Document p2p6MLz9KBNKZDN5JMKynXRMk

,'IK'M v!\M I\Ul kfK1' \sMia\riO\ 990-1991 DIRECTORY K~- 41s -i i *+ - CH* CMHAEAMDICWACLTWEBS ASSOCIATION Page 1 1 2 4 5 8 11 12 13 I* 15 rs^ 17 18 19 20 21 22 23 24 25 4. i* 27 28 29 31 32 33 41 44 '46 52 53 Purpose of the Association Objectives of the Association Responsible Care Officers Staff Board of Directors Meeting Schedules (Board of Directors and Board Committees) Committees of the Board of Directors Executive Committee Finance Committee Membership Committee Program Committee Employee Benefits Committee Standing Committees Communications Committee Distribution Committee Energy Committee Engineering and Operations Committee Environmental Management Committee Federal Government Relations Committee Health and Safety Committee intellectual Property Committee International Affairs Committee International TVade Committee State Affairs Committee TlIX Policy Committee Special Committees .. Chemical Industry Federation Advisory Council Chemical Self-Funded Technical Advocacy and Research fChemstar) Policy Committee Responsible Care Coordinating Croup < ': i Members General Principles Applicable to the Structure and Operations of Committees Rules of Procedure for Committees Antitrust Guide for CMA Committee Members Obligations and Procedures for Member Dissent CMA and Advocacy vvv 0Q0004874- f --> r *. i or CMHANEUUFCAACLTURERS ASSOCIATION CHEMICAL MANUFACTURERS ASSOCIATION :n The Chemical Manufacturers Association represents the chemical industry in North America. Founded in 1872, CMA is the oldest trade association in the Western Hemisphere. CMA's approximately 180 member companies represent more than 90 percent ofthe productive capacity ofbasic industrial chemicals within the United States. The Association brings together member company experts to help resolve industry-wide public policy, technical and scientific problems. It communicates with government and the public on vital issues and administers research studies and tests on a wide range ofchemical products and practices. PURPOSE As set forth under Article II of the Bylaws, the purpose of the Association shall be the promotion of the inter- ests of the chemical industry of the United States of America and Canada. OBJECTIVES The Board of Directors has stated the objectives of the Association as follows: 1. To provide leadership to its members, and to repre sent them in presenting industry interests, views, and recommendations to the legislative and execu tive branches of the federal government and to the regulatory agencies (and to state and local govern ments when appropriate) on those matters which affect the industry's health, vigor, and well being. 2. To aid in developing and maintaining a dear under standing by the public of the chemical industry and its contributions to the public welfare and to the advancement of our national, state, and local econ omies: and by appropriate, timely, and effective means to make known the contributions, accom plishments. and changing needs of the industry to the public broadly, and particularly to those initia tors of thought and action outside the industry whose opinions, decisions, and actions affect the industry. 3. To provide leadership and guidance and to under take programs to improve the chemical industry's service to the public by developing and promoting safe and clean practices in the manufacture, trans portation, handling, and use of chemicals and chemical products. 4.1b conduct or sponsor legitimate activities designed to achieve worthwhile benefit or savings to the Association members where individual company efforts cannot effectively accomplish the desired result. VVV 000004875 1 RESPONSIBLE CARE A Public Commitment or CXMCAL MANUFACTURERS ASSOCIATION Mr ublic concerns about the impact of chemicals and hazardous wastes on human health and the environment continue to grow. Those concerns, whether real or perceived, have a direct impact on the chemical industry. Recognizing this, CMA's Board of Directors approved an initiative called "Responsible Care: A Public Commitment" in September 1988. The goal of Responsible Care is to continuously improve the chemical industry's performance in environmental, health and safety quality through the commitment and joint efforts of its individual member companies and of the Association. The initiative is designed to be responsive to public concerns. On October 30,1988, CMA's membership adopted a Bylaw change mak ing participation in Responsible Care an obligation of CMAmembership. The Responsible Care initiative has six prograraskneits: 1) Guiding Principles A statement of the philosophy and commitment by each member company regarding environmental, health and safety responsibilities in the manage ment of chemicals. 2) Codes of Management Practices Management goals which members are to make continuous good faith efforts to attain. 3) A Public Advisory Panel A cross-section of environmental, health and safety thought leaders to assist the industry in identifying and developing programs and actions that are responsive and are viewed as being responsive to public concerns. 4) Member Self-Evaluations Reports, measurements and other demonstrations of program implementation and progress toward improved environmental, health and safety performance in the responsible management of chemicals. 5) Executive Leadership Groups Periodic regional meetings of executive contacts to review Codes of Management Practices under development, discuss members' progress on existing codes and identify areas where assistance from the Association or other companies is needed. 6) Obligation of Membership Bylaw obligation of member companies to ascribe to the Cuiding Principles, participate in the development of the codes and programs, make good-faith efforts to implement the program elements of the Responsible Care initiative, and use the Responsible Care name and logo according to the Association's guidelines. VVV 000004876 >1 h of ak- iny ige- ns. nd ; on t or 'go GUIDING PRINCIPLES for RESPONSIBLE CARE As a member of the Chemical Manufacturers Association, this company is committed to support a continuing effort to improve the industry's responsible management of chemicals. We pledge to manage our business according to these principles: 1. To recognize and respond to community concerns about chemicals and our operations. 2. To develop and produce chemicals that can be manufactured, transported, used and disposed of safely. 3. To make health, safety and environmental considerations a priority in our planning for all existing and new products and processes. 4. To report promptly to officials, employees, customers and the public, information on chemical-related health or environmen tal hazards and to recommend protective measures. 5. To counsel customers on the safe use, transportation and disposal of chemical products. 6. To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. 7. To extend knowledge by conducting or supporting research on the health, safety and environmental effects of our products, processes and waste materials. 8. To work with others to resolve problems created by past handling and disposal of hazardous substances. 9. To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. 10. To promote the principles and practices of Responsible Care by sharing experiences and offering assistance to others who produce, handle, use, transport or dispose of chemicals. VVV 000004877 3 |39 IM H l > =r !b or CMHAENMUFICAACLTURERS ASSOCIATION OFFICERS `CHAIRMAN OF THE BOARD H. EUGENE McBRAYER Exxon Chemical Company, 9 Old Kings Highway South, Darien, CT 06820-4575 VICE CHAIRMAN OF THE BOARD FRANK P POPOFF The Dow Chemical Company, 2030 Willard H. Dow Center, Midland. MI 48674 `CHAIRMAN OF THE EXECUTIVE COMMITTEE JOHN W. JOHNSTONE. JR. Olin Corporation, P.O. Box 1355, Stamford, CT 06904-1355 PRESIDENT ROBERT A. ROLAND 887-1106 VICE PRESIDENT-- TECHNICAL DIRECTOR GERALDINE V. COX 887-1260 VICE PRESIDENT--TREASURER CARY C. HERRMAN 887-1230 VICE PRESIDENT -- COMMUNICATIONS JON HOLTZMAN 887-1200 VICE PRESIDENT- STATE AFFAIRS JAMES D. McINTlRE 887-1330 VICE PRESIDENT -- FEDERAL GOVERNMENT RELATIONS WILLIAM M. STOVER 887-1122 VICE PRESIDENT -- SECRETARY CHARLES W, VAN VIACK 887-1108 VICE PRESIDENT -- GENERAL COUNSEL DAVID F. ZOLL 887-1350 < c>. `Directors and Board Committee Members ex officio wVV 000004878 4 , DIRECTOR t ATIORS IRS IONS i' OUNSEL Members ex officio or CHEMOJ. ***NUCTURSW ASSOCIATION STAFF TECHNICAL DEPARTMENT Vice PrwMNt -- Technical DtpirtaMl iCHEMSTAR. NCRIC AND ENVIRONMENTAL GROUP] GERALDINE V. COX - 887-1260 Director, Natloeal Chemical Iuhu* ii4 laftraitiu Ceater HENRY J. SAUER-887-1254 NMi|tn Chemical Referral Ceater FRANCES G. BIASE - 887-1318 Naiafo, CHKNTRBC/CHEMNET MICHAEL L. DONAHUE - 887-1188 Nuafcr, CHENTREC Syatcma R. JAY CHEZEM - 887-1257 3Mnlm CHEMTREC Operatioaa HOWARD E. MANNING - 887-1267 Director, Eaelroamcatal Program JOE J. MAYHEW- 887-1164 Associate Director, Air Program RICHARD G. SIGMAN - 887-1313 Maaager, Air Program KAREN K. F1DLER-887-1176 Maaage* Air Program MARK L. WARNER-887-1383 Aaeoclat* Director, Solid Waatc Program DOROTHY A. KELLOCC- 887-1178 Maaagtr, Solid Waste Program CYNDY J. BRYCK-887-1290 Maaager, Solid Waatc Program JAMES C. MULL1CAN - 887-1270 Aaaoeiate Director, Water ead Greoadwater Program BRENDA A. CUCCHERINI - 887-1174 Aaaoeiate Director, Waat* oad Relooa* Redaction ANN M. MASON-887-1180 Naaagcr, Waate aad Rcleaae Radactioa SUZANNE C. WILLS-887-1366 Deputy Tfcchalcal Director, Chemical Self-Puded Tochalcal Advocacy aod Research Dlvtaioa Director LANGLEY A. SPURLOCK - 887-1187 Seaior Paaol Naaagcr ELIZABETH FESTA GORMLEY 887-1194 Aaaeciate Director ROBERT R. ROMANO - 887-1198 TECHNICAL -- continued Aaaoeiate Director CAROL R. STACK - 887-1196 Seaior Paael Maaagor BARBARA 0. FRANCIS - 887-1314 Aaaoeiate Director HASMUKH C. SHAH - 887-D92 Seaior Paael Naaagcr JONATHON T. BUSCH -8W-1189 Scalar Paael Naaagcr SUSAN R. HOWE-887-1293 Aaaoeiate Dlrocter ELIZABETH J. MORAN - 887-1182 Paael Naaagcr MARIAN K. STANLEY - 887-1207 Aaalataat Vie* Preaidcat -- Techalcal Dcpartmeat [HEALTH. SAKETY. DISTRIBUTION. ENGINEERING AND PLANT OPERATIONS GROl'Pi GORDON D. STRICKLAND - 887-1388 Director, Health Program KATHRYN A. ROSICA - 887-1282 Naaagcr, Health Program LESLIE J. KING --887-1323 Aaeeciatc Director, Health Program CLAUDETTE M. COFTA - 887-1278 Maaager, Health Program EMILY M. CURRIE - 887-1292 Maaager, Health Program DIANE S. LAYNE-887-1365 Aaaoeiate Director. Health Program SANDRA L, TIREY - 887-1274 Maaager, Health Program KAREN W. CREEDON - 887-1384 Aaaoeiate Director, (CAER) DEBORAH J. WIENER-887-1150 Director, Safety aad Plaat Operalioar DONALD D. HELIN - 887-1296 Maaager, Safety aad Plaat Oparatleae DAVID A. HASTINGS - 887-1280 Aaaoeiate Director, Safety aad Plaat Oporatleaa DIANA T. ARTEMIS - 887-1386 -- continued VVV 000004879 or CHBSCA4. MAMJfeCTUAERS ASSOCIATION STAFF--coatlaaed TECHNICAL -- continued Direct**. DUtTlkitlti PngriM RICHARD M. DOYLE-887-1272 Nu4tr, Emi|mci Rest**** Plsaaiog lit IVaiaiag ALMA M. HOWARD - 887-1263 Hui|<r, DMrikatlM Safety Prafruu FRANK J. PR1NCIPI -- 887-1262 Maasgsr, Dletrlbstla Safety Pnfrwu MICHAEL HEIMOWITZ -- 887-1360 FEDERAL GOVERNMENT RELATIONS DEPARTMENT Vice PreaMeat -- Federal Cmraactl Rslatloas WILLIAM M. STOVER - 887-1122 Director, Federal Legislative Affaire (Sopcrfoad aad Pradact Liability) TIMOTHY F. BURNS-887-1124 Legislative Rcpreseatative (FatcaU aad Special Programs) ROSE MARIE SANDERS - 887-1123 Leglalatlee Bepreseatalive (Hasardoos Waste aad Groeadwatsr) ROBERT B. FLAGG -887-1141 Legislative Maeager (Air aad Water Quality) KAREN J. NEALE - 887-1126 Legislative Repreacatatlve (Health aad Safety) EILEEN M. WINKELMAN -887-1134 Legislative Repveseatatlve (Esergy aad Traasportatiem) GARY W. GRIFFITH - 887-1136 Legislative Bcprescatatlve (Tbutioa aed Trade) CLAUDE P. B0UDR1AS --887-1138 Maaager, Federal Grassroots Program BRADLYA. BROADWELL-887-1146 Asalstaat Maaager of Grassroots RICHARD T. WILLIAMS - 887-1341 Director, Trade aed Ecoaomica ALLEN J. LENZ-887-1132 Associate Director (Taxatloe) ROBERT B. HILL-887-1128 Associate Director (Eaergy) THOMAS PARKERJR. - 887-1167 6 FEDERAL GOVERNMENT--continued Associate Director llaUraatioeal Trade) K. JAMES O'CONNOR. JR. -887-1130 Sealor Ecoaomlat T. KEVIN SWIFT - 887-1286 Ecoaomlat JENNIFER L. McDUFF-887-1121 Director of latoraatloaal Affairs R. GARRITY BAKER - 887-1338 COMMUNiegWraPEPARTMENT Vico Presidoat -- Ceaummicstioas JON HOLTZMAN - 887-1200 Admlalstratlvs Assistaat, Catalyst Awards PATRICIA A. SOKOLOFF - 887-1223 Director, Bcspoaslbl* Car* LORI M. RAMONAS-887-1264 Coordlaator, Respoasible Cars BONNIE M. C1LL0TT-887-1285 Director, Meetlogs aed Coovestieas EDIE FLEMING -- 887-1114 Asalstaat Director, Mcetiags aad Coavoatloaa DEBORAH F. BRAWNER-887-1316 Director, Media Commaaicatioas JEFFREY C. VAN -887-1222 Associate Director, Media Coauaoaicatioas THOMAS J. CILROY-887-1224 Editor; CbemEcology, LAURIE L. HAYES - 887-1204 Maaager, Breadcast News Service LINDA A. EDWARDS - 887-1139 Ifcckaicsl Coordlaator CHRISTOPHER PIANTADOSI 887-L393 Director, Isaac sad Member Comstualcatlea* JOHN E. SLAVICK-887-1210 Sealer Editor, CMA News JAMES P. TURNER -887-1206 -- continued VVV 000004680 -- continued ioaai Trad*) ?.-887-1130 286 K -- 887-1121 I 338 IRTMENT tiljnl Award* -887-1223 64 re -87-1285 OBt and Convention -887-1316 aunaaicatioa* '-1224 87-1204 Service 887-1139 rADOSl - mnnicatioa* 1206 --continued COMMUNICATIONS -- continued Manager, Mtabtr Coaaialciilou LAURA E. DIAMOND-887-1217 Manager, Communication* lasoea JAYNE 1. DAVIS-887-1226 Manager, Member Communications TIMOTHY M. RICHARDSON - 887-1218 STATE AFFAIRS DEPARTMENT Vice President -- State Affair* JAMES D. MclNTIRE- 887-1330 Director, State Pederatioa and Aaeociatiaa Liaiaoa D. CHRISTOPHER CATHCART -887-1265 Director, State leeaea WILLIAM H. WESTENDORF- 887-1340 Aaaociate Director, State leeaea JOAN E. RILEY -887-1268 Manager, State laanee IARRY F. GALLO - 887-1320 Manager, State [iiuti M.ARY B. HEATON - 887-1342 Manager, State laaaea STEVEN M. MANZO-887-1276 OFFICE OF CENERAt COUNSEL Vice Preaideat -- General Connaai DAVID F. ZOLL- 887-1350 Deputy General Connect DONALD D. EVANS-887-1354 Aaaiatant Ceaeral Connaala KATHY D. BAILEY-887-1186 MARILYN D. BROWNING-887-1118 SUSAN T. CONTI - 887-1356 RONALD A. SHIPLEY-887-1160 E. THOMAS SMERDON-887-1158 MICHAEL P. WALLS-887-1170 Connaala NANCY C. COOKSON - 887-1241 ROBERT D. ONDOCSIN -887-1352 DELL E. PERELMAN - 887-1162 GENERAL ADMINISTRATION Preaideat ROBERT A. ROLAND - 887-1106 Admiaiatrative Aaaiatant STEPHANIE A. HENRY - 887-1107 Vice Preaideat -- Corporate Secretary CHARLES W. VAN VLACK - 887-1108 Vice Prealdest -- Treasurer GARY C. HERRMAN -887-1230 Director, Peraonael MIRTHA T. ORME -887-1232 Controller RAYMOND J. O'BRYAN - 887-1240 Aaaiatant Controller THOMAS E. HARLOW -887-1221 Aaaiatant Controller ELIZABETH M. BURGAN- 887-1147 Manager, Employee Benefit* JANET C, SANDERS -- 887-1242 Director, Basieeaa Services J. MICHAEL McCRAW - 887-1336 Director, Printing, Distribution, Computer and Information Service* BENTON I). COOK-887-1212 Aaaociate Director, Mnnagemeet Information Systems DENNIS B. BUSTAMANTE-887-1332 Manager, Management Information System* NADER YOL'SEFIAN-887-1346 Manager, Printing and Mall Services JAMES L, CLARK - 887-1250 i vvv 000004881 or CXEMCAl `AASASNOUCMIACTTIOUNREOS BOARD OF DIRECTORS TERM ENDING MAT 31,1991 RAYMOND F. BENTELE Mallinckrodt, Inc., RO. Box 5840, St. Louis, MO 63134 JOHN D. BURNS Vista Chemical Company, 900 Threadneedle. Houston. TX 77079 VINCENT A. CALARCO Crompton & Knowles Corporation. One Station Place, Metro Center. Stamford, CT 06902 W.H. CLARK. JR. Naico Chemical Company. One Nalco Center, Naperville. IL 60563*1198 EARNEST W. DEAVENPORT, JR. Eastman Chemical Company, RO. Box 511. Kingsport, TN 37622 ERNEST H. DREW Hoechst Celanese Corporation. Route 202-206 North, Somerville, NJ 08876 GLEN H. H1NER CE Plastics, One Plastics Ave.. Pittsfield, MA 01201 GERALD L. HOER1C Syntex Chemicals, Inc., 2075 N. 55th St.. Boulder. CO 80301 DAVID S. HOLLINGSWORTH Hercules Incorporated. Hercules Plaza, 1313 N. Market St.. Wilmington, DE 19894 DONALD E. KOLOWSKY Pfizer Inc.. 235 E. 42nd St.. New York. NY 10017-5755 H. WILLIAM LICHTENBERGER Union Carbide Corporation, 39 Old Ridgebury ! Danbury. CT 06817-0001 ROBERT H- MALOTT FMC Corporation. 200 E. Randolph Dr., Chicag IL 60601 PETER J. NEFF Rhone-Poule*c Inc.. CN5266. Princeton. NJ 08543-5266 JOfrBi DlONG The BFCoodrich Company. 3925 Embassy RirkwajtAkron. OH44313 JOHN E. PEPPERCORN Chevron Chemical Company, RO. Box 5047. T4004, San Ramon, CA 94583-0947 HERBERT A. SKLENAR Vulcan Materials Company, Metroplex 1 Dr., Birmingham. AL 35253-0497 OR1N R. SMITH Engelhard Corporation. Menlo Park. CN40. 33 Wood Ave. South. Edison, NJ 08818-2901 F. QUINN STEPAN Stepan Company. 22 W. Frontage Rd.. Northfielc IL 60093 LAWRENCE A. WICDOR Kronos. Inc. -- Rheox. Inc.. P.O. Box 700. Hightstown. NJ 08520 TERM ENDING MAY 31, 1992 CHARLES A. ALDAG Sherex Chemical Company. Inc., P.O. Box 646, Dublin. OH 43017 RICHARD BARTH CIBA-GEIGY Corporation, 444 Saw Mill River Rd., Ardsley. NY 10502 ELWOOD P BLANCHARD, JR. E. I. du Pont de Nemours & Company, 1007 Marl St., Wilmington. DE 19898 J. ROGER HIRL Occidental Chemical Corporation, P.O. Box 809050. Dallas, TX 75380 3 VVV 0000Q4892 TERM ENDING MAY 31,1992 -- continued BEN H. LOCHTENBERC (Cl Americas Inc.. Concord Pike < New Murphy Rd.. Wilmington. DE 19897 CARL W. LORENTZEN Grace Specialty Chemicals Co.. Grace Plaza. 1114 Avenue of the Americas. New York. NY 10036 J. ROBERT LOVETT Air Products and Chemicals. Inc.. 7201 Hamilton Blvd., Allentown, PA 18195 FREDERIC M. POSES Allied-Signallnc., RO. Box 3000R, Morristown, NJ 07960 M. WHITSON SADLER Solvay America, Inc., 3333 Richmond Ave.. Houston, TX 77098 ARTHUR R. SICEL Velsicol Chemical Corporation, 5600 N. River Rd., Rosemont. IL 60018 HAROLD A. SORCENTI ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square, PA 19073-2387 JOHN HOYT STOOKEY Quantum Chemical Corporation, 99 Park Ave., New York. NY 10016 ROBERT G. WEEKS Mobil Corporation, 150 E. 42nd St.. New York. NY 10017 H. DANIEL WENSTRUP CHEMCENTRAL Corporation, 7050 W. 71st St., Chicago, IL 60638 J. LAWRENCE WILSON Rohm and Haas Company, Independence Mall West. Philadelphia, PA 19105 TERM ENDING MAY 31,1993 CYRIL C. BALDWIN, JR. Cambrex Corporation, One Meadowlands Plaza, East Rutherford, NJ 07073 i. A. (FRED) BROTHERS Ashland Oil, Inc., PO. Box 2219, Columbus, OH 43216 ROBERT D. CADIEUX Amoco Chemical Company, P.O. Box 87759, Chicago, IL 60680-0759 BOB G. GOWER Lyondell Petrochemical Company, P.O. Box 3646, Houston, TX 77253-3646 PETER R. HEINZE BASF Corporation, PO. Box 181, Parsippany, NJ 07054 JON M. HUNTSMAN Huntsman Chemical Corporation, 200 Eagle Cate Tower, 60 East South Ifemple St., Salt Lake City, UT 84111 CONRADS. KENT Akzo Chemicals Inc., 300 S. Riverside Plaza, Chicago, IL 60606 TRUMAN L. KOEHLER Sandoz Corporation, 4000 Monroe Rd., Charlotte, NC 28205 THOMAS MARSHALL Aristech Chemical Corporation, 600 Grant St., Pittsburgh, PA 15230-0250 SEYMOUR S. PRESTON, III ATOCHEM North America, Inc., Pennwalt Bldg., Three Parkway, Philadelphia, PA 19102 -- continued 9 CM* chemcal MANUFACTURERS 4SS0CIATICW BOARD -- continncd TERM ENDING MAY 31,1993 -- continued S. JAY STEWART Morton International. Inc.. 110 N. Wacker Dr.. Chicago, 1L 60606*1560 BILL M. THOMPSON Phillips Petroleum Company, Phillips Bldg., Bartlesville. OK 74004 HE1NN F. TOMFOHRDE, III GAF Chemicals Corporation. 1361 Alps Rd.. Wayne, NJ 07470 WILLIAM WISHN1CK Witco Corporation. 510 Madison Ave., New York, NY 10022*4236 CMP CMHAENMUIFCAACLTURERS ASSOCIATION MB BOARD OF Dll BOARD OF DIRECTC September 10-11 November 5 January 15 April -9 June 5 EXECUTIVE COMM! September 10 November 4 January 14 March 5 April 8 May 7 June 5 FINANCE COMMITT March 4 April 7 VVV 000004-884 10 _i._. a ChmCal MASASNOUCFAIACTTKU>sRERS MEETING SCHEDULES BOARD OF DIRECTORS AND BOARD COMMITTEES BOARD OF DIRECTORS September 10-11 November 5 January 15 April 8-9 June 5 EXECUTIVE COMMITTEE September 10 November 4 January 14 March 5 April 8 May 7 June 5 FINANCE COMMITTEE March 4 April 7 YVV 000004885 ___________1JL._ CH CM-AENMUICFAAACTURES assoCjadcn COMMITTEES OF THtBQ&RD OF DIRECTORS EXECUTIVE COMMITTEE FUNCTION: To exercise the powers of the Board of Directors with respect to conducting the business and affairs of the Haociator. including alt matters of policy and administration, axpt *ien the Board of Directors is in session. CHAIRMAN JOHN W. JOHNSTONE. JR ELWOOD P. BLANCHARD, JR. E. 1. du Pont de Nemours & Company, 1007 Market St., Wilmington, DE 19898 ROBERT D. CADIEUX Amoco Chemical Company, RO. Box 87759. Chicago. IL 60680-0759 EARNEST W. DEAVENPORT. JR. Eastman Chemical Company, P.O. Box 511, Kingsport, TN 37662 ERNEST H. DREW Hoechst Celanese Corporation, Route 202-206 North, Somerville, NJ 08876 GLEN H, HINER GE Plastics, One Plastics Ave., Pittsfield, MA 01201 J. ROCER HIRL Occidental Chemical Corporation, P.O. Box 809050, Dallas, TX 75380 DAVID S. HOLLINGSWORTH Hercules Incorporated, Hercules Plaza, 1313 N. Market St., Wilmington, DE 19894 JOHN VJOHNSTONE, JR. OfeCorporation, P.O. Box 1355, Stamford. CT 0004-1355 t EUttNE McBRAYER Enon Chemical Company. 9 Old Kings Highway Suth. Darien. CT 06820-4575 JQBiC PEPPERCORN Cbvron Chemical Company, P.O. Box 5047. TO04, San Ramon. CA 94583-0947 HAWP. POPOFF Be Dow ChemicaJ Company, 2030 Willard H. Dow finter, Midland, Ml 48674 UBBm A. ROLAND fltaucai Manufacturers Association, 2501 M St., Wm Washington, DC 20037 M.WWSON SADLER Siliay America. Inc.. 3333 Richmond Ave., Huston, TX 77098 F.QUBN STEPAN Sbpan Company, 22 W. Frontage Rd., Northfield, 1L60093 J. LAVBENCE WILSON Man and Haas Company, Independence Mall Vest. Philadelphia, PA 19205 FINANCE CO FUNCTION: Toadutse lh< relating to financing, mem CHAIRMAN J. ROGER HIRL JOHN D. BURNS Vista Chemical Coi Houston, TX 7707` W.H. CLARK, JR. Nalco Chemical Cc Naperville. IL 605i PETER R.HE1NZE BASF Corporation NJ 07054 J. ROGER HIRL Occidental Chemic. 809050, Dallas. TX H.W1X1AM LICHTEN Union Carbide Cori Danbury, CT 06817 VVV OOOOG4Q86 12 FINANCE COMMITTEE FUNCTION* To advise the Board of Directors on policy relating to financing, membership fees, and the budget. CHAIRMAN J. ROGER HIRL JOHN D. BURNS Vista Chemical Company, 900 Threadneedle, Houston, TX 77079 W.H. CLARK, JR. Nalco Chemical Company, One Nalco Center, Naperville, IL 60563-1198 PETER R. HE1NZE BASF Corporation, RO. Box 181, Parsippany, NJ 07054 J. ROGER HIRL Occidental Chemical Corporation, P.O. Box 809050. Dallas. TX 75380 H. WILLIAM LICHTENBERGER Union Carbide Corporation, 39 Old Ridgebury Rd., Danbury, CT 06817-0001 CARL W. LORENTZEN Grace Specialty Chemicals Co., Grace Plaza. 1114 Avenue of the Americas, New York, NY 10036 JOHN D. ONG The BPCoodrich Company, 3925 Embassy Parkway, Akron, OH 44313 HERBERT A, SKLENAR Vulcan Materials Company, Metroplex 1 Dr.. Birmingham, AL 35253-0497 HAROLD A. SORCENTI ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square, PA 19073 i ! I Note: In addition, the elected officers are ex officio members. 00000488 or CMHAENMUIFCAACLTURERS ASSOCIATION MEMBERSHIP COMMITTEE FUNCTION* To receive and pass upon each application for membership in the Association, and to report to the Board of Directors as to eligibility for membership of each applicant under the Bylaws. CHAIRMAN VINCENT A. CALARCO CYRIL C. BALDWIN. JR. Cambrex Corporation. One Meadowlands Plaza, East Rutherford. NJ 07073 VINCENT A. CALARCO Crompton & Knowles Corporation. One Station Place, Metro Center, Stamford. CT 06902 ROBERT H. MALOTT FMC Corporation. 200 E. Randolph Dr.. Chicago, IL 60601 THOMAS MARSHALL Aristech Chemical Corporation. 600 Grant St., Pittsburgh. PA 15230-0250 FREDERIC M. POSES Allied-Signal Inc., P.O. Box 3000R. Morristown, NJ 07960 ARTHUR R, SICEL Velsicol Chemical Corporation, 5600 N. River Rd., Rosemont, IL 60018 S. JAY STEWART Morton International. Inc.. 110 N. Wacker Dr., Chicago, IL 60606-1560 JOHN HOYT STOOKEY Quantum Chemical Corporation. 99 Park Ave., New York, NY 10016 HEINN F. TOMFOHRDE. Ill GAF Chemicals Corporation, 1361 Alps Rd., Wayne, NJ 07470 H. DANIEL WENSTRUP CHEMCENTRAL Corporation, 7050 W. 71st St., Chicago, IL 60638 LAWRENCE A. WICDOR Kronos, Inc. -- Rheox, Inc., RO. Box 700, Hightstown, NJ 08520 PROGRAM- FUNCTION: To plan t the Chemical Industry CHAIRMAN J.A.lFREDl BROTH CHARLES A. ALDA' Sherex Chemic Dublin, OH 43< J. A. (FRED) BROTH Ashland Oil, In OH 43216 GERALD L. HOERlt Syntex Chemic CO 80301 JON M. HUNTSMAI Huntsman Che Tower, 60 East UT 84111 BEN H. LOCHTENI K3 Americas h R<L, Wilmingtc Note: In addition, the elected officers are ex officio member* vvv 000004888 14 PROGRAM COMMITTEE FUNCTION: To plan the programs of the Annual Meeting and the Chemical Industry Conference ot the Association. CHAIRMAN J. A. IFRED) BROTHERS CHARLES A. ALDAC Sherex Chemical Company. Inc.. RO. Box 646, Dublin. OH 43017 J.A. (FRED) BROTHERS Ashland Oil. Inc.. RO. Box 2219. Columbus. OH 43216 GERALD L. HOER1C Syntex Chemicals, Inc., 2075 N. 55th St.. Boulder. CO 80301 JON M. HUNTSMAN Huntsman Chemical Corporation. 2000 Eagle Cate Tower, 60 East South Temple St.. Salt Lake City, UT 84111 BEN H. LOCHTEHBEKG 1CI Americas he.. Concord Pike & New Murphy Rd., Wilmington, DE 19897 J. ROBERT LOVETT Air Products and Chemicals. Inc.. 7201 Hamilton Blvd.. Allentown. PA 18195 PETER J. NEFF Rhone-Poulenc Inc.. CN5266. Princeton, NJ 08543-5266 SEYMOUR S. PRESTON, III ATOCHEM North America. Inc.. Pennwalt Bldg., Three Parkway. Philadelphia. PA 19102 ROBERT C. WEEKS Mobil Corporation. 150 E. 42nd St.. New York. NY 10017 WILLIAM WISHNICK Wttco Corporation. 520 Madison Ave., New York, NY 10022-4236 VVV 000004889 Note: In addition, the elected officers are ex officio members. CMP CUhAeNmUiMcaClTURfSS ASSOCIATCW EMPLOYEE BENEFITS COMMITTEE CMHAENMUICfAACLTuRfnS ASSOCIATION C k. COMMUNIC FUNCTION: To advise the iioard of Directors regarding bene- pension plan and all other non-salary employee benefits PURPOSES: With res fits, financing, and administration of the Associations employee will advise the Execute ^attitudes involving the CHAIRMAN RAYMOND F. BENTELE RICHARD BARTH C1BA-GEICY Corporation. 444 Saw Mill River Rd., Ardsley, NY 10502 RAYMOND F. BENTELE Maliinckrodt. Inc.. P.O. Box 5840, St. Louis. MO 63134 BOB C. COWER Lyondell Petrochemical Company, RO. Box 3646. Houston, TX 77253-3646 CONRAD S. KENT Akzo Chemicals Inc.. 300 S. Riverside Plaza. Chicago, 1L 60606 TRUMAN L. KOEHLER Sandoz Corporation, 4000 Monroe Rd.. Charlotte, NC 28205 DONALD E. KOLOWSKY Pfizer Inc., 235 E. 42nd St.. New York. NY 10017-5755 ORIN R. SMITH Engelhard Corporation. Menlo Park. CN40, 33 Wood Ave. South. Edison, NJ 08818-2901 BILL M. THOMPSON Phillips Petroleum Company. Phillips Bldg., Bartlesville. OK 74004 CHAIRMAN* VICKY M.SUAZO VICE CHAIRMAN* D. BRENT McGINNl TERM ENDING Mi WILLIAM R. JENKI FMC Corporate IL 60601 DONALD R. KIRTL1 Hercules lncor[ Market St.. Wii J.LfLYNN) MADDC -i Chevron Chemi San Ramon. CA GEORGE R MIGA Amoco Chemict MC3705, Chicas WILLIAM H. SCARE Shell Oil Comp. TX 77252 VICKY M. SUAZO Dow Chemical 1 Washington. Dt TERM ENDING Mi WILLIAM C. ADAMe ICI Americas In DE 19897 ROBERT M. BERZO Union Carbide 1 C-2201. Danbur THOMAS A. CHIZM. CIBA-GEJGY G Ardsley, NY M Note: In addition, the elected officers are ex officio members. VVV 000004890 16 CMhANemUFicAaClTURERS ASSOC IATCW STANDING COMMITTEES COMMUNICATIONS COMMITTEE PURPOSES: With respect to communications, the Committee will advise the Executive Committee and start on problems and attitudes involving the chemical industry's relations with the public and provide guidance and assistance on the initiation and implementation of constructive programs m this area, CHAIRMAN* VICKY M. SUAZO VICE CHAIRMAN* D. BRENT McCINNIS STAFF EXECUTIVE JEFFREY C. VAN TERM ENDING MAY 31,1991 WILLIAM R. JENKINS FMC Corporation. 200 E. Randolph Dr., Chicago, IL 60601 DONALD R. KIRTLEY Hercules Incorporated. Hercules Plaza, 1313 N. Market St., Wilmington, DE 19894 J.HLYNNI MADDOX Chevron Chemical Company, P.O. Box 5047, San Ramon, CA 94583-0947 GEORGE P. MIGA Amoco Chemical Company, 200 E. Randolph Dr., MC3705, Chicago, IL 60601 WILLIAM H. SCARBOROUGH Shell Oil Company, P.O. Box 2463, Houston, TX 77252 VICKY M. SUAZO Dow Chemical U.S.A.. 1776 Eye St,, NW, Suite 575, Washington, DC 20006 TERM ENDING MAY 31,1992 WILLIAM C. ADAMS ICI Americas Inc., 6 Rollins Bldg., Wilmington, DE 19897 ROBERT M. BERZOK Union Carbide Corporation, 39 Old Ridgebury Rd., C-2201, Danbury, CT 06817 THOMAS A. CHIZMADIA CIBA-GE1GY Corporation, 444 Saw Mill River Rd., Ardsley, NY 10502 WILLIAM M. CORCORAN Allied-Signal Inc., Engineered Materials Sector, RO, Box 1087R. Morristown, NJ 07960 D. BRENT McGiNNIS Ashland Chemical Company, PO. Box 2219, Columbus, OH 43216 TERM ENDING MAY 31,1993 CHARLES A. DANA. JR. Occidental Chemical Corporation, P.O. Box 809050, Dallas. TX 75380 ALEXANDER M. HOUSTON Olin Corporation, P.O. Box 1355, Stamford, CT 06904-1355 KENNETH JACOBSON E.J. du Pont de Nemours & Company, 1701 Pennsylvania Ave., NW, Suite 900, Washington, DC 20006 JILL B. JOHNSON Exxon Chemical Americas, RO. Box 3272. Houston, TX 77253-3272 LOUIS H. K1STNER SCM Chemicals, Inc., 7 St. Raul St., Suite 1010, Baltimore, MD 21202 Through May 31.1991 i VVV 000004091 cn CK*"ANMVfOACjTUR9S ^SSOOATON DISTRIBUTION COMMITTEE ENERGY CON PURPOSES* Under the policies established bv the Board of Directors and within the authority specified by the Executive Committee, the Committee oversees Association proprams to insure safe and efficient distribution oi chemicals and to pro mote effective emergency response, in doing so. the Committee will: identify key issues and foeus eiYorts on matters of greatest significance to the chemtcai manufacturing industry: establish speciric objectives on key issues and mobilize resources to pro duce timely results: develop and recommend to the Executive Committee policies and positions on legislative, regulatory and technical questions: advocate effective and reasonable legisla CHAIRMAN* ROBERT P. FRENCH VICE CHAIRMAN* PHILIP R. GRIFFITHS TERM ENDING MAY 3L 1991 JOSEPH J. CATTO American Cyanamid Company, One Cyanamid Plaza, Wayne. NJ 07470 CORDON E. CHRISTMAN Mobay CorporationJtatajrfid., Pittsburgh. PA 15205-9741 PHILIP R, GRIFFITHS Exxon Chemical Americas, 13501 Katy Freeway, Houston, TX 77079 RONALD M. JACOBSON Rohm and Haas Company, Independence Mall West, Philadelphia. PA 19105 J.C. WILLIAMS The Procter & Gamble Company, PO. Box 599, Cincinnati, OH 45217 TERM ENDING MAY 31,1992 MARVIN A. CRANE Ethyl Corporation, 451 Florida St., Baton Rouge, LA 70801 ROBERT R FRENCH E.I. du Pont de Nemours & Company, Materials & Logistics Dept., Wilmington, DE 19898 A.S. RIVERS Monsanto Company, 800 N. Lindbergh Blvd., St. Louis, MO 63167 18 tion on the distribution of chemicals: advise the Executive Committee on Association staffing and resources required by the Committee to achieve its objectives: help member compa nies understand the major trends, developments, key issues, and Association actions in the distribution area: develop publicawareness of chemtcai manufacturing industry contributions to the safe distribution of chemicals: sponsor joint initiatives with other organizations to continue to improve the safe distribution of chemicals: and promote member participation in CMA initiatives. STAFF EXECUTIVE RICHARD M. DOYLE PURPOSES* Wuh respect productivity matters that a> manufacturing industry, in trocbemical feedstocks, the discussion of chemical mar major industrial energy cm CHAIRMAN* ROYCE D. LAFF1TTE VICE CHAIRMAN* THOMAS D, F1NNIGAN LARRY N. WATSON Chevron Chemical Company. 6001 Bollinger Canyon Rd., San Ramon, CA 94583-0947 RONALD R. WEBER Air Products and Chemicals. Inc., 7201 Hamilton Blvd.. Allentown, PA 18195 TERM ENDING MAY 31,1993 JOHN J. ARCHER Ashland Chemical Company, P.O. Box 2219. Columbus, OH 43216 DONALD A. CENTER Union Carbide Corporation. 39 Old Ridgebury Rd., Danbury, CT 06817-0001 DONALD M. MURRAY The BFGoodrich Company, 6100 Oak Tree Blvd., Cleveland. OH 44131 EDWARD D. OLMO Shell Chemical Company. RO. Box 2463, Houston, TX 77252 B. FIELDING ROLSTON Eastman Chemical Company, P.O. Box 511. Kingsport. TN 37662 TERM ENDING MAY: JOHN C. deRUYTER E. 1. du Pont de Net 6090, Newark. DE THOMAS D. FINNIGAN Union Carbide Cor Suite 1200, Washin THOMAS A. GAMBLE Hercules Incorpora Market St., Wiisin PKTL. MAETO BASF Cm p--lion. NJ 07054 EDWARD H. MERGENS Shell Chemical Cor TX 77252 term ENDING may: WILLIAM H. CHAMBEI Vista Chemical Cor Houston, TX 7707S NORMAN L. DAVIS Monsanto Compam Louis, MO 63167 GARY S. FURMAN American Cyanamic Plaza. Wayne, NJ 0 'Through May 31.1991 vvv 000004892 ENERGY COMMITTEE PURPOSES* With respect to energy utilization and energy productivity matters that are significant to the chemical manufacturing industry, including those relating to pe trochemical feedstocks, the Committee will: serve as a torum for discussion of chemical manufacturing industry concerns as a major industrial energy consumer: monitor, evaluate and an- alvze the chemical industry's interest in proposed legislation and regulations: develop and recommend to the Executive Com mittee appropriate Association activities, programs, policies and positions on legislative, regulatory and technical questions: and provide support for other authorized Association programs as thev relate to energy issues. CHAIRMAN* ROYCE C. LAFF1TTE VICE CHAIRMAN* THOMAS D. FINN1CAN STAFF EXECUTIVE THOMAS PARKER, JR. TERM ENDING MAY 31,1991 JOHN C. deRUYTER E. I. du Pont de Nemours & Company, RO. Box ; 6090, Newark, DE 19714-6090 1 THOMAS D. FINNICAN Union Carbide Corporation, 1100 15th St., NW, ? Suite 1200. Washington. DC 20005 'THOMAS A. GAMBLE Hercules Incorporated. Hercules Plaza, 1313 N. Market St., Wilmington, DE 19894 PAT L. MAISTO BASF Corporation. RO. Box 181, Parsippany, j. NJ 07054 ' EDWARD H. MERGENS . Shell Chemical Company, P.O. Box 2463, Houston, TX 77252 TERM ENDING MAY 31,1992 WILLIAM H. CHAMBERLAIN Vista Chemical Company, 900 Threadneedle, Houston, TX 77079 NORMAN L. DAVIS Monsanto Companv, 800 N. Lindbergh Blvd., St. L Louis. MO 63167 CARY S. FURMAN American Cyanamid Company, One Cyanamid Plaza, Wayne, NJ 07470 JAMES R. MUCHONEY Aristech Chemical Corporation, 600 Grant St., Pittsburgh, PA 15230 ANTHONY C, TUMMARELLO Occidental Chemical Corporation, P.O. Box 809050, Dallas. TX 75380 TERM ENDING MAY 31,1993 R. DAVID DAMRON Hoechst Celanese Chemical Group, P.O. Box 569320, Dallas, TX 75356-9320 ROYCE D. UFFITTE Eastman Chemical Company, P.O. Box 7444, Longview, TX 75607 GEORGE MATZKE GAF Corporation. 1361 Alps Rd,, Wayne, NJ 07470 ROY NOBLE Rhone-Fbulenc Inc., CN5266, Princeton, NJ 08543-5266 JAMES E. YOCHIM Chevron Chemical Company, P.O. Box 3766, Houston, TX 77253 'Through May 31,1991 chemical MASASNOUCFIAACTTIOUNRERS ENGINEERING AND OPERATIONS COMMITTEE ENVIRONM PURPOSES* With respect to engineering design, construc tion, operation, and maintenance of facilities for manufacture, storage and handling of industrial chemicals as significant to the chemical manufacturing industry, the Committee will: serve as a lorum for discussion 01 chemical manufacturing industry concerns: develop and recommend to the Executive Committee policies and positions on legislative, regulatory, and technical questions: and provide support Jor authorized Association programs. CHAIRMAN* PERCY R. KAVASMANECK VICE CHAIRMAN* RAY E. OLSEN STAFF EXECUTIVE DONALD D. HELIN TERM ENDING MAY 31,1991 VANCE M. BAKEMAN Grace Specialty Chemicals Co., 1114 Avenue of the Americas, New York, NY 10036 TEDF. HENKEN Chevron Chemical Company, 6001 Bollinger Canyon Rd,, Bldg. T-4318. San Ramon. CA 94583 PERCY R. KAVASMANECK Union Carbide Corporation, P.O. Box 8361, South Charleston, W7-25303 LARRY D. SHAYER Monsanto Company, 800 N. Lindbergh Blvd., St. Louis, MO 63167 TERM ENDING MAY 31,1992 VICTOR E. BAKER CIBA-GEIGY Corporation, 444 Saw Mill River Rd,, Ardsley, NY 10502 LANDON N. KENNY Tennessee Eastman Company, P.O. Box 511, Kingsport, TN 37662 WILLIAM J. MANN Pfizer Inc.. 235 E. 42nd St., New York, NY 10017-5755 RAY E. OLSEN Exxon Chemical Company, P.O. Box 400, Baytown. TX 77522-2090 WILLIAM L. TANNER Shell Chemical Company, RO. Box 2033. Houston. TX 77024 TERM ENDING MAY 31,1993 LARRY L. HENDERSON Hoechst Celanese Corporation, Route 202-206 North, Somerville, NJ 08876 EUGENE J. KLOSAK Nalco Chemical Company, One Nalco Center, Naperville, IL 60563-1198 MacGREGOR SCOTT ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square, PA 19073-2387 RANDALL E. VARILEK Air Products and Chemicals, Inc., 7201 Hamilton Blvd., Allentown, PA 18195 JAMES N. WILKES The Dow Chemical Company, 400 W. Sam Houston Parkway South, Houston, TX 77042-1299 PURPOSES* Under tt Board of Directors ana -the Executive Commit environmental activitu identify key environtm of greatest significanu establish specific objec resources to produce a advocate responsible e which consider econon fectiveness. risks, and: CHAIRMAN* THOMAS L. JENNU VICE CHAIRMAN* HUGH J. CAMPBEL TERM ENDING M HUGH J. CAMPBEL E.l. du Pont de Dept.. P.O. 609 THOMAS L. JENNP Occidental Che Blvd. South, B' JERRY B. MARTIN Dow Chemical Midland, MI 48 JOHN M. SALMELA Chevron Chem Canyon Rd., Bl 94583-0947 TERM ENDING M GERALD!. BRESN1 Amoco Chemii Chicago. IL 60 CHARLES D. MALL Monsanto Com Louis, MO 6316 MICHAEL M. MARS Lonza Inc., 17- 'Through May 31,1991 WV 000004894 ENVIRONMENTAL MANAGEMENT COMMITTEE PURPOSES) Under the broad policies established by the Board or Directors and within limits of authority specified bv the Executive Committee, the Committee oversees Association environmental activities. In so doing, the Committee will: identify key environmental issues and focus efforts on matters of greatest significance to the chemical manufacturing industry establish specific objectives on the key issues and mobilize resources to produce decisive timely results: aggressively advocate responsible environmental legislation and regulation which consider economic impacts, energy implications, cost ef fectiveness, risks, and benefits: seek relief from unreasonable environmental legislation and regulation by appropriate means, which may include legal action: advise the Executive Commit tee on Association staffing and resources required by the Com mittee to achieve its objectives: help member companies under stand their environmental responsibilities by informing them of major trends, developments, key issues, and Association ac tions: develop awareness of chemical manufacturing industry contributions to environmental management and facts sur rounding key issues: and initiate and sponsor research and development on environmental issues of widespread interest to the chemical manufacturing industry. CHAIRMAN" THOMAS L. JENNINGS VICE CHAIRMAN" HUGH J. CAMPBELL, JR. STAFF EXECUTIVE JOE J. MAYHEW TERM ENDING MAT 31,1991 HUGH J. CAMPBELL, JR. E. I. du Pont de Nemours & Company. Engineering Dept., P.O. 6090. Newark, DE 19714-6090 THOMAS L. JENNINGS Occidental Chemical Corpentian, 360 Rainbow Blvd. South. Box 728. Niagara fhlls, NY 14302 JERRY B. MARTIN Dow Chemical U.S.A., 2020 Willard H. Dow Center, Midland. MI 48674 JOHN M. SALMELA Chevron Chemical Company, 6001 Bollinger Canyon Rd., Bldg. T2000, San Ramon, CA 94583-0947 TERM ENDING MAT 31,1992 GERALD I. BRESNICK Amoco Chemical Company, P.O. Box 87759, Chicago, IL 60680-0759 CHARLES D. MALLOCH Monsanto Company, 800 N. Lindbergh Blvd., St. Louis, MO 63167 MICHAEL M. MARSHALL Lonza Inc., 17-17 Route 208, Fhir Lawn, NJ 07410 CARL MATT1A The BFGoodrich Company, 3925 Embassy Parkway, Akron. OH 44313 RICHARD L. MONTY GE Plastics, One Plastics Ave,, Pittsfield, MA 01201 TERM ENDING MAT 31.1993 ROBERT T. JACKSON Union Carbide Corporation, 39 Old Ridgebury Rd,, Danbury, CT 06817-0001 RONALD R. KIENLE Shell Chemical Company, P.O. Box 2463, Houston, TX 77252 DAVID M. KISER Eastman Kodak Company, 1776 Eye St,, NW, Suite 1050, Washington, DC 20006 ROBERT C. NILES Grace Specialty Chemicals Co., 55 Hayden Ave,, Lexington, MA 02173 CHARLES T. SEAY Exxon Chemical Americas, 13501 Katy Freeway, Houston, TX 77079 Through May 31,1991 VVV 000004395 CM ChKCAL MANUMCTURERS ASS0Ci*I1O< FEDERAL GOVERNMENT RELATIONS COMMITTEE PURPOSES: With respect to communications between the chemical manufacturing industry and the federal government on matters significant to the chemical manufacturing industry, the Committee will: seek to anticipate, identify, and establish priorities with respect to issues and opportunities: advise the Executive Committee and other Association entities regarding policy formation: participate in the planning of Association programs aimed at specific issues or objectives, with emphasis on strategy considerations; oversee and participate in the exe cution of legislative programs: and monitor, evaluate, and seek to enhance the effectiveness of authorized Association programs. HEALT1 PURPOSES: 1 concerning hur identify key hei greatest signifk objectives and ? vefop and recon positions on le CHAIRMAN* WILLIAM T. LYONS VICE CHAIRMAN* CHARLES H. ROWTON STAFF EXECUTIVE TIMOTHY F. BURNS CHAIRMAN* JOHNC. WILi MBOA1RM THOMAS J. M TERN ENDING MAY 31,1991 ALAN D. FIERS Grace Specialty Chemicals Co.. 919 18th St.. NW. Suite 400. Washington. DC 20006 DONALD R. GREELEY Hoechst Celanese Corporation. 919 18th St., NW. Suite 700. Washington, DC 20006 CHARLES H. ROWTON Exxon Corporation, 1899 L St., NW. Suite 1100, Washington. DC 20036 HAROLD S. RUSSELL FMC Corporation. 1627 K St., NW, Suite 500, Washington, DC 20006 RALPH D. SCHUMACK Dow Corning Corporation, 1800 M St., NW, Suite 325 South, Washington, DC 20036 TERN ENDING MAY 31,1992 JULIE ARCHULETA Occidental Chemical Corporation, 1747 Pennsylvania Ave., NW, Suite 375, Washington, DC 20006 KENNETH E. DAVIS Rohm and Haas Company, Independence Mall West. Philadelphia. PA 19105 22 WELLS DENYES Eastman Kodak Company, 1776 Eye St., NW. Suite 1050, Washington. DC 20006 PHILIP C. HOLLADAY Shell Oil Company, 1025 Connecticut Ave., NW. Suite 200. Washington, DC 20036 WILLIAM T. LYONS CIBA-GEICY Corporation, 1747 Pennsylvania Ave.. NW, Suite 700. Washington. DC 20006 TERM ENDING MAY 31,1993 GERRIE BJORNSON The BPGoodrich Company, 1825 Eye St., NW, Suite 400, Washington, DC 20006 JEREMIAH J. KENNEY, JR. Union Carbide Corporation, 1100 15th St., NW, Suite 1200. Washington, DC 20005 JOSEPH J. MARTYAK Rhone-Poulenc Inc., 655 J5th St., NW, Suite 225, Washington, DC 20005 STACEY J. MOBLEY E.I. du Pont de Nemours & Company, 1701 Pennsylvania Ave., NW, Suite 900, Washington, DC 20006 THOMAS C. MORRIS Phillips Petroleum Company. 1776 Eye St,, NW, Suite 700. Washington, DC 20006 'Through May 31,1991 TERM ENDW WALLACE F. I Dow Corn MI 48686 JAMES H. PRh Quantum Dr., Cincir JAMES H. SEN Monsanto Louis, MO 'ttWIDD.SIGM Exxon Che Houston, 1 JOHN C. WILLI Shell Oil G TX 77210 term endin< EUGENE C. CAI ARCO Cher Newtown S SUSAN P. ENGE Hoechst Ce North, Som MARVIN A. FRH American C Plaza, Wayr vvv 000004896 f i HEALTH AND SAFETY COMMITTEE PURPOSES* The Committee oversees Association programs concerning human health and safety. The Committee will: identify key health and safetv issues and focus on matters of greatest significance to the chemical industry: establish specific objectives and mobilize resources to produce timely results: de velop and recommend to the Executive Committee policies and positions on legislative, regulatory, and teenmeai questions; provide cost-effective support for authorized Association pro grams that enhance chemical industry productivity and com petitiveness through health and safety programs; seek relief from unreasonable health and safety legislation and regulation by appropriate means; sponsor research and development on human health and safety issues of widespread interest to the chemical industry. CHAIRMAN" JOHN C. WILLETT VICE CHAIRMAN" THOMAS J. MARRIOT. JR. STAFF EXECUTIVE KATHRYN A. ROSiCA TERM ENDING MAY 31,1991 WALLACE F. DYSTE Dow Corning Corporation. P.O. Box 994. Midland. Ml 48686-0994 JAMES H. PRICE Quantum Chemical Corporation. 11500 Northlake Dr., Cincinnati. OH 45249 JAMES H. SENCER Monsanto Company, 800 N. Lindbergh Blvd., St. Louis, MO 63167 DAVID D. SIGMAN Exxon Chemical Company, 13501 Katy Freeway, Houston, TX 77079 JOHN C. WILLETT Shell Oil Company, P.O. Box 4320. Houston, TX 77210 TERM ENDING MAY 31,1992 EUGENE C. CAPALDI ARCO Chemical Company, 19 Campus Blvd., Newtown Square. PA 19073 SUSAN P. ENGELMAN Hoechst Celanese Corporation, Route 202-206 North, Somerville. NJ 08876 MARVIN A. FRIEDMAN American Cyanamid Company, One Cyanamid Plaza. Wayne, NJ 07470 PHILIP G. LEWIS Rohm and Haas Company, P.O. Box 584, Bristol. PA 19007 HAINES B. LOCKHART Eastman Kodak Company, 343 State St., Rochester, NY 14650 TERM ENDING MAY 31,1993 JOHN J. KASPER Nalco Chemical Company, One Nalco Center, Naperville. IL 60563-1198 THOMAS J. MARRIOT, JR. Air Products and Chemicals, Inc., 7201 Hamilton Blvd., Allentown, PA 18195-1501 NEIL O. NEUNABER Olin Corporation, RO. Box 1355, Stamford, CT 06904-1355 LADD W. SMITH Occidental Chemical Corporation, 360 Rainbow Blvd. South, Niagara Fblis, NY 14302 GARY L. TER HAAR Ethyl Corporation, 451 Florida St., Baton Rouge, LA 70801 *Through May 31.1991 i i 23 Wtf C00004B97 or CHEMCM. UAMJHCTUREPS ASSOCIATION INTERNATIONAL TRADE COMMITTEE PURPOSES: With respect to trade policy matters of interest to the chemical manufacturing industry, the Committee will: monitor international trade data and events, develop policies on trade issues, recommend policies and action to the Executive Committee and provide support for authorized Association policies. CHAIRMAN* NANCIE S. JOHNSON VICE CHAIRMAN* JOSEPH A. CILLAN STAFF EXECUTIVE K. JAMES O'CONNOR. JR. TERM ENDING MAY 31,1991 MARK BLASS Air Products and Chemicals. Inc., 7201 Hamilton Blvd.. Allentown, PA 18195-1501 NANCIE S. JOHNSON E.I. du Pont de Nemours & Company, 1701 Pennsylvania Ave., NW. Suite 900, Washington. DC 20006 GEORGE M. MACK1E CrompttJn & Knowles Corporation. 3001 N. Graham SL, Charlotte. NC 28201 DONALD H. MARSHALL The BFGoodrich Company, 6100 Oak Tree Blvd.. Cleveland, OH 44131 JOSEPH E. PATTISON FMC Corporation, 2000 Market SL, Philadelphia, PA 19103 TERM ENDING MAY 32.99* WILLIAM E. CQHiiEUUS Dow Chemical U.S.A., 2020 Willard H. Dow Center, Midland, Ml 48674 DAVID J. ELLIOTT The Procter & Camble Company, One Procter & Gamble Plaza, Cincinnati, OH 45201 EDWARD D. GRIFFITH ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square. PA 19073 THOMAS M. HELSCHER Monsanto Company, 700 14th St.. NW. Suite 1100, Washington, DC 20005 SANDRA E. TAYLOR 1CI Americas Inc., 1600 M St., NW, Suite 702, Washington, DC 20036 TERM ENDING MAY 31,1993 JOSEPH A. GILLAN Exxon Chemical Company, 9 Old Kings Highway South, Darien, CT 06820-4575 POLLY HANNAS W. R. Grace & Co.. 919 18th St.. NW, Suite 400. Washington, DC 20006 BUDC. PETTIGREW Eastman Chemical International, P.O. Box 431, Kingsport, TN 37662 MICHAELS. REYNOLDS Vista Chemical Company, 900 Threadneedie, Houston, TX 77079 MAX L. TURN1PSEED Ethyl Corporation, 1155 15th St., NW, Suite 611, Washington, DC 20005 `Through May 31,1991 26 STATE PURPOSES matters signi monitor and. define and es emerging issi tors. Executi' Association e delivery of pc Association p tactical plans CHAIRMAN' C. ROBERT VKXCUUR D. LYNN JO! TERM END C. ROBERT , Exxon L Houstor D. LYNN JOL TennessKingspo RALPH C. LC CIBA-GE Ardsley, DEBORAH L. The BFC Parkway, 5USXN M. GEPtasfa Suite 806 termekm? JAMES R. BUT Ashland ( GEOFFREY B. Rohm anc 210, Wash GRAHAM H. J; Nalco Che Naperville WV 000004893 STATE AFFAIRS COMMITTEE PURPOSES: With respect to state legislative and regulatory matters significant to the chemical industry, the Committee will: monitor and review proposed major legislation and regulations: define and establish priorities with respect to current and emerging issues and opportunities: advise the Board or Direc tors. Executive Committee, standing committees and other Association entities in the development, implementation and delivery of policy; provide support for and liaison with other Association programs and committees: recommend strategy and tactical plans for specified state issues, and manage implemen tation of strategy after approval: manage state issues by work ing through member companies, chemical councils and their Federation, state business associations, organizations repre senting state and local elected officials, and appropriate coali tions: implement direct legislative or regulatory advocacy on a selected basis in states with no CIC structure on issues of na tional significance to the chemical industry: and conduct longrange planning with respect to state legislative and regulatory issues. CHAIRMAN" C. ROBERT BALL VICE CHAIRMAN* D. LYNN JOHNSON STAFF EXECUTIVE WILLIAM H. WESTENDORF TERM ENDING MAT 31,1991 C. ROBERT BALL Exxon Chemical Americas, 13501 Katy Freeway. Houston. TX 77079 D. LYNN JOHNSON Tennesse Eastman Company, P.O. Box 511, . Kingsport, TN 37662 RALPH C. LOOMIS | C1BA-GE1CY Corporation, 444 Saw Mill River Rd., 1 Ardsley, NY 10502 ! DEBORAH L. NEALE The BPGoodrich Company, 3925 Embassy Parkway, Akron, OH 44313 SUSAN M. WALTER CE Plastics, 1331 Pennsylvania Ave., NW, Suite 800, Washington, DC 20004 ' TERM ENDING MAT 31,1992 I JAMES R. BUTLER I Ashland Oil, Inc., RO. Box 391, Russell, KY 41114 GEOFFREY B. HURWITZ Rohm and Haas Company, 1667 K St., NW, Suite 210, Washington, DC 20006 GRAHAM H. JACKSON Nalco Chemical Company, One Nalco Center, Naperville, IL 60563-1198 JERRY RING Dow Chemical U.S.A., 47 Building, Midland, MI 48667 DAVID A. SN1VELY BP Chemicals. Inc.. 200 Public Square. 4G-5800-J, Cleveland. OH 44144-2375 TERM ENDING MAT 31, 1993 D.H. BREWER Olin Corporation, 4363 N. Ocoee St,, Cleveland, TN 37311 JERRY CHAMBERS American Cyanamid Company, 1575 Eye St,, NW, Suite 200, Washington, DC 20005 ROBERT J. CHRISTIE FMC Corporation, 200 E. Randolph Dr,, Chicago, IL 60601 TIMOTHY J. HOLT Air Products and Chemicals, Inc., 7201 Hamilton Blvd., Allentown, PA 18195 COLBERT R. WILHITE E.I. du Pbnt de Nemours & Company, 1007 Market St, D8078, Wilmington, DE 19898 Through May 31,1991 27 ! VVV 000004899 CM CWASHlASfhWO*C*C>IAAATCLITOUNflERS TAX POLICY COMMITTEE PURPOSES: With respect to federal and state tax matters, the Committee will: advise the Executive Committee of the formulation of Association policies, review proposed legisla tion. regulations, and treaties and recommend to the Executive Committee appropriate Association positions thereon: develop and recommend to the Executive Committee proposals to be ad vocated by the Association for the revision of existing laws: and provide technical support for authorized Association programs. CHAIRMAN* RICHARD A. OVERTON VICE CHAIRMAN* CEORCE B. ERENSEN STAFF EXECUTIVE ROBERT B. HILL TERM ENDING MAY 31,1991 DOUGLAS E. BERG Amoco Corporation. 200 E. Randolph Dr.. Chicago. 1L 60601 MICHAEL H. BURNSIDE Chevron Chemical Company, 6001 Bollinger Canyon Rd.. San Ramon. CA 94583-0947 JOHN A. CARR1G Phillips fttroleum Company. 710 Plaza Office Bldg., Bartlesville. OK 74004 WILLIAM C. DAKIN Mobil Corporation. 150 E. 42nd St.. New York. NY 10017 WILLIAMSON R DONALD E.I. du Pont de Nemours & Company. 1007 Market St.. Wilmington. DE 19896 THOMAS C. FRIEL Rohm and Haas Company Independence Mall West, Philadelphia. PA 35105 TERM ENDING MAT 31,1992 WILLIAM M. BELUMY. JR. Union Carbide Corporation, 39 Old Ridgebury Rd., Danbury, CT 06817 HOWARD KAREL ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square, PA 19073 JAMES R. LOWE Exxon Chemical Company, 9 Old Kings Highway South, Darien, CT 06820 ROBERT J. MOODY FMC Corporation. 200 E. Randolph Dr.. Chicago, 1L 60601 28 RICHARD A. OVERTON Monsanto Company, 800 N. Lindbergh Blvd., St. Louis. MO 63167 MICHAEL J. PRENDERGAST Aristech Chemical Corporation. 600 Grant St.. Suite 2858. Pittsburgh, PA 15230-0250. THOMAS C. SINGLEY Shell Oil Company, P.O. Box 2463. Houston, TX 77252 TERM ENDING MAY 31,1993 SEAN T. CRIMMINS Ashland Oil. inc., RO. Box 391, Ashland, KY 41114 ROBERT M. DOBRESKI Eastman Kodak Company, 343 State St., Rochester, NY 14650 GEORGE B. ERENSEN Olin Corporation, 120 Long Ridge Rd.. Stamford, CT 06904-1355 THOMAS M. HINDMARCH 1C1 Americas Inc.. Concord Rke & New Murphy Rd., Wilmington, DE 19897 JO ANNE LAWLER Hercules Incorporated, Hercules Plaza, Room 7223 SW, Wilmington, DE 19894 M.D, (BUCK) MENSSEN Minnesota Mining and Manufacturing Company, 3M Center, 220-6E-02, St. Paul, MN 55144-1000 ANTHONY J. SAGGESE Texaco Inc.. 2000 Westchester Ave.. Suite 1001. White Plains, NY 10650 'Through May 31,1991 n CMMANEUMFCAACLTURERS ASSOCIATION CHEMIC PURPOSES: Wi Industry Federati Advisory Council iron implemented promote informat Councils, and bet CHAIRMAN ' GEORGE A. VP VICE CHAIRMA HAL BOZARTH GERALD B. ALi Chemical Ii c/o Eastm. South San DAVID C. ANCE Ohio Chem P.O. Box 31 DORSEY W. AYl Chemical C 5548 Manci ROGER BEUTN Michigan G Corporatior MI 49355 DAN BORNE Louisiana C. Baton Roug HAL BOZARTH Chemical ln< Viavfikfe, THACK BROWN Chemical Ini c/o Burrou; Cornwallis R DONALD M. DAY Chemical Co Chesterfield. WILLIAM J. DER( Alabama Chi Corporation, vvv 0OGOO49QC or CWnWEUMFC^AClT. IRERS ASSOCIATION SPECIAL COMMITTEES CHEMICAL INDUSTRY FEDERATION ADVISORY COUNCIL PURPOSES: With respect to implementation of the Chemical Industry Federation, the Chemical Industry Federation Advisory Council will: serve as a rorum for addressing Federa tion implementation progress, ideas, activities and concerns; promote information exchange among Chemical Industry Councils, and between the Chemical Industry Councils and CMA: comment on a range of CMA activities that affect the Chemical Industry Councils' abilities to conduct advocacy or carry out proactive initiatives, and advise the Association on how those activities can be improved and implemented through the Chemical Industry Councils. CHAIRMAN GEORGE A. VINCENT VICE CHAIRMAN HAL BOZARTH STAFF EXECUTIVE D. CHRISTOPHER CATHCART GERALD B. ALLEN Chemical Industry Council of California. c/o Eastman Kodak Company. 270 Lawrence Ave.. South San Francisco, CA 94080 DAVID C. ANCELL Ohio Chemical Council, c/o PPG Industries. Inc., P.O. Box 31. Barberton. OH 44203 DORSEY W. AYERS Chemical Council of Missouri, c/o Rheox. Inc., 5548 Manchester Ave., St. Louis, MO 63110 ROGER BEUTNER Michigan Chemical Council, c/o Amway Corporation. MC 552C. 7575 E. Fulton Rd., Ada. MI 49355 DAN BORNE Louisiana Chemical Association. P.O. Box 1188. Baton Rouge. LA 70821 HAL BOZARTH Chemical Industry Council of New Jersey, Capitol View Bldg., 150 W. State St., Trenton, NJ 08608 THACK BROWN Chemical Industry Council of North Carolina, c/o Burroughs Wellcome Company, 3030 Cornwallis Rd., Research Triangle Park, NC 27709 DONALD M. DAVIS Chemical Council of Missouri, 284 Glen Valley Dr., Chesterfield, MO 63017 WILLIAM J. DEROCHER Alabama Chemical Association, c/o Olin Corporation, RO. Box 28, McIntosh. AL 36553 ROY L. DUGGAN Florida Chemical Industry Council, c/o Air Products and Chemicals. Inc., P.O. Box 467. Pensacola, FL 32592 BARRY L. GIBBS Alliance of Chemical Industries of New York State, Inc., c/o General Electric Company. 1 Noryl Ave., Selkirk. NY 12158 DIANA M. H1NCHCLIFF Alliance of Chemical Industries of New York State, Inc., 152 Washington Ave., Albany, NY 12210 D. LYNN JOHNSON Chemical Industry Committee, Tennessee Association of Business, c/o Tennessee Eastman Company, RO. Box 511, Kingsport, TN 37662 LOUIS H.KISTNER Chemical Industry Council of Maryland, c/o SCM Chemicals, Inc., 7 St. Paul St, Suite 1010, Baltimore, MD 21202 PAUL A. KRONENBERG Chemical Industry Council of California, 1121 L St., Suite 904, Sacramento, CA 95814 PAUL R. LAWLER Chemical Industry Council of North Carolina, RO. Box 751, Raleigh, NC 27602 JOHN W. PAIGE Chemical Industry Council of Associated Industries of Kentucky, c/o Dow Corning Corporation. RO. Box 310, Carrollton, KY 41008 -- continued 29 VVV 000004901 ii CM*ANMUCP4AkC'UReSS ASSOCIATION CHEMICAL INDUSTRY FEDERATION ADVISORY COUNCIL-- continued DAVID PATTI Pennsylvania Chemical Industry Council, 212 N. Third St., Lower Level 2, Harrisburg, PA 17101 A.D. RILEY Louisiana Chemical Association, c o Allied-Signal Inc.. PO. Box 226. Ceismar. L\ 70734 C. DAVID SATTERFIELD Chemical Industries Council oi Illinois. 9801 YV. Higgins Rd.. Suite 480. Rosemont. IL 6u018 JEFFREY H. SOMMERMANN Chemical Industry Council of Delaware, c o Formosa Plastics Corporation. P.O. Box 320. Delaware City. DE 19706 ANDREW J. SUCH Michigan Chemical Council. Capitol House. 320 W. Ottawa St.. Lansing. MI 48933 A. WAYNE TAMARELL1 Chemical Industry Council of New Jersey, c/o Dock Resins, 1512 W. Elizabeth Ave.. Linden. NJ 07036 JAMES M. TRAMMELL Pennsylvania Chemical Industry Council, c/o Sun Con^any, Inc.. Cranberry Court, Suite 101. 212 N. ThirdSt.. Harrisburg. PA 17101 PECCY J. VINCE OhioChemical Council, 17 S. High St.. Suite 810. Colinbus. OH 43215 CEORCEA VINCENT Checal Industries Council of Illinois, c o The CP. Hall Company. 7300 S. Central Ave.. Chicago. IL 60638 jacke. white Chemical Industry Committee. West Virginia Manafecturers Association, c/o American Cyavamid Company. Polymer Products Div.. Wlfew bland. WV 26190 HARRY P. WHITWORTH "VkosChemical Council, 1402 Nueces. Austin, TX 7878-1534 WIUlAMT. WOOD. JR. Choncal Industry Council of Delaware, c/o Wood, Byrd & Associates. One Commerce Center. Suite 1010. Wilmington. DE 19801 LARRYE WRIGHT TesasChemical Council, c/o Dow Chemical USA, Ifcas Operations, APB Bldg., Freeport, TX 77541 CHEMICAL SE RESEARCH PC PURPOSESi With respect t< Business Councils. the CHE> in an advisory capaotv for tb CHAIRMAN EARNEST W. DEAVENPt VICE CHAIRMAN ERNEST H. DREW GERALDINE V. COX Chemical Manufacti KW Washington. D EARNEST W. DEAVENP Eastman Chemscal t Kingsport. TN 376t ERNEST H. DREW Hoechst Celanese C North. Somerville. ( 30 VVV 000004902 CHEMICAL SELF-FUNDED TECHNICAL ADVOCACY AND RESEARCH POLICY COMMITTEE PURPOSES: With respect to the CHEMSTAR paneis and Business Councils, the CHEMSTAR Policy Committee will serve in an advisory capacity for the CMA Executive Committee and Board of Directors to help ensure that all panels and councils are conducted in a manner consistent with Association policies and the CHEMSTAR Guidelines. CHAIRMAN EARNEST W DEAVENPORT. JR. VICE CHAIRMAN ERNEST H. DREW STAFF EXECUTIVE LANGLEY A. SPURLOCK GERALDINE V. COX Chemical Manufacturers Association. 2501 M St.. NW, Washington. DC 20037 EARNEST W. DEAVENPORT. JR. Eastman Chemical Company, PO. Box 511, Kingsport, TN 37662 ERNEST H. DREW Hoechst Celanese Corporation, Route 202-206 North, Somerville, NJ 08876 GARY C. HERRMAN Chemical Manufacturers Association, 2501 M St., NW, Washington, DC 20037 DAVID F.ZOLL Chemical Manufacturers Association, 2501 M St., NW. Washington. DC 20037 31 VVV 000004903 or CHEMICAL MANUFACTURERS ASSOCIATION RESPONSIBLE CARE COORDINATING GROUP PURPOSESt With respect to monitoring and coordinating a Responsible Care workplan for the Association that is designed to ensure effective implementation of the initiative, the Coordinating Croup will: define guidelines and recommend priorities for code development to the Board Public Perception Committee for Executive Committee and Board action: advise standing committees as they develop codes oi management practices and assist them in moving the codes through the review process: dehne the member self-evaluation process: support the executive leadership group program: and coordinate other features incorporated as the initiative is implemented. The Coordinating Group shall report to the Ad Hoc Board Public Perception Committee and through the Communications Department to the President. The Ad Hoc Board Public Perception Committee shall provide policy oversight for the group, as authorized and directed by the Executive Committee and Board of Directors. CHAIRMAN ERNEST F. RUPPE STAFF EXECUTIVE LORI M. RAMONAS DANIEL L. ASH Rohm and Haas Kentucky, P.O. Box 32260. Louisville, KY 40232 ROBERT D. BRADFORD Olin Corporation, P.O. Box 1355, Stamford, CT 06804-1355 KEITH A. FULTON Exxon Chemical Americas, RO. Box 4004, Baytown. TX 77522-4004 CLYDE H. GREENEST Union CarbideCmpmdaw, 39 Oldttdgebury Rd., C2, Danbury, CT 06817-6001 EDWARD D. GRIFFITH ARCO Chemical Company, 3801 W. Chester Pike, Newtown Square, PA 19073 RONALD W. JACOBSON Rohm and Haas Company, Independence Mail West, Philadelphia, PA 19105 PERCY R. KAVASMANECK Union Carbide Corporation, RO. Box 8361, South Charleston. WV 25303 SCOTTY B. PATRICK Ashland Chemical Company, 5200 Blazer Memorial Parkway, Dublin. OH 43017 WILLIAM J. ROBERTS Air Products and Chemicals, Inc., 7201 Hamilton Blvd., Allentown. PA 18195 ERNEST F. RUPPE E. I. du Pont de Nemours & Company, 9000 DuPont Bldg., Wilmington. DE 19898 ARTHUR R. SICEL Velsicol Chemical Company, 5600 N. River Rd.. Rosemont, IL 60018 GARY A. SUNSHINE ICI Americas Inc., Concord Pike & New Murphy Rd., Wilmington, DE 19897 0. EDWARD WALL First Chemical Corporation, P.O. Box 1249, Jackson, MS 39205-1249 JOHN C. WILLET Shell Oil Company, P.O. Box 4320, Houston, TX 77210 BEN WOODHOUSE Dow Chemical U.S.A., 2020 Willard H. Dow Center, Midland, MI 48674 iza CMhANMUFCAACLTURERS ASSOCIATION MEMBERS A Alrco Guei, ADIt Ave.. Murray Hil Air Products sad ( Blvd.. Allentowr Akso Chemical* In Chicago, IL 606i Albright WMeon Richmond, VA 2 Albright & WiUon Rd., (Toronto! Is (416) 239*7111 Alcoa Coastal Chei Suite 3160, Hou: Allied-Signal Inc. 07960 --(20114f American Cyanam: Plaza, Wayne. N American Syntheti Box 32960, Lou -Amoco Chemical C Chicago, IL 606- ANGUS Chemical ( Northbrook, IL ABCO Chemical C Newtown Squar Aritech Chemical Pittsburgh, RA' Arisona Chemical Highway 98, Pa (904) 785-6700 Aahlaad Chemical Oil, lac. - P.O. (614)889-3333 | 32 VVV 0OQ49O4 C-'EMICW. MANUFACTURERS ASSOCIATION MEMBERS A Alrco Cues, A Division of BOC -- 575 Mountain Ave.. Murray Kill. NJ 07974 - (201) 464-8100 Air Products and 'Chemicals, Inc. -- 7201 Hamilton Blvd.. Allentown. PA 18195 -- <215) 481-4911 Akzo Chemicals Inc. -- 300 S. Riverside Plaza. Chicago, 1L 60606 -- (3121 906-7500 Albright & Wilson Americas -- RO. Box 26229. Richmond. VA 23260-6229 - (804) 752-6100 Albright A Wilson Americas (Canada) -- 2 Gibbs Rd.. (Toronto! Islington, ON. Canada M9B 1R1 -- (416) 239-7111 Alcoa Coastal Chemicals-- 1100 Louisiana St.. Suite 3160. Houston. TX 77002 -- (713) 658-9000 Allied-Signal Inc. -- P.O. Box 3000R. Morristown. NJ 07960-1201) 455-2000 American Cyanamld Company -- One Cyanamid Plaza. Wayne, NJ 07470 -(201) 831-2000 American Synthetic Rubber Corporation -- P.O. Box 32960. Louisville, KY 40232 - (502) 448-2761 Amoco Chemical Company -- P.O. Box 87759, Chicago. IL 60680-0759 - (312) 856-3200 ANGUS Chemical Company -- 2211 Sanders Rd., Northbrook, 1L 60062 - (312) 498-6700 ARCO Chemical Company -- 3801 W. Chester Pike, Newtown Square, PA 19073-2387 --{215) 359-2000 Aristech Chemical Corporation -- 600 Grant St, Pittsburgh, PA 15230-0250-1412) 433-2747 Arisona Chemical Company --1001 E. Business Highway 98. Panama City, FL 32401 -- (904) 785-6700 Ashland Chemical Company Division of Ashland Oil, lac. - RO. Box 2219. Columbus, OH 43216 (614) 889-3333 ATOCHEM North America, Inc. -- Three Parkwav, Philadelphia. PA 19102 - (215) 587-7000 Ausimont USA, Inc. -- 44 Whippany Rd.. Morristown. NJ 07962-(201) 292-6250 B J.T. Baker Inc. -- 222 Red School Lane. Phiilipsburg. NJ 08865-(201) 859-2151 BASF Corporation -- Eight Campus Dr.. Parsippany. NJ 07054-(201) 263-5821 Bayer USA Inc. -- 500 Grant St.. One Mellon Center, Pittsburgh, PA 15219-2502 - (412) 394-5500 Bets Laboratories, Inc. -- 4636 Somerton Rd.. Trevose. PA 19047 -(215) 355-3300 Big Three Industries, Inc. -- P.O. Box 3047, Houston. TX 77253 -(713) 868-0333 Borden Packaging and Industrial Products, Division of Borden, lac. --180 E. Broad St., Columbus, OH 43215 -(614) 225-4000 BP Chemicals, Inc. -- 200 Public Square. Cleveland, OH 44114-2375 - (216) 586-4141 Buflhlo Color Corporation--959 Route 46 East, Parsippany, NJ 07054-{201) 316-5600 Burris Chemical, lac. -- P.O. Box 70788, Charleston. SC 29415-(803) 554-7511 33 VVV 000004905 MASASNOUCFIAACTTIOUNRERS MEMBERS--continued C Cabot Corporation -- PO. Box 9073. Waltham. MA 02254-9073 --*irtl7) 890-U200 Callahan Chemical Company -- Broad St. and Filmore, BO. Box 65. Palmyra. NJ 08065 -- 1609) 786-7900 Callery Chemical Company -- PO. Box 429. Pittsburgh. PA 15230-(412) 538-3510 Cambrex Corporation -- One Meadowlands Plaza. East Rutherford. NJ 07073-(201) 804-3000 Cartta Chemical Company, Division of Cartu Corporation -- P.O. Box 1500. LaSalle. !L 61301-(815) 223-1500 Champlln Refining and Chemicals, Inc. -- P.O. Box 160066. Irving. TX 75016-0066 - <214) 402-7000 CHEMCENTRAL Corporation - 7050 W. 71 st St., Chicago, IL 6063*-- (22**4-7000 Chemical Products Corporation -ftQ Box 449, Cartersville. CA 30120 - (404) 3&4M4 Chemtech Industries, lac.* Manufactured Products Division -- P.O. Box 31000, St. Louis, MO 63131-1000 - (314) 966-9968 Chevron Chemical Company -- P.O. Box 5047. San Ramon, CA 94583-0947 - (415) 842-5500 Church A Dwight Co., Inc. - CN5297, 469 N. Harrison St., Princeton, NJ 08540 -- (609) 683-5900 CIBA-GEICY Corporation -- 444 Saw Mill River Rd., Ardstey. NY 10502-(914) 478-3131 Coulton Chemical Corporation -- 6600 Svlvania Ave., Sylvania. OH 43560-3997-1419) 885-4661 CP Chemicals, Inc. -- One Parker Plaza. Fort Lee. NJ 07024-1201)944-6020 CPS Chemical Company lac. -- PO. Box 162. Old Bridge. NJ 08857 - (201) 727-3100 Crompton A Knowles Corporation -- One Station Place. Metro Center. Stamford. CT 06902 -- (203)353-5400 Crosfield Chemicals, Inc. -- 101 Ingalls Ave., Joliet, IL 60435-(815) 727-3651 D Dakota Gasification Company -- 1600 E. interstate Ave.. Bismarck. ND 58501 - (701) 221-4400 Deguasa Corporation -- 65 Challenger Rd., Ridgefield Park, NJ 07660 - (201) 641-6100 Deltech Corporation -- 550 Route 206, Bedminster, NJ 07921-(201) 781-1100 The Dexter Corporation -- One Elm St., Windsor Locks, CT 06096 - (203) 627-9051 Dixie Chemical Company, lac. -- P.O. Box 130410, Houston, TX 77219-0410 -(713) 863-1947 Dover Chemical Corporation -- P.O. Box 40. Dover, OH 44622-1216) 343-7711 The Dow Chemical Company -- 2030 Willard H. Dow Center, Midland. MI 48674 - (517) 636-1000 Dow Corning Corporation -- RO. Box 994. Midland. Ml 48686-0994--(517) 496-4000 E.I. duPnnt dc Nemours A Company -- 1007 Market St., Wilmington, DE 19898 -- (302) 774-1000 E Eastman Chemical C Kingsport. TN 37( EM Industries, Inc. 10532-(914)592- Eogelhard Corporate 33 Wood Ave. Sou (2(H) 321-5000 Ethyl Corporation -- 23217-(804)788- Bnoi Chemical Com South. Darien. CT F Fairmount Chemical Newark. NJ 07105- Ferro Corporation -- OH 44114-1183-(2 Flan Oil and Chemica American Petrofi Dallas. TX 75221 - Fhest Chemical Corpc Jackson, MS 39205 Fisher SciedBBe Con Pittsburgh, PA 1521 FMC Corporation -- 2 60601-(312) 861-e 34 VVV 000004906 E EutPtn Chemical Company -- PO. Box 511. Kingsport. TN 37662-- uSl5i 229-2000 EM Industries, Inc. -- 5 Skvline Dr., Hawthorne. NY 10532-1914(592-4660 ' Engelhard Corporation -- Menlo Park CN40. 33 Wood Ave. South. Edison. NJ 08818-2901 -- (201)321-5000 Ethyl Corporation -- P.O. Box 2189. Richmond. VA 23217-(804) 788-5000 Exxon Chemical Company-- 9 Old Kings Highway South. Darien. CT 06820-4575 --(203) 655-5200 F Falrmotmt CbomkaJ Co., Inc. -- 117 Blanchard St.. Newark. NJ 07105 - (201) 344-5790 Ferro Corporation --1000 Lakeside Ave., Cleveland. OH 44114-1183--<216) 641-8580 Fiaa Oil and Chemical Company Subsidiary of American Petrofina Inc. -- RO. Box 2159, Dallas, TX 75221 -(214) 750-2400 First Chemical Corporation -- PO. Box 1249, Jackson, MS 39205-1249 - (601) 949-0246 FUher Scientific Company--711 Forbes Ave., Pittsburgh. PA 15219-(412) 562-8300 FMC Corporation -- 200 E. Randolph Dr., Chicago, 1L 60601-(312) 861-6000 G GAF Corporation -- 1361 Alps Rd.. Wavne. NJ 07470 - (201) 628-3000 Gantrade Corporation -- 210 Summit Ave., Montvaie. \J 07645-(201) 573-1955 GenCorp Polymer Products, Latex Operations-- RO. Box 3545, Akron, OH 44309-3545 (216) 668-7000 General Chemical Corporation -- 90 E. Halsey Rd.. Parsippany, N3 07054 - (201) 515-0900 Georgia Gulf Corporation -- P.O. Box 105197. Atlanta, CA 30348 - (404) 395-4500 Georgia-Pacific Corporation, Chemical Division - RO. Box 105605, Atlanta. CA 30348 (404) 521-4000 GE Plastics -- 3135 Easton TUrnpike, Fairfield, CT 06431-(203) 373-2211 Gleaudaa Corporation, Chemical Division -- 100 Delawanna Ave., Clifton, NJ 07015-5034(201)365-8235 The BFCoodrich Company--3925 Embassy Parkway, Akron, OH 44313 - (216) 374-2000 W.L. Gore ft Associates, Iacu, Polymer Products Division -- P.O. Box 9559, Newark, DE 19714-9559 - (302) 366-0766 Grace Specialty Chemicals Co. -- Grace Plaza, 1114 Avenue of-the-Americas, New York. NY 10036-(212) 819-5500 Great Lakes Chemical Corporation -- P.O. Box 2200, West Lafayette, IN 47906 - (317) 463-2511 f VVV 000004907 CM* CHEUCAL MANUFACTURERS ASSOCIATION MEMBERS--cMtlaocd H The C.R Hall Company -- 7300 S. Central Ave.. Chicago. IL 60638-6597 --1312) 767-4600 The Hall Chemical Company -- 28966 Lakeland Blvd.. Wickliffe. OH 44092-(216) 944-8500 Halocarbon Product* Corporation -- 82 Burlews Ct.. Hackensack, NJ 07601 -- (201) 343-8703 Haltenaann, Inc. -- 16717 Jacintoport Blvd.. Houston. TX 77015-1713) 452-5951 Hanlin Group, Inc. -- PO. Box CN3106. Edison. NJ 08818-(201) 225-4840 Harborchem -- RO. Box 377. Livingston, NJ 07039 -- (201) 535-6500 Harcro* Chemicals Inc. -- 205 N. Michigan Ave.. Chicago, IL 60601 - (312) 856-0028 Hardman Incorporated -- 600 Cortlandt St.. Belleville. NJ 07109 - (201) 751-3000 Harwich Chemical Corporation -- RO. Box 9360. Akron, OH 44305-0360 - (216) 798-9300 Hatco Chemical Corporation -- King George Post Rd., Fords. NJ 08863 - (201) 738-1000 Henkel Corporation -- 2200 Renaissance Blvd., Culph Mills, PA 19406 --(215) 270-8100 Hercules Incorporated -- Hercules Plaza, 1313 N. Market St., Wilmington, DE 19894 -- (302) 594-5000 Hoechst Celanese Corporation -- Route 202-206 North, Somerville, NJ 08876 - (201) 231-2000 Hoffmaao-LaRoche loc. -- 340 Kingsland St.. Nutlev, NJ 07110-1201) 235-5000 Hnla America Inc. -- HO. Box 456. Piscatawav, NJ 08855-0456 -- <201> 980-6965 Huntsman Chemical Corporation -- 200 Eagle Cate Tower. 60 East South Temple St.. Salt Lake Citv, I'T 84111 -(801) 532-5200 1 ICI Americas Inc. -- Concord Pike & New Murphy Rd.. Wilmington, DE 19897 -(302) 886-3000 ITT Rayonler Inc. -- 1177 Summer St.. Stamford. CT 06904 -(203) 348-7000 J Johnson Matthey -- P.O. Box 733. Valley Forge, PA 19482-0733 - (215) 971-3000 Joaes-Hamilton Co. -- P.O. Box 464. Newark, CA 94560-(415) 797-2471 K Knlnmn Chemical Inc. --1110 Bank of California Center, Seattle, WA 98164- (206) 682-7890 Kao Corporation of America -- 2711 Centerville Rd.. Wilmington, DE 19808-(302) 992-0188 Kerr-McGcc Chemical Corporation -- P.O. Box 25861, Oklahoma City. OK 73125 - (405) 270-1313 Kronos, Inc. -- Rheox, Inc. -- P.O. Box 700, Hightstown. NJ 08520-(609) 443-2000 L Laporte Inc. -- One 28217-(7041 522 LaRoche Chemical*. Rouge. LA 70821 Laurel Industries, It Cleveland. OH 44 EU Lilly and Compai 307 E. McCarty Si (317)276-2000 Liquid Carbonic lad Oak Brook. IL 60.r Lonsa Inc. -- 17-17 Rc (201) 794-2400 The Lnbrisol Corpor Wickliffe, OH 4401 LyontM Ptinihemi Houston, TX 7725. M Malliackrodt, lac. -- 63134 - (314) 895- Marsulex Inc. -- 111 C ON, Canada M2H: McCean-Roheo, Inc. 50 Public Square, (216) 441-4900 Merck A Co., lac. -- 1 07065-<201)574- Mcrtchcm Company Houston. TX 7700". 36 VVV 0C0004908 L Laporte Inc. -- One Woodlawn Green, Charlotte. NC 28217 -- (7041 522-76(53 LaRoche Chemicals, Inc. -- P.O. Box 1031. Baton Rouge. LA 70821 -(504i 356-8463 Laurel Industries, Inc. -- 29525 Chagrin Blvd., Cleveland, CH 44122-(216) 831-5747 Ell Lilly and Company -- Lilly Corporate Center, 307 E. McCarty St.. Indianapolis, IN 46285 -- (317) 276-2000 Liquid Carbonic Industries Inc, -- 800 Jorie Blvd., Oak Brook, 1L 60521 - (708) 572-7000 Loan Inc. -- 17-17 Route 208. Fair Lawn, NJ 07410 -- (201) 794-2400 The Lubrisol Corporation -- 29400 Lakeland Blvd.. Wickliffe, OH 44092 - (216) 943-4200 Lyondell Petrochemical Company -- P.O. Box 3646, Houston, TX 77253-3646-(713) 652-7200 M Malliaekrodt, Inc. - P.O. Box 5840, St. Louis, MO 63134 - (314) 895-2000 Marsules Inc. -- Ill Cordon Baker Rd., North York, ON, Canada M2H 3R1 -(416) 496-9655 McCeaa-Roheo, Inc. -- 1250 Terminal Tower, 50 Public Square, Cleveland, OH 44113-2251 (216) 441-4900 Merck & Co., Inc. -- P.O. Box 2000, Rahway, NJ 07065 -- (201) 574-4000 Merichem Company -- 4800 Texas Commerce Tower. Houston, TX 77002-3068 - (713) 224-3030 Mllliken Chemical. Division of Milliken & Company -- P.O. Box 1927, Spartanburg, SC 29304-1803) 573-2020 Minnesota Mining and Manufacturing Company, Chemical Division -- 3M Center. St. Paul. MN 55144-1000 - < 612) 733-1110 Mobil Chemical Company, A Division of Mobil Corporation -- P.O. Box 10070. Stamford, CT 06904-2070-(203) 328-7000 Monsanto Company -- 800 N. Lindbergh Blvd., St. Louis. MO 63167 - (314) 694-1000 Mooney Chemicals, Inc. -- 2301 Scranton Rd.. Cleveland. OH 44113-9988 - (216) 781-8383 Morton International, Inc. -- 110 N. Wacker Dr., Chicago, IL 60606-1560 - (312) 807-2000 MTM Chemicals - 8720 Red Oak Blvd.. Suite 426, Charlotte, NC 28217 - (704) 529-1575 N Nalco Chemical Company -- One Naico Center, Naperville, IL 60563-1198 - (708) 305-1000 National Starch and Chemical Corporation -- PO. Box 6500, Bridgewater, NJ 08807 -- (201) 685-5000 Neperu, lac. -- Route 17, Harriman, NY 10926 -- (914) 782-1200 Cl* CAMSHASENOMUCFOIAATCLITOiJNflERS MEMBERS -- continued Neste Resins Corporation -- PO. Box 270. Springrield. OR 97477 -- 1503) 687-8840 Neville Chemical Company -- 2800 Neville Rd.. Pittsburgh, PA 15225-1496 --<412) 331-4200 NOVA Corporation of Alberta -- 201 N. Front St.. Sarnia. ON, Canada N7T 7V1 -- (519) 332-1212 Novacor Chemicals Ltd. -- 801 Seventh Ave.. SW, Calgary. AB, Canada T2P 3P7 -(403) 290-8977 O Occidental Petroleum Corporation, Occidental Chemical Corporation -- PO. Box 809050. Dallas. TX 75380 -- <214J 404-3800 Olin Corporation -- P.O. Box 1355, Stamford. CT 06904-1355-1203) 356-2000 OMI International Csepesnilnn/Ethonc Corporation -- 21441 Hoover Rd., Warren, Ml 48089-(313) 497-9100 Owens-Cornlng Flberglnn Corporation -- Fiberglas Tower. Toledo, OH 43659-(419) 248-8000 P Penick Corporation -- 158 Mt. Olivet Ave., Newark, NJ 07114-(201) 621-2800 Peridot Chemicals (New Jersey), Inc. -- 1333 Broad St., Clifton, NJ 07015 - (201) 614-9300 Perstorp Polyols, Inc. -- 600 Matzinger Rd.. Toledo, OH 43612-1419)729-5448 Petrollte Corporation -- 100 N. Broadwav, St. Louis. MO 63102-1314)241-8370 Pfizer Inc. -- 235 E. 42nd St.. New York. NY 10017-5755-1212) 573-2323 Phillips 66 Company, A Subsidiary of Phillips Petroleum Company -- Bartlesville, OK 74004 -- 1918) 661-6600 PPG Industries, Inc., Chemicals Group -- One PPG Place. Pittsburgh. PA 15272-(412) 434-3131 The PQ Corporation -- PO. Box 840, Valley Forge, PA 19482-0840 - (215) 293-7200 The Procter A Gamble Company -- P.O. Box 599, Cincinnati, OH 45217-(513) 983-1100 PVS Chemicals, Inc. -- 11001 Harper Ave., Detroit, Ml 48213 - 013) 921-1200 Q Quantum Chemicnl Corporation -- 99 Park Ave., New York, NY 10016 -(212) 949-5000 R Reichhold Chemicals, Inc. - P.O. Box 13582, Research Triangle Park, NC 27709 -- (919) 544-9225 Reilly Industries, Inc. -- 151 N. Delaware St., Indianapolis, IN 46204 - (317) 638-7531 Rhone-Poulenc Inc. -- CN5266. Princeton, NJ 08543-5266 - (201) 297-0100 Rohm and Haas Coi Philadelphia. PA Rohm Tech Inc. -- 1: 1617)321-6984 Ruetgeri-Nease Ch 201 Struble Rd.. (814)238-2424 S Sandoz Corporatlc NC 28205 - (70- SCM Chemicals, In 21202 --(301) 78 Scott Polymers, In TX 76111-(817 Shell Canada Chen Shell Canada 1 Dr., Don Mills, ( (416) 443-7111 Shell Chemical Co TX 77252 --(712 Thtfcphcrd Che St., Cincinnati, Sherry Wmmkrfg DuWm, OH 430 Sloae IsdulrimC Birmingham, A) Solkatroaic Chens Fairfield, NJ CTT Solvay America, Ii 77227 -- (713) 5. 38 yW 000004910 Rohm and Baa* Company -- Independence Mall West. Philadelphia, PA 19105 -(215) 592-3000 Rohm Tech loc. - 195 Canal St.. Malden. MA 02148 (617)321-6984 Rnetgers-Nease Chemical Company, Inc. -- 201 Struble Rd., State College. PA 16801 -- (814) 238-2424 S Sandos Corporation -- 4000 Monroe Rd., Charlotte NC28205-{704) 331-7087 1 SCM Chemical*, Inc. -- 7 St. Paul St.. Baltimore. MD 21202 -- < 301) 783-1120 Scott Polymer*, Inc. -- 3607 N. Sylvania, Fort Worth. TX 76111-(817) 831-3531 Shell Canada Chemical Company; Division of Shell Canada Product* Limited -- 75 Wyntord Dr., Don Mills, ON. Canada M3C 2Z4 -- (416)443-7111 Shell Chemical Company -- PO. Box 2463. Houston. TX 77252-1713)241-6161 The Shepherd Chemical Company -- 4900 Beech St., Cincinnati, OH 45212 - (513) 731-1110 Shores Chemical Company; Inc. -- RO. Box 646, Dublin. OH 43017 -(614) 764-6500 Sloaa Industrie* Corporation -- P.O. Box 5327, || Birmingham, AL 35207-(205) 254-7805 Solkntronic Chemicals Inc. -- 30 Two Bridges Rd.. Fairfield, NJ 07006 -- (201) 882-7900 ^ Sohray America, Inc. -- PO. Box 27328, Houston, TX 77227-(713) 526-2000 Spectrnm Chemical Manufacturing Corporation -- 14422 S. San Pedro St.. Gardena. CA90248-(213) 516-8000 Standard Chloriae Chemical Co., Inc. -- 1035 Belleville Turnpike. Kearnv. NJ 07032(201) 997-1700 Stepan Company -- 22 W. Frontage Rd., Northfield, 1L 60093 -(708) 446-7500 Sterling Chemicals, Inc. -- 333 Clay St.. Suite 3700. Houston. TX 77002 - (713) 650-3700 Son Refining and Marketing Company Chemicals Dlrtsioa -- Ten Penn Center, 1801 Market St., Philadelphia, PA 19103-1699 --(215) 977-3000 Syntex Chemicals, Inc. -- 2075 N. 55th St., Boulder, CO 80301-(303) 442-1926 T Ifcxaco Chemical Company Subsidiary of Ifcxaco Inc. - RO. Box 27707, Houston, TX 77227-7707 (713)961-3711 Texas Brine Corporation -- 2000 West Loop South, Suite 990, Houston, TX 77027 - (713) 877-2700 Thus Petrochemical* Corporation -- 8707 Katy Freeway, Suite 300, Houston, TX 77024 -- (713)461-2223 Tloxlde Canada Inc, -- P.O. Box 580, Sorel, PQ, Canada J3P 5P8 -(514) 742-2711 39 CN CNEMCAL MANUFACTURERS association MEMBERS--cmi>m4 CM C.^HgUfUWCCMT.USERS ASSOCIATION genera OPERAT U Ualoo Camp Corporation, Chemical Products Division - 1600 Valiev Rd., Wayne. NJ 07470(2011628-2000 Union Carbide Corporation -- 39 Old Ridgeburv Rd.. Danbury. CT 06817-0001 -(203) 794-2000 Unlroyai Chemical Company, Inc. -- World Headquarters. Middleburv, CT 06749 -- (203)573-2000 United States Boras & Chemical Corporation -- P.O. Box 75128, Sanford Station, Los Angeles, CA 90075-(213) 251-5400 Univar Corporation --1600 Norton Bldg,, Seattle. WA 98104-(206) 447-5911 Unocal Chemicals Division, Uoocal Corporation -- 1345 N. Meacham Rd.. Schaumburg, 1L 60196-(708) 619-2500 UOP - Box 5017. Des Plaines. IL 60017-5017 (312)391-2000 V Preamble. Th tion 8. authori: R.T. Vanderbilt Company, Inc. -- P.O. Box 5150, Norwalk. CT 06855 - (203) 853-1400 Committee to a and functions; The Bylaws fm Velsleol Chemical Corporation--5600 N. River the conduct ol Rd.. Rosemont. SL 60018-(312)698-9700 ciation policy z Board or Exect VUIcase Corporation -- 6855 W. 65th St.. Chicago. IL To assist the 60638-1312) 496-4200 'ions consisten Vista Chemical Company -- 900 Threadneedle. Houston. TX 77079 - (713) 588-3000 pies applicable mittees are lorr ur other group Vulcan Chemicals, A Division of Vulcan Materials Company -- P.O. Box 7689, Birmingham, Ad_ 35253-(205) 877-3000 business shall i except where si Committee ort sary by the Pre As used in tf cated. the term W committees ana thorized from t Executive Com: of members of i Wacker Chemical Corporation -- 9100 Shelbyville Rd.. Louisville, KY 40222 - (502) 429-0711 L Functional Nation's commi Westvaco Corporation, Chemical Division -- RO. Box 70848. Charleston Heights. SC 29425-0848 -- (803) 740-2300 marily along fu committee havi: uct or product si of the Board Weyerhaeuser Paper Company, Chemicals the Association Division - Tacoma, WA 98477 - (206) 924-2345 of any such con determine whet Witen Corporation -- 520 Madison Ave., New York, to handle the pi NY 10022-4236 -(212) 605-3800 Is of such gener or special comtr Ocular product wnuinttees for; ad hoc. Unless < Z committee shall renewal for peri Zeon Chemicals USA, Inc. -- 4100 Bells Lane, f the BqmL Louisville. KY 40232-1502) 772-5820 2* Pnrpoaem. I ance with PURI hies which havt roittee. Each co: i toe Association 3* Organicatii 40 00000VJ1Z vvv CM CHEMCM. WAMJRCTUflERS ASSOCIATION GENERAL PRINCIPLES APPLICABLE TO THE STRUCTURE AND OPERATION OF COMMITTEES* t Preamble. The Association's Bylaws, in Article V, Sec tion 8, authorize the Board of Directors or the Executive Committee to appoint such committees with such duties and functions as may from time to time be determined. The Bylaws further permit adoption of regulations foT the conduct of committee affairs consistent with Asso ciation policy and subject to review and approvai by the Board or Executive Committee as appropriate. To assist the committees in carrying out their func tions consistent with the Bylaws, certain general princi ples applicable to the structure and operation of all com mittees are formalized in this Resolution. No committee or other group operating under CMA auspices on CMA business shall deviate from heae general principles, except where specifically authorized by the Executive Committee or the Board (or as determined to be neces sary by the President or Secretary of the Association). As used in this Resolution, unless otherwise indi cated, the term "committee" includes all CMA standing committees and such special committees as may be au thorized from time to time, but does not include the Executive Committee or other committees composed of members of the Board. L Functional ra. Product Committee*. The Asso ciation's committees shall continue to be organized pri marily along functional rather than product lines. No committee having to do with a particular chemical prod uct or product segment shall be formed without approv al of the Board (or in an emergency by the President of the Association). Before agreeing to the establishment of any such committee^ihe Executive Committee shall determine whether theexisting committees are adequate to handle the problem, and if not, whether the problem is of such general concern as to call for a new standing or special committee. All committees dealing with a par ticular product segment of the industry and all other committees for a temporary purpose shall be deemed ad hoc. Unless otherwise specified, the term of such committee shall be no longer than two years, subject to renewal for periods of one year or less by specific action of the Board. 2. Purposes. Each committee shall operate in accord ance with PURPOSES setting forth its authorized activ ities which have been approved by the Executive Com mittee. Each committee's PURPOSES shall be printed in the Association's annual Directory. 3. OrgSBlsatloa. All committees shall, unless other wise authorized, be subject to the following rules in respect to their organization: (a) Members. Each committee normally shall be limited to not more than 15 members. The mem bers shall be recommended by the President of the Association and appointed by the Executive Com mittee from qualified full time personnel of member companies interested in supporting such activities. To the maximum extent practicable, appointments should be reasonably representative of all inter ested member companies, taking into account such factors as their size, geographical location, chemi cals manufactured, and differences in the general nature of their operations. Normally, a member company may have only one representative on a given committee. Members of any necessary task groups shall be appointed by the committee on the same basis. The membership of each committee should be comprised of persons well qualified in the committees field of activity, normally having primary responsibilities within that field in their respective companies. Nomination for committee membership will be made by member company Ex ecutive Contacts and shall include name, company affiliation and personal title, background relevant to committee's field of activity, and description of responsibilities within the company. A committee may nominate for consideration by the President or Executive Committee one or more associate mem bers representing governmental bodies or scientific trade associations where such representation on a continuing basis will facilitate significantly the com mittee's programs. Associate members shall have non-voting status and be subject to review and Executive Committee confirmation annually. <b) Dull Groups. A committee may form such task groups as may be necessary to assist it in con ducting its authorized activities. The Executive Committee shall be promptly advised of the forma tion of each such task group, and terms of refer ence in each case shall be established in writing by the parent committee subject to the review and approval by CMA staff and the President of the Association. "As approved by the Board ofDirectors on Marc/? 12,1963, and amended by the Executive Committee on March 19,1971; July 11.1978, and June 3,1981. i 1 I 41 WV 000004913 ic) Officer*. The chairman of each committee to serve as its chief executive officer, and a vice chairman, shall be appointed annually by the Exec utive Committee. The heads of task groups shall be appointed by the respective chairmen with commit tee approval.' idl Rotation. The term of individual commit tee members shall be three years, one third of the membership being rotated annually. Initial commit tee membership terms will be scaled to accommo date this rotation. Upon the expiration of one term of committee membership, a waiting period of at least one year must lapse before a former member becomes eligible for reappointment. For this pur pose. a term will be regarded as three years or any fraction thereof according to the member's latest appointment to that committee. A committee mem ber appointed chairman in the third year of his committee tenure may be appointed to a second year as chairman in which case he would serve in this post outside of the member limit on committee membership. A chairman cannot be extended in this manner for more than one additional year. (e) Staff*Executive and Committee Secre tary. Each committee shall have as its staff execu tive and secretary a full time CMA staff employee who shall function as the Board's administrative representative for such committee and as its chief administrative officer. It shall be the staff execu tive's duty and responsibility to see that all opera tions and proceedings of the committee, and of all its task groups, are conducted in full conformity with their purposes and this Resolution, consulting with General Counsel as necessary. On all proce dural questions arising within any committee, in cluding matters related to established Association policy, the staff executive's decision shall be accepted, pending appropriate review. 4. Meetings. The business of each committee shall be conducted in executive sessions attended by its members and by others who have a leading role in matters to be considered at the particular meeting. Each task group meeting shall be an executive session of assigned mem bers of the task group plus any members of the parent committee who wish to be present. (a) Frequency. Each committee and task group will meet only as necessary to perform au thorized committee business as determined by the chairman in consultation with the CMA staff. Meet ings should not be held where subject matter can be adequately and practicably handled by corre spondence or telephone between the appropriate staff executive and individual members. b> UcatitB. To the extent practicable and in the absence of cogent reasons for being elsewhere, all committee and task group meetings should be held in Washington. D.C.. preferably at the Associa tion's office. Other locations, such as major city air ports. may be considered in instances when they would afford greater convenience and cost savings to attendees. (cl Agenda. Following consultation with the committee chairman, the staff executive assigned to each committee shall prepare written agenda prior to each of its meetings, which agenda shall be cleared in advance with General Counsel. Id) Attciduce of StaffExecntlve. No CMA committee meeting shall be held without the attendance of the staff executive assigned to it or other full time CMA staff employee. General Coun sel or his designate should also attend any meeting whenever in his option the nature of any subject on the agenda makes his presence desirable. lelMimtM. The staff executive assigned as secretary to the committee shall keep accurate and complete minutes of alt business transacted at each meeting, which are to be subject to review and ap proval by General Counsel. <f) Diacossiee* Limited to Agenda. All substantive discussions at any CMA committee meeting are to be limited to authorized aspects of subjects on the agenda, except where additions to the agenda are specifically approved by the staff ex ecutive assigned to the committee. 'Hre.staff execu tive's decision as to the propriety of any subject matter raised for discussion at any meeting shall be accepted, pending appropriate review. Any discus sions or occurrences on the occasion of any meet ing which are contrary to CMA's policies or rules and which have come to the staff executive's atten tion shall be reported promptly by him to his super visor and to General Counsel. (g) Iksk CroBf. The foregoing rules on greetings are applicable to all committees, task groups, and any other working groups, and any other working groups meeting under CMA aus pices, except that subparagraphs (c). (d), and (e) may be modified as indicated below in those cases where the group must meet in order to carry out a Snorted and specific written assignment from the parent committee and it is impractical for a staff executive to be present. In each such case, (i) the specific assignment must be set forth in the parent committee's mini assigned as seen be satisfied that sary and that tht require staff pres group is to be re ties of the CMA r ulariy those spei and (ivl the chaii rate andcomplet mittee and to tht thing occurring (h) Camera sessions, each o at least two per \ five Contacts wh m the membersh and other intere; companies may. 42 vw 000004914 committee's minutes: tii) the CMA staff executive assigned as secretary to the parent committee must be satisfied that the meeting in question is necessary and that the subject matter is not such as to require staff presence, tiii) the chairman of the group is to be responsible for carrying out the duties of the CMA staff executive, including partic- ularly those specified in subparagraph if) above; and tiv) the chairman must promptly make an accurate and complete written report to the parent committee and to the CMA start executive as to everything occurring at such meeting. fh) General Meeting*. Apart from executive sessions, each committee shall schedule meetings. at least two per year, to which designees of Executive Contacts whose companies are not represented in the membership of the committee shall be invited and other interested representatives of member companies may attend. Such meetings shall be scheduled and notices issued amply in advance as often as appropriate to keep the designees and others informed about the committee's activities and provide opportunities for offering suggestkms. 5. Policy SUtemeat*. Statements of Association policy or position developed by any CMA committee or other group for submission to the Congress or any governmental or other external agency shall, unless otherwise authorized, be transmitted by the President or other appropriate officer of the Association, 6* Report*. An account of the significant program activities of each committee shall appear in the Annual Report of the Association. The President and Executive Committee shall be kept informed on a current basis by communication from the chairman and the assigned staff executive. Presentation of reports to the Board shall be made as determined by the Executive Committee. 7. Periodic Reminder to Committee Members. A copy of this Resolution, as it may be amended from time to time, shall be furnished to each member of each CMA committee and task group thereof at the beginning of his duties as a member, and at least once a year there after so long as he remains a member. t : i i i ****# VVV 000004915 CH CHEMCAi MANOfACTUR6RS ASSOCIATION RULES OF PROCEDURE FOR COMMITTEES* 1. Purposes. The purpose of each committee shall be as set forth in the CMA Directory. 2. Membership. Nominees, in addition to compe tence in the subject area, should have the perspec tive to recognize which matters are truly significant to the chemical industry, and have the talents and personal inclination to be dynamic workers. The nominee's position in the company should provide ready access to the Executive Contact so as to au thoritatively reflect corporate views and also assure company backing in devoting a considerable por tion of time and associated company resources to committee activities. 3. Officers 3.1 The officers of a committee will be a chair man and a vice chairman. 3.2 The officers will serve for a term of one year commencing June 1. 3.3 Chairman 3.3.1 The chairman will preside at meetings and exercise general supervision over affairs of the committee within the general framework of CMA policies. 3.3.2 The chairman will be responsible for full re porting at regular meetings of all committee activities not previously reported. 3.3.3 The chairman will familiarise the vice chair man with all the functions of the chairman in order to provide for proper and effective continuity in the chairman's absence. 3.3.4 With the concurrence of the committee, the chairman may establish task groups, define their purpose and scope, appoint their mem bership, and designate the chairman. 3.3.5 The chairman will designate from the mem bership of the committee liaison assignments to various CMA standing committees and task groups as necessary. 3.4 Viee Chairman In the absence of the chairman, the vice chairman shall fulfill all the functions of the chairman. `As approved by the Executive Committee on July 11,1978 and amended by the Executive CommitteeJune 3,1981. 4. Secretary/StafFEiecutive 4.1 The secretary shall be the CMA staff execu tive assigned to the committee. 4.2 The staff executive shall exercise those au thorities and responsibilities prescribed by the "General Principles Applicable to the Structure and Operations of Committees." 4.3 The staff executive shall prepare and distrib ute notices of meetings, agenda, and min utes. and have custody of the official records of the committee. 5. Meetings 5.1 Meetings of the committee will be held at the call of the chairman. 5.2 A majority of the committee members shall constitute a quorum at any meeting. 5.3 Tksk groups shall arrange separate meetings as justified by their assignment, subject to call by their respective chairmen and ad vance notice to the members from the staff executive. 5.4 The staff executive shall issue advance no tices for all meetings of the committee and task groups, and no meeting may be held in the absence thereof. 5.5 It shall be the responsibility of the chairman of a task group to submit a timely request to the staff executive concerning any desired modifications of subparagraphs 4<c), (d), or (e) of the "General Principles Applicable to the Structure and Operations of Commit tees" under the provisions of subparagraph 4(g). 5.6 Actions shall be decided by a majority of members present. The presiding officer may vote to break a tie. The staff executive is not entitled to vote. 6. Ikik Group* 6.1 Designations of task groups for special as signments. as to their membership, purpose, and scope shall be recorded in committee minutes. All task groups shall be reviewed annually by the committee. Unless recom mended for continuance by the committee and authorized by the President of the Association they terminate. 6.2 Committee membership is not a prerequisite to serving on task groups. 6.3 The chai officio rr be furni: together furmshe sponden activitie: 6.4 Task gre keeping progres* 6.5 Task gre reports 1 chairma each reg concern recomm 6.6 The tern is define sub-unit 7. Admlniftratii 7.1 The con any soui scope of 7.2 An agen meeting those in whenevi liC" 44 vvv 000004916 i 1 6.3 The chairman and vice chairman shall be ex officio members of all task groups and shall be furnished notices of their meetings. They, together with the staff executive, shall be furnished copies of all reports and corre spondence pertaining to task group activities. 6.4 Tbsk group chairmen shall be responsible for keeping their members informed regarding progress of activities and assigned tasks. 6.5 T^sk group chairmen shail furnish written reports to the committee chairman, vice chairman and staff executive in advance of each regular meeting of the committee concerning activities, plans and recommendations. 6.6 The term "task group" as used in these rules is defined to include any other committee sub-units. Z Administration 7.1 The committee may consider matters from any source provided they fall within the scope of the declared PURPOSES. 7.2 An agenda of matters to be considered at meetings shall be prepared and furnished to those involved, at least one week in advance whenever practicable. 7.3 Minutes of meetings shall be prepared and distributed promptly. Corrections or addi tions shall be considered at the next meet ing. In addition to normal distribution, such minutes shall be furnished to other member company representatives designated by their Executive Contact to receive them. 7.4 Voting may be conducted by letter ballot when, in the judgement of the staff execu tive. circumstances warrant. 7.5 Appearance before any legislative or regula tory body or other organization on CMA's behalf shall be made only as officially autho rized. If, in any such appearance other than as a duly authorized representative, a person identifies himself with CMA in any way, he shall also make clear that he is not repre senting CMA in such participation. 8. Legal Assistance. Requests for legal assistance shall be directed by the committee chairman or staff executive to the CMA Ceneral Counsel. Assistance of the Ceneral Counsel, staff counsel, or member company will normally be provided. Outside coun sel. if required, will be selected and supervised by the Ceneral Counsel and will be engaged only after approval by the President or Executive Committee. & Primary Requiremeat. These rules are designed to supplement CMA's "Ceneral Principles Applica ble to the Structure and Operations of Commit tees," originally approved March 12,1963, as subse quently amended. Nothing in these rules shall be interpreted or applied in such manner as to conflict with that document. i i . VVV 000004917 45 CHEMICAL MANUFACTURERS ASSOCIATION ANTITRUST GUIDE FOR CMA COMMITTEE MEMBERS This is designed to be a layman's guide on how the anti trust laws apply to trade association activities, with par ticular reference to CMA committee work. It is written for both the guidance of those committee members who have no particular knowledge of this complicated sub ject. and to provide a useful reminder or "refresher course" for those who have had the benefit ot antitrust advice from their own company counsel. The Chemical Manufacturers Association is a non profit industry association representing about 180 chemical producers. Like other industry associations. CMA is composed of member companies (many of whom are competitors of one another) representatives of which serve on its Board of Directors and on its committees. Whenever competitors meet together problems can arise under the antitrust laws. If the meeting or other activities among competitors is conducted by or through a trade association, it is just as vulnerable to antitrust attack as if the same companies were meeting or acting together without the medium ot an association. Trade associations generally seek, quite properly, to promote understanding and cooperation among their members. But if this "cooperation" restrains competition, both the association and its members will be in trouble under the antitrust laws. Antitrust enfoncement is being emphasized as never before. Thejuiaher of criminal and civil antitrust actions is steadily increasing. Congress has greatly in creased both criminal and civil antitrust penalties, has made important procedural changes, and has substan tially increased the budgets for thrAntitrust Division of the Department of Justice and the Federal Trade Com mission, the two agencies charged with antitrust en forcement, The courts are expanding the scope of anti trust prohibitions which may especially affect trade association activities, and such associations are more frequently becoming the objects of FTC and Antitrust Division investigations. In view of these developments, increased awareness of the applications of the antitrust laws to association activities is essential. Like most reputable trade associations, CMA has objectives and programs that are well within the law. It also makes every effort to prevent possible antitrust abuses from arising. But a large responsibility also rests upon its member companies -- and particularly upon their individual representatives who serve on CMA com mittees. This means that committee members should know enough about this subject to be able, in their CMA work, to avoid actions or discussions that might raise antitrust questions. The main purpose of this guide is to help all committee members to recognize what is. or might become, an "antitrust question." Some actions or discussions bv members of a trade associations are clearly illegal; many others are wholly legal and proper; and there is a sizeable "grey area" or danger zone in between. This grey area between legal and illegal association activity is often vague and uncer tain. and CMA's policy has always been to keep far away from the doubtful zones. The Association's aim is not only to avoid actual vi olations of the law -- it wants to prevent even any ap pearance of violation which might invite suspicion or in vestigation on the part of the enforcement authorities. To protect itself and its members in this respect, CMA has adopted and observes several basic policies: 1. It has well-defined, constructive objectives and programs which are designed to promote the overall in terest of the industry and the public. 2. Its organizational structure consists primarily of standing committees with specific and limited functional purposes: and activities concerned with pricing or mar keting chemical products are scrupulously avoided, and limitations are also imposed of the subject matter and duration of "ad hoc" committees dealing with specific chemical products or product segments. 3. It maintains various procedural safeguards par ticularly those set forth in the "General Principles Ap plicable to the Structure and Operation of Committees" which appears in the Association's annual Directory. 4. It retains counsel to help insure full observance of the above policies and procedures, and to provide guidance and protective advice as to all CMA operations from an antitrust standpoint. THE FEDERAL Beginning in 1890. Cor statutes which are kno' trust laws. These laws ; serve our competitive j couraging free and ope The federal antitrust la philosophy underlying that a free market in w; to determine the condi: distribution and sale, a deals independently, se ble allocation of high q lowest possible prices. The central core o formed by the Shermai Federal Trade Commiss also enacted antitrust I but no attempt is made manual. Similarly, ther areas of federal antitru: man Act and many par bear directly on the act but are usually not inv' The primary focus hen involving relationships than vertical relations!pany and its customers Section 1 of the S "combinations" or "coi commerce. These are ti duct by two or more pe ments and understand! or oral, formal or iD&m petition,.fiecause of fr anacaliansUctraties. 'weapon used bythe Dt suits against trade assr suits are usually based agreement among com Federal Trade Commisi trade association activ Petition under Section sion Act which prohibi competition.") Although the Ian deliberately general in 46 000004913 THE FEDERAL ANTITRUST LAWS Beginning in 1890. Congress has enacted a series of statutes which are known collectively as the federal anti trust laws. These laws are designed to promote and pre serve our competitive private enterprise system by en couraging free and open competition in open markets. The federal antitrust laws give the force of law to the philosophy underlying our economic system, namely, that a free market in which supply and demand operate to determine the conditions and terms of production, distribution and sale, and where each seller and a buyer deals independently, serves to achieve the most equita ble allocation of high quality goods and services at the lowest possible prices. The central core of federal antitrust legislation is formed by the Sherman Act (18901 and the Clayton and Federal TVade Commission Acts (1914). Most states have also enacted antitrust laws similar to the federal statutes but no attempt is made to discuss them in this brief manual. Similarly, there is no discussion herein of other areas of federal antitrust law (such as the Robinson-Patman Act and many parts of the Clayton Act) which may bear directly on the activities of individual companies but are usually not involved in association activities. The primary focus here is on horizontal conduct "i.e." involving relationships between competitors, rather than vertical relationships such as those between a com pany and its customers. Section 1 of the Sherman Act prohibits "contracts," "combinations" or "conspiracies" in restraint of trade or commerce. These are terms of collective action or con duct by two or more persons, and they include agree ments and understandings of all kinds, whether written or oral, formal or informal, which unduly restrain com petition. Because of the collective nature of most trade associations' activities, this section is the principal "*apon used by the Department of Justice in antitrust suits against trade associations or their members. Such suits are usually based upon an alleged conspiracy or agreement among competitors to restrain trade. (The rederal Trade Commission also can, and does, challenge tode association activity which is alleged to lessen com petition under Section 5 of the Federal Trade Commis sion Act which prohibits "unfair methods of competition") . Although the language of the antitrust statutes is deliberately general in its coverage, prohibiting "(every) contract, combination or conspiracy in restraint of trade" and "unfair methods of competition," the courts have defined a number of specific activities as inherently unlawful, the so-called "per se" offenses (see "Prohib ited Activities," infr.). The legality of other activities is determined by the "rule of reason." i.e., whether the ac tivity is ancillary to the achievement of a legitimate business objective and is no more restrictive of competi tion than necessary to achieve that objective. Although this necessarily involves difficult questions of interpreta tion, even here useful guidelines for antitrust compli ance have evolved from the courts' decisions. The im portance of obtaining legal counsel in any area of uncertainty cannot be overemphasized, for the sanctions imposed for violations of the antitrust laws are severe. ANTITRUST ENFORCEMENT The federal antitrust laws are enforced by the Depart ment of Justice (Antitrust Division) and the Federal TVade Commission and frequently provide the basis for suits by private parties. All of the following penalties can be imposed for vi olations of antitrust laws. 1. IMPRISONMENT. Violations which arecrimi nal offenses, including most prohibited collusive activ ities, are felonies. The Federal Sentencing Guidelines, which became effective in November, 1987, establish a minimum jail term of 4 to 10 months for first offenders. In addition, the minimum recommended sentence under the Guidelines is increased as the volume of commerce in question increases. For example, if the offense in volved a volume of commerce greater than $50,000,000, the minimum sentence would be increased to 10 to 16 months. Prison sentences are increasingly common, and convicted felons may be denied citizenship, voting and other privileges. 2. FINES. Minimum fines of $20,000 for individ uals, and $100,000 for corporations, are required under the Sentencing Guidelines. However, the permissible range of fines for an individual is 4 to 10 percent of the volume of commerce: the range for an organization is from 20 to 50 percent of the volume of commerce af fected. Assuming a corporation is found to have violated the antitrust laws, affecting $50,000,000 of commerce, the permissible fine would range from $10,000,000 to $25,000,000! An individual may not be reimbursed by his corporation for fines paid by him and fines are not deductible for income tax purposes. 47 3. INJUNCTIVE COURT AND FEDERAL TRADE COMMISSION ORDERS. Orders (injunc tions! which prohibit future violations or activities can be imposed as a result of civil action brought by the De partment of Justice, the Federal Trade Commission, or private parties, with far-reaching consequences. Such injunctions may contain sweeping prohibitions which go well beyond the scope of the violations charged and pro hibit conduct which is not itself considered contrary to the antitrust laws. Such orders can seriously limit free dom of corporate or association action, require burden some and time consuming reporting obligations, cause day-to-day activities to be supervised by a court or agency, and even require dissolution of a trade associa tion. Violation of an injunctive order issued by a court can result in contempt proceedings with attendant fines, while failure to comply with an injunction ("cease and desist order") issued by the Federal Trade Commission carries penalties of up to $10,000 for each day the noncompliance continues. 4. TREBLE DAMAGES. A sanction which has been applied with increasing frequency as private anti trust suits have rapidly increased in recent years is the "treble damage" provision of the antitrust laws which al lows persons or businesses injured by an antitrust viola tion to recover three times the amount of actual dam ages sustained, ^urti r--ri hi r resulted in hundreds of millions of dollarspaid to private liti gants. Thus, an antitnat'violation could impair the fi nancial resources of any corporation and significantly weaken its competitive position. PROHIBITED ACTIVITIES As noted above, many antitrust violations -- and partic ularly those involving trade associations -- result from concerted or collusive activity, that is. from an "agree ment" between or among competitors which result in a restraint of trade. An illegal agreement may be proved in a number of ways. It need not be written, and seldom is. Rather, the term "agreement" in antitrust parlance may mean no more than knowing adherence to or a partici pation in a common scheme. Explicit promises, commit ments. or assurances are not necessary to establish a vi olation. nor must the parties actually carry out the agreement. (This definition of "agreement" is assumed throughout). Convictions for collusive activities can be based on a series of seemingly isolated facts which have been linked to present a chain of circumstantial evidence from which an agreement or conspiracy -- a meeting of the minds --can be inferred; for example, identical price in creases by competitors following shortly after a trade as sociation meeting at which "business conditions" and the need of the industry for higher prices were dis cussed. For this reason it is important when participat ing in CMA committee work or other association activ ities. which involve contact with other members ofthe industry, to avoid doing or saying anything which night even give an appearance of agreement with others in areas which may involve a lessening of competition. (a) AgreeaeaU Involving Prices. Pricing is the most sensitive subject under the antitrust laws, "Price" in this context includes all the elements of the terms of sale: sales prices, discounts, allowances, freight, credit terms, container deposits, and all other services or con ditions integrally related to a sale. Any agreement be tween competitors which fixes, stabilizes, maintains, bol sters, depresses, or tampers in any way with price is unlawful "per se." that is, the activity is indefensible and illegal without further analysis of its reasonableness, good intentions, arguable benefits to the public, or ex tenuating circumstances. In short there is no defense. "Price-fixing" encompasses not only agreements with competitors on a selling price, it may also include, for example, agreement to buy up surplus goods, to ad here to a formula (or determining prices, to standardize discounts, to control raw material prices, and any other agreement which has the net result of affecting the price structure of a given product. Moreover, it is just as un lawful for competitors to agree on the prices at which they will offer to buy from their suppliers, as on those at which they sell. As previously noted, an agreement can be shown in a number of ways. Thus, even the mere ex change of price lists between competitors serves as evi dence of an illegal price-fixing agreement. The essential rule is that each seller must deter mine on its own the prices at which it purchases and sells. To avoid inferences of agreement or collusion -- and there can be no exceptions -- CMA members must not engage m any d: competitors regardh other marketing po following are a few. been found by cour price-fixing. 1. Some super violated the Sherm; included a trade ass pant made remarks to stop passing lowt consumers and keei viewing this and otf pricing practices, tl the attendees at the gaged in an illegal i low and retail price* verdict for over 32 i torneys' fees. I 2. In another c company in a marki other major compa: which he described tors and changing t openly agreed to re his discount schedt however, the leadin proposed at the me by one, adopted the discount schedules managers were con conspiracy. The fac were at the meeting quently reclassified discount schedules had inti---fully con 3. Sales officio ufacturers in the Si sionally calling eac specific and curren Supanie Court hel fhe effect of stabiiu Price reductions ar decision wasreachi the calls did not re; Rather, each defeni 48 VVV 000004920 can be based on h have been iai evidence from neeting of the entica) price iny after a trade asmditions" and es were dishen participatsociation activnembers ot the ling which might cith others in competition. ea. Pricing is the ust laws. "Price" s of the ter-ns of s, freight, credit 'vices or con venient be es, maintains, bol- with price is s indefensible and easonabteness, he public, or ex'e is no defense. n!y agreements may also include, plus goods, to ad* es, to standardize es. and any other ` affecting the price :r, it is just as un prices at which jers. as on those at an agreement can even the mere extors serves as evi dent. `Her must deter: purchases and it or collusion -- |A members must not engage in any direct or indirect discussions with any competitors regarding prices, pricing policies, or any other marketing policy which may affect pricing. The following are a few examples of activities which have been found bv courts to constitute evidence of illegal price-fixing. 1. Some supermarket executives were held to have violated the Sherman Act on the basis of evidence which included a trade association meeting where one partici pant made remarks to the general effect that it was time to stop passing lower wholesale meat prices on to the consumers and keep some or it for themselves. After viewing this and other evidence in light of the article pricing practices, the court upheld a jury verdict that the attendees at the trade association meeting had en gaged in an illegal conspiracy to keep wholesale prices low and retail prices high. (The jury awarded plaintiffs a verdict for over 32 million dollars, plus the plaintiffs' at torneys' fees.) 2. In another case, the sales manager of the leading company in a market invited the sales managers of the other major companies in the market to a meeting at which he described a proposal for reclassifying distribu tors and changing discount schedules. No one present openly agreed to reclassify his distributors and change his discount schedules. Subsequent to the meeting, however, the leading company instituted the changes proposed at the meeting and the other companies, one by one, adopted the same distributor classifications and discount schedules. All of the companies and their sales managers were convicted of engaging in an unlawful conspiracy. The fact that all of the individual defendants were at the meeting, heard the discussion, and subse quently reclassified their distributors and changed their discount schedules, supported a jury finding that they had unlawfully conspired to fix prices. 3. Sales officials of corrugated cardboard box man ufacturers in the Southeast followed a practice of occa sionally calling each other to determine quotes given on specific and current sales to identified customers. The Supreme Court held the practice illegal because it had the effect of stabilizing prices (i.e., it tended to limit price reductions and the range of price changes). The decision was reached in spite of an express finding that the calls did not result in an actual agreement on prices. Rather, each defendant, on receiving a request for pric ing information, usually furnished the data with the ex pectation that reciprocal information would be fur nished to him. This simple exchange of information was held to establish an unlawful combination conspiracy under the Sherman Act. lb) Agreement* to Control Production or Sales. Competitors may not agree to limit or control production or sales. Any limitations on output by direct or indirect agreement are illegal per se and cannot be justified, even where the purpose is to preserve the in dustry or conserve natural resources. (c) Division of Territories and Allocation of Customers. Any agreement between competitors to di vide or allocate either sales territories or customers is unlawful per je. Exchanges of information with compet itors relating to customers or territories can create the appearance such collusion or agreement and must be strictly avoided. (d) Refusals to Deal. Any agreement among com petitors which results in a refusal to deal with suppliers or other competitors -- for example, a blacklist or boy cott -- is illegal per se. For this reason exchanges of in formation (e.g. credit information) concerning particu lar customers which might lead to parallel decisions not to deal should be avoided. Application of Antitrust Laws to Trade Association Activities The valuable and proper activities of CMA and its com mittees can be accomplished effectively if participating members are alert to the prohibited types of behavior described above and react quickly when danger signals appear. Obviously, CMA activities should be conducted in such a way as to avoid any possible inference of agree ment among its members with respect to prices, control ling production or sales, division of territories, or re fusals to deal in any form whatsoever. Farther guidelines are given here to highlight potential danger zones to be avoided. When a danger zone appears, counsel should be consulted for specific guidance. In reviewing the following guidelines there are a few general points you should bear in mind: 1. As indicated above, an otherwise lawful act may become unlawful if done for an improper purpose, or if it is part of a larger standardization 49 VVV 000004921 jfe. 1 program might be justifiable considered by itself, but not if it is combined with other activities to facilitate the fixing of uniform prices. In other words, the courts may look at the cumulative ef fect of several activities -- not at each one separately. 2. Good motives are not an excuse tor doing things that are otherwise unlawful, either be cause they fall within one of the "per se" catego ries discussed previously or because they are more restrictive of competition than necessary to accomplish their legitimate objectives. Thus even though a product standardization program may be intended to increase competition by providing consumers with important information, it may nevertheless be found unlawful if conducted in a manner more restrictive than necessary to achieve its legitimate purpose. 3. An ostensibly lawful program or activity runs a greater risk of getting into vulnerable areas if conducted by a group of competitors mak ing the same product. That is the main reason why CMA operates primarily through functional committees, and imposes limitations on the sub ject matter and duration of any "ad hoc" commit tees dealing with matters concerning a specific chemical product or product segment. 4. As a member olaMA comnitttee, you and your canpan?can be held responsible for any improper acts that may occur which you know about (or should know rtout), and if you fail to protest or disassociate yourself from them. Participation laCMA Coaalttee Heetiigi All meetings of CMA committees must be conducted in strict compliance with the procedures set out in the "General Principles Applicable to the Structure and Op erations of Committees."* These General Principles pro vide for agendas, attendance of staff representatives, and for the keeping of accurate and complete minutes -- all of which are designed to avoid antitrust risks. If you participate in a CMA task group meeting held without a staff member being present (pursuant to the special circumstances set for in subparagraph 4(g) of the General Principles), be sure that the meeting com plies with the requirements of that subparagraph 4tg{ including an "accurate and complete written report.. . as to everything occurring at such meeting." Note: The attitude of enforcement personnel will be governed by what committee or task group members actually do. not by what is said in reports or minutes that may be incomplete or inaccurate. CMA committee members participating in activities involving advocacy before governmental entities should be familiar with and carefully observe the guidelines set out in the memorandum "General Principles and Guide lines for MCA Advocacy" dated May 14,1975. [n general, advocacy should be conducted in lawful ways and di rected solely at efforts to influence that policy. It should not be used as a sham or as a means to affect competi tion directly and independently of what would be the effect of the government policy which is sought to be influenced. While committee agendas will have been cleared in advance with CMA counsel, it is the obligation of all committee members to make sure that their own partici pation in committee meetings will not give rise to even an inference of antitrust wrongdoing. Thus, even when carrying out approved and legitimate activities members must be careful to avoid discussions or exchanges of in formation with their competitors on any subject relating to the "per se" restraints listed above since such discus sions or information exchanges may give rise to infer ences of agreement. As examples, you should avoid any discussion with competitors of the following: (a) Individual company prices, price changes, price differentials, mark-ups, discounts, allowances, credit terms, etc. (b) Individual company figures on costs, produc tion, capacity, inventories, sales, etc. (c) Industry pricing policies, price levels, price changes, differentials, etc. (di Changes ir inventoried' (e> Transports ual shipme; basing poir ization. etc Note: This wa charges against Mt phosphate) case. Mi the producers in sis practices charged.: was another princif charges pertained tlong since been aba ity was illegal, but j in signing a conseni tices charged, in ore ing litigation. (0 Bids on con: cedures for: ig) Plans of ind design, prot particular p ries or custc (h) Matters relai tomers that .them from a. (i)Any matter rt Regardless ofsi or tolerate anyaMth nection with CMA tot which is concerned v tee's terms of referen form with the proced * As approved by the Board ofDirectors on March 12.1963. and amended by the Executive Committee on March 19,1971; July 11.1978. and June 3,1981. 50 YVV 00000*922 * Id) Changes in industry production, capacity, or inventories. (e) Transportation rates or rate policies ot individ ual shipments or particular products, including basing point systems, zone prices, freight equal ization, etc. Note: This was an alleged factor in the 1962 FTC charges against MCA (now CMAl in the TSP (trisodium phosphate) case. MCA denied the charges, but joined the producers in signing a consent order prohibiting the practices charged. Standardization of TSP containers was another principal factor in the TSP case these charges pertained to an activity in 1939-1940 which has long since been abandoned. MCA denied that this activ ity was illegal, but joined the respondent TSP producers in signing a consent order prohibiting the various prac tices charged, in order to avoid costly and time consum ing litigation. (0 Bids on contracts for particular products; pro cedures for responding to bid invitations. (g) Plans of individual companies concerning the design, production, distribution or marketing of particular products, including proposed territo ries or customers. (h) Matters relating to individual suppliers or cus tomers that might have the effect of excluding them from any market. (i) Any matter relating to TSP as a specific product. Regardless of subject matter, you should not attend or tolerate any meeting with your competitors in con nection with CMA business which has no agenda, or which is concerned with matters outside your commit tee's terms of reference, or which otherwise fails to con form with the procedures in the General Principles. Informal Gathering! It is important to avoid discussions of the above sub jects. not only at formal CMA or committee meetings, but also in connection with social or other gatherings on those occasions. Ifany improper discussion should start in your presence, you should protest: if the discus sion continues, you should promptly excuse yourself from the group and communicate your protest to the ap propriate CMA staff manager. Even if you do not take part in any improper discussion, your presence without participation could still get you and your company into trouble. Any individuals who participate in such im proper discussions, whether deliberately or innocently, are doing their companies, and CMA, a real disservice, and subjecting themselves to possible liability. In case of doubt as to whether a particular subject may properly be discussed with your competitors, you should consult your own company counsel. Document! Care must be taken to avoid wording any written docu ments including reports or notes from committeemeet ings in a way that might be interpreted as indicating, contrary to fact, the existence of an antitrust violation. Every memorandum, letter or other document dealing with prices, competition, or the other danger areas spe cified in this guide should be written with the assump tion that it will one day be examined for antitrust impli cations. An antitrust case may be based on documents which are in reality innocent or innocuous but have been written in such a way as to create suspicion and re quire explanation. Such documents may include per sonal notes based on recollection, or taken at committee or other meetings, which record personal impressions rather than the facts of what transpired. Coscluioa It is hoped that this guide will help you to understand how the antitrust laws bear upon trade association ac tivities, and to carry out your CMA work in full compli ance with these laws and with CMA policies. Again, please remember that this is a limited outline and is not intended to be a complete description of the application of the antitrust laws. For answers to specific problems, you should consult CMA counsel and your own com pany counsel. 51 VVV 00000492 3 CIV* CMHANtMUCFAACi.TURERS ASSOCIATION OBLIGATIONS AND PROCEDtBKPOR MEMBER DISSENT* CIV* CHEMICAL MANU*1*0 T UaE^S association CMA AND AE The strength of an effective association in an advocacy role is its ability to identify issues of common concern to its members and to reach agreement on collective policy. When that agreement is reached, the Association can then strongly advocate a unified industry position. While the Association's objective is to strive lor con sensus on every issue, CMA recognizes that there may be cases, following the constructive sharing of diverse opinions, when individual members may ultimately choose to dissent from a CMA position. If a member company intends to advocate publicly a position on an issue which it believes is not consistent with an existing CMA position, the company should first inform the Association, by letter to the President, stat ing the basis for its disagreement, and give the Associa tion a reasonable length of time to respond before pre senting its position to others outside the Association. Before external dissent takes place, thorough internal discussion should be conducted either to resolve or con firm identified differences. The Association has the re sponsibility of expeditiously reweighing its original posi tion to determine whether it should be modified. To aid this internal review, members who initiate this process of dissent should inform the Association of any parties to whom they have expressed a contrary position and what the nature of the dialogue was so that this infor mation can be utilized in the process of reevaluating the Association's position. If the identified differences arenot resolved, the As sociation recognizes the right of the member company to pubficly pursue its own position. When presenting its position to others, the dissenting member company should make dear that it speaks for itself and not for the Association and the industry. Anyone can express to others outside the Association a CMA position, but onlv one designated by the Board or the President can repre sent that he speaks on behalf of CMA. Similar procedures should be followed in those cases where the Association does not have an existing position on an issue, but has begun the process of deve loping such a position. In those instances, the member company should inform the Association, by letter to the President, of its intent to present that position to others. If possible, the member company should defer present ing its position to others until CMA has had a reason able opportunity to review the company's position, identify any potential areas of significant concern and at tempt to reach an agreement on a CMA position. The Association recognizes that in some cases the time for CMA review and action will be very limited. In the ab sence of a CMA position on an issue, a member company presenting its position to others shouid make it clear that it is speaking for itself and not the Association. Advocacy means plead advocacy is implicit in chemical manufacturu ducted forthrightly an matters which affect a broadly concern the cl even though not imim To be beneficial.; Solid evidence and rca effective presentation Enlightened and the common good rati `As approved by the Board ofDirectors on June 5,1980, and amended by the Board on June 6, 1985- 52 As approved by the Ex VVV 000004924 or CHCMtCAl MANUFACTURERS association CMA AND ADVOCACY* Advocacy means pleading or defending a cause, hence advocacy is implicit m CMA's representation of the chemical manufacturing industry, and should be con ducted forthrightly and forcefully, concentrating on matters which affect a number ot its members or which broadly concern the chemical manufacturing industry even though not immediately arfecting many members. To be beneficial, advocacy must be persuasive. Solid evidence and reasoned interpretation coupled with effective presentation are needed. Enlightened and progressive advocacy is directed to the common good rather than being merely sell serving. Bearing in mind the pervasive significance of chemicals, it is vital that CMA advocacy so qualify. Advocacy on behalf of a collective industrial group must heed antitrust limitations. For this reason and be cause of the fact that certain chemicals compete with others in the marketplace for similar purposes. CMA normally limits its advocacy to matters having general applicability, as contrasted with those involving particu lar chemical substances or companies. If an important precedent-setting principle is involved, however. CMA may elect to advocate it regarding the principle alone. The foregoing precepts underlie CMA's advocacy role. Each member company should recognize this in no wav diminishes its responsibility to protect its own inter ests. nor is intended to restrict independence in so do ing. Each member company is encouraged to express its individual views. Ms approved by the Executive Committee on July 11,1978. 53 cn CMhANEUMECAaClTUHERS ASSOCIATION NOTES VVV 000004926 VVV 000004927 CHEMICAL MANUFACTURERS ASSOCIATION TO: CMA Air Contacts December 27, 1990 SUBJECT: Clean Air Strategic Plan Enclosed is the final version of the Strategic Plan which describes how CMA will conduct its regulatory advocacy program in response to the new reauthorized Clean Air Act. The Plan is divided into three parts: (I) an introduction which summarizes the key findings of the report; (II) a compilation of strategic work plans developed hy each work group which describe the action items and work products that are necessary to meet each objective; and (III) appendices which provide detailed cost data and other explanatory notes. Simultaneous to this mailing, the Strategic Plan has been mailed to the CMA Board of Directors in preparation for theig January 1991 meeting In Washington. If the Plan is approved by the Boards we will begin implementing it immediately. If you have any questions about the Plan, please give me a call at (202) 887-1313. Thank you for your help in developing this Plan. Sincerely Enclosure Richard G. Slgman Associate Director Air Programs 2501 M Street. NW, Washington, DC 20037 202-887-1100 Telex89617 (CMAWSH) VVV 000004928 CMA STRATEGIC PLAN FOR REGULATORY ADVOCACY IN RESPONSE TO THE REAUTHORIZED 1990 CLEAN AIR ACT December 21,1990 err CHEMICAL MANUFACTURERS ASSOCIATION 2SOI M Street NW 2028871100 Washington. D.C 20037 Te<e* 89617 (CMA WSH) VVV 000004929 - : -5 .7*1 CMA STRATEGIC PLAN FOR REGULATORYADVOCACY IN RESPONSE TO THE REAUTHORIZED 1990 CLEAN AIR ACT December SI, 1990 vw 00Q0GA93G TABLE OF CONTENTS PART I - INTRODUCTION Background ................................................................................................................. 1 Scope of the Plan.................................................. 2 Goals and Objectives.................................................................................................. 3 Measurement of Progress ................................................................................. ,...... 4 Costs ............................................................................................................................. 5 Plan Implementation Costs.................................................... 5 Total Cost .................................................................................................. 5 Figure 1 - Comparison of Historical vs. Plan Costa....................... 6 Figure 2 - Breakdown ofTotal Costs............................................... 7 Table 1 Comparison of Historical vs. Plan Costs ....................... 8 CMACost .................................................................................................. 8 Outside Services ................................................................................ 8 Figure 3 CMA Outside Services for Air Programs ............ 9 CMA Staff ......................................................................................... 10 Regulatory Compliance Cost.......................................................................... 10 Table 2 - Implementation Cost vs. Regulatory Compliance Cost 10 Figure 4 - Air Pollution Abatement: Gross Annual Costs.......... 11 CostBenefit........ -................................................................. --............................. 12 Table 3 - Cost/Benefit of Strategic Plan ...................................... 12 PARTII -STRATEGIC WORK PLANS Goal 1.................. 14 Objective 1 - Chemical Listing/Delisting ........................................... 14 Objective 2 - MACT Source Categories............................................... 18 Objective 3 - MACT Standards for Process Vents, Storage Tanks and Tranfer Operations ................................................................. 22 Objective 4 MACT Standards for Wastewater Treatment............ 27 Objective 5 - MACT Standards for Equipment Leaks ..................... 31 Objective 6 Equipment Leak Emission Factors.............................. 34 Objective 7 - NSPS/CTG Regulations.................................................. 37 Objective 8 - Nonattainment Issues.................................................... 41 Objective 9 - Permitting Issues............................................................. 46 Objective 10 - Enforcement Issues...................................................... 50 Objective 11 - Ambient Ozone Standards........................................... 54 Objective 12 - Ozone Attainment Strategy........................................ 57 Objective 13 - Residual Risk................................................................. 60 Objective 14 - Air Quality Modeling Guidelines................................ 66 Objective 15 - Accidental Releases...................................................... 69 Goal 2.......................................................................................................................... 74 Objective 1 - Member Company Communication.............................. 74 Goal 3.......................................................................................................................... 78 Objective 1 - Air Pollution Research.................................................... 78 VVV 000004931 PART IH-APPENDICES I - Anticipated Trade Associations Activities --............................................. II- Historical Cost - Estimate ofTotal Costs for Fiscal Year 89/90..................... III - Breakdown ofCosts- Summary ........................................*........................ IV - Outside Services - Expected Expenditures ............................................... V - Air Pollution Abatement Gross Annual Costs....................--..... .............. VI -RolesofCMA Cemmitteea/Task andWork Groups .................................. VHA - Goal I Coordinations of Strategic Action Items byWork Group ..... vub - Goal 2,3 - Coordinations ofStrategic Action Items by WoTk Group.. VIII - Air Issues Task Group - Schedule of Meetings..................... DC - Glossary ofTerms............................................................... .'."""".`I* 83 84 86 86 87 88 91 92 93 94 */* V- VVV 000004932 PART I - INTRODUCTION BACKGROUND In November 1990, the first Clean Air Act (CAA) amendments in thirteen years were signed by President Bush. With these amendments will come massive new regulatory programs, projected to be the most encompassing in scope and the most expensive in the history of environmental regulation. At about the same time that President Bush signed the Clean Air Act amendments into law, the CMA Board of Directors approved die report of the Ad Hoc Subcommittee on Regulatory Advocacy. That report recommended that the Environmental Management Committee, through the appropriate Task Groups and Work Groups, create a pilot program to implement the recommendations of the report. This program would improve regulatory advocacy by adhering closely to an "ideal vision and process" identified in die Subcommit tee's recommendations. The pilot program, as reflected in this Strategic Plan, identifies how CMA can most effectively advocate industry positions in the development of the new Clean Air Act regulatory programs. The ideal vision and process embodied in the Plan describe: key issues in regulatory development and their importance to the chemical industry; how success of the Plan can be measured; Q the barriers to successful implementation of the Plan; Q the resources needed to carry out the Plan; Q the cost to conduct the Plan; and the benefits of successful advocacy. This five-year plan begins with an overall statement ofgoals and objectives. Each of the elements in the ideal vision and process listed above is then described in the context of each objective. While the costs to CMA and its member companies to implement the Plan are significant, (approximately a 34% increase) over historical costs, ifwe are successful we can save the industry in excess of $1.4 billion, measured in terms ofdeferred capital expenditures and decreased overall costs ofcompliance. Since the savings estimates are extremely conservative, there is no question that the overall cost of implementation of this Plan is low compared to the benefits. Obviously, the chemical industry is not the only industry to be affected by these amendments. While we are ahead of other industry groups in responding to most new programs, we have anticipated that CMA can significantly leverage its resources by working with other trade associations. Specifically, CMA will seek joint funding arrangements with other associations on projects of mutual interest as it has in the past with other air projects. In addition, CMA plans to increase its effectiveness and minimize duplicative efforts by actively participating in an inter-industry coalition. This coalition, currently under development by CMA and others, will organize major advocacy efforts and exchange information on industry activities. Areas where there are overlapping interests, where inter-association efforts are most likely to be beneficial, are identified in Appendix I. VVV 000004933 1 The Plan is organised into three parts: (I) Introduction which includes this hackground, the scone ofthe plan, goals in responding to the Act, the objectives necessary to meet these goals, the costs ofimplementing this plan and complyingwith anticipated regulations, and the benefit of such actions; (II) Strategic Work Plana which describe in detail for each objective: the action items, work products, responsible groups, barriers and opposition, CMA and company resources needed, and the cost and benefit of the objective; and (III) Appendices which describe the role of each work group and task group in the process, the projects they are responsible for, bow CMA will coordinate with other trade associations, economic data, future meetings of the AITG, and a glossary of key terms. FartI ofthe Planis designed to serve as a stand-alone document summarizingthe main components ofthe Plan. SCOPE OF THE PLAN The Clean Air Act amendments of1990 is one ofthe most far-reaching environmental legislation ever enacted. Notonly are traditional sources ofair pollution subjectto new levels ofcontrol, butmanypreviously unregulated sources will also be included. For the first time, the Clean Air Act has adopted a technology-based approach, followed by a risk-based determination, for the control ofhazardous air pollutants. These provisions alone will result in the promulgation of literally hundreds of regulations, as well as numerous related guidance documents, studies, and reports. This Plan addresses those aspects of the Clean Air Act that are of most concern to CMA members, including: nonattainment rules; technology-based standards for control of air toxics; risk assessment and risk management provisions; risk-based standards for control of air toxics; new source performance standards; requirements to manage accidental releases; Q permitting; and Q enforcement. Since this Plan will evolve over time as more information becomes available, the work plans for responding to certain provisions in the Act that have not historically been part of CMA's Air Program will be added at a later date. These provisions include: atmospheric deposition to the Great Lakes and coastal waters; solid waste combustion; publicly owned treatment works; consumer products; visibility, the Environmental Protection Agency (EPA) and the Government Accounting Office (GAO) reports on benefits and costs; and acid rain. Finally, those areas that will not be included in the Plan since they are being addressed by other trade associations include: vehicle emissions, alternative fuels, Chlorofluorocarbons (CFCs), and controls for small sources such as dry cleaners and gas stations. 2 VVV 000004934 OPALS AND OB. ss The Plan includes three main goals to effective Clean Air advocacy. Each goal is made up of objectives which are measurable and achievable and designed to accomplish the stated goal in a specified period oftime. Part 11 of this Plan includes a separate work plan for each objective. A list of the goals and objectives follows. (The prder of the objectives does not indicate anv priority ranking but rather follows along lines of work group responsibilities. It should be noted that, in general. Goal 1 is ofhigher importance than Goals 2 and 3, and in most, instances, residual risk and MACT related activities are highest priority within Goal 1.) Goal l. To enhance the advocacy role of the chemical industry to act expeditiously, responsibly, and positively, in influencing the development and implementation of responsible Clean Air regu lations. Objectives: Advocate for ... 1. The development of a reasonable and straightforward process for chemical listing/delisting. 2. An appropriate source category list which includes a reasonable number of sources for Maximum Achievable Control Technology (MACT) standards with a staggered phase-in-sched ule. 3. The development of MACT standards for vents, storage and transfer operations which are technically feasible, performance based, and cost effective. 4. An acceptable definition of MACT for wastewater treatment which allows adequate time for compliance. 5. MACT standards for equipment leaks that reduce emissions while being economically and technically feasible. 6. Revisions ofexisting EPA emission factors for equipmentleaks and identification and promotion of implementation by member companies of low equipment leak emissions performance tech nology and operating practices. 7. The development of reasonable New Source Performance Standards (NSPS). 8. The promulgation of nonattainment regulations that target sources which are major contribu tors to the problem, contain reasonable requirements, recognize voluntaryemissions reductions and are cost effective. 9. The development of a Federal permit program that allows and encourages states to avoid multiple permits for the same source; contains reasonable application requirements and sched ules; encourages permit issuance in a timely and cost effective manner; embraces rather than replaces good state permit program elements; and recognizes and encourages voluntary and innovative control efforts. 10. The establishment ofenforcement criteria that are reasonable and fair; differentiate penalties by seriousness of offense; and do not abridge the protection of the Constitution regarding self- incrimination. 11. Sound scientific changes, if necessary, to the ozone standard. 12. Reconsideration of EPA's current ozone attainment strategy to properly account for nitrogen oxides (NOx) controls, contribution of area, mobile, and biogenic sources, and ozone and precursor transport. 3 VVV 000004935 13. A residual risk determination procedure that accurately identifies real risks posed to a community. (This comprises a major portion ofa larger CMA-wide project on risk. Costs in the Plan for this activity account for only that portion necessary to support the Clean Air Act im plementation.) 14. Air quality modeling guidelines that result in reasonable, resource effective models and model application rules. 15. The development of reasonable accidental releases/process safety management regulations. final 2 : Ohiactive: To communicate the results of the advocacy efforts to member companies. Acquaint member companies with results of advocacy efforts so that they may be prepared for anticipated regulations. finaT 3: Objective: ^ Monitor and positivelyinfluence air pollution researchandadvocate forthe use ofsuch research in crafting sound and scientifically based legislation and regulations. Hie development of a program to monitor current air pollution research and contribute to additional research that may influence the development ofmore auanLifically based legislation and regulations. MEASUREMENT OF PROGRESS -'x The appropriate task group will have the lead responsibility for monitoring adherence to the Plan. Progress will be measured by completion ofspecific action items and objectives. Periodic progress reports on each objective will be prepared and forwarded for CMA Board updates. Over time, the objectives may be modified, deleted, or new ones added as appropriate. Similarly, modifications, deletions, or additions to the actions under each objective are also easily made with accompanying changes to the resource needs. 4 WV 000004936 COSTS Costs associated with the Plan include both the cost ofimplementing the Plan ("Plan Implementation Costs"), and the costs to the chemical industry for compliance with all new regulations, ("Regulatory Compliance Costs"). Plan Implementation Costa Contents The implementation costs associated with meeting each objective include: Q Outside Purchased Services (O.P.S.)--which are broken down by department (not including the Office of General Counsel); Company time (time for meetings, preparation ofcomments, etc.)--which is converted to dollars by multiplying the number of days by $80Q/day; 3 Company travel associated with each objective; CMA stafftime (broken down by department)--which is converted to dollars by multiplying the number of days by $400/day (Note that the staff totals do not include support staff); CMA travel (broken down by department)--which equals approximately $600 per trip; and Outside Legal Services (O.L.S.) (Office of General Counsel only). Total Cost To put the cost of implementing this Plan into perspective, it is important to compare it with the cost of the Air Programfor the last fiscal year (FY89/90). Based on historical data (see Appendix II), it is estimated that this Plan would require only a 34% increase in funding from last year. This is due to the unusually high level of activity last year as CMA's Air Program simultaneously supported the industry legislative advocacy efforts on the Clean Air Act and regulatory negotiations with EPA. As can be seen from Figure 1, the incremental funding necessaryvaries from cost category to cost category. Company time and travel expenses will increase only 14% and 13% respectively as companies shift support from legislative advocacy to regulatory advocacy. The same can be said for CMA stafftime which increases only 41%. Where increases in costs are significant, a change in the type of support for advocacy is responsible. For instance, reviewing and commenting on regulations requires extensive technical and legal support far beyond that necessary to analyze broad legislative initiatives. Much of this support cannot be provided by in-house staff. Thus, significant increases in outside services for the Technical Department (105%) and the Office of General Counsel (86%) are required. In addition, as CMA shifts its focus from Capitol Hill to EPA's Air Office located in North Carolina, travel costs will go up. (Note that company travel costs will not be increased by this shift.) Also important to note is the breakdown of cost categories within the Plan. Although the outside service budget will rise significantly, it makes up only 22% of the total cost (see Figure 2). Thus, while all of the numbers, taken in the abstract appear high, a significant portion of the total, approximately 49%, represents the value of member company time and travel, and is not part of CMA's budget. Appendix III provides a breakdown ofthe costs of the Plan by objective and cost element. A summary of WV 000004937 5 VVV 000004938 6 COMPARISON OF HISTORICAL VS. PLAN COSTS (FIVE YEAR TOTALS FOR EACH IN DOLLARS) FY 69/90 FIGURES TIMES 5 YEARS r VW 000004939 7 BREAKDOWN OF TOTAL COSTS (FY 90/91 - 94/95) O.P.S. OUTSIDE PURCHASED SERVICES O.L.f OUTSIDE LEGAL SERVICES total costs to CMA and its members for all objectives, for all five years ofthe Plan are listed below in Table 1. Historical costs (FY 89/90 times 5 years) are also provided for reference. TABLE 1 COMPARISON OF HISTORICAL VERSUS PLAN COSTS (in dollars) Cost Category Outside Purchased Services Outside Legal Services Company Time Company Travel CMA Staff Time CMA Staff Travel Total Plan (1) 2,796,250 1,021,500 6,582,400 1,855,600 5,100,800 122,000 17,478,550 Historical(2) 1,364,250 550,000 5,763^200 1,642,550 3,616,667 88,000 13,024,667 % Increase 105% 86% 14% 13% 41% 39% 34% Notea (1) Plan - Totals For FY 90/91 through FY 94/95 (2) Hirtoncal - Totals For FY 89/90 times five yean for comparison purposes CMA Costs Outside Services The bulk of the responsibility for implementation of this Plan will fall primarily to the Technical Department and the Office of General Counsel. While some support will be provided by the State Affairs and Federal Government Relations Departments, the Plan envisions this solely as member company and staff support -- not outside services. Within the Technical Department, costs have been broken out by the Environmental Division and the Health and Safety Programs. (Appendix IV provides a detailed break down of outside services costs by fiscal year, objective, and Department.) Particularly in the first full year of the Plan, when the bulk of regulatory decisions will be made by EPA, the costs represent a significant increase over spending levels in the current fiscal year (see Figure 3). By FY 1993/94, costs decrease significantly, to a level much closer to current spending levels. Interestingly, the level offunding needed overthe five years ofthe Plan is about the same magnitude as fixndingfor Clean Water Act implementation in the early 1980s. VVV 000004940 8 VVV 000004941 FIGURE 3 CMA OUTSIDE SERVICES FOR AIR PROGRAM (HISTORICAL VS. PROJECTED UNDER PLAN) DOLLARS (Thousands) OS 1985 86 87 88 89 90' 91 92 93 94 FISCAL YEARS TECH EXPENDITURES TECH PROPOSED EXP. COUNSEL EXPENDITURES COUNSEL PROPOSED EXP Currant Flaoal Yttr (FY 90/91) CMA Staff One ofthe most significant impacts ofthi* Plan will be on human resource demands. Increased activities, that will require increased staff, include the management of additional work groups, management of an increased number of contracts, additional interaction with the EPA and other agencies (consistent with the ideal advocacy process), and anticipated use of the "regulatory negotiation" process for at least two major rulemakings. To adequately manage the increased work load, the Environmental Division in requesting two ney manager positions be added in FY 91/92. These managers would serve as staffexecutives to the new work groups, manage a portion of the outside services contracts and manage one or more of the regulatory negotiation groups. In addition, the Office ofGeneral Counsel (O.G.C.) is requestingan increase in stafffrom the 1.67attorneys now assigned to Air Programs. OGC anticipates that as a result of increased client activities, and the increased pace ofthe rulemaking process generally, they will need to add one attorney and one paralegal in FY 91/92. Because the activities envisioned in this Plan peak between 1991-1993, we are considering seeking a "loaned executive* from a member company who would staffsome ofthe work in the first two years ofim plementation of the Plan. 71181 individual could serve as a "typical* staff executive or fulfill a more specialized role. In either case, he or she would be a member of the CAA staff matrix. Regulatory Compliance Cwrt Compared with historical environmental costs, the impact of the Clean Air Act amendments on the chemical industry will be enormous. In 1989, the industry spent a total of about $3.4 billion for all types of pollution abatement By 1995, as a direct result of new Clean Air Act requirements, this figure will increase to at least $6 billion (in 1989 dollars). By2005,theannualcostwiUincreasetoatleast$10.4billion(in 1989dollars). Other costs; such as those for acid rain controls (both in terms ofdirect control costs and increased costs ofelectricity), permit ra^Banatts, and other control programs, will add another $1.3 to 2.5 billion to the costs each year. While the impact ofthe Clean Air Act will be felt for many years to come, the most significant increases in costs will occur in 1992 (see Figure 4 and Appendix V) just as implementation of this Plan is at its height This riBe will be so steep thatit actually outpaces the increase in costs for implementation ofthis Plan. When compared to histoncal figures for impfemoatation ofthe CMAAir Program versus gross annual costs, the cost ofthis Plan iaaanrfer iBaeentage of co^Bance costs: TABLE 2 IMPLEMENTATION COST VERSUS REGULATORY COMPLIANCE COSTS Cost of CMA's Air Program in FY 89/90 Air Pollution Abatement Gross Annual Costs in FY 89/90 Cost of CMA's Air Program as a Percentage ofCompliance Costs Cost of Strategic Plan (FY 90/91 through FY 94/95) Air Pollution Abatement Gross Annual Costs (FY 90/91 through FY 94/95) Cost of Plan as a Percentage of Compliance Costs $2,604,933 $782,500,000 0.33% $17,478,550 $8,365,000,000 0.21% 10 VVV 000004942 YVV 0 0 0 0 0 4 9 4 3 FIGURE 4 AIR POLLUTION ABATEMENT GROSS ANNUAL COSTS (1984 - 2002) Billions* 6 i------------------------ 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 0 1 2 Chemical Industry `Billions in constant 1989 dollars Q Through implementation of this Plan, CMA members most likely will see a decrease in the overall cost of compliance. Based on experience with regulations under the old Clean Air Act, and using very conservative assumptions of the possible impacts of effective advocacy, the Air Issues Task Group has estimated that the decrease in cost to the industry will be at least $1.4 billion over the next ten years. This figure, while admittedly inexact, is based on an estimate of: Q decreased costs to comply with the regulations (avoidance of the most expensive control option); reduced number of fines and shutdowns (more reasonable rules make compliance more certain); better allocation of capital expenditures (avoidance of premiums that result when demand for con trols exceeds supply, and phase-in of industry compliance); and Q reduced administrative costs for permitting. When the cost ofimplementing the Plan, $17.5 million, is compared to a cost avoidance of at least $1.4 billion, the cost/benefit ratio is very favorable. Not included in these savings are the reduced compliance costs for the years beyond the life ofthe Plan. Since many of the decisions made during Plan implementation (FY 90/91- FY 94/95) will affect the regulatory requirements as far out as the year 2001, success during the Plan's implementation will provide an additional bonus in later years. For instance, the size and diversity within a source category will be determined by EPA during FY 90/91 setting the schedule for how all sources will be regulated over the next ten years. Estimated eosts and benefits are summarized below in Table 3. TABLE3 COST BENEFIT OF THE STRATEGIC PLAN Cost of Strategic Plan: Cost of the Clean Air Act Without Advocacy: The cost of the Plan is J20% of the cost of the Clean Air Act to the industry Cost of Strategic Plan: Net Savings Under Strategic Plan: Cost/Benefit Ratio: % 17,500,000 $ 8,400,000,000 $ 17,500,000 $ 1,400,000,000 * 0.0125 "Does not include estimated savings beyond FY 1994^95 due to advocacy efforts in Plan. 12 000004944 VVV PART II STRATEGIC WORK PLANS VVV 0000049*5 13 r GOAL #1, OBJECTIVE *1 CHEMICAL LISTING/DELISTING To enhance the advocacy role of the chemical industry to act expedi tiously. responsibly, and positively in influencing the development and implementation of responsible Clean Air regulations. ftW-IECTIVE U Advocate for the development of a reasonable and straightforward process for chemical listing/delisting Company Time *OJ\S. CMA Staff Company Travel CMA Travel *0.1^3. 230 Days *60.000 660 Days *72,000 *5,400 *210,000 (Outside Purchased Services Outside Legal Services) ^CTIQN participate in preliminary meetings with EPA Collect and review information Propose Regulatory Negotiations to EPA Develop CMA positions Draft position papers on basis for list Propose CMA LisbDclist procedure Respond to EPA and other party suggeslions Participate in Regulatory Negotiations Meetings Respond to Issues Comment on proposed rules Review final rules RESP. GROUP LEAD/SUPPORT AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S AT/H&S WORK PRODUCT Minutes, reports TIMING 3(30/91 Report Letter proposal White-paper Contractor reports Contractor report Letter proposal to EPA Minutes, reports 6/01/91-900(91 6/30/91 (1) 9/3091 (2) 12/31/91 3/3192 3/3192 Minutes, reports 3/31/92 CMA reports CMA comments Evaluation/summary AT-Air Toxics Work Group H&S-Health and Safety Committee 10/31/92 12/3192 12/31/93 CONTRACTOR COSTS (la) (lb) (2) CMA RESOURCE BREAKDOWN $10,000 $30,000 $20,000 TECHNICAL STAFF (Days) Environmental 450 Health 4 Safety LEHaj| 110 ioo FISCAL YEAR 1990/91 1991/92 199192 TRAVEL ($) *2.400 *3,000 OP.S/OJ-S. <*) * 60,000 $210,000 14 VVV 000004946 GOAL #1, OBJECTIVE #1 - CHEMICAL LISTING/DELISTING jwagrintion of Issue The Clean Air Act contains a list of 189 hazardous air pollutants including 17 categories ofcompounds such as glycol ethers, for which EPA must develop MACT standards. The Act contains provisions for EPA to add ot delete a substance from the list. Additions may be made if EPA judges there is sufficient evidence that a substance is a carcinogen orcauses other serious or irreversible health effects. More importantly, EPA may delete a pollutant from the list if there is sufficient lack of evidence of carcinogenicity or other health effects. To get a substance listed or delisted, a petition must be filed with adequate supporting information. frortflncg to Industry In general the magnitude of the hazardous air pollutant list defines the scope of the MACT standards on the chemical industry. The list contains substances that range widely in the degree and nature ofassociated health effects. In particular, the compound classes included on the list contain specific compounds that vary significantly in their health effects. The chemical delisting provisions are an important tool for industry to use taeasurethat EPA regulates the chemicals that Congress intended, Le.r those that cause or can be reasonably expected to cause cancer or other serious or irreversible health effects. Triteria for Success To be a usable provision, the petition process developed by EPA for listing/delisting substances must be Uraightforward. Both the necessary actions on the part ofthe petitioner and the reviewermust be well-defined. For example, the type and amount ofinformation needed to support a petition should be specified. Additionally, the criteria forjudging petitions and the schedule for granting or denying them should be specified. Each of these elements should be addressed by EPA when they develop the petition process. The criteria for success for any individual petition would be a timely and critical review of each technicallysupported petition with the judgment by EPA that such petitions should be granted. EPA's decision should be presented in such a way that negative public perception is avoided, and if possible to have pro-environmental group acceptance of proposals/petition. Timing The Clean Air Act allows individuals to submit petitions to have substances added to or deleted from the hazardous air pollutant list any time after enactment. EPA has 18 months after receipt of a petition to either grant or deny it. EPA, therefore, must have its petition process in place very soon after enactment. To have the greatest chance of success, a petition should be submitted for consideration before EPA has invested a lot oftime and resources in developing MACT standards for categories emitting that substance. At the latest, petitions must be submitted before the MACT standard is issued for that substance. For the chemical industry, therefore, petitions should be submitted as soon as possible after the Act is passed but no later than two years after enactment. gfiliiuis 1. Proactive advocacy methods - CMA could conduct proactive advocacy by providing input on a workable petition approach before EPA has developed it and by working with EPA on development and evaluation of information needed ta support individual petitions for specific substances.. 2. Traditional advocacy methods (Reactive) - CMA could approach advocacy in a traditionally reactive manner by providing oral and/or written comments to EPA after EPA decisions on the petition process are announced and by submitting and/or commenting on individual petitions for listing/delisting specific substances. 15 WV 000004947 GOAL #1, OBJECTIVE #1 - Chemical Listing/Deliating (coni.) 3. Nn action - CMA could take no advocacy position whatsoever on EPA's petition process or on individual petitions to get specific substances delisted. Rarriftra and Opposition EPA probably views the development ofthe petition process for adding or deleting specific substances from the hazardous air pollutant list as an administrative activity. Thereforet they may not welcome the chemical industry's input on how this process should work. Furthermore, from experience under SARA Title III, it is likely that the delisting of substances will be a "high hurdle" as EPA will be reluctant to go against Congress in their development of the list. The public perception of delisting a chemical is likely to be very negative. Cost and Benefit Benefits will undoubtedly vary from company to company. Primary benefits will be to avoid unnecessary expenditures (capital and expense) that result in little or no positive impact on human health or environment Benefit estimated at $20,000,000 per chemical delisted before MACT controls are required. Ifadvocacy results in a listing/delisting procedure that enables five chemicals to be delisted, or that prevents five additional chemicals from being listed, cost savings of approximately $100,000,000 could be realized. Actions Selected Proactive Advocacy 1. Schedule meeting with EPA to identify key players and share thoughts and ideas. 2. Review EPA plans and-develop strategy to positively influence delisting process. 3. Decide if cost/benefit analysis warrants further action. 4. Evaluate chemical listing/delisting as candidate for regulatory negotiation with EPA and other interested parties. 16 VVV 00000494a qqLj #1, OBJECTIVE #1" Chemical Liating/Delisting (oont.) RESOURCE NEEDS Preliminary Meetings with EPA Member Member CMA Company Company Tech, Time Travel Time ____... _____ CMA CMA CMA Onteide Legal Tech. Legal Legal Tima Travel Travel Barmeae jsseL-__SSi__ --ifi_________ <> - Outalde Piirehaaed Services w 2D 6,000 8 10 L200 14200 pad Collection nod Review Propo-e Beg-Neg to EPA Setup nagMag.Prorris kfaotiiy issuee..^ interested partier* and schedule 10 6,000 10 6,000 10 6,000 30 6,000 36 22 22 112 10 -- 0 -- 10 -* 0 -- 10 * GOO 60,000 16 * * 0 & 20,000 20,000 Prepoee CMA Lift/Delist Procedure* 60 18,000 134 16 1,200 L200 100,00k Respond to Reeponae* Comment on Proposal 60 18,000 30 6,000 134 92 5 -15 * 0 20,000 0 -- 20,000 Review Anal rule Totals -- -230 $72,000 660 10 -100 $2,400 0 3,000 -$210,000 -$60,000 RnnnmrihilitY The Air Toxics Work Group, in conjunction with the Health and Safety Committee, will take the lead in pro.Dting CMA's advocacy on this issue. Performance Measures 1. Well defined guidance/regulation in place for member companies to use. 2. Guidance acceptable to environmental advocacy groups and public at large. 3. EPA acceptance of CMA suggestions/comments. 4. Open dialogue with EPA (meetings and correspondence). 17 VVV 000004949 GOAL #1, OBJECTIVE #2 MACT SOURCE CATEGORIES GQALtl; To enhance the advocacy role ofthe chemical industry to act expedi tiously, responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE *2= Advocate for an appropriate source category list which includes reasonable number of sources for MACT standards with a staggered phaae in schedule. Company Time *OP3. CMA Staff Company Travel CMA Travel O.LA 360 Days *78,000 508 Days *108,000 *4,800 *0 *<Outside Purchased Services Outside Legal Services) action Meet with EPA Develop database Propose iouroe grouping Review EPA groupings Work with EPA on final list Inform member companies RPSP GROUP AT AT AT AT AT AT WORK PRODUCT Minutes, proposals Technical database for source category selection (Contractor report) List of sources List of sources List of sources Reports TIMING On-going (1) 1291/90 (2) 3/3191 (3) 7/3191 8/3091 9/3091 AT-Air Toxics Work Group roWTRifTOR (1) (2) ` (3) COSTS $36,000 *12,000 *30,000 FISCAL YEAR 199091 199091 199192 TECHNICAL Environmental LPflAl. STAFF (Day*) 448 60 TRAVEL (*) 2,400 2,400 O.P.R/O.L-S. (*) 78,000 0 18 VVV 000004950 GOAL #1, OBJECTIVE #2 - MACT SOURCE CATEGORIES 22ggQptuiiuil8fiii& fhe Clean Air Act requires EPA to publish a list of all categories of mqjor sources of hazardous air pollutants within 12 months of enactment. EPA must develop MACT standards for all categories on the list according to a schedule prescribed in the Act. The Clean Air Act gives EPA a lot of discretion in how broadly or narrowly they define source categories on the list. For example, EPA could list the Synthetic Organic Chemical manufacturing Industry (SOCM1) as a source category. Conversely, they could list individual chemical protection processes such as butadiene production and ethylene oxide production as source categories. In addition to how broadly and narrowly EPA defines source categories, CMA is also concerned about the schedule under which EPA will issue MACT standards for the chemical industry. jmr--Industry 'The way in which EPA defines source categories within the chemical manufacturing industry could have a significant impact on several aspects ofClean Air Act implementation. First, it will set the basis for how MACT standards are to be developed. IfEPA defines a broad source category such as "SOCMVlfft will be necessary for EPA to develop generic standards that can be applied broadly across all facilities atihe industry. However, ifEPA defines source categories on the basis ofindividual process categories, then itaroold be possible for EPA to consider unique aspects of each individual source category when developing its MACT standard. Ihe schedule for issuing MACT standards is also ofextreme importance to industry. Under the Clean Air Act, EPA must issue MACT standards for at least 40 source categories within two years of enactment. EPA has indicated to CMA that they intend to regulate all SOCMI facilities within the 40 source categories regulated at Year two. In addition to the MACT standards themselves, the way in which EPA defines source categories will determine the basis for how residual risk determinations are made in the future. Criteria for Success Ibe source category list published by EPA should distinguish among subsets of the chemical manufacturing industry for purposes ofdeveloping MACT standards and for purposes ofapplyingresidual risk determinations. Ideally, these subsets should be based on individualchemical production processes such as butadiene production or ethylene oxide production. Alternatively, these subsets could combine individual chemical production processes into common groupings based on the characteristics ofthe process, the chemicals produced, or other operational criteria for which different control strategies would be appropriate. The schedule for regulating source categories in the chemical industry should provide for a staggered phasein to ensure that the compliance burden is spread out over a reasonable period of time. The availability of industry resources, as well as control equipment and other compliance-related services should be considered. The ability of State agency personnel to meet the corresponding permit load should also be considered in determining a reasonable phase-in schedule. Ximjug EPAhas already begun work on the source category list. EPA has informed CMA of their intention to list SOCMI" as a source category rather than to list individual chemical production processes or other subsets of SOCMI. However, they are receptive to other approaches provided that CMA can develop technically supportable recommendations in the next few months (by end of 1990). Because of the statutory requirement that EPA publish the list of source categories within 12 months of enactment, the period for advocacy on this U8U will be brief. 19 VVV 000004951 GOAL #1, OBJECTIVE #2 -- MACT Source Categories (oont.) With regard to the schedule for issuing MACT standards for the chemical industry, EPA has informed CMA of their intention to promulgate generic standards for the "SOCMT source category in the first group of MACT standards promulgated within two years ofenactment EPA is already working on developing these standards. To successfully advocate this issue, CMA must provide EPA with technically supportable arguments very early in the rulemaking process. The most effective timing would be to combine input to EPA on the MACT standards schedule with information provided to EPA on the source category list (by end of 1990). However, unlike the source category list, CMA could comment on the MACT standards implementation schedule as late as proposal of the MACT standards. guiiSBA 1. Proactive advocacy methods - CMA could conduct proactive advocacy by providing technical support information for alternative approaches while EPA is still in the decision-making phase. 2. Traditional advocacy methods (Reactive) - CMA could approach advocacy in a traditionally reactive manner by providing oral and/or written comments to EPA after EPA decisions are announced at the National Air Pollution Control Techniques Advisory Committee (NAPCTAC) or proposed in the Federal Register. 3. No action -- CMA could take no advocacy position whatsoever on EPA's Source Category list development and regulatory schedule. Barriers and Opposition EPA has a tremendous task ahead of them to meet the statutory standards development requirements and schedules. One way that EPA can help ensure meeting the statutory deadlines is to group the chemical manufacturing industry into one category, i.e., SOCM1, and to develop generic standards that can be broadly applied across the industry. In this way, EPA does not have to collect information on every chemical production category and do a separate rulemakingfor them. Instead, it may rely on ''available" information for the chemical industry as a whole. A major obstacle to successful advocacy on this issue is convincing EPA that alternative approaches will not interfere with their ability to meet their statutory deadlines. Other barriers include opposition by environmental advocacy groups such as Natural Resources Defense Counsel, EDF, Sierra Club, etc., in the event of a lack of mutual understanding by such groups as to what industry and EPA are trying to accomplish. Cost and Benefit Savings of several hundred million dollars per year could be realized in avoided interest expense, efficient use ofcapital, engineering, design and construction services thereby avoiding significant premiums where demand for equipment and services exceed supply by a factor of two or more. Actions Selected Proactive Advocacy 1. Meet with EPA in early stages to share thoughts. 2. Open dialogue with all levels of EPA to communicate information and concerns. 3. Respond to EPA requests for information. WV 00004952 20 gOAL #1 OBJECTIVE #2 - MACT Source Categories (cont.) 4 Develop data necessary to meet EPA's need and CMA's needs: sound technical reasons to not regulate SOCMI as one source; Q industry cannot meet congressional mandates with current pollution equipment manufacturing capability; and RESOURCE NEEDS Activity preliminary Meetings with EPA Data Collection sad Bensw Respond to EPA l^Mds Propose Sources (PnbxBinvy) Discuss Sou--Omupings (EPA) Develop tudAupote Schedule to EPA Review EPA Responses Totals Member Company Time (Days) 36 36 36 72 Member Company Travel (6) 10300 10300 10300 21300 CMA Tech Time (Days) 8 76 70 140 CMA Legal Time (Days) 10 5 10 10 72 21300 36 10300 72 21300 360 $106,000 28 70 66 448 5 10 10 60 CMA CMA Outside Outside Tech. Legal Legal Purchased Travel Travel Services Services () <) () ($) 1300 -- 1300 - 0 -- 36.000 00 - 0 12.000 1300 1300 00 0 $2,400 $2,400 -- 30.000 -- 0 -* 0 $0 $78,000 Itesnmtsihilitv TheAir Tories Work Group wilLftake the lead in promoting CMA's advocacy on this issue. Pnrfonimnce Measures 1. Open dialogue with EPA (meetings and correspondence). 2. EPAacceptance ofCMA suggestions/comments, etc., before EPA releases first written draft ofsource cate gories. 3. Respond to EPA requests for data. 4. Provide guidance to EPA on data needs, gaps and use of data. 5 CMA/EPA consenaufcan source categories. 21 VV\f QOOOQ4.953 GOAL *1, OBJECTIVE *3 MACT STANDARDS FOR PROCESS VENTS, STORAGE TANKS AND TRANSFER OPERATIONS To enhance the advocacy role ofthe chemical industry to act expedi tiously, responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE #3: The development of Maximum Achievable Control Technology (MACT) standards for vents, storage and transfer operations which are technically feasible, performance baaed, and cost effective. EgTTMATiro RESOURCE Company Time OJ\S. CMA Staff Company Travel CMA Travel *O.LS. 1.740 Days $1,040,000 2.362 Days $320,000 $18,000 $130,000 *(Outside Purchased Services Outside Legal Services) ACTION Meat with EPA Suggested technical ap proaches to EPA Review and comment on EPA plans and proposals for Credit for Early Reduction Program Create generic MACT lan guage: scope; records; reports; etc. Review 50 proposed MACT standards for process vents Review 16 proposed MACT standards for transfer opera tions Review 11 proposed MACT standards for storage opera tions RESP. CROUP AT AT AT/PENWG AT AT AT AT CONTRACTOR (1) (2) (3) (4) COSTS $ 20.000 $760,000 $160,000 $110,000 90/91 0% 10% 0% 0% CMA RESPITED HHRAimnWN STAFF (Days) TECHNICAL Environmental T.ECAI. 1312 560 WOES PRODUCT Minutes, reports Minutes, reports Meetings, comments TTMTNO On-going On-going 12/90-4/91 Written proposal to EPA Draft technical report* and comments Draft technical reports and comments (1) 03091 Thru 11/3092 (2) 11/3091 Thru 12(31/96 (3) 11/3091 Thro 12/3195 Draft technical reports and comments (4) 11/3091 Thru 12/3196 AT-Air Toxics Work Group PENWG Permitting, Enforcement and Nonattainment Work Gn 0192 100% 30% 40% 40% 9293 0% 30% 20% 20% 9394 0% 20% 20% 20% ms 0% 10% 20% 20% TRAVEL ($) 9.000 9,000 22 O.PjSj'OX^. ($) 1,040,000 130.000 VVV 000004954 GOAL #1, OBJECTIVE #3 - -MACT STANDARDS FOR PROCESS VENTS, STORAGE TANKS AND TRANSFER OPERATIONS j.rrirrintion of Issue The Clean Air Act requires EPA to develop MACT standards for all categories ofmajor sources ofhazardous air pollutants. Process vents, transfer operations, storage tanks, equipment leaks, and wastewater operations are five sources of emissions of hazardous air pollutants from chemical manufacturing facilities. EPA currently plans to develop technology standards for these sources as part of the overall MACT standards for chemical manufacturing source categories. Elements in the MACT standards of concern to the chemical industry include; applicability determination, including de minimis cutoffs; technology-based emission standards -- may be performance standards or work practice/operation requirements; Q emissions monitoring and test procedures for demonstrating compliance; and 1 recordkeeping and reporting requirements. The Air Toxics Work Group will focus advocacy efforts on all elements of MACT standards development for process vents, transfer operations, and storage tanks1. The Air Toxics Work Group will also be initially responsible for advocacy efforts on any additional emissions sources (except equipment leaks and wastewater operations) identified by EPA in the future. Tmnortflnce to Industry Virtually all chemical manufacturing facilities have process vents, transfer operations, and/or storage tanks. Therefore, chemical manufacturing facilities that are major sources will be required to implement the MACT standards for these sources. Major sources are defined as facilities emitting greater than 10 tons per year (tpy) of any angle Hazardous Air Pollutants (HAPs) or 25 tpy of all HAPs combined. rriteria for Success The MACT standards for process vents, transfer operations, and storage tanks should: Specify performance standards whenever possible instead of specifying a particular technology; 3 include de minimis cutoffs; Take into account differences in chemical processes to the extent that these differences suggest different control approaches; 'The Fugitive Emissions WorkGroup will lead advocacy efforts on the MACT standards forequiprnent leaks. The Secondary Emissions Work Group will lead advocacy efforts on the MACT standards for wastewater operations. (See Goal 1, Objective 4 & 5} 23 Wy 00Q0Q4955 GOAL #1, OBJECTIVE #8 -MACT Standard lor Proccas Vents, Storage Tanks and Transfer Operations (eont.) Be phased in over time across the chemical manufacturing industry; Be easy to understand and to implement; Balance the costs and benefits; and Contain reasonable recordkeeping and reporting requirements. XllBjUU EPA has informed CMA of their intention to regulate process vents, transfer operations, and storage tanks at chemical manufacturing facilities as part of the first set of MACT standards to be issued within 2 years of enactment. EPA has already begun work on these MACT standards in anticipation of the Clean Air Act reauthorization. Their current rulemaking schedule calls for proposal ofMACT standards for at least 40 source categories by November 1992. Potions 1. Regulatory Negotiations (Reg-Neg) - CMA could encourage EPA to enter into a regulatory negotiation with CMA and other affected groups for any or all of the MACT standards. 2. Proactive advocacy methods -- CMA could conduct proactive advocacy by providing information and scheduling periodic discussions with EPA throughout the standards development period, as well as through comment and testimony. 3. Traditional advocacy methods (Reactive) - CMA could approach advocacy in a traditionally reactive manner by providing comments and testimony on proposed regulations. 4. Nn action -- CMA could take no advocacy position whatsoever on EPA's MACT standards development activities. Barriers and Opposition EPA feels that their tight regulatory development schedule precludes close coordination with CMA during the rulemaking period. Information on alternative approaches identified by CMA that might otherwise be considered by EPA may be disregarded because of the impact on the rulemaking schedule. To be'successful, CMA must bring information forward to the Agency on alternative approaches as early as possible in the rulemaking process. CMA's ability to do this will depend on the availability of resources, including CMA staff, member company, and outside purchased services. As always, one key to EPA developing sound technology-based standards will bean adequate data base. Because EPA has adopted a tight schedule for developing MACT standards, it will be impossible for them to develop a comprehensive data base of up-to-date information related to process vents, transfer operations, and storage tanks. In fact, EPA has indicated that new information is being collected only for transfer operations and only from 9 companies. Consequently, there will be a lot of pressure placed on CMA to voluntarily provide up-todate information to EPA to ensure that MACT standards are based on the most recent, representative industry data. CMA's ability to provide the necessary information will depend on the member companies' willingness and ability to provide resources (manpower and money) to produce the needed data. 24 Wy O0004956 GOAL #1, OBJECTIVE #3 -- MACT Standards for Process Vents, Storage Tanks, and Transfer Operations (coni.) "nd Benefit Compl*nce costs for MACT standards on process vents and storage tanks, will be substantial. Successfully advocating requirements for cost effective controls and reasonable recordkeeping and reporting requirements will minimize compliance costs. Savings on the order of several hundred million dollars may be realized with successful advocacy. ArtiP"* Sheeted frnntPive Advocacy X. Meet with EPA in early stages to share thoughts, identify concerns, and formulate strategies to advance CMA positions. 2, Open and maintain dialogue with EPA at all levels. 3 Identify areas where CMA can contribute to EPA activities (technical resourcesdata, etc.). 4. Identify technical reasons to support CMA positions. ,, 5. Propose to EPA methods and ideas on how equipment, processes, etc. should be grouped for regulation. 6. Draft regulations for EPA that advance CMA positions with respect to: Q types of control; level of control; efficiencies; de minimis cutoffs; applicability; schedule; LI alternative control devices; recordkeeping; reporting; 3 test methods; and 3 appropriate consideration of cost effectiveness in setting regulations, e.g., use of TRE equations. 25 WV 000004957 >AL *1, OBJECTIVE #3 - MACT Standards for Prow Vents, storage Tanks and Transfer Operations (cont.) RESOURCE NEEDS Member Activity Generic Language MACT Standards MACT Process Vents MACT Transfer Operations MACTStonge Challenge offinal rules Totals (D*y) 206 900 400 132 100 1740 Member ($> 24.000 225,000 33,000 20,000 18,000 $320,000 CMA Tech. Time (Day) 140 1,050 448 154 20 1,812 CMA Legal Time (Days) 250 100 100 50 50 550 CMA Travel ($) 6,000 4,000 4.000 4,000 *18.000 Outside Legal Services (9) 40,000 20,000 20,000 20.000 30,000 $130,000 Outside Purchased Services ($) 20,000 750,000 160,000 110,000 -- $1,040,000 Veponeihilltv As discussed previously, the Air Toxics Work Group will take the lead in promoting CMA's advocacy on all ele ments of the MACT standards for process vents, transfer operations, and storage tanks. The Air Toxics Work Group will coordinate with the Fugitive Emissions Work Group and Secondary Emissions Work Group on aspects of the MACT standards advocacy that are of common concern. Performance Measures 1. Open dialogue with EPA (meetings and correspondence); share information. 2. EPA acceptance of CMA input/comments/suggestions before EPA releases first written drafts of regula tions, etc. 3. EPA staff visits to member company plants. 4. CMA consensus on issues (sub-issues). 5. Communications to member companies in timely manner. 26 VVV 00000495a GOAL *lt OBJECTIVE #4 MACT STANDARDS FOR WASTEWATER TREATMENT the advocacy role ofthe chemical industry to act mpe Ptiausly responsibly and positively ia influencing the develop^eot mud implementation of responsible Clean Air regulations. 0ftZEXB&14i Advocate for an acceptable definition of MACT for wastewater treatment which allows adequate time for compliance. Company Tims OJA CMAStalT Company Travel CMA Travel O.L.S. 840 Days $344,000 870 Days $106,000 $11,400 $210,000 "(Outside Purchased Services Outside Legal Services) jtCTlQN Meeting* with EPA (three) SEWG t Develop sub-categories/ ATWG * divisions for SOCM1 to advo cate to EPA r Review industry 114 re sponses SEWG Draft CMA control options oprtftns aart target tMaanes eaptaanstconoerns with generic MACT.will not work. SEWG Review Method 25D proce dures SEWC EMTG Develop emission data for waste water treatment units SEWG Develop emission data for col lection system components SEWG Decide Reg-Neg participation SEWG Deartep estimating techtriqrt* collection system emissiaaa SEWG Regulatory Pfcgetiation SEWG Comment on proposed regula tions SEWG Review final rules SEWC Programs to Assess Volatile Emissions (PAVE) upgrades SEWG WORK PRODUCT Minutes Reports, written proposal Strategy Strategy Strategy Contractor database Contractor database Strategy Contractor report Negotiated rule Comments Summary/evaluation Contractor service TfMtNC On-going 1/91 2/91 291 rff'*' 691 (1) 1190 (2) 1291 391 (3) 892 692 192 1192 (4) 693 CONTRACTOR (1) (2a) (2b) (3a) (3b) (4) CMA RPROTTPrV BREAKDOWN COSTS $ 24,000 $ 60,000 $200,000 $ 25,000 $ 25,000 $ 20,000 SEWG-Secondary Emissions Work Group AJTG-Air issues Task Group EMTG - Environmental Monitoring Task Group FISCAL YEAR 1990/91 1990/91 1991/92 1991/92 199293 199293 STAFF (Days) TRAVEL ($> OJ*^yOX-fi (> Environmental i LRQAt 770 5,400 100 6.000 27 344,000 210,000 Wv 000004959 GOAL #1, OBJECTIVE #4 - MACT STANDARDS FOR WASTEWATER TREATMENT Description of Ime and Important to Industry The Clean Air Act Amendments will result in stringent emission controls for Air Ibrics. Secondary emissions (SE) of volatile organic compounds (VOC) from industrial wastewater will require control if plant emissions exceed 10 tpy for any combination of the list of 189. EPA has not shared their vision for MACT relative to SEf but ifthey reiterate Control Technology Guidance (CTG), the Chemical Industry will be required to either cover or seal all wastewater collection systems and treatment units priorto biological units. Alternatively, VOC's can be removed by steam distillation before discharge into sewer system. Both options will be very costly. Criteria for Success 1. EPA adoption of CMA estimating procotols for SE. 2. Cost-effective control requirements. 3. Definition of MACT for WWT that is acceptable to CMA Member Companies. 4. EPA acknowledgement that biological degradation is acceptable treatment method. 5. Reasonable compliance schedule for MACT. 6. Ideally, current BDT WWT practice is acceptable. liming CAA Legislation MACT Proposal MACT Promulgation Compliance/Implementation 11/90 11/91 11/92 11/95 Options 1. Traditional advocacy methods (Reactive) - CMA could conduct reactive advocacy by commenting only after proposal, and litigating after promulgation. 2. Proactive advocacy methods - CMA could conduct proactive advocacy by drafting their own version of regulations and by actively participating in regulatory negotiations. 28 VVV 000004960 r GOAL #1> OBJECTIVE #4 - MACT Standards for Wastewater Treatment (cont.) 1 Some barriers to advocating an acceptable definition ofMACT for wastewater treatment that allows adequate ; for compliance include: possible reluctance by EPA to discuss the issue; insufficient funds and/or manpower to complete projects; - environmental lobby groups pushing for technology forcing standards for which technology does not exist; and I a two year rule making schedule limits time to interact with EPA. i : fntlf Benefit ! t*. I Compliance costs for wastewater MACT standards will be substantial. Costs niiniiiui nf an wnirli as several | hundred million dollars could be realized if advocacy is successful in producing affi rtivi control require- ' ments, reasonable test methods, and efficient recordkeeping and reporting requirements. Mrn* Elected Proactive advocacy. 29 VVV 00000*961 GOAL 1, OBJECTIVE #4 - MACT Standard for Wastewater Treatment (cont) RESOURCE NEEDS Activity Member Company Time (Days) Meetings w/EPA (three) 24 Review industry 114 responses 24 Draft SE Control Options 96 Review Method 25D procedures 32 Develop database for WWT Units (literature) 8 Develop data base for collection system (measurement) 16 Reg-Neg Participation 576 Develop Estim. Technique for collection system 48 PAVE upgrade -- Comment on proposed regula tion* 16 Review final rule Member Company Travel ($) 4,500 4.500 12,000 8,000 4,000 8,000 54.000 8,000 - 3,000 CMA Tech. Time (Days) 9 20 78 62 18 26 470 40 - 67 CMA Legal Time (Days) 10 6 5 4 3 3 46 -- 20 5 CMA Tech. Travel (t) 2,400 --* -- " 3,000 --- CMA Legal Travel ($) 2,400 3,600 Totals 840 $106,000 770 100 $5,400 $6,000 Outaide Legal dm ices ($) 10,000 Outaidf Purchaser Servie* ($ - ** - - *200,000 --* $210,000 24.00 250,00 BO.OC 92DJJC - $344,0 Responsibility SEWork Group has responsibility for most ofthe actions/projects. Liaison with Monitoring WG will also be iT portent relative to VOC Test Method 25D. Performance Measures 1. Adoption of CMA protocols to estimate SE. 2. Acceptance by EPA of CMA database. 3. Acceptance by EPA of biological degradation as equivalent to distillation. 30 VVV 000004962 GOAL #1, OBJECTIVE #5 MACT STANDARDS FOR EQUIPMENT T.FAire enhance the advocacy role ofthe chemical industry to act expediresponsibly and positively in influencing the development implementation of responsible Clean Air regulations. LlbTTrTTVE *S; Advocate for MACT standards for equipment leaks that reduce ffniini'*"* while being economically ana technically feasible. ESTIMATED RFaOTTWCW REQtTlREIHEMTg. Company Time O.P.S. CMASUfT Company Travel CMA Travel *O.L. 60 Days none 70 Days 622.000 $1,200 0 (Outside Purchased Services Outside Legal Services) yrioN Review proposed and'final tlACT stand--ds for consis tency with negotiated agreeinent and comment andfor liti gate as appropriate. RESP. CROUP FEWG PBMOMICE BRBAJmOWW STAFF (Days) Environmental IRflAL 40 30 WORK PRODUCT Comments, written recom mendations TTMTWO Fall 1991 Fall 1992 FEWG-Fugitive Emissions Work Group TRAVEL ($) 600 600 oranLs. m 0 0 31 VVV 000004963 GOAL #1 OBJECTIVE #5 - MACT STANDARDS FOR EQUIPMENT LEAKS Ttescrintinn nf lamia EPA is developing standards for equipment leaks through a negotiated rulemaking process. These standards will be issued as part ofthe MACT standards for chemical manufacturing facilities under the new Clean Air Act The MACT standards will be potentially applicable to 189 hazardous air pollutants listed in the new Clean Air Act These standards may also be used to replace existing NSPS, NESHAP, RCRA, and State rules. Importance to Industry Emissions from leaking equipment represent on average 60% of the emissions from a chemical process unit Therefore, EPA is expected to continue to focus regulatory attention on this emission source within chemical manufacturing facilities. Criteria for Succeaa Success will be achieved in the regulatory negotiation process if the promulgated rules result in reduced emissions from equipment leaks while: being economically and technically feasible; O containing performance standards instead of technology standards; resulting in quantifiable emission results; providing flexibility for alternative means of compliance; rewarding good performers; having reasonable compliance schedules; and Q being easy to understand and implement. The regulatory negotiations are expected to be completed by early 1991. EPA plans to promulgate regulations on the basis ofthe negotiated agreement within two years of enactment. The agreement is expected to contain a staggered schedule for implementingthe equipment leak regulations to all SOCMI facilities within a 12-month period. Thus, all affected facilities will have to begin implementingthe equipment leak regulations within three years of enactment. Options 1. Ttefrulatorv Negotiations - Continue participation in the regulatory negotiation process already under way. This process has been successful to date. 2. Discontinue Regulatory Negotiation ~ Discontinue negotiations and permit EPA to develop regulations. CMA input would be limited to comment and/or testimony on the proposed regulation. 32 VVV 000004964 r GOAL #1, OBJECTIVE #5 - MACT Standard for Equipment Leaks (oont.) flarricrs and Opposition Environmental groups favor "technology forcing" MACT standards. This objective must be balanced in the negotiated agreement for equipment leaks. Cast and Benefit Benefits of the emerging agreement include: avoidance of technology requirements; reduced monitoring frequency for good performance; and avoidance of enforceable violations. The cost savings associated with these features is expected to exceed $50 million annually. Actions Selected Continue paitiapation in the regulatory negotiation. RESOURCE NEEDS Activity Member Company Time (Days) Review/comment on pro* posed and final regulations 60 Total 60 Member Company Travel ($) 22.000 $22,000 CMA Tech. Time (Day*) 40 CMA Legal Time (Days) 30 40 30 CMA Tech. Travel ($) 600 $600 CMA Legal Travel <$) 600 Outside Legal Services <$> 0 Outaide Purchased Services <*) 0 $600 $0 %o Responsibility Fugitive Emissions Work Group with assistance from former members of the BENZ Work Group. Performance will be judged on the basis of the quality of IS* adopted regulations. ! 33 i VVV 000004965 GOAL *1, OBJECTIVE *6 EQUIPMENT LEAK EMISSION FACTORS GOAL *1: To enhance the advocacy role ofthe cherrucal industry to act expedi tiously, responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE : Advocate for revision of existingEPAemission factors for equipment leaks and identification and promotion of implementation by mem ber companies of low equipment leak emissions performance tech nology and operating practices. Company Time O.P.S. CMA StafT Company Travel CMA Travel O.LS. 360 Days $125,000 282 Days $140,800 $3,600 $0 (Outside Purchase Services Outside Legal Services) ACTION Build POSSES database through cooperative e/Torts of FEWG, CMA CHEMSTAR Panels, and API Perform analysis of POSSEE database PFSP GROUP FEWG FEWG Communicate results of POSSEE database analysis with EPA FEWG WQBKPBOPUCT Industry-wide database of equipment leak data TIMING (2) Present to (2) mid-1993 Contractor report/CMA analysis identifying low emission per formance technology and im proved eurisaiOQ estimation tools Minutes, written comments (3) 1991-1994 (4) (5) 1991-1994 FEWG-Fugitive Emissions Work Group POSSEE - Plant Organisational SoftwareSystem forEmissions fromEquipment (ViNTB ACTOR (la) (lb) (2a) (2b) (3) (4) (5) COSTS $6,000 $9,000 $ 3,000 $7,000 $60,000 $20,000 $20,000 FISCAL YEAR 1990/91 1991/92 1990)91 1991/92 1991/92 1992/93 199394 TECHNICAL Environmental t.FGAL STAFF (Daya) 192 90 TRAVEL ($) 1300 1300 ($) 125,000 -- VVV 000004966 34 GOAL #1, OBJECTIVE #6 - EQUIPMENT LEAK EMISSION FACTORS p*.rintionofIsie Measurement and quantification ofemissions from leaking equipment and what technology options represent low emission performance technology will continue to be ofinterest to chemical manufacfcuringfacilities because of SARA and other factors. In addition, accurate emission factors for equipment leaks will be an important element for several provisions ofthe new Clean Air Act including credit for early reduction demonstrations and residual risk determinations. Jlfifwirtaintt* to Industry Accurate quantification of emissions from equipment leaks is necessary to increase the public s confidence in release estimates. Furthermore, improved emission factors may help facilities to take advantage of negligible risk and credit for early reduction provisions in the new Clean Air Act More accurate emission factors will be ft crucial element when EPA performs residual risk determinations in the future. If emission factors overestimate fugitive emissions, facilities will be required to adopt additional controls for no reason. The identification oflow emission performance technology options will facilitate rnmplinnrfi withithr performance- based standards. ~ Criteria for Success ft** Success will be achieved ifEPA revises the existing emission factors based on information provided by CMA and iflow emission performance technology and operating practices are identified and implemented by the member companies. Timing Efforts toward improving emission quantification methods are expected to be needed throughout the five year planning period. In the short-term (in the next one to two years), unproved emission factors would be useful to facilities making credit for early reduction demonstrations. They will be essential for the residual risk determination step (approximately seven-eight years after enactment). The MACT standards for equipment leaks will require the identification of low emission performance technology within two to three years after enactment. To meet this goal, the group will need to collect, analyze, and communicate information on low emission performance technology over the next two to three years. Options 1. Collect Information Proactively - CMA has already started the development of a data base (Plant Organizational Software System for Emissions from Equipment, called POSSEE) to support this issue. API has recently indicated a desire to participate cooperatively in the POSSEE system, Tile CHEMSTAR panels also have ongoing efforts in the emission quantification area which need to be encouraged and incorporated into our advocacy efforts. We will need to follow through with the development and analysis of this data base and present the results to EPA in a timely manner. 2. ' No Action -- Accept existing emission factors and leave it up to individual companies to identify low emission performance technology to meet their compliance needs. Barriers and Opposition Lack of fiscal support for POSSEE would be one barrier to successful advocacy on this issue. Another barrier would be if insufficient data are collected through POSSEE, or data are of poor quality. 35 L VVV Q00GGA967 GOAL #1, OBJECTIVE *6 ~ Equipment Leak Emissions Factors (eont.) Post and Benefit Benefits of successful advocacy would include: appropriate application; accurate credit for early reduction demonstrations; and cooperative industry wide effort to collectinformation on low emissions performance technology, reducing the burden on individual companies. The cost savings from avoidance ofresidual risk standards for 10% ofthe industry alone is estimated to be $500 million dollars between 1995 and 2005. Actions Selected Continue efforts to build and analyze an industry-wide data base through POSSEE, and communicate the results to EPA and the membership. RESOURCE NEEDS Activity Build POSSEE database Analyze POSSEE database Communicate POSSEE results to EPA Total* Member Company Time (Days) Member Company Travel (S) 12) 55,000 160 73,000 SO 12300 360 *140300 CMA Tech. Time (Days) 78 102 12 CMA Legal Time (Days) 30 30 30 192 90 CMA Tech. Travel (Days) 0 600 1300 CMA Legal Travel (*) 0 600 2300 Outside Legal Services (*) 0 0 0 Outside Purchased Service* (*) 25.000 100,000 0 *1300 *1300 *0 *125,000 Responsibility Fugitive Emissions Work Group in coordination with CMA CHEMSTAR Panels. Performance Measures Performance will be judged on whether CMA is successful in collecting, evaluating, and communicating needed information and whether EPA revises their emission factors to take into account the information. 36 VVV 000004966 GOAL #1, OBJECTIVE #7 NSP&CTG REGULATIONS GOAL, f1: To enhance the advocacy role ofthe chemical industry to act expedi tiously. responsibly end positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE tli Advocate for the development of reasonable New Source Perform ance Standards (NSPS). ESTIMATED RESOURCE rrouirkmrnt Company Time O.P.S. CMA Staff Company Travel CMA Travel O.LS. 390 Days none 466 Days $30,000 $3,600 $110,000 "(Outside Purchased Services Outside Legal Services) ACTION Meet with EPA Baanew current NSPS Hi i sin ~new NSPS Review amftvsiBed CTGs Review MACT stndards Reviewde minimia cutoffs Review credit for early reduc tion Review acid rain Review enforcement RRSP- GROUP NSPS NSPS NSPS NSPS AT AT AT NSPS PENWG WORK PRODUCT Consensus of objectivea/EPA initiatives (minutes) Comments Comments EPA 114 Letters datable comments Comments Comments Comments EPA 114 Letters database comments Comments TIMING 691 \2m On-going Owning 2, 4, 7,10 years as approp. As approp. As approp. As approp As approp. CMA RF-SOTTRCF BREAKDOWN TECHNICAL Environmental I-F-GAT. NSPS-New Source Performance Standards Work Group AT-Air Toxics Work Group PENWG-Permitting, Enforcement and Nonattainment Work Group STAFF (Days) 216 250 TRAVEL ($) 1.200 2.400 OPAOJ-S, ($) 0 110.000 37 VVV 000004969 GOAL #1, OBJECTIVE #7- NSPS/CTG REGULATIONS Description of Issue and Importance to Industry The pending amendments to the Clean Air Act leave intact EPA's New Source Performance Standards (NSPS) program. Currently, there are approximately one-dozen pending NSPS; clearly, more are to come. The expected NSPS regulations will require significant expenditure by the Chemical Industry. The NSPS Work Group proposes to advocate the development and promulgation ofregulations for the chemical manufacturing industry which reflect the industry's concerns in EPA's establishment of: Title I (Nonattainment) issues such as current and planned NSPS rules, new NSPS rules, and new and revised Control Technology Guidance (CTGs); U Title III (Air Toxics) issues such as when industry may be required to employ "modifications'' which trigger new source requirements, use of different control technologies to limit or prevent emissions and the prevention of extreme cases of over-control, setting of limits where specific requirements apply to minor sources within a facility, control technology-control equipment availability - vs. ElPA's MACT phase-in schedules, determinations of de minimus increase in emissions for defining "modifications" (standards for new and existing sources are expected to bfethe same, where as de minimus cutoffs, size cutoffs, etc., will be evaluated as part ofthe regulatoryalternatives), NSPS for solid waste incinerators, and regulatory guidance on credit for early reduction programs; Q Title IV (Acid Rain) issues such as inclusion ofindustrial units (in possible NSPS for NOx emissions from electric utility steam generating units); and Title VII (Enforcement) issues such as general guidance and source compliance certification guide lines. Criteria for Succeaa 1. Promulgation of performance-based standards. 2. Promulgation of alternative means of compliance. 3. Promulgation of reasonable compliance schedules: including reasonable time frame for industry compliance when NSPS are proposed many years before the promulgation of final regulations. 4. Establishment of on-going dialogue with EPA and NSPS WG, and CMA members. 5. Participation in EPA Control Technology Guidance, both new and revised, which reflects actual performance in appropriate applications in industry. Timing CAA Legislation Current/Proposed NSPS rules Generic standards (proposed) Generic standards (promulgated) MACT Standards (promulgated) 40 categories 25% 50% 100% 11/90 10/91 11/92 12/92 12/94 12/97 12/00 For waste combustors, EPA must finalize NSPS (MACT) standards by 12/94. 38 VVV 000004970 gOAL #1 OBJECTIVE #7 -- NSPS/CTG Regulation* (coni.) XYnnr^^ Advocacy 1. Participate in development/drafting of regulations. 2. Influence the drafting of regulations. 3. Comment on proposed regulations/CTGs. 4. Participate in the development of information/data used to prepare CTGs. Arrive Advocacy X. Pnaride comments to EPA related to proposed regulation&'CTGs. > 2. Provide support in litigation efforts. and Opposition Some of the barriers to obtaining reasonable NSPSs are: EPA insists on built-in technology forcing MACT standards; EPA acts independently of CMA input; lack of resources at CMA; U adverse economic conditions; and lack of performance - based information. Cost and Benefit Successful advocacy on this issue will result in cost savings associated with reasonable, flexible performance standards instead of prescribed technology standards. Estimated cost savings could be as much as 50 million dollars between 1992 and 1998. Actions Selected 1 Data Collection for EPA 114 letters. 2 Develop database for CMA strategy. 3 Coordinate MACT Strategy with Air Toxics Work Group to develop a CMA strategy. 4. Comments. 39 VVV 000004971 GOAL *1, OBJECTIVE #7 - NSPS/CTG Regulations (conU Activity <1) Meeting w/EPA (2) Current NSPS (3) NguNSFS (4) Ngw/RcYiacd CTGa (5) MACT Standards (6) ne iTiinimie/eutnffil (7) reduction (8) (9) . Total* RESOURCE NEEDS Member Company lima (Day*) 18 - 290 GO 1 1 1 Mambar Company Travel ($) 5,000 - 25,000 - * mm CMA Tech. Tima (Days) 8 - 10* 64 6 6 6 CMA Legal Tima (Days) 20 30 50 50 15 15 15 CMA Tach. Travel () CMA Legal Travai (*) Outaide Legal Service () Outside Purchased Sm-vloe ($) 1,200 1,200 -- 0 10.000 - 0 40,000 0 60,000 0 * 0 - 0 .. 18 1 390 $30,000 16 40 0 * 6 IS 0 1.200 216 250 $L200 $2,400 iuo.000 -- - .. Responsibility The NSPS WG has responsibility for the development/review ofcurrent NSPS, new NSPS, new/revised CTGs, and Acid Rain regulations. The lead on MACT standards, and de minimis cut-off, is the responsibility of the Air Toxics WG, with participation by the NSPS WG as appropriate. The lead on enforcement issues is the responsibility of the Permitting, Enforcement and Nonattainment WG with participation by the NSPS WG on an "as-needed" (support) basis. Performance Measures 1. Quality and quantity of data collected (database). 2. Number of CMA comments submitted which result in changed EPA position (effective influence). 3. Number of "Wins" achieved. 4. Number of training opportunities (workshops) provided to member companies. VVV 000004972 40 r GOAL 1, OBJECTIVE *8 NONATTAINMENT ISSUES To cnhfir**1 the advocacy role ofthe chemical industry to act expedi tiously. reaponsibly and positively in influencing the development and impleUKQtatiao of responsible Clean Air regulations. flfoTFmVE #8; Advocate for the promulgation of nonattainment regulations that target sources which are major contributors to the problem, contain reasonable requirements, recognize voluntary emissions reductions and are cost effective. Company Time OP.S. CMA Staff Company Travel CMA Travel O.LA 866 Days none 961 Days *231,000 *11.300 *120,000 *<Outside Purchased Services Outside Legal Services) ^cmoNS Identify issues of concern or ioUmt Heptfly-w^or player* and target contacts Arrange to have appropriate dialogue with target contacts msgp. GROUP PENWG PENWG PENWG Meet with target contacts and provide input on CMA posi tions Review draft/proposed guid ance regulations Decide whether to prepare written commenta/testimony Decide whether to provide oral testimony to Agency Review final regulations Determine information needs Monitor on-going situation and highlight significant de velopments PENWG PENWG PENWG PENWG PENWG PENWG PENWG CMA RESOURCE BREAKDOWN TECHNICAL Environmental LEGAL STAFF (Days) 686 276 WORK PRODUCT TIMING Issue papers or other appn**^ On-going priate records List ofcontacts On-goi***, Meeting scheduled and agenda prepared or appropri ate oral/wntten communica tion transmitted Meeting minutes and position identification Issues of concern identified Oo^ofag Within 7 days of meeting Within 30 days of receipt Written CMA comments/testimony or input to other organi zation or no work product Oral testimony or no work product. Recommendations on litiga tion Budget request or project as signment Communication to appropri ate people By end ofcomment period oi as timely if no specified com ment period As timely Within 20 days of issuance oi as timely On-going On-going PENWG-Permitting, Enforcement andNonattainment Work Group TRAVEL ($) 7,100 4,200 O.P.S/O.LS. (*> 0 120,000 41 VVV 000004973 GOAL #1, OBJECTIVE *8 -NONATTAINMENT ISSUES Description of bme The Clean Air Act will result in major new requirements on sources located in nonattainment areas. These requirements range from inventory requirements to mandated percentage reductions of emissions of volatile organic compounds (VOCs), nitrous oxide (NOx) or carbon monoxide (CO). Expansion of sources in nonattain ment areas may be difficult, if not impossible due to the more stringent offset requirements. Availability of offsets will be limited due to other mandates such as percentage emission reduction requirements and more stringent emission limitations from CTGs and MACT. Nonattainment sub-set issues include: Offset Requirements, e.g., Ratio & Actual vs. Allowable; 3 Netting Issues; Permitting Guidelines/Requirements; SIP Revision Regulations; Nonattainment Area Boundary Determination Guidelines; Permit Fees; Q Sanctions; Q Inventory Preparation Guidance; 3 % Reduction Requirement-Federal Policies; Credits for Early Reduction Policy/Guidance; - State Delegation/FIP Issue; Q Major Source Definition Issue; 3 Generic Control Requirements/Levels; EPA Nonattainment Policies; Maintenance Plan Requirements; Visibility Policy; Reclassification Policies/Maintenance Plan; Ambient Monitoring Policy; 3 Source Monitoring Requirements/Policy; and VOC/NO, Tradeoffs. Importance to Industry Greater than 65% ofCMA member company facilities are located in areas classified as not attainingthe National Ambient Air Quality Standards. The 1990 Clean Air Act will expand existing nonattainment area boundaries, drawing in an even larger percentage ofthe industry. More stringent State Implementing Plan requirements wifi limit chemical industry expansion. They will also limit chemical industry customer and product growth. Requirements for the control of emissions of a facility within nonattainment areas will increase the cost of operatingoffacilities located in these areas and could disrupt competitiveness with facilities in attainment areas and in international markets. Criteria for Success The federal regulations target sources which are major contributors to the problem, i.e., equitably address chemical industry emissions in context oftotal emissions; contain reasonable requirements and schedules which allow modification/construction ofindustrial source as needed; are cost effective; and recognize and give credit for voluntary emission reductions in the percent reduction program. VVV 000004974 42 qOAL #1, OBJECTIVE #8 - Nonattainment Issues (coni.) 2jjni& Some nonattainment area requirements, such as preparation of inventories, will be implemented within one year of enactment of the amended CAA. Other requirements such as revised SIP submittals or imposition of neW CTG requirements will take place two-three years after enactment Guidance/policy/regulation to implement the new or additional nonattainment area requirements will generally be issued in the first one-two years after enactment. PA is currently formulating policy to address nonattainment area issues. ftp+inns 1. Do nothing. Read/follow the issue but take no overt action to influence outcome of the issue. 3. Read/follow and provide assistance to another association/group to influence the outcome of the issue. 4. Read/follow and take overt action to influence the outcome of the issue. The CMA Permitting Enforcement Work Group plans to invoke Options three or four dependn^ on the issue and the action deemed appropriate on each issue. gfljTjprg and Onnrwitinn Timing - The significant number of new regulations that must be issued over a short period.oTtime will make EPA even less inclined to make changes to proposed rules. Rules will be pushed through the system to try to meet statutory timetables. Resources - Company resources needed just to comply with requirements may distract resources from advocacy efforts. Associations/groups not immediately impacted may be willing to sit back and wait to see what happens to the precedent setting regulations in the chemical industry. Selling CMA positions to the regulators and the public may rest to a large extent on otherassociation's support. Attitudes - EPA's efforts to remove state flexibility and to oversee every activity in delegated programs will be a barrier to cost effective, timely, and reasonable nonattainment area requirements. Environmental groups and the public in general will want more stringent, less flexible regulations. They want zero emissions. They also want more and more information disclosed regarding operations and emissions, and want to say if, how, and when facilities are operated and constructed. States want EPA to tell them what they must do so they do not have to shoulder the burden of imposing stringent nonattainment area requirements. CMA will not be the only interest group seeking to influence the outcome of the regulations. Affiliations with other trade groups4may not be strong enough to assure "industry" speaks with one position. 43 VVV 000004975 GOAL #1, OBJECTIVE #8 - Nonatt&inment Issues (coni.) The nonattainment aspects ofthe reauthorized CAA will impact >65% of CMA member company facilities. The costs ofthe nonatt&inment provisions will be substantial as areas are required to reduce VOC emissions by 3366% from where they are now. In addition what is required in nonattainment areas will set the floor for what could be determined to be MACT under air toxics. Other policies established for nonattainment will also have important precedent setting aspects. The cost/beneflt on an item to item basis cannot be determined at this time but the return on the hours CMA projects to invest in this issue should be positive. Actions Selected 1. Meet with EPA and determine their position and plans. 2. Review draft and proposed regulations. 3. Submit comments or revised draft regulations. RESOURCE NEEDS Activity Work Group mectmgs'position development Preparation of Comments Meetings with EPA and other trade associations Litigation, if necessary Totals Member Company Time (Days) 270 Member Company Travel ($) $154,000 460 0 135 $77,000 -- -655 $231,000 CMA Tech. Time (Days) 250 CMA Legal Time (Days) 70 CMA Tech. Travel ($) 0 316 120 0 120 60 7.100 -- 35 -- 686 275 $7,100 CMA Legal Travel ($) 4.200 $4,200 Outside Legal Services ($) -- Outside Purchased Services ($) 0 90,000 0 0 30.000 $120,000 $0 Responsibility The primary responsibility for all elements concerning nonattainment policy rests with the Air Permitting and Enforcement Work Group. Elements of the nonattainment regulations regarding modelling, monitoring, or specific control technique requirements are handled by other CMA groups. Performance Measures Performance will be measured by inclusion in EPA policy and regulations of reasonable requirements and schedules and consideration of cost effectiveness and voluntary reductions. VVV 000004976 44 GOAL 1, OBJECTIVE # 9 PERMITTING ISSUES flOALil; To enhance the advocacy role ofthe chemical industry to act expedi tiously, responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE ffr Advocate for the development of a federal permit program that allows and encourages states to avoid multiple permits for the same source; contains reasonable application requirements and schedules; encourages permit issuance in a timely and cost effective manner; embraces rather than replaces good state permit program elements; and recognizes and encourages voluntary and innovative control ef forts. Company Time OJ.S. CMASUfT Company Travel CMA Travel O.LS. 886 Days $36,000 1031 Days $241,000 $14,300 $100,000 (Outside Purchased Services Outside Legal Services) ACTION Identify issues of concern or interest Identify major players and target tIntis at EPA and in States Arrange to hose appropriate dialoguewith tHpO contacts HB&rar PENWG/SAC PENWG/SAC PENWG/SAC Meet with target contacts at EPA and State agencies and provide input on CMA posi tion* Review dra/Vproposed guid ance/regulations from EPA and priority States Decide whether to prepare written comments'testimony to EPA or State agencies Decide whether to provide oral testimony to EPA orStatc agencies Review final regulations Determine information needs Monitor on-going situation and highlight significant de velopments PENWG/SAC PENWG/SAC PENWG/SAC PENWG/SAC PENWG/SAC PENWG/SAC PENWG/SAC WORK PROmiCT Issue papers or other appro priate records List ofcontacts TTMTNG (1) On-going On-going Meeting scheduled and agenda prepared or appropri ate oral/written communica tions transmitted Meeting minutes and position identification On-going Within 7 dsys of meeting Issues of concern identified Written CMA comments/testi mony or input to other organi zation or no work product Oral testimony or no work product Recommendations on litiga tion Budget request or project as signment Communication to appropri ate people Within 30 days of receipt By end of comment p nod or as timely if i specified comment p riod. As timely Within 20 days of issuance or as timely On-going (2) On-going CONTRACTOR (1) (2) 1URCE BREAKDOWh TECHNICAL Environmental LEGAL STATE AFFAIRS COSTS $20,000 $15,000 STAFF (Days) 681 350 100 PENWG-Permitting, Enforcement and Nonattainment Work Grm SAC - State Affairs Committee FISCAL YEAR 199091 199091 TRAVEL ($) 7,100 4,200 3^)00 OJ^/OLS. 35,000 100,000 0 45 VVV 000004977 GOAL # 1, OBJECTIVE # 9 - -PERMITTING ISSUES Description of Issue The Clean Air Act Amendments will result in new and additional permit requirements which will affect essentially all of the chemical industry. Some of the new requirements include specific permits for emissions of air toxics and new permit requirements in nonattainment areas. Permit fees of approximately $25/ton of regulated pollutant will also be mandated. Due to the degree of EPA and public involvement in each permit, significant delays in obtaining permits are anticipated. State programs are expected to be even more overloaded because ofthe new requirements. States must accept the new permit program and will have only a limited amount oftime to review and submit Plans for permitting programs to EPA for approval. Although EPA has expressed an interest in retaining as much of each state's existing program aspossible, it is probable that many states will require extensive Plan changes in order to meet the minimum requirements. If states fail to submit the plans on time or to submit approvable plans, industry may be subject to sanctions. States will likely have an influence on EPA's regulations and program requirements. Permitting sub-issues to be followed include: Q Standard Application Form; Q EPA Permit Program Guidance for Nonattainment/Air Toxics/Accidental Releases; 3 Permit Fee Guidance; Application Submittal Schedule; 3 Completeness Determination Guidance; Q Recordkeeping/Reporting Guidance; 3 SIP Revision Regulations; 3 PSD Permitting Policy & Guidance (De minimis. Permit Applicability Regulations); Visibility Policy; 3 Construction Permit/Operating Permit Interface Guidance; Public Notice/Public Hearing Procedures; 3 Air Toxic Permitting Policy; 3 Nonattainment Permitting Policy; 3 Acid Rain Industrial Source Permitting Policy (Allowances); 3 Area Source Permitting (Exc. Mobile Source) Policy; Permitting Exemptions (De Minimis, Source Type, e.g., labs); 3 Generic Control Requirements/Levels; 3 Permit Hammers; and Credit for early reduction. Importance tn Industry The permitting provisions of the Clean Air Act Amendments will have a profound effect on the industry as a whole as well as on individual companies and facilities. Significant resources will need to be dedicated to new and expanded permitting activities to satisfy state and/or federal requirements. These include resources to review and understand revised state and federal regulations, implementing the technical and financial aspects ofthe new permit program, resources to handle public notice and potential comment on each permit requested, to protect permits once issued through possible citizen suits, and financial resources for fees on each ton of regulated pollutant. Because ofthe potential overlap ofpermittingrequirements between PSD/nonattainment, air toxics, NSPS and NESHAPs, it is imperative that state permitting programs be streamlined as much as possible, in order to lessen the burden both on the regulated community and the regulatory agencies. Industry will otherwise face redundant and lengthy permit problems which could result at best in a no growth situation or in the worst case a noncompliance or shutdown situation. VVV 000004978 46 GOAL #1* OBJECTIVE # 9 - Permitting Issues (cont.) pp^ria for SucceaB The federal permit program avoids multiple permits for the same source, i.e., a separate state permit is not required for air toxics, for nonattainment, for NSPS, etc.; contains reasonable application requirements and schedules, i.e., criteria for application completeness is established; encourages permit issuance in a timely and cost effective manner, e.g., review times are established, fee calculations are based on justifiable criteria; embraces rather than replaces good state permit program elements already in existence, e.g., exemptions for some source categories and operations, flexibility to substitute chemicals within process units; and recognizes and encourages voluntary and innovative control efforts. Timing EPA is already drafting or is assimilating data to begin drafting regulations in support of the Clean Air Act Amendments. Therefore, the need for CMA meetings/discussions with EPA, STAPPA/ALPCO, priority State regulatory officials, and others which influence regulatory development is current. Within 12 months of enactment, EPA will be required to propose the minimum standarda/requirements of a permit program which states will then be required to include in their revised SIPS within a 2 year period. 1. Do nothing. 2. Read/follow the issue but take no overt action to influence outcome of the issue. 3. Read/follow and provide covert assistance to another association/group to influence the outcome of the issue. 4. Read/follow and take overt action to influence the outcome of the issue. The CMA Permitting/Enforcement Work Group plans to invoke Options 3 or 4 depending on the issue and the action deemed appropriate on each issue. Barriers and Opposition Timing - The significant number of new regulations that must be issued over a short period of time will make EPA even less inclined to make changes to proposed rules or guidance. Rules/guidance will be pushed through the system to try to meet statutory deadlines. States will be expected to modify existing permit programs or develop new programs within specified short time frames, which could limit industry's opportunites. Resources - Company resources needed tojust comply with requirements may distract resources from advocacy efforts. Associations/groups not immediately impacted may be willing to sit back and wait to see what happens to the precedent setting regulations in the chemical industry. Selling CMA positions to the regulators and the public may rest to a large extent on other association support. Attitudes - EPA's efforts to remove state flexibility an to oversee every activity in delegated programs will be a barrier to cost effective, timely, and reasonable permit requirements. The legislative language developed by Congress may preclude some desirable permitting elements. 47 vvv 000004979 GOAL #1, OBJECTIVE # 9 - Permitting Imum (coni.) EPA staffers already have preconceived ideas regarding the regulatory language they want and changingtheir minds may be difficult. CMA will not be the only interest group seeking to influence the outcome of the regulations. Affiliations with other trade groups may not be strong enough to assure "industry" speaks with one position States want EPA to tell them what they must do so they do not have to shoulder the burden of defense on imposing stringent permit requirements. Environmental groups and the public want more stringent less flexible permit requirements. They want zero emissions. They also want more information disclosed regarding operations and emissions, and they want a say in if, how and when facilities get construction and operatingpermits. These groups also want tojudge the merits of issuing permits on abstract rather than technical criteria. and Benefit The permitting aspects of the reauthorized CAA will impact all major sources. The costa of the program to industry are directly proportional to extent of and reasonableness ofthe new requirements. Cost/benefit on an issue by issue basis cannot be determined at this time. CMA forecasts investing in this issue are expected to be positive. Actionh Selected 1. Meet with:EPA. and determine their position and plans, and provide input. 2. Review draft and proposed regulations. 3. Submit comments on revised or draft regulations, and on emerging positions. 4. Litigation, if necessary. WV 000004980 48 GOAL #1, OBJECTIVE 19 - Permitting Issues (cont.) RESOURCE NEEDS Activity Member Member Company Company Time Travel (Days) ($) Work Group meetings/ position development 430 $154,000 preparation ofComments 300 0 MMiingi with EPA end.. otterWrude association**- 136 $77,000 Meeting with CICs end State regulatory sgendes SO 10.000 litigation, if necessary Totals Y 886 $2414)00 CMA Tech. Time (Days) 264 206 119 10 *681 CMA Legal Time (Days) 80 140 70 10 60 350 CMA State Affairs Time (Days) 90 20 0 50 0 100 CMA Tech. Travel ($> 0 0 7,100 0 0 $7,100 CMA Legal Travel ($) 0 0 44200 0 0 $4,200 CMA State Affair* Travel <$) Outside Legal Service* (*) Outside Purchase Services (S) - $36,000 0 0 70,000 0 0 * 0 3,000 0 0 0 30.000 $3,OOS~*-$M>OtOOO $35,000 Bfisjunbilite The primary responsibility for all air permitting issues (including construction or operating permits for air toxics, nonattainment, attainment, NSPS, NESHAP, and acid rain) is assigned to the Permitting, Enforcement and Nonattainment Work Group (PENWG). The PENWG will coordinate with the State Affairs Committee on activities related to individual State permitting programs. PftTformnnfle Successful advocacy will be measured in terms of whether Feder&l//State permit programs contain features to ensure simple, straightforward permitting requirements that are consistent with existing programs and voluntary efforts. 49 WV 000004981 GOAL 1, OBJECTIVE #10 ENFORCEMENT ISSUES GQALLL To enhance the advocacy role of the chemical industry to act expedi tiously, responsibly ana positively in influencing the development and implementation ofresponsible Clean Air regulations. OBJECTIVE *10: Advocate for the establishment of enforcement criteria that are rea sonableand fair, differentiate penalties byseriousnessofoffense; and do not abridge the protection of the Constitution regarding self in crimination. Company Tima OPA CMA Staff Company Travel CMA Travel O.I*S. 647 Days to 406 Day* $40,000 to $40,000 (Outside Purchased Services Outside Legal Services) ACTION Identify issues of concern or interest Incorporate legal concerns into CMA commente/testimony on permitting and nonattainment Marling* with other associa tions, EPA, and DOJ RESP. GROUP LEAD/SUPPORT PENWG/OGC PENWG/OGC PENWG/OGC wrtpg pwr,nnr-r Issues identified andconcerns communicated to legal group Written CMAcommenta/testimony or input Summaries of meetings TIMING On-going By end ofcomment period or as timely ifno specified com ment period On-going PENWG-Permitting, Enforcement and Nonattainment Work Group OGC-CMA Office of General Counsel TECHNICAL Environmental I-EfSAr. STAFF (Days) 106 300 TRAVEL (*> 0 0 ojpjs/ojs. (S) 0 40,000 VVV 000004902 50 GOAL #1, OBJECTIVE #10 - -ENFORC: NT ISSUES jft.yrint.nn of Iaaue The new Clean Air Act amendments are breaking new ground in criminal enforcement and in some instances raise substantial constitutional issues. A few examples are: the imposition of penalties on a "per day" basis resulting in excessive fines and possibly prison terms for relatively minor infractions. Some of these may well contravene the protection ofthe 8th amendment against "cruel and unusual punishment". The requirements to keep records and report violations may also infringe on an individual s right under the 5th amendment against self-incrimination. The broad authority under the act jeopardizes plant managers and the continued operation offacilities even if there are only minor technical violations. The primary concerns under civil penalties are excessive fines and orders to shut down operations. Underthe Clean AirAct, agencies are empowered to issue Administrative Penalties, Field Citations, and awards for information leading to penalties. The proposed scope of authority under the Clean Air Act far exceeds that granted the agency in other statutes. Fnfn--nrnt sub-issues to be followed include: Q. Criminal Penalty Policy/Guidance; CL CSvffPenalty Policy/Guidance: Administrative Penalty Policy/Guidance; Bounty Hunter Provisions; Q Citations; Calculation of Penalties; Q Sanctions; FIPS; Recordkeeping/Reporting; Compliance Audits; and Inspections. v. ' 7^.' Importance to Industry Criminal penalties of up to $25,00G/day and/or possibility of imprisonment of one or more years per violation, for even minor technical violations, is a significant concern to managers offacilities operating in the U.S. This issue warrants high attention. There is also potential for plant shutdown as part ofthe enforcement provisions. Criteria for Success 1. Enforcement provisions in federal criteria and guidance differentiate penalties for seriousness of offense. 2. Audits, inspections and other information gathering and selfreporting activities required under the CAA amendments do not abridge the protection provided by the constitution related to self incrimination. tuning Impact immediate upon enactment of the CAA amendments. Also the specific impacts of the enforcement provisions need to be considered as other elements ofthe CAA amendments are implemented in the SIP revision guidance and in individual standards or regulations for source categories. 51 VVV 000004983 GOAL #1, OBJECTIVE #10 - Enforcement Issues (cont.) Option# 1. Do nothing. 2. Read/follow the issue but take no overt action to influence outcome of the issue. 3. Read/follow and provide assistance to another association/group to influence the outcome of the issue. 4.. Read/follow and take overt action on behalf of CMA to influence the outcome of the issue. The CMA Permitting/Enforcement Work Group plans to invoke Options 3 or 4 depending on the issue and th( action deemed appropriate on each issue. Barriers and Opposition Timing - The enforcement requirements may, upon enactment, immediately impact industry. Resources - EPA and/or DOJ may be unwilling to work on a work product that is not required and limits thei flexibility/discretion in penalties. Attitudes - Environmental groups and the public may be unreceptive to any guidance/provisions that alio alternatives to the moskstringent enforcement action to be made against a company. Cast and Benefit Ifone year of a chemical industry officer's time in prison could be avoided, the benefit would be significant, fro the individual's perspective, from the company's perspective, from an industry perspective and from the CNf perspective. Actiftpfi Selected The Permitting/Enforcement Work Group will help the legal group formed by CMA's Office of General Count to handle air enforcement concerns to identify enforcement issues in the legislative language and in polici guidance and regulations issued by EPA Work products ofthe legal group will be used to strengthen commei prepared on permitting and nonattainment issues. 52 VVV 000004984 GOAL #1* OBJECTIVE #10 - Enforcement Issues (eont.) RESOURCE NEEDS Activity Subgroup meetingm/poeition developmeat/eomment development. Work group review ieeuee/commenu Meeting* with EPA DQJ, other bade eMOmslMa*. Utigtffcv Tstate Member Mrmhnr cm%% Co?KSS (Days) <$> 440 20.000 67 10JXK) 40 10,000 -- -647 $40,000 CMA Tech. Time (Day*) 82 13 10 - 106 CMA Legal Time (Day*) 100 CMA Tech. Travel ($> 0 CMA Legal Travel () 0 100 - - 60 0 60 -800 $0 0 $0 Outside Legal Service# <) 0 Outalde Purchased Service* (9) 0 -00 4000*4 $40,000 $0 Responsibility Criteria development will be handled by CMA legal group with assistance from the Permitting, Enforcement and Nonattainment Work Group. Review offederal SIP provisions that may include enforcement aspects will be managed by the Permitting/Enforcemert Group. Primary responsibility for comments to the agency on technical control standards which may also address enforcement/compliance issues would rest with the group * assigned responsibility for preparing comments on that issue. The Perraitting/Enforcement Work Group would be available as a reference source or consultant to other groups as requested. Performance Measures Performance will be measured by whether EPA considers CMA's input in development of reasonable Constitutional enforcement provisions. 53 000C04985 <>86*00000 AAA *9 0 0 000*92 (t) STOfSTcTO 009 009 002*1 ($> 13AV1U 26a 661 HYdA avoBU dnaiQ *M OTOlO*OMO SaioS-uo 9661-6661 26/9 (l) 26-1661 1661 9MRQ, sajoa Sa^aajq siaaannoa/Xacnitisaj, uodaj jopviiaos ajoa aaaipaan* doqupo^ rnaarmoQ Z^lQdd SSOii 09 Bl 6B <**<!) -JjTVT.R 000*92$ SIS03 TVOU'l Xwj*g ? mraaH inuauiooiiAug TV3THH5IIX (1) 90I9Vdi\09 OMO OMO OMO OMO OMO JH0S) JB9H sansst pj*ptr*i aaozossnosip oi Vd3 ifliM *8in jaam fvuuqfcn at aiaapivv^ s8tn qaam 0VSV3 l* siaauiuioo aanuM iiuiqns pa* XjnB3i- pjipmM aaozo am jo sauoj aApvtaaii* i*niAg pj*pa*i aaozo aqi jo *atAai ixau joj doq*qjo* paiosuods*vd3 in a)*dpiv*<l pjvpow aaozo aifl o) tau*ip poeod aid ao inaamioo pa* MOtAag NOU.3V (taovuag |8aq aptvmo saouuag pa**qainj apwvK))* 0 00**2$ 000'*Z$ ioi 000*92$ Aa OL sno* \M2 vwo iaA*4j, Xudmoo jjas vwo S*dO* awi XavdaioQ 'pjvpm^s aaozo sip <n `Amsaoau ji `saSxraip aijrjuapz panes joj aj*oo*pv !tti aAiioareo 'noQvinSai Jiy cnra^ ajqnvodm jo aoimaacnaidtnt pa* iaaoido[9ASp uuaan[}ui in XiaApwod pa* *iqi*aodsi `Aisnoii -ipadza v* 0} .Crjsnpai (sannaip aqjjo {cu ajwooap* aqi aoavqaa oj. SdHVONVXS 3NOZO XN3iaWV II* 3A1L33THO *1* TVOO GOAL #1, OBJECTIVE #11 - AMBIENT OZONE STANDARDS nf Itunt* Continued research on ozone health and ecological effedsmay indicate the need to change the ozone standards to now reflect health/ecological information such as apmsible lower 1 -hr standard of0.10 ppm and a possible g hours or longer standard. jmr~Wj,nne TnduBtrv A change ofthe ozone standard (either a lower standardor a different form of the standard) will certainly add many more areas into a nonattainment designation. fVttorin for fitaceeag Any changes to the ozone standard will have a soud scientific basis including, where appropriate, a consideration of costs and true exposure. Timing The ozone standard is expected to be reaffirmed during 1991. No change in existing form is expected, but a range may be proposed for discussion purposes. Work on a different form ofthe ozone standard is expected to continue and to be included in a new ozone standard assessment beginning in late 1991 continuing until 1994. Options L . Do nothing. 2. Ttaartive, become, involvedwhere approproate. r:. V 3. Proactive involvement: requires greater commitment from members and staff. Barriers and Opposition. 1. EPA does not accept our input. 2. Lack of ozone experts within CMA member companies to serve on work groups. Cost and Benefit A change to-the ozone standard (either a lower standard or a different form of the standard) will likely result in increased compliance costs to industry as a result of State regulations on stationary sources designed to achieve the revaaedstandard. Successful advocacy on this issue will help limit costs to industry to the minimum level needed to attain a scientifically based standard. 55 VVV 000004987 GOAL #1, OBJECTIVE #11 Ambient Ozone Standards (eont.) Actinnw Selected 1. Maintain on-going dialogue with EPA regulators and ozone researchers to follow new and pending Os related issues. 2. Participating in EPA SAB/CASAC Meetings and presenting testimony as needed. 3. Interface with API and other trade associations as appropriate to define common issues. RESOURCE NEEDS Activity Review Standard. Workshop Evaluate Alternative Standards CASAC Pmticipation Meeting with EPAnother associations Totals Mambar Company Tima (Day*) 22 9 6 18 15 70 Member Company Traval (*) *7,500 3000 0 5000 7,700 *24,000 CMA Tech. Time (Days) 1* 6 6 14 13 57 CMA Legal Tim# (Days) 15 5 6 15 10 50 CMA Tech. Travel (*> 0 600 0 600 600 *1000 CMA Lagal Travel <#) 0 0 0 0 600 $600 Outside Lagal Sarvtoas (*) ---.. *0 Outside Purchased Sarvtesc (*) 0 0 *25,000 0 0 *25.000 Responsibility The Ozone Work Group with the involvement and coordination of the Health & Safety Committee. Performance Measures 1. No change in existing ozone standard in 1991 review, unless scientifically valid. 2 New ozone standard that is scientifically based and considers cost and true exposure. VVtf 00000*988 GOAL #1, OBJECTIVE #12 OZONE ATTAINMENT STRATEGY To enhance the advocacyrole ofthe chemical industry to act expedi tiously. responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. nftirrTIVE *12: Advocate for reconsideration of EPA's current ozone attainment strategy to properly account for NOx controls, contributions of area, nykiu, and biogenic sources, and ozone and precursortransport and other atmospheric transformation phenomena. Company Time OJ.S. CMA Staff Company Travel CMA Travel O.S.L. 63 Days S30.000 110 Days $21,000 *1300 0 (Outside Purchased Services Outside Legal Services) ^ction setsw and comment on tech nical studies and/or EPA guid ance and regulators for SIP* EsnhiatetMQ^'eeraus VOC Informal meetings with EPA to discuss ooone attainment strategy iaaoes owe OWG OWG work ppomwrr Comments Contractor report Maeting mim1*** TTMINO 1991-1996 (1) &62 On-going CONTRACTOR (1) CMA RFSOI7RCF RRFAKOOWN TECHNICAL COSTS $30,000 STAFF (Days) 60 50 OWG-Ocone Work Group - 1991^2 TRAVEL ($) 1300 600 O.P.Sj'OJLmS. ($) 30,000 0 57 VW 00G0049B9 GOAL #1, OBJECTIVE #12 - OZONE ATTAENTMENT STRATEGY Description of lamie and Importance to Industry EPA currently is operating under an ozone strategy developed in 1986 which describes specific actions intended to improve efforts to reach attainment. This plan will be revised to incorporate new scientific findings and the new requirements ofthe Clean Air Act. The plan will probably look at emissions inventories, the contribution of NO, to the formation or reduction of ozone and the relative contribution to air quality from all sources, e.g., motor vehicles, area sources, industrial plants, and biogenic sources. The results will determine what must be controlled and to what extent. Since most ofthe chemical industry is in ozone nonattainmentareas, this strategy could have a large impact on industry activities. Criteria for Siiceeaa Development of a strategy which accurately reflects: Q the relative contribution of each source of emissions to total ozone levels; Q the value of reducing NO,; and Q the actual levels of ozone by area. Xuaias Major activities to revise or let stand the current ozone standard will probably occur in 1991. A new ozone strategy (with or without a new standard) will probably be developed over the next two to three years. Options 1. Do nothing. 2. Review and comment on EPA strategy. 3. Review and comment on EPA strategy and evaluate NO, versus Volatile Organic Compounds (VOC) controls. 4. Coordinate with API and other trade associations. Barriers and Opposition Interests of CMA may conflict with those of other trade associations, e.g.. Motor Vehicle Manufacturers Association; lack ofozone experts within member companies to serve on CMA work groups; EPA refusal to alter assumptions in strategy so that it may complete the strategy by an early date. Pont and Benefit A shift in EPA's ozone attainment strategy emphasizing NO, control instead ofVOC control, for example, could have substantial cost impacts. If CMA's work on this issue shows that a shift in the ozone attainment strategy is scientifically invalid, the industry could save significant resources by avoiding unnecessary NO, control requirements. Anions Selected Options three and four were selected. 58 VVV 000004990 GOAL lit OBJECTIVE #12 - Ozone Attainment Strategy (oont.) RESOURCE NEEDS Activity jtcrfeir and comment os atudiea/ ptdanc^SlP regulations Evaluate NOx vs. VOC controls Meetings withEPA/otherassociatione Totals Mombar (Days) ao ao 13 63 Member <> S12.000 CMA Tech. Time (Days) 34 CMA Legal Time CDeya) ao CMA Tech. Travel () 0 CMA Legal Travel (9) 0 Outside Legal Service* ($) Outside PnirhastMl Batik, as ($) 0 S4.000 16 16 0 0 r.-lw0 10 16 SL200 600 -- $30,000 0 tiuooo 60 60 f!20 -r' $600 a $30,000 TWnonsihilitv The Ozone Work Group will have the lead but will coordinate with other work groups in the Technical department, as appropriate. Measurement of Performance Development of a strategy which accurately reflects: the relative contribution of eactrsvurce of emissions to total ozone levels; the value of reducing NOx; and the actual levels of ozone by area. 59 VVV ^0000499| GOAL 11, OBJECTIVE *13 RESIDUAL RISK COALfI To enhance the advocacy rale of the chemical industry to act expedi tiously, responsibly and positively in influencing the development and implementation of responsible Clean Air regulations. OBJECTIVE ftlS: Advocate for a residual risk determination procedure that accurately identifies read risks posed to a community. ATED RESOURCE CbmjFMny Time CMA Staff Company Travel CMA Travel O.L.S. 1.021 Day* *726.260 487 Days *121300 *6300 *31300 *(Outside Purchased Services Outside Legal Services) ACTION Establish Ride Assessment/Management Coalition Interact with NAS Study on risk assessment Coordinate industry input to RARM Commission Interact with EPA risk assess men! study. Mwtiiw with EPA on three-tiered appraam and reasonable model protocols Beview HEMS Mode] revisions Evaluate EPA's developing "Toxic Expected Exceedances" (TOXX) modeling approach Review EPA risk assessment guidelines for cancer and other acute and chronic health endpoints Assess impact of exposure as sumptions on risk Interact with NAS study on hu man exposure to airborn toxicants Develop alternatives to ultra con servative exposure assessment Exposure in residual risk standards Establish acceptable methods to assess dermal exposure Monitor developments in expo sure policy Monitor and interpret research on health effects of air toxicants Facilitate or collaborate in community health research EPA Study monitor synthesize and interpret research on the health effect* of air toxics, photooxid&nls and acid aerosols ADSG RATG ADSG RATG EATG ADSG RATG ADSG RATG ADMWG RATG EATG ADMWG ADMWG RATG EATG EATG EATG EATG EATG EATG ETC ETC ETC work PRomrrr Meetings, reports Meetings, reports TEWING (1) On-going (2) 191-1293 Meetings, reports, legislative (3) 4/92-12/93 records Meetings, reports (4) 11*2 Meetings 1/91-96*' Meetings, comments contractor report Contractor report (5) 6/91 1292 (6) 791 Comments, meetings (7) 291 Contractor reports (8) 691 Comments 191 Contractor reports (9) 591 Contractor reports Position papers, workshops (10) 192-1292 (11) 1291-1292 Meetings, comments 191-95 Contractor reports meetings Meetings. contractor reports Contractor reports meetings (12) 191-94 (13) 192-1295 1/91-94 AHSGR - Ad Hoc Study Group on Risk RATG ~ Risk Assessment Task Group EATG - Exposure Assessment Task Grou p ETG -- Epidemiology Task Group ADMWG - Air Dispersion Modeling Work Group 60 VVV 000004992 GOAL *1, OBJECTIVE #13 -Residual Risk (eont) CONTRACTOR (l) (2) (3> (4) (6a) (6b) (6) (7) (8) (9) 111) (12) (13) fTMA RESOURCE HHEAKDOffN TECHNICAL Environmental Health & Safety** T.TOAT- COSTS * 37.000* t 37.600* S 37.600* $ 37.500* $ 40.000 * 25,000 $ 20,000 $ 40.000 $ 40,000 $ 60.000 t 5,000* t 5.000* $ 6.000* $ 26^60* S 12.600* S 6.250* $ 16.000 $ 26,000 $ 60,000 t 60,000 60.000 $ 60.000 * 18,750* $ 6.250* $ 6.250* STAFF (Days) 77 286 124 TRAVEL (8) 2,400 3,600 600 FISCAL TEAR FY 91/92 FV 92/93 FY 9V94 FY 94/96 FY 92/93 FY 92/93 FY9203 FY 91/92 FY 92/93 FY 91/92 FY 91/92 FY 92/93 FY 93/94 FY 90/91 (FUNDED) FY 90/91 FY 91/92 FY 92/93 FY 91/92 FY92/93 FY 91/92 FY 92/93 FY 93/94 FY 92(93 FY 93/94 FY 94/96 01*3/0X8. (*) 130,000 596,250 31.600 Projects will support multi-media programs. Total costs have been divided by 4 to reflect pro-rated share for dean Air Act programs. Hours shown reflect pro-rated share for air programs. Actual resources will be higher. 61 WV 000004993 GOAL #1, OBJECTIVE #13 - - RESIDUAL RISK rteacrintion of Ttn and Importance to Industry The Clean Air Act Amendments requires a review and re-evaluation of federal risk assessment and management activities and the appropriate use of these practices in regulating chemicals. This review will occur in the following phases: 1) a National Academy of Sciences (NAS) will review the risk assessment methodology used by EPA to determine the carcinogenic risk associated with exposure to hazardous air pollutants; 2) A Risk Assessment and Risk Management (RARM) Commission will be formed to address policy implications and appropriate uses of risk assessment and risk management in regulatory programs under various Federal laws and will prepare legislative recommendations to Congress; 3) an EPA study (in consultation with the Surgeon General) on appropriate methods for calculation residual risk and the public health significance of the calculated risk and technology and commercially available methods and costs of reducing such risks. The study may include legislative recommendations; and 4) If Congress fails to act on legislative recommendations within 8 years, a residual risk standard of 1 x 10* (to the individual most exposed) would be established. This multi-stage review will result in acceptable risk approaches being established that would cover not only air toxics but also regulation of chemical under other statutes and Federal agencies. All chemical industry operations that result in exposure of communities and workers to potentially hazardous compounds may be affected. Criteria for Success EPA adoption of a flexible risk assessment process that incorporates all available information and includes consideration of costs, expected benefits, limits oftechnology, potential negative effects ofregulation, and risks ofalternative management options. Xuninft CAA legislation National Academy of Sciences study Risk Assessment and Management Commission EPA risk assessment study Residual risk standards Compliance/Implementation November 1990 February 1991 May 1992 November 1992 November 1996-1998 November 1998-2000 Ontinna Reactive 1. Comment only after commission and study reports and proposed regulations 2. Litigate after promulgation of residual risk standards Proactive 1. Develop recommendations for improving the risk assessment process (position papers and legislative rec ommendations) 2. Reg.-Neg. participation 62 VVV 000004994 #1, OBJECTIVE <13 --Residual Risk (eont.) Barriers to a residual risk procedure that accurately identifies real risks posed to a community may be: insufficient funds and/or manpower to complete projects; Q Environmental lobby groups advocating for unreasonable residual risk standards that do not distinguish between carcinogens and non-carcinogens; and EPA may be unwilling to alter its course based on CMA input |WndBenefit The total cost to industry ofresidual risk standards will be a function ofhow many sources exceed unaccpetable residual risk levels after MACT. This, in turn, is strongly influenced by the residual risk determination methods. Successful advocacy to ensure reasonable risk assessment and modeling methods could have a significant impact on the number of affected sources as well as the stringencyof the.'sasiduaJ risk standards themselves. Xrrtinnn Selected Proactive advocacy through development and forwarding of recommendations was selected. 63 VVV 00000^995 GOAL #1, OBJECTIVE *13 - Residual Risk (eonU RESOURCE NEEDS Activity Member Company Time (Days) Member Company Travel (8) CMA Tech. suer (Days) Risk Asaessment/Management Coalition NAS Study RARM Commission EPA Study 422 4,800 42 9,000 38 19.000 90 9.000 58 25 19 21 RAIG HEMS Model EPA risk assessment guidelines for can* cer and other health endpoints 15 4,500 10 19 3,750 14 EATG Impact of Exposure Assumption on Risk PhaseTl Phase III Ultra conservative Exposure Assessmeat HEMS Model Dermal Exposure Exposure Policy NAS Study Residual Risk 12 1,350 4 48 2,026 5 15 875 10 24 2.400 8 - -- - 2 300 2 18 5.400 10 50 6,900 22 F.PTTG Air Toxica health research Community health research 130 9,000 60 38 3,500 18 ADMWG Support of 3-tiered approach Evaluate HEM2 Model 12 10,000 23 15,000 12 34 Evaluate TOXX model approach 23 15,000 31 Totals 1,021 *121300 363 CMA Legal Staff (Days) 11 15 5 5 5 4 1 1 2 3 2 5 5 15 25 20 124 CMA Tech Travel (> CMA Legal Travel <*) Outaide Outside Legal Purchased Services Services (*) <*) -- 0 1Z500 150.000 *- 0 5,000 40,000 0 5,000 25,000 900 0 5,000 20,000 1300 600 0 0 1,250 -- 15,000 0 26,250 .- 0 0 0 0 -- * * 0 750 18,750 600 0 * 0 0 0 76,000 - 0 0 - 0 2.000 -- 0 0 15.000 600 0 300 0 0 180,000 0 31,250 0 1,200 1,200 *6,000 0 0 0 *600 *31,500 0 80,000 60,000 *726,250 VVV 000004996 64 GOAL #1, OBJECTIVE #13 -- Residual Risk (cont.) fl^nangjhilitv Hie Ad Hoc Study Group on Risk, RATG, and EATG has responsibility for the actions/projects as detailed above. These groups will liaison with other trade associations and EMC task and work groups as indicated. 1. NAS support for alternative risk assessment procedures and using all available information to assess potential risks. 2. RARM recommendations to use risk assessment tools to set priorities across federal activities to ensure significant threats to public health are reduced; and risk management decisions (control of chemical emissions) incorporate socio-economic, cost/net health benefit, and technical feasibility. 3. ' IfEPA and the Surgeon General demonstrate that the potential public health threat posed by the chemical industry is minimal and decreasing. 4. Federal agencies and Congress incorporate the above process into regulatory and legplative policy. 65 WVV OOOOO4997 GOAL #1, OBJECTIVE 14 AIK QUALITY MODELING GUIDELINES GOAL *1: To enhance the advococacy role ofthe chemical industry to act expe ditiously. responsibly aod positively io influencing the development end implementation of responsible Clean Air regulations. OBJECTIVE #14 Advocate for air quality modeling guidelines that result in reason* able, resource-effective models and model application rules. Company Tims OJ.S. CMA StafT Company Travel CMA Travel O.LS. 24 Days $99,600 90 Days $25,000 0 o <Outside Purchased Services Outside Legal Semcee) ACTION Comment on 1990 proposed Evaluate area and volume source models Comment on 1993 proposed revisions to Guidelines REAP. GROUP ADMWG ADMWG ADMWG CONTRACTOR (1) (2) (3) TECHNICAL Environmental LEGAL COSTS $30,000 $34,500 $35,000 STAFF (Day*) 40 50 WORE PRODUCT Written and oral comments Contractor report Written and oreal comments TIMING <U 3/91 (2) 291 (3) 3/94 ADMWG-Air Dispersion Modeling Work Group FISCAL YEAR 1990/91 199091 1993/94 TRAVEL (!) 0 0 O.P.S. ($) $99,600 0 66 vvv OOOOOA99B GOAL #1, OBJECTIVE #14 - - AIR QUALITY MODELING GUIDELINES flirtation of Inane and Tmporfain> in Tnrftic+m, The EPA is required every three years to revise its Guideline on Air Quality Models The Clean Air Act Amendments will require that existing chemical facilities obtain operating permits. The Guideline specifies what airquality models may be used forState Implementation Plan development and permitting, and how those models are to be applied. Most emission regulations and permit determinations are based on those models. Incorrect or unreasonably conservative models and model applications can result in unreasonable emission regulations and in unjustified permit denial. flp-iteria for Success Successful influence on the modeling Guideline would result in more accurate models and more resource efficient models, and reasonable modeling application rules. Timing The proposed Guideline revisions should be published during the Fourth Quarter of 1990. The final revisions shouRbe presented at the triannual "Conference on Air Quality Modeling", probably late in theEirst Quarter, 1991. Options Reacting 1. Contract for a consultant to prepare comments with Work Group guidance, and present them at the Conference. Use of a recognized authority on modeling gives this option the advantage of higher credibility. 2 Work Group prepare comments and present them at the Conference. Coordinate other activities with API. This option has the advantage of lower out-of-pocket cost to CMA Proactive Proactive advocacy on this issue is not practical because of the structure of the Guideline revision procedure and because of the personalities of the EPA personnel involve. Barriers and Opposition The Source-Receptor Branch ofEPA's Office ofAir Quality Planning and Standards, the branch responsible for theGtrideline is very conservative in their modeling approach. In addition, environmental groups may try to impose unreasonable conservatism on the Guideline. 67 VVV 000004999 GOAL. #1, OBJECTIVE #14 - Air Quality Modeling* Guidelines (oont.) and Benefit Modeling costs will be incurred by companies when they apply for permits under the reauthorized Clean Air Act. Successful advocacy on this issue will help ensure that modeling costs are reasonable. In addition, successful advocacy on this issue will promote the use ofreasonable model application rules. By avoiding overlyconservative model applications, facilities may be able to forego expenditures for unnecessary controls. Actions Selected Contract a consultant to produce written and verbal comments on the proposed revisions to the Guideline. RESOURCE NEEDS Activity Evaluation of area and volume source models for possible regula tory application Meeting&'Devclopmeot of Com ments on 1990 Proposed Guide lines MeetingaDevelopment of Com ments on 1993 Proposed Guide lines Totals Member Company (Days) 4 Member Company Travel <) 4,000 10 10,000 10 11,000 24 $26,000 GMA Tecb. Time (Days) 4 GMA Legal Time (Deye) 6 18 22 18 22 40 50 CMA Travel (8) 0 Outside Legal 8aiticca <> -- Outside Purchased Services <$> 34.600 0 * * 30.000 0 36,000 $0 $99,500 Rganoimibilitv This work will be the responsibility of the Air Dispersion Modeling Work Group. Mpasnrement of Performance Guidelines including only reasonable model application rules, resource-efficient models, and accurate models would indicate successful advocacy. 68 VVV 000005000 GOAL *1, OBJECTIVE *15 ACCIDENTAL RELEASES To enhance the advocacy role ofthe chemical industry to act expedi tiously. responsibly and positively in influencing the development and implementation ofresponsible Clean Air regulations, nurem-TVE aib; Advocate for the development of reasonable accidental release/proc ess safety management regulations. ESTIMATED RE90URGE REQUIREMENTS; Company Time OW, CMA Staff Company Travel CMA Travel 0.L&. 306 Days $110300 468 Days $146,000 $1300 $70,000 *(Outside Purchased Services Outside Legal Services) ACTION Establish ARWG Preliminary meeting with EPA Mu-- OnilA s PSM rule making Meet with EPA on relearn models Provide input to Safety RESP. GROUP LEAD/SUPPORT ARWG ARWG ARWG ADMWG/ EATG ARWG WORK PRODUCT Charter membership list Minutes, reports Updates Minutes Letter to Administration TIMING 12/31/90 1/31/91 - ongoing atr.f 4/aotti Meetings with ETA on rulemaking development Monitoring EPA's rulemak ing development OSHA/EPA list comparison/ analysis Develop CMA positions on list Meet with EPA to advocate positions Propose CMA List/Delist procedure Evaluate accidental release models under consideration Develop CMA's response to accidental release rulemak ing Review EPA's proposed rulemaking on chemical list Prepare written comments on chemical list proposal interface with Safety Board Review OSHAs PSM Anal rule Provide hazard assessment and risk management plan input to EPA and Safety Board Prepare testimony for EPA hearings, if held ARWG ARWG ARWG ARWG ARWG ARWG ADMWG/ EATG ARWG ARWG ARWG ARWG ARWG ARWG ARWG Minutes, reports Updates Contractor report White-paper Minutes, reports Letter proposal to EPA Contractor's report Contractor's report Identify issues of concern CMA comments Updates Reports, Legal analysis CMA comments CMA testimony ongohy ongoing (1) 4/30/91 4/30/91 6/3091 6/3091 (2) 591- 8/3191 (3) 8/3191 10/3191 10/319112/3191 10/3191-ongoing 10/319111/3191 1^3191 12/2991 69 WV 000005001 GOAL. # 1 OBJECTIVE #15 - Accidental Releases (cont.) ACTION Review EPA'b proposed rule making for rick management plana, etc. Prepare written comments on EPA propoaal Review EPA final chemical list rule Prepare tectimony for EPA risk management plan pro posed rule hearings, ifheld Monitor EPA Riak Manage ment Plan rulemaking Review Risk Management Plan final rule Monitor and respond, if neces sary, to Safety Board's recom mendationstoEPA and OSHA ARWG ARWG ARWG ARWG ARWG ARWG ARWG WORKPRODUCT Identify issues of concern CMA comments Reports, Legal analysis % CMA testimony Updates Reports Updates, comments TTMTNO 11/1692 11/16921/1593 11/159212/1692 2/2893 ongoing 11/59312/1693 ongoing CONTRACTOR (1) (2a) (2b) (3) TECHNICAL Environmental Safety & Plant Operations LEGAL COSTS #*1300,.000000 ##4300.,000000 STAFF (Days) 40 200 228 ARWG - Accidental Release Work Group ADMG - Air Dispersion Modeling Work Group EATG - Exposure Assessment Task Group FISCAL YEAS 199091 199091 199192 199192 TRAVEL (S) 1,200 0 600 OJP.SJO.LS. <*> 50,000 60,000 70,000 J ]i 3 ! J4 ! < 70 000005002 GOAL #1, OBJECTIVE #15 - - ACCIDENTAL RETJSASKS jfr^rintion of Issue and Tmnnrtnn^ in Tndneti-v Under the Accidental Release provisions of the Clean Air Act, EPA and OSHA must promulgate a number of regulations. EPA must promulgate an initial list of 100 substances which are known to cause or may reasonably be anticipated to cause death, injury or serious adverse health or environmental effects. EPA must also promulgate regulations and guidance for the prevention, detection and correction of accidental releases, eluding a requirement to prepare and implement risk management plans. An independent safety board will be established to investigate the causes of accidental releases which result in fatalities, serious injuries or substantial property damage. OSHA must also promulgate a chemical process safety standard. These activities will have a major impact on how the chemical industry operates, and are, therefore, of vital importance. For each substance listed under the accidental release provisions, EPA must promulgate a threshold quantity which determines the applicability of requirements. EPA will base these threshold levels in part on the dispersibility*#a chemical. Which models are used and how will play an important part in this determination. This information will also be used when the Agency decides to add or delete substances,from the provisions. Thus, the design and use of these models could have enormous impact on the hsfrHtey in earns of what substances get regulated, to what extent, and even whether a source can qualify for a permit to continue operations. Criteria for Succew 1. EPA and OSHA will develop reasonable accidental release process safety regulations. 2. Design and use by EPA of models that accurately reflect expected concentrations of listed pollutants due to accidental releases. Within two years ofenactment, EPA is required to promulgate a list of 100 substances subject to the provisions. At the same time, EPA is required to establish the threshold quantities. The list may be revised from time to time for the addition or deletion of substances. Within three years of enactment, EPA is required to promulgate release precaution, detection and correction requirements. The safety board will be established within the first year after enactment, because its first report is due to EPA 18 months after enactment. The OSHA standard must be promulgated within one year of enactment. Options ARWG 1. Do nothing. 2. Monitor activities, but do nothing. 3. Monitor activities and employ reactive advocacy methods. 4. Employ proactive advocacy methods to influence outcomes. 71 VVV 000005003 GOAL #1, OBJECTIVE #15 - Accidental Releaaca (cent.) ADMWG/EATG 1. Do nothing. 2. Evaluate current models as they become available. 3. Design new models. Barriers and Onnoaitinn EPA is unwilling to work with CMA because of: Q short time frame for rulemakings; lack of resources at CMA; and Q EPA acts independently of CMA input. Possible difficulty in gaining access to all information necessary to evaluate current models. EPA refuses to consider revisions due to vested interest in current models or the agency does not have adequate time to design orreview a new model and still meet statutory requirements for developing threshold levels. Coat and Benefit The costs of these regulations will be substantial because member companies will have to prepare risk management^lass for all chemicals stored at their facilities above the threshold quantities. The specific cost/benefit of these activities cannot be detemined at this time but the return on the hours CMA projects to invest in this issue should be positive. Action* Selected Option 4 was chosen, where possible. 72 VVV 000005004 r i GOAL #1, OBJECTIVE #15 * Accidental Releases (conL) RESOURCE NEEDS Activity Meet with EPA on release models Evaluate Accidental Release Models BPA chemical list activities EPA Walt Management Plan Rulemaking Total* <* Member Company Time (Days) 5 15 143 143 306 Member ($> 4.000 11.000 65.000 65,000 $145,000 CMA Tech. lime (Days) a 32 CMA Legal Time (Days) 8 20 CMA Travel ($) L200 L200 CMA Legal Travel ($) 600 0 Ontside Legal Services ($) -- -- Outside Purchased Services ($) 504)00 100 100 0 0 20,000 30,000 100 100 0 0 50.000 30,000 240 226 $1,200 $600 $70,000 $110,00 ftesnonsihilitv TheAcddental Release Work Group will have the lead but will need to coordinate with other work groups/task ginpasnch as the Air Dispersion Modeling WorkGroup. Measurement of Performance 1. Use of models based on reasonable criteria. 2. Reasonable, cost-effective risk management plan requirements. 73 VVV 000005005 GOAL #2, OBJECTIVE #1 MEMBER COMPANY COMMUNICATION fiQALiLfc To communicate the result* of the advocacy effort* to member com panies. OBJECTIVE Sit Acquaint member companies and other CMA Departments with re sults ofAdrocacyeffort sothatcompanies may be prepared Cor antici pated regulations and other Departments can be prepared for legis lative activities. Bids CMA StaffTime Company Travel CMA Travel O.LS. 405 Days $73400 1.312 Days $160,000 $31400 Outside Purchase Services Outside Legal flerviuee) ACTION Prepare and distribute re sults in newsletter Conduct workshops) on spe cific regulations Participate in co-sponsored workshops with EPA and/or other outside organisations. Executive letter from R. Ro land to eenior executives CMA Environmental Alert*, publication* Presentations at EMC Present information to CMA Board Present information at CMA updates Invite ether teak group and CMA committee members to AJTG meeting. Create brochureit), video tapes, and workshop materi als, as appropriate to inform member companies Inform CICs Identify need foT and prepare tarhnirnl corrections to CAA Provide support to future air legislative activities LEA A1TOHAS AJTG/HAS ABWCVHAS ATTG/HAS AJTG AITG/HAS AITG/HAS AITG/HAS AITG/HAS AITG/HAS/CC SAC A1TG/HAS AUTG/GR AJTG/AUTG/GR/HAS ffOMPBADPCT Air Issues Newsletter WorkahopU) and its proreertin^ Brochures, workshop meteriels Letter Alert EMC meeting minutes Test of President Update proceedings Minutes of meetings TINjno On-going 1 per year over 3 yean (1) On-going On-going On-going On-going On-going On-going On-going Video tepee A brochures Letters Technical correction* Position papers (2) Over 5 years, moat (3) tape A brochures (4) completed in first 3 years On-going On-going On-going A1TG - Air issues Task Group ALJTG - - Air Legislative Issues Task Group CC - - Communication Committee GR - Government Relations SAC - State Affaire Committee HAS - Health and Safety 74 VVV G00005G06 GOAL #2, OBJECTIVE #1 - Member Company Communication (oont.) nONTRACTOR (1) <2) (S) (4) pMAiffimtmrff hbbakdown TBCHHIfiAL Environmental Health and Safety 1JMUL roffr t 8.600 *20.000 S20,000 $25,000 STAFF (Days) 280 ISO 722 200 1990/91 1961/92 1991/62 1998*4 TRAVEL ($) 1240 154)00 4.000 0 OPA/OLS. ($) 204)00 63,000 0 0 75 WV 000005007 GOAL #2, OBJECTIVE #1- -i'01 3ER COMPANY COMMUNICATION Description at 1mm** and Tmi^rtonwi te TnHteir Die importance ofinforming member companies ofthe results ofthe advocacy efforts so that they may be better prepared for forthcoming regulation is self-explanatory. Criteria for Success Informing member companies of the results of the advocacy efforts such that they are prepared for upcoming regulation. Outreach activities over a period of five years are anticipated. A majority of those activities are anticipated to occur during the first three years. 1. Proactive. 2. Reactive^ Barriera and Opposition Die main barrier that is seen is possible shortage of resources in order to appropriately inform member com panies. Cost and Benefit The costs are anticipated to be somewhere in the area of $1,000,000 spread over five years with the majority offunds being spent in the first three years. The benefit will be a reduction in possible fines and penalties as a result of non-compliance. Actions Selected Actions are proactive rather than reactive in preparing texts in the form of brochures and workshops, videotapes, and any and all appropriate measures to ensure information reaches member companies. 000500Q 76 gflQUBBS Resources to fulfill this Goal and Objective are primarily the Air Issues Task Group with support from Health Safety groups as approriate; however, input is also from the Communications Committee and possible the State Affairs Committee. RESOURCE NEEDS Activity Newsletter*. Environmental Alert*, snd other mailing* CMA workshop* end updates EMC ud Board brief!091 Bmchnre*. videotapes, and emfcatap matehals -gWaeea--red ea^ahope with ontatde orginiretiens Supporton legislstiw activities Totals Member Company Time (Dejrm) 0 76 10 260 20 40 406 Member Company Travel <*) 0 CMA Tech. Time (Deye) 100 CMA Legal Time (Daps) 226 CMA Govt. Relations (Days) 0 60,000 76 76 54>00 20 42 744300 136 260 0 0 0 74)00 10 80 0 24.000 60 60 <160,000 990 722 200 200 CMA CMA Outside Outside Tech. Legal Legal Purchased Trav(Se)l Trav(Se)l Services ($) Outvie(S--) 00 0 0 214)00 44)00 O 0 00 00 0 664)00 64>00 0 ^ 0 ajoo $27,000 $4,000 0 $0 $73,500 RwioonsibUitv Carrying out this Goal aad Objective is the responsibility of the Air Issues Task Group. Ti ifnn--11 TiTrmnrrn ft niftmrh frnm rimNii iiimiimiir that have been adequately informed to enable compliance with regulations. > 77 VVV 000005009 GOAL #S, OBJECTIVE #1 AIR POLLUTION RESEARCH flOALMi Monitor and positivelyinfluence air pollution research and advocate forthe uaeofancfaraaaardi in crafting sound and ariantiflcally baaed legislation and regultiens. OBJECTIVE H: Develop a program to monitor current air pollution research and contribute to additional research that may influence the develop ment of more scientifically based legislation and regulations. EgTTMATEP BMnmirB BICOinRiniBNTfl- Company Time Company Travel CMA Staff Time CMA StaffTravel O.P.8.* O.LS. 102 Days $48400 316 $4300 $50400 0 '(Outside Purchased Services Outside Legal Services) ACTION Identify and review current air pollution research activities of Govt., Industry, academia, etc. Prioritise activities according to potential on CAA Advocacy Hi nllfj bai ilf rf high priority pngaeta Arrange meetings with.' lay contacts Meet with key contacts Summarize current research activities and identify additional research opportu nities Circulate report to appropri ate contacts (Govt., industry, academia) Revise and submit report for formal CMA approval along with necessary OPS requests or new research Execute contract* Monitor CMA research activi ties Draft alternative regulatory/ legislative frameworks for con- trolling air pollution baaed on results of research Organize forums for discus sion of new frameworks Draft CAA amendments based on framework RESP. GROUP AITG** AITG** AUG** AITG** AITGAITG-" AiTG-- AITG- AITGAITG** AITG** AITG-- AITG** listing TTMTKn On-going listing T jaHwy Meeting schednleled end agenda prepared Meeting minutes Report Within one month of completion ofreview activity On-gong On-going Within 14 days of meeting On-going Coordinate action with out side groups Report Within 7 days of CMA approval ofreport Within 30 days of receipt of comments Contract Periodic reports to AITG Report On-going On-going On-going Meetings Legislative language On-going On-going -- AiTG - Air Issues Tssk Group in oversight role; day-to-day managerial tasks and contract management are the responsibili ties of the relevant work group(i) 78 VVV 000005010 GOAL #3, OBJECTIVE #1 - Air Pollution Research (oont.) frtVTRACTOR (1) COSTS $50,000 FISCAL YEAR 1992*1993 RESOURCE RRFAgnOWN 'pBTTINICAL fhaianmniUl CHEMSTAE PCTG PETG Health and Safety IJCCAL STAFF (Day>) 13S 20 60 20 20 70 TRAVEL ($) 1.800 600 600 600 600 600 OJ>3A>L8. .- 60,000 PCTC - Proceu Control Taak Group PETG rrnrw fimiaaou Taek Group 79 VVV 000005011 GOAL #3, OBJECTIVE #1- - AIR POLLUTION RESEARCH Tnf unH Tm^rtanae tn Industry Many of the requirements in the Clean Air Act are based on outdated scientific evidence. In addition, EPA generally uses the most conservative assumptions when applying this information to the development of regulations and guidance. As a result, industry is often subject to controls far beyond what reasonable science dictates is necessary. For example, an area within the country is considered to be in nonattainment for ozone if the fourth highest monitor reading taken within the past three years shows an ozone concentration ofgreater than 0.12 ppm for more than one hour. Los Angeles exceeded this level 145 days during the 1986 to 1988 period. Thus, based on this, Los Angeles is subject to the most stringent ozone requirements in the country. Another measure ofozone not used by EPA is how often an area is below the standard for gll monitoring hours. Using this approach, Los Angeles meets the ozone standard 97.3% ofthe time. In fact, using this measurement, all nonattainment areas are below the standard 99.4% of the time. Since the health effects from exposure to ozone are short term and reversible, this raises serious questions about current requirements in nonattainment areas. Furthermore, in some areas natural sources may be causing the ozone nonattainment. We need to understand the natural cleansing mechanism. Criteria for Straeaa Passage ofamendments to the current Clean Air Act which include sound scientific approaches for the control of air pollutants, and recognize the contribution of natural contributions. jQflUlKC The Clean Air Act is expected to be reauthorized in 5 years. Based on this, the schedule of activities for influencing this reauthorization is as follows: 1991-- Identification and review of current research activities. 1992/93-- Development of chemical industry research programs to supplement existing research. 1994-- Following completion of research, development of alternative regulatory frameworks based on research findings and exchange of ideas with other groups in industry and government. 1995-- Qntiofui Development of amendments to the Clean Air Act encompassing new regulatory approaches. 1. Do nothing. 2. Monitor current research programs. 3. Monitor current research programs and fund additional research as necessary. Rnrrfpr* and Onnoaitlon There are two primary barriers to achieving success: (1) inadequate funding to complete the research, and (2) Congressional or EPA disregard of research findings. and Benefit Research, monitoringresults, and developing newregulatory approaches will be costly; however the benefit will be more sound regulatory requirements. 80 VVV C00005012 GOAL f 3, OBJECTIVE #1 -- Air Pollution Research (cont.) RESOURCE NEEDS Activity Identify A Review Research Meetings with EPA and Key Researchers Development at Report Muuitar CXml' DrmJl Framework* : Poruma Draft Amendments Totals Membae (Days) as 12 6 4 10 30 2 102 Member ($) 12400 12,000 CMA Tech. Tine (Daya) 60 16 CMA Legal Time (Days) 16 10 CMA Tech. Trawl (8) 0 3300 4,800 4300 4300 4300 4300 $48300 28 24 32 62 33 246 10 0 40 10 0 10 1200 10 0 70 $4300 CMA Legal Travel () * 600 Outside Legal Services ($) -- *- - -- 600 *4 - * -* * Outside Purchased Services () 0 0 0 50300 0 0 0 $50,000 Arrtinnn Selected Option "3" was selected. Rciftpflnfiihility The Air Issues Task Group will have genera) managerial and oversight responsibilities for this project. Actual contract management will rest with the relevant AITG work groups. Other groups with responsibility are identified in Appendix IV. Performance Measures Enactment of legislation which incorporates new regulatory approaches based on sound science. 81 VVV 000005013 PARTin APPENDICES Vvv 000050l4 82 APPENDIX I ANTICIPATED TRADE ASSOCIATIONS1 ACTIVITIES ATR TRRTTFS Air Tories JBsk Assessment Qmm* non-attainment Permitting Enforcement Vehicle emission reduction Area sources Accidental releases Alternative fuels Hd SOCMA XX XX XX XX X XX dX MVMA Xz NAM X dia KPRT NPCA XX X XX XX X X XX X *-* X XX X XX XX X X X SOCMA - Synthetic end Organic ManufactureTM Association API - American Petroleum institute MVMA - Motor Vehicle Manufacturers Association NAM National Association of Manufacturers NPCA - National Paint and Coatings Association A1SI American Iron and Steel Institute EPRI - Electric Power Reeearch Institute 83 VW 000005015 DRAFT 31 A u g u s t 1988 VW 000005343 Exhibit 2.3-3 (continued) Alt RELEASES Of 10* 1C CHEMICALS LEAPING 10 IWO INCUS*** C- ROSE EVACUEES (1902 1906) PATE BBfMKI 1 HMMI NUMBER NUMBER SUBSIAMCES RELEASED ..........................................................ENO EFFECTS-------- Of Of Of SUBSIANCE 2 SUBSTANCE ) 1ST 2M> MO AIN INJURIES DEATHS EVACUEES 12`N*y*IS 04-AprU 26-Jan-R3 OSNov-SS oust 1C NITRIC ACIP SULFURIC ACIO AMfQNIA (ANHYDROUS) VR FI UU UU SP V FI EX SP VR UU UU FI UU UU UU 0 0 6,600 AO 0 $.000 10 0 1,000 1 0 2,000 12 D*c-R2 02-Jut-02 06 Nay-02 20-Sap-12 2S-Fafe-02 30-Nov 02 1AS*p02 2I-Apr*02 10* Apr-02 13-Sap-82 ACROLEIN NITRIC ACIO NALCIC ACIO VINTL CHLORIDE TITRAETNTL LEAD PHOSPHORUS TRICHLORIDE STYRENE CHLORINE HTDROCEH PEROXIDE CHLORINE CHLORINE SQDIIM NTDROSUFIDE PARAQUAT HYOROCNLOtlC ACID SflDUM HYDROKiDE EH FI VR UU EX FI VR SP EM FI VR UU FI EX SP VR SP VR UU UU EX fl VR UU EX FI UU UU FI VR UU UU VR UU UU UU FI UU UU UU 1 0 20,000 6A 2 $.000 10 0 3,500 S 0 3,000 2 0 3,000 11 0 3,000 1 0 2,500 0 0 2,100 12 0 2,100 29 0 2,000 t i FIVE YEAR TOTAL 1,S19 $ 190,575 End Effect Cod**: IF - apill; VR - vapor rl*u; fl fir*; EX - uplotion; UU - mknoHn 9 8 VVV 0 0 0 0 0 5 3 4 4 APPEND* ESTNATE OF TOTAL COSTS FOR FYIMO worn GROUP fflRMTff MEETMQ fOF REPS COMPANY TIME (DATS COMPANY TRAVEL IB OPS EMVfl (ft OPS. 01.1 HEALTH! GENERAL SAFETY couNsa 1ft (ft THE EMffl (0IW TIME THE HEALTHS GENERAL SAFETY COLSMEL (DAYS) (OAYSI ISC GOVT REl (DAYS RUE STATE TRAVEL AFFAIRS ENVH ((MVS) (ft TRAVEL HEALTH I SAFETY (ft TRAVEL TRAVEL GENERAL GOVT COUNSEL REl (ft Ift TRAVEL NSC STATE TIME* AFFAIRS TRAVEL ID ft (HI MflS II IS DU 131.040 MB 1 II Ml 10.011 tram 1 IS 14 4*M BOOMS} ) T 4 MM COMM 1 S 37.1 ITMi MDK 14 HU MAN ns 11 T 147 47.77S HAPS 1 It 114 LM PS 3 11 MS 10,010 AMOBP --PCM 4 4 -- 11 II tli 20.030 *4 27,300 ............- ............ - MM ton 114 1440* 33*510 171.000 101,MO 110.000 IQ n (ft (ft (ft (ft (ft SO IN M0 10 0 0 40 0 0 40 I S 10 s 40 MO M 100 10 1 0 0 N 40 7 V 10 0 * SO -- I"...........---- -- MS 117 (ft (ft 400 <1* MO 0 0 0 0 S 0 0 0 0 0 MO (1ft UM 4.S00 uoo mi ns l! MOOLLAAB 110 FAC YEARS NUMBERS M RAN INCREASE RHUE5TS IMS,440 MM.SIO II71.0M *101*00 S110.0N *33*400 S44.BI ItM.HO 044.00 N NON 14.000 *4.NO N.7G3JN II.443.550 006,000 801*00 NS0.N0 Sl.NK.m SKM.M7 ISRUN 1730.000 N wax BOON *33.000 IMS.400 era,no 7N.7U 11.031.000 S.CBJOO SOSNO SIAML4N mao 14*000 NANO KINO t40.no 14% i% 144% M% N 70% Ml 74% #% - 2*% 9% 77% 0 0 * 1 TOTAL FOR FV MO 1 N H 10 1 FYNSOTIMES FIVE YEARS 11 NON SN.000 | TOTAL FOR NAN 04) 1 - PERCENT INCREASE REQUESTS 12.004,03 11304,07 117,47*3*0 34% FROM WAN|FYSMlTlm#iFYM* MBTOMCALFYN(X3YRS| UMCREA9E OUtftOE PUKftASEO SERVICE QUISDE LEGAL SERVICES CONMUIVTBC CONWY TRAVEL CMA STAFF THE ( CM*STAFF TRAVEL B.7NAM *1.0*100 SMS.M HAIM SMN.M0 *18.000 TOTAL II 7.<7t,B0 11.3*4*50 MOON 0.7BJN *1,142.560 t3.lll.N7 (NON 104*7% 073% 1411% 13*7% 41*4% 34*4% 113,034.07 **20% OPS -OuNM* PimAmh* Swfaw OLS.~OMa* L*4 SHom AUTO-Ah I^M* la*Gw* MQ~* hmm T^ita* STTMREO-Sla'Mtmi IfcfiMM T* <k* ECCMWO CnuHiWtOwM SECONDARY fim*A|OniiilnWa*fr<Mp FUQffNE f^SutoW-- Wwta-- EW-Oi^^lHtoVrllfcrt&V^onislHBiNiHMwi HAPS-TNwSwAL NUNN WM (> NSPS An Smiii NNiBUi SviAwVi <Vu> 0wu AWOI3P-AhttyrtMii4ilr|VMiCtau GR-Gotim* MAn STAFFSktoAlw* mEMmK (1) ItoGgNMiity Nii4mCMAEnlwiM***wiMIM0rt (2) IsIRvnHnSiiw-SaMVanCMAIAMtngRaMr* (ft Cc^^T)MO^TMMVIurtNMtM^`X-|AMtoMRVX 30% RrtNpSiw X i6DfP* --40) taMllM IHRNMtaBiM) X tSOMm *-- I* Ca^irTVxP MdwNONiw*-- QnwARMMu IS CB^TMwMNMMX^MM^|VX,HuRbwMIN)rwilM>v<,X 70%PfcipMiaXNOQft IS 0PAnM01A|6wALh< SM<lFYSS>IOftMtMB*<tw |7| O P.S.H^RMBM^ -Sw<BHMS>wASMNr8<p1lg APWy^WdmuNbH^PiASMft<A9ilFl)MVM<by.C (S TfcwCnilaniwN D><<n3404irOwX|3MU.>C4IAw5MMr* (S r--HrtSiWaMNy BiMw340NrM>-- X|.4U,ICIIA-- (IS Twwt^M BM0w34O4<wX(1*lrt+ 3CMAIAmniniG (11) TnvNEft+MMfMiUg^ BaaVaiFYAMOBudptEvMntUM (IQ TwM(MM*>May SmVm**SMNrSuBMrtto Ah Mi Hii H^ti S StW Trml FiftMVMMty 4.) (l)| TnOruwiMMarw MMwC*rNrM>X|l W4CUiMn>riiww* |U) |*^amr*MMTrM--Fm(M>SMV**1inR.tOMMtX)40O.fea0kitML 3 S c o o o o o U7 Ui Ui %a*4qppn|>vM(^>iMli|pT6rwOPMOP<IWMMqvrn k) --iw w M sinh *s< wins F**wg*wa m w*yw**^i wu W ^^(^^rfOBfJFww^sdo^F^jiw^irrfo <0 TOO! 8*0*211 ttm Tl 861 08 oooait Til nwi TOO wan TO 08'IS`I T0I ocroiii twouot *tVHld*J8WI0 MUMSIW BAWUAWJftOO SliAMdNOO no **0 TWiQl NTU JO NMOQnOM Ofl?0?tC 1VJ01 owe* 000 00* ooo'w* 0001 corn OOO'W 0808 0819 08*24 oa'u OdWH 0881* ooo*iri ON onoorit 0888 08*88 08808 08*188 05284 08*88 08*88 08*088 00*808 IZ> m m't WIT 08801 09 8? 009*87 08*81? 08*8? 08* 000 08 081 oori oorc 0800 8 a 8 Kl 81 0 0 088 08*8 088 81 000> 000*1 00021 000'lC 000Dot 08 tu 0CI oorts OOO'K ooru owe? sn 0 08 0 00 0 0 08 08* 0 08 0 0 08 08 0 000* o0ce> 0 0 0 OK't 0 0 00*? 0 0 008*1 00 08 00 08* 00 08* 00 00*? 0 08* ft oori 00*? oori oori 0 81'i oOoWr?i 081 08 00* 08* 00*? 08? oori ft 0n8o8s1 o0 08* 000'ltl 0 081 ooo'u o 081 08'N 0 0 ooon o 81? 08*18 81 08*181? 08*IS 088 0 0 08*1 0881 0 on on* 088 0881 0 0 08* 08*a 0 on? 0881 0 on? 08?2 0 nHU 08 n8 0 IKKl u ooraON 000*8 000*8 08*11 08*11 OK *2ft 0 000*8 08*8 088 tw 000*11 8C*8 0881 0S1U 068? 18*1 8O 8 01 08 0 8 S8M 8a 81 0 ft ft 0008 O9O2SB 0 0 0 8 80 81 0 8099 0 0 18 m 1881 0 m08 &* it* 0III m*li2ft m5 01? ctri on 1 000*1C 0081 ft ft 0 00 81 Oil os* 08 ooe*ic 0 808 000`S 0 088 0 0 000*21 0 08'm 08*8*1 00080'010/ 088 80S 0 ears 0 000*21 ft worn 08*8*1 000*2 088 086 088 0 086 0 881 oao'*K 08*8*1 08*2 088 S 8 29980 990 OK ON 8 08 nn ON OS 8 (I) V3UO 7391000 73AWJ1 TVtf3N3Q dd2S 73**81 WIO ddm VHO III JU33V8 H17V9H 73AVU1 ddViS mo Si MO 7nu M1S mo SI SIH032 lawm ddVIS mo SI 18VUI ANVdTIOO (saw) ISAM) H3H10 SM3SNOOO 3nu. 7VU3M30 dJViS 9*1 810 d*lS mo <BAW> A13JVS OHITOH anu i*a mo Mfl* SIMM mu ddVU mo mu dd4 mo s* 89*700 1VU3N30 no SI Aia#rs IHIW3M WO SI AN3 *cfO S> WHOM ffrfO 8 SawI 38? AMKMOO firmoaM rwioi i i Tree 1800 17000 jw*ns MMNBddV a/noctfiMLaEmicaexAj (NOOUOT) OtpMvM GOAL 2 GOAL 3 1 2 1 4 5 7 A I 10 11 12 13 14 15 1 1 0fSfi) 0150 : (Ml Ml 10400 10400 41000 0 71000 0 74400 10400 00 MB 0 0 20400 0 10400 HOB 10400 0 10400 00 00 31750 0 34490 e 40400 0 OPS Oil 0142 fliK 30400 30400 353400 221000 0 75400 0 0 9 9 25400 30400 89.750 0 70400 150400 0 2D400 150400 0 0 20400 20400 40400 0 0 0 3400 0 20400 0 4P . ola. Ml M 0 0 270400 45400 0 30400 0 9 0 0 9 0 311JS0 0 0 0 40400 50400 0 0 40400 0 9 0 13J00 0 50400 071 014. Ml Ml 0 0 204400 0 0 mm 0 0 0 0 0 0 101750 35400 0 0 20400 0 0 0 40400 0 0 0 uoo 0 0 QAC. OL& 0400 MOO 044. TOTAL 014. TOTAL TOTAL OUTJOCSSMCa 0 0 30400 0 0 75400 120400 SLOT 1.041000 0 0 334400 00 0 0 0 125400 0 30400 0 0 SOOT 0 30490 0 35400 00 0 0 0.759 0 0 0 0 4400 0 90400 SOT 30400 721250 50400 110400 21(LOT 0 130400 21UN 0 0 110400 (20400 100400 40400 0 0 31400 0 TOOT 270400 75400 1,170400 SHOT 0 125400 110400 120400 13SOT 40400 B400 757.750 HOT 1KU00 734 0uoo 0 40400 0 0 0 3MD0 0 0 0 D 0 73400 00 0 0 mm 0 00 0 0 80400 0 SOOT SUBTOTALS TOTAL OUTMCE SERVICES 9Y FISCAL YEAR 402.750 7QOT 1.121750 03490 7QSOT 253400 332.750 mm 171750 174400 1751250 1421400 3417450 471750 1441250 503L750 mm 341750 OUTSOE SERVICES BY tXV/OEPT ENViTECHMCAL HEALTH/TECHMGOL 9SAFETY* PLOTOTJ HMVTE STATE AFFAIRS GOVT RELATIONS GENERAL COUNSEL FY90B1 ACOmONAL 8 1TOTAL FY M FUNDS NECESSARY 5 1FY M COUMTTED FOR FUN 325400 131713 31750 31750* 33400 0 90 00 7QOT 70400* 1M.737 0 33400 0 0 0 <71750 213413 233237 FVt 131750 50400 0 0 423400 1443450 FYMS 4M4D0 271250 0 0 0 83400 131750 FYB344 251400 101710 20400 0 0 18400 433250 FY0M5 121000 43.750 0 0 0 174400 Ml750 TOTAL 2001800 SHOT 111309 0 0 1421400 TOTAL 3417.750 ADJUSTMENT TO INCLUDE MOOT 3 3105400FOR ALiFYOMf ACTWirteB 121250 OUTSIDE SBWCES BY DEPARTMENT TECHNICAL STATE AFFNRS QOVT.flELATKMfi LEGAL FY3001 4RYS0 0 0 70400 mm fyouob i44iao prmm TOOT 9 0 auto mm 66 FY 93/04 332,750 0 0 CJOO FY 04/93 172.750 0 0 174,000 Ml750 TOTAL 2713450 0 0 1421400 AM7.710 VVV G000Q53A6 i 3 ti 3 S * !r t 3 t 52 s* is ji ii gis si s* ta 1 :t iI nun rn tm m m ? m w m w iaei. nM*a < < (<n*o m i | j 87 | w ! | 0000053^7 APPENDIX VI CMA STRATEGIC PLAN ROLES OF CMA COMMITTEES/TASK & WORK GROUPS ENVIRONMENTAL MANAGEMENT COMMITTEE Hie Environmental Management Committee is the oversight committee to the Air Issues Task Group. They will be kept informed and act as a resource supplying group should the Air Issues Ihsk Group need assistance. AIR ISSUES TASK GROUP: Mission: It is the mission ofthe Air Issues Task Group to monitor and provide technical support for all phases of the air standards and regulatory process including data development, negotation, notice and comment, rulemaking, and litigation. The Task Group shall guide and coordinate comments and technical support for membership and in response to regulatory action. Work Groups L Air Dispersion Modeling Work Group. Mission: Assist member companies of the chemical industry by addressing air dispersion modeling concerns. Assuring the proper use of the dispersion models in the regulatory process. : 2. Air Permitting, Enforcement and Nonattainment Work Group. Mission: Initiateand communicate a proactive stance on EPA activities regarding permitting, enforce ment, and attainment issues to assure that CMA's positions are represented. 3. Air Toxics Work Group. Mission: To positively impact, through participation in the development of, regulatory activities involving air toxics. Initial emphasis will be on new regulations dealing with chemical lists, source category selection and MACT standards to be issued by EPA under Title III ofthe reauthorized Clean Air Act. 4. Fugitive Emissions Work Group. Mission: Monitor and provide technical support and guidance related to emissions from leaking equipment (called fugitive emissions) for all phases of the regulatory development process including data development and review, negotiation, notice and comment on rulemaking, and litigation. Prepare comments and technical support and guidance to meet membership needs in anticipation of a response to regulatory actions. 5. New Source Performance Standards Ad Hoc Work Group. Mission: This work group continues to form and operate when needed to respond to EPA s regulatory efforts about new source performance standards (NSPS) for source categories. 88 yy y 000005346 6. Ozone Work Group. Mission: Represent the interest of CMA member companies while assisting the Federal government in developing a scientifically sound basis for promulgating appropriate National Ambient Air Quality Standards and regulations for Ozone. 7. Secondary Emissions Work Group. Mission: Prepare comments and technical support/guidance for membership needs and respond to regulatory action in the area ofsecondary emissions. SecondaryEmissions are defined as: emissions which occur as a result ofa construction or operation ofa major stationary source but do not come from the major stationary source itself. HEALTH AND SAFETY COMMITTEE Ad Hoc Study Group on Risk The Ad Hoc Study Group on Risk will oversee a CMAinitiative to address the broad spectrum oftechnical, social, economic andpolitical factors ofimposed risk. Members ofthe the group will represent several CMA committees and many disciplines. The group will develop a strategy to gain consensus among government, academia, industry and other groups on definitions, protocols, applications and limits of risk asaaasment. Additionally, the group will develop a CMA workplan and an interactive strategy with other organizations and associations to address rink assfinnmrnt and management issues. Efriiamokgy Task Group Develop advocacy principles, positions, and plans for CMA with respect to important issues related to the investigation of the relationship between human health effects and chemical exposure through occupational and environmental epidemiology disciplines. Accidental Release Work Group To lead CMA's regulatory advocacy efforts to OSHA and EPA in the development of reasonable process safety management and accidental release regulations and guidelines. Risk Assessment Task Group The Risk Assessment Task Group (RATG) will develop and advocate CMA positions on risk assessment issues. The overall goal is to improve the technical basis of risk assessment through central regulatory agencies and research organizations. The RATG will also conduct seminars for staff and member company representatives on risk assessment issues. Exposure Assessment Task Group Develop, coordinate, and advocate CMA positions and technical responses on exposure assessment issues of importance to the chemical industry. The EATG will advocate the use ofappropriate exposure assumptions and methods in the legislative/regulatory application of exposure assessment. Existing Chemicals Testing Task Group The Existing Chemicals Testing Task Group is responsible for CMA's advocacy and policy development regarding methods and programs to evaluate potential human health and environmental effects of existing industrial chemicals. 89 VVV 000005349 I GOVERNMENT RELATIONS COMMITTEE To review CMA comments relative to regulatory requirements, and provide information obtained through Hi]) contact that might be useful to the CMA assessment process. STATE AFFAIRS COMMITTEE The State Affairs Committee manages state issues by working through member companies, chemical councils and their Federation, state business associations, organizations represnting state and local elected officials, and appropriate coalitions; and implement directregulatory advocacy on a selected basis in states with no Chemical Industry Councils (CIC) structure on issues of national significance to the chemical industry. 90 VVV 000005350 APPENDIX VIIA COORDINATION OF STRATEGIC ACTION ITEMS FOR GOAL 1 An T Identifies The Work Group(s) Anticipating Action In Response To Plan Objectives rasing Chemical LiatingfttelisUng MACTSource Categories MACT Standards Process Vests Storage Tanks - Transfer Operations Equipment Leaks -WmSasvater Revhnaoe of equipment leak emission tsctorVidentificatkm of low emisskm perform ance technology Improved ennmeon estima tion techniques far secondary enuasiona NSPS CTGs Permitting Issues Nonattainment Issues Enforcement Issues Ambient Ozone Standards Ozone Attainment Strategy Residual Risk Modeling Air Quality Modeling Guide lines Accidental release Modeling Residual Risk Standards Accidental Release Require ments AX X X X X X X X X X PEW X X X WORK CROUPS* EE HE ATIM flaoAAfia NSPS OTHER CMA CONTROL TECH- COMMITTEE, m ma hiamfi HSC HSC X X X X X X X X X X X X X X X X H55 HSC HSC --fnumrn Office of General Counsel support on each issue. AT - AirTaxies Work group PEN -Permitting, Enforcement and Nonattainment Work Group FE - Fugitive Emissions Work Group SE - Secondary Emissions Work Group ADM - Air Dispersion Modeling Work Group 03/NAAQS - Ozone and National Ambient Air Quality Standards NSPS - New Source Performance Standards HSC .. Health and Saety Committee TG Task Group WG. Work Group HEWG-RMWG 91 000Q5j APPENDIX VHB COORDINATION OF STRATEGIC ACTION ITEMS FOR GOALS 2 AS An T Identifies The Work Groupie) Anticipating Action In Response To Plan Objectives WORK fiHfltTP ACTION Identification and Review of Research AT X PEN FE X SEC. EMISSIONS X ADM X Meet with key* Contacts Develop Report on Research* Monitor Contract* Draft Alternative Frame work* Draft CAA Amendments Distribute Newsletters, Conduct Workshops, Create Brochures XX X X X Q3NAAQS X Othm'CMA Committees TO WG (Name) CHEMSTAR PCTG PETG HAS AUTG OGC DfatrGR X Communications, GR, AUTG Responsibilities depend upon what typds) of research is selected. PCTG - Process Control Task Groui^Eng. A Operations Committee PETIT/ - Pressure Equipment Task Group HAS - Health and Safety Committee ACITG Air Legislative Issues Task Group GR - Government Relations AT - Air Toxica Work Group PEN - Permitting, Enforcement and Nonattainznent Work Group FE - Fugitive Emissions Work Group ADM - Air Dispersion Modeling Want Group 03/NAAQS Ozone and National Ambient Air Quality Standards TG.. Task Group WG * - Work Group CHEMSTAR - Chemical Self-funded Technical Advocacy A Research t 92 VVV 000005552 APPENDIXVm AIR ISSUES TASK GROUP SCHEDULE OF MEETINGS FY 1990/91 THROUGH FY 1994/90 January February March April May June July August September October November December X X X X X X X X X 1991 X X X X X X X X X X X 1992 X X X X X X X X X X 1993 X X X r,- X X X X X X X X X 1994 1995 93 VVv 000005353 APPENDIX IX GLOSSARY OF TERMS ^Actions: Specific defined activity which is measurable, achievable and designed to accomplish an aspect of a stated objective over a specific time period. ADMWG: Air Dispersion Modeling Work Group. AIHC: American Industrial Health Council. API: American Petroleum Institute. BDT: Best Demonstrated Technology. PASAG' Clean Air Scientific Advisory Committee. CFC's: Chlorofiuorocarbons. Chemical Self-Funded Technical Advocacy and Research. CIC: Chemical Industry Council. CMA Teeh./Legal Time: CMA staff devoted to the Strategic Plan at $50 per hour. This does not include costs for travel. Company Time: Sweat equity of company participants in CMA Committees, Task Groups and Work Groups. This has been estimated at $100 per hour over an eight hour day and does not include travel costs with it. CO: Carbon Monoxide. CTG: Control Techniques Guideline DQJ: Department of Justice EPF: Environmental Defense Fund EPA: Environmental Protection Agency. FTP: Federal Implemented Plan. GAO: Government Accounting Office. Goal: The identification in broad terminology of a level oftargeted accomplishments to be achieved by a group performing over some time period. HAP: Hazardous Air Pollutants. "TripaP vision and process: Terms used in the Ad-Hoc Regulatory Advocacy CMA Board Advocacy CMA Board Advisory Committee to identify an approach designed to improve regulatory advocacy for the chemical industry. MACT: Maximum Available Control Technology. MEI: Maximum Exposed Individual. 94 Vvy 0 00 5354 NA; Nonattainment-Geographical areas of the U.S. that have not achieved an ambient concentration of a specifically identified criteria pollutants. NAAQS-. National Ambient Air Quality Standards. NAPCTAC: National Air Pollution Control Techniques Advisory Committee. NAS: National Academy ofSciences. NESHAP: National Emissions Standard for Hazardous Air Pollutants. NQx: Oxides ofNitrogen includes Nitrogen Oxide and Nitrogen Dioxide. NRDC: National Resources Defense Council. USES: New Source Performance Standards. Qfl: Ozone. Objectives: Specific measurable and achievable accomplishments designed to accomplish an aspect ofa stated goal in a specftfiaAtame period. Q.G.C.: Office of General Counsel. Q.L.S.: Outside Legal Services. OES.: Outside Purchased Services-refers to anticipated cost to the chemical industry for outside consultants delivering a product designed to assist the chemical industry in advocacy efforts. sr OSHA: Occupational Safety and Health Administration. .1 PAVE: Programs to Assess Volatile Emissions. PENWG: Permitting, Enforcement and Nonattainment Work Group. PSD: Prevention of Significant Deterioration. POSSEE: Plant Organizational Software System for Emissions from Equipment RARM: Risk Assessment and Risk Management RCRA; Resource Conservation and Recovery Act Reg/Neg-. Regulatory Negotiations. Residual Risk: Term refers to potential impact of chemicals released from the facility after passing through control equipment RUk Assessment: A process to evaluate the potential impact of chemical releases to the environment on communities in the environment using an established process that considers concentration, dose and receptor condition among other parameters. SAB: Science Advisory Board. SARA : Superfund Ammendments and Reauthorization Act VVV OOOO05355 SIP: State Implemented Plan. SOCMI: Synthetic Organic Chemical Manufacturing Industry. STAPPA/ALAPCfV State and Territorial Air Pollution Program Administrators/Association of Local Air Pollution-Control Officials. Tech.: Technical. TRDF? Treatment Storage and Disposal Facilities. WG: Work Group. Work Product: Hard copy results of specific actions. WWT: Waste Water Treatment. 96 VW 000005356