The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
1
of
2
Proposed
Priority:
Miscellaneous
Plastic
Products
Manufacturing
Universe
&
Types
of
Facilities
This
sector
includes
establishments
primarily
engaged
in
processing
plastics
resins
into
intermediate
of
final
products
using
processes
such
as
extrusion
molding,
blow
molding,
injection
molding,
casting,
etc.
According
to
Dun
and
Bradstreet
(
2003),
there
are
38,644
facilities
and
according
to
the
Census
of
Manufacturers
(
1999)
there
are
16,856
establishments.
The
Online
Tracking
Information
System
(
OTIS),
an
EPA
information
system
that
contains
facility
enforcement
and
compliance
information,
identifies
a
compliance
history
for
2,727
facilities
and
1,898
Toxic
Release
Inventory
(
TRI)
reporters
(
2003).
The
industry
has
grown
approximately
20%
(
in
value
of
shipments)
over
the
past
10
years.

Geographic
Range
This
sector
covers
the
whole
country
with
the
greatest
concentration
in
Region
5
(
Great
Lakes
States),
and
other
concentrations
in
California,
Texas,
Pennsylvania,
North
Carolina,
New
York
and
New
Jersey.
Small
businesses
(
fewer
than
100
employees)
comprise
about
84%
of
this
sector
with
47%
employing
20
or
fewer
people.
However,
the
top
10
TRI
releasers
for
this
sector
are
either
large
corporations
or
subsidiaries
of
large
corporations.
(
Smaller
facilities
may
not
be
required
to
report
to
TRI).

Environmental
Risks
Concerns
include
air
releases
which
are
significantly
higher
than
most
other
sectors,
including
totals
from
either
plastic
resin
manufacture
or
organic
chemicals
manufacture
(
TRI
2000).
These
releases
include
hazardous
air
pollutants
such
as
styrene,
dichloromethane
(
aka
methylene
chloride),
xylene,
and
methanol.
According
to
TRI
Reports,
styrene
and
dichloromethane,
both
carcinogens
(
OSHA
Carcinogen
Listing),
are
each
released/
transferred
in
excess
of
20
million
pounds.
According
to
TRI
data,
more
than
47
million
pounds
of
other
carcinogens
are
released
from
this
sector,
including
43
million
pounds
of
onsite
releases.
Other
carcinogenic
releases/
transfers
include
n,
n­
dimethylformamide,
formaldehyde
and
ethlybenzene.

Of
all
the
sectors
reporting
under
TRI,
this
sector
ranks
fifth
for
air
releases,
and
ninth
for
total
releases.
Releases
of
hazardous
air
pollutants
(
HAPs),
and
Volatile
Organic
Compounds
(
VOCs)
include
dichloromethane,
styrene,
carbon
disulfide,
toluene,
Of
all
the
sectors
reporting
for
TRI,
this
sector
ranks
highest
for
releases
of
OSHA
carcinogens
to
air
and
fifth
for
total
TRI
releases
of
OSHA
carcinogens
(
primarily
releases
of
styrene
and
dichloromethane).
Plastic
foam
products
(
SIC
3086)
accounts
for
98%
of
this
sector's
dichloromethane
releases
and
30%
of
this
sector's
TRI
air
releases.
The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
2
of
2
Waste
water
releases
may
contain
toxic
chemicals
[
Clean
Water
Act
(
CWA)
requirements
and
effluent
guidelines
for
Plastic
Molding
and
Forming
Point
Source
Category
apply]
and
waste
pellets
which
are
classified
as
significant
materials
under
EPA
storm
water
regulations.
Additionally,
there
are
approximately
2,746
Resource
Conservation
and
Recovery
Act
(
RCRA)­
permitted
facilities
in
this
sector.
National
Pollutant
Discharge
Elimination
System
(
NPDES)
effluent
limitations
for
Plastic
Molding
and
Forming
Point
Source
Category
and
storm
water
regulations
also
apply.

Noncompliance
Information
This
sector
uses
plastic
resin
to
manufacture
various
plastic
products
including
plastic
film
and
sheet,
pipes
and
plumbing
fixtures,
bottles,
foam
products
(
such
as
styrofoam
cups,
and
furniture
cushioning),
various
plastic
consumer
goods
and
laminated
plastics.
Approximately
58%
of
the
sector
makes
"
Plastic
Products
Not
Elsewhere
Classified."
Data
from
OTIS
shows
that
over
the
last
2
year
period,
there
were
1,652
inspections
of
facilities
in
the
308
SIC
code.
Additionally,
OTIS
indicates
that
610
facilities
(
9%)
of
the
known
SIC
308
universe
are
currently
in
some
violation
of
environmental
regulations.

This
sector
appears
to
have
very
high
toxic
releases
(
primarily
to
air)
but
has
received
relatively
little
compliance
attention.
There
are
several
air
rules
that
apply
to
this
sector:
HAP
Equipment
Leak
National
Emissions
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
Leak
Detection
and
Repair
Program
(
LDAR)
(
general
standards
for
identification
of
leaks
from
pumps,
compressors,
pressure
relief
valves,
connectors
and
closed
vent
systems,
etc);
Flexible
Polyurethane
Foam
Production
MACT
(
compliance
date
10/
8/
01,
will
reduce
methylene
chloride
by
68
%
and
reduce
air
toxic
emissions
by
98
%
at
affected
facilities);
Flexible
Polyurethane
Foam
Fabrication
Operation
MACT,
(
compliance
date
2006,
will
reduce
air
toxics
emissions
from
new
or
reconstructed
flame
lamination
facilities
by
90%
);
Reinforced
Plastic
Composites
Production
MACT
(
compliance
date
2006,
will
reduce
air
toxic
emissions,
particularly
styrene,
by
65%
and
will
also
reduce
emissions
of
VOCs);
Plastic
Parts
and
Products
Coatings,
NESHAP
(
compliance
8/
03,
will
reduce
air
toxics
by
80
%
over
`
97
levels).
There
are
also
two
New
Source
Performance
Standards
(
NSPS)
that
apply:
Standards
of
Performance
for
Industrial
Surface
Coating:
Surface
Coating
of
Plastics
Parts
for
Business
Machines
(
establishes
limits
on
VOC
emissions
from
facilities
that
apply
coatings
to
plastic
parts
used
in
business
machines);
and
Standards
of
Performance
for
Polymeric
Coating
of
Support
Substrates
Facilities
(
establishes
limits
on
VOC
emissions
from
facilities
that
apply
elastomers,
polymers,
or
prepolymers
to
a
support
web).
