported are released by fewer than 10 facilities. Overall, the organic chemicals industry reports the use of about half of the roughly 600 TRI reportable chemicals.
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Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286),
by Number of Facilities Reporting (Releases Reported in pounds/year)*
Chemical Name Methanol Toluene Ammonia Xylene (Mixed Isomers) Benzene Chlorine Formaldehyde Ethylene Glycol N-butyl Alcohol Nitrate Compounds Hydrochloric Acid (1995 and after "Acid Aerosols" Ethylbenzene Ethylene Styrene N-hexane Phenol Naphthalene Certain Glycol Ethers Propylene Zinc Compounds Acetaldehyde Cyclohexane Maleic Anhydride Methyl Ethyl Ketone Methyl Isobutyl Ketone Copper Compounds Dichloromethane 1,2,4-trimethylbenzene Acrylic Acid Propylene Oxide 1,3-butadiene Ethylene Oxide Nitric Acid Biphenyl Aniline Chloromethane Formic Acid Polycyclic Aromatic Compounds[PBT] Cumene Sulfuric Acid (1994 and after "Acid Aerosols" Only Barium Compounds N,n-dimethylformamide Nickel Compounds Sodium Nitrite Chlorodifluoromethane Chloroethane Chlorobenzene Phthalic Anhydride Acetonitrile Dimethylamine Tert-butyl Alcohol Acrylonitrile Dicyclopentadiene # Reporting Chemical 278 179 169 128 103 92 90 90 89 88 87 75 75 74 72 71 69 69 63 59 51 50 48 47 43 42 42 40 39 39 39 38 38 38 37 35 34 32 30 30 30 29 29 28 27 27 27 27 27 27 26 26 25 Fugitive Air 3,912,475 2,657,687 2,380,590 623,681 521,616 84,788 171,456 703,306 202,970 517 320,566 308,199 6,016,036 318,753 1,596,421 252,980 106,289 143,832 2,728,645 4,226 302,805 349,609 29,022 295,954 636,118 325 270,914 71,232 96,543 61,004 416,282 104,457 17,428 87,173 60,746 192,552 97,353 21,378 181,133 33,255 2,124 34,570 116 174 1,036,287 117,292 75,227 42,872 121,362 38,044 537,999 83,992 88,752 Point Air 13,933,787 1,328,947 6,631,275 189,952 981,150 341,885 590,489 263,220 437,658 4,846 2,436,134 248,117 5,229,560 414,241 1,469,279 177,624 319,392 68,906 2,231,243 8,663 501,401 232,819 94,141 153,075 240,543 2,297 1,593,846 22,567 53,143 99,296 556,472 151,142 35,802 6,268 110,058 481,349 111,538 14,199 347,323 587,041 3,542 13,035 5,429 1,019 853,487 130,617 301,303 86,375 99,411 38,467 105,206 181,243 15,601 Water Discharges 167,959 4,488 865,496 13,940 1,940 37,100 45,016 93,569 3,296 36,970,944 255 2,625 112 1,024 3,283 442 43,385 2,607 35,256 4,687 15,166 3,768 15,182 14,943 4,160 687 5,565 233 108 1,001 1,214 9,093 668 113,545 2,020 97 1,000 28,228 1,197 16,489 150,413 2,891 680 79 10,480 2,410 1,963 216 2,433 Underground Injection 7,868,577 154,733 17,043,040 32,055 105,954 3,817,671 455,430 1,890,507 10,326,216 Land Disposal 132,361 3,423 144,995 8,000 3,212 6,655 5,833 656 67,602 Total Avg. Releases Releases Per Facility 26,015,152 93,580 4,149,278 23,180 27,065,392 160,150 867,628 6,778 1,613,872 15,669 463,773 5,041 4,631,287 51,459 1,521,358 16,904 2,535,087 28,484 47,370,128 538,297 2,756,955 31,689 1,091,262 11,245,596 1,000,567 3,175,443 2,363,158 607,191 315,322 4,962,500 485,701 1,133,683 679,485 123,449 592,702 895,432 142,724 1,868,997 96,441 672,539 162,633 972,864 256,826 11,579,091 94,736 877,118 708,749 3,065,180 38,104 540,103 621,296 402,592 48,802 68,966 2,179,897 1,892,665 248,589 457,823 129,247 7,825,940 83,306 1,411,821 3,545,860 106,815 14,550 149,941 13,521 44,103 33,284 8,800 4,570 78,770 8,232 22,229 13,590 2,572 12,611 20,824 3,398 44,500 2,411 17,245 4,170 24,945 6,759 304,713 2,493 23,706 20,250 90,152 1,191 18,003 20,710 13,420 1,683 2,378 77,853 70,099 9,207 16,956 4,787 289,850 3,085 54,301 136,379 4,273
530,250 260,000 107,705 1,875,339 179,721 43,140 454 324,571 81,879 6 139,500 2,900 64,026 3 516,946 2,100 226 11,518,220 696,924 34,177 2,740,685 550
2,071 7,461 1,014 53,932 1,347 16,059 5 437,102 219 12 280 405 689 61,133 74 1,955 342 2 7,641 81 297 3 2,059 507 11,000
43 27,745 2,028,206
368,655 19,187 85
80,008 7,594,103 950 766,176 3,280,408
1,206 584 3,435 477 1 29
29
November 2002
Chemical Name Diethanolamine Vinyl Acetate Chromium Compounds Methyl Methacrylate O-xylene Manganese Compounds 1,2-dichloroethane Dioxin and Dioxin-Like Compounds[PBT] Anthracene Hydrogen Fluoride Phenanthrene N-methyl-2-pyrrolidone Triethylamine Butyl Acrylate Chloroform Pyridine Butyraldehyde Epichlorohydrin Cresol (Mixed Isomers) Methyl Acrylate Hydroquinone Diisocyanates Methyl Tert-butyl Ether Hydrogen Cyanide Bromine Nickel Benzyl Chloride Cobalt Compounds Lead Compounds[PBT] Acrylamide Allyl Alcohol Trichloroethylene Carbon Disulfide Tetrachloroethylene Sec-butyl Alcohol Cyanide Compounds Ethyl Acrylate Acrolein Carbon Tetrachloride Antimony Compounds Mercury Compounds[PBT] Nitrobenzene Propionaldehyde Allyl Chloride Benzo(g,h,i)perylene[PBT] O-toluidine Mercury[PBT] P-xylene Cyclohexanol Isobutyraldehyde 1,4-dioxane 2-methoxyethanol 1,2-dichlorobenzene Hexachlorobenzene[PBT] # Reporting Chemical 24 24 24 22 22 21 20 20 20 19 18 18 18 18 18 18 17 17 16 16 16 16 16 16 16 15 15 15 15 15 15 15 14 14 14 14 14 14 13 13 13 13 13 13 13 12 12 12 12 12 12 11 11 11 Fugitive Air 24,166 519,283 39 183,621 123,135 1,059 74,676 5 8,333 50,221 15,747 19,542 22,434 26,597 14,398 38,335 70,899 15,125 9,857 127,929 568 42,507 56,181 24,208 16,317 306 8,446 454 2,127 955 340,164 25,033 34,375 50,236 26,859 118 12,239 4,765 21,228 861 16,780 18,768 4,875 943 3,243 99,796 74,583 110,668 20,879 64,019 15,699 43 Point Air 2,147 1,174,490 1,233 362,406 170,981 8,323 94,852 121 7,653 176,558 11,125 2,616 63,340 54,651 52,751 19,240 129,169 5,067 9,397 19,488 120 394 76,392 268,828 3,916 573 2,176 12,146 573 974 25,601 6,375 29,537 22,549 13,405 4,789 14,301 11,736 133,443 637 222 13,414 64,296 125,390 4,215 7,326 136 395,276 64,772 17,328 15,697 4,538 45,506 5 Water Discharges 4,801 473 2,821 2,908 2,378 91,508 35 88 111 250 115 959 10,995 14,460 281 15 383 814 289 3,160 9,529 212 3,466 83 31,180 487 17 5,452 1 1,520 77 941 6,202 9 113 45 279 5 120 3,576 12 25 40 4,978 129 30,890 3,286 585 37 Underground Injection 223,177 202 Land Disposal 51,006 4,549 17,645 56 201,094 14 440 1 23 172 19 13,682 Total Avg. Releases Releases Per Facility 82,120 3,422 1,921,972 80,082 21,940 914 548,935 24,952 296,550 13,480 301,984 14,380 169,577 8,479 654 33 16,098 227,052 27,159 589,172 125,631 95,979 67,430 893,335 200,083 20,698 634,768 161,376 175,048 43,701 149,524 981,665 20,233 51,147 10,705 63,855 3,263 5,341,311 654,929 31,409 83,130 72,863 41,205 2,281,202 26,954 217,164 154,716 89,912 244 327,416 91,999 130,265 5,170 17,634 140 495,218 2,797,249 128,125 70,166 71,843 64,168 85 805 11,950 1,509 32,732 6,979 5,332 3,746 49,630 11,770 1,218 39,673 10,086 10,941 2,731 9,345 61,354 1,265 3,410 714 4,257 218 356,087 43,662 2,094 5,938 5,204 2,943 162,943 1,925 15,512 11,901 6,916 19 25,186 7,077 10,020 398 1,469 12 41,268 233,104 10,677 5,847 6,531 5,833 8
566,036 15,180 271 835,760
611,641 13,670 171,200 70 688,362 11,553 3,525 5,339,361 283,712 17,326
123 3,059
800 7,352 55 35,249 16,550 76 4
372 1 912 2
2,269,181 403 200,550 2,777 297,084 3,100
85,358 17 18 2,259
7,040 3 2,652,916
1 106
2,700 1,600 778
30
November 2002
Chemical Name 4,4'-isopropylidenediphenol Vinyl Chloride Quinoline Creosote Diphenylamine Hydrazine Benzoyl Chloride Dichlorodifluoromethane Phosgene P-cresol Acetophenone 1,1-dichloro-1-fluoroethane Polychlorinated Biphenyls[PBT] Cumene Hydroperoxide M-xylene M-cresol Copper 4,4'-methylenedianiline Vanadium Compounds Dibenzofuran Molybdenum Trioxide 2-chloro-1,1,1,2-tetrafluoroethane Trichlorofluoromethane Boron Trifluoride Freon 113 O-cresol Dimethyl Sulfate 1-chloro-1,1-difluoroethane Chloroacetic Acid 1,2,4-trichlorobenzene Methyl Iodide Bromomethane 2-ethoxyethanol Dibutyl Phthalate Diaminotoluene (Mixed Isomers) 3,3'-dichlorobenzidine Dihydrochloride N,n-dimethylaniline Toluene Diisocyanate (Mixed Isomers) 1,2-butylene Oxide Vinylidene Chloride Propargyl Alcohol 4,6-dinitro-o-cresol Crotonaldehyde Acetamide Di(2-ethylhexyl) Phthalate Dimethyl Phthalate 1,3-phenylenediamine 1,1,2-trichloroethane Phosphorus (Yellow or White) Diethyl Sulfate Cadmium Compounds Monochloropentafluoroethane Aluminum (Fume or Dust) Dinitrotoluene (Mixed Isomers) 2-methylpyridine # Reporting Chemical 11 10 10 10 10 10 10 10 9 9 9 9 9 9 9 9 8 8 8 8 8 7 7 7 7 7 7 7 7 6 6 6 6 6 6 6 6 6 5 5 5 5 5 5 5 5 5 4 4 4 4 4 4 4 4 Fugitive Air 8,087 53,870 2,452 9,910 9,558 2,555 6,166 158,393 348 6,179 24,202 179,758 29,846 153,987 6,433 9 11,009 151 9,442 15 58,227 117,585 1,463 175,354 1,867 596 104,544 1,395 3,541 20,589 594 6,132 687 4,827 2,108 1,674 2,388 16,247 1,944 5 3,235 42 3,660 33 192 2,870 5 2,830 8 54,509 60 3,438 6,251 Point Air 9,577 15,903 4,480 26,443 13,990 127 1,169 28,984 1,294 7,604 16,014 261,532 18 782 59,901 3,678 259 346 52 14,374 1,374 13,936 3,242 523 51,250 1,756 34 183,655 820 51,947 38,522 327,699 56,640 455 3,355 16 13,538 158 1,436 5,949 1,344 118 2,842 237 1,441 1,716 124 253 19 24 5,240 24,632 5,104 12,486 Water Discharges 2,107 15 5 32 10 5 28 22 168 23 94 37 373 296 78,872 16 94 5 885 1,272 9 22 34 19 22 129 2 1,809 5 48 319,553 580,000 Underground Injection Land Disposal 1,657 6 Total Avg. Releases Releases Per Facility 21,428 1,948 69,773 6,977 38,366 3,837 36,358 3,636 26,780 2,678 2,692 269 7,335 733 187,382 18,738 1,642 182 333,364 37,040 620,254 68,917 441,458 49,051 56 6 160,722 17,858 213,916 23,768 553,118 61,458 16,761 2,095 41,659 5,207 109,224 13,653 23,832 2,979 78,692 9,836 72,168 10,310 121,712 17,387 1,986 284 227,876 32,554 505,510 72,216 692 99 288,233 41,176 2,515 359 55,507 9,251 60,143 10,024 328,293 54,716 62,901 10,483 151,144 25,191 32,991 5,498 21 4 15,694 2,616 1,833 305 3,824 765 23,855 4,771 1,034,826 206,965 123 25 39,125 7,825 2,195,452 439,090 3,897 779 4,185 837 38,997 7,799 2,994 748 258 65 2,849 712 37 9 59,754 14,939 24,868 6,217 11,846 2,961 29,759 7,440
31,413 3,200
16 15
130,000 28 542,970 596 30,000 20,105 71,800 15,524 8 10,044 5,409
501,865
13 40 300
1,002
150,000 23,000
1 1,623 1,031,538 33,038 2,195,410 808 179 1,900 3 36,910 10 36
5 5 176 4 22
3,300 11,000
31
November 2002
Chemical Name Methacrylonitrile 1,3-dichlorobenzene Silver 2,4-dimethylphenol 1,1,1-trichloroethane Chloroprene Pentachlorobenzene[PBT] Toluene-2,4-diisocyanate Barium 1,2-dichloroethylene 1,2-phenylenediamine Acifluorfen, Sodium Salt Vanadium (Except When Contained in an Alloy) 1,2-dibromoethane Zinc (Fume or Dust) Titanium Tetrachloride Dichlorotetrafluoroethane (Cfc-114) Benzoyl Peroxide Asbestos (Friable) 2-methyllactonitrile Tetrabromobisphenol A[PBT] 1,1,2,2-tetrachloroethane Methyl Chlorocarbonate Peracetic Acid 4-nitrophenol 1,4-dichlorobenzene 1,1,1,2-tetrachloroethane 2,4-dinitrotoluene 3-chloro-2-methyl-1-propene Methylene Bromide Isopropyl Alcohol (Manufacturing, Strong-acid Proc P-chloroaniline Benzal Chloride P-phenylenediamine N-methylolacrylamide Decabromodiphenyl Oxide Quinone 2,4-dinitrophenol P-nitroaniline Benomyl Benzoic Trichloride Safrole Dihydrosafrole O-anisidine 1,2-dichloro-1,1-difluoroethane Bis(2-chloroethyl) Ether Dicamba Dinitrobutyl Phenol 2-nitrophenol 2-chloro-1,1,1-trifluoroethane 2-mercaptobenzothiazole Dichlorofluoromethane P-cresidine # Reporting Chemical 4 4 4 4 4 4 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 Fugitive Air 989 2,819 411 16,770 40 3 93 19 27 Point Air 2,250 121 360 7,108 137 2 1 671 783 137 305 145 1,000 195 26 21,078 2,014 1,002 468 22 4 2,146 65 33,109 327 1 167 1,527 1,827 20 9 34 50 912 1 2,020 1 45 9 9 19 3,705 8 5 39 12 69,400 246 106,405 703 Water Discharges 6 79 5 53 Underground Injection 54,549 Land Disposal Total Avg. Releases Releases Per Facility 55,538 13,885 5,075 1,269 200 50 201,796 50,449 23,931 5,983 177 44 2 1 4 1 67,672 22,557 876 292 3,771 1,257 6,143 2,048 21,043 7,014 2,871 200 2,458 98,599 2,014 141,786 473 150 2,243 3,255 404 56,878 529 27 452 1,542 3,812 486 245 1,010 506 4,197 4 23,289 3,931 6 538 260 260 724 9,270 141 10 39 17 77,750 35,519 119,709 1,956 957 67 819 32,866 671 47,262 158 50 748 1,085 135 18,959 176 14 226 771 1,906 243 122 505 253 2,098 2 11,645 1,965 3 269 130 130 362 4,635 71 5 20 8 38,875 17,760 59,855 978
201,020
1 118 5,811 8,121 5 65
67,000 3,497 12,777
1,801 5 2,391 77,516
41 5
1,777 5 128 2,239 1,109 323 23,570 202 2 285 15 1,985 406 236 15 456 4 1 1,911 5 493 251 251 705 5,520 133 5 5 8,350 5 13,304 1,029
139,007
16 25 24
174
60 7 954 3,285 23,287
45
35,268 224
32
November 2002
Chemical Name Antimony 2,2-dichloro-1,1,1-trifluoroethane Chromium Cobalt Catechol Ethylidene Dichloride Ethyl Chloroformate Silver Compounds Picloram Nitrapyrin Molinate Propargite C.i. Disperse Yellow 3 Malononitrile Thiourea Prometryn Sodium Dimethyldithiocarbamate Lead[PBT] Manganese Urethane Piperonyl Butoxide Cupferron Trans-1,4-dichloro-2-butene Arsenic P-dinitrobenzene M-dinitrobenzene Ethyleneimine 5-nitro-o-anisidine Styrene Oxide 2,4,5-trichlorophenol Diazinon 1,1,2,2-tetrachloro-1-fluoroethane 1,2-dichloro-1,1,2-trifluoroethane Carbonyl Sulfide O-dinitrobenzene 2,4-diaminotoluene Bis(2-chloroethoxy)methane Allylamine 2,4-d Butyl Ester 2,4-d 3,3'-dichlorobenzidine Perchloromethyl Mercaptan Ozone Fenbutatin Oxide Iron Pentacarbonyl 2,6-dinitrotoluene Oryzalin 3,3'-dimethoxybenzidine Dihydrochloride 2-phenylphenol Dichlorobenzene (Mixed Isomers) Chloromethyl Methyl Ether Methyl Isocyanate Norflurazon Octachlorostyrene[PBT] Pendimethalin[PBT] # Reporting Chemical 2 2 2 2 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Fugitive Air 15,413 1 99 1,565 24 Point Air 46 5,518 30 265 250 227 15 86 8 52 215 31 Water Discharges 3,296 5 43 996 200 Underground Injection Land Disposal 38 Total Avg. Releases Releases Per Facility 3,380 1,690 20,936 10,468 419 209 1,562 781 450 225 326 163 1,580 790 110 55 508 508 1,101 251 56 255,157 810 516 2 31,340 74,735 29,634 144 343 5 42,189 93 955 3 15 8 378 4 25 108,518 466,000 105 303 10,632 1,000 5 1,319 10 90 16 1,924 1,283 27 24 52 10 1,350 13 1,101 251 56 255,157 810 516 2 31,340 74,735 29,634 144 343 5 42,189 93 955 3 15 8 378 4 25 108,518 466,000 105 303 10,632 1,000 5 1,319 10 90 16 1,924 1,283 27 24 52 10 1,350 13
346 300
500 105 25 255,157 74
944 36
736 411 1
105 1 31,340 74,735 33
21
29,580 144 343 1
42,189 10 5 56 20 73,027 1 211 1,320 250 8 5 5 14 664 1,280 12 345 3 5 8 271 1 5 35,486 466,000 44 92 10 750 4 1,030 5 85 2 3 27 12 24 4 36 10 81 466 5 51 3 5 60 9,302 1 248 134
33
1,260
1,350 13
302
332
634
634
33
November 2002
Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), by Number of Facilities Reporting (Releases Reported in pounds/year)*
Chemical Name Hexazinone Permethrin 3-iodo-2-propynyl Butylcarbamate Picric Acid 3,3'-dichlorobenzidine Sulfate Fomesafen Propanil Arsenic Compounds Ethyl Dipropylthiocarbamate 1,4-dichloro-2-butene Chlorophenols Ametryn 2,4-dichlorophenol 2,4,6-trichlorophenol Tetrachlorvinphos N-nitrosodiphenylamine Saccharin (Manufacturing, No Supplier Notification 2-nitropropane Dimethylcarbamyl Chloride 1,2-dichloropropane Paraldehyde Hexachlorocyclopentadiene Pentachloroethane Chlorotrifluoromethane Atrazine Propyleneimine # Reporting Chemical 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 Fugitive Air 2 288 Point Air Water Discharges 1,874 7 274 577 250 815 89 3 403 266 92 99 70 221 250 88 1,176 250 92 39 157 149 12 25 29 1 Underground Injection Land Disposal Total Avg. Releases Releases Per Facility 1,876 1,876 295 295 21,367 1,974 750 995 89 43 560 440 134 99 80 21,367 1,974 750 995 89 43 560 440 134 99 80 16,829 102 5 33 696 10 16,005 331 70 469,710
21,093
10
1 9,588 7,017 224 16,829 1 3 99 102 1 2 3 5 1 14 19 33 1 332 364 696 1 9 1 10 1 1,420 14,580 5 16,005 1 161 169 1 331 1 17 53 70 467** 32,553,643 50,360,923 39,171,452 95,144,436 2,124,451 219,354,897 [PBT] Persistent, Bioaccumulative, and Toxic * Refer to Section III for a discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column
headings, and the definition of persistant, bioaccumulative, and toxic chemicals.
**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
34
November 2002
Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), by Number of Facilities Reporting (Transfers Reported in pounds/year)*
Chemical Name
Methanol
Toluene
Ammonia
Xylene (Mixed Isomers)
Benzene
Chlorine
Formaldehyde
Ethylene Glycol
N-butyl Alcohol
Nitrate Compounds
Hydrochloric Acid (1995 and after "Acid Aerosols"
Ethylbenzene
Ethylene
Styrene
N-hexane
Phenol
Naphthalene
Certain Glycol Ethers
Propylene
Zinc Compounds
Acetaldehyde
Cyclohexane
Maleic Anhydride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Copper Compounds
Dichloromethane
1,2,4-trimethylbenzene
Acrylic Acid
Propylene Oxide
1,3-butadiene
Ethylene Oxide
Nitric Acid
Biphenyl
Aniline
Chloromethane
Formic Acid
Polycyclic Aromatic Compounds[PBT] Cumene Sulfuric Acid (1994 and after "Acid Aerosols" Only Barium Compounds N,n-dimethylformamide Nickel Compounds Sodium Nitrite Chlorodifluoromethane Chloroethane Chlorobenzene Phthalic Anhydride Acetonitrile Dimethylamine Tert-butyl Alcohol Acrylonitrile Dicyclopentadiene Diethanolamine Vinyl Acetate Chromium Compounds Methyl Methacrylate O-xylene Manganese Compounds 1,2-dichloroethane Dioxin and Dioxin-Like Compounds[PBT] # Reporting POTW Chemical Transfers 278 20,036,448 179 62,687 169 2,184,927 128 12,480 103 5,091 92 3,624 90 660,534 90 10,349,832 89 1,442,267 88 20,333,408 87 20 75 75 74 72 71 69 69 63 59 51 50 48 47 43 42 42 40 39 39 39 38 38 38 37 35 34 32 30 30 30 29 29 28 27 27 27 27 27 27 26 26 25 24 24 24 22 22 21 20 20 1,368 243 36,907 552 644,708 2,446 955,735 9,270 1,188,158 108 447 487,694 69,780 27,400 274 5,541 1,128,221 151,147 250 63,436 33,987 111,285 922,560 281 79,714 8 5,625 176,202 472,318 8,106 202,287 354 2,690 110,259 8 262,166 574,667 61,194 36,432 30,297 1,273 297 61,148 16,125 273 24 Disposal Transfers 649,306 354,644 1,451,355 100,443 20,504 113,088 959,225 83,406 4,816,868 7,930 16,912 1,529 693 28,338 177,185 91,488 2,326,777 87 2,006 2,956 29,778 9,834 472,058 9,754 18,786 106,333 4,860 153,787 34 6,154,652 12,294 219,532 7 34,552 367,218 88,228 635 203,370 428 706,377 1,294 84,770 130 217 2,539,677 39,378 1,801 71,835 4,585 844 153,116 7,432 206,649 102,287 19,586 943,334 1,744 253 Recycling Transfers 7,311,495 2,767,314 117,039 1,244,063 1,212,323 530 287,020 1,362 2,247 593,873 2,500,339 287,599 6,303,351 1,808 222,427 62 738,733 5,437 798,627 2,154,659 452,955 1,436 23,001 60,424 870,770 23,600 10 64,287 74,000 1,869,080 561,342 24,480 976,507 20,872 231,455 165,800 171 57 294 2,023 270,003 549,321 31 321,814 6,255,710 75,551 767,008 175,429 6,798 410,427 408,987 216,088 1 Treatment Transfers 20,357,616 7,781,329 706,756 2,647,063 1,236,731 454,054 684,406 1,629,396 658,121 6,368,480 64,315 421,897 9 297,338 3,500,079 949,527 211,928 314,744 117,735 208,154 817,156 777,222 108,173 920,839 1,529,442 63,184 806,062 2,138 10,191 78 36,624 252,195 5,666,448 117,663 691,998 82,195 29,023 14,414 345,967 227,037 278,097 374,786 935,980 297,427 1,504,742 327,605 499,998 78,725 16,056 31,076 745,976 Energy Recovery 39,862,432 16,786,000 111,698 7,696,733 591,636 285,217 9,265,735 3,740,885 3,916 1,467,573 1,062,455 1,702,555 3,374,972 576,470 1,272,662 52 300,309 136,306 47,270 2,991,541 1,426,985 528,907 419,117 4,584,524 28,521 1,578 1 118,799 1,797,480 57,286 1,533,934 95,803 211,730 1,544 258,238 2,719 131,884 552,101 682,326 530,637 3,123 6,480,152 229,595 332,551 546 6,539,457 Total Transfers 88,217,297 27,751,974 4,571,775 11,700,782 3,066,285 457,678 1,743,775 22,491,208 5,926,041 31,521,003 76,181 2,501,623 252 3,898,568 5,491,478 4,997,545 7,271,380 2,636,437 117,787 2,558,474 1,696,770 1,694,309 827,895 3,622,623 3,226,065 2,654,117 2,521,332 508,064 6,625,140 186,666 188,807 63,549 6,285,687 1,365,343 8,629,620 175,237 2,340,208 609,511 408,606 1,885,673 940,914 1,101,431 1,690,990 454,209 594,322 672,954 1,491,159 3,629,689 2,074,822 594,989 7,628,675 374,099 619,454 221,170 7,323,162 757,243 588,562 1,256,760 1,281,273 6,649,244 7,076 Avg Transfers Per Facility 317,328 155,039 27,052 91,412 29,770 4,975 19,375 249,902 66,585 358,193 876 33,355 3 52,683 76,271 70,388 105,382 38,209 1,870 43,364 33,270 33,886 17,248 77,077 75,025 63,193 60,032 12,702 169,875 4,786 4,841 1,672 165,413 35,930 233,233 5,007 68,830 19,047 13,620 62,856 31,364 37,980 58,310 16,222 22,012 24,924 55,228 134,433 76,845 22,037 293,411 14,388 24,778 9,215 305,132 31,552 26,753 57,125 61,013 332,462 354
35
November 2002
Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286),
by Number of Facilities Reporting (Transfers Reported in pounds/year)*
Chemical Name Anthracene Hydrogen Fluoride Phenanthrene N-methyl-2-pyrrolidone Triethylamine Butyl Acrylate Chloroform Pyridine Butyraldehyde Epichlorohydrin Cresol (Mixed Isomers) Methyl Acrylate Hydroquinone Diisocyanates Methyl Tert-butyl Ether Hydrogen Cyanide Bromine Nickel Benzyl Chloride Cobalt Compounds Lead Compounds[PBT] Acrylamide Allyl Alcohol Trichloroethylene Carbon Disulfide Tetrachloroethylene Sec-butyl Alcohol Cyanide Compounds Ethyl Acrylate Acrolein Carbon Tetrachloride Antimony Compounds Mercury Compounds[PBT] Nitrobenzene Propionaldehyde Allyl Chloride Benzo(g,h,i)perylene[PBT] O-toluidine Mercury[PBT] P-xylene Cyclohexanol Isobutyraldehyde 1,4-dioxane 2-methoxyethanol 1,2-dichlorobenzene Hexachlorobenzene[PBT] 4,4'-isopropylidenediphenol Vinyl Chloride Quinoline Creosote Diphenylamine Hydrazine Benzoyl Chloride Dichlorodifluoromethane Phosgene P-cresol Acetophenone 1,1-dichloro-1-fluoroethane Polychlorinated Biphenyls[PBT] Cumene Hydroperoxide M-xylene M-cresol Copper # Reporting Chemical 20 19 18 18 18 18 18 18 17 17 16 16 16 16 16 16 16 15 15 15 15 15 15 15 14 14 14 14 14 14 13 13 13 13 13 13 13 12 12 12 12 12 12 11 11 11 11 10 10 10 10 10 10 10 9 9 9 9 9 9 9 9 8 POTW Transfers 86 3 52,677 5 118,677 281 57,935 36,233 9,364 4,541 255 39,814 1,001 858 128,250 500 1,204 66 15 137,481 597 10 1,348 10 68,930 4,739 429,881 117 2 107 4,713 43 2,056 5,593 9,087 20,120 37,330 5 3 1 54 250 3,039 85 251 1,086 32,546 7 353,094 12,335 963 12,002 Disposal Transfers 48,914 1,571 11,932 7,010 18,026 7,563 739 34,083 12,203 983 3,644 11,000 23 32,129 560 682 686 42,139 2,640 154,276 104,134 1,178 2 918 21 270 5,890 7,727 410 63,040 59 6,354 283 3,375 44,923 219 161 43 4,357 149,650 2,185 750 9,025 608 1,581 7 2,445 20,644 23,864 Recycling Transfers 496,127 1,092 16,900 111,499 1,200 Treatment Transfers 103,836 189,168 139,744 16,036 140,970 11,016 396,230 279,459 27,967 23,863 130,496 10,623 7,842 93,704 14,361 11,779 202,220 2,242 641,093 752,822 44,640 180 845,291 7,270 477,729 172,103 5,552 15,850 1,213 10,868 141,955 62 266,856 2,165,679 182 122,052 1,144 128,758 43,309 10,976 50,178 233,199 5,952 6,374 2,515 17,476 19,315 56,460 46 303,839 4,565 4,464 22,737 981,077 24,222 4,407 700 7,346 16,111 483,995 117,720 31,241 70,544 631,395 10,540 1,241,214 169,678 21,600 823,282 380 229,123 2,325 206,023 3,872 18,073 526,289 169,125 293,197 445,879 6,871 96 3,649 286 23,465 Energy Recovery 103,091 5,099 127,276 4,503,153 104,396 77,253 45,681 57,329 529,462 14,556 26,218 491,097 6,787 152,194 207,617 Total Transfers 255,927 195,838 775,082 4,579,968 263,397 214,509 459,831 540,305 607,065 48,766 164,899 512,975 54,466 278,027 223,539 13,319 2,027,932 377,818 528,012 795,435 856,971 162,040 962,323 334,473 39,239 931,716 701,808 32,037 1,820,777 170,150 290,757 287,194 142 2,995,422 5,558 436,550 51,827 337,056 220 47,224 38,999 736,404 191,431 331,277 689,068 7,946 15,507 61,072 23,820 40,245 146,986 131 304,090 7,500 4,565 939,329 10,891,201 1,561,608 24,832 358,555 593,842 1,669,886 155,125 Avg Transfers Per Facility 12,796 10,307 43,060 254,443 14,633 11,917 25,546 30,017 35,710 2,869 10,306 32,061 3,404 17,377 13,971 832 126,746 25,188 35,201 53,029 57,131 10,803 64,155 22,298 2,803 66,551 50,129 2,288 130,055 12,154 22,366 22,092 11 230,417 428 33,581 3,987 28,088 18 3,935 3,250 61,367 15,953 30,116 62,643 722 1,410 6,107 2,382 4,024 14,699 13 30,409 750 507 104,370 1,210,133 173,512 2,759 39,839 65,982 185,543 19,391
1,696,776 335,179
521,926
2,184 224,152 83 82,000 3,392 59 1,200 1 960 1,383 680 58,400 40,158 7,500
32,371 2,843 290 250 311 330 139,544
818,151 70,661 320 341,011 1,660,747 3,579
83,257 10,833,075 509,863 804 239,485 500
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Chemical Name 4,4'-methylenedianiline Vanadium Compounds Dibenzofuran Molybdenum Trioxide 2-chloro-1,1,1,2-tetrafluoroethane Trichlorofluoromethane Boron Trifluoride Freon 113 O-cresol Dimethyl Sulfate 1-chloro-1,1-difluoroethane Chloroacetic Acid 1,2,4-trichlorobenzene Methyl Iodide Bromomethane 2-ethoxyethanol Dibutyl Phthalate Diaminotoluene (Mixed Isomers) 3,3'-dichlorobenzidine Dihydrochloride N,n-dimethylaniline Toluene Diisocyanate (Mixed Isomers) 1,2-butylene Oxide Vinylidene Chloride Propargyl Alcohol 4,6-dinitro-o-cresol Crotonaldehyde Acetamide Di(2-ethylhexyl) Phthalate Dimethyl Phthalate 1,3-phenylenediamine 1,1,2-trichloroethane Phosphorus (Yellow or White) Diethyl Sulfate Cadmium Compounds Monochloropentafluoroethane Aluminum (Fume or Dust) Dinitrotoluene (Mixed Isomers) 2-methylpyridine Methacrylonitrile 1,3-dichlorobenzene Silver 2,4-dimethylphenol 1,1,1-trichloroethane Chloroprene Pentachlorobenzene[PBT] Toluene-2,4-diisocyanate Barium 1,2-dichloroethylene 1,2-phenylenediamine Acifluorfen, Sodium Salt Vanadium (Except When Contained in an Alloy) 1,2-dibromoethane Zinc (Fume or Dust) Titanium Tetrachloride Dichlorotetrafluoroethane (Cfc-114) Benzoyl Peroxide Asbestos (Friable) 2-methyllactonitrile Tetrabromobisphenol A[PBT] 1,1,2,2-tetrachloroethane Methyl Chlorocarbonate Peracetic Acid # Reporting Chemical 8 8 8 8 7 7 7 7 7 7 7 7 6 6 6 6 6 6 6 6 6 5 5 5 5 5 5 5 5 5 4 4 4 4 4 4 4 4 4 4 4 4 4 4 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 POTW Transfers 2,017 250 1 1,556 1 389 255 21,282 225,765 10 365 5 19,098 259 29,347 3,700 64 591 9,026 2,300 60 4,296 7 26,096 114,579 73 7,270 7 2,008 24 5 22,093 940 224,796 148,400 1 32,146 7 10 202 5 80 92 35,917 120,435 553 7 1 581 445 225,664 4,654 353 2,838 16 93,520 7,192 8 142 2,310 621 6,117 2,348 13,764 841,268 2,647 44,830 7,998 115,020 630 84 1,178 46,778 2,079 598,000 240 4,200 2,558,590 62,518 570 Disposal Transfers 6,550 186,514 10,306 57,930 Recycling Transfers 49,040 288 40,294 13,200 128,504 Treatment Transfers 28,028 52,547 17,385 16,990 11,314 117,635 4,048 212,000 161,940 187,863 395 162 23,802 28,245 37,800 79,221 477 11,817 11,533 69,966 11 2,442 3,309 21,446 1,276,247 11,605 720 662 Energy Recovery 249 23,827 20,744 Total Transfers 36,844 235,554 87,218 136,353 30,191 11,314 246,139 79,457 274,519 263,148 389 209,088 21,741 240,918 27,675 493,437 57,105 123,269 91,187 277,758 56,483 67,062 243,203 1,631 2,442 5,795 29,002 1,280,223 2,570,202 720 5,846,891 6,141 2,348 13,769 863,361 6,847 45,770 225,461 7,998 713,020 149,030 85 240 32,146 3,495 46,788 227,743 5,209 2,851 80 250 93,520 43,109 120,435 1,134 453 Avg Transfers Per Facility 4,605 29,444 10,902 17,044 4,313 1,616 35,163 11,351 39,217 37,593 56 34,848 3,623 40,153 4,612 82,240 9,517 20,545 15,198 55,552 11,297 13,412 48,641 326 488 1,159 5,800 256,045 642,550 180 1,461,723 1,535 587 3,442 215,840 1,712 11,443 56,365 1,999 178,255 37,258 28 80 10,715 1,165 15,596 75,914 1,736 950 27 83 31,173 14,370 40,145 378 151
73,853 101,208 16,700 14,400 3,863 455,801 17,000 104,111 7,670 277,281 44,400 86 58,658 1,620 1,030 36 1,671 5,843,600
1,383 250 2,305
665
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Chemical Name 4-nitrophenol 1,4-dichlorobenzene 1,1,1,2-tetrachloroethane 2,4-dinitrotoluene 3-chloro-2-methyl-1-propene Methylene Bromide Isopropyl Alcohol (Manufacturing, Strongacid Proc P-chloroaniline Benzal Chloride P-phenylenediamine N-methylolacrylamide Decabromodiphenyl Oxide Quinone 2,4-dinitrophenol P-nitroaniline Benomyl Benzoic Trichloride Safrole Dihydrosafrole O-anisidine 1,2-dichloro-1,1-difluoroethane Bis(2-chloroethyl) Ether Dicamba Dinitrobutyl Phenol 2-nitrophenol 2-chloro-1,1,1-trifluoroethane 2-mercaptobenzothiazole Dichlorofluoromethane P-cresidine Antimony 2,2-dichloro-1,1,1-trifluoroethane Chromium Cobalt Catechol Ethylidene Dichloride Ethyl Chloroformate Silver Compounds Picloram Nitrapyrin Molinate Propargite C.i. Disperse Yellow 3 Malononitrile Thiourea Prometryn Sodium Dimethyldithiocarbamate Lead[PBT] Manganese Urethane Piperonyl Butoxide Cupferron Trans-1,4-dichloro-2-butene Arsenic P-dinitrobenzene M-dinitrobenzene Ethyleneimine 5-nitro-o-anisidine Styrene Oxide 2,4,5-trichlorophenol Diazinon 1,1,2,2-tetrachloro-1-fluoroethane 1,2-dichloro-1,1,2-trifluoroethane # Reporting Chemical 3 3 3 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 POTW Transfers 59,511 Disposal Transfers Recycling Transfers Treatment Transfers 209,742 50,317 24 7,213 Energy Recovery 837 Total Transfers 59,511 209,742 51,154 24 7,213 402,304 11,797 1,100,092 17,981 289,145 242,302 9,411 49,589 1 5 5 1,983 94,254 130,118 880 8,850 18,034 3,600 200,228 10,630 25,949 15,811 6,463 6,222 5,178 1,260 386 119,698 250 76,999 8,330 250 78,079 12,921 450 Avg Transfers Per Facility 19,837 69,914 17,051 12 3,606 201,152 5,898 550,046 8,990 144,572 121,151 4,705 24,795 1 2 2 991 47,127 65,059 440 4,425 9,017 1,800 100,114 5,315 12,975 7,905 3,231 3,111 2,589 630 193 59,849 250 78,079 12,921 450
402,304 10,947 92 17,981 130 51 8,042 5 5 1,983 500 8,850 2,509 192,242 10,570 12,249 15,811 3,222 2,356 7 340 1,080 1,101 450 119,358 3,000 32 1,260 347 15,525 3,600 6,028 60 1,246 2,822 1,958 94,254 130,118 380 164,935 183,793 1,369 7,560 1 850 1,100,000
124,080 58,458 42,029
13,700
5,217
250
3,240
12 3,076 7,336 866 2,066 8,994 4,141 1,166 17 473 5
12 3,942 9,402 8,994 5,307 17 473 5
12 3,942 9,402 8,994 5,307 17 473 5
7,306
30,589
37,895
37,895
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Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), by Number of Facilities Reporting (Transfers Reported in pounds/year)*
Chemical Name Carbonyl Sulfide O-dinitrobenzene 2,4-diaminotoluene Bis(2-chloroethoxy)methane Allylamine 2,4-d Butyl Ester 2,4-d 3,3'-dichlorobenzidine Perchloromethyl Mercaptan Ozone Fenbutatin Oxide Iron Pentacarbonyl 2,6-dinitrotoluene Oryzalin 3,3'-dimethoxybenzidine Dihydrochloride 2-phenylphenol Dichlorobenzene (Mixed Isomers) Chloromethyl Methyl Ether Methyl Isocyanate Norflurazon Octachlorostyrene[PBT] Pendimethalin[PBT] Hexazinone Permethrin 3-iodo-2-propynyl Butylcarbamate Picric Acid 3,3'-dichlorobenzidine Sulfate Fomesafen Propanil Arsenic Compounds Ethyl Dipropylthiocarbamate 1,4-dichloro-2-butene Chlorophenols Ametryn 2,4-dichlorophenol 2,4,6-trichlorophenol Tetrachlorvinphos N-nitrosodiphenylamine Saccharin (Manufacturing, No Supplier Notification 2-nitropropane Dimethylcarbamyl Chloride 1,2-dichloropropane Paraldehyde Hexachlorocyclopentadiene Pentachloroethane Chlorotrifluoromethane Atrazine Propyleneimine # Reporting Chemical 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 POTW Transfers Disposal Transfers Recycling Transfers Treatment Transfers 61 250 17 Energy Recovery Total Transfers 61 250 467 Avg Transfers Per Facility 61 250 467
450
24 3
24,000
19,180
150,000
193,204 3
193,204 3
110 11,033 686 14,462 448 19 157,038 4,900 39,780 6,240 1 15 762 12,500 1,522 750 53,615 92,934
110 11,033 686 14,910 19 157,038 4,900 39,780 12,500 7,762 750 16 54,377 92,934
110 11,033 686 14,910 19 157,038 4,900 39,780 12,500 7,762 750 16 54,377 92,934
3,010 41,324 3 100
34,600
37,610 41,324 103
37,610 41,324 103 95
1 95 95 1 1 1 1 530 31,661 502 32,693 1 1 1 1 467** 65,055,291 26,150,154 50,991,020 79,389,964 152,670,979 374,257,408 [PBT] Persistent, Bioaccumulative, and Toxic * Refer to Section III for a discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column
headings, and the definition of persistant, bioaccumulative, and toxic chemicals.
**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
32,693
801,407
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The TRI database contains a detailed compilation of self-reported, facilityspecific chemical releases. The top reporting facilities for this sector are listed below (Table 12).
Table 12: Ten Largest Volume TRI Releasing Facilities in the Organic Chemicals Industry*
Rank Facility Total TRI Releases in Pounds 24,266,032 16,870,944 14,799,253 11,282,922 10,648,084 10,306,093 6,885,314 6,684,616 5,846,299 4,882,960
1 BASF Corporation - Freeport, TX BP Chemicals Incorporated - Port Lavaca, TX 2 Du Pont Victoria Plant - Victoria, TX 3 Solutia Chocolate Bayou - Alvin, TX 4 Sterling Chemicals Incorporated - Texas City, TX 5 E I Dupont De Nemours & Company - Beaumont, TX 6 Angus Chemical Company - Sterlington, LA 7 International Specialty Products Technologies Inc. - Texas City, TX 8 Rubicon Incorporated - Geismar, LA 9 Honeywell International Incorporated - Hopewell, VA 10 Source: 2000 Toxics Release Inventory Database * Being included in this list does not mean that the release is associated with non-compliance with environmental laws.
IV.B. Summary of Selected Chemicals Released The following is a synopsis of current scientific toxicity and fate information for the top chemicals (by weight) that facilities within this sector selfreported as released to the environment based upon 2000 TRI data. Because this section is based upon self-reported release data, it does not attempt to provide information on management practices employed by the sector to reduce the releases of these chemicals. Information regarding pollutant release reductions over time may be available from EPAs TRI program, or directly from the industrial trade associations that are listed in Section VIII of this document. Since these descriptions are cursory, please consult the sources referenced below for a more detailed description of both the chemicals described in this section, and the chemicals that appear on the full list of TRI chemicals appearing in Section IV.A. The brief descriptions provided below were taken from the Hazardous Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a computer system run by the National Library of Medicine. It includes a number of toxicological databases managed by EPA, National Cancer
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Institute, and the National Institute for Occupational Safety and Health.1 HSDB contains chemical-specific information on manufacturing and use, chemical and physical properties, safety and handling, toxicity and biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and analysis methods, and additional references. The information contained below is based upon exposure assumptions that have been conducted using standard scientific procedures. The effects listed below must be taken in context of these exposure assumptions that are more fully explained within the full chemical profiles in HSDB. For more information on TOXNET, contact the TOXNET help line at 800-231-3766 or see the website at http://toxnet.nlm.nih.gov/. Nitrate compounds Toxicity. Nitrate compounds that are soluble in water release nitrate ions which can cause both human health and environmental effects. Human infants exposed to aqueous solutions of nitrate ion can develop a condition in which the bloods ability to carry oxygen is reduced. This reduced supply of oxygen can lead to damaged organs and death. Because it is a source of nitrogen, an essential element for aquatic plant growth, nitrate ion may contribute to eutrophication of standing or slow-moving surface water, particularly in nitrogen-limited waters, such as the Chesapeake Bay. Carcinogenicity. There is currently no evidence to suggest that nitrate compounds are carcinogenic. Environmental Fate. Nitrogen in nitrate is the form of nitrogen most available to plants. In the environment, nitrate ion is taken up by plants and becomes part of the natural nitrogen cycle. Excess nitrate can stimulate primary production in plants and can produce changes in the dominant species of plants, leading to cultural eutrophication and ultimately to deterioration of water quality. Methanol (CAS: 67-56-1) Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the respiratory tract, and is toxic to humans in moderate to high doses. In the body, methanol is converted into formaldehyde and formic acid. Methanol is excreted as formic acid. Observed toxic effects at high dose levels generally include central nervous system damage and blindness. Long-term
Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical Substances), and TRI (Toxic Chemical Release Inventory).
1
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exposure to high levels of methanol via inhalation cause liver and blood damage in animals. Ecologically, methanol is expected to have low toxicity to aquatic organisms. Concentrations lethal to half the organisms of a test population are expected to exceed one mg methanol per liter water. Methanol is not likely to persist in water or to bioaccumulate in aquatic organisms. Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic. Environmental Fate. Liquid methanol is likely to evaporate when left exposed. Methanol reacts in air to produce formaldehyde which contributes to the formation of air pollutants. In the atmosphere it can react with other atmospheric chemicals or be washed out by rain. Methanol is readily degraded by microorganisms in soils and surface waters. Physical Properties. Methanol is highly flammable. Ammonia (CAS: 7664-41-7) Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and upper respiratory system. Ecologically, ammonia is a source of nitrogen (an essential element for aquatic plant growth), and may therefore contribute to eutrophication of standing or slow-moving surface water, particularly in nitrogen-limited waters such as the Chesapeake Bay. In addition, aqueous ammonia is moderately toxic to aquatic organisms. Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic. Environmental Fate. Ammonia combines with sulfate ions in the atmosphere and is washed out by rainfall, resulting in rapid return of ammonia to the soil and surface waters. Ammonia is a central compound in the environmental cycling of nitrogen. Ammonia in lakes, rivers, and streams is converted to nitrate. Physical Properties. Ammonia is a corrosive and severely irritating gas with a pungent odor. Nitric Acid (CAS: 7697-37-2) Toxicity. The toxicity of nitric acid is related to its potent corrosivity as an acid, with ulceration of all membranes and tissues with which it comes in Sector Notebook Project 42 November 2002
contact. Concentrated nitric acid causes immediate opacification and blindness of the cornea when it comes in contact with the eye. Inhalation of concentrated nitric acid causes severe, sometimes fatal, corrosion of the respiratory tract. Ingestion of nitric acid leads to gastric hemorrhaging, nausea, and vomiting. Circulatory shock is often the immediate cause of death due to nitric acid exposure. Damage to the respiratory system may be delayed for months, and even years. Populations at increased risk from nitric acid exposure include people with pre-existing skin, eye, or cardiopulmonary disorders. Ecologically, gaseous nitric acid is a component of acid rain. Acid rain causes serious and cumulative damage to surface waters and aquatic and terrestrial organisms by decreasing water and soil pH levels. Nitric acid in rainwater acts as a topical source of nitrogen, preventing hardening off of evergreen foliage and increasing frost damage to perennial plants in temperate regions. Nitric acid also acts as an available nitrogen source in surface water, stimulating plankton and aquatic weed growth. Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic. Environmental Fate. Nitric acid is mainly transported in the atmosphere as nitric acid vapors and in water as dissociated nitrate and hydrogen ions. In soil, nitric acid reacts with minerals such as calcium and magnesium, becoming neutralized, and at the same time decreasing soil buffering capacity against changes in pH levels. Nitric acid leaches readily to groundwater, where it decreases the pH of the affected groundwater. In the winter, gaseous nitric acid is incorporated into snow, causing surges of acid during spring snow melt. Forested areas are strong sinks for nitric acid, incorporating the nitrate ions into plant tissues. Physical Properties. Nitric acid is a colorless or yellow fuming liquid with an acrid smell; it is caustic and corrosive. Ethylene (74-85-1) Toxicity. Ethylene has been used as an anaesthetic; the effects reported here are related to its properties as an anaesthetic. Asphyxia may occur from breathing ethylene in enclosed spaces and in cases where the atmospheric oxygen has been displaced to about 15 to 16 percent or less. Carcinogenicity. According to the International Agency for Research on Cancer, there is inadequate evidence in humans and animals to suggest carcinogenicity in humans.
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Environmental Fate. In the air, ozone, nitrate radicals, and hydroxyl radicals may degrade ethylene. In water and soil, ethylene may be oxidized to produce ethylene oxide, and the chemical may permeate soil and sediment. The major environmental fate process is volatilization. The most probable way humans are exposed is by inhaling ethylene from contaminated air. Physical Properties. Ethylene is a colorless gas with a sweet smell and is non-corrosive. IV.C. Other Data Sources The toxic chemical release data obtained from TRI captures the vast majority of facilities in the organic chemicals industry. It also allows for a comparison across years and industry sectors. Reported chemicals are limited however to the approximately 650 required by TRI. Most of the hydrocarbon emissions from organic chemical facilities are not captured by TRI (EPA, 1992). The EPA Office of Air Quality Planning and Standards has compiled air pollutant emission factors for determining the total air emissions of priority pollutants (e.g., total hydrocarbons, SOx, NOx, CO, particulates, etc.) from many chemical manufacturing sources. The EPA Office of Airs Aerometric Information Retrieval System (AIRS) contains a wide range of information related to stationary sources of air pollution, including the emissions of a number of air pollutants which may be of concern within a particular industry. With the exception of volatile organic compounds (VOCs), there is little overlap with the TRI chemicals reported above. Table 13 summarizes releases in 2001 of volatile organic compounds (VOCs), nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO2), and particulate matter of 10 microns or less (PM10).
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Table 13: Air Pollutant Releases by Industry Sector (tons/year) CO NO2 PM10 PM25 SO2 Industry Sector
Metal Mining Oil and Gas Extraction Non-Fuel, Non-Metal Mineral Mining Textiles Lumber and Wood Products Wood Furniture and Fixtures Pulp and Paper Printing Inorganic Chemicals Plastic Resins and Man-made Fibers Pharmaceuticals Organic Chemicals Agricultural Chemicals Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Castings Nonferrous Metals Fabricated Metal Products Electronics and Computers Motor Vehicle Assembly Aerospace Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Dry Cleaning 8,039 151,763 27,001 7,448 142,955 7,046 567,542 604 176,697 28,890 2,662 128,454 18,492 438,375 2,515 161,113 1,080,576 104,350 418,647 6,029 22,105 13,439 2,832 471 711,155 83 5,231 436,151 217 45,341 366,793 15,747 15,043 37,313 3,008 318,263 2,466 94,938 56,946 14,676 166,398 65,389 298,602 9,565 372,679 105,794 6,298 30,882 11,672 6,428 15,388 7,413 2,139 6,681,163 153 2,079 5,789,099 438 61,358 4,607 48,760 5,343 57,009 6,905 85,403 1,723 19,549 5,493 2,273 34,637 10,257 33,620 5,209 127,283 60,962 22,393 24,019 4,691 3,184 4,016 1,834 1,574 285,932 2,162 186 252,539 190 32,534 4,379 20,956 3,386 38,337 5,260 10,926 226,208 16,874 25,544 9,189 2,779
VOC
2,109 94,549 3,806 18,286 100,761 62,457 144,373 80,982 43,563 83,363 13,407 159,319 12,700 161,207 87,258 32,687 44,608 17,285 8,663 90,575 27,453 95,861 7,440 4,984 191,063 6,787 2,398 54,727 3,163
63,577 488,029 1,723 1,915 12,586 201,994 4,155 1,455 16,900 7,311 26,870 3,217 78,647 47,501 15,654 17,433 3,264 2,349 2,270 1,287 753 165,029 733 140 141,002 117 71,815 17,132 102,461 65,765 478,998 20,368 312,740 307,981 4,770 244,413 18,742 6,882 24,123 5,363 2,537 12,976,279 66 90 12,667,567 220
Source: U.S. EPA Office of Air and Radiation, AIRS Database, 2001.
IV.D. Comparison of Toxic Release Inventory Between Selected Industries The following information is presented as a comparison of pollutant release and transfer data across industrial categories. It is provided to give a general sense as to the relative scale of releases and transfers within each sector profiled under this project. Please note that the following figure and table do not contain releases and transfers for industrial categories that are not included in this project, and thus cannot be used to draw conclusions regarding the total release and transfer amounts that are reported to TRI. Similar information is available within the annual TRI Public Data Release Book.
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Figure 7 is a graphical representation of a summary of the 2000 TRI data for the organic chemical industry and the other sectors profiled in separate notebooks. The bar graph presents the total TRI releases and total transfers on the left axis and the triangle points show the average releases per facility on the right axis. Industry sectors are presented in the order of increasing total TRI releases. The graph is based on the data shown in Table 14 and is meant to facilitate comparisons between the relative amounts of releases, transfers, and releases per facility both within and between these sectors. The reader should note, however, that differences in the proportion of facilities captured by TRI exist between industry sectors. This can be a factor of poor SIC matching and relative differences in the number of facilities reporting to TRI from the various sectors. In the case of the organic chemical industry, the 1993 TRI data presented here covers 417 facilities. Only those facilities listing SIC Codes falling within SIC 286 were used.
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Figure 7: 2000 Summary of TRI Releases and Transfers by Industry
450 400 350 Total Pounds (millions) 300 250 200 150 100 50 0
2821, 2823, 2824 2833, 2834 4911, 493 332, 336 333, 334 372, 376 2911 261-263 271-278 3731 286 281 287 331 371 25 30 32 34 22 10 24 36
SIC Range
Total Releases
Total Transf ers
Key to Standard Industrial Classification (SIC) Codes

SIC Range Industry Sector 02 01, 08 10 13 14 22 24 25 261-263 271-278 Agricultural Crops, Forestry Agricultural Livestock Metal Mining Oil and Gas Extraction SIC Range 281 2821, 2823, 2824 2833, 2834 286 Industry Sector Inorganic Chemicals Plastic Resins and Man-made Fibers Pharmaceuticals Organic Chemicals Agricultural Chemicals Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Casting SIC Range 333, 334 34 36 371 372, 376 3731 40, 42, 46, 49224925, 4932 44 45 4911, 493 7216 Industry Sector Nonferrous Metals Fabricated Metals Electronics and Computers Motor Vehicle Assembly Aerospace Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Generation Dry cleaning
Non-Fuel, Non-Metal Mining 287 Textiles Lumber and Wood Products Furniture and Fixtures Pulp and Paper Printing 2911 30 32 331 332, 336
47
November 2002
Table 14: Toxics Release Inventory Data for Selected Industries

TRI Releases SIC Range 2 Industry sector currently not subject to TRI reporting. Industry sector currently not subject to TRI reporting. 58 Industry sector currently not subject to TRI reporting. Industry sector currently not subject to TRI reporting. 194 410 280 268 163 343 369 151 467 172 162 1,154 484 325 447 181 2,047 419 622 184 39 9.0 56.0 5.3 4.0 54.8 185.3 16.8 125.7 42.1 21,860 63,336 9,081 184,340 7,759 5,968 19,495 8,277 19,884 100.2 28,358 78.5 25,948 78.1 78,927 219.4 47,377 374.3 30.1 36.2 71.0 56.7 327.5 75.5 128.9 275.5 133.7 123.7 30.1 2.5 15.1 19,275 199.0 129.5 45,534 205.1 128.2 64,085 91.8 19.0 50,148 51.5 211.6 90,180 51.5 21,971 21,971 45,921 72,139 254,766 80,833 30,417 11,973 20,099 29,389 164,981 40,849 128,258 38,991 88,279 43,019 46,674 12,316 Industry sector currently not subject to TRI reporting. Industry sector currently not subject to TRI reporting. Industry sector currently not subject to TRI reporting. 613 9,552 NA 23,484 388.7 2,327.8 6,575.7 73,037 1,617,941 280,007 78.0 2,374.1 4,139.7 14,647 Industry sector currently not subject to TRI reporting. NA 1,213,016 176,277 4,701.9 10,715.4 2,830,957 456,285 466.7 87,684 13.0 18,912 13.5 19,605 36.6 28,305 7.1 5,497 8.9 17,018 8.1 15,527 17.0 43.7 26.6 263.1 70.5 220.0 334.5 214.0 593.6 108.3 114.7 171.2 98.8 453.2 92.3 314.2 330.3 142.7 179.7 35.4 6.4 32,545 33,802 38,517 112,151 72,119 110,006 117,673 274,041 128,210 109,344 37,921 48,457 51,249 228,317 49,930 312,598 46,750 94,247 62,514 54,951 32,200 402.1 690,837 2.8 4,894 404.9 695,731 01, 08 10 13 14 22 24 25 261,262,263 271-278 281 2821, 2823, 2824 2833, 2834 286 287 2911 30 32 331 332, 336 333, 334 34 36 371 372, 376 3731 40, 42, 46, 4922- 4925, 4932 44 45 4911, 493 7216 # TRI Facilities Total Ave. Releases Releases per Facility (million lbs.) (pounds) Total Transfers (million lbs.) Ave. Transfers per Facility (pounds) Total Releases +Transfers (million lbs.) Average Releases + Transfers per Facility (pounds) TRI Transfers
Industry Sector
Agricultural Crops, Forestry
Agricultural Livestock
Metal Mining
Oil and Gas Extraction
Non-Fuel, Non-Metal Mining
Textiles
Lumber and Wood Products
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Plastic Resins and Man-made Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
48
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Casting
Nonferrous Metals
Fabricated Metals
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power Generation
Dry cleaning
Sector Notebook Total
November 2002
2000 TRI Total Source: US EPA Toxics Release Inventory Database, 2000.
Organic Chemical Industry V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Some companies have creatively implemented pollution prevention techniques that improve efficiency and increase profits while at the same time minimizing environmental impacts. This can be done in many ways such as reducing material inputs, re-engineering processes to reuse by-products, improving management practices, and substituting benign chemicals for toxic ones. Some smaller facilities are able to actually get below regulatory thresholds just by reducing pollutant releases through aggressive pollution prevention policies. In order to encourage these approaches, this section provides both general and company-specific descriptions of some pollution prevention advances that have been implemented within the organic chemical industry. While the list is not exhaustive, it does provide core information that can be used as the starting point for facilities interested in beginning their own pollution prevention projects. When possible, this section provides information from real activities that can, or are being implemented by this sector -- including a discussion of associated costs, time frames, and expected rates of return. This section provides summary information from activities that may be, or are being implemented by this sector. When possible, information is provided that gives the context in which the technique can be effectively used. Please note that the activities described in this section do not necessarily apply to all facilities that fall within this sector. Facility-specific conditions must be carefully considered when pollution prevention options are evaluated, and the full impacts of the change must examine how each option affects air, land and water pollutant releases. The leaders in the organic chemical industry, similar to those in the chemical industry as a whole, have been promoting pollution prevention through various means. The most visible of these efforts is the Responsible Care initiative of the American Chemistry Council. Responsible Care is mandatory for Council members who must commit to act as stewards for products through use and ultimate reuse or disposal. One of the guiding principles of this initiative is the inclusion of waste and release prevention objectives in research and in design of new or modified facilities, processes and products. The Synthetic Organic Chemical Manufactures Association (SOCMA) also requires its members to implement the Responsible Care Guiding Principles as a condition of membership. SOCMA is instituting the Responsible Care management practice codes on a phased-in basis to assist its approximately 110 non-Council members, which are primarily small and batch chemical manufacturers, in successfully implementing their programs. Using pollution prevention techniques which prevent the release or generation of pollution in the first place have several advantages over end-ofSector Notebook Project 49 November 2002
pipe waste treatment technologies. Table 15 below lists the direct and indirect benefits that could result. Table 15: Pollution Prevention Activities Can Reduce Costs Direct Benefits Reduced waste treatment costs Reduced capital and operating costs for waste treatment facilities Reduced off-site treatment and disposal costs Reduced manufacturing costs due to improved yields Income or savings from sale or reuse of wastes Reduced environmental compliance costs (e.g., fines, shutdowns) Reduced or eliminated inventories or spills Reduced secondary emissions from waste treatment facilities Retained sales (production threatened by poor environmental performance or sales) Indirect Benefits Reduced likelihood of future costs from: Remediation Legal liabilities Complying with future regulations Use of emission offsets (internal and external) Improved community relations Reduced societal costs Improved public health
Source: Chemical Manufacturers Association,1993.
These incentives may encourage organic chemical manufacturers to undertake pollution prevention activities voluntarily, but a number of barriers still exist in achieving widespread adoption of pollution prevention. The U.S. Office of Technology Assessment has identified and characterized a number of these barriers in its report titled Industry, Technology, and the Environment. Pollution prevention can be carried out at any stage during the development of a process. In general, changes made at the research and development stage will have the greatest impact; however, changes in the process design and operating practices can also yield significant results. In the research and development stage, all possible reaction pathways for producing the desired product can be examined. These can then be evaluated in light of yield, undesirable by-products, and their health and environmental impacts. The area of green synthesis is the focus of considerable research funded jointly by the Agency and by the National Science Foundation. Several alternative syntheses have already been developed that could reduce wastes. For example, Joseph M. Desimone of the University of North Sector Notebook Project 50 November 2002
Carolina, Chapel Hill, has used supercritical carbon dioxide as a medium for carrying out dispersion polymerizations. He uses a specially engineered freeradical initiator to start the reaction and a polymeric stabilizer to affect the polymerization of methyl methacrylate. Because the carbon dioxide can easily be separated from the reaction mixture, this reaction offers the possibility of reduced hazardous waste generation, particularly of aqueous streams contaminated with residual monomer and initiator. Because of the large investment in current technology and the lifetime of capital equipment, pollution prevention at the earliest stages is unlikely unless a company undertakes the design of a new production line or facility. Also, producers of specialty chemicals in particular must work within the specifications of customers and maintain the flexibility required to manufacture many chemicals at a single facility. Despite these limitations, there are numerous pollution prevention opportunities that can be realized by modifying current processes and equipment. Table 16 presents examples for several areas of the chemical manufacturing process.
51
November 2002
Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

Area By-products Co-products Quantity and Quality Potential Problem Possible Approach
P Process inefficiencies result in the

generation of undesired by-products and co-products. Inefficiencies will require larger volumes of raw materials and result in additional secondary products. Inefficiencies can also increase fugitive emissions and wastes generated through material handling.
P Increase product yield to reduce byproduct and co-product generation and raw material requirements.
Uses and Outlets
P By-products and co-products are not

fully utilized, generating material or waste that must be managed.
P Identify uses and develop a sales outlet.

Collect information necessary to firm up a purchase commitment such as minimum quality criteria, maximum impurity levels that can be tolerated, and performance criteria.
Catalysts Composition
P The presence of heavy metals in

catalysts can result in contaminated process wastewater from catalyst handling and separation. These wastes may require special treatment and disposal procedures or facilities. Heavy metals can be inhibitory or toxic to biological wastewater treatment units. Sludge from wastewater treatment units may be classified as hazardous due to heavy metals content. Heavy metals generally exhibit low toxicity thresholds in aquatic environments and may bioaccumulate.
P Catalysts comprised of noble metals,

because of their cost, are generally recycled by both onsite and offsite reclaimers.
Preparation and Handling
P Emissions or effluents are generated

with catalyst activation or regeneration.
P Obtain catalyst in the active form. P Provide insitu activation with

appropriate processing/activation facilities.
P Develop a more robust catalyst or P Catalyst attrition and carryover into

product requires de-ashing facilities, which are a likely source of wastewater and solid waste. support.
52
November 2002
Table 16: Process/Product Modifications Create Pollution Prevention Opportunities (Continued)

Area Catalysts (cont.) Preparation and Handling (cont.) Potential Problem Possible Approach
P Catalyst is spent and needs to be

replaced.
P In situ regeneration eliminates

unloading/loading emissions and effluents versus offsite regeneration or disposal.
P Pyrophoric catalyst needs to be kept

wet, resulting in liquid contaminated with metals.
P Use a nonpryrophoric catalyst.

Minimize amount of water required to handle and store safely.
P Short catalyst life.
P Study and identify catalyst deactivitation

mechanisms. Avoid conditions which promote thermal or chemical deactivation. By extending catalyst life, emissions and effluents associated with catalyst handling and regeneration can be reduced.
Effectiveness
P Catalyzed reaction has by-product

formation, incomplete conversion and less-than-perfect yield.
P Reduce catalyst consumption with a

more active form. A higher concentration of active ingredient or increased surface area can reduce catalyst loadings.
P Use a more selective catalyst which will

reduce the yield of undesired by-products.
P Improve reactor mixing/contacting to

increase catalyst effectiveness.
P Catalyzed reaction has by-product

formation, incomplete conversion and less-than perfect yield. Intermediate Products Quantity and Quality
P Develop a thorough understanding of

reaction to allow optimization of reactor design. Include in the optimization, catalyst consumption and by-product yield.
P Intermediate reaction products or

chemical species, including trace levels of toxic constituents, may contribute to process waste under both normal and upset conditions.
P Modify reaction sequence to reduce

amount or change composition of intermediates.
P Intermediates may contain toxic constituents or have characteristics that are harmful to the environment.
P Modify reaction sequence to change

intermediate properties.
P Use equipment design and process

control to reduce releases.
53
November 2002
Table 16: Process/Product Modifications Create Pollution Prevention Opportunities (Continued) Area
Process Conditions/ Configuration Temperature
Potential Problem
Possible Approach
P High heat exchange tube temperatures

cause thermal cracking/decomposition of many chemicals. These lower molecular weight by-products are a source of light ends and fugitive emissions. High localized temperature gives rise to polymerization of reactive monomers, resulting in heavies or tars. Such materials can foul heat exchange equipment or plug fixed-bed reactors, thereby requiring costly equipment cleaning and production outage.
P Select operating temperatures at or near

ambient temperature whenever possible.
P Use lower pressure steam to lower

temperatures.
P Use intermediate exchangers to avoid

contact with furnace tubes and walls.
P Use staged heating to minimize product

degradation and unwanted side reactions.
P Use superheat of high-pressure steam in

place of furnace.
P Monitor exchanger fouling to correlate

process conditions which increase fouling, avoid conditions which rapidly foul exchangers.
P Use online tube cleaning technologies to

keep tube surfaces clean to increase heat transfer.
P Use scraped wall exchangers in viscous

service.
P Use falling film reboiler, pumped recirculation reboiler or high-flux tubes. P Higher operating temperatures imply
heat input usually via combustion which generates emissions.
P Explore heat integration opportunities

(e.g., use waste heat to preheat materials and reduce the amount of combustion required.)
P Heat sources such as furnaces and

boilers are a source of combustion emissions.
P Use thermocompressor to upgrade lowpressure steam to avoid the need for additional boilers and furnaces.
P Vapor pressure increases with

increasing temperature. Loading/ unloading, tankage and fugitive emissions generally increase with increasing vapor pressure.
P If possible, cool materials before sending

to storage.
P Use hot process streams to reheat feeds.
54
November 2002

Area Process Conditions/ Configuration (cont.) Potential Problem Possible Approach
P Add vent condensers to recover vapors

Temperature (cont.) in storage tanks or process.
P Add closed dome loading with vapor

recovery condensers.
P Water solubility of most chemicals

increases with increasing temperature. Pressure
P Use lower temperature (vacuum

processing).
P Fugitive emissions from equipment.
P Equipment operating in vacuum service

is not a source of fugitives; however, leaks into the process require control when system is degassed.
P Seal leakage potential due to pressure

differential.
P Minimize operating pressure. P Determine whether gases can be recovered, compressed, and reused or require controls. P Improve metallurgy or provide coating
or lining.
P Gas solubility increases with higher

pressures. Corrosive Environment
P Material contamination occurs from

corrosion products. Equipment failures result in spills, leaks and increased maintenance costs.
P Neutralize corrosivity of materials

contacting equipment.
P Use corrosion inhibitors. P Increased waste generation due to

addition of corrosion inhibitors or neutralization. Batch vs. Continuous Operations
P Improve metallurgy or provide coating

or lining or operate in a less corrosive environment.
P Vent gas lost during batch fill.
PEqualize reactor and storage tank vent

lines.
PRecover vapors through condenser,

adsorber, etc.
P Waste generated by cleaning/purging

of process equipment between production batches.
P Use materials with low viscosity.

Minimize equipment roughness.
55
November 2002

Area Process Conditions/ Configuration (cont.) Potential Problem Possible Approach
P Optimize product manufacturing

Batch vs. Continuous Operations (cont.) sequence to minimize washing operations and cross-contamination of subsequent batches.
P Process inefficiencies lower yield and

increase emissions.
P Sequence addition of reactants and

reagents to optimize yields and lower emissions.
P Continuous process fugitive emissions

and waste increase over time due to equipment failure through a lack of maintenance between turnarounds. Process Operation/Design
PDesign facility to readily allow

maintenance so as to avoid unexpected equipment failure and resultant release.
P Numerous processing steps create

wastes and opportunities for errors.
P Keep it simple. Make sure all operations

are necessary. More operations and complexity only tend to increase potential emission and waste sources.
P Nonreactant materials (solvents,

absorbants, etc.) create wastes. Each chemical (including water) employed within the process introduces additional potential waste sources; the composition of generated wastes also tends to become more complex.
P Evaluate unit operation or technologies

(e.g., separation) that do not require the addition of solvents or other nonreactant chemicals.
P High conversion with low yield results

in wastes.
P Recycle operations generally improve

overall use of raw materials and chemicals, thereby both increasing the yield of desired products while at the same time reducing the generation of wastes. A casein-point is to operate at a lower conversion per reaction cycle by reducing catalyst consumption, temperature, or residence time. Many times, this can result in a higher selectivity to desired products. The net effect upon recycle of unreacted reagents is an increase in product yield, while at the same time reducing the quantities of spent catalyst and less desirable by-products.
56
November 2002

Area Process Conditions/ Configuration (cont.) Process Operation/Design Potential Problem Possible Approach
P Non-regenerative treatment systems

result in increased waste versus regenerative systems.
P Regenerative fixed bed treating or

desiccant operation (e.g., aluminum oxide, silica, activated carbon, molecular sieves, etc.) will generate less quantities of solid or liquid waste than nonregenerative units (e.g., calcium chloride or activated clay). With regenerative units though, emissions during bed activation and regeneration can be significant. Further, side reactions during activation/regeneration can give rise to problematic pollutants.
Product Process Chemistry
P Insufficient R&D into alternative

reaction pathways may miss pollution opportunities such as waste reduction or eliminating a hazardous constituent.
P R&D during process conception and

laboratory studies should thoroughly investigate alternatives in process chemistry that affect pollution prevention.
Product Formulation
P Product based on end-use performance

may have undesirable environmental impacts or use raw materials or components that generate excessive or hazardous wastes.
P Reformulate products by substituting

different material or using a mixture of individual chemicals that meet end-use performance specifications.
Raw Materials Purity
P Impurities may produce unwanted byproducts and waste. Toxic impurities, even in trace amounts, can make a waste hazardous and therefore subject to strict and costly regulation. P Excessive impurities may require more
processing and equipment to meet product specifications, increasing costs and potential for fugitive emissions, leaks, and spills.
P Use higher purity materials. P Purify materials before use and reuse if
practical.
P Use inhibitors to prevent side reactions. P Achieve balance between feed purity,
processing steps, product quality and waste generation.
P Specifying a purity greater than needed

by the process increases costs and can result in more waste generation by the supplier.
P Specify a purity no greater than what the

process needs.
57
November 2002

Area Raw Materials (cont.) Potential Problem Possible Approach
P Impurities in clean air can increase

Purity (cont.) inert purges.
PUse pure oxygen. PInstall guard beds to protect catalysts.
P Impurities may poison catalyst

prematurely resulting in increased wastes due to yield loss and more frequent catalyst replacement. Vapor Pressure
P Higher vapor pressures increase

fugitive emissions in material handling and storage.
P Use material with lower vapor pressure.
P High vapor pressure with low odor

threshold materials can cause nuisance odors. Water Solubility
P Use materials with lower vapor pressure

and higher odor threshold.
P Toxic or nonbiodegradable materials

that are water soluble may affect wastewater treatment operation, efficiency, and cost.
P Use less toxic or more biodegradable

materials.
P Higher solubility may increase

potential for surface and groundwater contamination and may require more careful spill prevention, containment, and cleanup (SPCC) plans.
P Use less soluble materials.
P Higher solubility may increase

potential for storm water contamination in open areas.
P Use less soluble materials. P Prevent direct contact with storm water
by diking or covering areas.
P Process wastewater associated with

water washing or hydrocarbon/water phase separation will be impacted by containment solubility in water. Appropriate wastewater treatment will be impacted.
P Minimize water usage. P Reuse wash water. P Determine optimum process conditions
for phase separation.
P Evaluate alternative separation

technologies (coalescers, membranes, distillation, etc.)
58
November 2002

Area Raw Materials (cont.) Toxicity Potential Problem Possible Approach
P Community and worker safety and

health concerns result from routine and nonroutine emissions. Emissions sources include vents, equipment leaks, wastewater emissions, emergency pressure relief, etc.
P Use less toxic materials. P Reduce exposure through equipment

design and process control. Use systems which are passive for emergency containment of toxic releases.
P Surges or higher than normal continuous levels of toxic materials can shock or miss wastewater biological treatment systems resulting in possible fines and possible toxicity in the receiving water.
P Use less toxic material. P Reduce spills, leaks, and upset

conditions through equipment and process control.
P Consider effect of chemicals on

biological treatment; provide unit pretreatment or diversion capacity to remove toxicity.
P Install surge capacity for flow and

concentration equalization. Regulatory
P Hazardous or toxic materials are

stringently regulated. They may require enhanced control and monitoring; increased compliance issues and paperwork for permits and record keeping; stricter control for handling, shipping, and disposal; higher sampling and analytical costs; and increased health and safety costs.
P Use materials which are less toxic or

hazardous.
P Use better equipment and process design

to minimize or control releases; in some cases, meeting certain regulatory criteria will exempt a system from permitting or other regulatory requirements.
Form of Supply
P Small containers increase shipping

frequency which increases chances of material releases and waste residues from shipping containers (including wash waters).
P Use bulk supply, ship by pipeline, or use

jumbo drums or sacks.
P In some cases, product may be shipped

out in the same containers the material supply was shipped in without washing.
P Nonreturnable containers may increase waste.

Handling and Storage
P Use returnable shipping containers or

drums.
P Physical state (solid, liquid, gaseous)

may raise unique environmental, safety, and health issues with unloading operations and transfer to process equipment.
P Use equipment and controls appropriate

to the type of materials to control releases.
59
November 2002

Area Raw Materials (cont.) Potential Problem Possible Approach
P Large inventories can lead to spills,

Handling and Storage (cont.) Waste Streams Quantity and Quality inherent safety issues and material expiration.
P Minimize inventory by utilizing just-intime delivery.
P Characteristics and sources of waste

streams are unknown.
P Document sources and quantities of

waste streams prior to pollution prevention assessment.
P Wastes are generated as part of the

process.
P Determine what changes in process

conditions would lower waste generation of toxicity.
P Determine if wastes can be recycled

back into the process. Composition
P Hazardous or toxic constituents are

found in waste streams. Examples are: sulfides, heavy metals, halogenated hydrocarbons, and polynuclear aromatics.
P Evaluate whether different process

conditions, routes, or reagent chemicals (e.g., solvent catalysts) can be substituted or changed to reduce or eliminate hazardous or toxic compounds.
Properties
P Environmental fate and waste

properties are not known or understood.
P Evaluate waste characteristics using the

following type properties: corrosivity, ignitability, reactivity, BTU content (energy recovery), biodegradability, aquatic toxicity, and bioaccumulation potential of the waste and of its degradable products, and whether it is a solid, liquid, or gas.
Disposal
P Ability to treat and manage hazardous

and toxic waste unknown or limited.
P Consider and evaluate all onsite and

offsite recycle, reuse, treatment, and disposal options available. Determine availability of facilities to treat or manage wastes generated.
60
November 2002
Organic Chemical Industry Table 17: Modifications to Equipment Can Also Prevent Pollution
Possible Approach Equipment Compressors, blowers, fans Potential Environment Problem Design Related Operational Related
P Shaft seal leaks, piston

rod seal leaks, and vent streams
P Seal-less designs
(diaphragmatic, hermetic or magnetic)
P Preventive maintenance
program
P Design for low emissions

(internal balancing, double inlet, gland eductors)
P Shaft seal designs (carbon

rings, double mechanical seals, buffered seals)
P Double seal with barrier fluid

vented to control device Concrete pads, P Leaks to groundwater floors, sumps
P Water stops P Embedded metal plates P Epoxy sealing P Other impervious sealing
P Reduce unnecessary purges,

transfers, and sampling
P Use drip pans where

necessary
Controls
P Shutdowns and startups generate waste and releases
P Improve on-line controls P On-line instrumentation P Automatic start-up and

shutdown
P Continuous versus batch P Optimize on-line run time P Optimize shutdown interlock
inspection frequency
P Identify safety and P On-line vibration analysis P Use consensus systems (e.g., shutdown trip requires 2 out of 3 affirmative responses)
Distillation environment critical instruments and equipment
P Impurities remain in
process streams
P Increase reflux ratio P Add section to column P Column intervals P Change feed tray
P Change column operating

conditions - reflux ratio - feed tray - temperature - pressure - etc.
61
November 2002
Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued)

Possible Approach Equipment Distillation (cont.) Potential Environment Problem Design Related Operational Related
P Impurities remain in
process streams (cont.)
P Insulate to prevent heat loss P Preheat column feed P Increase vapor line size to
lower pressure drop
P Clean column to reduce

fouling
P Large amounts of
contaminated water condensate from stream stripping General P Contaminated manufacturing rainwater equipment areas
P Use reboilers or inert gas

stripping agents
P Use higher temperature steam
P Provide roof over process

facilities
P Return samples to process P Monitor stormwater discharge
P Segregate process sewer from

storm sewer (diking)
P Hard-pipe process streams to

process sewer
P Contaminated
sprinkler and fire water
P Seal floors P Drain to sump P Route to waste treatment
P Leaks and emissions

during cleaning
P Design for cleaning P Design for minimum rinsing
P Use drip pans for maintenance

activities
P Rinse to sump P Design for minimum sludge P Reuse cleaning solutions P Provide vapor enclosure P Drain to process
Heat exchangers
P Increased waste due to

high localized temperatures
P Use intermediate exchangers to

avoid contact with furnace tubes and walls
P Select operating temperatures

at or near ambient temperature when-ever possible. These are generally most desirable from a pollution prevention standpoint
P Use staged heating to minimize product degradation and unwanted side reactions. (waste heat >>low pressure steam >>high pressure steam)
P Use lower pressure steam to

lower temperatures
62
November 2002

Possible Approach Equipment Heat exchangers (cont.) Potential Environment Problem Design Related Operational Related
P Increased waste due to

high localized temperatures (cont.)
P Use scraped wall exchangers in

viscous service
P Monitor exchanger fouling to

correlate process conditions which increase fouling, avoid conditions which rapidly foul exchangers
P Using falling film reboiler,

piped recirculation reboiler or high-flux tubes
P Use lowest pressure steam

possible
P Use on-line tube cleaning

techniques to keep tube surfaces clean
P Contaminated
materials due to tubes leaking at tube sheets
P Use welded tubes or double

tube sheets with inert purge. Mount vertically
P Monitor for leaks
P Furnace emissions
Piping
P Use superheat of high-pressure

steam in place of a furnace
P Leaks to groundwater;
fugitive emissions
P Design equipment layout so as

to minimize pipe run length
P Monitor for corrosion and

erosion
P Eliminate underground piping

or design for cathodic protection if necessary to install piping underground
P Paint to prevent external

corrosion
P Welded fittings P Reduce number of flanges and

valves
P All welded pipe P Secondary containment P Spiral-wound gaskets P Use plugs and double valves for
open end lines
P Change metallurgy P Use lined pipe
63
November 2002

Possible Approach Equipment Piping (cont.) Potential Environment Problem Design Related Operational Related
P Releases when
cleaning or purging lines
P Use pigs for cleaning P Slope to low point drain P Use heat tracing and insulation
to prevent freezing
P Flush to product storage tank
P Install equalizer lines

Pumps
P Fugitive emissions
from shaft seal leaks
P Mechanical seal in lieu of

packing
P Seal installation practices P Monitor for leaks
P Double mechanical seal with

inert barrier fluid
P Double machined seal with

barrier fluid vented to control device
P Seal-less pump (canned motor

magnetic drive)
P Vertical pump P Fugitive emissions

from shaft seal leaks
P Use pressure transfer to

eliminate pump
P Residual heel of
liquid during pump maintenance
P Low point drain on pump

casing
P Flush casing to process sewer

for treatment
P Increase the mean time

between pump failures by: - selecting proper seal material; - good alignment; - reduce pipe-induced stress - Maintaining seal lubrication
P Injection of seal flush

fluid into process stream Reactors
P Use double mechanical seal

with inert barrier fluid where practical
P Poor conversion or
performance due to inadequate mixing
P Static mixing P Add baffles P Change impellers
P Add ingredients with optimum

sequence
64
November 2002

Possible Approach Equipment Reactors (cont.) Potential Environment Problem Design Related Operational Related
P Poor conversion
(cont.)
P Add horsepower P Add distributor
P Allow proper head space in

reactor to enhance vortex effect
P Waste by-product
formation
P Provide separate reactor for

converting recycle streams to usable products
P Optimize reaction conditions

(temperature, pressure, etc.)
Relief Valve
P Leaks P Fugitive emissions P Discharge to

environment from over pressure
P Provide upstream rupture disc P Vent to control or recovery

device
P Monitor for leaks and for

control efficiency
P Pump discharges to suction of

pump
P Monitor for leaks
P Thermal relief to tanks P Avoid discharge to roof areas to

prevent contamination of rainwater
P Frequent relief
P Use pilot operated relief valve

and operating pressure
P Reduce operating pressure
P Increase margin between design P Review system performance
Sampling
P Waste generation due

to sampling (disposal, containers, leaks, fugitives, etc.)
P In-line insitu analyzers P System for return to process
P Reduce number and size of

samples required
P Sample at the lowest possible P Closed loop P Drain to sump

temperature
P Cool before sampling P Optimize storage conditions to

reduce losses
Tanks
P Tank breathing and

working losses
P Cool materials before storage P Insulate tanks P Vent to control device (flare,
condenser, etc.)
P Vapor balancing P Floating roof
65
November 2002

Possible Approach Equipment Tanks (cont.) Potential Environment Problem Design Related Operational Related
P Tank breathing and

working losses (cont.)
P Floating roof P Higher design pressure
P Leak to groundwater
P All aboveground (situated so

bottom can routinely be checked for leaks)
P Monitor for leaks and

corrosion
P Secondary containment P Improve corrosion resistance P Large waste heel

Vacuum Systems
P Design for 100% de-inventory P Substitute mechanical vacuum

pump
P Recycle to process if practical P Monitor for air leaks P Recycle condensate to process P Stringent adherence to packing
procedures
P Waste discharge from

jets
P Evaluate using process fluid for

powering jet Valves
P Fugitive emissions
from leaks
P Bellow seals P Reduce number where practical P Special packing sets
Vents
P Release to
environment
P Route to control or recovery

device
P Monitor performance
It is critical to emphasize that pollution prevention in the chemical industry is process specific and oftentimes constrained by site-specific considerations. As such, it is difficult to generalize about the relative merits of different pollution prevention strategies. The age, size, and purpose of the plant will influence the choice of the most effective pollution prevention strategy. Commodity chemical manufacturers redesign their processes infrequently so that redesign of the reaction process or equipment is unlikely in the short term. Here operational changes are the most feasible response. Specialty chemical manufacturers are making a greater variety of chemicals and have more process and design flexibility. Incorporating changes at the earlier research and development phases may be possible for them. Changes in operational practices may yield the most immediate gains with the least investment. For example, the majority of the waste generated by the Sector Notebook Project 66 November 2002
chemical processing industry is contaminated water: Borden Chemical Company has collected and isolated its waste water in a trench coming from the phenol rail car unloading area and reused the water in resin batches. This eliminated the entire waste stream with a capital investment of $3,000 and annual savings of $1,500 a year in treatment costs. Rhone-Poulenc, in New Brunswick, New Jersey, is now sending all quality control and raw material samples back to be reused in the production process saving $20,000 per year and reducing waste volume by 3,000 pounds. Another area that can yield significant benefits is improved process control so that less off-specification product is produced (that must be discarded) and the process is run more optimally (fewer by-products). Exxon Chemical Americas of Linden, New Jersey, used continuous process optimization to reduce the generation of acid coke, a process residue, thus saving $340,000 annually in treatment costs. New in-line process controls are under development (a fertile area of research being pursued by the Center for Process Analytic Chemistry at the University of Washington) that may allow better process optimization through tighter process control. Chemical substitution, particularly of water for non-aqueous solvents, can also prevent pollution. For example, Du Pont at the Chamber Works in New Jersey is using a high-pressure water-jet system to clean polymer reaction vessels. This replaces organic solvent cleaning that annually produced 40,000 pounds of solvent waste. Installing the new cleaning system cost $125,000 but it will save $270,000 annually. Improved separations design also offers a pollution prevention opportunity since separations account for about 20 percent of energy use in the chemical process industry. In one case, a solvent was replaced by an excess of a reaction component, thus eliminating the need to separate the solvent from the waste stream while reducing separation costs.
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Organic Chemical Industry VI.
Federal Statutes and Regulations
SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS This section discusses the federal regulations that may apply to this sector. The purpose of this section is to highlight and briefly describe the applicable federal requirements, and to provide citations for more detailed information. The three following sections are included:
C C C
Section VI.A contains a general overview of major statutes

Section VI.B contains a list of regulations specific to this industry
Section VI.C contains a list of pending and proposed regulatory
requirements.
The descriptions within Section VI are intended solely for general information. Depending upon the nature or scope of the activities at a particular facility, these summaries may or may not necessarily describe all applicable environmental requirements. Moreover, they do not constitute formal interpretations or clarifications of the statutes and regulations. For further information, readers should consult the Code of Federal Regulations and other state or local regulatory agencies. EPA Hotline contacts are also provided for each major statute. VI.A. General Description of Major Statutes Clean Water Act The primary objective of the Federal Water Pollution Control Act, commonly referred to as the Clean Water Act (CWA), is to restore and maintain the chemical, physical, and biological integrity of the nation's surface waters. Pollutants regulated under the CWA are classified as either toxic pollutants; conventional pollutants, such as biochemical oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH; or non-conventional pollutants, including any pollutant not identified as either conventional or priority. The CWA regulates both direct and indirect dischargers (those who discharge to publicly owned treatment works). The National Pollutant Discharge Elimination System (NPDES) permitting program (CWA section 402) controls direct discharges into navigable waters. Direct discharges or point source discharges are from sources such as pipes and sewers. NPDES permits, issued by either EPA or an authorized state (EPA has authorized 43 states and one territory to administer the NPDES program), contain industry-specific, technology-based and water quality-based limits and establish pollutant monitoring and reporting requirements. A facility that proposes to discharge into the nation's waters must obtain a permit prior to initiating a discharge. A permit applicant must provide quantitative analytical data identifying the types of pollutants present in the facility's Sector Notebook Project 68 November 2002
effluent. The permit will then set forth the conditions and effluent limitations
under which a facility may make a discharge.
Water quality-based discharge limits are based on federal or state water
quality criteria or standards, that were designed to protect designated uses of
surface waters, such as supporting aquatic life or recreation. These
standards, unlike the technology-based standards, generally do not take into
account technological feasibility or costs. Water quality criteria and
standards vary from state to state, and site to site, depending on the use
classification of the receiving body of water. Most states follow EPA
guidelines which propose aquatic life and human health criteria for many of
the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated NPDES
permitting regulations for storm water discharges. These regulations require
that facilities with the following types of storm water discharges, among
others, apply for an NPDES permit: (1) a discharge associated with industrial
activity; (2) a discharge from a large or medium municipal storm sewer
system; or (3) a discharge which EPA or the state determines to contribute
to a violation of a water quality standard or is a significant contributor of
pollutants to waters of the United States.
The term storm water discharge associated with industrial activity means a storm water discharge from one of 11 categories of industrial activity defined at 40 CFR Part 122.26. Six of the categories are defined by SIC codes while the other five are identified through narrative descriptions of the regulated industrial activity. If the primary SIC code of the facility is one of those identified in the regulations, the facility is subject to the storm water permit application requirements. If any activity at a facility is covered by one of the five narrative categories, storm water discharges from those areas where the activities occur are subject to storm water discharge permit application requirements. Those facilities/activities that are subject to storm water discharge permit application requirements are identified below. To determine whether a particular facility falls within one of these categories, the regulation should be consulted. Category i: Facilities subject to storm water effluent guidelines, new source performance standards, or toxic pollutant effluent standards. Category ii: Facilities classified as SIC 24-lumber and wood products (except wood kitchen cabinets); SIC 26-paper and allied products (except paperboard containers and products); SIC 28-chemicals and allied products Sector Notebook Project 69 November 2002
(except drugs and paints); SIC 29-petroleum refining; SIC 311-leather tanning and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete; SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373ship and boat building and repairing. Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral mining. Category iv: Hazardous waste treatment, storage, or disposal facilities. Category v: Landfills, land application sites, and open dumps that receive or have received industrial wastes. Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and SIC 5093-automotive scrap and waste material recycling facilities. Category vii: Steam electric power generating facilities. Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41local passenger transportation; SIC 42-trucking and warehousing (except public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk storage stations and terminals. Category ix: Sewage treatment works. Category x: Construction activities except operations that result in the disturbance of less than five acres of total land area. Category xi: Facilities classified as SIC 20-food and kindred products; SIC 21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted paper and paperboard products; SIC 27-printing, publishing, and allied industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and allied products; SIC 30-rubber and plastics; SIC 31-leather and leather products (except leather and tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal products (except fabricated structural metal); SIC 35-industrial and commercial machinery and computer equipment; SIC 36electronic and other electrical equipment and components; SIC 37transportation equipment (except ship and boat building and repairing); SIC 38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous manufacturing industries; and SIC 4221-4225-public warehousing and storage.
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Phase II storm water requirements were established in 1999. Permits are now
required for certain small municipal separate storm sewer systems (MS4s)
and for construction activity disturbing between one and five acres of land
(i.e., small construction activities). The Phase II rule also revised the no
exposure exclusion and the temporary exemption for certain industrial
facilities that had been established under Phase I regulations.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to
a publicly owned treatment works (POTW). The national pretreatment
program (CWA section 307(b)) controls the indirect discharge of pollutants
to POTWs by industrial users. Facilities regulated under section 307(b)
must meet certain pretreatment standards. The goal of the pretreatment
program is to protect municipal wastewater treatment plants from damage
that may occur when hazardous, toxic, or other wastes are discharged into a
sewer system and to protect the quality of sludge generated by these plants.
EPA has developed technology-based standards for industrial users of POTWs. Different standards apply to existing and new sources within each category. Categorical pretreatment standards applicable to an industry on a nationwide basis are developed by EPA. In addition, another kind of pretreatment standard, local limits, are developed by the POTW in order to assist the POTW in achieving the effluent limitations in its NPDES permit. Regardless of whether a state is authorized to implement either the NPDES or the pretreatment program, if it develops its own program, it may enforce requirements more stringent than federal standards. Wetlands Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools, playas, and prairie potholes, are a subset of waters of the United States, as defined in Section 404 of the CWA. The placement of dredge and fill material into wetlands and other water bodies (i.e., waters of the United States) is regulated by the U.S. Army Corps of Engineers (Corps) under 33 CFR Part 328. The Corps regulates wetlands by administering the CWA Section 404 permit program for activities that impact wetlands. EPAs authority under Section 404 includes veto power of Corps permits, authority to interpret statutory exemptions and jurisdiction, enforcement actions, and delegating the Section 404 program to the states. EPAs Office of Water, at 202-566-1730, will direct callers with questions about the CWA to the appropriate EPA office. EPA also maintains a bibliographic database of Office of Water publications which can be accessed through the Ground Water and Drinking Water Resource Center, at 800-426-4791.
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Oil Pollution Prevention Regulation Section 311(b) of the CWA prohibits the discharge of oil, in such quantities as may be harmful, into the navigable waters of the United States and adjoining shorelines. The EPA Discharge of Oil regulation, 40 CFR Part 110, provides information regarding these discharges. The Oil Pollution Prevention regulation, 40 CFR Part 112, under the authority of Section 311(j) of the CWA, requires regulated facilities to prepare and implement Spill Prevention Control and Countermeasure (SPCC) plans. The intent of a SPCC plan is to prevent the discharge of oil from onshore and offshore nontransportation-related facilities. In 1990 Congress passed the Oil Pollution Act which amended Section 311(j) of the CWA to require facilities that because of their location could reasonably be expected to cause substantial harm to the environment by a discharge of oil to develop and implement Facility Response Plans (FRP). The intent of a FRP is to provide for planned responses to discharges of oil. A facility is SPCC-regulated if the facility, due to its location, could reasonably be expected to discharge oil into or upon the navigable waters of the United States or adjoining shorelines, and the facility meets one of the following criteria regarding oil storage: (1) the capacity of any aboveground storage tank exceeds 660 gallons, or (2) the total aboveground storage capacity exceeds 1,320 gallons, or (3) the underground storage capacity exceeds 42,000 gallons. 40 CFR Part 112.7 contains the format and content requirements for a SPCC plan. In New Jersey, SPCC plans can be combined with discharge prevention, containment and countermeasures (DPCC) plans, required by the state, provided there is an appropriate cross-reference index to the requirements of both regulations at the front of the plan. According to the FRP regulation, a facility can cause substantial harm if it meets one of the following criteria: (1) the facility has a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to or from vessels; or (2) the facility has a total oil storage capacity greater than or equal to one million gallons and meets any one of the following conditions: (i) does not have adequate secondary containment, (ii) a discharge could cause injury to fish and wildlife and sensitive environments, (iii) shut down a public drinking water intake, or (iv) has had a reportable oil spill greater than or equal to 10,000 gallons in the past five years. Appendix F of 40 CFR Part 112 contains the format and content requirements for a FRP. FRPs that meet EPAs requirements can be combined with U.S. Coast Guard FRPs or other contingency plans, provided there is an appropriate cross-reference index to the requirements of all applicable regulations at the front of the plan. For additional information regarding SPCC plans, contact EPAs RCRA, Superfund, and EPCRA Call Center, at 800-424-9346. Additional documents and resources can be obtained from the hotlines homepage at Sector Notebook Project 72 November 2002
www.epa.gov/epaoswer/hotline. The hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays. Safe Drinking Water Act The Safe Drinking Water Act (SDWA) mandates that EPA establish regulations to protect human health from contaminants in drinking water. The law authorizes EPA to develop national drinking water standards and to create a joint federal-state system to ensure compliance with these standards. The SDWA also directs EPA to protect underground sources of drinking water through the control of underground injection of fluid wastes. EPA has developed primary and secondary drinking water standards under its SDWA authority. EPA and authorized states enforce the primary drinking water standards, which are contaminant-specific concentration limits that apply to certain public drinking water supplies. Primary drinking water standards consist of maximum contaminant level goals (MCLGs), which are non-enforceable health-based goals, and maximum contaminant levels (MCLs), which are enforceable limits set generally as close to MCLGs as possible, considering cost and feasibility of attainment. Part C of the SDWA mandates EPA to protect underground sources of drinking water from inadequate injection practices. EPA has published regulations codified in 40 CFR Parts 144 to 148 to comply with this mandate. The Underground Injection Control (UIC) regulations break down injection wells into five different types, depending on the fluid injected and the formation that receives it. The regulations also include construction, monitoring, testing, and operating requirements for injection well operators. All injection wells have to be authorized by permit or by rule depending on their potential to threaten Underground Sources of Drinking Water (USDW). RCRA also regulates hazardous waste injection wells and a UIC permit is considered to meet the requirements of a RCRA permit. EPA has authorized delegation of the UIC for all wells in 35 states, implements the program in 10 states and all Indian lands, and shares responsibility with five states. The SDWA also provides for a federally-implemented Sole Source Aquifer program, which prohibits federal funds from being expended on projects that may contaminate the sole or principal source of drinking water for a given area, and for a state-implemented Wellhead Protection program, designed to protect drinking water wells and drinking water recharge areas. The SDWA Amendments of 1996 require states to develop and implement source water assessment programs (SWAPs) to analyze existing and potential threats to the quality of the public drinking water throughout the state. Every state is required to submit a program to EPA and to complete all assessments within 3 years of EPA approval of the program. SWAPs include: (1) Sector Notebook Project 73 November 2002
delineating the source water protection area, (2) conducting a contaminant source inventory, (3) determining the susceptibility of the public water supply to contamination from the inventories sources, and (4) releasing the results of the assessments to the public. EPAs Safe Drinking Water Hotline, at 800-426-4791, answers questions and distributes guidance pertaining to SDWA standards. The Hotline operates from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays. Visit the website at www.epa.gov/ogwdw for additional material. Resource Conservation and Recovery Act The Solid Waste Disposal Act (SWDA), as amended by the Resource Conservation and Recovery Act (RCRA) of 1976, addresses solid and hazardous waste management activities. The Act is commonly referred to as RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984 strengthened RCRAs waste management provisions and added Subtitle I, which governs underground storage tanks (USTs). Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 260-299) establish a cradle-to-grave system governing hazardous waste from the point of generation to disposal. RCRA hazardous wastes include the specific materials listed in the regulations (discarded commercial chemical products, designated with the code P or U; hazardous wastes from specific industries/sources, designated with the code K; or hazardous wastes from non-specific sources, designated with the code F) or materials which exhibit a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity and designated with the code D). Entities that generate hazardous waste are subject to waste accumulation, manifesting, and recordkeeping standards. A hazardous waste facility may accumulate hazardous waste for up to 90 days (or 180 days depending on the amount generated per month) without a permit or interim status. Generators may also treat hazardous waste in accumulation tanks or containers (in accordance with the requirements of 40 CFR Part 262.34) without a permit or interim status. Facilities that treat, store, or dispose of hazardous waste are generally required to obtain a RCRA permit. Subtitle C permits are required for treatment, storage, or disposal facilities. These permits contain general facility standards such as contingency plans, emergency procedures, recordkeeping and reporting requirements, financial assurance mechanisms, and unit-specific standards. RCRA also contains provisions (40 CFR Subparts I and S) for conducting corrective actions which govern the cleanup of releases of hazardous waste or constituents from solid waste management units at RCRA treatment, storage, or disposal facilities. Sector Notebook Project 74 November 2002
Although RCRA is a federal statute, many states implement the RCRA program. Currently, EPA has delegated its authority to implement various provisions of RCRA to 47 of the 50 states and two U.S. territories. Delegation has not been given to Alaska, Hawaii, or Iowa. Most RCRA requirements are not industry specific but apply to any company that generates, transports, treats, stores, or disposes of hazardous waste. Here are some important RCRA regulatory requirements:
C
Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR Part 257) establishes the criteria for determining which solid waste disposal facilities and practices pose a reasonable probability of adverse effects on health or the environment. The criteria were adopted to ensure non-municipal, non-hazardous waste disposal units that receive conditionally exempt small quantity generator waste do not present risks to human health and environment. Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) establishes minimum national criteria for all municipal solid waste landfill units, including those that are used to dispose of sewage sludge. Identification of Solid and Hazardous Wastes (40 CFR Part 261) establishes the standard to determine whether the material in question is considered a solid waste and, if so, whether it is a hazardous waste or is exempted from regulation. Standards for Generators of Hazardous Waste (40 CFR Part 262) establishes the responsibilities of hazardous waste generators including obtaining an EPA identification number, preparing a manifest, ensuring proper packaging and labeling, meeting standards for waste accumulation units, and recordkeeping and reporting requirements. Generators can accumulate hazardous waste on-site for up to 90 days (or 180 days depending on the amount of waste generated) without obtaining a permit. Land Disposal Restrictions (LDRs) (40 CFR Part 268) are regulations prohibiting the disposal of hazardous waste on land without prior treatment. Under the LDRs program, materials must meet treatment standards prior to placement in a RCRA land disposal unit (landfill, land treatment unit, waste pile, or surface impoundment). Generators of waste subject to the LDRs must provide notification of such to the designated TSD facility to ensure proper treatment prior to disposal.
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Federal Statutes and Regulations Used Oil Management Standards (40 CFR Part 279) impose management requirements affecting the storage, transportation, burning, processing, and re-refining of the used oil. For parties that merely generate used oil, regulations establish storage standards. For a party considered a used oil processor, re-refiner, burner, or marketer (one who generates and sells off-specification used oil directly to a used oil burner), additional tracking and paperwork requirements must be satisfied. RCRA contains unit-specific standards for all units used to store, treat, or dispose of hazardous waste, including Tanks and Containers. Tanks and containers used to store hazardous waste with a high volatile organic concentration must meet emission standards under RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require generators to test the waste to determine the concentration of the waste, to satisfy tank and container emissions standards, and to inspect and monitor regulated units. These regulations apply to all facilities who store such waste, including large quantity generators accumulating waste prior to shipment offsite. Underground Storage Tanks (USTs) containing petroleum and hazardous substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40 CFR Part 280) contain tank design and release detection requirements, as well as financial responsibility and corrective action standards for USTs. The UST program also includes upgrade requirements for existing tanks that were to be met by December 22, 1998. Boilers and Industrial Furnaces (BIFs) that use or burn fuel containing hazardous waste must comply with design and operating standards. BIF regulations (40 CFR Part 266, Subpart H) address unit design, provide performance standards, require emissions monitoring, and, in some cases, restrict the type of waste that may be burned.
EPA's RCRA, Superfund, and EPCRA Call Center, at 800-424-9346, responds to questions and distributes guidance regarding all RCRA regulations. Additional documents and resources can be obtained from the hotlines homepage at www.epa.gov/epaoswer/hotline. The RCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays. Comprehensive Environmental Response, Compensation, and Liability Act The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA to respond to releases, or threatened releases, of hazardous substances that Sector Notebook Project 76 November 2002
may endanger public health, welfare, or the environment. CERCLA also enables EPA to force parties responsible for environmental contamination to clean it up or to reimburse the Superfund for response or remediation costs incurred by EPA. The Superfund Amendments and Reauthorization Act (SARA) of 1986 revised various sections of CERCLA, extended the taxing authority for the Superfund, and created a free-standing law, SARA Title III, also known as the Emergency Planning and Community Right-to-Know Act (EPCRA). The CERCLA hazardous substance release reporting regulations (40 CFR Part 302) direct the person in charge of a facility to report to the National Response Center (NRC) any environmental release of a hazardous substance which equals or exceeds a reportable quantity. Reportable quantities are listed in 40 CFR Part 302.4. A release report may trigger a response by EPA or by one or more federal or state emergency response authorities. EPA implements hazardous substance responses according to procedures outlined in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions for cleanups. The National Priorities List (NPL) currently includes approximately 1,300 sites. Both EPA and states can act at other sites; however, EPA provides responsible parties the opportunity to conduct cleanups and encourages community involvement throughout the Superfund response process. EPA's RCRA, Superfund and EPCRA Call Center, at 800-424-9346, answers questions and references guidance pertaining to the Superfund program. Documents and resources can be obtained from the hotlines homepage at www.epa.gov/epaoswer/hotline. The Superfund Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays. Emergency Planning And Community Right-To-Know Act The Superfund Amendments and Reauthorization Act (SARA) of 1986 created the Emergency Planning and Community Right-to-Know Act (EPCRA, also known as SARA Title III), a statute designed to improve community access to information about chemical hazards and to facilitate the development of chemical emergency response plans by state and local governments. Under EPCRA, states establish State Emergency Response Commissions (SERCs), responsible for coordinating certain emergency response activities and for appointing Local Emergency Planning Committees (LEPCs). EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four types of reporting obligations for facilities which store or manage specified chemicals: Sector Notebook Project 77 November 2002
Federal Statutes and Regulations EPCRA section 302 requires facilities to notify the SERC and LEPC of the presence of any extremely hazardous substance at the facility in an amount in excess of the established threshold planning quantity. The list of extremely hazardous substances and their threshold planning quantities is found at 40 CFR Part 355, Appendices A and B. EPCRA section 303 requires that each LEPC develop an emergency plan. The plan must contain (but is not limited to) the identification of facilities within the planning district, likely routes for transporting extremely hazardous substances, a description of the methods and procedures to be followed by facility owners and operators, and the designation of community and facility emergency response coordinators. EPCRA section 304 requires the facility to notify the SERC and the LEPC in the event of a release exceeding the reportable quantity of a CERCLA hazardous substance (defined at 40 CFR Part 302) or an EPCRA extremely hazardous substance. EPCRA sections 311 and 312 require a facility at which a hazardous chemical, as defined by the Occupational Safety and Health Act, is present in an amount exceeding a specified threshold to submit to the SERC, LEPC and local fire department material safety data sheets (MSDSs) or lists of MSDSs and hazardous chemical inventory forms (also known as Tier I and II forms). This information helps the local government respond in the event of a spill or release of the chemical. EPCRA section 313 requires certain covered facilities, including SIC codes 20 through 39 and others, which have ten or more employees, and which manufacture, process, or use specified chemicals in amounts greater than threshold quantities, to submit an annual toxic chemical release report. This report, commonly known as the Form R, covers releases and transfers of toxic chemicals to various facilities and environmental media. EPA maintains the data reported in a publically accessible database known as the Toxics Release Inventory (TRI). All information submitted pursuant to EPCRA regulations is publicly accessible, unless protected by a trade secret claim.
EPA's RCRA, Superfund and EPCRA Call Center, at 800-424-9346, answers questions and distributes guidance regarding the emergency planning and community right-to-know regulations. Documents and resources can be obtained from the hotlines homepage at www.epa.gov/epaoswer/hotline.
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The EPCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays. Clean Air Act The Clean Air Act (CAA) and its amendments are designed to protect and enhance the nation's air resources so as to promote the public health and welfare and the productive capacity of the population. The CAA consists of six sections, known as Titles, which direct EPA to establish national standards for ambient air quality and for EPA and the states to implement, maintain, and enforce these standards through a variety of mechanisms. Under the CAA, many facilities are required to obtain operating permits that consolidate their air emission requirements. State and local governments oversee, manage, and enforce many of the requirements of the CAA. CAA regulations appear at 40 CFR Parts 50-99. Pursuant to Title I of the CAA, EPA has established national ambient air quality standards (NAAQSs) to limit levels of criteria pollutants, including carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant are designated as attainment areas; those that do not meet NAAQSs are designated as non-attainment areas. Under section110 and other provisions of the CAA, each state must develop a State Implementation Plan (SIP) to identify sources of air pollution and to determine what reductions are required to meet federal air quality standards. Revised NAAQSs for particulates and ozone were proposed in 1996 and will become effective in 2001. Title I also authorizes EPA to establish New Source Performance Standards (NSPS), which are nationally uniform emission standards for new and modified stationary sources falling within particular industrial categories. NSPSs are based on the pollution control technology available to that category of industrial source (see 40 CFR Part 60). Under Title I, EPA establishes and enforces National Emission Standards for Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented toward controlling specific hazardous air pollutants (HAPs). Section 112(c) of the CAA further directs EPA to develop a list of source categories that emit any of 188 HAPs, and to develop regulations for these categories of sources. To date EPA has listed 185 source categories and developed a schedule for the establishment of emission standards. The emission standards are being developed for both new and existing sources based on maximum achievable control technology (MACT). The MACT is defined as the control technology achieving the maximum degree of reduction in the emission of the HAPs, taking into account cost and other factors.
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Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, and planes. Reformulated gasoline, automobile pollution control devices, and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses to regulate mobile air emission sources. Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions program designed to reduce the formation of acid rain. Reduction of sulfur dioxide releases will be obtained by granting to certain sources limited emissions allowances that are set below previous levels of sulfur dioxide releases. Title V of the CAA establishes an operating permit program for all major sources (and certain other sources) regulated under the CAA. One purpose of the operating permit is to include in a single document all air emissions requirements that apply to a given facility. States have developed the permit programs in accordance with guidance and regulations from EPA. Once a state program is approved by EPA, permits are issued and monitored by that state. Title VI is intended to protect stratospheric ozone by phasing out the manufacture of ozone-depleting chemicals and restricting their use and distribution. Production of Class I substances, including 15 kinds of chlorofluorocarbons (CFCs), were phased out (except for essential uses) in 1996. EPA's Clean Air Technology Center, at 919-541-0800 or www.epa.gov/ttn/catc, provides general assistance and information on CAA standards. The Stratospheric Ozone Information Hotline, at 800-296-1996 or www.epa.gov/ozone, provides general information about regulations promulgated under Title VI of the CAA; EPA's EPCRA Call Center, at 800424-9346 or www.epa.gov/epaoswer/hotline, answers questions about accidental release prevention under CAA section112(r); and information on air toxics can be accessed through the Unified Air Toxics website at http://www.epa.gov/ttn/atw/. In addition, the Clean Air Technology Centers website includes recent CAA rules, EPA guidance documents, and updates of EPA activities. Federal Insecticide, Fungicide, and Rodenticide Act The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first passed in 1947, and amended numerous times, most recently by the Food Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the authority to oversee, among other things, the registration, distribution, sale and use of pesticides. The Act applies to all types of pesticides, including insecticides, herbicides, fungicides, rodenticides and antimicrobials. FIFRA covers both intrastate and interstate commerce. Sector Notebook Project 80 November 2002
Establishment Registration
Section 7 of FIFRA requires that establishments producing pesticides, or
active ingredients used in producing a pesticide subject to FIFRA, register
with EPA. Registered establishments must report the types and amounts of
pesticides and active ingredients they produce. The Act also provides EPA
inspection authority and enables the agency to take enforcement actions
against facilities that are not in compliance with FIFRA.
Product Registration
Under section 3 of FIFRA, all pesticides (with few exceptions) sold or
distributed in the U.S. must be registered by EPA. Pesticide registration is
very specific and generally allows use of the product only as specified on the
label. Each registration specifies the use site i.e., where the product may be
used and the amount that may be applied. The person who seeks to register
the pesticide must file an application for registration. The application
process often requires either the citation or submission of extensive
environmental, health and safety data.
To register a pesticide, the EPA Administrator must make a number of
findings, one of which is that the pesticide, when used in accordance with
widespread and commonly recognized practice, will not generally cause
unreasonable adverse effects on the environment.
FIFRA defines unreasonable adverse effects on the environment as (1)
any unreasonable risk to man or the environment, taking into account the
economic, social, and environmental costs and benefits of the use of the
pesticide, or (2) a human dietary risk from residues that result from a use of
a pesticide in or on any food inconsistent with the standard under section 408
of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a).
Under FIFRA section 6(a)(2), after a pesticide is registered, the registrant
must also notify EPA of any additional facts and information concerning
unreasonable adverse environmental effects of the pesticide. Also, if EPA
determines that additional data are needed to support a registered pesticide,
registrants may be requested to provide additional data. If EPA determines
that the registrant(s) did not comply with their request for more information,
the registration can be suspended under FIFRA section 3(c)(2)(B).
Use Restrictions
As a part of the pesticide registration, EPA must classify the product for
general use, restricted use, or general for some uses and restricted for others
(Miller, 1993). For pesticides that may cause unreasonable adverse effects
on the environment, including injury to the applicator, EPA may require that
the pesticide be applied either by or under the direct supervision of a certified
applicator.
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Reregistration
Due to concerns that much of the safety data underlying pesticide
registrations becomes outdated and inadequate, in addition to providing that
registrations be reviewed every 15 years, FIFRA requires EPA to reregister
all pesticides that were registered prior to 1984 (section 4). After reviewing
existing data, EPA may approve the reregistration, request additional data to
support the registration, cancel, or suspend the pesticide.
Tolerances and Exemptions
A tolerance is the maximum amount of pesticide residue that can be on a raw
product and still be considered safe. Before EPA can register a pesticide that
is used on raw agricultural products, it must grant a tolerance or exemption
from a tolerance (40 CFR Parts 163.10 through 163.12). Under the Federal
Food, Drug, and Cosmetic Act (FFDCA), a raw agricultural product is
deemed unsafe if it contains a pesticide residue, unless the residue is within
the limits of a tolerance established by EPA or is exempt from the
requirement.
Cancellation and Suspension
EPA can cancel a registration if it is determined that the pesticide or its
labeling does not comply with the requirements of FIFRA or causes
unreasonable adverse effects on the environment (Haugrud, 1993).
In cases where EPA believes that an imminent hazard would exist if a
pesticide were to continue to be used through the cancellation proceedings,
EPA may suspend the pesticide registration through an order and thereby halt
the sale, distribution, and usage of the pesticide. An imminent hazard is
defined as an unreasonable adverse effect on the environment or an
unreasonable hazard to the survival of a threatened or endangered species
that would be the likely result of allowing continued use of a pesticide during
a cancellation process.
When EPA believes an emergency exists that does not permit a hearing to be
held prior to suspending, EPA can issue an emergency order which makes the
suspension immediately effective.
Imports and Exports
Under FIFRA section 17(a), pesticides not registered in the U.S. and
intended solely for export are not required to be registered provided that the
exporter obtains and submits to EPA, prior to export, a statement from the
foreign purchaser acknowledging that the purchaser is aware that the product
is not registered in the United States and cannot be sold for use there. EPA
sends these statements to the government of the importing country. FIFRA
sets forth additional requirements that must be met by pesticides intended
solely for export. The enforcement policy for exports is codified at 40 CFR
Parts 168.65, 168.75, and 168.85.
Sector Notebook Project 82 November 2002
Under FIFRA section 17(c), imported pesticides and devices must comply with U.S. pesticide law. Except where exempted by regulation or statute, imported pesticides must be registered. FIFRA section 17(c) requires that EPA be notified of the arrival of imported pesticides and devices. This is accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1), which is filled out by the importer prior to importation and submitted to the EPA regional office applicable to the intended port of entry. U.S. Customs regulations prohibit the importation of pesticides without a completed NOA. The EPA-reviewed and signed form is returned to the importer for presentation to U.S. Customs when the shipment arrives in the U.S. NOA forms can be obtained from contacts in the EPA Regional Offices or www.epa.gov/oppfead1/international/noalist.htm. Additional information on FIFRA and the regulation of pesticides can be obtained from a variety of sources, including EPAs Office of Pesticide Programs www.epa.gov/pesticides, EPAs Office of Compliance, Agriculture and Ecosystem Division http://www.epa.gov/compliance/assistance/sectors/ agriculture.html, or The National Agriculture Compliance Assistance Center, 888-663-2155 or http://www.epa.gov/agriculture/. Other sources include the National Pesticide Telecommunications Network, 800-858-7378, and the National Antimicrobial Information Network, 800-447-6349. Toxic Substances Control Act Because the Toxic Substances Control Act (TSCA) applies primarily to the chemical industry, it is discussed in Section VI.B., Industry Specific Requirements. Coastal Zone Management Act The Coastal Zone Management Act (CZMA) encourages states/tribes to preserve, protect, develop, and where possible, restore or enhance valuable natural coastal resources such as wetlands, floodplains, estuaries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique feature of this law is that participation by states/tribes is voluntary. In the Coastal Zone Management Act Reauthorization Amendments (CZARA) of 1990, Congress identified nonpoint source pollution as a major factor in the continuing degradation of coastal waters. Congress also recognized that effective solutions to nonpoint source pollution could be implemented at the state/tribe and local levels. In CZARA, Congress added Section 6217 (16 U.S.C. section 1455b), which calls upon states/tribes with federally-approved coastal zone management programs to develop and implement coastal nonpoint pollution control programs. The Section 6217 Sector Notebook Project 83 November 2002
program is administered at the federal level jointly by EPA and the National Oceanic and Atmospheric Agency (NOAA). Section 6217(g) called for EPA, in consultation with other agencies, to develop guidance on management measures for sources of nonpoint source pollution in coastal waters. Under Section 6217, EPA is responsible for developing technical guidance to assist states/tribes in designing coastal nonpoint pollution control programs. On January 19, 1993, EPA issued its Guidance Specifying Management Measures For Sources of Nonpoint Pollution in Coastal Waters, which addresses five major source categories of nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3) forestry runoff, (4) marinas and recreational boating, and (5) hydromodification. Additional information on coastal zone management may be obtained from EPAs Office of Wetlands, Oceans, and Watersheds, www.epa.gov/owow, or from the Watershed Information Network www.epa.gov/win. The NOAA website, http://www.ocrm.nos.noaa.gov/czm/, also contains additional information on coastal zone management. VI.B. Industry Specific Requirements The organic chemical industry is affected by nearly all federal environmental statutes. In addition, the industry is subject to numerous laws and regulations from state and local governments designed to protect and improve the nations health, safety, and environment. A summary of the major federal regulations affecting the chemical industry follows. Clean Air Act (CAA) National Ambient Air Quality Standards
At organic chemistry manufacturing facilities, air emissions from both
processes and supporting equipment (e.g., boilers, storage tanks, and
equipment leaks) are regulated under the National Ambient Air Quality
Standards (NAAQS) and the State Implementation Plans (SIP) that enforce
the standards. States may implement controls to limit emissions of
particulate matter (PM), nitrogen dioxide (NO2), ozone (O3), and sulfur
dioxide (SO2), lead, and carbon monoxide (CO).
Although many limits are implemented at the state level, there are national guidelines that serve as a basis for more specific limits. Sources that are considered major under the Clean Air Act are subject to new source review (NSR), which includes the prevention of significant deterioration (PSD) review. Both NSR and PSD are permit programs for facilities that were constructed, reconstructed, or modified after a certain date.
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Facilities in NAAQS attainment areas must follow PSD requirements by demonstrating that the construction/modification project will not cause a violation of air quality limits and by implementing the best available control technology (BACT). New or modified facilities in nonattainment areas must follow NSR requirements, which require the source to meet the lowest achievable emission rate (LAER) and to obtain emission offsets to ensure that the nonattainment problem is not made worse by the new/modified source. In addition to the PSD/NSR pre-construction obligations, there are processspecific operational standards: New Source Performance Standards (NSPS). 40 CFR 60 lists these standards, which serve as minimum requirements in states SIPs. Individual states may impose requirements that are more strict. The following NSPSs are particularly relevant to the organic chemicals industry:
Subparts D, Db, Dc
Industrial boilers
(Regulates PM, nitrogen oxides (NOx) and sulfur
dioxide (SO2) from new boilers)
Subpart Ka, Kb
Volatile organic liquid storage vessels (Including
Petroleum Liquid Storage Vessels)
(Regulates VOC from applicable storage tanks
containing volatile organic liquids)
Equipment leaks
(Regulates VOC from equipment in the organic
chemicals industry)
Polymer manufacturing
[Regulates VOC from facilities manufacturing
polypropylene, polyethylene, polystyrene, or poly
(ethylene terephthalate)]
Air oxidation unit processes
(Regulates VOC from processes that use oxygen in air
as a reactant)
Distillation operations
(Regulates VOC from processes that separate vapor-
phase chemicals from liquid-phase chemicals)
Reactor processes
(Regulates VOC from processes that combine or
decompose chemicals)
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Subpart VV
Subpart DDD
Subpart III
Subpart NNN
Subpart RRR
Hazardous Air Pollutants Air toxics regulations apply to several parts of the organic chemical manufacturing process. The most important National Emission Standards for Hazardous Air Pollutants (NESHAP) for the industry is the Hazardous Organic NESHAP, referred to as HON (40 CFR 63 subparts F,G,H, and I). The HON regulates emissions of 111 hazardous air pollutants emitted by the organic chemicals industry from process vents, transfer operations, storage vessels, wastewater, and equipment leaks. The HON applies to major sources, which are defined as facilities that emit or have the potential to emit 10 tons per year or more of any hazardous air pollutant (HAP) or 25 tons per year or more of any combination of HAPs. Among other NESHAPs that are important to the industry are: Vinyl chloride manufacturers (40 CFR part 61 subpart F) Benzene equipment leaks (40 CFR part 61 subpart J) Equipment leaks (fugitive emission sources) (40 CFR 61 subpart V) Benzene storage vessels (40 CFR 61 subpart Y) Benzene transfer operations (40 CFR 61 subpart BB) Benzene waste operations (40 CFR part 61 subpart FF) Industrial cooling towers (40 CFR 63 subpart Q)
Part 61 NESHAPs can apply to a facility of any size and are not limited to major sources. Risk Management Program Organic chemical facilities are subject to section 112(r) of CAA, which states that stationary sources using extremely hazardous substances have a general duty to initiate specific activities to prevent and mitigate accidental releases. The general duty requirements apply to stationary sources that produce, process, handle, or store these substances, regardless of the quantity of managed at the facility. Although there is no list of extremely hazardous substances, EPAs Chemical Emergency Preparedness and Prevention Office provides some guidance at its website: http://yosemite.epa.gov/oswer/ceppoweb.nsf/content/index.html. The general duty clause requires facilities to identify hazards that may result from accidental releases, to design and maintain a safe facility, and to minimize the consequences of releases when they occur. Many large organic chemical facilities are subject to additional, more explicit risk management requirements. Facilities that have more than a threshold quantity of any of the 140 regulated substances in a single process are required to develop a risk management program and to summarize their program in a risk management plan (RMP). Facilities subject to the Sector Notebook Project 86 November 2002
requirements were required to submit a registration and RMP in 1999 or whenever they first exceed the threshold for a listed regulated substance after that date. All facilities meeting the RMP threshold requirements must follow Program 1 requirements: An offsite consequence analysis that evaluates specific potential release scenarios, including worst-case and alternative scenarios. A five-year history of certain accidental releases of regulated substances from covered processes. A risk management plan, revised at least once every five years, that describes and documents these activities for all covered processes.
In addition, many organic chemicals facilities may be subject to the requirements of Program 2 or 3. These additional requirements include: An integrated prevention program to manage risk. The prevention program will include identification of hazards, written operating procedures, training, maintenance, and accident investigation. An emergency response program. An overall management system to put these program elements into effect.
The list of chemicals that trigger RMP requirements can be found in 40 CFR
68.130; information to determine the required program level also can be
found in 40 CFR 68.
Title V permits
Title V requires that all major sources (and certain minor sources) obtain
an operating permit. Large organic chemical facilities are required to have
a Title V permit, and may be required to submit information about emissions,
control devices, and the general process at the facility in the permit
application. Permits may limit pollutant emissions and impose monitoring,
record keeping, and reporting requirements.
Monitoring requirements for many facilities with Title V permits are
specified in the Compliance Assurance Monitoring (CAM) regulations. For
facilities that meet emissions requirements on their permits through the use
of pollution control equipment, CAM requires that the facilities conduct
monitoring of that control equipment in order to assure that the equipment is
operated and maintained as prescribed in their permits.
Title VI Stratospheric Ozone Protection
Many organic chemical facilities operate industrial process refrigeration
units, such as chillers for chlorine dioxide plants. For those units that utilize
ozone-depleting chemicals, such as chlorofluorocarbons (CFCs), facilities are

required under Title VI to follow leak repair requirements.
Consolidated Air Rule (CAR)
The Consolidated Air Rule (CAR) is a pilot project for the synthetic organic
chemical manufacturing industry (SOCMI). The primary goal of the CAR
is to reduce the burden and potential confusion of complying with multiple
air regulations for the sources at a single facility, while ensuring protection
of the environment and improving compliance. The program is an optional
alternative rule for facilities subject to SOCMI air regulations.
For facilities that wish to comply with the CAR, the program consolidates major portions of the following new source performance standards (NSPS) and national emission standards for hazardous air pollutants (NESHAP) applicable to storage vessels, process vents, transfer operations, and equipment leaks within the SOCMI: 40 CFR part 60, subparts A, Ka, Kb, VV, DDD, III, NNN, and RRR 40 CFR part 61, subparts A, V, Y, and BB 40 CFR part 63, subparts A, F, G, and H
The CAR regulations, codified in 40 CFR 65, organize the requirements by specific emission point; as a result, the subparts more clearly delineate the requirements that would apply to each plant function. It is important to note that the CAR consolidates only those CFR subparts listed above. Organic chemicals facilities may be subject to other regulations under the CAA or other statutes, such as RCRA. Toxic Substances Control Act (TSCA) The Toxic Substances Control Act (TSCA) granted EPA authority to create a regulatory framework to collect data on chemicals in order to evaluate, assess, mitigate, and control risks that may be posed by their manufacture, processing, and use. TSCA provides a variety of control methods to prevent chemicals from posing unreasonable risk. It is important to note that pesticides as defined in FIFRA are not included in the definition of a chemical substance when manufactured, processed, or distributed in commerce for use as a pesticide. Section 4 of TSCA requires testing of existing chemicals both mixtures and individual substances. EPA has established a Master Testing List that presents testing priorities, based on risk and exposure potential. For example, EPA is currently working with manufacturers to encourage testing on chemicals that are produced and used in large volumes (High Production Volume Testing). At present these tests are voluntary, but EPA has authority Sector Notebook Project 88 November 2002
to develop a testing rule if it determines such a rule is necessary. Detail is provided in 40 CFR 766, 790-799. Section 5 states the requirements for premanufacture notices (PMNs). Chemical manufacturers are required to notify EPA 90 days before manufacturing or importing a chemical if the chemical is not listed in EPAs Chemical Substance Inventory, or if its use would be a significant new use. See 40 CFR 700, 720-725, 747 for more information. Section 6 regulates or bans the use of chemicals that pose unreasonable risks. Chemicals regulated under this rule include asbestos, chlorofluorocarbons (CFCs), lead, and polychlorinated biphenyls (PCBs). Details are listed in 40 CFR 747,749,761, and 763. Section 8 has several recordkeeping and reporting requirements, which are listed in 40 CFR 710-717. The Inventory Update Rule (IUR) under TSCA Section 8(a) requires companies that manufacture or import more than 10,000 lbs. of certain chemicals included in the TSCA Chemical Substance Inventory to report current data on the production volume, plant site, and site-limited status of these chemicals. Reporting under the IUR takes place at four-year intervals that began in 1986. The Preliminary Assessment Information Rule (PAIR) under TSCA Section 8(a) requires site-specific information on the manufacture or importing for commercial purposes of any chemicals listed in 40 CFR 712.30. The information includes: quantity of chemical, amount lost to the environment during production or importation, quantity of releases (controlled and noncontrolled) of the chemical, and per release worker exposure information. The Allegations of Significant Adverse Reactions Rule under TSCA Section 8(c) requires companies to keep a file of allegations of significant adverse reactions (to human health or the environment) of any chemical it manufactures, imports, processes, or distributes. The company must provide this information to EPA upon request. The Unpublished Health and Safety Studies Rule under TSCA Section 8(d) requires companies to submit to EPA a list and/or copies of unpublished studies that address the health or safety issues of certain listed chemicals. The Substantial Risk Information Requirement in Section 8(e) requires companies to report to EPA within 15 days any new information that reasonably supports the conclusions that a substance or mixture manufactured, imported, processed, or distributed by the company presents a substantial risk of injury to health or the environment.
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Section 12 of TSCA requires that exporters of chemicals subject to Sections 5, 6,or 7 of TSCA must notify EPA of the country of destination the first time a chemical is shipped to the country during a calendar year. Companies manufacturing chemicals subject to Section 4 of TSCA must notify EPA of the country of destination the first time that chemical is shipped to the country. Specific requirements are listed in 40 CFR 707. Section 13 requires importers of a chemical substance or mixture to certify at the port of entry that the shipment is either subject to and in compliance with TSCA (a positive certification), or that the shipment is not subject to TSCA (a negative certification). Details are listed in 40 CFR 707 and 19 CFR 12.118-12.128. EPAs TSCA Assistance Information Service, at 202-554-1404, answers questions and distributes guidance pertaining to Toxic Substances Control Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST, excluding federal holidays. Clean Water Act (CWA) There are two industry-specific components of the Clean Water Act (CWA) requirements: NPDES permitting and pretreatment programs. Other general CWA requirements, such as those for wetlands and stormwater, may also apply to the organic chemicals facilities and are described in Section VI.A. Individual NPDES requirements have been developed for specific subcategories of the industry; they are described in 40 CFR 414. For each of these subcategories (commodity organic chemicals, bulk organic chemicals, and specialty organic chemicals), the regulations outline some or all of the following for facilities that discharge wastewater directly to the environment: best practicable control technology currently available (BPT) and best conventional control technology (BCT) guidelines for the control of conventional pollutants (biological oxygen demand, total suspended solids, and pH). best available technology economically achievable (BAT) guidelines for the control of toxic and nonconventional pollutants. new source performance standards (NSPS) for the control of conventional, non-conventional, and toxic pollutants from new facilities that discharge directly to the environment. Approximately 60 chemicals are regulated under BAT and NSPS guidelines for the organic chemicals industry. 90 November 2002
For facilities that discharge their wastewater to a publicly-owned treatment works (POTW), pretreatment standards may apply. In addition to general standards established by EPA that address all industries, there are Pretreatment Standards for New Sources (PSNS) and Pretreatment Standards for Existing Sources (PSES) that are specific to 45 chemicals processed within the organic chemicals industry. These standards also are listed in 40 CFR 414. Emergency Planning and Community Right-to-Know Act (EPCRA) Three of the components of EPCRA are directly relevant to the organic chemicals industry: Emergency Planning (302(a)) - Businesses that produce, use or store hazardous substances must: 1) submit material safety data sheets or the equivalent, and 2) Tier I/Tier II annual inventory report forms to the appropriate local emergency planning commission. Those handling extremely hazardous substances above threshold planning quantities (TPQs) also are required to submit a one-time notice to the state emergency response commission. Emergency Notification of Extremely Hazardous Substance Release (304) - A business that unintentionally releases a reportable quantity of an extremely hazardous substance must report that release to the state emergency planning commission and the local emergency planning commission. Release Reporting (313) - Manufacturing businesses with ten or more employees that manufactured, processed, or otherwise used a listed toxic chemical in excess of the established threshold must file annually a Toxic Chemical Release form with EPA and the state. Documentation supporting release estimates must be kept for three years. If an organic chemicals company produces chemicals on the TRI list, the company has a duty to notify its customers of the percentage by weight of the listed chemicals. The company must also notify its customers whenever changes are made to the product that affect the amount of TRI chemicals, or when chemicals in its products become newly added to the TRI list by EPA.
Resource Conservation and Recovery Act (RCRA) Many RCRA requirements outlined in Section VI.A pertain to facilities in the organic chemicals industry. 40 CFR 261 presents guidelines for identifying Sector Notebook Project 91 November 2002
hazardous waste. There are over 50 materials listed as hazardous waste from specific sources in the organic chemicals industry (K wastes), and many more hazardous wastes from non-specific sources (F wastes) and materials with hazardous waste characteristics (D wastes) are generated by the industry. Facilities that generate hazardous wastes must follow the standards for hazardous waste generators (40 CFR 262) as discussed in Section VI.A. Many organic chemical facilities store some hazardous wastes at the facility beyond the accumulation time limits available to generators (e.g., 90 or 180 days). Such facilities are required to have a RCRA treatment, storage, and disposal facility (TSDF) permit (40 CFR 262.34). Some organic chemical facilities are considered TSDF facilities and therefore may be subject to the following regulations covered under 40 CFR 264: Contingency plans and emergency procedures (subpart D) Manifesting, record keeping, and reporting (subpart E) Use and management of containers (subpart I) Tank systems (subpart J) Surface impoundments (subpart K) Land treatment (subpart I) Corrective action of hazardous waste releases (subpart S) Air emissions standards for process vents of processes that process or generate hazardous wastes (subpart AA) Emissions standards for leaks in hazardous waste handling equipment (subpart BB) Emissions standards for containers, tanks, and surface impoundments that contain hazardous wastes (subpart CC)
It should be noted that many recycling and reclamation activities involving hazardous waste are considered to be treatment,2 depending on the particular recycling activities involved and the materials being recycled. Thus it is important to ensure that any time a facility is processing secondary materials it is not unknowingly engaging in hazardous waste treatment. Many organic chemical facilities are also subject to the underground storage tank (UST) program (40 CFR part 280). The UST regulations apply to facilities that store either petroleum products or hazardous substances (except hazardous waste) identified under the Comprehensive Environmental Response, Compensation, and Liability Act. (Hazardous waste is regulated
40 CFR 260.10 states that the definition of treatment is: any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or so as to recover energy or material resources from the waste, or so as to render such waste non-hazardous, or less hazardous; safer to transport, store, or dispose of; or amenable for recovery, amenable for storage, or reduced in volume.
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by other components of RCRA discussed above). UST regulations address design standards, leak detection, operating practices, response to releases, financial responsibility for releases, and closure standards. A number of RCRA wastes have been prohibited from land disposal unless treated to meet specific standards under the RCRA Land Disposal Restriction (LDR) program. The wastes covered by the RCRA LDRs are listed in 40 CFR part 268 subpart C and include a number of wastes that could potentially be generated at organic chemical facilities. Standards for the treatment and storage of restricted wastes are described in subparts D and E, respectively.
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Organic Chemical Industry VI.C. Pending and Proposed Regulatory Requirements
Information regarding proposed regulations affecting the organic chemical industry were obtained from EPAs United Agenda, which can be found at www.epa.gov/fedrgstr/unified.htm. The United Agenda is updated twice per year. The contacts listed after each proposed regulation can provide more information. Clean Air Act NSPS: Synthetic Organic Chemicals Manufacturing Industry Wastewater This rule will develop a new source performance standard to control air emissions of VOCs from wastewater treatment operations of the synthetic chemical manufacturing industry. As of mid-2002, a final rule was anticipated in December 2002. (Contact: Mary Tom Kissell, Office of Air and Radiation, 919-541-4516 or Kent Hustvedt, Office of Air and Radiation, 919-541-5395). NESHAP: Miscellaneous Organic Chemical Manufacturing and
Miscellaneous Coating Manufacturing
This regulation will cover organic chemical manufacturing processes not
covered by the HON or other MACT standards. The regulation will control
process vents (continuous and batch, including mixing operations),
equipment leaks, storage tanks, wastewater, solvent recovery, and heat
exchange systems. As mid-2002, a final rule is anticipated in late 2003.
(Contact: Randy McDonald, Office of Air and Radiation, 919-541-5402 or
Penny Lassiter, Office of Air and Radiation, 919-541-5396).
NESHAP: Combustion Turbine
The combustion turbine source category is listed as a major source of HAPs
under section 112 of the Clean Air Act. Combustion turbines also emit NOx,
SO2, CO, and PM. Combustion turbines are already regulated for NOx and
SO2 emissions under section 111 of the CAA. EPA will gather information
on HAP emissions from combustion turbines and determine the appropriate
maximum achievable control technology (MACT) to reduce HAP emissions.
As of mid-2002, a final rule was anticipated in late 2003. (Contact: Sims
Roy, Office of Air and Radiation, 919-541-5263 or Robert J. Wayland,
Office of Air and Radiation, 919-541-1045).
NESHAP: Generic MACT For Carbon Black, Ethylene, Cyanide and
Spandex
Several of the source categories that are subject to MACT standards contain
only a few sources (e.g., less than five). EPA plans to develop a generic
MACT standard for these source categories. As of mid-2002, a final rule was
iminent. (Contact: Mark Morris, Office of Air and Radiation, 919-541-5416
or Penny Lassiter, Office of Air and Radiation, 919-541-5396).
Organic Chemical Industry Resource Conservation and Recovery Act
Standardized Permit for RCRA Hazardous Waste Management Facilities EPA is considering creating a new type of general permit, called a standardized permit, for facilities that generate waste and routinely manage the waste on-site in tanks, containers, and containment buildings. Under the standardized permit, facility owners and operators would certify compliance with generic design and operating conditions set on a national basis. The permitting agency would review the certifications submitted by the facility owners and operators. The permitting agency would also be able to impose additional site-specific terms and conditions for corrective action or other purposes, as called for by RCRA. The standardized permit should streamline the permit process by allowing facilities to obtain and modify permits more easily while maintaining the protectiveness currently existing in the individual RCRA permit process. As of mid-2002, a final rule was anticipated in early 2003. (Contact: Vernon Myers, Office of Solid Waste and Emergency Response, 703-308-8660).
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Organic Chemical Industry VII.
Compliance and Enforcement History
COMPLIANCE AND ENFORCEMENT PROFILE Background Until recently, EPA has focused much of its attention on easuring compliance with specific environmental statutes. This approach allows the Agency to track compliance with the Clean Air Act, the Resource Conservation and Recovery Act, the Clean Water Act, and other environmental statutes. Within the last several years, the Agency has begun to supplement singlemedia compliance indicators with facility-specific, multimedia indicators of compliance. In doing so, EPA is in a better position to track compliance with all statutes at the facility level, and within specific industrial sectors. A major step in building the capacity to compile multimedia data for industrial sectors was the creation of EPA's Integrated Data for Enforcement Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's single-media databases, extract compliance records, and match the records to individual facilities. The IDEA system can match Air, Water, Waste, Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given facility, and generate a list of historical permit, inspection, and enforcement activity. IDEA also has the capability to analyze data by geographic area and corporate holder. As the capacity to generate multimedia compliance data improves, EPA will make available more in-depth compliance and enforcement information. Additionally, sector-specific measures of success for compliance assistance efforts are under development. Compliance and Enforcement Profile Description Using inspection, violation and enforcement data from the IDEA system, this section provides information regarding the historical compliance and enforcement activity of this sector. Compliance and enforcement records from EPA's data systems are compiled to the facility level using the Facility Registry System's (FRS) Master Source ID, which links records from virtually any of EPA's data systems to a facility record. For each facility (i.e., Master Source ID), the Industry Sector Notebooks analysis uses the facility-level SIC code that is designated by IDEA, which can be described as follows: 1. If the facility reports to TRI, then the designated SIC code is the primary SIC reported in the most recent TRI reporting year. 2. If the facility does not report to TRI, the first SIC codes from all linked AFS, PCS, RCRAInfo, BRS ID/permits are assembled. If more than one permit/ID exists for a particular program then only one record from that data system is used. The SIC code that occurs most often, if there is one,
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Organic Chemical Industry becomes the designated SIC code.
3. If the facility does not report to TRI and no SIC code occurs more often than others, the designated SIC code is chosen from the linked programs in the following order: AFS, PCS, BRS, RCR, NCD, DCK. If more than one permit/ID exists for a particular program then only one record from that data system is used. Note that EPA does not attempt to define the actual number of facilities that fall within each sector. Instead, the information presented in this section portrays the records of a subset of facilities within the sector that are well defined within EPA databases. As a check on the relative size of the full sector universe, most notebooks contain an estimated number of facilities within the sector according to the Bureau of Census (See Section II). With sectors dominated by small businesses, such as metal finishers and printers, the reporting universe within the EPA databases may be small in comparison to Census data. However, the group selected for inclusion in this data analysis section should be consistent with this sector's general make-up. Following this introduction is a list defining each data column presented within this section. These values represent a retrospective summary of inspections or enforcement actions, and solely reflect EPA, state and local compliance assurance activity that have been entered into EPA databases. To identify any changes in trends, the EPA ran two data queries, one for the past five calendar years (September 16, 1997 to September 15, 2002) and the other for the most recent 24-month period (September 16, 2000 to September 15, 2002). The five-year analysis gives an average level of activity for that period for comparison to the more recent activity. Because most inspections focus on single-media requirements, the data queries presented in this section are taken from single media databases. These databases do not provide data on whether inspections are state/local or EPA-led. However, the table breaking down the universe of violations does give the reader a general measurement of the EPA's and states' efforts within each media program. The presented data illustrate the variations across Regions for certain sectors.3 This variation may be attributable to state/local data entry variations, specific geographic concentrations, proximity to population centers, sensitive ecosystems, highly toxic chemicals used in production, or historical noncompliance. Hence, the exhibited data
EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
3
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do not rank regional performance or necessarily reflect which regions may have the most compliance problems. Compliance and Enforcement Data Definitions General Definitions Facility Registry System (FRS) -- this system assigns a common Master Source ID to EPA single-media permit records. The Master Source ID allows EPA to compile and review all permit, compliance, enforcement and pollutant release data for any given regulated facility. Integrated Data for Enforcement Analysis (IDEA) -- is a data integration system that can retrieve information from the major EPA program office databases. IDEA uses the FRS maintained Master Source ID identification number to "glue together" separate data records from EPAs databases. This is done to create a "master list" of data records for any given facility. Some of the data systems accessible through IDEA are: AIRS (Air Facility Indexing and Retrieval System, Office of Air and Radiation), PCS (Permit Compliance System, Office of Water), RCRAInfo (Resource Conservation and Recovery Information System, Office of Solid Waste), NCDB (National Compliance Data Base, Office of Prevention, Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental and Liability Information System, Superfund), and TRIS (Toxic Release Inventory System). IDEA also contains information from outside sources such as Dun and Bradstreet and the Occupational Safety and Health Administration (OSHA). Most data queries displayed in notebook sections IV and VII were conducted using IDEA. Data Table Column Heading Definitions Facilities in Search -- are based on the number of the FRS maintained Master Source IDs that were designated to the listed SIC code range. The SIC code range selected for each search is defined by each notebook's selected SIC code coverage described in Section II. Facilities Inspected -- indicates the level of EPA and state agency inspections for the facilities in this data search. These values show what percentage of the facility universe is inspected in a 24- or 60- month period. Number of Inspections -- measures the total number of inspections conducted in this sector. An inspection event is counted each time it is entered into a single media database. Average Time Between Inspections -- provides an average length of time, expressed in months, that a compliance inspection occurs at a facility within Sector Notebook Project 98 November 2002
Organic Chemical Industry the defined universe.
Facilities with One or More Enforcement Actions -- expresses the number of facilities that were party to at least one enforcement action within the defined time period. This category is broken down further into federal and state actions. Data are obtained for administrative, civil/judicial, and criminal enforcement actions. Administrative actions include Notices of Violation (NOVs). A facility with multiple enforcement actions is only counted once in this column (facility with three enforcement actions counts as one). All percentages that appear are referenced to the number of facilities inspected. Total Enforcement Actions -- describes the total number of enforcement actions identified for an industrial sector across all environmental statutes. A facility with multiple enforcement actions is counted multiple times (a facility with three enforcement actions counts as three). State Lead Actions -- shows what percentage of the total enforcement actions are taken by state and local environmental agencies. Varying levels of use by states of EPA data systems may limit the volume of actions accorded state enforcement activity. Some states extensively report enforcement activities into EPA data systems, while other states may use their own data systems. Federal Lead Actions -- shows what percentage of the total enforcement actions are taken by the United States Environmental Protection Agency. This value includes referrals from state agencies. Many of these actions result from coordinated or joint state/federal efforts. Enforcement to Inspection Rate -- expresses how often enforcement actions result from inspections. This value is a ratio of enforcement actions to inspections, and is presented for comparative purposes only. This measure is a rough indicator of the relationship between inspections and enforcement. This measure simply indicates historically how many enforcement actions can be attributed to inspection activity. Reported inspections and enforcement actions under the Clean Water Act (PCS), the Clean Air Act (AFS) and the Resource Conservation and Recovery Act (RCRA) are included in this ratio. Inspections and actions from the TSCA/FIFRA/EPCRA database are not factored into this ratio because most of the actions taken under these programs are not the result of facility inspections. This ratio does not account for enforcement actions arising from non-inspection compliance monitoring activities (e.g., self-reported water discharges) that can result in enforcement action within the CAA, CWA and RCRA. Facilities with One or More Violations Identified Sector Notebook Project 99 -- indicates the November 2002
percentage of inspected facilities having a violation identified in one of the following data categories: In Violation or Significant Violation Status (CAA); Reportable Noncompliance, Current Year Noncompliance, Significant Noncompliance (CWA); Noncompliance and Significant Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High Priority Violation (RCRA). The values presented for this column reflect the extent of noncompliance within the measured time frame, but do not distinguish between the severity of the noncompliance. Percentages within this column can exceed 100 percent because facilities can be in violation status without being inspected. Violation status may be a precursor to an enforcement action, but does not necessarily indicate that an enforcement action will occur. Media Breakdown of Enforcement Actions and Inspections -- four columns identify the proportion of total inspections and enforcement actions within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each column is a percentage of either the Total Inspections, or the Total Actions column.
100
November 2002
Organic Chemical Industry VII.A. Organic Chemicals Compliance History
Table 18 provides an overview of the reported compliance and enforcement data for the organic chemical industry over the past five years (September 16, 1997 to September 15, 2002). These data are also broken out by EPA Region thereby permitting geographical comparisons. A few points evident from the data are listed below.
C
Regions 6, 4, and 5 contain the largest number of organic chemical facilities, and account for the majority of inspections and enforcement actions. Region 3 conducts a disproportionately high number of inspections relative to the number of facilities in the region, and the region has the lowest average time between inspections (5 months). Regions 9 and 1 have the highest average time between inspections of organic chemicals facilities (50 and 22 months, respectively), but also have the highest rate of enforcement actions per inspection (0.16).
101
November 2002
Sector Notebook Project C

Facilities Inspected Number of Inspections Average Months Between Inspections Facilities with Total 1 or More Enforcement Enforcement Actions Actions Percent of State Lead Actions
Table 18: Five-Year Enforcement and Compliance Summary for the Organic Chemicals Industry, by Region D E F G H I J
Percent of Enforcement Federal Lead to Inspection Actions Rate
Region
Facilities In Search
102
National 1 2 3 4 5 6 7 8 9 10
1,107 32 149 106 216 156 267 103 24 31 23
832 25 111 83 156 118 214 77 16 13 19
8,839 88 933 1,225 2,211 1,165 2,433 516 116 37 115
8 22 10 5 6 8 7 12 12 50 12
574 12 88 62 102 78 184 20 10 10 8
811 14 105 102 163 76 304 23 6 6 12
72% 50% 78% 80% 82% 59% 69% 65% 17% 17% 58%
28% 50% 22% 20% 18% 41% 31% 35% 83% 83% 42%
0.09 0.16 0.11 0.08 0.07 0.07 0.12 0.04 0.05 0.16 0.10
November 2002
VII.B. Comparison of Enforcement Activity Between Selected Industries Tables 19 and 20 allow the compliance history of the organic chemical industry to be compared with the other industries covered by the industry sector notebooks. Comparisons between Tables 19 and 20 permit the identification of trends in compliance and enforcement records of the industry by comparing data covering the last five years to that of the past two years. Some points evident from the data are listed below.
C
The organic chemical industry has a relatively high frequency of inspections compared to the other sectors shown. On average, organic chemical facilities were inspected every six months. Organic chemical industry has a relatively high percent of facilities with violations and enforcement actions and a relatively high rate of enforcement per inspection compared to the other sectors listed. Of the sectors shown, the organic chemical industry has one of the highest percentage of EPA led enforcement actions versus state led actions.
Tables 21 and 22 provide a more in-depth comparison between the organic chemical industry and other sectors by breaking out the compliance and enforcement data by environmental statute. As in Tables 18 and 19, the data cover the last five years (Table 21) and the previous two years (Table 22) to facilitate the identification of recent trends. A few points evident from the data are listed below.
C
Inspections and actions conducted under the CAA and RCRA account for the vast majority of the industrys inspections and actions. In the past two years, the proportion of CAA inspections has decreased, but these inspections have resulted in a higher proportion of CAA enforcement actions.
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November 2002
Table 19: Five-Year Enforcement and Compliance Summary for Selected Industries
B
Facilities in Search 146 71 293 2,675 3,771 1,284 3,260 1,746 585 2,445 1,092 779 628 1,107 674 476 3,870 3,625 704 1,383 561 8,426 1,663 1,880 791 230 4,991 263 436 3,295 3,390 2,335 1,851 242 166 3,316 171 859 13,160 406 669 18,122 3,469 549 2,756 1,247 5,340 925 2,670 5,268 16,959 358 3,340 10 30 37 21 17 16 23 39 39 11 59 822 3,728 22 517 7,285 6 2,214 13,144 17 2,313 8,651 27 834 838 320 338 258 1,982 296 424 258 100 796 42 72 1,062 210 324 6,238 5 348 375 2,290 18 218 832 8,839 8 574 463 2,605 14 204 545 4,964 9 320 429 215 811 160 1,153 685 933 493 343 446 1,593 220 381 239 110 662 33 65 1,346 141 700 5,654 12 386 421 1,589 5,100 29 434 378 495 6,383 5 332 503 1,166 5,822 18 386 314 86% 85% 87% 74% 84% 78% 72% 52% 70% 88% 90% 72% 78% 89% 75% 74% 82% 62% 74% 0% 82% 74% 83% 91% 2,181 11,336 17 834 759 85% 911 4,002 19 278 271 86% 2,193 10,806 21 532 548 94% 6% 14% 15% 14% 15% 13% 26% 16% 22% 28% 48% 31% 12% 10% 28% 22% 11% 25% 26% 18% 38% 26% 0% 18% 26% 17% 9% 1,620 6,386 25 794 640 94% 6% 188 1,003 18 58 60 82% 18% 30 114 37 8 6 33% 67% 73 164 53 10 5 60% 40% 0.03 0.05 0.06 0.1 0.05 0.07 0.07 0.05 0.08 0.07 0.07 0.09 0.08 0.09 0.07 0.18 0.08 0.07 0.07 0.09 0.13 0.09 0.08 0.07 0.09 0.13 0.05 0.08 0.1 0.07 0.04 Facilities Inspected Number of Inspections Average Months Between Inspections Facilities with 1 or More Enforcement Actions Total Closed Enforcement Actions Percent State Lead Actions Percent Federal Lead Actions Enforcement to Inspection Rate
Industry Sector
Agricultural Crop Production
Agricultural Livestock Production
Metal Mining
Textiles
Lumber and Wood
Wood Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Plastic Resins and Fibers
Pharmaceuticals
Organic Chemicals
104
Ag. Chem. Pesticide & Fertilizer
Petroleum Refining
Rubber and Plastic
Iron and Steel
Metal Castings
Nonferrous Metals
Metal Products
Aerospace
Air Transportation
Fossil Fuel Electric Power
November 2002
Dry Cleaning
* Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Table 20: Two-Year Enforcement and Compliance Summary for Selected Industries
B
Facilities in Search Number 10 6 74 363 328 220 580 316 238 359 242 215 155 365 108 191 641 496 250 302 150 1728 320 1,897 854 295 4,696 81 112 1,810 785 126 216 6,355 1,212 410 179 63 490 31 52 701 238 47% 80% 44% 33% 67% 61% 67% 59% 68% 50% 54% 63% 24% 38% 46% 39% 30% 61% 54% 52% 51% 172 164 76 264 60 224 408 388 144 180 118 884 140 218 96 48 458 6 32 520 74 42% 234 63% 158 42% 182 40% 380 26% 24% 42% 27% 36% 40% 26% 44% 26% 93% 28% 26% 39% 36% 53% 30% 30% 27% 29% 48% 22% 7% 29% 29% 9% 35% 174 28% 24% 234 17% 39% 546 59% 60% 28 23% 23 352 204 145 328 139 185 162 141 161 62 261 37 447 313 351 149 172 159 588 86 167 69 35 327 4 18 493 50 75% 6 75% 5 2 1 Number 146 71 293 2,675 3,771 1,284 3,260 1,746 585 2,445 1,092 779 628 1,107 674 476 3,870 3,625 704 1,383 561 8,426 1,663 1,880 791 230 4,991 263 436 3,295 3,390 100 2,059 329 816 469 2,908 5,704 862 223 965 495 1,153 373 2,201 1,488 4,254 1,443 2,992 240 1,738 232 734 599 2,782 288 828 411 1,652 473 1,793 855 1,699 379 1,837 752 1,916 1,467 3,714 630 1,256 1,340 3,389 931 2,135 124 290 8 16 38 65 Percent* 26% Percent* 5% Facilities Inspected Number of Inspections Facilities with 1 or More Violations Total Closed Enforcement Actions Enforcement to Inspection Rate 0.02 0.31 0.08 0.16 0.06 0.12 0.09 0.07 0.1 0.1 0.08 0.1 0.07 0.09 0.05 0.26 0.1 0.08 0.07 0.15 0.16 0.1 0.1 0.09 0.08 0.12 0.07 0.03 0.08 0.08 0.04 Facilities with 1 or more Enforcement Actions
Industry Sector
Metal Mining
Textiles
Lumber and Wood
Pulp and Paper
Printing
Inorganic Chemicals
Pharmaceuticals
105
Organic Chemicals
Agricultural Chemical Pesticide & Fertilizer
Petroleum Refining
Rubber and Plastic
Iron and Steel
Metal Castings
Nonferrous Metals
Metal Products
Aerospace
Air Transportation
November 2002
Dry Cleaning
*Percentages in Columns E and F are based on the number of facilities inspected (Column C). Percentages can exceed 100% because violations and actions can occur without a facility inspection. * Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Table 21: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries
Clean Air Act % of Total Inspections % of Total Inspections 3% 3% 1% 6% 1% 13% 22% 24% 7% 35% 13% 22% 8% 12% 12% 12% 69% 87% 62% 64% 65% 45% 34% 381 239 110 662 406 669 18,122 33 65 1,346 61% 48% 58% 78% 40% 31% 75% 60% 68% 41% 16% 59% 36% 30% 0% 33% 28% 85% 1% 1% 11% 2% 7% 2% 4% 1% 3% 5% 1% 2% 2% 19% 15% 9% 8% 1% 1% 14% 3% 8% 2% 4% 1% 3% 9% 0% 0% 5% 9% 36% 29% 44% 38% 26% 24% 29% 12% 23% 33% 27% 52% 60% 37% 48% 36% 21% 57% 67% 5% 64% 24% 24% 5% 32% 28% 21% 36% 30% 21% 12% 24% 10% 21% 33% 22% 51% 67% 36% 57% 61% 0% 67% 66% 4% 80% 0% 0% 1% 1% 1% 1% 1% 2% 2% 2% 3% 5% 1% 1% 1% 0% 1% 1% 1% 2% 0% 0% 1% 0% 1% 0% 1% 0% 61% 48% 61% 96% 97% 74% 77% 75% 68% 65% 50% 51% 48% 48% 57% 63% 69% 86% 66% 79% 31% 48% 46% 6% 55% 19% 50% 12% 66% 0% 0% 73% 24% 20% 74% 0% 1% 73% 1% 2% 56% 13% 27% 13% 98% 1% 1% 1% 93% 0% 1% 4% 52% 26% 43% 13% 3% 50% 0% 17% 49% 17% 40% 0% 0% 36% 20% % of Total Actions % of Total % of Total Inspections Actions % of Total Inspections % of Total Actions Clean Water Act RCRA FIFRA/TSCA/ EPCRA/Other % of Total Actions 40% 17% 2% 0% 0% 4% 2% 1% 2% 2% 10% 3% 10% 7% 39% 1% 6% 2% 3% 5% 2% 7% 13% 4% 3% 0% 0% 0% 2% 2% 0%
Industry Sector 73 30 188 1,620 2,193 911 2,181 1,166 495 1,589 700 545 463 832 375 324 2,313 2,214 517 822 358 5,268 925 1,247 549 171 3,316 166 242 2,335 13,160 859 2,756 5,340 2,670 220 16,959 1,593 3,340 446 3,728 343 7,285 493 13,144 933 8,651 685 6,238 1,153 2,290 160 8,839 811 2,605 215 4,964 429 5,654 421 5,100 378 6,383 503 5,822 314 11,336 759 4,002 271 10,806 548 6,386 640 1,003 60 114 6 164 5
Total Closed Facilities Total Enforcement Inspected Inspections Actions
Metal Mining
Textiles
Lumber and Wood
Pulp and Paper
Printing
Inorganic Chemicals
106
Pharmaceuticals
Organic Chemicals
Petroleum Refining
Rubber and Plastic
Iron and Steel
Metal Castings
Nonferrous Metals
Metal Products
Aerospace
November 2002
Air Transportation
Dry Cleaning 1,851 3,469 141 36% 20% 0% 0% * Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Table 22: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries
Clean Air Act % of Total Inspections 59% 81% 46% 97% 97% 71% 75% 75% 64% 64% 44% 50% 44% 43% 51% 52% 69% 86% 60% 58% 59% 43% 30% 167 69 35 327 4 216 6,355 18 493 57% 46% 59% 75% 43% 29% 73% 83% 79% 85% 70% 60% 80% 46% 12% 63% 44% 37% 0% 50% 39% 87% 38% 52% 45% 7% 14% 13% 16% 2% 2% 13% 3% 8% 3% 5% 2% 4% 6% 1% 2% 1% 21% 65% 21% 56% 14% 0% 0% 0% 12% 14% 11% 13% 14% 6% 0% 2% 9% 2% 3% 1% 5% 1% 0% 11% 0% 0% 0% 8% 81% 28% 13% 85% 0% 0% 75% 1% 1% 61% 16% 22% 13% 24% 25% 7% 35% 42% 29% 49% 40% 33% 32% 29% 12% 27% 38% 32% 54% 65% 41% 50% 35% 24% 56% 69% 6% 63% 99% 1% 1% 2% 97% 0% 1% 3% 2% 1% 13% 22% 14% 4% 0% 25% 19% 37% 31% 24% 10% 20% 10% 17% 33% 16% 43% 63% 32% 51% 51% 0% 50% 56% 3% 94% 61% 35% 39% 19% 0% 60% 0% 20% 19% 0% 100% 0% 0% 37% 0% 5% 0% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 2% 3% 0% 0% 0% 0% 0% 0% 0% 1% 0% 0% 0% 0% 0% 0% 0% 0% % of Total Inspections % of Total Inspections % of Total Inspections Clean Water Act RCRA FIFRA/TSCA/ EPCRA/Other
Industry Sector 38 8 124 931 1,340 630 1,467 752 379 855 473 411 288 599 232 240 1,443 1,488 373 495 223 2,908 469 816 329 100 2,059 81 112 1,810 4,696 126 295 854 1,897 862 86 5,704 588 965 159 1,153 172 2,201 149 4,254 351 2,992 313 1,738 447 734 37 2,782 261 828 62 1,652 161 1,793 141 1,699 162 1,837 185 1,916 139 3,714 328 1,256 145 3,389 204 2,135 352 290 23 16 5 65 1
Facilities Inspected
Total Inspections
Total Closed Enforcement Actions % of Total Actions % of Total Actions % of Total Actions
% of Total Actions 0% 20% 0% 0% 1% 3% 2% 1% 1% 0% 7% 2% 6% 4% 24% 1% 2% 2% 4% 4% 2% 9% 21% 5% 6% 0% 0% 0% 6% 2% 0%
Metal Mining
Textiles
Lumber and Wood
Pulp and Paper
Printing
Inorganic Chemicals
Pharmaceuticals
Organic Chemicals
107
Petroleum Refining
Rubber and Plastic
Iron and Steel
Metal Castings
Nonferrous Metals
Metal Products
Aerospace
Air Transportation
November 2002
Dry Cleaning 785 1,212 50 37% 6% 0% 0% * Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Sector Facility Indexing Project -- Additional compliance information for the pulp and paper industry is available through EPAs Sector Facility Indexing Project (SFIP). This is a website that brings together environmental and other information from a number of data systems to produce facilitylevel profiles for five industry sectors (pulp manufacturing, petroleum refining, iron and steel production, primary nonferrous metal refining and smelting, and automobile assembly) and a subset of major federal facilities. SFIP information relates to compliance and inspection history, chemical releases and spills, demographics of the surrounding population and production. (Contact: SFIP hotline at 617-520-3015 or the website at http://www.epa.gov/sfipmtn1/) VII.C. Review of Major Legal Actions This section provides summary information about major cases that have affected this sector, and a list of Supplementary Environmental Projects (SEPs). SEPs are compliance agreements that reduce a facility's stipulated penalty in return for an environmental project that exceeds the value of the reduction. Often, these projects fund pollution prevention activities that can significantly reduce the future pollutant loadings of a facility. This section discusses major legal cases and pending litigation within the organic chemical industry as well as supplemental environmental projects (SEPs) involving organic chemicals facilities. Information regarding major cases or pending litigation is available from the Office of Regulatory Enforcement. VII.C.1. Review of Major Cases Amspec Chemical Corporation. In March 2000, Region 2 issued an administrative consent order resolving the multi-media cases brought against this company under 313 of EPCRA and 5 and 8 of TSCA. In addition to paying a $47,245 penalty, Amspec will perform two SEPs, with an estimated value of over $115,000. The first one consists of the installation and operation of equipment to recover some materials previously in the waste stream from the facilitys manufacturing operations. The second SEP involves the companys purchase of equipment for the local citys Office of Emergency Management allowing it to more effectively respond to emergencies involving chemical substances. Troy Chemical. In June 2000, Region 2 issued a final administrative order on consent to Troy Chemical. The agreement resolved a combined EPCRA 313 and TSCA 8 multi-media enforcement action involving the companys facility in Newark, New Jersey. Under the settlement, Troy will perform three separate SEPs with a combined worth of more than $220,000, and will also pay a civil penalty of $90,700. Troy will install equipment at its Newark Sector Notebook Project 108 November 2002
facility to reduce emissions of four listed chemical substances to both air (approximately 10,000 pounds annually) and water (more than 200,000 pounds annually). Troy had been cited for failure to submit TSCA-required Inventory Update Reports for five chemicals, and for under-reporting eleven others; and for failure to submit EPCRA-required reports for two chemicals. These violations occurred in the early 1990's. Occidental and Olin Corporation. Region 2 entered a consent decree with Occidental (the successor to the Hooker Chemical Company) and Olin Corp. in October, 1999, resolving their liability for Superfund response costs incurred by the United States and the State of New York at the 102nd Street Landfill Site in Niagara Falls, New York. Both companies disposed of hazardous substances at the site. The consent decree called for the companies to reimburse EPA about $6.87 million and New York approximately $690,000 for past costs and interest. In conjunction with remedial work at the landfill valued at about $44 million, pursuant to a 1991 unilateral administrative order issued by Region 2, the companies will have paid about 96% of the total site response costs. The decree also secured the companies' commitment to about $700,000 in payment of natural resource damages and replacement projects for lost resources. Shell Chemical Company. On July 19, 2000, EPA issued a Consent Agreement and Final Order (CAFO) in settlement of a complaint filed on September 20, 1999, that included a proposed penalty of $27,500 (EPA Docket No. CAA-6-99-039-99), for violations of the Clean Air Act and the Louisiana State Implementation Plan. The facility failed to correctly set the counter (FQ948) which resulted in a spill on December 8, 1998, of 148 lbs of hydrochloric acid to flow out through the hatch top of a tank car in violation of the Louisiana Administrative Code: Title 33, Part III, Section 905. The facility agreed to pay a $6,875 penalty and fund a Supplemental Environmental Project (SEP) in the amount of $27,796. The SEP provides for the following equipment for the St. Charles Parish Department of Emergency Preparedness: a weather data unit; risk map emergency response software; and an emergency operation center phone system. Westlake Petrochemicals Corporation. The U.S. Environmental Protection Agency Region 6 (EPA), in consultation with the Louisiana Department of Environmental Quality (LDEQ), issued a Consent Agreement and Final Order to Westlake Petrochemicals, for violations of federal and state regulations governing air emissions, the storage and handling of hazardous materials, and the use of toxic substances. Federal assessed penalties total $76,458. Clean Air Act alleged violations included the facility repeatedly failed to control the smoke from a flare and failed to report the violations, failure to properly label at least five pieces of leaking equipment which contributed to Sector Notebook Project 109 November 2002
illegal air emissions, and the facility was cited for improperly sampling and testing waste for benzene. Under the Emergency Planning and Community Right to Know Act, the facility had failed to report its use of chlorine dioxide from 1993 through 1997, a chemical which is required be to included in the annual Toxic Release Inventory report. The EPA also alleged that the company failed to accurately report its use of pyrolysis oil as required by the Toxic Substances Control Act. Under the Resource Conservation Recovery Act portion of the complaint, the facility is charged with improperly labeling and storing hazardous chemicals including mercury, chloroform and benzene, alleges that the company did not inspect areas where hazardous waste was stored to ensure that it was stored safely and that surrounding areas were not contaminated, and is charged with failing to train employees in safe handling of these materials and in correct emergency response procedures. Westlake Petrochemical has agreed to install and operate air monitoring equipment at its fence-line to measure various hazardous constituents for 3 years. The facility will also maintain a web site, as a mechanism to provide data from its air monitoring equipment. In addition, Westlake Petrochemical has agreed to respond to local residents concerns regarding data from the air monitoring equipment within 24 hours of their request. The estimated cost for implementation of the air monitoring project is $568,500. Westlake Petrochemical has also agreed to perform a third party compliance audit of its Sulphur facility. This audit will include all applicable State and Federal programs for its facility. E.I. Du Pont de Nemours. The Department of Justice and EPA reached a $1.5 million settlement on August 1, 2000 with E.I. Du Pont de Nemours (DuPont) related to a catastrophic chemical release in eastern Kentucky that led to the evacuation of several communities surrounding the plant. DuPont is a large chemical manufacturer that failed to maintain a safe facility under the General Duty Clause of the Clean Air Act. The charge arose from DuPonts use of cast iron piping in a tank used to store oleum (sulfur trioxide dissolved in sulfuric acid), and the companys failure to inspect the piping. The oleum solution corroded the cast iron piping, which ultimately fractured leading to the release of 23,800 gallons of sulfuric acid into the air. DuPont agreed to pay a $850,000 penalty and spend about $650,000 to create a state of the art emergency notification system for a 10-county region of Kentucky. U.S. v. Jack L. Aronowitz, et al. On January 31, 2000, the United States District Court for the Southern District of Florida, Fort Lauderdale Division, entered a judgment against Defendants, Jack L. Aronowitz and his company, Technical Chemicals and Products, Inc., and ordered them to pay past remaining costs of $401,177, plus interest and enforcement costs in EPAs CERCLA Section 107 Cost Recovery action to recover costs incurred at the Lauderdale Chemical Warehouse Site. On April 26, 2000, this Court granted the United States Request of Award of Trial and Related Expenses, holding Sector Notebook Project 110 November 2002
the defendants jointly and severally liable for an additional amount of $348,383. In 1994, EPA conducted a fund lead removal action at the Lauderdale Chemical Warehouse Site, in Ft. Lauderdale, Florida to remove chemicals that had been abandoned at the Site. From late 1977 through October 1992, this Site was used as a medical diagnostic chemical manufacturing plant, processing plant, and chemical storehouse. In a referral submitted to the Department of Justice in August of 1997, EPA requested a cost recovery suit be brought against the former owner/operators at the facility, Dr. Theodore Holstein, Jack L. Aronowitz and his company Technical Chemicals & Products, Inc., D.H. Blair & Co. and its President, Kenton Wood. EPA settled with D.H. Blair & Co. and Kenton Wood for $80,000. EPA has also settled with Theodore Holstein for $230,000. EPA then went to trial for two weeks before the U.S. District Court for the Southern District of Florida to seek a judgment that the remaining potentially responsible parties, Jack L. Aronowitz and his company, Technical Chemicals and Products, Inc., pay all the United States outstanding costs in this case, plus the costs of the trial. On January 31, 2000 the Court found for the United States, and against the defendants who are ordered to pay the United States outstanding costs of $401,177, plus interest and enforcement costs. US. v. B.P. Amoco, Des Moines TCE Site, Des Moines, Iowa. This Consent Decree entered into pursuant to Sections 106 and 107 of CERCLA provides for the settling defendants (BP Amoco PLC, Bayer Corporation, Chevron Chemical Company, Monsanto Company, and Shell Oil) to pay the United States $2,513,808, plus interest. This amount represents the Settling Defendants fair share of all past and estimates future response and oversight costs for Operable Units 2 and 4 (OU2/4) of the Des Moines TCE Site. EPA calculated the Settling Defendants fair share based upon a Non-Binding Preliminary Allocation of Responsibility (NBAR) prepared in accordance with Section 122(e) (3) of CERCLA. This amount includes a settlement premium based on anticipated future work at the site. This amount exceeds EPAs outstanding costs, with interest, so the balance of the settlement amount will be placed in a Special Account to be used for future work at the Site, i.e., long-term operation and maintenance of already completed removal actions and institutional controls. The other two identified potentially responsible parties, Dico, Inc. and its parent Titan Wheel International, which own and operate the Site, declined to participate in the settlement negotiations and are not parties to the Consent Decree. VII.C.2. Supplementary Environmental Projects (SEPs) SEPs are compliance agreements that reduce a facility's non-compliance Sector Notebook Project 111 November 2002
penalty in return for an environmental project that exceeds the value of the reduction. Often, these projects fund pollution prevention activities that can reduce the future pollutant loadings of a facility. Information on SEP cases can be accessed via the Internet at http://www.epa.gov/compliance/resources/ policies/civil/seps/index.html. Table 36 presents 25 examples of SEPs negotiated with facilities. The majority of SEPs were developed in Region VI (Arkansas, Louisiana, Oklahoma, and Texas). The three most common types of SEPs undertaken by the organic chemical industry were process changes, control technology installations or improvements, and non process-related projects. Nine of the SEPs were associated with process changes. Projects have included the recirculation of wastewater for reuse, the enclosure of equipment that previously released pollutants to the environment, and the replacement of PCB-containing electrical transformers. The value of these projects ranged from $22,280 to $12,000,000. Five of the projects involved control technology. These include the installation of particulate matter filtration units, upgraded thermal oxidizers, and concrete containment structures. The value of these projects ranged from $134,000 to $1,000,000. Twelve of the projects were not process-related. One of these required a cleanup of contaminated soil, but most of the others involved funding of Local Emergency Planning Committees (LEPC) or other emergency response organizations. These SEPs supported LEPC conferences and emergency response groups with equipment. The value of projects ranged from $3,000 to $19,596.
112
November 2002
Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry
Violation Information State/ Region Type CERCLA 103 EPCRA 304 $12,364 $19,596 Emergency planning and response CERCLA 103 CERCLA 103 CERCLA 103 EPCRA 104 $47,810 CERCLA 103 EPCRA 313 $17,000 $4,000 $1,500 $13,500 Emergency planning and response $25,675 Emergency planning and response $14,000 Emergency planning and response $22,280 Pollution prevention $2,500 $9,500 Emergency planning and response SEP Category NY Assessed Penalty SEP Cost to Company SEP Description Purchase emergency response equipment for Buffalo Fire Department. Supplemental Environmental Project Information
General Information
FY
Docket #
Company Name

TX Donate $1,500 in equipment to LEPC and $8,000 to Oklahoma LEPC regional conference. Donate $4,000 in equipment, $5,500 to Oklahoma LEPC conference, and $4,000 in assistance over two years to LEPC. Purchase emergency response equipment for Niagara County Health Department at a cost of $26,439. Donate $5,000 in equipment, $5,000 to Lake Charles LEPC conference, and $4,000 in assistance to LEPC. Purchase, install, and implement facility chemical tracking system (FCTS) to create and maintain central database to track chemical usage and inventories to support pollution prevention. $3,000 $9,000 Emergency planning and preparedness $3,000 $15,000 Emergency planning and preparedness Donate $2,000 in equipment, $3,000 to Oklahoma LEPC regional conference, and $4,000 in assistance over to years to LEPC. Donate $5,000 to Oklahoma LEPC conference and $10,000 for ICS training course. LA NY LA CO LA CERCLA 103 CERCLA 103 TX
1998
02-1997-0342
Buffalo Color Corporation
1998
06-1998-0151
Dow Chemical Company
1998
06-1997-0792
Formosa Plastics Corporation
113
1998
02-1995-0171
Olin Corporation
1998
06-1998-0744
Shell Chemical Company Geismar Plant
1997
08-95-0131
Boulder Scientific Co.
1997
06-97-0542
Condea Vista Company
November 2002
1997
06-97-0212
Dow Chemical Company
Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry (Continued)
Violation Information
State/ Region Type SEP Category CAA 112 RCRA 3002 RCRA 3004 RCRA 3005 $370,000 $1,094,338 Assessments and audits Pollution prevention Pollution reduction $15,000 Environmental restoration and protection $140,185 Pollution prevention RCRA 3002 RCRA 3005 RCRA 3005 $7,000 $3,750 Assessed Penalty SEP Cost to Company WA SEP Description Conduct pollution prevention audit and fugitive emissions audit; install regenerative thermal oxidizer, benzene tank tie-in, and toluene tank tie-in; upgrade carbon beds and install CEMS. Remediate contaminated soil area. Supplemental Environmental Project Information
General Information
FY
Docket #
Company Name

LA TX Modify production tanks to significantly reduce working loss emissions of phenol a hazardous air pollutant. Institute a process change at PO/MTBE unit in Port Neches, TX, which involves installation of systems to treat propylene recovery column overheads. CAA 110 CERCLA 103 EPCRA 313 RCRA 3002 TSCA 15(1)(c) $300,000 CERCLA 103 $4,000 $945,000 Pollution prevention Pollution reduction LA $14,000 Emergency planning and preparedness Donate $6,000 to Oklahoma LEPC regional conference, $2,000 in assistance over one year, and $4,000 for employee training on release reporting. $8,500 $148,148 Pollution prevention Pollution reduction Construction of a fully enclosed processing system, an auto make repackaging system and a dust control baghouse to reduce exposure to pyromellitic acid (PMA) powder. KS TSCA 15
1997
10-92-0226
Kalama Chemical, Inc.
1997
06-97-0689
Mackenzie Corporation
1997
06-97-0286
Schenectady International, Inc.
114
1997
06-92-0091
Texaco Chemical TX Co. (now known as Huntsman Petrochemical Co.)
1997
06-97-0720
WITCO Corporation
1996
07-95-0004
ALLCO Chemical Corporation
November 2002
State/ Region Type SEP Category CERCLA 103 $3,750 $19,167 Emergency planning and preparedness Assessed Penalty SEP Cost to Company TX SEP Description Donate equipment to LEPC, fund a LEPC conference, provide 2 years assistance to LEPC ($4,000), and purchase pollution prevention equipment. Donate equipment to LEPC, Perform a hazards analysis of hazardous materials. Conduct an in-plant drill with LEPC, SERC, and EPA. Supplemental Environmental Project Information
General Information
FY
Docket #
Company Name

LA CERCLA 103 $200 $7,200 Emergency planning and preparedness LA TSCA 15(1)(c) $8,182 $324,318 Pollution prevention Pollution reduction Change of heat transfer fluid to eliminate the source of inadvertently produced PCBs. Replace 69 PCB capacitors with non-PCB capacitors, and reclassify five PCBcontaminated transformers to non-PCB transformers. Install concrete containment structures for two non-hazardous waste oil storage tanks to prevent spillage. $3,000 Emergency planning and preparedness $198,000 Pollution reduction Fund an LEPC regional conference. Remove four operational PCB transformers from its Philadelphia facility (cost: $68,000), improve, above regulatory requirements, the air fabric filtration system for antimony oxide particulate matter at its Loredo, TX facility (cost: $134,000). Anzon also cleaned up PCB leaks at the Philadelphia facility. PA $0 RCRA 3004 RCRA 3005 RCRA 3007 RCRA 3008 CERCLA 103 TSCA 16 $1,250 $57,800 $390,000 Pollution reduction TX PA
1996
06-96-0118
E.I. duPont de Nemours & Co.
1996
06-96-0008
Olin Chemical
1996
06-91-0106
PPG Industries, Inc.
115
1996
03-92-0432
Neville Chemical Company
1996
06-96-0207
WITCO Corporation
1995
03-93-0108
Anzon, Inc.
November 2002
State/ Region Type SEP Category EPCRA 313 $56,250 $70,000 Pollution reduction Assessed Penalty SEP Cost to Company NJ SEP Description Modify the dinitrobenzene manufacturing process by installing automatic water flow controls. This will enable DuPont to reduce dinitrobenzene output in waste by up to 50,000 pounds per year. DuPont is required to provide status reports at six, twelve, and eighteen months. Supplemental Environmental Project Information
General Information

DE, PA RCRA 3008 $350,000 $951,000 Pollution prevention Reduce the release of pollutants to the environment by eliminating the current use of a sluiceway where chemicals are treated and subsequently discharged into the Delaware River, and modify the current industrial process at the Marcus Hok manufacturing plant by recirculating and recycling the wastewater for process reuse. Donate computer equipment to LEPC. NH $7,140 CERCLA 103(a) EPCRA 304 EPCRA 313 CERCLA 104 RCRA 3002 RCRA 3004 RCRA 3005 RCRA 9003 $5,100 $5,000,000 $7,140 Emergency planning and preparedness $1,000,000 Pollution reduction $12,000,000 Pollution prevention Pollution reduction NJ NY Install a thermal oxidizer to destroy chloroethane. Modify in-process refrigeration systems; eliminate CFC usage; modify food grade oxidant process; reformulate film manufacturing process; and 2 CBI material substitution/process modification SEPs.
FY
Docket #
Company Name
1995
02-94-0140
E.I. DuPont de Nemours & Co.
1995
03-89-1618
General Chemical Corporation (Allied-Signal)
116
1995
01-95-0060
Hampshire Chemical Corporation
1995
02-94-0260
Monsanto, The Chemical Group
1995
02-91-0208
Eastman Kodak
November 2002
Organic Chemical Industry VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
Activities and Initiatives
This section highlights the activities undertaken by this industry sector and public agencies to voluntarily improve the sector's environmental performance. These activities include those independently initiated by industrial trade associations. In this section, the notebook also contains a listing and description of national and regional trade associations. VIII.A. Sector-related Environmental Programs and Activities ChemAlliance ChemAlliance is an internet-based source of regulatory information for the chemical industry. It is funded by EPA and is operated by a partnership of environmental professionals in academia, government and industry. It seeks to help the industry comply with environmental regulations by providing the following resources: Regular feature articles by ChemAlliance staff and guest authors, providing timely and informative views on issues of importance to its readers. Up-to-date information on the regulations affecting chemical manufacturers, and cost-effective strategies to insure compliance Regulatory and compliance tools for technical assistance providers and industry professionals alike Information about pollution prevention in the chemical industry, and why it is an important part of any compliance strategy. Fun tools for managing information and customizing ChemAlliance to meet users needs.
ChemAlliance can be found at www.chemalliance.org. New Jersey Chemical Industry Project The U.S. Environmental Protection Agency's Industry Sector Policy Division is working with the New Jersey Department of Environmental Protection (NJ DEP), US EPA Region 2, and a stakeholder group of industry, environmental groups, and community representatives on a project with the batch chemical manufacturing industry in New Jersey. The New Jersey Chemical Industry Project is an effort to assess current environmental protection strategies on a sector basis and develop better approaches.
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The project has identified and analyzed corporate decision-making factors (drivers and barriers) that affect environmental performance at batch process chemical manufacturing facilities in New Jersey. New environmental protection strategies are being tested with a small number of these facilities. These strategies have been designed to address key issues identified in the analysis of drivers and barriers. The issues relate to permitting, reporting, process changes to reduce emissions, voluntary performance programs, and other types of flexibility in exchange for better environmental results. The stakeholder process ensures that the expertise and perspectives of industry, environmental groups, and community members are included in developing and evaluating the new strategies. (Contact: Catherine Tunis at EPAs Office Policy, Economics, and Innovation at 202-260-2698 or Tunis.Catherine@epa.gov , or see the projects website at http://www.epa.gov/sectors/sectors.html#chemical. Green Chemistry Initiative EPA's Green Chemistry Program promotes the research, development, and implementation of innovative chemical technologies that accomplish pollution prevention in both a scientifically-sound and cost-effective manner. To accomplish these goals, the Green Chemistry Program recognizes and supports chemical technologies that reduce or eliminate the use or generation of hazardous substances during the design, manufacture, and use of chemical products and processes. More specifically, the Green Chemistry Program supports fundamental research in the area of environmentally benign chemistry as well as a variety of educational activities, international activities, conferences and meetings, and tool development, all through voluntary partnerships with academia, industry, other government agencies, and non-government organizations. There are 45 companies, trade associations, scientific and research organizations, and other groups that are partners in the program. (Contact: Rich Engler at 202-564-8587 or engler.richard@epa.gov, or Carol Farris at 202-564-8554 or farris.carol@epa.gov in the Office of Prevention, Pesticides, and Toxic Substances, or see the website at www.epa.gov/greenchemistry/.) Design for the Environment The Design for the Environment (DfE) Program works with individual industry sectors to compare and improve the performance and human health and environmental risks and costs of existing and alternative products, processes, and practices. DfE partnership projects promote integrating cleaner, cheaper, and smarter solutions into everyday business practices. DfE has developed partnerships with industries directly downstream from the organic chemical industry, including detergent formulators, adhesive manufacturers, and ink manufacturers. (Contact: David Di Fiore at 202-2603374 or difiore.david@epa.gov, or Mary Cushmac at 202-260-4443 or Sector Notebook Project 118 November 2002
cushmac.mary@epa.gov in the Office of Prevention, Pesticides, and Toxic Substances, or see the website at www.epa.gov/dfe/projects/formulat/.) VIII.B. EPA Voluntary Programs High Production Volume Challenge As part of EPAs Chemical Right-to-Know Initiative, chemical producers and importers have been invited to provide basic toxicity information voluntarily on their high production volume (HPV) chemicals. HPV chemicals are those chemicals which are produced in or imported to the U.S. in amounts over 1 million pounds per year. The information generated through the Voluntary Challenge Program is made available to the public through the EPA website. Chemical companies that participate in the voluntary program make commitments identifying the chemicals they will adopt and test, and the schedule of which chemicals they will begin to test in each year of the program. Following the guidance established by EPA, participating companies will assess the adequacy of existing data; design and submit test plans; provide test results as they are generated; and prepare summaries of the data characterizing each chemical. The voluntary program uses the same tests, testing protocols, and basic information summary formats employed by the Screening Information Data Set (SIDS) program, a cooperative, international effort to secure basic toxicity information on HPV chemicals worldwide. Information prepared for this U.S. domestic program will be acceptable in the international effort as well. As of 2002, the program has been very successful; 403 companies have committed to providing health and environmental data on 2,011 chemicals. (For more information, see the website at www.epa.gov/opptintr/chemrtk/). National Environmental Performance Track The US EPA's National Environmental Performance Track Program is designed to motivate and reward top environmental performance. By encouraging a systematic approach to managing environmental responsibilities, taking extra steps to reduce and prevent pollution, and being good corporate neighbors, the program is rewarding companies that strive for environmental excellence. At the same time, many participating companies are finding that they are saving money and improving productivity. A number of organic chemical manufacturing facilities are participating in the Peformance Track program. (Contact: Performance Track hotline at 888339-PTRK or the website at www.epa.gov/performancetrack/.)
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Organic Chemical Industry WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPAs Office of Solid Waste and Emergency Response. The program is aimed at reducing municipal solid wastes by promoting waste minimization, recycling collection and the manufacturing and purchase of recycled products. As of 2001, the program had about 1,175 companies as members, including a number of major corporations. Members agree to identify and implement actions to reduce their solid wastes and must provide EPA with their waste reduction goals along with yearly progress reports. EPA in turn provides technical assistance to member companies and allows the use of the WasteWi$e logo for promotional purposes. Over thirty chemical companies currently are members of WasteWi$e. (Contact: Jeff Tumarkin at EPAs Office of Solid Waste and Emergency Response at (703) 308-8686 or Tumarkin.Jeff@epa.gov, or the WasteWi$e Hotline at 800-EPA-WISE (3729473) or www.epa.gov/wastewise.) Project XL Project XL, which stands for eXcellence and Leadership, is a national pilot program that allows state and local governments, businesses and federal facilities to develop with EPA innovative strategies to test better or more cost-effective ways of achieving environmental and public health protection. In exchange, EPA will issue regulatory, program, policy, or procedural flexibilities to conduct the experiment. Under Project XL, private businesses, federal facilities, business sectors and state and local governments are conducting experiments that address the following eight Project XL selection criteria: produce superior environmental results beyond those that would have been achieved under current and reasonably anticipated future regulations or policies produce benefits such as cost savings, paperwork reduction, regulatory flexibility or other types of flexibility that serve as an incentive to both project sponsors and regulators supported by stakeholders achieve innovation/pollution prevention produce lessons or data that are transferable to other facilities demonstrate feasibility establish accountability through agreed upon methods of monitoring, 120 November 2002
Organic Chemical Industry reporting, and evaluations
avoid shifting the risk burden, i.e., do not create worker safety or environmental justice problems as a result of the experiment.
By 2001, three chemical companies (Crompton, Eastman Kodak, and PPG) had undertaken projects under Project XL. (For more information, contact Chris Knopes in the Office of Reinvention Programs at (202) 260-9298 or Knopes.Christopher@epa.gov, or the website at www.epa.gov/projectxl.) Energy Star In 1991, EPA introduced Green Lights, a program designed for businesses and organizations to proactively combat pollution by installing energy efficient lighting technologies in their commercial and industrial buildings. In April 1995, Green Lights expanded into Energy Star Buildings a strategy that optimizes whole-building energy-efficiency opportunities. The energy needed to run commercial and industrial buildings in the United States produces 19 percent of U.S. carbon dioxide emissions, 12 percent of nitrogen oxides, and 25 percent of sulfur dioxide, at a cost of $110 billion a year. If implemented in every U.S. commercial and industrial building, the Energy Star Buildings upgrade approach could prevent up to 35 percent of the emissions associated with these buildings and cut the nations energy bill by up to $25 billion annually. The more than 7,000 participants include corporations, small businesses, universities, health care facilities, nonprofit organizations, school districts, and federal and local governments. Energy Star has successfully delivered energy and cost savings across the country, saving businesses, organizations, and consumers more than $5 billion a year. Over the past decade, Energy Star has been a driving force behind the more widespread use of such technological innovations as LED traffic lights, efficient fluorescent lighting, power management systems for office equipment, and low standby energy use. Manufacturers can become partners in Energy Star by pledging to undertake the following steps: Measure, track, and benchmark their organizations energy performance by using tools such as those offered by Energy Star Develop and implement a plan to improve energy performance in their facilities and operations by adopting the strategy provided by Energy Star Educate their staff and the public about our partnership with Energy 121 November 2002
Activities and Initiatives Star, and highlight our achievements with the Energy Star label, where available.
(Contact: Energy Star Hotline, 1-888-STAR-YES (1-888-782-7937) or visit the website at http://www.energystar.gov/default.shtml.) NICE3 The U.S. Department of Energy administers a grant program called The National Industrial Competitiveness through Energy, Environment, and Economics (NICE3). By providing grants of up to 50 percent of the total project cost, the program encourages industry to reduce industrial waste at its source and become more energy-efficient and cost-competitive through waste minimization efforts. Grants are used by industry to design, test, demonstrate, and assess the feasibility of new processes and/or equipment with the potential to reduce pollution and increase energy efficiency. The program is open to all industries; however, priority is given to proposals from participants in the chemicals, agriculture, aluminum, pulp and paper, glass, metal casting, mining, petroleum, and steel industries. (Contact: DOEs Golden Field Office at 303-275-4728, or see the website at www.oit.doe.gov/nice3.) EPA Audit Policy The U.S. Environmental Protection Agency (EPA) encourages companies with multiple facilities to take advantage of the Agency's Audit Policy (Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations, 65 Fed. Reg. 19618 (April 11, 2000) ) to conduct audits and develop environmental compliance systems. The Audit Policy eliminates gravity-based penalties for companies that voluntarily discover, promptly disclose and expeditiously correct violations of federal environmental law. More information on EPAs Audit Policy can be obtained from the Web site at: http://www.epa.gov/compliance/resources/policies/ incentives/ auditing/index.html. Small Business Compliance Policy The Small Business Compliance Policy promotes environmental compliance among small businesses (those with 100 or fewer employees) by providing incentives to discover and correct environmental problems. EPA will eliminate or significantly reduce penalties for small businesses that voluntarily discover violations of environmental law and promptly disclose and correct them. A wide range of resources are available to help small businesses learn about environmental compliance and take advantage of the Small Business Compliance Policy. These resources include: training, checklists, compliance guides, mentoring programs, and other activities. Sector Notebook Project 122 November 2002
Businesses can find more information through links on the Web site: http://www.epa.gov/smallbusiness/. Compliance Assistance Clearinghouse The National Environmental Compliance Assistance Clearinghouse is a Web-based clearinghouse designed to provide quick access to compliance assistance tools, contacts, and planned activities across EPA and other compliance assistance providers. The Clearinghouse also serves as a forum to collaborate and exchange information. The Clearinghouse provides links to compliance assistance activities, tools, or technical assistance that: 1) assist the regulated community in understanding and complying with environmental regulations; or 2) assist compliance assistance providers in helping the regulated community to comply with environmental regulations. The Clearinghouse Web site is http://www.epa.gov/clearinghouse/. VIII.C. Trade Association/Industry Sponsored Activity VIII.C.1. Environmental Programs Responsible Care The Responsible Care initiative of the American Chemistry Council requires all members and partners to continuously improve their health, safety, and environmental performance in a manner that is responsive to the public. Launched in 1988, the Responsible Care concepts are now being applied in over 40 countries around the world. Responsible Care is a comprehensive, performance-oriented initiative composed of the following ten elements: Guiding principles. The Responsible Care Guiding Principles are commitments that detail ethical ways the chemistry industry can benefit society, the environment and the economy. Every member and partner company CEO must sign the Guiding Principles and commit their company to working toward the vision of no accidents, injuries, or harm to the environment. Codes of management practices. The Codes are environmental, health and safety guidelines that member and partner companies must implement. Individual codes reflect the following: community awareness and emergency response, pollution prevention, process safety, distribution, employee health and safety, and product stewardship.
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Activities and Initiatives Dialogue with the public. With the help of environmentalists, educators, and health and safety specialists, we seek to identify and address public concerns. Self-evaluation. Each member and partner must annually report their progress toward implementing the Codes to help us direct our assistance efforts. Measures of performance. With specific performance measures, the industry and public can readily view the progress of Responsible Care. Performance goals. To measure individual progress, each member and partner must establish company-specific goals to be publicly reported each year. Management systems verification. This process provides members and partners with an independent review of the effectiveness of their systems for implementing Responsible Care. Mutual assistance. Company-to-company dialogue at all levels is one of the most effective methods of advancing Responsible Care. Networking occurs in organized leadership groups, regional forums and via the Internet. Partnership program. We help companies who transport, store, or distribute chemicals to participate in Responsible Care. Obligation of membership. As council members and partners, all companies are required to participate in Responsible Care and follow each of these requirements.
These elements cover all aspects of the chemical industrys operations, from research to manufacturing, distribution, transportation, sales and marketing, and to downstream users of chemical products. Through Responsible Care, Council members and partners gain insight from the public through, among other means, a national Public Advisory Panel and over 250 local Community Advisory Panels. This, coupled with the fact that participation in Responsible Care is an obligation of membership with the Council, make this performance improvement initiative unique. The Synthetic Organic Chemical Manufacturers Association (SOCMA), whose membership consists of smaller batch and custom chemical manufacturers with typically fewer than 50 employees and less than $50 million in annual sales, also has mandated that its members comply with Responsible Care. (Contact: American Chemistry Council, 703-741-5000or Sector Notebook Project 124 November 2002
http://www.americanchemistry.com/, or SOCMA at 202-721-4100 or www.socma.com.) Green Chemistry Institute The Green Chemistry Institute (GCI) is a non-profit organization founded in 1997 to promote Green Chemistry through research, education, information dissemination, conferences and symposia. GCI works across disciplines and academic, government and industry sectors to promote the development and implementation of science and technology to avoid the generation and production of hazardous wastes. GCI Board members are drawn from government, industry, academia and the National Laboratories to reflect a broad set of environmental interests and capabilities. GCI activities strive to discover, develop and deploy quantifiable new science and technology alternatives to existing chemical practice and achieve measurable declines in damage to human health and the environment. Green chemistry is a sciencebased approach to pollution prevention that has proven economically profitable to companies who have adopted greener technologies. In January 2001, GCI entered into a partnership agreement with The American Chemical Society (ACS). ACS seeks to address global issues at the intersection of chemistry and the environment. The ACS believes that it is better to prevent the entry of chemical substances into the environment than to address their known and unknown consequences at a later date. The ACS has articulated its support of green chemistry in its statements on sustainability and environmental protection. The alliance between ACS and the Green Chemistry Institute affords an opportunity to reaffirm and extend the importance of green chemistry in pollution prevention. (Contact: Dr. Dennis L. Hjeresen, Director, at 202-872-4078, or see the ACS website at www.chemistry.org.) Center for Waste Reduction Technologies The Center for Waste Reduction Technologies is under the aegis of the American Institute of Chemical Engineers. The center coordinates collaborative research on innovative, non-proprietary technologies and organizes regular meetings to help its members reduce environmental impacts. The center focuses its resources on four areas: sustainability, source reduction, waste management, and remediation. (Contact: 212-591-7424 or www.aiche.org/cwrt.) Global Environmental Management Initiative The Global Environmental Management Initiative (GEMI) is made up of group of leading companies dedicated to fostering environmental excellence by business. GEMI promotes a worldwide business ethic for environmental Sector Notebook Project 125 November 2002
management and sustainable development, to improve the environmental performance of business through example and leadership. In 2001, GEMIs membership consisted of about 40 major corporations including Ashland, Dow Chemical, DuPont, Eastman Kodak, Koch Industries, and Occidental. (Contact: GEMI at 202-296-7449 or see the website at: www.gemi.org.) ISO 14000 ISO 14000 is a series of internationally-accepted standards for environmental management. The series includes standards for environmental management systems (EMS), guidelines on conducting EMS audits, standards for auditor qualifications, and standards and guidance for conducting product lifecycle analysis. Standards for auditing and EMS were adopted in September 1996, while other elements of the ISO 14000 series are currently in draft form. While regulations and levels of environmental control vary from country to country, ISO 14000 attempts to provide a common standard for environmental management. The governing body for ISO 14000 is the International Organization for Standardization (ISO), a worldwide federation of over 110 country members based in Geneva, Switzerland. The American National Standards Institute (ANSI) is the United States representative to ISO. Information on ISO is available at the following Internet site: http://www.iso.ch/iso/en/ISOOnline.openerpage.
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Organic Chemical Industry VIII.C.2. Summary of Trade Associations American Chemical Society 1155 16th Street, NW
Washington, D.C. 20036
Phone: 202-872-4600
Fax: 202-872-4615
Internet: www.chemistry.org
Budget: $192,000,000 Staff: 1,700 Members: 145,000
The American Chemical Society (ACS) has an educational and research focus. The ACS produces approximately thirty different industry periodicals and research journals, including Environmental Science and Technology and Chemical Research in Toxicology. In addition to publishing, the ACS presently conducts studies and surveys; legislation monitoring, analysis, and reporting; and operates a variety of educational programs. The ACS library and on-line information services are extensive. Available fee-based services include STN, which offers current and archival information from over 200 scientific, technical, business, and patent databases covering a broad range of scientific fields, including chemistry, engineering, life sciences, pharmaceutics, biotechnology, regulatory compliance, patents, business. Founded in 1876, the ACS is presently comprised of 184 local groups and nearly 900 student groups nationwide. American Chemistry Council 1300 Wilson Boulevard Arlington, VA Phone: 703-741-5000 Fax: 703-741-6000
Internet:http://www.americanchemistry.com
Members: 185
Staff: 246
Budget: $36,000,000
A principal focus of the American Chemistry Council is on regulatory issues facing chemical manufacturers at the local, state, and federal levels. At its inception in 1872, the focus of the Council (formerly the Chemical Manufacturers Association) was on serving chemical manufacturers through research. Research is still ongoing at the Council. Member committees, task groups, and work groups routinely sponsor research and technical data collection that is then provided to the public in support of the Councils advocacy. Much additional research takes place through the CHEMSTAR program. CHEMSTAR consists of a variety of self-funded panels working on single-chemical research agendas. This research fits within the overall regulatory focus of the Council; CHEMSTAR study results are provided to both the Council membership and regulatory agencies. Other initiatives include the Responsible Care program, which includes six codes of Sector Notebook Project 127 November 2002
management practices designed to go beyond simple regulatory compliance. (This program is described earlier in Section VIII.C.1 of this document.) The Council also conducts workshops and technical symposia, promotes in-plant safety, operates a chemical emergency center (CHEMTREC) which offers guidance in chemical emergency situations, and operates the Chemical Referral Center which provides chemical health and safety information to the public. Ethylene Oxide Industry Council c/o American Chemistry Council
1300 Wilson Boulevard
Arlington, VA
Phone: 703-741-5000
The Ethylene Oxide Industry Council (EOIC), founded in 1981, is an
example of a panel group within the CHEMSTAR program of the American
Chemistry Council. The EOIC consists of ethylene oxide producers and
users. Ethylene oxide is used in the manufacture of antifreeze and polyester
fibers, and is widely used as a sterilizing agent. The EOIC develops
scientific, technological, and economic data on the safe use and manufacture
of ethylene oxide. Other duties include informing scientific and
governmental organizations of the industry's views and interests.
Synthetic Organic Chemicals Manufacturers Association 1850 M St N.W., Suite 700 Washington, D.C. 20036 Phone: 202-721-4100
Fax: 202-296-8120
Internet: www.socma.org
Members: 250
Staff: 50
Synthetic Organic Chemicals Manufacturers Association (SOCMA) is the national trade association representing the legislative, regulatory, and commercial interests of some 300 companies that manufacture, distribute, or market organic chemicals. Most of SOCMAs members are batch and custom chemical manufacturers who are the highly innovative, entrepreneurial and customer-driven sector of the U.S. chemical industry. The majority of SOCMAs members are small businesses with annual sales of less than $50 million and fewer than 50 employees. SOCMA assists its members in improving their environmental, safety, and health performance through various programs focusing on continuous improvement. A bi monthly newsletter provides information on legislative and regulatory developments, as well as on education and training opportunities. SOCMA Sector Notebook Project 128 November 2002
holds an annual meeting in May and also sponsors INFORMEX, the largest custom chemical trade show in the U.S. In addition, SOCMAs Association Management Center includes 40 self-funded groups that focus on single chemical issues. Consumer Specialties Products Association 900 17th St, NW, Suite 300 Washington, DC 20006 Phone: 202-872-8110
Fax: 202-872-8114
Internet: www.cspa.org
Members: 425
Staff: 31
This organization represents the manufacturers of such specialty chemical products as pesticides, cleaners, disinfectants, sanitizers, and polishes. The Consumer Specialties Products Association (CSPA) was founded in 1914. Today, the CSPA works with federal and state agencies and public representatives, to provide their membership with information on governmental activities and scientific developments. Some committees include: Government Affairs Advisory and Scientific Affairs. Publications include the quarterly Chemical Times & Trends, and the biweekly Executive Newswatch, an electronic newsletter summarizing legislative, regulatory and marketing developments. Halogenated Solvents Industry Alliance 2001 L Street NW, Suite 506a Washington, DC 20036 Tel: 202-775-0232 Fax: 202-833-0381 Internet: www.hsia.org Members: 200 Budget: $1,400,000
The goal of the Halogenated Solvents Industry Alliance (HSIA) is to develop programs to address problems involving halogenated solvents. The group is actively involved in legislative and regulatory issues affecting the industry, providing industry comments and information to agencies, and representing the industry at administrative hearings. The HSIA also sponsors working groups on issues specific to the solvent industry. Publications include the bimonthly newsletter Halogenated Solvents Industry Alliance, which includes a listing of publications available from the group and the monthly newsletter Solvents Update, which covers regulatory development and HSIA actions.
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Organic Chemical Industry American Institute of Chemical Engineers 3 Park Avenue New York, NY 10016 Phone: 212-591-7338 Fax: 212-591-8897 Internet: www.aiche.org
Members: 54,000 Staff: 103
The American Institute of Chemical Engineers (AICHE) is a professional society of chemical engineers. AICHE develops chemical engineering curricula and sponsors a variety of chemical study forums. AICHE is split into twelve divisions including the Environmental, Forest Products, Fuels and Petrochemical, and Safety and Health divisions. Approximately fourteen publications are produced by AICHE, such as the quarterly Environmental Progress, a periodic directory of members, and a variety of pamphlets. AICHE holds three conferences per year in various locations.
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Color Pigments Manufacturers Association, Inc. 300 N. Washington St., Ste. 102 Alexandria, VA 22314 Phone: 703-684-4044
Fax: 703-684-1795
Members: 50
Staff: 5
The Color Pigments Manufacturers Association (CPMA) represents North American manufacturers of pigments and pigment ingredients (i.e., dyes). The CPMA also represents the affiliates of manufacturers of those products who happen to manufacture the product overseas. The CPMA represents its membership before government agencies. No further information is available at this time. Fire Retardant Chemical Association 1681 Crown Avenue, Suite 202 Lancaster, PA 17601
Phone: 717-291-5616
Fax: 717-295-8455
Internet: www.fireretardants.org
Members: 42 Staff: 5
Chemical distributors/manufacturers active in promoting fire safety through chemical technology comprise the Fire Retardant Chemical Association (FRCA), founded in 1973. The FRCA serves as a forum for information dissemination on new developments, new applications, and current testing procedures for fire retardants and chemical fire safety products. Publications include the periodic Fire Retardant Chemicals Association - Membership Directory and the Fire Retardant Chemical Association Proceedings. Educational conferences are held semiannually. National Paint and Coatings Association 1500 Rhode Island Avenue, NW Washington, DC 20005 Phone: 202-462-6272 Fax: 202-462-8549 Internet: www.paint.org Members: 700 Staff: 40
Founded in 1933, the National Paint and Coatings Association (NPCA) represents manufacturers of paints and chemical coatings as well as suppliers of paint manufacturing equipment and raw materials. NPCA is involved in government relations programs, statistical surveys, and industry research. Sector Notebook Project 131 November 2002
Committees include Labeling, Scientific, and Government Supply. The NPCA publishes an annual report, a periodic newsletter and trade directory, and a variety of guides. Drug, Chemical, and Allied Trades Association 510 Route 130, Suite B1 East Windsor, NJ 08520 Phone: 609-448-1000 Fax: 609-448-1944
Members:500
Staff: 3
Budget: $500,000
Founded in 1890, The Drug, Chemical & Allied Trades Association, Inc. (DCAT) is a business development association whose membership is comprised of companies that manufacture, distribute or provide services to the drug, chemical, nutritional and related industries. The Association provides services, programs and activities designed to support the business development objectives of its membership.
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Organic Chemical Industry National Association of Chemical Recyclers 1875 Connecticut Ave., NW
Suite 1200
Washington, DC 20009
Phone: 202-986-8150
Fax: 202-986-2021
Members: 70 Staff: 3
National Association of Chemical Recyclers (NACR) founded in 1980, consists of recyclers of used industrial solvents. The organization promotes responsible and intelligent regulation and the beneficial reuse of waste. NACR monitors and reports on regulatory and legislative action affecting the practice of solvent recycling. NACR also compiles industry statistics. NACR publishes Flashpoint and a semiannual membership list. NACR holds a semiannual conference, usually in April or October.
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Organic Chemical Industry IX.
Contacts and References
CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY For further information on selected topics within the organic chemical industry a list of publications and contacts are provided below:
Contacts4
Name Walter DeRieux Organization U.S. EPA, Office of Enforcement and Compliance Assistance U.S. EPA, Office of Enforcement and Compliance Assistance U.S. EPA, Region V U.S. EPA, Office of Pollution Prevention and Toxics U.S. EPA, Office of Pollution Prevention and Toxics EPA, National Enforcement Investigations Center U.S. Department of Energy, Office of Industrial Technology Synthetic Organic Chemical Manufacturers Association Contact Information 202-564-7067 derieux.walter@epa.gov 202-564-7042 mia.marcia@epa.gov 312-886-6793 varner.bruce@epa.gov 202-564-8798 rawie.carol@epa.gov 202-566-0749 senthil.velu@epa.gov 303-236-6147 seidel.jimmy@epa.gov 202-586-8501 dickson.ozokwelu@ee.doe .gov 202-721-4198 gunnulfsenj@socma.org Subject Organic chemical industry sector lead Industrial processes and enforcement issues Clean Air Act, air toxics Toxic Substances Control Act
Marcia Mia
Bruce Varner Carol Rawie
Velu Senthil
Toxics Release Inventory
Jim Seidel
Industrial processes and regulatory requirements Technologies and processes with the potential for energy, environmental, and cost savings Industrial processes and federal environmental requirements
Dickson Ozokwelu
Jeff Gunnulfsen
Many of the contacts listed above have provided valuable background information and comments during development of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all statements made within this notebook.
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Organic Chemical Industry General Profile American Chemistry Council, 2001. Chemistry Product Chains.
Charles H. Kline & Co., 1999. Kline Guide to the Chemical Industry, 6th ed. Little Falls, NJ. Speed, Phillip, 1999. The Changing Competitive Landscape of the Chemical Industry. Chemical Bond. Synthetic Organic Chemicals Manufacturers Association. July. Szmant, H. Harry, 1989. Organic Building Blocks of the Chemical Industry. New York: John Wiley and Sons. U.S. Department of Commerce, 1998. 1997 County Business Patterns for the United States. U.S. Department of Commerce/Census Bureau, 2000. 1997 Economic Census: Bridge Between NAICS and SIC. U.S. Department of Commerce/International Trade Administration, 2000. U.S. Industry & Trade Outlook 2000. U.S. Department of Congress, McGraw-Hill. U.S. Department of Labor/Occupational Safety and Health Administration, 2001. Standard Industrial Classification Search. www.osha.gov/oshstats/sicser.html. U.S. Environmental Protection Agency/Office of Pollution Prevention and Toxics, 2002. Chemical Testing and Information. www.epa.gov/opptintr/chemtest. U.S. International Trade Commission, Synthetic Organic Chemicals, United States Production and Sales, 1992. [Published annually] 1992 Census of Manufactures, Industry Series, Industrial Organic Chemicals, Bureau of the Census. Process Descriptions and Chemical Use Profiles Buonicore, A.J., and Davis, W.T., 1992. Air Pollution Engineering Manual - Chapter 16: Pharmaceutical Industry, Richard Crume and Jeffrey Portzer, eds. Air and Waste Management Association. New York: Van Nostrand Reinhold. Chemical Manufacturers Association, 1993. Designing Pollution Prevention into the Process Research, Development and Engineering. Franck, H.G. and J.W. Stadelhofer, 1987. Industrial Aromatic Chemistry. Berlin: SpringerVerlag. Sector Notebook Project 135 November 2002
Hocking, M.B., 1998. Handbook of Chemical Technology and Pollution Control. San Diego: Academic Press, Second Edition. Kent, J.(ed.), 1992. Reigels Handbook of Industrial Chemistry. New York: von Nostrand Reinhold, Ninth Edition. Kirk-Othmer Encyclopedia of Chemical Technology (appropriate volumes). Perry, Robert H. and Cecil H. Chilton, Chemical Engineers Handbook. New York: McGrawHill Book Company. Peters, Max S. and Klaus D. Timmerhaus, Plant Design and Economics for Chemical Engineers. New York: McGraw-Hill Book Company. Shreve, Chemical Process Industries. SRI International, Menlo Park, CA. Szmant, H. Harry, 1989. Organic Building Blocks of the Chemical Industry, New York: John Wiley and Sons. Tomes Plus Information System. Denver, CO: Micromedia, Inc. Contains information on chemical use, production, and health effects. (303) 831-1400. Ullman's Encyclopedia of Chemical Technology (appropriate volumes). U.S. Environmental Protection Agency, 1987. Development Document of Effluent Limitations Guidelines for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category, EPA 440/1-87/009. U.S. Environmental Protection Agency, 1993. Control of Volatile Organic Compound Emissions from Batch Processes. EPA450R94020. Wells, G. Margaret, 1991. Handbook of Petrochemicals and Processes. Aldershot, England: Gower Publishing Company. Chemical Releases and Transfers National Library of Medicine, 2001. Hazardous Substances Data Bank. http://toxnet.nlm.nih.gov/ U.S. EPA, 1985. Compilation of Air Pollutant Emission Factors, Volume I: Stationary Point and Area Sources, Chapter 9, Petroleum Industry. September. U.S. EPA, 1992. Amoco - U.S. EPA Pollution Prevention Project, Yorktown, Virginia, Project Sector Notebook Project 136 November 2002
Organic Chemical Industry Summary, January. U.S. EPA, 1999. Toxics Release Inventory Database.
U.S. EPA, 2001a. AIRS Database. Office of Air and Radiation. November. Regulatory Profile U.S. EPA, 2001b. Using the SOCMI CAR: An Enabling Manual for the Synthetic Organic Chemical Manufacturing Industry (SOCMI) Consolidated Federal Air Rule (CAR). September. U.S. Government Printing Office, 2001a. Unified Agenda. Volume 66, Number 93, Page 2617726178. U.S. Government Printing Office, 2001b. Unified Agenda. Volume 66, Number 93, Pages 26232-26233. Pollution Prevention Breen, Joseph J., and Michael J. Dellarco, 1992. Pollution Prevention in Industrial Processes: The Role of Process Analytical Chemistry. Washington, DC: American Chemical Society. Chemical and Engineering News Design for the Environment: Chemical Syntheses that Dont Pollute September 5, 1994. Article on the 1994 American Chemical Society symposium Design for the Environment: A New Paradigm for the 21st Century. Chemical Manufacturers Association, 1993. Designing Pollution Prevention into the Process: Research, Development and Engineering. Du Pont Corporation and U.S. Environmental Protection Agency, 1993. Du Pont Chamber Works Waste Minimization Project. Dorfman, M.H. et al. Environmental Dividends: Cutting More Chemical Wastes. New York, NY: INFORM, Inc. Forester, William S., and John H. Skinner, 1992. Waste Minimization and Clean Technology: Waste Management Strategies for the Future. San Diego, CA: Academic Press. The Hazardous Waste Consultant, New York: Elsevier Science Inc. (A bimonthly journal.) Overcash, Michael R., 1986. Techniques for Industrial Pollution Prevention: A Compendium for Hazardous and Non-Hazardous Waste Minimization. Chelsea, MI: Lewis Publishers. Sector Notebook Project 137 November 2002
Sawyer, Donald T., and Arthur E. Martell, 1992. Industrial Environmental Chemistry: Waste Minimization in Industrial Processes and Remediation of Hazardous Waste. New York, NY: Plenum Press. Synthetic Organic Chemicals Manufacturers Association, 1993. SOCMA Pollution Prevention Study. Theodore, Louis, and Young C. McGuinn, 1992. Pollution Prevention. New York: Van Nostrand Reinhold. U.S. Congress, Office of Technology Assessment,1994. Industry, Technology, and the Environment: Competitive Challenges and Business Opportunities, OTA-ITE-586. January. Information Sources and Agencies Pollution Prevention Information Clearinghouse (PPIC) U.S. EPA The International Cleaner Production Information Clearinghouse (ICPIC); United Nations Environmental Programme (UNEP), U.S. EPA Books, Reports and Documents Noyes Data Corporation, Alternative Formulations and Packaging to Reduce Use of Chlorofluorocarbons, 1990, ISBN0-8155-1257-0. Research Triangle Institute, Alternatives for Measuring Hazardous Waste Reduction, 1991, PB91-208595. Noyes Data Corporation, Aqueous Cleaning as an Alternative to CFC and Chlorinated SolventBased Cleaning, 1991, ISBN0-8155-1285-6. EPA, Background Document on Clean Products Research and Implementation, 1990, EPA/600/S2-90/048. EPA, Case Studies from the Pollution Prevention Information Clearinghouse: Solvent Recovery, 1989, ISM-4 (PPIC). Government Institutes, Case Studies in Waste Minimization, 1991, ISBN0-86587-267-8. United Nations Environmental Programme (UNEP), Cleaner Production Newsletter, Industry and Environmental Office, ICPIC-1 (PPIC). EPA, Degreaser System Pollution Prevention Evaluation, 1990, EPA/600/S2-90/052. Sector Notebook Project 138 November 2002
Oregon Department of Environmental Quality, Guidelines for Waste Reduction and Recycling: Solvents, 1989, ISM-13 (PPIC). EPA, Guides to Pollution Prevention: Research and Educational Institutions, 1990, ISM-19 (PPIC). EPA, Guides to Pollution Prevention: The Fiberglass-Reinforced and Composite Plastics Industry, ISM-19 (PPIC). McGraw-Hill, Inc., Hazardous Waste Minimization, 1990, ISBN0-07-022043-3. Lewis Publishers, Hazardous Waste Minimization Handbook, 1989, ISBN0-87371-176-9. ASTM, Hazardous and Industrial Solid Waste Minimization Practices, 1989, ISBN0-80311269-6. EPA, Industrial Pollution Prevention for the 1990s, 1991, EPA/600/S8-91/052. EPA, Pollution Prevention Benefits Manual: Volume 1 (Draft), 1989, WAM-1 (PPIC). EPA, Pollution Prevention Fact Sheets: Chemical Production, FREG-1 (PPIC), free. EPA, Pollution Prevention Information Exchange System (PIES) User Guide, Version 1.1, 1989, EPA/600/9-89/086, free. City of Los Angeles, Pollution Prevention Opportunities Checklist: Chemical Manufacturing, FCLA-1-1 (PPIC). CMA, Pollution Prevention Resource Manual, 1991, $75.00 (non-members), $50.00 (members, Order no. 018031). EPA, Prevention Reference Manual: Chemical Specific, Volume 10: Control of Accidental Releases of Hydrogen Cyanide, 1987, EPA/600-S8-87/034j. EPA, Prevention Reference Manual: Chemical Specific, Volume 11: Control of Accidental Releases of Ammonia, 1987, EPA/600-S8-87/034k. EPA, Prevention Reference Manual: Chemical Specific, Volume 12: Control of Accidental Releases of Sulfur Dioxide, 1987, EPA/600/S8-87/034l. EPA, Prevention Reference Manual: Chemical Specific, Volume 13: Control of Accidental Releases of Methyl Isocyanate, 1987, EPA/600/S8-87/034m. EPA, Prevention Reference Manual: Chemical Specific, Volume 14: Control of Accidental Releases of Phosgene, 1987, EPA/600/S8-87/034n.
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EPA, Prevention Reference Manual: Chemical Specific, Volume 15: Control of Accidental Releases of Sulfur Trioxide, 1987, EPA/600/S8-87/034o. EPA, Prevention Reference Manual: Chemical Specific, Volume 1: Control of Accidental Releases of Hydrogen Fluoride (SCAQMD), 1987, EPA/600/S8-87/034a. EPA, Prevention Reference Manual: Chemical Specific, Volume 2: Control of Accidental Releases of Chlorine (SCAQMD), 1987, EPA/600/S8-87/034b. EPA, Prevention Reference Manual: Chemical Specific, Volume 3: Control of Accidental Releases of Hydrogen Cyanide (SCAQMD), 1987, EPA/600/S8-87/034c. EPA, Prevention Reference Manual: Chemical Specific, Volume 4: Control of Accidental Releases of Ammonia Cyanide (SCAQMD), 1987, EPA/600/S8-87/034d. EPA, Prevention Reference Manual: Chemical Specific, Volume 7: Control of Accidental Releases of Chloropicrin Cyanide (SCAQMD), 1987, EPA/600/S8-87/034g. EPA, Prevention Reference Manual: Chemical Specific, Volume 8: Control of Accidental Releases of Hydrogen Fluoride, 1987, EPA/600/S8-87/034h. EPA, Prevention Reference Manual: Chemical Specific, Volume 9: Control of Accidental Releases of Chlorine, 1987, EPA/600/S8-87/034i. EPA, Prevention Reference Manual: Chemical Specific, Volume 6: Control of Accidental Releases of Carbon Tetrachloride (SCAQMD), 1987, EPA/600/S8-87/034f. EPA, Prevention Reference Manual: Control Technologies. Volume 2: Post-Release Mitigation Measures for Controlling Accidental Releases of Air Toxics, 1987, EPA/600/S887/039b. EPA, Prevention Reference Manual: Control Technologies. Volume 1: Prevention and Protection Technologies for Controlling Accidental Releases of Air Toxics, 1987, EPA/600/S8-87/039a. EPA, Prevention Reference Manual: Overviews on Preventing and Controlling Accidental Releases of Selected Toxic Chemicals, 1988, EPA/600/S8-88/074. EPA, Prevention Reference Manual: User's Guide, Overview for Controlling Accidental Releases of Air Toxics, 1987, EPA/600/S8-87/028. EPA, Proceedings of the International Workshop on Research in Pesticide Treatment/Disposal/ Waste Minimization, 1991, EPA/600-S9-91/047. Alaska Health Project, Profiting from Waste Reduction in Your Small Business, 1988, free, QAM-2 (PPIC). Sector Notebook Project 140 November 2002
National Academy Press, Reducing Hazardous Waste Generation: An Evaluation and a Call for Action, 1985, $9.95, ISBN 0-309-03498-1. Noyes, Data Corporation, Solvent Waste Reduction, 1990, $45, ISBN 0-8155-1254-6. EPA, Solvent Waste Reduction Alternatives, 1989, EPA/625/4-89/021. EPA, Source Characterization and Control Technology Assessment of Methylene Choride Emissions from Eastman Kodak Company, Rochester, NY, 1989, EPA/600-S2-043. Government Institutes, The Greening of American Business: Making Bottom-Line Sense of Environmental Responsibility, 1992, $24.95, ISBN: 0-86587-295-3. Van Nostrand Reinhold, The Recycler's Manual for Business, Government, and the Environmental Community, 1992, $64.95, ISBN 0-442-01190-3. National Academy Press, Tracking Toxic Substances at Industrial Facilities: Engineering Mass Balance Versus Materials Accounting, 1990, ISBN 0-0309-04086-8. EPA, Waste Exchange Information Package, 1991, free, GEN-13 (PPIC). EPA, Waste Minimization: Environmental Quality with Economic Benefits, 1990, free, EPA/530-SW-87-026 (also GEN-14 (PPIC)). Government Institutes, Waste Minimization Manual, 1987, $57.00, ISBN: 0-86587-731-9. EPA, Waste Minimization Opportunity Assessment Manual, 1988, EPA/625/7-88/003. CMA, Waste Minimization Workshop Handbook, 1987, $250.00 (non-members); $100.00 (members), Order no. 018016. API, Waste Minimization in the Petroleum Industry: A Compendium of Practices, 1991, $35.00, Order no. 849-30200. Lewis Publishers, Waste Minimization: Implementing an Effective Program, due 1992, $59.00, ISBN 0-87371-521-7. Noyes Data Corporation, Waste Oil: Reclaiming Technology, Utilization, and Disposal, 1989, $39.00, ISBN 0-8155-1193-0. California Department of Health Service, Waste Reduction Fact Sheet: Pesticide Formulating Industry, free, FCAD-7 (PPIC). Executive Enterprises, Waste Reduction: Policy and Practice, $39.95, ISBN 1-55840-272-1.
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Organic Chemical Industry

Sector Notebook Project EPA/310-R-02-001

EPA Office of Compliance Sector Notebook Project

Profile of the Organic Chemical Industry 2nd Edition

Organic Chemical Industry

Sector Notebook Project

Sector Notebook Project

Organic Chemical Industry

Sector Notebook Project

AVAILABLE SECTOR NOTEBOOKS

EPA Publication Number

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Organic Chemical Industry

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Organic Chemical Industry

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VII. COMPLIANCE AND ENFORCEMENT PROFILE . . . . . . . . . . . . . . . . . . . . . . . . . . . 96

Organic Chemical Industry

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VIII. COMPLIANCE ACTIVITIES AND INITIATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . 117

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Organic Chemical Industry

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Organic Chemical Industry

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Material Safety Data Sheets

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Organic Chemical Industry I.

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INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

Organic Chemical Industry

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Organic Chemical Industry II.

Introduction, Background, and Scope

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Organic Chemical Industry

Introduction, Background, and Scope

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Organic Chemical Industry

Introduction, Background, and Scope

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Organic Chemical Industry

Introduction, Background, and Scope

Eyeglasses, foams Fabric and plastic coloring Latex, adhesives

Sources: U.S. Department of Labor, 2001; American Chemistry Council, 2001.

Organic Chemical Industry

Introduction, Background, and Scope

Figure 1: Annual Volume and Value of Common Organic Chemicals

Pounds Value ($)

Source: American Chemistry Council and Kline & Company, 1999.

Sector Notebook Project

Organic Chemical Industry