xvEPA
United States
Environmental Protection
Agency
Pesticides and
Toxic Substances
(TS-778)
EPA/560/2-89/002
Version 1.0
July 1989
Toxic Chemical Release
Inventory Risk
Screening Guide
Volume 1 - The Process
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EPA/560/2-89/002
July 1989
TOXIC CHEMICAL RELEASE INVENTORY RISK SCREENING GUIDE
(VERSION 1.0)
VOLUME 1: THE PROCESS
U.S. Environmental Protection Agency
Office of Toxic Substances
Washington, DC 20460
EPA 560/2-89-002
July 1989
\ Printed on Recycled Paper
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PREFACE
The Emergency Planning and Community Right-to-Know Act of 1986, or
Title III of the Superfund Amendments and Reauthorization Act (SARA) represents
a significant step forward in environmental protection. This Act establishes
several important "firsts" in collecting and sharing information about the
hazardous substances used in our communities. For the first time, communities
have access to information about the amounts, location, and potential effects of
hazardous chemicals being used or stored in designated quantities, and about
accidental releases of hazardous substances in the community. Also for the first
time, under Section 313 of the law, all sectors of society - government, industry,
academia, and the public - will have access to a common set of data regarding
the annual releases of toxic chemicals into the environment. The data will be
readily available through a nationally computerized data base called the Toxic
Chemical Release Inventory (TRI) and through computer-generated microfiche
data sets at county libraries. The TRI is the first national inventory of toxic
chemical releases to all environmental media - land, air, and water - from
industrial facilities. For all these reasons, EPA believes that the Toxic Chemical
Release Inventory will play a major role in helping communities learn about the
toxic chemicals in their area and to make informed decisions on how to safely
and effectively manage these substances.
The reporting does, however, come with its challenges. The purpose of this
guide is to describe some of the challenges raised by the TRI data and to
suggest ways of approaching them. The guide suggests steps that can be
taken to answer two key issues of concern:
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PREFACE (continued)
Setting risk-based priorities for followup investigation of TRI facilities and
chemicals within geographic areas of interest.
Identifying data needs and approaches for collecting information
necessary to respond to health and ecological questions from the
public.
The guide is directed at those individuals who are involved in interpreting
and explaining environmental pollution, exposures, and health risks to the
general public, especially at the local or sub-State level. Many users of this
guide will already be well-versed in evaluating risk and/or in helping members
of the public understand and deal with toxic chemicals, but Title III - particularly,
the Section 313 release data - presents new challenges for everyone.
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ACKNOWLEDGMENTS
This first edition of the TRI Risk Screening Guide (Version 1.0) is a compilation of the
efforts of many individuals dedicated to the objective of providing:
A useful source of risk information on Title III chemicals.
A risk screening procedure that
is quick and easy to use;
is scientifically supportable;
is consistent with other EPA risk screening procedures;
can be used with readily available input data; and
- produces an expression of risk compatible with the type and quality of input
data.
Foremost, I would like to acknowledge the contributions of Linda Saunders of Eastern
Research Group, the principal author of the Guide and my closest working associate, and
Lorraine Hester, my secretary through the ups and downs of this project. Jennifer Helmick of
Eastern Research Group also contributed editorial support in the development of the Guide.
An EPA "Expression of Risk Workgroup" was convened to provide technical guidance
and program office input. Representatives who made significant contributions include Alan
Ehrlich, Frank Gostomski, John Gustafson, Renate Kimbrough, Russ Kinerson, Rose Lew, Paul
Tobin, John Vandenburg, Dianne Groh, and Suzanne Wuerthele.
In addition, several EPA staff provided special support on specific components of the
risk screening procedure. Jim Darr, project manager of Roadmaps. arranged for many of the
tables of information on Title III chemicals which appear in Volume II; Gerain Perry provided
background information and tables on the reportable quantity process and values; Bob
Boethling, David Lynch, and Asa Leifer provided the necessary technical support to develop
the environmental fate guidance tables; and Loren Hall, Chris DeRosa, and Jim Cogliano
contributed valuable expert opinion. Loren Hall also assisted in the development of the case
study and the generation of the toxicological potency and environmental fate tables. Chris
DeRosa also provided the EPA reference doses and cancer potency values used to generate
part of Appendix A (Volume II).
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An external committee comprised of representatives from State and local governments and
environmental interest groups was also established to provide expert opinion on the subject
matter and its presentation in the guide. Members of this committee are:
George Aburn, Maryland Air Management Administration
Carl Birns, Kansas Department of Health and Environment
J. Wayne Cropp, Tennessee Air Pollution Control Bureau
Richard Dime, New Jersey Department of Environmental Protection
Bob Hodanbosi, Ohio Department of Environmental Protection
Jill Upoti, New Jersey Department of Environmental Protection
Fred Millar, Environmental Policy Institute
Jack Root, Arizona Department of Environmental Quality
Jim Setzer, Georgia Department of Natural Resources
Deborah Sheiman, Natural Resources Defense Council
Chris Wiant, Colorado TRI-County Health Department
Useful suggestions were also provided by a multitude of individuals, too numerous to list,
from all sectors of society, including government, industry, private consultants, and academia,
during the national "field test" of the Draft Risk Screening Guide in the fall of 1988.
Lastly, my management in the Office of Toxic Substances, i.e., Chuck Elkins, Office
Director, and Joe Merenda, Division Director, deserve credit for the foresight to devote
resources to the development of this manual in advance of requests for guidance on the use
of the TRI data.
I hope you find the TRI Risk Screening Guide useful in your efforts to determine the
potential health and environmental significance of the TRI data.
David Klauder, Ph.D.
Director,
Regional Risk Guidance Staff
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TABLE OF CONTENTS
VOLUME I
EXECUTIVE SUMMARY
ABBREVIATIONS AND ACRONYMS
GLOSSARY OF TERMS USED IN THE GUIDE
SECTION 1 - BACKGROUND
Toxic Chemical Release Reporting (Section 313)
Who Must Report
Chemicals Subject to Reporting
Releases Subject to Reporting
Burst Versus Routine Releases
The Limitations of the Toxic Release Inventory
Chemical Scope ,
Facilities Covered
Completeness of the Data
Reporting Errors
Looking Ahead
Availability of the TRI
Using the TRI
Exhibit 1 - Sources of Wastes
References
HI
vii
1
3
3
4
4
5
5
6
6
7
7
7
8
8
10
11
SECTION II - ELEMENTS OF RISK SCREENING
Toxicological Potency
13
14
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Exposure Evaluation
15
Plausible Exposure Pathways
Potential Environmental Levels
Risk Characterization
Exhibit 2 : Human Health Effects of Concern As
Identified Under Section 313
Exhibit 3 - Ecological Effects of Concern As
Identified Under Section 313
Exhibit 4 - Factors Affecting Toxicity
References
SECTION III - THE RISK SCREENING SYSTEM
Using the Risk Screening System
Before Beginning
How It Works
Toxicological Potency
Exposure Evaluation
Relative Risk Characterization
Case Study
After Screening - Then What?
The Qualitative Risk Screening Procedure
Releases to Air
Releases to Surface Water or POTW
Releases to Land
Figure 1 - Inner and Outer Zones: An Air Example
Facility Worksheet (Site-Specific Data)
Facility Worksheet (Chemical-Specific Data)
Relative Risk Worksheet
References
17
17
21
22
23
24
25
27
28
28
28
29
29
30
30
30
32
32
36
41
50
51
53
55
57
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SECTION IV - RESPONDING TO QUESTIONS
Setting Up a Communications System
How Communities View Risk
Rules of Risk Communication
The Importance of Citizen Participation
Followup
Exhibit 5 - Questions That May Be Asked
Exhibit 6 - Action Check List
Exhibit 7 - Factors Important in Risk Perception
and Evaluation
References
SECTION V - RESOURCES
Organizations
Training
Fact Sheets and Profiles
Data Bases
Hotlines
Exhibit 8 - Questions to Ask a Company's Technical
Contact
Exhibit 9 - EPA Regional Section 313 Contacts
Exhibit 10 - State Emergency Response Commissions, Regional
Section 313 Contacts, and State Designates
Agencies
Exhibit 11 - State/Local Poison Control Centers
59
60
60
61
62
64
65
66
71
73
77
77
80
80
81
82
87
88
89
100
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VOLUME II
APPENDIX A - TITLE III TOXICOLOGICAL POTENCY INDICES
Reportable Quantities (RQs)
Threshold Planning Quantities (TPQs)
Reference Doses (RfDs)
Cancer Potency
Aquatic Water Quality Criteria
Title III Toxicological Indices
APPENDIX B - ATMOSPHERIC CONCENTRATIONS
A-1
A-2
A-4
A-5
A-6
A-7
A-9
B-1
APPENDIX C - QUANTITY OF RELEASE C-1
Table C1 - Median Release Amounts by Chemical and Medium C-3
Table C2 - Toxic Chemical Release Inventory Submissions by SIC Code C-11
APPENDIX D - ENVIRONMENTAL FATE CHARACTERISTICS OF TRI CHEMICALS D-1
APPENDIX E - RELEASE GUIDANCE: TYPES, FREQUENCY, CONTROLS, AND E-1
ESTIMATION METHODS
Categories for Section 313 Chemicals E-2
Release Information E-4
APPENDIX F - CASE STUDY F-1
APPENDIX G - SYSTEMS AND MODELS FOR EVALUATING RISKS OF G-1
ENVIRONMENTAL POLLUTANTS
Chemical Scoring System for Hazard and Exposure G-1
Assessment (CSSHEA)
Graphical Exposure Modeling System (GEMS) G-2
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Hazard Ranking System (MRS)
Hazard Analysis Model
Modified Hazardous^TrPoirutant Prioritization System (MHAPPS)
Remedial Action Priority System (RAPS)
Human Exposure Model (HEM)
APPENDIX H - ROADMAPS
EPA's SARA Section 313 Roadmap Data Base
Information Presented in this Appendix
Regulatory Levels and Standards
States with Ambient Air Standards and Drinking Water Standards
Air Quality Criteria Documents (AQCD), Office of Health and
Environmental Assessment
Ambient Water Quality Criteria Documents (WQCD)
American Conference of Governmental Industrial Hygienists
(ACGIH), Threshold Limit Values and Biological Exposure
Indices
AQUIRE, Chemical Information System
CEPP/SARA Title III Section 302 Profiles
Chemical Hazard Information Profiles (CHIP)
Chemical Hazards Response Information System (CHRIS)
CHEMTRACK
Clement Associates, Inc. Chemical, Physical, and Biological
Properties of Compounds Present at Hazardous Waste Sites
Drinking Water Criteria Documents
ENVIROFATE, Cjjemical Information System
Exposure Assessments (EA)
G-3
G-4
G-5
G-6
G-7
H-1
H-1
H-2
H-3
H-15
H-26
H-28
H-29
H-30
H-31
H-32
H-33
H-34
H-35
H-36
H-37
H-38
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Federal-State Toxicoiogical and Regulatory Alliance
Committee (FSTRAC)
"For Your Information" (FYI Reports)
GENETOX, Chemical Information System
Hazardous Substances Data Bank, National Library of
Medicine TOXNET
Health Assessment Documents (HAD), Used by the Office of
Air Quality Planning and Standards
Health Effects Assessments (HEAs)
Health and Environmental Effects Profiles (HEEPs) and
Health and Environmental Effects Documents (HEEDs)
(ARC Monographs
Information System for Hazardous Organics in Water (ISHOW)
EPA's Integrated Risk Information System (IRIS)
LOG P and Related Parameters Database
National Air Toxics Information Clearinghouse (NATICH)
NIOSH Criteria Documents (NIOSHCRIT)
NIOSH Current Intelligence Bulletins (NIOSHCIB)
Office of Drinking Water Health Advisory Program (ODWHAP)
Oil and Hazardous Materials - Technical Assistance Data
System (OHM-TADS)
Registry of Toxic Effects of Chemical Substances (RTECS)
NIOSH '
Reportable Quantities for Carcinogens in Hazardous Substances
(RQCAR)
Reportable Quantities for Chronically Toxic Hazardous
Substances (RQTOX)
Risk Assessments: Carcinogenicity, Mutagenicity,
Teratogenicity, Reproductive Effects (RA; CA; MA; TA;
or ReproAssess)
H-39
H-40
H-42
H-43
H-44
H-45
H-46
H-47
H-49
H-50
H-51
H-52
H-54
H-55
H-56
H-57
H-58
H-60
H-61
H-62
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STORET Water Quality Database
Toxicity One-Liners
TSCA Section 8(e) Notices
APPENDIX I - EPA HAZARDOUS SUBSTANCE FACT SHEET
H-63
H-64
H-65
1-1
APPENDIX J - EPA CHEMICAL PROFILE
J-1
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EXECUTIVE SUMMARY
The Emergency Planning and Community Right-to-Know Act (Title III) of the Superfund
Amendments and Reauthorization Act (SARA) was designed to help communities deal safely
and effectively with the many hazardous substances that are used in our society. The toxic
chemical release reporting section (Section 313 of the Act) is the focus of this guide. Under
Section 313, certain businesses must report annually on their total aggregate releases of toxic
chemicals to air, water, and land. (Over 300 chemicals are subject to reporting.) These
aggregate data are referred to as the Toxic Chemical Release Inventory (TRI).
In the first years of reporting, there will be some initial difficulties in understanding and
using the TRI data. Because the reporting is new, the release data are expected to be limited
in type and quality. The data quality is expected to improve, however, in subsequent years
through a program of outreach, technical audits, facility inspections, and enforcement.
The risk screening system described in this guide is consistent with EPA's understanding
of the type and expected quality of the Section 313 data and readily available supplementary
data. The system is intended to serve as a framework for initial analyses .of the TRI data. It
can be viewed as a tool for setting risk-based priorities for followup investigation of TRI facilities
and chemicals within geographic areas of interest. The system relies on general risk
assessment principles and results in a qualitative (high, moderate, low) expression of risk. The
data requirements are, however, less detailed than those for a formal risk assessment.
Supplementary information will be required to fully characterize the risks from the Section
313 chemical releases, and to put these risks into perspective with those resulting from other
sources of chemicals in the community. Therefore, the guide provides sources of information
for obtaining these data, including organizations, fact sheets, profiles, training courses, data
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bases, models, hotlines, and contacts. The guide also includes information from Roadmaps.
a Section 313 chemical information directory.
The risk screening procedure described in this guide will be of limited value in answering
health-related questions from citizens (e.g., "Will I get cancer?" or "Is my cancer the result of
past exposures to these chemical releases?"). To address these questions, the guide presents
strategies for handling inquiries, tracking phone calls, assembling information, disseminating
Information, and building bridges with other organizations. It also provides guidance in
conveying risk-related information to the public. A number of risk communication principles
are described in the guide, along with a comprehensive listing of risk communication texts.
The TRI reporting will provide health and environmental officials with an unprecedented
amount of data concerning the release of toxic chemicals into the environment; these data will
be an important supplement to existing programs. It should be noted that this guide focuses
on the TRI chemicals because the release reporting provides a readily available source of
aggregate data upon which comparisons can be made and priorities established. If sufficient
release and toxioological data are available for other chemicals (including the Extremely
Hazardous Substances under Section 302 and the CERCLA hazardous substances under 304),
the system could be adapted to assess those chemicals.
The more information communities have about environmental hazards in their communities,
the better equipped they will be to ensure individuals' protection from unacceptable risks to
their health and safety. The TRI reporting, together with the other information gathered under
Title III, is an important step in this direction.
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ABBREVIATIONS AND ACRONYMS
ACGIH American Conference of Governmental Industrial Hygienists
AirRISC Air Risk Information Support Center
ATSDR Agency for Toxic Substances Disease Registry, Centers for Disease Control
BAT Best Available Technology
BACT Best Available Control Technology
BCF Bioconcentration Factor
BPT Best Practicable Technology
CAMEO Computer-assisted Management Emergency Operations
CAS Chemical Abstract Services
CCC Criterion Continuous Concentration
CD/ROM Compact Disk/Read Only Memory
CEPP Chemical Emergency Preparedness Program
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980
CMA Chemical Manufacturers Association
COMFiche Computer Output Microfiche
CSSHEA Chemical Scoring System for Hazard and Exposure Assessment
CTC Control Technology Center
CMC Criterion Maximum Concentration
DOE U.S. Department of Energy
EHS Extremely Hazardous Substance
EIS/C Emergency Information System/Chemical
EPA U.S. Environmental Protection Agency
GEMS Graphical Exposure Modeling System
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GIS
HEED
HEM
HRS
IRIS
ISCLT
LAER
LEPC
MATC
MHAPPS
MSDS
NATICH
NCC
NCI
NCIC
NIOSH
NLM
NOAA
NPL
NRG
NTIS
ODW
OSHA
OSWER
OTS
Geographic Information System
Health and Environmental Effects Document
1
Human Exposure Model
Hazard Ranking System
Integrated Risk Information System
Industrial Source Complex Long-Term Model
Lowest Achievable Emission Rate
Local Emergency Planning Committee
Maximum Acceptable Toxicant Concentrations
Modified Hazardous Air Pollution Prioritization System
Material Safety Data Sheet
National Air Toxics Information Clearinghouse
National Computer Center, U.S. EPA
National Cancer Institute
National Cartographic Information Center
National Institute of Occupational Safety and Health
National Library of Medicine
National Oceanic and Atmospheric Administration
National Priorities List
National Response Center
National Technical Information Services
Office of Drinking Water, U.S. EPA
Occupational Safety and Health Administration, U.S. Department of Labor
Office of Solid Waste and Emergency Response, U.S. EPA
Office of Toxic Substances, U.S. EPA.
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PCGEMS Graphical Exposure Modeling System - Personal Computer version
PIC Public Information Center
POTW Publicly Owned Treatment Works
RAPS Remedial Action Priority System
RCRA Resource Conservation and Recovery Act
RfD Reference Dose
RQ Reportable Quantity
RTECS Registry of Toxic Effects of Chemical Substances
SARA Superfund Amendments and Reauthorization Act of 1986
SDWA Safe Drinking Water Act
SERC State Emergency Response Commission
SIC Standard Industrial Classification
STAR Stability Array
TOXNET Toxicology Data Network
TPQ Threshold Planning Quantity
TRI Toxic Chemical Release Inventory
TSCA Toxic Substances Control Act
UF Uncertainty Factor
USGS U.S. Geological Survey
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GLOSSARY OF TERMS USED IN THE GUIDE
Absorption - The passage of one substance into or through another, often via a membrane
such as the skin, lungs, or gastrointestinal tract.
Acute exposure - A one-time or short-term exposure (usually high level).
Additive effect - A toxicologic interaction in which the combined effect of two chemicals is
equal to the sum of the effect of each chemical given alone (e.g., 2+3=5).
Adsorption - The attachment of the molecules of a liquid or gaseous substance to the surface
of a solid.
Adverse effect - A structural, functional, behavioral, or biochemical change that is deleterious
to the health of an organism.
Ambient - Environmental or surrounding conditions. For example, ambient temperatures are
temperatures of the surrounding area (e.g., air or water).
Antagonistic effect - An effect that occurs when two chemicals administered together interfere
with each other's actions, or one chemical interferes with the action of the other chemical.
Thus, the combined effect of the two chemicals is less than the sum of the effect of each
chemical given alone (e.g., 2 + 3 = 1).
Aquifer - An underground bed or layer or earth, gravel, or porous rock containing usable
amounts of ground water that can supply wells and springs.
Bioaccumuiation - The progressive increase in tissue concentrations of chemicals in organisms
higher in the food chain (sometimes referred to as biomagnification).
Bioavailabilitv - The degree to which an organism or target tissue has access to a substance
after chemical administration or exposure.
Bioconcentration - Increased concentrations of a chemical in an organism compared to the
surrounding environment.
Biodearadation - Decomposition of a substance into more elementary substances by the
action of microorganisms, such as bacteria and fungi.
Burst - A rapid release of short duration.
By-product - Any material other than the principal product that is generated during the
manufacture, processing, use, or disposal of another material.
Cancer potency - The expression of the relationship between the tumorigenic response and
the administered dose to target or test organisms.
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Carcinogen - An agent capable of producing cancer OR an agent capable of causing
malignant or non-malignant tumor formation.
Chemical mixture - Any combination of two or more chemicals, if the combination is not, in
whole or in part, the result of a chemical reaction^ the combination was produced by
a chemical reaction but could have been produced without a chemical reaction, it is also
treated as a mixture under Title III. A mixture also includes any combination which
consists of a chemical and associated impurities.
Chronic effect - Adverse responses that become apparent in an organism after prolonged or
repeated exposures, or after some time has elapsed from an initial exposure.
Chronic exposure - Exposure (usually low level) during a major portion of a lifetime to an
environmental agent. Compare with acute exposure.
CD/ROM (Compact Disc/Read Only Memory) - An optically-read laser disc, capable of storing
50 million characters (as compared to a magnetic floppy disc, which can store only 1.2
million characters). Information can be read from the disc, but not added or deleted.
COMFfche (Computer Output Microfiche) - Microfiche that has been formatted, processed,
and output directly by a computer (as compared to photographic reduction from a paper
original).
Criterion Continuous Concentration fCCCl - The U.S. EPA national water quality criteria
recommendation for the highest in-stream concentration of a toxicant to which organisms
can be exposed indefinitely without adverse effect.
Criterion Maximum Concentration (CMC) - The U.S. EPA national water quality criteria
recommendation for the highest in-stream concentration of a toxicant or effluent to which
organisms can be exposed for a brief period of time without causing mortality.
Degradation - Transformation of chemicals into smaller molecules through chemical,
photochemical, or biological processes.
Demography - The study of the characteristics of human populations such as size, growth,
density, distribution, and vital statistics.
Developmental toxfcrtv - Adverse effects observed in the developing organism that may result
from exposure prior to conception, during prenatal development, or postnatally to the time
of sexual maturation. Adverse developmental effects may be detected at any point in the
life span of the organism. The major manifestations of developmental toxicity include: 1)
death of the developing organism, 2) structural abnormality, 3) altered growth, and 4)
functional deficiency.
Dose - The amount of a chemical that enters an organism. It is usually expressed as the
amount of the substance per unit of body weight, e.g., mg/kg. The applied dose is the
amount of a chemical (per unit of body weight) at the point of contact (skin, lung,
gastointestinal tract). The delivered dose is the dose to the site or sites of toxic action
(target tissue).
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Dose-response curve - A graphical representation of the relationship between the amount of
a substance administered and the resulting effects.
Dose-response relationship - The relationship between the dose of a chemical and the extent
of adverse health effects.
Environmental fate -.What happens to a chemical in the envirpnment from its point of release
to point of exposure with organisms/populations of interest. The environmental fate of a
chemical is the sum total of all chemical and biological transformation processes acting
; on the chemical.
Environmental level - A qualitative characterization of amounts and concentrations of a
chemical in the environment at the point of contact with populations of interest.
Epidemiology - The study of the causes and distribution patterns of diseases in human and
animal populations. Such studies typically compare the health status of exposed groups
, with comparable unexposed (control) groups.
Exposure - Contact by an organism with a chemical or physical agent. The magnitude of
exposure is determined by measuring or estimating the amount of an agent available at
the exchange boundaries, i.e., lungs, gut, skin, during some specified time.
Exposure assessment - The determination or estimation (qualitative or quantitative) of the
magnitude, frequency, duration, and route of exposure. The assessment may include
past, current,, and anticipated exposures.
Exposure pathway - The route by which an organism comes in contact with a chemical (e.g.,
ingestion via water or food; inhalation via smoke or vapors; absorption through the skin
via consumer products such as solvents).
Extrapolation -The estimation of a value beyond the known range, on the basis of certain
variables within that known range, which the estimated value is assumed to follow.
EHSs (Extremely Hazardous Substances) - Chemicals that have the potential for causing
death or irreversible toxicity in unprotected populations after relatively short exposure
periods at low doses. (They.are acutely toxic.) On the basis of toxicity criteria, EPA
identified a list of chemicals (Section 302 of Title III of SARA) with acute toxicity.
Facility - All buildings, equipment, structures, and other stationary items which are located on
a single site or on adjacent sites and which are owned or operated by the same person
(or by any person who controls, is controlled by, or is under common control with, such
person).
Ground-Water Classification System Guidelines - EPA has established three classes of
ground waters to receive different levels of protection under its Final Ground-Water
Classification Guidelines and Ground-Water Protection Strategy (EPA, 1988 and 1984).
Class I, or Special Ground Waters, are ground waters highly vulnerable to contamination
and that are either irreplaceable sources of drinking water or ecologically vital ground
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waters (i.e., ground waters supplying a unique and easily disrupted ecosystem). Class
II ground waters are all non-Class I current and potential sources of drinking water or
water serving other beneficial purposes (e.g., irrigation, animal husbandry); Class II has
been defined to include the majority of the nation's ground waters that may be affected
by human activity. Class III ground waters are not a potential source of drinking water
(using common current purification technologies), and have limited beneficial uses.
Half-life - The time in which the concentration of a substance will be reduced by half. Half
life is a measure of the chemical's persistence in the environment.
Hydrolysis - Decomposition of a chemical compound by reaction with water, such as the
cleavage of an ester into the corresponding acid and alcohol.
Individual risk - The probability that an individual person will experience an adverse effect.
LQtf( (Lethal Concentration Low) - The lowest concentration, in air or water, of a chemical
at which some test animals will die following exposure.
* {Median Lethal Concentration! - The concentration at which 50% of the test organisms
will die when exposed to a substance for a specified period of time. Concentration is
usually given In parts per million (ppm), milligrams per cubic meter (mg/rn3), or milligrams
per liter (mg/L). The lower the LCJO, the more toxic the substance.
(Lethal Dose Low) - The lowest dose of chemical at which some test animals will die
following exposure.
(Median Lethal Dose) - The amount of a substance (applied dose) at which 50% of the
test organisms will die within a specified period of time. Dose is usually given in
milligrams per kilogram of body weight. The lower the LD50, the more toxic the substance.
Leaching - The process by which soluble chemicals are dissolved and carried away or moved
to a lower layer of soil by a percolating liquid such as water.
Lethal - Causing or capable of causing death.
LOAEL (Lowest-Observed-Adverse-Effect-Level) - The lowest dose in an experimental study
at which a statistically or biologically significant adverse effect is seen.
Local Emergency Planning Committee (LEPC) - A committee appointed by the State
Emergency Response Commission (SERC) as required by Sections 301 to 303 of Title III
of SARA to formulate a comprehensive emergency plan for its district.
Log P factanol/water partition coefficient) - A number derived from the ratio between
solubilities in nonpolar (e.g., fat) and polar (e.g., water) substances. Generally, the higher
the partition coefficient and Log P, the greater the likelihood that a substance will
accumulate in the organism.
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MATC /Maximum Acceptable Truant Concentration) - The mean value between the highest
no-effect concentration and the lowest concentration causing a statistically significant effect
in a chronic toxicity test on an environmental species.
MSDS (Material Safety Data Sheet) - A compilation of information required under the OSHA
Communications Standard on the identity of products and hazardous substances found
in the workplace, their toxicity, physical properties and hgzards, exposure limits, and
precautions for handling. Section 311 of SARA requires facilities to submit MSDSs under
certain circumstances.
Mutaaen - An agent capable of causing a change in the genetic material (DNA) of a cell.
Neurotoxicitv - Any adverse effect on the nervous system. This includes pathological changes
to the structure or functioning of the brain, spinal cord, or peripheral nerves, including
neuromuscular and behavioral effects.
NOAEL fNo-Observed-Adverse-Effect-Level) - The highest experimental dose at which there
is no statistically significant increase in a toxicologically significant effect.
Non-Point Source - The discharge of chemicals from locations that do not have a stationary
location or specific outlet. Examples are automobile emissions and pesticide storm runoff
into rivers.
Oxidation - The chemical reaction of oxygen (or other electron acceptors) with other
substances, as in burning and rusting.
Photolysis - The degradation of a chemical caused by exposure to light.
Point source - Stationary locations from which chemicals are discharged to the environment,
such as smokestacks and effluent pipelines.
pom (parts per million) - An expression describing a small concentration or amount, of
substance in a million parts of another material. "A drop in the bucket" is, literally,
approximately 1 ppm. (One drop of water in a standard 2.5 gallon bucket is 5 ppm.)
Qualitative - Describing the identity or characteristics of something with little or no indication
of amount or degree. '
Quantitative - Describing the amounts, concentrations, or degrees-of a thing or its
characteristics.
Release - Any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting,
escaping, leaching, dumping, or disposing into the environment (including the
abandonment or discarding of barrels, containers, and other closed receptacles) of any
toxic chemical.
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.RfD (Reference dose) * An estimate (with uncertainty spanning perhaps an order of magnitude
or greater) of the daily exposure to the human population (including sensitive subgroups)
that is likely to be without appreciable risk of deleterious effects during a lifetime The Rfd
fs expressed in units of mg/kg/day.
Bisk - The nature and probability of occurrence of an adverse effect on humans or
an environmental species.
Risk analysis - In the context of Section 302 of SARA, risk analysis is the third of a three-
step hazards analysis process for emergency planning. It requires an estimation of both
the occurrence of an accidental chemical release (unique to this process) as well as the
subsequent potential for exposure (with emphasis on human exposure to extremely
hazardous substances). It is a flexible, judgmental exercise that results in qualitative risk
statements.
Risk assessment - The process of estimating the probability of occurrence of adverse health
or ecological effects. Human health risk assessment includes: (1) description of the
potential adverse effects; (2) estimation of the extent of effects on humans exposed to a
given amount of chemical; (3) judgments on the type and number of persons affected
under different conditions of exposure; and (4) characterization of the uncertainties
incurred in determining the risk.
Rtek management - The decision-making process that uses the results of risk assessment to
evaluate and select regulatory and non-regulatory solutions to risk. Risk management
includes consideration of technical, legal, political, economic, and social factors.
Rfsk screening - A type of risk assessment using limited data. The process results in a
relative expression of risk (e.g., high, medium, low). Risk screening is useful for
establishing risk-based priorities and information needs for followup chemical- or site-
specific risk assessment activities. Although the risk screening process relies on general
risk assessment principles, the data input requirements are less demanding than those for
risk assessment, and the analysis is less rigorous than a formal risk assessment.
Route of exposure - The pathway by which the chemical is introduced into an organism (e g
inhalation, ingestion, or dermal exposure).
RQ (Reportable Quantity) - The quantity of a hazardous substance that triggers reporting
under CERCLA. If a substance is released in a quantity that exceeds its RQ, the release
must be reported to the National Response Center (NRC), as well as to the State
£ r£ency ResP°nse Commission (SERC) and the Local Emergency Planning Committee
(LEPC) for areas likely to be affected by the release.
Safe - Condition of exposure under which there is no risk of practical harm.
Sensitive Environment - Geographical areas bounded by legal, social, commercial, or
biological constraints. These include areas such as wetlands and national parks in need
of protection by Federal, State, or even municipal statutes; areas deemed by society as
desirable and therefore in need of protection from chemical contamination; areas where
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some human food source is grown (e.g., crops, catfish, or rainbow trout) or areas that are
used commercially (e.g., lakes or ponds where a fee is charged for boating or fishing);
and areas vital for maintenance of a particular population (be it terrestrial or aquatic),
including shoreline/wetland areas vital to the breeding or rearing of young, but not
necessarily endangered, species. Specialized habitats such as bogs and marshes also
may be considered sensitive environments.
Sensitive populations - Groups of people that may be more susceptible than the general
population (due to preexisting health conditions [e.g., asthmatics] or age [e.g., infants
and the elderly]) to the toxic effects of a chemical release.
Site - The point of release of, or potential exposure to, Section 313 emission.
Source - The location from which a chemical may be released to the environment. These
include intended release points (e.g., effluent pipes, smoke stacks) and unintended release
points (e.g., leaky valves).
Stability Array (STAR) - Statistical data from meteorological stations around the country that
provide meteorological input for modeling.
State Emergency Response Commission (SERC) - Commission appointed by each State
governor according to the requirements of Sections 301 to 303 of Title III of SARA. Duties
of the commission include designating emergency .planning districts, appointing local
emergency planning committees (LEPCs), supervising and coordinating the activities of
planning committees, reviewing emergency plans, receiving chemical release notifications,
and establishing procedures for receiving and processing requests from the public for
information.
Storage - Methods of keeping raw materials, finished goods, or products while awaiting use,
shipment, or consumption.
Super-fund - Federal authority, established by the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) in 1980, to respond directly to releases or
threatened releases of hazardous substances that may endanger health or welfare.
Cleanups are paid for out of a revolving fund, originally provided by general revenue plus
a tax on the chemical industry, and reimbursed through subsequent recovery from those
found responsible for the damage.
Svneraistic effect - Interaction between two or more substances that results in an effect
greater than the sum of their individual effects (e.g., 2+3=20).
Teratoaen - An agent capable of causing malformations or birth defects in the developing
organism following maternal exposure.
Threshold dose - The lowest amount or concentration of a chemical needed to produce a
measurable effect.
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TPQ (Threshold Planning Quantity) - The amount of an extremely hazardous substance
present at a facility above which the facility's owner/operator must give emergency
planning notification to the SERC and LEPC.
Tftte IH - A provision of the Superfund Amendments and Reauthorization Act (SARA) that
became law in 1986. Also known as the Emergency Planning and Community Right-to-
Khow Act, Title III establishes requirements for Federal, State, and local governments and
industry regarding emergency planning and community right-to-know reporting on
hazardous and toxic chemicals.
Toxic Chemical Release Inventory (TRI) - The data base containing annual toxic chemical
release reports submitted to EPA by certain manufacturing facilities, specified in Section
313 of Title III. The TRI is available to the public in county libraries through a national
computerized data base and through other means.
Toxte Chemical Release Form (Form R) - Information form required to be submitted by
facilities that manufacture, process, or otherwise use (in quantities above a specified
amount) chemicals listed in Section 313 of Title III of SARA.
Toxlctty - The ability of a substance to impair an organism, the central nervous system, or
other functional capacity, or enhance its susceptibility to the deleterious effects of other
substances.
Toxlcoloqical potency evaluation - A determination of whether a chemical causes an adverse
effect and, if so, at what dose the effect occurs.
Transport - The physical movement of a chemical in the environment.
Transformation - The chemical or biological conversion of a chemical into other chemical
forms, e.g., degradation of an organic hydrocarbon to carbon dioxide and water.
Uncertainty factor - Factors used in operationally deriving the RfD from experimental data.
These factors are intended to account for: (1) the variation in sensitivity among the
members of the human population; (2) the uncertainty in extrapolating animal data to the
case of humans; (3) the uncertainty in extrapolating from data obtained in a study that is
of less-than-lifetime exposure; (4) the uncertainty in using LOAEL rather than NOAEL data;
and (5) the inability of any single study to adequately address all possible adverse
outcomes in man.
Unit risk factor - A statistical upper bound of the probability than an individual will develop
cancer from continuous exposure to one unit of a carcinogen over a lifetime (70 years).
The unit risk factor is derived from a measure of the cancer potency of a carcinogen.
Volatilization - The process of evaporation or sublimation (change in physical state from the
liquid or solid to gaseous).
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Wellhead protection areas - As defined by the 1986 Safe Drinking Water Act Amendments,
Subsection 1428(e), a wellhead protection area is the surface and subsurface area
surrounding a water well or wellfield, supplying a public water system through which
contaminants are reasonably likely to move toward and reach the water well or wellfield.
The extent of a wellfield protection area within a State, necessary to provide protection
from contaminants which may have an adverse human health effect, is to be determined
by the State according to its Wellhead Protection Area Program submitted in accordance
with the statute.
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SECTION I - BACKGROUND
In recent years, the American public has become increasingly aware of and concerned
about the risks associated with exposure to toxic industrial chemicals. In 1984, a release of
toxic gas from a pesticides plant in Bhopal, India, killed or seriously injured thousands of
people. That tragedy, followed by a chemical release in West Virginia, set in motion a number
of emergency planning and information gathering activities in the United States. The U.S.
Environmental Protection Agency (EPA) established a voluntary program, called the Chemical
Emergency Preparedness Program (CEPP) to raise awareness about the potential for chemical
accidents and encourage communities to develop emergency plans. At the same time, the
Chemical Manufacturers Association (CMA) set up a program encouraging plant managers to
participate in local emergency planning and to explain their companies' operations to nearby
residents.1
The culmination of these and other efforts was the passage of a new law in October 1986.
The law, the Emergency Planning and Community Right-to-Know Act2 enacted as Title III of the
Superfund Amendments and Reauthorization Act (SARA, Public Law 99-499), was designed to
help communities deal safely and effectively with the many hazardous substances that are used
in our society. Also known as Title III, this law establishes requirements for:
Local, State, and Federal governments and industry regarding emergency planning
and emergency release notification.
Community right-to-know reporting on hazardous and toxic chemicals.
Under Title III, certain businesses must submit reports on the hazardous materials that
they manufacture, use, store, process, and release into the environment. Title III requires the
establishment of State Emergency Response Commissions (SERCs) and Local Emergency
Planning Committees (LEPCs). These entities have substantial responsibilities for implementing
Title III at the State and local levels. In addition, other agencies within the State and local
government may have responsibilities for managing and interpreting the data made available
under the Act.
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There gre four major provisions of the Act:3
" Panning for Chemical Emergencies. Under Sections 301 to 303. Governors appoint
SERCs, and SERCs establish and coordinate LEPCs. LEPCs develop and annually
review emergency response plans. Businesses are required to participate in
emergency planning and to notify SERCs and LEPCs if they have Extremely
Hazardous Substances (EHSs) present above threshold planning quantities. Over 300
chemicals are currently listed as EHSs based upon criteria indicating that these
substances are acutely lethal in small concentrations.
Emergency Notification of Chemical Accidents and Releases. Under Section 304.
businesses must report accidental releases of both EHSs and over 700 listed
hazardous substances defined under the Comprehensive Environmental Response,
Compensation, and Lability Act (CERCLA, also known as Superfund). Releases of
these chemicals above certain amounts must be.reported to the National Response
Center, the SERC, and the LEPC.
* Reporting of Hazardous Chemical Inventories. Under Sections 311 and 312
businesses must provide information to SERCs, LEPCs, and local fire departments
about hazardous chemicals that they produce, use, or store in designated amounts.
Businesses must submit Material Safety Data Sheets (MSDSs), which contain
information on a chemical's physical properties and health effects. The Occupational
Safety and Health Administration (OSHA) requires companies to keep MSDSs on file
for all hazardous chemicals used in the workplace. Companies must also submit
annual inventories of these same hazardous chemicals, containing information on
quantities, hazard categories, and other information.
" Toxic Chemical Release Reporting. Under Section 313. certain businesses must
submit annual reports to EPA and the State in which they operate for certain specified
toxic chemicals manufactured, imported, processed, or used at the facility. Facilities
must account for the total aggregate releases to the environment, of each toxic
chemical listed under Section 313 for the calendar year. These aggregate data are
referred to as the Toxic Chemical Release Inventory (TRI). EPA is mandated to make
this information available to the general public in a readily accessible form. The first
annual report (for the calendar year 1987) was due to EPA and the designated State
agencies on July 1, 1988.
There are two other sections of the Title III: Section 322 (trade secrets) and Sections 325
to 326 (penalties and citizen suits). Since the focus of this manual is Section 313, the guide
does not attempt to provide comprehensive descriptions of all sections of Title III. For more
information on the Act, see the reference list provided at the back of this section. In addition,
this guide should not be used in lieu of Federal Register documents or the Code of Federal
Regulations for purposes of compliance. Federal Register citations for the four sections of the
Act described above are provided in the reference list.
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TOXIC CHEMICAL RELEASE REPORTING (SECTION 313)
Who Must Report4
Plants, factories, or other facilities that are classified in the Standard Industrial
Classification (SIC) codes 20 through 39:
SIC
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
Industry Group
Food
Tobacco
Textiles
Apparel
Lumber and wood
Furniture
Paper
Printing and publishing
Chemicals
Petroleum and coal
Rubber and plastics
Leather
Stone, clay, and glass
Primary metals
Fabricated metals
Machinery (excluding electrical)
Electrical and electronic equipment
Transportation equipment
Instruments
Miscellaneous manufacturing
AND
Employ the equivalent of 10 or more full-time individuals.
AND Manufacture (including import) or process any of the Section 313 or
chemical categories in amounts greater than 75,000 pounds in 1987;
50,000 pounds in 1 988; or 25,000 pounds in 1 989 and subsequent years.
Use any listed chemical or chemical category in any other way (other
than manufacture) in amounts greater than 10,000 pounds in 1987 and
subsequent years. This includes processing (e.g., using trichloroethylene
to degrease tools) or importing of the listed chemical or chemical
category .
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Chemicals Subject to Reporting5
Over 300 toxic chemicals and chemical categories are subject to reporting under Section
313 (a listing of these chemicals is provided in Roadmaps. Appendix H of Volume II). Listed
chemicals and/or chemical categories that are components of mixtures also are subject to
reporting. The company may use the name of the mixture or the product trade name instead
of the chemical's actual name only if the specific identities of the chemicals in the mixture are
not known.
Companies can claim a chemical's identity as a trade secret, but they must substantiate
such a claim. A $25,000 fine for frivolous trade secret claims has been established under Title
III. If a firm claims a chemical is a trade secret, it must provide a generic name for that
chemical, and that name must be descriptive of the chemical structure. Companies may
withhold only the specific chemical identity of the compound - including chemical -name and
Chemical Abstract Services (CAS) number.
Releases Subject to Reporting
Section 313 requires reporting of the following chemical releases6:
To the air from fugitive or non-point sources. (Fugitive releases are those that are not
released through stacks, vents, or any other confined air stream.)
To the air from stack or point sources.
To the water directly discharged to a receiving stream.
In wastes that are injected underground.
To land on site (including landfills, surface impoundments, or landspreading).
To water discharged to a publicly owned treatment works (POTW).
In wastes transferred offsite for treatment or disposal.
The quantities reported reflect the amounts of chemical released after any onsite treatment
and are specific to the chemical or chemical category subject to reporting. Releases of the
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chemical to "the environment are given in pounds per year. The release quantities represent
the total amount of the chemical released from all possible sources for each medium. For
example, for water sources, releases estimated separately from process outfalls, pollution
control devices, and washing from containers are added and entered under "Discharges to
Water." Some sources of chemical wastes are listed in Exhibit 1.
i ' L1 ."['. " - -
Burst Versus Routine Releases
The releases reported by facilities under Section 313 will include both routine and burst
releases:
"Burst" releases are typically accidental, rapid releases of short duration.
Routine releases are those occurring during the conduct of normal operation at the
M facility, and are typically longer in duration than "bursts."
A reported release may have occurred over the course of a year, or on a single day. It
may be a combination of burst and routine releases. Because facilities are not required to
indicate the frequency, duration, or peak release rate of the release, it will be impossible to
know from the TRI reporting form alone whether a release was accidental or routine, short- or
long-term, or both. For Section 313 chemicals that are also Section 304 chemicals, releases
should be cross-checked to determine if any part of a specific release was accidental.
The guidance presented in this manual is applicable to releases that are longer in term
than bursts, and for which there are limited release data. A separate guide, the Technical
Guide for Hazard Analysis7 has been prepared for burst releases of the EHSs listed under
Section 302 of Title III. For the most part, burst releases of EHSs should be addressed using
the Technical Guide for Hazard Analysis: routine releases should be addressed using this
guide.
THE LIMITATIONS OF THE TOXIC CHEMICAL RELEASE INVENTORY
Toxic chemical release reporting can be viewed as a new beginning in environmental
awareness for both the government and the public. The reporting represents the first
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systematic way of gathering information about the release of specific toxic chemicals in or near
communities and of making these data readily available to the public. Because the-reporting
Is new for everyone - localities, States, the Federal government, manufacturers, processors,
users, and the public - and because the reporting requirements are phased in over time, there
will be some initial difficulties in understanding and using the data. During the first years of
reporting, the release data are therefore expected to be limited in type and quality.
Chemical Scope
The chemicals identified for reporting under Section 313 were drawn from lists developed
by New Jersey and Maryland in implementation of their State right-to-know laws. The
chemicals vary widely in toxicity. Large reported releases of chemicals, of relatively low toxicity
may be of much lesser environmental concern than smaller releases of highly toxic chemicals.
Moreover, the list of chemicals currently covered does not include all toxic chemicals of
concern being released into the environment. Chemicals may be added or deleted from the
list by petition or on the initiative of EPA.
Facilities Covered
Not all industrial releases of the listed chemicals are covered by the reporting
requirements. Those facilities that fall outside the specified range of SIC codes; those with
fewer than 10 full-time employees; and those producing, importing, processing, or using the
designated chemicals below threshold amounts are not required to participate in release
reporting. In addition, fewer facilities are required to report in the first year than in subsequent
years, and not everyone who is obligated to report will do so. Some smaller companies may
not even be aware they are required to report under this new law. EPA currently is
undertaking investigations and enforcement actions to increase the rate of compliance.
There are many sources of toxic chemicals besides industrial processes; these other
sources are not covered by the reporting requirements. For example, chemicals can be
released through consumer products, agricultural uses, and sources such as automobiles.
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Completeness of the Data
Companies are not required to report certain information which could be-important in
assessing the risk associated with the release, For example, while the location of the facility
must be described onihe reporting form, the location of point source releases (such as stack
heights and the locations of surface water discharges) will be uncertain. Also, the identities
of chemicals within mixtures and compound classes reported by the various reporting facilities
will not be known. In addition, much of the data provided by industries will be based on
engineering estimates (not on actual measurements of release), and the approaches used to
develop these estimates often yield errors. If monitoring data are readily available, industries
must use that data to calculate releases. However, no additional monitoring or measurements
are required.
Another limitation is that the data will be summary data, reported in units of pounds per
year; no information on frequency, duration, or peak release is required. This missing
information can also be important in determining the effects of the release on human health
and the environment.
Reporting Errors
Omissions, errors, and inaccuracies are bound to occur in reporting, especially during the
first years, due to unfamiliarity with the reporting requirements and form. For the 1987 calendar
year, for example, approximately 60% of the reporting facilities provided latitude and longitude
data (these data were optional), but over 15% of the figures provided were erroneously listed
as outside the continental United States (for example, in the Gulf of Mexico).8 There also may
be data entry errors, including those made while entering the TRI data into the EPA data base.
Looking Ahead
EPA expects the quality of the data reported to improve in subsequent years as industries
become familiar with the reporting requirements. It is also hoped that the data quality will
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further improve through a program of outreach, technical audits, facility inspections, and
enforcement. In addition, EPA plans to modify the reporting requirements in the future to
obtain additional release information. Finally, EPA has a program to check the reports for
obvious errors, guide companies in filling out forms correctly, and enforce filing requirements.
i
AVAILABILITY OF THE TRI
Title III mandates that EPA make the TRI available to the public via "telecommunications
and other means." There are several ways the public can access the information:
" TRI Public Data Base - The TRI data file will become part of the National Library of
Medicine's (NLM) Toxicology Data Network (TOXNET) and be available on line for
public access in the late spring of 1989.
« CD/ROM - The entire TRI data base will be available on Compact Disc/ Read Only
Memory (CD/ROM). Copies will be available in each of the Federal Depository
Libraries.
COMFiche - Computer Output Microfiche (COMFiche) will be available either by State
or for the entire TRI data base. The Government Printing Office will distribute a copy
of the TRI State data to each county in the State. COMFiche for the entire data base
will be available in each of the Federal Depository Libraries.
Magnetic Tape - The entire TRI data base will be available on magnetic tape in ASCII
format.
* Special Access - Until the TRI data can be made available to the public, information
on TRI submissions is available on an ad hoc basis from the Title III Reporting Center.
The center can handle inquiries either by mail, walk-in, or by phone. People wishing
to request or view information must first call the center for an appointment at 202-
0488-1501.
CD/ROM, COMFiche, and magnetic tape will be available for sale through the National
Technical Information Service and the Government Printing Office.
USING THE TRI
The following are examples of ways in which the Toxic Chemical Release Reporting Form
(Form R) may be used:
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Determine which substances were released into the environment during the preceding
year.
Determine how much of each substance^JrLp.Qunds_pejLyeac- went into air, land, and
water in specific geographic ares or nationwide.
Learn how the wastes were treated onsite and how efficient that treatment was.
Compare releases by similar facilities in different parts of the country.
Compare releases among different kinds of facilities.
Check the data against permits and emission standards to make sure facilities have
permission for releases or to flag candidates for further investigation.
Additional information and some form of risk screening will be needed to:
Find out if there are hot spots (areas with an unusually high number of releases).
Help set priorities for further investigation and reduction of releases.
- - " '
Identify new chemicals for regulatory consideration.
Help facilities internally identify priorities for release reduction.
This guide addresses two immediate uses of the Toxic Release Inventory: (1) establishing
priorities forfollowup investigation of TRI facilities and chemicals; and (2) identifying data needs
and approaches for collecting information necessary to respond to health and ecological
questions from the public.
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EXHIBIT 1 - SOURCES OF WASTES
When estimating releases of a chemical, industries must consider all sources
of wastes. Sources of waste include, but are not limited to:
Fugitive or non-point air sources
Equipment leaks from pumps, valves and/or flanges
Building ventilation systems
Evaporative losses from surface impoundments
Stack and other point air sources
Vents from reactors and other process vessels
Storage tank vents
Stacks or vents from pollution control equipment
Water sources
Process outfalls
Washings from vessels, containers, etc.
Pollution control devices
Stormwater runoff (if applicable)
Solids, slurries, and non-aqueous sources
Filter cakes
Spent catalysts
Pollution control wastes (such as absorber sludges) and/or
wastewater treatment sludges
Spent catalysts
Vessel or tank residues
Spills and sweepings
Spent solvents
By-products
1
Source: U.S. Environmental Protection Agency. 1 987. Estimating Releases
and Waste Treatment Efficiencies for the Toxic Chemical Release Inventory
, EPA 560/4-88-002. U.S. EPA, Office of Pesticides and Toxic
Substances, Washington, DC.
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REFERENCES
Notes
'U.S, Environmental Protection Agency. Chemicals in Your Community: A Guide to the
Emergency Planning and Community Riaht-to-Know Act (Washington, DC: U.S. EPA,
September 1988) 2.
'The Emergency Planning and Community Right-to-Know Act of 1986, 42 U.S.C. §§11001
et. seq.
3U.S. Environmental Protection Agency. Chemicals in Your Community. 15.
"U.S. Environmental Protection Agency. The Emergency Planning and Community Right-
to-Know Law: Section 313 Reporting Requirements (Springfield, Virginia: National Technical
Information Service, September 1987), 2-5.
5U.S. Environmental Protection Agency. Toxic Chemical Release Inventory Reporting Form
R and Instructions. EPA 56014-88-005. (Washington, DC: U.S. EPA, 1988).
6U.S. Environmental Protection Agency. Estimating Releases and Waste Treatment
Efficiencies for the Toxic Chemical Release Inventory Form. EPA 560/4-88-002. (Washington,
DC: U.S. EPA, December 1987) 2-1.
7U.S. Environmental Protection Agency, Federal Emergency Management Agency, and U.S.
Department of Transportation. Technical Guidance for Hazards Analysis: Emergency Planning
for Extremely Hazardous Substances (Washington, DC: U.S. EPA, December 1987).
8Klauder, David and Loren Hall. SARA Title III: Qualitative Vs. Quantitative Approaches
to Assessing Incomplete Data. Presentation to the International Life Sciences Institute (ILSI)
on February 15, 1989. Washington, DC.
Federal Register Citations
Sections 301 to 303 (emergency planning): April 22, 1987; December 17, 1987;
February 25, 1988 (40 CFR 300 and 355).
Section 304 (emergency release notification): April 22, 1987; December 19, 1987;
February 25, 1988 (40 CFR 300 and 355).
Sections 311-312 (hazardous chemical reporting): October 15, 1987; August 4, 1988 (40 CFR
370).
Section 313 (toxic chemical release reporting): February 16, 1988; June 20, 1988
(40 CFR 372).
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Other Sources of Information on Title III
Chemical Manufacturers Association. 1988. Community Guide to Title III.
Washington, DC.
Robert Wood Johnson Medical School. 1988. SARA Title III: Emergency Planning
and Community Riaht-to-Know. Infoletter, Vol. 2, No. 4, Piscataway, New Jersey.
U.S. Environmental Protection Agency. 1988. Title III Fact Sheet: Emergency
Planning and Community Right-to-Know. Washington, DC.
U.S. Environmental Protection Agency. Questions and Answers About the Emergency
Planning and Community Right-to-Know Act and the Toxic Release Inventory for Use bv
State/Local Officials. Office of Toxic Substances. National Technical Information Service,
Springfield, Virginia.
U.S. Environmental Protection Agency. Toxic Chemical Releases and Your Right to Know.
Office of Toxic Substances. National Technical Information Service, Springfield, Virginia.
U.S. Environmental Protection Agency. 1987. Protecting Our Environment:
Federal Environmental Laws. New York, New York.
U.S. Environmental Protection Agency. 1987. Release of Hazardous Substances: The Federal
Response. New York, New York.
U.S. Environmental Protection Agency. 1987. Title III: What It Means to You.
Philadelphia, Pennsylvania.
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SECTION II - ELEMENTS OF RISK SCREENING
.Each year, EPA and the States will receive thousands of Toxic Chemical Release Inventory
Reporting Forms. Few organizations will have the resources to treat the reported releases
equally. To make decisions about how best to apply their limited resources, organizations
responsible for handling TRI data must develop some system, however crude, for screening
and prioritizing the information. One screening criterion that most organizations may wish to
consider is potential risk to public health or the environment. This section presents one
approach to estimating relative risk - risk screening. Risk screening is a process that can be
used for gaining initial perspectives on Section 313 chemicals and for setting rough priorities
for further analysis, but should not be used for making final or absolute judgments about the
risk associated with a particular facility.
Risk screening, in the context of Section 313 of SARA, is a type of risk assessment used
when data or information needs are limited. The process generally results in a relative
expression of risk (e.g., high, moderate, low). Risk screening is useful for establishing risk-
based priorities as well as information needs for followup risk assessment activities. Although
the risk screening process relies on general risk assessment principles, the data requirements
are less detailed than those for a formal risk assessment. Risk screening results in less
definitive expressions of risk (or "relative risk rankings") than those derived from the risk
assessment process.
Risk assessment in the Federal government consists of four major components: hazard
identification, dose-response assessment, exposure assessment, and risk characterization.1 The
risk screening procedure described in this guide has three elements: toxicological potency
assessment, exposure evaluation, and risk characterization. Each of these elements is
described below.
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TOX1COLOGICAL POTENCY
In the risk screening procedure described in this manual, the first two steps of risk
assessment are combined into a single~element, toxicological potency Toxicological potency
involves:
Hazard identification, or the characterization of the nature of adverse health or
ecological effects that may be produced by a chemical (Exhibits 2 and 3 list the
adverse health and ecological effects identified under Section 313).
Dose-response relationships, or the magnitude of these effects at specific exposure
levels.
In risk assessment, experimental studies involving test organisms and/or epidemiological
studies are reviewed to determine if a chemical can cause health or environmental effects and
how these effects are exhibited, and to characterize the dose-response relationship. To make
this determination, a number of variables and factors must be considered (see Exhibit 4). For
purposes of risk screening on TRI data, the relative toxicological potency of the chemicals is
initially all that is needed. Various EPA estimates of toxicologicai potency are readily available,
including:
Reportable Quantities (RQs). Developed under the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), the RQ for a substance
is the level at or above which a release of that substance must be reported to the
NRC, the SERC, and the LEPC. There are five levels of RQs: 1, 10, 100, 1,000, and
5,000 pounds. An RQ is assigned to a chemical based on a consideration of the
chemical's intrinsic chemical, physical, and toxicological properties. RQs do not
provide a definite indication of how hazardous a chemical will be at its reportable level,
but they can be used to indicate a chemical's relative potential to cause toxicological
or ecological effects at a given exposure level.
Threshold Planning Quantities fTPQsi. TPQs have been set for each of the EHSs
listed under Section 302 of Title III. TPQs take into account the tendency of the
chemicals to become airborne, as well as their toxicity. Like RQs, TPQs are a relative
ranking system. There are six levels of TPQs: 1, 10, 100, 500, 1,000, and 10,000.
The numbers are generally higher than the RQs for the same chemical, but they can
be useful in determining relative toxicity.
Cancer Potency. Cancer potency is an expression of the relationship between the
tumorigenic response to a carcinogen and the administered dose to a target or test
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organism. EPA expresses cancer potency using unit risk factors, which translate the
estimated cancer potency into a probability of contracting cancer as a result of
exposure to a unit dose of a carcinogen over a lifetime (70 years). The unit risk factor
is obtained from a mathematical model used to extrapolate from high-dose effects
observed in animal studies to potential effects at low doses to which humans may be
exposed.
Reference Doses {RfDs). RfDs are EPA estimates of the daily exposure to the human
population, including sensitive populations, that are likely to be without appreciable risk
of deleterious effects during a lifetime. RfDs are estimated from either the lowest
exposure level at which an adverse effect was observed in animals or humans or on
the highest level at which no effect was observed. Appropriate safety factors are
applied.
Aquatic Water Quality Criteria (\NQC\ Values. Aquatic water quality criteria are EPA
estimates of the ambient concentration of a chemical in surface waters (freshwater or
marine waters) that will not cause adverse effects to aquatic organisms. WQC exist
for both acute and chronic toxicity to aquatic life. These concentrations are based on
information concerning the toxicity of the substance and its tendency to bioaccumujate.
(EPA also publishes water quality criteria for human health; however, other indices
have been selected for use in the risk screening system to address human health
concerns.)
Appendix A provides relative toxicological potency rankings for Title III chemicals based on their
RQ, TPQ, cancer potency, RfD, and WQC values. The appendix also describes each EPA
toxicity index in more detail.
EXPOSURE EVALUATION
No matter how toxic a chemical may be, it cannot cause an effect in a living organism
unless it comes into contact with that organism. Exposure is the amount of chemical an
individual or population comes in contact with during a given period of time. Release of a
chemical into the environment does not necessarily mean that exposure will occur. Exposure
depends on many site- and chemical-specific factors. Ideally, exposure is measured at the
point of contact between the chemical and the individual or population, either directly (e.g.,
personal monitoring) or indirectly (e.g., modeling). Opportunities to measure the actual
exposure are rare, however. Generally, exposure must be estimated from information on the
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levels of a chemical in the environment. (Information on environmental levels may, in turn, be
based on modeling estimates.)
For the risk screening methodology described in this guide, two key aspects of exposure -
the plausible exposure pathways and potential environmental levels of the chemicals of concern
- are considered qualitatively. An exposure pathway is the route by which an organism comes
in contact with a chemical, such as ingestion via water or inhalation via smoke or vapors The
environmental level refers to the qualitative characterization of amounts and concentrations of
a chemical in the environment at the point of contact with populations of interest.
There are a variety of possible exposure pathways resulting from releases of a toxic
chemical into air, to surface water or publicly owned treatment works (POTWs), or on land:
Releases to air can result in exposures to organisms living near and downwind from
facilities releasing toxic chemicals into the atmosphere through smokestacks (or other
sources of releases to air). Persistent chemicals may fall or be rained out of air onto
land or into surface water, resulting in exposures via these environmental media (see
below).
Plausible exposure pathways resulting from releases to surface waters depend on
downstream uses of the water, including drinking, cooking, bathing, water contact
sports, agricultural livestock watering, and industrial use. Since toxic chemicals can
also be taken up by animals and plants, individuals that consume aquatic organisms
(such as fish and shellfish from contaminated surface waters) may be exposed in this
manner. Releases to publicly owned treatment works may result in exposure if
chemicals are not removed through treatment processes and are released in POTW
effluent to surface water used by downstream communities.
When toxic chemicals are discharged on land, they can penetrate the soil. This may
become an exposure pathway for individuals who spend time outside. Exposure can
occur through inhalation of contaminated dust, incidental ingestion of soil (particularly
by children), or ingestion of soil by individuals with pica (an abnormal tendency to eat
non-food substances such as dirt). When chemicals migrate downward through the
soil, underlying ground water can become contaminated, resulting in an exposure
pathway through well water extraction. Chemicals also can be transported over land
via surface runoff, resulting in exposures through downgradient uses of land or surface
waters. In addition, discharges of volatile chemicals to water and soil can become
airborne and expose populations via inhalation. Specially-designed facilities such as
permanent landfills and underground injection wells may reduce the potential exposure
from land disposal.
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Organisms also can be exposed to toxic chemicals through several other pathways,
including consumer products such as paints, solvents, glues and deodorizers; pesticides on
food; occupational exposures; and indoor air pollutants such as tobacco smoke, fireplaces,
unvented stoves, and wood preservatives. While the risk screening system described in this
guide addresses only exposure pathways from TRI releases, the user should keep in mind that
other sources of toxic chemicals exist. In some locations the TRI releases may contribute
insignificantly to chemical exposures relative to other sources.
For the purposes of risk screening on the TRI data, the following factors need to be
examined to determine plausible exposure pathways and potential environmental levels:
Plausible Exposure Pathways
Site-Specific Data
Location of Chemical Releases
Characterization of Populations of interest
- Human or ecological (aquatic or terrestrial)
- Size
- Sensitive Populations
Media Uses
Geographic Distance to Populations of Interest
Physical Transport Characteristics of Area
Chemical-Specific Data
Physical Transport Characteristics of Chemical
Environmental Transformation Characteristics
Potential Environmental Levels
Site-Specific Data
Geographic Distance to Populations of Interest
Physical Transport Characteristics of Area
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Chemical-Specific Data
Quantity of Release
Physical Transport Characteristics of Chemical
Environmental Transformation Characteristics
Rates of Release
Each of these factors is described below.
Site-Specific Exposure Data:
Location of Chemical Releases. An accurate geographical location of each
chemical release must be known. From this release point, it is possible to determine
how the chemical is likely to move in the environment based on factors discussed
below.
Characterization of Populations of Interest. No injury can occur to an organism
unless a chemical comes in contact with the organism. It is necessary to identify
the organisms (human and other species, both aquatic and terrestrial) that live or
periodically enter areas near release points, the size of the population of interest, and
the existence of sensitive populations or environments (such as schools and
hospitals) that may be more susceptible than average to exposure.
Media Uses. Uses of air, water, and land by humans or animals can affect
exposure. Media uses include consumption (such as drinking water and eating fish),
recreation (such as swimming and boating) and occupation (such as irrigation and
farming). For example, if a given pollutant concentrates in the tissue of fish in Lake
Z, the amount of fish consumed by individuals who eat fish from Lake Z is a critical
factor affecting exposure.
« Geographic Distance to Populations of Interest. The distance from the release site
to a population of interest or point of media use (e.g., drinking water intake) is an
important consideration. In general, the further the populations of interest are from
the point a chemical enters the ambient environment, the less chance that exposure
will occur. However, the "effective" distance to organisms of interest depends also
on site- and chemical-specific physical transport processes.
Physical Transport Characteristics of Area. Chemicals can be carried or dispersed
physically in the environment. The physical characteristics of the release point and
the surrounding terrain influence the potential for exposure at any location away from
the source. The physical transport characteristics include:
- Spatial Distance - Chemicals released into air at low heights will, in general, be less
widely dispersed than chemicals released from high stacks. (Appendix B illustrates
how, under certain conditions, stack height can affect potential concentrations of
_
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chemicals at various distances from the release point.) Chemicals released into
surface waters near the banks of rivers or lakes may result in less dispersion and,
therefore, higher shoreline concentrations. In general, shallow aquifers are more
likely to become contaminated by overlying surface impoundments than deep
aquifers under similar containment, soil, and rainfall conditions.
- Meteorological conditions - Precipitation, wind speed and direction, humidity,
temperature, and other meteorological variables will affect the transport of
chemicals in air, in water, and on land. For example, populations located
downwind from the source of the release will generally be exposed to higher
concentrations of a chemical than those at equidistant upwind locations. Excessive
rainfall can cause surface runoff from land disposal sites, leading to downhill
exposures, including surface water contamination.
- Hvdroaeoloaical conditions - Chemicals will be transported differently in lakes, slow
rivers, swift streams, estuaries, or oceans. For example, tidal movement is the
overriding transport mechanism within an estuary, while thermal stratification may
control movement within a deep lake. Soil porosity will affect the downward
mobility of chemicals. Clay and silt soils will retard leaching whereas sandy or
fractured soils will enhance it.
- Topographical conditions - Terrain will also affect the way a chemical is transported.
-Mountain ranges and tall buildings, for example, may "block" the pathway of a
relatively low chemical plume. The ground slope near land disposal sites may
affect the potential for transport of a chemical via surface runoff.
Chemical-Specific Exposure Data fat a given site)
Quantity of Release. In general, the greater the quantity of a chemical released, the
greater the potential environmental levels of the chemical. (Appendix C presents
information that can be used to rank release quantities.) The other factors described
below must also be taken into consideration, however. For example, a small quantity
of a highly toxic substance released every day of the year might add up to a large
quantity; but not be a concern if it degrades rapidly in the environment.
Physical Transport Characteristics of Chemical.
- Adsorption and Leaching - Environmental transport of a chemical may be
enhanced or retarded in air, soil, and water if the chemical is readily sorbed to
dust, soil particles, or suspended and bottom sediments. For example, aquatic
organisms that are "bottom feeders" would be expected to be exposed to higher
levels of adsorbent chemicals. Adsorption is controlled by the characteristics of
the chemical and by the type (i.e., organic content) of the soil or sediment. Thus,
poorly adsorbed chemicals released to land will leach more rapidly than highly
adsorbent chemicals, resulting in greater potential for underlying ground water to
become contaminated.
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- Volatilization - Some organic chemicals with high vapor pressures and/or low water
solubilities have a tendency to volatilize. from water or land into the air.
Volatilization of chemicals into the air can occur from "holding" ponds, surface
water bodies, and spills or leaks on the ground.
- Bioconcentration - Chemicals may persist in the environment when taken up by
exposed plants and animals. The chemical accumulates in the organs and tissues
of the exposed organisms. If other animals and humans eat these organisms, the
chemical will be further concentrated (bioaccumulated).
Environmental Transformation Characteristics. Chemicals will either degrade or
persist in the environment, depending upon the environmental transformation properties
of the chemical: ,
- Photolysis - Some chemicals degrade rapidly when exposed to ultraviolet light.
This process may be important to chemicals in the atmosphere, in surface water
of sufficient clarity for sunlight to penetrate, and on the surface of the soil.;
- Oxidation - Some chemicals will degrade when exposed to oxygen or other
substances (like chlorine and ozone). Oxidation is the process by which .electrons
are removed from a chemical and then accepted by another substance (an
oxidizing element). Oxidation may occur in air, surface water, ground water, and.
soil. . ...,....., .... .,.,.. ...,'. ..., ,. ..,, ,
- Hydrolysis - Certain chemicals degrade when exposed to water. The water causes
the chemical bond to split and the substance decomposes. Hydrolysis may occur
in air, surface water, ground water, or soil.
.'.'. i / ' ' '.'.-, ' ' ' V.' " ', ' ..* * ' * -' , \ ''''.
- Biodegradation - Some chemicals are rapidly degraded by, bacteria, and other,
microorganisms. Biodegradation can occur in soil, ground water, surface water,
and, to a limited extent, in air.
- Biological treatment - If a chemical is released to a wastewater treatment facility (or
treated on-site) its concentration in the environment will depend on how rapidly it
is removed during the treatment process and on its persistence in the environment
following treatment. Some chemicals are rapidly removed during wastewater
treatment processes; others are resistant to treatment and may be released to
surface water in treatment plant effluents.
Rates of Release. As mentioned above, for acutely toxic chemicals, the frequency
and duration of the release are important factors. When an acutely toxic chemical is
released all at once or over a short period of time, it is more likely to trigger a
threshold response than if the same quantity of the chemical is released little by little
over a longer period of time. (Appendix B illustrates the expected effect of release rate
on potential concentrations of chemicals in the air at various distances from the release
point.)
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Appendix D provides data on physical transport and environmental transformation
properties of the Section 313 chemicals. Appendix E provides information on likely rates of
release for these chemicals.
RISK CHARACTERIZATION
Risk characterization, the final component in risk screening, combines the toxicological
potency assessment and the exposure evaluation to identify facilities, populations, and
chemicals that warrant further investigation. In this step, the risk screener describes risks in
relationship to other risks, i.e., in terms of the relative probability of harm. Descriptive terms,
(e.g., high, moderate, or trivial) may be used to characterize the risk. Comparisons may also
be used. For example, "The release of chemical A from facility X appears to pose a greater
concern to local public health than most other releases reported in the area." The risk
characterization step also includes a characterization of the nature of the uncertainties in the
data used in the risk screening procedure.
Risk screening does not result in estimates of the actual risks from toxic chemical
releases. For example, the risk screener will not be able to determine whether a chemical
release will increase the incidence rate of cancer in a nearby population, or what the
magnitude of such an increase might be. More rigorous risk assessment methodology and
additional data are needed to answer questions such as these.
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EXHIBIT 2 - HUMAN HEALTH EFFECTS OF CONCERN
AS IDENTIFIED UNDER SECTION 313
Carcinogenicitv. The property or quality of being able to
cause tumor formation in any tissue.
Heritable gene and chromosome mutations. Events that
occur in germ cells. These include deficiencies, duplications,
insertions, inversions, and translocations of chromosomes, as
well as gains or losses of whole chromosomes.
Neurotoxicitv. Any adverse effect on tne structure or function
of the central and/or peripheral nervous system related to
exposure to a chemical substance.
Reproductive and developmental toxic effects. Reproductive
toxic effects are adverse effects on the male or female
reproductive systems, while developmental toxic effects are
any adverse effects on the developing organism, including
death, structural abnormalities, altered growth, and functional
deficits such as learning disorders. Developmental toxicity
also includes teratogenic effects, which are permanent
structural abnormalities that may adversely affect
development or survival of the developing organism.
Other chronic effects. Any adverse effects other than cancer
that are observed from long-term repeated exposure to a
chemical.
Adverse acute effects. Adverse effects are any deleterious
effects suffered by an organism, while acute effects occur
rapidly as a result of short-term exposure to a high
concentration of a chemical. For TRI listing, both lethal and
nonlethal effects (such as eye and respiratory irritation) may
be considered significant adverse acute effects. These
effects occur outside the facility as a result of continuous or
frequently recurring releases.
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EXHIBIT 3 - ECOLOGICAL EFFECTS OF CONCERN
AS IDENTIFIED UNDER SECTION 313
Environmental toxicitv. EPA has identified several indicators of
toxicity. These include aquatic LC50, mammalian or avian LD50l and
avian 5-day dietary LCSO for acute effects. Chronic maximum
acceptable toxicant concentrations (MATCs) can be estimated for
aquatic organisms (or cases where some dietary concentration is
involved). For avian and mammalian toxicity tests, dosing by
gavage is frequently employed, and the NOEL (No-Observed-Effect
Level) is used.
Toxicitv and persistence. EPA is especially concerned about
chemical persistence in cases where toxicity concerns are based on
chronic toxicity data.
Toxicitv and bioaccumulation. Chemicals that bioaccumulate and
exhibit some toxicity are also of concern. Bioaccumulation can be
considered by evaluating measured bioconcentration factors (BCFs).
Chemicals with high BCFs possess a potential for concentrations to
build up in the food chain. In the absence of BCF data, the
octandl-water partition coefficient (log P) may be used to estimate a
BCF figure. Estimated log P data may be used in the absence of
log P data.
Any significant adverse effect on the environment. As defined under
the Toxic Substances Control Act (TSCA) 8(e) policy statement, any
significant adverse effect means "any ecologically significant change
in species interrelationships, such as changes in species behavior,
growth, or survival that in turn adversely affect the behavior, growth
or survival of other species."
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EXHIBIT 4 - FACTORS AFFECTING TOXICITY
Properties of the Individual chemical. Different chemicals vary
widely in their ability to produce toxic effects. Differences in
chemical structure account for variations in the rate at which a
chemical is absorbed, how it is metabolized, and how much of it is
excreted. Small differences in chemical structure can produce large
differences in toxicity.
Dose, frequency, and duration of exposure. Exposure to toxic
chemicals may be described as acute or chronic, depending on its
duration. Acute and chronic exposure to the same dose of a
chemical do not necessarily produce the same health effects. A
chemical that produces toxic effects when introduced into an
organism in large amounts over a short period of time may be non-
toxic or even beneficial when introduced in small amounts over a
long period of time. A chemical that is acutely non-toxic may be
toxic under chronic exposure conditions. These effects are related
to the ability of the body to detoxify chemicals. Small doses of
toxic chemicals may be tolerated because chemicals can be
metabolized or excreted from the system. In larger doses, or over
long periods of time, these chemicals may be able to accumulate in
parts of the body where they can produce toxic effects!
Route of exposure. The route of chemical entry into the body -
through inhalation exposure, ingestion exposure, cr dermal exposure
- plays an important role in determining toxicity. Differing routes of
exposure produce differing patterns of metabolism, distribution, or
excretion. Thus, individual chemicals differ in the route of exposure
through which they produce the most toxic effects. Protective
barriers such as the outer cell layers of skin and the cilia in the
respiratory tract limit the entry of certain chemicals. Other
chemicals can penetrate these barriers and enter the bloodstream.
Once in the blood, chemicals can be carried to body organs where
they can potentially cause injury.
Other environmental exposures. Another factor affecting toxicity is
the combination of different chemicals to which a person is
exposed. Two or more chemicals in combination may modify each
other's actions or the responses of the exposed individuals.
Exposure need not occur at the same time for interactive effects to
occur. Interactive effects can be additive, synergistic, or neutral.
Individual susceptibility. A number of individual characteristics,
including age, sex, nutritional and immunologic status, genetic
characteristics, and state of health may influence the individual's
response to toxic chemicals. Two individuals exposed to the same
dose of a toxic chemical may exhibit different reactions (such as
allergic reactions). - :
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REFERENCES
Notes
Environmental Protection Agency. 1984. Risk Assessment and Management:
Framework for Decision Making. EPA 600/9-85-002. U.S. EPA.
2U.S. Environmental Protection Agency. 1986. Toxicology Handbook.
Rockville, MD: Government Institutes, Inc.
Other Sources of Information on Toxicology. Exposure Assessment, and Risk
Characterization
Rail, David P. 1982. Medicine for the Layman: Environment and Disease.
Bethesda, MD: National Institutes of Health.
The Conservation Foundation. 1985. Risk Assessment and Risk Control.
Washington, DC: The Conservation Foundation.
Epting, Celia. 1977. Of Mice and Men: Health Risks and Safety Judgments.
Washington, DC: -.League of Women Voters of the United States.
Kamrin, Michael A. 1988. Toxicology: A Primer on Toxicology Principles and
Applications. Chelsea, Ml: Lewis Publishers.
Marczewski, Alice E. and Michael Kamrin. .1987'.'; Toxicology for the Citizen. Lansing, Ml:
Michigan State University, Center for Environmental Toxicology.
Ottoboni, M. Alice. 1984. The Dose Makes the Poison: A Plain-Language Guide
to Toxicology. Berkeley, CA: Vincente Books.
Sasnett, Sam K. No date. A Toxics Primer. Washington. DC: League of Women Voters of
the United States.
Turner, D.B. 1970. Workbook of Atmospheric Dispersion Estimates. Office of
Air Programs, U.S. Environmental Protection Agency.
U.S. Environmental Protection Agency. 1988. Superfund Exposure Assessment
Manual. Prepared for EPA's Office of Emergency and Remedial Response. OSWER
Directive 9285.5-1. Washington, DC: US..ERA Office of Solid Waste and Emergency
Response.
U.S. Environmental Protection Agency. 1987. The Routes of Exposure to
Environmental Chemicals. New York, NY.
U.S. Environmental Protection Agency. 1987. The Process of Risk Assessment
and Risk Management. New York, NY.
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U.S. Environmental Protection Agency. 1986. Superfund Public Health
Evaluation Manual. EPA/540/1-86/060. Washington, DC: U.S. EPA Office of Emergency
and Remedial Response.
U.S. Environmental Protection Agency. No date. Toxic Chemicals: What They
Are. How They Affect You. Chicago, IL
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SECTION III -THE RISK SCREENING SYSTEM
The screening system described in this section provides a qualitative risk-based approach
to identifying, from among all the TRI submissions for a particular community or geographic
area, those risk scenarios, facilities, chemicals, and populations of interest that should receive
the highest priority for followup investigation. It will be of limited value, however, in addressing
questions and concerns about actual risk that the public is likely to ask - questions like "Am
I safe?" Risk communication, which is discussed in Section IV, Responding to Questions, will
be helpful in addressing these concerns.
The screening procedure provides a logical process for considering the many variables
associated with a determination of potential risks at a facility or site. It describes how to
screen potential risks among multiple facilities, each releasing several chemicals into different
environmental media (air, water, and land). The same approach may be used to estimate
relative risks among chemicals at a specific facility.
The screening system was developed for use with Section 313 chemicals because the TRI
reporting provides a readily available source of aggregate data that is useful for making
comparisons and establishing priorities. If sufficient release and toxicological data are available
for other chemicals (including the Extremely Hazardous Substances under Section 302 and the
CERCLA hazardous substances under 304 of Title III), the system could be adapted to assess
those chemicals as well.
The risk screening system is a simplified version of EPA's Hazard Ranking System, which
has been adapted to address the TRI release scenarios. The Hazard Ranking System is the
principal mechanism for placing sites on the Superfund National Priority List (NPL) for followup
investigation.1 (Appendix G describes the Hazard Ranking System in more detail.) The system
is consistent with EPA's understanding of the type and expected quality of the Section 313
data and readily available supplementary data, and balances scientific rigor with simplicity and
ease of use.
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USING THE RISK SCREENING SYSTEM
Before Beginning
The steps of the risk screening procedure are designed to be flexible enough to serve the
Interest and needs of a diversity of users in all parts of the country. Only limited guidance is
provided for quantitative definition of qualitative terms used in the procedure, such as "high,"
"large," or "far from." The numerical values used to define these terms will vary depending on
site location, area of the country, program emphasis, and other factors. For consistency within
their own programs, agencies may want to establish quantitative ranges or limits for these
terms that will best meet program objectives and serve community interests.
Since it is difficult to assess risks when few data exist, as in the case of the TRI reporting,
it may be useful to consult with expert scientists and lexicologists when applying the system.
Sources of information useful for risk screening are listed in Section V, Resources. The more
reliable the information that agencies access in performing the screen, the greater the
confidence they can have in the results.
In addition, before applying this risk screening system, organizations may wish to
determine whether the release is permitted and meets the permit requirements. Releases from
permitted facilities in compliance with their permits may be less likely to pose a concern than
an unpermitted release or one in violation of a permit. However, the process of comparing TRI
releases with existing standards may not be straightforward (see Case Study, Appendix F).
Before performing a screen, agencies will want to make several copies of the sample
worksheets provided at the end of this section, since worksheets must be filled out for each
environmental medium into which there is a TRI chemical release.
How It Works
The risk screening procedure follows the basic risk assessment steps. The user considers
site- and chemical-specific data to characterize the relative toxicological potency of chemicals
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and to evaluate exposure (including plausible exposure pathways and potential environmental
levels). For each facility, the user fills out three workseets - Facility Worksheet on Site-Specific
Data, Facility Worksheet on Chemical-Specific Data, and Relative Risk Worksheet. A worksheet
is filled out for releases into each environmental medium (Air, Surface Water or Publicly Owned
Treatment Works [POTW], and Land) of concern. In the final step of the procedure the user
sets risk-based priorities for followup investigation of facilities, chemicals, and populations of
interest.
TOXICOLOGICAL POTENCY
To characterize relative toxicological potency, the. user chooses from among the EPA
toxicological indices on Title HI chemicals provided in Appendix A (reportable quantities,
threshold planning quantities, cancer potency, reference doses, and water quality criteria).
Chemicals of high or moderate concern, along with information on the quantity of release and
chemical-specific exposure factors, are recorded on the Facility Worksheet on Chemical-Specific
Data.
The risk screening procedure allows the user to consider risks to aquatic life as well as
humans and other terrestrial species. The selection of EPA indices for evaluating relative
toxicological potency will depend, in part, on which species are of concern. The user records
a description of the species of interest on the Facility Worksheet on Site-Specific Data, and
evaluates potential exposure routes and exposure factors for each.
EXPOSURE EVALUATION
As part of exposure evaluation, the user considers populations, exposure routes, and
exposure factors within Inner and Outer Zones. The risk screening procedure provides
suggested Inner Zones for each medium (e.g., 1 mile radius from the release site for Air).
Populations within the Inner Zone are considered to be in a plausible exposure pathway if they
are in contact with the medium into which chemicals are released. The Outer Zones are areas
beyond the Inner Zones that contain populations of interest that are likely to be exposed. The
user qualitatively characterizes the Outer Zones by evaluating the site- and chemical-specific
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data recorded on the Facility Worksheets. Information about populations, exposure routes, and
exposure factors within the Inner and Outer Zones are recorded on the Facility Worksheet on
Site-Specific Data.
RELATIVE RISK CHARACTERIZATION
In the final step of the risk screening procedure, data from the completed Facility
Worksheets for each medium are used to assess plausible exposure pathways, potential
environmental levels, and toxicological potency. Risk scenarios of "High," "Moderate," and
"Low" priority are identified on the Relative Risk Worksheet. Where possible, cross-media
priorities are established. The information recorded on the Relative Risk Worksheet and
Information about data gaps recorded on the Facility Worksheets can be used to direct
followup investigation activities.
Case Study
Appendix F applies the screening procedure to a theoretical situation. The case study
illustrates the kinds of data needed to perform risk screening, where to get these data, and
how to use the data to answer questions. The case study takes the user through each step
of the risk screening process and indicates the conclusions that may be drawn as a result of
the screen.
After Screening - Then What?
Ultimately, the decision-makers who have jurisdiction over the environment in a specific
geographic area must decide on the next steps. The risk screening procedure identifies high-
priority routes of potential exposure, facilities, and chemicals, as well as data gaps for followup
Information collection activities necessary to perform a more comprehensive risk assessment.
The risk assessment models provided in Appendix G can also be used as a guide to the kind
of Information agencies may want to collect to perform a quantitative risk assessment.
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In any case, additional information will be required to fully characterize the risks from the
TRI routine chemical releases and to put these risks into perspective with those resulting from
other sources of chemicals in the community - such as indoor air pollutants, roadway vehicles,
and consumer products. The risk screening procedure could be used to assess relative risks
of other sources of toxic chemicals, where the sources and amounts of release are known.
Even these analyses, however, would not allow one to make value judgments about which risks
are acceptable and unacceptable. The determination of acceptable risk, or what is "safe
enough," will require involvement of all interested parties within the potential exposure zones
from TRI chemical releases.
When assessing the type and extent of followup activities of a facility or geographic area,
agencies may also wish to consider non-risk factors, e.g., local, State, and Federal laws, public
concern, control technologies, economics, and politics. The level of public concern about an
area, facility, or individual release may be an important indicator of a situation requiring some
followup, both from a public health/environmental and a political standpoint. If a facility is
already using best practicable technology (BPT) or best available technology (BAT), it may not
be able to reduce the level of releases any further without tradeoffs. Budgetary restraints and
political factors will also be important considerations. Before allocating significant resources
to followup risk assessment activities, agencies should consider consulting an expert
toxicologist or risk assessor for advice on the validity of their risk screening conclusions, and
the feasibility and costs of their followup plan.
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THE QUAUTATIVE RISK SCREENING PROCEDURE
RELEASES TO AIR
I. Facility Worksheet on Site-Specific Data
(SITE-SPECIFIC EXPOSURE DATA)
1. Location of Chemical Releases, or Area of Indirect Entry into Air. Record the most
exact description of the release site or area of indirect entry into air from other media
(if noted under Releases to Surface Water or POTW or Releases to Land).' Complete
a separate Facility Worksheet on Site-Specific Data for each different entry location.
Group locations where releases are close together (e.g., releases within perhaps 1/2
mile) unless there are reasons not to do so (e.g., residences or recreational areas
in between release locations).
IF INSUFFICIENT^DATA are available to describe Location of Release or Area of
Indirect Entry into Air, risk screening of Releases to Air is not possible.
2. Radius of Inner Zone* A radius of I mile is suggested unless there is a reason to
select an alternative radius. Draw Inner Zone on a local map of area.
3. Population of Interest. Record description of populations of interest wi'thin the Inner
and a preliminary Outer Zone.0 Characterize species (human and/or ecological-
terrestrial or aquatic), population sizes, and any potentially sensitive subpopulations
in these zones.
I
IF NONE, go to Exposure Factors (both Site- and Chemical-Specific), to determine
the potential for indirect entry into other media.
4. Potential Exposure Routes. Identify uses of air that may result in exposures, and
record "breathing" under Media Uses. Record the direction (e.g., S, SE, NW) and
distance (for Outer Zone only) from the location of chemical release/entry to each
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population of interest. For Outer Zone populations which occupy large areas, record
a distance range from the closest to the farthest individuals within the population.
5. Exposure Factors (Site-Specific)
a. Wind Direction. Record "+(WD)" for populations of interest in predominantly
downwind direction from the locations of chemical release/entry. Record "-(WD)"
for those in predominantly upwind directions.
; b. Release Height. For Outer Zone populations of interest, record "+(RH)n for
; populations downwind from the release site when release heights are high.d
J - c. Other Factors. Consider other site-specific factors that might significantly affect
exposures to populations of interest. For example, wind patterns may be
seasonal or altered by topographical barriers. In addition, excessive rainfall
' ?, 'could reduce air concentrations of chemicals and result in indirect (and/or
surface water) exposure routes. (If so, record this on the Release to Air
worksheet and consider completing Releases to Land or Releases to Surface
> r ; Water for this indirect entry.)
IF INSUFFICIENT DATA are available to address potentially important Site-Specific
Exposure Factors, make a note under Data Gaps on the Facility Worksheet.
II. Facility Worksheet on Chemical-Specific Data
A. TOXICOLOGICAL POTENCY
Determine the most appropriate expression of toxicological potency for the chemical,
depending on the species of concern (see Appendix A). If there are several indices
that are applicable (e.g., for ranking toxicological potency for humans) choose the
index that results in the lowest ranking (the greatest toxicological potency). If the
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chemical falls under Group I or Group 2, list the chemical under the appropriate
heading.
IF INSUFFICIENT DATA are available to determine Toxicological Potency of any of
the chemicals released into Air, make a note under Data Gaps on the Facility
Worksheet
B. CHEMICAL-SPECIFIC EXPOSURE DATA
i
1. Quantity of Release. Group quantities of release into ranges of High, Medium, and
Low. No single ranking scale is applicable in all situations. Appendix C describes
several approaches that can be used to rank quantities of release. For example, a
particular release can be compared to the national average (median) quantity of a
chemical released to a particular environmental medium. The release can also be
!,
compared to local releases of other chemicals in the same industry or to releases of
the same chemical from other industries. Comparisons across environmental media
can also be made.
Record relative quantities of release for each Group I and 2 chemical. Also note
under "Release Quantity" what approach was used to rank releases (e.g.,
compare to national median for this chemical released to air.)
2. Exposure Factors (Chemical-Specific).
i
a. Environmental Transformation. Record "+(ET)" or "-(ET)" for chemicals that are
highly persistent or rapidly degraded in air, respectively (see Appendix D).
Fallout or rainout of persistent chemicals may result in indirect entry to surface
water or land. Note, however, that chemicals can degrade to other toxic
chemicals (or intermediates that lead to the formation of other toxic chemicals).
The oxidation or photolysis of volatile organic compounds may lead to local
ozone and smog problems.
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b. Release Rate. Record "+(RR)" for chemicals for which acute toxicity to humans
or terrestrial organisms is the end effect of highest concern (see Appendix A)
and release rates are intermittent or sporadic (see Appendix E and, if available,
reports of accidental releases submitted under SARA, Section 304). Acute
toxicity to populations of interest in the Inner Zone may be of concern.
c. Other Factors. If there are additional chemical-specific factors that could be
important in describing plausible exposure pathways and/or environmental levels
for any of the identified populations of interest, note them under Exposure
Factors (Chemical-Specific), on the Facility Worksheet.
IF INSUFFICIENT DATA are available to address any of the above Chemical-
Specific Exposure Factors, make a note under Data Gaps on the Facility
Worksheet.
111. Relative Risk Rank - See page 45.
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RELEASES TO SURFACE WATER OR POTW
I. Facility Worksheet on Site-Specific Data
(SITE-SPECIFIC EXPOSURE DATA)
1.
Location of Chemical Release, or Area of Indirect Entry into Surface Water. Record
the most exact description of the site of release to surface water, i.e., site of direct
entry from the facility, site of indirect entry from a publicly owned treatment works
(POTW), or area of indirect entry into surface water from other media (if noted under
Releases to Air or Releases to Land).' Complete a separate Facility Worksheet on
Site-Specific Data for each different entry location. Group locations where releases
are close together (e.g., releases within perhaps 1/2 mile) unless there are reasons
not to do so (e.g., drinking water intakes or recreational areas in between release
locations).
IF INSUFFICIENT DATA are available to describe location of Release or Area of
Indirect Entry into Surface Water, risk screening of Releases to Surface Water is not
possible.
2. Radius (arc) of Inner Zone.b A radius of 4 miles downstream for rivers and streams,
or arc for lakes, estuaries, and oceans is suggested unless there is a reason to
select an alternative area. Draw the Inner Zone on a local map of area.
3. Populations of Interest. Record a description of populations of interest within the
Inner and a preliminary Outer Zone.c Characterize species (human and/or ecological-
terrestrial or aquatic), population sizes, and any potentially sensitive subpopulations
in these zones.
IF NONE, go to Exposure Factors (both Site- and Chemical-Specific), to determine
the potential for indirect entry into other media.
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4. Potential Exposure Routes. For each population of interest, consider and record the
uses of surface water receiving chemical releases (or, if appropriate, receiving POTW
effluent) that result in water contact with populations of interest (e.g., drinking,
recreation, irrigation, harvesting aquatic organisms for fbbd) within Inner and Outer
Zones. For Outer Zone populations, record the direction and downstream (if river or
stream) distance from the location of chemical release/entry. For Outer Zone
populations that occupy large areas, record a distance range from the closest to
the farthest individuals within the population.
5. Exposure Factors (Site-Specific)
a. Dilution. Record a "+(DI)" if discharges are to small lakes or streams and a
"-DI)" if discharges are to large bodies of water.8
b. Treatment. Record a "-(TR)" if water is treated before it is used by the population
of interest (e.g., water passes through a POTW or a drinking water treatment
plant). See also Treatability" under Exposure Factors (Chemical-Specific).
c. Other Factors. Other site-specific factors that might significantly affect exposures
to populations of interest include spatial relationships between locations of
release and water use or intake (e.g., upstream water discharges and
downstream water intakes on the same side of the river).
IF INSUFFICIENT DATA are available to address potentially important Site-
Specific Exposure Factors, make a note under Data Gaps on the Facility
Worksheet.
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Facl»tv Worksheet on Chemical-Specific Data
A. TOXICOLOGICAL POTENCY
Determine the most appropriate expression of toxicological potency for the chemical
(see Appendix A). If the chemical falls under Group I or Group 2, list the chemical
under the appropriate heading.
IF INSUFFICIENT DATA are available to determine Toxicological Potency of any of
the chemicals released into Surface Water or POTW, make a note under Data Gaps
on Facility Worksheet.
B. CHEMICAL-SPECIFIC EXPOSURE DATA
1.
Quantity of Release. Group quantities of release into ranges of High, Medium, and
Low. No single ranking scale is applicable in all situations. Appendix C describes
several approaches that can be used to rank quantities of release. For example, a
particular release can be compared to the national average (median) quantity of a
chemical released to a particular environmental medium. The release can also be
compared to local releases of other chemicals in the same industry or to releases of
the same chemical from other industries. Comparisons across environmental media
can also be made.
Record relative quantities of release for each Group I and 2 chemical. Also note
under "Release Quantity" what approach was used to rank releases (e.g.,
compare to national median for this chemical released to surface water or
to POTW.)
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2. Exposure Factors (Chemical-Specific).
a. Adsorption. Record "-»-(AD)" for adsorbent chemicals (see Appendix D) if aquatic
"bottom-feeding" organisms are of interest or consumed as food by populations
of interest. The effects on potential exposures will be greatest in the. Inner Zone.
b. Bioconcentration. Record "+(BC)" for chemicals that may readily bioconcentrate
(see Appendix D) if aquatic populations in the Inner or Outer Zone are of interest
or are consumed as food by populations of interest.
c. Volatilization. Record a "-(VO)" for chemicals that may rapidly volatilize from water
(see Appendix D) and consider as an indirect entry into air. COMPLETE
RELEASES TO AIR.
d. Environmental Transformation. Record a "+(ET)" or a "-(ET)" for chemicals that
are highly persistent or rapidly degraded in water, respectively (see Appendix
' D). Note, however, that chemicals can degrade to other toxic chemicals (or
intermediates that lead to the formation of other toxic chemicals).
ve. Release Rate. Record "+(RR)" for chemicals for which acute toxicity to aquatic
organisms is the end effect of highest concern (see Appendix A) and release
rates are intermittent or sporadic (see Appendix E and, if available, reports of
accidental releases submitted under SARA, Section 304). Acute toxicity to
aquatic organisms of interest in the Inner Zone may be of concern.
f. Treatability for Releases to POTW or Equivalent On-Site Treatment. Record "-(TB)"
for chemicals listed in Appendix D that are readily removed during biological
treatment processes either by adsorption or degradation. Record a "+(TB)" for
those chemicals that are resistant to treatment and are more likely to reach
receiving waters in POTW effluents.
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g. Other Factors. If there are additional chemical-specific factors that could be
I
Important In describing plausible exposure pathways and/or environmental levels
for any of the identified populations of interest, note them under Exposure
Factors (Chemical-Specific) on the Facility Worksheet.
IF INSUFFICIENT DATA are available to address any of the above Chemical-Specific
Exposure Factors, make a note under Data Gaps on the Facility Worksheet.
i
HI. Relative Rtsk Rank - see page 45.
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RELEASES TO LAND
I. Facility Worksheet on Site-Specific Data ,
(SITE-SPECIFIC EXPOSURE DATA)
1. Location of Chemical Releases, or Areas of Indirect Entry onto Land. Record the
most exact description of the release site or area of indirect entry onto land from
other media (if noted under Releases to Air or Releases to Land)." Complete a
separate Facility Worksheet on Site-Specific Data for each different entry location.
Group locations where releases are close together (e.g., perhaps within 1/2 mile)
unless there are reasons not to do so (e.g., residences, recreational areas, or wells
in between release locations).
IF INSUFFICIENT DATA are available to describe location of Release or Area of
Indirect Entry onto Land, risk screening of Releases to Land is not possible.
2. Radius of Inner Zone* A radius of 12 feet and 1 mile from location of release to
aquifer and nearest well, respectively, and 1/2 mile downgradient runoff radius are
suggested, unless there is reason to select an alternative area. Draw Inner Zones
on a local map of the area.
3. Populations of Interest. Record a description of populations of interest within the
Inner and Outer Zone6 (human and/or ecological-terrestrial and aquatic), population
sizes, and any potentially sensitive subpopulations in these zones.
IF NONE, go to Exposure Factors (both Site- and Chemical-Specific), to determine
the potential for indirect entry into other media.
4. Potential Exposure Routes. For each population of interest in the Inner and Outer
Zones, consider and record the uses of land (e.g., farming, gardening). If ground
water is taken from wells, consider uses of this water (e.g., drinking, irrigation).
Evaluate the potential for direct access to the release site by neighborhood children
-41-
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and determine the likelihood that surface runoff from the site might contaminate
neighboring land or surface waters. For Outer Zone population, record the direction
and distance from the location of chemical release/entry. For Outer Zone populations
that occupy large areas, record a distance range from the closest to the farthest
individuals within the population.
5. Exposure Factors (Site-Specific)
a. Containment. Record a "+(CO)" for populations of interest if no approved and
effective containment measures are in place at the release site, (e.g., properly
lined and covered landfills or holding ponds).
b. Treatment. Record a "-(TR)" if ground water is treated before use by populations
of interest (e.g., ground water passes through a drinking water treatment plant).
c. Soil and Rainfall. Record a "+(SO/RF)" for populations of interest extracting
ground water in the vicinity of the release site if the soil is sandy or fractured and
rainfall in the area is abundant. Also record a "+(SO/RFJ" for organisms/
populations of interest that are using land or surface water downhill from the
disposal site within a zone of potential runoff if the soil shows signs of erosion.
Consider as an indirect entry to surface water and COMPLETE RELEASES TO
SURFACE WATER.
d. Soil and Wind. Record a "+(SO/WE)n for populations of interest that live or use
land or surface water close to the disposal site if conditions in the area are
generally dry and subject to wind erosion. Consider as an indirect entry to air
and COMPLETE RELEASES TO AIR.
e. Other Factors. Consider other site-specific. exposure factors that might
significantly affect exposures to populations of interest. For example, the
evapo/transpiration rate of the area may exaggerate volatization of chernicals into
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air. Or, the presence of surface springs could serve as a more direct conduit
to ground water.
IF INSUFFICIENT DATA are available to address potentially important Site-Specific
Exposure Factors, make a note under Data Gaps on the Facility Worksheet.
II. Facility Worksheet on Chemical-Specific Data
A. TOXICOLOGICAL POTENCY
Determine the most appropriate expression of toxicological potency for the chemical
(See Appendix A). If the chemical falls under Group 1 or Group 2, list the chemical
under the appropriate heading.
IF INSUFFICIENT DATA are available to determine Toxicological Potency of any
chemicals released to Land, make a note under Data Gaps on the Facility Worksheet.
B. CHEMICAL-SPECIFIC EXPOSURE DATA
1. Quantity of Release. Group quantities of release into ranges of High, Medium, and
Low. No single ranking scale is applicable in all situations. Appendix C describes
several approaches that can be used to rank quantities of release. For example, a
particular release can be compared to the national average (median) quantity of a
chemical released to a particular environmental medium. The release can also be
compared to local releases of other chemicals in the same industry or to releases of
the same chemical from other industries. Comparisons across environmental media
can also be made.
Record relative quantities of release for each Group 1 and 2 chemical. Also
note under "Release Quantity" what approach was used to rank releases
(e.g., compare to national median for this chemical released to land.)
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2. Exposure Factors (Chemical-Specific).
a. Leaching. Record a "+(LE)" for chemicals that have the potential to leach readily
into underlying ground water (see Appendix D).
b. Volatilization. Record a "-(VO)" if the chemical has the potential to rapidly
volatilize from land (see Appendix D) and consider as an indirect entry into air.
COMPLETE RELEASES TO AIR.
c. Environmental Transformation. Record a "+(ET)" or a "-(ET)" for chemicals that
are highly persistent or rapidly degraded in soil, respectively (see Appendix D)..
Note, however, that chemicals can be degraded to other toxic chemicals (or
intermediates that lead to the formation of other toxic chemicals).
d. Release Rate. Record "+(RR)" for chemicals for which acute toxicity to
organisms of interest is the end effect of highest concern (see Appendix A) and
release rates are intermittent or sporadic (see Appendix E and, if available,
reports of accidental releases submitted under SARA, Section 304). Acute
toxicity to populations of interest in the Inner Zone may be of concern.
e. Other Factors. If there are additional chemical-specific factors that could be
important in describing plausible exposure pathways and/or environmental levels
for any of the identified populations of interest, npte them under Exposure
Factors (Chemical-Specific) on the Facility Worksheet.
IF INSUFFICIENT DATA are available to address any of the above Chemical-Specific
Exposure Factors, make a note under Data Gaps on the Facility Worksheet (Part
IV). " . '
HI. Relative Risk Rank - See below.
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IV. Relative Risk Worksheet
The objective of this step is to set risk-based priorities for followup investigation of
facilities, chemicals, and populations of interest. The Relative Risk Worksheet is used to record
the results of the relative risk assessment performed in this step for releases to each medium.
A. INNER ZONE
By definition, populations of interest within the Inner Zone are in one or more plausible
exposure pathways, depending on the media uses of these populations. For Inner Zone
populations, evaluate both site- and chemical-specific data recorded on the Facility Worksheets
that affect potential environmental levels (described in Section II of the Guide) and the
toxicological potency of the chemicals released into the medium under study.
The highest potential risks will be to those populations of interest (considering size and
sensitivity) within the most plausible exposure pathways that may be exposed to high potential
environmental levels of chemicals with high toxicological potency. Record the requested data
on these high potential risk scenarios under "High," listing the chemicals determined to have
among the highest potential exposure levels and high toxicological potency under both
columns (see Case Study, Appendix F).
Consider listing release sites and plausible exposure pathways involving chemicals
determined to exhibit either high potential exposure levels or high tbxicological potency under
"Moderate." Large and/or sensitive populations meeting these criteria might be considered for
inclusion in the "High" relative risk category.
The same release site and/or plausible exposure pathway may be listed under more than
one relative risk category, depending on the potential environmental levels and toxicological
potency of chemicals released from the site.
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B. OUTER ZONE
Plausible exposure pathways for populations of interest in the Outer Zone must be
determined using the Facility Worksheet data and the risk screener's expert judgment.
Consider both direct and indirect potential exposure pathways. Consider the media uses and
distances from the sites of release to each population of interest. Also consider both site-
specific and chemical-specific exposure factors that may enhance exposures or decrease the
"relative effective distances" between populations and locations of release.
For those pathways determined to be of potential concern, consider the site- and chemical-
specific exposure data affecting potential environmental levels and toxicological potency as
described above under the Inner Zone. Compare these data with those for the Inner Zone
release sites and plausible exposure pathways already assigned "High" and "Moderate" priority.
In a similar fashion, record the requested data on potential risk scenarios in the Outer Zone,
under the appropriate relative risk category, "High" or "Moderate."
C. CROSS-MEDIA
In general, the risk screening results for one medium cannot be compared to those for
another medium. For example, it is not possible to compare the relative risk ranks for releases
to surface water with those for releases to land. However, by looking across all of the Relative
Risk Worksheets, users may be able to identify the highest priority potential risk scenarios for
followup investigation among all media releases.
D. DATA GAPS
Consider the data gaps for the risk scenarios selected for followup investigation, as well
as those listed as lower priority. These data gaps should be described, along with other
uncertainties and limitations in the risk screening procedure presented in this section, when the
results are communicated to others. The data gaps should also provide screeners with
guidance on the information that will be needed to perform a more comprehensive risk
assessment on the high priority sites and chemicals. Consult Appendix G for information on
available risk assessment models that match your needs and resources.
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NOTES
a The most exact geographic descriptions of a site in decreasing order are latitude/longitude
coordinates, facility street address, zip code.
b Suggested Inner Zones for the three media into which chemical releases are considered
by the risk screening procedure are:
Medium
Air
Surface Water
Flowing (e.g., river without tidal influence)
Static .(e.g., lake)
Land
Depth to aquifer
Distance to well
Downgradient runoff
Radius from Release Site
1 mile
4 miles (downstream)
4 miles (arc)
12 feet
1 mile
1/2 mile
Except for the depth to aquifer, the Inner Zone distances were determined by dividing the
proposed Hazard Ranking System target distance limits (53 FR 51962-52081) by four. (For
aquifer depth, the most shallow limit for clay/silt soil still receiving the highest weighted
value for aquifer depth was adopted.) The MRS target distance limits are based on
technical analyses using existing data at NPL sites and environmental fate models to
calculate distances within which risks to highly toxic, mobile, and persistent chemicals
would be considered acceptable, barring unusual circumstances. Each site is then scored
based on an evaluation of site- and chemical-specific risk factors within the target distance
limits (see Appendix G for a more complete description of the MRS). The HRS target
distance limits are not zones of plausible exposure, as are Inner Zones, but zones within
which plausible exposure pathways are evaluated. A divisor of four was chosen because,
in most cases, the results of the technical analyses showed that migration either occurred
or was highly likely to occur within the first quarter of the target distance limits.
The Outer Zone begins at the distance limits of the Inner Zone and extends as far as site-
and chemical-specific exposure data indicate chemicals may reasonably be expected to
be transported in environmental media which come into contact with populations of
interest. There could be as many Outer Zones as there are chemicals with distinctly
different sets of physical transport and/or environmental transformation characteristics.
Appendix D contains guidance on these characteristics for TRI chemicals. Initially, for
purposes of identifying populations of interest within the Outer Zone, the HRS target
distance limits could be used:
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Medium
Air
Surface Water
Flowing
(e.g., river without tidal influence)
Static
(e.g., lake)
Land
Depth to Aquifer
Distance to Well
Downgradient runoff
MRS Target Distance Limits
/Radius from Release Site)
4 miles
15 miles (downstream)
15 miles (arc)
800 feet
(sandy/fractured soil)
4 miles
2 miles
Consideration of site- and chemical-specific exposure factors through the risk screening
procedure should allow users to better define the general limits of the Outer Zone. Enough
site-specific exposure data relevant to the likely directional transport of chemicals in each
medium should be available to skew the boundaries of the Outer Zone in specific
directions.
Air example: Prevailing wind patterns should be reflected in the characterization of the
Outer Zone. The Outer Zone might appropriately be characterized as the mirror image of
the wind rose for the area (see Case Study, Appendix F), e.g., more conical or pear-
shaped; the base being in the direction of the wind flow and the apex continuous with the
radius of the Inner Zone.
In a given geographic area, the size of the "pear" will depend upon chemical-specific data.
The Outer Zone for some highly mobile and persistent chemicals may extend beyond the
4-mile HRS target distance limit. Likewise, users may determine that the transport of other
less mobile and rapidly degraded chemicals beyond the Inner Zone is unlikely. Under
such circumstances, the Outer Zone could be defined as being equivalent to the Inner
Zone. (See Figure 1).
"Low release heights" are those that occur at levels from ground to 5 or 10 meters.
Fugitive releases would most often be low. Indirect entry of chemicals into air from other
media (i.e., surface water or land) would also most often be low. "High release heights"
might be those that occur at levels in excess of 40 or 50 meters (See also Appendix B).
-48-
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e "Small" streams might be considered to be those with mean flow rates less than 350
million liters per day, the 25th percentile of all stream segments receiving discharges from
facilities in SIC 20-39. These same streams, at some time during the year, consist entirely
of plant effluent. "Large" rivers might be considered to be those with mean flow rates in
excess of 7,220 million liters per day, the 75th percentile of all stream segments receiving
discharges from facilities in SIC 20-39. In addition, an expression of dilution could include
a ratio of the amount of discharge of TRI chemicals (total pounds per year of all TRI
chemicals released to a surface water) to the volume of stream or river flow. In general,
the higher the ratio, the higher the potential concentrations of chemicals in the receiving
waters.
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Figure 1: Inner and Outer Zones: An Air Example
N
W
Innor Zone (Chemicals A, B, and C)
Outer Zone (Chemical A)
't
(1 mile radius)
Outer Zone (Chemical B)
Outer Zone (Chemical C)
Prevailing Wind Direction: NW (toward SE)
Chemical A: Low mobility and rapidly degraded
Chemical B: Moderate mobility and persistence
Chemical C: High mobility and/or persistence
.
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I
Ul
For Releases to:
I. FACILITY WORKSHEET
Site-Specific Data
From Site: (1)_
(Medium ~ Air, Surface Water or POTW, Land) (Name and Location of Release Site)
(3) POPULATIONS OF INTEREST (4) POTENTIAL EXPOSURE ROUTE (5) EXPOSURE FACTORS
Species Sensitive Medium (from Site of Release)
Name Size Subpopulations Uses Direction Distance "(miles)
INNER ZONE OF EXPOSURE EVALUATION
(2) Radius of Inner Zone
(e.g. Air: 1 mi)
1.
2.
3.
4.
OUTER ZONE OF EXPOSURE EVALUATION
5.
6.
7.
8.
DATA GAPS
-------
-------
For Releases to:
(Medium Air, Surface Water or POTW, Land)
II. FACILITY WORKSHEET
Chemical-Specific Data
From Site: (1)
(Name and Location of Release Site)
A. TOXICOLOGICAL POTENCY
Chemical Name
GROUP 1 (HIGH CONCERN)
A.
B. EXPOSURE DATA
(1) Release Quantity (2) Exposure Factors1
C. DATA GAPS
C.
D.
E.
GROUP 2 (MODERATE CONCERN)
F.
G.
H.
I.
'Exposure Factor Symbols
AD = Adsorption DI
AQ = Aquifer Depth ET
BC = Bioconcentration LE
CO = Contaminant RF
= Dilution RH
= Environ Transformation RR
= Leaching SO
= Rainfall TB
Release Height TR
Release Rate VO
Soil WD
Treatability WE
Treatment
Volatilitization
Wind Direction
Wind Erosion
Others:
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-------
III. RELATIVE RISK WORKSHEET
For Releases to:
(Medium Air, Surface Water or POTW, Land)
PLAUSIBLE EXPOSURE PATHWAY
Release Site
Location
Population
of Interest
Medium Uses
POTENTIAL ENVIR LEVELS
Chemical Names
TOX POTENCY
Chemical names
i
en
01
I
HIGH PRIORITY FACILITIES/POPULATIONS/CHEMICALS
1.
2.
3.
4.
5.
6.
MODERATE PRIORITY FACILITIES/POPULATIONS/CHEMICALS
7.
8-
9.
10.
11.
12.
-------
-------
REFERENCES
'U.S. Environmental Protection Agency. December 23, 1988. Hazard Ranking System
(MRS) for Uncontrolled Hazardous Substance Releases: Appendix A of the National Oil and
Hazardous Substances Contingency Plan: Proposed Rule. Federal Register. Volume 53. pp.
51962-52081, and MRS Revisions Technical Support Document.
Other Sources of information (Regional Risk Assessments)
U.S. Environmental Protection Agency. 1989. Estimation and Evaluation of Cancer Risks
Attributed to Air Pollution in Southeast Chicago. Chicago, IL: Region V, Air and Radiation
Division.
U.S. Environmental Protection Agency. 1987. Kanawha Valley Toxics Screening Study (Final
Report). Washington, DC: Region III, Environmental Services Division (Philadelphia) and
the Office of Policy Analysis.
U.S. Environmental Protection Agency. 1987. Baltimore Integrated Environmental Management
Project (Phase I Report). Washington, DC: Regulatory Integration Division, Office of Policy
Analysis, Office of Policy Planning and Evaluation.
U.S. Environmental Protection Agency. 1987.. The Total Exposure Assessment Methodology
(TEAM) Study (Project Summary). EPA/600/SG-871-002. Office of Acid Deposition,
Environmental Monitoring, and Quality Assurance.
U.S. Environmental Protection Agency. 1986. Santa Clara Valley: Integrated Environmental
Management Project (Revised Stage One Report). Washington, DC: Office of Policy
Analysis, Office of Policy, Planning, and Evaluation.
U.S. Environmental Protection Agency. 1986. Final Report of the Philadelphia Integrated
Management Project. Washington, DC: Regulatory Integration Division, Office of Policy
Analysis.
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SECTION IV - RESPONDING TO QUESTIONS
No one can predict how a community will respond to the avalanche of information that will
be made available under the toxic chemical release reporting. Some communities will use
information to develop effective solutions to environmental problems; other communities may
be apathetic and ignore the data. Still other communities may misinterpret the information and
become overly concerned about some chemicals. In any case, responding to the variety of
questions and concerns about the chemical releases will not be an easy task. Communicating
information on life and health issues is never simple, for these subjects evoke strong emotions.
The steering committee of Federal, State, and local government representatives that helped
develop this document identified several questions the public is likely to ask about the Toxic
Chemical Release Inventory. These questions fall into two main categories: risk assessment
and risk management (see Exhibit 5). Responding to risk-related questions will require
estimates of actual risk. These questions cannot be answered by risk screening, which
estimates "relative risk." Such questions can only be answered by a more rigorous risk
assessment. Responding to these questions will therefore require more information than what
is provided on the TRI reporting forms. Along with the emissions data, information on chemical
toxicity and level of exposure is needed. For some questions, information on applicable
standards and permits also is needed. Many sources for these types of data are provided in
Section V, Resources.
It is the risk communicator's responsibility to inform people about what is known and to
place risks into a meaningful perspective. This section provides guidance on how to talk about
and convey risk-related information to the public. It does not attempt to cover all aspects of
risk communication; the bibliography at the end of this section lists a number of useful
resources on this topic.
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SETTING UP A COMMUNICATIONS SYSTEM
The TRI provision (Section 313) of SARA Title III was enacted to provide toxic chemical
release information to the public. It is, therefore, essential to have in place a workable system"
for communicating with concerned citizens. There are several steps you can take and
resources you can assemble to ensure your agency's communications system is as efficient
as possible. Steps for answering questions, assembling information, and disseminating
materials are outlined in the "Action Checklist" in Exhibit 6. The checklist also suggests ways
to build bridges with other organizations. It's a good idea to consult with others to determine
who is best able to answer questions about risk and to issue communications jointly with other
trustworthy sources, such as credible university scientists or physicians.1 Remember that the
checklist presents general strategies for establishing or refining a response system, but that
different risk communication goals, audiences, and media require different risk communication
strategies.
HOW COMMUNITIES VIEW RISK
Different individuals will have different reactions to the Toxic Chemical Release Inventory
reporting. Individuals in some communities may think it a good idea. Others will be skeptical
that industry will comply with the reporting requirements or that the government will enforce
it. Still others may be unaware of TRI or of Title III altogether. Those who work within
agencies need to understand not only how the public views the TRI reporting, but also how
people perceive risks in general. By understanding public perception of risks, it is far easier
to anticipate community response. Research with focus groups reveals the following widely
held assumptions about chemical releases into the environment:2
All releases are illegal or accidental; none are routine and allowable.
No releases are safe.
Releases equal exposure and exposure equals health risks.
It's difficult and frustrating to attempt to seek information about chemical releases.
Neither industry nor the government are likely to take action to effectively address
environmental hazards.
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People's perceptions of risk may seem at times to defy logic, but these perceptions are based
on strongly held beliefs. To the experts, risk means facts and figures (such as expected
annual mortality), but to the public risk means much more than that. People often respond
more to factors other than the hazard itself (see Exhibit 7).
It is important to pay as much attention to these factors as to scientific variables. Take the
time to find out what people are thinking, using techniques such as interviews, focus groups,
and surveys. Recognize people's emotions and the "hidden agendas," symbolic meanings, and
economic or political considerations that often enter in to risk communication. If you neglect
the concerns of the community and concentrate only on the scientific information, you run the
frisk of outraging citizens and creating battlegrounds over risks that are perceived by the
agency -but not by citizens - as minimal.3 .
RULES OF RISK COMMUNICATION
"*"-(.' ''"''.- ; '"
While there is no simple formula for successful risk communication, the principles described
below can help agencies effectively communicate with the public about environmental risk.
Remember that .communicating about environmental problems cannot replace effective risk
management - "good" communication about risks will not make environmental problems
disappear.. .
Aim vour communications at the target audience. The questions that are likely to be
asked of you will come from citizens, workers, local and national environmental groups,
realtors, lawyers, and others. Each of these individuals will have different needs and
concerns. The more you know about your audience, the better you can formulate your
communications. To get to know your audience, you might ask questions like "What
do you already know?" "What would you like to know?" "Whom do you consider a
credible source of information?" "How do you feel about technology?" "How do you
feel about the environment?" A person's education and attitude toward technology, for
instance, are determining factors in what they care to hear about. Knowing your
audience will also help you avoid talking up or down to people.4
Accept and involve the public as a legitimate partner. Demonstrate your respect for the
public by involving the community early - before important decisions are made - and by
involving all parties that have an interest or stake in the issue under consideration.5
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i Be honest, frank, and open. Trust and credibility are key in communicating risk
information. If you do not know an answer or are uncertain, say so. There are many
uncertainties associated with the TRI data. Discuss the uncertainties, strengths, and
weaknesses of the data, and disclose risk information as soon as possible. Identify
worst-case estimates as such, and cite ranges of risk estimates when appropriate.6
Speak clearly and with compassion. Use simple, nontechnical language. Be sensitive
to local norms, such as speech and dress. Use examples, anecdotes, arid images that
make technical risk information personal. Avoid abstract, unfeeling language about
deaths, injuries and illnesses. Remember that most people will focus on risks to
themselves and their families. Acknowledge and respond to emotions that people
express - anxiety, fear, anger, outrage, helplessness. Acknowledge and respond to the
distinctions that the public views as important in evaluating risks. Use risk comparisons
to help put risks in perspective, but avoid comparisons that ignore distinctions that
people consider important. Always try to include a discussion of actions that are under
way or can be taken, and tell people what you can and cannot do.7
Put numbers in the proper context. The TRI reports show the total amounts in pounds
per year of the chemical releases subject to reporting. Because these numbers can be
alarming, it is important for people to understand the numerical significance of the
information reported and to put this information into the proper context. People need
to understand that such information does not in itself indicate the level of associated
risk. For example, a citizen may read in a report that the average concentration of a
Chemical X in the atmosphere at Plant Z is 0.5 ppm. It would be important to stress
to any citizen that might call expressing concern about this number thaf the specific
toxicity of Chemical X must be known to assign any meaning to this concentration.
Some highly toxic chemicals produce noticeable health effects at concentrations of less
than 0.5 ppm (usually over long periods of exposure) while others may be present in
much larger concentrations and pose no health threat.8
THE IMPORTANCE OF CITIZEN PARTICIPATION
The goal of risk communication should be to produce an informed, involved, solution-
oriented public; it should not be to diffuse public concerns or replace action. Citizen
Involvement will lead to a better understanding of risks, and community input can improve risk
management decisions made by government agencies.
Risk communicators can help direct citizens to the appropriate avenues of participation.
For example, a local company can be useful for providing citizens with information on the
frequency and duration of releases, treatment technologies, and waste minimization efforts.
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To encourage citizen participation, some of the following avenues might be recommended to
concerned individuals:
B Identify other concerned citizens. Local Emergency Planning Committees (LEPCs) will
be a good starting place for networking with other citizens. Citizen groups can compare
chemicals used, release quantities, and control technologies at the local facility with
those at similar facilities. If a company is doing a good job recycling and minimizing
waste, citizen groups can encourage that company to get its story into the media so
other facilities can benefit from its experience.
u Contact the company. Most companies are concerned about their public image and
may be more than happy to establish a meaningful liaison with a concerned citizen or
citizens' group. Call or write the public contact designated on the TRI reporting form
(Form R). Citizens may want to request a tour of the plant and ask to be put on any
community mailing list that the company maintains. Citizens can also ask the company
representative what that facility has done or is doing to minimize the releases of toxic
chemicals into the environment.
Write a followuo letter. Citizens can write to:
- The designated Region or Section 313 State contact.
- Local government officials such as local health officials, the Mayor, town council
members, selectmen or planning boards, and LEPCs.
- The U.S. Environmental Protection Agency (Federal, Regional, and State offices).
- The reporting company.
- Local and national environmental groups.
- Elected officials such as Senators and Congress members.
Contact appropriate hotlines for more information. Section V, Resources describes a
number of informational hotlines sponsored by EPA and other organizations. The
Emergency Planning and Community Right-to-Know Information Hotline will be
particularly useful for citizens who would like more information on Title 111 and related
issues.
Contact the family physician to discuss medical concerns.
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FOLLOWUP
Depending on your organization's resources and priorities, you may wish to flag certain
queries for follbwup. These queries can be identified in several ways:
Information provided by a caller may suggest that a situation deserves further followup.
Periodic and systematic review of the call logs will help identify releases, facilities, or
communities for which there have been unusually high levels of concern.
The risk screening described in Section II will help identify releases and facilities that
should receive a higher priority for followup from a public health and environmental
standpoint.
Title III is based on the belief that the more information citizens have about environmental
hazards in their communities, the better equipped they will be to ensure their own protection
from unacceptable risks to their health and safety. When sufficiently motivated, citizens are
quite capable of understanding and acting on complex risk information. While many of the
suggestions for improving risk communication in this section may seem to be common sense,
experience has shown they are consistently violated in practice. Understanding why they are
often not followed may help improve interaction with citizens and risk communication practices.
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EXHIBIT 5 - QUESTIONS THAT MAY BE ASKED
Risk Assessment Questions
1. Am I exposed?
2. To how much of Chemical X am I exposed?
3. Will I/my child get sick (e.g., die, get cancer)?
4. Is my present sickness (or that of my child or my community) the result of
past exposures to toxic chemicals?
5. How can I be sure if Chemical X caused this effect(s)?
6. What if I am exposed to more than one chemical?
7. Is the decline of the fish population in Lake X a result of these releases?
8. Can I eat the fish from this lake?
9. Can I swim in this lake?
Risk Management Questions
1. Why are releases of this chemical allowed at all?
2. What is being done to control releases?
3. Is the chemical regulated?
(a) If so, are the releases in compliance with existing
standards or permits?
(b) If not, why not?
4. How can I get more information about these releases?
5. What can I do to get the release of a particular chemical reduced?
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EXHIBIT 6 - ACTION CHECKLIST
ANSWERING QUESTIONS
1. How will you handle the calls as they come in? Will you:
Designate one or more people to answer the questions?
Prepare a guide instructing secretaries and others who generally answer
the phones on how and where to forward Section 313 related calls?
Establish an intra-State/Regional or local network to handle questions
you will be getting?
Supply written responses to inquiries? If so, what will you provide?
Suggest callers follow up inquiries with a letter detailing their concerns?
i
2. If you intend to designate people to answer questions, do you know
who within the Region, State, or locality are the contact points for
answering specific questions related to:
Health and/or environmental effects?
Exposure assessment?
Risk assessment?
Air, solid waste, ambient water, and drinking water questions?
Standards and regulations?
3. How will you document calls as they come in? Will you:
Ask responders to record essential information in a caller log, including:
- Caller's name (check your organization's policy regarding your ability
to keep callers' requests and queries confidential).
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EXHIBIT 6 (continued)
ANSWERING QUESTIONS (continued)
- Address.
- Telephone number.
- Date and time of call.
- Facility(s) of concern.
- Chemical (s) of concern.
- Caller's specific concerns.
- Reasons for concern.
- Source of the caller's information.
- Other information about caller's problem.
- Nature of verbal response provided.
- Documents sent.
- Further followup/response,
Create a system that enables you to track how many call were received per
facility? , '
Periodically review these files to ascertain the level and nature of public concern?
4. If a serious problem is apparent:
Do you know what action your agency can or will take?
Can you communicate this to the public?
ASSEMBLING INFORMATION
1. Have you assembled the appropriate materials that may be needed
to answer the questions?
Are copies of the Toxic Chemical Release Inventory Reporting Form readily
accessible?
Do you have access to report data from Sections 302, 304, 311, and 312 of Title
III?
Will you have access to the TRI data base or the information on the data base?
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EXHIBIT 6 (continued)
ASSEMBLING INFORMATION (continued)
Can you access the EPA Roadmaps data base that has been developed?
(Volume
li contains a hard-copy version of Roadmaps.)
Do you have information related to the health and/or environmental effects of
the TRI chemicals? (See Section V and Roadmaps.l
Do you have a listing of certified toxicologists, physicians, and poison control
centers in the area who are willing to assist in responding to citizens' health
questions? (Section V provides a listing of poison control centers.)
Do you know the status of Federal regulations on the Title III chemicals?
Do you know how your State regulates the Title III chemicals?
Do you have access to data from State media programs (e.g., air toxics or
water releases)? (Contacts for State media programs are provided in
Roadmaps.)
Have you collected maps containing site-specific information, such as facility
locations, and meteorological, topological, hydrological, and demographic
information (including sensitive population locations) in your geographic area
that are important to exposure evaluations?
Have you contacted local groups or associations, e.g., libraries, weather
services, LEPCs, in your geographic area of responsibility to determine their
willingness to provide site-specific information?
If you answered no to any of the above questions, do you know where to get
the information? (Section V and the reference lists at the end of each
section describe a number of useful resources.)
2. Will you read local newspaper articles to prepare draft responses to
anticipated questions about facilities and chemical releases in
your area?
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EXHIBIT 6 (continued)
ASSEMBLING INFORMATION (continued)
3. Do you want to prepare summary data of the Toxic Chemical Release
Inventory Reporting Forms? If so, will you do it by:
_State __county
_zip code _industry?
DISSEMINATING INFORMATION
1. Do you have plans to publicize your phone number?
2. Do you have summary information that you can give to the public
concerning:
The community right-to-know law? (Fact sheets and brochures are
available from the State and EPA Regional Section 313 contacts listed in
Appendix A and from your LEPC; other sources of information are listed
in the reference lists for Section I.)
Health and environmental effects? (This manual lists many sources of
health information, along with information on how.to obtain those sources.)
Access to the TRI data?
3. Do other programs in your State or locality know (have) what you have
in terms of materials you have assembled?
4. Will you be developing communication channels for sharing call
information with other agencies? If so, how will you share this
Information? .
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EXHIBIT 6 (continued)
DISSEMINATING INFORMATION (continued)
5. Do you have a form you can send to those who request more
Information? (See sample form below.)
REQUEST FOR MORE INFORMATION
Please send me more information on the following facility or chemical. (I have
attached sheets for other facilities/chemicals that interest me.)
Facility/chemical name: '
Name:
Address: _^
City:
County: ' '
Telephone No.:
I am interested in the potential uses of the hazardous substance data collected
under the Emergency Planning and Community Right-To-Know law. Specifically,
the reason that I am requesting information is:
v
n I am a firefighter and this information will help me take appropriate
precautions when dealing with an emergency situation.
o I want to discuss possible hazardous material exposure with my
physician.
n I am concerned about the releases of toxic chemicals into the
environment.
D Other
n I want to use my RIGHT-TO-KNOW!
Source: New Jersey Department of Environmental Protection, Bureau of
Hazardous Substances. Community Right-to-Know Fact Sheets.
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EXHIBIT 7 - FACTORS IMPORTANT IN RISK PERCEPTION AND EVALUATION
Factor
Catastrophic
potential
Familiarity
Understanding
Uncertainty
Controllability
(personal)
Voluntariness
of exposure
Effects on
children
Effects
manifestation
Effects on
future
generations
Victim identity
Dread
Trust in
institutions
Media attention
Conditions Associated with
Increased Public Concern
Facilities and injuries
grouped in time and space
Unfamiliar
Mechanisms or process
not understood
Risk scientifically
unknown or uncertain
Uncontrollable
Involuntary
Children specifically
at risk
Delayed effects
Risk to future
generations
Identifiable victims
Effects dreaded
Lack of trust in
responsible institutions
Much media attention
Conditions Associated with
Decreased Public Concern
Facilities and injuries
scattered and random
Familiar
Mechanisms or process
understood
Risk known to science
Controllable
Voluntary
Children not specifically
at risk
Immediate effects
No risk to future
generations
Statistical victims
Effects not dreaded
Trust in responsible
institutions
Little media attention
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Factor
Accident history
Equity
EXHIBIT 7 (continued)
Conditions Associated with
Increased Public Concern
Major and sometimes
minor accidents
Inequitable distribution
of risks and benefits
Conditions Associated with
Decreased Public Concern
No major or minor
accidents
Equitable distribution
of risks and benefits
Benefits
Reversibility
Origin
Unclear benefits
Effects irreversible
Caused by human actions
or failures
Clear benefits
Effects reversible
Caused by acts of
nature or God
Source: Covello, V.T., P.M. Sandman, and P. Slovic, "Risk Communication, Risk Statistics, and
Risk Comparisons: A Manual for Plant Managers," Chemical Manufacturers Association,
Washington, DC, 1988, p. 54.
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REFERENCES
Notes
MJ.S. Environmental Protection Agency. Seven Cardinal Rules of Risk Communication.
(Washington, DC: U.S. EPA, 1988).
2U.S. Environmental Protection Agency and Georgetown University Medical Center. Public
Needs Assessment. (Washington, DC: U.S. EPA, 1988).
3Hance, Billie Joe; Carol Chess; Peter M. Sandman; and the Environmental
Communication Research Program, Rutgers University. Improving Dialogue with Communities:
A Risk Communication Manual for Government. (Trenton, New Jersey: New Jersey
Department of Environmental Protection, 1988).
"Arkin, Elaine Bratic, David B. McCallum, and Maria Pavlova (Project Officer). Talking about
Toxic Substances: A Communications Handbook. (Washington, DC: U.S. EPA and
Georgetown University, 1988). Fisher, Ann, Gary H. McClelland, and William D. Schulze.
Strategies for Explaining Very Small Risks in a Community Context. (Pittsburgh, Pennsylvania:
Air Pollution Control Association, 1988).
5U.S. EPA. Seven Cardinal Rules.
6U.S. EPA. Seven Cardinal Rules.
7U.S. EPA. Seven Cardinal Rules.
8U.S. Environmental Protection Agency and Federal Emergency Management" Agency. Risk
Communication Resource Package (draft). (Washington, DC: U.S. EPA and FEMA, 1988).
Other Sources of Information on Risk Communication and Risk Perception
Bowonder, B. 1985. "Low Probability Event: A Case Study in Risk Assessment." Paper
presented at the workshop "Risk analysis in developing countries." Hyderabad, India.
Burger, E. 1984. Health Risks: The Challenge of Informing the Public. Washington, DC: The
Media Institute.
Chemical Manufacturers Association (with assistance from Rowan and Biewitt, Inc.). 1988.
Title III Community Awareness Workbook. Washington, DC: MA.
Covello, V.T. 1983. 'The Perception of Technological Risks: A Literature Review."
Technological Forecasting and Social Change. 23, 285-297.
Covello, V.T. 1984. "Uses of Social and Behavioral Research on Risk." Environment
International.
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Covello, V., D. von Winterfeldt, and P. Slovic. 1986. Risk Communication: Background Report
for the National Conference on Risk Communication. Washington, DC: Conservation
Foundation.
Conrad, J. (Ed.) 1980. Society. Technology, and Risk Assessment. New York, N Y :
Academic Press.
Creighton, J.L 1980. Public Involvement Manual: Involving the Public in Water and Power
Resource Discussions. Washington, DC: U.S. Government Printing Office.
Delli Priscoli, J., J. Creighton, C.M. Dunning, eds. 1983. "Public Involvement Techniques: A
Reader of Ten Years' Experience of the Institute for Water Resources." IWR Research
Report 82-R1. U.S. Army Corps of Engineers, Institute for Water Resources.
Earle, T.C. and G. Cvetkovich. 1983. "Risk Judgement and the Communication of Hazard
Information: Toward a New Look in the Study of Risk Perception." BH ARC (400/83/017),
Seattle, WA: Battelle Human Affairs Research Centers.
Rschoff, B. 1981. Acceptable Risk. New York, NY: Cambridge University Press.
Fischoff, B., P. Slovic, S. Lichtenstein, S. Read, and B. Combs. 1978. "How Safe Is Safe
Enough? A Psychometric Study of Attitudes Towards Technological Risks and Benefits."
Policy Sciences. 8, 127-52.
Fischoff, B., P. Slovic, and S. Lichtenstein. 1979. "Weighing the Risks." Environment. 21,
17-10, 32-38.
Fischoff, B., S. Watson, and C. Hope. 1984. "Defining Risk." Policy Sciences. 17, 123-139.
Kasperson, R. and J. Kasperson. 1983. "Determining the Acceptability of Risk: Ethical and
Policy Issues." In J. Rogers and D. Bates, eds., Risk: A Symposium. Ottawa, Canada:
The Royal Society of Canada.
Lowrence, W.W. 1976. Of Acceptable Risk: Science and the Determination of Safety. Los
Altos, CA: W. Kaufman.
Mazur, A. 1980. "Media Coverage and Public Opinion on Scientific Controversies." Journal
of Communications Research. 31, 106-115.
Media Institute. 1985. Chemical Risks: Fears. Facts, and the Media. Washington, DC:
Media Institute.
Mitchell, R.C. 1980. Public Opinion on Environmental Issues: Results of a National Public
Opinion Survey. Washington, DC: Council on Environmental Quality.
Otway, H.J. 1980. "Risk Perception: A Psychological Perspective." In M. Dierkes, S.
Edwards, and R. Coppock, eds., Technological Risk: Its Perspective and Handling in
Europe. Boston, MA: Oelgeschlager, Gunn and Hain.
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Otway, H.J. and D. von Winterfeldt. 1982. "Beyond Acceptable Risk: On the Social
Acceptability of Technologies." Policy Sciences. 8,127-152.
Peltu, M. 1985. "Risk Communication: The Role of the Media." In H. Otway, ed., Risk and
Regulation. London, England: Buttersworths.
Ruckelshaus, W. 1984. "Risk in a Free Society." Risk Analysis. Vol. 4, No. 3, September,
157-163.
Saarinen, T., ed. 1982. Perspectives on Increasing Hazard Awareness. Boulder, CO: Institute
of Behavioral Science.
Sandman, Peter M. Explaining Environmental Risk. U.S. Environmental Protection Agency,
Office of Toxic Substances. Springfield, VA: National Technical Information Service.
Slovic, P., B. Fischhoff, and S. Lichtenstein. 1982. "Facts and Fears: Understanding
Perceived Risk." In R. Schwing and W. A. Albers, eds., Social Risk Assessment: How Safe
Is Safe Enough? New York, NY: Plenum, 1980. Revision in D. Kahneman, P. Slovic, and
A. Tversky, eds., Judgement Under Uncertainty: Heuristics and Biases. New York, NY:
Cambridge University .Press 464-489.
Slovic, P., B. Fischhoff, and S. Lichtenstein. 1981. "Perceived Risk: Psychological Factors
and Social Implications." In F. Warner and D. H. Slater, eds., The Assessment and
Perception of Risk. London, England: The Royal Society.
Vertinsky, I. and P. Vertinsky. 1982. "Communicating Environmental Health Assessment and
Other Risk Information: Analysis of Strategies." In Kunreuther, H., ed., Risk: A Seminar
Series. IIASA-CP-82-S2, Laxenburg, Austria: International Institute for Applied Systems
Analysis 421-482.
Vlek, C., and D.J. Stallen. 1981. "Judging Risks and Benefits in the Small and in the Large."
Organizational Behavior and Human Performance. 28, 235-271,
U.S. Environmental Protection Agency. 1984. Risk Assessment and Risk Management:
Framework for Decision Making. Washington, DC: U.S, EPA, December.
Weinstein, N.D. 1984. "Why It Won't Happen to Me: Perceptions of Risk Factors and
Susceptibility." Health Psychology. 3, 431-457.
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SECTION V - RESOURCES
By itself the Toxic Chemical Release Inventory means very little in terms of human health
and environmental effects. As explained earlier, information on toxicological potency and
exposure are also needed to perform risk screening and to answer questions from the public.
While your organization will need to determine the extent to which you collect these kinds of
data, this section describes a number of resources that will be useful. Additional resources
are provided in Appendices A - J in Volume II.
Some of the resources described below were drawn from Public Education on Toxic
Substances: An Annotated Bibliography (September 1988). The bibliography was developed
under a cooperative agreement between EPA's Office of Toxic Substances and Georgetown
University Medical Center. The EPA's Air Risk Information Support Center's Sources of Health
Risk and Exposure Assessment Information Directory (Draft) and the Federal Emergency
Management Agency's Risk Communication Resource Package (Draft) were also used to
develop this section.
ORGANIZATIONS
m Local Companies. Many of these firms are themselves preparing to interpret the data
and respond to the public's questions. They may already have had extensive
interactions with the local community on the TRI. Companies will have data on the
chemicals, including possible health impacts, and may know the route of human
exposure to the chemical emissions. Exhibit 8 lists questions that would be useful
to ask local companies.
EPA Regional Offices. Regional Offices have experts on risk assessment, risk
communication, and risk management practices. They also have information resources
(such as fact sheets) on a range of related topics and on Title III. A listing of EPA
Regional contacts is provided in Exhibit 9.
State Section 313 Contacts. Each State has designated contacts that can provide
information related to the Toxic Chemical Release Inventory. See Exhibit 10 for a
listing of these contacts.
State and Federal Media Programs. These programs can provide information on
regulation and compliance. They may also have monitoring data, physical transport,
and environmental transformation data on specific chemicals. State agencies may also
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be able to tell you if a chemical has a State air or water standard, and if a particular
release is permitted. In this way, toxic chemicals released into the environment without
permit restrictions or standards can be identified. State programs also may be aware
of a permitted company's compliance record. Roadmaps (Appendix H of Volume II)
contains a listing of State media contacts.
» State Departments of Health. Toxicologists and environmental health and safety
specialists from State Departments of Health can provide information about the
biological effects of hazardous chemical exposure and the environmental impact of
hazardous chemical use in the community or area.
» State Emergency Response Commissions (SERCs). Each State is required to establish
a SERC that will serve as the link between local and Federal emergency response
teams. In many States, the SERC is made up of representatives from public agencies
and departments. In other States, it may be a part of existing State organizations,
such as environmental or health agencies. In almost all cases, its representatives can
help to identify people who can respond to questions raised by the TRI data. SERCs
designate local emergency planning districts within the state, and appoint a Local
Emergency Planning Committee (LEPC) to serve each of the districts. The SERC also
coordinates and supervises the LEPCs' actions by coordinating Title III information
received from facilities and EPA and assisting in understanding and communicating the
chemical risks. Exhibit 10 contains a listing of contacts for SERCs.
» Local Emergency Planning Committees (LEPCs). These are local committees
appointed by the SERCs and include representatives from many organizations: elected
officials, police and fire departments, health, environment and transportation agencies,
broadcast and print media, community groups, and reporting facility representatives.
LEPCs are the link between local communities and State-level emergency response
committees. They develop emergency plans for their community that include
emergency shelter, communication, and schedules for testing the plan. Although
LEPCs are not designated to received TRI data, they may have information about many
Title ill chemicals; local facilities; and meteorological, topological, hydrological, and
demographic information (including sensitive population locations) in your geographic
area. Call your EPA Region, SERC, or State Section 313 contact for more information.
Universities. Some universities have a school of public health, the faculty of which
should be familiar with risk assessment procedures. Universities also may employ
physical chemists, who can describe the properties and uses of hazardous chemicals,
and biochemists, who can describe the adverse health effects associated with
exposure to hazardous chemicals. Finally, some universities have environmental
studies and meteorological departments that can provide information useful to
exposure evaluations.
Society of Toxicology. This organization can assist in identifying both nationally
recognized experts and toxicologists in your area. Call your EPA Region or State
Section 313 contact for more information.
State/Local Poison Control Centers. Toxicologists at poison control centers can
discuss the acute and chronic health effects resulting from exposure to hazardous
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chemicals, identity the chemical hazards that are most prevalent in the community, and
describe preventive actions and remedial measures that should be taken to minimize
health problems. Exhibit 11 provides a listing of State and local Poison Control
Centers.
American Chemical Society (ACS). This organization has nearly 200 local sections
across the United States. Its members are chemists and chemical engineers who can
help interpret technical data. ACS members can also identity scientists in your
community. ACS is located at 1155 16th Street, N.W., Washington, DC 20036. 202-
872-4600.
Chemical Manufacturers Association (CMAV This organization can identity individuals
and companies with expertise on toxic chemicals and related topics. CMA is located
at 2501 M Street, N.W., Washington, DC 20037. 202-887-1100.
Agency for Toxic Substances and Disease Registry (ATSDR). Personnel from this
agency, which is a component of the Centers for Disease Control, can discuss toxic
substance use and associated adverse effects and relay specific case histories. Call
your EPA Region or State Section 313 contact for more information.
U.S. Geological Survey (USGS) and National Cartographic Information Center (NCIC).
These organizations have land use maps that can be useful in exposure evaluations.
Aerial photographs, which are archived at USGS, also can be used to indicate the
chronology of changes in an area's land use and identity indicators of contamination
(such as changes in soil conditions and vegetation), as well as patterns of dispersion,
and a general idea of site environs. Call your EPA Regional contact for more
information.
Census Bureau. For humans, census data may be accessed to determine the size,
distribution, and demographic characteristics of a geographically defined population.
Libraries. City, county, and university libraries may have technical documents that can
provide information on the physical transport and environmental transformation
processes that chemicals are likely to undergo in various media. County libraries will
also have microfiche copies of State TRI data.
Airport, weather services, television and radio stations, and the NOAA all will have
meteorological data that can be useful in exposure evaluations.
The Red Cross, town halls, physicians, health departments, hospitals, and schools will
be able to help pinpoint sensitive human populations.
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TRAINING
U.S. EPA Risk Assessment and Exposure Assessment Training Courses. These courses teach
basic principles of risk and exposure assessment. Call your Regional EPA contact for more
information. Some State agencies may offer similar courses. Check with your State Section
313 contact or State environmental or health department.
FACT SHEETS AND PROFILES
Information on toxicological potency is available for many Section 313 chemicals in various
fact sheets and profiles. Some of these publications are written for the public and may be
useful to distribute to callers.
Hazardous Substance Fact Sheets. These fact sheets are based on ones developed
for the workplace by the New Jersey Department of Health. Each chemical-specific
fact sheet contains a hazard summary; a brief description of the chemical; workplace
exposure limits; acute and chronic health effects; medical testing; and definitions of
terms. It is important to note, however, that these fact sheets contain occupational
data based on a healthy male worker population. Therefore, the information presented
(such as workplace exposure limits) do not reflect environmental exposures and may
not be protective of the general human population (which includes women, children,
and sensitive populations). These fact sheets are available from LEPCs and EPA
Regional Section 313 contacts. Appendix I of Volume II contains a sample, hazardous
substance fact sheet.
CEPP/SARA Title III Section 302 Profiles. Section 302 profiles are the chemical
reference documents used in the Chemical Emergency Preparedness Program (CEPP).
They include summaries of information on each of 366 chemicals on EPA's list of
Extremely Hazardous Substances in a format similar to the Occupational Health and
Safety Administration's (OSHA's) Material Safety Data Sheets (MSDSs). The following
chemical-specific information is included: general information about the chemical;
regulatory information; health hazard and fire and explosion hazard data; information
on the chemical's uses and precautions for safe handling; protective equipment and
emergency first-aid treatment. Appendix J of Volume II contains a sample Profile.
Section 302 profiles on specific Extremely Hazardous Substances are available from
State 313 contacts, SERCs, or EPA libraries. ,
Material Safety Data Sheets (MSDSs). For some chemicals, information on chemical
toxicity is available on the MSDSs that companies have filed with, the LEPC, SERC,
and local fire departments.
Toxicological Profiles. Under SARA, Section 110, ATSDR and EPA are required to
develop toxicological profiles on a specified number of hazardous substances
commonly found at facilities on the Superfund National Priorities List (NPL) and which
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pose the most significant potential threat to human health. Some of these profiles
have been completed on Title III chemicals and are available through ATSDR. Source:
Ms. Georgia Jones, Director, Office of External Affairs, Agency for Toxic Substances
and Disease Registry, Chamblee 28 South, 1600 Clifton Road, Atlanta, Georgia 30330.
Chemical Advisories. This series of fact sheets by EPA warns manufacturers,
employees, and homeowners of the hazards of these substances: 2-nitropropane;
used motor oil (in English and Spanish); nitrosamines; p-tert-Butyl benzole acid; 4-4'-
methylene bis(2)-chloroaniline; and toluenediamines. Source: U.S. Environmental
Protection Agency, Office of Toxic Substances (TS-799), 401 M Street SW, Washington,
DC 20460; 202-554-1404.
DATA BASES
Roadmaps. This is a Section 313 chemical information directory. Roadmaps can
point you to a number of data bases and documents containing information on health
and ecological effects, as well as physical transport and environmental transformation
of Section 313 chemicals. It also contains information on Federal and State regulatory
levels for these chemicals, as well as State contacts for various media (air, water, etc.)
programs. Some information from Roadmaps is provided in Appendix H of Volume
II. An on-line version is also available.
IRIS. IRIS is an on-line data base that contains the latest information about Agency
conclusions on toxicological potencies, health assessments, and regulatory decisions
on 'approximately 400 chemicals' (about 85 Section 313 chemicals). It has been
designed specifically for Federal, State, and local environmental health agencies. A
more detailed description of IRIS is provided in Roadmaps.
Environmental Transport and Fate Data Bases. Descriptions of useful environmental
transport and fate data bases are provided in Roadmaps. Among these are Envirofate
and the Hazardous Substances Data Bank.
National Air Toxics Information Clearinghouse (NATICH1 Data Base.
919-541-0850
FTS 629-0850
Monday through Friday, 7:30 a.m. to 5:00 p.m.
The National Air Toxics Information Clearinghouse assists Federal, State, and local
agencies in exchanging information about air toxics and the development of air toxics
programs. The core of the Clearinghouse is the NATICH data base, which contains
all the information collected from agencies, including regulatory program descriptions
and contacts; permitting data; acceptable ambient concentrations; ambient air
monitoring information; source test data; emissions inventory data; research methods
development information; and bibliographic and ongoing project citations. (See
Roadmaps for a more detailed description of NATICH.)
Exposure Analysis and Systems/These systems provide access to data and models
used in estimating chemical fate, exposed populations, and aggregate exposure. EPA
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has developed several exposure analysis systems, including the Graphical Exposure
Modeling System (PC-GEMS); the Computer-Assisted Management Emergency
Operations (CAMEO); and the Emergency Information System/Chemical (EIS/C). These
systems run on PCs and provide access to data management and analysis tools. PC-
GEMS includes data on selected environmental characteristics (primarily meteorology
and streams) and population; models for predicting concentrations in air, water, soil,
and ground water; and mapping and graphics capabilities. CAMEO, which currently
runs on a Macintosh, was designed for first responders to chemical spills and
emergency planners. A number of local governments have used CAMEO to load and
manage information on chemicals in their cities' facilities, and display this information
together with locally-entered data on populations, schools, and hospitals. CAMEO
contains two spill-scenario models, and can display extents of estimated plumes.
EIS/C, also primarily an emergency planning system, records chemical, facility,
transportation, vulnerable population, and other information. Check with the State
contacts listed in Exhibit 10 about the availability of these systems.
Geographic Information Systems (GIS}. GIS are computer mapping and analysis
systems that can store and combine multiple "layers" of information (e.g., rheteorologic,
geologic, hydrologic, demographic, land use data). Most GIS run on mainframe
systems, and are used for land use planning, although others which are oriented
toward environmental analysis have been recently implemented in EPA regions and
several states. Check with your Regional or State Section 313 contact for more
information (Exhibits 9 and 10).
Risk * Assistant.
703-683-6695
Risk * Assistant provides analytical tools, data bases, and information handling for risk
assessors at hazardous waste sites. The system's component programs, which require
only estimates of the types and concentrations of hazardous chemicals present at the
waste site, can perform a variety of tasks: analysis of exposure and risk,,taking into
account transport and fate, pathways of exposure, and current in-formation on the
hazard assessment of the chemicals; production of standardized risk reports; storage
of risk assessment methodologies and data; and cross referencing through four
databases that compile information from IRIS, regulatory standards and guidance,
chemical properties, and chemical synonyms and CAS numbers. The system is
currently only a prototype, and is still in the development stage.
HOTLINES
A number of hotlines sponsored by EPA and other organizations can provide information
(both verbal and written) on a wide range of topics related to toxic chemicals and health,
exposure, and risk assessments. The Emergency Planning and Community Right-to-Know
Information Hotline (described below) wi.ll be particularly useful,
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Emergency Planning and Community Riaht-to-Know fTitle IIIV Information Hotline
OS-120 , ^
U.S. EPA
401 M Street, S.W.
Washington, D. G. 20460
1-800-535-0202
202-479-2449 (Washington D.C. area and Alaska)
Monday through Friday, 8:30 a.m. to 7:30 p.m., EST
The EPCRA Information Hotline is operated under the guidance of the Office of Solid Waste
and Emergency Response and the Office of Toxic Substances. The Hotline can answer
questions from manufacturers, government agencies, and the general public regarding Title III.
Hotline specialists can answer questions and requests concerning all aspects of Title III, as well
as general issues regarding preventing and preparing,for chemical accidents.
Resource Conservation and Recovery Act rRCRAVComprehensive Environmental Response.
Compensation, and Liability Act fCERCLAl Notline
401 M Street, S.W.
Washington, D.C. 20460
1-800-424-9346 or 202-382-3000 ,
FTS 382-3000
Monday through Friday, 8:30 a.m. to 7:30 p.m., EST
The RCRA/CERCLA Hotline has been in operation since 1980. It is operated under the
guidance of EPA's Office of Solid Waste and Emergency Response. The primary function of
the RCRA/CERCLA Hotline is to assist the public and regulated community in understanding
EPA regulations and policy under the RCRA/CERCLA and Underground Storage Tank
programs. Hotline specialists answer regulatory and technical questions, and can respond to
requests for documents on virtually all aspects of the RCRA, CERCLA, and UST programs.
Federal, State, and local governments; regulated communities; people involved in managing
and cleaning up hazardous waste; and the general public may contact the RCRA/CERCLA
Hotline for information. .
Air RISC Hotline
919-541-0888
FTS 629-0888
Monday through Thursday, 7:30 a.m. to 5:00 p.m., EST
Friday, 7:30 a.m. to 4:00 p.m., EST
The Air Risk Information Support Center (Air RISC) provides, in a timely fashion, technical
assistance and information related to health, exposure, and risk assessments for toxic air
pollutants. The Air RISC is operated by EPA's Office of Air Quality Planning and Standards,
Office of Health and Environmental Assessment, and Center for Environmental Research
Information. The Air RISC Hotline puts agencies and offices in direct contact with a variety of
experts. The Hotline is designed to provide an initial, quick response based on available data
and expertise. The Air RISC also provides a feedback mechanism for State and local air
agencies to identify to EPA the technical support needs of their agencies in the areas of
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health, exposure, and risk assessment. Policy guidance and risk management advice,
however, are outside the scope of the Air RISC.
Control Technology Center (CTC\
919-541-0800
FTS 629-0800
Monday through Friday, 8:00 a.m. to 4:30 p.m. EST
The Control Technology Center (CTC) supports State and local agencies and EPA Regional
Offices in implementing air pollution programs for both toxic and criteria air pollutants by
providing engineering guidance and support on air pollution control technology. The CTC
Hotline provides initial, rapid responses to questions and problems based on available
information and expertise.
Toxic Substances Control Act fTSCAl Assistance Information Service
Office of toxic Substances (TS-799)
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
202-554-1404
FTS 554-1404
Monday through Friday, 8:30 a.m.. to 5:00 p.m., EST
The Toxic Substances Control Act (TSCA) Assistance Information Service is administered by
the Office of Toxic Substances. It provides information on TSCA regulations to the chemical
industry, labor and trade organizations, environmental groups, and the general public. The
TSCA Assistance Information Service can direct inquiries to the appropriate EPA personnel and
handle requests for certain publications related to management of toxic substances.
Best Available Control Technology (BACTVLowest Achievable Emission Rate (LAER1
Clearinghouse
Emission Standards Division
Office of Air Quality Planning and Standards (MD-13)
U.S. EPA
Research Triangle Park, NO 27711
919-541-5432
FTS 629-5432
Monday through Friday, 8:00 a.m. to 4:30 p.m., EST
The Best Available Control Technology (BACT)/Lowest Achievable Emission Rate (LAER)
Clearinghouse assists Federal, State, and local agencies in exchanging information about
BACT and LAER determinations as established under the Clean Air Act. This Clearinghouse
was established in 1979 and is a cooperative effort between EPA, and the State and Territorial
Afr Pollution Program Administrators and the Association of Local Air Pollution Control
Organizations.
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Public Information Center fPICl
U.S. EPA(PM-211B)
401 M Street, S.W.
Washington, D.C. 20460
202-382-2080
FTS 382-2080
Monday through Friday, 8:00 a.m. to 5:30 p.m., EST
The Public Information Center (PIC) answers inquiries from the public about EPA programs and
activities. PIC also offers a variety of nontechnical information materials. This well-established
public service is operated by the Office of Information Resource Management.
Risk Communication Hotline
Office of Policy, Planning, and Evaluation
U.S. EPA
401 M Street, S.W.
Washington, D.C. 20460
202-382-5606
FTS 382-5606
Monday through Friday, 8:30 a.m. to 4:30 p.m., EST
The Risk Communication Hotline serves EPA Regions and program offices. It is an up-to-date
resource for information on risk communication, research, skill building, implementation, and
evaluation. The primary purpose of this hotline is to provide support to EPA Regional Offices
and Headquarters; however, the Hotline staff will provide assistance to State and local
agencies as time and resources permit. State and local agencies should first contact their
Regional Offices with risk communicatioh questions and concerns. The Risk Communication
Hotline was established in 1987 and is operated under the Office of Policy, Planning, and
Evaluation.
Safe Drinking Water Hotline
401 M Street, S.W.
Washington, D.C. 20024
1-800-426-4791
Monday through Friday, 8:30 a.m. to 4:30 p.m., EST
The Safe Drinking Water Hotline, established in 1987, answers questions regarding the Safe
Drinking Water Act of 1974 (SDWA), the SDWA Amendments of 1986, and EPA drinking water
programs (including public water supply). The Hotline is targeted at a broad audience
ranging from regulatory agencies to the general public. In addition to responding to questions
on regulations, the Hotline can provide a list of Office of Drinking Water publications (available
through the National Technical Information Service for a fee) and copies of related Federal
Register notices, as well as add interested persons to the National Pesticides Survey mailing
list to receive monthly updates on that program.-
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Cancer Information Service
1-800-4-CANCER
Monday through Friday, 6:00 a.m. to 10:00 p.m.
Saturday, 10:00 a.m. to 6:00 p.m.
This Hotline is a service of the National Cancer Institute (NCI). All phone calls are
automatically routed to the nearest Regional NCI office. A national office in Maryland answers
calls' after normal business hours (9:00 a.m. to 4:30 p.m. local time) and on Saturdays. This
Hotline can answer general questions about the relationship of indoor air pollution and cancer;
however, more specific questions about air toxics are referred to other agencies. Callers can
also receive information about treatment, diagnosis, and prevention of cancer from this Hotline,
as well as literature and listings of local resources (including home health care, hospitals and
support groups).
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EXHIBIT 8 - QUESTIONS TO ASK A COMPANY'S TECHNICAL CONTACT
1. Does the total quantity of the~refeas«rreportecl include any accidental
releases? If so:
When did they happen?
How much of Chemical X was released?
How likely is it for such a release to happen again?
What area was affected?
Is there any unusual topography in the area?
Was the release reported consistent with Section 304 requests?
Were followup reports filed? If so, what do these reports say about
hazards and exposure?
2. What is the frequency of any routine releases?
3. What is the duration of any routine releases?
4. When and what is the peak release?
5. For air, what are the stack heights from which specific
chemicals are released?
6. For water, what are the exact locations of direct discharges?
7. How long have there been releases of Chemical X?
8. Do reported releases reflect past release levels?
9. Is the release pattern of Chemical X expected to change in the future?
10. If the TRI data indicate a mixture or chemical compound, what substances
might be expected to be present in the mixture or compound, and in what
quantities?
11. Is the company employing best practicable technology (BPT) or best
available technology (BAT)? What are they?
12. Has the company done any monitoring? If so, is this information
available? What sampling and analytical methods were used?
13. Has the company attempted to model potential exposures from release or
monitoring data? If so, what models and assumptions were used?
14. Is any lexicological information available on Chemical X?
15. Is any information available on potential transport and transformation of
Chemical X?
16. Has the company filed a report under Sections 311-312 (Reporting of
hazardous chemical inventories)?
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EXHIBIT 9 - EPA REGIONAL SECTION 313 CONTACTS
EPA Region 1 fCT, |MA. ME. NH. HI. VT)
Dwight Peavey
Pesticides and Toxics Branch
U.S. EPA (APT2311)
JFK Federal Building
Boston, MA 02203
(617) 565-3230
JPA Region 2 fNJ. NY. vi, PR)
Nora Lopez
Pesticides and Toxics Branch
U.S. EPA Region 2 (MS240)
Woodbridge Avenue, Building 209
Edison, NJ 08837
(201) 906-6890
EPA Region 3 (DE. MD. PA.VA. WV, PC)
Kurt Eisner
Toxics and Pesticides Branch
U.S. EPA Region 3 (3HW42)
841 Chestnut Street
Philadelphia, PA 19107
(215) 597-1260
EPA Region 4 fAL. PL Gfl. KY. MS. MC, sn,
Jill Perry
Pesticides and Toxic Substances Branch
U.S. EPA Region 4
345 Courtland Street
Atlanta, GA 30365
(404) 347-5053
EPA Region 5 (IL. IN. Ml. MN. OH. Wl)
Dennis WesolowskI
Pesticides and Toxic Substances Branch
U.S. EPA Region 5 (5SPT-7)
230 So. Dearborn Street
Chicago, IL 60605
(312) 353-5907
EPA Region 6 (Aft. LA. MM. QK, TV)
Gerald Carney
Pesticides and Toxic Substances Branch
U.S. EPA Region 6 (6TPT)
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-7244
EPA Region 7 flA. KS. MO. ME)
Ed West
Congressional and Intergovernmental Liaison
U.S. EPA Region 7 (CIGL) i
726 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2806
EPA Region 8 rCO. MT. ND. SD. UT.
Diane Groh !
Toxic Substances Branch
U.S. EPA Region 8 (8AT-TS)
999 18th Street
Denver, CO 80202-2405
(303) 293-1730
EPA Region 9 (KZ. CA. HI. NV. AS. GU.
Kathleen Gorforth
Pesticides and Toxics Branch
U.S. EPA Region 9 (A-4-3)
211 Main Street
San Franciso, CA 94105
(415) 974-7280
EPA Region 10 fAK. ID. OR. WA
Phil Wong
Pesticides and Toxic Substances Branch
U.S. EPA Region 10 (AT083)
1200 Sixth Avenue
Seattle, WA 98101
(206) 443-4016
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EXHIBIT 10
STATE EMERGENCY RESPONSE COMMISSIONS, REGIONAL SECTION 313 CONTACTS,
AND STATE DESIGNATED AGENCIES
This list is the U.S.-Environmental Protection Agency's listing of State Emergency Response
Commissions and State-designated agencies for the Emergency Planning and Community
Right-to-Know, Act. EPA has verified each contact individually. All addresses listed under
State Commissions receive the Section 302 emergency planning notification and the Section
304 emergency release notification unless otherwise specified. The State-designated
agencies receive the submissions for the sections listed in their headings. If one address is
listed with no heading, the State commission receives all submissions for every section of
the Act. if an additional addresses listed under the heading Mailing Address, this address
is to be used for mailings to the State commissions rather than the P.O. boxes used for the
form submissions.
Alabama
State Commission:
J. Danny Cooper, Co-Chair
Alabama Emergency Response Commission
Director, Alabama Emergency Management
Agency ,
520 South Court Street
Montgomery, AL 36130
(205) 834-1375
Contact: Dave White
Section 311 /312 Submissions:
Leigh Pegues, Co-Chair
Alabama Emergency Response Commission
Director, Alabama Department of Environmental
Management
1751 Congressman W.G. Dickinson Drive
Montgomery, AL 36109
(205) 271-7700
Contacts: L.G. Linn (205) 271-7700
E. John Wiiliford (205) 271-7931
Section 313 Submissions:
E. John Williford, Chief of Operations
Alabama Emergency Respopnse Commission
Alabama Department of Environmental
Management
1751 Congressman W.G. Dickinson Drive
Montgomery, AL 36109
(205) 271-7700
Contacts: LG. Linn (205) 271-7700
E. John Williford (205) 271 -7931
Alaska
Linda VanHaughten, Chair
Alaska State Emergency Response Commission
P.O. Box 0
Juneau, AK 99811
(907) 465-2600
Mailing Address:
Linda VanHaughten
Alaska State Emergency Response
Commission
3220 Hospital Drive
Juneau, AK 99811
American Samoa
State Commission;
Maiava O. Hunkin
Program Coordinator for the Territorial
Emergency Management Coordination
Office
American Samoan Government
Pago Pago, American Samba 96799
International #(684) 633-2331
Section 311/312 and 313
Submissions:
Pati Faiai, Director
American, Samoa EPA
Office of the Governor
Pago Pago, American Samoa 96799
International #(684) 633-2682
Arizona
Carl F. Funk, Executive Director
Arizona Emergency Response
Commission
Division of Emergency Services
5636 East McDowell Road
Phoenix, AZ 85008
(602) 231-6326
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EXHIBIT 10 (continued)
Arkansas
State Commission:
Randall Mathis, Acting Director
Arkansas Hazardous Materials Emergency
Response Commission
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
(501) 562-7444
Contact: Mike Bates (501) 455-6888
Section 311/312 and 313 Submissions:
Becky Bryant
Depository of Documents
Arkansas Department of Labor
10421 West Markham
Little Rock, AR 72205
Contact: John Ward (501) 562-7444
Mailing Address:
Arkansas Department of Pollution
Control and Ecology
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
Attn: John Ward
California
State Commission:
William Medlgovich, Chair
California Emergency Planning and
Response Commission
Director, Office of Emergency Services
2800 Meadowview Road
Sacramento, CA 95832
(916) 427-4287
Section 302, 304, and 311/312 Submissions:
California Emergency Planning and
Response Commission
Office of Emergency Services
Hazardous Materials Division
2800 Meadowview Road
Sacramento, CA 95832
(916) 427-4287
Contact: Gary Burton
Michelle LaBella
Dave Zocchetti
Section 313 Submissions:
Chuck Shulock
Office of Environmental Affairs
P.O. Box 2815
Sacramento, CA 95812
Attn: Section 313 Reports
(916) 324-8124
(916) 322-7236 Completed Form R
Information
Colorado
State Commission:
David C. Shelton, Chair
Colorado Emergency Planning
Commission
Colorado Department of Health
4210 East 11th Avenue
Denver, CO 80220
(303) 273-1624
Emergency release notification:
(303) 377-6326
After hours & weekends
(emergencies only):
(303) 370-9395
Section 311/312 & 313
Submissions:
Colorado Emergency Planning
Commission
4210 E. 11th Avenue
Denver, CO 80220
Contact: Richard Bardsley
(303) 273-1789
Pam Harley (303) 331-4858
Connecticut
Sue Vaughn, Title III
Coordinator
State Emergency Response
Commission
Department of Environmental
Protection
State Office Building
Room 161
165 Capitol Avenue
Hartford, CT 06106
(203) 566-4856
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EXHIBIT 10 (continued)
Delaware
State Commission:
Patrick W7 Murray, Chair
Delaware Commission on Hazardous
Materials
Department of Public Safety
Administration Center
Dover, DE 19901
Contact: George Frick (302) 736-3169
Section 302 Submissions:
Dominick Petrilli, Acting Director
Division of Emergency Planning and
Operations
P.O. Box 527
Delaware City, DE 19706
(302) 834-4531
Section 304 Submissions:
Phillip Retallick, Director
Division of Air and Waste Management
Department of Natural Resources and
Environmental Control
Richardson and Robbins Building
89 Kings Highway
P.O. Box 1401
Dover, DE 19901
(302) 736-4764
Section 311/312 Submissions:
Dr. Lawrence Krone, Chief
Bureau of Health and Social Services
802 Silver Lake Boulevard
Dover, DE 19901
(302) 736-4731
Section 313 Submissions:
Robert French, Chief Program Administrator
Air Resource Section
Department of Natural Resources and
Environmental Control
P.O. Box 1401
Dover, DE 19901
(302) 736-4791
District of Columbia
State Commission and Section
311/312 Submissions:
Joseph P. Yeldell, Director
State Emergency Response Commission for
Title III in the District of Columbia
Office of Emergency Preparedness
2000 14th Street, NW
Frank Reeves Center for Municipal Affairs
Washington, DC 20009
(202) 727-6161
Contact: Pamela Thurber
Environmental Planning
Specialist
Florida
Thomas G. Pelham, Chair
Florida Emergency Response
Commission
Secretary, Florida Department
of Community Affairs
2740 Centerview Drive
Tallahassee, FL 32399-2149
(904) 488-1472
In FL: 800-635-7179
Contact: Greg Dawkins
J. Leonard Ledbetter, Chair
Georgia Emergency Response
Commission
Commissioner, Georgia Department
of Natural Resources
205 Butler Street, SE
Floyd Towers East, 11th Floor
Atlanta, GA 30334
(404) 656-4713
Section 302, 304, 311/312, and
313 Submissions:
Jimmy Kirkland
Georgia Emergency Response
Commission
205 Butler Street, SE
Floyd Tower East
Atlanta, GA 30334
(404) 656-6905
Emergency release number:
(800) 241-4113
Guam
State Commission and Section
311/312 Submissions:
Dr. George Boughton, Chair
Guam State Emergency Response
Commission
Civil Defense
Guan Emergency Services Office
Government of Guam
P.O. Box 2877
Aguana, Guam 96910
(671) 734-3410
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EXHIBIT 10 (continued)
Section 313 Submissions:
Roland Solidio
Guam EPA
P.O. Box 2999
Aguana, Guam 96910
(671) 646-8863
Hawaii
State Commission and Section 311/312
Submissions:
Bruce S. Anderson, Ph.D., Vice Chair
Hawaii Emergency Response Commission
Hawaii Department of Health
P.O. Box 3378
Honolulu, HI 96801
(808) 548-2076
(80S) 548-5832
Contact: Samir Araman (808) 548-5832
Mark.lngoglia (808) 548-2076
Section 313 Submissions:
John C. Levin, M.D., Chair
Hawaii State Emergency Response Commission
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801-9904
(808) 548-6505
Idaho
State Commission:
Idaho Emergency Response Commission
Department of Health and Welfare
State House
Boise, ID 83720
(208) 334-5888
Section 311/312 & 313
Submissions:
Jenny Records
Idaho Emergency Response Commission
State House
Boise, ID 83720
(208) 334-5888
Illinois
State Commission and Section
311/312 Submissions:
Oran Robinson
Illinois Emergency Response Commission
Illinois Emergency Services and
Disaster Agency
Attn: Hazmat Section
110 East Adams Street
Springfield, IL 62706
(217) 782-4694
Section 313 Submissions:
Joe Goodner
Emergency Planning Unit
Illinois EPA
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217) 782-3637
Skip Powers, Director
Indiana Emergency Response
Commission
5500 West Bradbury Avenue
Indianapolis, IN 46241
(317) 243-5176
Iowa
State Commission and Section
302 Submissions:
Ellen Gordon, Co-Chair
Iowa Emergency Response Commission
Iowa Disaster Services
Hoover Building, Level A
Room 29
Des Moines, IA 50319
(515) 281-3231
Section 304 Submissions:
Air Quality and Solid Waste
Protection Bureau
Department of Natural Resources
Wallace Building, 5th Floor
Des Moines, IA 50319
(515) 281-8694
Contact: Pete Hamlin
Section 311/312 Submissions:
Iowa Emergency Response Commission
Iowa Division of Labor
1000 East Grand Avenue
Des Moines, IA 50319
(515) 281-6175
Contact: Don Peddy
Section 313 Submissions:
Department of Natural Resources
Records Department
900 East Grand Avenue
Des Moines, IA 50319
(515) 281-6175
Contact: Don Peddy
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EXHIBIT 10 (continued)
State Commission:
Karl Birns, Staff Director
Kansas Emergency Response Commission
Building 740, Forbes Field
Topeka, KS 66620
(913) 296-1690
Section 302 and 304 Submissions:
Karl Birns
Kansas Department of Health and Environment
Right-to-Know Program
Building 740, Forbes Field
Topeka, KS 66620
(913) 296-1690
Emergency release number only (24 hours):
(913) 296-3176
Section 311/312 and 313 Submissions:
Right-to-Know Program
Kansas Department of Health and Environment
Building 740, Forbes Field
Topeka, KS 66620-7430
(913) 296-1690
Contact: Karl Birns
Kentucky
State Commission and Section 311/312
Submissions:
Colonel James H. "Mike" Molloy, Chair
Kentucky Emergency Response Commission
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort, KY 40601-6168
(502) 564-8660
(502) 564-8682
Contact: Mike Molloy or Craig Martin
Section 313 Submissions:
Valerie Hudson
Kentucky Department of Environmental
Protection
18 Reilly Road
Frankfort, KY 40601
(502) 564-2150
Mailing Address:
Lucille Orlando
SARA Title III
Kentucky Department of Environmental Protection
Kentucky Disaster and Emergency Services
Boone National feuard Center
Frankfort, KY 60601-6161
Louisiana
State Commission and Section
311 /312 Submissions:
Sgt. Ronnie Mayeaux
Louisiana Emergency Response
Commission
Office of State Police
P.O. Box 66614
Baton Route, LA 70896
(504) 925-6113
Section 313 Submissions:
R. Bruce Hammatt
Emergency Response Coordinator
Department of Environmental Quality
P.O. Box 44066
Baton Rouge, LA 70804-4066
(504) 342-8932
Maine
David D. Brown, Chair
State Emergency Response
Commission
Station Number 72
Augusta, ME 04333
(207) 289-4080
In Maine: (800) 452-8735
Contact: Tammy Gould
Maryland
State Commission:
June L Swem
Governor's Emergency Management
Agency
c/o Maryland Emergency Management
Agency
2 Sudbrook Lane, East
Pikesville, MD 21208
(301) 486-4422
Section 302, 304, 311/312,
and 313 Submissions:
Marsha Ways
State Emergency Response
Commission
Maryland Department of the Environment
Toxics Information Center
2500 Broening Highway
Baltimore, MD 21224
(301) 631-3800
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EXHIBIT 10 (continued)
Massachusetts
Arnold Sarpenter
c/o Title III Emergency Response Commission
Department of Environmental Quality Engineering
One Winter Street. 9th Floor
Boston, MA 02108
(617) 292-5810
For LEPC information: Jack Callahan
(508) 820-2060
Michigan
Title III Coordinator
Michigan Department of Natural Resources
Environmental Response Division
Title III Notification
P.O. Box 30028
Lansing, Ml 48909
(517) 373-8481
Minnesota
Lee Tischler, Director
Minnesota Emergency Response Commission
Department of Public Safety
Room B-5
State Capitol
St. Paul, MN 55155
(612) 296-0488
Mississippi
J.E. Maher, Chair
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501, Fondren Station
Jackson, MS 39296-4501
(601) 960-9973
Contact:. Bill Austin
Dean Martin, Coordinator
Missouri Emergency Response Commission
Missouri Department of Natural Resources
P.O. Box 3133
Jefferson City, MO 65102
(314) 751-7929
Mailing Address:
Dean Martin
Missouri Emergency Response Commission
Missouri Department of Natural Resources
2010 Missouri Boulevard
Jefferson City, MO 65109
Montana
Tom Ellerhoff, Co-Chair
Montana Emergency Response
Commission
Environmental Sciences Division
Department of Health &
Environmental Sciences
Cogswell Building A-107
Helena, MT 59620
(406) 444-3948
Nebraska
Clark Smith, Coordinator
Nebraska Emergency Response
Commission
Nebraska Department of Environmental
Control
P.O. Box 98922
State House Station
Lincoln, NE 68509-8922
(402) 471-4217
State Commission and Section 31M
312 Submissions:
Joe Quinn
Nevada Division of Emergency
Management
2525 South Carson Street
Carson City, NV 89710
(702) 885-4240
Emergency release, number
(after hours and weekends):
(702) 885-5300
Section 313 Submission:
Bob King
Division of Emergency Management
2525 South Carson Street
Carson City, NV 98710
(702) 885-4240
New Hampshire
Richard Strome, Director
State Emergency Management Agency
Title III Program
State Office Park South
107 Pleasant Street
Concord, NH 03301
(603) 271-2231
Contact: Leland KImball
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EXHIBIT 10 (continued)
New Jersey
State Commission:
Tony McMahon, Director
New Jersey Emergency Response Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
CN-405
Trenton, NJ 08625
(609) 292-6714
Section 302, 304, and 311/312 Submissions:
New Jersey Emergency Response Commission
SARA Title III Project
Department of Environmental Protection
Division of Environmental Quality
Bureau of Hazardous Waste Information
CN-405
Trenton, NJ 06825
(609) 292-6714
Section 313 Submissions:
New Jersey Emergency Response Commission
SARA Title III Section 313
Department of Environmental Protection
Division of Environmental Quality
Bureau of Hazardous Waste Information
CN-405
401 East State Street
Trenton, NJ O8625
(609) 292-6714
New Mexico
Samuel Larcombe
New Mexico Emergency Response Commission
New Mexico Department of Public Safety
P.O. Box 1628
Santa Fe, NM 87504-1628
(505) 827-9222
New York
State Commission:
Anthony Germain, Deputy Director
State Emergency Management Office
Building 22
State Campus
Albany, NY 12226
(518) 547-9994
Section 302, 304, 311/312, and 313
Submissions:
New York Emergency Response
Commission
New York State Department of
Environmental Conservation
Bureau of Spill Response
50 Wolf Road/Room 326
Albany, NY 12233-3510
(518) 457-4107
Contact: William Miner
North Carolina
State Commission:
Joseph Myers, Chair
North Carolina Emergency Response
Commission
116 West Jones Street
Raleigh, NC 27603-1335
(919) 733-3867
Section 302, 304, 311/312, and
313 Submissions:
North Carolina Emergency Response
Commission
North Carolina Division of
Emergency Management
116 West Jones Street
Raleigh, NC 27603-1335
(919) 733-3867
In North Carolina: (800) 451-01403
General information only
Contacts: Vance Kee (919) 733-3844
Emily Kilpatrick (919) 733-386S
Darian Maylory (919) 733-3890
North Dakota
State Commission:
Ronald Affeldt, Chair
North Dakota Emergency Response
Commission
Division of Emergency
Management
P.O. Box5511
Bismark, ND 58502-5511
(701)224-2111
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EXHIBIT 10 (continued)
Section 302, 311/312, and
313 Submissions: _
SARA Title III Coordinator
North Dakota State Department of Health
and Consolidated Laboratories
1200 Missouri Avenue
P.O. Box 5520
Bismarck, ND 58502-5520
(701) 224-2374
Contact: Charles Rydell
Commonwealth of Northern Mariana Islands
State Commission and Section
311/312 Submissions:
Felix A. Sasamoto, Civil Defense
Coordinator
Office of the Governor
Capitol Hilt
Commonwealth of Northern Mariana Islands
Salpan, CNMI 96950
International # (670) 322-9529
Section 313 Submissions:
Russel Meecham, III
Division of Environmental Quality
P.O. Box 1304
Salpan, CNMI 96950
(670) 234-6984
Ohio
State Commission and Section
311/312 Submissions:
Ken Schute, Coordinator
Ohio Emergency Response
Commission
Ohio EPA
Office of Emergency Response
P.O. Box 1049
Columbus, OH 43266-0149
(614) 644-2260
Section 313 Submissions:
Cindy Sferra-DeWulf
Division of Air Pollution Control
1800 Watermark Drive
Columbus, OH 43215
(614) 644-2270
Oklahoma
Jack Muse, Coordinator
Emergency Response Commission
Office of Civil Defense
P.O. Box 53365
Oklahoma City, OK 73152
(405) 521-2481
Contact: Aileen Ginther
Oregon
Ralph M. Rodia
Oregon Emergency Response
Commission
C/O State Fire Marshall
3000 Market Street Plaza
Suite 534
Salem, OR 97310
(503) 378-2885
Pennsylvania
State Commission:
Sanders Courtner
PA Emergency Response Commission
SARA Title III Officer
PEMA Response and Recovery
P.O. Box 3321
Harrisburg, PA 17105
(717) 783-8150
(717) 783-8193
Emergency Release Number
(24hrs): (717) 783-8150
Section 311/312 Submissions:
PA Emergency Response Commission
C/O Bureau of Right-to-Know
Room 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
(717) 783-2071
Section 313 Submissions:
James Tinney
C/O Bureau of Right-to-Know
Room 1503
Labor and Industry Building
7th & Forrester Streets
Harrisburg, PA 17120
(717) 783-8150
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EXHIBIT 10 (continued)
Puerto Rico
State Commission and Section
311/312 Submissions:
Mr. Santos Rohena, Chair
PR Emergency Response Commission
Environmental Quality Board
P.O. Box 11488
Sernades Juncos Station
Santurce, PR 00910
(809) 722-1175
(809) 722-2173
Section 313 Submissions:
SERC Commissioner
Title III-SARA Section 313
PR Environmental Quality Board
P.O. Box 11488
Santurce, PR 00910
(809) 722-0077
Rhode Island
State Commission:
Joseph A. DeMarco, Exec. Director
Rhode Island Emergency Response Commission
Rhode Island Emergency Management
Agency
State House Room 27
Providence, Rl 02903
(401) 277-3039
Emergency release number:
(401) 274-7745
Section 311/312 Submissions:
Lynn Colby
Rhode Island Department of Labor
Division of Occupational Safety
220 Elmwood Avenue
Providence, Rl 02907
(401) 457-1847
Section 313 Submissions:
Department of Environmental Management
Division of Air and Hazardous
Materials
291 Promenade St.
Providence, Rl 02908
Attn: Toxic Release Inventory
(401) 277-2808
Contact: Martha Mulcahy
South Carolina
State Commission and
Section 302 Submissions:
Stan M. McKinney, Chair
South Carolina Emergency Response
Commission
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
(803) 734-0425
Section 304, 311/312 Submissions:
Purdy McLeod
South Carolina Emergency
Response Commission
Division of Public Safety Programs
Office of the Governor
1205 Pendleton Street
Columbia, SC 29201
(803) 734-0425
Section 313 Submissions:
Ron Kinney
Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
(803) 734-5200
South Dakota
State Commission and
Section 311/312 Submissions:
Clark Haberman, Director
SD Emergency Response Commission
Department of Water and Natural
Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3151
Section 313 Submissions:
Lee Ann Smith, Director
South Dakota Emergency
Response Commission
Department of Water and
Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501-3181
(605) 773-3153
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EXHIBIT 10 (continued)
Tennessee
Lacy Suiter, Chair
Tennessee Emergency Response Commission
Director, Tennessee Emergency Management
Agency
3041 Sidco Drive
Nashville, TN 37204
(615) 252-3300
Outsfde of Tennessee: (800) 258-3300
In Tennessee: (800) 262-3300
Contact: Lacy Suiter
Tom Durham
Texas
State Commission:
Mike Scott, Coordinator
Texas Emergency Response Commission
Division of Emergency Management
P.O. Box 4087
Austin, TX 78773-0001
(512) 465-2138
Section 302, 311/312 Submissions:
Dr. William Elliot
Texas Department of Health
Division of Occupational Safety and Health
1100 West 49th Street
Austin, TX 78756
(512) 458-7410
Section 313 Submissions:
David Barker, Supervisor
Emergency Response Unit
Texas Water Commission
P.O. Box 13087
Capitol Station
Austin, TX 78711-3087
(512) 463-8527
Contact: Priscilla Seymour
Utah
State Commission:
Lorayne Tempest-Frank, Director
Comprehensive Emergency Management
P.O. Box 58136
Salt Lake City, UT 84108-0136
(801) 533-5271
Section 311 /312 and 313
Submissions:
Neil Taylor
Utah Hazardous Chemical
Emergency Response Commission
Utah Division of Environmental
Health
P.O. Box 16690
Salt Lake City, UT 84116-0690
(801) 538-6121
Vermont
State Commission:
Jeanne VanVlandren, Chairman
Vermont Emergency Response
Commission
Department of Labor and
Industry
120 State Street
Montpelier, VT 05602
(802) 828-2286
Contact: Robert McLeod
(802) 828-2765
Section 311/312 & 313
Submissions:
Dr. Jan Carney, Deputy
Commissioner
Department of Health
60 Main Street
P.O. Box 70
Burlington, VT 05402
(802) 863-7281
Virgin Islands
Allan D. Smith, Commissioner
Department of Planning and
Natural Resources
U.S. Virgin Islands Emergency
Response Commission
Title III
Suite 231, Nisky Center
Charlotte Amalie
St. Thomas, VI 00802
(809) 774-3320 Extension 169 or 170
Contact: Gregory Rhymer
Virginia
Wayne Halbleib, Director
Virginia Emergency Response Council
Department of Waste Management
James Monroe Building i
18th Floor
101 North 14th Street
Richmond, VA 23219
(804) 225-2513
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EXHIBIT 10 (continued)
Washington
Chuck Clarke
Washington Emergency Response Commission
Department of Community Development
Mail Stop GH-51
9th and Columbia Blvd.
Olympia, WA 98504
(206) 753-5625
Contact: In Washington: (800) 633-7585
Bill Bennett (206) 459-9191
West Virginia
State Commission and Section
311/312 Submissions:
Carl L. Bradford, Director
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
State Office Building, EB-30
Charleston, WV 25305
(304) 348-5380
Emergency release number: (304) 348-5380
Contact: Bill Jopling
Wisconsin
State Commission
Richard I. Braund, Director
Wisconsin Emergency Response
Commission
Division of Emergency Government
4802 Sheboygan Avenue
P.O. Box 7865
Madison, Wl 53707
(608) 266-3232
Section 313 Submissions:
Russ Dumst
Department of Natural Resources
P.O. Box 7921
Madison, Wl 53707
(608) 266-9255
Wyoming
Ed Usui, Executive Secretary
Wyoming Emergency Response
Commission
Wyoming Emergency Management
Agency
Comprehensive Emergency
Management
P.O. Box 1709
Cheyenne, WY 82003
(307) 777-7566
Contact: Brooke Hefner
Mailing Address:
Ed Usui
Wyoming/ Emergency Response
Commission
Wyoming Emergency Management
Agency
Comprehensive Emergency
Management
5500 Bishop Boulevard
Cheyenne, WY 82009
-99-
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EXHIBIT 11 - STATE/LOCAL POISON CONTROL CENTERS
;
Alabama Poison Center
205-345-0600
800-462-0800 (AL only)
Arizona Pofson Control System
602-626-7899
602-626-6016 (Tucson)
602-253-3334 (Phoenix)
800-362-0101 (AZonly)
Blodgett Regional Poison Center
616-774-7854
^00-442-4571 (616 area code only)
800-632-2727 (Ml only)
Cardinal Glennon Children's
Hospital Regional Poison Center
314-772-8300
314-772-5200
800-392-9111 (MO only)
Central Ohio Poison Center
614^61-2012
614-228-1323
800-682-7625 (OH only)
Duke Univ. Poison Control Center
919-684-8111
919-684-4438
800-672-1697 (NC only)
Georgia Poison Control Center
404-589-4400
800-282-5846 (GA only)
404-525-3323 (TTY)
Hennepin Regional Poison
Center (Minnesota)
612-347-3144
612-347-3141
612-347-6219 (TTY)
Kentucky Regional Poison
Center of Kosair Children's Hospital
502-562-7253
502-589-8222
800-722-5725 (KY only) (TDD)
Long Island Regional Poison
Control Center
516-542-3707
516-542-2323
Los Angeles County Medical
Association Regional Poison
Control Center
213-664-1212
213-484-5151
Louisiana Regional Poison
Control Center
318-674-6364
318-425-1524
800-535-0525 (LA only)
Maryland Poison Center
301-528-7604
301-528-7701
Massachusetts Poison Control System
617-735-6607
617-232-2120
800-682-9211 (MA only)
Michigan Poison Control Center?
313-745-5329
313-745-5711
800-462-6642 (313 area code only)
800-572-1655 (remainder of Ml)
Mid-Plains Poison Center
402-390-5434
402-390-5400
800-642-9999 (NE only)
800-228-9515 (surrounding states)
-100-
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EXHIBIT 11 (continued)
Intermountain Regional Poison
Control Center
801-581-7504
801-581-2151
800-662-0062 (UT only)
Minnesota Regional Poison
Center
612-221-2113
800-222-1222 (MN only)
National Capital Poison Center
202-625-6073
202-625-3333
New Jersey Poison Information
and Education System
201-926-7443
201-923-0764
800-962-1253 (NJ only)
New Mexico Poison and Drug
Information Center
505-277-4261
505-843-2551
800-432-6866 (NM only)
New York City Poison Control Center
212-340-4497
212-340-4494
North Central Texas Poison Center
214-920-2586
916-453-3692
214-920-2400
800-441-0040 (TX only)
Oregon Poison Control and
Drug Information Center
503-225-7799
503-225-8968 (Portland, OR)
800-452-7165 (OR only)
Pittsburgh Poison Center
412-647-5600
412-681-6669
Rhode Island Poison Center
401-277-5906
401-277-5727
612-221-3096
Rocky Mountain Poison Center
303-893-7774
303-629-1123
800-332-3073 (CO only)
800-525-5042 (MT only)
800-442-2702 (WY only)
San Diego Regional Poison Center
619-294-3666
619-294-6000
San Francisco Bay Area Regional
Poison Control Center
415-821-8324
415-476-6600
Southwest Ohio Regional Poison
Control System
513-872-5111
800-872-5111
Tampa Bay Regional Poison
Control Center
813-251-6911
813-253-4444
800-282-3171
Texas State Poison Center
409-761-3332
409-765-1420
713-654-1701 (Houston)
516-478-4490 (Austin)
800-392-8548 (TX only)
-101-
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EXHIBIT 11 (continued)
UCMC Regibnal Poison Control Center
916-453-3414
West Virginia Poison Center
304-347-1212
304-348-4211
800-642-3625
ftU.S. GOVERNMENT PRINTING OFFICE: 1932 .6 5 0 - 2 "t 9/
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