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
Organic Chemical Industry 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 EPA’s 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 EPA’s 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 EPA’s 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. 

Sector Notebook Project ii November 2002 
Organic Chemical Industry Sector Notebook Project 

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 Industry 

EPA/310-R-95-001. Profile of the Dry Cleaning Industry

EPA/310-R-95-002. Profile of the Electronics and Computer Industry*

EPA/310-R-95-003. Profile of the Wood Furniture and Fixtures Industry

EPA/310-R-95-004. Profile of the Inorganic Chemical Industry*

EPA/310-R-95-005. Profile of the Iron and Steel Industry

EPA/310-R-95-006. Profile of the Lumber and Wood Products Industry

EPA/310-R-95-007. Profile of the Fabricated Metal Products Industry*

EPA/310-R-95-008. Profile of the Metal Mining Industry

EPA/310-R-95-009. Profile of the Motor Vehicle Assembly Industry

EPA/310-R-95-010. Profile of the Nonferrous Metals Industry

EPA/310-R-95-011. Profile of the Non-Fuel, Non-Metal Mining Industry

EPA/310-R-02-001. Profile of the Organic Chemical Industry, 2nd Edition*

EPA/310-R-95-013. Profile of the Petroleum Refining Industry

EPA/310-R-95-014. Profile of the Printing Industry

EPA/310-R-02-002. Profile of the Pulp and Paper Industry, 2nd Edition

EPA/310-R-95-016. Profile of the Rubber and Plastic Industry

EPA/310-R-95-017. Profile of the Stone, Clay, Glass, and Concrete Ind.

EPA/310-R-95-018. Profile of the Transportation Equipment Cleaning Ind.

EPA/310-R-97-001. Profile of the Air Transportation Industry

EPA/310-R-97-002. Profile of the Ground Transportation Industry

EPA/310-R-97-003. Profile of the Water Transportation Industry

EPA/310-R-97-004. Profile of the Metal Casting Industry

EPA/310-R-97-005. Profile of the Pharmaceuticals Industry

EPA/310-R-97-006. Profile of the Plastic Resin and Man-made Fiber Ind.

EPA/310-R-97-007. Profile of the Fossil Fuel Electric Power Generation Industry 

EPA/310-R-97-008. Profile of the Shipbuilding and Repair Industry

EPA/310-R-97-009. Profile of the Textile Industry

EPA/310-R-97-010. Sector Notebook Data Refresh-1997 **

EPA/310-R-98-001. Profile of the Aerospace Industry

EPA/310-R-00-001. Profile of the Agricultural Crop Production Industry

Contact: Ag Center, (888) 663-2155

EPA/310-R-00-002. Profile of the Agricultural Livestock Production Industry

Contact: Ag Center, (888) 663-2155

EPA/310-R-00-003. Profile of the Agricultural Chemical, Pesticide and Fertilizer Industry

Contact: Agriculture Division, 202 564-2320

EPA/310-R-00-004. Profile of the Oil and Gas Extraction Industry

Government Series 

EPA/310-R-99-001. 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.

Sector Notebook Project iii November 2002 
Organic Chemical Industry Sector Notebook Project 

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. 

Sector Notebook Project iv November 2002 
Organic Chemical Industry Sector Notebook Project 

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

II. 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

III. 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

IV. 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

V. POLLUTION PREVENTION OPPORTUNITIES .............................49

VI. 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

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 
Organic Chemical Industry Sector Notebook Project 

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

Sector Notebook Project vi November 2002 
Organic Chemical Industry Sector Notebook Project 

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

Sector Notebook Project vii November 2002 
Organic Chemical Industry Sector Notebook Project 

LIST OF ACRONYMS 

AFS AIRS Facility Subsystem (CAA database)

AIRS Aerometric Information Retrieval System (CAA database)

AOR Area of Review (SDWA)

BAT Best Available Technology Economically Achievable

BCT Best Conventional Pollutant Control Technology

BIFs Boilers and Industrial Furnaces (RCRA)

BMP Best Management Practice

BOD Biochemical Oxygen Demand 

BPT Best Practicable Technology Currently Available

CAA Clean Air Act

CAAA Clean Air Act Amendments of 1990

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CERCLIS CERCLA Information System

CFCs Chlorofluorocarbons

CFR Code of Federal Regulations

CGP Construction General Permit (CWA)

CO Carbon Monoxide 

CO2 Carbon Dioxide

COD Chemical Oxygen Demand 

CSI Common Sense Initiative 

CWA Clean Water Act

CZMA Coastal Zone Management Act

D&B Dun and Bradstreet Marketing Index

DOC United States Department of Commerce

DPCC Discharge Prevention, Containment and Countermeasures

EIS Environmental Impact Statement

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act 

ESA Endangered Species Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FINDS Facility Indexing System

FR Federal Register

FRP Facility Response Plan

HAPs Hazardous Air Pollutants (CAA)

HSDB Hazardous Substances Data Bank

HSWA Hazardous and Solid Waste Amendments

IDEA Integrated Data for Enforcement Analysis

LDR Land Disposal Restrictions (RCRA)

LEPCs Local Emergency Planning Committees 

MACT Maximum Achievable Control Technology (CAA)

MCLGs Maximum Contaminant Level Goals 

MCLs Maximum Contaminant Levels 

MEK Methyl Ethyl Ketone

Sector Notebook Project viii November 2002 
Organic Chemical Industry Sector Notebook Project 

MSDSs Material Safety Data Sheets 

MSGP Multi-Sector General Permit (CWA)

NAAQS National Ambient Air Quality Standards (CAA)

NAFTA North American Free Trade Agreement

NAICS North Americal Industrial Classification System

NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NEC Not Elsewhere Classified

NEIC National Enforcement Investigations Center 

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants

NICE3 National Industrial Competitiveness Through Energy, Environment and Economics

NO2 Nitrogen Dioxide

NOI Notice of Intent

NOT Notice of Termination

NOV Notice of Violation 

NOx Nitrogen Oxides 

NPDES National Pollution Discharge Elimination System (CWA)

NPL National Priorities List 

NRC National Response Center 

NSPS New Source Performance Standards (CAA)

OAQPS Office of Air Quality Planning and Standards

OAR Office of Air and Radiation

OECA Office of Enforcement and Compliance Assurance

OMB Office of Management and Budget

OPA Oil Pollution Act

OPPTS Office of Prevention, Pesticides, and Toxic Substances

OSHA Occupational Safety and Health Administration 

OSW Office of Solid Waste

OSWER Office of Solid Waste and Emergency Response

OW Office of Water

P2 Pollution Prevention

PCS Permit Compliance System (CWA Database)

PM10 Particulate Matter of 10 microns or less

PMN Premanufacture Notice

POTW Publicly Owned Treatments Works 

PSD Prevention of Significant Deterioration (CAA)

PT Total Particulates

RCRA Resource Conservation and Recovery Act

RCRIS RCRA Information System

RQ Reportable Quantity (CERCLA)

SARA Superfund Amendments and Reauthorization Act 

SDWA Safe Drinking Water Act

SEPs Supplementary Environmental Projects 

SERCs State Emergency Response Commissions 

SIC Standard Industrial Classification 

Sector Notebook Project ix November 2002 
Organic Chemical Industry Sector Notebook Project 

SIP State Implementation Plan

SO2 Sulfur Dioxide 

SOx Sulfur Oxides

SOCMI Synthetic Organic Chemical Manufacturing Industry

SPCC Spill Prevention Control and Countermeasures

STEP Strategies for Today’s Environmental Partnership

SWPPP Storm Water Pollution Prevention Plan (CWA)

TOC Total Organic Carbon 

TRI Toxic Release Inventory

TRIS Toxic Release Inventory System

TCRIS Toxic Chemical Release Inventory System

TSCA Toxic Substances Control Act

TSD Treatment Storage and Disposal

TSP Total Suspended Particulates

TSS Total Suspended Solids 

UIC Underground Injection Control (SDWA)

USDW Underground Sources of Drinking Water (SDWA)

UST Underground Storage Tanks (RCRA)

VOCs Volatile Organic Compounds

Sector Notebook Project x November 2002 
Organic Chemical Industry Sector Notebook Project 

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 
Organic Chemical Industry Sector Notebook Project 

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 

OECA’s 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. 

Sector Notebook Project 2 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

II. 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 Industry Sector 

281 Inorganic chemicals 

282 Plastics materials and synthetics 

283 Drugs 

284 Soaps, cleaners, and toilet goods 

285 Paints and allied products 

286 Organic chemicals 

287 Agricultural chemicals 

289 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. 

Sector Notebook Project 3 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

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 SIC Description 1997 NAICS NAICS Description 

2861 Gum & wood chemicals 325191 Gum & wood chemical mfg 

2865 Cyclic crudes & intermediate 325110 Petrochemical mfg (part) 

325132 Synthetic organic dye & pigment mfg 

325192 Cyclic crude & intermediate mfg 

2869 Industrial organic chemicals, not 

elsewhere classified 

325110 Petrochemical mfg (part) 

325120 Industrial gas mfg (part) 

325188 All other basic inorganic chemical mfg 

(part) 

325193 Ethyl alcohol mfg 

325199 All other basic organic chemical mfg (part) 

Source: U.S. Census Bureau, 2000. 

Sector Notebook Project 4 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

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. 

Sector Notebook Project 5 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

Table 3: Summary of Major Organic Chemical Products 

Category Example Chemicals Example End Uses 

Aliphatic and other acyclic 

organic chemicals 

Ethylene, butylene, and 

formaldehyde 

Polyethylene plastic, 

plywood 

Solvents Butyl alcohol, ethyl acetate, 

ethylene glycol ether, 

perchloroethylene 

Degreasers, dry cleaning 

fluid 

Polyhydric alcohols Ethylene glycol, sorbitol, 

synthetic glycerin 

Antifreeze, soaps 

Synthetic perfume and 

flavoring materials 

Saccharin, citronellal, 

synthetic vanillin 

Food flavoring, cleaning 

product scents 

Rubber processing chemicals Thiuram, hexamethylene 

tetramine 

Tires, adhesives 

Plasticizers Phosphoric acid, phthalic 

anhydride, and stearic acid 

Rain coats, inflatable toys 

Synthetic tanning agents Naphthalene sulfonic acid 

condensates 

Leather coats and shoes 

Chemical warfare gases Tear gas, phosgene Military and law enforcement 

Esters and/or amines of 

polyhydric alcohols and fatty 

and other acids 

Allyl alcohol, diallyl maleate Paints, electrical coatings 

Cyclic crudes and 

intermediates 

Benzene, toluene, mixed 

xylenes, naphthalene 

Eyeglasses, foams 

Cyclic dyes and organic 

pigments 

Nitro dyes, organic paint 

pigments 

Fabric and plastic coloring 

Natural gum and wood 

chemicals 

Methanol, acetic acid, rosin 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 
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Organic Chemical Industry Introduction, Background, and Scope 

Figure 1: Annual Volume and Value of Common Organic Chemicals Ethylene dichloride MTBE Vinyl chloride Methanol (synthetic) Styrene Dimethyl terephthalate Formaldehyde Ethylene oxide Cumene Ethylene glycol 

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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. 

Sector Notebook Project 7 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

Table 4: Facility Size Distribution of Organic Chemical Facilities 

Industry 

Distribution of Facilities According to Number of Employees 

(% of Total in Parentheses) 

1-19 

Employees 

20-99 

Employees 

100-499 

Employees 

>499 

Employees 

Total 

Facilities 

Gum and wood chemicals 

(SIC 2861) 

52 (74%) 10 (14%) 8 (11%) 0 (0%) 70 (100%) 

Cyclic crudes and 

intermediates (SIC 2865) 

75 (38%) 67 (34%) 51 (26%) 6 (3%) 199 (100%) 

Industrial organic 

chemicals, not elsewhere 

classified (SIC 2869) 

268 (36%) 254 (34%) 177 (24%) 44 (6%) 743 (100%) 

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. 

Sector Notebook Project 8 November 2002 
Organic Chemical Industry Introduction, Background, and Scope 

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). 

Sector Notebook Project 9 November 2002 
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Organic Chemical Industry Introduction, Background, and Scope 

Table 5: Top 20 U.S. Chemical Producers in 2001 

Rank Company 2001 Chemical Salesa 

(millions of dollars) 

Dow Chemical 27,805 

DuPont 26,787 

ExxonMobil 15,943 

Huntsman Corp. 8,500 

General Electric 7,069 

BASF 6,852 

Chevron Phillips 6,010 

PPG Industries 5,933 

Equistar Chemicals 5,909 

Shell Oil 5,524 

Air Products 5,467 

Eastman Chemical 5,384 

BP 5,300 

Praxair 5,158 

Rohm and Haas 4,917 

Atofina 4,380 

Monsanto 3,755 

Honeywell 3,313 

Lyondell Chemical 3,226 

Nova Chemicals 3,194 

a

 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.

Sector Notebook Project 10 November 2002 
Organic Chemical Industry Industrial Process Description 

III. 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 
Organic Chemical Industry Industrial Process Description 

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 

Sector Notebook Project 12 November 2002 
Organic Chemical Industry Industrial Process Description 

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 
Organic Chemical Industry Industrial Process Description 

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. 

Sector Notebook Project 14 November 2002 
Organic Chemical Industry Industrial Process Description 

2 + ———> 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 

Sector Notebook Project 15 November 2002 
Organic Chemical Industry Industrial Process Description 

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; Riegel’s 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 Percent of Ethylene Use 

Polyethylene 54 

Ethylene dichloride 16 

Ethylene oxide-glycol 13 

Ethylbenzene-styrene 7 

Linear olefins-alcohol 3 

Vinyl acetate 2 

Ethanol 1 

Other 4 

Source: Kirk-Othmer Encyclopedia of Chemical Technology. 

Sector Notebook Project 16 November 2002 
Organic Chemical Industry Industrial Process Description 

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. 

Sector Notebook Project 17 November 2002 
Organic Chemical Industry Industrial Process Description 

Figure 4: Ethylene Products 

Low Density 

Polyethylene & 

Linear Low 

Density 

Polyethylene 

Ethylene Oxide Ethylene Glycol 

Fibers 

Ethylene Dichloride Vinyl Chloride PVC 

Crude 

Oil/ 

Natural 

Gas 

Food Packaging, Film, 

Trash Bags, Diapers, 

Toys, Housewares 

High Density 

Polyethylene 

Housewares, Crates, 

Drums, Food Containers, 

Bottles 

Siding, Window 

Frames, Swimming 

Pool Liners, Pipes 

Automotive 

Antifreeze 

Pantyhose, 

Carpets, 

Clothing 

Polyester 

Resin Bottles 

Film 

Miscellaneous 

Ethylbenzene Styrene 

Linear 

Alcohols Detergents 

Vinyl Acetate 

Adhesives, Coatings, 

Textile/Paper 

Finishing, Flooring 

Miscellaneous 

Polystyrene 

Resins 

Insulation, 

Cups, 

Models 

Styrene 

Acrylonitrile 

Resins 

Instrument 

Lenses, 

Housewares 

Styrene 

Butadiene 

Rubber 

Tires, 

Footwear, 

Sealants 

Styrene 

Butadiene 

Latex 

Miscellaneous 

Carpet 

Backing, 

Paper 

Coatings 

Ethylene 

Source: American Chemistry Council, 2001. 

Sector Notebook Project 18 November 2002 
Organic Chemical Industry Industrial Process Description 

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 Percent of Propylene Use 

Polypropylene 36 

Acrylonitrile 16 

Propylene oxide 11 

Cumene 9 

Butyraldehydes 7 

Oligomers 6 

Isopropyl alcohol 6 

Other 9 

Source: Szmant. 

Figure 5 shows the major intermediates and finished products associated with 

propylene. 

Sector Notebook Project 19 November 2002 
Organic Chemical Industry Industrial Process Description 

Figure 5: Propylene Products 

Crude Oil Propylene 

Propylene 

Oxide 

Propylene Glycol Polyesters 

Polyurethane 

Polypropylene 

Resins 

Fibers 

Isopropyl Alcohol Acetone Methyl 

Methacrylate 

Oxoalcohols Plasticizers PVC

Plastics

Solvents

Acrylonitrile Polyacrylonitrile

Acrylic

Fiber

Acrylic

Resins

Modacrylic

Fiber

Polyols Foams,

Coatings,

Lacquers

Auto Steering Wheels,

Knobs, Auto Grills, Pipe,

Film, Shirt Package,

Strapping, Rope & Twine 

Indoor/Outdoor

Carpets, Matting 

Solvents, Coatings,

Cosmetics, Health Care

Plastics, Signs,

Plexiglass,

Paints, TailLight Lenses,

Lighting Panels

Rain

Coats,

Inflatable

Toys

Coatings

Carpets, Sweaters,

Draperies,

Dresses, Coats

Lenses, Light

Fixtures, Coatings,

Domestics 

Synthetic Furs, Coatings

ABS Resins

Telephones, Auto

Parts, Bath Tubs

Cumene

Phenol Phenolic Resins, Nylon 

Fibers, Solvents

Super Absorbent

Polymers, Coatings,

Adhesives, Detergents

Acrylic Acid, 

Acrylates

Miscellaneous

Auto Patch

Compounds,

Furniture Parts,

Boats, Fibers

Source: American Chemistry Council, 2001. 

Sector Notebook Project 20 November 2002 
Organic Chemical Industry Industrial Process Description 

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 Percent of Benzene Use 

Ethylbenzene 52 

Cumene 22 

Cyclohexane 14 

Nitrobenzene 5 

Chlorobenzenes 2 

Linear detergent alkylate 2 

Other 3 

Source: Kirk-Othmer Encyclopedia of Chemical Technology. 

Figure 6 summarizes the primary benzene intermediates and products. 

Sector Notebook Project 21 November 2002 
Organic Chemical Industry Industrial Process Description 

Figure 6: Benzene Products 

Crude 

Oil 

Ethylene 

Cracker 

Benzene 

Ethylebenzene Styrene 

Polystyrene 

Resins 

Insulation, Cups, 

Models 

Styrene 

Acrylonitrile 

Resins 

Instrument 

Lenses, 

Housewares 

Styrene 

Butadiene 

Rubber 

Tires, Footwear, 

Sealants 

Styrene 

Butadiene 

Latex 

Carpet Backing, 

Paper Coatings 

Miscellaneous 

Cumene 

Acetone 

Phenol 

Bisphenol 

A 

Phenolic 

Resins 

Miscellaneous 

Polycarbonate 

Resins 

Epoxy 

Resins 

Football 

Helmets, 

Eyeglasses, 

Computers 

Protective 

Coatings, 

Adhesives 

Plywood, 

Coatings, 

Housings 

Cyclohexane 

Adipic 

Acid 

Caprolactam 

Miscellaneous 

Nylon Fibers 

& Resins 

Miscellaneous 

Nylon Fibers 

& Resins 

Aniline 

Isocyanates 

Rubber Chemicals 

Pesticides 

Dyes 

Miscellaneous 

Chlorobenzenes 

Miscellaneous 

Pesticides, Dyes 

Source: American Chemistry Council, 2001. 

Sector Notebook Project 22 November 2002 
Organic Chemical Industry Industrial Process Description 

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 Potential Sources of Emissions 

Air Point source emissions: stack, vent (e.g. laboratory hood, distillation unit, 

reactor, storage tank vent), material loading/unloading operations (including 

rail cars, tank trucks, and marine vessels) 

Fugitive emissions: pumps, valves, flanges, sample collection, mechanical 

seals, relief devices, tanks 

Secondary emissions: waste and wastewater treatment units, cooling tower, 

process sewer, sump, spill/leak areas 

Liquid wastes 

(Organic or 

Aqueous) 

Equipment wash solvent/water, lab samples, surplus chemicals, product 

washes/purifications, seal flushes, scrubber blowdown, cooling water, steam 

jets, vacuum pumps, leaks, spills, spent/used solvents, housekeeping (pad 

washdown), waste oils/lubricants from maintenance 

Solid Wastes Spent catalysts, spent filters, sludges, wastewater treatment biological sludge, 

contaminated soil, old equipment/insulation, packaging material, reaction byproducts, spent carbon/resins, drying aids 

Ground Water 

Contamination 

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 

Source: Chemical Manufacturers Association, 1993. 

Sector Notebook Project 23 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

IV. 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 

Sector Notebook Project 24 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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 
Organic Chemical Industry Chemical Releases and Transfers 

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 

EPA’s 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. 

Sector Notebook Project 26 November 2002 
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Organic Chemical Industry Chemical Releases and Transfers 

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 Council’s Responsible Care® initiative is intended 

Sector Notebook Project 27 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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 program’s 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 EPA’s 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. 

Sector Notebook Project 28 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)*

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Methanol 278 3,912,475 13,933,787 167,959 7,868,577 132,361 26,015,152 93,580 

Toluene 179 2,657,687 1,328,947 4,488 154,733 3,423 4,149,278 23,180 

Ammonia 169 2,380,590 6,631,275 865,496 17,043,040 144,995 27,065,392 160,150 

Xylene (Mixed Isomers) 128 623,681 189,952 13,940 32,055 8,000 867,628 6,778 

Benzene 103 521,616 981,150 1,940 105,954 3,212 1,613,872 15,669 

Chlorine 92 84,788 341,885 37,100 463,773 5,041 

Formaldehyde 90 171,456 590,489 45,016 3,817,671 6,655 4,631,287 51,459 

Ethylene Glycol 90 703,306 263,220 93,569 455,430 5,833 1,521,358 16,904 

N-butyl Alcohol 89 202,970 437,658 3,296 1,890,507 656 2,535,087 28,484 

Nitrate Compounds 88 517 4,846 36,970,944 10,326,216 67,602 47,370,128 538,297 

Hydrochloric Acid (1995 and after "Acid 

Aerosols" 

87 320,566 2,436,134 255 2,756,955 31,689 

Ethylbenzene 75 308,199 248,117 2,625 530,250 2,071 1,091,262 14,550 

Ethylene 75 6,016,036 5,229,560 11,245,596 149,941 

Styrene 74 318,753 414,241 112 260,000 7,461 1,000,567 13,521 

N-hexane 72 1,596,421 1,469,279 1,024 107,705 1,014 3,175,443 44,103 

Phenol 71 252,980 177,624 3,283 1,875,339 53,932 2,363,158 33,284 

Naphthalene 69 106,289 319,392 442 179,721 1,347 607,191 8,800 

Certain Glycol Ethers 69 143,832 68,906 43,385 43,140 16,059 315,322 4,570 

Propylene 63 2,728,645 2,231,243 2,607 5 4,962,500 78,770 

Zinc Compounds 59 4,226 8,663 35,256 454 437,102 485,701 8,232 

Acetaldehyde 51 302,805 501,401 4,687 324,571 219 1,133,683 22,229 

Cyclohexane 50 349,609 232,819 15,166 81,879 12 679,485 13,590 

Maleic Anhydride 48 29,022 94,141 6 280 123,449 2,572 

Methyl Ethyl Ketone 47 295,954 153,075 3,768 139,500 405 592,702 12,611 

Methyl Isobutyl Ketone 43 636,118 240,543 15,182 2,900 689 895,432 20,824 

Copper Compounds 42 325 2,297 14,943 64,026 61,133 142,724 3,398 

Dichloromethane 42 270,914 1,593,846 4,160 3 74 1,868,997 44,500 

1,2,4-trimethylbenzene 40 71,232 22,567 687 1,955 96,441 2,411 

Acrylic Acid 39 96,543 53,143 5,565 516,946 342 672,539 17,245 

Propylene Oxide 39 61,004 99,296 233 2,100 162,633 4,170 

1,3-butadiene 39 416,282 556,472 108 2 972,864 24,945 

Ethylene Oxide 38 104,457 151,142 1,001 226 256,826 6,759 

Nitric Acid 38 17,428 35,802 11,518,220 7,641 11,579,091 304,713 

Biphenyl 38 87,173 6,268 1,214 81 94,736 2,493 

Aniline 37 60,746 110,058 9,093 696,924 297 877,118 23,706 

Chloromethane 35 192,552 481,349 668 34,177 3 708,749 20,250 

Formic Acid 34 97,353 111,538 113,545 2,740,685 2,059 3,065,180 90,152 

Polycyclic Aromatic Compounds[PBT] 32 21,378 14,199 2,020 507 38,104 1,191 

Cumene 30 181,133 347,323 97 550 11,000 540,103 18,003 

Sulfuric Acid (1994 and after "Acid 

Aerosols" Only 

30 33,255 587,041 1,000 621,296 20,710 

Barium Compounds 30 2,124 3,542 28,228 43 368,655 402,592 13,420 

N,n-dimethylformamide 29 34,570 13,035 1,197 48,802 1,683 

Nickel Compounds 29 116 5,429 16,489 27,745 19,187 68,966 2,378 

Sodium Nitrite 28 174 1,019 150,413 2,028,206 85 2,179,897 77,853 

Chlorodifluoromethane 27 1,036,287 853,487 2,891 1,892,665 70,099 

Chloroethane 27 117,292 130,617 680 248,589 9,207 

Chlorobenzene 27 75,227 301,303 79 80,008 1,206 457,823 16,956 

Phthalic Anhydride 27 42,872 86,375 129,247 4,787 

Acetonitrile 27 121,362 99,411 10,480 7,594,103 584 7,825,940 289,850 

Dimethylamine 27 38,044 38,467 2,410 950 3,435 83,306 3,085 

Tert-butyl Alcohol 26 537,999 105,206 1,963 766,176 477 1,411,821 54,301 

Acrylonitrile 26 83,992 181,243 216 3,280,408 1 3,545,860 136,379 

Dicyclopentadiene 25 88,752 15,601 2,433 29 106,815 4,273 

Sector Notebook Project 29 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Diethanolamine 24 24,166 2,147 4,801 51,006 82,120 3,422 

Vinyl Acetate 24 519,283 1,174,490 473 223,177 4,549 1,921,972 80,082 

Chromium Compounds 24 39 1,233 2,821 202 17,645 21,940 914 

Methyl Methacrylate 22 183,621 362,406 2,908 548,935 24,952 

O-xylene 22 123,135 170,981 2,378 56 296,550 13,480 

Manganese Compounds 21 1,059 8,323 91,508 201,094 301,984 14,380 

1,2-dichloroethane 20 74,676 94,852 35 14 169,577 8,479 

Dioxin and Dioxin-Like 

Compounds[PBT] 

20 5 121 88 440 654 33 

Anthracene 20 8,333 7,653 111 1 16,098 805 

Hydrogen Fluoride 19 50,221 176,558 250 23 227,052 11,950 

Phenanthrene 18 15,747 11,125 115 172 27,159 1,509 

N-methyl-2-pyrrolidone 18 19,542 2,616 959 566,036 19 589,172 32,732 

Triethylamine 18 22,434 63,340 10,995 15,180 13,682 125,631 6,979 

Butyl Acrylate 18 26,597 54,651 14,460 271 95,979 5,332 

Chloroform 18 14,398 52,751 281 67,430 3,746 

Pyridine 18 38,335 19,240 835,760 893,335 49,630 

Butyraldehyde 17 70,899 129,169 15 200,083 11,770 

Epichlorohydrin 17 15,125 5,067 383 123 20,698 1,218 

Cresol (Mixed Isomers) 16 9,857 9,397 814 611,641 3,059 634,768 39,673 

Methyl Acrylate 16 127,929 19,488 289 13,670 161,376 10,086 

Hydroquinone 16 568 120 3,160 171,200 175,048 10,941 

Diisocyanates 16 42,507 394 800 43,701 2,731 

Methyl Tert-butyl Ether 16 56,181 76,392 9,529 70 7,352 149,524 9,345 

Hydrogen Cyanide 16 24,208 268,828 212 688,362 55 981,665 61,354 

Bromine 16 16,317 3,916 20,233 1,265 

Nickel 15 306 573 3,466 11,553 35,249 51,147 3,410 

Benzyl Chloride 15 8,446 2,176 83 10,705 714 

Cobalt Compounds 15 454 12,146 31,180 3,525 16,550 63,855 4,257 

Lead Compounds[PBT] 15 2,127 573 487 76 3,263 218 

Acrylamide 15 955 974 17 5,339,361 4 5,341,311 356,087 

Allyl Alcohol 15 340,164 25,601 5,452 283,712 654,929 43,662 

Trichloroethylene 15 25,033 6,375 1 31,409 2,094 

Carbon Disulfide 14 34,375 29,537 1,520 17,326 372 83,130 5,938 

Tetrachloroethylene 14 50,236 22,549 77 1 72,863 5,204 

Sec-butyl Alcohol 14 26,859 13,405 941 41,205 2,943 

Cyanide Compounds 14 118 4,789 6,202 2,269,181 912 2,281,202 162,943 

Ethyl Acrylate 14 12,239 14,301 9 403 2 26,954 1,925 

Acrolein 14 4,765 11,736 113 200,550 217,164 15,512 

Carbon Tetrachloride 13 21,228 133,443 45 154,716 11,901 

Antimony Compounds 13 861 637 279 2,777 85,358 89,912 6,916 

Mercury Compounds[PBT] 13 222 5 17 244 19 

Nitrobenzene 13 16,780 13,414 120 297,084 18 327,416 25,186 

Propionaldehyde 13 18,768 64,296 3,576 3,100 2,259 91,999 7,077 

Allyl Chloride 13 4,875 125,390 130,265 10,020 

Benzo(g,h,i)perylene[PBT] 13 943 4,215 12 5,170 398 

O-toluidine 12 3,243 7,326 25 7,040 17,634 1,469 

Mercury[PBT] 12 136 3 1 140 12 

P-xylene 12 99,796 395,276 40 106 495,218 41,268 

Cyclohexanol 12 74,583 64,772 4,978 2,652,916 2,797,249 233,104 

Isobutyraldehyde 12 110,668 17,328 129 128,125 10,677 

1,4-dioxane 12 20,879 15,697 30,890 2,700 70,166 5,847 

2-methoxyethanol 11 64,019 4,538 3,286 71,843 6,531 

1,2-dichlorobenzene 11 15,699 45,506 585 1,600 778 64,168 5,833 

Hexachlorobenzene[PBT] 11 43 5 37 85 8 

Sector Notebook Project 30 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

4,4'-isopropylidenediphenol 11 8,087 9,577 2,107 1,657 21,428 1,948 

Vinyl Chloride 10 53,870 15,903 69,773 6,977 

Quinoline 10 2,452 4,480 15 31,413 6 38,366 3,837 

Creosote 10 9,910 26,443 5 36,358 3,636 

Diphenylamine 10 9,558 13,990 32 3,200 26,780 2,678 

Hydrazine 10 2,555 127 10 2,692 269 

Benzoyl Chloride 10 6,166 1,169 7,335 733 

Dichlorodifluoromethane 10 158,393 28,984 5 187,382 18,738 

Phosgene 9 348 1,294 1,642 182 

P-cresol 9 6,179 7,604 28 319,553 333,364 37,040 

Acetophenone 9 24,202 16,014 22 580,000 16 620,254 68,917 

1,1-dichloro-1-fluoroethane 9 179,758 261,532 168 441,458 49,051 

Polychlorinated Biphenyls[PBT] 9 18 23 15 56 6 

Cumene Hydroperoxide 9 29,846 782 94 130,000 160,722 17,858 

M-xylene 9 153,987 59,901 28 213,916 23,768 

M-cresol 9 6,433 3,678 37 542,970 553,118 61,458 

Copper 8 9 259 373 596 15,524 16,761 2,095 

4,4'-methylenedianiline 8 11,009 346 296 30,000 8 41,659 5,207 

Vanadium Compounds 8 151 52 78,872 20,105 10,044 109,224 13,653 

Dibenzofuran 8 9,442 14,374 16 23,832 2,979 

Molybdenum Trioxide 8 15 1,374 94 71,800 5,409 78,692 9,836 

2-chloro-1,1,1,2-tetrafluoroethane 7 58,227 13,936 5 72,168 10,310 

Trichlorofluoromethane 7 117,585 3,242 885 121,712 17,387 

Boron Trifluoride 7 1,463 523 1,986 284 

Freon 113 7 175,354 51,250 1,272 227,876 32,554 

O-cresol 7 1,867 1,756 9 501,865 13 505,510 72,216 

Dimethyl Sulfate 7 596 34 22 40 692 99 

1-chloro-1,1-difluoroethane 7 104,544 183,655 34 288,233 41,176 

Chloroacetic Acid 7 1,395 820 300 2,515 359 

1,2,4-trichlorobenzene 6 3,541 51,947 19 55,507 9,251 

Methyl Iodide 6 20,589 38,522 22 8 1,002 60,143 10,024 

Bromomethane 6 594 327,699 328,293 54,716 

2-ethoxyethanol 6 6,132 56,640 129 62,901 10,483 

Dibutyl Phthalate 6 687 455 2 150,000 151,144 25,191 

Diaminotoluene (Mixed Isomers) 6 4,827 3,355 1,809 23,000 32,991 5,498 

3,3'-dichlorobenzidine Dihydrochloride 6 16 5 21 4 

N,n-dimethylaniline 6 2,108 13,538 48 15,694 2,616 

Toluene Diisocyanate (Mixed Isomers) 6 1,674 158 1 1,833 305 

1,2-butylene Oxide 5 2,388 1,436 3,824 765 

Vinylidene Chloride 5 16,247 5,949 1,623 36 23,855 4,771 

Propargyl Alcohol 5 1,944 1,344 1,031,538 1,034,826 206,965 

4,6-dinitro-o-cresol 5 5 118 123 25 

Crotonaldehyde 5 3,235 2,842 33,038 10 39,125 7,825 

Acetamide 5 42 2,195,410 2,195,452 439,090 

Di(2-ethylhexyl) Phthalate 5 3,660 237 3,897 779 

Dimethyl Phthalate 5 33 1,441 808 1,900 3 4,185 837 

1,3-phenylenediamine 5 192 1,716 179 36,910 38,997 7,799 

1,1,2-trichloroethane 4 2,870 124 2,994 748 

Phosphorus (Yellow or White) 4 5 253 258 65 

Diethyl Sulfate 4 2,830 19 2,849 712 

Cadmium Compounds 4 8 24 5 37 9 

Monochloropentafluoroethane 4 54,509 5,240 5 59,754 14,939 

Aluminum (Fume or Dust) 4 60 24,632 176 24,868 6,217 

Dinitrotoluene (Mixed Isomers) 4 3,438 5,104 4 3,300 11,846 2,961 

2-methylpyridine 4 6,251 12,486 22 11,000 29,759 7,440 

Sector Notebook Project 31 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Methacrylonitrile 4 989 54,549 55,538 13,885 

1,3-dichlorobenzene 4 2,819 2,250 6 5,075 1,269 

Silver 4 121 79 200 50 

2,4-dimethylphenol 4 411 360 5 201,020 201,796 50,449 

1,1,1-trichloroethane 4 16,770 7,108 53 23,931 5,983 

Chloroprene 4 40 137 177 44 

Pentachlorobenzene[PBT] 3 2 2 1 

Toluene-2,4-diisocyanate 3 3 1 4 1 

Barium 3 671 1 67,000 67,672 22,557 

1,2-dichloroethylene 3 93 783 876 292 

1,2-phenylenediamine 3 19 137 118 3,497 3,771 1,257 

Acifluorfen, Sodium Salt 3 27 305 5,811 6,143 2,048 

Vanadium (Except When Contained in an 

Alloy) 

3 145 8,121 12,777 21,043 7,014 

1,2-dibromoethane 3 1,801 1,000 5 65 2,871 957 

Zinc (Fume or Dust) 3 5 195 200 67 

Titanium Tetrachloride 3 2,391 26 41 2,458 819 

Dichlorotetrafluoroethane (Cfc-114) 3 77,516 21,078 5 98,599 32,866 

Benzoyl Peroxide 3 2,014 2,014 671 

Asbestos (Friable) 3 

2-methyllactonitrile 3 1,777 1,002 139,007 141,786 47,262 

Tetrabromobisphenol A[PBT] 3 5 468 473 158 

1,1,2,2-tetrachloroethane 3 128 22 150 50 

Methyl Chlorocarbonate 3 2,239 4 2,243 748 

Peracetic Acid 3 1,109 2,146 3,255 1,085 

4-nitrophenol 3 323 65 16 404 135 

1,4-dichlorobenzene 3 23,570 33,109 25 174 56,878 18,959 

1,1,1,2-tetrachloroethane 3 202 327 529 176 

2,4-dinitrotoluene 2 2 1 24 27 14 

3-chloro-2-methyl-1-propene 2 285 167 452 226 

Methylene Bromide 2 15 1,527 1,542 771 

Isopropyl Alcohol (Manufacturing, 

Strong-acid Proc 

2 1,985 1,827 3,812 1,906 

P-chloroaniline 2 406 20 60 486 243 

Benzal Chloride 2 236 9 245 122 

P-phenylenediamine 2 15 34 7 954 1,010 505 

N-methylolacrylamide 2 456 50 506 253 

Decabromodiphenyl Oxide 2 912 3,285 4,197 2,098 

Quinone 2 4 4 2 

2,4-dinitrophenol 2 1 1 23,287 23,289 11,645 

P-nitroaniline 2 1,911 2,020 3,931 1,965 

Benomyl 2 5 1 6 3 

Benzoic Trichloride 2 493 45 538 269 

Safrole 2 251 9 260 130 

Dihydrosafrole 2 251 9 260 130 

O-anisidine 2 705 19 724 362 

1,2-dichloro-1,1-difluoroethane 2 5,520 3,705 45 9,270 4,635 

Bis(2-chloroethyl) Ether 2 133 8 141 71 

Dicamba 2 5 5 10 5 

Dinitrobutyl Phenol 2 39 39 20 

2-nitrophenol 2 5 12 17 8 

2-chloro-1,1,1-trifluoroethane 2 8,350 69,400 77,750 38,875 

2-mercaptobenzothiazole 2 5 246 35,268 35,519 17,760 

Dichlorofluoromethane 2 13,304 106,405 119,709 59,855 

P-cresidine 2 1,029 703 224 1,956 978 

Sector Notebook Project 32 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Antimony 2 46 3,296 38 3,380 1,690 

2,2-dichloro-1,1,1-trifluoroethane 2 15,413 5,518 5 20,936 10,468 

Chromium 2 30 43 346 419 209 

Cobalt 2 1 265 996 300 1,562 781 

Catechol 2 250 200 450 225 

Ethylidene Dichloride 2 99 227 326 163 

Ethyl Chloroformate 2 1,565 15 1,580 790 

Silver Compounds 2 24 86 110 55 

Picloram 1 8 500 508 508 

Nitrapyrin 1 

Molinate 1 944 52 105 1,101 1,101 

Propargite 1 36 215 251 251 

C.i. Disperse Yellow 3 1 31 25 56 56 

Malononitrile 1 255,157 255,157 255,157 

Thiourea 1 736 74 810 810 

Prometryn 1 411 105 516 516 

Sodium Dimethyldithiocarbamate 1 1 1 2 2 

Lead[PBT] 1 31,340 31,340 31,340 

Manganese 1 74,735 74,735 74,735 

Urethane 1 21 29,580 33 29,634 29,634 

Piperonyl Butoxide 1 144 144 144 

Cupferron 1 343 343 343 

Trans-1,4-dichloro-2-butene 1 4 1 5 5 

Arsenic 1 42,189 42,189 42,189 

P-dinitrobenzene 1 12 81 93 93 

M-dinitrobenzene 1 10 345 466 134 955 955 

Ethyleneimine 1 3 3 3 

5-nitro-o-anisidine 1 5 5 5 15 15 

Styrene Oxide 1 8 8 8 

2,4,5-trichlorophenol 1 56 271 51 378 378 

Diazinon 1 1 3 4 4 

1,1,2,2-tetrachloro-1-fluoroethane 1 20 5 25 25 

1,2-dichloro-1,1,2-trifluoroethane 1 73,027 35,486 5 108,518 108,518 

Carbonyl Sulfide 1 466,000 466,000 466,000 

O-dinitrobenzene 1 1 44 60 105 105 

2,4-diaminotoluene 1 211 92 303 303 

Bis(2-chloroethoxy)methane 1 1,320 10 9,302 10,632 10,632 

Allylamine 1 250 750 1,000 1,000 

2,4-d Butyl Ester 1 4 1 5 5 

2,4-d 1 8 1,030 248 33 1,319 1,319 

3,3'-dichlorobenzidine 1 5 5 10 10 

Perchloromethyl Mercaptan 1 5 85 90 90 

Ozone 1 14 2 16 16 

Fenbutatin Oxide 1 664 1,260 1,924 1,924 

Iron Pentacarbonyl 1 1,280 3 1,283 1,283 

2,6-dinitrotoluene 1 27 27 27 

Oryzalin 1 24 24 24 

3,3'-dimethoxybenzidine Dihydrochloride 1 12 4 36 52 52 

2-phenylphenol 1 10 10 10 

Dichlorobenzene (Mixed Isomers) 1 

Chloromethyl Methyl Ether 1 1,350 1,350 1,350 

Methyl Isocyanate 1 13 13 13 

Norflurazon 1 

Octachlorostyrene[PBT] 1 

Pendimethalin[PBT] 1 302 332 634 634 

Sector Notebook Project 33 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 10: 2000 TRI Releases for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Releases Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Hexazinone 1 2 1,874 1,876 1,876 

Permethrin 1 288 7 295 295 

3-iodo-2-propynyl Butylcarbamate 1 

Picric Acid 1 274 21,093 21,367 21,367 

3,3'-dichlorobenzidine Sulfate 1 

Fomesafen 1 577 221 1,176 1,974 1,974 

Propanil 1 250 250 250 750 750 

Arsenic Compounds 1 

Ethyl Dipropylthiocarbamate 1 815 88 92 995 995 

1,4-dichloro-2-butene 1 89 89 89 

Chlorophenols 1 3 39 1 43 43 

Ametryn 1 403 157 560 560 

2,4-dichlorophenol 1 266 149 25 440 440 

2,4,6-trichlorophenol 1 92 12 29 1 134 134 

Tetrachlorvinphos 1 99 99 99 

N-nitrosodiphenylamine 1 

Saccharin (Manufacturing, No Supplier 

Notification 

1 70 10 80 80 

2-nitropropane 1 9,588 7,017 224 16,829 16,829 

Dimethylcarbamyl Chloride 1 3 99 102 102 

1,2-dichloropropane 1 2 3 5 5 

Paraldehyde 1 14 19 33 33 

Hexachlorocyclopentadiene 1 332 364 696 696 

Pentachloroethane 1 9 1 10 10 

Chlorotrifluoromethane 1 1,420 14,580 5 16,005 16,005 

Atrazine 1 161 169 1 331 331 

Propyleneimine 1 17 53 70 70 

467** 32,553,643 50,360,923 39,171,452 95,144,436 2,124,451 219,354,897 469,710 

[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.

Sector Notebook Project 34 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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

# Reporting POTW Disposal Recycling Treatment Energy Total Avg Transfers 

Chemical Transfers Transfers Transfers Transfers Recovery Transfers Per Facility 

278 20,036,448 649,306 7,311,495 20,357,616 39,862,432 88,217,297 317,328 

179 62,687 354,644 2,767,314 7,781,329 16,786,000 27,751,974 155,039 

169 2,184,927 1,451,355 117,039 706,756 111,698 4,571,775 27,052 

128 12,480 100,443 1,244,063 2,647,063 7,696,733 11,700,782 91,412 

103 5,091 20,504 1,212,323 1,236,731 591,636 3,066,285 29,770 

92 3,624 454,054 457,678 4,975 

90 660,534 113,088 530 684,406 285,217 1,743,775 19,375 

90 10,349,832 959,225 287,020 1,629,396 9,265,735 22,491,208 249,902 

89 1,442,267 83,406 1,362 658,121 3,740,885 5,926,041 66,585 

88 20,333,408 4,816,868 2,247 6,368,480 31,521,003 358,193 

Hydrochloric Acid (1995 and after "Acid 87 20 7,930 64,315 3,916 76,181 

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

75 1,368 16,912 593,873 421,897 1,467,573 2,501,623 33,355 

75 243 9 252 

74 36,907 1,529 2,500,339 297,338 1,062,455 3,898,568 52,683 

72 552 693 287,599 3,500,079 1,702,555 5,491,478 76,271 

71 644,708 28,338 949,527 3,374,972 4,997,545 70,388 

69 2,446 177,185 6,303,351 211,928 576,470 7,271,380 105,382 

69 955,735 91,488 1,808 314,744 1,272,662 2,636,437 38,209 

63 117,735 52 117,787 1,870 

59 9,270 2,326,777 222,427 2,558,474 43,364 

51 1,188,158 87 62 208,154 300,309 1,696,770 33,270 

50 108 2,006 738,733 817,156 136,306 1,694,309 33,886 

48 447 2,956 777,222 47,270 827,895 17,248 

47 487,694 29,778 5,437 108,173 2,991,541 3,622,623 77,077 

43 69,780 9,834 798,627 920,839 1,426,985 3,226,065 75,025 

42 27,400 472,058 2,154,659 2,654,117 63,193 

42 274 9,754 452,955 1,529,442 528,907 2,521,332 60,032 

40 5,541 18,786 1,436 63,184 419,117 508,064 12,702 

39 1,128,221 106,333 806,062 4,584,524 6,625,140 169,875 

39 151,147 4,860 2,138 28,521 186,666 4,786 

39 250 153,787 23,001 10,191 1,578 188,807 4,841 

38 63,436 34 78 1 63,549 1,672 

38 33,987 6,154,652 60,424 36,624 6,285,687 165,413 

38 111,285 12,294 870,770 252,195 118,799 1,365,343 35,930 

37 922,560 219,532 23,600 5,666,448 1,797,480 8,629,620 233,233 

35 281 7 117,663 57,286 175,237 5,007 

34 79,714 34,552 10 691,998 1,533,934 2,340,208 68,830 

Polycyclic Aromatic Compounds[PBT] 32 8 367,218 64,287 82,195 95,803 609,511 19,047 

Cumene 30 5,625 88,228 74,000 29,023 211,730 408,606 13,620 

Sulfuric Acid (1994 and after "Acid 30 635 1,869,080 14,414 1,544 1,885,673 62,856 

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 

30 176,202 203,370 561,342 940,914 31,364 

29 472,318 428 24,480 345,967 258,238 1,101,431 37,980 

29 8,106 706,377 976,507 1,690,990 58,310 

28 202,287 1,294 20,872 227,037 2,719 454,209 16,222 

27 84,770 231,455 278,097 594,322 22,012 

27 354 130 165,800 374,786 131,884 672,954 24,924 

27 2,690 217 171 935,980 552,101 1,491,159 55,228 

27 110,259 2,539,677 297,427 682,326 3,629,689 134,433 

27 8 39,378 57 1,504,742 530,637 2,074,822 76,845 

27 262,166 1,801 294 327,605 3,123 594,989 22,037 

26 574,667 71,835 2,023 499,998 6,480,152 7,628,675 293,411 

26 61,194 4,585 78,725 229,595 374,099 14,388 

25 844 270,003 16,056 332,551 619,454 24,778 

24 36,432 153,116 31,076 546 221,170 9,215 

24 30,297 7,432 745,976 6,539,457 7,323,162 305,132 

24 1,273 206,649 549,321 757,243 31,552 

22 297 102,287 75,551 410,427 588,562 26,753 

22 61,148 19,586 31 767,008 408,987 1,256,760 57,125 

21 16,125 943,334 321,814 1,281,273 61,013 

20 273 1,744 6,255,710 175,429 216,088 6,649,244 332,462 

Dioxin and Dioxin-Like Compounds[PBT] 20 24 253 6,798 1 7,076 354 

Sector Notebook Project 35 November 2002 

876 

3 
Organic Chemical Industry Chemical Releases and Transfers 

Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Transfers Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

Anthracene 20 86 48,914 103,836 103,091 255,927 12,796 

Hydrogen Fluoride 19 1,571 189,168 5,099 195,838 10,307 

Phenanthrene 18 3 11,932 496,127 139,744 127,276 775,082 43,060 

N-methyl-2-pyrrolidone 18 52,677 7,010 1,092 16,036 4,503,153 4,579,968 254,443 

Triethylamine 18 5 18,026 140,970 104,396 263,397 14,633 

Butyl Acrylate 18 118,677 7,563 11,016 77,253 214,509 11,917 

Chloroform 18 281 739 16,900 396,230 45,681 459,831 25,546 

Pyridine 18 57,935 34,083 111,499 279,459 57,329 540,305 30,017 

Butyraldehyde 17 36,233 12,203 1,200 27,967 529,462 607,065 35,710 

Epichlorohydrin 17 9,364 983 23,863 14,556 48,766 2,869 

Cresol (Mixed Isomers) 16 4,541 3,644 130,496 26,218 164,899 10,306 

Methyl Acrylate 16 255 11,000 10,623 491,097 512,975 32,061 

Hydroquinone 16 39,814 23 7,842 6,787 54,466 3,404 

Diisocyanates 16 32,129 93,704 152,194 278,027 17,377 

Methyl Tert-butyl Ether 16 1,001 560 14,361 207,617 223,539 13,971 

Hydrogen Cyanide 16 858 682 11,779 13,319 832 

Bromine 16 128,250 686 1,696,776 202,220 2,027,932 126,746 

Nickel 15 500 42,139 335,179 377,818 25,188 

Benzyl Chloride 15 1,204 2,640 2,242 521,926 528,012 35,201 

Cobalt Compounds 15 66 154,276 641,093 795,435 53,029 

Lead Compounds[PBT] 15 15 104,134 752,822 856,971 57,131 

Acrylamide 15 137,481 1,178 7,270 16,111 162,040 10,803 

Allyl Alcohol 15 597 2 477,729 483,995 962,323 64,155 

Trichloroethylene 15 10 44,640 172,103 117,720 334,473 22,298 

Carbon Disulfide 14 1,348 918 180 5,552 31,241 39,239 2,803 

Tetrachloroethylene 14 10 21 845,291 15,850 70,544 931,716 66,551 

Sec-butyl Alcohol 14 68,930 270 1,213 631,395 701,808 50,129 

Cyanide Compounds 14 4,739 5,890 10,868 10,540 32,037 2,288 

Ethyl Acrylate 14 429,881 7,727 141,955 1,241,214 1,820,777 130,055 

Acrolein 14 410 62 169,678 170,150 12,154 

Carbon Tetrachloride 13 117 2,184 266,856 21,600 290,757 22,366 

Antimony Compounds 13 2 63,040 224,152 287,194 22,092 

Mercury Compounds[PBT] 13 59 83 142 11 

Nitrobenzene 13 107 6,354 2,165,679 823,282 2,995,422 230,417 

Propionaldehyde 13 4,713 283 182 380 5,558 428 

Allyl Chloride 13 3,375 82,000 122,052 229,123 436,550 33,581 

Benzo(g,h,i)perylene[PBT] 13 43 44,923 3,392 1,144 2,325 51,827 3,987 

O-toluidine 12 2,056 219 128,758 206,023 337,056 28,088 

Mercury[PBT] 12 161 59 220 18 

P-xylene 12 43 43,309 3,872 47,224 3,935 

Cyclohexanol 12 5,593 4,357 10,976 18,073 38,999 3,250 

Isobutyraldehyde 12 9,087 149,650 1,200 50,178 526,289 736,404 61,367 

1,4-dioxane 12 20,120 2,185 1 169,125 191,431 15,953 

2-methoxyethanol 11 37,330 750 293,197 331,277 30,116 

1,2-dichlorobenzene 11 5 9,025 960 233,199 445,879 689,068 62,643 

Hexachlorobenzene[PBT] 11 3 608 1,383 5,952 7,946 722 

4,4'-isopropylidenediphenol 11 1 1,581 680 6,374 6,871 15,507 1,410 

Vinyl Chloride 10 54 7 58,400 2,515 96 61,072 6,107 

Quinoline 10 250 2,445 17,476 3,649 23,820 2,382 

Creosote 10 20,644 19,315 286 40,245 4,024 

Diphenylamine 10 3,039 23,864 40,158 56,460 23,465 146,986 14,699 

Hydrazine 10 85 46 131 13 

Benzoyl Chloride 10 251 303,839 304,090 30,409 

Dichlorodifluoromethane 10 7,500 7,500 750 

Phosgene 9 4,565 4,565 507 

P-cresol 9 1,086 32,371 818,151 4,464 83,257 939,329 104,370 

Acetophenone 9 32,546 2,843 22,737 10,833,075 10,891,201 1,210,133 

1,1-dichloro-1-fluoroethane 9 7 70,661 981,077 509,863 1,561,608 173,512 

Polychlorinated Biphenyls[PBT] 9 290 320 24,222 24,832 2,759 

Cumene Hydroperoxide 9 353,094 250 4,407 804 358,555 39,839 

M-xylene 9 12,335 311 341,011 700 239,485 593,842 65,982 

M-cresol 9 963 330 1,660,747 7,346 500 1,669,886 185,543 

Copper 8 12,002 139,544 3,579 155,125 19,391 

Sector Notebook Project 36 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Transfers Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

4,4'-methylenedianiline 8 2,017 6,550 28,028 249 36,844 4,605 

Vanadium Compounds 8 186,514 49,040 235,554 29,444 

Dibenzofuran 8 250 10,306 288 52,547 23,827 87,218 10,902 

Molybdenum Trioxide 8 57,930 40,294 17,385 20,744 136,353 17,044 

2-chloro-1,1,1,2-tetrafluoroethane 7 

Trichlorofluoromethane 7 1 13,200 16,990 30,191 4,313 

Boron Trifluoride 7 11,314 11,314 1,616 

Freon 113 7 128,504 117,635 246,139 35,163 

O-cresol 7 1,556 4,048 73,853 79,457 11,351 

Dimethyl Sulfate 7 1 62,518 212,000 274,519 39,217 

1-chloro-1,1-difluoroethane 7 161,940 101,208 263,148 37,593 

Chloroacetic Acid 7 389 389 56 

1,2,4-trichlorobenzene 6 255 3,700 570 187,863 16,700 209,088 34,848 

Methyl Iodide 6 21,282 64 395 21,741 3,623 

Bromomethane 6 

2-ethoxyethanol 6 225,765 591 162 14,400 240,918 40,153 

Dibutyl Phthalate 6 10 23,802 3,863 27,675 4,612 

Diaminotoluene (Mixed Isomers) 6 365 9,026 28,245 455,801 493,437 82,240 

3,3'-dichlorobenzidine Dihydrochloride 6 5 2,300 37,800 17,000 57,105 9,517 

N,n-dimethylaniline 6 19,098 60 104,111 123,269 20,545 

Toluene Diisocyanate (Mixed Isomers) 6 4,296 79,221 7,670 91,187 15,198 

1,2-butylene Oxide 5 477 277,281 277,758 55,552 

Vinylidene Chloride 5 259 7 11,817 44,400 56,483 11,297 

Propargyl Alcohol 5 29,347 26,096 11,533 86 67,062 13,412 

4,6-dinitro-o-cresol 5 114,579 69,966 58,658 243,203 48,641 

Crotonaldehyde 5 11 1,620 1,631 326 

Acetamide 5 2,442 2,442 488 

Di(2-ethylhexyl) Phthalate 5 1,383 73 3,309 1,030 5,795 1,159 

Dimethyl Phthalate 5 250 7,270 21,446 36 29,002 5,800 

1,3-phenylenediamine 5 2,305 1,276,247 1,671 1,280,223 256,045 

1,1,2-trichloroethane 4 7 2,558,590 11,605 2,570,202 642,550 

Phosphorus (Yellow or White) 4 720 720 180 

Diethyl Sulfate 4 2,008 621 662 5,843,600 5,846,891 1,461,723 

Cadmium Compounds 4 24 6,117 6,141 1,535 

Monochloropentafluoroethane 4 2,348 2,348 587 

Aluminum (Fume or Dust) 4 5 13,764 13,769 3,442 

Dinitrotoluene (Mixed Isomers) 4 22,093 841,268 863,361 215,840 

2-methylpyridine 4 2,647 4,200 6,847 1,712 

Methacrylonitrile 4 

1,3-dichlorobenzene 4 940 44,830 45,770 11,443 

Silver 4 665 224,796 225,461 56,365 

2,4-dimethylphenol 4 7,998 7,998 1,999 

1,1,1-trichloroethane 4 115,020 598,000 713,020 178,255 

Chloroprene 4 148,400 630 149,030 37,258 

Pentachlorobenzene[PBT] 3 1 84 85 28 

Toluene-2,4-diisocyanate 3 240 240 80 

Barium 3 32,146 32,146 10,715 

1,2-dichloroethylene 3 7 2,310 1,178 3,495 1,165 

1,2-phenylenediamine 3 10 46,778 46,788 15,596 

Acifluorfen, Sodium Salt 3 225,664 2,079 227,743 75,914 

Vanadium (Except When Contained in an 

Alloy) 

3 202 4,654 353 5,209 1,736 

1,2-dibromoethane 3 5 2,838 8 2,851 950 

Zinc (Fume or Dust) 3 80 80 27 

Titanium Tetrachloride 3 92 16 142 250 83 

Dichlorotetrafluoroethane (Cfc-114) 3 93,520 93,520 31,173 

Benzoyl Peroxide 3 35,917 7,192 43,109 14,370 

Asbestos (Friable) 3 120,435 120,435 40,145 

2-methyllactonitrile 3 

Tetrabromobisphenol A[PBT] 3 553 581 1,134 378 

1,1,2,2-tetrachloroethane 3 7 1 445 453 151 

Methyl Chlorocarbonate 3 

Peracetic Acid 3 

Sector Notebook Project 37 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Transfers Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

4-nitrophenol 3 59,511 59,511 19,837 

1,4-dichlorobenzene 3 209,742 209,742 69,914 

1,1,1,2-tetrachloroethane 3 50,317 837 51,154 17,051 

2,4-dinitrotoluene 2 24 24 12 

3-chloro-2-methyl-1-propene 2 7,213 7,213 3,606 

Methylene Bromide 2 

Isopropyl Alcohol (Manufacturing, Strongacid Proc 

2 402,304 402,304 201,152 

P-chloroaniline 2 10,947 850 11,797 5,898 

Benzal Chloride 2 92 1,100,000 1,100,092 550,046 

P-phenylenediamine 2 17,981 17,981 8,990 

N-methylolacrylamide 2 

Decabromodiphenyl Oxide 2 

Quinone 2 130 164,935 124,080 289,145 144,572 

2,4-dinitrophenol 2 51 183,793 58,458 242,302 121,151 

P-nitroaniline 2 8,042 1,369 9,411 4,705 

Benomyl 2 7,560 42,029 49,589 24,795 

Benzoic Trichloride 2 1 1 1 

Safrole 2 5 5 2 

Dihydrosafrole 2 5 5 2 

O-anisidine 2 1,983 1,983 991 

1,2-dichloro-1,1-difluoroethane 2 94,254 94,254 47,127 

Bis(2-chloroethyl) Ether 2 130,118 130,118 65,059 

Dicamba 2 500 380 880 440 

Dinitrobutyl Phenol 2 8,850 8,850 4,425 

2-nitrophenol 2 2,509 15,525 18,034 9,017 

2-chloro-1,1,1-trifluoroethane 2 3,600 3,600 1,800 

2-mercaptobenzothiazole 2 192,242 6,028 1,958 200,228 100,114 

Dichlorofluoromethane 2 10,570 60 10,630 5,315 

P-cresidine 2 13,700 12,249 25,949 12,975 

Antimony 2 15,811 15,811 7,905 

2,2-dichloro-1,1,1-trifluoroethane 2 1,246 5,217 6,463 3,231 

Chromium 2 3,222 3,000 6,222 3,111 

Cobalt 2 2,822 2,356 5,178 2,589 

Catechol 2 1,260 1,260 630 

Ethylidene Dichloride 2 7 32 347 386 193 

Ethyl Chloroformate 2 

Silver Compounds 2 340 119,358 119,698 59,849 

Picloram 1 

Nitrapyrin 1 250 250 250 

Molinate 1 1,080 76,999 78,079 78,079 

Propargite 1 250 1,101 3,240 8,330 12,921 12,921 

C.i. Disperse Yellow 3 1 450 450 450 

Malononitrile 1 

Thiourea 1 

Prometryn 1 

Sodium Dimethyldithiocarbamate 1 12 12 12 

Lead[PBT] 1 3,076 866 3,942 3,942 

Manganese 1 7,336 2,066 9,402 9,402 

Urethane 1 

Piperonyl Butoxide 1 8,994 8,994 8,994 

Cupferron 1 

Trans-1,4-dichloro-2-butene 1 

Arsenic 1 4,141 1,166 5,307 5,307 

P-dinitrobenzene 1 17 17 17 

M-dinitrobenzene 1 473 473 473 

Ethyleneimine 1 

5-nitro-o-anisidine 1 5 5 5 

Styrene Oxide 1 

2,4,5-trichlorophenol 1 

Diazinon 1 

1,1,2,2-tetrachloro-1-fluoroethane 1 7,306 30,589 37,895 37,895 

1,2-dichloro-1,1,2-trifluoroethane 1 

Sector Notebook Project 38 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 11: 2000 TRI Transfers for Organic Chemical Facilities (SIC 286), 

by Number of Facilities Reporting (Transfers Reported in pounds/year)* 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

Carbonyl Sulfide 1 

O-dinitrobenzene 1 61 61 61 

2,4-diaminotoluene 1 250 250 250 

Bis(2-chloroethoxy)methane 1 450 17 467 467 

Allylamine 1 

2,4-d Butyl Ester 1 

2,4-d 1 

3,3'-dichlorobenzidine 1 24 24,000 19,180 150,000 193,204 193,204 

Perchloromethyl Mercaptan 1 3 3 3 

Ozone 1 

Fenbutatin Oxide 1 

Iron Pentacarbonyl 1 

2,6-dinitrotoluene 1 110 110 110 

Oryzalin 1 11,033 11,033 11,033 

3,3'-dimethoxybenzidine Dihydrochloride 1 

2-phenylphenol 1 

Dichlorobenzene (Mixed Isomers) 1 686 686 686 

Chloromethyl Methyl Ether 1 

Methyl Isocyanate 1 

Norflurazon 1 14,462 448 14,910 14,910 

Octachlorostyrene[PBT] 1 19 19 19 

Pendimethalin[PBT] 1 

Hexazinone 1 157,038 157,038 157,038 

Permethrin 1 4,900 4,900 4,900 

3-iodo-2-propynyl Butylcarbamate 1 39,780 39,780 39,780 

Picric Acid 1 

3,3'-dichlorobenzidine Sulfate 1 12,500 12,500 12,500 

Fomesafen 1 6,240 1,522 7,762 7,762 

Propanil 1 750 750 750 

Arsenic Compounds 1 1 15 16 16 

Ethyl Dipropylthiocarbamate 1 762 53,615 54,377 54,377 

1,4-dichloro-2-butene 1 92,934 92,934 92,934 

Chlorophenols 1 

Ametryn 1 

2,4-dichlorophenol 1 

2,4,6-trichlorophenol 1 

Tetrachlorvinphos 1 3,010 34,600 37,610 37,610 

N-nitrosodiphenylamine 1 41,324 41,324 41,324 

Saccharin (Manufacturing, No Supplier 

Notification 

1 3 100 103 103 

2-nitropropane 1 95 95 95 

Dimethylcarbamyl Chloride 1 

1,2-dichloropropane 1 

Paraldehyde 1 

Hexachlorocyclopentadiene 1 530 31,661 502 32,693 32,693 

Pentachloroethane 1 

Chlorotrifluoromethane 1 

Atrazine 1 

Propyleneimine 1 

467** 65,055,291 26,150,154 50,991,020 79,389,964 152,670,979 374,257,408 801,407 

[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.

Sector Notebook Project 39 November 2002 
1

2

3

4

5

6

7

8

9

10

Organic Chemical Industry Chemical Releases and Transfers 

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 

BASF Corporation - Freeport, TX 24,266,032 

BP Chemicals Incorporated - Port Lavaca, TX 16,870,944 

Du Pont Victoria Plant - Victoria, TX 14,799,253 

Solutia Chocolate Bayou - Alvin, TX 11,282,922 

Sterling Chemicals Incorporated - Texas City, TX 10,648,084 

E I Dupont De Nemours & Company - Beaumont, TX 10,306,093 

Angus Chemical Company - Sterlington, LA 6,885,314 

International Specialty Products Technologies Inc. - Texas City, TX 6,684,616 

Rubicon Incorporated - Geismar, LA 5,846,299 

Honeywell International Incorporated - Hopewell, VA 4,882,960 

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 EPA’s 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 

Sector Notebook Project 40 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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 blood’s 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 

1 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). 

Sector Notebook Project 41 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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 
Organic Chemical Industry Chemical Releases and Transfers 

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. 

Sector Notebook Project 43 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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 Air’s 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). 

Sector Notebook Project 44 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Table 13: Air Pollutant Releases by Industry Sector (tons/year) 

Industry Sector CO NO2 PM10 PM25 SO2 VOC 

Metal Mining 8,039 45,341 61,358 32,534 10,926 2,109 

Oil and Gas Extraction 151,763 366,793 4,607 4,379 226,208 94,549 

Non-Fuel, Non-Metal Mineral Mining 27,001 15,747 48,760 20,956 16,874 3,806 

Textiles 7,448 15,043 5,343 3,386 25,544 18,286 

Lumber and Wood Products 142,955 37,313 57,009 38,337 9,189 100,761 

Wood Furniture and Fixtures 7,046 3,008 6,905 5,260 2,779 62,457 

Pulp and Paper 567,542 318,263 85,403 63,577 488,029 144,373 

Printing 604 2,466 1,723 1,723 1,915 80,982 

Inorganic Chemicals 176,697 94,938 19,549 12,586 201,994 43,563 

Plastic Resins and Man-made Fibers 28,890 56,946 5,493 4,155 71,815 83,363 

Pharmaceuticals 2,662 14,676 2,273 1,455 17,132 13,407 

Organic Chemicals 128,454 166,398 34,637 16,900 102,461 159,319 

Agricultural Chemicals 18,492 65,389 10,257 7,311 65,765 12,700 

Petroleum Refining 438,375 298,602 33,620 26,870 478,998 161,207 

Rubber and Plastic 2,515 9,565 5,209 3,217 20,368 87,258 

Stone, Clay, Glass and Concrete 161,113 372,679 127,283 78,647 312,740 32,687 

Iron and Steel 1,080,576 105,794 60,962 47,501 307,981 44,608 

Metal Castings 104,350 6,298 22,393 15,654 4,770 17,285 

Nonferrous Metals 418,647 30,882 24,019 17,433 244,413 8,663 

Fabricated Metal Products 6,029 11,672 4,691 3,264 18,742 90,575 

Electronics and Computers 22,105 6,428 3,184 2,349 6,882 27,453 

Motor Vehicle Assembly 13,439 15,388 4,016 2,270 24,123 95,861 

Aerospace 2,832 7,413 1,834 1,287 5,363 7,440 

Shipbuilding and Repair 471 2,139 1,574 753 2,537 4,984 

Ground Transportation 711,155 6,681,163 285,932 165,029 12,976,279 191,063 

Water Transportation 83 153 2,162 733 66 6,787 

Air Transportation 5,231 2,079 186 140 90 2,398 

Fossil Fuel Electric Power 436,151 5,789,099 252,539 141,002 12,667,567 54,727 

Dry Cleaning 217 438 190 117 220 3,163 

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. 

Sector Notebook Project 45 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

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. 

Sector Notebook Project 46 November 2002 
Organic Chemical Industry Chemical Releases and Transfers 

Figure 7: 2000 Summary of TRI Releases and Transfers by Industry 

0 

50 

100 

150 

200 

250 

300 

350 

400 

450 

SIC Range 

Total Pounds (millions) 

Total Releases Total Transf ers 

10 

261-263 

22 24 

25 

286 287 

2833, 2834 

2821, 2823, 2824 

281 

271-278 

34 

333, 334 332, 336 

331 

30 32 

2911 

4911, 493 

3731 

372, 376 

371 

36 

Key to Standard Industrial Classification (SIC) Codes 

SIC Range Industry Sector SIC Range Industry Sector SIC Range Industry Sector 

02 Agricultural Crops, Forestry 281 Inorganic Chemicals 333, 334 Nonferrous Metals 

01, 08 Agricultural Livestock 2821, 2823, 

2824 

Plastic Resins and Man-made 

Fibers 34 Fabricated Metals 

10 Metal Mining 2833, 2834 Pharmaceuticals 36 Electronics and Computers 

13 Oil and Gas Extraction 286 Organic Chemicals 371 Motor Vehicle Assembly 

14 Non-Fuel, Non-Metal Mining 287 Agricultural Chemicals 372, 376 Aerospace 

22 Textiles 2911 Petroleum Refining 3731 Shipbuilding and Repair 

24 Lumber and Wood Products 30 Rubber and Plastic 40, 42, 46, 4922-

4925, 4932 Ground Transportation 

25 Furniture and Fixtures 32 Stone, Clay, Glass and Concrete 44 Water Transportation 

261-263 Pulp and Paper 331 Iron and Steel 45 Air Transportation 

271-278 Printing 332, 336 Metal Casting 4911, 493 Fossil Fuel Electric Power Generation 

7216 Dry cleaning 

Sector Notebook Project 47 November 2002 
Organic Chemical Industry Chemical Releases and Transfers Average Releases + Transfers per Facility (pounds) (million lbs.) (pounds) (million lbs.) (pounds) (million lbs.) 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

695,731 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

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 19,884 12,316 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

87,684 

Industry sector currently not subject to T

RI reporting. 

2,830,957 

456,285 

Total Releases 

+Transfers 

404.9 

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 

466.7 

4,701.9 

10,715.4 

Table 14: Toxics Release Inventory Data for Selected Industries 

TRI Transfers 

Ave. Transfers 

per Facility 

4,894 

15,527 

5,497 

19,605 

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 

14,647 

1,213,016 

176,277 

Total 

Transfers 

2.8 

8.1 

7.1 

13.5 

51.5 

51.5 

91.8 

205.1 

199.0 

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 

78.0 

2,374.1 

4,139.7 

TRI Releases 

Ave. Releases 

per Facility 

690,837 

17,018 

28,305 

18,912 

90,180 

50,148 

64,085 

45,534 

19,275 

47,377 

78,927 

25,948 

28,358 

21,860 

63,336 

9,081 

184,340 

7,759 

5,968 

19,495 

8,277 

73,037 

1,617,941 

280,007 

Total 

Releases 

402.1 

8.9 

36.6 

13.0 

211.6 

19.0 

128.2 

129.5 

15.1 

219.4 

78.1 

78.5 

100.2 

42.1 

125.7 

16.8 

185.3 

54.8 

9.0 

56.0 

5.3 

4.0 

388.7 

2,327.8 

6,575.7 

# TRI 

Facilities 

58 

194 

410 

280 

268 

163 

343 

369 

151 

467 

172 

162 

1,154 

484 

325 

447 

181 

2,047 

419 

622 

184 

39 

613 

9,552 

23,484 

SIC 

Range 

2 

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 

NA NA 

Industry Sector 

Agricultural Crops, Forestry Agricultural Livestock Metal Mining Oil and Gas Extraction Non-Fuel, NonMetal Mining Textiles Lumber and Wood Products Furniture and Fixtures Pulp and Paper Printing Inorganic Chemicals Plastic Resins and Manmade Fibers Pharmaceuticals Organic Chemicals Agricultural Chemicals 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 

2000 TRI Total 

Source: US EPA Toxics Release Inventory Database, 2000. 

Sector Notebook Project 48 November 2002 
Organic Chemical Industry Pollution Prevention 

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 
Organic Chemical Industry Pollution Prevention 

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 
Organic Chemical Industry Pollution Prevention 

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. 

Sector Notebook Project 51 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities 

Area Potential Problem Possible Approach 

By-products 

Co-products 

Quantity and Quality 

Uses and Outlets 

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 By-products and co-products are not 

fully utilized, generating material or 

waste that must be managed. 

P Increase product yield to reduce byproduct and co-product generation and raw 

material requirements. 

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 

Preparation and 

Handling 

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 Emissions or effluents are generated 

with catalyst activation or regeneration. 

P Catalyst attrition and carryover into 

product requires de-ashing facilities, 

which are a likely source of wastewater 

and solid waste. 

P Catalysts comprised of noble metals, 

because of their cost, are generally 

recycled by both onsite and offsite 

reclaimers. 

P Obtain catalyst in the active form. 

P Provide insitu activation with 

appropriate processing/activation facilities. 

P Develop a more robust catalyst or 

support. 

Sector Notebook Project 52 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Catalysts (cont.) 

Preparation and 

Handling (cont.) 

Effectiveness 

P Catalyst is spent and needs to be 

replaced. 

P Pyrophoric catalyst needs to be kept 

wet, resulting in liquid contaminated 

with metals. 

P Short catalyst life. 

P Catalyzed reaction has by-product 

formation, incomplete conversion and 

less-than-perfect yield. 

P Catalyzed reaction has by-product 

formation, incomplete conversion and 

less-than perfect yield. 

P In situ regeneration eliminates 

unloading/loading emissions and effluents 

versus offsite regeneration or disposal. 

P Use a nonpryrophoric catalyst. 

Minimize amount of water required to 

handle and store safely. 

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. 

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 Develop a thorough understanding of 

reaction to allow optimization of reactor 

design. Include in the optimization, 

catalyst consumption and by-product yield. 

Intermediate 

Products 

Quantity and Quality 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 Intermediates may contain toxic 

constituents or have characteristics that 

are harmful to the environment. 

P Modify reaction sequence to reduce 

amount or change composition of 

intermediates. 

P Modify reaction sequence to change 

intermediate properties. 

P Use equipment design and process 

control to reduce releases. 

Sector Notebook Project 53 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Process Conditions/ 

Configuration 

Temperature 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 Higher operating temperatures imply 

“heat input” usually via combustion 

which generates emissions. 

P Heat sources such as furnaces and 

boilers are a source of combustion 

emissions. 

P Vapor pressure increases with 

increasing temperature. Loading/ 

unloading, tankage and fugitive 

emissions generally increase with 

increasing vapor pressure. 

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 Explore heat integration opportunities 

(e.g., use waste heat to preheat materials 

and reduce the amount of combustion 

required.) 

P Use thermocompressor to upgrade lowpressure steam to avoid the need for 

additional boilers and furnaces. 

P If possible, cool materials before sending 

to storage. 

P Use hot process streams to reheat feeds. 

Sector Notebook Project 54 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Process Conditions/ 

Configuration 

(cont.) 

Temperature (cont.) 

Pressure 

Corrosive 

Environment 

Batch vs. Continuous 

Operations 

P Water solubility of most chemicals 

increases with increasing temperature. 

P Fugitive emissions from equipment. 

P Seal leakage potential due to pressure 

differential. 

P Gas solubility increases with higher 

pressures. 

P Material contamination occurs from 

corrosion products. Equipment failures 

result in spills, leaks and increased 

maintenance costs. 

P Increased waste generation due to 

addition of corrosion inhibitors or 

neutralization. 

P Vent gas lost during batch fill. 

P Waste generated by cleaning/purging 

of process equipment between 

production batches. 

P Add vent condensers to recover vapors 

in storage tanks or process. 

P Add closed dome loading with vapor 

recovery condensers. 

P Use lower temperature (vacuum 

processing). 

P Equipment operating in vacuum service 

is not a source of fugitives; however, leaks 

into the process require control when 

system is degassed. 

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 Neutralize corrosivity of materials 

contacting equipment. 

P Use corrosion inhibitors. 

P Improve metallurgy or provide coating 

or lining or operate in a less corrosive 

environment. 

PEqualize reactor and storage tank vent 

lines. 

PRecover vapors through condenser, 

adsorber, etc. 

P Use materials with low viscosity. 

Minimize equipment roughness. 

Sector Notebook Project 55 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Process Conditions/ 

Configuration 

(cont.) 

Batch vs. Continuous 

Operations (cont.) 

Process 

Operation/Design 

P Process inefficiencies lower yield and 

increase emissions. 

P Continuous process fugitive emissions 

and waste increase over time due to 

equipment failure through a lack of 

maintenance between turnarounds. 

P Numerous processing steps create 

wastes and opportunities for errors. 

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 High conversion with low yield results 

in wastes. 

P Optimize product manufacturing 

sequence to minimize washing operations 

and cross-contamination of subsequent 

batches. 

P Sequence addition of reactants and 

reagents to optimize yields and lower 

emissions. 

PDesign facility to readily allow 

maintenance so as to avoid unexpected 

equipment failure and resultant release. 

P Keep it simple. Make sure all operations 

are necessary. More operations and 

complexity only tend to increase potential 

emission and waste sources. 

P Evaluate unit operation or technologies 

(e.g., separation) that do not require the 

addition of solvents or other nonreactant 

chemicals. 

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. 

Sector Notebook Project 56 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Process Conditions/ 

Configuration 

(cont.) 

Process 

Operation/Design 

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 

Product Formulation 

P Insufficient R&D into alternative 

reaction pathways may miss pollution 

opportunities such as waste reduction or 

eliminating a hazardous constituent. 

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 R&D during process conception and 

laboratory studies should thoroughly 

investigate alternatives in process 

chemistry that affect pollution prevention. 

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 Specifying a purity greater than needed 

by the process increases costs and can 

result in more waste generation by the 

supplier. 

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 Specify a purity no greater than what the 

process needs. 

Sector Notebook Project 57 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Raw Materials 

(cont.) 

Purity (cont.) 

Vapor Pressure 

Water Solubility 

P Impurities in clean air can increase 

inert purges. 

P Impurities may poison catalyst 

prematurely resulting in increased wastes 

due to yield loss and more frequent 

catalyst replacement. 

P Higher vapor pressures increase 

fugitive emissions in material handling 

and storage. 

P High vapor pressure with low odor 

threshold materials can cause nuisance 

odors. 

P Toxic or nonbiodegradable materials 

that are water soluble may affect 

wastewater treatment operation, 

efficiency, and cost. 

P Higher solubility may increase 

potential for surface and groundwater 

contamination and may require more 

careful spill prevention, containment, and 

cleanup (SPCC) plans. 

P Higher solubility may increase 

potential for storm water contamination 

in open 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. 

PUse pure oxygen. 

PInstall guard beds to protect catalysts. 

P Use material with lower vapor pressure. 

P Use materials with lower vapor pressure 

and higher odor threshold. 

P Use less toxic or more biodegradable 

materials. 

P Use less soluble materials. 

P Use less soluble materials. 

P Prevent direct contact with storm water 

by diking or covering areas. 

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.) 

Sector Notebook Project 58 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Raw Materials 

(cont.) 

Toxicity 

Regulatory 

Form of Supply 

Handling and 

Storage 

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 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 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 Small containers increase shipping 

frequency which increases chances of 

material releases and waste residues from 

shipping containers (including wash 

waters). 

P Nonreturnable containers may increase 

waste. 

P Physical state (solid, liquid, gaseous) 

may raise unique environmental, safety, 

and health issues with unloading 

operations and transfer to process 

equipment. 

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 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. 

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. 

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 Use returnable shipping containers or 

drums. 

P Use equipment and controls appropriate 

to the type of materials to control releases. 

Sector Notebook Project 59 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 16: Process/Product Modifications Create Pollution Prevention Opportunities

(Continued) 

Area Potential Problem Possible Approach 

Raw Materials 

(cont.) 

Handling and 

Storage (cont.) 

P Large inventories can lead to spills, 

inherent safety issues and material 

expiration. 

P Minimize inventory by utilizing just-intime delivery. 

Waste Streams 

Quantity and Quality 

Composition 

Properties 

Disposal 

P Characteristics and sources of waste 

streams are unknown. 

P Wastes are generated as part of the 

process. 

P Hazardous or toxic constituents are 

found in waste streams. Examples are: 

sulfides, heavy metals, halogenated 

hydrocarbons, and polynuclear 

aromatics. 

P Environmental fate and waste 

properties are not known or understood. 

P Ability to treat and manage hazardous 

and toxic waste unknown or limited. 

P Document sources and quantities of 

waste streams prior to pollution prevention 

assessment. 

P Determine what changes in process 

conditions would lower waste generation 

of toxicity. 

P Determine if wastes can be recycled 

back into the process. 

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. 

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. 

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. 

Source: Chemical Manufacturers Association, 1993. 

Sector Notebook Project 60 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Compressors, 

blowers, fans 

P Shaft seal leaks, piston 

rod seal leaks, and vent 

streams 

P Seal-less designs 

(diaphragmatic, hermetic or 

magnetic) 

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 

P Preventive maintenance 

program 

Concrete pads, 

floors, sumps 

P Leaks to groundwater 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 On-line vibration analysis 

P Use “consensus” systems (e.g., 

shutdown trip requires 2 out of 3 

affirmative responses) 

P Continuous versus batch 

P Optimize on-line run time 

P Optimize shutdown interlock 

inspection frequency 

P Identify safety and 

environment critical instruments 

and equipment 

Distillation 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. 

Sector Notebook Project 61 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued) 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Distillation 

(cont.) 

P Impurities remain in 

process streams (cont.) 

P Large amounts of 

contaminated water 

condensate from stream 

stripping 

P Insulate to prevent heat loss 

P Preheat column feed 

P Increase vapor line size to 

lower pressure drop 

P Use reboilers or inert gas 

stripping agents 

P Clean column to reduce 

fouling 

P Use higher temperature steam 

General 

manufacturing 

equipment 

areas 

P Contaminated 

rainwater 

P Contaminated 

sprinkler and fire water 

P Leaks and emissions 

during cleaning 

P Provide roof over process 

facilities 

P Segregate process sewer from 

storm sewer (diking) 

P Hard-pipe process streams to 

process sewer 

P Seal floors 

P Drain to sump 

P Route to waste treatment 

P Design for cleaning 

P Design for minimum rinsing 

P Design for minimum sludge 

P Provide vapor enclosure 

P Drain to process 

P Return samples to process 

P Monitor stormwater discharge 

P Use drip pans for maintenance 

activities 

P Rinse to sump 

P Reuse cleaning solutions 

Heat 

exchangers 

P Increased waste due to 

high localized 

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. 

(waste heat >>low pressure steam 

>>high pressure steam) 

P Select operating temperatures 

at or near ambient temperature 

when-ever possible. These are 

generally most desirable from a 

pollution prevention standpoint 

P Use lower pressure steam to 

lower temperatures 

Sector Notebook Project 62 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued) 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Heat 

exchangers 

(cont.) 

P Increased waste due to 

high localized 

temperatures (cont.) 

P Contaminated 

materials due to tubes 

leaking at tube sheets 

P Furnace emissions 

P Use scraped wall exchangers in 

viscous service 

P Using falling film reboiler, 

piped recirculation reboiler or 

high-flux tubes 

P Use lowest pressure steam 

possible 

P Use welded tubes or double 

tube sheets with inert purge. 

Mount vertically 

P Use superheat of high-pressure 

steam in place of a furnace 

P Monitor exchanger fouling to 

correlate process conditions 

which increase fouling, avoid 

conditions which rapidly foul 

exchangers 

P Use on-line tube cleaning 

techniques to keep tube surfaces 

clean 

P Monitor for leaks 

Piping P Leaks to groundwater; 

fugitive emissions 

P Design equipment layout so as 

to minimize pipe run length 

P Eliminate underground piping 

or design for cathodic protection 

if necessary to install piping 

underground 

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 

P Monitor for corrosion and 

erosion 

P Paint to prevent external 

corrosion 

Sector Notebook Project 63 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued) 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Piping (cont.) 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 Install equalizer lines 

P Flush to product storage tank 

Pumps P Fugitive emissions 

from shaft seal leaks 

P Fugitive emissions 

from shaft seal leaks 

P Residual “heel” of 

liquid during pump 

maintenance 

P Injection of seal flush 

fluid into process stream 

P Mechanical seal in lieu of 

packing 

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 Use pressure transfer to 

eliminate pump 

P Low point drain on pump 

casing 

P Use double mechanical seal 

with inert barrier fluid where 

practical 

P Seal installation practices 

P Monitor for leaks 

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 

Reactors P Poor conversion or 

performance due to 

inadequate mixing 

P Static mixing 

P Add baffles 

P Change impellers 

P Add ingredients with optimum 

sequence 

Sector Notebook Project 64 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued) 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Reactors 

(cont.) 

P Poor conversion 

(cont.) 

P Waste by-product 

formation 

P Add horsepower 

P Add distributor 

P Provide separate reactor for 

converting recycle streams to 

usable products 

P Allow proper head space in 

reactor to enhance vortex effect 

P Optimize reaction conditions 

(temperature, pressure, etc.) 

Relief Valve P Leaks 

P Fugitive emissions 

P Discharge to 

environment from over 

pressure 

P Frequent relief 

P Provide upstream rupture disc 

P Vent to control or recovery 

device 

P Pump discharges to suction of 

pump 

P Thermal relief to tanks 

P Avoid discharge to roof areas to 

prevent contamination of 

rainwater 

P Use pilot operated relief valve 

P Increase margin between design 

and operating pressure 

P Monitor for leaks and for 

control efficiency 

P Monitor for leaks 

P Reduce operating pressure 

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 Closed loop 

P Drain to sump 

P Reduce number and size of 

samples required 

P Sample at the lowest possible 

temperature 

P Cool before sampling 

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 

P Optimize storage conditions to 

reduce losses 

Sector Notebook Project 65 November 2002 
Organic Chemical Industry Pollution Prevention 

Table 17: Modifications to Equipment Can Also Prevent Pollution (Continued) 

Equipment 

Potential 

Environment Problem 

Possible Approach 

Design 

Related 

Operational 

Related 

Tanks (cont.) P Tank breathing and 

working losses (cont.) 

P Leak to groundwater 

P Large waste heel 

P Floating roof 

P Higher design pressure 

P All aboveground (situated so 

bottom can routinely be checked 

for leaks) 

P Secondary containment 

P Improve corrosion resistance 

P Design for 100% de-inventory 

P Monitor for leaks and 

corrosion 

P Recycle to process if practical 

Vacuum 

Systems 

P Waste discharge from 

jets 

P Substitute mechanical vacuum 

pump 

P Evaluate using process fluid for 

powering jet 

P Monitor for air leaks 

P Recycle condensate to process 

Valves P Fugitive emissions 

from leaks 

P Bellow seals 

P Reduce number where practical 

P Special packing sets 

P Stringent adherence to packing 

procedures 

Vents P Release to 

environment 

P Route to control or recovery 

device 

P Monitor performance 

Source: Chemical Manufacturers Association, 1993. 

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 
Organic Chemical Industry Pollution Prevention 

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. 

Sector Notebook Project 67 November 2002 
Organic Chemical Industry Federal Statutes and Regulations 

VI. 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 Section VI.A contains a general overview of major statutes

C Section VI.B contains a list of regulations specific to this industry

C 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 
Organic Chemical Industry Federal Statutes and Regulations 

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 
Organic Chemical Industry Federal Statutes and Regulations 

(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 373-

ship 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 41-

local 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 36-

electronic and other electrical equipment and components; SIC 37-

transportation 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. 

Sector Notebook Project 70 November 2002 
Organic Chemical Industry Federal Statutes and Regulations 

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. EPA’s 

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. 

EPA’s 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 EPA’s 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 EPA’s RCRA, 

Superfund, and EPCRA Call Center, at 800-424-9346. Additional documents 

and resources can be obtained from the hotline’s homepage at 

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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 1⁄2 years of EPA approval of the program. SWAPs include: (1) 

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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. 

EPA’s 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 RCRA’s 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. 

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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. 

C 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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• 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 

hotline’s 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 

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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 hotline’s 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: 

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• 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 hotline’s 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 800-

424-9346 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 Center’s 

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. 

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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.

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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 EPA’s Office of Pesticide 

Programs www.epa.gov/pesticides, EPA’s 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 

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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 

EPA’s 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 

nation’s 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

Subpart Ka, Kb

Subpart VV

Subpart DDD

Subpart III

Subpart NNN

Subpart RRR

Industrial boilers

(Regulates PM, nitrogen oxides (NOx) and sulfur

dioxide (SO2) from new boilers)

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 vaporphase chemicals from liquid-phase chemicals)

Reactor processes

(Regulates VOC from processes that combine or

decompose chemicals)

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Organic Chemical Industry Federal Statutes and Regulations 

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,” EPA’s Chemical Emergency Preparedness and Prevention 

Office provides s o m e 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 

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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

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Organic Chemical Industry Federal Statutes and Regulations 

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 

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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 EPA’s 

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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Organic Chemical Industry Federal Statutes and Regulations 

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. 

EPA’s 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. 

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Organic Chemical Industry Federal Statutes and Regulations 

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 

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Organic Chemical Industry Federal Statutes and Regulations 

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 

2 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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Organic Chemical Industry Federal Statutes and Regulations 

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 Federal Statutes and Regulations 

VI.C. Pending and Proposed Regulatory Requirements 

Information regarding proposed regulations affecting the organic chemical 

industry were obtained from EPA’s 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).

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Organic Chemical Industry Federal Statutes and Regulations 

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 Compliance and Enforcement History 

VII. 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 Compliance and Enforcement History 

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 

3 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). 

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Organic Chemical Industry Compliance and Enforcement History 

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 EPA’s 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 Compliance and Enforcement History 

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 -- indicates the 

Sector Notebook Project 99 November 2002 
Organic Chemical Industry Compliance and Enforcement History 

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. 

Sector Notebook Project 100 November 2002 
Organic Chemical Industry Compliance and Enforcement History 

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. 

C 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). 

C 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). 

Sector Notebook Project 101 November 2002 
Organic Chemical Industry Compliance and Enforcement History Table 18: Five-Year Enforcement and Compliance Summary for the Organic Chemicals Industry, by Region J Enforcement to Inspection Rate 0.09 0.16 0.11 0.08 0.07 0.07 0.12 0.04 0.05 0.16 0.10 I Percent of Federal Lead Actions 28% 50% 22% 20% 18% 41% 31% 35% 83% 83% 42% H Percent of State Lead Actions 72% 50% 78% 80% 82% 59% 69% 65% 17% 17% 58% G Total Enforcement Actions 811 

14 

105 102 163 

76 

304 

23 

6 6 

12 

F 

Facilities with 

1 or More 

Enforcement 

Actions 

574 

12 88 62 

102 

78 

184 

20 10 10 

8 

E 

Average 

Months 

Between 

Inspections 

8 

22 10 

5 6 8 7 

12 12 50 12 

D 

Number of 

Inspections 

8,839 

88 

933 

1,225 2,211 1,165 2,433 

516 116 

37 

115 

C 

Facilities 

Inspected 

832 

25 

111 

83 

156 118 214 

77 16 13 19 

B 

Facilities In 

Search 

1,107 

32 

149 106 216 156 267 103 

24 31 23 

A 

Region 

National 

1 2 3 4 5 6 7 8 9 

10 

Sector Notebook Project 102 November 2002 
Organic Chemical Industry Compliance and Enforcement History 

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. 

C 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. 

C 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 industry’s inspections and 

actions. 

C 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. 

Sector Notebook Project 103 November 2002 
Organic Chemical Industry Compliance and Enforcement History

Table 19: Five-Year Enforcement and Compliance Summary for Selected Industries 

J 

Enforcement 

to 

Inspection 

Rate 

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 

I 

Percent 

Federal 

Lead 

Actions 

40% 

67% 

18% 

6% 

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% 

H 

Percent 

State Lead 

Actions 

60% 

33% 

82% 

94% 

94% 

86% 

85% 

86% 

85% 

87% 

74% 

84% 

78% 

72% 

52% 

70% 

88% 

90% 

72% 

78% 

89% 

75% 

74% 

82% 

62% 

74% 

0% 

82% 

74% 

83% 

91% 

G 

Total 

Closed 

Enforcement 

Actions 

5 

6 

60 

640 

548 

271 

759 

314 

503 

378 

421 

429 

215 

811 

160 

1,153 

685 

933 

493 

343 

446 

1,593 

220 

381 

239 

110 

662 

33 

65 

1,346 

141 

F 

Facilities with 

1 or More 

Enforcement 

Actions 

10 

8 

58 

794 

532 

278 

834 

386 

332 

434 

386 

320 

204 

574 

218 

348 

834 

838 

320 

338 

258 

1,982 

296 

424 

258 

100 

796 

42 

72 

1,062 

210 

E 

Average 

Months 

Between 

Inspections 

53 

37 

18 

25 

21 

19 

17 

18 

5 

29 

12 

9 

14 

8 

18 

5 

27 

17 

6 

22 

10 

30 

37 

21 

17 

16 

23 

39 

39 

11 

59 

D 

Number of 

Inspections 

164 

114 

1,003 

6,386 

10,806 

4,002 

11,336 

5,822 

6,383 

5,100 

5,654 

4,964 

2,605 

8,839 

2,290 

6,238 

8,651 

13,144 

7,285 

3,728 

3,340 

16,959 

2,670 

5,340 

2,756 

859 

13,160 

406 

669 

18,122 

3,469 

C 

Facilities 

Inspected 

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 

1,851 

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 

A 

Industry Sector Agricultural Crop Production Agricultural Livestock Production Metal Mining Oil and Gas Extraction Non-Fuel, NonMetal Mining Textiles Lumber and Wood Wood Furniture and Fixtures Pulp and Paper Printing Inorganic Chemicals Plastic Resins and Fibers Pharmaceuticals Organic Chemicals Ag. Chem. Pesticide & Fertilizer Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Castings Nonferrous Metals Metal Products Electronics and Computers Motor Vehicle Assembly Aerospace Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Dry Cleaning 

* Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available. 

Sector Notebook Project 104 November 2002 
Organic Chemical Industry Compliance and Enforcement History

Sector Notebook Project 105 November 2002 Table 20: Two-Year Enforcement and Compliance Summary for Selected Industries

A

C

D

E

F

G

H

Industry Sector Facilities in Search Facilities Inspected Number of Inspections

Facilities with 1 or More

Violations

Facilities with 1 or more

Enforcement Actions

Total Closed

Enforcement

Actions

Enforcementto Inspection

Rate Number Percent* Number Percent*

Agricultural Crop Production 146 38 65 10 26% 2 5% 1 0.02

Agricultural Livestock Production 71 8 16 6 75% 6 75% 5 0.31

Metal Mining 293 124 290 74 60% 28 23% 23 0.08

Oil and Gas Extraction 2,675 931 2,135 363 39% 546 59% 352 0.16

Non-Fuel, NonMetal Mining 3,771 1,340 3,389 328 24% 234 17% 204 0.06

Textiles 1,284 630 1,256 220 35% 174 28% 145 0.12

Lumber and Wood 3,260 1,467 3,714 580 40% 380 26% 328 0.09

Wood Furniture and Fixtures 1,746 752 1,916 316 42% 182 24% 139 0.07

Pulp and Paper 585 379 1,837 238 63% 158 42% 185 0.1

Printing 2,445 855 1,699 359 42% 234 27% 162 0.1

Inorganic Chemicals 1,092 473 1,793 242 51% 172 36% 141 0.08

Plastic Resins and Fibers 779 411 1,652 215 52% 164 40% 161 0.1

Pharmaceuticals 628 288 828 155 54% 76 26% 62 0.07

Organic Chemicals 1,107 599 2,782 365 61% 264 44% 261 0.09

Agricultural Chemical Pesticide & Fertilizer 674 232 734 108 47% 60 26% 37 0.05

Petroleum Refining 476 240 1,738 191 80% 224 93% 447 0.26

Rubber and Plastic 3,870 1,443 2,992 641 44% 408 28% 313 0.1

Stone, Clay, Glass and Concrete 3,625 1,488 4,254 496 33% 388 26% 351 0.08

Iron and Steel 704 373 2,201 250 67% 144 39% 149 0.07

Metal Castings 1,383 495 1,153 302 61% 180 36% 172 0.15

Nonferrous Metals 561 223 965 150 67% 118 53% 159 0.16

Metal Products 8,426 2,908 5,704 1728 59% 884 30% 588 0.1

Electronics and Computers 1,663 469 862 320 68% 140 30% 86 0.1

Motor Vehicle Assembly 1,880 816 1,897 410 50% 218 27% 167 0.09

Aerospace 791 329 854 179 54% 96 29% 69 0.08

Shipbuilding and Repair 230 100 295 63 63% 48 48% 35 0.12

Ground Transportation 4,991 2,059 4,696 490 24% 458 22% 327 0.07

Water Transportation 263 81 126 31 38% 6 7% 4 0.03Air Transportation 436 112 216 52 46% 32 29% 18 0.08

Fossil Fuel Electric Power Generation 3,295 1,810 6,355 701 39% 520 29% 493 0.08

Dry Cleaning 3,390 785 1,212 238 30% 74 9% 50 0.04

*Percentages in Columns E and F are based on the number of facilities inspected (Column C). 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.

B

Percentages can exceed 100%
Organic Chemical Industry Compliance and Enforcement History

Sector Notebook Project 106 November 2002 Table 21: Summary by Statute for Selected Industries Industry Sector Facilities Inspected Total Inspections Total Closed Enforcement Actions Clean Air Act

Clean Water Act RCRA

FIFRA/TSCA/EPCRA/Other

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

Agricultural Crop Production 73 164 5 61% 40% 0% 0% 36% 20% 3% 40%

Agricultural Livestock Production 30 114 6 48% 50% 0% 17% 49% 17% 3% 17%

Metal Mining 188 1,003 60 61% 52% 26% 43% 13% 3% 1% 2%

Oil and Gas Extraction 1,620 6,386 640 96% 93% 0% 1% 4% 6% 0% 0%

Non-Fuel, NonMetal Mining 2,193 10,806 548 97% 98% 1% 1% 1% 1% 0% 0%

Textiles 911 4,002 271 74% 56% 13% 27% 13% 13% 1% 4%

Lumber and Wood 2,181 11,336 759 77% 73% 1% 2% 22% 24% 1% 2%

Wood Furniture and Fixtures 1,166 5,822 314 75% 74% 0% 1% 24% 24% 1% 1%

Pulp and Paper 495 6,383 503 68% 73% 24% 20% 7% 5% 1% 2%

Printing 1,589 5,100 378 65% 66% 0% 0% 35% 32% 1% 2%

Inorganic Chemicals 700 5,654 421 50% 50% 12% 13% 36% 28% 2% 10%

Plastic Resins and Fibers 545 4,964 429 51% 55% 19% 22% 29% 21% 2% 3%

Pharmaceuticals 463 2,605 215 48% 46% 6% 8% 44% 36% 2% 10%

Organic Chemicals 832 8,839 811 48% 48% 12% 15% 38% 30% 3% 7%

Agricultural Chemical Pesticide &Fertilizer

375 2,290 160 57% 31% 12% 9% 26% 21% 5% 39%

Petroleum Refining 324 6,238 1,153 63% 79% 12% 8% 24% 12% 1% 1%

Rubber and Plastic 2,313 8,651 685 69% 69% 1% 1% 29% 24% 1% 6%

Stone, Clay, Glass and Concrete 2,214 13,144 933 86% 87% 1% 1% 12% 10% 1% 2%

Iron and Steel 517 7,285 493 66% 62% 11% 14% 23% 21% 0% 3%

Metal Castings 822 3,728 343 64% 60% 2% 3% 33% 33% 1% 5%

Nonferrous Metals 358 3,340 446 65% 68% 7% 8% 27% 22% 1% 2%

Metal Products 5,268 16,959 1,593 45% 41% 2% 2% 52% 51% 1% 7%

Electronics and Computers 925 2,670 220 34% 16% 4% 4% 60% 67% 2% 13%

Motor Vehicle Assembly 1,247 5,340 381 61% 59% 1% 1% 37% 36% 0% 4%

Aerospace 549 2,756 239 48% 36% 3% 3% 48% 57% 0% 3%

Shipbuilding and Repair 171 859 110 58% 30% 5% 9% 36% 61% 1% 0%

Ground Transportation 3,316 13,160 662 78% 0% 1% 0% 21% 0% 0% 0%

Water Transportation 166 406 33 40% 33% 2% 0% 57% 67% 1% 0%

Air Transportation 242 669 65 31% 28% 2% 5% 67% 66% 0% 2%

Fossil Fuel Electric Power Generation 2,335 18,122 1,346 75% 85% 19% 9% 5% 4% 1% 2%

Dry Cleaning 1,851 3,469 141 36% 20% 0% 0% 64% 80% 0% 0%

* Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.

Five-Year Inspection and Enforcement 
Organic Chemical Industry Compliance and Enforcement History

Sector Notebook Project 107 November 2002 Table 22: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries Industry Sector Facilities Inspected Total Inspections Total Closed Enforcement Actions Clean Air Act

Clean Water Act RCRA FIFRA/TSCA/

EPCRA/Other

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

Agricultural Crop Production 38 65 1 59% 100% 0% 0% 37% 0% 5% 0%

Agricultural Livestock Production 8 16 5 81% 60% 0% 20% 19% 0% 0% 20%

Metal Mining 124 290 23 46% 61% 35% 39% 19% 0% 0% 0%

Oil and Gas Extraction 931 2,135 352 97% 97% 0% 1% 3% 2% 0% 0%

Non-Fuel, NonMetal Mining 1,340 3,389 204 97% 99% 1% 1% 2% 1% 0% 1%

Textiles 630 1,256 145 71% 61% 16% 22% 13% 13% 0% 3%

Lumber and Wood 1,467 3,714 328 75% 75% 1% 1% 24% 22% 0% 2%

Wood Furniture and Fixtures 752 1,916 139 75% 85% 0% 0% 25% 14% 0% 1%

Pulp and Paper 379 1,837 185 64% 81% 28% 13% 7% 4% 0% 1%

Printing 855 1,699 162 64% 0% 0% 0% 35% 0% 1% 0%

Inorganic Chemicals 473 1,793 141 44% 56% 14% 12% 42% 25% 0% 7%

Plastic Resins and Fibers 411 1,652 161 50% 65% 21% 14% 29% 19% 0% 2%Pharmaceuticals 288 828 62 44% 45% 7% 11% 49% 37% 0% 6%

Organic Chemicals 599 2,782 261 43% 52% 14% 13% 40% 31% 2% 4%

Agricultural Chemical Pesticide &Fertilizer

232 734 37 51% 38% 13% 14% 33% 24% 3% 24%

Petroleum Refining 240 1,738 447 52% 83% 16% 6% 32% 10% 0% 1%

Rubber and Plastic 1,443 2,992 313 69% 79% 2% 0% 29% 20% 0% 2%

Stone, Clay, Glass and Concrete 1,488 4,254 351 86% 85% 2% 2% 12% 10% 0% 2%

Iron and Steel 373 2,201 149 60% 70% 13% 9% 27% 17% 0% 4%

Metal Castings 495 1,153 172 58% 60% 3% 2% 38% 33% 0% 4%

Nonferrous Metals 223 965 159 59% 80% 8% 3% 32% 16% 0% 2%

Metal Products 2,908 5,704 588 43% 46% 3% 1% 54% 43% 0% 9%

Electronics and Computers 469 862 86 30% 12% 5% 5% 65% 63% 1% 21%

Motor Vehicle Assembly 816 1,897 167 57% 63% 2% 1% 41% 32% 0% 5%

Aerospace 329 854 69 46% 44% 4% 0% 50% 51% 0% 6%

Shipbuilding and Repair 100 295 35 59% 37% 6% 11% 35% 51% 0% 0%

Ground Transportation 2,059 4,696 327 75% 0% 1% 0% 24% 0% 0% 0%

Water Transportation 81 126 4 43% 50% 2% 0% 56% 50% 0% 0%

Air Transportation 112 216 18 29% 39% 1% 0% 69% 56% 0% 6%

Fossil Fuel Electric Power Generation 1,810 6,355 493 73% 87% 21% 8% 6% 3% 0% 2%

Dry Cleaning 785 1,212 50 37% 6% 0% 0% 63% 94% 0% 0%

* Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Organic Chemical Industry Compliance and Enforcement History 

Sector Facility Indexing Project -- Additional compliance information for 

the pulp and paper industry is available through EPA’s 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 facility’s manufacturing operations. The second SEP 

involves the company’s purchase of equipment for the local city’s 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 company’s 

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 
Organic Chemical Industry Compliance and Enforcement History 

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 
Organic Chemical Industry Compliance and Enforcement History 

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 resident’s 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 

DuPont’s use of cast iron piping in a tank used to store oleum (sulfur trioxide 

dissolved in sulfuric acid), and the company’s 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 EPA’s 

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 
Organic Chemical Industry Compliance and Enforcement History 

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 

EPA’s 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 
Organic Chemical Industry Compliance and Enforcement History 

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. 

Sector Notebook Project 112 November 2002 
Organic Chemical Industry Compliance and Enforcement History Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry Supple

mental Environmental Project Infor

mation 

SEP Description 

Purchase emergency response equipment for Buffalo Fire Department. 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. 

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. 

SEP Category 

$19,596 Emergency planning 

and response 

$9,500 Emergency planning 

and response 

$13,500 Emergency planning 

and response 

$25,675 Emergency planning 

and response 

$14,000 Emergency planning 

and response 

$22,280 Pollution prevention 

$9,000 Emergency planning 

and preparedness 

$15,000 Emergency planning 

and preparedness 

Violation Information 

SEP Cost to 

Company 

Assessed 

Penalty 

$12,364 

$2,500 $1,500 

$47,810 

$4,000 

$17,000 

$3,000 $3,000 

Type 

CERCLA 

103 EPCRA 304 

CERCLA 

103 

CERCLA 

103 

CERCLA 

103 EPCRA 104 

CERCLA 

103 

EPCRA 313 

CERCLA 

103 

CERCLA 

103 

General Information 

State/ 

Region 

NY TX LA 

NY 

LA CO LA TX 

Company Name 

Buffalo Color 

Corporation 

Dow Chemical 

Company 

Formosa Plastics 

Corporation 

Olin Corporation Shell Chemical 

Company – Geismar Plant 

Boulder Scientific 

Co. 

Condea Vista 

Company 

Dow Chemical 

Company 

Docket # 

02-1997-0342 

06-1998-0151 06-1997-0792 

02-1995-0171 06-1998-0744 

08-95-0131 

06-97-0542 

06-97-0212 

FY 

1998 1998 1998 1998 1998 1997 1997 1997 

Sector Notebook Project 113 November 2002 
Organic Chemical Industry Compliance and Enforcement History Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry (Continued) Supple

mental Environmental Project Infor

mation 

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. 

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. Donate $6,000 to Oklahoma LEPC regional conference, $2,000 in assistance over one year, and $4,000 for employee training on release reporting. 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. 

SEP Category 

$1,094,338 Assessments and 

audits Pollution prevention Pollution reduction 

$15,000 Environmental 

restoration and protection 

$140,185 Pollution prevention 

$945,000 Pollution prevention 

Pollution reduction 

$14,000 Emergency planning 

and preparedness 

$148,148 Pollution prevention 

Pollution reduction 

Violation Information 

SEP Cost to 

Company 

Assessed 

Penalty 

$370,000 

$3,750 

$7,000 

$300,000 

$4,000 

$8,500 

Type 

CAA 112 

RCRA 3002 RCRA 3004 RCRA 3005 

RCRA 3002 

RCRA 3005 

RCRA 3005 

CAA 110 

CERCLA 103 EPCRA 313 RCRA 3002 TSCA 15(1)(c) 

CERCLA 

103 

TSCA 15 

General Information 

State/ 

Region 

WA LA TX TX LA KS 

Company Name 

Kalama Chemical, 

Inc. 

Mackenzie 

Corporation 

Schenectady 

International, Inc. 

Texaco Chemical 

Co. (now known as Huntsman Petrochemical Co.) 

WITCO 

Corporation 

ALLCO Chemical 

Corporation 

Docket # 

10-92-0226 06-97-0689 

06-97-0286 

06-92-0091 

06-97-0720 

07-95-0004 

FY 

1997 1997 1997 1997 1997 1996 

Sector Notebook Project 114 November 2002 
Organic Chemical Industry Compliance and Enforcement History Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry (Continued) Supple

mental Environmental Project Infor

mation 

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. 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. 

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. 

SEP Category 

$19,167 Emergency planning 

and preparedness 

$7,200 Emergency planning 

and preparedness 

$324,318 Pollution prevention 

Pollution reduction 

$390,000 Pollution reduction 

$3,000 Emergency planning 

and preparedness 

$198,000 Pollution reduction 

Violation Information 

SEP Cost to 

Company 

Assessed 

Penalty 

$3,750 

$200 

$8,182 

$0 

$1,250 

$57,800 

Type 

CERCLA 

103 

CERCLA 

103 

TSCA 

15(1)(c) 

RCRA 3004 

RCRA 3005 RCRA 3007 RCRA 3008 

CERCLA 

103 

TSCA 16 

General Information 

State/ 

Region 

TX 

LA 

LA PA TX 

PA 

Company Name 

E.I. duPont de 

Nemours & Co. 

Olin Chemical 

PPG Industries, 

Inc. 

Neville Chemical 

Company 

WITCO 

Corporation 

Anzon, Inc. 

Docket # 

06-96-0118 

06-96-0008 

06-91-0106 

03-92-0432 

06-96-0207 

03-93-0108 

FY 

1996 1996 1996 1996 1996 1995 

Sector Notebook Project 115 November 2002 
Organic Chemical Industry Compliance and Enforcement History Table 23: FY 1995-1999 Supplemental Environmental Projects Overview: Organic Chemical Industry (Continued) Supple

mental Environmental Project Infor

mation 

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. 

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. 

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. 

SEP Category 

$70,000 Pollution reduction 

$951,000 Pollution prevention 

$7,140 Emergency planning 

and preparedness 

$1,000,000 Pollution reduction 

$12,000,000 Pollution prevention 

Pollution reduction 

Violation Information 

SEP Cost to 

Company 

Assessed 

Penalty 

$56,250 

$350,000 

$7,140 

$5,100 

$5,000,000 

Type 

EPCRA 313 

RCRA 3008 

CERCLA 

103(a) EPCRA 304 

EPCRA 313 

CERCLA 

104 RCRA 3002 RCRA 3004 RCRA 3005 RCRA 9003 

General Information 

State/ 

Region 

NJ DE, PA NH 

NJ 

NY 

Company Name 

E.I. DuPont de 

Nemours & Co. 

General Chemical 

Corporation (Allied-Signal) 

Hampshire 

Chemical Corporation 

Monsanto, The 

Chemical Group 

Eastman Kodak 

Docket # 

02-94-0140 

03-89-1618 

01-95-0060 

02-94-0260 

02-91-0208 

FY 

1995 1995 1995 

1995 1995 

Sector Notebook Project 116 November 2002 
Organic Chemical Industry Activities and Initiatives 

VIII. COMPLIANCE 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. 

Sector Notebook Project 117 November 2002 
Organic Chemical Industry Activities and Initiatives 

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 EPA’s Office 

Policy, Economics, and Innovation at 202-260-2698 or 

Tunis.Catherine@epa.gov, or see the project’s 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 202-260-

3374 or difiore.david@epa.gov, or Mary Cushmac at 202-260-4443 or 

Sector Notebook Project 118 November 2002 
Organic Chemical Industry Activities and Initiatives 

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 EPA’s 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 888-

339-PTRK or the website at www.epa.gov/performancetrack/.) 

Sector Notebook Project 119 November 2002 
Organic Chemical Industry Activities and Initiatives 

WasteWi$e Program 

The WasteWi$e Program was started in 1994 by EPA’s 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 EPA’s 

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 (372-

9473) 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, 

Sector Notebook Project 120 November 2002 
Organic Chemical Industry Activities and Initiatives 

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 nation’s 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 organization’s 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 

Sector Notebook Project 121 November 2002 
Organic Chemical Industry 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: DOE’s 

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 EPA’s 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 
Organic Chemical Industry Activities and Initiatives 

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. 

Sector Notebook Project 123 November 2002 
Organic Chemical Industry 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 industry’s 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 
Organic Chemical Industry Activities and Initiatives 

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 
Organic Chemical Industry Activities and Initiatives 

management and sustainable development, to improve the environmental 

performance of business through example and leadership. In 2001, GEMI’s 

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. 

Sector Notebook Project 126 November 2002 
Organic Chemical Industry Activities and Initiatives 

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 Members: 185

Arlington, VA Staff: 246

Phone: 703-741-5000 Budget: $36,000,000

Fax: 703-741-6000

Internet:http://www.americanchemistry.com

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 Council’s 

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 
Organic Chemical Industry Activities and Initiatives 

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 Members: 250

Washington, D.C. 20036 Staff: 50 

Phone: 202-721-4100

Fax: 202-296-8120 

Internet: www.socma.org

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 SOCMA’s 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 SOCMA’s 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 bimonthly newsletter provides information on legislative and regulatory 

developments, as well as on education and training opportunities. SOCMA 

Sector Notebook Project 128 November 2002 
Organic Chemical Industry Activities and Initiatives 

holds an annual meeting in May and also sponsors INFORMEX, the largest 

custom chemical trade show in the U.S. In addition, SOCMA’s Association 

Management Center includes 40 self-funded groups that focus on single 

chemical issues. 

Consumer Specialties Products Association 

900 17th St, NW, Suite 300 Members: 425

Washington, DC 20006 Staff: 31

Phone: 202-872-8110

Fax: 202-872-8114

Internet: www.cspa.org

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 Members: 200 

Washington, DC 20036 Budget: $1,400,000

Tel: 202-775-0232 

Fax: 202-833-0381 

Internet: www.hsia.org 

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. 

Sector Notebook Project 129 November 2002 
Organic Chemical Industry Activities and Initiatives 

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. 

Sector Notebook Project 130 November 2002 
Organic Chemical Industry Activities and Initiatives 

Color Pigments Manufacturers Association, Inc. 

300 N. Washington St., Ste. 102 Members: 50

Alexandria, VA 22314 Staff: 5

Phone: 703-684-4044 

Fax: 703-684-1795

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 Members: 42 

Lancaster, PA 17601 Staff: 5

Phone: 717-291-5616

Fax: 717-295-8455

Internet: www.fireretardants.org

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 Members: 700 

Washington, DC 20005 Staff: 40

Phone: 202-462-6272 

Fax: 202-462-8549 

Internet: www.paint.org 

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 
Organic Chemical Industry Activities and Initiatives 

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 Members:500 

East Windsor, NJ 08520 Staff: 3

Phone: 609-448-1000 Budget: $500,000

Fax: 609-448-1944

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. 

Sector Notebook Project 132 November 2002 
Organic Chemical Industry Activities and Initiatives 

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. 

Sector Notebook Project 133 November 2002 
Organic Chemical Industry Contacts and References 

IX. 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 Organization Contact Information Subject 

Walter DeRieux U.S. EPA, Office of 

Enforcement and 

Compliance Assistance 

202-564-7067 

derieux.walter@epa.gov 

Organic chemical industry sector 

lead 

Marcia Mia U.S. EPA, Office of 

Enforcement and 

Compliance Assistance 

202-564-7042 

mia.marcia@epa.gov 

Industrial processes and 

enforcement issues 

Bruce Varner U.S. EPA, Region V 312-886-6793 

varner.bruce@epa.gov 

Clean Air Act, air toxics 

Carol Rawie U.S. EPA, Office of 

Pollution Prevention and 

Toxics 

202-564-8798 

rawie.carol@epa.gov 

Toxic Substances Control Act 

Velu Senthil U.S. EPA, Office of 

Pollution Prevention and 

Toxics 

202-566-0749 

senthil.velu@epa.gov 

Toxics Release Inventory 

Jim Seidel EPA, National 

Enforcement 

Investigations Center 

303-236-6147 

seidel.jimmy@epa.gov 

Industrial processes and regulatory 

requirements 

Dickson Ozokwelu U.S. Department of 

Energy, Office of 

Industrial Technology 

202-586-8501 

dickson.ozokwelu@ee.doe 

.gov 

Technologies and processes with 

the potential for energy, 

environmental, and cost savings 

Jeff Gunnulfsen Synthetic Organic 

Chemical Manufacturers 

Association 

202-721-4198 

gunnulfsenj@socma.org 

Industrial processes and federal 

environmental requirements 

4 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. 

Sector Notebook Project 134 November 2002 
Organic Chemical Industry Contacts and References 

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 
Organic Chemical Industry Contacts and References 

Hocking, M.B., 1998. Handbook of Chemical Technology and Pollution Control. San Diego: 

Academic Press, Second Edition. 

Kent, J.(ed.), 1992. Reigel’s 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 Contacts and References 

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 26177-

26178. 

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 Don’t 

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 
Organic Chemical Industry Contacts and References 

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 
Organic Chemical Industry Contacts and References 

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, ISBN0-8031-

1269-6. 

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. 

Sector Notebook Project 139 November 2002 
Organic Chemical Industry Contacts and References 

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/S8-

87/039b. 

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 
Organic Chemical Industry Contacts and References 

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. 

Sector Notebook Project 141 November 2002 
Charge your order, 

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Fax your orders (202) 512-2250

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Order online at http://bookstore.gpo.gov

Order Processing Code: 3212 

Qty GPO Stock # Title Price (each) Total 

Published in 1995 

005-000-00512-5 Profile of the Dry Cleaning Industry, 104 pages $6.50 

055-000-00513-3 Profile of the Electronics and Computer Industry, 160 pages $11.00 

055-000-00518-4 Profile of the Fabricated Metal Products Industry, 164 pages $11.00 

055-000-00515-0 Profile of the Inorganic Chemical Industry, 136 pages $9.00 

005-000-00516-8 Profile of the Iron and Steel Industry, 128 pages $8.00 

055-000-00517-6 Profile of the Lumber and Wood Products Industry, 136 pages $9.00 

055-000-00519-2 Profile of the Metal Mining Industry, 148 pages $10.00 

055-000-00520-6 Profile of the Motor Vehicle Assembly Industry, 156 pages $11.00 

055-000-00521-4 Profile of the Nonferrous Metals Industry, 140 pages $9.00 

055-000-00522-2 Profile of the Non-Fuel, Non-Metal Mining Industry, 108 pages $6.00 

055-000-00524-9 Profile of the Petroleum Refining Industry, 124 pages $11.00 

005-000-00525-7 Profile of the Printing Industry, 124 pages $7.50 

055-000-00527-3 Profile of the Rubber and Plastic Industry, 152 pages $11.00 

055-000-00528-1 Profile of the Stone, Clay, Glass and Concrete Industry, 124 pages $7.50 

055-000-00529-0 Profile of the Transportation Equipment Cleaning Industry, 84 pages $5.50 

055-000-00514-1 Profile of the Wood Furniture and Fixtures Industry, 132 pages $8.00 

Published in 1997 

055-000-00570-2 Profile of the Air Transportation Industry, 90 pages $7.50 

055-000-00576-1 Profile of the Fossil Fuel Electric Power Generation Ind., 160 pages $14.00 

055-000-00571-1 Profile of the Ground Transportation Industry, 130 pages $10.00 

055-000-00573-7 Profile of the Metal Casting Industry, 150 pages $13.00 

055-000-00574-5 Profile of the Pharmaceutical Manufacturing Industry, 147 pages $13.00 

055-000-00575-3 Profile of the Plastic Resin & Man-made Fiber Industry, 180 pages $15.00 

055-000-00577-0 Profile of the Shipbuilding and Repair Industry, 120 pages $9.50 

055-000-00578-8 Profile of the Textile Industry, 130 pages $10.00 

055-000-00572-9 Profile of the Water Transportation Industry, 90 pages $7.50 

Published in 1998 

055-000-00579-6 Sector Notebook Data Refresh-1997, 210 pages $17.00 

055-000-00619-9 Profile of the Aerospace Industry, 130 pages $10.00 

Published in 1999 

055-000-00620-2 Profile of Local Government Operations, 310 pages $25.00 

Published in 2000 

055-000-00635-1 Profile of the Agricultural Chemical, Pesticide and Fertilizer Industry, 200 pp. $18.00 

055-000-00636-9 Profile of the Agricultural Crop Production Industry, 178 pages $16.00 

055-000-00633-4 Profile of the Agricultural Livestock Production Industry, 159 pages $15.00 

055-000-00634-2 Profile of the Oil and Gas Extraction Industry, 154 pages $16.00 

Published in 2000 

055-000-00646-6 Profile of the Organic Chemical Industry, 2nd Edition, 144 pages $21.00 

055-000-00645-8 Profile of the Pulp and Paper Industry, 2nd Edition, 127 pages $21.00 

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