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
                                         -i-

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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.
                                       -ii-

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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
                                       -111-

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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.
                                       -iv-

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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
                                       -v-

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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.
                                         -vii-

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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).
                                        -viii-

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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
                                          -ix-

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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.
                                         -x-

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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.
                                           -xi-

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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
                                          -Xll-

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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.
                                        -xiii-

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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).
                                        -XIV-

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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.
                                       -xv-

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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.
                                        -1-

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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.
                                       -2-

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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 .
                                      -3-

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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
                                               -4-

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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
                                        — 5—

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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.
                                       -6-

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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
                                      -7-

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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:
                                      -8-

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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.
                                         -9-

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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
                                      -14-

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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
                                        -15-

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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
                                        -17-

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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
_
                                                  -18-

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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.
                                       -21-

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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."
                        -23-

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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).                                -      :
                    -24-

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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.
                                      -25-

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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
                                     -26-

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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
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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
                                            -42-

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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.
                                         -45-

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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.
                                       -46-

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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:
                                       -47-

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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.
                                        -49-

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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
.
                                               -50-

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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

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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.

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                                    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.
                                       -57-

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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.
                                        -59-

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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.
                                       -60-

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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
                                         -61-

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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.
                                       -62-

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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.
                                        -63-

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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.
                                       -64-

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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?
                                -65-

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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).
                               -66-

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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?
                                    -67-

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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?
                                      -68-

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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?                                    .
                                  -69-

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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.
                                 -70-

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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
                                        -71-

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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.
                                     -72-

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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.
                                       -73-

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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.
                                       -74-

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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.
                                       -75-

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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
                                       -77-

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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
                                   -78-

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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.
                                -79-

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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
                                       -80-

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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
                                       -81-

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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
                                       -83-

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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.
                                       -84-

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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.-
                                        -85-

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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).
                                      -86-

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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)?
                              -87-

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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

                                       -88-

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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
                                   -89-

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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
                                   -90-

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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
                                    -91-

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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
                                 -92-

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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
                                   -93-

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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
                                   -94-

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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
                                    -95-

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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
                                 -96-

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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
                                    -97-

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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
                                   -98-

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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/
                                   -102-

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