Sector Notebook Project Inorganic Chemicals 

This report is one in a series of volumes published by the U.S. Environmental Protection Agency 

(EPA) to provide information of general interest regarding environmental issues associated with 

specific industrial sectors. The documents were developed under contract by Abt Associates 

(Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA). This publication may be 

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 281 
Sector 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 281
Sector 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 281 
Sector 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 281 
Sector 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 281 
Sector 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 281
Sector 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 281
Sector 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 281
Sector 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

NO2 - Nitrogen Dioxide

NOV - Notice of Violation 

NOX - Nitrogen Oxide 

September 1995 iv SIC 281 
Sector 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 

SO2 - Sulfur Dioxide 

SOX - 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 281 

Sector Notebook Project Inorganic Chemicals 

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 

I.A. Summary of the Sector Notebook Project 

Environmental policies based upon comprehensive analysis of air, water and 

land pollution are an inevitable and logical supplement to traditional singlemedia approaches to environmental protection. Environmental regulatory 

agencies are beginning to embrace comprehensive, multi-statute solutions to 

facility permitting, enforcement and compliance assurance, education/ 

outreach, research, and regulatory development issues. The central concepts 

driving the new policy direction are that pollutant releases to each 

environmental medium (air, water and land) affect each other, and that 

environmental strategies must actively identify and address these interrelationships by designing policies for the "whole" facility. One way to 

achieve a whole facility focus is to design environmental policies for similar 

industrial facilities. By doing so, environmental concerns that are common to 

the manufacturing of similar products can be addressed in a comprehensive 

manner. Recognition of the need to develop the industrial “sector-based” 

approach within the EPA Office of Compliance led to the creation of this 

document. 

The Sector Notebook Project was initiated by the Office of Compliance within 

the Office of Enforcement and Compliance Assurance (OECA) to provide its 

staff and managers with summary information for eighteen specific industrial 

sectors. As other EPA offices, states, the regulated community, 

environmental groups, and the public became interested in this project, the 

scope of the original project was expanded. The ability to design 

comprehensive, common sense environmental protection measures for specific 

industries is dependent on knowledge of several inter-related topics. For the 

purposes of this project, the key elements chosen for inclusion are: general 

industry information (economic and geographic); a description of industrial 

processes; pollution outputs; pollution prevention opportunities; Federal 

statutory and regulatory framework; compliance history; and a description of 

partnerships that have been formed between regulatory agencies, the regulated 

community and the public. 

For any given industry, each topic listed above could alone be the subject of 

a lengthy volume. However, in order to produce a manageable document, this 

project focuses on providing summary information for each topic. This 

format provides the reader with a synopsis of each issue, and references where 

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

researched from a variety of sources, and was usually condensed from more 

detailed sources pertaining to specific topics. This approach allows for a wide 

coverage of activities that can be further explored based upon the citations 

September 1995 1 SIC 281 
Sector Notebook Project Inorganic Chemicals 

and references listed at the end of this profile. As a check on the information 

included, each notebook went through an external review process. The Office 

of Compliance appreciates the efforts of all those that participated in this 

process and enabled us to develop more complete, accurate and up-to-date 

summaries. 

I.B. Additional Information 

Providing Comments 

OECA’s Office of Compliance plans to periodically review and update the 

notebooks and will make these updates available both in hard copy and 

electronically. If you have any comments on the existing notebook, or if you 

would like to provide additional information, please send a hard copy and 

computer disk to the EPA Office of Compliance, Sector Notebook Project, 

401 M St., SW (2223-A), Washington, DC 20460. Comments can also be 

uploaded to the Enviro$en$e Bulletin Board or the Enviro$en$e World Wide 

Web for general access to all users of the system. Follow instructions in 

Appendix 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 

The scope of the existing notebooks reflect an approximation of the relative 

national occurrence of facility types that occur within each sector. In many 

instances, industries within specific geographic regions or states may have 

unique characteristics that are not fully captured in these profiles. For this 

reason, the Office of Compliance encourages state and local environmental 

agencies and other groups to supplement or re-package the information 

included in this notebook to include more specific industrial and regulatory 

information that may be available. Additionally, interested states may want 

to supplement the "Summary of Applicable Federal Statutes and Regulations" 

section with state and local requirements. Compliance or technical assistance 

providers may also want to develop the "Pollution Prevention" section in more 

detail. Please contact the appropriate specialist listed on the opening page of 

this notebook if your office is interested in assisting us in the further 

development of the information or policies addressed within this volume. 

If you are interested in assisting in the development of new notebooks for 

sectors not covered in the original eighteen, please contact the Office of 

Compliance at 202-564-2395. 

September 1995 2 SIC 281 
Sector Notebook Project Inorganic Chemicals 

II. INTRODUCTION TO THE INORGANIC CHEMICALS INDUSTRY 

This section provides background information on the size, geographic 

distribution, employment, production, sales, and economic condition of the 

inorganic chemicals industry. The type of facilities described within the 

document are also described in terms of their Standard Industrial 

Classification (SIC) codes. Additionally, this section contains a list of the 

largest companies in terms of sales. 

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

The inorganic chemical industry manufactures over 300 different chemicals 

accounting for about 10 percent of the total value of chemical shipments in the 

U.S.1 This industry categorization corresponds to Standard Industrial 

Classification (SIC) code 281 Industrial Inorganic Chemicals established by 

the Bureau of Census to track the flow of goods and services within the 

economy. The 281 category includes alkalies and chlorine (SIC 2812), 

industrial gases (SIC 2813) (e.g., hydrogen, helium, oxygen, nitrogen, etc.), 

inorganic pigments (SIC 2816), and industrial inorganic chemicals, not 

elsewhere classified (SIC 2819). Approximately two-thirds of the value of 

shipments for the inorganic chemical industry, including over 200 different 

chemicals, are classified under industrial inorganic chemicals, not elsewhere 

classified (SIC 2819). The industry does not include those establishments 

primarily manufacturing organic chemicals, agricultural pesticides, drugs, 

soaps, or cosmetics. However, the 281 industry group does include a 

significant number of integrated firms that are engaged in the manufacture of 

other types of chemicals at the same site. Conversely, many manufacturing 

facilities not categorized under SIC 281, especially 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 their 

processes at the same facility.2 For example, a significant number of inorganic 

chemical manufacturing processes are part of very large chemical 

manufacturing or pulp manufacturing facilities, making characterization 

strictly by SIC code difficult. 

Whenever possible, this notebook describes the entire inorganic chemical 

industry. In many cases, however, specific details relating to some of the 

topics covered by the notebook (facility size, economic trends, geographic 

distribution, pollutant releases, pollution prevention issues, and applicable 

regulations) vary depending on the type of inorganic chemical manufacturing 

process. The large number of different industrial processes used in the 

inorganics industry could not all be covered in this notebook. As a result, 

most sections of this notebook describe the entire inorganic chemical industry 

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

September 1995 3 SIC 281 
Sector Notebook Project Inorganic Chemicals 

to the largest single industrial process within the industry: chlorine and caustic 

soda production (SIC 2812). Section III, Industrial Process Description, 

rather than attempting to describe every inorganic chemical manufacturing 

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 of 

a mineral origin, but not of a basic carbon molecular. Inorganic chemicals are 

used at some stage in the manufacture of a great variety of other products. 

The industry's products are used as basic chemicals for industrial processes 

(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 consumption 

(i.e., mineral fertilizers, glass, and construction materials). The largest use of 

inorganic chemicals is as processing aids in the manufacture of chemical and 

nonchemical products. Consequently, inorganic chemicals often do not 

appear in the final products.3 

Chlor-alkali Sector 

The chlor-alkali industry produces mainly chlorine, caustic soda (sodium 

hydroxide), soda ash (sodium carbonate), sodium bicarbonate, potassium 

hydroxide, and potassium carbonate. In 1992, chlorine and caustic soda 

production accounted for about 80 percent of the chlor-alkali industry's value 

of shipments and, in terms of weight, were the eighth and ninth largest 

chemicals produced in the U.S., respectively. Chlorine and caustic soda are 

co-products produced in about equal amounts primarily through the 

electrolysis of salt (brine).4 

The majority of domestic chlorine production (70 percent) is used in the 

manufacturing of organic chemicals including: vinyl chloride monomer, 

ethylene dichloride, glycerine, glycols, chlorinated solvents, and chlorinated 

methanes. Vinyl chloride, which is used in the production of polyvinyl 

chloride (PVC) and many other organic chemicals, accounts for about 38 

percent of the total domestic chlorine production. The pulp and paper 

industry consumes approximately 15 percent of U.S. chlorine production, and 

about eight percent is used in the manufacturing of other inorganic chemicals. 

Other major uses are disinfection treatment of water, and the production of 

September 1995 4 SIC 281 
Sector Notebook Project Inorganic Chemicals 

hypochlorites. More than two-thirds of all chlorine is consumed in the same 

manufacturing plant in the production of chemical intermediates.5 

The largest users of caustic soda are the organic chemicals industry (30 

percent) and the inorganic chemicals industry (20 percent). The primary uses 

of caustic soda are in industrial processes, neutralization, and off-gas 

scrubbing; as a catalyst; and in the production of alumina, propylene oxide, 

polycarbonate resin, epoxies, synthetic fibers, soaps, detergents, rayon, and 

cellophane. The pulp and paper industry uses about 20 percent of total 

domestic caustic soda production for pulping wood chips, and other 

processes. Caustic 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 chemical industry is characterized by a relatively large number 

of small facilities. The Bureau of the Census identified 665 companies a operating 1,429 facilities within SIC 281 in 1992. Most of these facilities

were classified under SIC 2819 -- industrial inorganic chemicals, not 

elsewhere classified -- which are typically smaller facilities producing specialty 

inorganic chemicals. The Bureau of Census employment data for 1992 

(Exhibit 1) indicated that about 63 percent of inorganic chemical facilities 

employed fewer than 20 people. A significant portion of inorganic chemicals 

are produced and used within the same plant in the manufacturing of organic 

chemicals. The number of these facilities and the number of people employed 

in the inorganic chemical production 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 281 
Sector 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. 

Inorganic chemical facilities are typically located near consumers and to a 

lesser extent raw materials. The largest use of inorganic chemicals is in 

industrial processes for the manufacture of chemicals and nonchemical 

products; therefore, 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 chemicals produced are used by the organic 

chemicals manufacturing industry, the geographical distribution of inorganic 

facilities is very similar to that of organic chemicals facilities (Exhibit 2). 

September 1995 6 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Exhibit 2: Inorganic Chemicals Facilities Distribution 

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Miles 

0 100 200 300 400

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

Chlor-alkali Sector 

The alkali and chlorine industry, however, consists of a relatively small 

number of medium to large facilities. The Bureau of the Census identified 34 

companies operating 51 facilities within the SIC 2812 in 1992. According to 

The Chlorine Institute (an industry trade group), there were 25 companies 

operating 52 chlorine production plants in 1989. The Bureau of Census 

employment data for 1992 indicated that about 60 percent of those employed 

in the chlor-alkali industry worked at facilities with over 50 employees 

(Exhibit 1).7,8 

The distribution of the chlor-alkali sector differs from that of the inorganic 

chemicals industry as a whole. Since chlorine and caustic soda are coproducts produced in almost equal amounts, the distribution of the caustic 

soda manufacturing industry is essentially the same as the chlorine 

manufacturing industry. Chlorine is difficult to store and transport 

economically; therefore, chlorine and caustic soda are produced near the 

September 1995 7 SIC 281 
Sector Notebook Project Inorganic Chemicals 

chlorine consumers which are primarily chemical manufacturers and pulping 

operations. Consequently, chlor-alkali facilities are concentrated near the 

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 located 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 281 
1

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 Gale 

Research Inc., compiles financial data on U.S. companies including those 

operating within the inorganic chemicals manufacturing industry. Ward’s 

ranks U.S. companies, whether they are a parent company, subsidiary or 

division, by sales volume within the 4-digit SIC codes that they have been 

assigned as their primary activity. Exhibit 4 lists the top ten inorganic 

chemical manufacturing companies in the U.S. Readers should note that: 1) 

Companies are assigned a 4-digit SIC that most closely resembles their 

principal industry; and 2) Sales figures include total company sales, including 

sales derived from subsidiaries and operations not related to the manufacture 

of inorganic chemicals. Additional sources of company specific financial 

information 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 

Ranka Companyb 

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 281 
Sector Notebook Project Inorganic Chemicals 

II.B.3. Economic Trends 

Inorganic Chemicals Industry 

The Bureau of the Census estimated that there were 1,429 facilities in the 

inorganic chemical industry in 1992. The industry employed 103,000 people 

and had a total value of shipments of $27.4 billion. The total value of 

shipments for the inorganic chemicals industry increased about one percent 

per year between 1992 and 1994. These values do not include inorganic 

chemicals manufactured for captive use within a facility nor the value of other 

non-industrial inorganic chemical products manufactured by the same facility. 

It does, however, include intra-company transfers which are significant in this 

industry. The inorganic chemical industry's growth rate is expected to 

continue to increase with the growth of the economy. The U.S. is a net 

exporter of inorganic chemicals with most exports shipped to the European 

Community (EC) followed by Canada and Mexico. This positive trade 

balance increased significantly in 1993 to $1.7 billion and is expected to 

continue as the European economy improves. By comparison, the 1992 

Census of Manufactures for Industrial Organic Chemicals reports a 1992 

value of shipments for organic chemicals of $64.5 billion and a total 

employment of 125,100 people. The 1992 value of shipments for the entire 

chemical industry (SIC 28) totaled $292.3 billion with an employment of 

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 growth in output, as a reflection of the U.S. 

economy's recession. The industry has historically had low profit margins 

which, in recent years, have decreased further with increasing pollution 

abatement costs.11 

Chlor-alkali Sector 

The Bureau of the Census data for 1992 shows that there were 51 facilities 

within the inorganic chemicals industry that manufactured alkalies and 

chlorine. These chlor-alkali facilities employed 8,000 people and had a total 

value 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 can depend on the demand of the other product. The market 

pull has switched several times between caustic soda and chlorine in the past 

few decades. Presently, chlorine demand is controlling production; 

September 1995 10 SIC 281 
Sector 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 the 

consumption of chlorine, however, and domestic caustic soda demand is 

expected to control production in the coming years.12 

After reaching record high levels in the late 1970s, chlorine production 

declined in the early 1980s due in part to the economic recession between 

1980 and 1982. Chlorine production increased slowly through the 1980s and, 

as of 1992, had not reached the record high levels and growth rates of the 

1970s. This is due in part to the relative maturity of the chlorine usage 

industries and more recent environmental pressures aimed at curtailing 

chlorine use. Regulatory restrictions on the production or disposal of some 

products which require large amounts of chlorine to manufacture (i.e., 

chlorofluorocarbons, PVC, and chlorinated solvents) have adversely affected 

the market. Chlorine's commercial appeal has been further reduced by 

initiatives such as the International Joint Commission of Great Lakes Water 

Quality (a Canada-U.S. environmental oversight group) and a number of 

environmental groups 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 stored 

economically. Increased demand for chlorine must be met immediately by 

increased chlorine production via electrolysis of brine and, consequently, 

caustic soda production. Domestic and export demand for caustic soda was 

very strong in the 1980s with the pick up of the world economy and an 

increase 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. The demand for caustic soda is expected to continue to 

grow 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 from 

natural sources of trona ore. Demand for caustic soda may also decrease as 

pulp mills increase their reclamation of caustic soda from spent pulping 

liquor.14 

September 1995 11 SIC 281 

Sector Notebook Project Inorganic Chemicals 

III. INDUSTRIAL PROCESS DESCRIPTION 

This section describes the major industrial processes within the inorganic 

chemical industry, including the materials and equipment used, and the 

processes employed. The section is designed for those interested in gaining 

a general understanding of the industry, and for those interested in the interrelationship between the industrial process and the topics described in 

subsequent sections of this profile -- pollutant outputs, pollution prevention 

opportunities, and Federal regulations. This section does not attempt to 

replicate published engineering information that is available for this industry. 

Refer to Section IX for a list of reference documents that are available. 

This section specifically contains a description of commonly used production 

processes, associated raw materials, the byproducts produced or released, and 

the materials either recycled or transferred off-site. This discussion, coupled 

with schematic drawings of the identified processes, provide a concise 

description of where wastes may be produced in the process. This section 

also describes the potential fate (via air, water, and soil pathways) of these 

waste products. 

III.A. Industrial Processes in the Inorganic Chemical Industry 

Chlorine and caustic soda are co-products of electrolysis of saturated aqueous 

solutions of sodium chloride, NaCl (salt water or brine). In addition, 

relatively small amounts (by weight) of hydrogen gas are produced in the 

process. The overall chemical reaction is as follows: 

2 NaCl + 2 H2O v 2 NaOH + Cl2 + H2 

Energy, in the form of direct current (d-c) electricity, is supplied to drive the 

reaction. The 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 28 

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

Virtually all chlorine produced in the U.S. is manufactured by one of these 

three electrolysis processes. Each electrolytic cell consists of an anode and 

September 1995 13 SIC 281 
Sector Notebook Project Inorganic Chemicals 

cathode in contact with the brine solution. Exhibit 5 shows the basic 

elements, inputs and outputs of each type of electrolytic cell. The 

distinguishing feature of each cell type is the method employed to separate 

and prevent the mixing of the chlorine gas and sodium hydroxide. 

Consequently, each process produces a different purity of chlorine gas and a 

different 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, followed by mercury cells with 

17 percent, and membrane cells with five percent. The industry is moving 

away from mercury and diaphragm cells and is moving towards the use of 

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 281 
Sector Notebook Project Inorganic Chemicals 

Exhibit 5: Chlorine Electrolysis Cells 

September 1995 15 SIC 281
Sector 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 RuO2 

or TiO2 coating

(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 

H2 

30-33% NaOH and 

H2 

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 

Cl2 

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 through 

which a thin layer of mercury (about three mm) flows over the bottom 

(Exhibit 7). The cells are operated at 75 to 85 EC and atmospheric pressure. 

The mercury layer serves as the cathode for the process and the saturated 

brine solution (25.5 percent NaCl by weight) flows through the troughs above 

the mercury. The anodes are usually incorporated into the cell covers and are 

suspended horizontally in the brine solution. The height of the anodes within 

the brine is adjusted to the optimal height either manually or through an 

automatic computer controlled system.17 

Electrolytic cell anodes were made of graphite until the late 1960s when 

anodes of titanium coated with ruthenium oxide (RuO2) and titanium oxide 

(TiO2) were developed. The RuO2 and TiO2 anodes, termed DSA 

(dimensionally stable) anodes, are more stable than the graphite anodes (i.e., 

they do not need to be replaced as frequently) and are more energy efficient.18 

September 1995 16 SIC 281 
Sector 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 extraction slits in the cell covers. Sodium ions are absorbed by the 

mercury layer and the resulting sodium and mercury mixture, called the 

amalgam, is processed in "decomposer" cells to generate sodium hydroxide 

and reusable mercury. The amalgam entering the decomposer cell has a 

sodium concentration of approximately 0.2 to 0.5 percent by weight. The 

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 

flowing through the cell come into direct contact with the graphite. The 

hydrolysis of the water on the graphite in the presence of the amalgam results 

in a strong exothermic reaction generating mercury to be reused in the 

electrolytic cell, a 50 percent caustic soda solution, and hydrogen gas. 

Mercury cells are operated to maintain a 21 to 22 percent by weight NaCl 

concentration in the depleted 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 

solution and use new brine as make-up in order to prevent the build up of 

sulfate impurities in the brine.19,20 

September 1995 17 SIC 281 
Sector Notebook Project Inorganic Chemicals 

The mercury process has the advantage over diaphragm and membrane cells 

in that it produces a pure chlorine gas with no oxygen, and a pure 50 percent 

caustic soda solution without having to further concentrate a more dilute 

solution. However, mercury cells operate at a higher voltage than diaphragm 

and membrane cells and, therefore, use more energy. The process also 

requires a very pure brine solution with little or no metal contaminants. 

Furthermore, elaborate precautions must be taken to avoid releases of 

mercury to the environment. 

III.A.2. Diaphragm Cell 

In the diaphragm cell process, multiple cells consisting of DSA anode plates 

and cathodes are mounted vertically and parallel to each other (Exhibit 8). 

Each cell consists of one anode and cathode pair. The cathodes are typically 

flat hollow steel mesh or perforated steel structures covered with asbestos 

fibers, which serve as the diaphragm. The asbestos fiber structure of the 

diaphragm prevents the mixing of hydrogen and chlorine by allowing liquid to 

pass through to the cathode, but not fine bubbles of chlorine gas formed at the 

anodes. The diaphragm also hinders the back-diffusion to the anode of - hydroxide (OH ) ions formed at the cathode. The cells are operated at 90 to

95 EC and atmospheric pressure. Brine flows continuously into the anode 

chamber and, subsequently, through the diaphragm to the cathode. As in the 

mercury cell process, chlorine gas is formed at the anodes; however, in the 

diaphragm process, caustic soda solution and hydrogen gas are formed 

directly at the cathode. The chlorine gas is drawn off from above the anodes 

for further processing. The hydrogen gas is drawn off separately from the 

cathode chambers.21,22 

Two basic types of diaphragm cells are in use today. The first, monopolar 

cells, have an electrode arrangement in which the anodes and cathodes are 

arranged in parallel. As a result of this configuration, all cells have the same 

voltage of about three to four volts; up to 200 cells can be constructed in one 

circuit. The second basic type of diaphragm cell is the bipolar cell, in which 

the anode of one cell is directly connected 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 the 

reduced anode and cathode surface area in the bipolar configuration, bipolar 

units tend to be much larger than monopolar units. Production of chlorine 

and caustic soda by the diaphragm process is split approximately equally 

between monopolar and bipolar systems.23 

September 1995 18 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Exhibit 8: Typical Diaphragm Electrolysis Cell and Flow Diagram 

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

Diaphragm cells are operated 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 the 

mercury cell process.24 

Diaphragms are constructed of asbestos because of its chemical and physical 

stability and because it is a relatively inexpensive and abundant material. 

Beginning in the early 1970s, asbestos diaphragms began to be replaced by 

diaphragms containing 75 percent asbestos and 25 percent fibrous 

September 1995 19 SIC 281 
Sector Notebook Project Inorganic Chemicals 

polytetrafluoroethylene (PTFE). These diaphragms, trade named Modified 

Diaphragms, are more stable and operate more efficiently than the fully 

asbestos diaphragms. Modified Diaphragms are the most common 

diaphragms currently in use.25 

Diaphragm cells have the advantage of operating at a lower voltage than 

mercury cells and, therefore, use less electricity. In addition, the brine 

entering a diaphragm cell can be less pure than that required by mercury and 

membrane 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 the 

caustic soda produced contains chlorides and requires evaporation to bring it 

to a usable concentration.26 

III.A.3. Membrane Cell 

In the membrane cell process, the anode and cathode are separated by a 

water-impermeable ion-conducting membrane (Exhibit 9). Brine solution 

flows through the anode compartment where chlorine gas is generated. The 

sodium ions migrate through the membrane to the cathode compartment 

which contains flowing caustic soda solution. Water is hydrolyzed at the - cathode, releasing 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 solution produced does not contain salt as in the diaphragm cell 

process. Depleted brine is discharged from the anode compartment and 

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 the 

substrate and that increases surface area and electrical conductivity. Coating 

materials include Ni-S, Ni-Al, and Ni-NiO mixtures, as well as mixtures of 

nickel and platinum group metals. Anodes are typically of the DSA type.28 

The most critical components of the membrane cells are the membranes 

themselves. The membranes must remain stable while being exposed to 

chlorine on one side and a strong caustic solution on the other. Furthermore, 

the membranes must have low electrical resistance, and allow the transport of 

sodium ions and not chloride ions and reinforcing fabric, and a 

perfluorocarboxlate polymer all bonded together. 

September 1995 20 SIC 281 
Sector 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 the diaphragm cell process, the bipolar cells have less voltage loss 

between the cells than the monopolar cells; however, the number of cells 

connected together in the same circuit is limited.29 

Membrane cells have the advantages of producing a very pure caustic soda 

solution and of using less electricity than the mercury and diaphragm 

processes. In addition, the membrane process does not use highly toxic 

materials such as mercury and asbestos. Disadvantages of the membrane 

process are that the chlorine gas produced must be processed to remove 

oxygen and water vapor, and the caustic soda produced must be evaporated 

to increase the concentration. Furthermore, the brine entering a membrane 

cell must be of a very high purity, which often requires costly additional 

purification steps prior to electrolysis.30 

September 1995 21 SIC 281 
Sector Notebook Project Inorganic Chemicals 

III.A.4. Auxiliary Processes 

Brine Purification 

Approximately 70 percent of the salt used in chlorine gas production is 

extracted from natural salt deposits; the remainder is evaporated from 

seawater. Salt from natural deposits is either mined in solid form or is leached 

from the subsurface. Leaching involves the injection of freshwater into 

subterranean salt deposits and pumping out brine solution. Brine production 

from seawater typically occurs by solar evaporation in a series of ponds to 

concentrate the seawater, precipitate out impurities, and precipitate out solid 

sodium chloride. Regardless of the method used to obtain the salt, it will 

contain impurities that must be removed before being used in the electrolysis 

process. Impurities primarily consist of calcium, magnesium, barium, iron, 

aluminum, sulfates, and trace metals. Impurities can significantly reduce the 

efficiency of the electrolytic cells, by precipitating out and subsequently 

blocking a diaphragm or damaging a membrane depending on the process 

used. Certain trace metals, such as vanadium, reduce the efficiency of 

mercury cells and cause the production of potentially dangerous amounts of 

hydrogen gas. Removal of impurities accounts for a significant portion of the 

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

In addition to the dissolved natural impurities, chlorine must be removed from 

the 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 which 

reduces product yields. In addition, chlorine gas in the brine solution will 

cause corrosion of pipes, pumps, and containers during further processing of 

the brine. In a typical chlorine plant, HCl is added to the brine solution 

leaving the cells to liberate the chlorine gas. A vacuum is applied to the 

solution to collect the chlorine gas for further treatment. To further reduce 

the chlorine levels, sodium sulfite or another reducing agent is added to 

remove the final traces of chlorine. Dechlorinated brine is then resaturated 

with solid salt before further treating to remove impurities.32 

Depending on the amount of impurities 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 of 

impurities. Calcium carbonate impurities are precipitated out through 

treatment with sodium carbonate; magnesium, iron, and aluminum are 

precipitated out through treatment with sodium hydroxide; and sulfates are 

precipitated out through the addition of calcium chloride or barium carbonate. 

Most trace metals are also precipitated out through these processes. 

Flocculants are sometimes added to the clarifying equipment to improve 

September 1995 22 SIC 281 
Sector Notebook Project Inorganic Chemicals 

settling. The sludges generated in this process are washed to recover 

entrained sodium chloride. Following the clarification steps, the brine solution 

is typically passed through sand filters followed by polishing filters. The brine 

passing through these steps will contain less than four parts per million (ppm) 

calcium and 0.5 ppm magnesium which is sufficient purification for the 

diaphragm and mercury cell processes. For brine to be used in the membrane 

process, however, requires a combined calcium and magnesium content of less 

than 20 parts per billion (ppb). 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 water 

vapor. Chlorine gas from the diaphragm process also contains liquid droplets 

of sodium hydroxide and salt solution. The first steps in processing the 

chlorine to a usable product consists of cooling the chlorine to less than ten 

degrees centigrade and then passing it through demisters or electrostatic 

precipitators to remove water and solids. 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 sulfuric acid mist. If the chlorine is to be 

liquefied, liquid chlorine is then added 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 reaching the chlorine-steel ignition point during 

compression.34 

Chlorine gas is either used in gaseous form within the facility, transferred to 

customers via pipeline, or liquefied for storage or transport. Liquid chlorine 

is of a higher purity than gaseous chlorine and is either used within the facility 

or is transferred via rail tank car, tank truck, or tank barge. The demand for 

liquid chlorine has increased in recent years and, in 1987, accounted for about 

81 percent of chlorine produced in the U.S.35 

Chlorine liquefaction processes typically liquefy only about 90-95 percent of 

the chlorine. This gas and the chlorine gas left inside tank truck tanks, rail car 

tanks, or barges after removal of liquid chlorine is impure and must be 

recovered in a chlorine recovery unit. The gas is compressed and cooled 

using 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. 

The chlorine gas is cooled and scrubbed of carbon tetrachloride using liquid 

chlorine and the resulting pure chlorine is sent to the chlorine liquefaction 

system.36 

Caustic Soda Processing 

September 1995 23 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Caustic soda solution generated from chlor-alkali processes is typically 

processed to remove impurities and to concentrate it to either a 50 percent or 

73 percent water-based solution or to anhydrous caustic soda. The caustic 

soda from the mercury and membrane processes is relatively pure. Product 

from the mercury process requires only filtration to remove mercury droplets. 

The evaporators used to concentrate the caustic soda solution in the 

diaphragm process are typically multi-stage forced circulation evaporators. 

The evaporators have salt settling systems to remove precipitated salt. 

Sodium borohydride is often added to reduce corrosion of the equipment. 

Evaporators for the membrane process are usually much simpler than those 

for the diaphragm process because the salt concentration in the membrane cell 

caustic solution is very low.37 

Hydrogen Processing 

The hydrogen produced in all of the electrolytic processes contains small 

amounts of water vapor, sodium hydroxide, and salt which is removed 

through cooling. The hydrogen produced during the mercury cell process also 

contains small amounts of mercury which must be removed by cooling the 

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 and pollutant outputs of the chlor-alkali industry are relatively small 

both in number and volume in comparison to the chemical manufacturing 

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 and 

purifying the chlorine gas produced. The major pollutant outputs from all 

three electrolytic processes are chlorine gas emissions (both fugitive and point 

source); spent acids; freon (both fugitive and point source); impurities 

removed from the input salt or brine; and pollutants originating from 

electrolytic cell materials and other system parts. 

Pollutant outputs have decreased in recent years as the industry moves away 

from the mercury and diaphragm cell processes to the more efficient (in terms 

of material and energy inputs and outputs) membrane cell process. In 

addition, improved cell part materials have been developed, such as DSA 

anodes and Modified Diaphragms, which are more stable and create less 

undesirable byproducts. 

Inputs and pollutant outputs from the auxiliary processes such as brine 

purification, chlorine processing, caustic soda processing, and hydrogen 

processing are described in Section III.B.4. 

September 1995 24 SIC 281 
Sector Notebook Project Inorganic Chemicals 

III.B.1. Mercury Cell 

Wastewater streams from mercury cell facilities arise from the chlorine drying 

process, brine purge, and miscellaneous sources. Small amounts of mercury 

are found in the brine purge and miscellaneous sources which include floor 

sumps and cell wash water. Before treatment, mercury concentrations 

(principally in the form of mercuric chloride, HgCl4

2-) typically range from 0 

to 20 ppm. Thereby segregating most mercury bearing wastewater streams 

from non-mercury bearing wastewater streams. Prior to treatment, sodium 

hydrosulfide is used to precipitate mercuric sulfide. The mercuric sulfide is 

removed through filtration before the water is discharged.39 

Air emissions consist of mercury vapor and chlorine gas released in relatively 

small amounts as fugitive emissions from the cells; and in the tail gases of the 

chlorine processing, caustic soda processing, and hydrogen processing. 

Process tail gases are wet scrubbed with 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 and 

mercury emissions are negligible. The tail gas scrubber water is typically 

reused as brine make-up water.40 

Solid wastes containing mercury include: solids generated during brine 

purification; spent graphite from decomposer cells; spent caustic filtration 

cartridges from the filtration of caustic soda solution; spilled mercury from 

facility sumps; and mercury cell "butters," which are semisolid amalgams of 

mercury with barium or iron formed when an excess of barium is used during 

salt purification. Most mercury bearing solid wastes are shipped off-site to 

outside reclaimers who recover the mercury. The remaining wastes are 

disposed of in secure landfills using either chemical or physical methods to 

recover maximum feasible amount of mercury.41 

III.B.2. Diaphragm Cell 

Wastewater streams from the diaphragm cell process originate from the 

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 lead 

and graphite anodes and asbestos diaphragms generates lead, asbestos, and 

chlorinated hydrocarbons in the caustic soda and chlorine processing waste 

streams. Lead salts and chlorinated hydrocarbons are generated from 

corrosion of the anodes, and asbestos particles are formed by the degradation 

of the diaphragm with use. Over the past twenty years, all but a few 

diaphragm cell facilities have switched from the use of lead and graphite 

anodes with asbestos diaphragms to DSA anodes and Modified Diaphragms 

which resist corrosion and degradation. The lead, asbestos, and chlorinated 

September 1995 25 SIC 281 
Sector Notebook Project Inorganic Chemicals 

hydrocarbon 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 relatively 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 chlorine 

emissions in tail gases after treatment are negligible. The spent caustic 

solution is neutralized prior to discharge.43 

Solid wastes generated in the diaphragm process consist primarily of solids 

generated during brine purification and scrapped cell parts including, cell 

covers, piping and used diaphragms. Discarded cell parts are either landfilled 

on-site, as is typically the case for spent diaphragms, or shipped off-site for 

disposal. Used cathodes and DSA anodes are shipped off-site for recovery of 

their titanium content.44 

III.B.3. Membrane Cell 

Wastewater from the diaphragm cell process originates from the barometric 

condenser during caustic soda evaporation, chlorine drying, and wash water 

from the ion exchange resin used to purify the brine solution. The ion 

exchange wash water consists of dilute hydrochloric acid with small amounts 

of dissolved calcium, magnesium, and aluminum chloride. The wastewater is 

combined with the other process wastewaters and treated by neutralization.45 

Chlorine is released in relatively 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 chlorine 

emissions in tail gases after treatment are negligible. The spent caustic 

solution is neutralized prior to discharge.46 

Solid waste generated in the diaphragm process consists primarily of solids 

generated during brine purification and used cell parts which include 

membranes, cathodes and DSA anodes. The used membranes are typically 

returned to the supplier and the used cathodes and DSA anodes are shipped 

off-site for recovery of their titanium content.47 

III.B.4. Auxiliary Processes 

Brine Purification 

Brine solutions are typically treated with a number of chemicals to remove 

impurities prior to input to the electrolytic cells. In the case of mercury and 

September 1995 26 SIC 281 
Sector Notebook Project Inorganic Chemicals 

membrane cell systems, the brine is first acidified with HCl to remove 

dissolved chlorine. Next, sodium hydroxide and sodium carbonate are added 

to precipitate calcium and magnesium ions as calcium carbonate and 

magnesium hydroxide. Barium carbonate is then added to remove sulfates 

which precipitate out as barium sulfate. The precipitants are removed from 

the brine solution by settling and filtration. Pollutant outputs from this 

process include fugitive chlorine emissions and brine muds.48 

Brine muds are one of the largest waste streams of the chlor-alkali industry. 

On average, about 30 kilograms (kg) of brine mud are generated for every 

1,000 kg of chlorine produced. The volume of mud will vary, however, 

depending on the purity of the salt used. Some facilities use pre-purified (i.e., 

chemical grade) evaporated salts which will produce only 0.7 to 6.0 kg of 

brine mud per 1,000 kg of chlorine produced. Brine mud typically contains 

magnesium hydroxide, calcium carbonate, and, in most cases, barium sulfate. 

Mercury cell brine muds usually contain mercury either in the elemental form 

or as the complex ion, mercuric chloride (HgCl4

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 in 

lagoons on-site. When the lagoons become filled, the brine mud is either 

dredged and landfilled off-site, or drained and covered over. Some plants that 

use brine solution leached from subterranean deposits inject brine muds into 

the salt cavities that are no longer being used.50 

Chlorine Processing 

The chlorine gas recovered from electrolytic cells is cooled to remove water 

vapor. The condensed water is usually recycled as brine make-up although 

some facilities combine this waste stream with other waterborne waste 

streams prior to treatment. The remaining water vapor is removed by 

scrubbing 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 of 79 percent sulfuric acid wastewater is generated per 1,000 kg of 

chlorine produced. The majority of the spent sulfuric acid waste is shipped 

off-site for refortification to concentrated sulfuric acid or for use in other 

processes. The remainder 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 the 

absorption of the chlorine in a stream of carbon tetrachloride. The chlorine 

is subsequently removed in a stripping process in which the carbon 

tetrachloride is either recovered and reused, or is vented to the atmosphere.52 

September 1995 27 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Caustic Soda Processing 

Caustic soda solution generated from chlor-alkali processes is typically 

processed to remove impurities and, in the case of the diaphragm and 

membrane processes, is concentrated to either a 50 percent or 73 percent 

water-based solution or 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 evaporators is condensed in barometric condensers 

and, in the case of the diaphragm process, will primarily contain about 15 

percent caustic soda solution and high concentrations of salt. If sodium 

sulfate is not removed during the brine purification process, salt recovered 

from the evaporators is often recrystallized to avoid sulfate buildup in the 

brine. If the salt is recrystallized, the wastewater from sodium hydroxide 

processing will also contain sodium sulfates. Significant levels of copper may 

also be present in the wastewater due to corrosion of pipes and other 

equipment. Wastewater from the membrane process contains caustic soda 

solution and virtually no salt or sodium sulfates.53 

Caustic soda processing wastewater is typically neutralized with hydrochloric 

acid, lagooned, and then discharged directly to a receiving water or land 

disposed. The caustic soda generated from the mercury process only requires 

filtration to remove mercury droplets which are typically recovered for reuse. 

Hydrogen Processing 

The hydrogen produced in all of the electrolytic processes contains small 

amounts of water vapor, sodium hydroxide, and salt which is removed 

through cooling. Condensed salt water and sodium hydroxide solution is 

either recycled as brine make-up or treated with other waterborne waste 

streams. The hydrogen produced during the mercury cell process, however, 

also contains small amounts of mercury which must be removed prior to 

liquefaction. Most of the entrained mercury is extracted by cooling the gas. 

The condensed mercury is then returned to the electrolytic cells. Some 

facilities further purify the hydrogen gas of mercury using activated carbon 

treatment. Spent activated carbon is typically shipped off-site as a hazardous 

waste.54 

III.C. Management of Chemicals In Wastestream 

The Pollution Prevention Act of 1990 (PPA) requires facilities to report 

information about the management of TRI chemicals in waste and efforts 

made to eliminate or reduce those quantities. These data have been collected 

annually in Section 8 of the TRI reporting Form R beginning with the 1991 

reporting year. The data summarized below cover the years 1992-1995 and 

is meant to provide a basic understanding of the quantities of waste handled 

September 1995 28 SIC 281 
Sector Notebook Project Inorganic Chemicals 

by the industry, the methods typically used to manage this waste, and recent 

trends in these methods. TRI waste management data can be used to assess 

trends in source reduction within individual industries and facilities, and for 

specific TRI chemicals. This information could then be used as a tool in 

identifying opportunities for pollution prevention compliance assistance 

activities. 

From the yearly data presented below it is apparent that the portion of TRI 

wastes reported 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 reported for 1992 and 1993 are estimates of 

quantities already managed, the quantities reported for 1994 and 1995 are 

projections only. The PPA requires these projections to encourage facilities 

to consider future waste generation and source reduction of those quantities 

as well as movement up the waste management hierarchy. Future-year 

estimates are not commitments that facilities reporting under TRI are required 

to meet. 

Exhibit 10 shows that the inorganic chemicals industry managed about 1.7 

trillion pounds of production-related waste (total quantity of TRI chemicals 

in the waste 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 environment. Column C is calculated by 

dividing the total TRI transfers and releases by the total quantity of 

production-related waste. In other words, about 85 percent of the industry’s 

TRI wastes were managed on-site through recycling, energy recovery, or 

treatment as shown in columns E, F and G, respectively. The majority of 

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 

related wastes (11 percent), shown in column D, is either released to the 

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 of 

ProductionRelated 

Waste 

6 a Transferred 

% Released 

and b Off-site 

% Released 

and 

Disposedc 

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 281
Sector 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 comparative 

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 within SIC Codes 20-39 (manufacturing industries) that 

have more than 10 employees, and that are above weight-based reporting 

thresholds 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 sector 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 sector, it is an excellent tool for drawing comparisons 

across industries. 

Although this sector notebook does not present historical information 

regarding TRI chemical releases, please note that in general, toxic chemical 

releases across all industries have been declining. In fact, according to the 

1993 Toxic Release Inventory Data Book, reported releases dropped by 42.7 

percent between 1988 and 1993. Although on-site releases have decreased, 

the total amount of reported toxic waste has not declined because the amount 

of toxic chemicals transferred off-site has increased. Transfers have increased 

from 3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. Better 

management practices have led to increases in off-site transfers of toxic 

chemicals for recycling. More detailed information can be obtained from 

EPA's annual Toxics Release Inventory Public Data Release book (which is 

available through the EPCRA Hotline at 800-535-0202), or directly from the 

Toxic Release Inventory System database (for user support call 202-260-

1531). 

Wherever possible, the sector notebooks present TRI data as the primary 

indicator of chemical release within each industrial category. TRI data 

provide the type, amount and media receptor of each chemical released or 

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 facilities are not subject to TRI reporting 

because they are not considered manufacturing industries, or because they are 

below TRI reporting thresholds. Examples are the mining, dry cleaning, 

September 1995 31 SIC 281 
Sector 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. 

Weighting each pound of release equally does not factor in the relative 

toxicity of each chemical that is released. The Agency is in the process of 

developing an approach to assign toxicological weightings to each chemical 

released so that one can differentiate between pollutants with significant 

differences in toxicity. As a preliminary indicator of the environmental impact 

of the industry's most commonly released chemicals, the notebook briefly 

summarizes 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 statistical 

classification standard used for all establishment-based Federal economic 

statistics. The SIC codes facilitate comparisons between facility and industry 

data. 

TRI Facilities -- are manufacturing facilities that have 10 or more full-time 

employees and are above established chemical throughput thresholds. 

Manufacturing facilities are defined as facilities in Standard Industrial 

Classification primary codes 20-39. Facilities must submit estimates for all 

chemicals that are on the EPA's defined list and are above throughput 

thresholds. 

Data Table Column Heading Definitions 

The following definitions are based upon standard definitions developed by 

EPA’s Toxic Release Inventory Program. The categories below represent the 

possible pollutant destinations that can be reported. 

RELEASES -- are an on-site discharge of a toxic chemical to the 

environment. This includes emissions to the air, discharges to bodies of 

water, releases at the facility to land, as well as contained disposal into 

underground injection wells. 

Releases to Air (Point and Fugitive Air Emissions) -- include all air 

emissions from industry activity. Point emission occur through confined air 

streams as found in stacks, ducts, or pipes. Fugitive emissions include losses 

September 1995 32 SIC 281 
Sector Notebook Project Inorganic Chemicals 

from equipment leaks, or evaporative losses from impoundments, spills, or 

leaks. 

Releases to Water (Surface Water Discharges) -- encompass any releases 

going directly to streams, rivers, lakes, oceans, or other bodies of water. Any 

estimates for stormwater runoff and non-point losses must also be included. 

Releases to Land -- includes disposal of toxic chemicals in waste to on-site 

landfills, land treated or incorporation into soil, surface impoundments, spills, 

leaks, or waste piles. These activities must occur within the facility's 

boundaries for inclusion in this category. 

Underground Injection -- is a contained release of a fluid into a subsurface 

well for the purpose of waste disposal. 

TRANSFERS -- is a transfer of toxic chemicals in wastes to a facility that is 

geographically or physically separate from the facility reporting under TRI. 

The quantities reported represent a movement of the chemical away from the 

reporting facility. Except for off-site transfers for disposal, these quantities 

do not necessarily represent entry of the chemical into the environment. 

Transfers to POTWs -- are wastewaters transferred through pipes or sewers 

to a publicly owned treatments works (POTW). Treatment and chemical 

removal depend on the chemical's nature and treatment methods used. 

Chemicals not treated or destroyed by the POTW are generally released to 

surface waters or 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 been 

recycled, they may be returned to the originating facility or sold commercially. 

Transfers to Energy Recovery -- are wastes combusted off-site in industrial 

furnaces for energy recovery. Treatment of a chemical by incineration is not 

considered to be energy recovery. 

Transfers to Treatment -- are wastes moved off-site for either neutralization, 

incineration, biological destruction, or physical separation. In some cases, the 

chemicals are not destroyed but prepared for further waste management. 

Transfers to Disposal -- are wastes taken to another facility for disposal 

generally as a release to land or as an injection underground. 

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

September 1995 33 SIC 281 
Sector 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 code. The Bureau of Census identified 

1,429 facilities manufacturing inorganic chemicals. More than half of these 

facilities, however, have fewer than 20 employees, many of which are likely 

to be below the TRI reporting thresholds of employment (TRI reporting 

threshold is greater than 10 employees) and/or chemical use and, therefore, 

are not required to report to TRI. 

According to TRI data, in 1993 the inorganic chemical industry released 

(discharged to the air, water, or land without treatment) and transferred 

(shipped off-site) a total of 250 million pounds of 112 different chemical toxic 

chemicals. This represents about 10 percent of the TRI releases and transfers 

of the chemical manufacturing industry and about three percent of the total 

releases and transfers of all manufacturers that year. In comparison, the 

organic chemical 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 declining in recent years. Between 

1988 and 1993 TRI emissions from chemical companies (all those categorized 

within SIC 28, not just inorganic chemical manufacturers) to air, land, and 

water were reduced 44 percent, which is slightly above the average for all 

manufacturing sectors reporting to TRI.56 

Because the chemical industry (SIC 28) has historically released more TRI 

chemicals than any other industry, the EPA has worked to improve 

environmental performance within this sector. This has been done through a 

combination of enforcement actions, regulatory requirements, pollution 

prevention projects, and voluntary programs (e.g. 33/50). In addition, the 

chemical industry has focused on reducing pollutant releases. For example, 

the Chemical Manufacturers Association’s (CMA’s) Responsible Care 

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 the 

program. Participation involves demonstrating a commitment to the 

program's mandate of continuous improvement in environment, health, and 

safety. In June of 1994, the CMA approved the use of a third-party 

verification of management plans to meet these objectives. 

Exhibits 11 and 12 present the number and volumes of chemicals released and 

transferred by inorganic chemical facilities, respectively. The frequency with 

which chemicals are reported by facilities within a sector is one indication of 

the diversity of operations and processes. Many of the TRI chemicals are 

released or transferred by only a small number of facilities which indicates a 

wide diversity of production processes, particularly for specialty inorganics --

September 1995 34 SIC 281 
Sector 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. This 

release profile differs from other TRI industries which average approximately 

30 percent to the water, 59 percent to air, and 10 percent to land. Examining 

the inorganic chemical industry's TRI reported toxic chemical releases 

highlights the likely origins of the large water releases for the industry (Exhibit 

11). 

As presented in Exhibit 11, on-site underground injection of essentially one 

chemical, hydrochloric acid, accounts for the largest portion, 55 percent, of 

the inorganic chemical industry's total releases and transfers as reported in 

TRI. Only five facilities of the 555 identified facilities reported releasing 

hydrochloric acid through underground injection. Two of these facilities 

accounted for over 85 percent of the total hydrochloric acid injected to the 

subsurface, or 42 percent of the inorganic chemical industry's total releases 

and transfers. Land disposal accounted for the next largest amount, 17 

percent, of the industry's total releases. The largest single chemical released 

to the air by the inorganic chemical industry, carbonyl sulfide, is only emitted 

by eleven facilities manufacturing certain inorganic pigments. 

Discharges to POTWs accounted for 43 percent of the industry’s total 

transfers of TRI chemicals. Ammonia, hydrochloric acid, and sulfuric acid 

account for over 66 percent of the 70 million pounds transferred off-site. 

Finally, approximately 22 million pounds, accounting for 31 percent of the 

total, are transferred off-site for treatment (Exhibit 12). 

September 1995 35 SIC 281 
Sector Notebook Project Inorganic Chemicals Exhibit 11: 1993 Releases for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting (Releases reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL FUGITIVE AIR POINT AIR WATER DISCHARGES UNDERGROUND INJECTION LAND DISPOSAL TOTAL RELEASES AVG. RELEASES PER FACILITY SULFURIC ACID 311 47,743 538,584 7,482 5 29,520 623,334 2,004 HYDROCHLORIC ACID 167 29,428 1,420,262 3,748 120,745,708 213,351 122,677,352 734,595 AMMONIA 152 1,984,440 2,726,774 1,885,475 0 1,162,987 7,759,676 51,051 CHLORINE 121 52,954 3,017,393 6,105 0 0 3,076,452 25,425 PHOSPHORIC ACID 72 4,673 417,181 500 5 0 422,359 5,866 NITRIC ACID 71 13,211 56,538 250 5 0 70,004 986 ACETONE 54 40,304 19,261 0 0 0 59,565 1,103 ZINC COMPOUNDS 53 39,171 72,705 104,180 0 86,384 302,440 5,706 CHROMIUM COMPOUNDS 41 4,294 13,008 33,935 0 19,036,934 19,088,171 465,565 COPPER COMPOUNDS 33 2,317 15,238 1,827 0 428 19,810 600 NICKEL COMPOUNDS 29 1,253 20,000 8,872 5 34,289 64,419 2,221 METHANOL 28 105,224 878,239 77,887 0 0 1,061,350 37,905 BARIUM COMPOUNDS 27 2,279 8,176 5,629 0 353,000 369,084 13,670 DICHLORODIFLUOROMETHANE 26 741,761 54,302 0 0 0 796,063 30,618 LEAD COMPOUNDS 26 1,370 12,730 287 0 58,053 72,440 2,786 MANGANESE COMPOUNDS 26 124,003 146,393 87,548 0 7,672,768 8,030,712 308,874 HYDROGEN FLUORIDE 24 93,040 84,932 5 0 10 177,987 7,416 COBALT COMPOUNDS 21 1,001 2,018 996 0 33,460 37,475 1,785 ETHYLENE GLYCOL 20 543 765 505 0 702 2,515 126 TOLUENE 20 84,679 11,313 0 0 4 95,996 4,800 ANTIMONY COMPOUNDS 16 2,010 11,439 273 0 1 13,723 858 XYLENE (MIXED ISOMERS) 16 9,608 7,998 0 0 52 17,658 1,104 PHOSPHORUS (YELLOW OR 14 1,200 4,137 5 0 323,749 329,091 23,507 PROPYLENE 14 14,451 2,215 0 0 0 16,666 1,190 AMMONIUM NITRATE 13 697 8,858 496,400 0 599,028 1,104,983 84,999 AMMONIUM SULFATE 11 1,613 4,935 0 0 0 6,548 595 CARBONYL SULFIDE 11 380 9,676,486 0 0 0 9,676,866 879,715 GLYCOL ETHERS 11 4,028 40,640 0 0 0 44,668 4,061 TITANIUM TETRACHLORIDE 11 7,900 4,492 0 0 0 12,392 1,127 ETHYLENE OXIDE 10 428 19,890 0 0 0 20,318 2,032 COPPER 9 523 1,250 83 0 0 1,856 206 MOLYBDENUM TRIOXIDE 9 1,155 12,291 3,749 5 500 17,700 1,967 FORMALDEHYDE 8 493 11,703 0 0 0 12,196 1,525 ZINC (FUME OR DUST) 8 255 6,476 0 0 0 6,731 841 ARSENIC COMPOUNDS 7 260 264 391 0 504 1,419 203 MERCURY 7 5,903 1,597 215 0 1,519 9,234 1,319 1,1,1-TRICHLOROETHANE 7 1,200 505 0 0 0 1,705 244 ASBESTOS (FRIABLE) 6 0 1 0 0 0 1 0 CARBON TETRACHLORIDE 6 25,632 259,791 0 0 2 285,425 47,571 CHROMIUM 6 260 520 86 0 267,786 268,652 44,775 DICHLOROTETRAFLUOROETHANE 6 709,950 5 0 0 0 709,955 118,326 ETHYLENE 6 527 5,287 0 0 0 5,814 969 METHYL ETHYL KETONE 6 10,205 2,601 0 0 41 12,847 2,141 NAPHTHALENE 6 819 33,652 741 0 5 35,217 5,870 CADMIUM COMPOUNDS 5 431 4,237 21 0 124 4,813 963 DICHLOROMETHANE 5 53,174 9,322 0 0 0 62,496 12,499 DIETHANOLAMINE 5 3,325 750 0 0 0 4,075 815 ACETONITRILE 4 2,085 1,696 0 0 0 3,781 945 

September 1995 36 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 11 (cont.): 1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting (Releases reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL FUGITIVE AIR POINT AIR WATER DISCHARGES UNDERGROUND INJECTION LAND DISPOSAL TOTAL RELEASES AVG. RELEASES PER FACILITY CARBON DISULFIDE 4 70,006 4,334 250 0 0 74,590 18,648 CHLOROFORM 4 13,282 27,017 360 0 0 40,659 10,165 CYANIDE COMPOUNDS 4 5 5 0 0 0 10 3 NICKEL 4 38 880 5 0 250 1,173 293 PHTHALIC ANHYDRIDE 4 250 250 0 0 0 500 125 SELENIUM COMPOUNDS 4 10 270 87 0 0 367 92 TRICHLOROFLUOROMETHANE 4 307,250 1,205 0 0 0 308,455 77,114 1,2,4-TRIMETHYLBENZENE 4 1,110 1,290 250 0 5 2,655 664 ALUMINUM (FUME OR DUST) 3 42 660 0 0 0 702 234 BENZENE 3 505 5 0 0 0 510 170 ETHYLBENZENE 3 505 250 0 0 0 755 252 FREON 113 3 30,954 67 0 0 0 31,021 10,340 HYDRAZINE 3 330 0 33 0 0 363 121 MANGANESE 3 250 316 34 0 1,180,335 1,180,935 393,645 MONOCHLOROPENTAFLUOROEHTANE 3 402,000 7,721 0 0 0 409,721 136,574 TRICHLOROETHYLENE 3 255 35,305 5 0 0 35,565 11,855 ACETALDEHYDE 2 6 3,100 0 0 0 3,106 1,553 ACRYLONITRILE 2 255 5 0 0 0 260 130 CHLORINE DIOXIDE 2 86 176 0 0 0 262 131 COBALT 2 13 251 0 0 5 269 135 CRESOL (MIXED ISOMERS) 2 276 510 0 0 0 786 393 CYCLOHEXANE 2 255 5 0 0 0 260 130 HYDROQUINONE 2 0 0 0 0 0 0 0 LEAD 2 76 0 9 0 8,500 8,585 4,293 METHYL ISOBUTYL KETONE 2 250 303 0 0 0 553 277 METHYL TERT-BUTYL ETHER 2 790 5 0 0 0 795 398 PHENOL 2 264 145 0 0 0 409 205 SILVER COMPOUNDS 2 0 5 0 0 0 5 3 TETRACHLOROETHYLENE 2 400 305 0 0 0 705 353 ACRYLIC ACID 1 250 5 0 0 0 255 255 ARSENIC 1 5 0 0 0 0 5 5 BARIUM 1 0 0 0 0 0 0 0 BROMOTRIFLUOROMETHANE 1 34,000 0 0 0 0 34,000 34,000 CAPTAN 1 5 0 0 0 0 5 5 CHLOROBENZENE 1 250 5 0 0 0 255 255 CHLOROETHANE 1 522 0 0 0 0 522 522 CHLOROMETHANE 1 501 0 0 0 0 501 501 CREOSOTE 1 250 5 0 0 0 255 255 CUMENE 1 750 750 0 0 0 1,500 1,500 DI(2-ETHYLHEXYL) PHTHALATE 1 250 5 0 0 0 255 255 DIBUTYL PHTHALATE 1 250 5 0 0 0 255 255 DIMETHYL PHTHALATE 1 10 0 0 0 0 10 10 DIMETHYL SULFATE 1 0 0 0 0 0 0 0 ETHYL ACRYLATE 1 250 5 0 0 0 255 255 HYDROGEN CYANIDE 1 0 30 0 0 0 30 30 ISOPROPYL ALCOHOL 1 250 250 0 0 0 500 500 MALEIC ANHYDRIDE 1 250 5 0 0 0 255 255 MERCURY COMPOUNDS 1 250 250 0 0 0 500 500 

September 1995 37 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 11 (cont.): 1993 Releases for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting (Releases reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL FUGITIVE AIR POINT AIR WATER DISCHARGES UNDERGROUND INJECTION LAND DISPOSAL TOTAL RELEASES AVG. RELEASES PER FACILITY METHYL METHACRYLATE 1 250 5 0 0 0 255 255 N-BUTYL ALCOHOL 1 250 250 0 0 0 500 500 O-XYLENE 1 5 0 0 0 0 5 5 P-XYLENE 1 5 0 0 0 0 5 5 PERACETIC ACID 1 10 2,100 42 0 0 2,152 2,152 POLYCHLORINATED BIPHENYLS 1 0 0 0 0 0 0 0 SELENIUM 1 5 250 0 0 0 255 255 SILVER 1 750 250 0 0 0 1,000 1,000 STYRENE 1 250 250 0 0 0 500 500 THIOUREA 1 0 0 0 0 0 0 0 VINYL ACETATE 1 5 0 0 0 0 5 5 VINYL CHLORIDE 1 0 0 0 0 0 0 0 1,1,2-TRICHLOROETHANE 1 250 5 0 0 0 255 255 1,2-DICHLOROETHANE 1 5 0 0 0 0 5 5 1,2,4-TRICHLOROBENZENE 1 5 0 0 0 0 5 5 1,4-DIOXANE 1 5 0 0 0 0 5 5 TOTAL 555 5,366,356 19,737,660 2,728,270 120,745,733 31,064,296 179,642,315 323,680 

September 1995 38 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 12: 1993 Transfers for Inorganic Chemical Manufacturing Facilities (SIC 281) in TRI, by Number of Facilities Reporting (Transfers reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL POTW DISCHARGES DISPOSAL RECYCLING TREATMENT ENERGY RECOVERY TOTAL TRANSFERS AVG. TRANSFERS PER FACILITY SULFURIC ACID 311 11,146 250,434 1,025,242 6,820,665 0 8,107,487 26,069 HYDROCHLORIC ACID 167 528 4,598,609 0 10,423,062 0 15,022,199 89,953 AMMONIA 152 22,101,429 371,669 528,230 65,300 0 23,066,628 151,754 CHLORINE 121 5 610 0 270 0 885 7 PHOSPHORIC ACID 72 3,913 2,130 23,218 132,065 0 161,326 2,241 NITRIC ACID 71 10 250 0 438,614 0 438,874 6,181 ACETONE 54 1,655 23 15,726 11,249 84,368 113,021 2,093 ZINC COMPOUNDS 53 7,382 509,395 159,713 30,265 0 706,755 13,335 CHROMIUM COMPOUNDS 41 4,078 121,569 47,843 51,452 0 224,942 5,486 COPPER COMPOUNDS 33 4,228 321,517 576,642 7,733 0 910,120 27,579 NICKEL COMPOUNDS 29 9,840 86,370 278,630 106,692 0 481,532 16,605 METHANOL 28 16,209 4,000 291,354 175 1,802,765 2,114,503 75,518 BARIUM COMPOUNDS 27 5,080 370,288 0 123,560 0 498,928 18,479 DICHLORODIFLUOROMETHANE 26 0 0 20,600 16 0 20,616 793 LEAD COMPOUNDS 26 1,301 89,660 1,153,211 1,087,669 0 2,331,841 89,686 MANGANESE COMPOUNDS 26 1,446 1,694,840 7,300 2,206,411 0 3,909,997 150,385 HYDROGEN FLUORIDE 24 185 230,250 77,587 38,700 0 346,722 14,447 COBALT COMPOUNDS 21 3,996 13,580 8,050 10,598 0 36,224 1,725 ETHYLENE GLYCOL 20 3,951 0 30,912 2,248 13,852 50,963 2,548 TOLUENE 20 1,375 203 25,347 32,384 217,979 277,288 13,864 ANTIMONY COMPOUNDS 16 3,735 52,815 16,000 7,171 0 79,721 4,983 XYLENE (MIXED ISOMERS) 16 0 73 250 5,127 188,093 193,543 12,096 PHOSPHORUS (YELLOW OR 14 0 1 0 26,000 0 26,001 1,857 PROPYLENE 14 0 0 0 0 0 0 0 AMMONIUM NITRATE 13 1,923,495 160 603,440 0 0 2,527,095 194,392 AMMONIUM SULFATE 11 6,506,733 8,247 0 6,092 0 6,521,072 592,825 CARBONYL SULFIDE 11 0 0 0 0 0 0 0 GLYCOL ETHERS 11 628 506 0 37,387 13,405 51,926 4,721 TITANIUM TETRACHLORIDE 11 0 16 0 489 86 591 54 ETHYLENE OXIDE 10 0 0 0 0 0 0 0 COPPER 9 46 938,477 0 55,261 0 993,784 110,420 MOLYBDENUM TRIOXIDE 9 7,652 52,424 61,220 0 0 121,296 13,477 FORMALDEHYDE 8 255 250 0 362 0 867 108 ZINC (FUME OR DUST) 8 250 1,710 250 0 0 2,210 276 ARSENIC COMPOUNDS 7 5 59,900 250 904 0 61,059 8,723 MERCURY 7 0 3,486 5,222 1,010 0 9,718 1,388 1,1,1-TRICHLOROETHANE 7 0 0 250 5 0 255 36 ASBESTOS (FRIABLE) 6 0 33,070 0 0 0 33,070 5,512 CARBON TETRACHLORIDE 6 0 1,400 0 34,107 0 35,507 5,918 CHROMIUM 6 0 48,930 2,763 37,765 0 89,458 14,910 DICHLOROTETRAFLUOROETHA 6 0 0 0 0 0 0 0 ETHYLENE 6 0 0 0 0 0 0 0 METHYL ETHYL KETONE 6 0 92 0 443 33,567 34,102 5,684 NAPHTHALENE 6 0 48 0 880 250 1,178 196 CADMIUM COMPOUNDS 5 35 585 5 4,061 0 4,686 937 DICHLOROMETHANE 5 0 0 5,147 5 0 5,152 1,030 DIETHANOLAMINE 5 450 0 0 0 0 450 90 ACETONITRILE 4 0 0 0 5 22,239 22,244 5,561 

September 1995 39 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 12 (cont.): 1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting (Transfers reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL POTW DISCHARGES DISPOSAL RECYCLING TREATMENT ENERGY RECOVERY TOTAL TRANSFERS AVG. TRANSFERS PER FACILITY CARBON DISULFIDE 4 250 10 0 0 500 760 190 CHLOROFORM 4 0 7,700 0 72,311 0 80,011 20,003 CYANIDE COMPOUNDS 4 1 0 0 4 0 5 1 NICKEL 4 97 505 23,670 0 0 24,272 6,068 PHTHALIC ANHYDRIDE 4 5 0 0 5 2,412 2,422 606 SELENIUM COMPOUNDS 4 2 27 0 295 0 324 81 TRICHLOROFLUOROMETHANE 4 0 0 3,100 1,705 0 4,805 1,201 1,2,4-TRIMETHYLBENZENE 4 0 0 0 1,854 3,188 5,042 1,261 ALUMINUM (FUME OR DUST) 3 0 0 0 0 0 0 0 BENZENE 3 0 0 0 5 0 5 2 ETHYLBENZENE 3 0 0 0 5 0 5 2 FREON 113 3 0 0 0 1,500 0 1,500 500 HYDRAZINE 3 0 0 0 0 0 0 0 MANGANESE 3 0 183,412 0 0 0 183,412 61,137 MONOCHLOROPENTAFLUOROE 3 0 0 0 0 0 0 0 TRICHLOROETHYLENE 3 0 0 0 1,305 0 1,305 435 ACETALDEHYDE 2 0 0 0 0 0 0 0 ACRYLONITRILE 2 0 0 0 5 0 5 3 CHLORINE DIOXIDE 2 130 0 0 0 0 130 65 COBALT 2 4 5 2,300 0 0 2,309 1,155 CRESOL (MIXED ISOMERS) 2 0 0 0 5 0 5 3 CYCLOHEXANE 2 0 0 0 5 0 5 3 HYDROQUINONE 2 500 0 0 0 0 500 250 LEAD 2 0 750 0 66 0 816 408 METHYL ISOBUTYL KETONE 2 0 0 0 5 820 825 413 METHYL TERT-BUTYL ETHER 2 0 0 0 5 0 5 3 PHENOL 2 0 0 0 5 0 5 3 SILVER COMPOUNDS 2 5 5 0 0 0 10 5 TETRACHLOROETHYLENE 2 0 0 0 5 0 5 3 ACRYLIC ACID 1 0 0 0 5 0 5 5 ARSENIC 1 0 0 0 70,761 0 70,761 70,761 BARIUM 1 0 26,217 0 0 0 26,217 26,217 BROMOTRIFLUOROMETHANE 1 0 0 0 0 0 0 0 CAPTAN 1 0 0 0 0 0 0 0 CHLOROBENZENE 1 0 0 0 5 0 5 5 CHLOROETHANE 1 0 0 0 0 0 0 0 CHLOROMETHANE 1 0 0 0 0 0 0 0 CREOSOTE 1 0 0 0 5 0 5 5 CUMENE 1 0 0 0 1,000 0 1,000 1,000 DI(2-ETHYLHEXYL) 1 0 0 0 5 0 5 5 DIBUTYL PHTHALATE 1 0 0 0 5 0 5 5 DIMETHYL PHTHALATE 1 0 0 0 0 0 0 0 DIMETHYL SULFATE 1 0 0 0 0 0 0 0 ETHYL ACRYLATE 1 0 0 0 5 0 5 5 HYDROGEN CYANIDE 1 0 0 0 0 0 0 0 ISOPROPYL ALCOHOL 1 0 0 0 5 0 5 5 MALEIC ANHYDRIDE 1 0 0 0 5 0 5 5 MERCURY COMPOUNDS 1 5 1,525 0 5 0 1,535 1,535 

September 1995 40 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 12 (cont.): 1993 Transfers for Inorganic Chemical Manufacturing Facilities in TRI, by Number of Facilities Reporting (Transfers reported in pounds/year) CHEMICAL NAME # REPORTING CHEMICAL POTW DISCHARGES DISPOSAL RECYCLING TREATMENT ENERGY RECOVERY TOTAL TRANSFERS AVG. TRANSFERS PER FACILITY METHYL METHACRYLATE 1 0 0 0 5 0 5 5 N-BUTYL ALCOHOL 1 0 0 0 5 0 5 5 O-XYLENE 1 0 0 0 0 0 0 0 P-XYLENE 1 0 0 0 0 0 0 0 PERACETIC ACID 1 0 0 0 110 0 110 110 POLYCHLORINATED 1 0 0 0 0 0 0 0 SELENIUM 1 0 0 0 1,450 0 1,450 1,450 SILVER 1 0 0 1,011 0 0 1,011 1,011 STYRENE 1 0 0 0 5 0 5 5 THIOUREA 1 0 0 0 0 0 0 0 VINYL ACETATE 1 0 0 0 0 0 0 0 VINYL CHLORIDE 1 0 0 0 0 0 0 0 1,1,2-TRICHLOROETHANE 1 0 0 0 5 0 5 5 1,2-DICHLOROETHANE 1 0 0 0 0 0 0 0 1,2,4-TRICHLOROBENZENE 1 0 0 0 0 0 0 0 1,4-DIOXANE 1 0 0 0 0 0 0 0 TOTAL 555 30,622,040 10,087,743 4,994,483 21,958,678 2,383,524 70,046,468 126,210 

September 1995 41 SIC 281
1

2

3

4

5

6

7

8

9

10

Sector Notebook Project Inorganic Chemicals 

The TRI database contains a detailed compilation of self-reported, facilityspecific chemical releases. The top reporting facilities for this sector are listed 

below. Facilities that have reported only the SIC codes covered under this 

notebook appear on the first list. The second list contains additional facilities 

that have reported the SIC code covered within this report, and one or more 

SIC codes that are not within the scope of this notebook. Therefore, the 

second list includes facilities that conduct multiple operations -- some that are 

under the scope of this notebook, and some that are not. Currently, the 

facility-level data do not allow pollutant releases to be broken apart by 

industrial process. 

Exhibit 13: Top 10 TRI Releasing 

Inorganic Chemicals Facilitiesb 

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 281 
1

2

3

4

5

6

7

Sector Notebook Project Inorganic Chemicals 

Exhibit 14: Top 10 TRI Releasing Facilities Reporting 

Inorganic Chemical SIC Codes to TRIc 

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 brief descriptions provided below were taken from the 1993 Toxics 

Release Inventory Public Data Release (EPA, 1994), and the Hazardous 

Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a 

computer system run by the National Library of Medicine. It includes a 

number of toxicological databases managed by EPA, the National Cancer 

Institute, and the National Institute for Occupational Safety and Health.d 

HSDB contains chemical-specific information on manufacturing and use, 

chemical and physical properties, safety and handling, toxicity and biomedical 

effects, pharmacology, environmental fate and exposure potential, exposure 

standards and regulations, monitoring and analysis methods, and additional 

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 281 
Sector Notebook Project Inorganic Chemicals 

references. The information contained below is based upon exposure 

assumptions that have been conducted using standard scientific procedures. 

The effects listed below must be taken in context of these exposure 

assumptions that are more fully explained within the full chemical profiles in 

HSDB. For more information on TOXNET, contact the TOXNET help line 

at 800-231-3766. 

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 in the iron and steel industry, as an activator 

of petroleum wells, as a boiler scale remover, and as a neutralizer of caustic 

waste streams. The largest release of hydrochloric acid by the inorganic 

chemical industry is in the form of underground injection of spent 

hydrochloric acid used to manufacture chlorosulfonic acid and other 

products.57 

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

aerosols have been implicated in causing and exacerbating a variety of 

respiratory ailments. Dermal exposure and ingestion of highly concentrated 

hydrochloric acid can result in corrosivity. 

Ecologically, accidental releases of solution forms of hydrochloric acid may 

adversely 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. 

Environmental Fate. Releases of hydrochloric acid to surface waters and 

soils will be neutralized to an extent due to the buffering capacities of both 

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) 

Sources. Chrome pigments, chromates, chromic acid, chromium salts, and 

other inorganic chromium compounds are some of the larger volume products 

of the inorganic 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 281 
Sector Notebook Project Inorganic Chemicals 

by the inorganic chemicals industry are land disposed in the form of chromium 

containing sludges. 

Toxicity. Although the naturally-occurring form of chromium metal has very 

low toxicity, chromium from industrial emissions is highly toxic due to strong 

oxidation characteristics and cell membrane permeability. The majority of the 

effects detailed below are based on Chromium VI (an isomer that is more 

toxic than Cr III). Exposure to chromium metal and insoluble chromium salts 

affects the respiratory system. Inhalation exposure to chromium and 

chromium salts may cause severe irritation of the upper respiratory tract and 

scarring of lung tissue. Dermal exposure to chromium and chromium salts 

can also cause sensitive dermatitis and skin ulcers. 

Ecologically, although chromium is present in small quantities in all soils and 

plants, it is toxic to plants at higher soil concentrations (i.e., 0.2 to 0.4 percent 

in soil). 

Carcinogenicity. Different sources disagree on the carcinogenicity of 

chromium. Although an increased incidence in lung cancer among workers 

in the chromate-producing industry has been reported, data are inadequate to 

confirm that chromium is a human carcinogen. Other sources consider 

chromium VI to be a known human carcinogen based on inhalation exposure. 

Environmental Fate. Chromium is a non-volatile metal with very low 

solubility in water. If applied to land, most chromium remains in the upper 

five centimeters of soil. Most chromium in surface waters is present in 

particulate form as sediment. Airborne chromium particles are relatively 

unreactive and are removed from the air through wet and dry deposition. The 

precipitated chromium from the air enters surface water or soil. Chromium 

bioaccumulates in plants and animals, with an observed bioaccumulation 

factor of 1,000,000 in snails. 

Carbonyl Sulfide (CAS: 463-58-1) 

Sources. 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 sulfide 

causes eye and skin irritation and adverse central nervous system effects such 

as giddiness, headache, vertigo, amnesia, confusion, and unconsciousness. If 

ingested, gastrointestinal 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 very 

September 1995 45 SIC 281 
Sector Notebook Project Inorganic Chemicals 

high concentrations of carbonyl sulfide causes sudden collapse, 

unconsciousness, and death from sudden respiratory paralysis. Recovery from 

sublethal exposure is slow, but generally complete. Degradation products of 

carbonyl sulfide (especially hydrogen sulfide) can result in toxic symptoms and 

death. 

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

is carcinogenic. 

Environmental Fate. If released to soil or surface waters, carbonyl sulfide 

will rapidly volatilize. It is not expected to adsorb to soil sediments or organic 

matter nor is it expected to bioconcentrate in fish and aquatic organisms. 

Carbonyl sulfide is hydrolyzed in water to carbon dioxide and hydrogen 

sulfide. Carbonyl sulfide is expected to have a long residence time in the 

atmosphere. Atmospheric removal of carbonyl sulfide may occur by slow 

reactions 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 the 

inorganic chemical industry. Manganese is used as a purifying and scavenging 

agent in metal production, as an intermediate in aluminum production and as 

a constituent of non-ferrous alloys to improve corrosion resistance and 

hardness.59 

Toxicity. There is currently no evidence that human exposure to manganese 

at levels commonly observed in ambient atmosphere results in adverse health 

effects. However, recent EPA review of the fuel additive MMT 

(methylcyclopentadienyl manganese tricarbonyl) concluded that use of MMT 

in gasoline could lead to ambient 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 

central nervous system. Early symptoms include languor, speech 

disturbances, sleepiness, and cramping and weakness in legs. A stolid masklike appearance 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. Chronic 

manganese poisoning is reversible if treated early and exposure stopped. 

Populations at greatest risk of manganese toxicity are the very young and 

those with iron deficiencies. 

September 1995 46 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Ecologically, 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. 

Environmental Fate. Manganese is an essential nutrient for plants and 

animals. As such, manganese accumulates in the top layers of soil or surface 

water sediments and cycles between the soil and living organisms. It occurs 

mainly as a solid under environmental conditions, though may also be 

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 soluble 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 

chemical industry processes using or producing ammonia include the 

manufacturing of: ammonium chloride, ammonium hydroxide, ammonium 

thiosulfate, ammonium nitrate, hydrazine, and hydrogen cyanide. 

Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and 

upper respiratory system. Ecologically, ammonia is a source of nitrogen (an 

essential element for aquatic plant growth), and may therefore contribute to 

eutrophication of standing or slow-moving surface water, particularly in 

nitrogen-limited waters such as the Chesapeake Bay. In addition, aqueous 

ammonia is moderately toxic to aquatic organisms. 

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

is carcinogenic. 

Environmental Fate. Ammonia combines with sulfate ions in the 

atmosphere and is washed out by rainfall, resulting in rapid return of ammonia 

to the soil and surface waters. Ammonia is a central compound in the 

environmental cycling of nitrogen. Ammonia in lakes, rivers, and streams is 

converted to nitrate. 

Physical Properties. Ammonia is a corrosive and severely irritating gas with 

a pungent odor. 

IV.C. Other Data Sources 

September 1995 47 SIC 281 
Sector Notebook Project Inorganic Chemicals 

In addition to chemicals covered under TRI, many other chemicals are 

released. For example, the EPA Office of Air Quality Planning and Standards 

has compiled air pollutant emission factors for determining the total air 

emissions of priority pollutants (e.g., VOCs, SOx, NOx, CO, particulates) from 

many chemical industry sources. 

The EPA Office of Air’s Aerometric Information Retrieval System (AIRS) 

contains a wide range of information related to stationary sources of air 

pollution, including the emissions of a number of air pollutants which may be 

of concern within a particular industry. With the exception of volatile organic 

compounds (VOCs), there is little overlap with the TRI chemicals reported 

above. Exhibit 15 summarizes annual releases of carbon monoxide (CO), 

nitrogen dioxide (NO2), particulate matter of 10 microns or less (PM10), total 

particulate (PT), sulfur dioxide (SO2) and volatile organic compounds 

(VOCs). 

September 1995 48 SIC 281 
Sector 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 281
Sector 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 industrial categories. It is provided to give a general 

sense as to the relative scale of releases and transfers within each sector 

profiled under this project. Please note that the following figure and table do 

not contain releases and transfers for industrial categories that are not 

included in this project, and thus cannot be used to draw conclusions 

regarding the total release and transfer amounts that are reported to TRI. 

Similar information is available within the annual TRI Public Data Release 

Book. 

Exhibit 16 is a graphical representation of a summary of the 1993 TRI data for 

the inorganic chemicals industry and the other sectors profiled in separate 

notebooks. The bar graph presents the total TRI releases and total transfers 

on the left axis and the triangle points show the average releases per facility 

on the right axis. Industry sectors are presented in the order of increasing 

total TRI releases. The graph is based on the data shown in Exhibit 17 and 

is meant to facilitate comparisons between the relative amounts of releases, 

transfers, and releases per facility both within and between these sectors. The 

reader should note, however, that differences in the proportion of facilities 

captured by TRI exist between industry sectors. This can be a factor of poor 

SIC matching and relative differences in the number of facilities reporting to 

TRI from the various sectors. In the case of the inorganic 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 281 
Sector Notebook Project Inorganic Chemicals 

Exhibit 16: Summary of 1993 TRI Data:

Releases and Transfers by Industry

0 

100 

200 

300 

400 

500 

600 

700 

Total Pounds (millions) 

0 

200,000 

400,000 

600,000 

800,000 

1,000,000 

Average 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 281
Sector Notebook Project Inorganic Chemicals Exhibit 17: Toxics Release Inventory Data for Selected Industries Average Releases + Transfers per Facility (pounds) 46,000 24,000 148,000 147,000 133,000 104,000 369,000 706,000 450,000 3,088,000 123,000 1,825,000 1,349,000 1,052,000 Industry 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.) 28.8 11.9 46.4 46.7 53.7 163.4 224.8 218.1 249.7 481.9 267.7 695.3 280.7 438.4 1993 TRI Transfers Average Transfers per Facility (pounds) 4,000 7,000 13,000 32,000 116,000 29,000 239,000 157,000 126,000 2,676,000 83,000 1,600,000 472,000 688,000 Total Transfers (million lbs.) 2.2 3.5 4.2 10.2 47.1 45 145.5 48.4 70 417.5 195.7 609.5 98.2 286.7 1993 TRI Releases Average Releases per Facility (pounds) 42,000 17,000 135,000 115,000 17,000 75,000 130,000 549,000 324,000 412,000 30,000 225,000 877,000 364,000 Total Releases (million lbs.) 26.6 8.4 42.2 36.5 6.7 118.4 79.3 169.7 179.6 64.3 72 85.8 182.5 151.6 # TRI Facilities 634 491 313 318 406 1,579 609 309 555 156 2,363 381 208 417 SIC Range 32 24 25 2711-2789 36 30 371 2611-2631 2812-2819 2911 34 331 333, 334 2861-2869 10 14 7216 Industry Sector Stone, Clay, and Concrete Lumber and Wood Products Furniture and Fixtures Printing Electronic Equip. and Components Rubber and Misc. Plastics Motor Vehicles, Bodies, Parts, and Accessories Pulp and Paper Inorganic Chem. Mfg. Petroleum Refining Fabricated Metals Iron and Steel Nonferrous Metals Organic Chemical Mfg. Metal Mining Nonmetal Mining Dry Cleaning 

September 1995 52 SIC 281
Sector Notebook Project Inorganic Chemicals 

V. POLLUTION PREVENTION OPPORTUNITIES 

The best way to reduce pollution is to prevent it in the first place. Some 

companies have creatively implemented pollution prevention techniques that 

improve efficiency and increase profits while at the same time minimize 

environmental impacts. This can be done in many ways such as reducing 

material inputs, re-engineering processes to reuse by-products, improving 

management practices, and employing substitute toxic chemicals. Some 

smaller facilities are able to actually get below regulatory thresholds just by 

reducing pollutant releases through aggressive pollution prevention policies. 

In order to encourage these approaches, this section provides both general 

and company-specific descriptions of some pollution prevention advances that 

have been implemented within the inorganic 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 own 

pollution prevention projects. When possible, this section provides 

information from real activities that can, or are being implemented by this 

sector -- including a discussion of associated costs, time frames, and expected 

rates of return. This section also provides the context (in terms of type of 

industry and/or type of process affected) in which the pollution prevention 

technique can effectively be used. 

There have been numerous cases have where the chemical industry has 

simultaneously reduced pollutant outputs and operating costs through 

pollution prevention techniques. In the inorganic chemicals manufacturing 

sector, however, economically viable pollution prevention opportunities are 

not as easily identified as in other sectors. The relatively small size and limited 

resources of a typical inorganic chemical facility limits the number of feasible 

pollution prevention options. The limited resources available to the industry 

eliminates many pollution prevention options that require significant capital 

expenditures such as process modifications and process redesign. In addition, 

the inorganic chemicals industry's products are primarily commodity chemicals 

for which the manufacturing processes have been developed over many years. 

Commodity chemical manufacturers redesign their processes infrequently so 

that redesign of the reaction process or equipment is unlikely in the short 

term. In addition, the industry's process equipment has been amortized over 

long periods of 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 process 

modifications, operational changes, raw material substitutions, and recycling. 

Pollution prevention in the chemical industry in process specific. As such it 

is difficult to generalize about the relative merits of different pollution 

prevention strategies. The age and size of the facility, and the type and 

September 1995 53 SIC 281 
Sector Notebook Project Inorganic Chemicals 

number of its processes will determine the most effective pollution prevention 

strategy. Brief descriptions of some of the more widespread, general pollution 

prevention techniques found to be effective at inorganic chemicals facilities 

are provided below. Many of these pollution prevention opportunities can be 

applied to the petrochemical industry as a whole due to the many similar 

processes found throughout the industry. It should be noted that many of the 

ideas identified below as pollution prevention opportunities, aimed at reducing 

wastes and reducing materials use, have been carried out by the chemicals 

manufacturing industry for many years as the primary means of improving 

process efficiencies and increasing profits. 

In chlor-alkali production, pollution prevention options have been 

demonstrated for both the mercury cell and diaphragm cell processes; 

however, the best opportunity to reduce pollutant outputs, conserve energy, 

and reduce costs in the chlor-alkali industry are in the conversion to the 

membrane cell process. In terms of energy consumption, the membrane cell 

process uses only about 77 percent of that of the mercury cell process and 

about 90 percent of that of the diaphragm cell process. The membrane cell 

process also generates significantly less airborne and waterborne pollutants 

and solid wastes (see Section III.B. - Raw Material Inputs and Pollution 

Outputs). 

Substitute raw materials. The substitution or elimination of some of the raw 

materials used in the manufacturing of inorganic chemicals can result in 

substantial waste reductions and cost savings. Because impurities in the feed 

stream can be a major contributor to waste generation, one of the most 

common substitutions is to use a higher purity feedstock. This can be 

accomplished either by working with suppliers to get a higher quality feed or 

by installing purification equipment. Raw materials can also be substituted 

with less toxic and less water soluble materials to reduce water contamination, 

and with less volatile materials to reduce fugitive emissions. Sometimes 

certain raw materials can be eliminated all together. The need for raw 

materials that end up as wastes should be reexamined to determine if raw 

materials can be eliminated by modifying the process and improving control. 

Improve reactor efficiencies. Since the chemical products are primarily 

created inside the process reactor, it can be the primary source for waste (offspec) materials. One of the most important parameters dictating the reactor 

efficiency is the quality of mixing. A number of techniques can be used to 

improve mixing, such as installing baffles in the reactor, a higher rpm motor 

for the agitator, a different mixing blade design, multiple impellers, and pump 

recirculation. The method used to introduce feed to the reactor can also have 

an effect on the quality of mixing. A feed distributor can be added to equalize 

residence time through the reactor, and feed streams can be added at a point 

September 1995 54 SIC 281 
Sector Notebook Project Inorganic Chemicals 

in time closer to the ideal reactant concentration. This will avoid secondary 

reactions which form unwanted by-products. 

Improve catalyst. The catalyst plays a critical role in the effectiveness of 

chemical conversion in the reactor. Alternative chemical makeups and 

physical characteristics can lead to substantial improvements in the 

effectiveness 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 and 

effluents generated during catalyst activation can be eliminated by obtaining 

the catalyst in the active form. 

Optimize processes. Process changes that optimize reactions and raw 

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 

systems are often capable of automatic startups, shutdowns, and product 

changeover which can bring the process to stable conditions quickly, 

minimizing the generation of off-spec wastes. Other process optimization 

techniques include: equalizing the reactor and storage tank vent lines during 

batch filling to minimize vent gas losses; sequencing the addition of reactants 

and reagents to optimize yields and lower emissions; and optimizing 

sequences to minimize washing operations and cross-contamination of 

subsequent batches. 

Reduce heat exchanger wastes and inefficiencies. Heat exchangers are 

often the source of significant off-spec product wastes generated by 

overheating the product closest to the tube walls. The best way to reduce offspec product from overheating is by reducing the heat exchanger tube wall 

temperature. This can be accomplished through a number of techniques 

which do not reduce the overall heat transferred such as: reducing the tube 

wall temperature and increasing the effective surface area of the heat 

exchanger; using staged heating by first heating with waste heat, then low 

pressure steam, followed by superheated high pressure steam; monitor and 

prevent fouling of the heat exchanger tubes so that lower temperature heat 

sources can be used; using noncorroding tubes which will foul less quickly 

than tubes that corrode. 

Improve wastewater treatment and recycling. A large portion of the 

inorganic chemical industry's pollutants leave the facilities as wastewater or 

wastewater 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. Modern 

wastewater treatment technologies such as ion exchange, electrolytic cells, 

September 1995 55 SIC 281 
Sector Notebook Project Inorganic Chemicals 

reverse osmosis, and improved distillation, evaporation, and dewatering can 

often be added to existing treatment systems. Wastewater streams containing 

acids or metals can be concentrated enough to be sold commercially as a 

product by slightly altering the manufacturing process, adding processing 

steps, and segregating wastewater streams. Furthermore, many wastewater 

streams can be reused within the same or different processes, significantly 

reducing discharges to the wastewater treatment system. An ion exchange 

system installed in a mercury cell chlor-alkali plant reduced mercury by 99 

percent in the facility's effluent. An inorganic chemicals plant making 

photochemistry solution generated a wastewater containing silver. 

Electrolytic cells were installed that recovered 98 percent of the silver and an 

evaporator was added that concentrated the remaining liquid for disposal 

resulting in a 90 percent reduction in waste volume. 

Prevent leaks and spills. The elimination of sources of leaks and spills can 

be a very cost effective pollution prevention opportunity. Leaks and spills can 

be prevented by installing seamless pumps and other "leakless" components, 

maintaining a preventative maintenance program, and maintaining a leak 

detection program. 

Improve inventory management and storage. Good inventory 

management can reduce the generation of wastes by preventing materials from 

exceeding their shelf life, preventing materials from being left over or not 

needed, and reducing the likelihood of accidental releases of stored material. 

Designating a materials storage area, limiting traffic through the area, and 

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 and 

provides additional examples provided by the Chemical Manufacturers 

Association. 

September 1995 56 SIC 281 
Sector 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. 

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

raw material requirements. 

P Identify uses and develop a sales 

outlet. Collect information necessary to 

firm up a purchase commitment such as 

minimum quality criteria, maximum 

impurity levels that can be tolerated, 

and performance criteria. 

Catalysts 

Composition 

Preparation and Handling 

P The presence of heavy metals in 

catalysts can result in contaminated 

process wastewater from catalyst 

handling and separation. These wastes 

may require special treatment and 

disposal procedures or facilities. Heavy 

metals can be inhibitory or toxic to 

biological wastewater treatment units. 

Sludge from wastewater treatment units 

may be classified as hazardous due to 

heavy metals content. Heavy metals 

generally exhibit low toxicity thresholds 

in aquatic environments and may 

bioaccumulate. 

P Emissions or effluents are generated 

with catalyst activation or regeneration. 

P Catalyst attrition and 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 281
Sector 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 which 

will 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 281
Sector 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 281
Sector 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. 

PEqualize reactor and storage tank vent 

P Use materials with low viscosity. 

Minimize equipment roughness. 

lines. 

PRecover vapors through condenser, 

adsorber, etc. 

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

September 1995 60 SIC 281
Sector 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 

PDesign 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 281
Sector 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 P Impurities may produce unwanted byproducts and waste. Toxic impurities, 

even in trace amounts, can make a waste 

hazardous and therefore subject to strict 

and costly regulation. 

P Excessive impurities may require more 

processing and equipment to meet 

product specifications, increasing costs 

and potential for fugitive emissions, 

leaks, and spills. 

P Use higher purity materials. 

P Purify materials before use and reuse 

if practical. 

P 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 281
Sector 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. 

PUse pure oxygen. 

PInstall guard beds to protect catalysts. 

P Use material with lower vapor 

pressure. 

P Use materials with lower vapor 

pressure and higher odor threshold. 

P Use less toxic or more biodegradable 

materials. 

P Use less soluble materials. 

P Use less soluble materials. 

P Prevent direct contact with storm 

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 281
Sector 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 281
Sector 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. 

P Minimize 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 281
Sector 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 281
Sector 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 281
Sector 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 near 

ambient 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 281
Sector 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 281
Sector 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 281
Sector 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 281
Sector 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 emphasize that pollution prevention in the chemical industry is 

process specific and oftentimes constrained by site-specific considerations. 

As such, it is difficult to generalize about the relative merits of different 

pollution prevention strategies. The age, size, and purpose of the plant will 

influence the most effective pollution prevention strategy. Commodity 

chemical manufacturers redesign their processes infrequently so that redesign 

of the reaction process or equipment is unlikely in the short term. Here, 

operational changes are the most feasible response. Specialty chemical 

manufacturers are making a greater variety of chemicals and have more 

process and design flexibility. Incorporating changes at the earlier research 

and development phases may be possible for them. 

September 1995 72 SIC 281 
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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 descriptions within Section VI are intended solely for general 

information. Depending upon the nature or scope of the activities at a 

particular facility, these summaries may or may not necessarily describe all 

applicable environmental requirements. Moreover, they do not constitute 

formal interpretations or clarifications of the statutes and regulations. For 

further information, readers should consult the Code of Federal Regulations 

and other state or local 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 which 

amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and 

hazardous (Subtitle C) waste management activities. The Hazardous and 

Solid Waste Amendments (HSWA) of 1984 strengthened RCRA’s waste 

management provisions and added Subtitle I, which governs underground 

storage tanks (USTs). 

Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 

260-299) establish a “cradle-to-grave” system governing hazardous waste 

from the point of generation to disposal. RCRA hazardous wastes include the 

specific materials listed in the regulations (commercial chemical products, 

designated with the code "P" or "U"; hazardous wastes from specific 

industries/sources, designated with the code "K"; or hazardous wastes from 

non-specific sources, designated with the code "F") or materials which exhibit 

a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity 

and designated with the code "D"). 

Regulated entities that generate hazardous waste are subject to waste 

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 implement the permitting 

program. Subtitle C permits contain general facility standards such as 

September 1995 73 SIC 281 
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contingency plans, emergency procedures, record keeping and reporting 

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 of 

hazardous waste or constituents from solid waste management units at 

RCRA-regulated facilities. 

Although RCRA is a Federal statute, many States implement the RCRA 

program. Currently, EPA has delegated its authority to implement various 

provisions of RCRA to 46 of the 50 States. 

Most RCRA requirements are not industry specific but apply to any company 

that transports, treats, stores, or disposes of hazardous waste. Here are some 

important RCRA regulatory requirements: 

C Identification of Solid and Hazardous Wastes (40 CFR Part 261) 

lays out the procedure every generator should follow to determine 

whether the material created is considered a hazardous waste, solid 

waste, or is exempted from regulation. 

C Standards for Generators of Hazardous Waste (40 CFR Part 262) 

establishes the responsibilities of hazardous waste generators including 

obtaining an ID number, preparing a manifest, ensuring proper 

packaging and labeling, meeting standards for waste accumulation 

units, and record keeping and reporting requirements. 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 

disposal 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 land 

disposal unit (landfill, land treatment unit, waste pile, or surface 

impoundment). Wastes subject to the LDRs include solvents, 

electroplating wastes, heavy metals, and acids. Generators of waste 

subject to the LDRs must provide notification of such to the 

designated TSD facility to ensure proper treatment prior to disposal. 

C Used Oil storage and disposal regulations (40 CFR Part 279) do not 

define Used Oil Management Standards impose management 

requirements affecting the storage, transportation, burning, 

processing, and re-refining of the used oil. For parties that merely 

generate used oil, regulations establish storage standards. For a party 

considered a used oil marketer (one who generates and sells 

September 1995 74 SIC 281 
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off-specification used oil directly to a used oil burner), additional 

tracking and paperwork requirements must be satisfied. 

C Tanks and Containers used to store hazardous waste with a high 

volatile organic concentration must meet emission standards under 

RCRA. Regulations (40 CFR Part 264-265, Subpart CC) require 

generators to test the waste to determine the concentration of the 

waste, to satisfy tank and container emissions standards, and to 

inspect and monitor regulated units. These regulations apply to all 

facilities who store such waste, including generators operating under 

the 90-day accumulation rule. 

C Underground Storage Tanks (USTs) containing petroleum and 

hazardous substance are regulated under Subtitle I of RCRA. Subtitle 

I regulations (40 CFR Part 280) contain tank design and release 

detection requirements, as well as financial responsibility and 

corrective action standards for USTs. The UST program also 

establishes increasingly stringent standards, including upgrade 

requirements for existing tanks, that must be met by 1998. 

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

containing hazardous waste must comply with strict design and 

operating standards. BIF regulations (40 CFR Part 266, Subpart H) 

address unit design, provide performance 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 to 

questions and distributes guidance regarding all RCRA regulations. The 

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 

The Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA 

to respond to releases, or threatened releases, of hazardous substances that 

may endanger public health, welfare, or the environment. CERCLA also 

enables EPA to force parties responsible for environmental contamination to 

clean it up or to reimburse the Superfund for response costs incurred by EPA. 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

revised various sections of CERCLA, extended the taxing authority for the 

Superfund, and created a free-standing law, SARA Title III, also known as the 

Emergency Planning and Community Right-to-Know Act (EPCRA). 

The CERCLA hazardous substance release reporting regulations (40 CFR 

Part 302) direct the person in charge of a facility to report to the National 

September 1995 75 SIC 281 
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Response Center (NRC) any environmental release of a hazardous substance 

which exceeds a reportable quantity. Reportable quantities are defined and 

listed in 40 CFR §302.4. A release report may trigger a response by EPA, or 

by one or more Federal or State emergency response authorities. 

EPA implements hazardous substance responses according to procedures 

outlined in the National Oil and Hazardous Substances Pollution Contingency 

Plan (NCP) (40 CFR Part 300). The NCP includes provisions for permanent 

cleanups, known as remedial actions, and other cleanups referred to as 

"removals." EPA generally takes remedial actions only at sites on the 

National Priorities List (NPL), which currently includes approximately 1300 

sites. Both EPA and states can act at other sites; however, EPA provides 

responsible parties the opportunity to conduct removal and remedial actions 

and encourages 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 program. The CERCLA 

Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding 

Federal holidays. 

Emergency Planning And Community Right-To-Know Act 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

created the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), a statute designed to improve 

community access to information about chemical hazards and to facilitate the 

development of chemical emergency response plans by State and local 

governments. EPCRA required the establishment of State emergency 

response commissions (SERCs), responsible for coordinating certain 

emergency response activities and for appointing local emergency planning 

committees (LEPCs). 

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four 

types of reporting obligations for facilities which store or manage specified 

chemicals: 

C EPCRA §302 requires facilities to notify the SERC and LEPC of the 

presence of any "extremely hazardous substance" (the list of such 

substances is in 40 CFR Part 355, Appendices A and B) if it has such 

substance in excess of the substance's threshold planning quantity, and 

directs the facility to appoint an emergency response coordinator. 

C EPCRA §304 requires the facility to notify the SERC and the LEPC 

in the event of a release exceeding the reportable quantity of a 

September 1995 76 SIC 281 
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CERCLA hazardous substance or an EPCRA extremely hazardous 

substance. 

C EPCRA §311 and §312 require a facility at which a hazardous 

chemical, as defined by the Occupational Safety and Health Act, is 

present in an amount exceeding a specified threshold to submit to the 

SERC, LEPC and local fire department material safety data sheets 

(MSDSs) or lists of MSDS's and hazardous chemical inventory forms 

(also known as Tier I and II forms). This information helps the local 

government respond in the event of a spill or release of the chemical. 

C EPCRA §313 requires manufacturing facilities included in SIC codes 

20 through 39, which have ten or more employees, and which 

manufacture, process, or use specified chemicals in amounts greater 

than threshold quantities, to submit an annual toxic chemical release 

report. This report, commonly known as the Form R, covers releases 

and transfers of toxic chemicals to various facilities and environmental 

media, and allows EPA to compile the national Toxic Release 

Inventory (TRI) database. 

All information submitted pursuant to EPCRA regulations is publicly 

accessible, unless protected by a trade secret claim. 

EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes 

guidance regarding the emergency planning and community right-to-know 

regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30 

p.m., ET, excluding Federal holidays. 

Clean Water Act 

The primary objective of the Federal Water Pollution Control Act, commonly 

referred to as the Clean Water Act (CWA), is to restore and maintain the 

chemical, physical, and biological integrity of the nation's surface waters. 

Pollutants regulated under the CWA include "priority" pollutants, including 

various toxic pollutants; "conventional" pollutants, such as biochemical 

oxygen demand (BOD), total suspended solids (TSS), fecal coliform, oil and 

grease, and pH; and "non-conventional" pollutants, including any pollutant not 

identified as either conventional or priority. 

The CWA regulates both direct and indirect discharges. The National 

Pollutant Discharge Elimination System (NPDES) program (CWA §402) 

controls direct discharges into navigable waters. Direct discharges or "point 

source" discharges are from sources such as pipes and sewers. NPDES 

permits, issued by either EPA or an authorized State (EPA has authorized 

approximately forty States to administer the NPDES program), contain 

industry-specific, technology-based and/or water quality-based limits, and 

September 1995 77 SIC 281 
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establish pollutant monitoring requirements. A facility that intends to 

discharge into the nation's waters must obtain a permit prior to initiating its 

discharge. A permit applicant must provide quantitative analytical data 

identifying the types of pollutants present in the facility's effluent. The permit 

will then set forth the conditions and effluent limitations under which a facility 

may make a discharge. 

A NPDES permit may also include 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 

standards, unlike the technological standards, generally do not take into 

account technological feasibility or costs. Water quality criteria and standards 

vary from State to State, and site to site, depending on the use classification 

of the receiving body of water. Most States follow EPA guidelines which 

propose aquatic life and human health criteria for many of the 126 priority 

pollutants. 

Storm Water Discharges 

In 1987 the CWA was amended to require EPA to establish a program to 

address storm water discharges. In response, EPA promulgated the NPDES 

storm water permit application regulations. Storm water discharge associated 

with industrial activity means the discharge from any conveyance which is 

used for collecting and conveying storm water and which is directly related to 

manufacturing, processing, or raw materials storage areas at an industrial 

plant (40 CFR 122.26(b)(14)). These regulations require that facilities with 

the following storm water discharges apply for an NPDES permit: (1) a 

discharge associated with industrial activity; (2) a discharge from a large or 

medium municipal storm sewer system; or (3) a discharge which EPA or the 

State determines to contribute to a violation of a water quality standard or is 

a significant contributor of pollutants to waters of the United States. 

The term "storm water discharge associated with industrial activity" means a 

storm water discharge from one of 11 categories of industrial activity defined 

at 40 CFR 122.26. Six of the categories are defined by SIC codes while the 

other five are identified through narrative descriptions of the regulated 

industrial activity. If the primary SIC code of the facility is one of those 

identified in the regulations, the facility is subject to the storm water permit 

application requirements. If any activity at a facility is covered by one of the 

five narrative categories, storm water discharges from those areas where the 

activities occur are subject to storm water discharge permit application 

requirements. 

Those facilities/activities that are subject to storm water discharge permit 

application requirements are identified below. To determine whether a 

particular facility falls within one of these categories, the regulation should be 

consulted. 

September 1995 78 SIC 281 
Sector Notebook Project Inorganic Chemicals 

Category i: Facilities subject to storm water effluent guidelines, new source 

performance standards, or toxic pollutant effluent standards. 

Category ii: Facilities classified as SIC 24-lumber and wood products 

(except wood kitchen cabinets); SIC 26-paper and allied products (except 

paperboard containers and products); SIC 28-chemicals and allied products 

(except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather 

tanning and finishing. 

Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal 

mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral mining. 

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

Category v: Landfills, land application sites, and open dumps that receive or 

have received industrial wastes. 

Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and 

SIC 5093-automotive scrap and waste material recycling facilities. 

Category vii: Steam electric power generating facilities. 

Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41-

local passenger transportation; SIC 42-trucking and warehousing (except 

public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water 

transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk 

storage stations and terminals. 

Category ix: Sewage treatment works. 

Category x: Construction activities except operations that result in the 

disturbance of less than five acres of total land area. 

Category xi: Facilities classified as SIC 20-food and kindred products; SIC 

21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related 

products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture 

and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted 

paper and paperboard products; SIC 27-printing, publishing, and allied 

industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and 

allied products; SIC 30-rubber and plastics; SIC 31-leather and leather 

products (except leather and tanning and finishing); SIC 323-glass products; 

SIC 34-fabricated metal products (except fabricated structural metal); SIC 35-

industrial and commercial machinery and computer equipment; SIC 36-

electronic and other electrical equipment and components; SIC 37-

September 1995 79 SIC 281 
Sector Notebook Project Inorganic Chemicals 

transportation equipment (except ship and boat building and repairing); SIC 

38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous 

manufacturing industries; and SIC 4221-4225-public warehousing and 

storage. 

Pretreatment Program 

Another type of discharge that is regulated by the CWA is one that goes to a 

publicly-owned treatment works (POTWs). The national pretreatment 

program (CWA §307(b)) controls the indirect discharge of pollutants to 

POTWs by "industrial users." Facilities regulated under §307(b) must meet 

certain pretreatment standards. The goal of the pretreatment program is to 

protect municipal wastewater treatment plants from damage that may occur 

when hazardous, toxic, or other wastes are discharged into a sewer system 

and to protect the quality of sludge generated by these plants. Discharges to 

a POTW are regulated primarily by the POTW itself, rather than the State or 

EPA. 

EPA has developed technology-based standards for industrial users of 

POTWs. Different standards apply to existing and new sources within each 

category. "Categorical" pretreatment standards applicable to an industry on 

a nationwide basis are developed by EPA. In addition, another kind of 

pretreatment standard, "local limits," are developed by the POTW in order to 

assist the POTW in achieving the effluent limitations in its NPDES permit. 

Regardless of whether a State is authorized to implement either the NPDES 

or the pretreatment program, if it develops its own program, it may enforce 

requirements more stringent than Federal standards. 

EPA’s Office of Water, at (202) 260-5700, will direct callers with questions 

about the CWA to the appropriate EPA office. EPA also maintains a 

bibliographic database of Office of Water publications which can be 

accessed through the Ground Water and Drinking Water resource center, at 

(202) 260-7786. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA) mandates that EPA establish 

regulations to protect human health from contaminants in drinking water. The 

law authorizes EPA to develop national drinking water standards and to 

create a joint Federal-State system to ensure compliance with these standards. 

The SDWA also directs EPA to protect underground sources of drinking 

water through the control of underground injection of liquid wastes. 

EPA has developed primary and secondary drinking water standards under its 

SDWA authority. EPA and authorized States enforce the primary drinking 

September 1995 80 SIC 281 
Sector Notebook Project Inorganic Chemicals 

water standards, which are, contaminant-specific concentration limits that 

apply to certain public drinking water supplies. Primary drinking water 

standards consist of maximum contaminant level goals (MCLGs), which are 

non-enforceable health-based goals, and maximum contaminant levels 

(MCLs), which are enforceable limits set as close to MCLGs as possible, 

considering cost and feasibility of attainment. 

The SDWA Underground Injection Control (UIC) program (40 CFR Parts 

144-148) is a permit program which protects underground sources of drinking 

water by regulating five classes of injection wells. UIC permits include 

design, operating, inspection, and monitoring requirements. Wells used to 

inject hazardous wastes must also comply with RCRA corrective action 

standards in order to be granted a RCRA permit, and must meet applicable 

RCRA land disposal restrictions standards. The UIC permit program is 

primarily State-enforced, since EPA has authorized all but a few States to 

administer the program. 

The SDWA also provides for a Federally-implemented Sole Source Aquifer 

program, which prohibits Federal funds from being expended on projects that 

may contaminate the sole or principal source of drinking water for a given 

area, and for a State-implemented Wellhead Protection program, designed to 

protect drinking water wells and drinking water recharge areas. 

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

and distributes guidance pertaining to SDWA standards. The Hotline 

operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays. 

Toxic Substances Control Act 

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

a regulatory framework to collect data on chemicals in order to evaluate, 

assess, mitigate, and control risks which may be posed by their manufacture, 

processing, and use. TSCA 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 premanufacture notice (PMN) must be submitted to EPA prior to 

manufacture or import. The PMN must identify the chemical and provide 

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 environmental 

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 281 
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Under TSCA §6, EPA can ban the manufacture or distribution in commerce, 

limit the use, require labeling, or place other restrictions on chemicals that 

pose unreasonable risks. Among the chemicals EPA regulates under §6 

authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated 

biphenyls (PCBs). 

EPA’s TSCA Assistance Information Service, at (202) 554-1404, answers 

questions and distributes guidance pertaining to Toxic Substances Control 

Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., ET, 

excluding Federal holidays. 

Clean Air Act 

The Clean Air Act (CAA) and its amendments, including the Clean Air Act 

Amendments (CAAA) of 1990, are designed to “protect and enhance the 

nation's air resources so as to promote the public health and welfare and the 

productive capacity of the population.” The CAA consists of six sections, 

known as Titles, which direct EPA to establish national standards for ambient 

air quality and for EPA and the States to implement, maintain, and enforce 

these standards through a variety of mechanisms. Under the CAAA, many 

facilities will be required to obtain permits for the first time. State and local 

governments oversee, manage, and enforce many of the requirements of the 

CAAA. CAA regulations appear at 40 CFR Parts 50 through 99. 

Pursuant to Title I of the CAA, EPA has established national ambient air 

quality standards (NAAQSs) to limit levels of "criteria pollutants," including 

carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur 

dioxide. Geographic areas that meet NAAQSs for a given pollutant are 

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 State Implementation Plan (SIP) to identify sources of air pollution and to 

determine what reductions are required to meet Federal air quality standards. 

Title I also authorizes EPA to establish New Source Performance Standards 

(NSPSs), which are nationally uniform emission standards for new stationary 

sources falling within particular industrial categories. NSPSs are based on the 

pollution control technology available to that category of industrial source but 

allow the affected industries the flexibility to devise a cost-effective means of 

reducing emissions. 

Under Title I, EPA establishes 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 further directed EPA to develop a list of sources that emit any of 

189 HAPs, and to develop regulations for these categories of sources. To 

date EPA has listed 174 categories and developed a schedule for the 

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establishment of emission standards. The emission standards will be 

developed for both new and existing sources based on "maximum achievable 

control technology" (MACT). The MACT is defined as the control 

technology achieving the maximum degree of reduction in the emission of the 

HAPs, taking into account cost and other factors. 

Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, 

and planes. Reformulated gasoline, automobile pollution control devices, and 

vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses 

to regulate mobile air emission sources. 

Title IV establishes a sulfur dioxide emissions program designed to reduce the 

formation of acid rain. Reduction of sulfur dioxide releases will be obtained 

by granting to certain sources limited emissions allowances, which, beginning 

in 1995, will be set below previous levels of sulfur dioxide releases. 

Title V of the CAAA of 1990 created a permit program for all "major 

sources" (and certain other sources) regulated under the CAA. One purpose 

of the operating permit is to include in a single document all air emissions 

requirements that apply to a given facility. States are developing the permit 

programs in accordance with guidance and regulations from EPA. Once a 

State program is approved by EPA, permits will be issued and monitored by 

that State. 

Title VI is intended to protect stratospheric ozone by phasing out the 

manufacture of ozone-depleting chemicals and restrict their use and 

distribution. Production of Class I substances, including 15 kinds of 

chlorofluorocarbons (CFCs), will be phased out entirely by the year 2000, 

while certain hydrochlorofluorocarbons (HCFCs) will be phased out by 2030. 

EPA's Control Technology Center, at (919) 541-0800, provides general 

assistance and information on CAA standards. The Stratospheric Ozone 

Information Hotline, at (800) 296-1996, provides general information about 

regulations promulgated under Title VI of the CAA, and EPA's EPCRA 

Hotline, at (800) 535-0202, answers questions about accidental release 

prevention under CAA §112(r). In addition, the Technology Transfer 

Network Bulletin Board System (modem access (919) 541-5742)) includes 

recent CAA rules, EPA guidance documents, and updates of EPA activities. 

VI.B. Industry Specific Requirements 

The inorganic chemical industry is affected by nearly all federal environmental 

statutes. In addition, the industry is subject to numerous laws and regulations 

from state and local governments designed to protect and improve health, 

safety, and the environment. A summary of the major federal regulations 

affecting the chemical industry follows. 

September 1995 83 SIC 281 
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Federal Statutes 

Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA), passed in 1976, gives the 

Environmental Protection Agency comprehensive authority to regulate any 

chemical substance whose manufacture, processing, distribution in commerce, 

use, or disposal may present an unreasonable risk of injury to health or the 

environment. Three sections are of primary importance to the inorganic 

chemical industry. Section 5 mandates that chemical companies submit to 

EPA pre-manufacture notices that provide information on health and 

environmental effects for each new product and test existing products for 

these effects. To date, over 20,000 premanufacturing notices have been filed. 

Section 4 authorizes the EPA to require testing of certain substances. Section 

6 gives the EPA authority to prohibit, limit, or ban the manufacture, process, 

and use of chemicals. Under Section 6 of TSCA, EPA has banned most uses 

of asbestos. In 1990, however, the chlor-alkali industry was able to show that 

it did not have difficulty meeting the required exposure limits for asbestos 

fibers, and the use of asbestos as a diaphragm material was exempted from the 

TSCA ban. 

Clean Air Act 

The Clean Air Act Amendments of 1990 set National Emission Standards for 

Hazardous Air Pollutants (NESHAP) from industrial sources for 41 pollutants 

to be met by 1995 and for 148 other pollutants to be reached by 2003. 

Several provisions affect the inorganic chemical industry. The EPA will 

promulgate maximum achievable control technology (MACT) standards and 

Lowest Achievable Emission Rates will be required in NAAQS nonattainment areas (Iliam Rosario, U.S. EPA, OAQPS, WAM for Chlorine 

Production NESHAP (919)-541-5308). An information collection request 

survey was sent out to the chlor-alkali industry in 1992. The data obtained 

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 the chlor-alkali industry by 1997. For any subject facility, a six year 

extension of MACT requirements is available if they can demonstrate early 

emission reductions. 

The Clean Air Act Amendments of 1990 contain provisions to phase out the 

use of ozone depleting chemicals such as chlorofluorocarbons, halons, carbon 

tetrachloride, and methyl chloroform, as required by the Montreal Protocol 

on Substances that Deplete the Ozone Layer. The chlor-alkali industry has 

been and will continue to be significantly affected by these provisions due to 

decreases in the demand for chlorine as a feedstock in manufacturing these 

chemicals. In addition, many of these chemicals are used extensively by the 

industry to process chlorine. 

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Clean Water Act 

The Clean Water Act, first passed in 1972 and amended in 1977 and 1987, 

gives 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 and 

indirect (to a Publicly Owned Treatment Works) discharges. Effluent 

guidelines for the chlor-alkali industry were last updated in 1984 (40 CFR 

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 emissions 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 and 

streams. Many mills are switching from chlorine to alternative bleaching 

agents in response to the effluent restrictions. Pulp mills accounted for about 

15 percent of the chlorine demand in the U.S. in 1982 and 11 percent in 1992. 

The demand for chlorine for pulp bleaching is expected to continue to 

decrease through the 1990s. 

Resource Conservation and Recovery Act 

The Resource Conservation and Recovery Act (RCRA) of 1976 gives the 

EPA authority to establish a list of solid and hazardous wastes, and to 

establish standards and regulations for handling and disposing of these wastes. 

New wastes 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, however, to propose new hazardous waste listings for 

the 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 also 

requires companies to establish programs to reduce the volume and toxicity 

of hazardous wastes. It was last amended in 1984 when Congress mandated 

some 70 new programs for the hazardous waste (Subtitle C) program. 

Included were tighter standards for handling and disposing of hazardous 

wastes, land disposal prohibitions, corrective action (or remediation) 

regulations, and regulations for underground storage tanks. The inorganic 

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 Occupational Safety and Health Act gave the Department of Labor the 

authority to set comprehensive workplace safety and health standards 

including permissible exposures to chemical in the workplace and authority to 

conduct inspections and issue citations for violations of safety and health 

September 1995 85 SIC 281 
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regulations. The chemical industry is subject to hazard identification 

standards established by OSHA, which require extensive documentation of 

chemicals in trade and in the workplace and mandate warning labels on 

containers. The industry is also subject to OSHA's Hazard Communication 

Standard and various state and local laws, which give workers the right to 

know about hazardous chemicals in the workplace. 

Hazardous Materials Transportation Act 

The Hazardous Materials Transportation Act (HMTA) gives the Department 

of Transportation authority to regulate the movement of hazardous materials. 

Chemical manufacturers must comply with regulations governing shipment 

preparation, including packaging, labeling and shipping papers; handling, 

loading and unloading; routing emergency and security planning; incident 

notifications; and liability insurance. The chemical manufacturers must also 

comply with operating requirements for vehicle, vessel, and carrier 

transportation of hazardous materials by road, rail, air, and sea. The 

chemicals covered by the HMTA span a broad list of substances, including 

hazardous wastes normally regulated by RCRA and hazardous materials that 

DOT designates as hazardous for the purposes of transportation that may not 

be considered hazardous under RCRA. These regulations especially apply to 

chlorine gas which can cause significant risk during transport. 

Pollution Prevention Act 

The Pollution Prevention Act makes it a national policy of the United States 

to reduce or eliminate the generation of waste at the source whenever feasible. 

The EPA is directed to undertake a multi-media program of information 

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 Reduction Act affects those facilities that use, 

manufacture, or process more than a specified amount of substances that are 

on the Massachusetts toxic or hazardous substances list. Facilities must 

submit annual reports on the amounts of substances used, manufactured, or 

processed and must pay annual fees based on these amounts. In addition, 

facilities must prepare toxics use reduction plans which show in-plant changes 

in production processes or raw materials that would reduce, avoid, or 

eliminate the use or generation of toxic or hazardous substances. The 

Massachusetts toxic or hazardous substance list initially consists of those 

September 1995 86 SIC 281 
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substances listed under §313 of EPCRA and will eventually include those 

substances 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 Conservation and Recovery Act (RCRA) listed waste streams 

specific to the inorganic chemical industry have not been updated since the 

original RCRA hazardous wastes list developed in 1980. EPA is under a 

court-ordered deadline to propose and finalize additional waste listings for the 

industry by March 1997 and March 1988, respectively. The Office of Solid 

Waste will begin assessing the 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 are 

scheduled to be promulgated by EPA by 1997. (Contact: Iliam Rosario, U.S. 

EPA, OAQPS, WAM for Chlorine Production NESHAP, 919-541-5308) The 

standards required will, in most cases, be in the form of MACT standards. 

Lowest Achievable Emission Rates will be required in NAAQS nonattainment areas. An information collection request survey was sent out to 

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. 

The chlor-alkali industry will continue to be affected by the provisions to 

phase out the use of ozone depleting chemicals as required by the Montreal 

Protocol on Substances that Deplete the Ozone Layer. The demand for 

chlorine as a feedstock in manufacturing these chemicals, 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 refrigerants increases, and 

as alternative processes are introduced. 

September 1995 87 SIC 281 
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VII. COMPLIANCE AND ENFORCEMENT HISTORY 

Background 

To date, EPA has focused much of its attention on measuring compliance with 

specific environmental statutes. This approach allows the Agency to track 

compliance with the Clean Air Act, the Resource Conservation and Recovery 

Act, the Clean Water Act, and other environmental statutes. Within the last 

several years, the Agency has begun to supplement single-media compliance 

indicators with facility-specific, multimedia indicators of compliance. In doing 

so, EPA is in a better position to track compliance with all statutes at the 

facility level, and within specific industrial sectors. 

A major step in building the capacity to compile multimedia data for industrial 

sectors was the creation of EPA's Integrated Data for Enforcement Analysis 

(IDEA) system. IDEA has the capacity to "read into" the Agency's singlemedia databases, extract compliance records, and match the records to 

individual facilities. The IDEA system can match Air, Water, Waste, 

Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given 

facility, and generate a list of historical permit, inspection, and enforcement 

activity. IDEA also has the capability to analyze data by geographic area and 

corporate holder. 

Compliance and Enforcement Profile Description 

Using inspection, violation, and enforcement data from the IDEA system, this 

section provides information regarding the historical compliance and 

enforcement activity of this sector. In order to mirror the facility universe 

reported in the Toxic Chemical Profile, the data reported within this section 

consists of records only from the TRI reporting universe. With this decision, 

the selection criteria are consistent across sectors with certain exceptions. For 

the sectors that do not normally report to the TRI program, data have been 

provided from EPA's Facility Indexing System (FINDS) which tracks facilities 

in all media databases. Please note, in this section, EPA does not attempt to 

define the actual number of facilities that fall within each sector. Instead, the 

section portrays the records of a subset of facilities within the sector that are 

well defined within EPA databases. 

As a check on the relative size of the full sector universe, most notebooks 

contain an estimated number of facilities within the sector according to the 

Bureau of Census (See Section II). With sectors dominated by small 

businesses, such as metal finishers and printers, the reporting universe within 

the EPA databases may be small in comparison to Census data. However, the 

group selected for inclusion in this data analysis section should be consistent 

with this sector's general make-up. 

September 1995 88 SIC 281 
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Following this introduction is a list defining each data column presented 

within this section. These values represent a retrospective summary of 

inspections or enforcement actions, and solely reflect EPA, state, and local 

compliance assurance activity that have been entered into EPA databases. To 

identify any changes in trends, the EPA ran two data queries, one for the past 

five calendar years (August 10, 1990 to August 9, 1995) and the other for the 

most recent twelve-month period (August 10, 1994 to August 9, 1995). The 

five-year analysis gives an average level of activity for that period for 

comparison to the more recent activity. 

Because most inspections focus on single-media requirements, the data 

queries presented in this section are taken from single media databases. These 

databases do not provide data on whether inspections are state/local or EPAled. However, the table breaking down the universe of violations does give the 

reader a crude measurement of the EPA's and states' efforts within each media 

program. The presented data illustrate the variations across regions for e certain sectors. This variation may be attributable to state/local data entry

variations, specific geographic concentrations, proximity to population 

centers, sensitive ecosystems, highly toxic chemicals used in production, or 

historical noncompliance. Hence, the exhibited data do not rank regional 

performance or necessarily reflect which regions may have the most 

compliance problems. 

Compliance and Enforcement Data Definitions 

General Definitions 

Facility Indexing System (FINDS) -- this system assigns a common facility 

number to EPA single-media permit records. The FINDS identification 

number allows EPA to compile and review all permit, compliance, 

enforcement and pollutant release data for any given regulated facility. 

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration 

system that can retrieve information from the major EPA program office 

databases. IDEA uses the FINDS identification number to ?glue together” 

separate data records from EPA’s databases. This is done to create a ?master 

list” of data records for any given facility. Some of the data systems 

accessible through IDEA are: AIRS (Air Facility Indexing and Retrieval 

System, Office of Air and Radiation), PCS (Permit Compliance System, Office 

of Water), RCRIS (Resource Conservation and Recovery Information 

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 281 
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Office of Prevention, Pesticides, and Toxic Substances), CERCLIS 

(Comprehensive Environmental and Liability Information System, Superfund), 

and TRIS (Toxic Release Inventory System). IDEA also contains information 

from outside sources such as Dun and Bradstreet and the Occupational Safety 

and Health Administration (OSHA). Most data queries displayed in notebook 

sections IV and VII were conducted using IDEA. 

Data Table Column Heading Definitions 

Facilities in Search -- are based on the universe of TRI reporters within the 

listed SIC code range. For industries not covered under TRI reporting 

requirements, the notebook uses the FINDS universe for executing data 

queries. The SIC code range selected for each search is defined by each 

notebook's selected SIC code coverage described in Section II. 

Facilities Inspected -- indicates the level of EPA and state agency facility 

inspections for the facilities in this data search. These values show what 

percentage of the facility universe is inspected in a 12 or 60 month period. 

This column does not count non-inspectional compliance activities such as the 

review of facility-reported discharge reports. 

Number of Inspections -- measures the total number of inspections 

conducted in this sector. An inspection event is counted each time it is 

entered into a single media database. 

Average Time Between Inspections -- provides an average length of time, 

expressed in months, that a compliance inspection occurs at a facility within 

the defined universe. 

Facilities with One or More Enforcement Actions -- expresses the number 

of facilities that were party to at least one enforcement action within the 

defined time period. This category is broken down further into federal and 

state actions. Data are obtained for administrative, civil/judicial, and criminal 

enforcement actions. Administrative actions include Notices of Violation 

(NOVs). A facility with multiple enforcement actions is only counted once in 

this column (facility with three enforcement actions counts as one). All 

percentages that appear are referenced to the number of facilities inspected. 

Total Enforcement Actions -- describes the total number of enforcement

actions identified for an industrial sector across all environmental statutes. A

facility with multiple enforcement actions is counted multiple times (a facility

with three enforcement actions counts as three). 

State Lead Actions -- shows what percentage of the total enforcement

actions are taken by state and local environmental agencies. Varying levels

of use by states of EPA data systems may limit the volume of actions

September 1995 90 SIC 281 
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accorded state enforcement activity. Some states extensively report 

enforcement activities into EPA data systems, while other states may use their 

own data systems. 

Federal Lead Actions -- shows what percentage of the total enforcement 

actions are taken by the United States Environmental Protection Agency. 

This value includes referrals from state agencies. Many of these actions result 

from coordinated or joint state/federal efforts. 

Enforcement to Inspection Rate -- expresses how often enforcement actions 

result from inspections. This value is a ratio of enforcement actions to 

inspections, and is presented for comparative purposes only. This measure is 

a rough indicator of the relationship between inspections and enforcement. 

Reported inspections and enforcement actions under the Clean Water Act 

(PCS), the Clean Air Act (AFS) and the Resource Conservation and Recovery 

Act (RCRA) are included in this ratio. Inspections and actions from the 

TSCA/FIFRA/EPCRA database are not factored into this ratio because most 

of the actions taken under these programs are not the result of facility 

inspections. This ratio does not account for enforcement actions arising from 

non-inspection compliance monitoring activities (e.g., self-reported water 

discharges) that can result in enforcement action within the CAA, CWA and 

RCRA. 

Facilities with One or More Violations Identified -- indicates the number 

and percentage of inspected facilities having a violation identified in one of the 

following data categories: In Violation or Significant Violation Status (CAA); 

Reportable Noncompliance, Current Year Noncompliance, Significant 

Noncompliance (CWA); Noncompliance and Significant Noncompliance 

(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unresolved High 

Priority Violation (RCRA). The values presented for this column reflect the 

extent of noncompliance within the measured time frame, but do not 

distinguish between the severity of the noncompliance. Percentages within 

this column may exceed 100 percent because facilities can be in violation 

status without being inspected. Violation status may be a precursor to an 

enforcement action, but does not necessarily indicate that an enforcement 

action will occur. 

Media Breakdown of Enforcement Actions and Inspections -- four 

columns identify the proportion of total inspections and enforcement actions 

within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each 

column is a percentage of either the ?Total Inspections,” or the ?Total 

Actions” column. 

September 1995 91 SIC 281 
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VII.A. Inorganic Chemical Industry Compliance History 

Exhibit 20 provides an overview of the reported compliance and enforcement 

data for the inorganic chemical industry over the past five years (August 1990 

to August 1995). These data are also broken out by EPA Region thereby 

permitting geographical comparisons. A few points evident from the data are 

listed below. 

C Slightly more than half of the TRI reporting inorganic chemical 

facilities in the EPA databases were inspected over the five year 

period resulting in an average of 11 months between inspections of 

these facilities. 

C On average, the states carried out three times the number of 

inspections as the Regions; however, the percentage of state led 

actions varied across the Regions from 44 percent to 96 percent. 

C The enforcement to inspection rate varied significantly from Region 

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 Chemicals Exhibit 20: Five-Year Enforcement and Compliance Summary for Inorganic Chemicals Manufacturing J Enforcement to Inspection Rate 0.08 0.07 0.12 0.09 0.26 0.15 0.13 0.31 0.11 0.13 I Percent Federal Lead Actions 28% 11% 11% 55% 39% 56% 20% 4% 14% 24% H Percent State Lead Actions 72% 89% 89% 45% 61% 44% 80% 96% 86% 76% G Total Enforcement Actions 0 29 38 113 42 106 9 5 53 7 402 F Facilities with 1 or More Enforcement Actions 0 12 12 21 11 24 2 4 9 4 99 E Average Months Between Inspections 38 8 7 7 14 14 18 27 25 19 11 D Number of Inspections 16 354 544 916 469 401 62 38 171 63 3,034 C Facilities Inspected 5 29 41 54 62 40 12 9 35 11 298 B Facilities in Search 10 46 60 105 108 93 19 17 70 20 548 A Region I II III IV V VI VII VIII IX X TOTAL 

September 1995 93 SIC 281
Sector Notebook Project Inorganic Chemicals 

VII.B. Comparison of Enforcement Activity Between Selected Industries 

Exhibits 21 and 22 allow the compliance history of the inorganic chemical 

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 the 

industry by comparing data covering the last five years to that of the past year. 

Some points evident from the data are listed below. 

C The inorganic chemicals industry has a relatively low frequency of 

inspections compared to most of the other sectors shown. On 

average, the number of months between inspections at inorganic 

chemicals facilities has been only about twice that of organic 

chemicals facilities. 

C Over the past five years the inorganic chemical industry has had a ratio 

of enforcement actions to inspections lower than most of the other 

sectors listed including the organic chemicals sector. This difference 

has continued over the past year. 

C Enforcement actions are brought 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 

chemicals industry and other sectors by breaking out the compliance and 

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 24) to facilitate the identification of recent trends. A few points 

evident from the data are listed below. 

C Inspections of inorganic chemical facilities are split relatively evenly 

between Clean Air Act, Clean Water Act, and RCRA, although RCRA 

accounts for a significantly larger portion of the total actions brought 

against the inorganic chemicals industry over the past five years. 

C Significantly more Clean Water Act inspections are carried out at 

inorganic 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 brought 

against the industry and the Clean Air Act has taken a far greater 

share. 

September 1995 94 SIC 281 
Sector Notebook Project Inorganic Chemicals Exhibit 21: Five-Year Enforcement and Compliance Summary for Selected Industries J Enforcement to Inspection Rate 0.13 0.11 0.13 0.19 0.25 0.14 0.16 0.10 0.06 0.12 0.06 0.12 0.12 0.15 0.15 0.27 0.11 I Percent Federal Lead Actions 22% 15% 24% 34% 34% 28% 1% 53% 24% 21% 9% 22% 30% 20% 24% 21% 20% H Percent State Lead Actions 78% 85% 76% 66% 66% 72% 99% 47% 76% 79% 91% 78% 70% 80% 76% 79% 80% G Total Enforcement Actions 502 514 402 726 797 499 103 155 192 232 91 391 301 840 470 212 240 F Facilities with 1 or More Enforcement Actions 115 176 99 152 110 115 29 67 84 78 34 146 73 280 145 68 81 E Average Months Between Inspections 5 52 11 6 3 6 88 34 20 15 11 30 11 26 16 31 16 D Number of Inspections 3,766 4,723 3,034 3,864 3,257 3,555 633 1,519 3,422 1,891 1,534 3,386 2,475 5,509 3,097 777 2,216 C Facilities Inspected 265 1,035 298 316 145 275 245 339 631 301 213 739 268 1,340 474 222 390 B Facilities in Search 306 4,106 548 412 156 374 933 873 1,143 464 293 1,665 468 2,346 844 405 598 A Industry Sector Pulp and Paper Printing Inorganic Chemicals Organic Chemicals Petroleum Refining Iron and Steel Dry Cleaning Metal Mining Non-Metallic Mineral Mining Lumber and Wood Furniture Rubber and Plastic Stone, Clay, and Glass Fabricated Metal Nonferrous Metal Electronics Automobiles 

September 1995 95 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 22: One-Year Inspection and Enforcement Summary for Selected Industries A B C D E F G H Facilities with 1 or More Violations Facilities with 1 or more Enforcement Actions Total Enforcement Actions Industry Sector Facilities in Search Facilities Inspected Number of Inspections Number Percent* Number Percent* Enforcement to Inspection Rate Pulp and Paper 306 189 576 162 86% 28 15% 88 0.15 Printing 4,106 397 676 251 63% 25 6% 72 0.11 Inorganic Chemicals 548 158 427 167 106% 19 12% 49 0.12 Organic Chemicals 412 195 545 197 101% 39 20% 118 0.22 Petroleum Refining 156 109 437 109 100% 39 36% 114 0.26 Iron and Steel 374 167 488 165 99% 20 12% 46 0.09 Dry Cleaning 933 80 111 21 26% 5 6% 11 0.10 Metal Mining 873 114 194 82 72% 16 14% 24 0.13 Non-metallic Mineral Mining 1,143 253 425 75 30% 28 11% 54 0.13 Lumber and Wood 464 142 268 109 77% 18 13% 42 0.58 Furniture 293 160 113 66 41% 3 2% 5 0.55 Rubber and Plastic 1,665 271 435 289 107% 19 7% 59 0.14 Stone, Clay, and Glass 468 146 330 116 79% 20 14% 66 0.20 Nonferrous Metals 844 202 402 282 104% 22 11% 72 0.18 Fabricated Metal 2,346 477 746 525 110% 46 10% 114 0.15 Electronics 405 60 87 80 133% 8 13% 21 0.24 Automobiles 598 169 284 162 96% 14 8% 28 0.10 * 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 281
Sector Notebook Project Inorganic Chemicals Exhibit 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries Clean Air Act Clean Water Act Resource Conservation and Recovery Act FIFRA/TSCA/ EPCRA/Other Industry Sector Facilities Inspected Total Inspections Total Enforcement Actions % of Total Inspections % of Total Actions % of Total Inspections % of Total Actions % of Total Inspections % of Total Actions % of Total Inspections % of Total Actions Pulp and Paper 265 3,766 502 51% 48% 38% 30% 9% 18% 2% 3% Printing 1,035 4,723 514 49% 31% 6% 3% 43% 62% 2% 4% Inorganic Chemicals 298 3,034 402 29% 26% 29% 17% 39% 53% 3% 4% Organic Chemicals 316 3,864 726 33% 30% 16% 21% 46% 44% 5% 5% Petroleum Refining 145 3,237 797 44% 32% 19% 12% 35% 52% 2% 5% Iron and Steel 275 3,555 499 32% 20% 30% 18% 37% 58% 2% 5% Dry Cleaning 245 633 103 15% 1% 3% 4% 83% 93% 0% 1% Metal Mining 339 1,519 155 35% 17% 57% 60% 6% 14% 1% 9% Non-metallic Mineral Mining 631 3,422 192 65% 46% 31% 24% 3% 27% 0% 4% Lumber and Wood 301 1,891 232 31% 21% 8% 7% 59% 67% 2% 5% Furniture 293 1,534 91 52% 27% 1% 1% 45% 64% 1% 8% Rubber and Plastic 739 3,386 391 39% 15% 13% 7% 44% 68% 3% 10% Stone, Clay, and Glass 268 2,475 301 45% 39% 15% 5% 39% 51% 2% 5% Nonferrous Metals 474 3,097 470 36% 22% 22% 13% 38% 54% 4% 10% Fabricated Metal 1,340 5,509 840 25% 11% 15% 6% 56% 76% 4% 7% Electronics 222 777 212 16% 2% 14% 3% 66% 90% 3% 5% Automobiles 390 2,216 240 35% 15% 9% 4% 54% 75% 2% 6% 

September 1995 97 SIC 281
Sector Notebook Project Inorganic Chemicals Exhibit 24: One-Year Inspection and Enforcement Summary by Statute for Selected Industries FIFRA/TSCA/ EPCRA/Other % of Total Actions 3% 4% 6% 1% 6% 6% 7% 19% 11% 6% 13% 11% 3% 4% 2% 4% 6% % of Total Inspections 0% 0% 0% 1% 1% 0% 0% 0% 0% 0% 0% 1% 0% 1% 0% 0% 1% Resource Conservation and Recovery Act % of Total Actions 7% 66% 36% 49% 47% 50% 67% 6% 16% 61% 10% 71% 37% 69% 77% 87% 69% % of Total Inspections 10% 44% 45% 50% 30% 36% 78% 10% 5% 63% 41% 46% 38% 44% 61% 69% 56% Clean Water Act % of Total Actions 21% 3% 21% 16% 16% 26% 22% 34% 16% 13% 10% 4% 8% 3% 8% 7% 9% % of Total Inspections 35% 5% 29% 13% 19% 35% 1% 43% 26% 8% 1% 14% 18% 21% 14% 14% 10% Clean Air Act % of Total Actions 69% 27% 38% 34% 31% 18% 4% 42% 58% 20% 67% 14% 52% 24% 14% 2% 16% % of Total Inspections 56% 50% 26% 36% 50% 29% 21% 47% 69% 29% 58% 39% 45% 33% 25% 17% 34% Total Enforcement Actions 88 72 49 118 114 46 11 24 54 42 5 59 66 72 114 21 28 Total Inspections 576 676 427 545 437 488 111 194 425 268 160 435 330 402 746 87 284 Facilities Inspected 189 397 158 195 109 167 80 114 253 142 293 271 146 202 477 60 169 Industry Sector Pulp and Paper Printing Inorganic Chemicals Organic Chemicals Petroleum Refining Iron and Steel Dry Cleaning Metal Mining Non-metallic Mineral Mining Lumber and Wood Furniture Rubber and Plastic Stone, Clay, and Glass Nonferrous Metals Fabricated Metal Electronics Automobiles 

September 1995 98 SIC 281
Sector Notebook Project Inorganic Chemicals 

VII.C. Review of Major Legal Actions 

Major Cases/Supplemental Environmental Projects 

This section provides summary information about major cases that have 

affected this sector, and a list of Supplementary Environmental Projects 

(SEPs). SEPs are compliance agreements that reduce a facility's stipulated 

penalty in return for an environmental project that exceeds the value of the 

reduction. Often, these projects fund pollution prevention activities that can 

significantly reduce the future pollutant loadings of a facility. 

VII.C.1. Review of Major Cases 

Historically, OECA’s Enforcement Capacity and Outreach Office does not 

regularly compile information related to major cases and pending litigation 

within an industry sector. The staff are willing to pass along such information 

to Agency staff as requests are made. In addition, summaries of completed 

enforcement actions are published each fiscal year in the Enforcement 

Accomplishments Report. To date, these summaries are not organized by 

industry sector. (Contact: Office of Enforcement Capacity and Outreach 202-

260-4140) 

VII.C.2. Supplementary Environmental Projects 

Supplemental environmental projects (SEPs) are an enforcement option that 

requires the non-compliant facility to complete specific projects. Regional 

summaries of SEPs undertaken in the 1993 and 1994 federal fiscal years were 

reviewed. Five SEPs were undertaken that involved inorganic chemical 

manufacturing facilities, as shown in Exhibit 25. 

CERCLA violations engendered three out of the five SEPs identified; the 

fourth and fifth were due to a CAA violation and a TSCA violation. Due to 

regional reporting methods, the specifics of the original violations are not 

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 both 

inorganic and organic chemicals. This project has been included in both 

industry sector project summaries. The FY 1993 and 1994 SEPs for inorganic 

chemical manufacturers fall into four categories: process related projects; 

control and recovery technology inprovement or installation; leak prevention; 

and donations to the community. 

September 1995 99 SIC 281 
Sector Notebook Project Inorganic Chemicals 

•Process related projects 

A Region IV project carried out in 1993 entailed specific process 

changes intended to reduce chlorinated wastes at the facility. In 

conjunction with other non-process components of the project, the 

implementation cost was $93,000. 

•Control and recovery technology improvement/installation 

A Louisiana facility, the combined organic and inorganic chemical 

manufacturer, implemented a SEP to reduce emissions from returned 

gas canisters. The SEP involved the installation of recovery 

technologies to reduce emissions of residual CFC and HCFC from the 

used canisters. The cost to the company was $158,400. 

•Leak prevention 

A Region IV facility constructed retaining walls around underground 

storage tanks to prevent hazardous leachate from reaching 

groundwater. The cost to the company was $46,200. 

•Donations to Community 

Following a CERCLA violation, a facility in Texas donated emergency 

and computer equipment to the Local Emergency Planning 

Commission (LEPC) which could be used in the planning and 

responding to potential chemical emergencies. The facility also agreed 

to participate in LEPC activities and to provide technical assistance. 

September 1995 100 SIC 281 
--- --- ---

--- --- ------ --- --- ---

--- --- ---

--- --- ---

Sector Notebook Project Inorganic Chemicals Exhibit 25: FY-1993-1994 Supplemental Environmental Projects Overview: Inorganic Chemical Manufacture Supplemental Environmental Projects Description Company purchased, installed, and operated equipment for recovery of residual CFCs and HCFCs in used gas cylinders returned by customers Altered process to reduce chlorinated wastes, provided computer and Cameo training for county EMA, donated funds to LEPC for hazards analysis, and held response exercises at plant Constructed retaining walls around underground storage tanks to prevent hazardous material leachate from reaching groundwater Donated emergency and/or computer equipment to LEPC for response/planning for chemical emergencies, agreed to participate in LEPC activities and to provide technical assistance N/A Facilities identified as combined inorganic and organic chemical manufacturers * Violation Information Terms Initial penalty: Initial proposed cash penalty for violation Final penalty: Total penalty after SEP negotiation SEP credit: Cash credit given for SEP so that, Final penalty - SEP credit = Final cash penalty SEP cost to company: Actual cost to company of SEP implementation NOTE: 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 deduction for SEP credit Pollutant Reduction Pollutant Reduction Pollutant of Concern CFC/HCFC chlorinated waste Violation Information SEP Cost to Company $158,400 $93,000 $46,200 $10,000 $198,000 SEP Credit N/A Final Penalty $25,000 $2,000 $10,000 $3,000 N/A Initial Penalty $88,360 $90,000 $40,000 $25,000 N/A Type CAA CERCLA 103/EPCRA 304 CERCLA, EPCRA CERCLA 103(a) TSCA General Information State/ Region 

* LA 

Reg. 4 Reg. 4 TX 

Anzon, Inc. Reg.III Company Name LaRoche Chemicals, Inc. Coastal Chemicals Scholle Corp. ALCOA 

Docket # 6-93-16 

FY 93 93 93 93 94 

September 1995 101 SIC 281
Sector Notebook Project Inorganic Chemicals 

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 

This section highlights the activities undertaken by this industry sector and 

public agencies to voluntarily improve the sector's environmental 

performance. These activities include those independently initiated by 

industrial trade associations. In this section, the notebook also contains a 

listing and description of national and regional trade associations. 

VIII.A. Sector-related Environmental Programs and Activities 

None identified. 

VIII.B. EPA Voluntary Programs 

33/50 Program 

The "33/50 Program" is EPA's voluntary program to reduce toxic chemical 

releases and transfers of seventeen chemicals from manufacturing facilities. 

Participating companies pledge to reduce their toxic chemical releases and 

transfers by 33 percent as of 1992 and by 50 percent as of 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 those 

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 out operations in addition to inorganic chemicals 

manufacturing. The SIC codes reported by each company are listed in no 

particular order. In addition, the number of facilities within each company 

that are participating in the 33/50 program and that report SIC 281 to TRI is 

shown. Finally, each company’s total 1993 releases and transfers of 33/50 

chemicals and the percent reduction in these chemicals since 1988 are 

presented. 

The inorganic chemicals industry as a whole used, generated or processed 

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 in 

similar quantities. These three toxic chemicals account for about nine percent 

of TRI releases and transfers from inorganic chemical facilities. Seventy-five 

companies, representing 168 facilities, listed under SIC 281 (inorganic 

chemicals) are currently participating in the 33/50 program. This accounts for 

30 percent of the facilities reporting to SIC code 281 to TRI which is 

significantly higher than the average for all industries of 14 percent 

participation. (Contact: Mike Burns, 202-260-6394 or the 33/50 Program, 

202-260-6907) 

September 1995 102 SIC 281 
Sector 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 281
Sector 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 281
Sector Notebook Project Inorganic Chemicals 

Environmental Leadership Program 

The Environmental Leadership Program (ELP) is a national initiative piloted 

by EPA and state agencies in which facilities have volunteered to demonstrate 

innovative approaches to environmental management and compliance. EPA 

has selected 12 pilot projects at industrial facilities and federal installations 

which will demonstrate the principles of the ELP program. These principles 

include: environmental management systems, multimedia compliance 

assurance, third-party verification of compliance, public measures of 

accountability, community involvement, and mentoring programs. In return 

for participating, pilot participants receive public recognition and are given a 

period of time to correct violations discovered during these experimental 

projects. Forty proposals were received from companies, trade associations, 

and federal facilities representing many manufacturing and service sectors. 

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

of Edison, NJ), one pharmaceutical manufacturer (Schering Plough of 

Kenilworth, NJ), and one manufacturer of agricultural chemicals (Gowan 

Milling of Yuma, AZ) submitted proposals. (Contact: Tai-ming Chang, ELP 

Director, 202-564-5081 or Robert Fentress 202-564-7023) 

Project XL 

Project XL was initiated in March 1995 as a part of President Clinton’s 

Reinventing Environmental Regulation initiative. The projects seek to 

achieve cost effective environmental benefits by allowing participants to 

replace or modify existing regulatory requirements on the condition that they 

produce greater environmental benefits. EPA and program participants will 

negotiate and sign a final Project Agreement, detailing specific objectives that 

the regulated entity shall satisfy. In exchange, EPA will allow the participant 

a certain degree of regulatory flexibility and may seek changes in underlying 

regulations or statutes. Participants are encouraged to seek stakeholder 

support from local governments, businesses, and environmental groups. EPA 

hopes to implement fifty pilot projects in four categories including facilities, 

sectors, communities, and government agencies regulated by EPA. 

Applications will be accepted on a rolling basis and projects will move to 

implementation within six months of their selection. For additional 

information regarding XL Projects, including application procedures and 

criteria, see the May 23, 1995 Federal Register Notice. (Contact: Jon Kessler, 

Office of Policy Analysis, 202-260-4034) 

Green Lights Program 

EPA’s Green Lights program was initiated in 1991 and has the goal of 

preventing pollution by encouraging U.S. institutions to use energy-efficient 

lighting technologies. The program has over 1,500 participants which include 

major corporations; small and medium sized businesses; federal, state and 

September 1995 105 SIC 281 
Sector Notebook Project Inorganic Chemicals 

local governments; non-profit groups; schools; universities; and health care 

facilities. Each participant is required to survey their facilities and upgrade 

lighting wherever it is profitable. EPA provides technical assistance to the 

participants through a decision support software package, workshops and 

manuals, and a financing registry. EPA’s Office of Air and Radiation is 

responsible for operating 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 the 

manufacturing and purchase of recycled products. As of 1994, the program 

had about 300 companies as members, including a number of major 

corporations. Members agree to identify and implement actions to reduce 

their solid wastes and must provide EPA with their waste reduction goals 

along with yearly progress reports. EPA, in turn, provides technical 

assistance to member companies and allows the use of the WasteWi$e logo 

for promotional purposes. (Contact: Lynda Wynn 202-260-0700 or the 

WasteWi$e Hotline, 800-372-9473) 

Climate Wise Recognition Program 

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

commitment to reduce greenhouse gas emissions in accordance with the 

Climate Change Convention of the 1990 Earth Summit. As part of the 

Climate Change Action Plan, the Climate Wise Recognition Program is a 

partnership initiative run jointly by EPA and the Department of Energy. The 

program is designed to reduce greenhouse gas emissions by encouraging 

reductions across all sectors of the economy, encouraging participation in the 

full range of Climate Change Action Plan initiatives, and fostering innovation. 

Participants in the program are required to identify and commit to actions that 

reduce greenhouse gas emissions. The program, in turn, gives organizations 

early recognition for their reduction commitments; provides technical 

assistance through consulting services, workshops, and guides; and provides 

access to the program’s centralized information system. At EPA, the program 

is operated by the Air and Energy Policy Division within the Office of Policy 

Planning and Evaluation. (Contact: Pamela Herman 202-260-4407) 

September 1995 106 SIC 281 
Sector Notebook Project Inorganic Chemicals 

NICE3 

The U.S. Department of Energy and EPA’s Office of Pollution Prevention are 

jointly administering a grant program called The National Industrial 

Competitiveness through Energy, Environment, and Economics (NICE3). By 

providing grants of up to 50 percent of the total project cost, the program 

encourages industry to reduce industrial waste at its source and become more 

energy-efficient and cost-competitive through waste minimization efforts. 

Grants are used by industry to design, test, demonstrate, and assess the 

feasibility of new processes and/or equipment with the potential to reduce 

pollution and increase energy efficiency. The program is open to all 

industries; however, priority is given to proposals from participants in the pulp 

and paper, chemicals, primary metals, and petroleum and coal products 

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 Global 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 

management and sustainable development to improve the environmental 

performance of business through example and leadership. In 1994, GEMI’s 

membership consisted of about 30 major corporations including Amoco 

Corporation. 

National Pollution Prevention Roundtable 

The National Pollution Prevention Roundtable published The Pollution 

Prevention Yellow Pages in September 1994. It is a compilation of 

information collected from mail and telephone surveys of state and local 

government pollution prevention programs. (Contact: Natalie Roy 202-543-

7272) The following state programs listed themselves as having expertise in 

pollution prevention related 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 281 
Sector 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 281
Sector Notebook Project Inorganic Chemicals 

Center for Waste Reduction Technologies, under the aegis of the American 

Institute of Chemical Engineers, sponsors research on innovative technologies 

to reduce waste in the chemical processing industries. The primary 

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 Prevention 

and Toxics signed an agreement in January of 1994 to coordinate the two 

agencies' programs of basic research related to pollution prevention. The 

collaboration will stress research in the use of less toxic chemical and 

synthetic feedstocks, use of photochemical processes instead of traditional 

ones that employ toxic reagents, use of recyclable catalysts to reduce metal 

contamination, and use of natural feedstocks when synthesizing chemicals in 

large quantities. 

Chemical Manufacturers Association 

The Chemical Manufacturers Association funds research on issues of 

interest to their members particularly in support of their positions on proposed 

or possible legislation. They recently funded a study to characterize the 

environmental fate of organochlorine compounds. 

Responsible Care Program 

The Responsible Care Program of the Chemical Manufacturers Association 

requires members to pledge commitment to six codes that identify 106 

management practices that companies must carry out in the areas of 

community awareness and emergency response, pollution prevention, process 

safety, distribution, employee health and safety, and product stewardship. 

ISO 9000 

ISO 9000 is a series of international total quality management guidelines. 

After a successful independent audit of their management plans, firms are 

qualified to be ISO 9000 registered. In June of 1993, the International 

Standards Organization created a technical committee to begin work on new 

standards for environmental management systems. The new standards are 

called ISO 14000 and are expected to be issued in 1996. 

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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.

The ACS produces approximately thirty different industry periodicals and

research journals, including Environmental Science and Technology and

Chemical Research in Toxicology. In addition to publishing, the ACS

presently conducts studies and surveys; legislation monitoring, analysis, and

reporting; and operates a variety of educational programs. The ACS library

and on-line information services are extensive. Some available on-line

services are Chemical Journals Online, containing the full text of 18 ACS

journals, 10 Royal Society of Chemistry journals, and five polymer journals,

and the Chemical Abstracts Service (CAS), which provides a variety of

information on chemical compounds. 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

Presently, the principle focus of the Chemical Manufacturers Association

(CMA) 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. Research is still ongoing

at the CMA, however, as the CHEMSTAR program illustrates. 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;

CHEMSTAR study results are provided to both CMA membership and

regulatory agencies. Other initiatives include the "responsible care" program.

Membership in the CMA is contingent upon enrollment in the "responsible

care" program, which includes six codes of management practice (including

pollution prevention) that attempt to "go beyond simple regulatory

compliance.” The CMA also conducts workshops and technical symposia,

promotes in-plant safety, operates a chemical emergency center

(CHEMTREC) which offers guidance in chemical emergency situations, and

operates the Chemical Referral Center which provides chemical health and

safety information to the public. Publications include: ChemEcology, a 10-

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issue-per-year newsletter covering environmental, pollution-control, workersafety, 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 established in 1924 and represents companies

in the U.S., Canada, and other countries that produce, distribute, and use

chlorine, sodium and potassium hydroxides, and sodium hypochlorite; 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 Chlorine Chemistry Council (CCC), established in 1993, is a business

council of the Chemical Manufacturers Association (CMA) and is made up of

producers and users of chlorine and chlorine-related products. With

involvement from all stakeholders, the CCC works to promote science-based

public policy regarding chlorine chemistry and is committed to develop and

produce only those chemicals that can be manufactured, transported, used,

and disposed of safely. CCC facilitates risk-benefit analyses and product

stewardship through the collection, development, and use of scientific data on

health, safety, and environmental issues. CCC hopes to heighten public

awareness of chlorine chemistry and its many societal benefits by collaborating

with the public health and scientific community in assessing and

communicating chlorine-related human health and environmental issues.

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IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 

For further information on selected topics within the inorganic chemicals 

industry a list of contacts and publications are provided below: 

Contactsf 

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 Census of Manufacturers, Industry Series, Industrial Inorganic Chemicals, Bureau of the 

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 of the Census [Data will be superseded by a more comprehensive report in September of 

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 281 
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Chlorine and Its Derivatives: A World Survey of Supply, Demand, and Trade to 1992, Tecnon 

Consulting Group, London, 1988. 

North American Chlor-Alkali Industry Plants and Production Data Book, Pamphlet 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, volume 1, John Wiley and Sons, 

New York, 1994. 

Buchner, Schliebs, Winter, Buchel. Industrial Inorganic Chemistry, VCH Publishers, New York, 

1989. 

Multi-media Assessment of the Inorganic Chemicals Industry, Chapter 12-Salt Derivatives, Prepared 

for U.S. EPA Industrial Environmental Research Laboratory by Verser, Inc., Springfield, Virginia, 

1980. 

Recommendations To Chlor-alkali Manufacturing Facilities for the Prevention of Chlorine 

Releases, The Chlorine Institute, First Edition, October, 1990. 

Assessment of Solid Waste Management Problems and Practices in the Inorganic Chemicals 

Industry, Final Report, Versar, Inc. for U.S. Environmental Protection Agency, Industrial 

Environmental Research Laboratory, Cincinnati, Ohio, April 1979. 

Chlorine, Its Manufacture, Properties, and Uses, J.S. Sconce, Reinhold Publishing Corp., New York, 

1962. 

Electrolytic Manufacture of Chemicals from Salt, D.W.F. Hardie and W.W. Smith, The Chlorine 

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 Institute, West Publishing Co., St. Paul, Minn., 

1993. 

Development Document for Effluent Limitations Guidelines and New Source Performance Standards 

for the Major Inorganic Products Segment of the Inorganic Chemicals Point Source Category, U.S. 

Environmental Protection Agency, Washington, D.C., March 1974. Report No. EPA-440/1-74-007a. 

September 1995 113 SIC 281 
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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 281 
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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 281 
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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 281 
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GPO Order Form 

September 1995 117 SIC 281
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September 1995 118 SIC 281
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September 1995 119 SIC 281