Sector Notebook Project Inorganic Chemicals

This report is one in a series of volumes published by the U.S. Environmental Protection Agenc y (EPA) to provide information of general interest regarding environmental issues associated wit h specific industrial sectors. The documents were developed under contract by Abt Associate s (Cambrid ge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA). This publication may b e purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of available Sector Notebooks and document numbers is included on the following page.

All telephone orders should be directed to:

Superintendent of Documents U.S. Government Printing Office Washington, DC 20402 (202) 512-1800 FAX (202) 512-2250 8:00 a.m. to 4:30 p.m., ET, M-F

Using the form provided at the end of this document, all mail orders should be directed to:

U.S. Government Printing Office P.O. Box 371954 Pittsburgh, PA 15250-7954

Complimentary volumes are available to certain groups or subscribers, such as public and academic libraries, Federal, State, local, and foreign governments, and the media. For further information, and for answers to questions pertaining to these documents, please refer to the contact names and numbers provided within this volume.

Electronic versions of all Sector Notebooks are available free of charge at the following web address: www.epa.gov/oeca/sector

. Direct technical questions to the “Feedback” button at the bottom of the web page.

September 1995 SIC 281Sector Notebook Project Inorganic Chemicals

Cover photograph by Steve Delaney, EPA. Photograph courtesy of Vista Chemicals, Baltimore, Maryland. Special thanks to Dave Mahler.

September 1995 SIC 281Sector Notebook Project Inorganic Chemicals

EPA/310-R-95-004



### EPA Office of Compliance Sector Notebook Project

Profile of the Inorganic Chemical Industry

September 1995

Office of Compliance Office of Enforcement and Compliance Assurance U.S. Environmental Protection Agency 401 M St., SW (MC 2221-A) Washington, DC 20460

Sector Notebook Contacts

September 1995 SIC 281Sector Notebook Project Inorganic Chemicals

The Sector Notebooks were developed by the EPA’s Office of Compliance. Questions relating to the Sector Notebook Project can be directed to:

Seth Heminway, Coordinator, Sector Notebook Project US EPA Office of Compliance 401 M St., SW (2223-A) Washington, DC 20460 (202) 564-7017

Questions and comments regarding the individual documents can be directed to the appropriate specialists listed below.

Document Number Industry Contact Phone (202) EPA/310-R-95-001. Dry Cleaning Industry Joyce Chandler 564-7073 EPA/310-R-95-002. Electronics and Computer Industry* Steve Hoover 564-7007 EPA/310-R-95-003. Wood Furniture and Fixtures Industry Bob Marshall 564-7021 EPA/310-R-95-004. Inorganic Chemical Industry* Walter DeRieux 564-7067 EPA/310-R-95-005. Iron and Steel Industry Maria Malave 564-7027 EPA/310-R-95-006. Lumber and Wood Products Industry Seth Heminway 564-7017 EPA/310-R-95-007. Fabricated Metal Products Industry* Scott Throwe 564-7013 EPA/310-R-95-008. Metal Mining Industry Jane Engert 564-5021 EPA/310-R-95-009. Motor Vehicle Assembly Industry Anthony Raia 564-6045 EPA/310-R-95-010. Nonferrous Metals Industry Jane Engert 564-5021 EPA/310-R-95-011. Non-Fuel, Non-Metal Mining Industry Rob Lischinsky 564-2628 EPA/310-R-95-012. Organic Chemical Industry* Walter DeRieux 564-7067 EPA/310-R-95-013. Petroleum Refining Industry Tom Ripp 564-7003 EPA/310-R-95-014. Printing Industry Ginger Gotliffe 564-7072 EPA/310-R-95-015. Pulp and Paper Industry Seth Heminway 564-7017 EPA/310-R-95-016. Rubber and Plastic Industry Maria Malave 564-7027 EPA/310-R-95-017. Stone, Clay, Glass, and Concrete Industry Scott Throwe 564-7013 EPA/310-R-95-018. Transportation Equipment Cleaning Ind. Virginia Lathrop 564-7057 EPA/310-R-97-001. Air Transportation Industry Virginia Lathrop 564-7057 EPA/310-R-97-002. Ground Transportation Industry Virginia Lathrop 564-7057 EPA/310-R-97-003. Water Transportation Industry Virginia Lathrop 564-7057 EPA/310-R-97-004. Metal Casting Industry Jane Engert 564-5021 EPA/310-R-97-005. Pharmaceuticals Industry Emily Chow 564-7071 EPA/310-R-97-006. Plastic Resin and Man-made Fiber Ind. Sally Sasnett 564-7074 EPA/310-R-97-007. Fossil Fuel Electric Power Generation Ind. Rafael Sanchez 564-7028 EPA/310-R-97-008. Shipbuilding and Repair Industry Anthony Raia 564-6045 EPA/310-R-97-009. Textile Industry Belinda Breidenbach 564-7022 EPA/310-R-97-010. Sector Notebook Data Refresh-1997 Seth Heminway 564-7017 EPA/310-R-98-001. Aerospace Industry Anthony Raia 564-6045 EPA/310-R-98-002. Agricultural Chemical, Pesticide, and Shruti Sanghavi 564-4158 Fertilizer Industry EPA/310-R-98-003. Agricultural Crop Production Industry Ginah Mortensen (913)551-7864 EPA/310-R-98-004. Agricultural Livestock Production Ind. Ginah Mortensen (913)551-7864

September 1995 SIC 281Sector Notebook Project Inorganic Chemicals

EPA/310-R-98-005. Oil and Gas Exploration and Production Dan Chadwick 564-7054 Industry EPA/310-R-98-008. Local Government Operations John Dombrowski 564-7036 *Spanish Translations Available

September 1995 SIC 281Sector Notebook Project Inorganic Chemicals

Industry Sector Notebook Contents: Inorganic Chemicals Manufacturing

Exhibits Index

............................................................. iii

List of Acronyms

............................................................ v

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

...................... 1 A. Summary of the Sector Notebook Project

.................................... 1 B. Additional Information

.................................................. 2

II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY

................ 3 A. Introduction, Background, and Scope of the Notebook

.......................... 3 B. Characterization of the Inorganic Chemical Industry

............................ 4 1. Product Characterization

.............................................. 4 2. Industry Size and Geographic Distribution

................................. 5 3. Economic Trends

................................................... 10

III. INDUSTRIAL PROCESS DESCRIPTION

.................................... 13 A. Industrial Processes in the Inorganic Chemical Industry

......................... 13 1. Mercury Cell

...................................................... 16 2. Diaphragm Cell

.................................................... 18 3. Membrane Cell

..................................................... 20 4. Auxiliary Processes

................................................. 22 B. Raw Material Inputs and Pollution Outputs in the Production Line

................ 24 1. Mercury Cell

...................................................... 25 2. Diaphragm Cell

.................................................... 25 3. Membrane Cell

..................................................... 26 4. Auxiliary Processes

................................................. 27 C. Management of Chemicals In Wastestream

.................................. 29

IV. CHEMICAL RELEASE AND TRANSFER PROFILE

........................... 31 A. EPA Toxic Release Inventory for the Inorganic Chemical Industry

................ 34 B. Summary of Selected Chemicals Released

................................... 43 C. Other Data Sources

.................................................... 48 D. Comparison of Toxic Release Inventory Between Selected Industries

.............. 50

September 1995 i SIC 281Sector Notebook Project Inorganic Chemicals

V. POLLUTION PREVENTION OPPORTUNITIES

............................... 53

VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS

...... 73 A. General Description of Major Statutes

...................................... 73 B. Industry Specific Requirements

........................................... 84 C. Pending and Proposed Regulatory Requirements

.............................. 87

VII. COMPLIANCE AND ENFORCEMENT HISTORY

............................ 89 A. Inorganic Chemical Industry Compliance History

............................. 93 B. Comparison of Enforcement Activity Between Selected Industries

................ 95 C. Review of Major Legal Actions

.......................................... 100 1. Review of Major Cases

............................................. 100 2. Supplementary Environmental Projects

.................................. 100

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

............... 103 A. Sector-related Environmental Programs and Activities

........................ 103 B. EPA Voluntary Programs

.............................................. 103 C. Trade Association/Industry Sponsored Activity

.............................. 108 1. Environmental Programs

............................................ 108 2. Summary of Trade Associations

....................................... 111

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 113

ENDNOTES

............................................................. 115

September 1995 ii SIC 281Sector Notebook Project Inorganic Chemicals

Exhibits Index

Exhibit 1: Inorganic Chemicals Industry Dominated by a Large Number of Small Facilities

..... 6 Exhibit 2: Inorganic Chemicals Facilities Distribution

.................................. 6 Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast, Southeast, Northwest, and Great Lakes Region

............................................... 8 Exhibit 4: Top U.S. Companies with Inorganic Chemical Manufacturing Operations

.......... 9 Exhibit 5: Chlorine Electrolysis Cells

............................................. 15 Exhibit 6: Main Characteristics of the Different Electrolysis Processes

................... 16 Exhibit 7: Mercury Electrolysis Cell and Flow Diagram

............................... 17 Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram

....................... 19 Exhibit 9: Typical Membrane Electrolysis Cell

...................................... 21 Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry (SIC 281) as Reported within TRI

...................................... 30 Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting

....................................... 36 Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting

....................................... 39 Exhibit 13: Top 10 TRI Releasing Inorganic Chemicals Facilities

......................... 42 Exhibit 14: Top 10 TRI Releasing Facilities Reporting Inorganic Chemical SIC Codes to TRI

... 43 Exhibit 15: Pollutant Releases (short tons/year)

...................................... 48 Exhibit 16: Summary of 1993 TRI Data: Releases and Transfers by Industry

................ 51 Exhibit 17: Toxics Release Inventory Data for Selected Industries

........................ 52 Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities

......... 57 Exhibit 19: Modifications to Equipment Can Also Prevent Pollution

...................... 66 Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic Chemicals Manufacturing

............................................. 94 Exhibit 21: Five-Year Enforcement and Compliance Summary for Selected Industries

......... 96 Exhibit 22: One-Year Inspection and Enforcement Summary for Selected Industries

.......... 97 Exhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries

.. 98 Exhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected Industries

.. 99 Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview: Inorganic Chemical Manufacture

...................................... 102 Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)

........... 104 Exhibit 27: Contacts for State and Local Pollution Prevention Programs

.................. 109

September 1995 iii SIC 281Sector Notebook Project Inorganic Chemicals

List of Acronyms

AFS - AIRS Facility Subsystem (CAA database) AIRS - Aerometric Information Retrieval System (CAA database) BIFs - Boilers and Industrial Furnaces (RCRA) BOD - Biochemical Oxygen Demand 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 CO - Carbon Monoxide COD - Chemical Oxygen Demand CSI - Common Sense Initiative CWA - Clean Water Act D&B - Dun and Bradstreet Marketing Index DSA - Dimensionallly stable ELP - Environmental Leadership Program EPA - United States Environmental Protection Agency EPCRA - Emergency Planning and Community Right-to-Know Act FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act FINDS - Facility Indexing System HAPs - Hazardous Air Pollutants (CAA) HSDB - Hazardous Substances Data Bank 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 MSDSs - Material Safety Data Sheets NAAQS - National Ambient Air Quality Standards (CAA) NAFTA - North American Free Trade Agreement NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA) NCP - National Oil and Hazardous Substances Pollution Contingency Plan NEIC - National Enforcement Investigation Center NESHAP - National Emission Standards for Hazardous Air Pollutants NO 2 - Nitrogen Dioxide NOV - Notice of Violation NO X - Nitrogen Oxide

September 1995 iv SIC 281Sector Notebook Project Inorganic Chemicals

NPDES - National Pollution Discharge Elimination System (CWA) NPL - National Priorities List NRC - National Response Center NSPS - New Source Performance Standards (CAA) OAR - Office of Air and Radiation OECA - Office of Enforcement and Compliance Assurance 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) POTW - Publicly Owned Treatments Works RCRA - Resource Conservation and Recovery Act RCRIS - RCRA Information System SARA - Superfund Amendments and Reauthorization Act SDWA - Safe Drinking Water Act SEPs - Supplementary Environmental Projects SERCs - State Emergency Response Commissions SIC - Standard Industrial Classification SO 2 - Sulfur Dioxide SO X - Sulfur Oxides TOC - Total Organic Carbon TRI - Toxic Release Inventory TRIS - Toxic Release Inventory System TCRIS - Toxic Chemical Release Inventory System TSCA - Toxic Substances Control Act TSS - Total Suspended Solids UIC - Underground Injection Control (SDWA) UST - Underground Storage Tanks (RCRA) VOCs - Volatile Organic Compounds

September 1995 v SIC 281Sector Notebook Project Inorganic Chemicals

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

I.A. Summary of the Sector Notebook Project

Enviro nmental policies based upon comprehensive analysis of air, water and la nd pollution are an inevitable and logical supplement to traditional single

media approaches to environmental protection. Environmental regulator y agencies ar e beginning to embrace comprehensive, multi-statute solutions to facil ity permitting, enforcement and compliance assurance, education / outreach, research, and r egulatory development issues. The central concepts driv ing the new policy direction are that pollutant releases to eac h

en vironmental medium (air, water and land) affect each other, and tha t enviro nmental strategies must actively identify and address these inter

relati onships by designing policies for the "whole" facility. One way t o 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 comprehensiv e

manner. Recognition of the need to develop the industrial “sector-based ” appro ach within the EPA Office of Compliance led to the creation of thi s document.

The Sector Notebook Project was initiated by the Office o f Compliance within the Office of Enforcement a nd Compliance Assurance (OECA) to provide its staff and manag ers with summary information for eighteen specific industrial
sect ors. As other EPA offices, states, the regulated community
, enviro nmental groups, and the public became interested in this project, th e scope of t he original project was expanded. The ability to desig n comprehensive, common sense environmental protection measures for specific industries is depen dent on knowledge of several inter-related topics. For the
purposes of this project, the key elements chosen for inclusion are: genera l indu stry information (economic and geographic); a description of industria l
processes; pollution outputs; pollution prevention opportunities; Federa l statutory and regulatory framework; compliance history; and a description of partnerships that have been formed between regulatory ag encies, 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 managea ble document, this projec t focuses on providing summary information for each topic. Thi s format provides the reader with a synopsis of each issu e, and references where

more in -depth information is available. Text within each profile wa s

res earched from a variety of sources, and was usually condensed from more detailed sources pertaining to specific topics. Thi s approach allows for a wide
coverage of activities that can be further explored based upon the citation s

September 1995 1 SIC 281Sector Notebook Project Inorganic Chemicals

and references listed at th e end of this profile. As a check on the information included, each notebook went through an external revi ew process. The Office of C ompliance appreciates the efforts of all those that participated in thi s proc ess and enabled us to develop more complete, accurate and up-to-dat e summaries.

I.B. Additional Information

Providing Comments

OECA’s Office of Compliance plans to periodically review and update th e notebo oks and will make these updates available both in hard copy an d electronically. If you have any comments on the existing notebook, or if you would like to provide additional information, please send a hard copy an d computer disk to the EPA Office of Compliance, Sector Notebook Project, 401 M St ., SW (2223-A), Washington, DC 20460. Comments can also b e uploaded to the Enviro$en$e Bul letin Board or the Enviro$en$e World Wide We b for general access to all users of the system. Follow instructions i n Appen dix A for accessing these data systems. Once you have logged in
, procedures for uploading text are available from the on-line Enviro$en$e Help System.

Adapting Notebooks to Particular Needs

Th e scope of the existing notebooks reflect an approximation of the relative national occurrence of facility types that occur within each sector. In many instance s, industries within specific geographic regions or states may hav e uniq ue characteristics that are not fully captured in these profiles. For thi s reason, the Office of Compliance encourages state and local environmenta l
ag encies and other groups to supplement or re-package the informatio n include d in this notebook to include more specific industrial and regulator y information that may be available. Additionally, interested states may wan t to supplement the "Summary of Applicable Federal Statutes and Regulations" section with state and local requi rements. Compliance or technical assistance providers may also want to develop the "Pollution Preventi on" section in more detail. Please contact th e appropriate specialist listed on the opening page of this note book if your office is interested in assisting us in the furthe r development of the information or policies addressed within this volume.

If

you are interested in assisting in the development of new notebooks fo r sectors no t covered in the original eighteen, please contact the Office o f Compliance at 202-564-2395.

September 1995 2 SIC 281Sector Notebook Project Inorganic Chemicals

II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY

This section provides background information on the size, geographi c distri bution, employment, production, sales, and economic condition of th e ino rganic chemicals industry. The type of facilities described within th e document are also described in terms of their Standard Industria l Classifi cation (SIC) codes. Additionally, this section contains a list of th e largest companies in terms of sales.

II.A. Introduction, Background, and Scope of the Notebook

The in organic chemical industry manufactures over 300 different chemical s accounting for about 10 percent of the total value of chem ical shipments in the U.S. 1 This industry categorization corresponds to Standard Industria l Classification (SIC) code 281 Industrial Inorganic Chemicals established by the Bureau o f Census to track the flow of goods and services within th e economy. The 281 category includes alkalies and chlorine (SIC 2812)
, ind ustrial gases (SIC 2813) (e.g., hydrogen, helium, oxygen, nitrogen, etc.), inor ganic pigments (SIC 2816), and industrial inorganic chemicals, no t elsewhere classified (SIC 2819). Approximately two-thirds of the value o f shipmen ts for the inorganic chemical industry, including over 200 differen t chemicals, are classified under industrial inorganic chemicals, not elsewhere classif ied (SIC 2819). The industry does not include those establishment s pri marily manufacturing organic chemicals, agricultural pesticides, drugs
, soaps, or cosmetics. However, the 281 industry group does include a significant number o f integrated firms that are engaged in the manufacture of other types of chemicals at the same site. Conversely, many manufacturin g facilities not categorized under SIC 281, especi ally organic chemicals facilities (SIC 286), fertilizer plants (SIC 287) , pulp and paper mills (SIC 26), and iron and steel mills (SIC 331), produce and use inorganic chemicals in thei r processes at the same facility. 2 For example, a s ignificant number of inorganic chemical manufacturing processes are part of very large chemica l manufacturing or pulp manufacturing facilities, making characterizatio n strictly by SIC code difficult.

Whene ver possible, this notebook describes the entire inorganic chemica l ind ustry. In many cases, however, specific details relating to some of th e topics c overed by the notebook (facility size, economic trends, geographi c distr ibution, pollutant releases, pollution prevention issues, and applicabl e regulations) vary depe nding on the type of inorganic chemical manufacturing
process. The large number of different industrial processes used in th e inorganics industry could not all be covered in this notebook. As a result
, most sections of this notebook describ e the entire inorganic chemical industry

as a whole. These sections are usually augmented with information specific

September 1995 3 SIC 281Sector Notebook Project Inorganic Chemicals

to the largest single industrial process within t he industry: chlorine and caustic soda pr oduction (SIC 2812). Section III, Industrial Process Description
, rath er than attempting to describe every inorganic chemical manufacturin g process, deals solely with the production of chlorine and caustic soda.

II.B. Characterization of the Inorganic Chemical Industry

II.B.1. Product Characterization

Inorganic Chemicals Industry

The inorganic chemical industry manufactures chemicals which are often o f a mineral origin, but not of a basic carbo n molecular. Inorganic chemicals are used at s ome stage in the manufacture of a great variety of other products

. The in dustry's products are used as basic chemicals for industrial processe s (i. e., acids, alkalies, salts, oxidizing agents, industrial gases, and halogens) ; chemical products to be used in manufacturing products (i.e., pigments, dry colors, and alkali metals); and finished products for ultimate consumptio n (i.e., mineral fertilizers, g lass, and construction materials). The largest use of inorgani c chemicals is as processing aids in the manufacture of chemical and nonch emicalproducts. Consequently, inorganic chemicals often do no t appear in the final products. 3

Chlor-alkali Sector

The chl or-alkali industry produces mainly chlorine, caustic soda (sodiu m hyd roxide), soda ash (sodium carbonate), sodium bicarbonate, potassiu m hydroxid e, and potassium carbonate. In 1992, chlorine and caustic sod a production accounted for about 80 percent of the chlor-alkali industry's value of

shipmen ts and, in terms of weight, were the eighth and ninth larges t

c h emicals produced in the U.S., respectively. Chlorine and caustic soda are

co -products produced in about equal amounts primarily through th e electrolysis of salt (brine). 4

The m ajority of domestic chlorine production (70 percent) is used in th e manufacturing of organic chemicals including: vinyl chloride monomer
, ethylene dichloride, glycerine, glycols, chlorinated solvents, and chlorinated meth anes. Vinyl chloride, which is used in the production of polyviny l chloride (PVC) and many other organic chemicals, accounts for about 3 8 percen t of the total domestic chlorine production. The pulp and pape r industry consumes approximately 15 percen t of U.S. chlorine production, and about eight percent is used in the man ufacturing of other inorganic chemicals. Other major uses are disinfection treatment of water, and the production of

September 1995 4 SIC 281Sector Notebook Project Inorganic Chemicals

hypochlori tes. More than two-thirds of all chlorine is consumed in the same manufacturing plant in the production of chemical intermediates. 5

The larges t users of caustic soda are the organic chemicals industry (3 0 percent) and the inorganic chemica ls industry (20 percent). The primary uses of caustic soda are in industrial processes, neutralization, and off-ga s

scru bbing; as a catalyst; and in the production of alumina, propylene oxide
, polycarbonate resin, epoxies, synthetic fibers, soaps, detergents, rayon, an d cello phane. The pulp and paper industry uses about 20 percent of tota l domest ic caustic soda production for pulping wood chips, and othe r processes. Ca ustic soda is also used in the production of soaps and cleaning products, and in the petroleum and natural gas extraction industry as a drilling fluid. 6

II.B.2. Industry Size and Geographic Distribution

Inorganic Chemical Industry

The inorganic ch emical industry is characterized by a relatively large number of

sma ll facilities. The Bureau of the Census identified 665 companie s

a operatin g 1,429 facilities within SIC 281 in 1992. Most of these facilitie s

were classified under SIC 2819 -- industrial inorganic chemicals, no t elsewhere classified -- which are typically small er facilities producing specialty in organic chemicals. The Bureau of Census employment data for 199 2 (Exh ibit 1) indicated that about 63 percent of inorganic chemical facilitie s employed fewer than 20 peo ple. A significant portion of inorganic chemicals are produced and us ed within the same plant in the manufacturing of organic chemicals. The number of these facilit ies and the number of people employed in the inorganic chemical produ ction portion of the industrial processes is not included in this data.

a Variation in facility counts occur across data sources due to many factors including, reporting and definition differences. This notebook does not attempt to reconcile these differences, but rather reports the data as they are maintained by each source.

September 1995 5 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 1: Inorganic Chemicals Industry Dominated by a Large Number of Small Facilities
Inorganic Chemicals Chlor-alkali
Employees per Facility Number of Facilities Percentage of Facilities Number of Facilities Percentage of Facilities

1-9 682 48% 12 24%

10-19 212 15% 6 12%

20-49 253 18% 3 6%

50-249 221 15% 23 44%

250-999 51 3% 6 12%
1,000->2,500 10 1% 1 2%

Total 1,429 100% 51 100%

Source: Bureau of the Census, 1992 Census of Manufacturers.

Inor ganic chemical facilities are typically located near consumers and to a le sser extent raw materials. The largest use of inorganic chemicals is i n in dustrial processes for the manufacture of chemicals and nonchemica l products; therefo re, facilities are concentrated in the heavy industrial regions along the Gulf Coast, both east and west coasts, and the Great Lakes region. Since a large portion of inorganic chemic als produced are used by the organic chemica ls manufacturing industry, the geographical distribution of inorganic facilities is very similar to that of organic chemicals facilities (Exhibit 2).

September 1995 6 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 2: Inorganic Chemicals Facilities Distribution

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(Source: U.S. EPA Toxic Release Inventory Database, 1993)

Chlor-alkali Sector

The alkal i and chlorine industry, however, consists of a relatively smal l number of medium to large facil ities. The Bureau of the Census identified 34 companies operating 51 fac ilities within the SIC 2812 in 1992. According to The Chlorine Institute (an industry trade group), there were 25 companie s operati ng 52 chlorine production plants in 1989. The Bureau of Censu s employment data for 1992 indica ted that about 60 percent of those employed in th e chlor-alkali industry worked at facilities with over 50 employee s (Exhibit 1). 7
, 8

The distribution of the chlor-alkali sector differs from that of the inorgani c chemica ls industry as a whole. Since chlorine and caustic soda are co

products produced in almost equal amounts, the distribution of the causti c

so damanufacturing industry is essentially the same as the chlorin e manufacturing industry. Chlorine is difficult to store and transpor t economically; therefore, chlorine and caustic soda are produced near th e

September 1995 7 SIC 281Sector Notebook Project Inorganic Chemicals

chlo rine consumers which are primarily chemical manufacturers and pulping
ope rations. Consequently, chlor-alkali facilities are concentrated near th e chemical industries along the Gulf Coast, followed by the Great Lakes region

as shown in the table below. Other important areas are in the vicinity of the pulp mills of the Southeast and Northwest (Exhibit 3). In 1989, almost half of the chlorine plants in the U.S. (72 percent of domestic chlorine production)

were loc ated along the Gulf Coast. Two states, Louisiana and Texas
, accounted for two-thirds of the domestic chlorine production. 9

Exhibit 3: Chlorine Capacity Located Primarily Along Gulf Coast, Southeast, Northwest, and Great Lakes Region

State Chlorine Plants Number of per year) (thousand tons Annual Capacity

Capacity Operating Total U.S. Percent of

Louisiana 9 4,068 37%

Texas 5 3,314 30%

New York 4 652 6%

Alabama 5 592 5% Washington 4 503 5% West Virginia 2 392 3% Georgia 3 246 2%

Tennessee 1 230 2%
Other States (14) 19 1,139 10%

U.S. Total 52 11,136 100%

Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed. Vol. 1, 1993

.

September 1995 8 SIC 2811

2

3

4

5

6

7

8

9

10 Sector Notebook Project Inorganic Chemicals

Ward’s Business Directory of U.S. Private Companies , produced by Gal e Research Inc., compiles financial data on U.S. companies including thos e opera ting within the inorganic chemicals manufacturing industry. Ward’ s ranks U.S. companies, whether they are a parent company, subsidiary o r div ision, by sales volume within the 4-digit SIC codes that they have bee n assigned a s their primary activity. Exhibit 4 lists the top ten inorgani c chemica l manufacturing companies in the U.S. Readers should note that: 1) Compani es are assigned a 4-digit SIC that most closely resembles thei r principal industry; and 2) Sales figures include total company sales, including sales derived from su bsidiaries and operations not related to the manufacture of

inor ganic chemicals. Additional sources of company specific financia l info rmation include Standard & Poor’s Stock Report Services , Dunn & Bradstreet’s Million Dollar Directory , Moody’s Manuals, and annual reports.



### Exhibit 4: Top U.S. Companies with Inorganic Chemical Manufacturing Operations

Rank a Company b 1993 Sales (millions of dollars)

Dow Chemical Co. - Midland, MI 18,800

Hanson Industries, Inc. - Iselin, NJ 6,092

WR Grace and Co. - Boca Raton, FL 6,049

Occidental Chemical Corp. - Dallas, TX 4,600

BOC Group, Inc. - Murray Hill, NJ 4,500

FMC Corp. - Chicago, IL 3,899

Eastman Kadak Co. - Kingsport, TN 3,740

Air Products and Chemicals, Inc. - Allentown, PA 2,931

ARCO Chemical Co. - Newtown Square, PA 2,837

Ethyl Corp. - Richmond, VA 2,575

Note: When Ward’s Business Directory listed both a parent and subsidiary in the top ten, a only the parent company is presented above to avoid double counting sales volumes. Not all sales can be attributed to the companies’ inorganic chemical manufacturing operations.

Companies shown listed SICs 2812, 2813, 2816 and 2819 as primary activities. b

Source: Ward’s Business Directory of U.S. Private and Public Companies - 1993.

September 1995 9 SIC 281Sector Notebook Project Inorganic Chemicals

II.B.3. Economic Trends

Inorganic Chemicals Industry

The Bure au of the Census estimated that there were 1,429 facilities in th e inorganic chemical i ndustry in 1992. The industry employed 103,000 people

an d had a total value of shipments of $27.4 billion. The total value o f shipme nts for the inorganic chemicals industry increased about one percen t per year between 1992 and 1994. These values do not include inorgani c chemicals manufactured for captive use wi thin a facility nor the value of other non-industrial inorganic chemical products manufactured by the same facility. It does, however, include intra-comp any transfers which are significant in this industry

. The inorganic chemical industry's growth rate is expected t o continue t o increase with the growth of the economy. The U.S. is a ne t exporter of inorganic chemicals with most exports shipped to the European Commu nity (EC) followed by Canada and Mexico. This positive trad e bal ance increased significantly in 1993 to $1.7 billion and is expected t o continue as the European economy improves. By comparison, the 199 2 Cens us of Manufactures for Industrial Organic Chemicals reports a 199 2 val ue of shipments for organic chemicals of $64.5 billion and a tota l employment of 125,100 people. The 1992 value of shipments for the entire chemical industry (SIC 28) totaled $292.3 billion with an employment o f 850,000 people. 10

Because inorganic chemicals are used in the manufacturing of many products, the industry tends to grow at the same rate as overall industrial production. In the late 1980s, the industry experienced high growth rates and, in the early 1990s, the industry saw little real gr owth in output, as a reflection of the U.S. economy' s recession. The industry has historically had low profit margin s wh ich, in recent years, have decreased further with increasing pollutio n abatement costs. 11

Chlor-alkali Sector

The Bureau of the Census data for 1992 shows that there were 51 facilitie s within the inorganic chemicals industry that manufactured alkalies an d chlorine. These chlor-alkali facilities employed 8,000 people and had a total valu e of shipments of $2.8 billion. This was an increase of 1.7 percent from 1991. The chlor-alkali industry as a whole is expected to grow at its past rate of

1.5 times gross domestic product (GDP) growth through the 1990s

. Because chlorine and caustic soda are electrolysis co -products, the production of one product c an depend on the demand of the other product. The market pull has switch ed several times between caustic soda and chlorine in the past few decades. Presently, chlorine demand is controlling production ;

September 1995 10 SIC 281Sector Notebook Project Inorganic Chemicals

consequently, there is a current excess availability of caustic soda in the U.S. This excess material is typically exported to fill a significant demand outside the U.S

. The consumption of caustic soda is growing faster than th e

cons umption of chlorine, however, and domestic caustic soda demand i s expected to control production in the coming years. 12

After r eaching record high levels in the late 1970s, chlorine productio n decl ined in the early 1980s due in part to the economic recession betwee n 1980 and 1982. Chlorine production increased s lowly through the 1980s and,

as of 19 92, had not reached the record high levels and growth rates of th e 1970s. Th is is due in part to the relative maturity of the chlorine usag e industries and more recent environmental pressures aimed at curtailin g chlorine use. Regulatory restrictions on the production or disposal of some products which require large amounts of chlorine to manufacture (i.e.
, chlorofluorocarbons, P VC, and chlorinated solvents) have adversely affected the mar ket. Chlorine's commercial appeal has been further reduced b y initiatives such as the International Joint Commission of Great Lakes Water Quality (a Canada-U.S. environmental oversight group) and a number o f environmental gr oups which call for a gradual phaseout or an immediate ban of chlorine and chlorinated compounds as industrial feedstocks. 13

The production of caustic soda is very dependent on the short term and long
term chlorine demand and production because chlorine cannot be store d

eco nomically. Increased demand for chlorine must be met immediately b y incr eased chlorine production via electrolysis of brine and, consequently
, caustic so da production. Domestic and export demand for caustic soda was
very stro ng in the 1980s with the pick up of the world economy and a n in crease in pulp and paper production. In the late 1980s, there was a worldwide shortage of caustic soda due to increased demand and lower U.S. chlorine production. Th e demand for caustic soda is expected to continue to
gro w in the coming years; however, there are a number of uncertainties that may limit the growth rate. Some industries have begun switching from caustic soda to soda ash where possible to avoid caustic soda shortages. Soda ash, which is extremely plentiful in the U.S., is obtained almost entirely fro m natur al sources of trona ore. Demand for caustic soda may also decrease as
pu lp mills increase their reclamation of caustic soda from spent pulpin g liquor. 14

September 1995 11 SIC 281Sector Notebook Project Inorganic Chemicals

III. INDUSTRIAL PROCESS DESCRIPTION

This section describes the major industrial processes within the inorgani c chem ical industry, including the materials and equipment used, and th e processes employed. The section is designed for those interested in gaining
a general understanding of the industry, and for those interested in the interre lationship between the industrial process and the topics described i n subsequent sections of this profile -- pollutant outputs, pollution prevention opportuni ties, and Federal regulations. This section does not attempt t o replicate pub lished engineering information that is available for this industry. Refer to Section IX for a list of reference documents that are available.

This section specifica lly contains a description of commonly used production processes, associated raw materials, the byprodu cts produced or released, and the materials eit her recycled or transferred off-site. This discussion, coupled wit h schematic drawings of the identified processes, provide a concis e descr iption of where wastes may be produced in the process. This sectio n also describes the potential fate (via air, water, and soil pathways) of thes e waste products.

III.A. Industrial Processes in the Inorganic Chemical Industry

Chlorine and caustic soda are co-products of elec trolysis of saturated aqueous

so lutions of sodium chloride, NaCl (salt water or brine). In addition
, relativel y small amounts (by weight) of hydrogen gas are produced in th e process. The overall chemical reaction is as follows:

2 NaCl + 2 H 2 O v 2 NaOH + Cl 2 + H 2
Energy, in the form of direct current (d-c) electricity, is supplied to drive the reaction. Th e amount of electrical energy required depends on the design of the electrolytic cell, the voltage used, and the concentration of brine used

. For each ton of chlorine produced, 1.1 tons of sodium hydroxide and 2 8 kilograms of hydrogen are produced.

Three types of electrolysis processes are used for the manufacture of chlorine, caustic soda, and hydrogen from brine:

C Mercury Cell Process

C Diaphragm Cell Process

C Membrane Cell Process

Vir tually all chlorine produced in the U.S. is manufactured by one of thes e three electrolysis processes. Each electrolytic cell consists of an anode an d

September 1995 13 SIC 281Sector Notebook Project Inorganic Chemicals

cath ode in contact with the brine solution. Exhibit 5 shows the basi c elements
, inputs and outputs of each type of electrolytic cell. Th e di stinguishing feature of each cell type is the method employed to separat e

an d prevent the mixing of the chlorine gas and sodium hydroxide

. Consequently , each process produces a different purity of chlorine gas and a differ ent concentration of caustic soda. Exhibit 6 is a summary of the major differences between each cell type. In 1988, diaphragm cells accounted for 76 percent of all domestic chlorine production, foll owed by mercury cells with 17 percent, and membrane cells with five percent. The industry is movin g

aw ay from mercury and diaphragm cells and is moving towards the use o f membrane cells. Membrane cells are a relatively recent development which have fewer adverse effects on the environment and produce a higher quality product at a lower cost than the other methods. 15
, 16

September 1995 14 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 5: Chlorine Electrolysis Cells

September 1995 15 SIC 281Sector Notebook Project Inorganic Chemicals

(Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.)

Exhibit 6: Main Characteristics of the Different Electrolysis Processes
Component Mercury Cell Diaphragm Cell Membrane Cell

Cathode Mercury flowing over steel Steel or steel coated with activated nickel Steel or nickel with a nickel based catalytic coating Diaphragm/ Membrane None Asbestos or polymer modified asbestos Ion-exchange membrane

Anode Titanium with RuO 2 or TiO coating 2 (DSA anode) Titanium with RuO or TiO coating (DSA anode) 2

2 Titanium with RuO or TiO coating (DSA anode) 2

2

Cathode Product Sodium amalgam 10-12% NaOH with 15-17% NaCl and H 2 30-33% NaOH and H 2

Decomposer/ 50% NaOH and H Evaporator Product from decomposer 2 50% NaOH with 1% NaCl and solid salt from evaporator 50% NaOH with very little salt

Electricity Consumption Cl 3,300 kWh per ton

2 2,750 kWh per ton Cl 2 2,100-2,450 kWh per ton NaOH

Source: Kirk-Othmer Encyclopedia of Chemical Technology, 4th Edition, 1994.

III.A.1. Mercury Cell

The mercury cell process consists of slightly inclined steel troughs throug h which a thin layer of mercury (about three mm) flows over the botto m (Exhibit 7). The cell s are operated at 75 to 85 E C and atmospheric pressure. The merc ury layer serves as the cathode for the process and the saturate d brine solution (25.5 percent NaCl by weight) flo ws through the troughs above the mercury. The anodes are usually inco rporated into the cell covers and are suspended horizontally in t he brine solution. The height of the anodes within the brine is adjusted to the optimal height either manually or through a n automatic computer controlled system. 17

Elect rolytic cell anodes were made of graphite until the late 1960s whe n

ano des of titanium coated with ruthenium oxide (RuO 2 ) and titanium oxid e (TiO 2 ) were developed. The RuO 2 and TiO 2 anodes, termed DS A (dimensional ly stable) anodes, are more stable than the graphite anodes (i.e., they do not need to be replaced as frequent ly) and are more energy efficient. 18

September 1995 16 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 7: Mercury Electrolysis Cell and Flow Diagram

(Source: Industrial Inorganic Chemistry, Büchner, et al., 1989.)

The chlorine gas is produced at the anodes where it moves upward through
gas extr action slits in the cell covers. Sodium ions are absorbed by th e mercury l ayer and the resulting sodium and mercury mixture, called th e amalgam, is processed in "decomposer" cells to generate sodium hydroxid e and reusa ble mercury. The amalgam entering the decomposer cell has a sodium concentration of approximately 0.2 to 0.5 percent by weight. Th e decomposer consists of a short-circuited electrical cell where graphite serves as the anode and the amalgam serves as the cathode. The amalgam and water flowin g through the cell come into direct contact with the graphite. Th e hydrolysis of the water on the gra phite in the presence of the amalgam results in a str ong exothermic reaction generating mercury to be reused in th e ele ctrolytic cell, a 50 percent caustic soda solution, and hydrogen gas

. Mercury ce lls are operated to maintain a 21 to 22 percent by weight NaC l concentration in the depl eted brine leaving the cell. The dissolved chlorine is removed from the depleted brine solution, which is then resaturated with solid salt and purified for further use

. Some facilities purge small amounts of brine

so lution and use new brine as make-up in order to prevent the build up o f sulfate impurities in the brine. 19
, 20

September 1995 17 SIC 281Sector Notebook Project Inorganic Chemicals

The merc ury process has the advantage over diaphragm and membrane cells in that it produces a pu re chlorine gas with no oxygen, and a pure 50 percent causti c soda solution without having to further concentrate a more dilut e solution. However, mercury cells operate at a higher voltage than diaphragm and membr ane cells and, therefore, use more energy. The process als o requ ires a very pure brine solution with little or no metal contaminants

. Furthe rmore, elaborate precautions must be taken to avoid releases o f mercury to the environment.

III.A.2. Diaphragm Cell

In t he diaphragm cell process, multiple cells consisting of DSA anode plates and catho des are mounted vertically and parallel to each other (Exhibit 8)

. Each cell consists of one anode and cathode pair. The cathodes are typically fl at hollow steel mesh or perforated steel structures covered with asbesto s fibe rs, which serve as the diaphragm. The asbestos fiber structure of th e diaphragm prevents the mixing of hydroge n and chlorine by allowing liquid to pass through to the cathode, but not fine bubbles of chlorine gas formed at the anod es. The diaphragm also hinders the back-diffusion to the anode o f

- hydroxide (OH ) ions formed at the cathode. The cells are operated at 90 to 95 E C and atmospheric pressure. Brine flows continuously into the anod e chamber and, subsequentl y, through the diaphragm to the cathode. As in the
mercury ce ll process, chlorine gas is formed at the anodes; however, in th e diaphra gm process, caustic soda solution and hydrogen gas are forme d directly at the cathod e. The chlorine gas is drawn off from above the anodes for furt her processing. The hydrogen gas is drawn off separately from th e cathode chambers. 21
, 22

Tw o basic types of diaphragm cells are in use today. The first, monopola r cells, have an electrode arrangement in which the anodes and cathodes ar e arranged i n parallel. As a result of this configuration, all cells have the same voltage of about three to four vol ts; up to 200 cells can be constructed in one ci

rcuit. The second basic type of diaphragm cell is the bipolar cell, in which the anode of one cell is directly conne cted to the cathode of the next cell unit. This type of arrangement minimizes voltage loss between cells; however, since the total voltage across the entire set of cells is the sum of the individual cell voltages
, the number of cells per unit is limited. To compensate for th e reduced an ode and cathode surface area in the bipolar configuration, bipolar units tend to be much larger than monopolar units. Production of chlorin e and ca ustic soda by the diaphragm process is split approximately equall y between monopolar and bipolar systems. 23

September 1995 18 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram

(Source: Industrial Inorganic Chemistry, Büchner, et al., 1989)

Diaphragm cells are ope rated such that about 50 percent of the input NaCl is decomposed resulting in an effluent mixture of brine and caustic soda solution containing eight to 12 percent NaOH and 12 to 18 percent NaCl by weight. This solution is evaporated to 50 percent NaOH by weight at which point all of the salt, except a residual 1.0 to 1.5 percent by weight, precipitates out

. The salt generated is very pure and is typically used to make more brine

. Because the brine and caustic soda solution are mixed in a single effluent, a fresh brine solution (no recycled brine ) is constantly entering the system. The diaphragm cell process does not, therefore, require a brine purge to prevent sulfate build up, or treatment to remove entrained chlorine gas, as in th e mercury cell process. 24

Diaphragms are constructed of asbestos because of its chemical and physical stab ility and because it is a relatively inexpensive and abundant material

. Beginnin g in the early 1970s, asbestos diaphragms began to be replaced b y diaphragms containing 75 percent asbestos and 25 percent fibrou s

September 1995 19 SIC 281Sector Notebook Project Inorganic Chemicals

polyt etrafluoroethylene (PTFE). These diaphragms, trade named Modifie d Di aphragms, are more stable and operate more efficiently than the full y

as bestos diaphragms. Modified Diaphragms are the most commo n diaphragms currently in use. 25

Diaphragm cells have the advantage of operating at a lower voltage tha n mercury cells and, therefore, use less electricity. In addition, the brin e entering a diaphragm cell can be less pure than that required by mercury and membra ne cells. The chlorine gas produced by the diaphragm process
, however, is not pure and must be processed to remove oxygen, water, salt
, and sodium hydroxide. Another disadvantage of the process is that th e caustic soda produced co ntains chlorides and requires evaporation to bring it to a usable concentration. 26

III.A.3. Membrane Cell

In the m embrane cell process, the anode and cathode are separated by a water-impermeable ion-conducting membrane (Exhibit 9). Brine solutio n flows thro ugh the anode compartment where chlorine gas is generated. The sod ium ions migrate through the membrane to the cathode compartmen t which cont ains flowing caustic soda solution. Water is hydrolyzed at th e

- cathode, r eleasing hydrogen gas and hydroxide (OH ) ions. The sodium and hydroxide ions combine to produce caustic soda which is typically brought to

a

concentration of 32 to 35 percent by recirculating the solution before it is discharged from the cell. The membrane prevents the migration of chloride ions from the anode compartment to the cathode compartment; therefore, the caustic soda sol ution produced does not contain salt as in the diaphragm cell
process

. Depleted brine is discharged from the anode compartment an d resaturated with salt. 27

The cathode material used in membrane cells is either stainless steel or nickel. The cathodes are often coated with a catalyst that is more stable than th e substrate and that incr eases surface area and electrical conductivity. Coating
mate rials include Ni-S, Ni-Al, and Ni-NiO mixtures, as well as mixtures o f nickel and platinum group metals. Anodes are typically of the DSA type. 28

Th e most critical components of the membrane cells are the membrane s themselve s. The membranes must remain stable while being exposed t o chlorine on one side and a strong caustic solution on the other. Furthermore, the membranes must have low electric al resistance, and allow the transport of sod ium ions and not chloride ions and reinforcing fabric, and a perfluorocarboxlate polymer all bonded together.

September 1995 20 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 9: Typical Membrane Electrolysis Cell

(Source: Industrial Inorganic Chemistry, Büchner, et al., 1989.)

Membrane cells can be configured either as monopolar or bipolar. As in the

case of t he diaphragm cell process, the bipolar cells have less voltage los s betwee n the cells than the monopolar cells; however, the number of cell s connected together in the same circuit is limited. 29

Membra ne cells have the advantages of producing a very pure caustic sod a solution and of using less electricity than the mercury and diaphrag m pro cesses. In addition, the membrane process does not use highly toxi c mate rials such as mercury and asbestos. Disadvantages of the membran e pro cess are that the chlorine gas produced must be processed to remov e oxygen and water vapor, and the caustic soda produced must be evaporated
to i ncrease the concentration. Furthermore, the brine entering a membran e cell mu st be of a very high purity, which often requires costly additiona l purification steps prior to electrolysis. 30

September 1995 21 SIC 281Sector Notebook Project Inorganic Chemicals

III.A.4. Auxiliary Processes

Brine Purification

Approxi mately 70 percent of the salt used in chlorine gas production i s extracted from natural salt deposits; the remainder is evaporated fro m seawater. Salt from natural deposits is either mined in solid form or is leached from the subsurface. Leaching involves the injection of freshwater int o subterranean salt de posits and pumping out brine solution. Brine production from seawater typically occurs by solar evaporation in a series of ponds t o concentrate the seawa ter, precipitate out impurities, and precipitate out solid sodium chlor ide. Regardless of the method used to obtain the salt, it wil l contain impuritie s that must be removed before being used in the electrolysis
pro cess. Impurities primarily consist of calcium, magnesium, barium, iron
, aluminum , sulfates, and trace metals. Impurities can significantly reduce the effi ciency of the electrolytic cells, by precipitating out and subsequentl y bl ocking a diaphragm or damaging a membrane depending on the proces s used. Certain trace metals, such as vanadium, reduce the efficiency o f

me rcury cells and cause the production of potentially dangerous amounts of hydrogen gas. Removal of impurities a ccounts for a significant portion of the

ove rall costs of chlor-alkali production, especially in the membrane process. 31

In addition to the dissolved natural impuritie s, chlorine must be removed from th e recycled brine solutions used in mercury and membrane processes

. Dissolved chlorine gas entering the anode chamber in the brine solution will
react with hydroxide ions formed at the cathode to form chlorate whic h reduces product yields. In addition, chlorine gas in the brine solution wil l cause corrosion of pipes, pumps, and containers during further processing of the br ine. In a typical chlorine plant, HCl is added to the brine solutio n leaving the cells to liberate the chlorine gas. A vacuum is applied to th e solution to collect the chlorine gas for further treatment. To further reduce the chlo rine levels, sodium sulfite or another reducing agent is added t o

remove the final traces of chlorine. Dechlorinated brine is then resaturate d with solid salt before further treating to remove impurities. 32

Depending on the amount of impuritie s in the salt and the electrolysis process utilized, different purification steps will be required

. Brine solution is typically heated before treatment to improve reaction times and precipitation o f impur ities. Calcium carbonate impurities are precipitated out throug h
tre atment with sodium carbonate; magnesium, iron, and aluminum ar e precip itated out through treatment with sodium hydroxide; and sulfates ar e precipitated out through the addition of calcium chloride or barium carbonate. Most tra ce metals are also precipitated out through these processes

. Floccula nts are sometimes added to the clarifying equipment to improv e

September 1995 22 SIC 281Sector Notebook Project Inorganic Chemicals

settl ing. The sludges generated in this process are washed to recove r entrained sodium chloride. Following the clarification steps, the brine solution is typically passed through sand filters fol lowed by polishing filters. The brine passing through these steps will co ntain less than four parts per million (ppm) calcium and 0.5 ppm magnesium which is sufficient purification for th e diaphragm and mercury cell proces ses. For brine to be used in the membrane process, however, requires a combined calcium and magnesi um content of less than 20 parts per billion (p pb). Brine for the membrane process is, therefore, passed through ion exchange columns to further remove impurities. 33

Chlorine Processing

The chlorine gas produced by electrolytic processes is saturated with wate r vapor. Chlorine gas fro m the diaphragm process also contains liquid droplets of sodium hydroxide and salt solution. The first steps in processing th e chlorine to a usable product consists of cooling the chlorine to less than ten degre es centigrade and then passing it through demisters or electrostati c precipitators to remove water and solid s. Next the chlorine is passed through packed towers with concentrated sulfuric acid flowing countercurrently. The
water vapor is absorbed by the sulfuric acid and the dry chlorine gas is then passed through demisters to remove sulfur ic acid mist. If the chlorine is to be liquefied, liquid chlorine is then add ed to the gas to further purify the chlorine and to prechill it prior to compression. Prechilling is primarily carried out to prevent the temperature from reachin g the chlorine-steel ignition point during compression. 34

C h lorine gas is either used in gaseous form within the facility, transferred to
customers v ia pipeline, or liquefied for storage or transport. Liquid chlorine is of a higher purity than gaseous chlori ne and is either used within the facility or is tran sferred via rail tank car, tank truck, or tank barge. The demand for liquid chlorine has increased in recent yea rs and, in 1987, accounted for about 81 percent of chlorine produced in the U.S. 35

Chlorine liq uefaction processes typically liquefy only about 90-95 percent of the chlorine. This gas and the chlorine gas le ft inside tank truck tanks, rail car
ta nks, or barges after removal of liquid chlorine is impure and must b e

recovere d in a chlorine recovery unit. The gas is compressed and coole d usi ng cold water followed by Freon. The chilled gas is fed up through a packed column in which carbon tetrachloride flows downward absorbing the chlorine. The chlorine-rich carbon tetrachloride is fed to a chlorine stripper in

which the chlorine and carbon tetrachloride separate as they are heated

. T h e chlorine gas is cooled and scrubbed of carbon tetrachloride using liquid chlorine a nd the resulting pure chlorine is sent to the chlorine liquefactio n system. 36 Caustic Soda Processing

September 1995 23 SIC 281Sector Notebook Project Inorganic Chemicals

Caustic soda solution generated from chlor-alkali processes is typicall y processed to remove impurities and t o concentrate it to either a 50 percent or 73 p ercent water-based solution or to anhydrous caustic soda. The causti c soda from the mercury and membrane processes is relatively pure. Product from the mercury process requires only filtration to remove mercury droplets. The evapo rators used to concentrate the caustic soda solution in th e diap hragm process are typically multi-stage forced circulation evaporators

. The evaporators have salt settling systems to remove precipitated salt

. Sodium bo rohydride is often added to reduce corrosion of the equipment

. Evaporators for the membrane process are usually much simpler than thos e for the diaphragm process because the salt conc entration in the membrane cell caustic solution is very low. 37

Hydrogen Processing

The hydro gen produced in all of the electrolytic processes contains smal l
amount s of water vapor, sodium hydroxide, and salt which is remove d through cooling. The hydrogen produced during the mercury cell process also contains small amounts of mercury which must be removed by cooling th e hydrogen gas to condense the mercury and treating with activated carbon. 38

III.B. Raw Material Inputs and Pollution Outputs in the Production Line

Inputs an d pollutant outputs of the chlor-alkali industry are relatively smal l bot h in number and volume in comparison to the chemical manufacturin g industry as a whole. The inputs are primarily salt and water as feedstocks ; acids and chemical precipitants used to remove impurities in the input brine

or output chlorine and caustic soda; and freon used for liquefying an d
pu rifying the chlorine gas produced. The major pollutant outputs from al l three electrolytic processes are chlorine gas emissions (both fugitive and point

source ); spent acids; freon (both fugitive and point source); impuritie s

re moved from the input salt or brine; and pollutants originating fro m electrolytic cell materials and other system parts.

Pollutant outp uts have decreased in recent years as the industry moves away from the mercury and diaphragm cell proc esses to the more efficient (in terms of

mater ial and energy inputs and outputs) membrane cell process. I n add ition, improved cell part materials have been developed, such as DS A anodes and Modified Diaphragms, which are more stable and create les s undesirable byproducts.

In puts and pollutant outputs from the auxiliary processes such as brin e purifi cation, chlorine processing, caustic soda processing, and hydroge n processing are described in Section III.B.4.

September 1995 24 SIC 281Sector Notebook Project Inorganic Chemicals

III.B.1. Mercury Cell

Wastewater streams from mercury cell fa cilities arise from the chlorine drying process, b rine purge, and miscellaneous sources. Small amounts of mercury

are found in the brine purge and miscellaneous sources which include floo r sump s and cell wash water. Before treatment, mercury concentration s (prin cipally in the form of mercuric chloride, HgCl 4 2- ) typically range from 0
to 20 ppm. Thereby segregating most mercury bearing wastewater streams fr om non-mercury bearing wastewater streams. Prior to treatment, sodiu m hydr osulfide is used to precipitate mercuric sulfide. The mercuric sulfide i s removed through filtration before the water is discharged. 39

Air emissions consist of m ercury vapor and chlorine gas released in relatively small amounts as fugitive e missions from the cells; and in the tail gases of the chlorine processing, caustic soda processing, and hydrogen processing

. Process tail gases are wet scrubbed w ith caustic soda or soda ash solutions to remove chlorine and mercury vapor. Residual chlorine emissions in tail gases after treatment are less than one kg per 1,000 kg of chlorine produced an d

me rcury emissions are negligible. The tail gas scrubber water is typicall y reused as brine make-up water. 40

Solid wastes containing mercury include: solids generated during brin e purification; spent graphite from decomposer cells; spent caustic filtratio n cartridges from the filtration of caustic soda solution; spilled mercury fro m facility sumps; and mercury cell "butters," which are semisolid amalgams of mercury with barium or iron formed when an excess of barium is used during sal t purification. Most mercury bearing solid wastes are shipped off-site t o outsi de reclaimers who recover the mercury. The remaining wastes ar e disp osed of in secure landfills using either chemical or physical methods t o recover maximum feasible amount of mercury. 41

III.B.2. Diaphragm Cell

Wastewater streams from the diaphragm cell process originate from th e barometric condenser during caustic soda evaporation, chlorine drying, and from purification of salt recovered from the evaporators. These wastewaters and their treatment are described below in Section III.B.4. The use of lea d and gr aphite anodes and asbestos diaphragms generates lead, asbestos, an d chl orinated hydrocarbons in the caustic soda and chlorine processing wast e strea ms. Lead salts and chlorinated hydrocarbons are generated fro m corrosion of the anodes, and asbes tos particles are formed by the degradation of t he diaphragm with use. Over the past twenty years, all but a fe w diaphra gm cell facilities have switched from the use of lead and graphit e anode s with asbestos diaphragms to DSA anodes and Modified Diaphragms wh ich resist corrosion and degradation. The lead, asbestos, and chlorinated

September 1995 25 SIC 281Sector Notebook Project Inorganic Chemicals

hydrocarbo n contaminants are, therefore, no longer discharged in significant amounts from most diaphragm cell chlor-alkali facilities. Those facilities that discharged caustic processing wastewater streams to on-site lagoons may
, however, still have significant levels of these contaminants on-site. 42

Chlorine is released in relat ively small amounts as fugitive emissions from the cells and in the process tail gases. Process tail gases are wet scrubbed with soda ash or caustic soda solutions to remove chlorine. Residual chlorin e emissions in tail gases after treatment are negligible. The spent causti c solution is neutralized prior to discharge. 43

Solid wastes generated in the diaphragm process consist primarily of solid s gener ated during brine purification and scrapped cell parts including, cel l covers, piping and used diaphrag ms. Discarded cell parts are either landfilled

on -site, as is typically the case for spent diaphragms, or shipped off-site fo r disposal. Used cathodes and DSA anodes are shipped off-site for recovery of their titanium content. 44

III.B.3. Membrane Cell

Wastewater from the diaphragm cell process originates from the barometric conde nser during caustic soda evaporation, chlorine drying, and wash water from the i on exchange resin used to purify the brine solution. The io n exchange wash water cons ists of dilute hydrochloric acid with small amounts of dissolved calcium, magnes ium, and aluminum chloride. The wastewater is combined with the other p rocess wastewaters and treated by neutralization. 45

Chlorine is released in relat ively small amounts as fugitive emissions from the cells and in the process tail gases. Process tail gases are wet scrubbed with soda ash or caustic soda solutions to remove chlorine. Residual chlorin e emissions in tail gases after treatment are negligible. The spent causti c solution is neutralized prior to discharge. 46

Solid waste generated in the diaphragm process consists primarily of solid s gen erated during brine purification and used cell parts which includ e membrane s, cathodes and DSA anodes. The used membranes are typicall y

r e turned to the supplier and the used cathodes and DSA anodes are shipped off-site for recovery of their titanium content. 47

III.B.4. Auxiliary Processes

Brine Purification

Brin e solutions are typically treated with a number of chemicals to remov e i m purities prior to input to the electrolytic cells. In the case of mercury and

September 1995 26 SIC 281Sector Notebook Project Inorganic Chemicals

mem brane cell systems, the brine is first acidified with HCl to remov e dissolved chlorine. Next, sodium hydroxide and sodium carbonate are added
to p recipitate calcium and magnesium ions as calcium carbonate an d
mag nesium hydroxide. Barium carbonate is then added to remove sulfate s which precipitate out as barium sulfate. The precipitants are removed from the brine solution by settling and filtration. Pollutant outputs from thi s process include fugitive chlorine emissions and brine muds. 48

Brine muds are one of the largest waste streams of the chlor-alkali industry. On a verage, about 30 kilograms (kg) of brine mud are generated for ever y 1,0 00 kg of chlorine produced. The volume of mud will vary, however
, depending on the purity of the salt used. Some facilities use pre-purified (i.e., chemi cal grade) evaporated salts which will produce only 0.7 to 6.0 kg o f brine mud per 1,000 kg of chlorine produced. Brine mud typically contains magnesium hydroxide, cal cium carbonate, and, in most cases, barium sulfate. Mercury cell brine muds usually contain mercury either in the elemental form or as the complex ion, mercuric chloride (HgCl 4 2- ). Mercury- containing brine muds are typically disposed of in a RCRA Subtitle C landfill after treatment with sodium sulfide which converts the mercury to an insoluble sulfide. 49

Brine muds are usually segregated from other process wastes and stored i n lagoons o n-site. When the lagoons become filled, the brine mud is eithe r dredged and landfilled off-site, or drained and co vered over. Some plants that

use brine solution leached from subterranean deposits inject brine muds into the salt cavities that are no longer being used. 50

Chlorine Processing

The chlor ine gas recovered from electrolytic cells is cooled to remove water
vapor. The condensed water is usually recycled as brine make-up althoug h

some facilities combine this waste stream with other waterborne wast e streams prior to treatment. The remaining water vapor is removed b y scrubbi ng the chlorine gas with concentrated sulfuric acid. The chlorine gas is then compressed and cooled to form liquid chlorine. Between six kg and 35 kg o f 79 percent sulfuric acid wastewater is generated per 1,000 kg o f chlorine produced. The majority of the spent sulfuric acid waste is shippe d off-site f or refortification to concentrated sulfuric acid or for use in othe r processes. The remaind er is used to control effluent pH and/or is discharged to water or land disposed. 51

The process of purifying and liquefying impure chlorine gas involves th e absorption of the chlorine in a stream of carbon tetrachloride. The chlorine is subseq uently removed in a stripping process in which the carbo n tetrachloride is either reco vered and reused, or is vented to the atmosphere. 52

September 1995 27 SIC 281Sector Notebook Project Inorganic Chemicals

Caustic Soda Processing

Caustic soda solution generated from chlor-alkali processes is typicall y proces sed to remove impurities and, in the case of the diaphragm an d membr ane processes, is concentrated to either a 50 percent or 73 percen t water-based solution o r to anhydrous caustic soda. About five tons of water
must be evaporated per ton of 50 percent caustic soda solution produced

. The water vapor from the evaporato rs is condensed in barometric condensers and, in the case of the diaphragm process, will primarily contain about 1 5 percent caustic soda solution and high concentrations of salt. If sodiu m sulfate is not removed during the brine purification process, salt recovere d fr om the evaporators is often recrystallized to avoid sulfate buildup in th e brine. If the salt is recrystallized, the wastewater from sodium hydroxid e processing will also contain sodium su lfates. Significant levels of copper may also be pre sent in the wastewater due to corrosion of pipes and othe r equip ment. Wastewater from the membrane process contains caustic sod a solution and virtually no salt or sodium sulfates. 53

Caustic soda processing wastewate r is typically neutralized with hydrochloric acid
, lagooned, and then discharged directly to a receiving water or lan d disposed. The caustic soda generated from the mercury process only requires filtration to remove mercury dr oplets which are typically recovered for reuse.

Hydrogen Processing

The hydro gen produced in all of the electrolytic processes contains smal l
amount s of water vapor, sodium hydroxide, and salt which is remove d through cooling. Condensed salt water and sodium hydroxide solution i s either re cycled as brine make-up or treated with other waterborne wast e streams. T he hydrogen produced during the mercury cell process, however, als o contains small amounts of mercury which must be removed prior t o li

quefaction. Most of the entrained mercury is extracted by cooling the gas. Th e condensed mercury is then returned to the electrolytic cells. Som e facilitie s further purify the hydrogen gas of mercury using activated carbo n treatment. Spent activated carbon is typically shipped off-site as a hazardous
waste. 54

III.C. Management of Chemicals In Wastestream

The Po llution Prevention Act of 1990 (PPA) requires facilities to repor t inf ormation about the management of TRI chemicals in waste and effort s made to eliminate or reduce tho se quantities. These data have been collected annually in Section 8 of the TRI reporting Form R beginning with the 1991
repor ting year. The data summarized below cover the years 1992-1995 and i s meant to provide a basic understanding of the quantities of waste handled

September 1995 28 SIC 281Sector Notebook Project Inorganic Chemicals

by the industry, the methods typically used to manage this waste, and recent trend s in these methods. TRI waste management data can be used to assess trends in source reduction within individual industries and facilities, and fo r speci fic TRI chemicals. This information could then be used as a tool i n identifying opportunities for pollution prevention compliance assistanc e activities.

Fr om the yearly data presented below it is apparent that the portion of TR I wastes report ed as recycled on-site has increased and the portions treated or managed through treatment on-site have decreased between 1992 and 1995 (projected). While the quantities repor ted for 1992 and 1993 are estimates of quant ities already managed, the quantities reported for 1994 and 1995 ar e projec tions only. The PPA requires these projections to encourage facilities to consi der future waste generation and source reduction of those quantities

as wel l as movement up the waste management hierarchy. Future-yea r estimates are not commitments that facilities r eporting under TRI are required
to meet.

Exhibit 1 0 shows that the inorganic chemicals industry managed about 1. 7 trillion pounds of production-related waste (total quantity of TRI chemicals in the wa ste from routine production operations) in 1993 (column B)

. Column C reveals that of this production -related waste, 15 percent was either transferred off-site or released to the envir onment. Column C is calculated by divid ing the total TRI transfers and releases by the total quantity o f production-related waste. In other words, about 85 percent of the industry’s TRI w astes were managed on-site through recycling, energy recovery, o r treatment a s shown in columns E, F and G, respectively. The majority o f waste that is released or transferred off-site can be divided into portions that are recycled off-site, recovered for energy off-site, or treated off-site as shown in columns H, I and J, respectively. The remaining portion of the production relate d wastes (11 percent), shown in column D, is either released to th e environment through direct discharges to air, land, water, and underground injection, or it is disposed off-site.

September 1995 29 SIC 281---

--- Sector Notebook Project Inorganic Chemicals

Exhibit 10: Source Reduction and Recycling Activity for Inorganic Chemicals Industry (SIC 281) as Reported within TRI

A B C D On-Site Off-Site

Year (10 lbs.) Quantity ofProductionRelated Waste

6 a Transferred % Released and

b Off-site % Released and Disposed c E F G H I J

% Recycled % Energy Recovery % Treated % Recycled % Energy Recovery % Treated

1992 1,642 16% 12% 42% 0% 42% <1% <1% 3%

1993 1,712 15% 11% 45% 0% 40% <1% <1% 3%

1994 1,759 11% 47% <1% 39% <1% <1% 3%

1995 1,732 10% 48% 0% 40% <1% <1% 3%
Within this industry sector, non-production related waste is < 1% of production related wastes for 1993. a Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related b
wastes.

Percentage of production related waste released to the environment and transferred off-site for disposal. c

September 1995 30 SIC 281Sector Notebook Project Inorganic Chemicals

IV. CHEMICAL RELEASE AND TRANSFER PROFILE

This section is designed to provide background information on the pollutant releases that are reported by this industry. The best source of comparativ e pollutant release information is the Toxic Release Inventory System (TRI)

. Pursuant to the Emergency Planning and Community Right-to-Know Act
, TRI includes self-reported facility release and transfer data for over 600 toxic chemicals. Facilities wi thin SIC Codes 20-39 (manufacturing industries) that have mor e than 10 employees, and that are above weight-based reportin g th resholds are required to report TRI on-site releases and off-site transfers

. TRI is not specific to the chemical industry. The information presented within the sec tor notebooks is derived from the most recently available (1993) TRI reporting year (which then included 316 chemicals), and focuses primarily on the on-site releases reported by each sector. Because TRI requires consistent reporting regardless of sec tor, it is an excellent tool for drawing comparisons across industries.

Althoug h this sector notebook does not present historical informatio n regarding TRI chemical releases, please note that in general, toxic chemical rele ases across all industries have been declining. In fact, according to th e 1993 Toxic Release Inventory Da ta Book, reported releases dropped by 42.7
per cent between 1988 and 1993. Although on-site releases have decreased, the total amount of reported toxic wast e has not declined because the amount of toxic chemicals transferred off-site has increased. Transfers have increased from 3.7 bi llion pounds in 1991 to 4.7 billion pounds in 1993. Bette r manage ment practices have led to increases in off-site transfers of toxi c chemi cals for recycling. More detailed information can be obtained fro m EPA's annual Toxics Release Inventory Public Data Release book (which is available through the EP CRA Hotline at 800-535-0202), or directly from the To xic Release Inventory System database (for user support call 202-260

- 1531).

Wherever possible, the sector notebooks present TRI data as the primar y indicator of chemical release within each industrial category. TRI dat a pr ovide the type, amount and media receptor of each chemical released o r transferred. When other sources of pollutant release data have been obtained, these data have been included to augment the TRI information.

TRI Data Limitations

The reader should keep in mind the following limitations regarding TRI data. Within some sectors, the majority of faciliti es are not subject to TRI reporting because they are not considered manufactur ing industries, or because they are below TR I reporting thresholds. Examples are the mining, dry cleaning
,

September 1995 31 SIC 281Sector Notebook Project Inorganic Chemicals

printing, and transportation equipment cleaning sectors. For these sectors
, release information from other sources has been included.

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. Wei ghting each pound of release equally does not factor in the relativ e toxicity of each chemical that is released. The Agency is in the process o f developing an approach to assign toxicological weightings to each chemical

re leased so that one can differentiate between pollutants with significan t differences in toxicity. As a preliminary ind icator of the environmental impact of

th e industry's most commonly released chemicals, the notebook briefl y

summa rizes the toxicological properties of the top chemicals (by weight ) reported by each industry.

Definitions Associated With Section IV Data Tables

General Definitions

SIC Code -- is the Standard Industrial Classification (SIC) is a statistica l classification standard used for all establishment-based Federal economi c statistics. The SIC codes fa cilitate comparisons between facility and industry data.

TRI Facilities -- are manufacturing facilities that have 10 or more full-time employ ees and are above established chemical throughput thresholds

. Manufacturing facilities are defined as facilities in Standard Industria l Classifi cation primary codes 20-39. Facilities must submit estimates for al l chemicals that are on the EPA's defined list and are above throughpu t thresholds.

Data Table Column Heading Definitions

The f ollowing definitions are based upon standard definitions developed b y EPA’s Toxic Release Inventory Program. The ca tegories below represent the possible pollutant destinations that can be reported.

RELEASES -- are an on-site discharge of a toxic chemical to th e environment. This includes emissions to the air, discharges to bodies o f water, releases at the facility to land, as well as contained disposal int o underground injection wells.

Release s to Air (Point and Fugitive Air Emissions) -- include all ai r emissions from industry activity. Point emission occur through confined air streams as found in sta cks, ducts, or pipes. Fugitive emissions include losses

September 1995 32 SIC 281Sector Notebook Project Inorganic Chemicals

from equipment leaks, or evaporative losses from impoundments, spills, o r leaks.

Releases to Water (Surface Water Discharges) -- encompass any releases going directly to streams, rivers, lakes, oceans, or other bodies of water. Any

e s timates for stormwater runoff and non-point losses must also be included.

Rel eases to Land -- includes disposal of toxic chemicals in waste to on-site landfills, land treated or incor poration into soil, surface impoundments, spills, leaks, or waste piles. These activities must occur within the facility' s boundaries for inclusion in this category.

Underground In jection -- is a contained release of a fluid into a subsurface well for the purpose of waste disposal.

TRANSFERS -- is a tr ansfer of toxic chemicals in wastes to a facility that is
geogr aphically or physically separate from the facility reporting under TRI

. The quantities reported re present 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 wastewaters t ransferred through pipes or sewers
to a publicly owned treatments works (POTW). Treatment and chemica l

remo val depend on the chemical's nature and treatment methods used

. Chemicals not treated or destroyed by the POTW are generally released t o surface waters or landfilled within the sludge.

Transfers to Recycling -- are sent off-site for the purposes of regenerating

or recovering still valuable materials. Once these chemicals have bee n recycled, they may be returned to the originating f acility or sold commercially.

Transfers to Energy Recovery -- are wastes combusted off-site in industrial furnaces for en ergy recovery. Treatment of a chemical by incineration is not considered to be energy recovery.

Transfers to Treatment -- are wastes moved off-site for ei ther neutralization, incineration, biological destruction, or phys ical 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 disposa l generally as a release to land or as an injection underground.

IV.A. EPA Toxic Release Inventory for the Inorganic Chemical Industry

September 1995 33 SIC 281Sector Notebook Project Inorganic Chemicals

The 1993 TRI data presented in Exhibits 11 and 12 for inorganic chemicals manufacturing covers 555 facilities

. These facilities listed SIC 281 (industrial inorganic chemicals) as a primary SIC c ode. The Bureau of Census identified 1,429 facilities manufacturing inorganic chemicals. More than half of thes e facilities, however, have fewer than 20 employees, many of which are likely
to be below the TRI reporting thresholds of employment (TRI reportin g threshold is greater than 10 employees) and/or chemical use and, therefore
, are not required to report to TRI.

Accordin g to TRI data, in 1993 the inorganic chemical industry release d (dischar ged to the air, water, or land without treatment) and transferre d (shipped off-site) a total of 250 million pou nds of 112 different chemical toxic chemicals. This represents about 10 percent of the TRI releases and transfers of t he chemical manufacturing industry and about three percent of the tota l releases and transfers of all manufacturers that year. In comparison, th e organic chem ical industry (SIC 286) produced 438 million pounds that year, almost twice that of the inorganic chemical industry. 55

The chemical industry's releases have been de clining in recent years. Between 1988 and 1993 TRI emissions from chemical compan ies (all those categorized within SIC 28, not just inorganic chemical manufacturers) to air, land, an d
wat er were reduced 44 percent, which is slightly above the average for al l manufacturing sectors reporting to TRI. 56

Beca use the chemical industry (SIC 28) has historically released more TR I ch emicals than any other industry, the EPA has worked to improv e environmental perf ormance within this sector. This has been done through a

com bination of enforcement actions, regulatory requirements, pollutio n prevention projects, and voluntary programs (e.g. 33/50). In addition, th e chemical industry has focused on reducing pollutant releases. For example, the Chemical Manufacturers Association’s (CMA’s) Responsible Car e initiative is intended to reduce or eximinate chemical manufacturers’ waste. All 184 members of the CMA, firms that account for the majority of U.S

. chemical industry sales and earnings, are required to participate in th e program. Participation involves demonstrating a commitment to th e progra m's mandate of continuous improvement in environment, health, an d safety. In June of 1994, the CMA approved the use of a third-part y verification of management plans to meet these objectives.

Exhibits 11 and 12 present the number and v olumes of chemicals released and transferred by inor ganic chemical facilities, respectively. The frequency with which chem icals are reported by facilities within a sector is one indication of the d iversity of operations and processes. Many of the TRI chemicals ar e released or transferred by only a small number of facilities which indicates a wide diversity of production proce sses, particularly for specialty inorganics --

September 1995 34 SIC 281Sector Notebook Project Inorganic Chemicals

over 70 percent of the 110 chemicals reported are released or transferred by fewer than 10 facilities.

The inorganic chemical industry releases 69 percent of its total TRI poundage to the water (including 67 percent to underground injection and two percent
to surface waters), 14 percent to the air, and 17 percent to the land. Thi s release profile differs from ot her TRI industries which average approximately 30 percent to the water, 59 percent t o air, and 10 percent to land. Examining th e inorganic chemical industry's TRI reported toxic chemical release s highlights the likely origins of the large water releas es for the industry (Exhibit 11).

As presented in Exhibit 11, on-site underground injection of essentially on e chemical, hydrochloric acid, accounts for the largest portion, 55 percent, of the inorganic chemical industry's total releases and transfers as reported i n TRI. Onl y five facilities of the 555 identified facilities reported releasin g hydroc hloric acid through underground injection. Two of these facilitie s

accoun ted for over 85 percent of the total hydrochloric acid injected to th e subsur face, or 42 percent of the inorganic chemical industry's total release s and transfers. Land disposal accounted for the next largest amount, 1 7 percent, of the indu stry's total releases. The largest single chemical released to the air by the inorga nic chemical industry, carbonyl sulfide, is only emitted by eleven facilities manufacturing certain inorganic pigments.

Discha rges to POTWs accounted for 43 percent of the industry’s tota l
tran sfers of TRI chemicals. Ammonia, hydrochloric acid, and sulfuric aci d

ac count for over 66 percent of the 70 million pounds transferred off-site

. Finally
, approximately 22 million pounds, accounting for 31 percent of th e total, are transferred off-site for treatment (Exhibit 12).

September 1995 35 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 11:1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting(Releases reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALFUGITIVEAIRPOINTAIRWATERDISCHARGESUNDERGROUNDINJECTIONLANDDISPOSALTOTALRELEASESAVG. RELEASESPER FACILITYSULFURIC ACID31147,743538,5847,482529,520623,3342,004HYDROCHLORIC ACID16729,4281,420,2623,748120,745,708213,351122,677,352734,595AMMONIA1521,984,4402,726,7741,885,47501,162,9877,759,67651,051CHLORINE12152,9543,017,3936,105003,076,45225,425PHOSPHORIC ACID724,673417,18150050422,3595,866NITRIC ACID7113,21156,5382505070,004986ACETONE5440,30419,26100059,5651,103ZINC COMPOUNDS5339,17172,705104,180086,384302,4405,706CHROMIUM COMPOUNDS414,29413,00833,935019,036,93419,088,171465,565COPPER COMPOUNDS332,31715,2381,827042819,810600NICKEL COMPOUNDS291,25320,0008,872534,28964,4192,221METHANOL28105,224878,23977,887001,061,35037,905BARIUM COMPOUNDS272,2798,1765,6290353,000369,08413,670DICHLORODIFLUOROMETHANE26741,76154,302000796,06330,618LEAD COMPOUNDS261,37012,730287058,05372,4402,786MANGANESE COMPOUNDS26124,003146,39387,54807,672,7688,030,712308,874HYDROGEN FLUORIDE2493,04084,9325010177,9877,416COBALT COMPOUNDS211,0012,018996033,46037,4751,785ETHYLENE GLYCOL2054376550507022,515126TOLUENE2084,67911,31300495,9964,800ANTIMONY COMPOUNDS162,01011,4392730113,723858XYLENE (MIXED ISOMERS)169,6087,998005217,6581,104PHOSPHORUS (YELLOW OR141,2004,13750323,749329,09123,507PROPYLENE1414,4512,21500016,6661,190AMMONIUM NITRATE136978,858496,4000599,0281,104,98384,999AMMONIUM SULFATE111,6134,9350006,548595CARBONYL SULFIDE113809,676,4860009,676,866879,715GLYCOL ETHERS114,02840,64000044,6684,061TITANIUM TETRACHLORIDE117,9004,49200012,3921,127ETHYLENE OXIDE1042819,89000020,3182,032COPPER95231,25083001,856206MOLYBDENUM TRIOXIDE91,15512,2913,749550017,7001,967FORMALDEHYDE849311,70300012,1961,525ZINC (FUME OR DUST)82556,4760006,731841ARSENIC COMPOUNDS726026439105041,419203MERCURY75,9031,59721501,5199,2341,3191,1,1-TRICHLOROETHANE71,2005050001,705244ASBESTOS (FRIABLE)60100010CARBON TETRACHLORIDE625,632259,791002285,42547,571CHROMIUM6260520860267,786268,65244,775DICHLOROTETRAFLUOROETHANE6709,9505000709,955118,326ETHYLENE65275,2870005,814969METHYL ETHYL KETONE610,2052,601004112,8472,141NAPHTHALENE681933,6527410535,2175,870CADMIUM COMPOUNDS54314,2372101244,813963DICHLOROMETHANE553,1749,32200062,49612,499DIETHANOLAMINE53,3257500004,075815ACETONITRILE42,0851,6960003,781945

September 1995 36 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 11 (cont.):1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting(Releases reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALFUGITIVEAIRPOINTAIRWATERDISCHARGESUNDERGROUNDINJECTIONLANDDISPOSALTOTALRELEASESAVG. RELEASESPER FACILITYCARBON DISULFIDE470,0064,3342500074,59018,648CHLOROFORM413,28227,0173600040,65910,165CYANIDE COMPOUNDS455000103NICKEL438880502501,173293PHTHALIC ANHYDRIDE4250250000500125SELENIUM COMPOUNDS410270870036792TRICHLOROFLUOROMETHANE4307,2501,205000308,45577,1141,2,4-TRIMETHYLBENZENE41,1101,290250052,655664ALUMINUM (FUME OR DUST)342660000702234BENZENE35055000510170ETHYLBENZENE3505250000755252FREON 113330,9546700031,02110,340HYDRAZINE333003300363121MANGANESE32503163401,180,3351,180,935393,645MONOCHLOROPENTAFLUOROEHTANE3402,0007,721000409,721136,574TRICHLOROETHYLENE325535,30550035,56511,855ACETALDEHYDE263,1000003,1061,553ACRYLONITRILE22555000260130CHLORINE DIOXIDE286176000262131COBALT213251005269135CRESOL (MIXED ISOMERS)2276510000786393CYCLOHEXANE22555000260130HYDROQUINONE20000000LEAD2760908,5008,5854,293METHYL ISOBUTYL KETONE2250303000553277METHYL TERT-BUTYL ETHER27905000795398PHENOL2264145000409205SILVER COMPOUNDS20500053TETRACHLOROETHYLENE2400305000705353ACRYLIC ACID12505000255255ARSENIC15000055BARIUM10000000BROMOTRIFLUOROMETHANE134,000000034,00034,000CAPTAN15000055CHLOROBENZENE12505000255255CHLOROETHANE15220000522522CHLOROMETHANE15010000501501CREOSOTE12505000255255CUMENE17507500001,5001,500DI(2-ETHYLHEXYL) PHTHALATE12505000255255DIBUTYL PHTHALATE12505000255255DIMETHYL PHTHALATE11000001010DIMETHYL SULFATE10000000ETHYL ACRYLATE12505000255255HYDROGEN CYANIDE10300003030ISOPROPYL ALCOHOL1250250000500500MALEIC ANHYDRIDE12505000255255MERCURY COMPOUNDS1250250000500500

September 1995 37 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 11 (cont.):1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting(Releases reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALFUGITIVEAIRPOINTAIRWATERDISCHARGESUNDERGROUNDINJECTIONLANDDISPOSALTOTALRELEASESAVG. RELEASESPER FACILITYMETHYL METHACRYLATE12505000255255N-BUTYL ALCOHOL1250250000500500O-XYLENE15000055P-XYLENE15000055PERACETIC ACID1102,10042002,1522,152POLYCHLORINATED BIPHENYLS10000000SELENIUM15250000255255SILVER17502500001,0001,000STYRENE1250250000500500THIOUREA10000000VINYL ACETATE15000055VINYL CHLORIDE100000001,1,2-TRICHLOROETHANE125050002552551,2-DICHLOROETHANE150000551,2,4-TRICHLOROBENZENE150000551,4-DIOXANE15000055TOTAL5555,366,35619,737,6602,728,270120,745,73331,064,296179,642,315323,680

September 1995 38 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 12:1993 Transfers for Inorganic Chemical Manufacturing Facilities(SIC 281)in TRI, by Number of Facilities Reporting(Transfers reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALPOTWDISCHARGESDISPOSALRECYCLINGTREATMENTENERGYRECOVERYTOTALTRANSFERSAVG. TRANSFERSPER FACILITYSULFURIC ACID31111,146250,4341,025,2426,820,66508,107,48726,069HYDROCHLORIC ACID1675284,598,609010,423,062015,022,19989,953AMMONIA15222,101,429371,669528,23065,300023,066,628151,754CHLORINE1215610027008857PHOSPHORIC ACID723,9132,13023,218132,0650161,3262,241NITRIC ACID71102500438,6140438,8746,181ACETONE541,6552315,72611,24984,368113,0212,093ZINC COMPOUNDS537,382509,395159,71330,2650706,75513,335CHROMIUM COMPOUNDS414,078121,56947,84351,4520224,9425,486COPPER COMPOUNDS334,228321,517576,6427,7330910,12027,579NICKEL COMPOUNDS299,84086,370278,630106,6920481,53216,605METHANOL2816,2094,000291,3541751,802,7652,114,50375,518BARIUM COMPOUNDS275,080370,2880123,5600498,92818,479DICHLORODIFLUOROMETHANE260020,60016020,616793LEAD COMPOUNDS261,30189,6601,153,2111,087,66902,331,84189,686MANGANESE COMPOUNDS261,4461,694,8407,3002,206,41103,909,997150,385HYDROGEN FLUORIDE24185230,25077,58738,7000346,72214,447COBALT COMPOUNDS213,99613,5808,05010,598036,2241,725ETHYLENE GLYCOL203,951030,9122,24813,85250,9632,548TOLUENE201,37520325,34732,384217,979277,28813,864ANTIMONY COMPOUNDS163,73552,81516,0007,171079,7214,983XYLENE (MIXED ISOMERS)160732505,127188,093193,54312,096PHOSPHORUS (YELLOW OR1401026,000026,0011,857PROPYLENE140000000AMMONIUM NITRATE131,923,495160603,440002,527,095194,392AMMONIUM SULFATE116,506,7338,24706,09206,521,072592,825CARBONYL SULFIDE110000000GLYCOL ETHERS11628506037,38713,40551,9264,721TITANIUM TETRACHLORIDE1101604898659154ETHYLENE OXIDE100000000COPPER946938,477055,2610993,784110,420MOLYBDENUM TRIOXIDE97,65252,42461,22000121,29613,477FORMALDEHYDE825525003620867108ZINC (FUME OR DUST)82501,710250002,210276ARSENIC COMPOUNDS7559,900250904061,0598,723MERCURY703,4865,2221,01009,7181,3881,1,1-TRICHLOROETHANE7002505025536ASBESTOS (FRIABLE)6033,07000033,0705,512CARBON TETRACHLORIDE601,400034,107035,5075,918CHROMIUM6048,9302,76337,765089,45814,910DICHLOROTETRAFLUOROETHA60000000ETHYLENE60000000METHYL ETHYL KETONE6092044333,56734,1025,684NAPHTHALENE604808802501,178196CADMIUM COMPOUNDS53558554,06104,686937DICHLOROMETHANE5005,147505,1521,030DIETHANOLAMINE5450000045090ACETONITRILE4000522,23922,2445,561

September 1995 39 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 12 (cont.):1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting(Transfers reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALPOTWDISCHARGESDISPOSALRECYCLINGTREATMENTENERGYRECOVERYTOTALTRANSFERSAVG. TRANSFERSPER FACILITYCARBON DISULFIDE42501000500760190CHLOROFORM407,700072,311080,01120,003CYANIDE COMPOUNDS41004051NICKEL49750523,6700024,2726,068PHTHALIC ANHYDRIDE450052,4122,422606SELENIUM COMPOUNDS42270295032481TRICHLOROFLUOROMETHANE4003,1001,70504,8051,2011,2,4-TRIMETHYLBENZENE40001,8543,1885,0421,261ALUMINUM (FUME OR DUST)30000000BENZENE30005052ETHYLBENZENE30005052FREON 11330001,50001,500500HYDRAZINE30000000MANGANESE30183,412000183,41261,137MONOCHLOROPENTAFLUOROE30000000TRICHLOROETHYLENE30001,30501,305435ACETALDEHYDE20000000ACRYLONITRILE20005053CHLORINE DIOXIDE2130000013065COBALT2452,300002,3091,155CRESOL (MIXED ISOMERS)20005053CYCLOHEXANE20005053HYDROQUINONE25000000500250LEAD207500660816408METHYL ISOBUTYL KETONE20005820825413METHYL TERT-BUTYL ETHER20005053PHENOL20005053SILVER COMPOUNDS255000105TETRACHLOROETHYLENE20005053ACRYLIC ACID10005055ARSENIC100070,761070,76170,761BARIUM1026,21700026,21726,217BROMOTRIFLUOROMETHANE10000000CAPTAN10000000CHLOROBENZENE10005055CHLOROETHANE10000000CHLOROMETHANE10000000CREOSOTE10005055CUMENE10001,00001,0001,000DI(2-ETHYLHEXYL)10005055DIBUTYL PHTHALATE10005055DIMETHYL PHTHALATE10000000DIMETHYL SULFATE10000000ETHYL ACRYLATE10005055HYDROGEN CYANIDE10000000ISOPROPYL ALCOHOL10005055MALEIC ANHYDRIDE10005055MERCURY COMPOUNDS151,5250501,5351,535

September 1995 40 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 12 (cont.):1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting(Transfers reported in pounds/year)CHEMICAL NAME# REPORTINGCHEMICALPOTWDISCHARGESDISPOSALRECYCLINGTREATMENTENERGYRECOVERYTOTALTRANSFERSAVG. TRANSFERSPER FACILITYMETHYL METHACRYLATE10005055N-BUTYL ALCOHOL10005055O-XYLENE10000000P-XYLENE10000000PERACETIC ACID10001100110110POLYCHLORINATED10000000SELENIUM10001,45001,4501,450SILVER1001,011001,0111,011STYRENE10005055THIOUREA10000000VINYL ACETATE10000000VINYL CHLORIDE100000001,1,2-TRICHLOROETHANE100050551,2-DICHLOROETHANE100000001,2,4-TRICHLOROBENZENE100000001,4-DIOXANE10000000TOTAL55530,622,04010,087,7434,994,48321,958,6782,383,52470,046,468126,210

September 1995 41 SIC 2811

2

3

4

5

6

7

8

9

10 Sector Notebook Project Inorganic Chemicals

The TRI database contains a detailed compilation of self-reported, facility

specific chemical releases. The top reporting fac ilities for this sector are listed below. Facilities that have reported only the SIC codes covered under thi s notebook appear on the first lis t. The second list contains additional facilities that have repo rted the SIC code covered within this report, and one or more SIC c odes that are not within the scope of this notebook. Therefore, th e second list includes facilities that cond uct multiple operations -- some that are under the scope of this notebook, and some that are not. Currently, th e faci lity-level data do not allow pollutant releases to be broken apart b y industrial process.



## Exhibit 13: Top 10 TRI Releasing Inorganic Chemicals Facilities b

Rank Facility in Pounds Total TRI

Releases

Du Pont Delisle Plant - Pass Christian, MS 58,875,734

Du Pont Johnsonville Plant - New Johnsonville, TN 51,215,700

Cabot Corp. Cab-O-Sil Div. - Tuscola, IL 13,926,440

American Chrome & Chemicals Inc. - Corpus Christi, TX 12,113,360

Occidental Chemical Corp. - Castle Hayne, NC 6,705,795

Chemetals Inc. - New Johnsonville, TN 5,684,893

Kaiser Aluminum & Chemical Corp. - Mulberry, FL 4,876,348

Kerr-McGee Chemical Corp. - Henderson, NV 2,333,175

SCM Chemicals Americas Plant II - Ashtabula, OH 2,238,400

Louisiana Pigment Co. L.P. - Westlake, LA 1,465,753

Source: U.S. EPA, Toxics Release Inventory Database, 1993.

b Being included on this list does not mean that the release is associated with non-compliance with environmental laws.

September 1995 42 SIC 2811

2

3

4

5

6

7 Sector Notebook Project Inorganic Chemicals

Exhibit 14: Top 10 TRI Releasing Facilities Reporting Inorganic Chemical SIC Codes to TRI c

Rank Reported in TRI SIC Codes Facility Pounds Releases in Total TRI

2819, 2873, 2874 IMC-Agrico Co., Faustina Plant - Saint James, LA 127,912,967
2819, 2869 Cytec Industries, Inc., Fortier Plant - Westwego, LA 120,149,724
2819, 2874 IMC-Agrico Co., Uncle Sam Plant - Uncle Sam, LA 61,807,180

2816 Du Pont Delisle Plant - Pass Christian, MS 58,875,734

2816 Du Pont Johnsonville Plant - New Johnsonville, TN 51,215,700
2819, 2823 Courtaulds Fibers, Inc. - Axis, AL 42,658,865
2819, 2869, 2841, 2879 Monsanto Co. - Alvin, TX 40,517,095

8 2819, 2869, 2865 Sterling Chemicals, Inc. - Texas City, TX 24,709,135

9 2819, 2873, 2874 Arcadian Fertilizer L.P. - Geismar, LA 22,672,961

10 2812, 2813, 2869 Vulcan Chemicals - Wichita, KS 17,406,218
Source: U.S. EPA, Toxics Release Inventory Database, 1993.

IV.B. Summary of Selected Chemicals Released

The brie f descriptions provided below were taken from the 1993 Toxic s Release Inventory Public Data Release (EPA, 1994), and the Hazardou s Su bstances 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, the National Cance r In stitute, and the National Institute for Occupational Safety and Health. d HS DB contains chemical-specific information on manufacturing and use
, chemical and physical properties, s afety and handling, toxicity and biomedical effects, pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and analysis methods, and additiona l

c Being included on this list does not mean that the release is associated with non-compliance with environmental laws.

d 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).

September 1995 43 SIC 281Sector Notebook Project Inorganic Chemicals

references. The information contained below is based upon exposur e assumptions that have been conducted using standard scientific procedures. The effects listed below must be taken in context of these exposur e

assum ptions 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.

Hydrochloric Acid (CAS: 7647-01-1)

Sources. Hydrochloric acid is one of the highest volume chemicals produced by the inorganic chemical industry. Some of its more common uses are as a pickling liquor and metal cleaner i n the iron and steel industry, as an activator of

petroleum wells, as a boiler scale remover, and as a neutralizer of caustic
wast e streams. The largest release of hydrochloric acid by the inorgani c che mical industry is in the form of underground injection of spen t hydro chloric acid used to manufacture chlorosulfonic acid and othe r products. 57

Toxicity. Hyd rochloric acid is primarily a concern in its aerosol form. Acid

aero sols have been implicated in causing and exacerbating a variety o f

r e spiratory ailments. Dermal exposure and ingestion of highly concentrated hydrochloric acid can result in corrosivity.

Ecologically, accidental releases of solution forms of hydrochloric acid may adve rsely affect aquatic life by including a transient lowering of the pH (i.e., increasing the acidity) of surface waters.

Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic.

Envir onmental Fate. Releases of hydrochloric acid to surface waters an d soils wil l be neutralized to an extent due to the buffering capacities of bot h systems. The extent of these reactions will depend on the characteristics of the specific environment.

Physical Properties. Concentrated hydrochloric acid is highly corrosive.

Chromium and Chromium Compounds (CAS: 7440-47-3; 20-06-4)

Sou rces. Chrome pigments, chromates, chromic acid, chromium salts, an d other inorganic chromium compounds are some of th e larger volume products of the inor ganic chemicals industry. Chrome is used as a plating element for metal and plastics to prevent corrosion, and as a constituent of certain steels and inorganic pigments. Most chromium wastes released to the environment

September 1995 44 SIC 281Sector Notebook Project Inorganic Chemicals

by the inorganic chemicals industry are land dispo sed in the form of chromium containing sludges.

Toxicity. Although the naturally-occu rring form of chromium metal has very low toxicity, chromium from industrial emissions is highly toxic due to strong oxidation characteristics and cell membra ne permeability. The majority of the effects det ailed below are based on Chromium VI (an isomer that is mor e toxic than Cr III). Exposure to chromium m etal and insoluble chromium salts affe cts the respiratory system. Inhalation exposure to chromium an d chromium salt s may cause severe irritation of the upper respiratory tract and scarring of lung tissue. Dermal exposure to chromium and chromium salt s can also cause sensitive dermatitis and skin ulcers.

Ecologically, altho ugh chromium is present in small quantities in all soils and plants, it is toxic to plants at higher soil concen trations (i.e., 0.2 to 0.4 percent in soil).

Carci nogenicity. Different sources disagree on the carcinogenicity o f chromium. Although an increased incidence in lung cancer among workers in the chromate-producing ind ustry has been reported, data are inadequate to confir m that chromium is a human carcinogen. Other sources conside r chromium VI to be a known human carc inogen based on inhalation exposure.

Environm ental Fate. Chromium is a non-volatile metal with very lo w solu bility in water. If applied to land, most chromium remains in the uppe r five centimeters of soil. Most chromium in surface waters is present i n parti culate form as sediment. Airborne chromium particles are relativel y unreactive and are removed from the air through wet and dry deposition. The precipitated chromium from the air enters surface water or soil. Chromium bioa ccumulates in plants and animals, with an observed bioaccumulatio n factor of 1,000,000 in snails.

Carbonyl Sulfide (CAS: 463-58-1)

So urces. Carbonyl sulfide is the largest volume chemical released to the air by the inorganic chemicals industry. Carbonyl sulfide is primarily generated by a relatively small number of facilities hydrolyzing ammonium or potassium thiocyanate during the manufacturing of inorganic pigments and dyes. 58

Toxicity. Exposure to low to moderate concentrations of carbonyl sulfid e causes eye and skin irritation and adverse central nervous system effects such as giddiness, headache, v ertigo, amnesia, confusion, and unconsciousness. If ingested, gas trointestinal effects include profuse salivation, nausea, vomiting and diarrhea. Moderate carbonyl sulfide poisoning also causes rapid breathing and heartbeat, sweating, weakness, and muscle cramps. Exposure to ver y

September 1995 45 SIC 281Sector Notebook Project Inorganic Chemicals

high c oncentrations of carbonyl sulfide causes sudden collapse
, unconsciousness, and death from sudden respiratory para lysis. Recovery from sublethal exposure i s slow, but generally complete. Degradation products of carbonyl sulfide (especially hydrogen sulfide) can resul t in toxic symptoms and death.

Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic.

En vironmental Fate. If released to soil or surface waters, carbonyl sulfide will rapidly volatilize. It is not expected to adsorb to soil sediments or organic
matt er nor is it expected to bioconcentrate in fish and aquatic organisms

. Ca rbonyl sulfide is hydrolyzed in water to carbon dioxide and hydroge n sulfide

. Carbonyl sulfide is expected to have a long residence time in th e atmospher e. Atmospheric removal of carbonyl sulfide may occur by slo w reaction s with other gases, and may also occur through adsorption by plants and soil microbes.

Manganese and Manganese Compounds (CAS: 7439-96-5; 20-12-2)

Sources. Manganese is both a product and chemical intermediate of th e inorganic chemical industry. Manganese is used as a purifying and scavenging agent in metal p roduction, as an intermediate in aluminum production and as

a const ituent of non-ferrous alloys to improve corrosion resistance an d hardness. 59

Toxicity. There is cur rently no evidence that human exposure to manganese at levels commonly o bserved in ambient atmosphere results in adverse health effects. However, recent EPA review of the fuel additive MM T (methylcyclopentadienyl m anganese tricarbonyl) concluded that use of MMT in gasoline could lead to ambie nt exposures to manganese at a level sufficient to cause adverse neurological effects in humans.

Chronic manganese poisoning bears some similarity to chronic lead poisoning. Occurring via inhalation of manganese dust or fumes, it primarily involves the

cen tral nervous system. Early symptoms include languor, speec h disturbances, sle epiness, and cramping and weakness in legs. A stolid masklike appeara nce of face, emotional disturbances such as absolute detachment broken by uncontrollable laughter, euphoria, and a spastic gait with a tendency to fall while walking are seen in more advanced cases. Chroni c mangan ese poisoning is reversible if treated early and exposure stopped

. Pop ulations at greatest risk of manganese toxicity are the very young an d those with iron deficiencies.

September 1995 46 SIC 281Sector Notebook Project Inorganic Chemicals

Ecologicall y, although manganese is an essential nutrient for both plants and animals, in excessive concentrations manganese inhibits plant growth.

Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic.

Envir onmental Fate. Manganese is an essential nutrient for plants an d animals. As such, m anganese accumulates in the top layers of soil or surface
water sediments and cycles between the soil and living organisms. It occurs mainl y as a solid under environmental conditions, though may also b e transported in the atmosphere as a vapor or dust

Ammonia (CAS: 7664-41-7)

Sources. Ammonia is used in many chemical manufacturing processes and is the building block for all synthetic nitrogen products. Its prevalence and its volatile and water solub le characteristics allow it to be readily released to the air and water. In the inorganic chemical manufacturing industry, ammonia can be either a feedstock or a by-product. Some of the more common inorganic chem ical industry processes using or producing ammonia include th e

ma nufacturing of: ammonium chloride, ammonium hydroxide, ammoniu m thiosulfate, ammonium nitrate, hydrazine, and hydrogen cyanide.

Toxicity. Anhydrous ammonia is irritating t o the skin, eyes, nose, throat, and upper respi ratory system. Ecologically, ammonia is a source of nitrogen (an essential element for aquatic plant growth), and may therefore contribute to

eu trophication of standing or slow-moving surface water, particularly i n nitrogen-limited waters such as the Chesapeake Bay. In addition, aqueou s ammonia is moderately toxic to aquatic organisms.

Carcinogenicity. There is currently no evidence to suggest that this chemical is carcinogenic.

En vironmental Fate. Ammonia combines with sulfate ions in th e atmosphere and is washed out by rainfall, resu lting in rapid return of ammonia
to the soil and surface waters. Ammonia is a central compound in th e

en vironmental cycling of nitrogen. Ammonia in lakes, rivers, and streams is converted to nitrate.

Physical Properties. Ammonia is a cor rosive and severely irritating gas with a pungent odor.

IV.C. Other Data Sources

September 1995 47 SIC 281Sector Notebook Project Inorganic Chemicals

In addi tion to chemicals covered under TRI, many other chemicals ar e released. For example, the EPA Office of A ir Quality Planning and Standards has c ompiled air pollutant emission factors for determining the total ai r emissions of priority pollutants (e.g., VOCs, SO
x , NO
x , CO, particulates) from many chemical industry sources.

Th e EPA Office of Air’s Aerometric Information Retrieval System (AIRS )
conta ins a wide range of information related to stationary sources of ai r pollution, including th e emissions of a number of air pollutants which may be of concern within a particular industry. Wit h the exception of volatile organic

com pounds (VOCs), there is little overlap with the TRI chemicals reporte d abo ve. Exhibit 15 summarizes annual releases of carbon monoxide (CO)
, nitrogen dioxide (NO 2 ), pa rticulate matter of 10 microns or less (PM 10 ), total
pa rticulate (PT), sulfur dioxide (SO2) and volatile organic compound s (VOCs).

September 1995 48 SIC 281Sector Notebook Project Inorganic Chemicals


## Exhibit 15: Pollutant Releases (short tons/year)

Industry Sector CO NO 2 PM 10 PT SO 2 VOC

Metal Mining 5,391 28,583 39,359 140,052 84,222 1,283
Nonmetal Mining 4,525 28,804 59,305 167,948 24,129 1,736

Lumber and Wood Production 123,756 42,658 14,135 63,761 9,419 41,423

Furniture and Fixtures 2,069 2,981 2,165 3,178 1,606 59,426
Pulp and Paper 624,291 394,448 35,579 113,571 541,002 96,875
Printing 8,463 4,915 399 1,031 1,728 101,537
Inorganic Chemicals 166,147 103,575 4,107 39,062 182,189 52,091
Organic Chemicals 146,947 236,826 26,493 44,860 132,459 201,888
Petroleum Refining 419,311 380,641 18,787 36,877 648,155 369,058

Rubber and Misc. Plastics 2,090 11,914 2,407 5,355 29,364 140,741

Stone, Clay and Concrete 58,043 338,482 74,623 171,853 339,216 30,262

Iron and Steel 1,518,642 138,985 42,368 83,017 238,268 82,292

Nonferrous Metals 448,758 55,658 20,074 22,490 373,007 27,375

Fabricated Metals 3,851 16,424 1,185 3,136 4,019 102,186
Computer and Office Equipment 24 0 0 0 0 0

Electronics and Other Electrical Equipment and Components 367 1,129 207 293 453 4,854

Motor Vehicles, Bodies, Parts and Accessories 35,303 23,725 2,406 12,853 25,462 101,275

Dry Cleaning 101 179 3 28 152 7,310

Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.

September 1995 49 SIC 281Sector Notebook Project Inorganic Chemicals

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 in dustrial categories. It is provided to give a general

sense as to the relative scale of releases and transfers within each secto r profiled under this project. Please note that the following figure and table do
not conta in releases and transfers for industrial categories that are no t incl uded in this project, and thus cannot be used to draw conclusion s regard ing the total release and transfer amounts that are reported to TRI

. Sim ilar information is available within the annual TRI Public Data Releas e Book.

Exhibit 16 is a graphical representation of a summary of t he 1993 TRI data for the inorganic chemicals industry and the other sectors profiled in separat e 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 rig ht axis. Industry sectors are presented in the order of increasin g total TRI releases. The graph is based on the data shown in Exhibit 17 and is meant to facilitate comparisons between the relative amounts of releases
, transfers, and releases per f acility both within and between these sectors. The reade r should note, however, that differences in the proportion of facilitie s captured by TRI exist betwe en industry sectors. This can be a factor of poor SIC matc hing and relative differences in the number of facilities reporting to TRI from the various sectors. In the case of the inorga nic chemicals, the 1993 TRI data presented here covers 555 facilities. These facilities listed SIC 2812- 2819 (inorganic chemicals) as a primary SIC code.

September 1995 50 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 16: Summary of 1993 TRI Data: Releases and Transfers by Industry

0 100 200 300 400 500 600 700Total Pounds (millions)

0 200,000 400,000 600,000 800,000 1,000,000Average Releases per Facility (lbs.)

36 24 32 27 25 2911 34 371 331 30 286 26 281 333, 334

Total Releases Total Transfers Avg. Releases/Facility

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

36 Electronic Equipment and Components 2911 Petroleum Refining 286 Organic Chemical Mfg.

24 Lumber and Wood Products 34 Fabricated Metals 26 Pulp and Paper

32 Stone, Clay, and Concrete 371 Motor Vehicles, Bodies, Parts, and Accessories 281 Inorganic Chemical Mfg.

27 Printing 331 Iron and Steel 333,334 Nonferrous Metals

25 Wood Furniture and Fixtures 30 Rubber and Misc. Plastics

September 1995 51 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 17: Toxics Release Inventory Data for Selected IndustriesAverage Releases+ Transfers perFacility (pounds)46,00024,000148,000147,000133,000104,000369,000706,000450,0003,088,000123,0001,825,0001,349,0001,052,000Industry sector not subject to TRI reporting.Industry sector not subject to TRI reporting.Industry sector not subject to TRI reporting.Source:U.S. EPA, Toxics Release Inventory Database, 1993.Total Releases+ Transfers(million lbs.)28.811.946.446.753.7163.4224.8218.1249.7481.9267.7695.3280.7438.41993 TRI TransfersAverageTransfersper Facility(pounds)4,0007,00013,00032,000116,00029,000239,000157,000126,0002,676,00083,0001,600,000472,000688,000TotalTransfers(million lbs.)2.23.54.210.247.145145.548.470417.5195.7609.598.2286.71993 TRI ReleasesAverageReleasesper Facility(pounds)42,00017,000135,000115,00017,00075,000130,000549,000324,000412,00030,000225,000877,000364,000TotalReleases(million lbs.)26.68.442.236.56.7118.479.3169.7179.664.37285.8182.5151.6# TRIFacilities6344913133184061,5796093095551562,363381208417SICRange3224252711-278936303712611-26312812-2819291134331333, 3342861-286910147216Industry SectorStone, Clay, and ConcreteLumber and Wood ProductsFurniture and FixturesPrintingElectronic Equip. andComponentsRubber and Misc. PlasticsMotor Vehicles, Bodies,Parts, and AccessoriesPulp and PaperInorganic Chem. Mfg.Petroleum RefiningFabricated MetalsIron and SteelNonferrous MetalsOrganic Chemical Mfg.Metal MiningNonmetal MiningDry Cleaning

September 1995 52 SIC 281Sector Notebook Project Inorganic Chemicals
V. POLLUTION PREVENTION OPPORTUNITIES

The best way to reduce pollution is to prevent it in the first place. Som e companies have creatively implemented pollution prevention techniques that improve efficiency and increase profits while at the same time minimiz e environm ental impacts. This can be done in many ways such as reducin g material inputs, re-engineering processes to reuse by-products, improvin g management practices, and employing substitute toxic chemicals. Som e smaller facilities are able to actually get below regulatory thresholds just b y reducing pollutant releases through aggressive pollution prevention policies.

In o rder to encourage these approaches, this section provides both genera l and company-specific descriptions of some pollu tion prevention advances that have been implemented within the inorgan ic chemical manufacturing 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 ow n pollution prevention projects. When possible, this section provide s in formation from real activities that can, or are being implemented by thi s sector -- including a discussion of associated costs, time frames, and expected
rates o f return. This section also provides the context (in terms of type o f industry and/or type of process affected) in which the pollution preventio n technique can effectively be used.

There hav e been numerous cases have where the chemical industry ha s simu ltaneously reduced pollutant outputs and operating costs throug h pollut ion prevention techniques. In the inorganic chemicals manufacturin g sector, however, economically viable pollution prevention opportunities are not as easily identified as in other sectors. The relati vely small size and limited resources of a typical inorganic chemical facility limits the number of feasible pollution pre vention options. The limited resources available to the industry el iminates many pollution prevention options that require significant capita l expenditures such as process modifications and process re design. In addition, the inorganic chemicals industry's products are primari ly commodity chemicals for which the manufacturing processes hav e been developed over many years. Commodit y chemical manufacturers redesign their processes infrequently so that red esign of the reaction process or equipment is unlikely in the shor t term. In a ddition, the industry's process equipment has been amortized over long periods o f time making cost-effective process equipment improvements

scarce. As a result, pollution prevention in the inorganic chemicals industry is somewhat restricted to the less costly options, such as minor proces s modifications, operationa l changes, raw material substitutions, and recycling.

Pollution prevention in the chemical industry in process specific. As such it is diffic ult to generalize about the relative merits of different pollutio n prevention strategies. The age and size of the facility, and the type an d

September 1995 53 SIC 281Sector Notebook Project Inorganic Chemicals number of its processes will determine t he most effective pollution prevention strategy. Brief descriptions of some of the mo re widespread, general pollution
preven tion techniques found to be effective at inorganic chemicals facilitie s are provided below. Many of these pollution prevention opportunities can be applied to the petrochemical industry as a whole due to the many simila r processes found throughout the indus try. It should be noted that many of the ideas identified below as pollution prevention opport unities, aimed at reducing
wast es and reducing materials use, have been carried out by the chemical s manufa cturing industry for many years as the primary means of improvin g process efficiencies and increasing profits.

In chlor-alkali production, pollution prevention options have bee n demons trated for both the mercury cell and diaphragm cell processes ; however, t he best opportunity to reduce pollutant outputs, conserve energy, and reduce costs in the chlor-alkali industry are in the conversion to th e membra ne cell process. In terms of energy consumption, the membrane cell
proce ss uses only about 77 percent of that of the mercury cell process an d ab out 90 percent of that of the diaphragm cell process. The membrane cel l
process also generates significantly less airborne and waterborne pollutant s and solid wastes (see Section III.B. - Raw Material Inputs and Pollutio n Outputs).

Substitute raw materials. The substitution or eliminatio n of some of the raw material s used in the manufacturing of inorganic chemicals can result i n substantial waste reductio ns and cost savings. Because impurities in the feed
stream can be a major contributor to waste generation, one of the mos t

common su bstitutions is to use a higher purity feedstock. This can b e accomplished either b y working with suppliers to get a higher quality feed or by installing purification equipment. Raw materials can also be substitute d with less toxic and less water soluble materials to re duce water contamination,

an d with less volatile materials to reduce fugitive emissions. Sometime s cert ain raw materials can be eliminated all together. The need for ra w mate rials that end up as wastes should be reexamined to determine if ra w materials can be eliminated by modifying the process and improving control.

Improv e reactor efficiencies. Since the chemical products are primaril y created inside the process reactor, it can be the primary source for waste (offspec) materials. One of the most important parameters dictating the reactor effici ency is the quality of mixing. A number of techniques can be used t o improve mixing, such as installing baffles in the reactor, a higher rpm motor for the agitator, a different m ixing blade design, multiple impellers, and pump recirculation. The method used to introdu ce feed to the reactor can also have an effect on the quality of mixing. A feed dis tributor can be added to equalize residence t ime through the reactor, and feed streams can be added at a point

September 1995 54 SIC 281Sector Notebook Project Inorganic Chemicals
i n

time closer to the ideal reactant concentration. This will avoid secondary reactions which form unwanted by-products.

Improve cat alyst. The catalyst plays a critical role in the effectiveness o f chemi cal conversion in the reactor. Alternative chemical makeups an d phy sical characteristics can lead to substantial improvements in th e eff ectiveness and life of a catalyst. Different catalysts can also eliminate byproduct formation. Noble metal catalysts can replace heavy metal catalysts
to eliminate wastewater contaminated with heavy metals. The consumption of catalysts can be reduced by using a more active form and emissions an d effluents generated during catalyst activation can be eliminated by obtaining the catalyst in the active form.

Opti mize processes. Process changes that optimize reactions and ra w materials use can reduce waste generation and releases. Many larger facilities are using computer controlled systems which analyze the process continuously and respond more quickly and accurately than manual control systems. These syst ems are often capable of automatic startups, shutdowns, and produc t chan geover which can bring the process to stable conditions quickly
, minimizing the generation of off-spec wastes. Other process optimizatio n tech niques include: equalizing the reactor and storage tank vent lines during batch filling to minimi ze vent gas losses; sequencing the addition of reactants and reagents to optimize yields and lower emissions; and optimizin g

se quences to minimize washing operations and cross-contamination o f subsequent batches.

Reduce heat exchanger wastes and inefficiencies. Heat exchangers ar e oft en the source of significant off-spec product wastes generated b y overheating the product closest to the tube walls. T he best way to reduce offspec product from overheating is by reducing the heat exchanger tube wal l
te mperature. This can be accomplished through a number of technique s which do not reduce the overall heat transferred such as: reducing the tube wall temp erature and increasing the effective surface area of the hea t exchang er; using staged heating by first heating with waste heat, then lo w press ure steam, followed by superheated high pressure steam; monitor an d prevent fo uling of the heat exchanger tubes so that lower temperature hea t

sourc es can be used; using noncorroding tubes which will foul less quickl y than tubes that corrode.

Imp rove wastewater treatment and recycling. A large portion of th e inorganic chemical industry's pollutants leave the facilities as wastewater or

was tewater treatment system sludge. Improved treatment and minimization of

wastewater are effective pollution prevention opportunities that often do
not require significant changes to the industrial processes. Moder n waste water treatment technologies such as ion exchange, electrolytic cells
,

September 1995 55 SIC 281Sector Notebook Project Inorganic Chemicals

rev erse osmosis, and improved distillation, evaporation, and dewatering can often be added to existing treatment sys tems. Wastewater streams containing

ac ids or metals can be concentrated enough to be sold commercially as a pr oduct by slightly altering the manufacturing process, adding processin g steps, and segregating wastewater streams. Furthermore, many wastewater
streams can be reused within the same or different processes, significantl y reducing discharges to the wastewater treatment system. An ion exchang e system in stalled in a mercury cell chlor-alkali plant reduced mercury by 9 9 perce nt in the facility's effluent. An inorganic chemicals plant makin g pho tochemistry solution generated a wastewater containing silver

. Electrolytic cells were ins talled that recovered 98 percent of the silver and an evaporator was added that concentrated the remaining liquid for disposa l resulting in a 90 percent reduction in waste volume.

Preve nt leaks and spills. The elimination of sources of leaks and spills can be a very cost effective pollution prevention oppor tunity. Leaks and spills can be prev ented by installing seamless pumps and other "leakless" components, mainta ining a preventative maintenance program, and maintaining a lea k detection program.

Impro ve inventory management and storage. Good inventor y management can reduce the generation of wastes by preve nting materials from exceedin g their shelf life, preventing materials from being left over or no t needed, and re ducing the likelihood of accidental releases of stored material. Designating a materials storage area, limiting traffic through the area, an d giving one person the responsibility to maintain and distribute materials can reduce materials use, and the contamination and dispersal of materials.

Exhibit 18 summarizes the above pollution prevention opportunities an d provid es additional examples provided by the Chemical Manufacturer s Association.

September 1995 56 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 18: Process/Product Modifications Create Pollution Prevention Opportunities

Area Potential Problem Possible Approach

Byproducts Coproducts

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. PIncrease 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 carry over 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

Develop a more robust catalyst or support. P

Provide in situ activation with appropriate processing/activation facilities.

September 1995 57 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

Catalysts (cont’d)

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

P

Use a nonpryrophoric catalyst. Minimize amount of water required to handle and store safely.

P

Study and identify catalyst effluents versus offsite regeneration or disposal.

deactivation 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

P

Improve reactor mixing/contacting to increase catalyst effectiveness. increased surface area can reduce catalyst loadings.

P

Use a more selective catalyst whichwill reduce the yield of undesired byproducts.

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.

September 1995 58 SIC 281Sector Notebook Project Inorganic Chemicals
Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

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

P

Explore heat integration opportunities (e.g., use waste heat to preheat materials and reduce the amount of combustion

P

Use thermocompressor to upgrade low-pressure 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. reactions.

P

Use a super heat 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.

required.)

September 1995 59 SIC 281Sector Notebook Project Inorganic Chemicals
Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

Process Conditions/ Configuration (cont’d)

Temperature (cont’d)

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 Use lower temperature (vacuum processing). P

Add vent condensers to recover vapors in storage tanks or process.

P

Add closed dome loading with vapor recovery condensers.

P

Equipment operating in vacuum

P

Minimize operating pressure.

P

Determine whether gases can be recovered, compressed, and reused or service is not a source of fugitives; however, leaks into the process require control when system is degassed.

require controls.

P

Improve metallurgy or provide coating or lining.

P

Neutralize corrosivity of materials

P

Improve metallurgy or provide coating or lining or operate in a less corrosive environment. contacting equipment.

P

Use corrosion inhibitors.

P

Improve metallurgy or provide coating or lining.

P

Equalize reactor and storage tank vent

P

Use materials with low viscosity. Minimize equipment roughness. lines.

P

Recover vapors through condenser, adsorber, etc.

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

September 1995 60 SIC 281Sector Notebook Project Inorganic Chemicals

Area Potential Problem Possible Approach

Process Conditions/ Configuration (cont’d)

Batch vs. Continuous Operations (cont’d)

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, absorbents, etc.) create wastes. Each chemical (including water) employed within the process introduces additional potential waste sources; the composition generated wastes also tends to become more complex.

P

High conversion with low yield results in wastes. P Sequence addition of reactants and reagents to optimize yields and lower

P

Design facility to readily allow maintenance so as to avoid unexpected equipment failure and resultant release. P

Optimize product manufacturing sequence to minimize washing operations and cross-contamination of subsequent batches.

emissions.

P

Keep it simple. Make sure all operations are necessary. More

P

Evaluate unit operation or technologies (e.g., separation) that do not require the addition of solvents or other nonreactant chemicals. operations and complexity only tend to increase potential emission and waste

sources.

P

Recycle operations generally improve overall use of raw materials and chemicals, thereby increasing the yield of desired products while at the same time reducing the generation of wastes. A case-in-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.

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

September 1995 61 SIC 281Sector Notebook Project Inorganic Chemicals

Process Conditions/ Configuration (cont’d)

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 reducing waste 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

P

Reformulate products by substituting different material or using a mixture of individual chemicals that meet end-use performance specifications. prevention.

Raw Materials

Purity PImpurities may produce unwanted byproducts and waste. Toxic impurities, even in trace amounts, can make a waste hazardous and therefore subject to strict and costly regulation.

P

Excessive impurities may require more processing and equipment to meet product specifications, increasing costs and potential for fugitive emissions, leaks, and spills. P Use higher purity materials.

P

Purify materials before use and reuse if practical.

P

Achieve balance between feed purity, processing steps, product quality, and waste generation. P

Use inhibitors to prevent side reactions.

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

September 1995 62 SIC 281Sector Notebook Project Inorganic Chemicals

Raw Materials (cont’d)

Purity (cont’d)

Vapor Pressure

Water Solubility P Specifying a purity greater than needed by the process increases costs and can generate more waste generation by the supplier.

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. P Specify a purity no greater than what the process needs.

P

Use pure oxygen.

P

Install 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

P

Minimize water usage.

P

Reuse wash water.

P

Determine optimum process conditions for phase separation. water by diking or covering areas.

P

Evaluate alternative separation technologies (coalescers, membranes, distillation, etc.)

September 1995 63 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

Raw Materials (cont’d)

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

P

Use less toxic material.

P

Reduce spills, leaks, and upset conditions through equipment and process control. releases.

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

P

Use returnable shipping containers or drums. material supply was shipped in without washing.

P

Use equipment and controls appropriate to the type of materials to control releases.

September 1995 64 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 18 (cont.): Process/Product Modifications Create Pollution Prevention Ops.

Area Potential Problem Possible Approach

Raw Materials (cont’d)

Handling and Storage (cont’d) P Large inventories can lead to spills, inherent safety issues and material expiration. PMinimize inventory by utilizing justin-time 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

P

Determine what changes in process conditions would lower waste prevention assessment.

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. Designing Pollution Prevention into the Process, Research, Development and Engineering

.

September 1995 65 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19: Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

Compressors, blowers, fans P Shaft seal leaks Piston rod seal leaks Vent streams P Seal-less designs (diaphragmatic, hermetic or magnetics)

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

necessary P

Use drip pans where

Controls P Shutdowns and Start-ups 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 two out of three affirmative responses) P Continuous versus batch

P

Optimize on-line run time

P

Optimize shutdown interlock inspection

P

Identify safety and

instruments and equipment frequency

environment critical

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

- temperature

- etc. - feed tray

- pressure

September 1995 66 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

Distillation (cont’d) P Impurities remain in process streams (cont’d)

P

Large amounts of contaminated water condensage from stream stripping P Insulate to prevent heat loss

P

Preheat column feed

P

Increase vapor line size to lower pressure drop

stripping agents P

Use reboilers or inert gas P Clean column to reduce fouling

steam P

Use higher temperature

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

Seal floors

P

Design for cleaning P

Segregate process sewer from storm sewer (diking)

P

Hard-pipe process streams to process sewer

P

Drain to sump

P

Route to waste treatment

P

Design for minimum rinsing

P

Design for minimum sludge

P

Provide vapor enclosure

P

Drain to process P Return samples to process

P

Use drip pans for maintenance activities P

Monitor stormwater discharge

P

Rinse to sump

P

Reuse cleaning solutions

September 1995 67 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

Heat exchangers

Piping P Increased waste due to high localized temperatures

P

Leaks to groundwater P

Contaminated materials due to tubes leaking at tube sheets

P

Furnace emissions

Fugitive emissions 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

Design equipment layout so P

Use welded tubes or double

Mount vertically

as to minimize pipe run 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

tube sheets with inert purge.

P

Use super heat of highpressure steam in place of a furnace

length

P

Eliminate underground piping or design for cathodic protection if necessary to install piping underground

P

Use welded fittings

P

Reduce number of flanges and valves P Select operating temperatures at or nearambient temperature whengenerally most desirable from a pollution prevention standpoint

P

Use lower pressure steam ever possible. These are

to lower temperatures

P

Monitor for corrosion and surfaces clean

P

Monitor for leaks

erosion P

Monitor exchanger fouling to correlate process

fouling, avoid conditions which rapidly foul exchangers

P

Use on-line tube cleaning techniques to keep tube

P

Paint to prevent external corrosion conditions which increase

September 1995 68 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

Piping (cont’d) P Leaks to groundwater Fugitive emissions (cont’d)

P

Releases when cleaning or purging lines P Use all welded pipe

P

Use "pigs" for cleaning P

Use secondary containment

P

Use spiral-wound gaskets

P

Use plugs and double valves for open end lines

P

Change metallurgy

P

Use lined pipe

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 Mechanical seal in lieu of packing

P

Use pressure transfer to eliminate pump

P

Low point drain on pump casing 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 Seal installation practices

P

Flush casing to process sewer for treatment P

Monitor for leaks

September 1995 69 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

Pumps (cont’d)

Reactors P Injection of seal flush

P

Poor conversion or fluid into process stream

performance due to inadequate mixing

P

Waste by-product formation P Use double mechanical seal

P

Static mixing with inert barrier fluid where

P

Add baffles practical

P

Change impellers

P

Provide separate reactor for converting recycle streams to P

Add horsepower

P

Add distributor

usable products P Increase the mean time

P

Add ingredients with between pump failures by:

optimum sequence - selecting proper seal material; - aligning well; - reducing pipe-induced stress; - maintaining seal lubrication

P

Optimize reaction conditions (temperature, P

Allow proper head space

effect

pressure, etc.) in reactor to enhance vortex

Relief Valve P Leaks

P

Fugitive emissions

P

Discharge to environment from over pressure

P

Frequent relief P Provide upstream rupture

P

Vent to control or recovery

P

Pump discharges to suction of pump

P

Use pilot operated relief disc

device

P

Thermal relief to tanks

P

Avoid discharge to roof areas to prevent contamination of rainwater

valve

P

Increase margin between design and operating pressure P Monitor for leaks and for

P

Monitor for leaks

P

Reduce operating control efficiency

pressure

P

Review system performance

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

September 1995 70 SIC 281Sector Notebook Project Inorganic Chemicals

Possible Approach

Equipment Environment Problem Related Related Potential Design Operational

Sampling P Waste generation due to P On line in situ analyzers P Reduce number and size sampling (disposal, of samples required containers, leaks, fugitives, P System for return to process etc.) P Sample at the lowest P

Closed loop possible temperature

P

Drain to sump P Cool before sampling

Tanks P Tank breathing and P Cool materials before P Optimize storage working losses storage conditions to reduce losses P

Insulate tanks

P

Vent to control device (flare, condenser, etc.)

P

Vapor balancing

P

Floating roof

P

Leak to groundwater P All aboveground (situated P Monitor for leaks and

P

Large waste heel P Design for 100 percent de- P Recycle to process if P

Floating roof

P

Higher design pressure

so bottom can routinely be corrosion checked for leads)

P

Secondary containment

P

Improve corrosion resistance

inventory practical
Vacuum Systems P Waste discharge from jets P Substitute mechanical P Monitor for air leaks
vacuum pump

P

Evaluate using process fluid P Recycle condensate to for powering jet process

September 1995 71 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 19 (cont.): Modifications to Equipment Can Also Prevent Pollution

Equipment Environment Problem Potential Possible Approach

Related Design Related Operational

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. Designing Pollution Prevention into the Process, Research, Development and Engineering

.

It is critical to emphas ize that pollution prevention in the chemical industry is
proc ess specific and oftentimes constrained by site-specific considerations

. As such, it is difficult to generalize about the relative merits of differen t pollution prevention strategies. The age, size, and purpose of the plant will in fluence the most effective pollution prevention strategy. Commodit y chemical manufacturers redesi gn their processes infrequently so that redesign of

the reaction process or equipment is unlikely in the short term. Here
, oper ational changes are the most feasible response. Specialty chemica l manufac turers are making a greater variety of chemicals and have mor e process and design flexibility. Incorporating changes at the earlier research and development phases may be possible for them.

September 1995 72 SIC 281Sector Notebook Project Inorganic Chemicals
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 regulations

The desc riptions within Section VI are intended solely for genera l information

. Depending upon the nature or scope of the activities at a particul ar facility, these summaries may or may not necessarily describe al l applicable environmental requirements. Moreover, they do not constitut e fo rmal interpretations or clarifications of the statutes and regulations. Fo r fur ther information, readers should consult the Code of Federal Regulations and other state or local agencies. EPA Hotline contacts are also provided for each major statute.

VI.A. General Description of Major Statutes

Resource Conservation And Recovery Act

The Resource Conservation And Recovery Act (RCRA) of 1976 whic h amended the Solid Waste Disposal Act, addresses solid (Subtitle D) an d ha zardous (Subtitle C) waste management activities. The Hazardous an d Soli d Waste Amendments (HSWA) of 1984 strengthened RCRA’s wast e managem ent provisions and added Subtitle I, which governs undergroun d storage tanks (USTs).

Regulatio ns promulgated pursuant to Subtitle C of RCRA (40 CFR Part s 260-299) establish a “cradle-to-grave” system governing hazardous wast e from the point of generation to disposal. RCRA ha zardous wastes include the
sp ecific materials listed in the regulations (commercial chemical products
, designa ted with the code "P" or "U"; hazardous wastes from specifi c industries/sources, designated with the code "K"; or hazardous wastes from non-specific sources, designated with the c ode "F") or materials which exhibit a hazardous waste characteristic (ignitability, corrosivit y, reactivity, or toxicity and designated with the code "D").

Regulate d entities that generate hazardous waste are subject to wast e accumulation, manifesting, and record keeping standards. Facilities that treat, store, or dispose of hazardous waste must obtain a permit, either from EPA or from a State agency which EPA has authorized to impl ement the permitting
prog ram. Subtitle C permits contain general facility standards such a s

September 1995 73 SIC 281Sector Notebook Project Inorganic Chemicals contingency plans, emergency procedures, record keeping and reportin g requirements, financial assurance mechanisms, and unit-specific standards

. RCRA also contains provisions (40 CFR Part 264 Subpart S and §264.10) for conducting corrective actions which govern the cleanup of releases o f ha zardous waste or constituents from solid waste management units a t RCRA-regulated facilities.

Althou gh RCRA is a Federal statute, many States implement the RCR A program. Currently, EPA has delegated its authority to implement variou s provisions of RCRA to 46 of the 50 States.

Most RCRA requirements are not in dustry specific but apply to any company that transports, treats, stores, or disp oses of hazardous waste. Here are some important RCRA regulatory requirements:

C Ide ntification of Solid and Hazardous Wastes (40 CFR Part 261) lays out the procedure every generator should follow to determin e whether the material created is considered a hazardous waste, soli d waste, or is exempted from regulation.

C Standards for Generators o f Hazardous Waste (40 CFR Part 262) establishes the responsibilities of hazardous waste generators including obtaini ng an ID number, preparing a manifest, ensuring prope r pack aging and labeling, meeting standards for waste accumulatio n units, and record keeping and reporting re quirements. Generators can accumulate hazardous waste for up to 90 days (or 180 days depending on the amount of waste generated) without obtaining a permit.

C Land Disposal Restrictions (LDRs) are regulations prohibiting the dispos al of hazardous waste on land without prior treatment. Under the LDRs (40 CFR 268), materials must meet land disposal restriction (LDR) treatment standards prior to placement in a RCRA lan d disposal unit (landfill, land treatment unit, waste pile, or surfac e impoun dment). Wastes subject to the LDRs include solvents
, electroplating wastes, heavy metals, and acids. Generators of waste subjec t to the LDRs must provide notification of such to th e designat ed TSD facility to ensure proper treatment prior to disposal.

C Used Oil s torage and disposal regulations (40 CFR Part 279) do not define Used Oil Management Standards impose managemen t requirements affecting the storage, transportation, burning
, proce ssing, and re-refining of the used oil. For parties that merel y generate used oil, regulations e stablish storage standards. For a party consider ed a used oil marketer (one who generates and sell s

September 1995 74 SIC 281Sector Notebook Project Inorganic Chemicals
of f-specification used oil directly to a used oil burner), additiona l tracking and paperwork requirements must be satisfied.

C Tanks and Containers used to store hazardous waste with a hig h vol atile organic concentration must meet emission standards unde r RCRA. Regulations (40 CFR Part 264-265, Subpart CC) requir e gen erators to test the waste to determine the concentration of th e waste, to satisfy tank and container emissions standards, and t o inspect a nd monitor regulated units. These regulations apply to al l facilities who store such waste, including generators operating under the 90-day accumulation rule.

C Underground Storage Tanks (USTs) containing petroleum an d hazardous substance are regulated under Subt itle I of RCRA. Subtitle I reg ulations (40 CFR Part 280) contain tank design and releas e dete ction requirements, as well as financial responsibility an d

cor rective action standards for USTs. The UST program als o establishes increasingly stringent standards, including upgrad e requirements for existing tanks, that must be met by 1998.

C Boilers and Industrial Furnaces (BIFs) that use or burn fue l

co ntaining hazardous waste must comply with strict design an d
oper ating standards. BIF regulations (40 CFR Part 266, Subpart H) address unit design, provide performa nce standards, require emissions monitoring, and restrict the type of waste that may be burned.

EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds t o questio ns and distributes guidance regarding all RCRA regulations. Th e RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding Federal holidays.

Comprehensive Environmental Response, Compensation, And Liability Act

Th e Comprehensive Environmental Response, Compensation, and Liabilit y Act (CERCLA), a 1980 law commonly kn own as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances tha t may enda nger public health, welfare, or the environment. CERCLA als o enables EPA to force parties responsible for environmental contamination to clean it up or to reimburse the Superfund for response costs incurred by EPA. The Sup erfund Amendments and Reauthorization Act (SARA) of 198 6 revise d various sections of CERCLA, extended the taxing authority for th e 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 reporti ng regulations (40 CFR Part 302) d irect the person in charge of a facility to report to the Nationa l

September 1995 75 SIC 281Sector Notebook Project Inorganic Chemicals Response Center (NR C) any environmental release of a hazardous substance wh ich exceeds a reportable quantity. Reportable quantities are defined an d listed in 40 CFR §302.4. A rel ease 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 Hazard ous Substances Pollution Contingency Plan (NCP) (40 CFR Part 3 00). The NCP includes provisions for permanent cle anups, known as remedial actions, and other cleanups referred to a s "removals. " EPA generally takes remedial actions only at sites on th e National Priorities List (NPL), which currently includes approximately 1300 sites. Both EPA and states can act at other sites; however, EPA provide s respo nsible parties the opportunity to conduct removal and remedial actions and encourag es community involvement throughout the Superfund response
process.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, answers questions and references guidance pertaining to the Superfund progra m. The CERCLA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excludin g Federal holidays.

Emergency Planning And Community Right-To-Know Act

The Sup erfund Amendments and Reauthorization Act (SARA) of 198 6

cre ated the Emergency Planning and Community Right-to-Know Ac t (EPCRA, a lso known as SARA Title III), a statute designed to improv e community access to inform ation about chemical hazards and to facilitate the dev elopment of chemical emergency response plans by State and loca l
govern ments. EPCRA required the establishment of State emergenc y

re sponse commissions (SERCs), responsible for coordinating certai n

em ergency response activities and for appointing local emergency plannin g committees (LEPCs).

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four types of reporting obligations for facilities which store or manage specifie d chemicals:

C EPCRA §302 requires fac ilities to notify the SERC and LEPC of the
presence of any "extremely hazardous substance" (the list of suc h substances is in 40 CFR Part 355, Appendices A and B) if it has such substance in excess of the substance's th reshold planning quantity, and directs the facility to appoint an emergency response coordinator.

C EPCRA §304 re quires the facility to notify the SERC and the LEPC in the ev ent of a release exceeding the reportable quantity of a

September 1995 76 SIC 281Sector Notebook Project Inorganic Chemicals
CERC LA hazardous substance or an EPCRA extremely hazardou s substance.

C EPCR A §311 and §312 require a facility at which a hazardou s chem ical, as defined by the Occupational Safety and Health Act, i s present in an amount exceeding a specified threshold to submit to the SE RC, LEPC and local fire department material safety data sheet s (MSDSs) or lists of MSDS's and hazardous chemical inventory forms (also known as Tier I and II forms). This information helps the local government res pond in the event of a spill or release of the chemical.

C EPCRA §313 requires manufac turing facilities included in SIC codes 20 th rough 39, which have ten or more employees, and whic h 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 vario us facilities and environmental

me dia, and allows EPA to compile the national Toxic Releas e Inventory (TRI) database.

All inf ormation submitted pursuant to EPCRA regulations is publicl y accessible, unless protected by a trade secret claim.

EPA's EPCRA Hotline, at (800) 535-0202, ans wers questions and distributes guidance regarding the emergency planning and community right-to-know regulations. The EPCRA Hotl ine operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding Federal holidays.

Clean Water Act

The primary objective of the Federa l Water Pollution Control Act, commonly referred to as the Clean Water Act (CWA), is to restore and maintain th e chem ical, physical, and biological integrity of the nation's surface waters

. Pollutants regulated under the CWA include "priority" pollutants, including variou s toxic pollutants; "conventional" pollutants, such as biochemica l oxygen demand (BOD ), total suspended solids (TSS), fecal coliform, oil and grease, and pH; and "non-conventional" pollutants, inclu ding any pollutant not identified as either conventional or priority.

The CWA regulates both direct and indirect discharges. The Nationa l Pollutant Dischar ge Elimination System (NPDES) program (CWA §402) controls direct discharges into navigable waters. Direct discharges or "point

sour ce" discharges are from sources such as pipes and sewers. NPDE S pe rmits, issued by either EPA or an authorized State (EPA has authorize d approxi mately forty States to administer the NPDES program), contai n indus try-specific, technology-based and/or water quality-based limits, an d

September 1995 77 SIC 281Sector Notebook Project Inorganic Chemicals
establi sh pollutant monitoring requirements. A facility that intends t o discharge into the nation's waters must obtain a permit prior to initiating its discharge. A permit applicant must provide quantitative analytical dat a identifying the types of pollutants present in the facility's effluent. The permit will then set forth the conditions and efflue nt limitations under which a facility may make a discharge.

A NPDES permit may also includ e discharge limits 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 standard s, unlike the technological standards, generally do not take int o account technological feasibility or costs. Wate r 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 whic h
propose aquatic life and human health criteria for many of the 126 priorit y pollutants.

Storm Water Discharges

In 1987 the CWA was amended to require EPA to establish a program t o address storm water discharges

. In response, EPA pr omulgated the NPDES storm water permit application regulations. St orm water discharge associated with ind ustrial activity means the discharge from any conveyance which i s used for collecting and conveying storm water and which is directly related to manufa cturing, processing, or raw materials storage areas at an industria l
p l ant (40 CFR 122.26(b)(14)). These regulations require that facilities with the follo wing storm water discharges apply for an NPDES permit: (1) a discharge associated with industrial activity; (2) a discharge from a large or medium muni cipal 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 w ater discharge associated with industrial activity" means a storm water discharge from one of 11 categories of industrial activity defined at 40 CFR 122.26. Six of the categories are defined by SIC codes while the other five are identified through narrative descriptions of the regulate d ind ustrial activity. If the primary SIC code of the facility is one of thos e identified in the regulations, the facility is subject to the storm water permit application requi rements. If any activity at a facility is covered by one of the five narrat ive categories, storm water discharges from those areas where the activi ties occur are subject to storm water discharge permit applicatio n requirements. Those facilities/activities that are subject to storm water discharge permi t applic ation requirements are identified below. To determine whether a particular facility falls within one of these categories, the regulation should be consulted.

September 1995 78 SIC 281Sector Notebook Project Inorganic Chemicals

Category i : Facilitie s subject to storm water effluent guidelines, new source performance standards, or toxic pollutant effluent standards.

Cat egory ii: Facilities classified as SIC 24-lumber and wood product s (except wood kitchen cabinets); SIC 26-paper and allied products (excep t paperboard containers and products); SIC 28-chemicals and allied products (ex cept drugs and paints); SIC 291-petroleum refining; and SIC 311-leather tanning and finishing.

Ca tegory iii: Facilities classified as SIC 10-metal mining; SIC 12-coa l mining; SIC 13-oil and gas extraction; and SIC 14-nonmetal lic mineral mining.

Category iv: Hazardous waste treatment, storage, or disposal facilities.

Category v: Landfills, land applicat ion sites, and open dumps that receive or have received industrial wastes.

Category vi: Faci lities 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 (excep t public war ehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water transportation; SIC 45-transportation by air; and SIC 5171-petroleum bul k storage stations and terminals.

Category ix: Sewage treatment works.

Category x: Construction activities except operations that result in th e 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 relate d produ cts; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture

a n d fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
pap er and paperboard products; SIC 27-printing, publishing, and allie d industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and alli ed products; SIC 30-rubber and plastics; SIC 31-leather and leathe r products (e xcept leather and tanning and finishing); SIC 323-glass products; SIC 34-fabricated metal products (except fabricated str uctural metal); SIC 35- indus trial and commercial machinery and computer equipment; SIC 36

- elect ronic and other electrical equipment and components; SIC 37

-

September 1995 79 SIC 281Sector Notebook Project Inorganic Chemicals

tr ansportation equipment (except ship and boat building and repairing); SIC 38-meas uring, analyzing, and controlling instruments; SIC 39-miscellaneous manufacturing industries; and SIC 4221-4225-public warehousing an d storage.

Pretreatment Program

Another type of disc harge that is regulated by the CWA is one that goes to a publi cly-ownedtreatment works (POTWs). The national pretreatmen t program (CWA §307(b)) controls the indirect discharge of pollutants t o POTWs by "industrial users." Facilities regulated under §307(b) must meet certain pretreatment standards. The goal of the pretreatment program is t o protect municipal wastewater treatment plants from damage that may occur when haza rdous, toxic, or other wastes are discharged into a sewer syste m and to protect the quality of sludge generated by these plants. Discharges to a POTW are regulated primarily by the POTW itself, rather than the State or EPA.

EP A has developed technology-based standards for industrial users o f POTWs. Different standards apply to existing and new sources within each catego ry. "Categorical" pretreatment standards applicable to an industry on

a nationwide basis are developed by EPA. In addition, another kind o f pretreatment standard, "local limits," are developed by the POTW in order to assist the POTW in achieving the effluent limitations in its NPDES permit.

Rega rdless 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.

EPA’s Office of W ater, at (202) 260-5700, will direct callers with questions abo ut the CWA to the appropriate EPA office. EPA also maintains a biblio graphic database of Office of Water publications which can b e accessed through the Groun d Water and Drinking Water resource center, at (202) 260-7786.

Safe Drinking Water Act

Th e Safe Drinking Water Act (SDWA) mandates that EPA establis h regulations to protect human health from contaminants i n drinking water. The la w authorizes EPA to develop national drinking water standards and t o create a joint Federal-State system to ensure compliance with these standards. The SDWA also directs EPA to protect underground sources of drinkin g water through the control of underground injection of liquid wastes.

EPA has developed primary and secondary drinking water standards under its SDWA authority. EPA and authorized States enforce the primary drinkin g

September 1995 80 SIC 281Sector Notebook Project Inorganic Chemicals

water standards, which are, contaminant-specific concentration limits tha t apply to certain public drinking water supplies. Primary drinking wate r stan dards consist of maximum contaminant level goals (MCLGs), which are

non-e nforceable health-based goals, and maximum contaminant level s (MCLs), which are enforceable limits set as close to MCLGs as possible
, considering cost and feasibility of attainment.

The SDWA Underground Injection Contr ol (UIC) program (40 CFR Parts 144-148) is a permit program which protects undergrou nd sources of drinking
wate r by regulating five classes of injection wells. UIC permits includ e design, operating, inspection, and monitoring requirements. Wells used t o inject h azardous wastes must also comply with RCRA corrective actio n standa rds in order to be granted a RCRA permit, and must meet applicabl e RCRA land disposal restrictions standards. The UIC permit program i s primari ly State-enforced, since EPA has authorized all but a few States t o administer the program.

The SDWA also provides for a Federally-implemented Sole Source Aquifer program, which prohibits Federal f unds from being expended on projects that
may cont aminate the sole or principal source of drinking water for a give n area, and for a State-imp lemented Wellhead Protection program, designed to protect drinking water wells and drinking water recharge areas.

EPA’s Safe Drinking Water Hotline, at (800) 426-4791, answers questions

an d distributes guidance pertaining to SDWA standards. The Hotlin e operates from 9:00 a.m. throug h 5:30 p.m., ET, excluding Federal holidays.

Toxic Substances Control Act

The Toxic Su bstances Control Act (TSCA) granted EPA authority to create

a

regulatory framework to collect data on chemicals in order to evaluate
, assess, mitig ate, and control risks which may be posed by their manufacture, processing, and use. TSC A provides a variety of control methods to prevent chemicals from posing unreasonable risk.

TSCA standards may apply at any point during a chemical’s life cycle. Under TSCA § 5, EPA has established an inventory of chemical substances. If a chemical is not already on the inventory, and has not been excluded by TSCA,

a prem anufacture notice (PMN) must be submitted to EPA prior t o manuf acture or import. The PMN must identify the chemical and provid e available information on health and environmental effects. If available data are not sufficient to evaluate the chemicals effects, EPA can impose restrictions pending the development of information on its health and environmenta l effects. EPA can also restrict significant new uses of chemicals based upon factors such as the projected volume and use of the chemical.

September 1995 81 SIC 281Sector Notebook Project Inorganic Chemicals Under TSCA §6, EPA can ban the manufacture or distribution in commerce, li mit the use, require labeling, or place other restrictions on chemicals tha t pose unr easonable risks. Among the chemicals EPA regulates under § 6 auth ority are asbestos, chlorofluorocarbons (CFCs), and polychlorinate d biphenyls (PCBs).

EPA’s TSCA Assistance Information Service, at (202) 554-1404, answer s questions and distributes guidance pertaining to Toxic Substances Control Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET, excluding Federal holidays.

Clean Air Act

The Clean Air Act (CAA) and its amendments, including the Clean Air Ac t Ame ndments (CAAA) of 1990, are designed to “protect and enhance th e nat ion's air resources so as to promote the public health and welfare and the produc tive 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 enforc e these sta ndards through a variety of mechanisms. Under the CAAA, man y fa

cilities will be required to obtain permits for the first time. State and local
g o vernments oversee, manage, and enforce many of the requirements of the CAAA. CAA regulations appear at 40 CFR Parts 50 through 99.

Pu rsuant to Title I of the CAA, EPA has established national ambient ai r quality sta ndards (NAAQSs) to limit levels of "criteria pollutants," including carbon monoxide, lead, nitrogen dioxide, parti culate matter, ozone, and sulfur dio xide. Geographic areas that meet NAAQSs for a given pollutant ar e classified as attainment areas; those that do not meet NAAQSs are classified

as non-attainment areas. Under §110 of the CAA, each State must develop a S tate Implementation Plan (SIP) to identify sources of air pollution and to determine what reductions are required to meet Federal air quality standards.

Title I a lso authorizes EPA to establish New Source Performance Standards (NSPSs), which are natio nally uniform emission standards for new stationary sources falling within particular industrial cat egories. NSPSs are based on the pollution control technology available to that c ategory of industrial source but allow the affected indus tries the flexibility to devise a cost-effective means of reducing emissions.

Under Title I, EPA est ablishes and enforces National Emission Standards for Hazardous Air Pollutants ( NESHAPs), nationally uniform standards oriented towards controlling particular hazardous air pollutants (HAPs). Title III of the CAAA f urther directed EPA to develop a list of sources that emit any of 189 HAPs, and to develop regulations for these categories of sources. T o dat e EPA has listed 174 categories and developed a schedule for th e

September 1995 82 SIC 281Sector Notebook Project Inorganic Chemicals
estab lishment of emission standards. The emission standards will b e developed for both new and existing sources based on "maximum achievable control t echnology" (MACT). The MACT is defined as the contro l technology achieving the maximum deg ree of reduction in the emission of the HAPs, taking into account cost and other factors.

Title II of the CAA pertains to mobile sources, such as cars, trucks, buses
, and planes. Reformulated gasoline, autom obile 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 establishes a sulfur dioxide emissions program designed to reduce the formati on of acid rain. Reduction of sulfur dioxide releases will be obtained by granting to certain sources limited emissions allowances, which, beginning in 1995, will be set below previous levels of sulfur dioxide releases.

Tit le V of the CAAA of 1990 created a permit program for all "majo r sources" (and certain other sources) regulated under the CAA. One purpose of

th e operating permit is to include in a single document all air emission s requirements that apply to a given facility. States are developing the permit
progr ams in accordance with guidance and regulations from EPA. Once a State p rogram is approved by EPA, permits will be issued and monitored by that State.

Title VI is intended to protect stratospheric ozone by phasing out th e manufacture of ozone-depleting chemicals and restrict their use an d distrib ution. Production of Class I substances, including 15 kinds o f chloro fluorocarbons (CFCs), will be phased out entirely by the year 2000
, while certain hydrochlorofluorocarbon s (HCFCs) will be phased out by 2030.

EPA's C ontrol Technology Center, at (919) 541-0800, provides genera l assista nce and information on CAA standards. The Stratospheric Ozon e Information Hotline, at (800) 296 -1996, provides general information about regulations promulgated under Title VI of the CAA, and EPA's EPCR A Hotl ine, at (800) 535-0202, answers questions about accidental releas e prevent ion under CAA §112(r). In addition, the Technology Transfe r Net work Bulletin Board System (modem access (919) 541-5742)) include s recent CAA rules, EPA guidance documents, and updates of EPA activities.

VI.B. Industry Specific Requirements

The inorganic chemical industry is affecte d by nearly all federal environmental
statutes. In addition, the industry is su bject to numerous laws and regulations from stat e and local governments designed to protect and improve health
, safety, and the environment. A summary of the major federal regulation s affecting the chemical industry follows.

September 1995 83 SIC 281Sector Notebook Project Inorganic Chemicals
Federal Statutes

Toxic Substances Control Act

The T oxic Substances Control Act (TSCA), passed in 1976, gives th e En vironmental Protection Agency comprehensive authority to regulate an y chemical substance whose manufacture, processi ng, distribution in commerce,
use, or disposal may present an unreasonable risk of injury to health or th e

en vironment. Three sections are of primary importance to the inorgani c che mical industry. Section 5 mandates that chemical companies submit t o EP A pre-manufacture notices that provide information on health an d environ mental effects for each new product and test existing products fo r these effects. To date, over 20,000 prem anufacturing notices have been filed. Section 4 authorizes the EPA to require testing of certain substances. Section 6 gives the EPA authori ty to prohibit, limit, or ban the manufacture, process, and use of chemicals. Und er Section 6 of TSCA, EPA has banned most uses of asbestos. In 1990, however, the chlor-alkali i ndustry was able to show that it did n ot have difficulty meeting the required exposure limits for asbesto s fibers, and the use of asbestos as a diaphragm mater ial was exempted from the TSCA ban.

Clean Air Act

The Clean Air Act Amendments o f 1990 set National Emission Standards for Hazardous Air Pollutants (NESHAP) from industrial so urces for 41 pollutants
to be me t by 1995 and for 148 other pollutants to be reached by 2003

. Seve ral provisions affect the inorganic chemical industry. The EPA wil l promulgate max imum achievable control technology (MACT) standards and Lowest Achievable Emission Rates will be required in NAAQS non

attainme nt areas (Iliam Rosario, U.S. EPA, OAQPS, WAM for Chlorin e Produc tion NESHAP (919)-541-5308). An information collection reques t survey was sent out to the chlor-alkali industry in 1992. The data obtaine d from the survey will be analyzed and, based on the results, EPA will propose MACT standards (or EPA may propose that no new standards are necessary) for th e chlor-alkali industry by 1997. For any subject facility, a six yea r extension of MACT requirements is available if they can demonstrate earl y emission reductions.

The Clean Ai r Act Amendments of 1990 contain provisions to phase out the use of ozone depleting chemicals such a s chlorofluorocarbons, halons, carbon
tet rachloride, and methyl chloroform, as required by the Montreal Protoco l

on Substances that Deplete the Ozone Layer. The chlor-alkali industry ha s been and will continue to be significantly affected by these provisions due to decreases in the demand for chlorine as a feedstock in manufacturing thes e chemicals. In addition, many of these chemicals are used extensively by the industry to process chlorine.

September 1995 84 SIC 281Sector Notebook Project Inorganic Chemicals
Clean Water Act

The Cle an Water Act, first passed in 1972 and amended in 1977 and 1987
, gi ves EPA the authority to regulate effluents from sewage treatment works, chemical plants, and other industrial sources into waters. The act sets "best available technology" standards for treatment of wastes for both direct an d in direct (to a Publicly Owned Treatment Works) discharges. Effluen t guid elines for the chlor-alkali industry were last updated in 1984 (40 CF R Section 415). EPA is currently conducting a study to assess the need for new effluent guidelines. (Contact: George Zipf, U.S. EPA, Office of Water, 202- 260-2275)

Restrictions on dioxin emission s in the wastewater from pulp mills are having significant effects on the chlor-alkali industry. Dioxins are formed during the chlorine bleaching process and are subsequently released to rivers an d
st reams. Many mills are switching from chlorine to alternative bleachin g agents in response to the effluen t restrictions. Pulp mills accounted for about 15 percent of the chlorine demand in the U.S. in 1982 and 11 percent in 1992. The de mand for chlorine for pulp bleaching is expected to continue t o decrease through the 1990s.

Resource Conservation and Recovery Act

The Resou rce Conservation and Recovery Act (RCRA) of 1976 gives th e EPA aut hority to establish a list of solid and hazardous wastes, and t o establish standards and regulations for handling a nd disposing of these wastes. New wa stes specific to the inorganic chemical industry have not been added
to the RCRA list since the original waste listings in 1980. EPA is currently under a consent order, howeve r, to propose new hazardous waste listings for
t h

e industry by March 1997, and to finalize by March 1998. (Contact: Rick Brandes, U.S. EPA, Office of Solid Waste, 202-260-4770) The Act als o requires companies to establish programs to reduce the volume and toxicity of hazardous waste s. It was last amended in 1984 when Congress mandated

some 70 n ew programs for the hazardous waste (Subtitle C) program

. Includ ed were tighter standards for handling and disposing of hazardou s wastes, land disposal prohibitions, corrective action (or remediation ) regul ations, and regulations for underground storage tanks. The inorgani c chemical industry is strongly affected by the RCRA regulations because of the disposal costs for hazardous waste and the record keeping requirements.

Occupational Safety and Health Act

The O ccupational Safety and Health Act gave the Department of Labor the
aut hority to set comprehensive workplace safety and health standard s including permissible exposures to chemi cal in the workplace and authority to conduct i nspections and issue citations for violations of safety and healt h

September 1995 85 SIC 281Sector Notebook Project Inorganic Chemicals regul ations. The chemical industry is subject to hazard identificatio n sta ndards established by OSHA, which require extensive documentation o f chemic als in trade and in the workplace and mandate warning labels o n containers. The industry is also subject to OSHA's Hazard Communication Standard and various state and local laws, which give workers the right t o know about hazardous chemicals in the workplace.

Hazardous Materials Transportation Act

The Hazardous Materials T ransportation Act (HMTA) gives the Department of Transportation authority to regu late the movement of hazardous materials. Chemi cal manufacturers must comply with regulations governing shipmen t pre paration, including packaging, labeling and shipping papers; handling
, lo ading and unloading; routing emergency and security planning; inciden t notifications; and liability insurance. The chemical manufacturers must also

com ply with operating requirements for vehicle, vessel, and carrie r transportation of hazardous materials by road, rail, air, and sea. Th e chemicals covered by the HMTA span a broad list of substances, includin g hazardous wastes n ormally regulated by RCRA and hazardous materials that DOT designates as hazardous for th e purposes of transportation that may not be considered hazardous unde r RCRA. These regulations especially apply to chlorine gas which can cause significant risk during transport.

Pollution Prevention Act

The Pol lution Prevention Act makes it a national policy of the United States to reduce or eliminate the generation of waste at the sou rce whenever feasible. Th e EPA is directed to undertake a multi-media program of informatio n collection, technology transfer, and financial assistance to enable the states to implement this policy and to promote the use of source reduction techniques. The reorganization of the Office of Compliance by industry sector is part of EPA's response to this act.

State Statutes

Toxics Use Reduction Act, Massachusetts

The Massachusetts Toxics Use Reduct ion Act affects those facilities that use, manufacture, or process more than a specified amount of substances that are

on th e Massachusetts toxic or hazardous substances list. Facilities mus t submit annual reports on the amounts of substances used, manufactured, or
process ed and must pay annual fees based on these amounts. In addition
, facilities must prepare toxics use reduction plans which show in-plant changes in produc tion processes or raw materials that would reduce, avoid, o r elim inate the use or generation of toxic or hazardous substances. Th e Massachusetts toxic or hazardous substance list initially consists of thos e

September 1995 86 SIC 281Sector Notebook Project Inorganic Chemicals
substanc es listed under §313 of EPCRA and will eventually include thos e sub stances listed under CERCLA. New Jersey has recently passed a similar
act.

VI.C. Pending and Proposed Regulatory Requirements

Resource Conservation and Recovery Act (RCRA)

The Resource C onservation and Recovery Act (RCRA) listed waste streams specific t o the inorganic chemical industry have not been updated since th e origina l RCRA hazardous wastes list developed in 1980. EPA is under a court-ordered deadline to propose and finalize ad ditional waste listings for the industry by March 1997 and March 1988, respectively. The Office of Solid Waste will begin assessing th e need for new listings by early 1996. (Contact: Rick Brandes, U.S. EPA, Office of Solid Waste, 202-260-4770)

Clean Air Act

The new NESHAP standards for the inorganic chemical industry ar e scheduled to be promulgated by EPA by 1997. (Contact: Iliam Rosario, U.S. EPA, OAQPS, WAM for Chlorine Production NESHAP, 919-541-53 08) The standards required will, in most cases, be in the form of MACT standards

. Lowest Achievable Emission Rates will be required in NAAQS non

at tainment areas. An information collection request survey was sent out t o the chlor-alkali industry in 1992. The data obtained will be analyzed and used to assess the need for NESHAP standards in the chlor-alkali industry.

Th e chlor-alkali industry will continue to be affected by the provisions t o phase out the use of ozone depleting chemicals as required by the Montreal Protocol on Substances that Deplete the Ozone Layer. The demand fo r chlorine as a feedstock in manufacturing these che micals, which accounted for about 15 percent of total domestic demand in 1990, will continue to decline through the 1990s. In addition , costs of purifying and liquefying chlorine gas may increase as the cost of carbon tetrachloride and refr igerants increases, and as alternative processes are introduced.

September 1995 87 SIC 281Sector Notebook Project Inorganic Chemicals
VII. COMPLIANCE AND ENFORCEMENT HISTORY

Background

To date, EPA has focused much of its attention on measuri ng compliance with speci fic environmental statutes. This approach allows the Agency to trac k 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 single-media compliance indicators with facility-specific, multimedia indicato rs of compliance. In doing
so, EPA is i n a better position to track compliance with all statutes at th e facility level, and within specific industrial sectors.

A major step in building the capacity to compi le multimedia data for industrial
sectors was the creation of EPA's Integrated Data for Enforcement Analysis (IDEA) sy stem. IDEA has the capacity to "read into" the Agency's single

media databases, extract compliance records, and match the records t o ind ividual facilities. The IDEA system can match Air, Water, Waste
, Toxics/Pesticides/EPCRA, TRI, and En forcement Docket records for a given facility, and generate a list of historical permit, inspection, and enforcemen t activity. IDEA also has the capa bility to analyze data by geographic area and corporate holder.

Compliance and Enforcement Profile Description

Using inspection, violation, and enforce ment data from the IDEA system, this

sec tion provides information regarding the historical compliance an d enforcemen t activity of this sector. In order to mirror the facility univers e reported in the Toxic Chemical Profile, the data reported within this section consists of records only f rom the TRI reporting universe. With this decision, the selection criteria are consistent across sectors wit h certain exceptions. For the sectors that do not normally report to the TRI program, data have been provided from EPA's Facility Indexing System (FIND S) which tracks facilities in all media databases. Please note, in this section, EPA does not attempt to define the actual numbe r of facilities that fall within each sector. Instead, the section portray s 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 notebook s contain an estimated number of facilities within the sector according to th e Bu reau of Census (See Section II). With sectors dominated by smal l businesses, such a s metal finishers and printers, the reporting universe within the EPA databases may be small in comparison to Census data. However, the group select ed for inclusion in this data analysis section should be consistent with this sector's general make-up.

September 1995 88 SIC 281Sector Notebook Project Inorganic Chemicals
Follow ing this introduction is a list defining each data column presente d within t his section. These values represent a retrospective summary o f inspections or enforcement actions, and solely reflect EPA, state, and loca l compliance assurance activity that have be en entered into EPA databases. To identify any changes in trends, th e EPA ran two data queries, one for the past five calendar years (August 10, 1990 to Aug ust 9, 1995) and the other for the most recent twelve-month perio d (August 10, 1994 to August 9, 1995). The five-year analysis gives an average level of activity for that period fo r comparison to the more recent activity.

Becau se most inspections focus on single-media requirements, the dat a queries presented in this section are taken from sin gle media databases. These databases do not provide data on whether inspections are state/local or EPAled. However, the table breaking down the universe of vio lations does give the reader a crude measurement of the EPA's and states ' efforts within each media
pro gram. The presented data illustrate the variations across regions fo r

e certai n sectors. This variation may be attributable to state/local data entr y vari ations, specific geographic concentrations, proximity to populatio n

cen ters, sensitive ecosystems, highly toxic chemicals used in production, o r historical noncompliance. Hence, the exhibited data do not rank regiona l perf ormance or necessarily reflect which regions may have the mos t compliance problems.

Compliance and Enforcement Data Definitions

General Definitions

Facility Indexing S ystem (FINDS) -- this system assigns a common facility number to EPA single-media permit records. The FINDS identificatio n number a llows 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 syste m that can retrieve information from the major EPA program offic e databases. IDEA uses the FINDS identification number to ? glue together ” separate data records from EPA’s databa ses. This is done to create a ? master li st” of data records for any given facility. Some of the data system s

ac cessible through IDEA are: AIRS (Air Facility Indexing and Retrieva l System, Office of Air and Radiation), PCS (Permit Complia nce System, Office of

Wa ter), RCRIS (Resource Conservation and Recovery Informatio n System, Office of Solid Waste), NCDB (National Compliance Data Base
,

e 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).

September 1995 89 SIC 281Sector Notebook Project Inorganic Chemicals
Office of Prevention, Pesticides, and Toxic Substances), CERCLI S (Comprehensive Environmental and Liability Informatio n System, Superfund), and TRIS (Toxic Release Inventory System). IDEA als o contains information from outside sources such as Dun and Bradstree t and the Occupational Safety and Health Administration (OSHA). Most data que ries displayed in notebook sections IV and VII were conducted using IDEA.

Data Table Column Heading Definitions

Facilities in Se arch -- are based on the universe of TRI reporters within the listed S IC code range. For industries not covered under TRI reportin g requ irements, the notebook uses the FINDS universe for executing dat a queri es. The SIC code range selected for each search is defined by eac h notebook's selected SIC code coverage described in Section II.

Facilities Inspected -- indicates the level of EPA and state agency facilit y inspectio ns for the facilities in this data search. These values show wha t perce ntage of the facility universe is inspected in a 12 or 60 month period

. This column does not count non-inspectional comp liance activities such as the review of facility-reported discharge reports.

Num ber of Inspections -- measures the total number of inspection s

con ducted in this sector. An inspection event is counted each time it i s entered into a single media database.

Aver age Time Between Inspections -- provides an average length of time,

e x pressed in months, that a compliance inspection occurs at a facility within the defined universe.

Facilities with One or More Enforce ment Actions -- expresses the number of

facilities that were party to at least one enforcement action within th e defin ed time period. This category is broken down further into federal an d state actions. Data are obtain ed for administrative, civil/judicial, and criminal enforc ement actions. Administrative actions include Notices of Violatio n (NOVs). A facility with multiple en forcement actions is only counted once in this col umn (facility with three enforcement actions counts as one). Al l percentages that appear are referenced to the number of facilities inspected.

Tota l Enforcement Actions -- describes the total number of enforcemen t actions identified for an i ndustrial sector across all environmental statutes. A facility with multiple enforcement actions is counted multiple times (a facility with three enforcement actions counts as three). Sta te Lead Actions -- shows what percentage of the total enforcemen t actions are taken by state and local environmental agencies. Varying level s of u se by states of EPA data systems may limit the volume of action s

September 1995 90 SIC 281Sector Notebook Project Inorganic Chemicals
accorded state enforcement activity. Some states extensively repor t enforcement activities into EPA data systems, while other states may use their own data systems.

Federal Lead Actions -- shows what percentage of the total enforcemen t actio ns are taken by the United States Environmental Protection Agency

. This value includes referrals from state agenc ies. 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 t o inspections, and is presente d for comparative purposes only. This measure is

a ro ugh indicator of the relationship between inspections and enforcement

. Repo rted inspections and enforcement actions under the Clean Water Ac t (PCS), the Clean Air Act (AFS) and the Resource Conserv ation and Recovery Act (RCRA) are included in this ratio. Inspections and actions from th e TSCA/FIFRA/EPCRA databas e are not factored into this ratio because most of

the actions taken under these programs are not the result of facilit y inspections. This ratio does not acc ount for enforcement actions arising from

no n-inspection compliance monitoring activities (e.g., self-reported wate r discharge s) that can result in enforcement action within the CAA, CWA and RCRA.

Facilities with One or More Violations Identified -- indicates the number and percentage of inspected facilities having a viola tion identified in one of the following data categories: In Violation or Significant V iolation Status (CAA); Reportable Noncompliance, Current Year Noncompliance, Significan t No ncompliance (CWA); Noncompliance and Significant Noncomplianc e (FI FRA, TSCA, and EPCRA); Unresolved Violation and Unresolved Hig h Priority Vi olation (RCRA). The values presented for this column reflect the
exte ntof noncompliance within the measured time frame, but do no t distingu ish between the severity of the noncompliance. Percentages withi n thi s column may exceed 100 percent because facilities can be in violatio n status without being inspected. Violation status may be a precursor to a n enforcement action, but does not necessarily indicate that an enforcemen t action will occur.

Media Breakdown of Enforcement Actions and Inspections -- fou r columns iden tify 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 ? Tota l Actions” column.

September 1995 91 SIC 281Sector Notebook Project Inorganic Chemicals VII.A. Inorganic Chemical Industry Compliance History

Exhibit 20 provides an overview o f the reported compliance and enforcement data for the inorganic chemical industry ove r the past five years (August 1990
to August 1995). These data are also broken out by EPA Region thereb y permitting geographical comparisons. A few points evident from the data are listed below.

C Slightly more than half of the TRI reporting inorganic chemica l facili ties in the EPA databases were inspected over the five yea r peri od resulting in an average of 11 months between inspections o f these facilities.

C On average, the states carried out three times the number o f in spections as the Regions; however, the percentage of state le d actions varied across the Regions from 44 percent to 96 percent.

C The enforcement to inspection rate varied significantly from Regio n to Region. Region IX had the highest enforcement to inspection rate as well as the highest percentage of state led actions.

September 1995 92 SIC 281------ Sector Notebook Project Inorganic ChemicalsExhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic Chemicals ManufacturingJEnforcementto InspectionRate0.080.070.120.090.260.150.130.310.110.13IPercentFederalLead Actions28%11%11%55%39%56%20%4%14%24%HPercentState LeadActions72%89%89%45%61%44%80%96%86%76%GTotalEnforcementActions029381134210695537402FFacilities with 1or MoreEnforcementActions01212211124249499EAverageMonthsBetweenInspections3887714141827251911DNumber ofInspections163545449164694016238171633,034CFacilitiesInspected529415462401293511298BFacilitiesin Search1046601051089319177020548ARegionIIIIIIIVVVIVIIVIIIIXXTOTAL

September 1995 93 SIC 281Sector Notebook Project Inorganic Chemicals VII.B. Comparison of Enforcement Activity Between Selected Industries

Exhi bits 21 and 22 allow the compliance history of the inorganic chemica l manufacturing sector to be compared to the other industries covered by the industry sector notebooks. Comparisons between Exhibits 21 and 22 permit the identification of trends in compliance and enforcement records of th e industry by comparing data covering the last five years t o that of the past year. Some points evident from the data are listed below.

C The in organic chemicals industry has a relatively low frequency o f inspecti ons compared to most of the other sectors shown. O n

avera ge, the number of months between inspections at inorgani c chemical s facilities has been only about twice that of organi c chemicals facilities.

C Over the past five years the inorganic chemical ind ustry has had a ratio of enforcement actions to inspections lower than most of the othe r sectors li sted including the organic chemicals sector. This difference has continued over the past year.

C Enforcement actions are bro ught against only about 10 percent of the facilities with violations; lower than most other sectors listed.

Exhibits 23 and 24 provide a more in-depth comparison between the inorganic che micals industry and other sectors by breaking out the compliance an d enforcement data by environmental statute. As in the previous Exhibits (21 and 22), the data cover the last five years (Exhibit 23) and the last one year (Exhibit 2 4) to facilitate the identification of recent trends. A few point s evident from the data are listed below.

C Inspections of inorganic chemical facilities are split relatively evenl y between Clean Air Act, Clean Water Act, and RCRA, al though RCRA accounts for a signi ficantly larger portion of the total actions brought against the inorganic chemicals industry over the past five years.

C Sig nificantly more Clean Water Act inspections are carried out a t i n organic chemicals facilities in comparison to the organic chemicals industry, although the Clean Water Act accounts for a smaller portion of the total actions brought against inorganic chemicals facilities.

C Over the past year RCRA inspections have accounted for a significantly smaller portion of the enforcement actions brough t agai nst the industry and the Clean Air Act has taken a far greate r share.

September 1995 94 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 21: Five-Year Enforcement and Compliance Summary for Selected IndustriesJEnforcementtoInspectionRate0.130.110.130.190.250.140.160.100.060.120.060.120.120.150.150.270.11IPercentFederalLeadActions22%15%24%34%34%28%1%53%24%21%9%22%30%20%24%21%20%HPercentState LeadActions78%85%76%66%66%72%99%47%76%79%91%78%70%80%76%79%80%GTotalEnforcementActions50251440272679749910315519223291391301840470212240FFacilities with1 or MoreEnforcementActions115176991521101152967847834146732801456881EAverageMonthsBetweenInspections552116368834201511301126163116DNumber ofInspections3,7664,7233,0343,8643,2573,5556331,5193,4221,8911,5343,3862,4755,5093,0977772,216CFacilitiesInspected2651,0352983161452752453396313012137392681,340474222390BFacilitiesin Search3064,1065484121563749338731,1434642931,6654682,346844405598AIndustry SectorPulp and PaperPrintingInorganic ChemicalsOrganic ChemicalsPetroleum RefiningIron and SteelDry CleaningMetal MiningNon-Metallic MineralMiningLumber and WoodFurnitureRubber and PlasticStone, Clay, and GlassFabricated MetalNonferrous MetalElectronicsAutomobiles

September 1995 95 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 22: One-Year Inspection and Enforcement Summary for Selected IndustriesABCDEFGHFacilities with 1 orMore ViolationsFacilities with 1 or moreEnforcement ActionsTotalEnforcementActionsIndustry SectorFacilities inSearchFacilitiesInspectedNumber ofInspectionsNumberPercent*NumberPercent*Enforcement toInspection RatePulp and Paper30618957616286%2815%880.15Printing4,10639767625163%256%720.11Inorganic Chemicals548158427167106%1912%490.12Organic Chemicals412195545197101%3920%1180.22Petroleum Refining156109437109100%3936%1140.26Iron and Steel37416748816599%2012%460.09Dry Cleaning933801112126%56%110.10Metal Mining8731141948272%1614%240.13Non-metallic MineralMining1,1432534257530%2811%540.13Lumber and Wood46414226810977%1813%420.58Furniture2931601136641%32%50.55Rubber and Plastic1,665271435289107%197%590.14Stone, Clay, and Glass46814633011679%2014%660.20Nonferrous Metals844202402282104%2211%720.18Fabricated Metal2,346477746525110%4610%1140.15Electronics405608780133%813%210.24Automobiles59816928416296%148%280.10* Percentages in Columns E and F are based on the number of facilities inspected (Column C).Percentages can exceed 100% because violations and actions can occur without a facility inspection.

September 1995 96 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected IndustriesClean Air ActClean Water ActResourceConservation andRecovery ActFIFRA/TSCA/EPCRA/OtherIndustry SectorFacilitiesInspectedTotalInspectionsTotalEnforcementActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% of TotalActionsPulp and Paper2653,76650251%48%38%30%9%18%2%3%Printing1,0354,72351449%31%6%3%43%62%2%4%Inorganic Chemicals2983,03440229%26%29%17%39%53%3%4%Organic Chemicals3163,86472633%30%16%21%46%44%5%5%Petroleum Refining1453,23779744%32%19%12%35%52%2%5%Iron and Steel2753,55549932%20%30%18%37%58%2%5%Dry Cleaning24563310315%1%3%4%83%93%0%1%Metal Mining3391,51915535%17%57%60%6%14%1%9%Non-metallic MineralMining6313,42219265%46%31%24%3%27%0%4%Lumber and Wood3011,89123231%21%8%7%59%67%2%5%Furniture2931,5349152%27%1%1%45%64%1%8%Rubber and Plastic7393,38639139%15%13%7%44%68%3%10%Stone, Clay, and Glass2682,47530145%39%15%5%39%51%2%5%Nonferrous Metals4743,09747036%22%22%13%38%54%4%10%Fabricated Metal1,3405,50984025%11%15%6%56%76%4%7%Electronics22277721216%2%14%3%66%90%3%5%Automobiles3902,21624035%15%9%4%54%75%2%6%

September 1995 97 SIC 281Sector Notebook Project Inorganic ChemicalsExhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected IndustriesFIFRA/TSCA/EPCRA/Other% ofTotalActions3%4%6%1%6%6%7%19%11%6%13%11%3%4%2%4%6%% of TotalInspections0%0%0%1%1%0%0%0%0%0%0%1%0%1%0%0%1%ResourceConservation andRecovery Act% ofTotalActions7%66%36%49%47%50%67%6%16%61%10%71%37%69%77%87%69%% of TotalInspections10%44%45%50%30%36%78%10%5%63%41%46%38%44%61%69%56%Clean Water Act% ofTotalActions21%3%21%16%16%26%22%34%16%13%10%4%8%3%8%7%9%% of TotalInspections35%5%29%13%19%35%1%43%26%8%1%14%18%21%14%14%10%Clean Air Act% ofTotalActions69%27%38%34%31%18%4%42%58%20%67%14%52%24%14%2%16%% of TotalInspections56%50%26%36%50%29%21%47%69%29%58%39%45%33%25%17%34%TotalEnforcementActions887249118114461124544255966721142128TotalInspections57667642754543748811119442526816043533040274687284FacilitiesInspected1893971581951091678011425314229327114620247760169Industry SectorPulp and PaperPrintingInorganic ChemicalsOrganic ChemicalsPetroleum RefiningIron and SteelDry CleaningMetal MiningNon-metallic MineralMiningLumber and WoodFurnitureRubber and PlasticStone, Clay, and GlassNonferrous MetalsFabricated MetalElectronicsAutomobiles

September 1995 98 SIC 281Sector Notebook Project Inorganic Chemicals VII.C. Review of Major Legal Actions

Major Cases/Supplemental Environmental Projects

This se ction provides summary information about major cases that hav e affected this sector, and a list of Supplementary Environmental Project s (SEPs). SEPs are compliance agreements that reduce a facility's stipulate d penalty i n return for an environmental project that exceeds the value of th e reduction. Often, these projects fund pollution prevention activities that can significantly reduce the future pollutant loadings of a facility.

VII.C.1. Review of Major Cases

Histori cally, OECA’s Enforcement Capacity and Outreach Office does no t regular ly compile information related to major cases and pending litigatio n within an industry sector. The staff are wi lling to pass along such information
to Agency staff as requests are made. In addition, summaries of completed enf orcement actions are published each fiscal year in the Enforcemen t Acco mplishments Report. To date, these summaries are not organized b y industry sector. (Contact: Office of Enforcement Capacity and Outreach 202- 260-4140)

VII.C.2. Supplementary Environmental Projects

Supplemen tal environmental projects (SEPs) are an enforcement option that requires the non-compliant facility to complete specific projects. Regiona l summaries of SEPs undertaken in the 1993 and 1994 f ederal fiscal years were review ed. Five SEPs were undertaken that involved inorganic chemica l manufacturing facilities, as shown in Exhibit 25.

CERCLA violations engendered three out of the five SEPs identified; th e fourth and fifth were due to a CAA violation and a TSCA violation. Due to regiona l reporting methods, the specifics of the original violations are no t known and, for one SEP, details of the actual project were not available.

One of the five projects was conducted at a facility that manufactures bot h inorganic and organic chemicals. This project has been included in bot h industry sector project summaries. The FY 1993 and 1994 S EPs for inorganic chemical manufacturers fall into four categories: process related projects ; control and recovery technology i nprovement or installation; leak prevention; and donations to the community.

September 1995 99 SIC 281Sector Notebook Project Inorganic Chemicals •Process related projects A Region IV project carried out in 1993 entailed specific proces s changes intended to reduce chlorinated wastes at the facility. I n

con junction with other non-process components of the project, th e implementation cost was $93,000.

•Control and recovery technology improvement/installation A Lo uisiana facility, the combined organic and inorganic chemica l manufacturer, impl emented a SEP to reduce emissions from returned
gas ca nisters. The SEP involved the installation of recover y technologies to reduce emissions of r esidual CFC and HCFC from the used canisters. The cost to the company was $158,400.

•Leak prevention A Region IV facil ity constructed retaining walls around underground
sto rage tanks to prevent hazardous leachate from reachin g groundwater. The cost to the company was $46,200.

•Donations to Community Following a CERCLA violation, a facility in Texas do nated emergency

an d computer equipment to the Local Emergency Plannin g Commi ssion (LEPC) which could be used in the planning an d responding to potential chemical emergencies. The f acility also agreed to participate in LEPC activities and to provide technical assistance.

September 1995 100 SIC 281------------------------------------------------ Sector Notebook Project Inorganic ChemicalsExhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview: Inorganic Chemical ManufactureSupplemental Environmental ProjectsDescriptionCompany purchased, installed, andoperated equipment for recovery ofresidual CFCs and HCFCs in used gascylinders returned by customersAltered process to reduce chlorinatedwastes, provided computer and Cameotraining for county EMA, donated fundsto LEPC for hazards analysis, and heldresponse exercises at plantConstructed retaining walls aroundunderground storage tanks to preventhazardous material leachate fromreaching groundwaterDonated emergency and/or computerequipment to LEPC for response/planningfor chemical emergencies, agreed toparticipate in LEPC activities and toprovide technical assistanceN/AFacilities identified as combined inorganic and organic chemical manufacturers*Violation Information TermsInitial penalty: Initial proposed cash penalty for violationFinal penalty: Total penalty after SEP negotiationSEP credit: Cash credit given for SEP so that, Final penalty - SEP credit = Final cash penaltySEP cost to company: Actual cost to company of SEP implementationNOTE: Due to differences in terminology and level of detail between regional SEP information, in some cases the figure listed as Final penalty may be the Final cash penalty after deductionfor SEP creditPollutant ReductionPollutantReductionPollutant ofConcernCFC/HCFCchlorinatedwasteViolation InformationSEP CosttoCompany$158,400$93,000$46,200$10,000$198,000SEPCreditN/AFinalPenalty$25,000$2,000$10,000$3,000N/AInitialPenalty$88,360$90,000$40,000$25,000N/ATypeCAACERCLA103/EPCRA304CERCLA,EPCRACERCLA103(a)TSCAGeneral InformationState/Region*LAReg. 4Reg. 4TXAnzon, Inc.Reg.IIICompanyNameLaRocheChemicals,Inc.CoastalChemicalsScholleCorp.ALCOADocket#6-93-16FY9393939394

September 1995 101 SIC 281Sector Notebook Project Inorganic Chemicals
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

This s ection highlights the activities undertaken by this industry sector an d publi c agencies to voluntarily improve the sector's environmenta l performance. These activities include those independently initiated b y 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

None identified.

VIII.B. EPA Voluntary Programs

33/50 Program

Th e "33/50 Program" is EPA's voluntary program to reduce toxic chemica l releases and transfers of seventeen chemicals from manufacturing facilities

. Par ticipating companies pledge to reduce their toxic chemical releases an d transfers by 33 percent as of 1992 and by 50 percent as o f 1995 from the 1988 baseline year. Certificates of Appreciation have been given out to participants meeting their 1992 goals. The list of chemicals includes seventeen high-use chemicals reported in the Toxics Release Inventory. Exhibit 26 lists thos e companies participating in the 33/ 50 program that reported the SIC code 281
to TRI. Many of the companies shown listed multiple SIC codes and
, therefore, are likely to carry ou t operations in addition to inorganic chemicals

manu facturing. The SIC codes reported by each company are listed in n o parti cular order. In addition, the number of facilities within each compan y that are participating in the 33/50 program and that report SIC 281 to TRI is sho wn. Finally, each company’s total 1993 releases and transfers of 33/5 0 chemicals and the percent reduction in these chemicals since 1988 ar e presented.

The in organic chemicals industry as a whole used, generated or processe d almost all of the seventeen target TRI chemicals. Of the target chemicals
, chromium and chromium compounds, lead and lead compounds, and nickel and nickel compounds are released and transferred most frequently and i n similar quantities. These thr ee toxic chemicals account for about nine percent of TRI releases and tran sfers from inorganic chemical facilities. Seventy-five

com panies, representing 168 facilities, listed under SIC 281 (inorgani c chemicals) are currently participating in the 33/5 0 program. This accounts for 30 percen t of the facilities reporting to SIC code 281 to TRI which i s signifi cantly higher than the average for all industries of 14 percen t par ticipation. (Contact: Mike Burns, 202-260-6394 or the 33/50 Program
, 202-260-6907)

September 1995 102 SIC 281Sector Notebook Project Inorganic Chemicals 

### Exhibit 26: 33/50 Program Participants Reporting SIC 281 (Inorganic Chemicals)

Parent Company City, State Reported SIC Codes Facilities ing # of Participat- and Transfers (lbs.) 1993 Releases

1988 to 1993 % Reduction

3M MINNESOTA MINING & MFG CO. ST. PAUL, MN 2821, 2816, 2899 1 16,481,098 70
AIR PRODUCTS AND CHEMICALS ALLENTOWN, PA 2819, 2869 5 144,876 50
AKZO NOBEL INC. CHICAGO, IL 2819, 2869 1 930,189 13
ALBEMARLE CORP. RICHMOND, VA 2869, 2819 1 1,005,108 51
ALLIED-SIGNAL INC. MORRISTOWN, NJ 2819, 2869 4 2,080,501 50
ASHLAND OIL INC. RUSSELL, KY 2819 1 723,562 50
B F GOODRICH COMPANY AKRON, OH 2812, 2821, 2869 1 621,207 50
BASF CORP. PARSIPPANY, NJ 2869, 2865, 2819 1 1,157,548 50
BENJAMIN MOORE & CO. MONTVALE, NJ 2851, 2812, 7 20,635 *
BORDEN CHEM & PLAS LTD PARTNR COLUMBUS, OH 2813, 2821, 2869 1 12,662 ***
CABOT CORP. BOSTON, MA 3339, 2819 2 2,407,581 50
CALGON CARBON CORP. PITTSBURGH, PA 2819 1 14,845 50
CIBA-GEIGY CORP. ARDSLEY, NY 2819, 2865, 2869 2 1,875,028 50
CITGO PETROLEUM CORP. TULSA, OK 2911, 2819, 2869 1 1,164,354 20
CONKLIN COMPANY INC. SHAKOPEE, MN 2819, 2952, 2992 1 2,977 *
CORNING INC. CORNING, NY 3339, 2819 1 1,521,528 14
CRITERION CATALYST LTD PARTNR HOUSTON, TX 28190 3 3,716 *
CYTEC INDUSTRIES WEST PATERSON, NJ 2819, 2869 2 1,074,646 50
DEGUSSA CORP. RIDGEFIELD PARK, NJ 2819, 2869, 2879 1 676,418 ***

DOW CHEMICAL COMPANY MIDLAND, MI 2800, 2819, 2821 4 2,769,363 50
E. I. DU PONT DE NEMOURS & CO. WILMINGTON, DE 2816 9 11,740,853 50
EAGLE CHEMICALS INC. HAMILTON, OH 2899, 2819, 2841 1 500 33
EAGLE-PICHER INDUSTRIES INC. CINCINNATI, OH 2816 1 227,242 50 ELF AQUITAINE INC. NEW YORK, NY 2812 7 273,274 43
ENGELHARD CORP. ISELIN, NJ 3714, 2819 6 236,302 50
ETHYL CORP. RICHMOND, VA 2869, 2819, 1 251,519 46
FERRO CORP. CLEVELAND, OH 2819, 2869 5 165,529 50
FMC CORP. CHICAGO, IL 2812, 2819 4 502,318 50
GENERAL ELECTRIC COMPANY FAIRFIELD, CT 2821, 2812, 2869 2 5,010,856 50
GEORGIA GULF CORP. ATLANTA, GA 2865, 2812, 2819 1 39,480 80
GEORGIA-PACIFIC CORP. ATLANTA, GA 2611, 2621, 2812 1 2,722,182 50
HANLIN GROUP INC. EDISON, NJ 2812, 2819 3 6,174 75
HM ANGLO-AMERICAN LTD. NEW YORK, NY 2816 4 1,265,741 2
HOECHST CELANESE CORP. SOMERVILLE, NJ 2819, 2869, 2873 1 2,603,661 50
INTERNATIONAL PAPER COMPANY PURCHASE, NY 28190 1 2,784,831 50
ISK AMERICAS INC. SAN FRANCISCO, CA 2879, 2819 2 300,088 50
KEMIRA HOLDINGS INC. SAVANNAH, GA 2816, 2819 1 394,070 *
KERR-MCGEE CORP. OKLAHOMA CITY, OK 2819 3 374,098 35

LAIDLAW ENVIRONMENTAL SERVICES COLUMBIA, SC 2819, 2869 1 8,167 ***

LAROCHE HOLDINGS INC. ATLANTA, GA 2812, 2869 1 81,470 *
MALLINCKRODT GROUP INC. SAINT LOUIS, MO 2869, 2833, 2819 3 775,206 50

September 1995 103 SIC 281Sector Notebook Project Inorganic Chemicals

Parent Company City, State Reported SIC Codes Facilities ing # of Participat- and Transfers (lbs.) 1993 Releases

1988 to 1993 % Reduction

MAYO CHEMICAL CO. INC. SMYRNA, GA 2819 2 15 67
MILES INC. PITTSBURGH, PA 2819 3 1,095,504 40
MOBIL CORP. FAIRFAX, VA 2869, 2819, 2821 1 4,263,284 50
MONSANTO COMPANY SAINT LOUIS, MO 2865, 2869, 2819 3 1,683,580 23
MORTON INTERNATIONAL INC. CHICAGO, IL 2819, 2869 1 721,216 20
NALCO CHEMICAL COMPANY NAPERVILLE, IL 2899, 2819, 2843 2 107,651 50
OCCIDENTAL PETROLEUM CORP. LOS ANGELES, CA 2812, 2819 8 8,896,126 19
OLIN CORP. STAMFORD, CT 2819 4 574,673 70
PHILLIPS PETROLEUM COMPANY BARTLESVILLE, OK 2911, 2819 2 2,367,877 50
PPG INDUSTRIES INC. PITTSBURGH, PA 2812, 2816, 2869 3 2,772,331 50 PQ CORP. VALLEY FORGE, PA 2819 3 19 50
PROCTER & GAMBLE COMPANY CINCINNATI, OH 28190 1 612,520 *
RHONE-POULENC INC. MONMOUTH JUNCTION, NJ 2821, 2819, 2841 6 1,437,778 50

ROHM AND HAAS COMPANY PHILADELPHIA, PA 2819, 2869 1 1,210,244 50
SHELL PETROLEUM INC. HOUSTON, TX 2869, 2819 1 3,240,716 55
SHEPHERD CHEMICAL CO. CINCINNATI, OH 2819, 2869 1 828 72
SHERWIN-WILLIAMS COMPANY CLEVELAND, OH 2816, 2851 1 1,352,412 50
STANDARD CHLORINE CHEM. CO. KEARNY, NJ 2865, 2819 1 48,246 ***
STAR ENTERPRISE HOUSTON, TX 2911, 2819, 4463 1 601,640 50
STERLING CHEMICALS INC. HOUSTON, TX 2869, 2865, 2819 1 182,216 65
SUD-CHEMIE NORTH AMERICA DE LOUISVILLE, KY 2819 2 196,438 16
TEXACO INC. WHITE PLAINS, NY 2869, 2865, 2819 1 514,803 50
TEXAS INSTRUMENTS INC. DALLAS, TX 3674, 3812, 2819 2 344,225 25
UNILEVER UNITED STATES INC. NEW YORK, NY 2819 1 164,034 50
UNIROYAL CHEMICAL CORP. MIDDLEBURY, CT 2821, 2879, 2813 1 1,970,357 20
UNOCAL CORP. LOS ANGELES, CA 2819 1 238,520 50
UOP DES PLAINES, IL 2819, 2869 2 14,169 50
US DEPARTMENT OF ENERGY WASHINGTON, DC 2819 4 148,198 50
VELSICOL CHEMICAL CORP. ROSEMONT, IL 2865, 2819, 2869 1 224,664 50
VISTA CHEMICAL COMPANY HOUSTON, TX 2869, 2865, 2819 2 106,497 50
VULCAN MATERIALS COMPANY BIRMINGHAM, AL 2869, 2812 2 679,566 85
W R GRACE & CO INC. BOCA RATON, FL 2819 2 615,509 50
WEYERHAEUSER COMPANY TACOMA, WA 2621, 2611, 2812 1 1,006,356 *
WITCO CORP. NEW YORK, NY 2819, 2869 1 327,611 50 * = not quantifiable against 1988 data. ** = use reduction goal only. *** = no numerical goal. Source: U.S. EPA, Toxic Release Inventory, 1993.

September 1995 104 SIC 281Sector Notebook Project Inorganic Chemicals Environmental Leadership Program

The Environmen tal Leadership Program (ELP) is a national initiative piloted by EPA and state agencies in which facilitie s have volunteered to demonstrate innovat ive approaches to environmental management and compliance. EPA has s elected 12 pilot projects at industrial facilities and federal installation s which wil l demonstrate the principles of the ELP program. These principles inc lude: environmental management systems, multimedia complianc e assurance, third-party verification of compliance, public measures o f

ac countability, community involvement, and mentoring programs. In retur n for participatin g, pilot participants receive public recognition and are given a
per iod of time to correct violations discovered during these experimenta l projects. Forty pr oposals were received from companies, trade associations, and fe deral facilities representing many manufacturing and service sectors

. Two chemical companies (Ciba Geigy of St. Gabr iel, LA and Akzo Chemicals of

Edison, NJ), one pharmaceutical manufacturer (Schering Plough o f Kenilworth, NJ), and one manufacturer of agricultural chemicals (Gowa n Milling of Yuma, AZ) su bmitted proposals. (Contact: Tai-ming Chang, ELP Director, 202-564-5081 or Robert Fentress 202-564-7023)

Project XL

Pro ject XL was initiated in March 1995 as a part of President Clinton’ s Reinv enting Environmental Regulation initiative

. The projects seek t o achi eve cost effective environmental benefits by allowing participants t o replace or modify existi ng regulatory requirements on the condition that they
pr oduce greater environmental benefits. EPA and program participants will negotiate and sign a final Project Ag reement, detailing specific objectives that the regulated entity shal l satisfy. In exchange, EPA will allow the participant

a ce rtain degree of regulatory flexibility and may seek changes in underlying

re gulations or statutes. Participants are encouraged to seek stakeholde r support from local governments, business es, and environmental groups. EPA hopes to implement fifty pilot projects in four categories including facilities,

sec tors, communities, and government agencies regulated by EPA

. Applica tions will be accepted on a rolling basis and projects will move t o implementation within six months of their selection. For additiona l infor mation regarding XL Projects, including application procedures an d criteria, see the May 23, 1995 Federal Register Notice. ( Contact: Jon Kessler, Office of Policy Analysis, 202-260-4034)

Green Lights Program

EPA’s Gre en Lights program was initiated in 1991 and has the goal o f
preven ting pollution by encouraging U.S. institutions to use energy-efficient lighting technologies. The program has over 1,500 participants which include major co rporations; small and medium sized businesses; federal, state an d

September 1995 105 SIC 281Sector Notebook Project Inorganic Chemicals
local governments; non-profit groups; schools; universities; and health car e faciliti es. Each participant is required to survey their facilities and upgrad e ligh ting wherever it is profitable. EPA provides technical assistance to th e partic ipants through a decision support software package, workshops an d manuals, and a financing registry. EPA’s Office of Air and Radiation i s responsible for ope rating the Green Lights Program. (Contact: Maria Tikoff 202-233-9178 or the Green Light/Energy Star Hotline, 202-775-6650)

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 th e manufa cturing and purchase of recycled products. As of 1994, the program had about 300 companies as members, including a number of majo r

cor porations. Members agree to identify and implement actions to reduc e their solid wastes and must provide EPA with their waste reduction goal s along wit h yearly progress reports. EPA, in turn, provides technica l assistance to member companies and allows the use of the WasteWi$e logo for promotional purposes. (Contact: Lynda Wynn 202-260-0700 or th e WasteWi$e Hotline, 800-372-9473)

Climate Wise Recognition Program

The Clima te Change Action Plan was initiated in response to the U.S

. commitment to reduce greenhouse gas emissions in accordance with th e Cl imate Change Convention of the 1990 Earth Summit. As part of th e Clima te Change Action Plan, the Climate Wise Recognition Program is a partnership initiat ive run jointly by EPA and the Department of Energy. The
program is designed to reduce greenhouse gas emissions by encouragin g reductions across all sectors of the economy, encouraging participation in the full range of Climate Change Action Pl an initiatives, and fostering innovation. Participants in the program are required to ide ntify and commit to actions that reduce greenhou se gas emissions. The program, in turn, gives organizations

ea rly recognition for their reduction commitments; provides technica l assistance th rough consulting services, workshops, and guides; and provides access to the program’s centralized information system. At EPA, the program is operated by th e Air and Energy Policy Division within the Office of Policy Planning and Evaluation. (Contact: Pamela Herman 202-260-4407)

September 1995 106 SIC 281Sector Notebook Project Inorganic Chemicals
NICE 3

The U.S. Department of Energy and EPA’s Office of Pollution Prevention are joi ntly administering a grant program called The National Industria l Competitiveness through Energy, Envi ronment, and Economics (NICE 3 ). By providin g grants of up to 50 percent of the total project cost, the progra m encourages industry to reduce industri al waste at its source and become more

en ergy-efficient and cost-competitive through waste minimization efforts

. Gra nts are used by industry to design, test, demonstrate, and assess th e feasibil ity of new processes and/or equipment with the potential to reduc e pollution and increase energy efficiency. The program is open to al l industries; however, priority is given to proposals from participants in the pulp and paper, chemicals, primary metals, and petroleum and coal product s sectors. (Contact: DOE’s Golden Field Office, 303-275-4729)

VIII.C. Trade Association/Industry Sponsored Activity

VIII.C.1. Environmental Programs

Global Environmental Management Initiative

The Glo bal Environmental Management Initiative (GEMI) is made up of a group of leading companies dedicated to fostering environmental excellence by business. GEMI promotes a worldwide business ethic for environmental

ma nagement and sustainable development to improve the environmenta l perfo rmance of business through example and leadership. In 1994, GEMI’s member ship consisted of about 30 major corporations including Amoc o Corporation.

National Pollution Prevention Roundtable

The National Pollution Prevention Roundtable published The Pollutio n Prevention Yellow Pages in September 1994. It is a compilation o f inf ormation collected from mail and telephone surveys of state and loca l government pollution pre vention programs. (Contact: Natalie Roy 202-543- 7272) The fo llowing state programs listed themselves as having expertise in pollution prevention rel ated to inorganic chemical manufacture and use. The contacts listed below (Exhibit 27 ) are also likely to be aware of various stateand local-level initiatives affecting the inorganic chemical industry.

September 1995 107 SIC 281Sector Notebook Project Inorganic Chemicals

Exhibit 27: Contacts for State and Local Pollution Prevention Programs

State Program Contact Telephone

Alabama AL Dept. of Env. Protection, Ombudsman and Small Business Assistance Program Blake Roper, Michael Sherman (800) 533-2336 (205) 271-7861

AL WRATT Foundation Roy Nicholson (205) 386-3633

California CA State Dept. of Toxic Substances Control David Harley, Kim Wilhelm, Kathy Barwick (916) 322-3670

County Sanitation Districts of LA Michelle Mische (310) 699-7411

Colorado Region VIII HW Minimization Program Marie Zanowich (303) 294-1065

Illinois IL HW Research and Information Center David Thomas (217) 333-8940

Indiana IN Dept. of Env. Mgmt. Tom Neltner (317) 232-8172

Iowa IA Dept. of Natural Resources Larry Gibson (515) 281-8941
Kentucky KY Partners, State Waste Reduction Center Joyce St. Clair (502) 852-7260

Massachusetts Toxics Use Reduction Institute Janet Clark (508) 934-3346

Michigan University of Detroit Mercy Daniel Klempner (313) 993-3385

New Mexico Waste Management Education and Research Consortium Ron Bhada (505) 646-1510

North Dakota Energy and Env. Research Center Gerald Groenewold (701) 777-5000

Ohio Institute of Advanced Manufacturing Sciences Harry Stone, Sally Clement (513) 948-2050

Pennsylvania Center for Hazardous Materials Research Roger Price, Steven Ostheim (412) 826-5320

Rhode Island RI Center for P2, URI Stanley Barnett (401) 792-2443

South Carolina Clemson University Eric Snider (803) 656-0985

Texas TX Natural Resource Conservation Commission Andrew Neblett (512) 239-3100

Vermont Retired Engineers and Professionals Program Muriel Durgin (802) 879-4703
Washington WA State Dept. of Ecology Peggy Morgan (206) 407-6705

Wisconsin WI Dept. of Natural Resources, Small Business Assistance Program Robert Baggot (608) 267-3136

Wyoming WY Dept. of Env. Quality Charles Raffelson (307) 777-7391

Center for Waste Reduction Technologies

September 1995 108 SIC 281Sector Notebook Project Inorganic Chemicals Center for Waste Reduction Technologies, under the aegis of the American Institute of Chemical Engineers, sponsors rese arch on innovative technologies
to reduc e waste in the chemical processing industries. The primar y mechanism is through funding of academic research.

National Science Foundation and the Office of Pollution Prevention and Toxics

The National Science Foundation and EPA's Office of Pollution Preventio n and T oxics signed an agreement in January of 1994 to coordinate the tw o agencies' programs of ba sic research related to pollution prevention

. The collabora tion will stress research in the use of less toxic chemical an d synt hetic feedstocks, use of photochemical processes instead of traditiona l

ones that employ toxic reagents, use of recyclable catalysts to reduce meta l contaminati on, and use of natural feedstocks when synthesizing chemicals in large quantities.

Chemical Manufacturers Association

Th e Chemical Manufacturers Association funds research on issues o f interest to their members particularly in support of t heir positions on proposed

or possible legislation. They recently funded a study to characterize th e environmental fate of organochlorine compounds.

Responsible Care Program

The Responsible Care Program of th e Chemical Manufacturers Association requi res members to pledge commitment to six codes that identify 10 6 manage ment practices that companies must carry out in the areas o f community awareness and emergency resp onse, pollution prevention, process safety, distribution, employee health and safety, and product stewardship.

ISO 9000

ISO 900 0 is a series of international total quality management guidelines

. After a successful independent audit of their management plans, firms ar e qua lified to be ISO 9000 registered. In June of 1993, the Internationa l Standards Organiza tion created a technical committee to begin work on new
stan dards for environmental management systems. The new standards ar e called ISO 14000 and are expected to be issued in 1996.

September 1995 109 SIC 281Sector Notebook Project Inorganic Chemicals VII.C.2. Summary of Trade Associations

Chemical Industry

American Chemical Society 1155 16th Street, NW Washington, D.C. 20036 Members: 145,000 Phone: (202) 872-8724 Staff: 1700 Fax: (202) 872-6206 Budget: $192,000,000

The American Chemical Society (ACS) has an educational and research focus. Th e ACS produces approximately thirty different industry periodicals an d

re search journals, including Environmental Science and Technology an d Chemi cal Research in Toxicology

. In addition to publishing, the AC S presently conducts studies and surveys; legislation monitoring, analysis, and
repo rting; and operates a variety of educational programs. The ACS library and on-line information services are extensive. Some available on-lin e services are Chemical Journals Online , containing the full text of 18 AC S journals, 10 Royal Society of Chemistry journals, and five polymer journals, and the Chemical Abstracts Service (CAS), which provides a variety o f information on chemical comp ounds. Founded in 1876, the ACS is presently comprised of 184 local groups and 843 student groups nationwide.

Chemical Manufacturers Association 2501 M St., NW Members: 185 Washington, D.C. 20037 Staff: 246 Phone: (202) 887-1164 Budget: $36,000,000 Fax: (202) 887-1237 Contact: Joseph Mayhew

Present ly, the principle focus of the Chemical Manufacturers Associatio n (CM A) is on regulatory issues facing chemical manufacturers at the local
, state, and federal level. At its inception in 1872, the focus of the CMA was on serving chemical manufacturers through research. Res earch is still ongoing at the CMA, however, as the CHEMSTAR program illustra tes. CHEMSTAR consists of a variety of self-funded panels working on single-chemical research agendas. This research fits in with the overall regulatory focus of the CMA; CHEMST AR study results are provided to both CMA membership an d regulatory agencies. Other initiat ives include the "responsible care" program. Membe rship in the CMA is contingent upon enrollment in the "responsibl e care" program, which includes six codes of management practice (including pollution prevention) that attempt to "go beyond simple regulator y compliance.” The CMA also conducts workshops and technical symposia
, promo tes in-plant safety, operates a chemical emergency cente r (CHEMTREC) whic h offers guidance in chemical emergency situations, and operates the Chemical Referral Center which provides chemical health an d safety information to the public. Publications include: ChemEcology , a 10

-
September 1995 110 SIC 281Sector Notebook Project Inorganic Chemicals issue-per-year newsletter covering environmental, pollution-control, workersa fety, and federal and state regulatory actions, and the CMA Directory
, a listing of the CMA membership. The CMA holds an annual meeting in White Sulphur Springs, WV.

Chlor-alkali Industry

The Chlorine Institute, Inc. 2001 L Street, N.W. Suite 506 Washington, D.C. 20036 Phone: (202) 223-2790 Fax: (202) 223-7225 Members: 200 Budget: $1,500,000 Contact: Gary Trojak

The Chlorine Institute, Inc. was establis hed in 1924 and represents companies in the U .S., Canada, and other countries that produce, distribute, and us e chlorine, sodium and potassium hydroxides, and sodium hyp ochlorite; and that distribute and use hydrogen chloride. The Institute is a non-profit scientific and technical organization which serves as a safety, health, and environmental protection center for the industry.

Chlorine Chemistry Council 2501 M Street, N.W. Members: 30 Washington, D.C. 20037 Staff: 24 Phone: (202) 887-1100 Budget: $14,000,000 Fax: (202) 887-6925 Contact: Kip Howlett Jr.

The Chlor ine Chemistry Council (CCC), established in 1993, is a busines s council of the Chemical Manufacturers Association (CMA) and is made up of
pr oducers and users of chlorine and chlorine-related products. Wit h involvement from all stak eholders, the CCC works to promote science-based public policy regarding chlorine chemistry and is committed to develop an d
pr oduce only those chemicals that can be manufactured, transported, used
, and dispo sed of safely. CCC facilitates risk-benefit analyses and produc t stewardship through the collection, develop ment, and use of scientific data on heal th, safety, and environmental issues. CCC hopes to heighten publi c awareness of chlorine chemistry and its many societal be nefits by collaborating with th e public health and scientific community in assessing an d communicating chlorine-related human health and environmental issues.

September 1995 111 SIC 281Sector Notebook Project Inorganic Chemicals
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY

For fu rther information on selected topics within the inorganic chemical s industry a list of contacts and publications are provided below:

Contacts f

Name Organization Telephone Subject

Walter DeRieux EPA/OECA (202) 564-7067 Regulatory requirements and compliance assistance Sergio Siao EPA/NEIC (303) 236-3636 Industrial processes and regulatory requirements

Iliam Rosario EPA/OAQPS (919) 541-5308 Regulatory requirements (Air), Chlorine NESHAPs George Zipf EPA/OW (202) 260-2275 Regulatory requirements (Water)

Rick Brandes EPA/OSWER (202) 260-4770 Regulatory requirements (Solid waste)

Ed Burks EPA/Region IV (404) 347-5205 Inspections, regulatory requirements (RCRA)

Jim Gold EPA/Region VI (713) 983-2153 Inspections and regulatory requirements (Water, AIR and TSCA)

OECA: Office of Enforcement and Compliance Assistance NEIC: National Enforcement Investigations Center OAQPS: Office of Air Quality Planning and Standards OW: Office of Water OSWER: Office of Solid Waste and Emergency Response

General Profile

U.S. Industrial Outlook 1994 , Department of Commerce

1987 Ce nsus of Manufacturers, Industry Series, Industrial Inorganic Chemicals , Bureau of th e Census [Published every five years the next version will be available in September of 1994]

1992 Census of Manufacturers, Preliminary Report Industry Series, Industrial Inorganic Chemicals
, Bureau o f the Census [Data will be superseded by a more comprehensive report in September o f 1994]

f Many of the contacts listed above have provided valuable background information and comments during the development of this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all statements make within this notebook.

September 1995 112 SIC 281Sector Notebook Project Inorganic Chemicals
Chlorine and Its Derivatives: A World Survey of Supply, Demand, and Trade to 1992 , Tecno n Consulting Group, London, 1988.

North American Chlor-Alkali Industry Plants and Production Data Book , Pa mphlet 10, The Chlorine Institute, Washington, D.C., January, 1989.

Process Descriptions and Chemical Use Profiles

Riegel’s Handbook of Industrial Chemistry, 9th ed., Kent, James A., Ph.D., editor, Van Nostrand Reinhold, New York, 1993.

Kirk-Othmer Encyclopedia of Chemical Technology , Fourth edition, vol ume 1, John Wiley and Sons, New York, 1994.

Bu chner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry , VCH Publishers, New York
, 1989.

Multi-media Assessment of the Inorganic Chemicals Industry
, Chapter 12-Salt Derivatives, Prepared f o r U.S. EPA Industrial Environmental Research Laboratory by Verser, Inc., Springfield, Virginia, 1980.

Recomm endations To Chlor-alkali Manufacturing Facilities for the Prevention of Chlorin e Releases , The Chlorine Institute, First Edition, October, 1990.

Assessmen t of Solid Waste Management Problems and Practices in the Inorganic Chemical s Indu stry , Final Report, Versar, Inc. for U.S. Environmental Protection Agency, Industria l Environmental Research Laboratory, Cincinnati, Ohio, April 1979.

Chlorine, Its Manufacture, Properties, and Uses , J.S. Sconce, Reinhold Publ ishing Corp., New York, 1962.

Electro lytic Manufacture of Chemicals from Salt , D.W.F. Hardie and W.W. Smith, The Chlorin e Institute, New York, 1975.

Modern Chlor-Alkali Technology , Vol. 4, N.M. Prout and J.S. Moorhouse, eds., Elsevier Applied Science, 1990.

Regulatory Profile

Sustainable Environmental Law , Environmental Law Inst itute, West Publishing Co., St. Paul, Minn., 1993.

Development Document for Effluent Limitations Guidelines and New Source P erformance Standards for the Major Inorganic Products Segment of the Ino rganic Chemicals Point Source Category , U.S. Environmental Protection Agency, Washington, D.C., March 197 4. Report No. EPA-440/1-74-007a.

September 1995 113 SIC 281Sector Notebook Project Inorganic Chemicals
ENDNOTES

1. U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.

2. U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers, Industrial Inorganic Chemicals. April 1995.

3. U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.

4. U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers, Industrial Inorganic Chemicals. April 1995.

5. Büchner, Schliebs, Winter, Büchel. Industrial Inorganic Chemistry. New York: VCH Publishers, 1989.

6. Ibid.

7. U.S. Department of Commerce, Bureau of the Census. 1994 Census of Manufacturers, Industrial Inorganic Chemicals. April 1995.

8. Charles River Associates. Chlorine Chemistry Plays a Vital Role in the U.S. Economy. Washington, D.C.: The Chlorine Institute, 1993.

9. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

10. U.S. Department of Commerce. U.S. Industrial Outlook 1994. January 1994.

11. Ibid.

12. Ibid.

13. Ibid.

14. Ibid.

15. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

16. Büchner, Schliebs, Winter, Büchel. Industrial Inorganic Chemistry. New York: VCH Publishers, 1989.

17. Ibid.

18. Ibid.

19. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

September 1995 114 SIC 281Sector Notebook Project Inorganic Chemicals
20. Büchner, Schliebs, Winter, Büchel. Industrial Inorganic Chemistry. New York: VCH Publishers, 1989.

21. Ibid.

22. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

23. Ibid.

24. Ibid.

25. Ibid.

26. Büchner, Schliebs, Winter, Büchel. Industrial Inorganic Chemistry. New York: VCH Publishers, 1989.

27. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

28. Ibid.

29. Ibid.

30. Büchner, Schliebs, Winter, Büchel. Industrial Inorganic Chemistry. New York: VCH Publishers, 1989.

31. Kirk-Othmer Encyclopedia of Chemical Technology, Fourth Ed. New York: John Wiley and Sons, 1994.

32. Ibid.

33. Ibid.

34. Ibid.

35. Ibid.

36. Ibid.

37. Ibid.

38. Ibid.

39. Versar, Inc. Multi-Media Assessment of the Inorganic Chemicals Industry. Ch. 12. Cincinnati, Ohio: U.S. EPA Industrial Environmental Research Laboratory, August, 1980.

40. Versar, Inc. Multi-Media Assessment of the Inorganic Chemicals Industry. Ch. 12. Cincinnati, Ohio: U.S. EPA Industrial Environmental Research Laboratory, August, 1980.

September 1995 115 SIC 281Sector Notebook Project Inorganic Chemicals
41. Ibid.

42. Ibid.

43. Ibid.

44. Ibid.

45. Ibid.

46. Ibid.

47. Ibid.

48. Ibid.

49. Ibid.

50. Ibid.

51. Ibid.

52. Ibid.

53. Ibid.

54. Ibid.

55. U.S. EPA Office of Pollution Prevention and Toxics. 1993 Toxics Release Inventory Public Data Release. May 1994.

56. Ibid.

57. Kent, James A. Ph.D., editor. Riegel’s Handbook of Industrial Chemistry, 9th ed. New York: Van Nostrand Reinhold, 1993.

58. Ibid.

59. Ibid.

September 1995 116 SIC 281Sector Notebook Project Inorganic Chemicals

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