ADVANTAGE
`GLASS!
`
`SWITCHING TO PLASTIC IS AN
`ENVIRONMENTAL MISTAKE
`
`A Study Documenting the Environmental Advantages of Gloss Over Plastic Containers
`Based on Published Information
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`by "
`Henry S. Cole, Ph. D. and Kenneth A. Brown
`
`September 15,1993
`
`O-I Glass, Inc.
`Exhibit 1030
`Page 001
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`

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`ADVANTAGE GLASS!
`Switching to Plastic is an Environmental Mistake ’
`
`A Study Documenting the Environmental Advantages of Glass Over Plastic
`Containers Based on Published Information
`
`By Henry S. Cole, Ph. D. and Kenneth A. Brown
`
`Copyright © 1993 Kenneth A. Brown and Henry S; Cole, Ph. D.
`
`The authors encourage the copying and distribution of this work, and hereby grant to
`the public the right to reproduce their work on a non-commercial basis, so long as all
`copies contain proper attribution of authorship and the copyright notice displayed
`above.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 002
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`PREFACE
`
`This study was sponsored by the Glass Packaging Institute. The opinions and
`findings in the study are solely those of the authors and not necessarily those of the Glass
`Packaging Institute.
`
`ABOUT THEAUTHORS
`
`Henry S. Cole, Ph.D. is President ofHemy S. Cole & Associates, Inc., an
`environmental consulting firm which provides technical assistance, research, and
`information to businesses, envirortmental groups, and government. Dr. Cole has written
`numerous reports on atmospheric pollution, hazardous waste clean-up, and solid.waste
`issues. He has provided expert testimony to a number of Congressional Committees on a
`variety of environmental issues and recently authored a major study on mercury
`contamination in the United States.
`
`Previously, he served, as Science and Policy Director for Clean Water Action and
`Clean Water Fund. He was a Senior Scientist and Section Chief with the U.S. EPA’s
`Office of Air Quality, Planning, and Standards. He was a Professor of Environmental
`Studies at Howard University and an Associate Professor of Environmental Earth Science
`at the University of Wisconsin-Parkside. Dr. Cole obtained his Ph.D. in Meteorology at
`the University of Wisconsin, Madison. "
`
`Kenneth A. Brown is President of Kenneth Brown and Associates, a consulting
`firm which provides policy analysis, public relations, grassroot.s organizing and strategic
`planning services to businesses, non-profit organizations, and.government. He has written
`articles and testimony on a variety of environmental issues including solid waste,
`hazardous waste clean-up, and water pollution. Mr. Brown previously served as National
`Campaigns and Organizing Director for Clean Water Action and Clean Water Fund. Prior
`to that position, he was Director of the New Jersey Environmental Federation. He
`obtained his Master of Public Policy degree from the University of Michigan, Ann Arbor.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 003
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`PEER REVIEW PROCESS
`
`As part of the methodology for conducting this study, the authors obtained
`comments from twenty-eight expert peer reviewers including representatives of
`environmental organizations, recycling organizations, industry, universities, state
`environmental agencies, and the U.S. Environmental Protection Agency. The purpose of
`this peer review process was to obtain the input of various experts on the methodology
`used, and on the information, analysis, and findings presented-in this study.
`
`This peer review process should not be construed as an endorsement of this study
`or its findings by the reviewers or the organizations they represent. The opinions and
`findings are solely those of the authors.
`
`The authors wish to thank the following peer reviewers for commenting on this
`
`study.
`
`Michael Aucott, New Jersey Department of Environmental Protection and
`Energy, Office of Pollution Prevention
`Thomas Baif, Aveda Institute
`Sandy Buchanan, Ohio Citizen Action
`Philip Clapp, Spiegel & McDiarmid
`Jean Clark, New Jersey Recycling Forum
`Dr. Mark Cohen, Center for the Biology of Natural Systems, Queens College
`Dr. Barry Commoner, Center for the Biology of Natural Systems, Queens
`College
`Gary Davis, University of Tennessee, Center for Clean Products and Clean
`Technologies
`Dr. Kenneth Geiser, Massachusetts Toxics Use Reduction. Institute, University of
`Massachusetts, Lowell
`Amy Goldsmith, New Jersey Environmental Federation
`Ed Hopkins, Citizen Action
`Marie Kruzan, Association of New Jersey Recyclers
`Anne Leonard, Greenpeace
`Geoffrey Lomax, (formerly with the National Environmental Law Center)
`Dr. Fred Miilar, Friends of the Earth
`Dr. Warren Muir, INFORM
`Jane Nogaki, New Jersey Environmental Federation
`Dolores Phillips, New Jersey Environmental Federation
`Brenda Piatt, Institute for Local Self Reliance
`C. Philip Ross, Creative Opportunities, Inc.
`David Sarokin, U.S. Environmental Protection Agency, Office of Toxic
`Substances
`Karen Shapiro, Tellus Institute
`Sam Spofforth, Pennsylvania Clean Water Action
`Dr. Fred Weber, University ofTennessee, Department of Chemical Engineering
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`O-I Glass, Inc.
`Exhibit 1030
`Page 004
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`Tom Webster, Center for the Biology of NatuLal Systems, Queens.College
`Daniel J. Weiss, Sierra Club
`Bob Wendelgass, Pennsylvania Clean Water Action
`Jeanne Wirka, Materials for the Future Foundation
`
`The reviewers were asked to comment on a preliminary draft of this study. Their
`comments were very insightful. Many were incorporated into the current version.
`A summary of the major comments provided by th& peer reviewers and the authors’
`responses to those comments are presented in Chapter VIII of the study.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 005
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`TABLE OF CONTENTS
`
`Executive Summary
`
`Chapter I:
`
`Introduction
`
`Chapter II:
`
`Recycling: Glass vs. Plastics
`
`Chapter III:
`
`The Production Cycles for Glass and Plastic
`Containers
`
`Chapter IV:
`
`Emissions, Discharges and Wastes Associated
`with the Production of Glass and Plastic Containers
`
`Chapter V:
`
`Chemical Accidents Associated with Packaging
`Production
`
`Chapter VI:
`
`Glass and Plastic Containers: Energy Consumption
`
`Chapter VII:
`
`The Impact of Containers on the Marine Environment
`
`Chapter VIII:
`
`Summary of Peer Review Comments and Authors’
`Responses
`
`End Notes
`
`Appendices 1-5
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`Page
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`6
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`18
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`27
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`55
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`74
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`105
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`119
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`130
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`138
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`173
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`189
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`O-I Glass, Inc.
`Exhibit 1030
`Page 006
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`EXECUTIVE SUMMARY
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`All across America, the glass bottle is rapidly being replaced with plastic
`
`containers. A trip to any supermarket or convenience store shows that PET (polyethylene
`
`terephthalate), I-IDPE (high density polyethylene), PVC (polyvinyl chloride) and other
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`plastics are replacing glass container~ for a wide range of beverage and food products.
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`The shift to plastic may accelerate even more rapidly in the near future since the major
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`soft drink giants - Coke and Pepsi - recently announced their plans to replace most
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`of their remaining glass bottles with plastic containers in at least two major
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`markets.1
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`American consumers, ’however, continue to be wary of the environmental threats
`
`posed by the growing use of plastics. In fact, an internal plastics industry memo
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`acknowledged that "public opinion polls throughout the 1980s show that an increasing
`
`percentage of the general public believes plastics are harmful to health and the
`
`environment."2 A 1990 Roper poll found that Americans think plastic packaging is the
`
`secondmost serious cause of the nation’s solid waste problem. And a recent poll by the
`
`Winhlin Group found that 73 .percent of the American public believe that "plastic harms
`
`the environment. ,,3
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`This report finds that the public concern about plastics is warranted and that
`
`the massive switch from glass to plastics is an environmental mistake. This report
`
`presents evidence which documents that:
`
`¯ Glass is far more recyclable than plastic.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 007
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`¯ The production cycle for glass is simpler and inherently less hazardous than
`
`the production processes used to make plastics.
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`Plastic production generates far more toxic emissions and wastes than glass.
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`¯ Plastic production poses a much higher risk for chemical accidents than
`
`glass.
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`¯ Plastic containers pose a serious threat to ocean wildlife.
`
`The evidence indicates that saving the glass bottle and reversing the current trend
`
`toward plastic containers will reduce the use and emissions of toxic ~hemicals, reduce the
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`potential for dangerous chemical accidents, and help conserve valuable resources through
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`recycling. The many environmental advantages of glass over plastic containers are outlined
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`below.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 008
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`" TABLE ES-I:
`
`p
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`Summary of Environmental Advantages of Glass and Plastic Containers
`
`Environmental Advantages of Glass Over Plastics
`
`GLASS
`
`PLASTICS
`
`Simple Production Cycle: Few Points of
`Impact and Risk
`
`Complex Petrochemical Production
`Process: Many Impacts and Risks
`
`Few Hazardous Inputs..Fewer Toxic
`Emissions
`
`Large Amountsof Hazardous Chemicals
`"Large Amounts.of Toxic Emissions.
`
`No Serious Chemical Accidents
`
`:.Recycled :Easily andEconomically . .., ....
`
`Closed Loop Bottle to Bottle Recycling
`
`Many Chemical Accidents Causing
`Deaths, Injuries and Billions in Property
`Damage
`
`- :::.Difficult.arid Costly to Reey~le;.Dr "ahai’ng ~ .i.
`ii:Ci~i~u..dgets. .. . ,. : ..........:.:.,. ~.
`’- .
`
`Generally Recycled Only Once Pilot to
`Disposal
`
`DoesNotBurninIncinerators :: .-, .: . ¯/."..:. :Highly.Compatib!e.with!ncineration;
`¯ .-.i" ":. .: ".,: " " :.~.: .. :"~ ~!.iii./ :: .:.Buming.Plas.fcsCreatesTo~(cid:128)E.missions
`
`?. ~’.:.’~’-.i:’r.’:’." ,:.." ,.,~ --o . . : o. ?.:.’. -’:’" .
`Promotes Recycling-Based Future Promotes Incineration; Undermines
`Recycling
`
`¯ .No.RePorted .:Harm: to, M.arin~ ..Wildlife...-". :iii:.,i.:
`
`Environmental Advantages of Plastics Over Glass
`
`GLASS
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`PLASTICS
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`/
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`High Emissions ofNOx - Contributes to I Much Lower NOx En~’ssions
`Smog
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`Exhibit 1030
`Page 009
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`The Environmental Advantages ,of Glass
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`A. Glass is far more recyclable than plastic.
`
`1. The recycling rate for glass containers is more than double the rate for
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`plastic containers. The national recycling rate for glass containers is 33 percent while
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`only 15 percent of plastic containers are recycled nationally. (See Figure ES-1).
`
`2. Recycling plastic is far more difficult and expensive than recycling glass.
`
`Because it is extremely expensive to recycle plastics, cities are increasingly questioning
`
`whether they should include plastics in their recycling programs. The city of Philadelphia,
`
`for example, recently dropped plastic recycling because the costs are so high.4
`
`3. Glass containers can be recycled to glass containers many times, while
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`plastic containers are usually recycled only a single time - into carpets, "plastic
`
`lumber" and other non-container products. Although both types of recycling are
`
`beneficial, repeated, closed loop recycling, offers far greater benefits in the areas of
`
`avoided disposal, avoided resource consumption, and energy savings.~
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`4. The trend toward plastics is more compatible with incineration than
`
`recycling. It is much cheaper to incinerate plastics than to recycle them,6 Consequently,
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`the plastics industry is aggressively promoting incineration as a waste management option.
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`Glass on the other hand is non-combustible and less expensive to recycle than to
`
`incinerate."~ By its very nature, glass promotes recycling over incineration.
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`B. The production cycle for glass is simpler and inherently less hazardous than the
`
`production processes used to make plastics.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 010
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`F~ure ES-1 and Figure I1-!
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`1992 Recycling Rates
`Glass vs. Plastic Containers
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`33%
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`¯ 15%
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`Glass
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`Plastic
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`Sourc~ Glass Packaging Institute, April 1993.
`American Plastics Council, April 1993.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 011
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`1. The major ingredients used in glass production are naturally occurring
`
`minerals including sand, limestone, soda ash and feldspar. These materials are solid, inert,
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`non-flammable, and are largely non-toxic. Abundant supplies of these minerals exist in the
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`U.S. and throughout the world. Atter these minerals are mined and minimally processed,
`
`they are shipped to plants where they are mixed with cullet (recycled glass). The mixture
`
`is then melted in furnaces and formed into glass containers. The glass production cycle
`
`contains relatively few potential points of environmental and health impact.
`
`2. The major chemicals used to make plastic resins pose serious risks to
`
`public health and safety. Many of the chemicals used in large volumes to produce
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`plastic are highly toxic. Some chemicals, like benzene and vinyl chloride, are known to
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`cause cancer in humans; many tend to be gases and liquid hydrocarbons which readily
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`vaporize and pollute the air. Many are flammable and explosive. Even the plastic resins
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`themselves are flammable and have contributed to numerous chemical accidents.
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`3. As a petrochemical productionprocess, plastic manufacturing requires
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`substantial corporate and regulatory efforts to control and manage a broad range of
`
`risks to workers, communities and the environment. Fewer risks are posed by the
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`simpler, less hazardous production cycle of glass. Therefore, fewer regulatory
`
`requirements are needed to control the production of glass.
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`C. Plastic production generates far more toxic emissions and wastes than glass.
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`1. The production of plastic emits substantial amounts of toxic chemicals
`
`(e.g., ethylene oxide, benzene, and xylenes) to air and water. Many of the toxic
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`chemicals released in plastic production can cause cancer and birth defects and damage the
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`Page 012
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`nervous system, blood, kidneys, and immune systems.
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`These chemicals can also cause
`
`serious damage to ecosystems.
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`2. Three of the top five industries with the largest total toxic emissions and
`
`offsite disposal of toxic chemicals are involved in the production of plastic, according
`
`to the U.S. EPA’s Toxic Release Inventory. These three industries -- petroleum refining,
`
`industrial organic chemicals, and plastic materials and resins -- emitted and disposed over
`
`1.7 billion pounds of toxic chemicals in 1991. The glass container industry, on the other
`
`hand, emitted and disposed only 1.3 million pounds oftoxics in 1991.s
`
`3. Industry and scientific data (see Figure ES-2) indicate that:
`
`¯ The production of a 16-ounce PVC container results in over 800 times more
`
`toxic emissions than the production of a 16-ounce glass container.
`
`¯ The production of’a 16-ounci~ PET container is estimated to generate over 100
`
`times more toxic emissions than a glass bottle of the same size.
`
`¯ The production of a 16-ounce I-IDPE container produces more than 40 times
`
`the toxic emissions of a 16-ounce glass bottle.
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`4. In addition, plastic container production generates a greater burden of toxic
`
`substances in the form of sludges and other solid wastes than does glass production.
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`Exhibit 1030
`Page 013
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`FIGURE ES-2
`
`Estimated Toxic Emissions Generated in the Production of a
`16-Ounce Container: Glass vs. HDPE, PET and PVC.
`
`(in pounds per million containers)
`
`OFF-SCALE : 321
`
`100
`
`7O
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`10
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`.0
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`GLASS
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`HDPE
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`PET
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`PVC
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`Source: Emissions fi’om Tellus Packa~ng Study, Vol. II. For container weights, see
`Table IV-4.
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`Exhibit 1030
`Page 014
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`5. A substantial portion oftherhazardous and other industrial waste generated in
`
`plastics manufacture are burned in hazardous waste incinerators. This study finds no
`
`evidence that wastes from glass production are incinerated in hazardous waste
`
`incinerators.
`
`D. Plastic production poses a much higher risk for chemical accidents than glass.
`
`A review of several U.S. EPA data bases on chemical accidents and spills
`
`associated with industrial plants and transportation in the U.S. indicates that:
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`1. The chemical accident rate associated with glass production is negligible.
`
`2. Serious accidents - explosions, chemical fires, chemical spills and leaks
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`and toxic clouds which have caused deaths, injuries, evacuations and major
`
`property damage - are frequently associated with, the industries and chemicals
`
`involved in the production of plastic container materials.
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`¯ A review of the U.S. EPA’s data base of 10,000 accidents and spills from 1980-
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`87 shows that nearly 1,600 of the accidents were associated with: (1) plastic polymer
`
`resins (e.g., polypropylene and polyvinyl chloride) and monomers (e.g., propylene and
`
`vinyl chloride); and (2) the high volume chemical inputs and intermediates used to
`
`make the plastics. Sixteen of these accidents resulted in deaths while 179 caused
`
`injuries. On the other hand, the data base shows that activities potentially related to
`
`the glass container industry resulted in only ten chemical releases; none resulted in any
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`deaths or injurieS;.9
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`O-I Glass, Inc.
`Exhibit 1030
`Page 015
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`F~ure ES-3 and V-1
`
`Accidents Involving Chemicals
`Used in .Glass and Plastic Production
`
`178
`(off chart)
`
`1,583 "
`(off chart)
`
`~ Plastic
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`16
`
`No. of No. of No’. of
`Accidents with Accidents with Accidents with
`Deaths Injuries Evacuations
`
`Total No. of
`Accidents
`
`140
`
`120
`
`100
`
`80
`
`60
`
`40
`
`20
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`0
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`Sourc-" U,S. EP~ Acute Hazardom Events Data Base (1989).
`Contains Data on 10,000 Chemical Acddents from 1980-1987.
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`O-I Glass, Inc.
`Exhibit 1030
`Page 016
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`¯ A review of the Federal Accidental Release Information Programl which
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`¯ contains records of about 1500 accidental chemical releases from 1986-1990, shows
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`nearly 700 accidental releases for the industries that manufacture plastic and the
`
`chemicals used to make plastic. These releases resulted in over 300 injuries. There
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`was only one accidental release associated with the glass industry during this period,
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`and this release caused no injuries. ~0
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`E. Plastic containers pose a serious threat to ocean wildlife.
`
`Both glass and plastic containers contribute to the beach litter problem. However,
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`the evidence shows that glass containers have no significant impact on marine ecosystems
`
`and wildlife. Plastic containers, on the other hand, have major impacts on marine life. A
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`review of literature on the impact of container production and disposal on marine life
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`shows that:
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`1. Many species of birds, fish, and sea turtles ingest plastic container
`
`fragments and the resin pellets that are used to make containers and other plastic
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`products. Ingestion of plastic particles has been documented in at least 50 species of
`
`marine birds worldwide.~ In some cases, the plastic resembles the normal food of the
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`animal. For example, resin pellets closely resemble fish eggs.~2
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`2. The adverse effects of plastic ingestion on birds include intestinal blockage
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`and undernourishment (as the stomach fills with plastic). Juvenile birds appear to
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`be most vulnerable - and plastic ingestion may impair the survivability of some
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`species.
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`Page 017
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`3. Large quantities of plastic resin pellets are released into the marine
`
`environment each year. Sources include plastic production facilities which manufacture
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`pellets and the plants which use the pellets to make containers and other products. As
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`these and other facilities discharge pellets to rivers in coastal regions, the plastic pellets
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`travel to the ocean. Often, pellet contamination is heavily concentrated in the most
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`biologically productive portions of the ocean.
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`4. Large amounts of plastic products, including containers, are disposed of
`
`in the marine environment each year from vessels, litter and illegal dumping. Plastic
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`container materials then break down into pieces which, like pellets, can be ingested by
`marine organisms.
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`The Environmental Advantages of Plastic Containers
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`A. Criteria Air Pollutants.
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`The evidence presented in this report shows that plastic production results in lower
`
`emissions foi- most "criteria air pollutants" ~- particularly for oxides of nitrogen (NOx).
`
`Criteria pollutants are pollutants for which ambient air standards have been set by the U.S.
`
`EPA under the Clean Air Act.
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`1. Of the four materials compared, (Glass, PET, HDPE and PVC), HDPE tends to
`
`have the lowest emissions of criteria pollutants.
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`2. Glass has much higher NOx emissions than PET, HDPE and PVC. NOx
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`contributes to photochemical smog formation and is a respiratory irritant.
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`Page 018
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`3. Glass and PET have nearly equivalent emissions for SOx (sulfur oxides), and
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`particulate matter. Sulfur oxides are a major cause of acid rain. Glass has slightly lower
`
`emissions for the most dangerous particulates (inhalable particulates).
`
`Ener~ Consumption Associated with Glass and Plastic Containers
`
`1. Proponents of plastic often contend that the energy requirements for the
`
`distribution of plastic containers should be less than those for glass containers, due to the
`
`lighter weight of plastic containers. However, available evidence suggests that this
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`advantage is relatively small and exists only for larger container sizes (one liter and larger).
`
`Moreover, the energy required to produce both glass and plastic containers is much higher
`
`than the energy needed to distribute the end product.13
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`2. Evidence presented in this report suggests that it takes slightly less energy to
`
`produce a 16-ounce glass container than it does to make an equivalent PET container.
`
`Production of HDPE and PVC containers require substantially less energy than either PET
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`or glass containers of the same size.
`
`3. Evidence presented in this report suggests that the total energy costs
`
`(producing, distributing and disposing) of PET and glass containers are about the same
`
`for single-serve (e.g., 16-ounce) beverage containers. For larger containers, PET
`
`containers appear to use somewhat less energy.~4
`
`4. Considerable energy savings can accrue by increasing the portion of recycled
`
`curet used in glass production, particularly when large amounts of cullet can be obtained
`
`near the glass plant.~5
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`Exhibit 1030
`Page 019
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`Summary
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`The evidence presented in this study indicates that glass containers have a number’
`
`of significant environmental advantages over plastic. The only significant advantage found
`
`for plastics was substantially lower atmospheric emissions of nitrogen oxides. Plastic
`
`containers, from production to disposal, pose serious risks to public health and the
`
`environment in the form of chemical accidents, toxic emissions, and damage to marine life.
`
`Consequently, the evidence indicates that the continued shift from glass to plastic
`
`containers will have a negative impact on environment and public health. Unless this trend
`
`is reversed, we will see the continued replacement of a relatively benign and easily
`
`recyclable material (glass) with a material (plastic) that results in large amounts of toxic
`
`pollution, causes deadly chemical accidents, threatens marine life and is costly and difficult
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`to recycle.
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`Exhibit 1030
`Page 020
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`CHAPTER III: THE PRODUCTION CYCLES FOR GLASS AND
`
`PLASTIC CONTAINERS
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`A. Introduction ahd Maior Findings
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`This chapter describes how glass and major types of plastic containers are made.
`
`The processes and materials used to produce plastic and glass containers are vastly
`
`different. The fundamental differences between glass and plastic production create very
`
`different kinds of environmental and public health impacts. This chapter focuses on
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`materials and pro6esses and describes the nature of risks and impacts associated with
`
`various stages of production. Chapter IV’provides a more quantitative comparison of the
`
`types and amounts of wastes, emissions and discharges associated with different container
`
`materials. The major findings Of this chapter are as follows:
`
`1. The production cycle for glass is far simpler than that for plastics. In glass
`
`production, the major ingredients are naturally occurring minerals including sand,
`
`limestone, soda ash, and feldspar. Abundant supplies of these minerals exist both in the
`
`U.S. and globally. These minerals are mined, minimally processed, and shipped to a plant
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`where they are mixed with eullet (recycled glass), melted in furnaces, and formed ihto
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`glass containers in a single facility. There are few potential points of environmental and
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`health impact throughout the production of glass containers.
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`2. High volume materials used in glass production are primarily solid, inert,
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`non-flammable, non-volatile.~(they don’t evaporate into the air) and they have little
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`or no toxicity. As a result, chemical accidents at glass plants are virtually non-existent
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`and the toxic loading of emissions and waste streams tend to be low. However, one
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`Exhibit 1030
`Page 021
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`problem associated with glass production is the toxicity of fugitive silica dusts (see Section
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`,
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`3. The most significant environmental impacts associated with glass
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`production include: (a) energy use (See Chapter VI), and (b) criteria air pollutant
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`emissions including sulfur dioxide and nitrogen oxides (See Chapter IV).
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`4. Glass container production has a very high potential to use recycled cullet.
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`Plants manufacturing clear glass generally use about 30 percent cullet while those making "
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`green glass use up to 70 percent at many facilities. Moreover, 1.00 percent culler use has
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`been demonstrated. !o5 Use of cullet reduces virgin material use, energy use, and solid
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`waste generation.
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`5. Plastic resins used to make containers are primarily produced from
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`chemicals that are synthesized from petroleum and natural gas. These fossil energy
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`resources are far less plentiful and more precious than the rock minerals used to make
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`glass.
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`6. To make petroleum hydrocarbons into the different types of plastic
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`container resin (e.g., PET, HDPE, PVC, polystyrene) requires a complex series of
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`chemical processes. These processes include feedstock production, synthesis of chemical
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`intermediates and monomers (single units of resin), and formation of polymers (chains of
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`monomers that make up plastics). A number of separate facilities may be involved in the
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`production of plastic resins, and entirely separate plants transform the plastic pellets into
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`containers. Hazardous chemicals, wastes, and emissions are generated during the
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`different steps involved in plastic container production.
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`Exhibit 1030
`Page 022
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`7. Large volumes of hazardous chemicals are used in the production of
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`plastic resins. Most are liquids and gases which are volatile, chemically reactive,
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`flammable, explosive, .and highly toxic. Many can cause cancer, birth defects, or other
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`health problems. Examples include: ethylene, benzene, and vinyl chloride.
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`8. The use of large volumes of hazardous chemicals in the production of
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`plastics requires substantial corporate and regulatory efforts to control and manage
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`a broad range of risks. Such risks include worker exposure to t6xic chemicals, toxic air
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`and water pollution, hazardous wastes .and chemical accidents.
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`B. Glass Container Production
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`Glass production involves relatively few steps from the mining of materials to the
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`fabrication of finished bottles and there are very few materials involved in production. (See
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`Figure III-1.) The major raw materials used to make glass include: silica sand, limestone,
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`soda ash (sodium carbonate) and feldspar (a source of alumina).1°* Typical glass plants
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`currently incorporate 20 to 50 percent cullet (recycled glass) when producing glass
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`containers. Cert"in plants have used 100 percent culler in glass production.1°7 Using ’
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`culler replaces raw materials, reduces furnace energy requirements, and extends the life of
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`glass making equipment. Thus, glass companies have a major incentive to useas much
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`contaminant-free glass container cullet,as possible,
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`Minor constituents in the glass production process vary according to glass color.
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`Amber glass (which protects contents from fight) contains about 0.3 percent of iron oxide
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`and less than 0.1 percent sulfur.l°9 Green glass contains less than 0.2 percent iron and
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`approximately 0.2 percent chromic oxides.
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`Page 023
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`I:’~re II1-1
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`Schematic Diagram for Glass Production Cycle
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`LIMESTONE
`MINING
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`I.
`I
`I
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`CULLET
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`RECYCLING
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`GLASS
`CONTAINERS
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`CONSUMERS
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`~POSAL
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`I:iPJre 111-2
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`Schematic Diagram for Production of Ethylene-Based Plastics (HOPE) and PET
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`i
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`PET
`RESIN
`MANUFACTURE
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`DISPOSAl.
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`I! RESIN
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`Ad~apted ~ Fran~ln Associates, Comparative ~er~ and Environmental Impacts for So~ Drink Delivery S~tems, Ma_~h 1989.
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`Exhibit 1030
`Page 024
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`Mining and Processing of Mifi~erais. The’four major inputs used in glass
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`production are all naturally occurring minerals which require minimal processing prior to
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`use. Sand is mined in open quarries and requires little preparation. The principal impact is
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`damage to theland surface via excavation, disposal of overburden, erosion and stream
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`sedimentation. Ot~en, there is a need for land reclamation. Some quarries are converted
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`to ponds or wetlands as pa.rt of the reclamation process.
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`Limestone and Feldspar. These minerals are also mined in open quarries. T-he
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`minerals must be crushed and screened. Crushing causes fugitive emissions of dust. In ¯
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`addition to damage to the land surface, there is potential for soil erosion and sedimentation
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`of streams. Moreover, rock overburdens must be disposed and the land must be
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`reclaimed.
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`Soda Ash. Soda ash requires more processing than the other minerals used in
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`glass production. Although it can be produced synthetically (with the Solvay Process), the
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`U.S. glass industry primarily uses soda ash (sodium carbonate) from naturally occurring
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`minerals (trona ore and brines). Mined trona ore is crushed, graded and calcined (roasted)
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`at high temperatures to form crude sodium carbonate, which is then recrystalized in
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`solution and dried to form the ’purified product. Where soda ash is produced from brine
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`(salt water deposits), the brine is pumped out of the earth and purified via several steps,
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`including carbonation and calcining.~o
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`Wastewater from soda ash production contains ore impurities, treatment
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`chemicals, and unrecovered sodium carbonate. Wastewater is disposed of in evaporation
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`ponds. There is no discharge of soda ash wastewater to navigable waterways and EPA’
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`has exempted the soda ash industry from regulation under the federal Clean Water Act.~~
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`However, it is conceivable that such ponds may contribute to ground and surface water
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`Exhibit 1030
`Page 025
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`contamination. Paniculate matter is the only significant air emission from soda ash
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`plants. ~ ~2
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`The Glass Container Plant. Raw materials and cullet are shipped to the plant and
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`stored. The cullet must be crushed prior to mixing with the mineral inputs. The
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`regenerative furnaces used in most glass container plants are divided into two stages: the
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`first stage melts the batch by heating it to about 2800° F; the second gradually lowers the
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`temperature to prevent small gas bubbles.
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`After further cooling in the "forehearth," the molten glass is allowed to fall in a
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`stream. The stream is sheared into molten lumps called gobs. The gobs, in turn, fall
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`through tubes into a series of metal molds where the glass is blown and shaped into bottles
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`and jars. Water is used to cool metal surfaces (e.g., the blade which cuts the gobs). In
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`addition, the molds require periodic lubrication to prevent glass from sticking to the metal.
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`surfaces. Glass containers are then allowed to cool. Containers are then annealed
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`(reheated) in o