Agricultural Chemical Industry Sector Notebook Project



### EPA Office of Compliance Sector Notebook Project



## Profile of the Agricultural Chemical, Pesticide, and Fertilizer

Industry

September 2000

Office of Compliance

Office of Enforcement and Compliance Assurance

United States Environmental Protection Agency

1200 Pennsylvania Avenue, NW (MC 2221-A)

Washington, DC 20460Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 i This report is one in a series of volumes published by the United States 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), Science Applications International Corporation (McLean, VA), and Booz-Allen

& Hamilton, Inc. (McLean, VA). A listing of available Sector Notebooks is included on the following

page.

Obtaining copies:

Electronic versions of all sector notebooks are available via Internet on the Enviro$en$e World Wide

Web at www.epa.gov/oeca/sector . Enviro$en$e is a free, public, environmental exchange system

operated by EPA's Office of Enforcement and Compliance Assurance and Office of Research and

Development. The Network allows regulators, the regulated community, technical experts, and the

general public to share information regarding: pollution prevention and innovative techn ologies;

environmental enforcement and com pliance assistance; laws, executive orders, regulations, and

policies; points of contact for services and equip ment; and other related topics. The Network

welcomes receipt of environmental messages, information, and data from any public or private person

or organization. Direct technical questions to the “Feedback” button on the bottom of the web page.

Purchase printed bound copies from the Government Printing Office (GPO) by consulting the order

form at the back of this document or order via the Internet by visiting the on-line GPO Sales Product

Catalog at https://orders.access.gpo.gov/su_docs/sale/prf/prf.html

. Search using the exact title of

the document “Profile of the XXXX Industry” or simply “Sector Notebook.” When ordering, use the

GPO document number found in the order form at the back of this document.

Complimentary volumes are available to certain groups or subscribers, including public and

academic libraries; federal, state, tribal, and local governments; and the media from EPA’s National

Service Center for Environmental Publications at (800) 490-9198. When ordering, use the EPA

publication number found on the following page.

The Sector Notebooks were developed by the EPA’s Office of Compliance. Direct general questions

about the Sector Notebook Project to:

Seth Heminway, Coordinator, Sector Notebook Project

US EPA Office of Compliance

1200 Pennsylvania Avenue, NW (2223-A)

Washington, DC 20460

(202) 564-7017

For further information, and for answers to questions pertaining to these documents, please refer to

the contact names listed on the following page.Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 ii 

## S ECTOR 

## N OTEBOOK 

## C ONTACTS

Questions and comments regarding the individual documents should be directed to the specialists listed

below. See the Notebook web page at: www.epa.gov/oeca/sector for the most recent titles and staff

contacts.

EPA Publication

Number Industry Contact Phone (202)

EPA/310-R-95-001. Profile of the Dry Cleaning Industry Joyce Chandler 564-7073

EPA/310-R-95-002. Profile of the Electronics and Computer Industry* Steve Hoover 564-7007

EPA/310-R-95-003. Profile of the Wood Furniture and Fixtures Industry Bob Marshall 564-7021

EPA/310-R-95-004. Profile of the Inorganic Chemical Industry* Walter DeRieux 564-7067

EPA/310-R-95-005. Profile of the Iron and Steel Industry Maria Malave 564-7027

EPA/310-R-95-006. Profile of the Lumber and Wood Products IndustrySeth Heminway564-7017

EPA/310-R-95-007. Profile of the Fabricated Metal Products Industry*Scott Throwe564-7013

EPA/310-R-95-008. Profile of the Metal Mining Industry Maria Malave 564-5027

EPA/310-R-95-009. Profile of the Motor Vehicle Assembly Industry Anthony Raia 564-6045

EPA/310-R-95-010. Profile of the Nonferrous Metals Industry Debbie Thomas 564-5041

EPA/310-R-95-011. Profile of the Non-Fuel, Non-Metal Mining Industry Rob Lischinsky 564-2628

EPA/310-R-95-012. Profile of the Organic Chemical Industry * Walter DeRieux 564-7067

EPA/310-R-95-013. Profile of the Petroleum Refining Industry Tom Ripp 564-7003

EPA/310-R-95-014. Profile of the Printing Industry Ginger Gotliffe 564-7072

EPA/310-R-95-015. Profile of the Pulp and Paper Industry Seth Heminway 564-7017

EPA/310-R-95-016. Profile of the Rubber and Plastic Industry 564-2310

EPA/310-R-95-017. Profile of the Stone, Clay, Glass, and Concrete Ind.Scott Throwe564-7013

EPA/310-R-95-018. Profile of the Transportation Equip. Cleaning Ind. Virginia Lathrop 564-7057

EPA/310-R-97-001. Profile of the Air Transportation Industry Virginia Lathrop 564-7057

EPA/310-R-97-002. Profile of the Ground Transportation Industry Virginia Lathrop 564-7057

EPA/310-R-97-003. Profile of the Water Transportation Industry Virginia Lathrop 564-7057

EPA/310-R-97-004. Profile of the Metal Casting Industry Steve Hoover 564-7007

EPA/310-R-97-005. Profile of the Pharmaceuticals Industry Emily Chow 564-7071

EPA/310-R-97-006. Profile of the Plastic Resin and Man-made Fiber Ind. Sally Sasnett 564-7074

EPA/310-R-97-007. Profile of the Fossil Fuel Electric Power Generation Rafael Sanchez 564-7028

Industry

EPA/310-R-97-008. Profile of the Shipbuilding and Repair Industry Anthony Raia 564-6045

EPA/310-R-97-009. Profile of the Textile Industry 564-2310

EPA/310-R-98-001. Profile of the Aerospace Industry Anthony Raia 564-6045

EPA/310-R-97-010. Sector Notebook Data Refresh-1997 ** Seth Heminway 564-7017

EPA/310-R-99-006. Profile of the Oil and Gas Extraction Industry Dan Chadwick 564-7054

EPA/310-R-00-003. Profile of the Agricultural Chemical, Pesticide, and Michelle Yaras 564-4153

Fertilizer Industry

EPA/310-R-00-001 Profile of the Agricultural Crop Production Industry Ginah Mortensen 913-551-5211

EPA/310-R-00-002 Profile of the Agricultural Livestock Production Ginah Mortensen 913-551-5211

Industry

Government Series

EPA/310-R-99-001. Profile of Local Government Operations 564-2310

* Spanish translations available.

** This document revises compliance, enforcement, and toxic release inventory data for all profiles published in

1995.Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 iii 

### TABLE OF CONTENTS

LIST OF FIGURES

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

LIST OF TABLES

............................................................ vi

LIST OF ACRONYMS

........................................................ viii

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

........................ 1

I.A. Summary of the Sector Notebook Project

.................................. 1

I.B. Additional Information

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

II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY

................ 3

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

....................... 3

II.B. Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry

... 4

II.B.1. Product Characterization

...................................... 5

II.B.2. Industry Size and Geographic Distribution

........................ 19

II.B.3. Economic Trends

........................................... 24

III. INDUSTRIAL PROCESS DESCRIPTION

...................................... 27

III.A. Nitrogenous Fertilizers

.............................................. 27

III.A.1. Synthetic Ammonia

......................................... 27

III.A.2. Nitric Acid

............................................... 32

III.A.3. Ammonium Nitrate and Urea

.................................. 36

III.B. Phosphatic Fertilizers

............................................... 40

III.B.1. Phosphoric Acid (Wet Process)

............................... 40

III.B.2. Ammonium Phosphate

....................................... 43

III.B.3. Normal Superphosphate

..................................... 44

III.B.4. Triple Superphosphate

...................................... 47

III.C. Fertilizer Mixing

................................................... 49

III.D. Pesticide Formulating Processes

....................................... 51

III.D.1. Liquid Formulating and Packaging

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

III.D.2. Dry Formulating and Packaging

................................ 54

III.D.3. Aerosol Packaging

......................................... 56

III.D.4. Pressurized Gas Formulating and Packaging

...................... 57

III.D.5. Repackaging

.............................................. 57

III.E. Raw Material Inputs and Pollution Outputs

.............................. 59

III.E.1. Fertilizers

................................................ 59

III.E.2. Pesticide Formulating, Packaging, and Repackaging

................ 68

III.F. Management of Chemicals in Wastestream

............................... 74

IV. CHEMICAL RELEASE AND TRANSFER PROFILE

............................. 78

IV.A. EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural

Chemical Industry

................................................. 81

IV.B. Summary of Selected Chemicals Released

............................... 95

IV.C. Other Data Sources

................................................ 99

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

........ 101Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 iv V. POLLUTION PREVENTION OPPORTUNITIES

................................. 104

V.A. Equipment Cleaning

............................................... 108

V.B. Process Changes

.................................................. 112

V.C. Good Housekeeping

............................................... 114

VI. Summary of Applicable Federal Statutes and Regulations

......................... 120

VI.A. General Description of Major Statutes

................................. 120

Imports and Exports

.............................................. 122

VI.B. Industry Specific Requirements

...................................... 138

VI.C. State Regulation of Pesticides

........................................ 150

VI.D. Pending and Proposed Regulatory Requirements

......................... 152

VII. COMPLIANCE AND ENFORCEMENT HISTORY

............................. 155

VII.A. Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History

.............................................................. 159

VII.B. Comparison of Enforcement Activity Between Selected Industries

.......... 161

VII.C. Review of Major Legal Actions

..................................... 166

VII.C.1. Review of Major Cases

.................................... 166

VII.C.2. Supplementary Environmental Projects (SEPs)

.................. 170

VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

.................. 171

VIII.A. Sector-Related Environmental Programs and Activities

.................. 171

VIII.B. EPA Voluntary Programs

.......................................... 173

VIII.C. Trade Association/Industry Sponsored Activity

........................ 178

VIII.C.1. State Advisory Groups

.................................... 178

VIII.C.2. Trade Associations

....................................... 180

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS

................. 187Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 v 

### LIST OF FIGURES

Figure 1: Number of Facilities and Value of Shipments of the Fertilizer, Pesticide, and

Agricultural Chemical Manufacturing Industry

.............................. 6

Figure 2: Product Distribution for SIC 2873, Nitrogenous Fertilizers

.................... 9

Figure 3: Product Distribution for SIC 2874, Phosphorous Fertilizers

.................. 11

Figure 4: Product Distribution for SIC 2879, Pesticides and Miscellaneous Agricultural

Chemicals

......................................................... 16

Figure 5: Geographic Distribution of the Fertilizer Industry (SIC 2873, 2874, 2875)

....... 20

Figure 6: Geographic Distribution of the Pesticide Formulating and Miscellaneous

Agrichemical Formulating Facilities (SIC 2879)

........................... 22

Figure 7: Typical Process of Ammonia Synthesis

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

Figure 8: Typical Process of Dual-Stage, Weak Nitric Acid Production

................. 35

Figure 9: Typical Process Diagram of High Strength Nitric Acid Production

............. 36

Figure 10: Typical Process for Ammonium Nitrate and Urea Manufacturing

............... 39

Figure 11: Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant

............ 42

Figure 12: Typical Vacuum Evaporator Process

.................................... 42

Figure 13: Simplified Process Flow Diagram of Diammnonium Phosphate Production

....... 44

Figure 14: Typical Process for Normal Superphosphate Manufacturing

.................. 46

Figure 15: Typical Process for Triple Superphosphate

............................... 48

Figure 16: Typical Process for Liquid Formulating

.................................. 54

Figure 17: Typical Process for Dry Formulating

.................................... 56

Figure 18: Raw Material Flowchart for Principal Fertilizer Materials

................... 59

Figure 19: Summary of 1995 TRI Releases and Transfers by Industry

................... 102Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 vi 

### LIST OF TABLES

Table 1: Nitrogenous Fertilizer Products (SIC 2873)

................................ 7

Table 2: Phosphatic Fertilizer Products (SIC 2874)

................................. 9

Table 3: 1990 Direct vs Mixed Application of Primary Fertilizer Nutrients

.............. 12

Table 4: SIC 2879 Pesticides and Miscellaneous Agricultural Chemicals, List of Products

. 13

Table 5: Establishment Counts Based on Product Type

.............................. 18

Table 6: Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical

Manufacturing Industry

............................................... 19

Table 7: States with the Largest Number of Fertilizer Manufacturing Facilities

........... 21

Table 8: Top United States Agricultural Chemical Companies

........................ 23

Table 9: Fertilizer Materials Used in Bulk Blends

................................. 49

Table 10: Approximate Quantities of Most Commonly Used Conventional Pesticides in United

States Agricultural Crop Production

..................................... 70

Table 11: Summary of Potential Pollution Outputs for the Agricultural Chemical Industry

.... 73

Table 12: Source Reduction and Recycling Activity for the Fertilizer Industry as Reported

within TRI

......................................................... 75

Table 13: Source Reduction and Recycling Activity for the Pesticide and Miscellaneous

Agricultural Chemicals Industry

........................................ 76

Table 14: 1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)

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

.......... 84

Table 15: 1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)

by Number and Facilities Reporting (Transfers reported in pounds/year)

........ 85

Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of

Facilities Reporting (Releases reported in pounds/year)

..................... 86

Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)

by Number and Facilities Reporting (Transfers reported in pounds/year)

........ 89

Table 18: Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities

(SIC 2873, 2874, 2875)

.............................................. 93

Table 19: Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and Mixing SIC

Codes

............................................................ 93

Table 20: Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals Facilities

(SIC 2879)

........................................................ 94

Table 21: Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous Agricultural

Chemicals SIC Codes

................................................ 94

Table 22: Air Pollutant Releases by Industry Sector (tons/year)

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

Table 23: 1995 Toxics Release Inventory Data for Selected Industries

................. 102

Table 24: Waste Minimization Methods for the Fertilizer, Pesticide, and Agricultural Chemical

Industry

.......................................................... 107

Table 25: Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and

Agricultural Chemical Industry

........................................ 160

Table 26: Five-Year Enforcement and Compliance Summary for Selected Industries

...... 162

Table 27: One-Year Enforcement and Compliance Summary for Selected Industries

....... 163

Table 28: Five-Year Inspection and Enforcement Summary by Statute for Selected

Industries

......................................................... 164

Table 29: One-Year Inspection and Enforcement Summary by Statute for Selected

Industries

......................................................... 165Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 vii Table 30: Fertilizer, Pesticide, and Agricultural Chemical Industry Participation in the

33/50 Program

..................................................... 175Agricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 viii 

### LIST OF ACRONYMS

AAEA American Agricultural Economics Association

AAPCO Association of American Pesticide Control Officials

AAPFCO Association of American Plant Food Control Officials

ACPA American Crop Protection Association

AFS AIRS Facility Subsystem (CAA database)

AI Active Ingredient

AIRS Aerometric Information Retrieval System (CAA database)

ASA American Society of Agronomy

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

CFA California Fertilizer Association

CFCs Chlorofluorocarbons

CMA Chemical Manufacturers Association

CO Carbon Monoxide

COD Chemical Oxygen Demand

CSI Common Sense Initiative

CSMA Chemical Specialties Manufacturers Association

CWA Clean Water Act

DAP Diammonium Phosphate

DOT Department of Transportation

D&B Dun and Bradstreet Marketing Index

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act

FFDCA Federal Food, Drug, and Cosmetic Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FINDS Facility Indexing System

FIRT Fertilizer Industry Round Table

FQPA Food Quality Protection Act

HAPs Hazardous Air Pollutants (CAA)

HSDB Hazardous Substances Data Bank

IDEA Integrated Data for Enforcement Analysis

IFDC International Fertilizer Development Center

LDR Land Disposal Restrictions (RCRA)

LEPCs Local Emergency Planning Committees

MACT Maximum Achievable Control Technology (CAA)

MAP Monoammonium Phosphate

MCLGs Maximum Contaminant Level Goals

MCLs Maximum Contaminant Levels

MEA Monoethanolamine

MEK Methyl Ethyl Ketone

MSDSs Material Safety Data SheetsAgricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 ix NACD National Association of Chemical Distributors

NASDA National Association of State Departments of Agriculture

NASHA North American Horticultural Supply Association

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

NCP National Oil and Hazardous Substances Pollution Contingency Plan

NEC Not Elsewhere Classified

NEIC National Enforcement Investigation Center

NESHAP National Emission Standards for Hazardous Air Pollutants

NO

2 Nitrogen Dioxide

NOV Notice of Violation

NO

X Nitrogen Oxide

NPCA National Pest Control Association

NPDES National Pollution Discharge Elimination System (CWA)

NPK Nitrogen-Phosphorous-Potassium

NPL National Priorities List

NRC National Response Center

NRDC National Resources Defense Council

NSP Normal Superphosphate

NSPS New Source Performance Standards (CAA)

OECA Office of Enforcement and Compliance Assurance

OMB Office of Management and Budget

OPA Oil Pollution Act

OPPTS Office of Prevention, Pesticides, and Toxic Substances

OSHA Occupational Safety and Health Administration

OSW Office of Solid Waste

OSWER Office of Solid Waste and Emergency Response

OW Office of Water

P2 Pollution Prevention

PCS Permit Compliance System (CWA Database)

PRP Potentially Responsible Party

POTW Publicly Owned Treatments Works

PPI Potash and Phosphate Institute

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

SFIREG State FIFRA Issues Research and Evaluation Group

SIC Standard Industrial Classification

SO

2 Sulfur Dioxide

SO

X Sulfur Oxides

TOC Total Organic Carbon

TFI The Fertilizer Institute

TRI Toxic Release Inventory

TRIS Toxic Release Inventory System

TCRIS Toxic Chemical Release Inventory SystemAgricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 x TSCA Toxic Substances Control Act

TSP Triple Superphosphate

TSS Total Suspended Solids

TVA Tennessee Valley Authority

UIC Underground Injection Control (SDWA)

UPFDA United Products Formulators and Distributors Association

USDA United States Department of Agriculture

UST Underground Storage Tanks (RCRA)

VOCs Volatile Organic Compounds

WCPA Western Crop Protection AssociationAgricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 1 I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

I.A. Summary of the Sector Notebook Project

Integrated environmental policies based upon comprehensive analysis of air,

water and land pollution are a logical supplement to traditional single-media

approaches to environmental protection. Environmental regulatory agencies

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

permitting, enfor cement and compliance assurance, education/outreach,

research, and regulatory development issues. The central concepts driving

the new policy dir ection 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 inter-relati onships by

designing policies for the “whole ” facility. One way to achieve a whole

facility focus is to design environmental poli cies for similar industrial

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

manufacturing of similar products can be addressed in a compreh ensive

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

appr oach within the EPA Office of Compliance led to the creation of this

document.

The Sector Notebook Project was originally initiated by the O ffice of

Compliance within the Office of Enforcement and Compliance Assurance

(OECA) to provide its staff and managers with summary information for

eighteen spe c ific industrial sectors. As other EPA offices, states, the

regulated community, environmental groups, and the pub l ic became interested

in this project, the scope of the original project was expanded to its current

form. 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 proces ses; pollution outputs; pollution

prevention opport

u nities; 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 issu e, 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 activi ties that can be further explored based upon the

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

information included, each notebook went thro ugh an external review process.

The Office of Compliance appreciates the efforts of all those that participatedAgricultural Chemical Industry Sector Notebook Project

Sector Notebook Project September 2000 2 in this process who enabled us to develop more complete, accurate and up-todate summaries. Many of those who reviewed this notebook are listed as

contacts in Section IX and may be sources of additional info rmation. The

individuals and groups on this list do not necessarily concur with all

statements within this notebook.

I.B. Additional Information

Providing Comments

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

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

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

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

comput er disk to the EPA Office of Compliance, Sector Notebook Project

(2223- A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460.

Comments can also be uploaded to the Enviro$en$e World Wide Web for

general access to all users of the system. Follow instructions in Appendix A

for accessing this system. 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 industry sector described in this notebook approximates the

national occurrence of facility types within the sector. In many instances,

industries within specific geographi c regions or states may have unique

characteristics that are not fully captured in these profiles. The Office of

Compliance encourages stat e and local environmental agencies and other

groups to supplement or repackage the information included in this notebook

to include m

ore 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 wa nt 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

202-564-2310.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 3 II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY

This section provides background informat ion on the size, geographic

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

fertilizer, pesticide, and agricultural chemical industry. Facilities described

within this document are described in terms of their Standard In dustrial

Classification (SIC) codes whenever possible.

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

The scope of this Sector Notebook covers the manufacturing and production

of ferti lizers, the formulation of pesticide chemicals (both agricultural and

non-agricultural) manufactured at separa te facilities, and the production of

other miscellaneous agricultural chemicals. It does not include the use, sale,

distribution, or storage of such chemicals.

The Fertilizer, Pesticide, and Agricultural Chemical Industry is classified by

the Office of Management and Budget (OMB) under Standard Industrial

Classification (SIC) Industry Group Number 287. This class ification

corresponds to SIC codes which were established by the OMB to track the

flow of goods and services within the economy. Industry Group Number 287

includes SIC codes:

2873-- Nitrogenous Fertilizers

2874-- Phosphatic Fertilizers

2875-- Fertilizers, Mixing Only

2879-- Pesticides and Agricultural Chemicals, Not Elsewhere

Classified (n.e.c)

This notebook covers both fertilizer manufacturing and formulating operations

including ammonia synthesis, nitric and phosphoric acid production, and the

mixing, preparing, and packaging of nitrogenous and phosphatic fertilizers.

Establishments engaged in manufacturing fertilizer materials or mixing

fertilizers produced at the same establishment are classified under SIC codes

2873 and 2874. Mixing of fertilizer materials, such as compost, potting soil,

and fertiliz ers made in plants not manufacturing fertilizer materials, is

classified under SIC code 2875. This notebook does not include the mining

or grinding of phosphate rock, which is classified under SIC code 1475, and

it also does not include the use or application of fertilizers.

SIC code 2879, pesticides and agricultural chemicals not elsewhere classified

(n.e.c.), hereafter ref

erred to as pesticides and miscellaneous agricultural

chemicals, covers only the formulating, preparing, and packaging of ready-touse agricultural and household pest control chemicals. This industry code also

includes establishments primarily engaged in the manufacturing or formulating

of agricultural chemicals, not elsewhere classified, such as minor or trace

elements and soil conditio ners. This notebook does not discuss the use orAgricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 4 application of pesticide products. Establishments primarily engaged in the

manufac turing of basic or technical agricultural pesticides are classified in

Industry Group 281 if the chemicals produced are inorganic or Industry Group

286 if the chemicals produced are organic. This notebook also does not cover

the agricultural supply sector, SIC 5191, which is engaged in the wholesale

and distribution of various agricult ural supplies including fertilizers and

pesticides. Also, there is little discussion of the potassium fertilizer industry

as potash is classified under SIC 2819, Inorganic Chemicals n.e.c.

Federal government agencies, including United States EPA, are beginning to

implement an industrial classification system developed by OMB to replace

the SIC code system. The new system, which is based on similar production

pr ocesses, is called the North American Industrial Classification System

(NAIC S). In the NAIC system, the manufacturing of nitrogenous fertilizers

(SIC 2873) is classified as NAIC 325311, phosphatic fertilizers (SIC 2874)

as NAIC 325312, and fertilizer m ixing only (SIC 2875) as NAIC 325314.

Pesticide form

ulating and agricultural chemicals n.e.c. (SIC 2879) is classified

under NAIC 32532. Because EPA databases, and other databases used in this

document, are still using the SIC system, the industry sectors described in this

Sector Notebook are described in terms of their SIC codes.

II.B. Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry

As the world population increases, crop lands are unable to meet the growing

demand for food without employing some method of crop enhancement. There

are five common practices used to meet the growing demand:



### C increasing tilled acreage



### C improving plant strains



### C introducing or expanding irrigation



### C controlling pest by chemical or biological methods



### C initiating or increasing fertilizer usage

Increased utilization of the last two methods has created a large agrichemical

industry which produces a wide variety of products designed to increase crop

production and protect crops from disease and pests (Kent, 1992). Together,

the production of fertilizers and the formulation of pesticides was a $18.8

billion industry in 1992, employing over 40,000 people (USDOC, 1995).

Plants require 18 elements to grow, the most important being oxygen, carbon,

hydroge n, nitrogen, phosphorous, and potassium. Oxygen, carbon, and

hydrogen are obtained from the atmosphere and water, while nitrogen,

phosphorous, and potassium are naturally obtained from soil. However, under

current high yield production methods, soils are stripped of the essential

nutrients, requiring the addition of fertilizers (primarily consisting of nitrogen,

phosphorous, and potassium) to resupply the land. The additional 12 essential

nutrients are generally maintained in soil at sufficient levels for plant growth,Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 5 but they may be added to some fertilizers (Kent, 1992).

Even before the addition of nutrients to f arm lands, farmers were forced to

protect their crops against pests w i th chemicals. References to pesticide usage

date back to 1000 B.C. Pests are continuously adapting to pesticide chemicals

requiring new pesticides and the usage of multiple chemic al agents. The

industry is rapidly changing due to biological adaptation of pests, laboratory

discoveries, and government regulation (Kent, 1992). The pesticide industry

is faced with the need for new formulations an d the abundance of possible

combinations, but restricted by cost fact ors and a sometimes lengthy

registration process.

Pesticides are applied on about three-quarters of United States f arms and

households. Farmers’ expenditures on pesticides were equal to 4.6 percent of

total farm production expenditures in 1995, up f rom 3.9 percent in 1993.

About one billion pounds of active ingredient of conventional pesticides are

used annually in the United States; this usage involves about 21,000 pesticide

products (including non-agricultur al products) and 875 active ingredients

registered under the Federal Pesticide Law, according to the 1994 and 1995

Market Estimates for Pesticides Industry Sales and Usage (Aspelin, 1997).

II.B.1. Product Characterization

This notebook covers all aspects of fertilizer product i on and pesticide

formulating and pack

aging. However, because the industrial processes,

pollutant outputs, economics, size, and geographic distributi on of the two

industries are different, they are dealt with separately throughout the notebook.

Figure 1 compares the number of manufacturing facilities and value of

shipments for each of the major sectors within the Fertilizer, Pesticide, and

Agricultural Chemical Indust ry, as reported by the United States Bureau of

Census . The figure shows that the fertilizer mixing industry has the largest

number of faci lities but the smallest value of shipments. This reflects that,

compared to other sub-sectors within the Fertilizer, Pesticide and Agricultural

Chemical Industry, these facilities produce a relatively small volume of

product and sell a relatively low value produc t. Phosphatic fertilizer

producers, on the other hand, comprise the smallest number of facilities but

have a relatively large share of the industry’s value of shipments, reflecting

that individual facilities produce a relatively large volume of product.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 6 Figure 1: Number of Facilities and Value of Shipments of the Fertilizer,

Pesticide, and Agricultural Chemical Manufacturing Industry

Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United

States Department of Commerce, Bureau of the Census, May 1995.

* United States EPA has identified over 8,000 establishments that could fall within this SIC

code as it is defined by the OMB. See discussion in text below.

The Census of Manufacturers reports 263 establishments that can be defined

as p roducing pesticides and miscellaneous agricultural chemicals. These

establishments reportedly account for almost half of the value of shipments for

the sector. There are over 8,000 establishments identified by the United States

EPA that manufacture, formulate and package pesticides and other agricultural

chemicals and that could fall within OMB’s SIC code definition for this sector.

Many of these are small establishments and establishments that have a primary

line of business other than producing pesticides and ot her miscellaneous

agricultural chemicals. The Census only counts those facilities which report

an SIC code as their primary line of business, thus the number of facilities

shown above is not inclusive of all facilities involved in agricultural chemical

product ion. Under the “Pesticides and Miscellaneous Agricultural Chemicals”

heading later in this section, other pesticide producing establishment counts

are presented based on EPA esti mates and reporting under section 7 of the

Federal Insecticide, Fungicide, and Rodenticide Act.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 7 Nitrogenous Fertilizers

The nitrogenous fertilizer industry includes the production of synthetic

ammonia, nitric aci d, ammonium nitrate, and urea. Synthetic ammonia and

nitric acid, however, are used primarily as intermediates in the production of

am monium nitrate and urea fertilizers. Table 1 lists specific products

classified as nitrogenous fertilizers by OMB.

Table 1: Nitrogenous Fertilizer Products

(SIC 2873)

Ammonia liquor

Ammonium nitrate

Ammonium sulfate

Anhydrous ammonia

Aqua ammonia

Fertilizers, mixed, produced in nitrogenous fertilizer plants

Fertilizers, natural

Nitric acid

Nitrogen fertilizer solutions

Plant foods, mixed in nitrogenous fertilizer plants

Urea

Source: Standard Industrial Classification Manual, Office

of Management and Budget, 1987.

Synthetic Ammonia

Synthetic ammonia refers to ammonia that has been synthesized from natural

gas. In this process, natural gas molecules are reduced to carbon and

hydrogen. The hydrogen is then purified and reacted with nitrogen to produce

ammonia. Approximately 75 percent of the synthetic ammonia produced in the

United States is used as fertilizer, either directly as ammonia or indirectly after

fertilizer synthesis into urea, ammonium nitrate, and monoam monium or

diammonium phosphates. One-third of the fertilizer nitrogen is applied

directly to the land as anhydrous ammonia. The remaining 25 percent of

ammonia p roduced in the United States is used as raw material in the

manufacture of polymeric resins, explosives, nitric acid, and other products

(USEPA, 1993a).

Nitric Acid

Nitri c acid is formed by concentration, absorption, and oxidation of anhydrous

amm onia. About 70 percent of the nitric acid produced is consumed as an

i ntermediate in the manufacture of ammonium nitrate (NH

4 NO

3 ), wh ich is

primarily u sed in fertilizers. Another 5 to 10 percent of the nitric acid

produced is used in

adipic acid manufacturing, an intermediate in nylon

production. Explosive manufacturing utilizes nitric acid for organic nitrations

to produce nitrobenzene, dinitrotoluenes, and other chemical intermediates.

Other end uses of nitric acid are gold and silver separation, military munitions,Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 8 steel and brass pickling, photoengraving, and acidulation of phosphate rock

(USEPA, 1993a).

Ammonium Nitrate

Ammonium nitrate is produced by neutralizing nit ric acid with ammonia.

Approximately 15 to 20 percent of ammonium nitrate is used for explosives

and the balance for fertilizer. Ammonium nitrate is marketed in several forms,

depending upon its use. Liquid ammonium nitrate may be sold as a fertilizer,

generally in combination with urea. Liquid ammonium nitrate may also be

concentrated to form an ammonium nitrate “melt” for use in solids formation

processes. Solid ammonium ni trate may be produced in the form of prills,

grains, granules or crystals. Prills, round or needle-shaped aggregates, can be

produced in either high or low density form, depending on the concentration

of the melt. High density prills, granules and crystals are used as fertilizer,

grains are used so lely in explosives, and low density prills can be used as

either fertilizer or explosives (USEPA, 1993a).

Urea

Urea, also known as carbamide or carbonyl diamide, is produced by reacting

ammonia with carbon dioxide. Eighty-five percent of urea solution produced

is used in fertilizer mixtures, with three percent goi ng to animal feed

supple ments and 12 percent is used for plastics and other uses. Urea is

marketed as a solution or in solid form. Most solids are produced as prills or

granules for use as fertilizer or protein supplement in animal feed, and in

plastics manufacturing (USEPA, 1993a).

Ammonium sulfate

It is not economically feasible to produce ammonium sulfate for use as a

fertilizer. However, ammonium sulfate is formed as a by-product of other

process such as acid scrubbing of coke oven gas, synthetic fiber production,

and the ammoniation of process sulfuric acid (Hoffmeister, 1993). Therefore,

the production of ammonium sulfate is not described in this notebook.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 9 Figure 2: Product Distribution for SIC 2873, Nitrogenous Fertilizers

Source: Fertilizer Institute data as reported in Chemical and Engineering News, June 23, 1998.

Figures are based on Fertilizer Institute surveys and may not represent the entire industry.

Phosphatic Fertilizers

The phosphatic fertilizer industry can be divided into three major segments:

phosphoric acid, granular ammonium phosp hate, and normal and triple

sup erphosphate. Table 2 lists these, and a few additional, less common

products classified as phosphatic fertilizers by OMB.

Table 2: Phosphatic Fertilizer Products

(SIC 2874)

Ammonium phosphates

Calcium meta-phosphates

Defluorinated phosphates

Diammonium phosphates

Fertilizers, mixed, produced in phosphatic fertilizer plants

Phosphoric acid

Plant foods, mixed in phosphatic fertilizer plants

Superphosphates, ammoniated and not ammoniated

Source: Standard Industrial Classification Manual, Office of

Management and Budget, 1987.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 10 Phosphoric Acid

Phosphoric acid (H

3 PO

4 ) can be manufactured using either a wet or a thermal

process to react phosphate rock with sulfuric acid. Approximately 96 percent

of the phosphoric acid produced in the United States is produced using the wet

p rocess. Wet process phosphoric acid has a phosphorous concent ration

typically ranging from 26-30% as phosphorous pentoxide (P

2 O

5 ) and is used

in the production of ammonium phosphates and triple superphosphates.

Thermal process phosphoric acid is commonly used in the manufacture of high

grade chemicals requiring a much higher purity.

Ammonium Phosphates

Ammonium phosphate (NH

4 H

2 PO

4 ) is produced by reacting phosphoric acid

with an hydrous ammonia. Both solid and liquid ammonium phosphatic

fertilizers are produced in the Uni ted States The most common ammonium

phosphatic fertilizer grades are monoammonium phospha t e (MAP) and

diammonium phosphate (DAP). DAP has become one of the most commonly

used fertilizers because it provi d es a large quantity of plant food, is

compatible with most mix fertilizer ingredients, and is nonexplosive. It may

be directly applied or used in irrigation systems as it is completely soluble in

water. DAP is also preferred over MAP because it is capable of fixing twice

as much ammonia per phosphorous pentoxide in solid form (Nielson, 1987.)

MAP contains a higher concentration of phosphorous pentoxide than DAP. It

is favored for use with alkaline soils and may be applied either directly or in

a dry blend.

Normal Superphosphates

Like phosphoric acid, normal, or “ordinary,” superphosphate fertilizers are

produced by reacting phosphate rock with sulfuric acid. However, normal

superphosp hate (NSP) retains calcium sulfate which forms by the reaction

between phosphate rock and sulfuric acid. For this reason NSP retains its

importance wherever sulphur deficiency limits crop yields (UNEP, 1996).

NSP refers to fertilizer material containing 15 to 21 percent phosphorous as

phosphorous pentoxide (P

2 O

5 ). As defined by the Census Burea u

, NSP

contains not more than 22 percent of available P

2 O

5 (USEPA, 1993a).

Production of NSP has given way to the higher-yielding triple superphosph a tes

and ammonium phosphates. In 1990, production of NSP accounted for only

one percent by weight of the phosphorous fertilizer industry. Because of its

low P

2 O

5 concentration, shipping can be prohibitively expensive due to the

large volumes required. NSP is favored in low cost Nitrogen-PhosphorousPotassium (NPK) mixes because it is a less expensive form of phosphorous,

however, it is unacceptable for higher-grade mixes (Kent, 1992).

Triple Superphosphates

Triple sup erphosphates (TSP) are produced by reacting ground phosphate rock

with phosphoric acid. Triple superphosphate is also known as double, treble,

or concen

trated superphosphate. The phosphorus content of triple

superphosphates is over 40 percent, measured as phosphorus p entoxide (P

2 O

5 ),Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 11 Figure 3: Product Distribution for SIC 2874, Phosphorous Fertilizers which is its main advantage over other phosphatic fertilizers (USEPA, 1993a).

TSP began to be produced in large quantities when wet process phosphoric

acid production became available commercially. It is commonly produced

along with phosphoric acid near phospha te rock supplies. TSP may be

applied directly or as a bulk blend (Kent, 1992).

Source: Chemical and Engineering News, June 23, 1998. Figures are based on

Fertilizer Institute surveys and may not represent the entire industry.

Fertilizers, Mixing Only

A significant part of the fertilizer industry only purchases fertilizer materials

in bulk from fertilizer manufacturing facilities and mixes them to sell as a

fertilizer formulation.

Phosphorous is the single nutrient most likely to be applied in a fertilizer

mixture, as seen in Table 3.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 12 Table 3: 1990 Direct vs Mixed Application of

Primary Fertilizer Nutrients

Method, % applied

Nutrient Direct Mixtures

Nitrogen 80 20

Phosphorous 8 92

Potassium 65 35

TOTAL 61 39

Source: Hoffmeister, G., “Fertilizers,” Kirk-Othmer

Encyclopedia of Chemical Technology, V. 10, 1993.

Although the Bureau of the Census only counts 401 facilities reporting the SIC

code for fertilizer mixing (2875) in 1992, other sources estimated the true

number of fertilizer mixing facilities to be closer to five or six tho usand in

1984 (Adrilenas and Vroomen, 1990). About half of applied fertilizers are

bulk blends. Fertilizer mixing facilities generally serve a small area such as

farms within a ten to fifty mile radius. The processes involved are simple and

relatively little value is added to the raw materials purchased by mixing

f acilities. Nevertheless, there are many of these facilities and volume of

production results in a $1.8 billion industry (value of annual shipments). The

industrial process is simple and resembles that of the pesticide formulating

sector. A brief discussion of fertilizer mixing processes is included in this

notebook.

Pesticides and Miscellaneous Agricultural Chemicals

The pesticides and agricultural chemicals n.e.c. (referred to here as pesticides

and miscellaneous agricultural chemicals) industry group (SIC 2879)

formulates and prepares read y to use agricultural and household pesticides and

other agricultural chemicals. The manufacture of pesticide active ingredients

is classified under either Industry Group 281 for inorganic chemicals or 286

for organics which are not cove red by this notebook. ( See Profile of the

Ino rganic Chemicals Industry and Profile of the Organic Chemicals

Industry Sector Notebooks.) In the United States, over 850 different pesticide

formulations and preparation s are produced. In 1995, 31 new active

ingredients were registered in the United States (Aspelin, 1997). Most of these

pesticides can be classified as either insecticides, herbicides, or fungicides,

although many other minor classifications exist. Also included in this category

are blends of fertilizers and pesticides produced at pesticide formulating andAgricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 13 mixing facilities. Table 4 lists the pesticides and other products included in

SIC 2879.

Table 4: SIC 2879 Pesticides and Miscellaneous Agricultural

Chemicals, List of Products

Agricultural disinfectants

Agricultural pesticides

Arsenates and arsenites

Bordeaux mixture

Cattle dips and sheep dips

DDT

Defoliants

Fly sprays

Fungicides

Growth regulants

Herbicides Insecticides, agricultural and

household

Lime-sulfur, dry and solution

Lindane, formulated

Moth repellants

Nicotine and salts

Paris green

Pesticides, household

Phytoactin

Plant hormones Poison, household

Pyrethrin

Rodenticides

Rotenone

Soil conditioners

Sulfur dust

Thiocyanates

Trace elements

(agrichemical)

Xanthone

Source: Standard Industrial Classification Manual

, Office of Management and Budget,

1987.

In 1995, 77 percent (by volume) of all pesticides were used for agriculture, 12

percent for industrial, commercial, or governmental lands or facilities, and 11

percent for homes and gardens (Aspelin, 1997). Non-agricultural pesticides

and misc ellaneous agricultural chemicals are included in the data presented for

sales, production, waste management, and enforcement and compliance.

However, since they represent a relatively small part of the industry and cover

a wide range of chemicals and production processes, these products are not

covered in t

he Industrial Processes and Pollutant Outputs sections of this

document.

Herbicides

Herbicides (in both value and quantity) are the largest class of pesticides used

in the United States, as well as in the world. This class of pesticides, which

accounts for approximately fifty p ercent of the value of aggregate world

pesticide usage, is used to destroy or control a wide variety of weeds and

other unwanted plants. Because of its demonstrated farm labor savings, nearly

all the agricultural land in the United States is currently being treated with

some type of herbicide. In recent years, approximately fifty percent of total

United States pesticide consumption (by value) was herbicides (USITC,

1994).

Insecticides

Insecticides are the second largest pesticide category (by value) used in the

United States and in the world. In the early 1990s, insecticides accounted for

approximately twenty-nine percent of the total value of United States pesticide

consumption. Historically, the category of synthetic organic insecticides has

been divided into one of four major chemical groups:



### C organochlorines (e.g., DDT and chlordane)Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 14 

### C organophosphates (e.g., parathion and diazinon)



### C carbamates (e.g., carbaryl)



### C pyrethroids (e.g., natural and synthetic)

Several compounds, discovered during the 1950s, found widespread use in

agriculture because of their high toxicity to a variety of insects. However, the

qualities that made these chemicals so desirable also led to their eventual

removal from the market, as these products also proved harmful to humans and

to the environment. Spurred in part by increased environmental concern,

researchers developed a new series of less toxic synthetic compounds called

pyrethroids. These compounds are based on the natural pyrethroids, which are

found in such plants as the chrysanthemum (USITC, 1994).

Fungicides

In recent years, fungicides accounted for approximately ten percent of the

value of total United States pesticide consumption. Fungicides are used today

primarily to protect agricultural crops and seeds from various fungi; farmers

previously used inorganic products, such as elemental su lfur and copper

sulfate. Initially, synthetic products were commercially unsuccessful, because

of their high manufacturing costs. By the 1940s, however, newer, less

expensive products became commercially successful. Today, fungicides are

manufactured from a variety of chemical classes. Commercially, the most

important fungicides are halogenated compounds, the carbamates and

dithiocarbamates, and organophosphates (USITC, 1994).

Other Pesticides

Although small in total quantity consumed, a numbe r of other classes of

pesticide products are on the market. Some of these pesticides are not covered

by this Notebook.



### C Biological p esticides , also known as biopesticides, include true biological

agents, living or reproduced biological entities such as viruses or bacteria,

and naturally occurring biochemicals suc h as plant growth regulators,

hormones, and insect sexual attractants (pheromones) that funct ion by

modes of action other than innate toxicity. At the end of 1998, there were

approximately 175 registered biopesticide active ingredien t s and 700

products. Generally, biological pesticides pose little or no risk to human

health or the environment. Accordingly EPA generally requires much less

data to register a biopesticide than to register a conventional pesticide

(USEPA, 1999). To further facilitate the registration of biopesticides, in

1994, EPA established the Biopesticides and Pollution Prevention

Division in the Office of Pesticide Programs.



### C Plant growth regulators have been developed by many companies to

improve crop production. Plant growth regulators are produced for a

variety of purposes, including loosening ripened fruits for faster harvest;

controlling the size and firmness of fruits; and regulating the size of a plantAgricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 15 t o increase branching. These products account for a small portion of

world and United States usage. Future development will probably be

directed toward selected crops for which the application of these specialty

products is found to be the most cost effective (USITC, 1994).



### C Sex attrac tants may be used to attract insects to traps or to confuse

specific male insects, making it diffic ult to locate females for mating.

Commercially available sex ual attractants are synthetically produced

compounds. Insect growth regulators, such as juvenile growth hormones,

are synthetic compounds similar to the natural chemica ls that regulate

insect growth.



### C Genetically modified plants are plants developed throu g h the use of

biotechnology. There are three types of plants that are relevant to pest

control: herbicide- tolerant plants (which can tolerate certain types of

herbicides), insect-resistant plants (which can withstand attacks by certain

insects), and virus- and other pest-resistant plants (which are immune to

some types of plant viruses and other plant pests). As of September 1994,

several genetically m

odified plants had been commercialized and had

elicited optimism that genetically modified plants would become an

important new approach to controlling pests (USDA, 1995).

The e nvironmental benefits of reduced use of chemical pesticides are also

significant. Environmental side effects of traditional pesticides include the

cost of providing alternative sources of drinking water, increased treatment

costs for public and private water systems, lost boating and swimming

opportunities, worker safety con cerns, exposure to nearby residents, increased

exposures for farm children, possible loss of biodiversity, pressure on

t hreatened and endangered species, and damage to recreational and fish ery

resources (USDA, 1995).

Pesticide Formulations

Pesticide formulations may exist in any of the three following physical states:

liquid, dry, and pressurized gas. The liquid formulation may be applied

directly in liquid form or propelled as an aerosol. Some common dry-based

formulations are dusts, wettable powders, granules, treated seed, bait pellets,

encapsulated, and cubes. Pressurized gas formulations are used primarily for

soil fumigation (USEPA, 1996). Gaseous pesticides can be subjected to high

pressures which often convert the formulation to a liquid which can be stored,

transported and applied from gas cylinders.

Repackaging of pesticide formulations is common when materials are to be

transfer red from bulk storage to a smaller scale of packaging for use by a

consumer. Products are typically repackaged in smaller co ntainers and

consumer-specific labeling is added (USEPA, 1996).

In 1995, roughl y 79 percent of all pesticides were used on agriculturalAgricultural Chemical Industry Introduction and Scope

1 Production and importation of methyl bromide is currently being phased out. It will be reduced from 1991 levels

and will be completely phased out in 2005.

Sector Notebook Project September 2000 16 Figure 4: Product Distribution for SIC 2879, Pesticides and Miscellaneous

Agricultural Chemicals

cropland. The remainder were us ed in private homes and gardens and on

commercial and industrial property (Aspelin, 1997). Therefore, although nonagricultural pesticides are included in SIC code 2879 and thus the notebook,

the specific packaging or formulating requirements of those products are not

included. However, the sales, production, pollutant releases, and enforcement

and compliance data reflect non-agricultural pesticides as well as agricultural

pesticides.

The majority of pesticides were used on only a few major crops: cotton, corn,

soybeans, and apples. The major pesticide chemicals used in United States

agricultural crop production are atrazine, metolachlor, metam sodium, methyl

bromide 1 , and dichloropropene (Aspelin, 1997).

Source: American Crop Protection Association, as reported in Chemical and Engineering News, June 23,

1998.

Establishment Reporting Under FIFRA Section 7

Information reported under section 7 of the Federal Insecticide, Fungicide, and

Rodenticide Act (FIFRA) is another source of facility level data for the pesticidesAgricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 17 industry. All establishments that produce pesticides in the United States or that

import pesticides into the United States are required to register and report their

production volume to the EPA. These data differ from the Census of

Manufacturers da ta presented above for the agricultural chemical industry as a

who le. The Census of Manufacturers data only covers facilities that are

manufacturing these products, while the FIFRA data system more broadly includes

establishments that “produce ” these products. The term, “produce” has been

defined under FIFRA and 40 CFR Part 167 to mean “to manufacture, prepare,

propagate, compound, or process any pesticide, including any pesticide produced

pursuant to section 5 of FIFRA, any active ingredient, or device, or to package,

repackage, label, relabel, or otherwise change the container of any pesticide or

device.” Repackaging or otherwise changing the container of any pesticide or

device in bulk amounts constitutes pesticide production. Under FIFRA section 7,

products are reported under one of four product types:

1) Technical material or active ingredient

2) End-use blend, formulation, or concentrate

3) Repackaged or relabeled product

4) Device

The total number of establishments, domestic and foreign, that reported to EPA

under FIFRA section 7 are p resented in Table 5. Although there are

approximately twelve to thirteen thousand Active Registered Pesticide-Producing

Establishments, table 5 below on ly lists establishments that reported actual

production for the calender year 1996. The establishments that reported either

zero production or who were non-reporters for calender year 1996 are not

included in the establishment number totals in the table. The significant difference

between the pesticide producing establishment counts as reported under section

7 (8,612) and the pesticide and agricultural chemical manufactu r ers n.e.c. reported

by the Census (263) can be attributed to the section 7 broad inclusion of producers

v s. the relatively narrow, Census inclusion of manufacturers. In addition, the

Census of Manufacturers uses SIC code definitions which lump many pesticide

active ingredient manufacturers into SIC codes that represent organic or inorganic

chemicals. Establishments classified under the first product type, as well as some

of the second, may include facilities classified under the chemical manufacturing

SIC codes 286 or 281. Also, the Census only counts a facility in an SIC code if

they report a product in that SIC code as their primary line of business. Therefore,

facilities producing a variety of products might n ot be classified under all

applicable SIC codes. For example, a facility which produces many different

types of fertilizers as well as some pesticides might only be counted under the

fertilizer SIC codes by the Census Bureau to avoid double counting of facilities.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 18 Table 5: Establishment Counts Based on Product Type *

Type Product Total Domestic Foreign

1 Technical Material,

Active Ingredient 555 410 145

2 End-Use Blend,

Formulation,

Concentrate 2,590 2,454 136

3 Repackaged or

Relabeled Goods 5,267 5,243 24

4 Devices 200 166 34

Total 8,612 8,273 339

Source: U.S.EPA, Enforcement, Planning, Targeting & Data

Division,, FIFRA, section 7 Data System, United States EPA. 1996.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 19 II.B.2. Industry Size and Geographic Distribution

Table 6 lists the facility size distribution within the nitrogenous fertilizer,

phosphatic fertilizer, fertilizer mixing, and pesticide and agrichemical

formulating i ndustries. For each industry code, the majority of facilities

employ less than 50 people.

Table 6: Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical

Manufacturing Industry

FERTILIZERS PESTICIDES

Employees

per Facility Nitrogenous

Fertilizers

(SIC 2873) Phosphatic

Fertilizers (SIC

2874) Fertilizers, Mixing

only

(SIC 2875) Pesticides and

other

Agrichemicals

(SIC 2879)*

Number

of

Facilities Percentage

of

Facilities Number

of

Facilitie

s Percentage

of

Facilities Number

of

Facilities Percentage

of

Facilities Number

of

Facilitie

s Percentage

of

Facilities

1-9 60 39% 27 36% 205 51% 108 41%

10-49 47 31% 22 29% 166 41% 95 36%

50-249 43 28% 15 20% 30 8% 45 17%

250-499 1 1% 6 8% 0 0% 7 3%

500-2499 1 1% 5 7% 0 0% 8 3%

Total 152 100% 75 100% 401 100% 263* 100%

Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce, Bureau of the

Census, May 1995.

Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and employment

figures since 1992 are not reflected in these data.

* United States EPA has identified over 8,600 registered pesticide producing establishments. The SIC code as it is defined by the

OMB only includes 263 of those establishments.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 20 Figure 5: Geographic Distribution of the Fertilizer Industry (SIC 2873, 2874, 2875)

Figure 5 shows the United States distribution of fertilizer manufacturing and

mixing facilities. The geographic distribution of nitrogenous and phosphatic

fertilizer manufacturers is determined by natural resources and d emand.

Seventy percent of synthetic ammonia p lants in the United States are

concentrated in Louisiana, Texas, Oklahoma, Iowa, and Nebraska due to

abundant natural gas supplies. The majority of nitric acid plants are located

in agricultural regions such as the Midwest, South Central, and Gulf States in

order to accom

modate the high volume of fertilizer usage. Florida has the

largest phosphate rock supply in the United States, thus phosphoric acid

manu facturing is concentrated primarily in Florida and spreads into the

Southeast.

Source: 1992 Census of Manufacturers, Industry S eries: Agricultural Chemicals, United States

Department of Commerce, Bureau of the Census, May 1995.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 21 Table 7 further divides the geographic distribution of fertilizer manufacturing

and mixing facilit

ies. The top states in which the nitrogenous fertilizer,

phosphatic fertilizer, and fertilizer mixing industries are concentrated are

given along with their respective number of establishments. Florida’s supply

of phosphate rock causes a concentration of phosphatic and mixed fertilizer

facilities, while nitrogenous fertilizer plants are often located near sources of

raw materials.

Table 7: States with the Largest Number of Fertilizer Manufacturing Facilities

States in which

industry is

concentrated, based

on number of

establishments Nitrogenous

Fertilizers

(SIC 2873) Phosphatic

Fertilizers

(SIC 2874) Fertilizers,

Mixing only

(SIC 2875)

Top

States Establishments Top

States Establishments Top

States Establishments

California

Texas

Louisiana 17

12

8 Florida

North

Carolina 15

9 Florida

Ohio

Texas 42

31

26

% of total 24% 32% 25%

Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce,

Bureau of the Census, May 1995.

Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location,

and employment figures since 1992 are not reflected in these data.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 22 Figure 6: Geographic Distribution of the Pesticide Formulating and Miscellaneous

Agrichemical Formulating Facilities (SIC 2879) *

Figure 6 shows the United States distribution of pesticide formulating and

miscellaneous agrichemical formulating facilities. The distribution follows

the general distribution of the petrochemical industry (coasts and Great Lakes)

which the industry relies on for its raw materials, and the dist ribution of

agricultural production in the United States (Midwest and Great Plains states).

Source: 1992 Census of M a nufacturers, Industry Series: Agricultural Chemicals, United States

Department of Commerce, Bureau of the Census, May 1995.

* United States EPA has identified over 8,000 establishments that could fall within this SIC code as it

is defined by the OMB.Agricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 23 Table 8: Top United States Agricultural Chemical Companies

Rank Company 1997 Sales

(millions of

dollars) SIC Code(s) Reported

1 IMC Global - Northbrook, IL 2,981 2874, 2875, 2819, 1474, 1475

2 Zeneca Inc. - Wilmington, DE 2,822 2879, 2834,2899

3 Agrium United States Inc. - Spokane,

WA 1,814 2873

4 CF Industries, Inc. - Lake Zurich, IL 1,383 2873, 2874

5 PCS Nitrogen Inc. - Memphis, TN 1,310 2873, 2874

6 Dowelanco (now named Dow

AgriSciences) - Indianapolis, IN 1,288 2879

7 The Scotts Company - Marysville, OH 752 2873, 2874, 2879, 0139, 2499,

3524

8 Cargill Fertilizer - Riverview, FL 600 2874

9 ChemFirst Inc. - Jackson, MS 595 2873, 2865, 3567, 3312

10 La Roche Industries Inc. - Atlanta, GA 449 2873, 5191, 2812, 2869, 3291,

3569

Source: Dun & Bradstreet’s Million Dollar Directory, 1997

Note: Not all sales can be attributed to the companies agricultural chemical operations.

Dun & Bradstreet’s Million Dollar Directory

, compiles financial data on

United States companies including those operating within the Fertilizer,

Pesticide, and Agricultural Chemical Industry. Dun & Bradstreet ranks United

States companies, whether they are a parent company, subsidiary or division,

by sales volume within their assigned 4-digit SIC code. Readers should note

that: (1) companies are assigned a 4-digit SIC code that resembles their

principal industry most closely; and (2) sales figures include total company

sales, including subsidiaries and operations (p ossibly not related to

agricultural chemicals). Additional sources of company specific financial

information inc lude Standard & Poor’s S tock Report Service, Ward’s

Business Directory of United States Public and Private Com panies,

Moody’s Manuals, and annual reports.

The Bureau of the Census publishes concentration ratios, which measure the

degree of competition in a mar ket. They compute the value of shipments

per centage controlled by the top 4, 8, 20, and 50 companies in a given

industry. Within the agricultural chemical industry, the phosphatic fertilizerAgricultural Chemical Industry Introduction and Scope

Sector Notebook Project September 2000 24 industry had the highest concentration ratio for the top four companies in 1992,

62 percent. The pesticide and other agricultural chemicals, nitrogenous

fertilizers, and fertilizer mixing industries’ concentration ratios were 53, 48,

and 19 percent respectively.

II.B.3. Economic Trends

The United States is a major producer and exporter of agricultural chemicals.

It is the largest producer of phosphatic fertilizers and pesticides and the

second largest

producer of nitrogenous fertilizers in the world (USDOC,

1998).

Domestic Market Trends

The majority of important crops, such as corn and soybeans, are grown using

fertilizers and pesticides. As a result, year-to-year changes in the domestic

demand for agrichemicals reflect the level of planted acreage, which in turn

is affected by grain prices and we ather conditions. Increases in planted

acreage of corn, feedgrains and other crops in recent years have resulted in

increased demand and production of agrichem i cals in the United States.

Industry shipments of agricultural chemicals should show modest annual

growth through the end of the decade (USDOC, 1998).

The Federal Agricultural Improvement and Reform Act of 1996 could have a

major long-term impact on the agricultural chemical industry. This law gives

farmers greater flexibility in making planting decisions and allows them to rely

more on the marketplace as a guide for crop plantings. The bill eliminates the

annual acreage set-aside program, thus potentially boosting the levels of crop

acreage (USDOC, 1998).

Agricultural che mical production showed little change between 1995 and

1996. Total production was approximately 103 million pounds each year.

However, experts claim that due to lower dosage requirements for pesticides,

agrichemical demand is actually higher than it would appear. Pesticides saw

a six percent rise in produc tion from 1995 to 1996. Nitrogenous fertilizer

production was up approximately seven percen t, and phosphate production

increased slightly except

for its major product, diammonium phosphate. Prices

for agricultural chemicals rose three p ercent from 1995 to 1996, while the

number of production workers fell two percent (USDOC, 1998).

International Market Trends

The United States accounts for m ore than 50 percent of world trade in

phosphatic fertilizers, with a two-thirds share of total trade in DAP

(diammonium phosphate), the principal phosphatic fertilizer product. Exports

generally account for

about half of total shipments for the United States

phosphatic fertilizer industry, with about half of all exports going to China.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 25 I n ternational markets, especially less developed nations in Asia and Latin

America, hold greater market potenti al for the agrichemicals industry as

population levels grow, income levels rise, and demands for better standards

of living and diets increase the need for grain production. From the current

level of abo ut 5.8 billion, the world population is expected to increase by

about 80 million each year between 1996 and 2000. Developing nations are

becoming more sophisticated in agricultural practic e s, thus increasing their

usage of fertilizers and pesticides to improve production (USDOC, 1998).

The United States has been a net exporter of pesticide chemicals, and this is

expected to continue through the turn of the century. Exports of pesticides

accounted for about 25 percent of United States pesticide production in 1994,

according to The American Crop Protection Association. United States

pesticide producers benefit from a highly developed chemical sector and

strong demand from developing regions of the world. Nevertheless, export

opportunit

ies are being restrained by industry-wide globalization as producers

are choosing to site facilities closer to end-use markets. In addition,

regulatory reforms in Western Europe, such as the competitive acce ss provider

plan, are expected to limit prospe cts in that region, currently the largest

destination for United States produced pesticides (USDOC, 1998).

International competition for the United States phosphatic fertilizer industry

generally comes from countries with phosphate rock reserves and capacity to

convert rock into phosphate chemicals. Diammonium phosphate imports are

expected to account for most of the growth in world trade, thus giving the

United States a promising outlook for this product. Morocco possesses at least

50 percent of the wor ld’s rock reserves and is the largest phosphate rock

exporter. China and Russia are also major phosphate rock and fertilizer

producers, with Russia also a leading exporter of phosphate chemicals. In the

world pesticide markets, major competitors are companies based in Germany,

France, and Switzerland.

The United States is a net importer of nitrogenous fertilizers. Trinidad and

Tobago and Canada are the leading United States suppliers of nitrogen due to

their low-cost supplies of natural gas.

Agricultural biotechnology is beginning to play a major r o le in agricultural

pest control, spurred on by government pesticide restrictions, increased insect

resistan ce to pesticides, and farmers’ demand for productivity gains.

Genetically engineered plants will be higher y ielding, more resistant to

disease and insects, and tolerant to herbicides. A number of companies have

received approvals for the use of genetically engineered seeds, including corn

and cotton, that are resistant to insects and herbicide tolerant. Commercial

usage should increase rapidly over the next few years (USDOC, 1998).Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 26 This page left intentionally blank.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 27 III. INDUSTRIAL PROCESS DESCRIPTION

This section describes the major industrial processes within the Fertilizer,

Pes ticide, and Agricultural Chemical Industry, including the materials and

equipment used, and the processes employ ed. The section is designed for

those interested in gaining a gener al understanding of the industry, and for

those interested in the inter-relationship between the industrial process and

the topics described in subsequent sections of this profile

-- pollutant outputs,

poll u tion 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 resource materials and contacts

that are available.

This section specifically contains a description of commonly used production

processes, associated raw materials, the by-products produced or released,

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

coupled with schematic drawings of the identified processes, 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.

The three most important nutrients for plant growth are nitrogen, phosphorous,

and potassium. However, the production of the major potassium fertilizer salts,

or potash as they are commonly known, is typically considered an inorganic

chemical process (SIC 2819). Therefore, the di s cussion of fertilizer

production in this notebook is restricted to nitrogenous and phosphatic

mixtures. The fertilizer, pesticide, and agricultural chemical industry can be

divided into Nitrogenous Fertilizers, Phospha tic Fertilizers, Fertilizers

(Mixing-on

ly), and the formulating and preparing of pesticides and other

agricultural chemicals. A detailed description of the production processes for

nitrogenous and phosphatic fertilizers is presented here, along with brief

descriptions of the fertilizer mixing and pesticide formulating and preparing

industry.

III.A. Nitrogenous Fertilizers

The major nitrogenous fertilizers include synthetic ammonia, ammonium

nitrate, and urea. The various industrial processes used to manufacture these

products are described, as well as the production process for nitric acid, an

important intermediate in nitrogenous fertilizer production.

III.A.1. Synthetic Ammonia

Synthetic ammonia (NH

3 ) is produced by reacting hydrogen with nitrogen at

a molar ratio of three to one. Nitrogen is obtained fro m the air, which is

primarily comprised of nitrogen (78 percent) and oxygen (21 percent) (Lewis,

1993). Hydrogen is obtained from either the catalytic steam reforming ofAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 28 natural gas (methane) or naptha, or as the byproduct from the electrolysis of

brine at chlorine plants. In the United States, about 98 percent of the hydrogen

used to synthesize ammo n

ia is produced by catalytic steam reforming of natural

gas, and only 2 percent is obtained from chlorine plants (USEPA, 1993a).

Six proc ess steps are required to produce synthetic ammonia using the

catalytic steam reforming method:

1) natural gas desulfurization

2) catalytic steam reforming

3) carbon monoxide shift

4) carbon dioxide removal

5) methanation

6) ammonia synthesis.

The first, third, fourth, and fifth steps remove impurities such as sulfur, CO,

CO

2 and water from the feedstock, hydrogen and synthesis gas streams. In the

second step, hydrogen is manufactured and mixed with air (nitrogen). The

sixth step produces anhydrous ammonia from the synthetic gas. An anhydrous

compound is inorganic and does not contain water either adsorbed on its

surface or combined as water of crystallization. While almost all ammonia

plants use these basic process steps, details such as operating pressures,

temperatures, and quantities of feedstock vary from plant to plant. Figure 7

shows a simplified process flow diagram of a typical ammonia plant (USEPA,

1993a).

Natural gas desulfurization

In the natural gas desulfurization step, the sulfur content (primarily as H

2 S) in

natural gas feedstock is reduced to below 280 micrograms per cubic meter to

prevent poisoning of the catalyst used in the catalytic steam reforming step.

Desulfurization can be accomplished by passing the natural gas through a bed

of either activated carbon or zinc oxide. In both systems, the hydrogen sulfide

in the gas adsorbs to the surface of the activated carbon or zinc oxide medium

and the desulfurized natural gas passes through.

Over 95 percent of the amm onia plants in the United States use activated

carbon fortified with metallic oxide additives for feedstock desulfurization.

After a certain amount of impurities adsorb to the activated carbon, its

effectiveness is reduced and it must be regenerated by passin g superheated

steam through the carbon bed . The superheated steam strips out the sulfur

impurities, is condensed, and sent to the wastewate r treatment plant. One

disadvan t age of the activated carbon system is that some of the heavy

hydrocarbons in the natural gas adsorb to the carbon, decreasing its

effectiveness and lowering the heating value of the desulfurized gas.

The remaining five percent of plants use zinc oxide for desulfurization. The

zinc oxide system is capable of absorbing up to 20 percent sulfur by weightAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 29 Figure 7: Typical Process of Ammonia Synthesis

Source: United States EPA, 1993a.

(Hodge, 1994). Zinc oxide is replaced rather than regenerated, which lowersAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 30 energy consumption and mi nimizes impact to the atmosphere. The higher

molecular weight hydrocarbons are not removed; therefore, the heating value

of the natural gas is not reduced. However, it is impractical and uneconomical

to replace the zinc oxide beds so few plants use it (USEPA, 1993a).

Catalytic steam reforming

Next, the desulfurized natural gas is preheated by mixing with su perheated

steam. The mixture of steam and gas enters the primary reformer tubes which

are filled with a nickel-based reforming catalyst, and the tubes are heated by

natural gas or oil-fired burners. Approximately 70 percent of the me thane

(CH

4 ) is converted to hydrogen (H

2 ) and carbon dioxide (CO

2 ), according to

the following reaction:

0.88CH

4 + 1.26air + 1.24 H

2 O 

### 6 0.88 CO

2 +N

2 + 3H

2

The remainder of the CH

4 is converted to H

2 and CO. This process gas is then

sent to the secondary reformer, where it is mixed with compressed hot air at

540°C (1004°F). Sufficient air is added to produce a final synthesis gas

having a hydrogen-to-nitrogen mole ratio of three to one. The gas leaving the

secondary reformer (primarily hydrogen, nitrogen, CO, CO

2 , and H

2 0) is then

cooled to 360°C (680°F) in a waste heat boiler before being sent to the carbon

monoxide shift (USEPA, 1993a).

Carbon monoxide shift

After cooling, the secondary reformer effluent gas enters a high temperature

(350-400°C) CO shift converter which converts the CO to CO

2 , followed by

a low temperature (200-250°C) shift converter which continues to convert CO

to CO

2 (Kroschwitz and Howe-Grant, 1992). The high temperature CO shift

converter is filled with chromium oxide initiator and iron oxide catalyst. The

following reaction takes place (USEPA, 1993a):

CO + H

2 O 

### 6

CO

2 + H

2

The exit gas is then

cooled in a heat exchanger before being sent to a low

temperature shift converter for ammoni a

, amines, and methanol where CO

continues to be converted to CO

2 by a copper oxide/zinc oxide catalyst (Kent,

1992). In some plants, the gas is first passed through a bed of zinc oxide to

remove any residual sulfur contaminants that would poison the low

temperature shift catalyst. In other plants, excess low temperature shift catalyst

is added to ensure that the unit will operate as expected. Final shift gas from

this converter is cooled from 210 to 110°C (410 to 230°F) and unreacted

steam is condensed and separated from the gas in a knockout drum. The final

shift gas then enters the bottom of the carbon dioxide absorption system. The

condensed steam (process condensate) contains am monium carbonate ([(NH

4 )

2

CO

3 • H

2 O]) from the high temperature shift converter, methanol (CH

3 OH)

from the low temperature shift converter, and small amounts of sodium, iron,

copper, zinc, aluminum and calcium. Process condensate is sent to the stripperAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 31 to remove volatile gases such as ammonia, methanol, and carbon dioxide.

Trace metals remaining in the process condensate are typically removed in an

ion exchange unit (USEPA, 1993a).

Carbon dioxide removal

In this step, CO

2 in the final shift gas is removed. CO

2 removal can be done by

using one of two methods: monoethanolamine (C

2 H

4 NH

2 OH) scrubbing or hot

potassium scrubbing. Approximately 80 percent of the ammonia plants use

monoethanolamine (MEA) for removing CO

2

. In this process, the CO

2 gas is

passed upward through an adsorption tower countercurrent to a 15 percent to

30 percent solution of MEA in water fortified with corrosion inhibitors. After

absorbing the CO

2 , the amine-CO

2 solution is preheated and regenerated in a

reactivating tower. The reacting tower removes CO

2 by steam stripping and

then by heating. The CO

2 gas (98.5 percent CO

2 ) is either vented to the

atmosphere or used for chemical feedstock in other parts of the plant complex.

The regenerated MEA is pumped back to the absorber tower after being

cooled in a heat exchanger and solution cooler (USEPA, 1993a).

Methanation

Carbon dioxide absorption is not 100 percent effective in removing CO

2 from

the gas stream, and CO

2 can poison the synthesis conv erter. Therefore,

residual CO

2 in the synthesis gas must be removed by catalytic methanation.

In a reactor containing a nickel catalyst and at temperatures of 400 to 600°C

(752 to 1112°F) and pressures up to 3,000 kPa (435 psia) methanation follows

the following reaction steps:

CO

2 + H

2 

### 6

CO + H

2 O

CO + 3H

2 

### 6

CH

4 + H

2 O

CH

4 + 2H

2 O 

### 6

CO

2 + 4H

2

Exit gas from the methanator is almost a pure three to one mole ratio of

hydrogen to nitrogen (USEPA, 1993a).

Ammonia Synthesis

In the synthesis step, the hydrogen and nitrogen synthesis gas from the

methanator is converted to ammonia.

N

2 +3H

2 

### 6

2NH

3

First, the gas is compressed to pressures ranging from 13,800 to 34,500 kPa

(2000 to 5000 psia), mixed with recycled synthesis gas, and cooled to 0°C

(32°F). This results in a portion of the gas being converted to ammonia which

is condensed and separated from the unconverted synthesis gas in a liquidvapor separator and sent to a let-down separator. The unconverted synthesis

gas is further compressed and heated to 180°C (356°F) before entering a

synthesis converter containing an iron oxide catalyst. Ammonia gas exiting theAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 32 synthes is converter is condensed and separated, then sent to the let-down

separator. A small portion of the overhead gas is purged to prevent the buildup

of inert gases such as argon in the circulating gas system. Ammonia in the letdown separator is flashed to atmospheric pressure (100 kPa (14.5 psia)) at

33°C (-27°F) to remove impurities from the make-up gas. The flash vapor is

condensed in a let-down chiller where anhydrous ammonia is drawn off and

stored at low temperature (USEPA, 1993a).

Storage and Transport

Ammonia is typically stored at ambient pressure and -33°C (-28°F) in large

20,000 ton tanks. Some tanks are built with a double wall to minimize leakage

and insulate. If heat leaks into the tank and ammonia is vaporized, the vapors

a re typically captured, condensed, and returned to the tank. Ammonia is

mostly transported by barge to key agricultural areas, but there is also a small

system of interstate ammonia pipelines (Kent, 1992).

III.A.2. Nitric Acid

Nitric acid (HNO

3 ) is produced by two methods. The first method utilizes

oxidation, condensation, and absorption of ammonia to produce a “weak”

nitric acid. Weak nitric acid has a concentration ranging from 30 to 70 percent

nitric acid. The second method combines dehydrating, bleaching, condensing,

and absorption to produce “high strength” nitric acid from weak nitric acid.

High strength nitric acid generally contains more than 90 percent nitric acid

(USEPA, 1993a). The following text discusses each of these processes.

Weak Nitric Acid Production

Nearly all the weak nitric acid produced in the United States is manufactured

by the high temperature catalytic oxi dation of ammonia as shown schematically

in Figure 8. This process typically consists of three steps:

1) ammonia oxidation

2) nitric oxide oxidation

3) absorption.

Each step corresponds to a distinct chemical reaction.

Ammonia Oxidation

During ammonia oxidation, a one to nine ammonia to air mixture is oxidized

at a temperature of 750 to 800°C (1380 to 1470°F) as it passes through a

catalytic converter, according to the following reaction:

4NH

3 + 5 O

2 

### 6 4NO + 6H

2 O

The most commonly used catalyst is made of gauze squares of fine wire

constructed of 90 percent platinum and 10 percent rhodium. Under theseAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 33 conditions the oxid ation of ammonia to nitric oxide (NO) proceeds in an

exothermic reaction with 93 to 98 percent yield. Higher catalyst temperatures

increase reaction selectivity toward nitric oxide (NO ) production. Lower

catalyst t emperatures tend to be more selective toward nitrogen (N

2 ) and

nitrous oxide (N

2 O) (USEPA, 1993a). The nitric oxide then passes through

a waste heat boiler and a platinum filter in order to recover the precious metal

platinum (Kent, 1992).

Nitric Oxide Oxidation

The nitric oxide formed during the ammonia oxidation is further oxidized in

another p rocess step. The nitric oxide process stream is passed through a

cooler/condenser and cooled to 38°C (100°F) or less at pressures up to 800

kPa (116 psia). The nitric oxide reacts noncatalytically with residual oxygen

to form nitrogen dioxide and its liquid dimer, dinitrogen tetroxide:

2NO + O

2 

### 6 2NO

2 + N

2 O

4

(A dimer is a small polymer whose molecule is composed of two molecules

of the same composition (Lewis, 1993).) This slow, homogeneous reaction is

temperature and pressure dependent. Operating at low temperatures and high

pressures promotes maximum production of NO

2 within a minimum reaction

time (USEPA, 1993a).

Nitrogen dioxide absorption

The final step introduces the gaseous nitrogen dioxide/dimer mixture into an

absorption process after being cooled. The mixture is pumped into the bottom

of an absorption tower with trays, while liquid dinitrogen tetroxide (N

2 O

4 ) is

added at a higher point. Deionized water enters the top of the column. Both

liquids flow countercurrent to the dioxide/dimer gas mixture. The exothermic

reaction occurs as follows (USEPA, 1993a):

3NO

2 + H

2 O 

### 6

2HNO

3 + NO

A secondary air stream is introduced into the column to re-oxidize the NO that

is formed. This secondary air also removes NO

2 from the product acid.

Oxidation of NO to NO

2 takes place in the free space between the trays, while

absorption of NO

2 into the water occurs on the trays. An aqueous solution of

55 to 65 percent (typically) nitric acid is withdrawn from the bottom of the

tower. The acid concentration can vary from 30 to 70 percent nitric acid

depending upon the temperature, pressure, number of absorption stages, and

concentration of nitrogen oxides entering the absorber (USEPA, 1993a).

There are two variations of the process described above to pro duce weak

nitric acid: single-stage pressure process and dual-stage pressure process. In

the past, nitric acid plants have been operated at a single pressure, r anging

from atmospheric pressure to 1400 kPa (14.7 to 203 psia). However, since

the oxidation of ammonia is favored by low pressures and the oxidation ofAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 34 nitric oxide and the absorption of nitrogen dioxide are favored by higher

pressures, newer plants tend to operate a dual-stage p ressure system,

incorporating a compressor between the ammonia oxidizer and the condenser.

The oxidation reaction is carried out at pressures from sl ightly negative to

about 400 kPa (58 psia), and the absorption reactions are carried out at 800

to 1,400 kPa (116 to 203 psia) (USEPA, 1993a).

In the dual-stage pres sure system, the nitric acid formed in the absorber

(bottoms) is usually sent to an external bleacher where air is used to remove

(bleach) any dissolved oxides of nitrogen (NO, NO

2 , etc.). The bleacher gases

are then compressed and again passed through the absorber. The absorber tail

gas (distillate) is sent to an entrainment separator for acid mist removal. Next,

the tail gas is reheated in the ammonia oxidation h eat exchanger to

approximately 200°C (392°F). The gas is then passed through catalytic

reduction units for NO

x

emissions control. The final step expands the gas in

the power-recovery turbine. The thermal energy produced in this turbine can

be used to drive the compressor.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 35 Figure 8: Typical Process of Dual-Stage, Weak Nitric Acid Production

Source: United States EPA, 1993a.

High Strength Nitric Acid

High strength nitric acid (98 to 99 percent concentration) can be obtained by

con centrating weak nitric acid (30 to 70 percent concentration) using

extractive distillation. Extractive distillation is distillation carried out in the

presence of a dehydrating ag ent. Concentrated sulfuric acid (typically 60

percent sulfuri c acid) is most commonly used for this purpose. The weak

nitric acid cannot be concentrated by simple fractional distillation, in which

acid is concentrated by removing water vapor in a column with trays or plates.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 36 Figure 9: Typical Process Diagram of High Strength Nitric Acid Production The nitric acid concentration process consists of feeding strong sulfuric acid

and 55 to 65 percent nitric acid into the top of a packed dehydrating column at

approximately atmospheric pressure. The acid mixture flows downward and

concentrated nitric acid leaves the top of the column as 99 percent vapor,

containing a small amount of NO

2 and O

2 resulting from dissociation of nitric

acid. The concentrated acid vapor then goes to a bleacher and a countercurrent

condens er system to condense strong nitric acid and the separate out the

oxygen and nitrogen oxide by-products. The bleacher uses air to strip nitrogen

oxides out of the nitric acid and the countercurrent condenser system cools the

vapor by flowing air through the vapor causing droplets to separate out.

These nitrogen oxide by-products then flow to an absorption column where the

nitric oxide mixes with auxiliary air to form NO

2 , which is recovered as weak

nitric acid. Inert and unreacted gases are vented to the atmosphere from the top

of the absorption column. E missions from this process are relatively small

compared to weak acid production (USEPA, 1993a). Figure 9 illustrates a

typical high strength nitric acid production process.

Source: Adapted from United States EPA, 1993a.

III.A.3. Ammonium Nitrate and Urea

The manufacture steps for ammonium nitrate (NH

4 NO

2 ) and urea (CO(NH

2 )

2 )

are similar. In both cases, several major unit operations are involved,

including:

1) solution formation

2) concentration

3) solids formation

4) finishing

5) screeningAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 37 6) coating

7) product bagging and/or bulk shipping.

The se operations are shown schematically in Figure 10. Not all steps are

always necessary depending on the end product desired. For example, plants

p roducing ammonium nitrate or urea liquid solutions alone use only the

solution formation, solution blending and bulk shipping operation s. Plants

producing a solid product may employ all of the operations.

Solution synthesis

Ammonium nitrate.

Ammonium nitrate p lants produce an aqueous ammonium nitrate solution

through the reaction of ammonia and nitric acid in a neutralizer where water

is evaporated by the heat of the reaction as follows:

NH 3 + HN O

3 

### 6 NH

4 NO

3 + 26 kcal/g mol

The temperature, pressure, and final concentration of the ammonium nitrate are

interdependent. Higher temperatures and pressures can be used to produce a

higher concentration of ammonium nitrate (Hodge, 1994); however, th e

temperature of the operation should be below 120°C (250°F) in order to

prevent explosions. Up to 99.5 percent of the ammonia and nitric acid is

typically converted to ammoni um nitrate (Kent, 1992). Ammonium nitrate

solution can then be used as an ingredient for nitrogen solution fertilizers or

concentrated to a solid form.

Urea.

In the urea solution synthesis operation, ammonia (NH

3 ) and carbon dioxide

(CO

2 ) are reacted to form ammonium carbamate (NH

2 CO

2 NH

4 ) as follows:

2NH

3 + C O

2 

### 6 NH

2 CO

2 NH

4

Typical operating conditions include temperatures from 180 to 200°C (356 to

392°F), pressures from 14,000 to 25,000 kPa (140 to 250 psia), molar ratios

of NH 3 to CO

2 from 3:1 to 4:1, and a retention time of twenty to thirty minutes.

The ammonium carbamate is then dehydrated to yield 70 to 77 percent aqueous

urea solution. This reaction follows: (USEPA, 1993a)

NH

2 CO

2 NH

4 

### 6 NH

2 CONH

2 + H

2 O

Urea solution can be used as an ingredient of nitrogen solution fertilizers, or

it can be concentrated further to produce solid urea.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 38 Solids Concentration

Ammonium nitrate.

To produce a so l id product, the aqueous ammonium nitrate solution is

concentrated in an evaporator or concentrator. The resulting liquid “m e lt”

contains about 95 to 99.8 percent ammonium nitrate at approximately 149°C

(300°F). This melt is then used to make solid ammonium nitrate products

(USEPA, 1993a).

Urea.

The three methods of concent r ating the urea solution are vacuum concentration,

crystallization, and atmosp heric evaporation. The method chosen depends

upon the level of biuret (NH

2 CONHCONH

2 ) impurity allowable in the end

product. Biuret can cause mottling in urea solutions, reducing the fertilizers

effectiveness in foliar applications (Kent, 1992). Aqueous urea solution

decomposes with heat to biuret and ammonia. Therefore, if only a low level

of biuret impurity is allowed in the end product, the method with the least heat

requirement will be chosen, such as crystallization and vacuum concentration

( Kent, 1992). However, the simplest and most common method of solu tion

concentration is atmospheric evaporation.

Solids Formation

Prilling and granulation are the most common processes used to produce solid

am monium nitrate and urea. Prills are round or needle-shaped artificially

prepared aggregates of a material. To produce prills, concentrated melt is

spr ayed into the top of a prill tower. In the tower, melt droplets fall

countercurrent to a rising air stream that co ols and solidifies the falling

droplets into prills. P r ill density can be varied by using different

concentrations of ammonium nitrate melt. Low density prills, in the range of

1.29 specific gravity, are formed from a 95 to 97.5 percent ammonium nitrate

melt, and high density prills, in the range of 1.65 specific gravity, are formed

from a 99.5 to 99.8 percent melt. Low de nsity ammonium nitrate prills are

used for making blasting agents because they are more porous than high density

prills and will absorb oil. Most high den sity prills are used as fertilizers

(USEPA, 1993a).

Granulated ammonium nitrate and urea are produced by spraying a

concentrated melt (99.0 to 99.8 percent) onto small seed particles of

ammonium nitrate or urea in a long rotating cylindrical drum. As the seed

particles rotate in the drum, successive layers of the nitrogenous chemical are

added to the particles, forming granules. Pan granulators operate on the same

principle as drum granulators, except the solids are formed in a large, rotating

circular pan. Pan granulators produce a solid pr oduct with physical

characteristics similar to those of drum granules (USEPA, 1993a).

Although not widely used, additives such as magnesium nitrate or magnesium

oxide may be injected directly into the melt stream. Additives can serve threeAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 39 purposes: to raise the crystalline transition temperature of the final solid

product in order to retain its strength and density; to act as a desiccant,

drawing water into the final product to reduce caking; and to allow

solidification to occur at a low temperature by reducing the freezing point of

molten ammonium nitrate. (Kent, 1992)

Solids Cooling

The temperature of the nitrogenous pro duct exiting the solids formation

p rocess is approximately 66 to 124°C (150 to 255°F). To preven t

deterioration and agglomeration, the product must be cooled before storage

and shipping. Typically, ro t ary drums or fluidized beds are used to cool

granules and prills leaving the solids formation process. Because low density

prills have a high moisture content, they requ ire drying in rotary drums or

fluidized beds before cooling (USEPA, 1993a).

Solids Screening

Since the solids are produced in a wide variety of sizes, they must be screened

for consistently sized prills or granules. After cooling, off size prills are

dissolved and recycled back to the solution concentration process. Granules

are screened before cooling. Undersize particles are returned directly to the

granulator and ov ersize granules may be either crushed and returned to the

granulator or sent to the solution concentration process (USEPA, 1993a).

Solids Coating

Fol lowing screening, products can be coated in a rotary drum to prevent

agglomeration during storage and shipment. The most common coating

materials are clays and diatomaceous earth. However, the use of additives in

the melt before solidification may preclude the use of coatings.

The solid product is stored and shipped in either bulk or bags. The majority

of solid product is bulk shipped in trucks, enclosed railroad cars, or barges,

and approximately ten percent of solid ammonium nitrate and urea produced

in the United States is bagged (USEPA, 1993a).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 40 Figure 10: Typical Process for Ammonium Nitrate and Urea Manufacturing

Source: United States EPA, 1993a.

III.B. Phosphatic Fertilizers

The primary products of the phosphatic fertilizers industry are phosphoric

acid, ammonium phosphate, normal superphosphate, and triple superphosphate.

Phosphoric acid is sold as is or is used as an intermediate in producing other

phosphatic fertilizers. Monoammonium phosphate is favored for its high

phosphorous content, while diammonium phosphate i s favored for its high

nitrogen content. Normal superphosphate has a relatively low concentration of

phosphorous, however it is used in mixtures because of its low cost. Triple

superphosphate provides a high concentration of phosphorous, more than 40%

phosphorous pentoxide. The industrial proce sses for each of these products are

described below.

III.B.1. Phosphoric Acid (Wet Process)

In a wet process phosphoric acid facility (shown schematically in Figure 11),

phosphoric acid is produced by reacting sulfuric acid (H

2 SO

4 ) with naturally

occurring phosphate rock. The phosphate rock is mined, dried, crushed until

60 to 70 percent of the rock is less than 150 μm in diameter, and then

continuously fed into the reactor along with sulfuric acid (UNEP, 1996). The

reaction also combines calcium from the phosphate rock with sulfate, forming

cal cium sulfate (CaSO

4 ), commonly referred to as gypsum. Gypsum is

separated from the reaction solution by filtration.

Facilities in the United States generally use a dihydrate process that produces

gypsum in the form of calcium sulfate with two molecules of water (CaSO

4 

### C

2H

2 O or calcium sulfate dihydrate). Japanese phosphoric acid facilities useAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 41 a hemihydrate process which produces calcium sulfate with a half molecule

of water (CaSO

4 

### C 1⁄2 H

2 O). This one-step hemihydrate process has the

advantage of producing wet process phosphoric acid with a higher phosphate

pentoxide (P

2 O

5 ) concentration and less impurities than the dihydrate process.

D ue to these advantages, some United States companies have recently

converte d to the hemihydrate process. However, since most wet process

phosphoric acid is still produced by the dihydrate process, the hemihydrate

process will not be discussed in detail here.

A simplified reaction for the dihydrate process is as follows:

Ca

3 (PO

4 )

2 + 3H

2 SO

4 

### 6 2H

3 PO

4 + 3[Ca

3 SO

4 • 2H

2 O] 

### 9

To make the strongest phosphoric acid possible and to decrease evaporation

costs, a highly concentrated 93 percent sulfuric acid is normally used. Because

the proper ratio of acid to rock in the reactor is critical, precise automatic

process co ntrol equipment is employed in the regulation of these two feed

streams (USEPA, 1993a).

During the reaction, gypsum crystals are precipitated and separated from the

acid by filtration. The separated crystals must be washed thoroughly to yield

at least a 99 percent recovery of the filtered phosphoric acid. After washing,

the slurried gypsum is pumped into a gypsum settling pond for storage. Water

is siphoned off and recycled through a surge cooling pond to the phosphoric

acid process. Depending on a variety of factors, such as aver age ambient

temperature and annual rai nfall, settling and cooling ponds may require

between 0.25 and 1.0 acre for each ton of daily P

2 0

5 capacity (TFI, 1999).

Considera ble heat is generated in the reactor when the sulfuric acid and

phosphate rock react. In older plants, this heat was removed by blowing air

over the hot slurry surface. Modern plants vacuum flash cool a portion of the

slurry, and then recycle it back into the reactor.

Wet process phosphoric acid normally contains 26 to 30 percent P

2 O

5

. In most

cases, the acid must be further concentrated to meet phosphate feed material

specifications for fertilizer production. Depending on the types of fertilizer to

be produced, phosphoric acid is usually concentrated to 40 to 55 percent P

2 O

5 by using two or three vacuum evaporat ors (USEPA, 1993a). T hese

evaporators operate with a forced circulation and generate a vacuum through

vacuum pumps, steam ejectors, or an entraining condenser downstream of the

evaporator. Figure 12 illustrates a vacuum evaporator.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 42 Figure 11: Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant

Figure 12: Typical Vacuum Evaporator

Process Source: Adapted from United States EPA, 1993a.

Source: United States EPA, 1993aAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 43 III.B.2. Ammonium Phosphate

Diammonium phosphate (DAP) and monoammonium phosphate are the major

types of ammonium phosphatic fertilizer. Ammonium phosphates are produced

by reacting phosphoric acid with ammonia. The ammonium phosphate liquid

slurry produced is then converted to solid granules. Approximately 95 percent

of ammoniation-granulation plants in the United States use a rotary drum mixer

developed and patented by the Tennessee Valley Authority (TVA).

In the TVA DAP process, phosphoric acid is mixed in an acid surge tank with

93 percent sulfuric acid (H

2 SO

4 ) and recycled acid from wet scrubbers. The

mixed acids are then partially neutralized with liquid or gaseous anhydrous

ammonia in a brick-lined acid re actor. All of the phosphoric acid and

approximately 70 percent of the ammonia needed to complete the reaction are

introduced into this vessel. A slurry of ammonium phosphate and 22 percent

water are produced and sent through steam-traced lines to the ammoniatorgranulator.

Slurry from t

he reactor is distributed in the rotary drum granulator, and the

remaining ammonia (approximately 30 percent) is sparged under the slurry.

The basic rotary drum granulator consists of an open-ended, slightly inclined

rotary cylinder, with retaining rings at each end and a scraper or cutter

mounted inside the drum shell. A rolling bed of dry material is maintained in

the unit while the slurry is introduced through distributor pipes set lengthwise

in the drum. Gravity forces the slurry to travel through the turning granulator

to the lower end. Moist DAP granules are then discharged into a rotary dryer,

where excess water is evaporated and the chemical reaction is accelerated to

completion by the dryer heat. Dried granules are cooled and then sized on

vibrating screens. The product ranges in granule diameter from one to four

millimete rs (mm). The oversized granules are crushed, mixed with the

undersized, and recycled back to the ammoniator-granulat or. Product-size

DAP granules are allowed to cool, screened, bagged, and shipped. Before

being exhauste d to the atmosphere, particulate and ammonia rich off-gases

from the granulator, cooler, and screening operations pass through cyclones

and wet scrubbers (USEPA, 1993a).

TVA developed two minor modifica tions in their DAP process to produce

Monoammonium Phosph

a te (MAP). In one, the phosphoric acid is ammoniated

to an ammonia to phosphoric acid ratio of only 0.6 in the preneutralizer and

t hen 1.0 in the granulator. This compares to a ratio of about 1.4 for DAP.

With the second modification, the am monium to phosphoric acid ratio is

brought to 1.4 in the preneutralizer, then additional phosphoric acid is added

in the granulator to bring the ratio back to 1.0. The second method is preferred

by industry because higher t emperatures may be used to dry the MAP,

increasing production rates (Kent, 1992).

A schematic diagram of the ammonium phosphate process f low diagram isAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 44 GYPSUM

POND

WATER SECONDARY

SCRUBBER

PRIMARY

SCRUBBER

ACID

SURGE

TANK PHOSPHORIC

ACID

SULFURIC

ACID REACTOR

ANHYDROUS

AMMONIA FUEL,

AIR AMMONIATOR

GRANULATOR

ROTARY

DRYER SCREENS

CYCLONE

ROTARY

COOLER

PRODUCT

DUST

SUPPRESSANT

DUST

SUPPRESSANT UNDERSIZE COOLING AIR MILL

OVERSIZE Figure 13: Simplified Process Flow Diagram of Diammnonium Phosphate Production

shown in Figure 13.

Source: U.S.EPA, 1993a and TFI, 1999

III.B.3. Normal Superphosphate

Normal supe r phosphates (NSP) are prepared by reacting ground phosphate

rock with 65 to 75 percent sulfuric acid to produce a solid fertilizer material.

NSP is most often use d as a high-phosphate additive in the production of

granular fertilizers. It can also be granulated for sale as granulated

superphosphate or granular mixed fertilizer.

Th ere are two primary types of sulfuric acid used in superphosphate

manufacture: virgin and spent acid. Virgin acid is produced from elemental

sulfur, pyrites, and industrial gases and is relati vely pure. Spent acid is a

recycled waste product from various industries that u se large quantities of

sulfuric acid. Problems encountered with using spent acid include unusualAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 45 color, unfamiliar odor, and toxicity. An important factor in the production of

normal superphosphates is the amount of iron and aluminum in the phosphate

rock. Aluminum (as Al

2 O

3 ) and iron (as Fe

2 O

3 ) above five percent imparts an

ext reme stickiness to the superphosphate and makes it difficult to handle

(USEPA, 1993a).

A generalized process diagram of normal superphosphate production is shown

in Figure 14. Ground phosphate rock is weighed and mixed with sulfuric acid

(H

2 SO

4 ) and held in an enclosed area for about 30 minutes until the reaction

is partially completed. The mixing may be done in a cone mixer, which relies

on an inputted swirling motion of the acid to mix the rock and acid, a pug mill,

which operates with one or two mixing shafts, or a pan mixer, which agitates

the solution. The reaction is (AWMA, 1992):

Ca

10 (PO

4 )

6 F

2 CaCO

3 + 11H

2 SO

4 

### 6 6H 3 PO

4 + 11CaSO

4 *nH

2 O +

2HF + CO

2 + H

2 O

The mixture is then transferred, using an enclosed conveyer known as the den,

through the cutter whic h breaks up clumps, and finally to a storage pile for

curing. Off-gases from the reactor are typically treated in a wet scrubber.

Particulates throughout the process are control led with cyclones and baghouses

(USEPA, 1993a).

To produce granulated normal superphosphate, cured superphosphate is fed

through a clod breaker and sent to a rotary drum granulator w here steam,

water, and acid may be added to aid in granulation. Material is processed

through a rotary drum granulator, a rotary dryer, and a rotary cooler, and is

then screened to specification similar to the process used for ammonium nitrate

and urea. Finally, it is stored in bagged or bulk form prior to being sold

(USEPA, 1993a).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 46 Figure 14: Typical Process for Normal Superphosphate Manufacturing

Source: United States EPA, 1993a.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 47 III.B.4. Triple Superphosphate

Triple superphosphate provides a high concentration of phosphorous. Two

processes have been used to produce triple superphosphate: run-of-the-pile

(ROP-TSP) and granul a

r (GTSP). GTSP yields larger, more uniform particles

with improved storage and handling properties than ROP-TSP. At this time,

no facilities in the United States are producing ROP-TSP, so only the GTSP

process is described here.

Most GTSP material is made with the Dorr-Oliver slurry granulation process,

illustrated in Figure 15. This process is similar to that for normal

superphosphates with the major exception being that phosphoric acid is used

instead of sulfuric acid. In this process, ground phosphate rock or limestone

is reacted with phosphori c acid in one or two reactors in series (USEPA,

1993a). The reaction is:

Ca

5 F(PO

4 )

3 + 7H 3 PO

4 + 5H

2 O 

### 6 5Ca(H

2 PO

4 )

2 •H

2 O +HF

(Hodge, 1994) The phosphoric acid used in this process has a relatively low

concentration (40 percent P

2 O

5 ). The lower strength acid maintains the slurry

in a fluid state during a mixing period of one to two hours. A small sidestream

of slurry is continuously removed and distributed onto dried, recycled fines in

a granulator, where it coats the granule surfaces and builds up its size.

Granules are then dried in a rotary dryer, elevated and passed through screens

to eliminate oversize and undersize granules. Oversize granules are crushed

and sent back to the f

irst screen, while undersize ones are sent into the

emission control systems. The granules within the size range of the product

are then cooled and stored in a curing pile where the reaction is completed.

Particulates from the rock handling, drying, scre ening, cooling, and storing

processes are typically controlled with cyclones and bag houses and off-gases

from the reactor, granulator, and cyclones and baghouses are typically treated

with wet scrubbers (USEPA, 1993a).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 48 Figure 15: Typical Process for Triple Superphosphate

Source: United States EPA, 1993aAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 49 III.C. Fertilizer Mixing

A significant part of the fertilizer industry only purchases fertilizer materials

in bulk from fertilizer manufacturing facilities and mixes them to sell as a

fertilizer formulation. Fertilizer mixing facilities use many different materials

in their blends. The most common granular fertilizer materials are listed in

Table 9.

Table 9: Fertilizer Materials Used in Bulk Blends

Typical Grade

N-P

2 O

5 -K

2 O Percent of

fertilizer plants

using this material

Ammonium nitrate 31-0-0 41%

Urea 46-0-0 66%

Ammonium sulfate 21-0-0 22%

Diammonium phosphate (DAP) 18-46-0 95%

Monoammonium phosphate (MAP) 11-52-0 11%

Triple Superphosphate 0-46-0 78%

Normal superphosphate 0-20-0 4%

Potassium chloride 0-0-60 94%

Source: “Retail Marketing of Fertilizers in the United States,” by Hargett, Norman

and Ralph Pay, 1980 .

DAP is favored for fertilizer mixing because of its ease in storage and

handling, convenient low nitrogen and high phos phorous content, and

compatibility with almost any other material. Granular triple superphosphate

is also very popular, but is incompatible with urea, a common nitrogen source.

Therefore, TSP is commonly used in no-nitrogen bl ends necessary for

legumes. Ammonium sulfate has the lowest nitrogen content of the major

nitrogen sources, however its production cost is quite low. Potassium

chloride is the only major p otassium source used in fertilizer blending.

Additional materials may also be added to the blends, such as micronutrients

and pesticides (Nielson, 1987).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 50 Inert i ngredients may also be added to fertilizer mixtures to improve the

consistency or ease of application. Inert ingredients include sands, clays, and

water.

Fertilizer mixing plants consist of five primary phases:

1. mixing and storing

2. moving materials to mixers

3. proportioning of materials

4. mixing, and

5. moving the finished blend to holding bins or transport containers

Fertilizer materials may be mixed as bulk blends or formed into granulations

by a variety of processes. Bulk blending is a dry process, where different

fertili zers are combined. Materials are typically received by rail cars and

transferred through elevators to storage areas. Front-end loaders then carry the

materials to weighing hoppers which feed into the mixers. There are two types

of mixers most commonly used: the horizontal axis rotary drum mixer and the

inclined axis rotary drum mixer. The inclined axis mixer is similar to a cement

mixer in design and appearance. Ribbon-type bulk-blend mixers are also used

in some plants. A ribbon-type mixer has an axial shaft with mixing spokes

radiating out of the shaft in a configuration which forces the blend to flow in

a ribbon-like pattern through the mixture (Nielson, 1987).

After preparation and initial bulk blending of materials, granulation may be

employed in order to form larger fertilizer particles with multi-nutrient

compositions. Granulation of mixed fertilizers may be accomplished by steam

granulation, slurry granulation, melt, or compaction granulation.

Steam granulation

is primarily used in Europe and Australia. The process

results in little chemical reaction in order to maintain the P

2 O

5 content of the

fertilizer. Plasticity and agglomeration of the fertilizer materials is promoted

by the injection of steam into rotating pans, rotary drums, or pug mills. The

particles are then dried with heated air in a rotary drum dryer and cooled in

a rotary drum cooler. In some cases, particles may be coated with chalk or

clay to prevent caking (Hoffmeister, 1993).

Slurry granulation is more commonly used in the United States The process

involves a chemical reaction of the feed ingredients. In slurry granulation, one

of the feed ingredients is prepared as a slurry and reacted with the others in a

preneutralizer. The slurry is then fed to a granulator such as the ammoniatorgranulator developed by the TVA. Fertilizer producers in the United States

found that higher concent

r ations of acid could be fed to this preneutralizergranulator process than to a granulator alone, thus increasing the grades of

fertilizers and making the TVA process popular in the United States

(Hoffmeister, 1993).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 51 Another granulation process similar to slurry granulation is melt granulation.

The slurry feed is replaced by a hot, concentrated, almost anhydrous melt of

feed fertilizer, typically ammonium phosphate, prepared in a pipe reactor. The

hot melt provides the plasticity necessary for granulation. The granules cool

first in the granulator and then in the cooler, eliminating the need for a dryer.

Compaction granulation is based on the fact that most materials are semiplastic

and when subjected to high pressures, the materials will compact, deform, and

it is possible to roll them out into flat, stable sheets. These sheets are then

cracked, forming granule-size chips which are most stable and less prone to

caking th an other granulations. This process has been successful for many

fertilizer mixtures, particularly those including potassium chloride and

a mmonium phosphates and superphosphates. Ammonium sulfate, however, has

limited crystal plasticity, making it unsuitable for compaction granulation

(Hoffmeister, 1993).

The mixtures are then typically bagged in woven polypropylene bags for

strength and resistance, with liner bags to prevent leaks. The bags are either

clamped , tied, heat sealed, or sewn, sewing being the cheapest and most

common method (Nielson, 1987).

III.D. Pesticide Formulating Processes

Pesticide formulation involves the process of mixing, blending, or diluting one

or more pest

icide active ingredients (AIs) and inert ingredients to obtain a

product used for additional processing or an end-use (retail) product.

Formulatio n does not involve an intended chemical reaction (i.e., chemical

synthesis). AIs are produced at separate facilities not included in this

notebook. Pesticide formulations take many forms: water-based liquid;

organic solvent-base d liquid; dry products in granular, powder, and solid

forms; pressurized gases; and aero sols. The formulations can be in a

concentrated form requiring dilution before application, or they can be ready

to apply. The packaging of the formulated pesticide product depends on the

type of formulation. Liquids generally are packaged into jugs, cans, or drums;

dry formulations generally are packaged into bags, boxes, drum s, or jugs;

pressurized gases are packaged into cylinders; and aerosols are packaged into

aerosol cans.

Formulating, packaging, and repackaging is performed in a variety of ways,

ranging from very sophisticated and a utomated formulating and packaging lines

to completely manual lines. Descriptions of liquid formulating and packaging,

dry fo rmulating and packaging, aerosol packaging, pressurized gas formulating

and packaging, and repackaging operations are provided below.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 52 III.D.1. Liquid Formulating and Packaging

Liquid formulations contain mixtures of several raw materials, including AIs,

inert ingredients such as base solvents, emulsifiers, or surfactants. The solvent

must be able to dissolve the AIs and other ingredients. It may be water or an

organic chemical, such as isopropyl alcohol or petroleum distillate. In some

cases, the formulation is an emulsion and contains both water and an organic

solvent. Solid materials, such as powders or granules, may also be used as

part of a liquid formulation by dissolving or emulsifying the dry materials to

form a liquid or suspension. The formulated product may be in a concentrated

form requiring dilution before application, or may be ready to apply.

Typical liquid formulating lines consist of storage tanks or containers to hold

active and inert raw materials and a mixing tank for formulating the pesticide

product. A storage tank may also be used on the formulating line to hold the

formulated pesti c ide product, prior to a packaging step. Facilities may receive

their raw materials in bulk and store them in bulk storage tanks, or they may

receive the raw materials in smaller quantities, such as 55-gallon drums, 50-

pound bags, or 250-gallon minibulk refillable containers or “totes.” These

raw materials are ei ther piped to the formulation vessel from bulk storage

tanks or added directly to the ves sel from drums, bags, or minibulks.

Typically, water or the base solvent is added to the formulation vessel in bulk

quantities (USEPA, 1996). A typical liquid formulating line is shown in

Figure 16.

The formulating line may also include piping and pumps for moving the raw

material from the storage tanks to the mixing tank, and for moving formulated

pesticide product to the packaging line. Other items that may be part of the

line are premixing tank s, stirrers, heaters, bottle washers, and air pollution

control equipment. Some lines may also have refrigeration units for

formulation and storage equipment, scales, and other equipment.

Many liquid formulations are packaged by simply transferring the final product

into containers. Small quantities of product are often manually packaged by

gravity feeding the product directly from the formulation tank into the product

container. For larger quantities, the process is often automated. Formulated

product is transferred to the packaging l ine through pipes or hoses, or is

received from a separate formulating facility and placed in a filler tank. A

conveyor belt is used to carry product containers, such as jugs, bottles, cans,

or drums, through the filling unit, where nozzles dispense the appropriate

volume of product. The belt then carries the containers to a capper, which may

be automated or manual, and to a labeling unit . Finally, the containers are

packed into shipping cases (USEPA, 1996).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 53 Figure 16: Typical Process for Liquid Formulating

Source: United States EPA, 1996

III.D.2. Dry Formulating and Packaging

Dry formulations also contain active and inert ingredients. The final product

may be in many different forms, such as powders, dusts, granules, blocks, solid

objects impregnated with pesticide (e.g., flea collars), pesticides formed into

a solid shape (e.g., pressed tablets), microencapsulated dusts or granules (AI

coated with a polymeric membrane to prevent premature degr adation), or

encapsulated water soluble packaging. They are formulated in various ways,

including:



### C mixing powdered or granular AIs with dry inert carriers;



### C spraying or mixing a liquid active ingredient onto a dry carrier;



### C soaking or using pressure and heat to force active ingredients into a solid

matrix;



### C mixing active ingredients with a monomer and allowing the mixture to

polymerize into a solid; and



### C drying or hardening an active ingredient solution into a solid form.

These dry pesticide products may be designed to be applied in solid form or

dissolved or emulsified in water or sol vent prior to application (USEPA,

1996).

Because there are many type s of dry pesticide products, dry pesticide

formulating lines can vary considerably. In general, though, dry formulatingAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 54 lines have tanks or containers to hold the active ingredients and inert raw

materials, and may include mixing tanks, ribbon blenders, extruding equipment,

high pressure and temperature tanks for impregnating solids with active

ing redient, vacuums or other types of drying equipment, tanks or bins for

storage of the form

ulated pesticide product, pelletizers, presses, milling

equipment, sieves, and sifters (USEPA, 1996).

Raw materials for dry pesticide products may be liquid or solid. Liquid raw

materials may be stor ed in rail tank cars, tank trucks, minibulks, drums, or

bottles. Dry raw materials may be stored in silos, rail cars , tank trucks,

minibulks, metal drums, fiber drums, bags, or boxes. Liquid raw materials may

be pumped, poured or sprayed into formulation vessels, while dry raw

materials are frequen

tly transferred to formulation equipment by screw

conveyors (consisting of a helix mounted on a shaft and turning in a trough),

elevators, or by pouring.

Dry formu lating lines may also include piping and pumps to move raw

materials from storage tanks to the formulation equipment, and to move

formulated pesticide product to the packaging equipment. Other items that may

be included in the dry pesticide product line are premixing tanks, tanks for

storing formulated product prior to packaging, stirrers, heaters, refrigeration

units on formulation and storage equipment, scales, and air pollution control

equipment (e.g., cyclones, filters, or baghouses) (USEPA, 1996).

Dry pesticide products may be packaged into rail tank cars, tank trucks, totes,

and minibulks, but are typically packaged into bags, boxes , and drums. As

with many liquid formulations, dry formulations are packaged by simply

transferring the final product into boxes, drums, jugs, or bags. Small quantities

or bags are typically packaged manually using a gravit y feed from the

formulating unit into the containers or bags. Larger quantities may be packaged

on an automated line, similar to liquid packaging lines.

Figure 17 illustrates a dry pesticide formulation line.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 55 Figure 17: Typical Process for Dry Formulating

Source: United States EPA, 1996

III.D.3. Aerosol Packaging

Some pesticide products (typically water-based or solvent-based liquids) are

packaged as aerosols, which can be applied to surfaces or dispersed in the air.

The produc t is placed in spray cans that are put under pressure and a

propellant is added, which forces the product out of the can in an aerosol

spray. An aerosol packaging line typically includes a filler, a c apper, a

propellant injector, and a United States Department of Transportation (DOT)

test bath. In the filler, formulated pesticide product is dispensed into empty

aerosol cans, in much the same way as the liquid packagi n g lines fill

containers. The cans are then sent to the capper, where a cap with a nozzle is

placed on the can. The can enters a separate room, where the propellent is

injected into the can, a vacuum is pulled, and the cap is crimped to make the

can air tight. In order to comply with DOT regulations on the transport of

pressurized containers, each can must then be tested for leaks and rupturing in

a DOT test bath. Test baths indicate leaks by the appearance of bubbles at the

point of leakage on the cylinder. The aerosol packaging line may also include

a can washer to remove residue from can exteriors prior to entering the test

bath (to reduce contaminant buildup in the bath), a dryer to dry can exteriors,

and machin

ery to package aerosol cans into boxes for shipment (USEPA,

1996).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 56 III.D.4. Pressurized Gas Formulating and Packaging

Some pesticide products are formulated and packaged as pressurized gases,

primarily for the purpose of soil fumigation. Soil fumigation is used where the

nematodic and fungal populations in soil prohibit successful seed planting.

Volatile general toxicants, such as low molecular weight halogenated

compounds, are typically injected into the soil before planting, but are also

occasionally used once plants have reached maturity (Kent, 1992).

The active and inert ingredients are received as liquid, pressurized liquids, or

g a ses, and are stored in tanks, tank trucks, rail cars, or minibulk storage

containers. Liquid

ingredients are placed in a holding tank prior to

formulation. Formulating and packaging operations for these products usually

occurs in one step in a closed-loop system. The ingredients are metered by

w eight through pressurized transfer lines into DOT-approved steel applicati o n

cylinders. Other equipment that may be included in a pressuri zed gas line

include pump and piping, and heating and refrigerating units to maintain gas

pressures and temperatures in storage (USEPA, 1996).

The cylinders may be refilled at a l ater date, after they have been tested to

ensure that they are still capable of cont aining pressurized fluids. DOT

requires hydrostatic pressure testing, as well as visual examination of the

cylinder (USEPA, 1996).

III.D.5. Repackaging

Repackaging operations are similar to packaging operations, except the “raw

material” is an already formulated product that has been packaged for sale.

Repackagers often purchase formulated pesticide products, transfer the product

to new containers with customer-specific labeling, and sell them to

distributors (USEPA, 1996).

A separate type of repackaging, called refilling, is usually performed by

agrichemical facilities that transfer pesticide products from bulk storage tanks

into minibulks. These refillable containers are typically constructed of plastic

and typically have capacities ranging from 100 to 500 gallons. Minibulks may

be owned by the refilling establishment, the pesticide registrant, or by the end

user. Production lines usually consist of a bulk storage tank, a minibulk tank

into which the product is repackaged, and any interconnecting hoses or piping.

The bulk storage tanks may be dedicated by product and clustered together in

a diked area. The products are dispensed to the minibulks by the use of manual

system or a computer-regulated system of pumps and meters (USEPA, 1996).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 57 Figure 18: Raw Material Flowchart for Principal Fertilizer Materials III.E. Raw Material Inputs and Pollution Outputs

Raw material inputs and pollution outputs of fertilizer products and pesticide

products differ considerably, and, therefore, are discussed separately below.

The pollution outputs are discussed both specifically by product as well as

generally by process since there are some similariti es in the fertilizer and

pesticide production processes and pollutant outputs.

III.E.1. Fertilizers

The primary raw materials for fert ilizer manufacturing are phosphate rock,

natural gas, sulfuric acid, and carbon dioxide. These materials are combined

by several methods and in different proportions to produce a variety of

fertilizer products, as described in section III.

Figure 18 summarizes the fertilizer material inputs for the principal fertilizer

products.

Source: Adapted from Manual on Fertilizer Statistics, Food and Agriculture Organization of

the United Nations, Rome 1991.

Because the basic fertilizer nutrients are found in many natural and manmade

materials, raw materials for fertilizers can also be derived from sources other

than the virgin materials described above. Common sources of fertilizer

ingredients are sew erage treatment sludges and certain industrial wastes.

Although these waste-derived fertilizers m ay contain essentially the sameAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 58 nutrients as fertilizers derived from virgin materials, they also may contain

additional constituents that were present in the waste material and which may

not be beneficial, or are potential ly harmful to crops, human health, or the

environment. Such constituents may enter the food chain or groundwater and

could become concentrated in the soil after repeated use. Lead, cadmium and

arsenic are some of the more common fertilizer ingredien ts that could be

harmful if sufficient quantities are present. It should be noted, however, that

fertilizers derived from virgin materials also have the potential to conta i n

harmful levels of the se constituents if significant quantities are naturally

present in the raw materials.

One waste material input which has received some attention recently is cement

kiln dust (CKD). Although there has been a considerable amount of research

conducted on CKD use as a fertilizer, existing applications of CKD for this

purpose have been mostly anecdotal, and there is only limited evidence that

commercial CKD use as a fertilizer is growing significantly (USEPA, 1993b).

Like agricultural lime , CKD is alkaline and contains a number of essential

plant nutrients. Because of these parallel characteristics, CKD has been used

as an agricultural soil amendment. CKD possesses significant fertilizer

potential, particularly because of its high potassium content. Soil scientists

have also suggested that other key plant nutrients contained in CKD, such as

calcium, phosphorous, and zinc, might be beneficial in some fertilizer

applications. However, some concern has been raised over hazardous wastes

in CKD (USEPA, 1993b).

Coal combustion by-products are also receiving attention for their potential

agricultural benefits., including alleviating soil trace elemental deficiencies,

modifying soil pH, and increasing levels of Ca and S, infiltration rates, depth

of rooting, and drought tolerance. Flue gas desulfurization residues, which

contain gypsum, have the potential to improve water use efficiency, product

quality, and productivity of soil-crop systems. The short term benefits of coal

combustion by-products usage has been demonstrated, however, long term

effects have not been documented. Future hazards and benefits are yet to be

determined (Korcak, 1995). Electric-ar c furnace dust is also used as a

fertilizer ingredient since it contains a number of trace elements required by

plants, including zinc.

Pollution outputs are summarized in terms of air emission, wastewater, and

residual wastes.

Air Emissions

Synthetic Ammonia

Air pollutants from the manufacture of synthetic anhydrous a mmonia are

emitted primarily from four process steps:Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 59 

### C regeneration of the desulfurization bed,



### C heating of the catalytic steam,



### C regeneration of carbon dioxide scrubbing solution,



### C steam stripping of process condensate.

More than 95 percent of the ammonia plants in the United States use activated

carbon fortified with metallic oxide additives for feedstock desulfurization.

Vented regeneration steam contains sulfur oxides (SO

x ) and hydrogen sulfide

(H

2 S), depending on the amount of oxygen in the steam. Regeneration may also

emit hydrocarbons and carbon mo n oxide (CO). The reformer, heated with

natural gas or fuel oil, may emit combustion products such as NO

x , CO, SO

x , hydrocarbons, and particulates (USEPA, 1993a).

Carbon dioxide (CO

2 ) is removed from the synthesis gas by scrubbing with

monoethanolamine (C

2 H

4 NH

2 OH) or hot potassium carbon a te solution.

Regeneration of this CO

2 scrubbing solution with steam produces emissions

of water, NH

3 , CO, CO

2 and monoethanolamine (USEPA, 1993a).

Cooling the synthesis gas after low temperature shift conversion fo rms a

condensate containing NH

3 , CO

2 , methanol (CH

3 OH), and trace metals.

Condensate steam strippers are used to remove NH 3 and methanol from the

water, and steam from this may be vented to the atmo sphere, emitting NH

3 , CO

2 , and methanol (USEPA, 1993a).

Nitric Acid

Emissions fro m nitric acid manufacturing consist primarily of NO and NO

2 (which account for visible emissions), and trace amounts of HNO

3 mist and

NH 3

. The major so u rce of nitrogen oxides is the tail gas from the acid

absorption tower. In general, the quantity of nitrogen oxides (NO

x ) emissions

is directly related to the kinetics of the nitric acid formation reaction and

absorption tower design. NO

x emissions can increase when there is:



### C insufficient air supply to the oxidizer and absorber,



### C low pressure, especially in the absorber,



### C high temperatures in the cooler/condenser and absorber,



### C production of an excessively high-strength product acid,



### C operation at high throughput rates,



### C faulty equipment such as compressors or pumps which lead to

lower pressures, leaks, and reduced plant efficiency (USEPA,

1993a).

Comparatively small amounts of nitrogen oxides are also los t from acid

concentratin

g plants. These losses (mostly NO

2 ) are from the condenser

system, but the emissions are small enough to be contro lled easily by

absorbers.

Acid mist emissions do not occur from the ta il gas of a properly operatedAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 60 plant. The small amounts that may be present in the absorber exit gas streams

are typically removed by a separator or collector prior to entering the catalytic

reduction unit or expander.

The acid production system and storage tanks can be a significant source of

visible NOx emissions at nitric acid plants. Emissions from acid storage tanks

are most likely to occur during tank filling (USEPA, 1993a).

Ammonium Nitrate

The primary air emission s from ammonium nitrate production plants are

particulate matter (ammonium nitrate and coating materials), ammonia and

nitric acid. Ammonia and nitric acid are em itted primarily from solution

formation and granulators. Particulate matter (largely as ammonium nitrate)

can be emitted from most of the process operations (USEPA, 1993a).

The emission sources in solution formation and concentration processes are

neu tralizers and evaporators, emitting nitric acid and ammonia. The vapor

stream off the top of the neutralization reactor is primarily steam with some

ammonia and NH

4 NO

3 particulates present. Specific plant operating

characteristics, however, make these emissions vary depending upon use of

excess ammonia or acid in the neutralizer. Particulate emissions from these

operations tend to be smaller in size than those from solids production and

handling processes and generally are recycled back to the process (USEPA,

1993a).

Emissions from solids formation processes are ammonium nitrate particulate

matter and ammonia. The sources of primary importance are prill towers (for

high dens ity and low density prills) and granulators (rotary drum and pan).

Emissions from prill towers result from carryover of fine particles and fume

by the prill cooling air flowing through the tower. These fine particles are

from microprill formation, attrition of prills colliding with the tower or one

another, and rapid transition of the ammonia nitrate between crystal states

(USEPA, 1993a).

Microprill formation resulting from partially plugged orifices of melt spray

d evices can increase fine dust loading and emissions. Certain designs

(spinning buckets) and practices (vibratio n of spray plates) help reduce

plugged orifices and thus microprill formation. High ambient air temperatures

can cause increased emissions because of entrainment as a result of higher air

flow required to cool prills and because of increased fume formation at the

higher temperatures (USEPA, 1993a).

Emissions from screening operations are generated by the attrition of the

ammonium nitrate solids against the screens and against one another. Almost

all screening operations used in the ammonium nitrate manufacturing industry

are enclosed or have a cover over the uppermost screen. Emissions are ducted

from the process for recovery or reuse (USEPA, 1993a).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 61 Bagging and bulk loading opera tions are also a source of particulate

emissions. Dust is emit

ted from each type of bagging process during final

filling when dust laden air is displaced from the bag by the ammonium nitrate.

The potential for emissions during bagging is greater for coated than for

uncoated material. It is expected that emissions from bagging operations are

primarily the kaolin, talc or diatomaceous earth coating matter. About 90

percent of solid ammonium nitrate produced domestically is bulk loaded.

While particulate emissions from bulk loading are not generally controlled,

visible emissions are within typical state regulatory requirements (below 20

percent opacity) (USEPA, 1993a).

Urea

Emissions from urea manufacture are mainly ammonia and particulate matter.

Formaldehyde and methanol, hazardous a ir pollutants, may be emitted if

additives are used. Formalin TM

, used as a formaldehyde additive, may contain

up to 15 percent methanol. Ammonia is emitted during the solution synthesis

and solids production processes. Particulate matter is emitted during all urea

processes (USEPA, 1993a).

In the synthesis process, some emission control is inherent in the recycle

process where carbamate gases and/or liquids are recovered and recycled.

Typical emission sources f r om the solution synthesis process are

noncond ensable vent streams from ammonium carbamate decomposers and

separators. Emissions from synthesis processes are generally combined with

emissions from the solution concentration process and are vented through a

common stack. Combined particulate emissions from urea synthesis and

concentration operations are small compared to particulate emissions from a

typical solids-producing urea plant. The synthesis and concentration

operations are usually uncontrolled except for recycle provisions to recover

ammonia (USEPA, 1993a).

Uncontrolled emission rates from prill towers may be affected by the

following factors:



### C product grade being produced



### C air flow rate through the tower



### C type of tower bed



### C ambient temperature and humidity (USEPA, 1993a)

The total of mass emissions per unit is usually lower f or feed grade prill

production than for agric ultural grade prills, due to lower airflows.

Uncontrolled particulate em ission rates for fluidized bed prill towers are

higher than those for nonfluidized bed prill towers making agricultural grade

prills, and are approximately equal to those for nonfluidized bed feed grade

prills (USEPA, 1993a).

Ambient air conditions can affect prill tower emissions. Available data

indicate that colder temperatures promote the formation of smaller particlesAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 62 in the prill tower exhaust. Since smaller particles are more difficult to

remove, the efficiency of prill tower control devices tends to decrease with

ambient temperatures. This can lead to higher emission levels for prill towers

operated during cold weather. Ambient humidity can also affect prill tower

emissions. Air flow rates must be increased with high humidity, and higher air

flow rates usually cause higher emissions (USEPA, 1993a).

In the solids screening process, dust is generated by abrasion of urea particles

and the vibration of the screening mechanisms. Therefore, almost all screening

operations used in the urea manufacturing industry are enclosed or are covered

over the uppermost screen. Emissions attributable to coating include entrained

clay dust from loading, inplant transfer, and leaks from the seals of the coater

(USEPA, 1993a).

Phosphoric Acid

Gaseous fluorides such as silicon tetrafluoride (SiF

4 ) and hydrogen fluoride

(HF) can be major emissions from wet process acid production. Phosphate

rock contains 3.5 to 4.0 percent fluorine. Part of the fluorine from the rock is

precipitated with the gypsum, another part is leached out with the phosphoric

acid product, and the remaining port i on is vaporized in the reactor or

evaporator. The relative quantities of fluorides in the filter acid and gypsum

depend on the type of rock and the operating conditions. Final disposition of

the volatilized fluoride depends on the design and operation of the p lant

(USEPA, 1993a).

The reactor in which phosphate rock is reacted with sulfuric acid is the main

source of emissions. Fluoride emissions accompany the air used to cool the

reactor slurry. Vacuum flash cooling has replaced the air cooling method to a

large extent, since emissions are minimized in the closed system.

Acid concentration

by evaporation is another source of fluoride emissions.

Approximately 20 to 40 percent of the fluorine originally present in the rock

vaporizes in this operation. Particulate matter co ntaining fluorides can be

emitted direct

ly from process equipment. About three to six percent of the

particulates can be fluorides, as measured at one facility (USEPA, 1993a).

Ammonium Phosphates

The major sources of air emissions f rom the production of ammonium

phosphatic fertilizers include th e reactor, the ammoniator-granulator, the dryer

and cooler, product sizing and material transfer, and the gypsum pond. The

reactor and ammoniator-granulator produce emissions of gaseous ammonia,

gaseous fluorides such as hydrogen fluoride (HF) a nd silicon tetrafluoride

(SiF

4 ), and particulate ammonium phosphates. These two exhaust streams are

generally combined and passed through primary an d secondary scrubbers

(USEPA, 1993a).

Exhaust gases from the dryer and cooler also contain ammonia, fluorides andAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 63 particulates, and these streams are commonly combined and passed through

cyclones and primary and secondary scrubbers. Particulate emissions and low

levels of ammonia and fluorides from product sizing and material transfer

operations are controlled the same way (USEPA, 1993a).

Normal Superphosphates

Sources of emissions at a normal superphosphate plant include rock unloading

and feeding, mixing opera t ions (in the reactor), storage (in the curing building),

and fertilizer handling operations. Rock unloading, handling and feeding

generate particulate emissions of phosphate rock dust. The mi xer, den and

curing building emit gases in the form of silicon tetrafluoride (SiF

4 ), hydrogen

fluoride (HF) and particulates composed of fluoride and phosphate material

(USEPA, 1993a).

Triple Superphosphates

Emissions of fluorine compounds and dust parti cles occur during the

production of granulated triple superphosphate . Silicon tetrafluoride (SiF

4 )

and hydrogen fluoride (HF) are released by the acidulation reaction and they

evolve from the reactors, den, granulator, and dryer. Evolution of fluoride is

essentially finished in the dryer and there is little fluoride evolved from the

storage pile in the curing building (USEPA, 1993a).

Sources of particulate emissions include the reactor, granulator, dryer,

screens, cooler, mills, and transfer conveyo rs. Additional emissions of

particulate result from the unloading, grinding, storage, and transfer of ground

phosphate rock. Fac ilities may also use limestone, which is received in

granulated form and does not require additional milling (USEPA, 1993a).

Wastewater

Wastewater from the fertilizer industry can be classified into four groups:



### C process effluents resulting from contact with gas, liquid s, or

solids



### C dedicated effluents which may be separated for use in one

process or for recycling at a controlled rate



### C effluents from general services such as cleaning or pretreatment



### C occasional effluents such as leaks or spills

A numb er of process wastewater streams from the nitrogenous fertilizer

industry have been identified. Frequently these wastewaters contain high

levels of nitrogenous compounds such as ammonia, nit rates, and organic

nitro gen. In ammonia production, wastewater is generated from process

condensate stripping. Ammonium nitrate manufacturing produces process

wastewater in the neutralization process, the evaporation unit, and air cooling

equipment. The vacuum condenser in urea plants is a source of wastewater.

Most scrubbing operations a re also a source of wastewater. Nitric acidAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 64 production generates relatively little wastewater since there is no process

wastewater source. Steam generated in nitrogenous fertilizer processing may

contain dissolved and suspended solids, alkalinity, and hardness (USEPA,

1974).

The most common methods for removing nitrogenous compounds include:



### C Biological nitrification/denitrification



### C Air or steam stripping



### C Ion exchange



### C Breakpoint chlorination (Water Environment Federation, 19 94).

The major source of wastewater from any phosphatic fertilizer manufacturing

process is referred to as “pond water.” Phosphoric acid production creates

large quantities of pond water for cooling of the process, concentration of the

pr oduct and for processing and storage of the gypsum byproduct. Gypsum

slurry water is decanted from the top of the gypsum stacks and sent to the

cooling pond through collection ditches (USEPA, 1993a). Through

evapo ration and recycling, contaminant concentrations in pond water can reach

several grams per liter of phosphates and fluoride. Additional elemental

contaminants in pond w ater which originate in phosphate rock are arsenic,

cadmium, uranium, vanadium, and radium (USEPA, 1974).

The most common industry trea tment for removing phosphorous is lime

neutralization and settling.

Occasional wastewater is generated in any fertilizer producti on facility by

leaks, spills, cleaning, maintenance, and laboratory tests. Cleaning of cooling

an d pollution control systems also produces process wastewater. Cooling

water may contain ammonia, sulfate, chloride, phosphate , chromate, and

dissolved solids which become concentrated through evaporation (USEPA,

1974). The laundry of workers’ clothing is another source of wastewater

originating outside the actual process.

Solid/Hazardous/Residual Wastes

One of the largest solid wastes in the ferti lizer industry is phosphogypsum

which is produced during phosphoric acid production . Approximately 1.5 tons

of phosphogypsum is produced per ton of phosphate rock fed, or 5 tons per ton

of phosphoric acid produced (expressed as P

2 O

5 ). Gypsum (calcium sulphate

dihydr ate) is a mineral which also occurs in nature. Phosphogypsum is

produced by the reaction of phosphate rock wi th sulphuric acid during the

process of producing phosphoric acid. The term “phosphogypsum” is used to

specify the particular gypsum arising from the acidulation of phosphate rock,

because it contains trace amounts of many of the mineral imp urities that

accompany phosphate rock. One of these impurities is radium, the parent of

radon. Other trace impurities found in phosphogypsum include arsenic, nickel,

cadmium, lead, aluminum, fluoride, and phosphoric acid. Mainly because ofAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 65 the radium content, the EPA restricts use of phosphogypsum and stipulates that

no phosphogypsum with radium over ten pCi/g can be removed from the stacks

adjacent to the agricultural chemical plants (UNEP, 1996).

The use of

waste phosphogypsum for other purposes has been widely

encouraged, but economic and/or quality problems and/or the demand for the

resulting products frequently inhibit or prevent this. These problems relate not

only to the impurities in the gypsum, but also to its relatively high moisture

content. Plasterboard, plaster, and cement are the main possibilities. It is also

possible to recycle phosphogypsum in sulphuric acid production. The ready

av ailability of natural gypsum and the high cost of gypsum-based sulphuric

acid, as well as the presence of trace contaminants, are the main obstacles to

its use (Miller, 1995). However, in countries where gypsum and other

sulphurous raw materials are scarce, phosphogypsum has been successfully

used for these purposes (UNEP, 1996).

Dumping gypsum on land is not possib le everywhere because the material

settles and dries slowly and requires an adequat e land area and certain

climatic and soil conditions where the stack is situated. Gypsum stacks are

being increasingly regulated in terms of lining and cap syste m s to prevent

contaminated leaching or runoff (UNEP, 1996).

A ll phosphate ores contain traces of radioactive elements and a numb er of

metals. During processing, thes e are partitioned between beneficiation process

wastes, the waste from the further processing into intermediate and finished

fertilizer production, and some end up in the final product (UNEP, 1996).

Cadmium is a heavy metal which accumula tes in living systems and can

become toxic above certain limits. The quantity of cadmium c ontained in a

phosphatic fertilizer depends on the source of the rock or waste material from

which it was made. The cadmium content of phosphate rocks varies from

almost zero to over 300 mg/kg P

2 O

5

. The acidula tion of phosphate rock

partitions the cadmium between the fertilizer product and the by-products,

mainly the phosphogypsum arising from phosphoric acid production (UNEP,

1996).

The fertilizer industry

has for some decades tried to develop cadmium

separation processes. Processes studied so far have shown serious limitations

and problems, with regard to saf e ty, cost, energy consumption or

environmental concerns. Currently available processes are expensive and are

not economically viable except for phosphates destined for human or animal

consumption, which have a greate r added value. A process developed for

removing cadmium from phosphoric acid, which is used in the production of

many phosphatic fertilizers (except normal supe rphosphate), has shown

promise on a laboratory scale, but needs further testing before being used on

an industrial scale (UNEP, 1996).Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 66 Off-specification product, spills, and dusts collected in emission c ontrol

systems are potential sources of residual wastes. Products are occasionally

suspended or canceled, leaving stockpiles of residual product. Other possible

sources of solid wastes are spent catalysts, spent containers, wastew a ter

treatment sludges, and spent filters. Many of these wastes are transported offsite for disposal. However, with good housekeeping techniques and dedicated

systems, some of these wastes may be recycled back into the process instead

of being wasted.

Catalysts used in the steam reforming process need to be replaced every two

to six years. Spent catalysts contain oxides of hexavalent chromium, zinc, iron,

and nickel. They are typically returned to the manufacturer or other metal

recovery companies for recycling and reclamation of valuable materials

(UNEP, 1996).

III.E.2. Pesticide Formulating, Packaging, and Repackaging

As listed below, input raw materials include the pesticide concentrates from

pesticide manufacturing plants as well as diluents and other che mical additives

used in the formulating process:



### C Active Ingredients

Organic/inorg anic pesticides: insecticides, herbicides, fungicides, and

others. (See Table 10.)



### C Formulation and preparation materials

Dry formulations:

organic flours, sulfu r, silicon oxide, lime, gypsum, talc,

pyrophyllite, bentonites, kaolins, attapulgite, and volcanic ash.

Liquid formulations:

S olvents: xylenes, kerosenes, methyl isobutyl ketone, amy l

acetate, and chlorinated solvents.

Propellants: carbon dioxide and nitrogen.

Others: wetting and dispersing agents, masking a gents,

deodorants, and emulsifiers (USEPA, 1990).

In addition to pesticide materials, some facilities listed under SIC code 2879

produce fertilizer/pesticide blends. A variety of nitrogenous, phosphatic, and

mixed fertilizers may be inputted into bulk blending tanks to pro duce these

combinations.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 67 Table 10: Approximate Quantities of Most Commonly Used Conventional

Pesticides in United States Agricultural Crop Production

Chemical 1995 Consumption

(Million pounds

active ingredient) Chemical 1995 Consumption

(Million pounds

active ingredient)

Atrazine 68-73 Chlorpyrifos 9-13

Metolachlor 59-64 Chlorothalonil 8-12

Metam Sodium 449-54 Copper Hydroxide 7-11

Methyl Bromide 39-46 Propanil 6-10

Dichloropropene 38-43 Dicamba 6-10

2,4-D 31-36 Terbufos 6-9

Glyphosate 25-30 Mancozeb 6-9

Cyanazine 24-29 Fluometuron 5-9

Pendimethalin 23-28 MSMA 4-8

Trifluralin 23-28 Bentazone 4-8

Acetochlor 22-27 Parathion 4-7

Alachlor 19-24 Sodium Chlorate 4-6

EPTC 9-13

Source: Pesticide Industry Sales and Usage, 1994 and 1995 Market Estimates , EPA, August

1997.

Air Emissions

Air emissions can

be generated throughout the pesticide formulating and

packaging processes, mostly when fine particulates of pesticide dust become

suspended in air while the materials are being moved, processed, or stored.

Most dust or granule blending mills are equipped wit h vacuum systems,

cyclones, and wet scrubbers to collect fugitive dust. Some vacuum systems are

dedicated to certain processes to facilitate reuse of the dust. Other systems are

used to collect dust from a number of areas (USEPA, 1990). Dust generated

by pesticide formulation processes contain AIs which may be toxic to humans

and the environment. Thus, they are important to contain.

Volatile organic compound (VOC) emissions such as xylene may also arise

when solvent-based liquid formulations are produced. VOC emissions may

also be generated during equipment cleaning with solvents.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 68 Wastewater

Process wastewater is defined in 40 CFR 122.2 as “any water which, during

manufacturing or processing, comes into direct contact with or results from the

production or use of any raw material, byproduct, intermediate product,

finished product, or waste product.” Wastewater from the pesticide

formulat ing industry is typically due to cleaning of equipment and related

process areas and not the actual formulating processes (USEPA, 1996).

Cleaning and decontaminating blending and liquid pesticide mixing and

storage equipment generates pesticide-contaminated wastewater or solvent,

depending upon whether the equipment is used to formulate water or solventbased pesticides. Decontamination is performed between batches of different

types of formulations to prevent cross contamination of the subsequent batch.

Decontamination is also performed prior to taking the equipment out of service

for maintenance. The decontamination is commonly performed using high

pressure water hoses equipped with spray nozzles, portable steam generators,

or by running a batch of solvent through the formulating equipment (USEPA,

1990).

Active ingredient containe r s, such as 55-gallon drums, are often

decontaminated by triple rinsing. The decontamination is usually performed

using a high pressure water hose equipped with a spray nozzle or a portable

steam jenny. The containers can then be sold or given to commercial recycling

firms, depending on label directions (USEPA, 1990).

Floor, wall, and equipment exterior washing is typic ally performed using

water hoses equipped with spray nozzles. It may also involve the use of mops

and squeegees. Wastewater is also generated by clean-up of spills and leaks.

Wastewater from these operations typically contains AIs, sol vents, and wetting

agents (USEPA, 1990). Other sources of wastewater include:



### C Pollution control scrubber water



### C Department of Transportation leak test water



### C Safety equipment wash water



### C Laboratory equipment wash water



### C Shower water



### C Laundry water



### C Fire protection test water



### C Contaminated precipitation runoff (USEPA, 1996)

Solid/Hazardous/Residual Wastes

R esidual wastes include containers and container liners potentially

contaminated with pesticides, as well as off-spec product, dust collected fromAgricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 69 emissi on control equipment, and product spills. Contaminated laboratory

equipment and protective workers clothing are other potential solid waste

sources (USEPA, 1990).

Decontamination of the sol i d-based pesticide blending mills may generate

solid diluent contaminated with pesticides. The diluent typically consists of

clay for dust mills and sand for granule mills (USEPA, 1990).

In case of pesticide products which have been suspended or canceled, there

may be existing stocks of these products remaining. EPA may allow the use

of existing stocks or prohibit such us e. State environmental agencies

occasionally collect unusable pesticides.

Procedures for pesticide management have been proposed by EPA, as

authorized under section 19 of the Federal Insecticide, Fung icide, and

Rodenticide Act (FIFRA). For more details, refer to section VI.C on pending

and proposed regulatory requirements.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 70 Table 11: Summary of Potential Pollution Outputs for the Agricultural

Chemical Industry

Process Air Emissions Process Wastewater Residual Waste

Nitric Acid

Absorption Tower NO, NO

2 , HNO

3 in

tailgas NA Spent tower

materials, trays

Solution

Formulation and

Granulation NH

3 , HNO

3

particulates Condensed steam with

NH

4 NO

3 and NH

3 NA

Solids Formation Particulates, NO

x ,

SiF

4 , HF NA Dusts

Regeneration of

Desulfurization

and Filter Beds Hydrocarbons, CO,

NH

3 , CO

2 Condensed steam, NH

3 ,

CO

2 Spent bed material

Screening Dust NA Mixed undersized

captured dusts, used

screens

Wet Process

Phosphoric Acid

Production SiF

4 , HF Pond water Gypsum

Unloading of

materials into

blending tanks Dust/particulates

released in transfer NA Leftover raw material

containers

Open processing

and storage

equipment VOC’s NA NA

Equipment and

facility cleaning NA Washwater, waste

solvent Waste sands and

clays, used mops/

squeegees/etc.

Laboratory

procedures VOC’s and dusts

released Washwater, lab testing

water Off-spec product

used for

testing/analysis

Spills and runoff Dust/particulates

released by spill Contaminated

rainfall/runoff Contaminated solid

product

Pollution control

systems NA Contaminated scrubber

water Spent filter material

Source: Guide to Pollution Prevention, The Pesticide Formulating Industry, Center for

Environmental Research Information, United States EPA, Washington D.C., 1990.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 71 III.F. Management of Chemicals in Wastestream

The P o llution Prevention Act of 1990 (PPA) requires facilities to report

information about the management of Toxic Release Inventor y (TRI) chemicals

in waste and efforts made to eliminate or reduce those quantities. These data

ha v e 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 1995-1998 and are meant to provide a basic understanding of the

quantities of waste handled 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 tre n ds in source reduction within individual

industri es and facilities, and for specific TRI chemicals. This information

could then be used as a tool in identifying opportunities for pollution

prevention or compliance assistance activities.

While the quantities reported for 1995 and 1996 are estimates of quantities

already managed, the quantities listed by facilities for 1997 and 1 998 are

projections only. The PPA requires these projections to encourage facilities

to consider future source re duction, not to establish any mandatory limits.

Future-year estimates are not commitments that facilities reporting under TRI

are required to meet.

. Fertilizers

Table 12 shows that the TRI reporting fertilizer manufacturing and mixing

facilit ies managed about 566 million pounds of production related wastes

(to tal quantity of TRI chemicals in the waste from routine production

operations in column B) in 1996. From the yearly data presented in column B,

the total quantity of production related TRI wastes decreased between 1995

and 1996. Production related wastes are projected to increase in 1997 and

1998. Note that the affects of production increase s and decreases on the

quantities of wastes generated are not evaluated here.

In 1996, about 84 percent of the industry’s TRI wastes were managed on-site

through recycling, energy recovery, or treatment as shown in columns C, D,

and E, respectively. Most of these on-site managed wastes were recycled onsite. There is a negligible amount (<1%) of wastes being transferred off-site

for recycling, e nergy recovery, or treatment. The remaining portion of the

production related wastes (12 percent in 1995 and 16 percent in 1996), shown

in column I, is either released to the environment through direct discharges to

air, land, water, and underground injection, or is transferred off-site for

disposal.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 72 Table 12: Source Reduction and Recycling Activity for the Fertilizer Industry as

Reported within TRI

A B

On-Site Off-Site I

Year Quantity of

ProductionRelated

Waste

(10 6 lbs.) a % Released and

Disposed

c Offsite C D E F G H

%

Recycled % Energy

Recovery % Treated %

Recycled % Energy

Recovery % Treated

1995 719 76% 8% 4% 0% 0% 0% 12%

1996 566 77% 1% 6% 0% 0% 0% 16%

1997 606 77% 1% 7% 0% 0% 0% 15%

1998 617 78% 1% 7% 0% 0% 0% 14%

Source: 1996 Toxics Release Inventory Database.

a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.

b Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related

wastes.

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

Pesticides and Miscellaneous Agricultural Chemicals

Table 13 shows that the TRI report ing pesticide and miscellaneous agricultural

chemicals facilities managed about 252 million pounds of production related

wastes (total quantity of TRI chemicals in the waste from routine production

operations in column B) in 1996. From the yearly data presented in column B,

the total quantity of production related TRI wastes increased between 1995

and 1996. Production related wastes were projected to continue to increase

in 1997 and 1998. Note that the affects of production increases and decreases

on the quantities of wastes generated are not evaluated here.

In 1996, about 95 percent of the industry’s TRI wastes were managed on-site

through recycling, energy recovery, or treatment as shown in columns C, D,

and E, respectively. Most of these on-site managed wastes were recycled onsite. A small portion of the remaining wastes (4% in 1996) are transferred

off-site for recycling, ener gy recovery, or treatment. The remaining one

percent of the production related wastes, shown in column I, is either released

to t he environment through direct discharges to air, land, water, and

underground injection, or is transferred off-site for disposal.Agricultural Chemical Industry Industrial Process Description

Sector Notebook Project September 2000 73 Table 13: Source Reduction and Recycling Activity for the Pesticide and

Miscellaneous Agricultural Chemicals Industry as Reported within TRI

A B

On-Site Off-Site I

Year Quantity of

ProductionRelated

Waste

(10 6 lbs.) a % Released and

Disposed

c Offsite C D E F G H

%

Recycled % Energy

Recovery %

Treated % Recycled % Energy

Recovery % Treated

1995 245 85% 0% 10% 2% 1% 1% 2%

1996 252 84% 0% 11% 2% 1% 1% 1%

1997 266 84% 0% 11% 1% 1% 2% 1%

1998 279 85% 0% 11% 1% 1% 1% 1%

Source: 1996 Toxics Release Inventory Database.

a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.

b Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related

wastes.

c Percentage of production related waste released to the environment and transferred off-site for disposal.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 74 THIS PAGE WAS INTENTIONALLY LEFT BLANKAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 75 IV. CHEMICAL RELEASE AND TRANSFER PROFILE

This section is designed to provide background information on the pollutant

releases that are reported by this industry in correlation with other industries.

The best source of c omparative pollutant release information is the Toxic

Release Inventory (TRI). Pursuant to the Emergency Planning and Community

Right-to-Know Act, TRI includes self-reported facility release and transfer

data for over 600 toxic chemicals. Facilities within SIC Codes 20 through 39

(manufacturing industries) that have mo re than 10 employees, and that are

above weight-based reporting thresholds are required to report TRI on-site

releases and off-site transfers. The information presented within the sector

notebooks is derived from the most recently available (1996) TRI reporting

year (which includes over 600 chemicals), and focuses primarily on the onsite releases reported by ea ch sector. Because TRI requires consistent

reporting regardless of sector, it is an excellent tool for drawing comparisons

across industries. TRI data provide the type, amount and media receptor of

each chemical released or transferred.

Although this sector n

otebook does not present historical information regarding

TRI chemical releases over time, please note that in general, toxic chemical

releases have been declining. In fact, according to the 1996 Toxic Release

Inventory Public Data Release, reported onsite releases of toxic chemicals to

the environment decreased by 5 percent (111.6 million pounds) between 1995

and 1996 (not including chemicals added and removed from the TRI chemical

list during this period). Reported releases dropped by 48 percent between

1988 and 1996. Reported transfers of TRI chemicals to off-site locations

increased by 5 percent (14.3 million pounds) between 1995 and 1996. 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 Rel ease Inventory

System database (for user support call 202-260-1531).

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

indicator of chemical release within each indu strial 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

Certain limitations exist regarding TRI data. Within some sectors, (e.g. dry

cleaning, printing and transportation equipment cleaning) 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.

For these sectors, release information from other sources has been included.

In addition, many facilities report TRI more under than one SIC code reflecting

the multiple operations carried out onsite whether or not the operation is theAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 76 facilities primary area of business as reported to the U.S. Census B u reau.

Reported chemicals are limited to the approximately 600 TRI chemicals. A

portion of the emissions from agricultural chemical facilities, therefore, are not

captured by TRI. Also, reported releases and transfers may or may not all be

associated with the industrial operations described in this notebook.

The reader should also be aware that TRI “pounds released” data presented

within the notebooks is not equivalent to a “risk” ranking for each industry.

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

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

an approach to assign toxicological weightings 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 five chemicals (by weight)

reported by each industry.

Definitions Associated With Section IV Data Tables

General Definitions

SIC Code

-- is the Standard Industrial Classification (SIC) code, 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 th resholds.

Manufacturing facilities are defined as facilities in Standard I ndustrial

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

chemicals that are on the EP A’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 on-site discharges of a toxic chemical to the environment.

This includes emissions to the air, discharges to bodies of water, releases at

the facility to land, as well as contained disposal into underground injection

wells.

Releases to Air (Point and Fugitive Air Emissions)

-- include all air

emissions from industry activity. Point emissions occur through confined air

streams as found in stacks, vents, ducts, or pipes. Fugitive emissions includeAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 77 equipment leaks, evaporative losses from surface impoundments and spills,

and releases from building ventilation systems.

Releases to Water (Surface Water Discharges)

-- encompass any releases

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

Releases due to runoff, including storm water runoff, are also reportable to

TRI.

Releases to Land

-- occur within the boundaries of the repor ting facility.

Releases to land include disposal of toxic chemicals in landfills, land

treatment/application farming, surface impoundments, and other disposal on

land (such as spills, leaks, or waste piles).

Underground Injection

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

well for the purpose of waste disposal. Wastes containing TRI chemicals are

injected into either Class I wells or Class V wells. Class I wells are used to

inject liquid hazardous wastes or dispose of indus trial and municipal

wastewaters beneath the lowermost underground sourc e of drinking water.

Class V wells are generally used to inject non-hazardous fluid into or above

an underground source of drinking water. TRI reporting does not currently

distinguish b etween these two types of wells, although there are important

differences in environmental impact between these two methods of injection.

TRANSFERS

-- are transfers of toxic chemicals in wastes to a facility that is

geographically or physically separate from the facility reporting under TRI.

Chemicals reported to TRI as transferred are sent to off-site facilities for the

purpose of recycling, energy recovery, treatment, or disposal. The quantities

reported represent a movemen t of the chemical away from the reporting

facility. Except for off-site transfers for disposal, the reported quantities do

not necessarily represent entry of the chemical into the environment.

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

to a publicly owned treatments works (POTW). Treatment or removal of a

chemical from the wastewater depends on the nature of the chemical, as well

as the treatment methods present at the POTW. Not all TRI chemicals can be

treate d or removed by a POTW. Some chemicals, such as metals, may be

removed but not destroyed and may be disposed of in landfills or discharged

to receiving waters.

Transfers to Recycling

-- are w astes sent off-site for the purposes of

regenerating or recovery by a variety of recycling methods, including solvent

recovery, metals recovery, and acid regeneration. Once these chemicals have

been recycled, they may be returned to the originating facili ty or sold

commercially.

Transfers to Energy Recovery

-- are wastes combusted off-site in industrialAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 78 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 to be treated through a

variety of methods, including neutralizat ion, 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 f acility for disposal,

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

IV.A. EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural Chemical

Industry

This section summarizes the TRI data of fertilizer manufacturing and mixing

facilities reporting SIC codes 2873, 2874, or 2875 as their primary SIC code

and of pesticide and miscellaneous agricultural chemicals formulating

facilities reporting SIC code 2879 as their primary SIC code.

According to the 1995 Toxics Release Inventory (TRI) data, 190 fertilizer and

pesticide facilities reporting SIC 2873, 2874, 2875, or 2879 released (to the

air, water, or land) and transferred (shipped off-site or discharged to sewers)

a total of 106 million pounds of toxic chemicals during calendar year 1996.

This represents approximately 2 percent of the 5.6 billion pounds of releases

and transfers from all manufacturers (SICs 20-39) reporting to TRI that year.

The top two chemicals released by weight are ammonia and phosphoric acid

(both from fertilizer manufacturing). These two account for about 89 percent

(82 million pounds) of the industry’s total releases. Xylene, methanol, and

ethylbenzene are the three to p chemicals transferred by weight (all from

pesticide formulating). These three account for about 71 percent (9 million

pounds) of the total TRI chemicals transferred by the industries. The

variability in facilities’ TRI chemical profiles may be attributed to the variety

of processes and products in the industries. Eighty-seven percent of the 243

different chemicals reported were reported by fewer than 10 facilities.

Fertilizers (SIC 2873, 2874, 2875)

According to 1996 TRI data, fertilizer manufacturing and mixing facilities

released and transferred approximately 93 million pounds of pollutants during

calendar year 1996. One hundred and ninety facilities reported TRI emissions

for 46 chemicals. Only 13 of the 46 chemicals (28 percent) were reported (as

releases and/or transfers) by ten or more facilities, evidence of the diversity

of the industry. Fertilizer facilities released an average of 481,000 pounds per

facility and transferred an av erage of 8,000 pounds per facility. The high

release per facility values are, in a large part, a result of significant releases

for ammonia and phosphoric acid from seventy or more facilities.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 79 Releases

Table 14 presents the number and weights of chemicals released by fertilizer

m anufacturing and mixing facilities reporting SIC 2873, 2874, and 287 5 in

1996. The total quantity of releases was 91.3 million pounds or 98 percent

of the total weight of chemicals reported to TRI by the fertilizer industry (i.e.,

releases and transfers). The top chemical released by this industry is

ammonia, accounting for 54 percent of the total releases. Phosphoric acid is

the next largest release at 35 percent of the total. Fifty-eight percent of all TRI

releases in the fertilizer industry were air emissions, 53 percent as point

source and 5 percent as fugitive. Ammonia accounts for 91 percent of air

releases. The majority of the other releases were land disposed (32 percent)

with phosphori c acid accounting for 99 percent of land disposals. The

remaining nine percent was released a s water discharges or underground

injections.

Transfers

Table 15 presents the number and weights of chemicals transferred off-site by

fertilizer manufacturing and mixing facilities rep orting SIC 2873, 2874, or

2875 in 1996. The total amount of transfers was about 1.5 million pounds or

only two percent of the total amount of chemicals reporte d to TRI by the

fertilizer industry (i.e., releases and tran sfers). Transfers to recycling

facilities accounted for the largest amount, 51 percent of the total transfers.

The next greatest percentage went for disposal and the rest to treatment

facilities. No energy recovery transfers were reported for this industry.

Copper compounds, phosphoric acid, and zinc compounds represented the

largest transfers (primarily to recycling), as 60 percent of the total transfers.

Ammonia only accounted for 4 percent of the transfers compared to 54 percent

of releases.

Pesticides and Miscellaneous Agricultural Chemicals (SIC 2879)

According to 1996 TRI data, pe sticide formulating facilities released and

transferred approximately 13 million pounds of poll utants during calendar year

1996. One hundred and ninety-three facilities reported TRI emissions for 197

chemicals in 1996. Only 18 (9 percent) of these chemicals were reported by

ten or more facilities, evidence of the particularly diverse nature of the

industry. Pesticide formulating facilities released an average of 10,000

pounds of pollutants per facility and transferred an average of 59,000 pounds

per facility. The high average transfer per facility is due mostly to high

average xylene, ethylbenzene, and methanol transfers.

Releases

Table 16 presents the number and weights of chemicals released by pesticide

and miscellaneous agricultural chemicals formulating facilities reporting SICAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 80 2 879 in 1996. The total amount of releases was 2.0 million pounds or 15

percent of the total quantity of TRI chemicals reported by the pesticide and

miscellaneous agricult

ural chemicals industry (i.e., releases and transfers).

This is substantially less than the 98 percent of reported chemicals released

by the fertilizer industry. The top two chemicals released by this industry are

methanol (23 percent of releases) and dichloromethane (13 percent of

releases).

About 69 percent (1.4 million pounds) of all the chemicals released by the

pesticide industry were released to air in the form of point source emissions

(50 percent) and fugitive air releases (19 percent). Air releases were

primarily comprised of dichloromethane, carbon disulfide, and methyl isobutyl

ketone. Approximately 29 percent of the releases were by underground

injection, and the remaining releases were to water (2 percent) and land

disposal (1 percent). The relatively large number of chemicals reported to

TRI under SIC 2879 compared to the fertilizer industry illustrates the variety

of chemical formulations produced by the pesticide industry.

Transfers

T able 17 presents the number and weights of chemical t ransfers by the

pesticide and miscellaneous agricultural chem icals formulating facilities

reporting SIC 2879 in 1996. The total amount of transfers off-site was 11.3

million pounds or 85 percent of the total amount of chemicals reported to TRI

by the pesticide industry (i.e., releases and transfers). Xylene, methanol, and

ethylbenzene accoun ted for 58, 12, and 10 percent, respectively, of the

chemical TRI transfers. Transfers to recycling facilities accounted for the

largest quantity (51 percent) although only eight facilities reported recycling

transfers. Xylene accounted for 84 percent of all recycling transfers. Energy

recovery a nd treatment accounted for 23 and 31 percent respectively. The

remainder of transfers consisted of off-site disposals.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 81 Table 14: 1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)

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

Ammonia 106 4,590,371 43,967,432 427,065 539,900 78,814 49,603,582 467,958

Phosphoric Acid 72 1,452 8,631 2,939,394 0 29,071,310 32,020,787 444,733

Zinc Compounds 56 3,946 2,969 7,817 65 4,023 18,820 336

Manganese Compounds 43 5,292 1,696 1,500 0 500 8,988 209

Nitrate Compounds 42 1,529 261,250 3,108,211 971,850 125,960 4,468,800 106,400

Copper Compounds 37 1,477 525 1,443 60 528 4,033 109

Sulfuric Acid (1994 and after "Acid Aerosols"

Only) 32 3,237 1,435,613 5 15,000 25,587 1,479,442 46,233

Nitric Acid 30 22,388 17,418 10 0 7,655 47,471 1,582

Chlorine 30 5,345 25,787 7,818 0 0 38,950 1,298

Methanol 20 38,447 3,068,775 63,362 20 185 3,170,789 158,539

Formaldehyde 13 730 20,874 10 220 5 21,839 1,680

Chromium Compounds 11 251 0 536 90 1,430 2,307 210

Nickel Compounds 10 255 250 795 270 565 2,135 214

Copper 8 5 10 0 0 0 15 2

Zinc (Fume or Dust) 8 5 8 0 0 0 13 2

Lead Compounds 7 17 270 510 0 0 797 114

Hydrogen Fluoride 7 15,325 13,820 15 0 3,309 32,469 4,638

Diethanolamine 6 5 7,907 31,470 0 0 39,382 6,564

2,4-D 5 21 251 0 0 0 272 54

Manganese 5 5 10 0 0 0 15 3

Diazinon 4 0 2 0 0 0 2 1

Benfluralin 4 445 258 0 0 0 703 176

Atrazine 3 140 0 0 0 0 140 47

Trifluralin 2 239 0 0 0 0 239 120

Chromium 2 400 0 0 0 0 400 200

Cadmium Compounds 1

. . . . . . . Cobalt Compounds 1

. . . . . . . Diisocyanates 1 10 70 0 0 0 80 80

Certain Glycol Ethers 1 0 0 0 0 0 0 0

Carbaryl 1 5 5 0 0 0 10 10

N-butyl Alcohol 1 5 0 0 0 0 5 5

Quintozene 1 0 0 0 0 0 0 0

Mecoprop 1 10 250 0 0 0 260 260

Methoxone 1 5 250 0 0 0 255 255

Ethylene Glycol 1 750 0 13,000 0 250 14,000 14,000

Methyl Isobutyl Ketone 1 73,325 16,241 0 0 0 89,566 89,566

Dicofol 1 250 0

. 0 0 250 250

2,4-DP 1 7 250 0 0 0 257 257

Asbestos (Friable) 1 0 0 0 0 0 0 0

Dicamba 1 12 250 0 0 0 262 262

Nickel 1 400 0 0 0 0 400 400

Vanadium (Fume or Dust) 1

. . . . . . . Hydrochloric Acid (1995 and after "Acid

Aerosols" Only) 1 0 0 0 260,000 0 260,000 260,000

Thiophanate-methyl 1 0 0 0 0 0 0 0

Pendimethalin 1 0 0 0 0 0 0 0

Oxyfluorfen 1 0 0 0 0 0 0 0

_________ _________ _________ _________ _________ _________ _________ _________ 190** 4,766,111 48,851,072 6,603,991 1,787,475 29,320,121 91,327,740 480,672

** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 82 Table 15: 1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)

by Number and Facilities Reporting (Transfers reported in pounds/year)

Chemical Name #

Reporting

Chemical Potw

Transfers Disposal

Transfers Recycling

Transfers Treatment

Transfers Energy

Recovery

Transfers Total

Transfers Avg

Transfer

Per

Facility

Ammonia 106 51600

. . 11477

. 63077 595

Phosphoric Acid 72 0 289528

. 418

. 289946 4,027

Zinc Compounds 56 5 1060 179327 45834

. 226226 4,040

Manganese Compounds 43 0 1000

. 3834

. 4834 112

Nitrate Compounds 42 95000

. 14657 750

. 110407 2,629

Copper Compounds 37 0 11861 384419 11000

. 407280 11,008

Sulfuric Acid (1994 and after "Acid Aerosols"

Only) 32 0

. . . . 0 0

Nitric Acid 30 0 250

. . . 250 8

Chlorine 30 25

. . . . 25 1

Methanol 20 1542

. . . . 1542 77

Formaldehyde 13 250

. . . . 250 19

Chromium Compounds 11 0 14207 63230

. . 77437 7,040

Nickel Compounds 10 0

. 81600 20000

. 101600 10,160

Copper 8 0

. 14657

. . 14657 1,832

Zinc (Fume or Dust) 8 0 505 14657 5

. 15167 1,896

Lead Compounds 7 0 10

. . . 10 1

Hydrogen Fluoride 7 0

. . . . 0 0

Diethanolamine 6 19940

. . 20000

. 39940 6,657

2,4-D 5 0

. . 4613

. 4613 923

Manganese 5 0

. . . . 0 0

Diazinon 4 0

. . 4608

. 4608 1,152

Benfluralin 4 0

. . 1250

. 1250 313

Atrazine 3 0

. . 107880

. 107880 35,960

Trifluralin 2 0

. . . . 0 0

Chromium 2 0

. 14657

. . 14657 7,329

Cadmium Compounds 1

. . . . . . . Cobalt Compounds 1

. . . . . . . Diisocyanates 1 0

. . . . 0 0

Certain Glycol Ethers 1 0

. . . . 0 0

Carbaryl 1 0

. . 591

. 591 591

N-butyl Alcohol 1 0

. . . . 0 0

Quintozene 1 0

. . 4358

. 4358 4,358

Mecoprop 1 0

. . 250

. 250 250

Methoxone 1 0

. . 250

. 250 250

Ethylene Glycol 1 0

. 185

. . 185 185

Methyl Isobutyl Ketone 1 0

. . . . 0 0

Dicofol 1 0 250

. . . 250 250

2,4-DP 1 0

. . 250

. 250 250

Asbestos (Friable) 1 0 19300

. . . 19300 19,300

Dicamba 1 0

. . 250

. 250 250

Nickel 1 0

. 14657

. . 14657 14,657

Vanadium (Fume or Dust) 1

. . . . . . . Hydrochloric Acid (1995 and after "Acid

Aerosols" Only) 1 0

. . . . 0 0

Thiophanate-methyl 1 0

. . 4358

. 4358 4,358

Pendimethalin 1 0

. . 4358

. 4358 4,358

Oxyfluorfen 1 0

. . 4358

. 4358 4,358

_________ _________ _________ _________ _________ _________ _________ _________ 190** 168,362 337,971 782,046 250,692 0 1,539,071 8,100

** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 83 Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) 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

1,2,4-trimethylbenzene 24 5310 3185 0 0 0 8495 354

Xylene (Mixed Isomers) 24 24494 16327 0 17760 0 58581 2,441

Ethylene Glycol 22 7856 819 2521 2290 7922 21408 973

Naphthalene 21 4536 3402 17 0 20 7975 380

Malathion 17 571 280 10 0 0 861 51

Diazinon 17 21 227 10 0 0 258 15

Ammonia 14 20529 36889 4908 2300 360 64986 4,642

2,4-D 13 1926 1535 5 0 255 3721 286

Carbaryl 12 1005 9005 10 0 2500 12520 1,043

Methanol 12 12434 35850 8217 400300 51 456852 38,071

N-butyl Alcohol 12 1498 1668 0 0 0 3166 264

Captan 12 519 12106 5 5 0 12635 1,053

Quintozene 11 1050 561 0 0 0 1611 146

Trifluralin 11 1304 2578 87 0 0 3969 361

Chlorothalonil 11 622 1005 0 0 1670 3297 300

2,4-d 2-ethylhexyl Ester 11 2160 1065 5 0 0 3230 294

Ethylbenzene 10 1065 421 0 0 0 1486 149

Atrazine 10 4000 2430 5 1 0 6436 644

Copper Compounds 9 547 188 11 0 5 751 83

Zinc Compounds 9 2299 2307 0 0 0 4606 512

Dimethylamine 9 3547 7560 0 250 0 11357 1,262

Arsenic Compounds 8 267 1089 14 0 0 1370 171

Certain Glycol Ethers 8 10501 250 0 0 0 10751 1,344

Lindane 8 255 255 5 0 250 765 96

Bromomethane 8 9398 63421 0 0 0 72819 9,102

Chloropicrin 8 2240 5835 0 0 0 8075 1,009

Cumene 8 108 78 0 0 0 186 23

Permethrin 8 976 509 0 0 0 1485 186

Dicamba 7 348 324 132 59200 0 60004 8,572

Piperonyl Butoxide 6 35 6 0 0 0 41 7

Dimethoate 6 225 260 10 0 0 495 83

Mecoprop 6 510 920 0 0 255 1685 281

Toluene 6 11676 27350 39 536 71 39672 6,612

Thiram 6 510 1000 0 0 0 1510 252

Methyl Parathion 6 716 312 0 0 0 1028 171

Diuron 6 261 1250 8 0 0 1519 253

Prometryn 6 250 268 0 0 0 518 86

Chlorine 6 6020 2455 0 5 0 8480 1,413

Manganese Compounds 5 6657 75 0 0 0 6732 1,346

Nitrate Compounds 5 5 6 22000 0 0 22011 4,402

1,1,1-trichloroethane 5 1729 7400 0 0 0 9129 1,826

Carbon Disulfide 5 6817 112994 0 5 0 119816 23,963

Methoxone 5 265 510 250 0 250 1275 255

Metham Sodium 5 1266 258 1 0 2 1527 305

N-methyl-2-pyrrolidone 5 310 10 5 750 5 1080 216

Carbofuran 5 22 274 1 0 0 297 59

Bromoxynil Octanoate 5 270 251 0 0 0 521 104

Maneb 5 0 0 0 0 0 0 0

Cyanazine 5 285 1625 0 0 0 1910 382

Formaldehyde 4 3020 8018 1083 0 5 12126 3,032

Chloromethane 4 7434 82165 0 0 9 89608 22,402

Dichloromethane 4 12585 256135 100 0 23 268843 67,211

O-xylene 4 5602 35250 5 0 5 40862 10,216

Methyl Isobutyl Ketone 4 105310 58755 5 0 5 164075 41,019

Simazine 4 1005 1005 5 0 0 2015 504

Hydrochloric Acid (1995 and after "Acid

Aerosols" Only) 4 3698 48257 0 0 56 52011 13,003

Phosphoric Acid 4 438 0 0 0 0 438 110

Sulfuric Acid (1994 and after "Acid

Aerosols" Only) 4 1009 1 0 0 15 1025 256

Metribuzin 4 2 1010 5 0 0 1017 254

Acephate 4 255 1250 0 0 0 1505 376

Chromium Compounds 3 250 88 3 0 0 341 114

Chlorodifluoromethane 3 11406 2441 0 0 0 13847 4,616

Maleic Anhydride 3 1079 2385 5 0 0 3469 1,156

M-xylene 3 508 250 0 0 0 758 253

Dicofol 3 210 0 0 0 0 210 70

Aldicarb 3 21 1205 0 0 5 1231 410

Linuron 3 5 5 5 0 0 15 5

Ethyl Dipropylthiocarbamate 3 6706 619 2 29 0 7356 2,452

Paraquat Dichloride 3 500 500 0 0 0 1000 333Agricultural Chemical Industry Chemical Releases and Transfers

Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) 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

Sector Notebook Project September 2000 84 Propachlor 3 0 0 0 0 0 0 0

Fluometuron 3 260 512 0 0 0 772 257

Dimethylamine Dicamba 3 580 5 0 0 5 590 197

Carboxin 3 8 0 0 0 0 8 3

Copper 3 0 5 0 0 0 5 2

Ethoprop 3 250 615 0 0 0 865 288

Thiophanate-methyl 3 70 9 0 0 0 79 26

Pendimethalin 3 970 260 22 0 140 1392 464

Hexazinone 3 17 283 0 0 0 300 100

Ethylenebisdithiocarbamic Acid, Salts and

Esters 2 1057 57 0 0 0 1114 557

Trichlorfon 2

. . . . . . . Parathion 2

. . . . . . . Dichlorvos 2 0 0 0 0 0 0 0

S,s,s-tributyltrithiophosphate 2 1325 473 2 0 8 1808 904

2,4-db 2 470 250 0 0 0 720 360

1,4-dichlorobenzene 2 340 1371 0 0 0 1711 856

1,2-dichloroethane 2 6300 57000 33 0 250 63583 31,792

Chlorobenzene 2 320 0 0 0 0 320 160

Phenol 2 533 0 1 0 0 534 267

Diethanolamine 2 255 255 0 0 0 510 255

2,4-dp 2 250 5 0 0 5 260 130

Naled 2 0 50 0 0 0 50 25

Hydrazine 2 201 12 0 0 0 213 107

1,3-dichloropropylene 2 2301 120 0 0 0 2421 1,211

Propanil 2 250 2627 0 0 0 2877 1,439

Ametryn 2 255 298 5 0 0 558 279

Cycloate 2 0 49 1 2 0 52 26

Bromoxynil 2 5 10 0 0 0 15 8

2,4-d Butoxyethyl Ester 2 262 401 0 0 0 663 332

Sodium Dicamba 2 5 750 0 0 0 755 378

Dipotassium Endothall 2 39 4 0 0 0 43 22

Molinate 2 315 271 1 0 0 587 294

Chlorpyrifos Methyl 2 5 5 0 0 0 10 5

Zinc (Fume or Dust) 2 250 0

. 0 0 250 125

Nitric Acid 2 4000 398 5 0 280 4683 2,342

Resmethrin 2 1 0 0 0 0 1 1

Desmedipham 2 15 0 0 0 0 15 8

Thiophanate Ethyl 2

. . . . . . . Thiobencarb 2 530 281 0 0 0 811 406

Thiodicarb 2 250 1000 0 0 250 1500 750

Propiconazole 2 5 5 0 0 0 10 5

Cyfluthrin 2 3 13 0 0 350 366 183

Fomesafen 2 255 250 0 0 0 505 253

Quizalofop-ethyl 2 1 0

. 0 0 1 1

Lactofen 2 847 29 0 0 0 876 438

Bifenthrin 2 6 1 0 0 0 7 4

Myclobutanil 2

. . . . . . . Antimony Compounds 1 0 2 0 0 0 2 2

Chlorophenols 1 250 250 0 73400 0 73900 73,900

Cyanide Compounds 1 15 41 5 0 5 66 66

Diisocyanates 1

. . . . . . . Lead Compounds 1 130 139 0 0 0 269 269

Carbon Tetrachloride 1 66 41000 0 5 0 41071 41,071

Formic Acid 1 810 700 29 0 0 1539 1,539

Isopropyl Alcohol (Manufacturing,

Strong-acid Process Only, No Supplies) 1 0 15 0 0 0 15 15

N,n-dimethylformamide 1 1 38 0 0 0 39 39

Methoxychlor 1 5 5 0 0 0 10 10

Vinyl Chloride 1 552 644 0 0 0 1196 1,196

Tert-butyl Alcohol 1 20 121 0 0 0 141 141

2-methyllactonitrile 1 0 180 0 0 0 180 180

Triphenyltin Hydroxide 1

. . . . . . . Hexachlorocyclopentadiene 1 5 5 0 250 0 260 260

Dicyclopentadiene 1 141 562 0 0 0 703 703

Dimethyl Sulfate 1

. . . . . . . Methyl Ethyl Ketone 1 32 240 0 0 0 272 272

Dichloran 1

. . . . . . . P-xylene 1 5 5 0 0 0 10 10

1,3-butadiene 1 77 1200 0 0 0 1277 1,277

Cyclohexanol 1 0 18 0 0 0 18 18Agricultural Chemical Industry Chemical Releases and Transfers

Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) 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

Sector Notebook Project September 2000 85 N-hexane 1 2910 5560 0 0 0 8470 8,470

Pyridine 1 4836 5617 0 0 0 10453 10,453

Propoxur 1

. . . . . . . Di(2-ethylhexyl) Phthalate 1 10 25 0 0 0 35 35

Hexachlorobenzene 1 5 0 0 0 0 5 5

1,2,4-trichlorobenzene 1 8000 750 0 750 0 9500 9,500

2,4-dichlorophenol 1 2630 250 0 15390 0 18270 18,270

Triethylamine 1 3298 101 0 0 0 3399 3,399

Hydroquinone 1 250 5 0 0 0 255 255

Folpet 1 0 5 0 0 0 5 5

Merphos 1 200 0 0 0 0 200 200

Oxydemeton Methyl 1

. . . . . . . Bromacil 1 6 0 0 0 0 6 6

Methyl Isothiocyanate 1 0 0 0 0 0 0 0

Perchloromethyl Mercaptan 1 0 510 0 0 0 510 510

Methyl Isocyanate 1 0 0 0 0 0 0 0

Pebulate 1 250 250 0

. 0 500 500

Benfluralin 1

. . . . . . . Nitrapyrin 1

. . . . . . . Triallate 1 250 250 0 0 0 500 500

Dodine 1 5 5 0 0 0 10 10

Dimethyl Chlorothiophosphate 1 0 0 0 0 0 0 0

Temephos 1

. . . . . . . Terbacil 1

. . . . . . . Hydrogen Fluoride 1 0 0 0 0 0 0 0

Bromine 1 0 0 0 0 0 0 0

Mevinphos 1 0 0 0 0 0 0 0

Phosphine 1 0 1076 0 0 0 1076 1,076

Creosote 1 15 25 0 0 0 40 40

Zineb 1

. . . . . . . Fenbutatin Oxide 1

. . . . . . . Alachlor 1 2100 0 0 0 0 2100 2,100

Benomyl 1

. . . . . . . Oryzalin 1

. . . . . . . Oxydiazon 1 5 250 0 0 0 255 255

Aluminum Phosphide 1

. . . . . . . Bendiocarb 1

. . . . . . . Pronamide 1 5 250 0 0 0 255 255

Toluene Diisocyanate (Mixed Isomers) 1

. . . . . . . Propetamphos 1 5 5 0 0 250 260 260

Amitraz 1

. . . . . . . Tebuthiuron 1 0 5 0 0 0 5 5

Diflubenzuron 1

. . . . . . . Sulprofos 1

. . . . . . . Dinocap 1

. . . . . . . Fenpropathrin 1

. . . . . . . Profenofos 1

. . . . . . . Oxyfluorfen 1

. . . . . . . Triadimefon 1

. . . . . . . Vinclozolin 1

. . . . . . . Fenvalerate 1 1 0 0 0 0 1 1

Dimethipin 1

. . . . . . . Triclopyr Triethylammonium Salt 1 0 6 0 0 0 6 6

Fenarimol 1

. . . . . . . Acifluorfen, Sodium Salt 1 0 0 2 0 5 7 7

Chlorsulfuron 1 0 1

. 0 0 1 1

Fluvalinate 1

. . . . . . . Chlorimuron Ethyl 1 0 1

. 0 0 1 1

Tribenuron Methyl 1 0 1

. 0 0 1 1

_________ _________ _________ _________ _________ _________ _________ _________ 193** 369,954 995,519 39,600 573,228 15,287 1,993,588 10,329

** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 86 Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)

by Number and Facilities Reporting (Transfers reported in pounds/year)

Chemical Name #

Reporting

Chemical Potw

Transfers Disposal

Transfers Recycling

Transfers Treatment

Transfers Energy

Recovery

Transfers Total

Transfers Avg

Transfer

Per

Facility

1,2,4-trimethylbenzene 24 5 475

. 43314

. 43794 1,825

Xylene (Mixed Isomers) 24 9 2599 4851510 731777 1020414 6606309 275,263

Ethylene Glycol 22 463 3600 16070 11478

. 31611 1,437

Naphthalene 21 0 823

. 6962 45 7830 373

Malathion 17 0

. . 1207

. 1207 71

Diazinon 17 0

. . 3370

. 3370 198

Ammonia 14 25397

. . 47248

. 72645 5,189

2,4-d 13 263 6017

. 8700

. 14980 1,152

Carbaryl 12 5 2750

. 61666

. 64421 5,368

Methanol 12 4367 5

. 126038 1186991 1317401 109,783

N-butyl Alcohol 12 5 584

. 4150

. 4739 395

Captan 12 0 2191

. 2081

. 4272 356

Quintozene 11 4

. . 392714 221410 614128 55,830

Trifluralin 11 5 2278

. 9772

. 12055 1,096

Chlorothalonil 11 255 2005

. 1518

. 3778 343

2,4-d 2-ethylhexyl Ester 11 5 2077

. 23721

. 25803 2,346

Ethylbenzene 10 0 231 807182 150224 214836 1172473 117,247

Atrazine 10 73 5673

. 28161

. 33907 3,391

Copper Compounds 9 0 9267 754 1500

. 11521 1,280

Zinc Compounds 9 5 260 2730

. . 2995 333

Dimethylamine 9 5

. . 520

. 525 58

Arsenic Compounds 8 10 100655

. 231855

. 332520 41,565

Certain Glycol Ethers 8 57107

. . 1132

. 58239 7,280

Lindane 8 0 276

. 1388

. 1664 208

Bromomethane 8 0

. . . . 0 0

Chloropicrin 8 0

. . . . 0 0

Cumene 8 0 5

. 1453

. 1458 182

Permethrin 8 0 1250

. 1617

. 2867 358

Dicamba 7 5

. . 125

. 130 19

Piperonyl Butoxide 6 0

. . 2082

. 2082 347

Dimethoate 6 0

. . 3091

. 3091 515

Mecoprop 6 5 3896

. 2497

. 6398 1,066

Toluene 6 0

. . 2171

. 2171 362

Thiram 6 2 533

. 38081

. 38616 6,436

Methyl Parathion 6 0 360

. 2120

. 2480 413

Diuron 6 250

. . 380

. 630 105

Prometryn 6 12 250

. 6580

. 6842 1,140

Chlorine 6 6319

. . . . 6319 1,053

Manganese Compounds 5 5 5 21 6309

. 6340 1,268

Nitrate Compounds 5 5 5

. . . 10 2

1,1,1-trichloroethane 5 0

. . 22147

. 22147 4,429

Carbon Disulfide 5 0

. . . . 0 0

Methoxone 5 5 4778

. 941

. 5724 1,145

Metham Sodium 5 1 15862

. 4603 557 21023 4,205

N-methyl-2-pyrrolidone 5 0 1770

. 8041

. 9811 1,962

Carbofuran 5 0

. . 17525

. 17525 3,505

Bromoxynil Octanoate 5 0 16605

. 1448

. 18053 3,611

Maneb 5 0 250

. 1108

. 1358 272

Cyanazine 5 62 755

. 13905

. 14722 2,944

Formaldehyde 4 0 1200

. 29000

. 30200 7,550

Chloromethane 4 0 26

. . . 26 7

Dichloromethane 4 0

. 19277 3555

. 22832 5,708

O-xylene 4 0

. . 1310

. 1310 328

Methyl Isobutyl Ketone 4 940

. . 1630

. 2570 643

Simazine 4 5 1255

. 250

. 1510 378

Hydrochloric Acid (1995 and after "Acid

Aerosols" Only) 4 0

. . . . 0 0

Phosphoric Acid 4 0 25549

. . . 25549 6,387

Sulfuric Acid (1994 and after "Acid Aerosols"

Only) 4 0

. . . . 0 0

Metribuzin 4 0

. . 13213

. 13213 3,303

Acephate 4 250

. . 15800

. 16050 4,013

Chromium Compounds 3 1 11257

. 155

. 11413 3,804

Chlorodifluoromethane 3 0

. . . . 0 0

Maleic Anhydride 3 0

. . . . 0 0

M-xylene 3 0

. . 410

. 410 137

Dicofol 3 0

. . 250

. 250 83

Aldicarb 3 0

. . 32289

. 32289 10,763

Linuron 3 0

. . . . 0 0

Ethyl Dipropylthiocarbamate 3 5 590

. 9610

. 10205 3,402Agricultural Chemical Industry Chemical Releases and Transfers

Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)

by Number and Facilities Reporting (Transfers reported in pounds/year)

Chemical Name #

Reporting

Chemical Potw

Transfers Disposal

Transfers Recycling

Transfers Treatment

Transfers Energy

Recovery

Transfers Total

Transfers Avg

Transfer

Per

Facility

Sector Notebook Project September 2000 87 Paraquat Dichloride 3 32 5

. 250

. 287 96

Propachlor 3 15

. . 6490

. 6505 2,168

Fluometuron 3 235 1505

. 13785

. 15525 5,175

Dimethylamine Dicamba 3 0 255

. . . 255 85

Carboxin 3 2 384

. 390

. 776 259

Copper 3 0

. . . . 0 0

Ethoprop 3 0 250

. 1105

. 1355 452

Thiophanate-methyl 3 0 1167

. . . 1167 389

Pendimethalin 3 0

. . . . 0 0

Hexazinone 3 250 250

. 250

. 750 250

Ethylenebisdithiocarbamic Acid, Salts and Esters 2 0

. . 12830

. 12830 6,415

Trichlorfon 2 0

. . . . 0 0

Parathion 2

. . . . . . . Dichlorvos 2 0

. . 145 104 249 125

S,s,s-tributyltrithiophosphate 2 0

. . 116

. 116 58

2,4-db 2 0

. . 792

. 792 396

1,4-dichlorobenzene 2 0

. . 1365

. 1365 683

1,2-dichloroethane 2 0

. . . . 0 0

Chlorobenzene 2 0

. . 1700

. 1700 850

Phenol 2 0

. . . . 0 0

Diethanolamine 2 5 51

. 5

. 61 31

2,4-dp 2 0 39

. 3

. 42 21

Naled 2 5

. . 3176

. 3181 1,591

Hydrazine 2 0

. . . . 0 0

1,3-dichloropropylene 2 0

. . 51325

. 51325 25,663

Propanil 2 0

. . 1744

. 1744 872

Ametryn 2 0

. . 9700

. 9700 4,850

Cycloate 2 0 28

. 1006

. 1034 517

Bromoxynil 2 0 1388

. 8

. 1396 698

2,4-d Butoxyethyl Ester 2 0

. . 3256

. 3256 1,628

Sodium Dicamba 2 750

. . . . 750 375

Dipotassium Endothall 2 0

. . 250

. 250 125

Molinate 2 0 4405

. 1256 21 5682 2,841

Chlorpyrifos Methyl 2 0

. . 500

. 500 250

Zinc (Fume or Dust) 2 0

. . . . 0 0

Nitric Acid 2 0

. . . . 0 0

Resmethrin 2 0

. . 600

. 600 300

Desmedipham 2 0

. . 492

. 492 246

Thiophanate Ethyl 2

. . . . . . . Thiobencarb 2 0 4930

. . . 4930 2,465

Thiodicarb 2 5 250

. 18411

. 18666 9,333

Propiconazole 2 0 1332

. . . 1332 666

Cyfluthrin 2 0

. . 1019

. 1019 510

Fomesafen 2 0 2501

. 5

. 2506 1,253

Quizalofop-ethyl 2 0

. . . . 0 0

Lactofen 2 0 250

. 3069

. 3319 1,660

Bifenthrin 2 0

. . 48

. 48 24

Myclobutanil 2

. . . . . . . Antimony Compounds 1 0 132

. . . 132 132

Chlorophenols 1 0 2290

. 1198 670 4158 4,158

Cyanide Compounds 1 0

. . 4

. 4 4

Diisocyanates 1

. . . . . . . Lead Compounds 1 0

. 65000

. . 65000 65,000

Carbon Tetrachloride 1 0

. . . . 0 0

Formic Acid 1 0 830

. 2800

. 3630 3,630

Isopropyl Alcohol (Manufacturing, Strong-acid

Process Only, No Supplies) 1 0

. . . 529 529 529

N,n-dimethylformamide 1 250 54765

. 4055 2331 61401 61,401

Methoxychlor 1

. . . 500

. 500 500

Vinyl Chloride 1 0

. . . . 0 0

Tert-butyl Alcohol 1 0

. . 416

. 416 416

2-methyllactonitrile 1 0

. . . . 0 0

Triphenyltin Hydroxide 1

. . . . . . . Hexachlorocyclopentadiene 1 0

. . 3735 800 4535 4,535

Dicyclopentadiene 1 0

. . . . 0 0

Dimethyl Sulfate 1 0

. . . . 0 0

Methyl Ethyl Ketone 1 0

. . 814

. 814 814

Dichloran 1

. . . . . . . P-xylene 1 0

. . 250

. 250 250

1,3-butadiene 1 0

. . . . 0 0Agricultural Chemical Industry Chemical Releases and Transfers

Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)

by Number and Facilities Reporting (Transfers reported in pounds/year)

Chemical Name #

Reporting

Chemical Potw

Transfers Disposal

Transfers Recycling

Transfers Treatment

Transfers Energy

Recovery

Transfers Total

Transfers Avg

Transfer

Per

Facility

Sector Notebook Project September 2000 88 Cyclohexanol 1 0

. . 35289

. 35289 35,289

N-hexane 1 0

. . 20740 56 20796 20,796

Pyridine 1 8506

. . . . 8506 8,506

Propoxur 1

. . . . . . . Di(2-ethylhexyl) Phthalate 1 2

. . 1033

. 1035 1,035

Hexachlorobenzene 1 0

. . 3849 2215 6064 6,064

1,2,4-trichlorobenzene 1 0

. . 7920 890 8810 8,810

2,4-dichlorophenol 1 0

. . . . 0 0

Triethylamine 1 0

. . 61668 2568 64236 64,236

Hydroquinone 1 250

. . . . 250 250

Folpet 1 0

. . . . 0 0

Merphos 1 0

. . . . 0 0

Oxydemeton Methyl 1

. . . . . . . Bromacil 1 0

. . 868

. 868 868

Methyl Isothiocyanate 1 0

. . . . 0 0

Perchloromethyl Mercaptan 1 0

. . . . 0 0

Methyl Isocyanate 1 0

. . . . 0 0

Pebulate 1 0 500

. 250

. 750 750

Benfluralin 1

. . . . . . . Nitrapyrin 1

. . . . . . . Triallate 1 0 509

. 676

. 1185 1,185

Dodine 1 0

. . 500

. 500 500

Dimethyl Chlorothiophosphate 1 0

. . . . 0 0

Temephos 1

. . . . . . . Terbacil 1

. . . . . . . Hydrogen Fluoride 1 0

. . . . 0 0

Bromine 1 750

. . . . 750 750

Mevinphos 1 0

. . . . 0 0

Phosphine 1 0

. . . . 0 0

Creosote 1 5

. . 602

. 607 607

Zineb 1

. . . . . . . Fenbutatin Oxide 1

. . . . . . . Alachlor 1 0

. . 8600

. 8600 8,600

Benomyl 1

. . . . . . . Oryzalin 1

. . . . . . . Oxydiazon 1 0

. . 250

. 250 250

Aluminum Phosphide 1

. . . . . . . Bendiocarb 1

. . . . . . . Pronamide 1 0

. . 500

. 500 500

Toluene Diisocyanate (Mixed Isomers) 1

. . . . . . . Propetamphos 1 0 1000

. . . 1000 1,000

Amitraz 1

. . . . . . . Tebuthiuron 1 0

. . 937

. 937 937

Diflubenzuron 1

. . . . . . . Sulprofos 1 0

. . . . 0 0

Dinocap 1

. . . . . . . Fenpropathrin 1

. . . . . . . Profenofos 1

. . . . . . . Oxyfluorfen 1

. . . . . . . Triadimefon 1 0

. . . . 0 0

Vinclozolin 1

. . . . . . . Fenvalerate 1 0

. . 3994

. 3994 3,994

Dimethipin 1

. . . . . . . Triclopyr Triethylammonium Salt 1 0

. . 82

. 82 82

Fenarimol 1

. . . . . . . Acifluorfen, Sodium Salt 1 0

. . . . 0 0

Chlorsulfuron 1 0

. . 9807

. 9807 9,807

Fluvalinate 1

. . . . . . . Chlorimuron Ethyl 1 0

. . 36604

. 36604 36,604

Tribenuron Methyl 1 0

. . 17387

. 17387 17,387

_________ _________ _________ _________ _________ _________ _________ _________ 193** 106,917 306,983 5,762,544 2,494,611 2,654,437 11,325,492 58,681

** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 89 Top 10 TRI Releasing Agricultural Chemical Companies

The TRI database contains a detailed compilation of self-reported, facilityspecific chemical releases. The top reporting facilities for the agricultural

chemical industries are listed below in Tables 18,19, 20, and 21. Facilities

that have reported the primary SIC codes covered under this notebook appear

on Table 18 for fertilizers and Table 20 for pesticides and misce l laneous

agricultural chemicals. Tables 19 and 21 contain additional facilities that

have reported the SIC codes 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.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 90 Table 18: Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities

(SIC 2873, 2874, 2875) *

Rank Facility Total TRI Releases in Pounds

1 PCS Phosphate Co., Inc. - Aurora, NC 13,202,617

2 CF Ind. Inc. - Donaldsonville, LA 5,823,740

3 Unocal Agricultural Products - Kenai, AK 4,715,420

4 Terra Nitrogen - Catoosa, OK 4,147,000

5 PCS Nitrogen Fertilizer LP - Millington, TN 3,957,624

6 IMC Nitrogen Co. - East Dubuque, IL 3,954,025

7 IMC-Agrico - Uncle Sam, LA 3,570,548

8 Triad Chemical - Donaldsonville, LA 3,478,835

9 IMC-Agrico - Mulberry, FL 3,161,160

10 Farmland Ind. Inc. - Enid, OK 2,804,790

Total 45,615,759

Source: US Toxics Release Inventory Database, 1996.

* Being included on this list does not mean that the release is associated with non-compliance with

environmental laws.

Table 19: Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and Mixing

SIC Codes *

Rank Facility SIC Codes Reported in TRI Total TRI Releases

in Pounds

1 PCS Phosphate Co. Inc. - Geismar, LA 2873, 2874, 2819 23,192,580

2 PCS Phosphate Co. Inc. - Aurora, NC 2874 13,202,617

3 IMC Agrico Co. - St. James, LA 2873, 2874, 2819 12,794,917

4 Du Pont - Beaumont, TX 2822, 2865, 2869, 2873 10,880,836

5 Rubicon Inc. - Geismar, LA 2865, 2869, 2873 8,327,597

6 Monsanto Co. - Luling, LA 2879, 2834, 2873, 2869,

2819 7,742,540

7 Coastal Chemical Co. - Cheyenne, WY 2813, 2819, 2869, 2873,

2899 7,674,410

8 PCS Phosphate - White Springs, FL 2874, 2819 6,961,770

9 Vicksburg Chemical Co. - Vicksburg, MS 2819, 2873, 2812 6,139,460

10 CF Ind. Inc. - Donaldsonville, LA 2873 5,823,740

Total 102,740,467

Source: US Toxics Release Inventory Database, 1996.

* Being included on this list does not mean that the release is associated with non-compliance with

environmental laws.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 91 Table 20: Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals

Facilities (SIC 2879) *

Rank Facility Total TRI Releases in Pounds

1 BASF Corp. - Beaumont, TX 649,472

2 Rhone-Poulenc Ag. Co. - Woodbine, GA 242,293

3 American Cyanamid Co. - Palmyra, MO 227,942

4 Zeneca Inc. - Perry, OH 178,291

5 Farmland Ind. Inc. - Saint Joseph, MO 162,037

6 Zeneca Inc. - Pasadena, TX 149,968

7 Bayer Corp. - Kansas City, MO 45,881

8 Trical Inc. - Hollister, CA 32,447

9 FMC Corp. - Institute, WV 22,195

10 McLaughlin Gormley King Co. - Chaska, MN 21,611

Total 1,732,137

Source: US Toxics Release Inventory Database, 1996.

* Being included on this list does not mean that the release is associated with non-compliance with

environmental laws.

Table 21: Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous

Agricultural Chemicals SIC Codes *

Rank Facility SIC Codes Reported in TRI Total TRI

Releases in

Pounds

1 Monsanto Co. - Luling, LA 2879, 2834, 2873, 2869, 2819 7,742,540

2 Monsanto

- Alvin, TX 2869, 2819, 2841, 2879 7,718,029

3 Uniroyal Chemical Co. - Geismar, LA 2822, 2869, 2879 2,936,127

4 Du Pont - La Porte, TX 2819, 2869, 2879 2,633,242

5 Dow Chemical USA - Midland, MI 2800, 2819, 2821, 2834, 2869,

2879 1,523,414

6 Novartis Crop Protection Inc. - St. Gabriel,

LA 2819, 2865, 2869, 2879 1,488,589

7 Tippecanoe Laboratories - Shadeland, IN 2834, 2879 1,206,435

8 Clinton Laboratories - Clinton, IN 2833, 2879 1,158,105

9 Ciba Specialty Chemicals Corp. - McIntosh,

AL 2879, 2821, 2865, 3069 1,067,347

10 Du Pont - Belle, WV 2821, 2869, 2879 795,378

Total 28,269,206

Source: US Toxics Release Inventory Database, 1996.

* Being included on this list does not mean that the release is associated with non-compliance with

environmental laws.Agricultural Chemical Industry Chemical Releases and Transfers

2 TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological

databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and

Health. For more information on TOXNET, contact the TOXNET help line at 800-231-3766. 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). HSDB contains chemical-specific information on

manufacturing and usage, chemical and physical properties, safety and handling, toxicity and biomedical effects,

pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and

analysis methods, and additional references.

Sector Notebook Project September 2000 92 IV.B. Summary of Selected Chemicals Released

The following is a synopsis of current scientific toxicity and fate information

for the top chemicals (by weight) that facilities within this sector self-reported

as released to the environment based upon 1995 TRI data. Because this

section is based upon self-reported release data, it does not attempt to provide

i nformation on management practices employed by the sector to reduce the

release of these chemicals. Information regarding pollutant release reduction

over time may be available from EPA’s TRI and 33/50 programs, or directly

from the industrial trade associations that are listed in Section IX of this

document. Since these descriptions are cursory, please consult these sources

for a more detailed description of both the chemicals described in this section,

and the chemicals that appear on the full list of TRI chemicals appearing in

Section IV.A.

T he brief descriptions provided below were taken from the Hazardous

Substances Data Bank (HSDB) and the I ntegrated Risk Information System

(IRIS), both accessed via TOXNET. 2 The discussions of toxicity describe the

range of possible adverse health effects that have been found to be associated

with exposur e to these chemicals. These adverse effects may or may not

occur at the levels released to the environment. Individuals interested in a

more detailed picture of the chemi cal concentrations associated with these

adverse effects should consult a toxicologist or the toxicity literature for the

chemical to obtain more information. The effects listed below must be taken

in context of these exposure assumptions that are explained more fully within

the full chemical profiles in HSDB. For more information on TOXNET,

contact the TOXNET help line at 1-800-231-3766.Agricultural Chemical Industry Chemical Releases and Transfers

3 The reporting standards for ammonia were changed in 1995. Ammonium sulfate is deleted from the list and

threshold and release determinations for aqueous ammonia are limited to 10 percent of the total ammonia present

in solution. This change will reduce the amount of ammonia reported to TRI. Complete details of the revisions

can be found in 40 CFR Part 372.

Sector Notebook Project September 2000 93 Ammonia 3 (CAS: 7664-41-7)

Sources. Ammonia is the primary nitrogen source for all nitrogenous

fertilizers and ammonium phosphatic fertilizers.

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 ammonia 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 e nvironmental cycling of nitrogen.

Ammonia in lakes, rivers, and streams is converted to nitrate.

Physical Properties. A mmonia is a colorless gas at atmospheric pressure, but

is shipped as a liquefied compressed gas. It is soluble to about 34 percent in

water and has a boiling point of -28 degrees F. Ammonia is corrosive and has

a pungent odor.

Phosphoric Acid

(CAS: 7664-38-2)

Sources. P hosphoric acid is the primary phosphorous source used for

phosphatic fertilizers.

Toxicity. P ho sphoric acid is toxic by ingestion and inhalation, and is an

irritant to skin and eyes. The toxici ty of phosphoric acid is related to its

corrosivity as an acid, with ulceration of membranes and tissues with which

it comes in contact. Because it is a source of phosphorous , an essential

element for aquatic plant growth, phosphoric acid may contribute to

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

phosphorous-limited waters such as the Great Lakes.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 94 Carcinogenicity. T here is currently no evidence to suggest that phosphoric

acid is carcinogenic.

Environmental Fate. The acidity of phosphoric acid may be reduced readily

by natural water hardness minerals. The phosphate will persist until used by

plants as a nutrient.

Physical Propertie s. P hosphoric acid is a thick, colorless, and odorless

crystalline solid, often used in an aqueous solution. Its boiling point is 415°

F and it is soluble in water.

Nitrate compounds

Sources. M any different nitrate compounds are formed dur ing nitrogenous

fertilizer production.

Toxicity. Nitrate compounds that are soluble in water release nitrate ions

which can cause both human health and environmental effects. Human infants

exposed to aqueous solutions of nitrate ion can develop a condition in which

the blood’s ability to carry oxygen is reduced. This reduced supply of oxygen

can lead to damaged organs and death. Because it is a source of nitrogen, an

essential element for aquatic plant growth, nitrate ion may contribute to

eutrophicatio n of standing or slow-moving surface water, particularly in

nitrogen-limited waters, such as the Chesapeake Bay.

Carcinogenicity. There is currently no evidenc e to suggest that nitrate

compounds are carcinogenic.

Environmenta l Fate. Nitrogen in nitrate is the form of nitrogen most

available to plants. In the environment, nitrate ion is taken up by plants and

becomes part of the natural nitrogen cyc le. Excess nitrate can stimulate

primary production in plants and can produce changes in the dominant species

of plants, leading to cultural eutrophication and ultimately to deterioration of

water quality.

Methanol (CAS: 67-56-1)

Sources. Methanol is generated in ammonia production. It is also used as a

solvent and for equipment cleaning in pesticide formulations.

Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the

respiratory tract and is toxic to humans in moderate to high doses. In the body,

methanol is converted into formal dehyde and formic acid. Methanol is

excreted as formic acid. Observed toxic effects at high dose levels generally

include central nervous system damage and blindness. Long-termAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 95 exposure to high levels of methanol via in halation cause liver and blood

damage in animals.

Ecologically, methanol is expected to have low toxicity to aquatic organisms.

Concentrations lethal to half the organisms of a test population are expected

to exceed one mg methanol per liter water. Methanol is not likely to persist

in water or to bioaccumulate in aquatic organisms.

Carcinogenicity. There is currently no evidence to suggest that methanol is

carcinogenic.

Environmental Fate. Methanol is highly volatile and flammable. Liquid

methanol is likely to evaporate when left exposed. Methanol reacts in air to

produce formaldehyde which contributes to the formation of air pollutants. In

the atmosphere it can react with other atmospheric chemicals or be washed out

by rain. Methanol is readily degraded by microorganisms in soils and surface

waters.

Physical Properties. M ethanol is a colorless liquid with a characteristic

pungent odor. It is miscible with water, and its boiling point is 147°F.

Sulfuric Acid

(CAS: 7664-93-9)

Sources. Sulfuric acid is a raw material of most fertilizer products.

Toxicity. C oncentrated sulfuric acid is corrosive. In its aerosol form, sulfuric

acid has been implicated in causing and exacerbating a variety of respiratory

ailments.

Ecologically, accidental relea s es of solution forms of sulfuric acid may

adversely affect aquatic life by inducing a transient lowering of the pH (i.e.,

i ncreasing the acidity) of surface waters. In addition, sulfuric acid in its

aerosol form is also a component of acid rain. Acid rain can cause serious

damage to crops and forests.

Carcinogenicity. There is currently no evidence to suggest that sulfuric acid

is carcinogenic.

Environmental Fate. Releases of sulfuric 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. Sulfuric acid is an oily, odorless liquid which can be

colorless to dark-brown. It is miscible, and its boiling point is 554°F.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 96 Sulfuric aci d reacts violently with water with evolution of heat and is

corrosive to metals. Pure sulfuric acid is a solid below 51°F.

IV.C. Other Data Sources

The toxic chemical release data obtained from TRI captures only about 236 of

the facilities in the Fertilizer, Pesticide, and Agricultural Chemical Industry.

However, it allows for a comparison acro ss years and industry sectors.

Reported chemicals are limited to the approximately 600 TRI chemicals. A

portion of the emissions from agricultural chemical facilities, therefor e, are not

captured by TRI. The EPA Office of Air Quality Planning and Standards has

compiled air pollutant emission factors for determining the total air emissions

of priority pollutants (e.g., total hydrocarbons, SOx, NOx, CO, particulates,

etc.) from many chemical manufacturing and formulating sources.

The 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 pollutant s which may be of concern within a

particular in dustry. With the exception of volatile organic compounds

(VOCs), there is little overlap with the TRI chemicals reported above. Table

22 summarizes annual releases (from the industries for which a Sector

Notebook Profile was prepared) of carbon monoxide (CO), nitrogen dioxide

(NO

2 ), particulate matter of 10 microns or less (PM10), sulfur dioxide (SO

2 ),

and volatile organic compounds (VOCs).Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 97 

### Table 22: Air Pollutant Releases by Industry Sector (tons/year)

Industry Sector CO NO

2 PM10 PT SO

2 VOC

Metal Mining 4,951 49,252 21,732 9,478 1,202 119,761

Non-Fuel, Non-Metal Mining 31,008 21,660 44,305 16,433 9,183 138,684

Textiles 8,164 33,053 1,819 38,505 26,326 7,113

Lumber and Wood Products 139,175 45,533 30,818 18,461 95,228 74,028

Wood Furniture and Fixtures 3,659 3,267 2,950 3,042 84,036 5,895

Pulp and Paper 584,817 365,901 37,869 535,712 177,937 107,676

Printing 8,847 3,629 539 1,772 88,788 1,291

Inorganic Chemicals 242,834 93,763 6,984 150,971 52,973 34,885

Plastic Resins and Man-made

Fibers 15,022 36,424 2,027 65,875 71,416 7,580

Pharmaceuticals 6,389 17,091 1,623 24,506 31,645 4,733

Organic Chemicals 112,999 177,094 13,245 129,144 162,488 17,765

Agricultural Chemicals 12,906 38,102 4,733 14,426 62,848 8,312

Petroleum Refining 299,546 334,795 25,271 592,117 292,167 36,421

Rubber and Plastic 2,463 10,977 3,391 24,366 110,739 6,302

Stone, Clay, Glass and Concrete 92,463 335,290 58,398 290,017 21,092 198,404

Iron and Steel 982,410 158,020 36,973 241,436 67,682 85,608

Metal Castings 115,269 10,435 14,667 4,881 17,301 21,554

Nonferrous Metals 311,733 31,121 12,545 303,599 7,882 23,811

Fabricated Metal Products 7,135 11,729 2,811 17,535 108,228 5,043

Electronics and Computers 27,702 7,223 1,230 8,568 46,444 3,464

Motor Vehicle Assembly 19,700 31,127 3,900 29,766 125,755 6,212

Aerospace 4,261 5,705 890 757 3,705 10,804

Shipbuilding and Repair 109 866 762 2,862 4,345 707

Ground Transportation 153,631 594,672 2,338 9,555 101,775 5,542

Water Transportation 179 476 676 712 3,514 3,775

Air Transportation 1,244 960 133 147 1,815 144

Fossil Fuel Electric Power 399,585 5,661,468 221,787 13,477,36

7 42,726 719,644

Dry Cleaning 145 781 10 725 7,920 40

Source: United States EPA Office of Air and Radiation, AIRS Database, 1997.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 98 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 TRI 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.

Figure 19 is a graphical representation of a summary of the TRI data for the

Fertilizer, Pesticide, and Agricultural Chemical Industry and the other sectors

profiled in separate notebooks. The bar graph presents the total TRI releases

and total transfers on the vertical axis. Industry sectors are presented in the

order of increasing SIC code. The graph is based on the data shown in Table

23 and is meant to facilitate comparisons between the relative amounts of

releases and transfers both within and between these sectors. Table 23 also

presents the average releases per facility in each industry. The reader should

note 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 Fertilizer, Pesticide, and Agricultural

Chemic al Industry, the 1995 TRI data presented here covers 236 facilities.

These facilities listed SIC 2873, 2874, 2875, or 2879 as a primary SIC code.Agricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 99 0 100 200 300 400 500 6002224252611-26312711-27892812-28192821, 2823, 28242833, 28342861-286928729113032331332, 336333, 33434363713731

SIC RangeTotal Pounds (millions)

Total Releases Total Transfers Figure 19: Summary of 1995 TRI Releases and Transfers by Industry

Source: US EPA 1995 Toxics Release Inventory Database.

SIC

Range Industry Sector SIC

Range Industry Sector SIC

Range Industry Sector

22 Textiles 2833, 2834 Pharmaceuticals 332, 336 Metal Casting

24 Lumber and Wood

Products 2861-2869 Organic Chem. Mfg. 333, 334 Nonferrous Metals

25 Furniture and Fixtures 287 Agricultural Chemicals 34 Fabricated Metals

2611-2631 Pulp and Paper 2911 Petroleum Refining 36 Electronic Equip. and

Comp.

2711-2789 Printing 30 Rubber and Misc. Plastics 371 Motor Vehicles, Bodies,

Parts, and Accessories

2812-2819 Inorganic Chemical

Manufacturing 32 Stone, Clay, and Concrete 3731 Shipbuilding

2821, 2823,

2824 Resins and Plastics 331 Iron and SteelAgricultural Chemical Industry Chemical Releases and Transfers

Sector Notebook Project September 2000 100Table 23: 1995 Toxics Release Inventory Data for Selected IndustriesTRI ReleasesTRITransfersIndustry SectorSICRange# TRIFacilitiesTotalReleases(million lbs.)Ave.Releases perFacility(pounds)TotalTransfers(million lbs.)Ave. Trans.per Facility(pounds)Total Releases+Transfers(million lbs.)Average Releases +Transfers perFacility (pounds)Textiles2233917.853,0007.021,00024.874,000Lumber and Wood Products2439730.076,0004.110,00034.186,000Furniture and Fixtures2533637.6112,0009.929,00047.5141,000Pulp and Paper2611-2631305232.6763,00056.5185,000289.1948,000Printing2711-278926233.9129,00010.440,00044.3169,000Inorganic Chem. Mfg.2812-281941360.7468,00021.7191,000438.5659,000Resins and Plastics2821,2823,282441064.1156,000192.4469,000256.5625,000Pharmaceuticals2833, 283420029.9150,000147.2736,000177.1886,000Organic Chemical Mfg.2861-2869402148.3598,000208.6631,000946.81,229,000Agricultural Chemicals28723677.1326,78811.448,46188.5375,000Petroleum Refining291118073.8410,00029.2162,000103.0572,000Rubber and Misc. Plastics301,947143.173,000102.653,000245.7126,000Stone, Clay, and Concrete3262343.970,00031.851,00075.7121,000Iron and Steel33142390.7214,000513.91,215,000604.61,429,000Metal Casting332, 33665436.055,00073.9113,000109.9168,000Nonferrous Metals333, 334282201.7715,000164582,000365.71,297,000Fabricated Metals342,67683.531,000350.5131,000434.0162,000Electronic Equip. and Comp.364074.311,00068.8169,00073.1180,000Motor Vehicles, Bodies,Parts, and Accessories37175479.3105,000194257,000273.3362,000Shipbuilding3731432.456,0004.195,0006.5151,000Source: US EPA Toxics Release Inventory Database, 1995.Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 101 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 a nd increase profits while at the same time minimizing

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

material inputs, re-engineering processes to reuse by-products, im proving

management practices, and substituting toxic chemicals with those less toxic.

Some smaller facilities are able to actually get below regulatory thresholds

just by reducing pollutant releases through ag gressive pollution prevention

policies.

The Pollution Prevention Act of 1990 established a n ational policy of

managing waste through source reduction, which means preventing the

generation of waste. The Pollution Prevention Act also established as national

policy a hierarchy of waste management options for situations in which source

red uction cannot be feasiblely implemented. In the waste management

hierarchy, if source reduction is not feasible the next alternative is recycling

of wastes, followed by en ergy recovery, and waste treatment as a last

alternative.

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

company-s p ecific descriptions of some pollution prevention advances that

have been implemented within the Fertilizer, Pesticide, and Agricultural

Chemical Industry. While the list is not exhaustive, it does provide core

information that can be used as the starting point for facilities interested in

beginning their

own pollution prevention projects. This section provides

summary information from activities that may be, or are being implemented by

this sector. When possible, information is provided that gives the context in

which the technique can be u sed effectively. Please note that the activities

described in this section do not nece s sarily apply to all facilities that fall

within this sector. Facility-specific conditions must be carefully considered

when pollution prevention options are evaluated, and the full impacts of the

change must examine how each o ption affects air, land and water pollutant

releases.

The Fertilizer, Pesticide, and Agricultural Chemical Industr y uses many

p ollution prevention (P2), recycle and reuse, and water conservati o n

practices. Wastewaters are primarily generated not by the production or

formulating processes themselves but by cleaning operations of the process

areas and associated equipment. Because the wastewaters are mostly cleaning

rinsates and not waters of

reaction, the pollution prevention practices are not

process-specific. There are many P2, recycle and reuse, and water

conservation practices that are widely accepted and practiced by the

Fertilizer, Pesticide, and Agricultural Chemical Industry today.Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 102 These pollution preventi on, recycle and reuse, and water conservation

practices fall into three groups: production practices, housekeeping practices,

and practices that use equipment that, by design, promote pollution prevention.

Some of th

ese practices and equipment conserve water, others reduce the

amount of fertilizer or pesticide product in the wastewater, and still others may

prevent the generation of a wastewater altogether (USEPA, 1996). A number

of common P2 practices are listed below.

Production practices include:



### C triple-rinsin

g raw material shipping containers directly into the

formulation



### C scheduling production to minimize cleanouts



### C segregating processing/formulating/packaging equipment by:

- individual product

- solvent-based versus water-based formulations

- products that contain similar active ingredients in different

concentrations



### C storing interior equipment rinse waters for use in formulating the

same product



### C packaging products directly from formulation vessels



### C using raw material drums for packaging final products



### C dedicating equipment (possibly only mix tank or agitator) for

“hard-to-clean” formulations

Housekeeping practices include:



### C performing preven

tive maintenance on all valves, fittings, and

pumps



### C placing drip pans under leaky valves and fittings or under any

valves or fittings where hoses or lines are routinely connected and

disconnected



### C cleaning u

p spills or leaks in outdoor bulk containment areas to

prevent contamination of storm waterAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 103 Equipment that promotes pollution p revention by reducing or eliminating

wastewater generation includes:



### C low-volume/high-pressure hoses



### C spray nozzle attachments for hoses



### C squeegees and mops



### C low-volume/recirculating floor scrubbing machines



### C portable steam cleaners



### C drum triple rinsing stations



### C roofs over outdoor tank farms (USEPA, 1996)Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 104 Table 24: Waste Minimization Methods for the Fertilizer, Pesticide, and

Agricultural Chemical Industry

Waste Stream Waste Minimization Methods

Equipment Cleaning Wastes Maximize production runs.

Store and reuse cleaning wastes.

Use of wiper blades and squeegees.

Use of low-volume, high-efficiency

cleaning.

Use of plastic or foam “pigs.”

Spills and Area Washdowns Use of dedicated vacuum system.

Use of dry cleaning methods.

Use of recycled water for initial cleanup.

Actively involved supervision.

Off-Specification Products Strict quality control and automation.

Reformulating off-spec batches.

Containers Return containers to supplier and or reuse as

directed.

Triple rinse containers.

Drums with liners versus plastic drums or

bags.

Segregating solid waste.

Air Emissions Control bulk storage air emissions.

Dedicate dust collection systems.

Use automatic enclosed cut-in hoppers.

Eliminate emissions of ammonia from

reaction of anhydrous ammonia and

phosphoric acid.

Miscellaneous Wastewater Streams Pave high spillage areas.

Source: Guides to Pollution Prevention, The Pesticide Formulating Industry, Center for

Environmental Research Information, United States EPA, Cincinnati, Ohio, 1990.Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 105 V.A. Equipment Cleaning

Shipping Container/Drum Cleaning Operations

Fertilizer and pesticide facilities f requently receive raw materials in

containers such as 55-gallon plastic or steel drums or 30-gallon fiber drums.

In some cases, the empty drums are returned to the supplier, but usually the

facility is responsible for disposal of the drums. The simplest, most costeffective, and best approach to pr e vent pollution associated with cleaning

drums and shipping containers is to rinse empty drums pri or to disposal to

capture the raw material residue for direct reuse in future formulations of the

same product. In this way, the facility not only eliminates a potential highly

contaminated wastewater source, but is also able to recover the product value

of the raw material and avoids costs associated with storage of the wastewater

(USEP A, 1996). However, pesticide chemicals formulating and packaging

facilities and pesticide repackaging and refilling facilities should consult the

List of Pollution Prevention Alternative Practices and ensure compliance with

the effluent guidelines and standards found in 40 CFR 455 Subparts C and E

before implementing pollution prevention techniques listed in this section.

Rinsing procedures for pesticide drums are provided in 40 CFR Part 165. The

most common method of drum rinsing in the agriche mical industry is triple

rinsing. After a drum containing AIs or pesticide products is emptied, it

should be triple rinsed with the solvent that will be used in the formulation.

This method prevents the creation of a rinsate that cannot be added directly to

the formulation (e.g., a faci lity will not create a water-based rinsate when

producing a solvent-based product). Note in some cases the label may specify

how to rinse.

Some facilities use a high-pressure, low-volume wash system equipped with

a hose and a spray nozzle to triple rinse drums; volumes of five to fifteen

gallons of water per drum have been reported. EPA has identified many

facilities that reuse t

hese rinsates directly in product formulations. Other

facilities treat drum rinsate and reuse the effluent for further drum or equipment

rinsing. If the rinsate cannot be reused directly in product formulations,

another effective metho d to reduce wastewater generation during shipping

container/drum cleaning processes is the use of drum rinsing stations (USEPA,

1996).

One facility uses a three-cell station for triple-rinsing drums. The water in the

first cell is used for the first rinse, the water in the second cell is used for the

second rinse, and the water in the third cell is used for the final rinse. The

rinse water in the first cell is reused until it is visually too contaminated to

effectively clean the drums. At that time, it is removed from the cell (for

treatment) and the rinse water from the second cell is transferred into the first

cell. The rinse water from the third cell is transferred into the second cell, and

the third cell is refilled with treated effluent from their treatment system. EachAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 106 cell contains approximately 100 gallons of water; approximately 70 drums can

be rinsed before the first cell requires water changing (USEPA, 1996).

Another site uses a unique, closed-loop set-up for emptying and triple rinsing

raw material drums. The system was designed by the facility for several

purposes: to aid it in emptying and cleaning drums and performing the triple

rinse, to eliminate the need for storage of the water (or solvent) for reuse, and

to prevent mathematical errors by the operators during the weighing out of raw

materials and water (or solvent). The system consists of two 55-gallon drums,

a formulation tank, and connecting hoses. One of the drums is permanently

fixed on top of the formulation tank. The formulation tank and drum are

situated on a load cell (used for weighing). The second drum, which is full of

raw material, is placed on the ground next to the formulation tank. One hose

is used to vacuum out the raw material and transfer it to the drum on the

formulations tank/load cell. The other hose is equipped with a doughnutshaped nozzle that provides the triple rinse by spraying the interior of the now

emp t y raw material drum. The rinsate that is created by the triple rinse

procedure is automatically removed by the vacuum line and is transferred to

the drum on the formulation tank/load cell.

The load cell can be used to weigh the amount of raw material and/or rinsate

that is added to the formulation by zeroing out the weight of the tank and drum.

This allows the volume of both raw material and rinse water (or solvent) to

be factored into the total volume of water ( or solvent) required in the

formulation. The drum on top of the formulation tank is equipped with a

spring-loaded valve that enables the operator to take weight mea surements

prior to emptying the contents of the drum into the mix tank. This set-up has

almost completely eliminated operator math errors and related formulation

specification problems.

Bulk Tank and Equipment Cleaning

Pesticide formulating and fertilizer mixing facilities sometimes produce large

quantities of formulated pesticide and fertilizer products and receive large

quantities of raw materials used to produce those products. Those products

and raw materials are stored on site in bulk tanks. The tanks are typically

rinsed on l y when it becomes necessary to use the tank to store a different

material. Each time the facility switches the product stored in a bulk tank, the

tank is rinsed. Bulk tanks are sometimes also rinsed at the end of a season as

a part of general maintenance (USEPA, 1996). Pesticide formulating and

fertilizer mixing facilities should consult the List of Pollution P revention

Alternative Practices and ensure compliance with the effluent guidelines and

standards found in 40 CFR Part 455 Subparts C and E before implementing

pollution prevention techniques involving bulk tank and other equipment

cleaning.

P roduct changeover cleanings can be eliminated or greatly reduced byAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 107 dedicating equipment to specific products or groups of products. Although

entire lines are not generally dedicated, there are many facilities that dedicate

tanks to formulation mixing only, thereby eliminating one of the most highly

contaminated wast

ewater streams generated at pesticide formulating and

packaging facilities. Facilities also dedicate lines to the production of a

specific product type, such as water-based versus solvent-based products,

thereby reducing the number of cleanings required, and allowing greater reuse

of the cleaning water or solvent.

Another effective pollution prevention technique is to schedule production to

reduce the number of product changeovers, which reduces the number of

equipment interior cleanings required. Facilities may also reduce the number

of changeover cleanings required or the quantity of water or solvent used for

cleaning by scheduling products in groups. Products may lend themselves to

a particular production sequence if they have common active ingredients,

assuming the products also have the same solvent base (including water).

Where other raw material cross-contamination problems are not a concern, no

cleaning woul d be required between changeover. Facilities that have

implemented this technique have conducted testing to ensure that product

quality is not adversely affected (USEPA, 1996).

Scheduling production according to packaging type can reduce changeover

cleanings of packaging equipment. Packaging lines are often able to handle

containers of different sizes; a slight adjustment to one packaging line, such as

adding a short length of hose, may prevent the use of an entirely different set

of packaging equipment that would also require cleaning. Packaging can also

be performed directly out of the formulati on vessels to avoid using and

subsequently cleaning interim storage tanks and transfer hoses.

Another effective pollution prevention and water conservation techniq u e to

minimize the quantity of rinse water generated by equipment interior cleaning

is the use of water hoses equipped with hand-control devices (for example,

spray-gun nozzles such as those used on garden hoses). This practice prevents

the free flow of water from unattended hoses. Another technique to conserve

water is the use of high-pressure, low-volume washer s instead of ordinary

hoses. One of the facilities visited indicated that, by using high-pressure

washers, they reduced typical equipment interior rinse volumes from twenty

gallons per rinse to ten gallons per rinse (USEPA, 1996).

Steam cleaning can also be a particularly effective method to clean viscous

products that otherwise require considerable volumes of water and/or the

addition of a detergent to remove. Many facilities have access to steam from

boilers on site; however, if there is no existing source of steam, steam cleaning

equipment can be purchased. Although steam generation can increase energy

consumption and add NO

x and SO

x pollutants to the atmosphere, there are

benefits to be gained. Facilities may end up creating a much smaller volume

of wastewater and may potentially avoid the need to use detergents or otherAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 108 cleaning agents that could prevent product recovery. However, steam would

be a poor choice for cleaning applications where volatile organic solvents or

inerts are part of the product, as the steam would accelerate the volatilization

of the organic compounds.

Facilities also clean equipment int eriors by using squeegees to remove the

product from the formulation vessel and by using absorbent “pigs” to clean

products out of the transfer lines before equipment rinsing. These techniques

minimize the quantity of clean i ng water required, although they generate a

solid waste stream requiring disposal. Regardless of whether or not residual

product is removed from equipment inte riors before rinsing, if certain

conditions are met, equipment interior rinsate can typically be reused as makeup water the next time that a water-based product is being formulated with the

same chemical (USEPA, 1996). Pesticide chemicals formulating and

packaging facilities and pesticide repackaging and refilling facilities should

consult the List of Pollution Prevention Alternative Practices and ensure

compliance with the effluent guidelines and standards found in 40 CFR Part

455 Subparts C and E before implementing pollution prevention techniques

involving bulk tank and other equipment cleaning.

One facility uses a unique method of cleaning to reduce the volume of water

needed to clean equipment interiors. At this facility, the production lines are

hooked to dedicated product storage tanks. Prior to rinsing these production

lines, the facility uses air to “blow” the residual product in the line back to

product storage. Not only will these lines require less water to clean, but the

residual product that is blown back to storage is not diluted and should not

affect the product specifications in any way.

Another facility drastically reduced dichloromethane usage at several plants

by switching to soap and water for cleaning. This change enabled the facility

to cut its target chemicals by two-thirds. The facility also reduced the release

of carbon tetrachloride, and installed a closed-loop rec ycling system, to

reduce water usage (CMA, 1993).

Aerosol Container Leak Testing

No method of eliminating wastewater from tes t baths has been identified.

However, the volume of water used may be minimized by using a contained

(or batch) water b ath as opposed to a continuous overflow water bath. A

contained water bath is completely emptied and refilled wit h water when

required, based upon visual inspection by the operator. Therefore, the quantity

of wastewater generated depends on the frequency of refilling and the volume

of the bath (200 gallons is a typical volume of the contained water baths). One

facility uses a contained water bath and heats the bath with steam to ensure that

the temperature of the cans reaches 130°F. This facility indicated that steam

condensation ca uses some overflow that exits the bath via a standpipe. A

co ntinuous overflow bath would probably generate more wastewater perAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 109 production unit than a batch water bath (USEPA, 1996).

One facility has installed a diatomaceous earth filter on one DOT test bath.

The facility recirculate s the bath water through the filter to remove

contaminants such as oil and grease and suspended solids. The filtered water

is then reused in the bath, thereby extending the usefulness of the bath water.

The facility anticipates they will dispose of the filter as nonhazardous waste.

Another facility uses a can-washing step prior to the DOT test bath, presenting

an additional source of wastewater. This can washing is performed at the

operator’s discretion to reduce the quantity of contaminants entering the bath

water. The effectiveness of this step has not been quantitatively determined

(USEPA, 1996).

Laboratory Equipment Cleaning

Man y pesticide formulating and packaging facilities operate on-site

laboratories for conducting quality control tests of raw mat erials and

f o rmulated products. Wastewater is generated from these tests and from

cleaning glassware used in the tests. One effective pollution prevention/reuse

technique during labora tory equipment cleaning operations is to dedicate

laboratory sinks to certain produc ts, and collect any wastewater generated

from the testing of those products either for reuse in the same product or for

transfer back to the AI manufacturer or product registrant. In the cases where

the facility uses solvents in conjunction with the qual ity control tests

performed in the laboratory, the solvent-contaminated water may not be able

to be reused in the process (USEPA, 1996).

V.B. Process Changes

Storage Tanks

One method to reduce the amount of waste water from ammonium nitrate

production is to incorporate a wastewater evaporator system which reduces

the amount of contaminated cooling water discharge. The wastewater passes

through a series of evaporation steps whereby the vapors are used as wash

water in the calcium carbonate filters and the concentrated solution is pumped

to the neutralizers where it is mixed with the acidic nitrogen-phospha t e

solution and used to regulate the nitrogen-phosphate nutrie nt ratio of the

fertilizer. Through this modified technology, steam and electric energy

consumption increases somewhat, but such increases are balanced by the more

effective utilizat

ion of nitrogen and the reduction of wastewater. More

information on this method can be found in “Waste Water Evaporation Process

for Fertilizer Production Technology,” Compendium on Low and Non-waste

Technology , United Nations Economic and Social Counsel.

(http://es.inel.gov/studies/cs244.html)Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 110 Many methods are available for reducing the amount of emissions resulting

from fixed roof storage tanks. Some of these methods include use of

conservation vents, conversion to floating roof tanks, use of nitrogen

blanketing to suppress emissions and reduce material oxidation, use of

refrigerated condensers, use of lean-oil or carbon absorbers, or use of vapor

equilibration lines. When dealing with volatile materials, employment of one

or more of these methods can result in cost savings to the facility by reducing

raw material losses and improving compliance with local air quality

requirements (USEPA, 1996).

Air Emission Control Systems

Agricultural chemical facilities often produce large quantities of dust which

are collected from numerous sources. The chemical composition of the

various dust sources can vary widely. Opportunities often exist to reduce

waste generation through segregation of these waste dusts and particulates.

At Daly-Herring Co., in Kin gston, NC, dust streams from several different

production areas were handled by a single baghouse. Since all of the streams

were mixed, none of the waste could be recycled to the process that generated

them. By installing separate dedicated baghouses for each production line, all

of the collected pesticide dust could be recycled. The initial investment for

the equipment was $9,600. The payback period was only ten months. DalyHerring saved over $9,000 per year in disposal costs and $2,000 per year in

raw material costs (Hunt, 1989).

At FMC Corp. in Fresno, CA, common dust collectors were used by multiple

production systems. Due to the cross contamination of materials, recycling

was impossible. To promote recycling, the company compartmentalized the

dust collectors with each compartment serving a single source. All collected

mate rials are analyzed for cross contamination and if none exists, they are

reused in the succeeding product batch. Other work involved the installation

of self-contained dust collectors at each inlet ho pper dump station so that

captured dust can be returned to the system (USEPA, 1996).

Facilities may also use wet scrubbers to control air emissions. Some facilities

may only need a wet scrubbe r on one particular process (i.e., a dedicated

scrubber). These facilities have been able to reuse the scrubber blowdown or

changed-out scrubber water as make-up water in the for mulation of that

particular product. Some facilities with nondedicated scrubbers have beenAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 111 able to use the scrubber blowdown or changed-out scrubber water for floor or

equipment exterior cleaning (USEPA, 1996).

Microprill Formation

Microprill formation resulting from partially plugged orifices of melt spray

devices can increase fine dust loading and emissions. Certain designs

(spinning buckets) and p r actices (vibration of spray plates) help reduce

microprill formation. Reducing the ambient air temperature reduces emissions

because the air flow required to cool prills and the formation of fumes are

decreased at lower temperatures.

V.C. Good Housekeeping

Floor/Wall/Equipment Exterior Cleaning

During processing, fo r mulating, and packaging operations, the exteriors of

equipment may become soiled from drips, sp ills, and dust (especially

equipment located near dry lines). The floors in the area become dirty in the

same ma nner and also from normal traffic. Facility workers clean the

equipment exteriors and floors for general housekeeping purposes, and to keep

sources of product contamination to a minimum. When water is used, these

cleaning procedures become a source of wastewater.

Wastewater

can again be minimized through the use of high-pressure, lowvolume washers rather

than ordinary water hoses. Additionally, some

facilities practice steam cle aning rather than water cleaning of equipment

exteriors to reduce the amount of wastewater generated (USEPA, 1996).

Instead of hosing down the exterior of a piece of equipment, some facilities

wipe equipment exteriors with rags or use a solvent cleaner, such as a

commerc ially available stainless steel cleaner. This practice avoids

generating a wastewater stream, but does create a solid waste that, depending

on the solvent used, could be considered a hazardous waste. Squeegees are

also used to clean equipment exteriors and floors, and are not disposed of after

single uses. It may be possible to dedicate squeegees to a certain line or piece

of equipment, but using squeegees may still require using some water (USEPA,

1996).

Some facilities use automated floor scrubbers, which replace the practice of

hosing down floors. Floor scrubbers are mechanical devices that continually

reci rculate cleaning water to clean flat, smooth surfaces with circulating

brushes. During operation, the scrubber collects the cleaning water in a small

tank that is easily emptied after the cleaning process, or at a later date. Using

a floor scrubbin

g machine can require as little as five to fifteen gallons of

cleaning solution (typ ically water) per use. A mop and a single bucket ofAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 112 water can also be used in place of a hose. Floor mopping can generate as little

as ten gallons of water per cleaning depending on the size of the surface to be

cleaned (USEPA, 1996).

A number of facilities reuse their floor wash water with and without filtering.

One facility has set up its production equipment on a steel-grated platform

directly above a collection sump. Following production, the equipment and

the floor of the platfo r m, on which the operator stands when formulating

product, are rinsed and the water is allowed to flow into the sump. A pump

and a filter have been installed in the sump area to enable the operator to

transfer this rinsate back into the formulat ion tank for the next formulation.

This sump is als o connected to floor trenches in the packaging area for the

same product. When the exterior of the packaging equipment and the floors in

this area are rinsed, this water is directed to the trenches and eventually ends

up in the collection sump for reuse (USEPA, 1996).

Leaks and Spills Clean-Up

Dry products that have leaked or spilled can be vacuumed or swept without

generating any wastewater. Liquid leaks and spills can be collected into a

trench or sump (for reuse, discharge, or disposal) with a squeegee, leaving

only a residue to be mopped up or hosed down if further wat er cleanup is

required. Liquid leaks and spills can also be cleaned up using absorbent

material, such as absorbent pads or soda ash. For an acidic product, soda ash

or a similar base material will also serve to neutralize the spill. If a residue

remains, some water may be used for mopping up or hosing the area down, but

met hods to reduce floor wash should be implemented whenever possible.

Many facilities clean up leaks and spills from water- based products with

water and then solvent-based products with absorbent materials . Using an

absorbent material may be the best practic e for cleaning up small scale

solvent-based leaks and spills; howeve r, EPA does recognize that this material

then needs to be disposed of (cross-media transfe r). Therefore, good

housekeeping practices m ay be even more important in the case of organic

solvent-based product spills and leaks because, if not prevented, these spills

and leaks may have to be cleaned up with absorbent material and disposed of

(USEPA, 1996).

Direct reuse of products which have leaked or spil led is another possible

pollution prevention technique. If drip pans or other containers are used to

catch leaks and spills, the material (either water-based or solvent-based) can

be immediately reused in the product being processed, formulated, or

packaged, or stored for use in the next product batch. Collection hoppers or

rubs can be installed beneath packaging fillers to capture spills and

immediately direct the spills back to the fillers. Leaks or spills around bulkAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 113 storage tanks can be contained by dikes, which, in fact, are often required by

state regulations (USEPA, 1996).

Precipitation Runoff

Precipitation runoff includes all precipitation that falls on facility surfaces that

are believed to be contaminated. Contaminated precipitation runoff can be

prevented by bringing all operations indoors, as many facilities have done, or

by covering outdoor storage tanks and dikes with roofs, which has also been

done at many facilities. The roofs would ideally extend low enough to prevent

crosswinds from blowing rain into spill-contain ment dikes. To prevent

rainwater contamination, the drain spouts a nd gutters should conduct roof

runoff to areas away from process operations, and the roofs should be kept in

good repair (USEPA, 1996).

If operations remain outdoors, a transfer, or containment pad should be

installed with a sump or other means of collecting rinse water. The pad should

be constructed of asphalt or concrete and maintained with crack sealer and a

top coat sealer to control infiltration. The pad should also be large enough to

contain wind-blown p articulates from dry materials. If pads are cleaned

before a rainfall, then uncontaminated precipitation runoff may be directly

discharged to surface drains (CFA, 1996). Facilities c an also monitor the

water in a containment system by periodically testing for a variety of

contaminants.

It may be difficult for facilities that do not require large volumes of water to

reuse all the precipitation collected in the containment system. These facilities

could keep the containment system free of any spilled pesticides through good

housekeeping practices so that precipitation fallin g into the containment system

does not become con

taminated. Some facilities house their pesticide bulk

storage area inside a building or under a covered area to eliminate

precipitation from collecting in the containment system, as well as to protect

the area from vandalism and severe weather (USEPA, 1996).

Containment Pad in the Loading/Unloading Area

Agrichemical deal ers sometimes install loading/containment pads in the

operation area to contain and collect any product spills that may occur during

pesticide loading operations. The pad is usually installed contiguous to the

b ulk storage tanks and the repackaging of products into smaller contain ers.

Facilities may also conduct all their portable cleaning operations, such as

rinsing minibulk containers, directly on the pad in order to contain and collect

the rinsates.

T he pad is normally constructed of concrete and is sloped to a sump area.

Some facilities divide the sump area into individual collection basins so that

the fac i lities can segregate wastewaters contaminated by different productsAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 114 and reuse these wastewaters for applications. For instance, facilities in the

Midwest frequ

ently have two collection basins; one basin collects

wastewaters con

taminated with corn herbicides and the other collects

wastewaters contaminated with soybean herbicides. As part of this collection

system, some facilities install one or more tanks to store wastewater until it

can be applied to land, while other facilities use portable minibulk tanks to

store the waste w ater. When facilities collect wastewaters that must be

segregated by different types of products, multiple storage tanks are used to

avoid contamination (USEPA, 1996).

V. D. Energy Efficiency

Installation of a Feed-Gas Saturator

A mixture of steam and natural gas with a volumetric ratio of steam to carbon

of about 3.5:1 is reacted in the primary reformer of reforming ammonia plants.

Mos t of the steam is generated from heat sources within the plant, but the

bala nce of the steam has to be produced in auxiliary boilers. This retrofit

permits the use of low-level heat from the flue gases, which would otherwise

be lost, to be used in saturating the feed natural gas with water. This generates

extra steam which replaces some of the steam generated in the boiler (UNEP,

1996).

Modification of Convection Coils

As a result of other modifications, the temperature profile of the flue gases may

change consid erably in the cold-leg section of the primary reformer. This

change can be compensated for by replacing the low steam superheat coil with

a new one with additional rows of tubes and heavier fins on all tubes (UNEP,

1996).

Low-heat Removal of Carbon Dioxide

The traditional systems used for removal of carbon dioxide from the process

steam uses hot potassium carbonate which requires heat for regeneration. This

heat comes from process heat but needs to be suppl emented with external

steam. A new low-heat removal system is now available, which uses flashing

for part of the regeneration process, and requires less external heat (UNEP,

1996).

Ammonia Synthesis Modifications

Ammonia Converter Retrofit

The vertical quench-type converters are changed from ax ial flow to radial

flow, greatly decreasing the pressure drop across the converter which in turn

allows the use of smaller si ze catalyst with a larger surface area. This

improved catalyst yields a higher conversion per pa ss, generating a lowerAgricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 115 recycle volume. The lower recycle volume and the lower pressure drop result

in reduced energy requirements. This modification yields an increase effective

capacity of the ammonia converter of about 35 percent (UNEP, 1996).

Addition of Process Computer

A dedicated process computer can be installed along with other on-line

analysis and control systems to monitor and control key variables. With this

system, continuous set point changes are possible to optimize the operation of

several plant areas such as hydrogen/nitrogen ratio, steam/carbon ratio,

synthesis loop purge, methane leakage, conver ter control, and refrigeration

purge (UNEP, 1996).

Hydrogen Recovery from the Purge Gas

Inert gases must be pumped from the plant to avoid their buildup in the system.

This purge is carrie d out by removing a side stream of synthesis gas after

recovering th

e ammonia. By installing the proper recovery system, the

hy drogen in this gas mixture can be recovered decreasing the energy

requirements of the process by about five percent or permitting an increase of

about five percent in production capacity (UNEP, 1996).Agricultural Chemical Industry Pollution Prevention Opportunities

Sector Notebook Project September 2000 116 THIS PAGE WAS INTENTIONALLY LEFT BLANKAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 117 

### VI. S UMMARY OF 

### A PPLICABLE 

### F EDERAL 

### S TATUTES AND 

### R EGULATIONS

This section discusses the federal regul a tions 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 general discussion on State regulation of

pesticides



### C Section VI.D con

tains a list of pending and proposed regulatory

requirements

The descriptions within Section VI are intended solely for general information.

Depending upon the nature or scope of the activities at a particular facility,

these summaries may or may not necessarily describe all applicable

environmental requirements. Moreover, they do not constitute formal

in terpretations or clarifications of the statutes and regulations. For further

information, readers should consult the Code of Federal Regulations (CFR)

and other state or local regulatory agencies. EPA Hotline contacts are also

provided for each major statute.

VI.A. General Description of Major Statutes

Federal Insecticide, Fungicide, and Rodenticide Act

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first

passed in 1947, and amended numerous times, most recently by the Food

Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the

authority to oversee, among other things, the registration, distribution, sale and

us e of pesticides. The Act applies to all types of pesticides, including

insectic ides, herbicides, fungicides, rodenticides, and antimicrobials. FIFRA

covers both intrastate and interstate commerce.

Establishment Registration

Section 7 of FIFRA requir es that establishments producing pesticides, or

active ingredients used in produc ing a pesticide subject to FIFRA, register

with EPA. Registered establishments must report the types and amounts of

pesticides and active ingredients they produce. The Act also provides EPA

inspection authority and enforcement authority for facilities/persons that are

not in compliance with FIFRA.

Product Registration

Under section 3 of FIFRA, all pesticides (with few exceptions) sold or

distributed in the United States must be registered by EPA. Pesticide

registration is very specific and generally allows use of the product only asAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 118 specified on the label. Each registration specifies the use site, i.e., where the

product may be used, and amount that may be applied. The person who seeks

to register the pesticide must file an application for regis tration. The

application process ofte n requires either the citation or submission of

extensive environmental, health, and safety data.

To register a pesticide, the EPA Administrator must make a number of

findings, one of whic h is that the pesticide, when used in accordance with

widespread and commonly recognized practice, will not generally cause

unreasonable adverse effects on the environment.

FIFRA defines “unreasonable adverse effects on the environment” as “(1) any

unreasonable risk to man or the environment, taking into account the economic,

social, and environmental costs and benefits of the use of the pesticide, or (2)

a human dietary risk from residues that result from a use of a pesticide in or on

any food inconsistent with the standard under section 408 of the Federal Food,

Drug, and Cosmetic Act (21 U.S.C. 346a).”

Un der FIFRA section 6(a)(2), after a pesticide is registered, the registrant

must also notify EPA of any additiona l facts and information concerning

unreasonable adverse environmental e ffects of the pesticide. Also, if EPA

determines that additional data are needed to support a registered pesticide,

registrants may be required to provide additional data. If EPA determines that

the registrant(s) did not comply with their request for more information, the

registration can be suspended under FIFRA section 3(c)(2)(B) and section 4.

Use Restrictions

As a part of the pesticide registration, EPA must classify the product for

general use, restricted use, or general for some uses and restricted for others

(Miller, 1993). For pesticides that may cause unreasonable adverse effects on

the environment, including injury to the applicator, EPA may require that the

pesticide be applied either by or under the direct supervision of a certified

applicator.

Reregistration

Due to concerns that much of the safety data underlying pesticide registrations

becomes outdated and inadequate, in addition to providing that registrations

be reviewed every 15 years, FIFRA requires EPA to reregister all pesticides

that were registered prior to 1984 (section 4). After reviewing existing data,

EPA may approve t

he reregistration, request additional data to support the

registration, cancel, or suspend the pesticide.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 119 Tolerances and Exemptions

A tolerance is the maximum amount of pesticide residue that can be on a raw

product and still be considered safe. Before EPA can register a pesticide that

is used on raw agricultural products, it must grant a tolerance or exemption

from a tolerance (40 CFR sections 163.10 through 163.12). Under the Federal

Food, Drug, and Cosmetic Act (FFDCA), a raw agric u ltural product is deemed

unsafe if it contains a pesticide residue, unless the residue is within the limits

of a tolerance established by EPA or is exempt from the requirement.

Cancellation and Suspension

EPA can cancel a registration if it is determined th at the pesticide or its

labeling does not comply with the requirements of FIFRA or causes

unreasonable adverse effects on the environment (Haugrud, 1993).

In cases where EPA believes that a n “imminent hazard” would exist if a

pesticide were to continue to be used through the cancellation proceedings,

EPA may suspend the pesticide registration through an order and thereby halt

the sal e, distribution, and usage of the pesticide. An “imminent hazard” is

defined as an unreasonable adverse effect on the environment or an

unreasonable hazard to the survival of a threatened or endangered species that

would be the likely result of allowing continued use of a pesticide during a

cancellation process.

When EPA believes an emergency exists that does not permit a hearing to be

held prior to suspending, EPA can issue an emergency order which makes the

suspension immediately effective.

Imports and Exports

Under FIFRA section 17(a), pesticides not registered in the United States and

intended solely for export are not required to be registered provided that the

exporter obtains and submits to EPA, prior to export, a statement from the

foreign purchaser acknowledging that the purchaser is aware that the product

is not registered in the United States and cannot be sold for use there. EPA

sends these statements to the government of the importing country. FIFRA sets

forth additional requirements that must be met by pesticides intended solely for

export. The enforcement policy for exports is codified in sections 40 CFR

sections 168.65, 168.75, and 168.85.

Under FIFRA section 17(c), imported pesticides and devices must comply

with United States pesticide law. Except where exempted by regulation or

statute, imported pesticides must be registered. FIFRA section 17(c) requires

that EPA be notified of the arrival of imported pesticides and devices. This

is accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1),

which is filled out by the importer prior to importation and submitted to the

EPA regional office applicable to the intended port of entry. United States

Custo ms regulations prohibit the importation of pesticides without a completed

NOA. The EPA-reviewed and signed form is returned to the importer forAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 120 presentation to United States Customs when the shipment arrives in the United

States NOA forms can be obtained from contacts in the EPA Regional Offices

or www.epa.gov/oppfead1/international/noalist.htm.

Additional information on FIFRA and the regulation of pesticides can be

obtained from a variety of sources, including EPA’s Office of Pesticide

Programs’ homepage at www.epa.gov/pestici des, EPA’s Office of

Compliance, Agriculture and Ecosystem Division at

http://es.epa.gov/oeca/agecodiv.htm, or The National Agriculture

Compliance Assistance Center toll-free at 888-663-2155 or

http://es.epa.gov/oeca/ag. Other sources include the National Pesticide

Telecommunications Network toll-free at 800-858-7378 and the National

Antimicrobial Information Network toll-free at 800-447-6349.

Clean Water Act

The primary objective of the Federal Water Pollution Control Act

, commonly

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

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

Pollutants regulated under the CWA are classified as either “toxic” pollutants;

“conventional” pollutants, such as biochemical oxygen demand (BOD), total

suspended solids (TSS), fecal coliform, oil and grease, and pH; or “nonconventional” pollutants, including any pollutant not identified as either

conventional or priority.

The CWA regulates both direct and “indirect ” dischargers (those who

discharge to publicly owned treatment works). The National Pollutant

Discharge Elimination System (NPDES) permitting program (CWA section

402) controls direct discharges into navigable waters. Direct discharges or

“point source” discharges are from sources such as pipes and sewers. NPDES

permits, issued by either EPA or an authorized state (EPA has authorized 43

states and 1 territory to administer the NPDES program), contain industryspecific, technology-based and water quality-based l i mits and establish

pollutant monitoring and reporting requirements. A facility that proposes to

di scharge into the nation’s waters must obtain a permit prior to initiating a

discharge. A permit applicant must provide quantitative analytical data

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

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

may make a discharge.

Water quality-based dis charge limits are based on federal or state water

quality criteria or standards, that were designed to protect designated uses of

surface waters, such as supporting aquatic life or recreation. These standards,

unlike the technology-based standards, generally do not take into account

technological feasibility or costs. Water quality criteria and standards vary

from state to state, and site to site, depending on the use classification of the

receiving body of water. Most states follow EPA guidelines which proposeAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 121 aquatic life and human health criteria for many of the 126 priority pollutants.

Storm Water Discharges

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

address storm water discharges. In response, EPA promulgated NPDES

permitting regulations for storm water discharges. These regulations require

that f a cilities with the following types of storm water discharges, among

others, apply for an NPDES permit: (1) a discharge associated with industrial

activi ty; (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 section 122.26. Six of the categories are defined by SIC codes

while the other f

ive 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 occu r are subject to storm water discharge permit

application requirements.

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

application requirements are identified below. To determine whether a

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

consulted.

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

performance standards, or toxic pollutant effluent standards.

Category ii: F acilities class ified as SIC 24-lumber and wood products

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

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

(except drugs and paints); SIC 29-petroleum refining; SIC 311-leather tanning

and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete; SIC 33-

primary metals; SIC 3441-fabricated structural metal; and SIC 373-ship and

boat building and repairing.

Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal

mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral mining.

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

Category v: L

andfills, land application sites, and open dumps that receive or

have received industrial wastes.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 122 Category vi: F acilities 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 : F

acilities 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: C o nstruction 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, ena mels, 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 fabri cated structural metal); SIC 35-

industrial and commercial machinery and computer eq uipment; SIC 36-

electronic and other electrical equipme nt and components; SIC 37-

transportation equipment (except ship and boat building and repairing); SIC

38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous

manufacturing industrie s; 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 (POTW ). The national pretreatment program

(CWA section

307(b)) controls the indirect discharge of pollutants to POTWs

by “industr ial users.” Facilities regulated under section 307(b) must meet

certain pretreatment standards. The goal of the pretreatment program is to

protect municipal wastewater treatme nt plants from damage that may occur

when hazardous, toxic, or other wastes are discharged into a sewer system and

to protect the quality of sludge generated by these plants.

EPA has developed te chnology-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 toAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 123 assist the POTW in achieving the effluent limitations in its NPDES permit.

Regardless of whether a state is authorized to implement either the NPDES or

the pretreatment

program, if it develops its own program, it may enforce

requirements more stringent than federal standards.

Wetlands

Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools,

playas, and prairie potholes, are a subset of “waters of the United States,” as

defined in section 404 of the CWA. The placement of dredge and fill material

into wetlands and other water bodies (i.e., waters of the United States) is

regulated by the United States Army Corps of Engineers (Corps) under 33 CFR

Part 328. The Corps regulates wetlands by administering the CWA section

404 permit program for activities that impact wetlands. EPA’s authority under

section 404 includes veto power of Corps permits, auth ority to interpret

statutory exemptions and jurisdiction, enforcement actions, and delegating the

section 404 program to the states.

EPA’s Office of Water, at (202) 260-5700, will direct callers with questions

about the CWA to the appropriat e 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.

Oil Pollution Prevention Regulation

Section 311(b) of the CWA prohibits the discharge of oil, in such quantities

as may be harmful, into the navigable waters of the United States and adjoining

shorelines. The EPA Discharge of Oil regulation, 40 CFR Part 110, provides

information regarding these discharges. The Oil Pollution Prevention

regulation, 40 CFR Part 112, under the authority of section 311(j) of the CWA,

requires regulated facilities to pre pare and implement Spill Prevention Control

and Countermeasure (SPCC) plans. The intent of a SPCC plan is to prevent

the discharge of oil from onshore and offshore non-transportation-related

facilities. In 1990, Congress passed the Oil Pollution Act which amended

section 311(j) of the CWA to require facilities that because of their location

could reasonably be expected to cause “substantial harm” to the environment

by a discharge of oi l to develop and implement Facility Response Plans

(FRP). The intent of a FRP is to provide for planned responses to discharges

of oil.

A facility is SPCC-regulated if the faci lity, due to its location, could

reasonably be expected to discharge oil into or upon the navigable waters of

the United States or adjoining shorelines, and the facility meets one of the

following criteria regarding oil storage: (1) the capacity of any aboveground

storage tank exceeds 660 gallons, or (2) t h e total aboveground storage capacity

exceeds 1,320 gallons, o r (3) the underground storage capacity exceeds 42,000

gallons. The 40 CFR section 112.7 contains the format and contentAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 124 requirements for a SPCC plan. In New Jersey, SPCC plans can be combined

with DPCC plans required by the state provided there is an appropriate crossreference index to the requirements of both regulations at the front of the plan.

According to the FRP regulation, a facility can cause “substantial harm” if it

meets one of the following c riteria: (1) the facility has a total oil storage

capacity greater than or equal to 42,000 gallons and transfers oil over water

to or from vessels; or (2) the facility has a total oil storage capacity greater

than or equal to 1 million gallons and meets any one of the following

conditions: (i) does not have adequate secondary containment, (ii) a discharge

could cause “injury” to fish and wildlife and sensitive environments, (iii) shut

down a public drinking water i ntake, or (iv) has had a reportable oil spill

greater than or equal to 10,000 gallons in the past 5 years. Appendix F of 40

CFR Part 112 contains the format and content requirements for a FRP. The

FRPs that meet EPA’s requirements can be combined with United States Coast

Guard FRPs or ot

her contingency plans, provided there is an appropriate

cross-reference index to the requirements of all applicable regulations at the

front of the plan.

For additional information re g arding SPCC plans, contact EPA’s RCRA,

Superfund, and EPCRA Hotline, at (800) 424-9346. Additional documents

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

www.epa.gov/epaoswer/hotline. The hotline operates weekdays from 9:00

a.m. to 6:00 p.m., EST, excluding federal holidays.

Safe Drinking Water Act

The Safe Drinking Water A ct (SDWA) mandates that EPA establish

regulations to protect human health from contaminants in drinking water. The

law authorizes EPA to develop national drinking water standards and to create

a joint federal-state system to ensure compliance with these standards. The

SDWA also directs EPA to protect underground sources of drinking water

through the control of underground injection of fluid wastes.

EPA has developed primary and secondary drinking water standards under its

SDWA authority. EPA and authorized states enforce the primary drinking

water standards that are contaminant-specific concentration limits that apply

to certain public drinking water supplies. Primary drinking water standards

consist of maximum contaminant level goals (M CLGs), which are

non-enforceable h

ealth-based goals, and maximum contaminant levels (MCLs),

which are enforceable limits set generally as close to MCL Gs as possible,

considering cost and feasibility of attainment.

The SDW A 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. The UIC permits include

design, operating, inspection, and monitoring requ irements. Wells used toAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 125 inject hazardous wastes must also comply wit h 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 often

state/tribe-enforced, since EPA has authorized many states/tribes to administer

the program. Currently, EPA shares the UIC permit program responsibility in

seven states and runs the program in 10 states and on all tribal lands.

The SDWA also provides for a federally-implemented Sole Source Aquifer

program, which prohibits federal funds from being expended on projects that

may contaminate the sole or principal source of drinking water for a given

area, and for a state-implemented Wellhead Protection program, designed to

protect drinking water wells and drinking water recharge areas.

The SDWA Amendments of 1996 require states to develop and implement

source water assessment programs (SWAPs) to analyze existing and potential

threats to the quality of the public drinking water throughout the state. Every

state is required to submit a program to EPA and to complete all assessments

within 3 1⁄2 years of EPA app roval of the program. SWAPs include: (1)

delineating the source water protection area; (2) co nducting a contaminant

source inventory; (3) determining the susceptibility of the public water supply

to contamination from the inventories sources; and (4) releasing the results of

the assessments to the public.

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

and distributes guidance pertaining to SDWA standards. The Hotline

operates from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays.

Visit the website at http://www.epa.gov/ogwdw for additional material.

Resource Conservation and Recovery Act

The Solid Waste Disposal Act (SWDA), as amended by the Resource

Conservation and Recovery Act (RCRA) of 1976, addresses soli d and

hazardous waste management activities. The Act is commonly referred to as

RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984

strengthened RCRA’s waste management provisions and added Sub title 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 go v erning hazardous waste

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

specific materials listed in the regulations (discarded commercial chemical

products, designated with the code “P” or “U”; hazardous wastes from specific

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

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

a hazardous waste characteristic (ignit ability, corrosivity, reactivity, or

toxicity and designated with the code “D”).Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 126 Entities that generate hazardous waste are subject to waste accumulation,

manifesting, and recordkeeping standa rds. A hazardous waste facility may

accumulate hazardous waste for up to 90 days (or 180 days depending on the

amount generated per month) without a permit or interim status. Generators

may also treat hazardous waste in accumulation tanks o r containers (in

accordance with the requirements of 40 CFR section 262.34) without a permit

or interim status.

Facilities that tr eat, store, or dispose of hazardous waste are generally

required to obtain a RCRA permit. Subtitle C permits for treatment, storage,

or disposal facilities contain general facility standards such as contingency

plans , emergency procedures, recordkeeping and reporting requirements,

financial assuranc e mechanisms, and unit-specific standards. RCRA also

c ontains provisions (40 CFR Part 264 Subparts I and S) for co nducting

corrective actions which govern the cleanup of releases of hazardous waste or

constituents from solid waste management units at RCRA treatment, storage,

or disposal facilities.

Although RCRA is a federal statute, many states implement the RCRA

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

provisions of RCRA to 47 of the 50 states and two United States territories.

Delegation has not been given to Alaska, Hawaii, or Iowa.

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

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

are some important RCRA regulatory requirements:



### C Criteria for Classification of Solid Waste Disposal Facilities and Practices

(40 CFR Part 257) establishes the criteria for determining which solid waste

disposal f

acilities and practices pose a reasonable probability of adverse

effects on health or the environment. The criteria were adopted to ensure nonmunicipal, non

-hazardous waste disposal units that receive conditionally

exempt small quantity generator waste do not present risks to human health and

environment.



### C Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) establishes

minimum national criteria for all municipal solid waste landfill units,

including those that are used to dispose of sewage sludge.

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

the standard to determine whether the mater ial in question is considered a

solid waste and, if so, whether it is a hazardous waste or is exempted from

regulation.

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

establishes the responsibilities of hazardous waste generators including

obtaining an EPA ID number, preparing a manifest, ensuring proper packagingAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 127 and labeling, meeting standards for waste accumulation units, and

recordkeeping and reporting requirements. Generators can accumulate

hazardous waste on-site for up to 90 days (or 180 days depending on the

amount of waste generated) without obtaining a permit.

• Land Disposal Restrictions (LDRs) (40 CFR Part 268) are regulations

prohibiting the disposal of hazardous waste on land without prior treatment.

Under the LDRs program, materials must meet treatment standards prior to

placement in a RCRA land disposal unit (landfill, land treatment unit, waste

pile, or surface impoundment). Generators of waste subject to the LDRs must

provide notification of such to the designated TSD facility to ensure proper

treatment prior to disposal.

• Used Oil Management Standards (40 CFR Part 279) impose management

requirements affecting the storage, transportation, burning, processing, and

re-refi n ing of the used oil. For parties that merely generate used oil,

regulations establish storage standards. For a party considered a used oil

processor, re-refiner, burner, or marketer (one who generates an d sells

off-specification used oil directly to a used oil burner), additional tracking and

paperwork requirements must be satisfied.

• Tanks and Containers Standards (40 CFR Part 264-265, S ubpart CC)

contains unit-specific standards for all units used to store, treat, or dispose of

hazardous waste. Tanks and containers used to store hazardous waste with a

high volatile organic conce ntration must meet emission standards under

RCRA. Regulations require generators to test the waste to determine the

concentration of the waste, to satisfy tank and container emissions standards,

and to inspect and monitor regulated units. These regulations apply to all

facilities who store such waste, including large quantity generators

accumulating waste prior to shipment offsite.

• Underground Storage Tanks (USTs) containing petrole um and hazardous

substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40

CFR Part 280) contain tank design and release detection requirements, as well

as financial responsibility and corrective action standards for USTs. The UST

program also includes upgrade requirements for existing tanks that were to be

met by December 22, 1998.

• Boilers and Ind

ustrial Furnaces (BIFs) that use or burn fuel containing

hazardous waste must comply with design and operating standard s. BIF

regulations (40 CFR Part 266, Subpart H) address unit design, prov ide

performance standards, require e missions monitoring, and, in some cases,

restrict the type of waste that may be burned.

EPA's RCRA, Superfund, and EPCRA Hotline, at (800) 424-9346, responds

to questions and distributes guidance regar ding all RCRA regulations.

A dditional documents and resources can be obtained from the hotlin e’sAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 128 homepage at http://www.epa.gov/epaoswer/hotline. The RCRA Hotline

operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal

holidays.

Comprehensive Environmental Response, Compensation, and Liability Act

The Comprehensive Environmental Response, Compensation, and Liabi lity

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

to respond to releases, or t hreatened releases, of hazardous substances that

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

enables EPA to force parties responsible for environmental contamination to

clean it up or to reimburse the Superfund for response or remediation costs

in c urred 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 Communit y Right-to-Know Act

(EPCRA).

The CERCLA hazardous substance release reporting regulations (40 CFR Part

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

Center (NRC) an

y environmental release of a hazardous substance which

equals or exceeds a reportable quantity. Reportable quantities are listed in 40

CFR section 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 substa nce responses according to procedures

outlined in the National Oil and Hazardous Substances Pollution Contingency

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

T he National Priorities List (NPL) currently includes approximately 1,300

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

responsible parties the opportunity to conduct cleanups and encourages

community involvement throughout the Superfund response process.

EPA's RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers

questions and references guidance pertaining to the Superfund program.

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

http:// www.epa.gov/epaoswer/hotline. The Superfund Hotline operates

weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.

Emergency Planning and Community Right-To-Know Act

The Superfund Amendments and Reauthorization Act (SARA) of 1986 created

the Emergen

cy 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 fa c ilitate the development of

chemical emergency response plans by state and local governments. Under

EPCRA, states establish State Emergency Response Commissions (SERCs),Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 129 responsi ble 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:

• EPCRA section 302 requires facilities to notify the SERC and LEPC

of the presence of any extremely hazardous substance at the facility in

an amount in excess of the established threshold planning quantity. The

list of extremely hazardous substances and their threshold planning

quantities is found at 40 CFR Part 355, Appendices A and B.

• EPCRA section 303 requires that each LEPC develop an emergency

plan. The plan must contain (but is not limited to) the identification of

facilities within the planning d istrict, likely routes for transporting

extr e mely hazardous substances, a description of the methods and

procedures to be followed by facility owners and operators, and the

designation of community and facility emer gency response

coordinators.

• EPCRA section 304 requires the facility to notify the SERC and the

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

CERCLA hazardous subst ance (defined at 40 CFR Part 302) or an

EPCRA extremely hazardous substance.

• EPCRA sections 311 and 312 require a facility at which a hazardous

chemical, as defined by the Occupat ional Safety and Health Act, is

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

SERC, LEPC and local fire department material saf e ty data sheets

(MSDSs) or lists of MSDSs and hazardous chemical inventory forms

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

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

• EPCRA section 313 requires certain covered facilities, includ i ng SIC

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

and which manufacture, process, or use specified chemical s 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 to x ic chemicals to various facilities and

environmental media. EPA maintains the data reported in a publically

accessible database known as the Toxics Release Inventory (TRI).

All informatio n submitted pursuant to EPCRA regulations is publicly

accessible, unless protected by a trade secret claim.

EPA's RCRA, Superfund, and EPCRA Hotline, at (800) 535-0202, answers

questions and distributes guidance regarding the emergency planning and

community right-to- know regulations. Documents and resources can beAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 130 obtained from the hotline’s homepage at

http://www.epa.gov/epaoswer/hotline. The EPCRA Hotline operates

weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.

Clean Air Act

The Clean Air Act (CAA) and its amendments are designed to “protect and

enhance the nation's air resou rces so as to promote the public health and

welfare and the productive capacity of the population.” The CAA consists of

six sections, known as Titles, which direct EPA to establish national standards

for ambient air quality and for EPA and the states to implement, maintain, and

enforce these standards through a variety of mechanisms. Under the CAA

,

many facilities are required to obtain operating permits that consolidate their

air emission requirements. State and local governments oversee, manage, and

enforce many of the requirements of the C AA. CAA regulations appear at 40

CFR Parts 50-99.

Pursuant to Titl e I of the CAA, EPA has established national ambient air

quality standards (NAAQSs) to limit levels of “criteria pollutants,” including

carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur

dioxide. Geographic areas that meet NAAQSs for a given pollutant are

designated as attainment areas; those that do not meet NAAQSs are designated

as non-attainment areas. Under section 110 and other provisions of the CAA,

each state must develop a State Implementation Plan (SIP) to identify sources

of air pollution and to determine what reductions are required to meet federal

air quality standards. Revised NAAQSs for particulates and ozo ne were

finalized in 1997. However, these revised NAAQSs are currently being

challenged before the U.S. Supreme Court.

Title I also authorizes EPA to establish New Source Performance Standards

(NSP S), which are nationally uniform emission standards for new and

modified stationary sources fall ing within particular industrial categories. The

NSPSs are based on the pollution control technology available to that category

of industrial source ( see 40 CFR Part 60).

Under Title I, EPA establishes and enforces National Emission Standards for

Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented

toward controlling specific hazardous air pollutants (HAPs). Section 112(c)

of the CAA

further directs EPA to develop a list of sources that emit any of

188 HAPs and to develop regulations for these categories of sources. To date

E PA has listed 185 source categories and developed a schedule for the

establishment of emission standards. The emission standards are being

developed for both new and existing sources based on “maximum achievable

control technology” (MACT). The MACT is defined as the control technology

achieving the maximum degree of reduction in the emission of the HAPs, taking

into account cost and other factors.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 131 Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, and

planes. Reformulated gasoline, automobile pollution control devices, and

vapor recovery nozzles on gas pumps are a few of the mechanisms EPA uses

to regulate mobile air emission sources.

Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions program

designed to reduce the formation of acid rain. Reduction of sulfur dioxide

releases will be obtained by granting to certain sources limited emissions

allowances that are set below previous levels of sulfur dioxide releases.

Title V of the CAA establishes an operating permit program for a ll “major

sources” (and certain other sources) regulated under the CAA. One purpose

of the operating permit is to include in a s ingle document all air emissions

requirements that apply to a given facility. States have developed the permit

prog rams in accordance with guidance and regulations from EPA. Once a

state program is approved by EPA, permits are issued and monitored by that

state.

Title VI of the CAA is intended to protect stratospheric ozone by phasing out

the manufactu

re of ozone-depleting chemicals and restrict their usage and

di stribution. Production of Class I substances, including 15 kinds of

chlorofluorocarbons (CFCs), were phased out (except for essential uses) in

1996. Methyl bromide, a common pesticide, has been identified as a

significant stratospheric ozone depleting chemical. The production and

importation of methyl bromide, therefore, is currently being phased out in the

United States and internationally. As specified in the Federal Register of June

1, 1999 (Volume 64, Number 104) and in 40 CFR Part 82, methyl bromide

production and importation will be reduced from 1991 levels by 25% in 1999,

by 50% in 2001, by 70% in 2003, and completely phased out by 2005. Some

uses of methyl bromide, such the production, importation, and consumption of

methyl bromide to fumigate commodities entering or leaving the United States

or any state (or political subdivision thereof) for purposes of compliance with

Animal and Plant Health Inspection Service requirements or with any

international, federal, st ate, or local sanitation or food protection standard,

will be exempt from this rule. After 2005, exceptions may also be made for

critical agricultural uses. The United States EPA and the United Nations

Environment Programme have identified alternatives to using methyl bromide

in agriculture. Information on the methyl bromide phase-out, including

alternatives, can be found at the EPA Methyl Bromide Phase-Out Web Site:

(http://www.epa.gov/docs/ozone/mbr/mbrqa.html).

EPA's Clean Air Technology Center, at (919) 541-0800 and at the Center’s

homepage at http://www.epa.gov/ttn/catc, provides general assistance and

information on CAA standards. The Stratospheric Ozone Information

Hotline, at (800) 296-1996 and at ht tp://www.epa.gov/ozone, provides

general information about regulations promulgated under Title VI of the

CAA; EPA's EPCRA Hotline, at (800) 535-0202 and atAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 132 http://www.epa.gov/epaoswer/hotline, answers questions about accidental

release prevention under CAA section 112(r); and information on air toxics

can be accessed through the Unified Air To xics website at

http://www.epa.gov/ttn/uatw. In addition, the Clean Air Technology

Center’s website includes recent CAA rules, EPA guidance documents, and

updates of EPA activities.

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 ris ks which may be posed by their manufacture,

processing, and use. TSCA provides a variety of control methods to prevent

chemicals from posing unreasonable risk. It is important to note that pesticides

as defined in F IFRA are not included in the definition of a “chemical

substance” when manufactured, processed, or distributed in commerce for use

as a pesticide.

TSCA standards may apply at any point during a chemical’s life cycle. Under

TSCA section 5, EPA established an inventory of chemical substances. If a

chemical substance 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 chemical’s effects, EPA can impose

restrictions pending the development of information on its he alth 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.

Under TSCA section 6, EPA can ban the manufacture or di stribution in

commerce, limit the use, require labeling, or p lace other restrictions on

chemicals that pose unreasonable risks. Among the chemicals EPA regulates

under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and

polychlorinated biphenyls (PCBs).

Under TSCA section 8(e), EP A requires the producers and importers (and

other s ) of chemicals to report information on a chemical’s production, use,

exposure, and risks. Companies producing and importing chemicals can be

required to report unpublished health and safety studies on listed chemicals

and to collect and record any allegati ons of adverse reactions or any

information indicating that a substance may pose a substantial risk to humans

or the environment.

EPA’s TSCA Assistance Information Service, at 202 554-1404, answers

questions and distributes guidance pertaining to Toxic Substances Control

Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,

excluding federal holidays.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 133 Coastal Zone Management Act

The Coastal Zone Management Act (CZMA) encourages stat es/tribes to

preserve, protect, develop, and where possible, restore or enhance valuable

natural coastal resources such as wetlands, floodplains, estuaries, beaches,

dunes, barrier islands, and coral reefs, as well as the fish and wildlife using

those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic

Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique feature

of this law is that participation by states/tribes is voluntary.

In the Coastal Zone Management Act Reauthorization Amendments (CZARA)

of 1990, Congress identified nonpoint source pollution as a major factor in the

continui ng degradation of coastal waters. Congress also recognized that

effective solutions to nonpoint source pollution could be implemented at the

state/tribe and local levels. In CZARA, Congress added section 6217 (16

U.S.C. section 1455b), whic h calls upon states/tribes with federally-approved

coasta l zone management programs to develop and implement coastal nonpoint

pollution control programs. The section 6217 program is administered at the

federal level jointly by EPA and the N ational Oceanic and Atmospheric

Agency (NOAA).

Section 6217(g) called for EPA, in consultati o n with other agencies, to

develop guidance on “management measures” for sources of nonpoint source

pollution in coastal waters. Under section 6217, EPA is responsible for

developing technical guidance to assist st ates/tribes in designing coastal

nonpo i nt pollution control programs. On January 19, 1993, EPA issued its

Guidance Specifying Management Measures Fo r Sources of Nonpoint

Pollution in Coastal Waters

, which addresses five major source categories

of nonpoint pollut ion: (1) urban runoff, (2) agriculture runoff, (3) forestry

runoff, (4) marinas and recreational boating, and (5) hydromodification.

Additional information on coastal zone management may be obtained from

EPA’s Office of Wetlands, Oceans, and Watersheds at

http://www.epa.gov/owow or from the Watershed Information Network at

http://www.epa.gov/win. The NOAA website at

http://www.nos.n oaa.gov/ocrm/czm/ also contains additional information on

coastal zone management.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 134 VI.B. Industry Specific Requirements

Th e agricultural chemical industry is affected by several major federal

environmental statutes. In addition, the industry is subject to numerous laws

and regulations from state and local governments designed to protect health,

safety, and the environment. A summary of the major federal regulations

affecting the agricultural chemical industry follows.

Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)

Every regulation promulgated under FIFRA affects the agricultural chemical

industry in some way. The FIFRA regulations are found in 40 CFR Parts 152

through 186. Each part and its title are listed below.

Part 152 - Pesticide Registration and Classification Procedures

Part 153 - Registration Policies and Interpretations

Part 154 - Special Review Procedures

Part 155 - Registration Standards

Part 156 - Labeling Requirements for Pesticides and Devices

Part 157 - Packaging Requirements for Pesticides and Devices

Part 158 - Data Requirements for Registration

Part 160 - Good Laboratory Practice Standards

Part 162 - State Registration of Pesticide Products

Part 163 - Certification of Usefulness of Pesticide Chemicals

Part 164 - Rules of Practice Governing Hearings, Under FIFRA,

Arising from Refusals to Register, Cancellations of

Registrations, Changes of Classifications, Suspensions of

Registrations and Other Hearings Called Pursuant to section

6 of the Act

Part 166 - Exemption of Federal and State Agencies for Use of

Pesticides Under Emergency Conditions

Part 167 - Registration of Pesticide and Active Ingredient Producing

Establishments, Submission of Pesticide Reports

Part 168 - Statements of Enforcement Policies and Interpretations

Part 169 - Books and Records of Pesticide Production and

Distribution

Part 170 - Worker Protection Standards

Part 171 - Certification of Pesticide Applicators

Part 172 - Experimental Use Permits

Part 173 - Procedures Governing the Rescission of State Primary

Enforcement Responsibility for Pesticide Use Violations

Part 177 - Issuance of Food Additive RegulationsAgricultural Chemical Industry Federal Statutes and Regulations

4 A custom blender means any establishment which provides the service of mixing pesticides to a customer’s

specifications, usually a pesticide(s)-fertilizer(s), pesticide-pesticide, or a pesticide animal feed mixture, when:

(1) The blend is prepared to the order of the customer and is not held in inventory by the blender; (2) the blend is

to be used on the customer’s property (including leased or rented property); (3) the pesticide(s) used in the blend

bears end-use labeling directions which do not prohibit use of the product in such a blend; (4) the blend is prepared

from registered pesticides; (b) the blend is delivered to the end-user along with a copy of the end-use labeling of

each pesticide used in the blend and a statement specifying the composition of mixture; and (6) no other pesticide

production activity is performed at the establishment.

Sector Notebook Project September 2000 135 Part 178 - Objections and Requests for Hearings

Part 179 - Formal Evidentiary Public Hearing

Part 180 - Tolerances and Exemptions from Tolerances for Pesticide

Chemicals in or on Raw Agricultural Commodities

Part 185 - Tolerances for Pesticides in Food

Part 186 - Pesticides in Animal Feed

Please refer to the general discussion of FIFRA in Section VI.A for additional

requirements not discussed below.

Product Registration Data Requirements

EPA requires the citation or submission of extensive environmental, health,

and/or safety data during the registration application process. The categories

of data required include the product’s chemistry; environmental fate; residue

chemis try, hazards to humans, domestic animals, and nontarget organisms;

spray drift characteristics; reentry protection requirements; and performance

(40 CFR Part 158). Under the “product chemistry” category, applicants must

supply technical informatio n describing the product’s active and inert

ingredients, manufacturing or formulating p rocesses and physical and chemical

characteristics. Data from “environmental fate” studies are used to assess the

effects of pesticide residues on the environment, including its toxicity to

people thr ough consumption or exposure to applied areas and its effect on

nontarget organisms and their habitat. Residue chemistry information includes

the expected frequency, amounts, and time of application, and test results of

residue remaining on treated food or feed. Information under “hazards to

humans, domestic animals, and non-target organisms” includes specific test

data assessing acute, subchronic, and chronic toxicity. All studies required to

be submitted

must satisfy Good Laboratory Practice (GLP) regulations (40

CFR Part 160). Guidelines for studies of product chemistry, residue

chemistry, environmental chemistry, hazard evaluation and occupational and

residential exposure can be found in 40 CFR Part 158.

Registration of Establishments

Any person

producing a pesticide or device, except a custom blender, 4 is

s ubject to section 7 and 40 CFR. Part 167; and is required to register his

establishment with EPA prior to beginning production. Foreign establishments

also must register with EPA if they produce a pesticidal product for import toAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 136 the United States. Establishments must be registered with EPA if they intend

that a substance produced will be used as an active ingredient of a pesticide

or if they have actual or constructive notice that the substance will be used as

an active ingredient. If a pesticide is produced for export, whether registered

or unregistered, or is produced under an experimental use per mit, the

producing establishment must be registered.

In order to register an establishment with EPA, contact the EPA Regional

office where the establishment is located, or for a foreign establishment, the

Washington, DC EPA office. The following information must be submitted on

EPA Form 354 0 -1 when registering an establishment: (1) the name and

address of the company; (2) the type of ownership; and (3) the name and

address of each producing establishment for which registration is sought. Any

changes to the information provided must be submitted to EPA within thirty

days after such changes occur. Upon receiving a complete application, EPA

will assign a registration number for each listed establishment. This number

must appear on the label.

Establishment Reporting Requirements

Under section 7(c)and 40 CFR. section 167.85, each registered pesticide

producing establishment must submit an annual production report to EPA by

March 1 of each year. Domestic establishments submit their report to the EPA

regional office where the company headquarters is located. Foreign

establishment production reports are submitted to the Washington, DC EPA

office. Custom blenders are exempt from this requirement.

The report must cover any pesticide, active ingredient, or device produced.

The report, to be submitted on specific EPA forms, includes the following

information: (1) the name and address of the establishment; (2) the amount of

each pesticide produced, repackaged, or relabeled in the past year; ( 3) the

amount of each pesticide sold, distributed, or exported in the past year; and (4)

the amount of the pesticide estimated to be produced, repackaged, or relabeled

in the current year. Foreign establishments only are required to submit a report

on pesticides imported into the United States.

Maintenance of Records

All producers of pesticides, devices, or active ingredients used in producing

any pesticide must maintain records concerning the production and shipment

of each pesticide under 40 CFR Part 169. These records are independent of

other required records, including in-plant maintenance, extermination, or

sanitation programs. Each establishment must maintain these records for two

years. In addition, records on disposal methods must be maintained for 20

years, as well as authorized human trials. Records containing research data

must be maintained as long as the registration is valid and the producer is in

business. All required records must be available if requested by an inspector.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 137 Prior Informed Consent

As part of its participation in a voluntary international program known as the

Prior Informed Consent procedure, EPA prepares the following lists of

pesticides t

hat are suspended, canceled or severely restricted. These lists

were last updated by EPA in August of 1997.

A “Suspended or Canceled” pesticide is defined as a pesticide for which all

registered uses have been prohibited by final government action, or for which

all requests for registration or equivalent action for all uses have, for health

or environmental reasons, not been granted.



### C Suspended or Canceled

1. aldrin

2. benzene hexachloride [BHC] (voluntary cancellation)

3. 2,3,4,5-Bis(2-butylene)tetrahydro-2-furaldehyde [Repellent-11]

4. bromoxynil butyrate (voluntary cancellation)

5. cadmium compounds (voluntary cancellation)

6. calcium arsenate (voluntary cancellation)

7. captafol (voluntary cancellation)

8. carbon tetrachloride

9. chloranil (voluntary cancellation)

10. chlordane

11. chlordimeform (voluntary cancellation)

12. chlorinated camphene [Toxaphene] (voluntary cancellation)

13. chlorobenzilate (voluntary cancellation)

14. chloromethoxypropylmercuric acetate [CPMA]

15. copper arsenate (voluntary cancellation)

16. cyhexatin (voluntary cancellation)

17. DBCP

18. decachlorooctahydro-1,3,4-metheno-2H-cyclobuta(cd) pentalen-2-

one[chlordecone]

19. DDT

20. dieldrin

21. dinoseb and salts

22. Di(phenylmercury)dodecenylsuccinate [PMDS] (voluntary

cancellation)

23. EDB

24. endrin (voluntary cancellation)

25. EPN (voluntary cancellation)

26. ethyl hexyleneglycol [6-12] (voluntary cancellation)

27. hexachlorobenzene [HCB] (voluntary cancellation)

28. lead arsenate (voluntary cancellation)

29. leptophos (Never received initial registration)

30. mercurous chloride

31. mercuric chlorideAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 138 32. mevinphos

33. mirex (voluntary cancellation)

34. monocrotophos (voluntary cancellation)

35. nitrofen (TOK) (voluntary cancellation)

36. OMPA (octamethylpyrophosphoramide)

37. phenylmercury acetate [PMA]

38. phenylmercuric oleate [PMO] (voluntary cancellation)

39. potassium 2,4,5-trichlorophenate [2,4,5-TCP]

40. pyriminil [Vacor] (voluntary cancellation)

41. safrole (voluntary cancellation)

42. silvex

43. sodium arsenite

44. TDE (voluntary cancellation)

45. Terpene polychlorinates [Strobane] (voluntary cancellation)

46. thallium sulfate

47. 2,4,5-Trichlorophenoxyacetic acid [2,4,5-T]

48. vinyl chloride

A “Severely Restricted” pesticide means a pesticide for which virtually all

registered uses have been prohibited by final government regulatory action, but

for which certain specific registered use or uses remain authorized.



### C Severely Restricted

1. arsenic trioxide

2. azinphos methyl

3. carbofuran (voluntary cancellation)

4. daminozide (voluntary cancellation)

5. heptachlor

6. methyl parathion

7. sodium arsenate

8. tributyltin compounds

Federal Food, Drug, and Cosmetics Act

Under the Federal Food , Drug, and Cosmetics Act (FFDCA), EPA sets

tolerances for pesticide residues in food. This authority originally belonged

to the Food and Drug Administration (FDA), but was transferred when EPA

was formed in 1970. FDA still has responsibility for enforcing compliance

with the tolerances. An agricultural product is deemed unsafe under the

FFDCA if it contains pesticide residues above the tolerance level established

by EPA or if there is no tolerance, unless it is exempt from the requirement for

tolerances.

The FFDCA also contains the Delaney Clause that bars the establishment of

food additive regulations covering substances that induce cancer in humans or

animals. Prior to the Food Quality Protection Act of 1996, this provisionAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 139 applied to certain pesticide res idues in processed food. With the 1996

amendments, pesticide residues are now governed by a single safety clause set

forth in section 408.

Toxic Substances Control Act (TSCA)

TSCA gives EPA comprehensive authority to regulate any chemical substance

whose manufacture, processing, distribution in comme rce, use, or disposal

may present an unreasonable risk of injury to health or the environment. EPA

keeps a n inventory of existing chemicals regulated under TSCA (TSCA section

8(b)). Certain chemicals are specifically excluded from the TSCA inventory,

such as pesticides, as defined when manufactured, processed, or distributed

in comm erce for use as a pesticide under FIFRA (40 CFR section

710.2(h)(2)). However, if a chemical has multiple uses, those uses not subject

to FIFRA are regulated by TSCA. In addition, certain mixtures of chemicals

are exempt from TSCA (40 CFR section 710.2(h)(1)) (Landfair, 1993).

Four sections are of primary importance to the remainder of the agricultural

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 (40

CFR Part 720). Over 20,000 premanufacture notices have been filed. Section

4 authorizes EPA to require testing of certain substances (40 CFR Part 790).

Section 6 gives EPA the authority to prohibit, limit, or ban the manufacture,

process, and usage of chemicals (40 CFR Part 750). Among the chemicals

EPA regulates under section 6 are asbestos, chlorofluorocarbons (CFCs), and

polychlo rinated biphenyls (PCBs). For certain chemicals, TSCA section 8

also imposes record-keeping and reporting requirements including substantial

risk notification; record-keeping for dat a relative to adverse reactions; and

periodic updates to the TSCA Inventory.

Resource Conservation and Recovery Act (RCRA)

The Resource Conservation and Recovery Act (RCRA) was enacted in 1976

to address problems related to hazardous and solid waste management. RCRA

gives EPA the authority to establish a list of solid and hazardous wastes and

to establish standards and regulations for the treatment, storage, and disposal

of these wastes. Regulations in Subtitle C of RCRA address the identification,

generation, transportation, treatment, storage, and disposal of hazardous

wastes. These regulations are found in 40 CFR Part 124 and CFR Parts 260-

279. Under RCRA, persons who generate waste must determine whether the

waste is defined as solid waste or haz a rdous waste. Solid wastes are

considered hazardous wastes if they are listed by EPA as hazardous or if they

exhibit characteristics of a hazardous waste: toxicity, ignitability, corrosivity,

or reactivity.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 140 Products, intermediates, and off-specification products potentially generated

at agricultural che mical facilities that are considered hazardous wastes are

listed in 40 CFR Part 261. Some of the handling and treatment requirements

for RCRA hazardous waste generators are covered under 40 CFR Part 262 and

include the following: determining what constitutes a RCRA hazardous waste

(Subpart A); manifesting (Subpart B); packaging, labeling, and accumulation

time limits (Subpart C); and record keeping and reporting (Subpart D).

Many agricultural chemical facilities store some hazardous w astes at the

facility beyond the accumulation time limits available to generators (e.g., 90

or 180 days). Such facilities are required to have a RCRA treatment, storage,

and disposal facility (TSDF) permit (40 CFR Part 262.34). Some agricultural

chemical facilities are considered TSDF facilities and are subject to a number

of regulations, including but not limited to those covered under 40 CFR Part

264: contingency plans and emergency procedures (40 CFR Part 264 Subpart

D); manifesting, record keeping, and reporting (40 CFR Part 264 Subpart E);

use and management of containers (40 CFR Part 264 Subpart I); tank systems

(40 CFR Part 264 Subpart J); surface impoundments ( 40 CFR Part 264

Subpart K); land treatment (40 CFR Part 264 Subpart M); corrective action of

hazardous waste releases (40 CFR Part 264 Subpart S); air emissions

standards for process vents of processes that process or generate hazardous

wastes (40 CFR Part 264 Subpart AA); e missions standards for leaks in

hazard ous waste handling equipment (40 CFR Part 264 Subpart BB); and

emissions standards for containers, tanks, an d surface impoundments that

contain hazardous wastes (40 CFR Part 264 Subpart CC).

Many agricultural chemical f acilities are also subject to the underground

storage tank (UST) program (40 CFR Part 280). The UST regulations apply

to facilities that store either petroleum products or hazard ous substances

(except hazardous waste) identified under the Comprehensive Environmental

Response, Compensation, and Liability Act. UST regulations address design

standards, leak detection, operating practices, response to releases, financial

responsibility for releases, and closure standards.

A number of RCRA wastes have been prohibited from land disposal unless

treated to meet specific standards under the RCRA Land Disposal Restriction

(LDR) program. The wastes covered by the RCRA LDRs are listed in 40 CFR

Part 268 Subpart C and include a number of wastes that could potentially be

generated at agricultural chemical facilities. Standards for the treatment and

storage of restricted wastes are described in Subparts D and E, respectively.

The LDRs also apply to the use of fertilizers containing hazard ous wastes.

Therefore, fertilizers containing hazardous wastes that do not meet the

applicable land disposal treatment standards cannot be spread on the land,

with some exceptions. Sp ecific exemptions to the use of certain recycled

materials and hazardous wastes in fertilizers have been provided in 40 CFR

Part 266, Subpart C

- Recycled Materials Used in a Manner ConstitutingAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 141 Disposal. Subpart C states that products containing recyclable materials are

not subject to regulation under RCRA if the recyclables are physically

inseparable from the product or if they meet the standards of 40 CFR Part 268,

Subpart D “for each recyclable material (i.e., hazardous waste) that they

contain.” These standards include limits on heavy metals. Subpart C also

states that zinc-containing fertilizers using hazardous waste K061 (emission

control dust/sludge from the primary production of steel in electric furnaces)

which is listed as hazardous due to its hexavalent ch romium, lead, and

cadmium content, are not subject to the land disposal requirements.

Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)

The Comprehensive Environmental Respon se, Compensation, and Liability

Act of 1980 (CERCLA) and the Superfund Amendments and Reauthorization

Act of 1986 (SARA) provide the basic legal framework for the federal

“Superfund” program to clean up abandoned hazardous waste sites (40 CFR

Part 300 et seq.). The 1986 SARA legislation extended CERCLA taxes for

five years and adopted a new broad-based corporate environmental tax,

ap plicable to the allied chemicals (SIC 28) industry, which includes the

agricultural chemical industry. In 1990, Con g ress passed a simple

reauthorization that did not substantially change the law but extended the

program authority until 1994 and the taxing authority until the end of 1995. A

comprehensive reauthorization was considered in 1994, but not passed. Since

t he expiration of the taxing authority on December 31, 1995, taxes for

Superfund have been temporarily suspended. The taxes can only be reinstated

by reauthorization of Superfund or an omnibus reconciliation act which could

specifically reauthorize taxing authority. The allied chemical industry paid

about $300 million a year in Superfund chemical feedstock taxes. Joint and

several liability generally requires Potentially Responsible Parties (PRPs) to

perform or pay for their fair share of cleanup costs.

Title III of the 1986 SARA amendments (also known as Emergency Response

and Community Right-to-Know Act, EPCRA) requires all manufacturing

facilities, including agricultural chemical facilities, to report annual

information about stored toxic substances, a s well as release of these

substances into the environment, to local and state governments and to the

public. This is known as the Toxic Release Inventory (TRI). EPCRA also

establishes requirements for federal, state, and local governments regarding

emergency planning. In 1994, over 300 more chemicals were added to the list

of chemicals for which reporting is required.

Clean Air Act (CAA)

The original CAA authorized EPA to set li mits on agricultural chemical

facility emissions. The new source performance standards (NSPS) for

fertilizer manufacturers can be found in 40 CFR Part 60:Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 142 Subpart G - Standards of Performance for Nitric Acid Plants

(40 CFR section 60.70 - 60.74)

Subpart T - Standards of Performance for the Phosphate Fertilizer

Industry: Wet Process Phosphoric Acid Plants

(40 CFR section 60.200 - 60.204)

Subpart U - Standards of Performance for the Phosphate Fertilizer

Industry: Superphosphoric Acid Plants

(40 CFR section 60.210 - 60.214)

Subpart V - Standards of Performance for the Phosphate Fertilizer

Industry: Diammonium Phosphate Plants

(40 CFR section 60.220 - 60.224)

Subpart W - Standards of Performance for the Phosphate Fertilizer

Industry: Triple Superphosphate Plants

(40 CFR section 60.230 - 60.234)

Subpart X - Standards of Performance for the Phosphate Fertilizer

Industry: Granular Triple Superphosphate Storage

Facilities (40 CFR section 60.240 - 60.244)

These standards primarily consist of emission and monitoring standards for

nitrogen oxides (Nitric Acid Plants) and fluorides (Phosphatic Fertilizer

Industry) .

The Clean Air Act Amendments of 1990 set National Emission Standards for

Hazardous Air Pollutants (NESHAP) from industrial sources for 41 hazardous

air pollutants to be met by 1995 and for 148 other hazardous air pollutants to

be reached by 2003. National emission standards for new and existing major

sources in phosphoric acid manufacturing, phos phate fertilizers production and

pesticide active ingredient production are listed in 40 CFR Parts 9 and 63. 40

CFR Parts 61 and 63 contains several provisions dealing with emissions

sources potentially found at an agricultural chemical facility (e.g. equipment

leaks, tanks, surface im poundments, separators, and waste treatment

operations) may affect the agricultural chemical industry. A number of the

chemicals used a nd produced at agricultural chemical manufacturing and

formulating facilities are hazardous air pollutants under CAA.

Under section 112(r) of CAA, owners and operators of stationary sources who

produce, process, handle, or store sub stances listed under CAA section

112(r)(3) or any other extremely hazardous substance have a “general duty”

to initiate specific activities to prevent and mitigate accidental releases. Since

the general duty requirements apply to stationary sources regardless of the

quantity of substances managed at the facility, many a gricultural chemical

manufacturing and formulating facilities ar e subject. Activities such as

identifying hazards which may re sult from accidental releases usingAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 143 appropriate hazard assessment techniques; de signing, maintaining and

operating a safe facility; and minimizing the consequences of accidental

releases if they occur are considered essential activities to satisfy the general

duty requirements. These statutory requirements have been in affect since the

passage of the Clean Air Act in 1990. Although there is no list of “extremely

hazardous substances,” EPA’s Chemical Emergency Prepare dness and

Prevention Office provides some guidance at its website:

http://www.epa.gov/swercepp.html.

Also under section 112(r), EPA was required to develop a list of at least 100

substances that, in the event of an accidental release, could cause death, injury,

or serious adverse effects to human health or the environ ment. The list

promulgated by EPA is contained in 40 CFR section 68.130 and includes

acutely toxic chemicals, flamma ble gases and volatile flammable liquids.

Under section 112(r)(7), facilities handling more than a threshold quantity

(ranging from 500 to 20,000 pounds) of these substances are subject to

chemical accident prevention provisions including the development and

implementation of a risk management program (40 CFR sections 68.150-

68.220). The requirements in 40 CFR Part 68 begin to go into effect in June

1999. Many of the chemicals on the 112(r) list ar e commonly handled by

agricultural chemical manufacturers and formulators in quantities greater than

the threshold values. Ammonia held by farmers for use as an agricultural

nutrient is exempt from the chemical accident prevention provisions.

Standards in 40 CFR Part 61 Subpart R - National Emission Standards for

Radon Emissions from P h osphogypsum Stacks (40 CFR sections 61.200

- 61.210) deal specifically with the phosphatic fertilizer industry. The

standards require monitoring and reporting of radon-222 emissions from the

stacks and sets limits on the amounts of radon-222 that can be emitted into the

air. EPA has also set standards for the maximum concentration of radium-226

allowed in phosphogypsum removed from stacks for use in agriculture.

Clean Water Act (CWA)

The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,

g ives EPA the authority to regulate effluents from sewage treatment works

, chemical plants, and other industrial sources into water s. The act sets

standards for treatment of wastes for both direct and indirect (to a Publicly

Own ed Treatment Works (POTW)) discharges. EPA has set effluent

guidelines for both the fertilizer manufacturing and formulating, and pesticide

formulating, packaging and repackaging point source categories. The

implementation of the guidelines is left primarily to the state s who issue

National Pollutant Discharge Elimination System (NPDES) permits for each

facility (EPA has authorized 43 states to operate the NPDES program).

Effluent guidelines specific to the fertili zer manufacturing and formulating

point source category are contained in 40 CFR Part 418 and are divided intoAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 144 product specific effluent guidelines as follows:

Subpart A - Phosphates (40 CFR section 418.10 - 418.17)

Subpart B - Ammonia (40 CFR section 418.20 - 418.27)

Subpart C - Urea (40 CFR section 418.30 - 418.36)

Subpart D - Ammonium Nitrate (40 CFR section 418.40 - 418.46)

Subpart E - Nitric Acid (40 CFR section 418.50 - 418.56)

Subpart F - Ammonium Sulfate (40 CFR section 418.60 - 418.67)

Subpart G - Mixed and Blend Fertilizer Production

(40 CFR section 418.70 - 418.77)

In 1997, revised effluent guidelines were finaliz ed for the Pesticide

Formulating, Packaging and Repackaging Subcategory. These regulations

replace the effluent guide lines established in 1978 for the Pesticide

Formulating and Packaging Subcategory. The revised guidelines are contained

in 40 CFR Part 455 and are divided into the following subcategories:

Subpart C - Pesticide Chemicals Formulating and Packaging Subcategory

Subpart E - Repackaging of Agricultural Pesticides Performed at

Refilling Establishments

Each Subpart consists of effluent standards representing the amount of effluent

reduction possible by using either best practicable control technologies (BPT),

best conventional pollution technologies (BCT), or bes t available technologies

(BAT). The states and EPA give effect to these standards through NPDES

permits that they issue to direct dischargers. BCT standards limit the

discharge of conventional pollutants, while BPT and BAT standards represent

successive levels of control of priority pollutants and non-conventional

pollutants.

For S ubcategory C, EPA established effluent limitations and pretreatment

standards which allow each f acility a choice of meeting a zero discharge

limitation or to comply with a pollution prevention alternative that authorizes

the discharge of some pesticide active ingredients (AIs) and priority pollutants

after various pollution prevention practices are followed and t reatment is

cond ucted as needed. For Subcategory E, EPA has established a zero

discharge limitation and pretreatment standard.

The S torm Water Rule (40 CFR section 122.26) requires fertilizer

manufacturing and formulating and pesticide formulating facilities discharging

storm water associa ted with industrial activities (40 CFR section 122.26

(b)(14)(ii)) to apply for NPDES permits for those discharges.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 145 Under 40 CFR 503 Subpart B - Land Application, EPA regulates the land

application of sewerage treatment sludge, which includes fertilizers derived

from sewerage treatment sludge. Subpart B regulations include specific

limitations on heavy metal content, as well as general operational and

management standards.

VI.C. State Regulation of Pesticides

All states have their

own pesticide laws and many states have their own

pesticide registration requirements. States have primary use enforcement

authority if EPA has determined that the state has adequate pesticide use laws

and has adopted adequate procedures to enforce those laws. The EPA may

enter into a cooperative agreement with a state to carry out enforcement of

state laws and train and certify applicators. The FIFRA allows states to

administer their own EPA-approved applicator certifications program. Also,

each state is allowed to regulate the sale and use of pesticides as long as the

regulations are at least as stringent as EPA’s and the regulations do not conflict

or differ from EPA’s labeling and packaging restrictions.

States typically require that fertilizer products be registered with the state and

that claims made on fertilizer labels can be substantiated. States also regulate

the efficacy of fertilizers through labeling requirements. S tate fertilizer

labeling requirements typically require that the label indicate the product

name, the brand and grade, the percentage of each nutrient (nitrogen, available

phosphate, potassium, etc.), and the name and address of the registrant. Some

states also require that the label indicate materials from which the nutrients are

derived.

Additional information on specific state requirements can be obtained from

the Association of American Pesticide Control Officials, Inc. (AAPCO) at:

http://aapco.ceris.purdue .edu/index.html. This website contains a list of

state pesticide control officials that includes contact information.Agricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 146 VI.D. Pending and Proposed Regulatory Requirements

FIFRA

Registration

• In order to reduce the potential for groundwater contamination from

certain pesticides, EPA pr oposed the Ground Water Pesticide

Management Plan Rule in June of 1996 (61 FR 33259 ). EPA is

proposing to restrict the use of certain pesticides by providing states

and tribes with the flexibility to protect the ground water in the most

appropriate way for local conditions, through the development and use

of Pesticide Management Plans (PMPs). When finali zed, the

regulations will likely give states and tribes the authority to develop

management plans that specify risk reductio n measures for the

following four pest

icides: atrazine, alachlor, simazine, and

metolachlor. Without EPA-approved plans, use of these chemicals

would be prohibited. A final rule is expected to be published in late

2000. (Contact: Arty Williams, United States EPA Office of

Prevention, Pesticides and Toxic Substances, 703-305-5239)

• In resp onse to the Food Quality Protection Act of 1996, EPA is

planning to propose revisions to antimicrobial registration and

classification procedures (40 CFR Part 152) that will reduce to the

extent possible the review ti me for antimicrobial pesticides.

Revisions to labeling requirements (40 CFR Part 156) and data

requirements for antimicrobial registration (40 CFR Part 158) are

also being pr oposed. The revisions are expected to be released in

early 2001. This regulation would also implement some general

provisions of FIFRA that pertain to all pesticides, including labeling

requirements a nd notification procedures. (Contact: Jean Frane, United

States EPA Office of Prevention, Pesticides, and Toxic Substances,

703-305-5944 and Paul Parsons, U nited States EPA Office of

Prevention, Pesticides, and Toxic Substances, 703-308-9073)

• In order to evalu ate the registrability of pesticide products, EPA is

expected to propose revisions to the data requirements for FIFRA

registration (40 CFR Part 158). These revisions would clarify all data

re quirements to reflect current practice and are expected to be

published in 2001. (Contact: Jean Frane, United States EPA Office of

Prevention, Pesticides, and Toxic Substances, 703-305-5944)

Use Restrictions

• In May of 1991, EPA proposed amendments to the existing Restricted

Use Classification (RUC) regulations (40 CFR Part 152, Subpart I) to

add criteria pertaining to the groundwater contamination potential of

pesticides (56 FR 22076). The criteria would be used to determineAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 147 which pesticides should be consi dered for restricted use

classifications to protect groundwater. A policy statement is expected

to be issued in late 2000. (Contact: Joseph Hogue, United States EPA

Office of Prevention, Pestici des, and Toxic Substances, 703-308-

9072)

Tolerances and Exemptions

• EPA expects to reassess pesticide tolerances and exemptions for raw

and processed foods established prior to August 3, 1996 (40 CFR Part

180, 40 CFR Part 185, 40 CFR Part 186), to determine whether they

meet the standard of the Federal Food, Drug an d Cosmetic Act

(FFDCA). FFDCA section 408 (q), as amended by the Food Quality

Protection Act, requires that EPA conduct th is reassessment on a

pha s ed 10-year schedule. For the current phased schedule, EPA is

required to complete reassessments as f ollows: 33% by August 3,

1999, 66% by August 3, 2002, and 100% by August 3, 2006. Based on

its reas s essment, EPA will likely propose a series of regulatory

actions to modify or revoke tolerances. (Contacts: Robert McNally,

United States EPA, Office of Prevention, Pesticides and Toxic

Substances, 703-308-8085 and Joseph Nevola, United States EPA

Office of Prevention Pesticides and Toxic Substances, 703-308-8037)

• Regulations specifying policies and procedures under which the EPA

can establish food tolerances associated with the use of pesticides

under emergency exemptions (40 CFR Part 176) are expected to be

finalized in late 2000. The EPA issues emergency exemptions for

temporary use of pesticides where emergency conditions exist. Under

FFDCA, as amended by the Food Quality Protection Act, EPA must

establish time-limited tolerances for such pesticides if the use is likely

to result in residues in food. (Contact: Joseph Hogue, United States

EPA Office of Prevention, Pesticides, and Toxic Substances, 703-308-

9072)

• EPA proposed a rule to adjust and update the fee structure and fee

amounts for tolerance actions, which are required under FFDCA (40

CFR section 180.33). The rule is expected to finalized in late 2000.

( Contact: Carol Peterson, United States EPA, Office of Prevention,

Pesticides, and Toxic Substances, 703-305-6598)

• Revisions to regulations on emergency exemptions under section 18 of

FIFRA, are expected to be issued in late 2001 (40 CFR Part 166).

EPA is considering revisions in four areas: 1) Options for increased

authority for states to administer certain aspects of the exemption

process, and/or increased use by the EPA of multi-year exemptions; 2)

the use of emergency exemptions to address pesticide resistance; 3) theAgricultural Chemical Industry Federal Statutes and Regulations

Sector Notebook Project September 2000 148 possibility of

granting exemptions based upon reduced risk

considerat

ions; and 4) definitions of emergency situation and

significant economic loss, which would affect whether or not an

exemption may be granted. (Contact: Joseph Hogue, United States

EPA Office of Pr evention, Pesticides, and Toxic Substances, 703-308-

9072)

Pesticide Storage and Disposal

• In 1994, EPA proposed a rule, authorized under section 19 of FIFRA,

to establis h standards for pesticide containers and secondary

containment relating to the distribution and sale of pesticides (59 FR

6712). Standards are expected to be developed for the removal of

pesticides from cont ainers, rinsing containers, container design,

container labeling, container refilling, the containment of stationary

bulk containers and for the containment of pesticide dispensing areas

(40 CFR Part 165, 40 CFR Part 156). A final rule is expected to be

published in late 2000. (Contact: Nancy Fitz, United States EPA,

Office of Prevention, Pesticides and Toxic Substances, 703-305-7385)

Exports

• The Rotterdam Agreement, signed in 1998 , requires that certain banned

or severely restricted hazardous chemicals are subject to intensive

information exchange procedures, and if an importing country decides

against import, exporting countries are obligated to prohibit export to

that country. Twenty-four pesticides are current ly covered by the

treaty. As a result of the United States signing of this treaty, EPA has

drafted legislation that allows it in the future to propose revisions to

its pesticide export policy. (Contact: Cathleen Barnes, United States

EPA Office of Prevention, Pesticides and Toxic Substances, 703-305-

7101)

Worker Protection

• EPA has proposed a chang e to the Worker Protection Standards (WPS)

of FIFRA (40 CFR Part 170). Specifically, the glove requirements may

be modified to a l low glove liners to be worn inside chemically

resistant gloves. The proposed rule wil l be finalized in 2001.

(Contact: Kevin Keaney, United States EPA Office of Prevention,

Pesticides and Toxic Substances, 703-305-5557)Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 149 VII. COMPLIANCE AND ENFORCEMENT HISTORY

Background

Until recently, EPA has focused much of its attention on measuring compliance

with speci fic environmental statutes. This approach allows the Agency to

track compliance with the Federal Insecticide, Fungicide, and Rodenticide

A ct, the Clean Air Act, the Resource Conservation and Recovery Act, the

Clean Water Act, and other environmental statutes. Within the last several

ye ars, 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 record s, and match the records to

individua l facilities. The IDEA system can match Air, Water, Waste,

Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given

facility, and generate a list of historical permit, inspection, and enforcement

activity. IDEA also has the capability to analyze data by geographic area and

corporate holder. As the capacity to generate multimedia compliance data

improves, EPA will make available more in-depth compliance and

enforcement information. Additionally, sector-specific measures of success

for compliance assistance efforts are under development.

Compliance and Enforcement Profile Description

Using inspection, violation and enforcement data from the IDEA system, this

section provides information regarding the historical compliance and

enforcement activity of

this sector. 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 consi s tent across sectors with certain exceptions. For

the sectors that do not nor mally 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 subs et of facilities within the

sector that are well defined within EPA databases.

A s a check on the relative size of the full sector universe, most notebooks

contain an estimated numb er 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 withinAgricultural Chemical Industry Compliance and Enforcement History

5 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).

Sector Notebook Project September 2000 150 the EPA databases may be small in comparison to Census data. However, the

group selected for inclusion in this data analysis section should be consistent

with this sector’s general make-up.

Following this introduc t ion is a list defining each data column presented

within this section. These values represent a retrospective summary of

inspections and enforcement actions, and reflect solely EPA, state, and local

compliance assurance activities 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 (April 1, 1992 to March 31, 1997) and the other for

the most recent twelve-month period (April 1, 1996 to March 31, 1997). The

f ive-year analysis gives an average level of activity for that period fo r

comparison to the more recent activity.

Be cause 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 EPA regions for

certain sectors. 5 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 whi c h regions may have the most

compliance problems.

Compliance and Enforcement Data Definitions

General Definitions

Facility Indexing System (FINDS)

-- assigns a common facility number to

EPA single-media permit records. The FINDS identification number allows

EPA to compile and revie w all permit, compliance, enforcement, and pollutant

release data for any given regulated facility.

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration

sys tem that can retrieve information from the major EPA program office

databases. IDEA uses the FINDS identification number to link separate data

records from EPA’s databases. This allows retrieval of records from acrossAgricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 151 media or statutes for any given facility, thus creating a “master list” of records

for that facility. Some of the data systems accessible through IDEA are: AFS

(Air Facility Indexing and Retrieval System, Office of Air and Radiation),

PCS (Permit Compliance System, Of fice of Water), RCRIS (Resource

Conservation and Recovery Information System, Office of Solid Waste),

N CDB (National Compliance Data Base, Office of Prevention, Pesticides, an d

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 S I C code range. For industries not covered under TRI reporting

requirements (metal mining, non metallic mineral mining, electric power

generation, ground transportation, water transportation, and dry cleaning), or

industries in which only a very small fraction of facilities report to TRI (e.g.,

printing), 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 th e level of EPA and state agency

inspec t ions for the facilities in this data search. These values show what

percentage of the facility un iverse is inspected in a one-year or five-year

period.

Number of Inspections

-- measures the total number of inspections conducted

in this sector. An inspection event is counted each time it is entered into a

single media database.

Average Time Between Inspections -- provides an average length of time,

expressed in months, between compliance inspections at a facility within the

defined universe.

Facilities with One or More Enforcement Actions

-- expresses the number

of facilities that were the subject of at least one enforcement action within the

defined time period. This category is broken down further into federal and

state actio n

s. 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, e.g., a facility with 3 enforcement actions counts as 1 facility.Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 152 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 multipl e times, e.g., a

facility with 3 enforcement actions counts as 3.

State Lead Actions

-- shows what percentage of the total enforcement actions

are taken by state and local environmental agencies. Varying levels of usage

by states of EPA data systems may limit the volume of ac tions recorded as

state enforcement activity. Some states extensively report enforcement

activities into EPA data systems, while other states may use their own data

systems.

Federal Lead Acti ons

-- 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

-- is a ratio of enforcement act ions to

inspections, and is presented for comparative purposes only. This ratio is a

rough indicator of

the relationship between inspections and enforcement. It

relates the number of enforcement actions and the number of inspections that

occ urred within the one-year or five-year period. This ratio includes the

inspecti ons and enforcement actions reported under the Clean Water Act

(CWA), the Clean Air Act (CAA) and the Resource Con servation and

Recovery Act (RCRA). 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. Also, this

ratio does not account for enforcement actions arising from non-ins pection

compli ance 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

percentage of inspected facilities having a violation identified in one of the

following data categories: In Violation or Significant Violation Status (CAA);

Reportable Noncompliance, Curr e nt Year Noncompliance, Significant

Noncompl i ance (CWA); Noncompliance and Significant Noncompliance

(FIFRA, TSCA, and EPCRA); Unresolved Violation and Unreso lved 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. 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 withinAgricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 153 EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each

column is a percentage of either th e “Total Inspections,” or the “Total

Actions” column.

VII.A. Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History

Table 25 provides an overview of the reported compliance and enforcement

data for the Fertilizer, Pesticide, and Agricultural Chemical Industry over five

years from April 1992 to April 1997. These data are also broken out by EPA

Regions thereby permitting geographical comparisons. A few points evident

from the data are listed below.



### C About 75 percent of agricultural chemical facility inspections and

73 percent of enforcement actions occurred in EPA Regions IV, V,

VI, and VII.



### C Region IX had the highest ratio of enforcement actions to

inspections (0.13) a nd the longest average time between

inspections (21 months). This indicates that fewer inspections

were conducted in relatio n to the number of facilities in the

Region, but that these inspections were more likely to result in an

enforcement action than inspections conducted in other Regions.



### C With the exception

of Region I, in which no inspections or

enforcement actions were carried out in between 1992 and 1997,

Region VIII had the lowest enforcement to inspection rate (0.03).Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 154 Table 25: Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and

Agricultural Chemical Industry

A B C D E F G H I J

Region Facilities

in Search Facilities

Inspected Number of

Inspections Average

Months

Between

Inspections Facilities with

1 or More

Enforcement

Actions Total

Enforcement

Actions Percent

State

Lead

Actions Percent

Federal

Lead

Actions Enforcement

to Inspection

Rate

I 3 0 0

-- 0 0 0% 0%

--

II 11 8 50 13 3 4 75% 25% 0.08

III 18 16 123 9 2 10 80% 20% 0.08

IV 77 44 449 10 15 41 83% 17% 0.09

V 35 23 128 16 4 7 57% 43% 0.05

VI 34 21 167 12 5 9 56% 44% 0.05

VII 43 31 225 11 8 17 71% 29% 0.08

VIII 9 5 33 16 1 1 100% 0% 0.03

IX 25 10 72 21 5 9 78% 22% 0.13

X 8 6 46 10 4 4 25% 75% 0.09

TOTAL 263 164 1,293 12 47 102 74% 26% 0.08

Source: Data obtained from EPA’s Integrated Data for Enforcement Analysis (IDEA) system in 1997.Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 155 VII.B. Comparison of Enforcement Activity Between Selected Industries

Tables 26 and 27 allow the compliance history of the agricultural chemical

sector to be compared to the other industries covered by the industry sector

notebooks. Comparisons between Tables 26 and 27 permit the identification

of trends in compliance and enforcement records of the various industries by

comparing data covering five years (April 1992 to April 1997) to that of the

last year for which data were available (April 1996 to April 1997). Some

points evident from the data are listed below.



### C T he agricultural chemical sector was inspected more frequentl y

than most of the sectors shown (12 months on average between

inspections).



### C Between 1992 and 1997, the industry had a higher enforcement to

inspection rate than most sectors (0.08); however, in 1997 the ratio

decreased to 0.05 which is lower than most sectors.



### C The agricultural chemical sector had one of the highest percentages

of facilities inspected with one or more violations (97 percent) in

1997, but one of the lowest percentages of facilities with one or

more enforcement actions (5 percent).

Tables 28 and 29 provide a more in-depth comparison between the Fertilizer,

Pesticide, and Agricultural Chemical Industry and other sectors by breaking

out the compliance and enforcement data by environmental statute. As in the

previous Tables (Tables 26 and 27), the data cover the years 1992 to 1997

(Table 28) and 1997 (Table 29) to facilitate the identification of recent trends.

A few points evident from the data are listed below.



### C The percent of inspections carried out under each environmental

statute has changed only slightly between the average of the years

199 2 to 1997 and that of the past year. The Clean Air Act

accounted for the most inspections (43 percent) during this period.

This increased to almost half of all agricultural chemical facility

inspections (49 percent) in 1997.



### C The percent of enforcement actions taken under each environmental

statute changed significantly from the 1992 to 1997 period to the

past year. Enforcement actions taken under the Clean Air Act

increased from 39 percent to 55 percent and enforcement actions

taken under RCRA increased from 30 percent to 36 percent. At the

same time, the enforcement actions taken under the Clean Water

Act went from 20 percent in 1992 to 1995 to no actions in 1997.Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 156Table 26: Five-Year Enforcement and Compliance Summary for Selected IndustriesABCDEFGHIJIndustry SectorFacilitiesin SearchFacilitiesInspectedNumber ofInspectionsAverageMonthsBetweenInspectionsFacilities with1 or MoreEnforcementActionsTotalEnforcementActionsPercentState LeadActionsPercentFederalLeadActionsEnforcement toInspectionRateMetal Mining1,2323781,600466311153%47%0.07Coal Mining3,2567413,748528813289%11%0.04Oil and Gas Extraction4,6761,9026,0714614930979%21%0.05Non-Metallic Mineral Mining5,2562,80312,8262538562277%23%0.05Textiles3552671,46515538390%10%0.06Lumber and Wood7124732,7671513426570%30%0.10Furniture4993862,37913659181%19%0.04Pulp and Paper4844304,630615047880%20%0.10Printing5,8622,0927,6914623842888%12%0.06Inorganic Chemicals4412863,08798923574%26%0.08Resins and Manmade Fibers3292632,43089321976%24%0.09Pharmaceuticals1641291,20183512280%20%0.10Organic Chemicals4253554,294615346865%35%0.11Agricultural Chemicals2631641,293124710274%26%0.08Petroleum Refining1561483,081312476368%32%0.25Rubber and Plastic1,8189814,3832517827682%18%0.06Stone, Clay, Glass andConcrete6153883,474119727775%25%0.08Iron and Steel3492754,476512130571%29%0.07Metal Castings6694242,5351611319171%29%0.08Nonferrous Metals2031611,64076817478%22%0.11Fabricated Metal Products2,9061,8587,9142236560075%25%0.08Electronics1,2508634,5001715025180%20%0.06Automobile Assembly1,2609275,9121325341382%18%0.07Shipbuilding and Repair44372439203284%16%0.13Ground Transportation7,7863,26312,9043637577484%16%0.06Water Transportation51419281638367061%39%0.09Air Transportation44423197327489788%12%0.10Fossil Fuel Electric Power3,2702,16614,2101440378976%24%0.06Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 157Table 27: One-Year Enforcement and Compliance Summary for Selected IndustriesABCDEFGHFacilities with 1 or MoreViolationsFacilities with 1 or moreEnforcement ActionsTotalEnforcementActionsIndustry SectorFacilitiesin SearchFacilitiesInspectedNumber ofInspectionsNumberPercent*NumberPercent*Enforcement toInspection RateMetal Mining1,23214221110272%96%100.05Coal Mining3,2563627659025%206%220.03Oil and Gas Extraction4,6768741,17312715%263%340.03Non-Metallic Mineral Mining5,2561,4812,45138426%735%910.04Textiles3551722959656%106%120.04Lumber and Wood71227950719269%4416%520.10Furniture49925445913654%94%110.02Pulp and Paper48431778824878%4314%740.09Printing5,8628921,36357765%283%530.04Inorganic Chemicals44120054815578%1910%310.06Resins and Manmade Fibers32917341915288%2615%360.09Pharmaceuticals1648020984105%810%140.07Organic Chemicals42525983724394%4216%560.07Agricultural Chemicals26310520610297%55%110.05Petroleum Refining15613256512998%5844%1320.23Rubber and Plastic1,81846679138983%337%410.05Stone, Clay, Glass andConcrete61525567815159%197%270.04Iron and Steel34919786617488%2211%340.04Metal Castings669234433240103%2410%260.06Nonferrous Metals2031083109891%1716%280.09Fabricated Metal2,9068491,37779694%637%830.06Electronics1,25042078040296%276%430.06Automobile Assembly1,2605071,05843185%357%470.04Shipbuilding and Repair4422511986%314%40.08Ground Transportation7,7861,5852,49968143%855%1030.04Water Transportation514841415363%1012%110.08Air Transportation444961516972%88%120.08Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 158Table 28: Five-Year Inspection and Enforcement Summary by Statute for Selected IndustriesIndustry SectorFacilitiesInspectedTotalInspectionsTotalEnforcementActionsClean Air ActClean Water ActRCRAFIFRA/TSCA/EPCRA/Other% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActionsMetal Mining3781,60011139%19%52%52%8%12%1%17%Coal Mining7413,74813257%64%38%28%4%8%1%1%Oil and Gas Extraction1,9026,07130975%65%16%14%8%18%0%3%Non-Metallic Mineral Mining2,80312,82662283%81%14%13%3%4%0%3%Textiles2671,4658358%54%22%25%18%14%2%6%Lumber and Wood4732,76726549%47%6%6%44%31%1%16%Furniture3862,3799162%42%3%0%34%43%1%14%Pulp and Paper4304,63047851%59%32%28%15%10%2%4%Printing2,0927,69142860%64%5%3%35%29%1%4%Inorganic Chemicals2863,08723538%44%27%21%34%30%1%5%Resins and Manmade Fibers2632,43021935%43%23%28%38%23%4%6%Pharmaceuticals1291,20112235%49%15%25%45%20%5%5%Organic Chemicals3554,29446837%42%16%25%44%28%4%6%Agricultural Chemicals1641,29310243%39%24%20%28%30%5%11%Petroleum Refining1483,08176342%59%20%13%36%21%2%7%Rubber and Plastic9814,38327651%44%12%11%35%34%2%11%Stone, Clay, Glass andConcrete3883,47427756%57%13%9%31%30%1%4%Iron and Steel2754,47630545%35%26%26%28%31%1%8%Metal Castings4242,53519155%44%11%10%32%31%2%14%Nonferrous Metals1611,64017448%43%18%17%33%31%1%10%Fabricated Metal1,8587,91460040%33%12%11%45%43%2%13%Electronics8634,50025138%32%13%11%47%50%2%7%Automobile Assembly9275,91241347%39%8%9%43%43%2%9%Shipbuilding and Repair372433239%25%14%25%42%47%5%3%Ground Transportation3,26312,90477459%41%12%11%29%45%1%3%Water Transportation1928167039%29%23%34%37%33%1%4%Air Transportation2319739725%32%27%20%48%48%0%0%Fossil Fuel Electric Power2,16614,21078957%59%32%26%11%10%1%5%Dry Cleaning2,3603,8136656%23%3%6%41%71%0%0%Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 159Table 29: One-Year Inspection and Enforcement Summary by Statute for Selected IndustriesFacilitiesInspectedTotalInspectionsTotalEnforcementActionsClean Air ActClean Water ActRCRAFIFRA/TSCA/EPCRA/OtherIndustry Sector% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActions% of TotalInspections% ofTotalActionsMetal Mining1422111052%0%40%40%8%30%0%30%Coal Mining3627652256%82%40%14%4%5%0%0%Oil and Gas Extraction8741,1733482%68%10%9%9%24%0%0%Non-Metallic Mineral Mining1,4812,4519187%89%10%9%3%2%0%0%Textiles1722951266%75%17%17%17%8%0%0%Lumber and Wood2795075251%30%6%5%44%25%0%40%Furniture2544591166%45%2%0%32%45%0%9%Pulp and Paper3177887454%73%32%19%14%7%0%1%Printing8921,3635363%77%4%0%33%23%0%0%Inorganic Chemicals2005483135%59%26%9%39%25%0%6%Resins and Manmade Fibers1734193638%51%24%38%38%5%0%5%Pharmaceuticals802091443%71%11%14%45%14%0%0%Organic Chemicals2598375640%54%13%13%47%34%0%0%Agricultural Chemicals1052061148%55%22%0%30%36%0%9%Petroleum Refining13256513249%67%17%8%34%15%0%10%Rubber and Plastic4667914155%64%10%13%35%23%0%0%Stone, Clay, Glass andConcrete2556782762%63%10%7%28%30%0%0%Iron and Steel1978663452%47%23%29%26%24%0%0%Metal Castings2344332660%58%10%8%30%35%0%0%Nonferrous Metals1083102844%43%15%20%41%30%0%7%Fabricated Metal8491,3778346%41%11%2%43%57%0%0%Electronics4207804344%37%14%5%43%53%0%5%Automobile Assembly5071,0584753%47%7%6%41%47%0%0%Shipbuilding and Repair2251454%0%11%50%35%50%0%0%Ground Transportation1,5852,49910364%46%11%10%26%44%0%1%Water Transportation841411138%9%24%36%38%45%0%9%Air Transportation961511228%33%15%42%57%25%0%0%Fossil Fuel Electric Power1,3182,43013559%73%32%21%9%5%0%0%Dry Cleaning1,2341,4361669%56%1%6%30%38%0%0%Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 160 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 Supplemental Environmental Projects (SEPs).

VII.C.1. Review of Major Cases

As indicated in EPA’s Enforcement Accomplishments Report, FY1995 and

FY1996 publications, about 17 significant enforcement actions were resolved

between 1995 and 1996 for the Fertilizer, Pesticide, and Agricultural

Chemical Industry.

American Cyanamid Comp any On June 28, 1995, Region II issued an

administrative complaint against American Cyanamid Company for violations

at its Lederle Laboratories facility located in Pearl River, New York. The

complaint proposed assessment of a $272,424 fine for the company’s failure

to submit timely TRI Form Rs for 1,1,1-trichloroethane , naphthalene,

phosphoric acid, toluene, manganese compounds and zinc compounds for the

reporting years 1990, 1991, 1992, and 1993.

Precision Generators, Inc. The Regional Administrator signed a consent

order in the Precision Generators, Inc., a FIFRA case, in which the

respondent agreed to pay the proposed penalty of $4,000. The administrative

complaint cited the respondent’s sale and misbranding of its unregistered

pesticide product ethylene fluid used to accelerate the ripening of fruits and

vegetables. Such a product is a “plant regulator” falling within the definition

of “pesticide” in FIFRA.

E.C. Geiger, Inc. On August 18, 1995, the Regional Administrator signed a

consent agreement and consent order finalizing settlement of the administrative

proceeding against E.C. Geiger, Inc. of Harleysville, Pennsylvania, for

violations of sections 12(a)(1)(A) and (B) o f FIFRA, 7 U.S.C. section

136j(a)(1)(A) and (B). The complaint alleged that during 1992, Geiger sold

or di stributed an unregistered and misbranded pesticide product, a rooting

hormone called “Indole-3-b utyric Acid-Horticultural Grade.” For these

violations the complaint sought a $14,000 penalty. Geiger has agreed to pay

a penalty of $8,900.

Rhone-Poulenc, Inc. Region III reached a settlement with Rhone-Poulenc,

Inc., in a Part II administrative action brought for violations of RCRA boiler

and industrial furnace (BIF) regulations at Rhone-Poulenc’s Institute, West

Virginia plant. The settlement calls for Rhone-Poulenc to pay a penalty of

over $244,000 and to undertake numerous compliance tasks.

I MC-Agrico Company On November 8, 1994, the Regional Administrator

ratified a consent decree between the United States and IMC-Agrico CompanyAgricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 161 concerning IMC’s violations of section 301(a) of the CWA. IMC owns and

operates phosphate rock mines and associated processing facilities in Florida

and Louisiana. Eight of its mineral extraction operations located throughout

Florida an

d its Port Sutton Phosphate Terminal located in Tampa, Florida,

were the subject of this referral. The action arose out of IMC’s violation of

its permit effluent limits for a variety of param eters including dissolved

oxygen, suspended solids, ammonia, and phosphorous, as well as nonreporting and stormwater violations at the various facilities-over 1,500 permit

violations total. The case was initiated following review of the facility

discharge monitoring reports and EPA and state inspections of the sites. The

consent decree settlement involved an up-front payment of $835,000 and a

$265,000 Supplemental Environmental Project (SEP). The pollution

prevention SEP involved conv erting IMC’s scrubber discharge and intake

water systems into a closed loop system, greatly reducing pollution loading at

the Port Sutton facility, by April 1995.

J.T. Eaton & Company, Inc. J.T. Eaton & Company, Inc. distributed and

sold at least 13 unregistered pesticides (mostly rodenticides). These

unregistered pesticides resulted from varying the form of the rodent bait and

the packaging of several of Eaton’s registered products (e.g., registered as a

bulk product) bu

t sold in ready-to-use place packs. The company also

distributed a nd sold a misbranded pesticide product and made inaccurate

claims in advertising for another product. A stop sale, use, or removal order

and an administrative complaint were issued simultaneously on March 23,

1995. The penalty assessed in the complaint was $67,500. The complaint

was settled on August 25, 1995, for $40,000.

Citizens Elevator C o., Inc. Citizens Elevator Co. repackaged and

dis tributed and sold the pesticide “Preview” in five gallon buckets, many

bearing pie filling labels, to at least 24 customers, constituting the distribution

and sale of an unregistered pesticide. The complaint, issued June 30, 1994,

assessed a penalty of $108,000. In supplemental environmental projects for

the pr evention of spills of pesticides and fertilizers and the safer, more

efficient storage and application of pesticides and fertilizer. The respondent

spent $184,771. A consent agreement signed June 30, 1995, settled the case

for $8,400.

Nitrogen Products, Inc. On September 25, 1995, a joint stipulation and order

of dismissal was filed in the United States District Court for the Eastern

District of Arkansas. Nitrogen Products, Inc. (NPI), agreed to pay a civil

penalty of $243,600 to the United States for violations of the Clean Air Act,

and Subparts A and R of 40 CFR Part 61. The foreign parent corporation,

Internationale Nederlanden Bank, N.V., acquired the facility throughAgricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 162 foreclosure and expended over $2 million to cover the phosphogypsum stack

and regrade.

Micro Chemical, Inc. The illegal transportation of hazardous waste by a

L o uisiana pesticide formulation company, Micro Chemical, Inc., to an

unpermitted dis p osal facility in violation of RCRA resulted in a $500,000 fine,

five years of probation , and compliance with corrective action measures

contained in a corrective action administrative order on consent. In March

1990, Micro Chemical transported 100 cubic yards of hazardous waste from

its facility to a field in Baskin, Louisiana-a location that did not have a RCRA

permit. After its discovery, it was removed under the Louisiana Department

of Agriculture’s guidance. Micro Chemical has taken measures to stabilize

and prevent the spread of pesticide contamination from the Micro Chemical

facility site, as required by a RCRA 3008(h) corrective action administrative

order on consent. The order will result in the removal of all contaminated soil

at the site, and the remediation of all off-site contamination that has migrated

into a drainage basin located adjacent to the site.

Chempace Corporation On September 26, 1996, Region V PTES filed a civil

administrative complaint against Chempace corporation of Toledo, Ohio

alleging 99 counts for the distribution or sale of unregistered and misbranded

pesticides, and pesticide production in unregistered establishments. The total

proposed penalty in the complaint is $200,000. The case is significant in that

Chempace had, previous to the complaint, canceled all of the company’s

pesticide product registrations pursuant to section 4 of FIFRA, as well as their

establishment registration pursuant to section 7. However, the company

continued to produce and sell those canceled pesticides in a facility that was

not registered.

Northrup King Co. On September 30, 1996, as a result of a FIFRA inspection

conducted by Region V on March 27-28, 1996, Region V issued a FIFRA civil

complaint to Northrup King Co. of Golden Valley, Minnesota. The pesticide

involved in the case is a genetically engineered corn seed that protects against

the corn borer . Because this case is the first FIFRA complaint involving a

genetically engineered pesticide, the case is nationa lly significant. The

complaint alleged 21 counts of sale and distribution of an unregistered

pesticide, 21 counts for

failure to file a Notice of Arrival for pesticide

imports, and 8 counts of pesticide production in unregistered establishments,

for a total proposed penalty of $206,500. A consent agreement and consent

order was filed simultaneously with, and in resolution of the complaint. The

respondent agreed to pay $165,200, which is the largest penalty collected by

Region V under FIFRA.

Micro Chemical. Micro Ch emical is a pesticide formulating, mixing, and

packaging facility 3,000 feet up gradient of the Winnsboro’s groundwater well

complex. In March 1990, a release from the facility was reported by a citizen.

In vestigations revealed that the company had attempted to dump 100 cubic

yards of pesticide contaminated soil offsite. People living near the dump siteAgricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 163 became i ll from the fumes and the state ordered the soil to be returned to

Micro Chemical. Ultimately a criminal case was initiated for the midnight

dumping. Other storage violations detected were the subject of an

administrative complaint issued in September 1992. A RCRA 3008(h) order

on consent was entered into on September 1994 to remediate the site. In

resolving the September 1992 complaint, a final order was issued on March

28, 1996. Micro Chemical agreed to pay a penalty of $25,000 and agreed to

fund a SEP valued at $25,000. The SEP established collection events for

household waste and waste pesticides in the Franklin Parish area. During

FY96, the SEP enabled about 100 tons of waste to be collected and properly

disposed.

Terra Industries, Inc. At the request of the Chemical Emergency Prevention

and Preparedness Office (CEPPO), and in accordance with section 112(r) of

the CAA, EPA released the results of its investigation into the cause of an

explosion of the ammonium nitrate plant at this nitrogen fertilizer

manufacturing facility. The report released in January 1996 identifies

numerous unsafe operating procedures at the plant as contributing factors to the

explosion, and recommends certain stand ard operating procedures which

would help prevent similar occurrences at ammonium nitrate production

facilities.

The Terra explosion occurred on December 13, 1994, killing four individuals

and injuring 18 others. It also resulted in the release of approximately 5,700

tons of anhydrous ammonia to the air and approximately 25,000 gallons of

nitric acid to the ground and required evacuation over a two-state area of over

2,500 persons from their homes.

In a subsequent action, an administrative civil complaint alleging violations

of EPCRA sections 213 and 313, and section 8(a) of TSCA, was filed citing

that Te rra International failed to submit Toxic Release Inventory (TRI)

information to EPA in a timely manner, and data submitted to EPA by Terra

failed to include releases of more than 17 million pounds of toxic chemicals

to the environment on-site.

Pfizer/AgrEvo Reporting of unreasonable adverse effects information i s

required under FIFRA section 6(a)(2), and failure to submit such reports has

resulted in a $192,000 settlement involving AgrEvo Environmental Health,

Inc. and Pfizer, Inc. The case arose in early 1994 after an individual reported

disabling neurological symptoms and chemical sensitivit y after using RID

products to kill lice. The ensuing EPA investigation revealed numerous

additional unreported incidents involving RID which is manufactured by

AgrEvo and distributed by Pfizer. EPA amended the complaint charging 24

counts against each company. FIFRA 6(a)(2) requires pesticide registrants to

submit to EPA any additional information (beyond that submitted in the

pesticide registration process) that they have regarding unreasonable adverse

effects of their pesticides on human health or the environment. The information

is used by the Agency in the determination of risks associated with pesticides.Agricultural Chemical Industry Compliance and Enforcement History

Sector Notebook Project September 2000 164 Rohm and Haa s Company This complaint cited Rohm and Haas for 66

violations under FIFRA section 12(a)(1)(c), for the distribution or sale of a

registered pesticide the composition of which differed from the composition

as described in its registration under FIFRA section 3. EPA registers

pesticides based upon the accurate assessment of components used in the

manufacture of t

he product. Use of an unapproved formula can lead to

production of a pesticide for which no assessment of risk has been determined

or result in unknown synergistic effects. Following settlement negotiations,

and in accordance with the FIFRA Enforcement Response Policy, the original

penalty of $330,000 was reduced to $118,800, based on a 20% reduction to

the gravity level, a 40% reduction for immediate self-disclosure, mitigation,

and corrective actions, and a 15% reduction for good attitude, cooperation,

and efforts to comply with FIFRA.

VII.C.2. Supplementary Environmental Projects (SEPs)

SEPs are com

pliance agreements that reduce a facility’s non-compliance

penalty i n return for an environmental project that exceeds the value of the

reduction. Often, these projects fund pollution prevention activities that can

reduce the future pollutant loadings of a facility. Information on SEP cases can

be accessed via the Internet at http://es.epa.gov/oeca/sep.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 165 VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES

This sectio n highlights the activities undertaken by this industry sector and

pu blic agencies to voluntarily improve the sector’s environmental

performance. These activities include those initiated i ndependently 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

National Agricultural Compliance Assistance Center (Ag Center)

EPA's Office o f Compliance, with the support from the United States

Department of Agriculture (USDA), developed EPA’s National Agriculture

Compliance Assistance Center (Ag Center). The Ag Center offers

comprehensive, easy -to-understand information about approaches to

compliance that are both environmentally protective and agriculturally sound.

The Ag Center focuses on providing information about EPA’s own

requirements. In doing so, the center relies heavily on existing s ources of

agricultural information and established dist ribution channels. Educational and

technical information on agricultural production is provided by the USDA and

other agencies, but assistance in complying with environmental requirements

has not traditionally been as readily available. The Ag Center is currently

working with USDA and other federal and state agencies to provide the

agricultural community, including regional and state regulatory agencies, with

a definitive source for federal environmental compliance information. The Ag

Center offers information on a variety of topics, including the following:

• Pesticides

• Animal waste management

• Emergency planning and response

• Groundwater and surface water

• Tanks / containment

• Solid / hazardous waste

Through a toll-free telephone number and a website that is reg u larly updated and

expanded, the Ag Center offers a variety of resources including:

• current news, compliance policies and guidelines, p ollution prevention

info r mation, sources of additional information and expertise, and

summaries of regulatory initiatives and requirements

• user-friendly materials that consolidate information about compliance

requirements, pollution prevention, and technical assistance resources

for use by regional and state a ssistance and educational programs,

trade associations, businesses, citizens, and local governmentsAgricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 166 • agri culture-related information on reducing pollution and using the

latest pollution prevention methods and technologies

• information on ways to reduce the costs of meeting environmental

requirements, including identification of barriers to compliance

The Ag Center's toll -free number is 1-888-663-2155 and the website address is:

http://es.epa.gov/oeca/ag/

National Pesticide Information Retrieval System (NPIRS)

Pur due University has developed a collection of databases through their Center

for Environmental and Regulatory Information Systems, one of which is the

National Pesticide Information Retrieval System. NPIRS is a collection of six

databases related to pesticides, including product registration document

i nformation, data submitter information, residue tolerances, fact s heets,

material safety data sheets, and the daily federal register. Full search access

to the NPIRS databases is by annual subscription.

Association of

American Plant Food Control Officials (AAPFCO) Label Recommendations

The AAPFCO is considering a set of recommendations issued by a task force

of fertilizer producers and state officials. These recommendations call for

labeling and standards for non-nutrient constituents in fertilizer and directions

that will allow users to apply fertilizers at a rate that will not exceed these

stand ards. One proposed addition to labels is to list all raw materials,

including recycled wastes; however, the concentration of these materials will

not be required (ARA, 1997).

Agricultural Research Institute

ARI was founded in 1951 as a part of the National Academy of Sciences, then

incorporated separately in 1973. ARI analyzes agricultural problems and

promotes research by its members to solve them. ARI pub lishes annual

meeting minutes, a directory, books, pamphlets, and newsletters.

National Association of State Departments of Agriculture (NASDA)

NASDA was founded in 1916 by directors of state and territorial departments

of agriculture to coordinate policies, procedures, laws, and activities between

the states and federal agencies and Congress. NASDA conducts research,

holds a trade show, and distributes several bu lletins, newsletters, and

directories.

ChemAlliance

EPA’s Office of Compliance developed ChemAlliance, a new Compliance

Assistance Center for the chemical industry. Among its features is an exciting

“expert help,” which offers an interactive guide to finding com plianceAgricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 167 resources specific to a user’s needs. Take a “virtual plant tour” to find out

which regulations apply to your company’s operations by click ing on a

detailed chemical plan

t illustration. ChemAlliance can be reached at

1-800-672-6048; its web site is located at . http://www.chemalliance.org

,

VIII.B. EPA Voluntary Programs

Pesticide Environmental Stewardship Program (PESP)

The Pesticide Environmental Stewardship Program (PESP) is a broad effort by EPA,

USDA, and the FDA to reduce pes ticide use and risk in both agriculture and

nonagricultural settings. In September 1993, the three agencies announced a federal

commitment to two major goals: 1) developing specific use/risk reduction strategies

that include reliance on biological pesticides and other approaches to pest control that

are thought to be safer than traditional chemical m e thods, and 2) by the year 2000,

having 75 percent of United States agricultur al acreage adopt integrated pest

management programs.

A key part of the PESP is the public/private partnership which began when EPA,

USDA, and FDA announced the partnership and more than 20 private organizations

signed on as charter members. All organizations with a commitment to pesticide

use/risk reduction are eligible to join the PESP, either as Partners or Supporters. The

PESP program has 35 partners. Together, these partners represent at least 45,000

pesticide users. The program has a goal of adding 35 new partners per year.

33/50 Program

The 33/50 Program is a ground breaking program that has focused on reducing

pollution from seventeen high-priority chemicals through voluntary partnerships with

industry. The program’s name stems from its goals: a 33% reduction in toxic releases

by 1992, and a 50% reduction by 1995, against a baseline of 1.5 billion pounds of

releases and transfers in 1988. The results have been impressive: 1,300 companies

have joined the 33/50 Program (representing over 6,000 facilities) and have reached

the national targets a year ahead of schedule. The 33% goal was reached in 1991, and

the 50% goal -- a reduction of 745 million pounds of toxic wastes -- was reached in

1994. The 33/50 Program can provide case studies on many of the corporate

accomplishments in reducing waste (Contact 33/50 Program Director David Sarokin

-- 202-260-6396).

Table 30 lists those companies participating in the 33/50 program that reported the

SIC codes 2873, 2874, 2875, and 2879 to TRI. Some of the companies shown also

listed facilities that are not producing agricultural chemicals. The number of facilities

within each company that are participating in the 33/50 program and that report SIC

codes 2873, 28 74, 2875, and 2879 is shown. Where available and quantifiable

against 1988 releases and transfers, each com pany’s 33/50 goals for 1995 and the

actual total releases and transfers and percent reduction between 1988 and 1995 are

presented. Eleven of the seventeen target chemicals were reported to TRI by

agricultural chemical facilities in 1995.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 168 Table 30 shows that 24 companies comprised of 78 facilit ies reporting SIC 287

participated in the 33/50 program. For those companies shown with more than one

agricultural chemical facility, all facilities may not have participated in 33/50. The

33/50 goals shown for companies with multiple facilities, however, were companywide, potentially aggregating more than one facility and facilities not carrying out

agricultural chemical operations. In addition to company-wide goals, individual

facilities within a company may have had their own 33/50 goals or may have been

specifically listed as not participating in the 33/50 program. Since the actual percent

reductions shown in the last column apply to only the companies’ agricultur a l chemical

facilities, direct comparisons to those company goals incorporating non-agricultural

chemical facilities or excluding certain facilities may not be possible. For information

on specific facilities participating in 33/50, contact David Sarokin (202-260-6907)

at the 33/50 Program Office.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 169 Table 30: Fertilizer, Pesticide, and Agricultural Chemical Industry Participation in the 33/50

Program

Parent Company

(Headquarters Location) Company-Owned

Facilities Reporting

33/50 Chemicals Company- Wide

% Reduction Goal 1

(1988 to 1995) 1988 TRI Releases

and Transfers of

33/50 Chemicals

(pounds) 2 1995 TRI Releases

and Transfers of

33/50 Chemicals

(pounds) 2 % of Change

per Facility

(1988-1995)

AMERICAN HOME PRODUCTS CORP.

MADISON, NJ 2 49 47,950 73,876 -54

ARCADIAN CORP.

MEMPHIS, TN 6 0 4,340 10,127 -133

BAY ZINC CO. INC.

MOXEE CITY, WA 1 50 77,250 252 100

CHEM-TECH LTD.

DES MOINES, IA 1 90 800 0 100

CHEVRON CORP.

SAN FRANCISCO, CA 3 50 8,746 0 100

CONAGRA INC.

OMAHA, NE 6 8 17,086 5,238 69

E.I. DU PONT DE NEMOURS & CO

WILMINGTON, DE 2 50 144,412 440,370 -205

ELF AQUITAINE INC.

NEW YORK, NY 1 49 3,068 0 100

FIRST MISSISSIPPI CORP.

JACKSON, MS 7 0 701,144 214,334 69

FMC CORPORATION

CHICAGO, IL 5 50 6,190 2,339 62

GLAXO WELLCOME INC.

RESEARCH TRIANGLE PARK, NC 1 37 1,125 0 100

GOWAN COMPANY

YUMA, AZ 1 0 0 2,207

---

IMC FERTILIZER GROUP INC.

NORTHBROOK, IL 7 0 56,350 51,548 9

ISK AMERICAS INC.

ATLANTA, GA 2 50 884,412 726,713 18

LAROCHE HOLDINGS INC.

ATLANTA, GA 1 0 17,590 0 100

MALLINCKRODT GROUP INC.

SAINT LOUIS, MO 1 44 0 0

---

MILES INC.

PITTSBURGH, PA 1 38 39,822 6,650 83

MONSANTO COMPANY

SAINT LOUIS, MO 1 23 0 1,260

---

RHONE-POULENC INC.

MONMOUTH JUNCTION, NJ 21 50 3,128,263 1,392,117 55

SC JOHNSON & SON INC.

RACINE, WI 1 50 19,086 20,096 -5

SANDOZ CORPORATION

NEW YORK, NY 3 50 207,086 87,000 58

TALLEY INDUSTRIES

PHOENIX, AZ 1 0 8,243 2,289 72

UNIVERSAL COOPERATIVES INC.

MINNEAPOLIS, MN 1 70 17,750 1,265 93

UNOCAL CORPORATION

LOS ANGELES, CA 2 50 0 9

---

Total 78

--- 5,390,713 3,037,690 44

Source: United States EPA 33/50 Program Office, 1997.

1 Company-Wide Reduction Goals aggregate all company-owned facilities which may include facilities not producing agricultural chemicals.

2 Releases and Transfers are from facilities only. 1995 33/50 TRI data were not available at time of publication.

* = Reduction goal not quantifiable against 1988 TRI data. ** = Use reduction goal only. *** = No numeric reduction goal.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 170 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 providing participants regulatory flexibility on the con dition

that they produce greater environmental benefits. EPA and program participants will

negotiate and sign a F inal Project Agreement, detailing specific environmental

objectives that the regulated e ntity shall satisfy. EPA will provide regulatory

flexibility as an incentive for the participants’ superior environmental performance.

Parti cipants are encouraged to seek stakeholder support from local governments,

businesses, and environmental groups.

There have been at least two Project XL propos als relating to fertilizer

production, however both of these have been either rejected or withdrawn.

PCS Nitrogen (formerly Arcadian Fertilizer) had prop o sed to reuse stockpiled

phosphogypsum as an ingredient in a soil enhancer. Another proposal by Dow

Chemical Company in Louisiana was to trade off equipment leak reductions

for r elief from some emissions control, monitoring, reporting and recordkeeping requirements.

E P A hopes to implement fifty pilot projects in four categories, including

industrial facilities, co m

munities, and government facilities regulated by EPA.

Applications will be accepted on a rolling basis. For additional information

regarding XL projects, including application procedures and criteria, see the

May 23, 1995 Federal Register Notice. (Contact: Fax-on-Demand Hotline

202-260-8590, Web: http://www.epa.gov/ProjectXL, or Christopher Knopes

at EPA’s Office of Policy, Planning and Evaluation 202-260-9298)

Climate Wise Program

EPA’s E NERGY S TAR Buildings Program is a voluntary, profit-based program designed

to improve the energy-efficiency in commercial and industrial buildings. Expanding

the successful Green Lights Program, E NERGY S TAR Buildings was launched in 1995.

This program relies on a 5-stage strategy designed to maximize energy savings thereby

lowering energy bills, improving occupant comfort, and preventing pollution -- all at

the same time. If implemented in ev ery commercial and industrial building in the

United States, E NERGY S TAR Buildings could cut the nation’s energy bill by up to $25

billion and prevent up to 35% of carbon dioxide emissions. (This i s equivalent to

taking 60 million cars of the road). E NE RGY S TAR Buildings participants include

corporations; small and medium sized businesses; local, federal and state

governments; non-profit groups; schools; universities; and health care facilities. EPA

provides technical and non-te chnical support including software, workshops, manuals,

communication tools, and an information hotline. EPA’s Office of Air and Radiation

manages the operation of the E N ERGY S TAR Buildings Program. (Contact: Green

Light/Energy Star Ho tline at 1-888-STAR-YES or Maria Tikoff Vargas, EPA ProgramAgricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 171 Director at 202-233-9178 or visit the E NERGY S TAR Buildings Program website at

http://www.epa.gov/appdstar/buildings/)

Green Lights Program

EPA’s Green Lights program was initiated in 1991 and has the go al of preventing

pollution by encou

raging United States institutions to use energy-efficient lighting

technologies. The program saves money for businesses and organizations and creates

a cleaner envir onment by reducing pollutants released into the atmosphere. The

program has over 2,345 participants wh ich include major corporations, small and

medium sized businesses, federal, state and loc al 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. As of March 1997,

participants had lowered their electric bills by $289 million annually. EPA provides

technical assistance to the participants through a decision support software package,

workshops and manuals, and an information hotline. EPA’s Office of Air and

Radiation is responsible for ope rating the Green Lights Program. (Contact: Green

Light/Energy Star Hotline at 1-888-STARYES or Maria Tikoff Vargar, EPA Program

Director, at 202-233-9178)

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 prevention, recycling collection and the manufacturing and purchase

of recycled products. As of 1997, the program had about 500 companies as members,

one third of whom are Fortune 1000 corporations. Members agree to identify and

implement actions to reduce their solid waste s setting waste reduction goals and

providing EPA with yearly progress reports. To member companies, EPA, in turn,

provide s technical assistance, publications, networking opportunities, and national and

regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473 or Joanne

Oxley, EPA Program Manager, 703-308-0199)

NICE 3

The United States Department of Energy is administering a grant program called The

National Industrial Competitiveness throug h Energy, Environment, and Economics

(NICE 3 ). By providing grants of up to 45 percent of the total project cost, the program

encourages industry to reduce industrial waste at its source and become more energyefficient and cost-competitive through waste minimization efforts. Grants are used by

industry to design, test, and demonstrate 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 forest

products, chemicals, petroleum refining, steel, aluminum, metal casting and glass

ma nufacturing sectors. (Contact: http//www.oit.doe.gov/access/ nice3, Chris Sifri,

DOE, 303-275-4723 or Eric Hass, DOE, 303-275-4728)Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 172 Design for the Environment (DfE)

DfE is working with several industries to identify cost-effective pollution prevention

strategies that reduce risks to workers and the environment. DfE helps businesses

compare and evaluate the performance, cost, pollution prevention benefits, and human

health and environmental risks associated with existing and alternative technologies.

The goal of these projects is to enc ourage businesses to consider and use cleaner

products, processes, and technologies. For more information about the DfE Program,

call (202) 260-1678. To obtain copies of DfE materials or for general information

about DfE, contact EPA’s Pollution Prevention Information Clearinghouse at (202)

260-1023 or visit the DfE Website at http://es.inel.gov/dfe.

VIII.C. Trade Association/Industry Sponsored Activity

VIII.C.1. State Advisory Groups

Association of American Pesticide Control Officials (AAPCO)

P.O. Box 1249

Hardwick, VT 05843

Phone: 802-472-6956

Fax: 802-472-6957

E-mail: aapco@plainfield.bypass.com Members: 55

Staff: 1

Form ed in 1947, the Association of American Pesticide Control Officials

(AAPCO) consists of state and federal pesticide regulatory officials. All

federal and provincial Canadian officials, officials of all North American

countries involve d with the regulation of pesticides may be members of

AAPCO as well. AAPCO holds meetings twice a year and publishes an

annual handbook that

contains uniform policies and model pesticide legislation

that the association has adopted.

AAPCO aims to promote uniform and effective state legislation and pesticide

regulatory programs. Its other objectives are to develop inspection

procedures, to promote labeling and safe use of pesticides, to provide

opportunities for members to exchange information, and to work with industry

to promote the usefulness and effectiveness of pesticide products.

State FIFRA Issues Research and Evaluation Group (SFIREG)

P.O. Box 1249

Hardwick, VT 05843

Phone: 802-472-6956

Fax: 802-472-6957

E-mail: aapco@plainfield.bypass.com Members:

10 state representatives

The State FIFRA Issues Research and Evaluation Group evolved in 1978 outAgricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 173 of a cooperative agreement between the EPA’s Office of Pesticide Programs

(OPP) and the Associati on of American Pesticide Control Officials (AAPCO).

SFIREG is an independent but related body of AAPCO that provides state

comments to the Office of Pesticide Programs on issues relating to the

manufacture, use and disposal of pesticides. Its membership is comprised of

ten state representatives, who represent and are selected by the states in each

of the ten EPA Regions.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 174 VIII.C.2. Trade Associations

Association of American Plant Food Control Officials (AAPFCO)

University of Kentucky

Division of Regulatory Services

103 Regional Services Building

Lexington, KY 40546-0275

Phone: 606-257-2668

606-257-2970

Fax: 606-257-7351 Members: 200

The AAPFCO is an organization of state fertilizer control officials from the

United States and Canada who are involved in the administration of fertilizer

regulations and laws. The AAPFCO’s purpose is to achieve uniformity

throughout their membership with regards to promoting effective legislation,

adequate sampling, accurate labeling, and safe use of fertilizers, as well as to

study and discuss relevant issues.

Agricultural Retailers Association (ARA)

11701 Borman Dr., Ste. 110

St. Louis, MO 63146

Phone: 800-844-4900

Fax: 314-567-6808 Members:1,100

Staff: 17

The Agricultural Retailers Association was founded in 1954 and is made up

of dealers, manufacturers, and suppliers of fluid fertilizers and agrichemicals,

as well as equipment manufacturers, retail affiliations, and state association

affiliates. ARA was formerly known as the National Nitrogen Solutions

Association. Their publications include A gricultural Retailers AssociationM embership Directory and Buyer’s Guide (annual), Connections

, a

bimonthly newsletter, and the Fluid Fertilizer Manual

.

Fertilizer Industry Round Table (FIRT)

5234 Glen Arm Rd.

Glen Arm, MD 21057

Phone: 410-592-6271

Fax: 410-592-5796 Nonmembership

The Fertilizer Industry Round Table was founded in 1951. Participants

include production, technical, and research personnel in the fertilizer industry.

FIRT acts as a forum for

discussion of technical and production problems.

They hold an annual meeting and publish the proceedings.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 175 The Fertilizer Institute (TFI)

501 2nd St., NE

Washington, DC 20002

Phone: 202-675-8250

Fax: 202-544-8123 Members: 300

Staff: 22

The Fertilizer Institute was founded in 1970 and now has 48 affiliated groups.

Members include producers, manufactur ers, retailers, trading firms, and

equipment manufacturers. TFI represents members in various legislative,

educational, and te chnical areas, and provides information and public relations

programs. Publications include: Directory of Fertilizer References , annual;

Fertilizer Facts and Figures

, a n nual; Fertilizer Institute--Action Letter

, monthly; Fertilizer Record , periodic.

Chemical Manufacturers Association (CMA)

1300 Wilson Blvd.

Arlington, VA 22209

Phone: 703-741-5000

Fax: 703-741-6000 Members: 185

Staff: 280

The Chemical Manufacturers Association was founded in 1872 and now has

a budget of $36 million. CMA conducts advocacy and administers research

areas of broad import to chemical manufacturing, such as pollution prevention

and other special research programs. CMA also conducts committee studies,

operates the Chemical Emergency Center (CHEM TREC) for guidance to

emergen cy service on handling emergencies involving chemicals and the

Chemical Reference Center which offers health and safety information about

chemical s to the public. Publications include semi-monthly newsletters,

ChemEcology and CMA News , and the CMA Directory and User’s Guide.

Chemical Specialties Manufacturers Association (CSMA)

1913 Eye St., NW

Washington, DC 20006

Phone: 202-872-8110

Fax: 202-872-8114 Members: 425

Staff: 31

The Chemical Specialties Manufacturers Association was found ed in 1914 and

is made up of manufacturers, marketers, formulators, and suppliers of

household, industrial, and personal care chemical specialty products such as

pesticides, cleaning products, disinfectants, sanitizers, and polishes. CSMA

serves as a liaison to federal and state agencies and public representatives,

provides information and sponsors seminars on governmental activities and

scientific developments.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 176 American Crop Protection Association (ACPA)

1156 15th St., NW, Ste. 400

Washington, DC 20005

Phone: 202-296-1585

Fax: 202-463-0474 Members: 82

Staff: 29

The American Crop Protection Association was founded in 1933 and now has

a budget of $7 million. Members include companies involved in producing or

formulating agricultural chemical products including agricultural fumigants,

agricultural scalicides, chemical plant sprays and dusts, d efoliants, soil

disinfectants, we ed killers, and others. It is comprised of legislative,

regulatory and science departments and publishes a periodic bulletin, man uals,

Growing Possibilities , quarterly, and This Week and Next , weekly.

Western Crop Protection Association (WCPA)

3835 N. Freeway Blvd. Ste. 140

Sacramento, CA 95834

Phone: 916-568-3660

Fax: 916-565-0113 Members: 170

Staff: 6

The WCPA is a regional organization of manufacturers, formulators,

distributors, and dealers o f basic pesticide chemicals and suppliers of

solvents, diluents, emulsifiers, and containers. They are affiliated with the

American Crop Protection Association. They publish several bulletins and

periodicals.

National Pest Control Association (NPCA)

8100 Oak St.

Dunn Loring, VA 22027

Phone: 703-573-8330

Fax: 703-573-4116 Members: 2,300

Staff: 21

The National Pest Control Association was founded in 1933 and now has a

budget of $2.8 million. Members include companies engaged in control of

insects, rodents, birds, and other pests. NPCA provides advisory services on

control procedures, new products, and safety and business administration

practices. NPCA sponsors research at several universities, furnishes,

technical information and advice to standards and code writing groups, and

maintains an extensive library on pests. NPCA publishes many titles including

manuals, newsletters, membership guides, technical releases, and reports.

International Fertilizer Development Center (IFDC)

PO Box 2040 Musc le Shoals,Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 177 AL 35662

Phone: 205-381-6600

Fax: 205-381-7408 Nonmembership

Staff: 180

The International Fertilizer Developmen t Center was founded in 1974 and

includes participants such as scientists, engineers, economists and specialists

in market research and development and communications. IFDC uses a $13.5

million budget to try to alleviate world hunger by increasing agricultural

production in the tropics and subtropics through dev elopment of improved

fertilizers. IFDC sponsors and conducts studies in fertilizer efficiencies and

offers courses on fertilizer produc tion, environmental issues, and crop

sustainability. They maintain greenhouses and laboratories, and publish

several periodicals and manuals.

United Products Formulators and Distributors Association(UPFDA)

1 Executive Concourse No. 103

Duluth, GA 30136

Phone: 404-623-8721

Fax: 404-623-1714 Members: 102

Staff: 1

The United Products Formulators and Distributors Association was founded

in 1968 and is made up of companies engaged in formulating and distributing

pesticide pro ducts. The UPFDA works to solve problems of member

companies and promote sound and beneficial legislation and to cooperate with

allied industries.

North American Horticultural Supply Association (NAHSA)

1790 Arch St.

Philadelphia, PA 19103

Phone: 215-564-3484

Fax: 215-564-2175 Members: 135

Staff: 3

The North American Horticultural Supply Association was founded in 1988

and represents horticultural supplies such as greenhouse buildin g materials and

supplies, pesticides, and ferti lizers. The NAHSA works to strengthen and

enhance the relationship between manufacturers and distributors and promotes

distribution in the market. They publish a quarterly newsletter, N AHSA News,

and an annual Industry Calendar.

American Agricultural Economics Association (AAEA)

1110 Buckeye Ave.

Ames, IA 50010-8063

Phone: 515-233-3202

Fax: 515-233-3101 Members: 4,500

Staff: 6Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 178 The American Agricultura l Economics Association, founded in 1910, is a

professional society of state, federal, and industrial agricultural economists,

teachers, and extension workers. The AAEA works to further knowledge of

agricultural economics through scientific research, instruction, publications,

meetings, and other activities. They publish a bimonthly newsletter, a semibimonthly American Journal of Agricultura l Economics , a quarterly magazine

Choices , and a biennial Handbook Directory

.

Institute for Agriculture and Trade Policy (IATP)

1313 5th St., SE, No. 303

Minneapolis, MN 55414

Phone: 612-379-5980

Fax: 612-379-5982

The IATP was founded in 1986 and has an annual budget of $1.15 million.

They maintain a speakers bureau and conduc t research programs on trade

agriculture, global institutions, North-South relations, and the Third World.

They publish several periodical bulletins.

California Fertilizers Association (CFA)

1700 I St., Ste. 130

Sacramento, CA 95814

Phone: 916-441-1584

Fax: 916-441-2569

The CFA represents fertilizer manufacturers, distributors, wholesalers, and

retail dealers that sell products within California. They maintain a legislative

hotline and publish studies and handbooks on issues pertaining to fertilizers.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 179 American Society of Agronomy (ASA)

677 S. Segoe Rd.

Madison, WI 53711

Phone: 608-273-8080

Fax: (608) 273-2021 Members: 12,500

Staff: 30

The ASA was founded in 1907 an d presently operates on a budget of 2.5

million dollars per year. ASA is a professional society of plant breeders, soil

scientists, chemists, educat ors, technicians, and other concerned with crop

production and soil management . ASA sponsors fellowship programs and

provides placement service. ASA publishes annual, bimonthly, and monthly

periodicals as well as special publications.

Potash and Phosphate Institute (PPI)

655 Engineering Drive No. 110

Norcross, GA 30092

Phone: 770-447-0335

Fax: 770-448-0439 Members: 14

Staff: 30

PPI supports scientific research in the areas of soil fertility, soil testing, plant

analysis, and tissue testing. PPI participates in farmers meetings, workshops,

and training c ourses and publish a quarterly magazine, B etter Crops with

Plant Food

.Agricultural Chemical Industry Activities and Initiatives

Sector Notebook Project September 2000 180 THIS PAGE WAS INTENTIONALLY LEFT BLANKAgricultural Chemical Industry Contacts and References

6 Many of the contacts listed above have provided valuable 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 made within this notebook.

Sector Notebook Project September 2000 181 IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS

For further information on selected topics within the Fertilizer, Pesticide, and Agricultural Chemical

Industry, a list of contacts and publications are provided below.

Contacts 6

Name Organization Telephone Subject

Michelle C.

Yaras EPA, Office of Enforcement and

Compliance Assurance (OECA),

Agriculture and Ecosystems Division,

Agriculture Branch 202 564-4153 Notebook Contact

Arty Williams EPA, Office of Prevention, Pesticides

and Toxic Substances (OPPT) 703 305-5239 Ground Water Pesticide

Management Plan Rule

Jean Frane EPA, OPPT 703 305-5944 Food Quality Protection Act

Paul Parsons EPA, OPPT 703 308-9073 FIFRA Data Requirements

David Stangel EPA, OECA 202 564-4162 Stored or Suspended

Pesticides; Good Laboratory

Practice Standards;

Pesticide Management and

Disposal

Joseph Hogue EPA, OPPT 703 308-9072 FIFRA

Restricted Use

Classifications

Robert McNally EPA, OPPT 703 308-8085 FIFRA Pesticide Tolerances

Joseph Nevola EPA, OPPT 703 308-8037 FIFRA Pesticide Tolerances

Ellen Kramer EPA, OPPT 703 305-6475 FIFRA Pesticide Tolerances

Carol Peterson EPA, OPPT 703 305-6598 FIFRA Tolerance Fee

Structure

Robert A. Forrest EPA, OPPT 703 308-9376 FIFRA Exemptions

Nancy Fitz EPA, OPPT 703 305-7385 FIFRA Pesticide

Management and Disposal

Cathleen Barnes EPA, OPPT 703 305-7101 FIFRA Prior Informed

Consent

John MacDonald EPA, OPPT 703 305-7370 Certification and Training

Kevin Keaney EPA, OPPT 703 305-5557 FIFRA Worker Protection

StandardsAgricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 182 The following people received a draft copy of this Sector Notebook and may have provided

comments.

Name Organization Telephone

Paul Bangser EPA, Office of General Counsel, Water Division 202 260-7630

Philip J. Ross EPA, Office of General Counsel, Pesticides and Toxic

Substances Division 202 260-0779

Don Olson, Chief EPA, Industrial Branch, OECA, Office of Regulatory

Enforcement, Water Enforcement Division 202 564-5558

Jon Jacobs EPA, OECA, Office of Regulatory Enforcement, Case

Development, Policy and Enforcement Branch -Eastern

Regions, Toxics and Pesticides Enforcement Division 202 564-4037

Jerry Stubbs EPA, Case Development, Policy and Enforcement BranchWestern Regions, Toxics and Pesticides Enforcement

Division, Office of Regulatory Enforcement 202 564-4178

Anne E. Lindsay,

Director EPA, Field and External Affairs Division

Office of Pesticide Programs 703 305-5265

Marcia E. Mulkey,

Director EPA, Office of Pesticide Programs 703 305-7090

Artie Williams,

Chief EPA, Environmental Field Branch, Field and External

Affairs Division, Office of Pesticide Programs 703 305-5239

Seth Heminway EPA, OC Sector Notebook Coordinator 202 564-7017

Sam Silverman EPA, Enforcement Coordinator

Region 1 617 565-3443

Laura Livingston EPA, Enforcement Coordinator

Region 2 212 637-4059

Samantha Fairchild EPA, Enforcement Coordinator

Region 3 215 814-5710

Sherri Fields EPA, Enforcement Coordinator

Region 4 404 562-9684

Tinka Hyde EPA, EPA, Enforcement Coordinator

Region 5 312 886-9296

Robert Lawrence EPA, Enforcement Coordinator

Region 6 214 665-6580

Diane Callier EPA, Enforcement Coordinator

Region 7 913 551-7459

Mike Gaydosh EPA, Enforcement Coordinator

Region 8 303 312-6773

Jo-Ann Semones EPA, Enforcement Coordinator

Region 9 415 744-1547

Ron Kreizenbeck EPA, Enforcement Coordinator

Region 10 206 553-1265

Edward M. White Assistant Pesticide Administrator, Indiana State Chemist

Office, Purdue University 765 494-1587Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 183 Dale Dubberly, Chief Bureau of Compliance Monitoring

Florida Department of Agriculture & Consumer Services 850 488-8731

Robin Rosenbaum Pesticide Registration Manager, Pesticide & Plant Pest

Management Division, Michigan Department of

Agriculture 517 335-6542

Buzz Vance Nebraska Department of Agriculture 402 471-6853

Donnie Dippel Assistant Commissioner, Pesticide Programs, Texas

Department of Agriculture 512 463-7476

Paul Kindinger Agricultural Retailers Association (ARA) 314 567-6655

Joel Padmore Association of American Plant Food Control Officials

(AAPFCO), Food & Drug Protection Division

North Carolina Department of Agriculture 919 733-7366

Renee Pinel California Fertilizers Association 916 441-1584

Mark Muller Institute for Agriculture and Trade Policy 612 870-3420

Rick Kirchhoff National Association of State Departments of Agriculture

(NASDA) 202 296-9680

Robert Rosenberg National Pest Control Association 703 573-8330

Robert E. Roberts Executive Director

Environmental Council of States (ECOS) 202 624-3660

Diane Bateman The Fertilizer Institute (TFI) 202 675-8250

Jay Vroom American Crop Protection Association 202 296-1585Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 184 Section II: Introduction to the Fertilizer, Pesticide, and Agricultural Chemical Industry

1992 Census of Manufacturers Industry Series: Agricultural Chemicals

, United States Department

of Commerce, Bureau of Census, Economics and Statistics Adminis t ration, Washington, DC, May

1995.

1987 Standard Industrial Classification Manual, Office of Management and Budget, 1987.

Aspelin, Arnold, Pesticide Industry Sales and Usage, 1994 and 1995 Market Estimates

, Office of

Prevention, Pesticides and Toxic Substances, USEPA, August 1997.

“Facts and Figures for the Chemical Industry,” Chemical and Engineering News , June 23, 1998.

Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in F ertilizer Production , Marcel

Dekker, Inc., 1994.

Hoffmeister, George. “Fertilizers”, Kirk-Othmer Encyclopedi a of Chemical Technology, 4 t h ed. New

York: John Wiley & Sons. 1993.

Kent, James A., ed., Riegel’s Handbook of Industrial Chemistry

, Ninth edition, Van Nostrand

Reinhold, New York, 1992.

Ollinger, Michael, and Fernandez-Cornejo, Jorge. R egulation, Innovation, and Market Structure

in the United States Pesticide Industry , Economic Research Service, USDA, June 1995.

Andrilenas, Paul, and Vroomen, Harry. United States Department of Agriculture, Seven Farm Input

Industries, Fertilizer , Economic Research Service, U.S.D.A., September 1990.

Dun & Bradstreet’s Million Dollar Directory, 1997.

United Nations Environment Programme and United Nations Industrial Development Organization,

Mineral Fertilizer Production and the Environment , UNEP, Paris, 1996.

United States Environmental Protection Agency, Enforcement, Planning, Targeting & Data Division,,

FIFRA, section 7 Data System , United States EPA. 1996.

United States Environmental Protection Agency, Development Docu ment for Best Available

Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide

Formulating, Packaging, and Repackaging Industry- Final

, EPA, Office of Water, Washington, DC,

September 1996.

United States Environmental Protection A gency, B iopesticides Web Site

, Office of Pesticide

Programs, <http://www.epa.gov/oppbppd1/biopesticides/>, August 1999.

United States Envi ronmental Protection Agency, C ompilation of

Air Pollutant Emission Factors (AP42)

, Fifth edition, EPA, Office of Air Quality Planning and Standards, Research Triangle Park, NC,

July 1993.Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 185 United States Environmental Protection Agency, Guides to Pollution Prevention, The Pest icide

Formulating Industry , EPA, Center for Environmental Research Information, Cincinnati, February

1990.

United States Industry & Trade Outlook ‘98

, United States Department of Commerce, International

Trade Administration, Washington, DC, 1998.

United States International Trade Commission, Industry & Trade Summary, Pesticide Products and

Formulations, USITC Publication 2750, Office of Industries, March 1994.

Section III: Industrial Process Description

Air and Waste M anagement Association, Buonicore, Anthony J. and Davis, Wayne T., ed., A ir

Pollution Engineering Manual , Van Nostrand Reinhold, New York, 1992.

Cremlyn, R., Pesticides , John Wiley & Sons, New York, 1978.

Hargett, Norman and Pay, Ralph, “Retail Marketing of Fertilizers in the United States” Presented at

the Fertilizer Industry Round Table, Atlanta, Georgia, 1980.

Hoffmeister, George. “Fertilizers”, Kirk-Othmer Encyclopedia of Chemical Technology, 4 th ed.

Volume 10, New York: John Wiley & Sons. 1993.

Kroschwitz, Jacqueline, and Howe-Grant, Mary (eds.). “Ammonia”, Kirk-Othmer Encyclopedia of

Chemical Technology, 4 th ed. Volume 2, New York: John Wiley & Sons. 1992.

Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in Fertilize r Production , Marcel

Dekker, Inc., 1994.

Kent, James A., ed., Riegel’s Handbook of Industrial Chemistry

, Ninth edition, Van Nostrand

Reinhold, New York, 1992.

Korcak, R.F. “Utilization of Coal Combustion By-Products in Agriculture and Horticulture,”

Agricultural Utilization of Urb an and Industrial By-Products , American Society of Agronomy,

Madison, WI, 1995.

Lewis, Richard J., Sr., ed., Hawl e y’s Condensed Chemical Dictionary

, Twelfth edition, Van

Nostrand Reinhold, New York, 1993.

Manual on Fertilizer Statistics

, Food and Agriculture Organization of the United Nations, Rome,

1991.

Miller, W.P. “Environmental Considerations in Land Application of By-Product Gypsum,”

Agricultural Utilization of Urban and Industrial By-Products

, American Society of Agronomy,

Madison, WI, 1995.Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 186 Nielson, Francis T., Manual of Fertilizer Processing , Marcel Dekker, Inc., New York, 1987.

The Fertilizer Institute (TFI), comments submitted by Jim Skillen on a draft of this Sector Notebook,

September 1999.

United Nati o ns Environment Programme, Mineral Fertilizer Production and the Environment

, Technical Report N.26, United Nations Industrial Development Organization, 1996.

United States Environmental Protection Agenc y, C ompilation of

Air Pollutant Emission Factors (AP42) , Fifth edition, EPA, Office of Air Quality Planning and Standards, Research Triangle Park, NC,

July 1993a.

United S tates Environmental Protection Agency, D evelopment Document for Best Available

Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide

Formulating, Packaging, and Repackaging Industry- Final

, EPA, Office of Water, Washington, DC,

September 1996.

United States Environmental Protection Agency, Development Document for Effluent Limitations

Guidelines and New Source Performance Standards for the Basic Fertilizer Chemicals Segment

of the Fertilizer Manufacturing Point Source Category , EPA, Office of Air and Water Programs,

Washington, DC, March 1974.

United States Envi ronmental Protection Agency, G uides to Pollution Prevention, The Pesticide

Formulating Industry

, Risk Reduction Engineering Laboratory and Center for Environmental

Research Information, Office of Research and Development, February 1990.

United States Environmental Protection Agency, Pesticide Industry Sales and Usage, 1994 and 1995

Market Estimates , Office of Prevention, Pesticides and Toxic Substances, August 1997.

United States Environmental Protection Agency, Report to Congress for Cement Kiln Dust

. Volume

II: Methods and Findings. Springfield, VA: United States Department of Commerce, December

1993b.

United States Environmental Protection Agency, 1996 Toxics Release Inventory Database

.

Water Environment Federation, Pretreatment of Industrial Wastes

, Manual of Practice FD-3,

Alexandria, VA, 1994.

Section IV: Chemical Release and Transfer Profile

United States Environmental Protection Agency, 1996 Toxics Release Inventory Database

.

United States Environmental Protection Agency, 1995 Toxics Release Inventory Database

.

United States EPA Office of Air and Radiation, AIRS Database, 1997.

United States Environmental Protection Agency, 1995 Toxics Release Inventory Public Data Release

, United States EPA Office of Pollution Prevention and Toxics, April 1997. (EPA 745-R-97-005)Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 187 Section V: Pollution Prevention Opportunities

California Fertilizer A ssociation, Dry and Liquid Fertilizer Handling Guidelines for Retail

Fertilizer Facilities, CFA, http://www.calfertilizer.org/fertguide.html, November 1996.

Hunt, Gary, et. al., eds. Case Summaries of Waste Reduction by Industries in the Southeast. Waste

Reduction Resource Center for the Southeast, North Carolina department of Natural Resources and

Community Development, Raleigh, NC, July 1989.

Preventing Pollution in the Chemical Industry, Five Years of Progress

, Chemical Manufacturers

Association, 1993.

United Nations Environment Programme, Mineral Fertilizer Production and the Environmen t

, Technical Report N.26, United Nations Industrial Development Organization, 1996.

U nited States Environmental Protection Agency, Development Document for Best Av ailable

Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide

Formulating, Packaging, and Repackaging Industry- Final

, EPA, Office of Water, Washington, DC,

September 1996.

United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide

Formulating Industry , EPA, Center for Environmental Research Information, Cincinnati, February

1990.

Section VI: Summary of Applicable Federal Statutes and Regulations

Haugrud, K. Jack. “Agriculture,” Chapter 8 in S ustainable Environmental Law, Integrating Natural

Resource and Pollution Abatement Law from Resources to Recovery

, Environmental Law Institute,

St. Paul, 1993.

Landfair, Stanley W. “Toxic Substances Control Act,” Chapter 11 in E nvironmental Law Handbook

, 12th ed., Government Institutes, Inc., Rockville, MD, 1993.

Miller, Marshall E. “Federal Regulation of Pesticides,” Chapter 13 in Environmental Law

Handbook , 12th ed., Government Institutes, Inc., Rockville, MD, 1993.

Section VII: Compliance and Enforcement History

United States Environmental Protection Agency, Data obtained from EPA’s Integrated Data for

Enforcement Analysis (IDEA) system in 1997.

Section VIII: Compliance Activities and Initiatives

Agricultural Retailers Association, Retailer Facts by FAX , ARA Weekly, November 7, 1997.Agricultural Chemical Industry Contacts and References

Sector Notebook Project September 2000 188 Center for Environmental and Regulatory Information Services. <http://www.ceris.purdue.edu>

Jaszczak, Sandra, ed. G

ale Encyclopedia of

Associations. 3 1st ed., International Thomson P ublishing

Co., 1996.

United States Environmental Protection Agency, 33/50 Program Office, 1997.