Technical Document: Sectors, Chemicals and Functions in the DSW Re

- Manufacturing Exclusion June 16, 2011



# Selection of Industry Sectors, Chemicals and Functions in the Remanufacturing Exclusion: Background Document in Support of the Definition of Solid Waste Rule

Prepared b y: 

### U.S. Environmental Protection Agency Office of Pollution Prevention and Toxics Economic, Exposure and Technology Division Pollution Prevention Division 1200 Pennsylvania Avenue NW Washington, DC 20460

June 16, 2011Introduction

This background document provides the basis for the selection of industries, chemicals, and functions in the Remanufacturing exclusion in the definition of solid waste rule. Companies within these sectors are highl y int egrated. These chemicals are used because of how they function, and are used within these sectors in the same way

– to manufacture a specialty (organic) chemical product

– such as a paint, plastic or drug. The Green Engineering Program within the Office of Chemical Safet y and Pollution Prevention (OCSPP) has for several years been stud yi ng re - manufacturing scenarios for “once

- used” solvents in the pharmaceutical industry sector that use solvents as chemical manufacturing and processing aids. By

focusing o n the life

- cy cle (beginning and end of life) impact in their manufacture, and reviewing Toxics Release Inventory Production Related Waste reporting, EPA has found that a large, but often hidden footprint is from the disposal of these solvents. EPA has det ermined that the environmental impacts from solvents used as manufacturing and processing aids could be significantly reduced if the product life of solvents used for these purposes were extended to more than a single use. 1 (Extension of life)
Why these Sectors? As stated in the Preamble, EPA selected these sectors as candidates for the re

- manufacturing exclusion because they

are manufacturing sectors not waste handling sectors, and because they use chemicals serving as chemical manufacturing and proc essing aids 2 . Sectors that use chemicals in this way

are limited to those that make chemicals, and these sectors are relativel y few in number. EPA has selected most of the sectors that fall into this group and would welcome comment on its selections. Si nce readers may well be familiar with numerous additional sectors downstream from chemical manufacturers which combine chemicals to make various end

- products, EPA would simply note that they

do not share the function of performing actual chemical manufacturing and processing, do not use chemicals in their capacity as manufacturing and processing aids and, thus, cannot be considered under the re

- manufacturing exclusion as proposed. Regarding the sectors selected as candidates for the re

- manufacturing excl usion, EPA would like to note a few things. The basic organic chemicals sector makes both pol ym er resins and specialty chemicals. Poly

mer resins are the backbone for paints, resins and plastics, whereas specialty chemicals are used to make the complex mo lecules in the pharmaceutical industry

. TRIreporting shows that the facilities within and among each sector are co

- located b y each other 3 and are customers of one another. Although there are man y small facilities within each of these sectors, the highe st volumes of material are reported b y a few large parent companies that manage the entire suppl y chain. Also, film

- forming agents are resins, but are reported in the paint & coatings sector. Makers of pol ym ers report in both basic organic and plastic & resin

1 Mass Balance Model is available to estimate emissions reduct ions from a process change of disposal to recycling. See Tables 8.1 and 8.2, Appendix 4 2 See discussion and table on “Why these functions?” one page below for TRI evidence of sector

- function relationship. 3 See Map 2, and Figures 6.1

– 6.8, Appendix 2.sectors. Some makers of specialty chemicals used in and sold to pharmaceutical companies actuall y report in the pharmaceutical industry.
Why these Chemicals? EPA has made its best estimate of those chemicals used as chemical manufacturing and pr ocessing aides in significant volumes from the list of all chemicals used by the four selected sectors. As noted in the Preamble to the Proposed Rule, “processing aid” solvents assist in the reaction, extraction, purification, and blending of ingredients and reactive products, but are not themselves reacted. These processing aid solvents, once used, can then be re

- manufactured to commercial grade again. These higher

- value solvents were selected because there are existing markets for all these solvents to b e re - manufactured to serve similar purposes to those of the original commercial

- grade materials. All these chemicals are solvents (some watery , some oily , some a specialt y combination of the two), and TRI reporting indicates these sectors use these solvent s in large volumes. EPA would welcome comments on any additions or deletions that could be made to its list of chemicals used as chemical manufacturing and processing aides in the four selected sectors.
Why these Functions? As noted in the Preamble , EPA has selected two chemical functions that a sector would need to be engaged in to make its chemical(s) eligible for re

- manufacturing under the exclusion: (1) the chemical would need to be serving as a chemical manufacturing aid (reacting, extracting, blending and/or purifying chemicals); or, (2) the chemical would need to be serving as a chemical processing aid (extracting, blending and purifying chemicals). EPA chose these functions because solvents used for these functions, when chosen to, can be ea sily separated readil y from the other reaction components. Eas y separation can occur because these solvents serve to dissolve other chemicals without bonding to them, in a contaminant

- free processing step, after which they

are removed as quickl y and compl etely as possible. This is in contrast to a solvent serving in an alternate function as a cleaner or degreaser, where the solvent gets contaminated, is more difficult to separate from grease or other contaminants, and is more likely to be discarded. EPA is able to discern the functional footprint of the selected solvents in sector facility TRI reports. Sectors that use a chemical in significant volumes as a manufacturing and processing aid have a significantly

higher waste

- to

- release ratio for that chem ical (discernable even in aggregate chemical reporting) than sectors that use a chemical for other functions. (See Table 1)Table 1. 2009 TRI Rank by Waste Reporting 4

2009 Rank by releases Industry Releases (lbs) Waste (lbs) Waste Divided by Release Number of TRI

submissions
1 Fossil Fuel Electric Power Generation 790,126,465 1,847,589,379 2.34 5,924 2 Lead Ore and Zinc Ore Mining 746,797,067 783, 140,544 1.05 72 3 Gold Ore Mining 187,690,280 285, 231,764 1.52 255 4 Copper Ore and Nickel Ore Mining 164,894,245 165, 736,271 1.01 156 5 Iron and Steel Mills 132,200,157 576, 390,882 4.36 1,156 6 Hazardous Waste Treatment and Disposal 105,000,685 430, 593,831 4.10 1,673 7 All Other Basic Organic Chemical Manufacturing 91,230,316 2,507,659,432 27.49 3,230 15 Plastics Material and Resin Manufacturing 47,759,444 1,182,155,225 24.75 2,472 18 Petrochemical Manufacturing 35,251,673 1,045,278,191 29.65 1,160 61 Paint and Coating Manufacturing 3,785,958 88,569,586 23.39 2,187 75 Pharmaceutical Preparation Manufacturing 2,927,669 127,941,377 43.70 376 A TRI

- reporting facility

has a high waste

- to

- release ratio when relativel y li ttle is being released on site and relativel y more of it is being managed as a waste. It s management as a waste could involve disposal onsite (e.g., burning for energy recovery or flaring) or offsite (e.g., incineration or burning at a cement kiln for ene rgy recovery). By

contrast, if a solvent were being used as a degreaser onsite, there would be a higher proportion of releases, since a solvent in use as a degreaser releases fugitive volatile emissions. The primary

reason for this footprint is clear in the anal ys is. Of the billion pounds reported of the 16 TRIchemicals by

these 4 sectors, over half is recy cled onsite. The largest ‘waste’ reporting submissions are in the basic organic chemical industry . When they choose to recy cle, virtually all o f chemical is recovered. (>99% of total production related waste) 5 . So there are no other releases or wastes associated with over 500 million of the billion pounds reported. TRI Production Related Waste is reported as a transfer, such as to landfill, un derground injection, POTW, energy

recovery , treatment and recycling. Any onsite or offsite recy cling is reported within the Total Production Related Waste number. So the footprint is clear to discern but not clear in it’s meaning, as the top waste submitters are also the top solvent recy clers. 6 A facilit y in Hopewell VA, (Map 1), has the 2nd and 3 rd largest waste submissions in all of TRIreporting. 2008TRIreporting shows that this facility recy cles 99.38% of its methanol, over 56,000 tons. As Map 1 illustrates, Hopewell also reports 168 tons of methanol being transferred to the local wastewater treatment facility . The methanol could be used as a wastewater facilit y treatment chemical. The use of methanol as a wastewater treatment chemical for r educing nitrate levels in POTWs has been successfully applied. 7

4 Adapted from RTKNET.org, 2009TRI Rank by Waste Reporting 5 See Table 4.4, Appendix 1: Top Waste Reporters / Top Recyclers

- By % of Total Waste 6 Id 7 Nearly 200 w astewater treatment facilities across the US are currently using methanol in their denit rification process. Blue Plains Wastewater Treatment Facility is the single largest point source of nitrogen for the Bay, at 20 tons of nitrogen per day. Methanol denitrification helped to reduce that number to 10 tons per day, half its original nitrogen discharge. The use of methanol denitrification at Blue Plains has resulted in a 30% drop in nitrogen levels in the Chesapeake Bay, from just one treatment plant. www.methanol.ru/ fotos/File/MethanolDenitrification.pdfMap 1.Sectors

The following sections further provide the rationale for the selection of the sectors and chemicals. Pharmaceutical Manufacturing Sector (Pharma): There are 208 submis sions of the 16 chemicals accounting for 10% of the billion pounds reported for the 4 sectors. As confirmed b y this sector’s waste to release ratio, this industry uses, conservatively , 100 kg solvents to make just one kg of Active Pharmaceutical Ingredient. 8 It appears that these companies outsource their ‘waste’ management. The highest percentage of the waste reported, 35% is going to offsite energy recovery . In the current environment, nearly half of these cleanest materials end up in a cement kiln or incinerator. There is both on

- site recy cling (29%) and off

- site recy cling (9%), with a combined total recycling rate of 38%. (See Table 2 below and Tables 1.1 and 1.2 in Appendix 1) Table 2. Pharmaceutical Sector Offsite and Onsite Recy cling

Pa int & Coating Manufacturing Sector (P&C) : There are 991 submissions of the 16 chemicals accounting for 9% of the billion pounds reported for the 4 sectors. As confirmed b y the high number of TRI submissions to a relatively low volume, the Paint & Coating s industry has 1000’s of products and must be able to turn around an order in a short period of time. As such, they

keep a variety

of monomers on hand. 9 These monomers are stored in the processing aid solvents so they

do not react before their time. 10 Th e highest percentage of the waste reported, 62%, is onsite recy cling. Off

- site recy cling account for 23% of the total reported waste, and, when combined with onsite recy cling, this industry has the highest percentage of total waste that is recycled: 85%. (See Table 3 below and Tables 2.1 and 2.2 in Appendix 1)

8 Preamble footnote 21 9 Goldschmidt, A., Streitberger, H., BASF handbook of Coating Technology, Typical Composition of Coatings , Figure 2.1.1, pg 28, 2003. 10 Dan Crowl, H. Dow

Professor for Chemical Process Safety , Michigan Technical University, email from 4/20 /11 Pharmaceutical Sector Recycling: Chemical Offsite Recycling Onsite Recycling METHANOL 1,366,677 7,704,629 CHLOROBENZENE 0 7,672,183 DICHLOROMETHANE 4,235,378 6,072,254 N-BUTYL ALCOHOL 0 4,410,529 TOLUENE 1,187,694 3,422,137 CYCLOHEXANE 0 2,511,052 ACETONITRILE 3,386,714 921,646 METHYL ISOBUTYL KETONE 170,000 0 CHLOROFORM 64,651 0 N-HEXANE 18,000 0 METHYL TERT-BUTYL ETHER 12,056 0 XYLENE (MIXED ISOMERS) 3,118 0 N,N-DIMETHYLFORMAMIDE 162 0 1,2,4-TRIMETHYLBENZENE 0 0 CHLOROMETHANE 0 0 ETHYLBENZENE 0 0Table 3. Paint & Coating Sector Offsite and Onsite Recy cling

Plastic & Resin Manufacturing Sector (P&R) : There are 438 submissions of the 16 chemicals accounting for 17% of the billion pounds reported for the 4 sectors. Petroleum refining and sy nthetic organic chemical manufacturing facilities produce the raw materials used to make plastic resin. Because of integration between the industries, the development of the petrochemical indus try

has contributed strongl y to the growth of the plastic resin industry 11

. The highest percentage of the waste reported, 41%, is onsite recy cling. Off

- site recy cling accounts for just 1% of the total reported waste. When combined with onsite recycling, this industry has a total recy cling rate of 42%. (See Table 4 below and Tables 3.1 and 3.2 in Appendix 1)

Table 4. Plastic & Resin Sector Offsite and Onsite Recycling

11 OECA sector profile notebook on Plastic and Manmade resins. EPA’s OECA Sector Notebook: http:/ /www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/index.html

Plastic & Coating Sector Recycling: Chemical Offsite Recycling Onsite Recycling CYCLOHEXANE 0 22,862,498 METHANOL 6,949,415 19,555,731 XYLENE (MIXED ISOMERS) 1,719,228 13,599,942 METHYL ISOBUTYL KETONE 424,332 7,589,887 N-HEXANE 2,142,264 4,343,100 TOLUENE 193,551 2,985,022 ETHYLBENZENE 366,211 2,171,612 N,N-DIMETHYLFORMAMIDE 0 1,863,080 CHLOROBENZENE 954,563 404,680 N-BUTYL ALCOHOL 93,817 16,514 1,2,4-TRIMETHYLBENZENE 66,172 2,662 DICHLOROMETHANE 0 0 CHLOROMETHANE 0 0 ACETONITRILE 0 0 CHLOROFORM 0 0 METHYL TERT-BUTYL ETHER 0 0 Paint & Coating Sector Recycling: Chemical Offsite Recycling Onsite Recycling XYLENE (MIXED ISOMERS) 2,424,162 25,918,934 METHANOL 310,962 14,164,696 TOLUENE 2,412,244 7,386,339 ETHYLBENZENE 397,294 4,760,217 METHYL ISOBUTYL KETONE 2,607,029 4,628,118 1,2,4-TRIMETHYLBENZENE 70,070 2,133,971 N-BUTYL ALCOHOL 514,642 1,247,171 N-HEXANE 15,865 146,346 DICHLOROMETHANE 52,581 4,876 CYCLOHEXANE 4,574 3,580 N,N-DIMETHYLFORMAMIDE 2,018 0 ACETONITRILE 0 0 CHLOROBENZENE 0 0 CHLOROFORM 0 0 CHLOROMETHANE 0 0 METHYL TERT-BUTYL ETHER 0 0Basic Organic Chemical Manufacturing Sector (BOM): There are 765 submissions o f the 16

chemicals accounting for 63% of the billion pounds reported for the 4 sectors. The organic chemicals industry

is broken down into two categories: bulk and specialt y. The final product for this sector is an actual chemical so it is inherent with in this industry to more effectivel y manage their chemicals on site. Organic Chemicals facilities, large and small volumes, report over 99% of their total production related waste being recy cled on site. 12 These submissions are of high enough volumes to be able to consume all pharmaceutical solvents currently being disposed of in a cement kiln. The highest percentage of the waste reported, 60%, is onsite recycling. There is no off

- site recy cling reported for this industry . (See Table 5 below and Table s 4.1 and 4.2 in Appendix 1) Table 5. Basic Organic Sector Onsite Recycling

All Four Manufacturing Sectors Combined: There are 2402 submissions of the 16 chemicals accounting for the billion pounds reported for all 4 sectors. Onl y 15% of this to tal mass is going to off

- site Energy

Recovery

(cement kiln) and off

- site Thermal Treatment (incinerator). The highest percentage of the waste reported, 53% is onsite recy cling. Off

- site recy cling account for 4% of the total reported waste. When combined with onsite recy cling, all four sectors combined have a total recy cling rate of 57%. On

- site recy cling and off

- site energy

recovery seem to be an ‘all’ of ‘nothing’ choice. Pharma facilities, having the highest off

- site energy

recovery , ty picall y have 100% of their total production related waste going to the cement kiln. When BOM chooses to recy cle, it is ty pically at rates of 100% of their total reported waste. (See Table 6 below and Tables 5.1 and 5.2 in Appendix)

12 See Table 4.4, Appendix 1: Top Waste Reporters / Top Recyclers

- By % of Total Waste Basic Organic Chemical Manufacturing Recycling: Chemical Onsite Recycling METHANOL 254,012,698 TOLUENE 119,123,526 XYLENE (MIXED ISOMERS) 14,510,678 N-BUTYL ALCOHOL 4,316,302 METHYL ISOBUTYL KETONE 3,882,200 ETHYLBENZENE 2,777,434 ACETONITRILE 2,319,728 DICHLOROMETHANE 1,841,486 CHLOROBENZENE 1,047,198 CHLOROMETHANE 508,485 N,N-DIMETHYLFORMAMIDE 436,500 CHLOROFORM 350,000 CYCLOHEXANE 167,981 METHYL TERT-BUTYL ETHER 101,994 N-HEXANE 16,251 1,2,4-TRIMETHYLBENZENE 14,000Table 6. All Four Sectors Combined: Offsite and Onsite Recy cling



### All Four Sectors Rec ycling: Chemical Offsite Recycling Onsite Recycling 

### METHANOL 13,367,148 295,437,754 TOLUENE 5,142,989 132,917,024 XYLENE (MIXED ISOMERS) 4,615,416 54,029,554 CYCLOHEXANE 15,077 25,545,111 METHYL ISOBUTYL KETONE 3,234,301 16,100,205 N-BUTYL ALCOHOL 635,449 9,990,516 ETHYLBENZENE 885,211 9,709,263 CHLOROBENZENE 954,563 9,124,061 DICHLOROMETHANE 5,223,964 7,918,616 N-HEXANE 2,464,066 4,505,697 ACETONITRILE 3,396,731 3,241,374 N,N-DIMETHYLFORMAMIDE 74,830 2,299,580 1,2,4-TRIMETHYLBENZENE 136,244 2,150,633 CHLOROMETHANE 340,000 508,485 CHLOROFORM 75,575 350,000 METHYL TERT-BUTYL ETHER 858,906 101,994Chemicals

Solvents can be broadl y classified into two categories: polar and non - polar , with polar being ‘water

- loving’ and non

- polar being ‘water

- hating’. Non
- Polar Solvents facilitate in the addition and removal of Hydrogen (+H) and / or a meth yl group (

- CH3). Polar Protic Solvents facilitate in the addition and removal of a Hy droxide group (

- OH) and / or the addition or removal of a methyl group (

- CH3). Polar Aprotic Solvents facilitate the addition of substances other than the carbon, h ydrogen and ox ygen. The Polarity

Index of the solvent provides a measure of a solvent's polarity. Water has a Polarit y Index of 10. Solvents with a polarity index of less than 3 are generally consid ered to be non

polar. 13 As a rule of thumb, polar solvents dissolve polar compounds best and non

- polar solvents dissolve non

- polar compounds best: "like dissolves like". Strongl y polar compounds like salt dissolve only

in very polar solvents like water, wh ile strongl y non - polar compounds like oil dissolve only

in very non - polar organic solvents like hexane. Similarly , water and hexane (or vinegar and vegetable oil) do not mix with each other and will quickl y separate into two layers even after being shaken well.

Non
- Polar Solvents : Non

- polar chemicals are made of carbon and hy drogen. Hexane, derived directly from crude oil, has a polarit y index of 0. Reactions using these solvents must be in water and ox ygen free environments as components from these m aterials interfere with the chemical reaction. Primary functions facilitate in the addition and removal of Hydrogen (+H) (hydrogenation / dehydrogenation) and the addition or removal of a methyl group (

- CH3) (alkylation / dealkylation). There are 6 non

- polar solvents: hexane, (1, 2, 4) trimethylbenzene, cy clohexane, ethylbenzene, toluene and xylene. Polar Protic Solvents : On the opposite scale of the non

- polar solvents are the polar protic solvents. Water (H

- O

- H) is a polar protic solvent. Polar protic solvents contain carbon, hydrogen and ox ygen. They differ from non

- polar as their primary function is the addition and removal of a h ydroxide group, (

– OH). Similar to non

- polar is the addition and removal of the methyl group (

- CH3). Methanol is CH3

- OH. There are 3 polar protic solvents: methanol, ethanol and n

- but yl alcohol. Polar Aprotic Solvents : These solvents have a broad range of polarities and are used in reactions with both polar protic and non

- polar solvents. These are specialty ch emicals made in batch processes several stages downstream from the starting building blocks and intermediate materials. Polar aprotics involve addition of other non

- organic substances, such as ammonia / nitrogen and salt / chlorine used to make acetonitri le and chloromethane. Chemical formulations contain carbons and h ydrogen, often contains ox ygen, and often contains another element such as nitrogen or chlorine. There are 9 polar protic solvents: acetonitrile, chlorobenzene, chloroform, chloromethane, d ichloromethane, methyl tert

- but yl ether (MTBE), Meth yl isobutyl ketone (MIK), n,n

- dimethylformamide, and tetrahydrofuran (THF).

13 See Table 7: Solvent Polarity with Health EffectsFunctions

Dow Chemical describes the function of these chemicals as. . “ A special task in that they merely provide assistan ce during the processing of....[chemical] materials. W hen this task is done, they should be removed again as quickly and completely as possible.” 14 This is what allows these materials to be readily

remanufactured. Two primary

categories are manufactured using processing aid solvents in this function: 1

- Specialty

Chemicals: Multi

– stage batch processing reactions where a chemical is ‘built’ onto a backbone, and 2

– Resins: The monomer, poly mers, and film forming agents that must be dissolved before they can be reacted. Used in making another Chemical: High temperatures break or ‘crack’ the carbon double bond, allowing component, x

--- y to be reacted onto the backbone.

Functions include enabling x

- y to attach with the molecule, removing x or y from the reacted molecule, an d removing x or y from the solvent itself so that it may be reused. The more complex the chemical, such as a specialt y chemical or a pharmaceutical, the more steps it takes to get there. These solvents are used in each step. Used in making a (pol ym er) R esin Dow Chemicals terms the ty pes of monomers used in chemical reactions to make poly mers as ‘functional monomers’. A functional monomer will continue to create its own poly mer chain, as aided by

the solvent, by

feeding in more of the functional monomer . Illustrated, again, with ethylene (C2H4)  pol yeth yl ene (C2nH4n):

The studied solvents are universally used to control the reaction conditions, i.e.

– keep the chemical from reacting and controlling the reaction of the chemical. There are a relativel y small subset of solvents used for this function that corresp ond with a broad range of double

- carbon bonded functional groups 15 and functional monomers.

14 Yocum and Nyquist, (e d), Functional Monomers: Their Preparation, Polymerization, and Application, 1973. 15 The theory and application of breaking a double carbon bond of a smaller molecule to make other chemicals is very broad. A series of books on chemistry edited by Patai in clude a double volume (1343 pgs) on “ The chemistry of double

- bonded functional groups ” , John Wiley & Sons, 1978.Health Effects

Risk is a function of hazard and exposure, 16 and, from a hazard perspective, all of these chemicals have suspected or recognized hazardous health ef fects associated with their manufacture, processing, and use. (Table 7) Although EPA and industry have been working to find substitutes for the more hazardous of these solvents, or find way s to use less of them, this has not y et been achieved. In additio n, some of these solvents are building block and primary intermediate chemicals, making them difficult to replace. Until lower

- risk substitutes for these solvents are found, it is helpful from a health risk standpoint to minimize the volume of solvents manufactured and to limit exposure to those already manufactured. The exclusion can help reduce exposure to these solvents in three way s. First, the exclusion would extend the useful life of existing solvents, which would reduce the health risks associat ed with their manufacture by slowing the rate at which they are manufactured. Second, the exclusion would reduce exposure to solvents already manufactured by

reducing the fuel blending of spent solvent. 17 Re

- manufacturing a spent solvent will eliminate th e need for blending it with another spent solvent to satisfy the fuel

- ratio requirements of incinerators and cement kilns. This, in turn, will reduce the fugitive emissions associated with unloading and loading containers of volatile solvents at fuel

- blend ing facilities. All solvents are volatile, and virtually all spent solvents must go through the fuel

- blending process prior to disposal. Third and finally , the exclusion can reduce the potential exposure from any transportation incidents, since it is likel y spent solvents can be transported shorter distances for re

- manufacturing purposes than they can for disposal purposes. 18

.

16 Allen, D., Shonnard, D, Green Engineering: Environmentally Conscious Design of Chemical Processes, Risk Concepts , chapter 2, pgs 35

- 62, Aust in, S., US EPA Editor, Published by Prentice

- Hall, 2001. 17 See 7.6 & 7.7, Appendix 3: Environmental Release and Exposure from Fuel Blending 18 See Map 2 and Figures 6.1

– 6.8, Appendix 2, Regional Maps.Table 7: Solvents by Polarity Index 19 with Health Effects 20

Solvent Che mi cal formula Polarity Index Health Hazard

–

Recognized or Suspected
Non
- polar solvents Hexane CH 3 - CH 2 - CH 2 - CH 2 - CH 2 - CH 3 0.0 Sus: DT, NT, RepT, ResT Cy c lohexane C 6 H 12 0.2 Sus: NT 1,2,4 Trimethylb enzene C 6 H 5 - CH 3 - CH 3 - CH 3 0.8 Sus: BT, NT, ResT Toluene C 6 H 5 - CH 3 2.4 Rec: DT Sus: BT, GT, IT, KT, NT RepT, ResT, ST Ethylbenzene C 6 H 5 - CH 2 - CH 3 2.4 Rec: CT Sus: BT, DT, ET, GT, KT, RepT, ResT, ST Xylene CH 3 CH 2 - O

- CH 2 - CH 3 2.5 Sus: BT, DT, GT, IT, KT, NT, RepT, ResT, ST Polar aprotic solvents Methyl t

- Butyl Ether (MTBE) C 5 H 12 - O 2.5 S us: CT, GT, KT, NT, ResT, ST Chlorobenzene C 6 H 5 - Cl 2.7 Sus: BT, DT, GT, KI, MT, NT, RepT, ST Dichloromethane CH 2 Cl 2 3.1 Rec: CT Sus: BT, ET, GT, KT, NT, RepT, ResT Chloroform CHCl 3 4.1 Rec: CT Sus: BT, T, ET, GT, KT, NT, RepT, ResT Methyl Isobutyl Ketone (CH 3 ) 2 CHCH 2 C(O)CH 3 4.0 Sus: DT, GT, KT, NT, ResT, ST Tetrahydrofuran (THF) /

- CH 2 - CH 2 - O

- CH 2 - CH 2 - \ 4.0 Sus: BT, DT, ET, GT, NT, ResT Acetonitrile (MeCN) CH 3 - C ≡N 5.8 Sus: BT, DT, GT, KT, HT, RepT, ResT Dimethylformamide (DMF) H

- C(=O)N(CH 3 ) 2 6.4 Sus: DT, GT, KT, NT, RepT, ResT, ST Polar protic solvents Butyl Alcohol CH 3 - CH 2 - CH 2 - CH 2 - OH 3.9 Sus: BT, GT, NT, ResT, ST Methanol CH 3 - OH 5.1 Sus: DT, GT, KT, NT, ResT, ST Ethanol CH 3 - CH 2 - OH 5.2 Su s: CT, BT, DT, ET, GT, NT, RepT, ResT, ST Water H

- O

- H 10 Sus: GT, NT Carcinogen: CT Cardiovascular or blood Toxicant: BT Developmental Toxicant: DT Endocri ne Toxicant: ET Gastrointestinal or liver Toxicant: GT Immunotoxicant: IT Kidney Toxicant: KT Muscular Skeletal Toxicant: MT Neurotoxicant: NT Reproductive Toxicant RepT Respiratory Toxicant ResT Skin or Sense Organ Toxican t ST

19 A Charles M. Hansen Hansen solubility parameters: a user's handbook CRC Press, 2007 , ISBN 0849372488 20 Scorecard.org / chemical profiles / health hazards15

MAP 216



### APPENDIX 1: Sector Characterization: Each Sector and All 4 Sectors Combined Pharmaceutical Manufacturing Sector Table 1.1 Production Related Waste (PRW) Offsite Reporting Table 1.2 Production Related Wa ste (PRW) Onsite Reporting & Summary Figure 1.1 US Sector Map 21 Paint & Coatings Manufacturing Sector Table 2.1 Production Related Waste (PRW) Offsite Reporting Table 2.2 Production Related Waste (PRW) Onsite Reporting & Summary Figure 2.1 US Sector Map Plastic & Resin Manufacturing Sector Table 3.1 Production Related Waste (PRW) Offsite Reporting Table 3.2 Production Related Waste (PRW) Onsite Reporting & Summary Figure 3.1 US Sector Map Basic Organic Chemical Manufacturin g Sector Table 4.1 Production Related Waste (PRW) Offsite Reporting Table 4.2 Production Related Waste (PRW) Onsite Reporting & Summary Figure 4.1 US Sector Map, Toluene Subset Table 4.3 Top Waste Reporters / Top Recyclers

- By % of Tot al Waste Table 4.4 Top Waste Reporters / Top Recyclers

- By Total Waste Table 4.5 Top Waste Reporters / Top Recyclers

- By Chemical Figure 4.2 Top Waste Reporter of Toluene: Henry Map Figure 4.3 Top Waste Reporter of Methanol: Hopewell Map
All 4 Sectors Combined Table 5.1 All 4 sector summary w/ RTKNET.org and OECA Sector Profile Notebook Links Table 5.2 Production Related Waste (PRW) Offsite Reporting Table 5.3 Production Related Waste (PRW) Onsite Reporting & Summary Figur e 5.1 US Sector Map: All 4 sectors combined with cement kilns

21 US Sector Maps: Facilities in United States reporting Toluene > 25,000 lbs w aste.17



### APPENDIX 2: Regional Maps: 22 

### Transportation and co
- located Potential Remanufacturing Facilities Figure 6.1 Pharmaceutical: Elkton, VA Figure 6.2 Pharmaceutical: Florence , SC Figure 6.3 Pharmaceutical: Albany, OR Figure 6.4 Basic Organic: Willow Island, WV Figure 6.5 Basic Organic: Elgin SC Figure 6.6 Basic Organic: Georgetown, IL Figure 6.6 Basic Organic Willow Island & Pharmaceutical Elkton Figure 6.7 Basic Organic Elgin & Pharmaceutical Florence Figure 6.8 Basic Organic Georgetown & Pharmaceutical Kalamazoo (Sector Anlysis, Map 2)


### APPENDIX 3: New Chemicals Assessment: Release and Exposure from Toluene Fuel Blending
7.1 Premanufacture Notice (PMN) Process Flow Chart 7.2 New Chemical assessment as it relates to the Remanufacturing Exclusion 7.3 ChemSTEER Worksheet: Manufacture and use (destroyed) as an intermediate Figure 7.1 Puerto Rico Map: Transport of Toluene f rom Pfizer to disposal 7.5 ChemSTEER worksheet: Fuel Blending (unload, blend, load) Activity 7.6 ChemSTEER: Fuel Blending: ENVIRONMENTAL RELEASES ESTIMATE SUMMARY 7.7 ChemSTEER: Fuel Blending: OCCUPATIONAL EXPOSURES ESTIMATE SUMMARY Figure 7.2 Cement Kiln US Sector Map 

### APPENDIX 4: Mass Balance Model and Embedded Emissions Modules
Table 8.1 Mass Balance Model Table 8.2 Modules Embedded in Mass Balance Model

22 Regional Maps: Facilities in Region reporting toluene > 25,000 lbs w aste. Includes current offsite disposal routes and locations of potential remanufacturing f acilities.