&EPA
United States
Environmental Protection
Agency
Office of Pollution
Prevention and Toxics
TS-799
EPA-745-R-93-005 *
September 1993
EPA's 33/50 Program
Fourth Progress Update
Interim Reduction Goal Achieved
One Year Early
printed on recycled paper
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ERA'S 33/50 PROGRAM: REDUCING RISKS
THROUGH VOLUNTARY ACTION
The 33/50 Program, an EPA voluntary pollution prevention
initiative, derives its name from its overall goals — an interim goal of
a 33% reduction by 1992 and an ultimate goal of a 50% reduction by
1995 in emissions of 17 high-priority toxic chemicals (see box), using 1988
TRI reporting as a baseline. 12,800 facilities reported that 1.474 billion pounds of 33/50
Program chemicals were either directly released to the environment or transferred off-site
to waste management facilities during 1988. The aim of the 33/50 Program is to reduce this
1.474 billion pounds of pollution by at least 50% — 737 million pounds — by 1995, with an
interim reduction target of more than 486 million pounds by 1992.
1992 INTERIM GOAL OF 33/50 PROGRAM ACHIEVED ONE YEAR EARLY
On May 25, 1993, EPA officially released the Toxics Release Inventory (TRI) reporting
data for 1991. One of the more noteworthy findings revealed in the 1991 TRI reporting data
is that releases and transfers of 33/50 Program chemicals declined by 34% between 1988
and 1991, surpassing the Program's 1992 interim 33% national reduction goal a full year
ahead of schedule (see Figure 1). Data reported by facilities to TRI for 1991 indicate that
releases and transfers of 33/50 Program chemicals declined from 1.474 billion pounds in the
Program's 1988 baseline year to 973 million pounds in 1991, when categories of reporting in
1991 that were not required for reporting in 1988 are excluded (see below). The 501 million
pound reduction in reported emissions through 1991
exceeds by nearly 15 million pounds the amount required
to achieve the Program's 1992 interim 33% reduction goal.
The early achievement of the Program's 1992 reduction
goal, together with an analysis of facilities' projected
on-site releases and off-site transfers to treatment and
disposal of the 17 target chemicals through 1993
(reported for the first time in 1991), offers strong
encouragement that the 33/50 Program's ultimate goal of
a 50% reduction by 1995 will be achieved.
Many states, a number of industry associations, and
numerous individual companies include 33/50 Program
chemicals within the scope of their own reduction
programs. Twenty-six states had established toxics use
reduction and pollution prevention programs prior to
establishment of the 33/50 Program, and these
contributed to its design. Others have used the 33/50
Program as a model. EPA views the 33/50 Program as an
umbrella under which the federal government, states,
industry, and communities work in partnership to achieve
common goals. Any progress in reducing emissions of
33/50 Program chemicals reflects the efforts of all these
partners.
17 PRIORITY CHEMICALS
TARGETED BY THE 33/50
PROGRAM
BENZENE
CADMIUM & COMPOUNDS
CARBON TETRACHLORIDE
CHLOROFORM
CHROMIUM & COMPOUNDS
CYANIDES
DICHLOROMETHANE
LEAD & COMPOUNDS
MERCURY& COMPOUNDS
METHYL ETHYL KETONE
METHYL ISOBUTYL KETONE
NICKEL & COMPOUNDS
TETRACHLOROETHYLENE
TOLUENE
TRICHLOROETHANE
TRICHLOROETHYLENE
XYLENES
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1,750
1,500
1,250
1,000
750
500
250
Millions of Pounds
1992 Goal:
987.7 million
pounds
1995 Goal:
737.1 million
pounds
1988
1989
1990
1991
Figure 1. TRI Releases and Transfers of 33/50 Program Chemicals, 1988-1991.
EXCLUSIONS OF NEW TRI REPORTING DATA
TRI reporting requirements were significantly expanded for 1991 as a result of
Congress' passage of the Pollution Prevention Act of 1990 (PPA). (A detailed description of
the new TRI reporting requirements and related modifications to Form R, the TRI reporting
form, is provided in the Appendix to this report.) However, analyses of the progress of the
33/50 Program consider only environmental releases reported in Section 5 of Form R and
those off-site transfers reported in Section 6 that facilities were required to report under 1988
TRI reporting requirements: transfers to POTWs and other transfers for treatment and disposal
(as well as "other," which includes reports with missing or invalid off-site transfer codes).
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Accordingly, the following quantities of the 17 33/50 Program chemicals that are
reported by facilities in Sections 6 and 8 of Form R are excluded when comparing 1991 and
future years' TRI data to the Program's 1988 baseline:
• Off-site Transfers to Energy Recovery (Form R Section 6.2);
• Off-site Transfers to Recycling (Form R Section 6.2);
• All Quantities Reported for Items in the new Mandatory Source Reduction and
Recycling Activities Section (Form R Section 8.1 - 8.10).
These new reporting categories do, however, provide valuable information to EPA,
the public, and the reporting facilities themselves, and are discussed later in this report.
These data will be used by the 33/50 Program extensively in the future to determine how
facilities achieve reductions in environmental releases.
COMPANY PARTICIPATION IN THE 33/50 PROGRAM
The 33/50 Program represents an innovative experiment aimed at demonstrating
whether voluntary reduction programs can augment the Agency's traditional command-
and-control approach to protecting the environment by achieving targeted reductions
more quickly than would regulations alone. The Program is part of a broad group of EPA
activities designed to encourage pollution prevention as the best means of achieving
reductions in toxic chemical emissions. The 33/50 Program seeks to instill a pollution
prevention ethic throughout the highest echelons of American businesses.
Initial communications about the 33/50 Program are directed to the Chief Executive
Officers of the parent companies of the more than 16,400 industrial facilities that have
reported to EPA's Toxics Release Inventory (TRI) emitting any of the Program's 17 target
chemicals between 1988 and 1990. To date, more than 7,600 companies have been
invited to participate, and more than 700 additional companies identified as being asso-
ciated with 33/50 Program chemicals for the first time in the 1991 TRI data will be contacted
by EPA this fall. The Program achieved a major milestone in November 1992 when the
1,000th company committed to reducing its releases of toxic chemicals into the environ-
ment. As of August 1993, 1,172 companies have elected to participate, pledging to
reduce voluntarily nearly 355 million pounds of pollution (see Figure 2). Company partici-
pation in the 33/50 Program has risen steadily from its
inception in early 1991, increasing twofold from July 1991 to
February 1992 (publication dates for the Program's first two
Progress Reports), and again by more than 50% in the
Program's second year.
n ..... ... ... about EPA's 33/50
Reduction pledges continue to approach the proqram? See the back
Program's national goals, their slower growth rate reflect-
ing the fact that companies with the greatest amounts of
releases and transfers (the "Top 600") were the first to be
contacted. In addition, the 355 million pounds of reduc-
tions pledged to date represent a lower bound, as
-3-
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1,300
1,200
1,100
1,000
900
800
700
600
500
400
300
200
100
0
Commitments
Number of Companies
1995 Pledged Reductions
Millions of Pounds
1,172
1995 Goals
737 million pounds
1992 Goals
486 million pounds
304
355
201
July'91 Feb'92 Aug'93
July'91 Feb'92 Aug'93
1,300
1,200
1,100
1,000
900
800
700
600
500
400
300
200
100
0
Figure 2. 33/50 Program Commitment Status, August 1993.
numeric reduction targets are still being set by about a third of the participating
companies, and companies appear to be achieving greater reductions than they initially
anticipated.
Facilities owned by companies that have elected to participate in the 33/50
Program are reporting greater reductions in emissions of the 17 target chemicals than are
the facilities associated with nonparticipating companies. Between 1988 and 1991, partici-
pating companies reported a nearly 40% decrease in releases and transfers of Program
chemicals, compared to a 25% decline reported by nonparticipants. The difference
between participants and nonparticipants is somewhat greater for on-site environmental
releases: a 36% reduction in releases for participants versus a 20% reduction for non-
participants. Participating companies, representing only 15% of the companies invited to
participate, were responsible for 62% of the total releases and transfers of Program chemi-
cals in the 1988 baseline year and 57% in 1991.
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Table 1. 33/50 Program Commitment Status Overview, August 4,1993.
"5400" New New New Total from
"Top 600" Companies in 1989 in 1990 in 1991 Ail Companies
Contacted in Contacted in Contacted in Contacted in Not Yet as of
March 1991 July 1991 July 1992 January 1993 Contacted 08/04/93
Numbers of Companies
Companies Contacted by EPA 542 5,028 1,085 971 725
Responses with Commitments
to 33/50 Program 321 767 54 30 0
Responses with Quantifiable
Commitments 242 446 2 7 0
Quantities of the 17 Targeted Chemicals Covered by the 33/50 Program (Millions of Pounds, 1988)
Total Releases and Transfers
Reported to TRI in 1988 1,053 398 3.34 13.97 6
Total from the Companies
Making Commitments 823 84 0.86 4.77 0
Total from the Companies with
Quantifiable Commitments 724 54 0.86 4.72 0
Amount of Reductions Pledged by
1995 in Quantifiable Commitments 328 25 0.23 1.69 0
8,351
1,172
697
1,474
913
784
355
Assessing the success of our efforts to encourage companies to participate in the
33/50 Program yields two conclusions. EPA's outreach to the larger companies has proven
highly successful with nearly 60% choosing to enroll (see Table 1). However, getting the
message across to the more numerous smaller companies has been decidedly more
difficult; only one in ten has elected to participate. Accordingly, EPA is initiating new
outreach approaches to encourage smaller companies to participate, such as calling
facilities directly to discuss the benefits of the Program and to identify and address any
barriers that prevent them from participating.
33/50 PROGRAM CHEMICAL RELEASES AND TRANSFERS, 1988-1991
Figure 3 and Table 2 present facilities' reports of on-site releases and off-site transfers
to treatment and disposal for 1988 through 1991. The data are aggregated for all TRI
chemicals that have been included in TRI reporting requirements for each of the four years.
In addition, 33/50 Program chemicals are broken out in aggregate for comparison to all
other TRI chemicals.
Facilities' 1991 TRI reports show that, in the first year after formal announcement of
the 33/50 Program, the 17 target chemicals experienced substantially greater proportional
reductions (-21%) than all other TRI chemicals (-8%). This represents a significant change in
the reduction pattern from the two previous years. Prior to 1991, reductions in the releases
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8000
7000
6000
5000
4000
3000
2000
1000
Millions of Pounds
All TRI Chemicals
(Excluding
Additions/Deletions)
TRI Chemicals Less
33/50 Chemicals
33/50 Program
Chemicals Only
Figure 3. Releases and Transfers of 33/50 Program Chemicals Compared to Other TRI Chemicals,
1988-1991.
and off-site transfers of the 17 33/50 Program chemicals lagged significantly behind
reductions in other TRI chemicals. When the 17 33/50 Program chemicals are subtracted,
remaining TRI releases and transfers declined by 23% from 1988 through 1990, from just
under 5 billion pounds to 3.7 billion pounds. During that same period, emissions of the 17
targeted 33/50 Program chemicals were reduced by only 16%, from 1.47 billion pounds to
1.24 billion pounds (see Table 1).
At the time that EPA was formulating the 33/50 Program (late 1990 - early 1991), 1988
was the most recent year for which TRI data were available. The Program's baseline and
goals were set accordingly. Reductions that companies achieved between 1988 and 1990
therefore contribute to the 33/50 Program's national reduction goals. However, these prior
reductions should not be viewed as resulting from the 33/50 Program, as companies were
first informed about the Program in February of 1991.
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Table 2. Releases and Transfers of 33/50 Program Chemicals Compared to Other TRI Chemicals,
1988-1991.
Year
1988
1989
1990
1991
1988-1991
1988-1990
1990-1991
All TRI Chemicals
(Excluding Additions/
Deletions)
Pounds
6,450,516,964
5,829,763,906
4,996,203,787
4,419,162,282
Percent Change
-31.4%
-22.5%
-11.5%
TRI Chemicals
Less 33/50
Chemicals
Pounds
4,976,369,274
4,434,701,979
3,760,960,034
3,446,042,372
Percent Change
-30.7%
-24.4%
-8.3%
33/50 Program
Chemicals
Only
Pounds
1,474,147,690
1,395,061,927
1,235,243,753
973,119,910
Percent Change
-33.9%
-16.2%
-21.2%
Commencing in 1991, the 17 33/50 Program chemicals appear to have been the
focus of increased reduction activities at TRI facilities. The 21.2% reduction in releases and
transfers of Program chemicals reported by facilities for 1990 -1991 is nearly twice the
amount of reductions reported in ihe previous year (11.5% between 1989 and 1990), and
fully four times greater than the reductions observed between 1988 and 1989 (5.4%). 33/50
Program chemicals also contributed significantly to aggregate TRI release and transfer
reductions observed between 1990 and 1991. While representing only 22% of the total
volume of 1988-comparable TRI releases and transfers in 1991, 33/50 Program chemicals
accounted for nearly half (45%) of the total TRI 1990 -1991 reductions. Of the 577 million
pounds in total TRI release/transfer reductions reported for 1991, 262 million are associated
with the Program's 17 target chemicals.
Facilities' 1991 TRI reports on releases and off-site transfers of 33/50 Program chemi-
cals, as well as updated reports for 1988 through 1990, are summarized by chemical and
release medium/transfer management method in Table 3 (organics are listed first). Off-site
transfers of 33/50 Program chemicals have declined at a much higher rate than have their
on-site environmental releases. Transfers are down 50% from 1988, 39% in the last year
alone. On-site releases, which accounted for 80% of the 33/50 Program 1988 release/
transfer baseline, declined by 30% through 1991 and 17% in the last year (compared to 9%
for all other TRI chemicals).
Figures 4 and 5 present reduction trends for 33/50 Program chemicals aggregated
by on-site release medium/off-site transfer type and by chemical, respectively.
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Table 3. TRI Releases and Transfers of 33/50 Chemicals, 1988-1991.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Year
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
Fugitive or
Nonpoint Air
Emissions
Pounds
9,971,308
14,516,266
15,045,660
20,235,191
528,100
419,001
943,133
1,081,552
7,660,997
8,388,150
8,872,690
7,566,776
31,726,830
37,744,015
42,295,554
48,751,550
33,149,766
42,863,784
41,693,966
38,687,923
8,411,877
9,688,471
10,850,259
13,015,362
6,482,575
9,074,857
11,966,038
16,125,229
73,620,294
84,413,528
93,193,936
102,808,393
69,230,762
83,389,447
91,649,649
90,767,027
16,642,065
18,565,243
22,579,951
25,879,146
31,107,600
35,488,852
39,705,859
38,303,001
18,923
31,249
41,571
32,649
Stack or
Point Air
Emissions
Pounds
7,503,182
10,686,871
11,694,181
11,027,298
1,018,701
1,320,225
2,507,116
2,695,101
11,421,891
14,138,445
16,841,084
17,469,790
47,611,641
62,532,366
81,864,100
79,242,388
70,271,889
85,627,333
94,365,489
97,348,615
18,786,642
18,021,527
20,673,502
18,610,414
10,204,876
13,321,145
15,512,638
19,668,296
124,944,414
157,264,379
176,358,467
189,388,805
68,274,801
81,112,035
84,215,221
86,001,968
18,416,403
20,358,601
26,769,836
27,900,517
92,889,918
109,258,390
124,577,635
126,721,344
55,518
78,820
79,336
90,293
Surface
Water
Discharges
Pounds
26,896
24,524
169,274
46,998
2,844
4,718
15,656
15,627
769,569
1,005,860
1,177,743
1,126,484
98,877
190,500
226,823
350,050
141,354
77,514
71,781
91,344
167,405
53,798
449,407
762,108
7,448
21,510
53,940
33,314
104,645
198,500
182,297
197,820
21,803
16,722
27,309
95,934
12,750
14,210
15,849
13,802
60,644
46,920
193,497
211,898
4,241
3,339
4,731
4,397
Underground
Injection
Pounds
834,242
689,066
668,610
825,035
42,470
31,557
122,043
98,054
65,089
89,560
64,338
36,002
1,317,706
850,018
1,937,469
1,478,834
355,736
146,199
200,703
253,762
161,600
52,221
81,850
116,650
14,000
11,012
50,005
72,250
1,373,207
1,432,918
620,403
1,473,666
2,805
1,581
2,318
1,000
800
805
390
390
139,963
105,394
70,161
144,978
1,540
1,575
1,772
2,409
Releases
to Land
Pounds
111,928
722,486
120,355
127,920
2,152
1,005
1,616
14,759
22,150
57,924
70,265
68,546
117,788
21,024
15,894
157,211
180,492
50,423
171,347
166,458
177,939
24,733
20,891
31,770
23,302
1,255
10,791
82,144
185,012
383,904
427,055
741,301
171,807
62,176
70,630
187,786
62,991
12,554
8,686
21,186
344,052
434,245
486,326
651,589
251,127
404,423
350,503
389,729
Total
Releases
Pounds
18,447,556
26,639,213
27,698,080
32,262,442
1,594,267
1,776,506
3,589,564
3,905,093
19,939,696
23,679,939
27,026,120
26,267,598
80,872,842
101,337,923
126,339,840
129,980,033
104,099,237
128,765,253
136,503,286
136,548,102
27,705,463
27,840,750
32,075,909
32,536,304
16,732,201
22,429,779
27,593,412
35,981,233
200,227,572
243,693,229
270,782,158
294,609,985
137,701,978
164,581,961
175,965,127
177,053,715
35,135,009
38,951,413
49,374,712
53,815,041
124,542,177
145,333,801
165,033,478
166,032,810
331,349
519,406
477,913
519,477
-8-
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Table 3. TRI Releases and Transfers of 33/50 Chemicals, 1988-1991, Continued.
Chemical Year
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
Transfers
to POTWs
Pounds
613,449
634,025
1,107,975
1,135,172
621
42,050
3,841
5,014
809,427
802,260
1,101,731
1,226,573
1,308,202
1,281,832
921,911
1,830,832
772,861
867,891
886,502
962,868
816,066
1,258,294
1,286,727
1,509,030
234,637
450,787
467,081
586,288
1,266,355
1,724,465
3,001,993
3,549,792
293,508
169,540
312,010
304,103
72,845
11,353
31,269
79,252
1,593,182
1,948,480
3,970,355
4,224,204
265,771
14,278
19,564
21,613
Transfers Off-site
for Treatment
Disposal/Other
Pounds
1,799,039
2,221,216
1,839,858
2,295,959
980,569
1,082,188
1,716,813
1,350,511
1,827,299
1,321,726
865,533
1,369,922
12,605,336
9,163,437
12,813,000
22,688,907
9,998,866
20,323,777
28,506,748
28,620,683
2,274,295
4,548,341
6,468,802
10,323,972
3,830,559
4,433,734
4,279,472
5,511,471
22,006,245
39,898,984
63,484,088
61,614,018
8,000,615
12,472,740
16,662,054
19,513,105
2,793,368
3,690,232
4,966,856
6,401,817
20,542,421
24,427,444
33,828,419
37,878,912
1,449,863
1,325,800
748,958
1,289,122
Total
Transfers
Pounds
2,412,488
2,855,241
2,947,833
3,431,131
981,190
1,124,238
1,720,654
1,355,525
2,636,726
2,123,986
1,967,264
2,596,495
13,913,538
10,445,269
13,734,911
24,519,739
10,771,727
21,191,668
29,393,250
29,583,551
3,090,361
5,806,635
7,755,529
11,833,002
4,065,196
4,884,521
4,746,553
6,097,759
23,272,600
41,623,449
66,486,081
65,163,810
8,294,123
12,642,280
16,974,064
19,817,208
2,866,213
3,701,585
4,998,125
6,481,069
22,135,603
26,375,924
37,798,774
42,103,116
1,715,634
1,340,078
768,522
1,310,735
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Table 3. TRI Releases and Transfers of 33/50 Chemicals, 1988-1991, Continued.
Chemical
Chromium and
chromium compounds
Cyanide compounds
Lead and
lead compounds
Mercury and
mercury compounds
Nickel and
nickel compounds
Total
Total less
33/50 Chemicals
Total for All
TRI Chemicals
Year
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
Fugitive or
Nonpoint Air
Emissions
Pounds
585,757
582,076
1,624,574
615,838
125,870
240,688
313,594
657,222
553,782
917,589
757,704
858,635
11,912
14,798
18,112
17,037
469,498
375,830
819,300
414,913
290,297,916
346,713,844
382,371,550
405,817,444
319,467,748
360,034,463
411,226,231
417,921,098
609,765,664
706,748,307
793,597,781
823,738,542
Stack or
Point Air
Emissions
Pounds
532,744
596,901
737,750
713,310
1,899,044
1,620,330
1,485,888
1,606,398
1,285,604
1,569,431
1,664,854
1,821,383
7,830
8,759
11,482
8,724
322,989
315,836
319,959
285,076
475,448,087
577,831,394
659,678,538
680,599,720
894,132,227
998,123,454
1,108,918,301
1,161,770,936
1,369,580,314
1,575,954,848
1,768,596,839
1,842,370,656
Surface
Water
Discharges
Pounds
352,522
448,076
546,412
400,837
119,860
129,089
160,186
197,201
138,433
132,656
149,235
241,243
671
809
1,568
1,656
126,954
146,456
206,813
219,780
2,156,916
2,515,201
3,652,521
4,010,493
241,340,401
194,317,559
184,372,712
307,060,098
243,497,317
196,832,760
188,025,233
311,070,591
Underground
Injection
Pounds
35,150
83,222
59,803
54,902
4,727,763
4,981,212
8,025,123
5,445,176
928
1,648
1,564
2,760
9
21
36
27
370,948
268,958
288,212
239,263
9,443,956
8,746,967
12,194,800
10,245,158
700,804,048
736,666,595
1,163,389,036
1,333,388,310
710,248,004
745,413,562
1,175,583,836
1,343,633,468
Releases
to Land
Pounds
25,916,872
28,257,128
34,477,025
40,228,739
26,785
24,320
29,499
108,969
17,022,789
19,069,275
20,075,314
26,962,797
5,315
4,199
5,202
13,779
1,672,468
6,060,825
4,413,068
3,629,809
46,294,969
55,591,899
60,754,467
73,584,492
374,865,144
407,087,493
394,274,534
453,962,230
421,160,113
462,679,392
455,029,001
527,546,722
Total
Releases
Pounds
27,423,045
29,967,403
37,445,564
42,013,626
6,899,322
6,995,639
10,014,290
8,014,966
19,001,536
21,690,599
22,648,671
29,886,818
25,737
28,586
36,400
41,223
2,962,857
7,167,905
6,047,352
4,788,841
823,641,844
991,399,305
1,118,651,876
1,174,257,307
2,530,609,568
2,696,229,564
3,262,180,814
3,674,102,672
3,354,251,412
3,687,628,869
4,380,832,690
4,848,359,979
-10-
-------
Table 3. TRI Releases and Transfers of 33/50 Chemicals, 1988-1991, Continued.
Chemical
Chromium and
chromium compounds
Cyanide compounds
Lead and
lead compounds
Mercury and
mercury compounds
Nickel and
nickel compounds
Total
Total less
33/50 Chemicals
Total for All
TRI Chemicals
Year
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
91
90
89
88
Transfers
toPOTWs
Pounds
1,188,103
1,113,077
1,330,666
2,125,066
121,728
119,291
149,462
1,152,581
592,526
191,277
152,316
211,951
64
316
2,058
2,141
639,048
314,721
449,440
902,504
10,588,393
10,943,937
15,194,901
19,828,984
400,008,494
455,179,147
543,380,257
554,216,396
410,596,887
466,123,084
558,575,158
574,045,380
Transfers Off-site
for Treatment
Disposal/Other
Pounds
20,265,897
35,623,076
32,774,374
31,664,881
824,994
1,589,950
2,436,901
2,719,125
20,156,681
56,043,501
31,041,273
30,708,010
193,973
213,305
188,144
275,017
9,339,653
14,521,060
18,593,857
15,835,967
138,889,673
232,900,511
261,215,150
280,061,399
515,424,310
609,551,323
629,140,908
748,050,206
654,313,983
842,451,834
890,356,058
1,028,111,605
Total
Transfers
Pounds
21,454,000
36,736,153
34,105,040
33,789,947
946,722
1,709,241
2,586,363
3,871,706
20,749,207
56,234,778
31,193,589
30,919,961
194,037
213,621
190,202
277,158
9,978,701
14,835,781
19,043,297
16,738,471
149,478,066
243,844,448
276,410,051
299,890,383
915,432,804
1,064,730,470
1,172,521,165
1,302,266,602
1,064,910,870
1,308,574,918
1,448,931,216
1,602,156,985
-11 -
-------
800
Millions of Pounds
700
600
500
400
300
200
100
• 1988
EH 1989
• 1990
01991
Fugitive Stack Surface Under- Land Transfers Treatment/
Air Air Water ground to POTWs Disposal/
Injection Other
Off-site
Figure 4. Total TRI Releases and Transfers of 33/50 Program Chemicals, by On-site Release Medium/
Transfer Management Type, 1988-1991.
-12-
-------
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
• 1988
• 1989
• 1990
EM991
100
200
Millions of Pounds
300
400
Figure 5. Total TRI Releases and Transfers of 33/50 Program Chemicals, by Chemical, 1988-1991.
- 13-
-------
TRI POLLUTION PREVENTION ACT DATA FOR 33/50 PROGRAM CHEMICALS
As described in the Appendix to this report the Pollution Prevention Act of 1990
substantially expanded the scope of TRI to include reporting on additional toxic chemical
management activities. Off-site transfers to energy recovery and recycling processes are
now reported in Section 6.2 of Form R in addition to the previously reported transfers to
POTWs and other treatment and disposal facilities. Off-site transfers to energy recovery and
recycling facilities are also reported in Section 8 of Form R, which was made mandatory
under the PPA, in addition to amounts of toxic chemicals combusted for on-site energy
recovery or recovered in on-site recycling processes. Section 8 also includes reporting on
amounts of toxic chemicals destroyed in on-site treatment systems and amounts sent to off-
site treatment facilities, as well as an aggregate of the amounts of each chemical the
facility released to the environment as a result of on-site operations plus the amounts
shipped off-site for disposal.
Section 8 reporting items described above pertain only to chemical quantities con-
tained in wastes that are the result of regular production-related activities. Toxic chemical
quantities contained in wastes that are generated at the facility through non-routine activi-
ties, such as spill cleanups and other catastrophic events, are reported in a separate Sec-
tion 8 reporting item. Each of the items reported for production-related wastes in Section 8
is reported in aggregate, by chemical, for the reporting year (1991), the prior year (1990),
and forecasted by facilities for the two successive years (1992 and 1993).
33/50 TRANSFERS TO ENERGY RECOVERY AND RECYCLING
Tables 4 and 5 present a complete summary of 1991 on-site releases and off-site
transfers reported by facilities in Sections 5 and 6 of Form R for each 33/50 Program chemi-
cal, by on-site release medium and off-site transfer type. Release reporting in Section 5,
summing to 823.6 million pounds, is identical in nature to reporting in prior years. Reporting
on off-site transfers, however, has been significantly affected by the new PPA requirement
to include transfers to energy recovery (216.4 million pounds) and transfers to recycling
(523.2 million pounds). Each of these new reporting categories on its own exceeds the total
for all off-site transfers that were previously required to be reported (149.5 million pounds).
These new data indicate that the bulk of 33/50 Program metals and their associated
compounds were shipped off-site for recycling. Some quantities of metals erroneously
have been reported as sent off-site for energy recovery, as metals do not contribute to the
heating value of the wastes in which they are contained and are not destroyed in energy
recovery processes. Off-site recycling of lead and its compounds alone accounted for
nearly 40% of all such transfers of 33/50 Program chemicals. Greater quantities of the
organic chemicals were also recycled than were burned for energy. Energy recovery was
a more prevalent off-site management method than recycling only for benzene, methyl
ethyl ketone, toluene, and xylenes.
MANAGEMENT OF 33/50 PROGRAM CHEMICALS IN WASTES
Tables 6 through 10 present all four years of Section 8 reporting data for each 33/50
Program chemical, by waste management activity (non-production-related wastes are
reported only for 1991). Again, the magnitude of the quantities associated with new report-
-14-
-------
Table 4. TRI Releases of 33/50 Chemicals, 1991.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethyiene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Chromium and
chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and
mercury compounds
Nickel and
nickel compounds
Total
Total less
33/50 Chemicals
Total for All
TRI Chemicals
Fugitive or
Nonpoint Air
Emissions
Pounds
9,971,308
528,100
7,660,997
31,726,830
33,149,766
8,411,877
6,482,575
73,620,294
69,230,762
16,642,065
31,107,600
18,923
585,757
125,870
553,782
11,912
469,498
290,297,916
336,081,480
626,379,396
Stack or
Point Air
Emissions
Pounds
7,503,182
1,018,701
11,421,891
47,611,641
70,271,889
18,786,642
10,204,876
124,944,414
68,274,801
18,416,403
92,889,918
55,518
532,744
1,899,044
1,285,604
7,830
322,989
475,448,087
908,726,582
1,384,174,669
Surface
Water
Discharges
Pounds
26,896
2,844
769,569
98,877
141,354
167,405
7,448
104,645
21,803
12,750
60,644
4,241
352,522
119,860
138,433
671
126,954
2,156,916
241,356,856
243,513,772
Underground
Injection
Pounds
834,242
42,470
65,089
1,317,706
355J36 '
161,600
14,000
1,373,207'
> 2,805
800
139,963
l,54b
35,150
4,727,763
928
9
370,948
9,443,956
700,933,181
710,377,137 '
Releases
to Land
Pounds
111,928
2,152
22,150
117,788
180,492
177,939
23,302
i 85,01 2
171,807
62,991
344,052
251,127
25,916,872
26,785
17,022,789
5,315
1,672,468
46,294,969
375,133,175
421,428,144
Total
Releases
Pounds
18,447,556
1,594,267
19,939,696
80,872,842
104,099,237
27,705,463
16,732,201
200,227,572
137,701,978
35,135,009
124,542,177
331,349
27,423,045
6,899,322
19,001,536
25,737
2,962,857
823,641,844
2,562,231,274
3,385,873,118
ing categories is overwhelming relative to the amounts for previously reported releases and
transfers. On-site recycling (4.3 billion pounds) dominates the waste management picture
for the 17 Program chemicals, more than quadrupling the 1988-conhparable figures in 1991.
As expected, quantities associated'With on-site waste management activities are substan-
tially greater than off-site transfers to similar management methods.
Analysts will note significant discrepancies between reported off-site transfers to
energy recovery and recycling in Sections 6 and 8. Less significant discrepancies can also
be observed in the reporting of off-site shipments to tredtnhent. The causes and meaning of
these discrepancies are discussed in the Appendix to this report. Figure 6 presents two
profiles of 1991 reporting data for 33/50 Program chemicals to illustrate the impact of the
expansions to TRI reporting brought about by the PPA. Two profiles are presented to
accommodate the significant discrepancies in reporting for off-site energy recovery and
recycling between Sections 6 and 8. In one profile (left), off-site energy recovery and
recycling data are taken from Section 6. In the other profile (right), off-site energy recovery
and recycling data are taken from Section 8. In both profiles, Section 8 data for off-site
treatment (77 million pounds) are omitted, as their inclusion would duplicate off-site
treatment quantities (102.5 million pounds) included in the 1988-comparable release/
transfer amount reported in Section 6. Section 8.1 reporting for on-site releases and off-site
-15-
-------
Table 5. TRI Transfers of 33/50 Chemicals, 1991.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Chromium and
chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and
mercury compounds
Nickel and
nickel compounds
Total
Total less 33/50 Chemicals
Total for All TRI Chemicals
Transfers
to POTWs
Pounds
613,449
621
809,427
1,308,202
772,861
816,066
234,637
1,266,355
293,508
72,845
1,593,182
265,771
1,188,103
121,728
592,526
64
639,048
10,588,393
401,318,705
411,907,098
Transfers to Transfers
Treatment to Disposal
Pounds Pounds
1,656,194
939,774
1,755,778
11,956,118
9,365,077
2,112,745
3,580,303
20,171,434
6,743,974
2,577,754
19,283,497
388,557
3,969,938
447,295
4,559,119
65,531
2,318,764
91,891,852
260,541,316
352,433,168
142,460
39,111
71,518
495,762
512,746
155,643
1 12,237
1,636,162
969,200
115,974
1,001,342
1,019,701
15,972,793
365,309
15,494,344
128,442
6,648,274
44,881,018
254,161,433
299,042,451
Transfers
to Energy
Recovery
Pounds
3,675,466
11,061
255,288
3,717,385
35,111,556
18,801,198
1,232,887
80,207,715
3,212,938
802,290
69,220,174
7,460
69,423
500
68,833
5
12,353
216,406,532
221,818,810
438,225,342
Transfers
to Recycling
Pounds
353,205
390,625
2,077,870
29,163,629
26,033,673
20,346,186
10,694,61 1
24,882,493
27,237,545
6,785,517
38,913,506
2,266,912
68,437,500
82,660
204,841,122
445,451
60,230,889
523,183,394
1,830,940,192
2,354,123,586
Other
Off-site
Transfers
Pounds
385
1,684
3
153,456
121,043
5,907
138,019
198,649
287,441
99,640
257,582
41,605
323,166
12,390
103,218
0
372,615
2,116,803
7,433,076
9,549,879
Total
Transfers
Pounds
6,441,159
1,382,876
4,969,884
46,794,552
71,916,956
42,237,745
15,992,694
128,362,808
38,744,606
10,454,020
130,269,283
3,990,006
89,960,923
1,029,882
225,659,162
639,493
70,221,943
889,067,992
2,976,213,532
3,865,281,524
transfers to disposal (846.3 million pounds) is also excluded in favor of their counterparts
from Section 5 and 6 (823.6 million pounds of on-site releases plus 44.9 million pounds of
transfers to disposal).
As indicated in Figure 6, the 140 million pound discrepancy between Section 6 and
Section 8 reporting for transfers to energy recovery and recycling, while nearly equal to the
total for all other off-site transfers of 33/50 Program chemicals, is less significant in the con-
text of total waste management for the 17 Program chemicals. More importantly, the
figure illustrates that 1988-comparable releases and off-site transfers play a relatively small
role in the management of 33/50 Program chemicals in wastes. When all quantities in
Section 8.1 through 8.8 are summed, the total amount of 33/50 Program chemicals in
wastes reported by facilities to TRI for 1991 is 7.3 billion pounds. (A similar total is developed,
50 million pounds (less than 1%) greater, when summing the figures used from Sections 5, 6,
and 8 in constructing the right bar of Figure 6.) The 973 million pounds of releases and
transfers that are the focus of the 33/50 Program's reduction goals account for only 13% of
this total.
Figures 7 and 8 present the data reported for 33/50 Program chemicals in Section 8
of Form R, aggregated by management method and chemical, respectively.
-16-
-------
SOURCE REDUCTION REPORTING HIGHEST FOR 33/50 PROGRAM CHEMICALS
Facilities are also required to report in Section 8 of Form R any source reduction
efforts that were directed toward TRI chemicals during the reporting year. Table 11 sum-
marizes facilities' reporting of source reduction activities for each of the 17 33/50 Program
chemicals. As a group and individually, 33/50 Program chemicals evidenced higher rates
of source reduction reporting than other TRI chemicals. Of the more than 21,000 Form R's
reporting that a source reduction activity was implemented during 1991, fully 40% (8,609)
were for the 17 33/50 Program chemicals, even though Program chemicals account for
only 30% of total TRI Form R's. More than a third of the Form R's for 33/50 Program chemi-
cals reported the occurrence of source reduction, compared to slightly more than a fifth of
the forms for other TRI chemicals.
Individual 33/50 Program chemicals had some of the highest rates of reporting on
source reduction. The three TRI chemicals with the greatest number of Form R's reporting
source reduction, and four of the top five, were 33/50 Program chemicals (1,1,1-trichloro-
ethane, toluene, xylenes, and methyl ethyl ketone). The high ranking for 33/50 Program
chemicals is partially due to the fact that they rank among the highest TRI chemicals in total
number of Form R's submitted, but they also evidenced some of the highest percentages of
Form R submissions indicating source reduction.
Sixteen 33/50 Program chemicals are among the top 35 TRI chemicals reporting
source reduction. Of these, organic chemicals generally evidenced higher percentages of
Form R's reporting source reduction than did the metals, ranging from 30% to 45% for the
nine organic chemicals with the largest number of source reduction reports. Among the
three 33/50 Program metals with large numbers of Form R's, lead came the closest to
achieving a similarly high source reduction reporting rate (28%). Twenty percent of the
reports for cadmium, the most frequently reported metal, indicated source reduction, as
did 16.5% of the reports for nickel.
Facilities described the type of source reduction activity that they implemented for
each chemical (see Table 11). 33/50 Program chemicals as a group did not differ signifi-
cantly from other TRI chemicals in the types of activities employed. Improvement in facility
operating practices is the most common approach. If, however, Form R source reduction
activity categories for Cleaning and Degreasing and for Surface Preparation and Finishing
are aggregated into another category, Process Modifications, Process Modifications would
rank as the most frequently employed source reduction activity, particularly so for 33/50
Program chemicals.
Facilities also described the methods they employed in identifying source reduction
opportunities. Table 12 summarizes facilities' reporting of source reduction activity identifi-
cation methods for each of the 17 33/50 Program chemicals. Here again, facilities did not
seem to treat Program chemicals differently than other TRI chemicals in their search for
source reduction opportunities. For the most part, facilities are drawing on their own
resources to investigate pollution prevention options, either by conducting formal audits
(Pollution Prevention Opportunity Audits or Materials Balance Audits) or by developing
ideas from management teams and employees. The 33/50 Program is built on the premise
-17-
-------
Table 6. TRI Data Collected under the Pollution Prevention Act for 33/50 Chemicals, 1990-1993:
Quantity Recycled(a).
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal On-site for 33/50 Chemicals
Subtotal On-site less 33/50 Chemicals
Subtotal On-site for All TRI Chemicals
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal Off-site for 33/50 Chemicals
Subtotal Off-site less 33/50 Chemicals
Subtotal Off-site for All TRI Chemicals
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Projected Data
1990
On-site
Pounds
186,221,940
13,809,422
4,120,879
153,704,577
860,316,285
172,649,101
141,398,774
1,044,915,519
188,056,560
223,411,546
176,416,278
3,680,759
66,854,044
4,826,689
722,419,745
1,544,836
40,416,570
4,004,763,524
10,447,403,204
14,452,166,728
1991
On-site
Pounds
196,393,605
10,238,966
4,125,901
182,108,296
864,307,237
' 184,837,606
118,584,078
1,118,482,253
204,077,933
253,517,471
207,081,028
3,865,283
91,951,101
3,815,454
774,086,405
1,282,925
48,601,735
4,267,357,277
12,111,751,405
16,379,108,682
1992
On-site
Pounds
202,417,036
14,299,143
4,149,851
171,887,424
873,842,445
183,517,967
100,085,824
1,126,516,579
170,420,702
253,726,305
173,057,124
3,800,234
84,412,237
5,370,332
843,333,074
946,870
44,418,955
4,256,202,102
11,643,298,317
15,899,500,419
1993
On-site
Pounds
205,490,682
14,824,425
4,189,401
175,443,735
877,203,944
179,009,876
100,707,105
1,108,863,252
104,844,395
250,591,479
176,307,518
3,765,578
86,717,179
4,666,497
896,477,272
951,870
46,024,696
4,236,078,904
11,765,547,167
16,001,626,071
Projected Data
1990
Off-site
Pounds
825,048
9,901
301,029
27,349,922
26,615,454
12,259,999
8,587,970
19,940,589
29,815,008
7,142,607
25,237,600
2,536,773
64,485,821
62,415
274,126,453
111,001
51,718,854
551,126,444
1,983,231,225
2,534,357,669
4,555,889,968
12,430,634,429
16,986,524,397
1991
Off-site
Pounds
1,414,752
390,538
2,078,744
26,224,925
24,888,298
17,952,566
9,035,196
24,557,245
28,751,600
7,446,327
33,701,307
2,039,641
106,599,026
38,280
273,499,683
274,247
78,737,821
637,630,196
2,624,350,735
3,261,980,931
4,904,987,473
14,736,102,140
19,641,089,613
1992
Off-site
Pounds
1,314,877
367,312
2,041,306
23,995,107
25,029,100
17,722,322
7,963,251
24,863,740
22,123,251
6,052,720
30,886,210
2,060,981
94,945,018
44,074
281,759,583
336,080
72,225,397
613,730,329
2,602,497,818
3,216,228,147
4,869,932,431
14,245,796,135
19,115,728,566
1993
Off-site
Pounds
814,678
366,722
2,041,313
19,742,164
24,040,995
18,119,834
7,924,658
23,355,561
14,070,105
4,984,824
32,032,227
2,081,824
99,739,938
8,465
294,874,150
336,334
73,600,958
618,134,750
2,598,748,897
3,216,883,647
4,854,213,654
14,364,296,064
19,218,509,718
-18-
-------
Table 7. TRI Data Collected under the Pollution Prevention Act for 33/50 Chemicals, 1990-1993:
Quantity Used for Energy Recovery (a).
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal On-site for 33/50 Chemicals
Subtotal On-site less 33/50 Chemicals
Subtotal On-site for AH TRI Chemicals
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal Off-site for 33/50 Chemicals
Subtotal Off-site less 33/50 Chemicals
Subtotal Off-site for All TRI Chemicals
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Projected Data
1990
On-site
Pounds
21,176,508
3,288,879
1,990,067
15,632,408
90,352,222
42,654,440
12,382,080
250,558,252
7,363,780
6,083,419
197,292,824
0
0
42,279,210
83,604
0
0
691,137,693
2,070,035,242
2,761,172,935
1991
On-site
Pounds
33,714,288
5,964,156
5,499,527
14,270,049
94,341,416
36,906,508
4,013,084
254,980,246
14,001,816
6,188,130
217,136,701
0
0
22,849,436
116,475
0
0
709,981,832
2,476,813,901
3,186,795,733
1992
On-site
Pounds
28,812,538
15,555,356
7,519,104
15,310,887
95,158,244
37,823,204
4,226,835
262,443,091
14,637,770
6,212,991
223,801,420
0
1
20,922,422
118,500
0
10
732,542,373
2,491,144,959
3,223,687,332
1993
On-site
Pounds
26,158,418
18,746,865
9,496,582
16,221,100
107,555,209
42,955,740
4,452,966
288,619,559
15,354,150
6,581,666
239,747,588
0
0
21,279,382
119,200
0
10
797,288,435
3,157,142,198
3,954,430,633
Projected Data
1990
Off-site
Pounds
3,372,068
1,835
346,140
5,746,239
36,653,958
12,022,235
909,105
72,799,299
3,493,538
1,002,311
64,803,135
6,282
53,683
14
32,312
0
13,875
201,256,029
225,699,366
426,955,395
892,393,722
2,295,734,608
3,188,128,330
1991
Off-site
Pounds
4,932,365
10,849
720,671
6,066,234
38,424,594
19,306,703
1,504,622
86,805,609
3,913,519
1,045,752
78,056,842
8,317
74,993
24
69,831
3,241
9,629
240,953,795
256,803,676
497,757,471
950,935,627
2,733,617,577
3,684,553,204
1992
Off-site
Pounds
4,529,408
5,281
621,330
5,319,225
36,077,565
18,676,693
1,080,036
86,510,188
3,033,116
811,472
75,318,262
7,620
74,344
415
66,704
9,435
4,701
232,145,795
253,747,321
485,893,116
964,688,168
2,744,892,280
3,709,580,448
1993
Off-site
Pounds
4,943,593
291
546,922
4,906,635
34,365,357
19,096,258
893,510
84,352,277
2,131,378
581,760
71,066,260
6,968
66,578
3,915
64,264
500
4,694
223,031,160
249,733,225
472,764,385
1,020,319,595
3,406,875,423
4,427,195,018
-19-
-------
Table 8. TRI Data Collected under the Pollution Prevention Act for 33/50 Chemicals, 1990-1993:
Quantity Treated(a).
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal On-site for 33/50 Chemicals
Subtotal On-site less 33/50 Chemicals
Subtotal On-site for All TRI Chemicals
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Subtotal Off-site for 33/50 Chemicals
Subtotal Off-site less 33/50 Chemicals
Subtotal Off-site for All TRI Chemicals
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Projected Data
1990
On-site
Pounds
21,865,259
13,123,649
33,086,010
31,161,206
33,969,950
9,079,196
19,531,235
99,851,002
3,620,168
1,798,181
32,087,790
962,670
25,996,738
49,102,212
44,258,209
35,157
18,885,365
438,413,997
8,608,976,557
9,047,390,554
1991
On-site
Pounds
31,256,769
15,074,894
26,581,978
34,185,873
45,423,894
11,765,185
15,284,084
128,268,450
3,047,769
4,886,629
49,180,388
712,333
35,697,855
50,527,548
42,243,213
35,853
19,545,273
513,717,988
9,269,656,632
9,783,374,620
1992
On-site
Pounds
30,799,920
14,924,565
26,600,006
36,339,814
48,814,259
11,945,634
15,786,368
142,527,931
2,439,239
4,698,415
52,651,046
705,249
40,377,635
51,209,641
42,763,966
37,450
18,863,329
541,484,467
9,615,878,074
10,157,362,541
1993
On-site
Pounds
31,517,292
15,362,639
26,773,101
38,081,156
48,466,536
12,198,975
15,981,873
163,838,919
2,850,333
4,790,711
55,059,974
612,729
42,648,217
52,074,846
42,621,846
99,321
18,847,258
571,825,726
9,584,434,494
10,156,260,220
Projected Data
1990
Off-site
Pounds
2,662,027
971,935
1,935,098
8,345,059
7,708,590
3,207,654
2,841,310
16,850,242
4,633,476
2,472,268
11,536,274
187,530
5,481,567
364,474
6,759,380
100,779
4,391,217
80,448,880
773,451,024
853,899,904
518,862,877
9,382,427,581
9,901,290,458
1991
Off-site
Pounds
2,163,924
840,933
2,007,797
10,528,620
7,757,468
2,532,919
3,305,286
13,865,706
5,253,041
2,630,021
11,994,985
357,559
4,972,054
418,974
5,719,036
64,797
2,593,065
77,006,185
797,279,247
874,285,432
590,724,173
10,066,935,879
10,657,660,052
1992
Off-site
Pounds
1,956,285
1,020,048
2,090,584
11,176,243
6,933,344
2,304,960
2,458,500
15,388,873
4,008,457
2,593,185
8,251,526
459,238
3,903,276
328,280
5,763,383
41,108
1,625,926
70,303,216
702,432,610
772,735,826
611,787,683
10,318,310,684
10,930,098,367
1993
Off-site
Pounds
1,819,685
658,157
1,485,414
11,040,959
5,865,304
2,050,784
858,165
13,451,138
2,752,287
2,440,062
7,538,476
386,540
3,205,968
263,037
5,232,153
31,997
1,555,650
60,635,776
675,556,541
736,192,317
632,461,502
10,259,991,035
10,892,452,537
-20-
-------
Table 9. TRI Data Collected under the Pollution Prevention Act for 33/50 Chemicals, 1990-1993:
Quantify Released (Includes Off-site Disposal)(a).
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Total Released On-site/Disposed of
Off-site for 33/50 Chemicals
Total Released On-site/Disposed of
Off-site less 33/50 Chemicals
Total Released On-site/Disposed of
Off-site for All TRI Chemicals
Projected Data
1990
Pounds
22,777,071
1,711,637
23,184,204
90,259,930
117,221,288
26,480,175
19,170,142
215,032,891
141,349,697
38,020,135
123,317,694
1,319,468
38,085,219
8,810,822
42,676,945
133,963
13,215,548
922,766,829
2,873,922,207
3,796,689,036
1991
Pounds
18,760,658
1,649,063
19,739,220
80,189,944
102,309,424
28,194,835
16,407,683
196,784,903
132,160,136
34,532,204
122,964,725
1,235,362
40,080,347
7,055,445
35,455,972
98,786
8,708,102
846,326,809
2,924,868,083
3,771,194,892
1992
Pounds
14,341,727
1,359,662
16,871,435
64,243,069
86,053,440
27,164,097
11,940,254
171,886,924
104,897,302
29,156,169
111,356,550
1,256,353
38,551,411
7,068,939
32,792,185
205,295
7,797,482
726,942,294
2,831,907,246
3,558,849,540
1993
Pounds
12,669,477
1,272,155
14,278,092
57,398,045
76,789,187
25,506,386
9,051,251
156,803,806
72,454,478
23,989,725
107,104,561
1,179,702
37,435,248
6,716,208
30,778,099
54,531
7,470,241
640,951,192
2,466,510,911
3,107,462,103
and promise of forging partnerships to achieve pollution prevention, and companies
appear to be relying heavily on partnerships with their employees and managers in
seeking source reduction opportunities.
Where facilities have sought outside assistance in identifying prevention oppor-
tunities, material/product/process vendors are the dominant choice. Facilities report little
reliance on State and Federal programs for assistance in their source reduction endeavors.
This may be a consequence of the fact that most government pollution prevention assist-
ance programs are in their infancies. But the heavy reliance on internal resources suggests
that familiarity with facility-specific conditions is critical to successful identification of
source reduction opportunities.
POLLUTION PREVENTION TECHNICAL ASSISTANCE FROM THE 33/50 PROGRAM
The 33/50 Program is developing ways to promote pollution prevention through
information collection and exchange and is facilitating the use and growth of existing
technical assistance programs and resources across the country. Some of EPA's pollution
prevention technology assistance and transfer efforts are listed below.
-21 -
-------
Table 10. TRI Data Collected under the Pollution Prevention Act for 33/50 Chemicals, 1990-1993:
Total Wastes(a).
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Chromium and
chromium compounds
Cyanides
Lead and lead compounds
Mercury and
mercury compounds
Nickel and
nickel compounds
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
1990
Total Production
Related Wastes
Pounds
258,899,921
32,917,258
64,963,427
332,199,341
1,172,837,747
278,352,800
204,820,616
1,719,947,794
378,332,227
279,930,467
630,691,595
8,693,482
200,957,072
105,445,836
1,090,356,648
1,925,736
128,641,429
6,889,913,396
26,982,718,825
33,872,632,221
1991
Total Production
Related Wastes
Pounds
288,636,361
34,169,399
60,753,838
353,573,941
1,177,452,331
301,496,322
168,134,033
1,823,744,412
391,205,814
310,246,534
720,115,976
8,218,495
279,375,376
84,705,161
1,131,190,615
1,759,849
158,195,625
7,292,974,082
30,461,523,679
37,754,497,761
Projected Data
1992
Total Production
Related Wastes
Pounds
284,171,791
47,531,367
59,893,616
328,271,769
1,171,908,397
299,154,877
143,541,068
1,830,137,326
321,559,837
303,251,257
675,322,138
8,289,675
262,263,922
84,944,103
1,206,597,395
1,576,238
144,935,800
7,131,955,496
30,182,301,425
37,314,256,921
1993
Total Production
Related Wastes
Pounds
283,413,825
51,231,254
58,810,825
322,833,794
1,174,286,532
298,937,853
139,869,528
1,839,284,512
214,457,126
293,960,227
688,856,604
8,033,341
269,813,128
85,012,350
1,270,166,984
1,474,553
147,503,507
7,147,945,943
30,137,673,433
37,285,619,376
1991
Non-Production
RelatedWastes
Pounds
108,722
101,757
124,714
490,093
164,607
57,244
221,631
666,612
293,081
161,449
633,162
115,133
370,195
3,508
830,774
5,299
145,458
4,493,439
26,957,593
31,451,032
Pollution Prevention Information Clearinghouse and
the Pollution Prevention Information Exchange System (PIES)
The Clearinghouse contains technical, policy, programmatic, legislative, and finan-
cial information on pollution prevention activities across the country and abroad. The
Clearinghouse is a free, non-regulatory service of EPA and may be reached by personal
computer modem (via PIES), telephone, or mail. PIES is a free computer bulletin board that
allows users to access the full range of information contained in the Clearinghouse. Since
the PIES system is interactive, users can address questions to other users and Clearinghouse
technical staff, order documents, and exchange information. PIES contains message
centers, technical databases, issue-specific "mini-exchanges," bulletins on pollution
prevention events, and a calendar of pollution prevention conferences and events. PIES
contains a specialized bulletin board, or mini-exchange, devoted to the 33/50 Program. To
(a) Submission of prior year (1990) data was optional in this first year of reporting. Data for 1992 and 1993
were estimated projections by the facilities submitting Form Rs for the 1991 reporting year. They do not
represent reported totals for the 1992 or 1993 reporting years (Tables 4-5 through 4-9).
-22-
-------
8,000
Millions of Pounds
6,000
4,000
2,000
0
Off-site Energy
Recovery and
Recycling from
Section 6
Off-site Energy
Recovery and
Recycling from
Section 8
On-site Recycling, Energy Recovery, and Treatment (4,267.4 million + 710.0 million
+ 513.7 million = 5,491.1 million in Section 8)
Off-site Recycling and Energy Recovery (739.6 million in Section 6; 878.6 million in
Section 8)
1988 Comparable Releases and Transfers (823.6 million Releases in Section 5 +
149.5 million Transfers to POTWs, Treatment, Disposal, and Other in Section 6 =
973.1 million)
Figure 6. New Reporting under the Pollution Prevention Act in 1991 for 33/50 Program Chemicals.
-23-
-------
8,000
Millions of Pounds
6,000
4,000
2,000
• 1990
• 1991
• 1992
Q1993
Recycled Recycled Energy Energy Treated
On-site Off-site Recovery Recovery On-site
On-site Off-site
Treated Released Total
Off-site On-site/ Production
Disposed of Wastes
Off-site
Figure 7. TRI Data Collected under the Pollution Prevention Act for 33/50 Program Chemicals, by
Management Method, 1990-1993.
-24-
-------
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanides
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
• 1990
• 1991
• 1992
EH 1993
500 1,000 1,500
Millions of Pounds
2,000
Figure 8. Total Production Wastes for 33/50 Program Chemicals, by Chemical, 1990-1993.
-25-
-------
Table 11. Number of Forms Reporting Source Reduction, by Source Reduction Category, by
Chemical, 1991.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Forms Reporting Source
Reduction Activities
Number of
TRI Forms
480
99
183
1,258
2,499
1,015
558
3,794
3,563
697
3,639
210
2,867
308
1,739
54
2,218
25,181
57,112
82,293
Number
155
28
67
517
958
382
210
1,475
1,590
290
1,341
59
578
91
480
12
364
8,597
12,784
21,381
Percent of
All Forms
32.3
28.3
36.6
41.1
38.3
37.6
37.6
38.9
44.6
41.6
36.9
28.1
20.2
29.5
27.6
22.2
16.4
34.1
22.4
26.0
Table 12. Methods Used to Identify Source Reduction Activity, by Chemical, 1991.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Chromium and
chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and
mercury compounds
Nickel and nickel compounds
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Number of
Forms Reporting
Source Reduction
Activities
155
28
67
517
958
382
210
1,475
1,590
290
1,341
59
578
79
480
12
364
8,585
12,796
21,381
Pollution Prevention
Opportunity Audit
Internal External
71
10
28
194
350
149
93
512
680
120
529
21
212
35
183
5
138
3,330
4,878
8,208
16
0
1
20
45
19
14
76
87
9
62
3
24
6
31
2
13
428
556
984
Materials
Balance
Audit
14
4
8
82
131
53
23
178
197
37
149
9
75
12
54
1
57
1,084
1,549
2,633
Participative
Team
Management
37
13
36
214
456
183
96
650
690
120
573
29
253
41
223
4
169
3,787
5,793
9,580
Employee
Recommendation
Formal
Informal Program
19
7
7
96
206
76
39
289
306
68
290
15
110
14
101
2
85
1,730
2,590
4,320
14
6
8
50
98
45
19
143
212
28
115
9
47
7
50
3
30
884
1,288
2,172
-26-
-------
Table 11. Number of Forms Reporting Source Reduction, by Source Reduction Category, by
Chemical, 1991, Continued.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylenes
Cadmium and cadmium compounds
Chromium and chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury and mercury compounds
Nickel and nickel compounds
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
Category of Source Reduction Activity (number of forms reporting)
Good
Operating
Practices
47
17
21
202
433
189
117
620
678
132
562
29
263
30
222
3
192
3,757
6,209
9,966
Inventory
Control
5
0
0
31
184
64
17
243
106
18
221
4
64
11
41
0
39
1,048
1,562
2,610
Spill
and Leak
Prevention
121
17
13
109
187
101
61
328
192
44
338
14
112
21
91
1
86
1,836
4,235
6,071
Raw
Material
Modifi-
cations
10
2
30
138
265
90
25
420
304
16
300
26
133
16
156
2
48
1,981
2,113
4,094
Process
Modifi-
cations
98
14
53
153
267
141
45
463
302
71
450
23
252
51
199
7
195
2,784
5,246
8,030
Cleaning
and
Degreasing
1
0
2
152
134
42
88
157
812
168
112
8
49
14
12
0
42
1,793
1,300
3,093
Surface
Preparation
and
Finishing
0
1
0
22
296
125
4
401
119
6
485
0
38
2
16
0
9
1,524
787
2,311
Product
Modifi-
cations
4
0
3
51
106
53
7
173
138
9
145
11
60
2
79
2
30
873
925
1,798
Table 12. Methods Used to Identify Source Reduction Activity, by Chemical, 1991, Continued.
Chemical
Benzene
Carbon tetrachloride
Chloroform
Dichloromethane
Methyl ethyl ketone
Methyl isobutyl ketone
Tetrachloroethylene
Toluene
1,1,1 -Trichloroethane
Trichloroethylene
Xylenes
Cadmium and
cadmium compounds
Chromium and
chromium compounds
Cyanide compounds
Lead and lead compounds
Mercury amd
mercury compounds
Nickel and nickel compounds
Total for 33/50 Chemicals
Total less 33/50 Chemicals
Total for All TRI Chemicals
State
Program
3
0
0
6
11
11
2
23
21
6
21
1
7
1
8
0
5
126
124
250
Federal
Program
1
0
0
4
5
3
1
8
13
1
4
0
4
1
0
0
0
45
45
90
Trade/
Industry
Program
7
0
10
26
81
35
21
110
111
11
99
3
45
4
31
1
21
616
775
1,391
Vendor
Assistance
17
3
7
117
299
107
49
466
443
76
458
17
132
19
90
2
77
2,379
2,532
4,911
Other
57
5
18
104
145
68
37
271
197
51
243
10
110
21
124
3
62
1,526
2,349
3,875
Number
of Forms
256
48
123
913
1,827
749
394
2,726
2,957
527
2,543
117
1,019
161
895
23
657
15,935
22,479
38,414
Percent
of Total
Forms
0.7
0.1
0.3
2.4
4.8
1.9
1.0
7.1
7.7
1.4
6.6
0.3
2.7
0.4
2.3
0.1
1.7
41.5
58.5
100.0
-27-
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university, and other pollution prevention programs across the country. For example, the
guide contains a complete listing of state and university programs that offer technical
assistance on pollution prevention and waste minimization to businesses and industry.
Copies of this guide may be obtained by calling EPA's Clearinghouse at (703) 821-4800.
Industry-Specific Pollution Prevention Guidance Manuals
The Pollution Prevention Research Branch of EPA's Office of Research and Develop-
ment is publishing a series of industry-specific Guides to Pollution Prevention. Sixteen
manuals have been published to date, and two additional manuals are scheduled for
publication late this year. The manuals supplement EPA's generic waste reduction manual,
the Facility Pollution Prevention Guide. The industry-specific manuals and the generic
manual are available by calling the Clearinghouse at (703) 821-4800, or by calling EPA's
Center for Environmental Research Information in Cincinnati, OH, at (513) 569-7562. A
complete list of these guidance manuals, as well as many other pollution prevention
manuals, appears in Section 1 of the 7993 Reference Guide to Pollution Prevention
Resources.
Identifying Research Needs and Documenting Pollution Prevention Successes
EPA is identifying areas where new research efforts could lead to beneficial and
readily transferable pollution prevention results. In addition, EPA is identifying successful and
innovative pollution prevention practices that companies have implemented as part of the
33/50 Program, and sharing this information with others. Companies who are aware of
pollution prevention needs, or that would like to share their pollution prevention successes
with others, are encouraged to contact the 33/50 Program at (202) 260-6907, or leave an
electronic message on the PIES system.
A summary of research opportunities related to the 17 targeted chemicals of the
33/50 Program was published this year by EPA's Risk Reduction Engineering Laboratory in
Cincinnati, OH. The document, Opportunities for Pollution Prevention Research to Support
the 33/50 Program, can be obtained by calling the Clearinghouse at (703) 821-4800.
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LOOKING TO THE FUTURE: AN AGENDA FOR ACTION
The 33/50 Program faces an ambitious agenda as it matures. Despite the evidence
that the Program's 1992 interim 33% reduction goal has been achieved a year early, efforts
to expand company participation will continue. In addition to the reduction goals, the
33/50 Program strives to promote the benefits of pollution prevention as widely as possible
throughout American industry. Accordingly, industry trade associations are being asked to
assist EPA in convincing smaller companies to participate. The Program's communications
with all companies include challenges to exceed their initial goals and stress the concept of
continuous improvement.
Increasing attention is also being directed toward recognizing companies' environ-
mental improvements. The Agency is following up on the Program's popular Certificates of
Appreciation (sent to all Program participants) by recognizing companies when they
achieve their reduction goals. More than 200 companies have already achieved some or
all of the 33/50 Program reduction targets. EPA also is planning to conduct a national 33/50
Program conference in Spring of 1994 to showcase the accomplishments of the Program's
company, state, and community partners.
Finally, preparations are underway to commence evaluating the Program's success
formally by using the expanded pollution prevention data reported in facilities' 1991 and
subsequent TRI reports. As detailed in the preceding pages, the 1991 TRI data suggest
exciting developments to date. However, important issues remain that require in-depth
analysis, including assessing the actual role played by the 33/50 Program in bringing about
reported reductions in facilities' releases and transfers of the target chemicals. The new TRI
data provide profiles of facilities' waste management patterns that will be useful in analyz-
ing these and other issues.
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33/50 PROGRAM FOURTH PROGRESS UPDATE-APPENDIX A
NEW FORM R INFORMATION REQUIRED
BY THE POLLUTION PREVENTION ACT (PPA) OF 1990
BEGINNING WITH THE 1991 REPORTING YEAR
Beginning with the 1991 reporting year, new information required by the Pollution
Prevention Act (PPA) of 1990 on the prevention and management of toxic chemicals in
wastes will be reported on Form R, the TRI Reporting Form. This new information gives, for
the first time, a comprehensive look at the quantities of TRI chemicals in wastes, an indica-
tion of how those quantities are managed, and an indication of what efforts are being
made to reduce or eliminate those quantities. This information expands the data collected
under TRI, beyond on-site releases and off-site transfers for treatment and disposal, to
include on-site recycling, energy recovery, and treatment, as well as off-site transfers to
recycling and energy recovery facilities. It also provides a baseline for assessing progress in
the prevention of quantities of toxic chemicals from entering wastes as well as for assessing
the management of toxic chemicals that enter wastes.
Some of this information, such as the quantities released and the quantities sent off-
site for treatment or disposal (including quantities released or transferred off-site due to
catastrophic events), has been reported before 1991. The remainder of the information is
completely new to Form R reporting. Still, other data that have been reported prior to 1991,
such as the quantities released and the quantities sent off-site for treatment, are now
aggregated and reported in a new and additional way. To assist readers in learning what
this new information is, what it means, and how it relates to the information that has been
collected in the past, a copy of the 1991 Form R has been included at the end of this
appendix, along with a section-by-section annotation of differences between the Form R's
for 1990 and 1991 (Figure A-3).
The following quantities of toxic chemicals in wastes are now required in Section 8 of
EPA's Form R to meet the requirements of section 6607(b) of the PPA:
• quantity released at the facility and disposed off-site;
• quantity used for energy recovery at the facility;
• quantity used for energy recovery off-site;
• quantity recycled at the facility;
• quantity recycled off-site;
• quantity treated at the facility;
• quantity treated off-site; and
• quantity released or transferred off-site due to catastrophic events or
remedial actions.
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In addition to the quantities listed above, facilities are required to provide an indica-
tion of production or activity modification at the facility to help assess changes in the quan-
tities of toxic chemicals in wastes relative to changes in production. Facilities also indicate
any source reduction activities they have implemented to reduce or eliminate quantities of
the reported toxic chemical in wastes and describe the methods they employ to identify
source reduction opportunities. A discussion of each of these data elements is presented
later in this document.
These new data categories required by the PPA provide important information to the
EPA, the public and the reporting facilities themselves. In addition, this new information can
help assess movement in the waste management hierarchy, established in the PPA as
national policy:
• pollution should be prevented at the source whenever feasible;
• pollution that cannot be prevented should be recycled in an
environmentally safe manner whenever feasible;
• pollution that cannot be prevented or recycled should be treated in an
environmentally safe manner whenever feasible; and
• disposal or other release into the environment should be employed only as
a last resort and should be conducted in an environmentally safe manner.
POLLUTION PREVENTION CHOICES
source
reduction
should be the
first choice.
SOURCE
REDUCTION
If source reduction is not possible,
recycling is the next best option.
RECYCLING
if recycling is not possible, energy recovery
is the next best option (where applicable).
ENERGY
RECOVERY
If energy recovery fs not possible, treatment is the next best option.
TREATMENT
If treatment is not possible, disposal is used as a last resort. DISPOSAL
Figure A-1. Waste Management Hierarchy.
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The decision-making process that should be used when determining how to prevent
and manage toxic chemicals in wastes is illustrated in Figure A-l.
In separate items of Section 8, the new Form R requires the reporting of chemical
quantities contained in wastes that are generated at a facility through production-related
activities and non-routine activities (i.e. spills or other catastrophic events). The quantities of
the toxic chemical contained in production-related wastes are to be reported for the
reporting year, the year prior to and the two years following the current reporting year.
Since 1991 was the first year for which this new Section 8 information was required, the PPA
did not require facilities to report quantities for 1990 when they did not have adequate
information to make a reasonable estimate. As a result, information for 1990 may not be
available to make comparisons across the four years reported. It should be noted that the
quantities reported for 1992 and 1993, the two years following the reporting year, are
projections only and not commitments that facilities reporting under TRI are required to
meet. The intent of requiring this information is to encourage facilities to implement source
reduction activities and move up the waste management hierarchy.
DATA REQUIRED BY THE POLLUTION PREVENTION ACT
To better understand the new information required by the PPA, a description for
each of the new data categories is presented below.
What is Pollution Prevention?
Through pollution prevention, risks to people and the environment can
be reduced, financial and natural resources can be saved that would
otherwise have to be expended on environmental cleanup or pollution
control, and industrial processes can become more efficient. Pollution pre-
vention is source reduction, which is defined in the PPA as any practice that:
• reduces the amount of any hazardous substance, pollutant, or contami-
nant entering any waste stream or otherwise released into the
environment (including fugitive emissions); and
• reduces the hazards to public health and the environment associated
with the release of such substances, pollutants, or contaminants.
Pollution prevention practices can include equipment process, pro-
cedure, or technology modifications, reformulation or redesign of products,
substitution of raw materials, and improvements in maintenance and inven-
tory controls. Under this definition, waste management activities, including
recycling, treatment, and disposal are not considered forms of pollution
prevention.
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Quantity released (Section 8.1 of Form R). This is the total quantity that was released
to the environment at the facility (directly discharged to air, land, and water, and injected
underground) and sent off-site for the purposes of disposal. Because this quantity includes
amounts disposed off-site, it differs from the total releases to the environment that facilities
report in Section 5 of Form R.
Quantity used for energy recovery on-site (Section 8.2 of Form R). This is the quantity
that was actually combusted for the purposes of energy recovery on-site. The reported
toxic chemical has to have a heating value that is high enough to sustain combustion in
some form of energy recovery device, such as a furnace (including kilns) or a boiler. For
example, metals or metal compounds should not be reported as combusted for energy
recovery because the parent metals do not contribute any heating value to the wastes
being combusted. The parent metals would be discharged to air or remain in the ash,
which is usually disposed. The amount reported should represent the amount actually
destroyed in the combustion process, not the amount that entered the energy recovery
unit. For example, 100,000 pounds of toluene entered a boiler which, on average, com-
busted 98% of the toluene. The remaining toluene was discharged to air. A total of 98,000
pounds is reported as combusted for energy recovery, and the remaining 2,000 pounds is
reported as released to air.
Quantity used for energy recovery off-site (Section 8.3 of Form R). This is the quantity
that was sent off-site for the purposes of energy recovery. It is the quantity that left the
facility boundary, not the amount actually combusted at the off-site location. The toxic
chemical must have a significant heating value and the off-site location must have some
form of energy recovery unit in place. These quantities should also have been reported in
Section 6 of Form R as off-site transfers, along with the receiving facility's name and
location.
Quantity recycled on-site (Section 8.4 of Form R). This is the quantity that was
recovered and made available for further use at the facility. It is not the quantity that
entered a recycling or recovery operation. This quantity may be greater than the actual
amount of the toxic chemical managed at the facility, depending on how the facility
reported. For example, a facility used a total of 15,000 pounds of 1,1,1-trichloroethane for
cleaning and other purposes during the reporting year. The toxic chemical was recycled in
batches for a total of 15 batches, resulting in 225,000 pounds of 1,1,1-trichloroethane
recycled during that year. This quantity is much greater than the amount of the toxic
chemical that was actually used at the facility, but reflects the amounts of 1,1,1-trichloro-
ethane in wastes that were managed at the facility during the reporting year. However,
not all facilities have reported in this manner.
Quantity recycled off-site (Section 8.5 of Form R). This is the quantity that was sent
off-site for the purposes of recycling. It is the quantity that left the facility boundary, not the
amount actually recovered at the off-site location. These quantities should also have been
reported in Section 6 of Form R as off-site transfers, along with the receiving facility's name
and location.
Quantity treated on-site (Section 8.6 of Form R). This is the quantity that was
destroyed in on-site waste treatment operations, not the amount that entered any treat-
ment operation. If 100,000 pounds of benzene were combusted in an incinerator that
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destroyed 99% of the benzene, the facility would have reported 99,000 pounds as treated
on-site. If the remaining 1,000 pounds were released through a stack, the 1,000 pounds
would have been reported as a quantity released (Section 8.1). For this data element,
"destroyed" means that the chemical no longer exists in its reportable form. For example,
reduction of a certain quantity of hexavalent chromium to trivalent chromium would not be
reported as a quantity treated because the chromium was not destroyed and was still in its
reportable form.
Quantity treated off-site (Section 8.7 of Form R). This is the quantity that was sent to
publicly owned treatment works (POTWs) and other off-site treatment locations. It is the
quantity that left the facility boundary, not the amount actually treated at the off-site
locations. Quantities included here should also be reported in Section 6 of Form R.
Data users should be aware that off-site locations can have varying levels of treat-
ment capabilities, which means that a toxic chemical sent to a POTW or another off-site
location may or may not have been treated in the sense that the chemical was destroyed
and not released to the environment.
For example, metals and certain organic chemicals may have been "passed
through" a POTW, meaning that they were discharged directly from the POTW. Metals may
also have been contained in the sludges from POTWs, which were disposed of on land. As
a result, quantities may have been reported as treated when they were ultimately released
to the environment. This could also have occurred at other off-site locations in that the
toxic chemical in wastes may have been treated and then disposed. In situations where
the toxic chemical was stabilized and/or solidified, this is almost always a treatment step
prior to disposal, usually in a landfill.
Quantity released to the environment due to one-time events (Section 8.8 of Form R).
This is the quantity that was released to the environment or sent off-site for recycling, energy
recovery, treatment, or disposal due to one-time events not associated with routine pro-
duction practices. Such events include catastrophic events, such as accidental releases,
and remedial actions. This quantity is separate from the quantities recycled, used for
energy recovery, treated and released, to allow distinctions to be made between those
quantities that are routinely associated with production operations and are more amen-
able to source reduction and those quantities that are not routinely associated with
production processes and are not as amenable to source reduction since they are not
readily anticipated. This separation of quantities is important in assessing progress in source
reduction at facilities.
An important consideration when looking at and using these data is that the indi-
vidual quantities are intended to be mutually exclusive of each other in order to avoid
double-counting. This is important because the sum of the quantities reported as recycled
(on- and off-site), used for energy recovery (on- and off-site), treated (on- and off-site) and
released, provides the total production-related quantity of the toxic chemical in wastes
that a facility must manage in that year.
-A5-
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ASSESSMENT OF PROGRESS IN SOURCE REDUCTION
Quantifying progress in waste reduction is a complex question that cannot be
answered by simply comparing quantities over time. Many factors affect the quantity of
toxic chemicals in wastes. One such factor is changes in production or activity at a facility.
For this reason, the Pollution Prevention Act requires facilities to provide on Form R (Section
8.9) a production ratio or activity index as an indicator of whether production or activity
involving the reported toxic chemical has increased, decreased, or remained steady from
the prior year to the current reporting year. For the 1991 reporting year, the ratio is calcu-
lated by dividing the production or activity involving the reported toxic chemical in 1991 by
the production or activity involving the reported toxic chemical in 1990. A ratio that is less
than 1.0 indicates that production or activity is down in 1991 as compared to 1990. A ratio
of 1.0 indicates that production or activity has remained steady. A ratio greater than 1.0
indicates that production or activity has increased. While the information reported on Form
R can be used to estimate changes in the quantities of toxic chemicals in wastes relative to
changes in production or activity, an accurate assessment of source reduction progress
would require more detailed information than is currently included on Form R. This and
other issues associated with the new information required on Form R are discussed later in
this document.
WHAT IS BEING DONE TO REDUCE THESE WASTES?
As previously mentioned, facilities are required to provide information on any source
reduction activity implemented during the reporting (calendar) year. Source reduction
activities are those that reduced or prevented a quantity of the reported toxic chemical
from being recycled, combusted for energy recovery, treated, or released (including
disposal).
The categories or types of source reduction activities that can be reported are:
• Good operating practices • Process modifications
• Inventory control • Cleaning and degreasing
• Spill and leak prevention • Surface preparation and finishing
• Raw material modifications • Product modifications
For each of these categories, there are more detailed activities reported on Form R
using specific codes. For example, raw material modifications include increasing the purity
of raw materials, substitution of raw materials, and "other" raw material modifications.
The revised Form R also requires that facilities indicate the method(s) used to identify
the reported source reduction activity. These methods include the following:
• Internal pollution prevention opportunity audit(s)
• External pollution prevention opportunity audit(s)
• Materials balance audits
• Participative team management
• Employee recommendation (independent of a formal company program)
-A6-
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• Employee recommendation (under a formal company program)
• State government technical assistance program
• Federal government technical assistance program
• Trade association/industry technical assistance program
• Vendor assistance
• Other
ISSUES ASSOCIATED WITH NEW FORM R REPORTING REQUIREMENTS
As with the first year of data collection under TRI (1987), EPA recognizes that the
quality of the data required by the PPA and reported for the first time under TRI in 1991 is
questionable. Just as the TRI program has developed over time since 1987, the issues and
problems associated with the collection of these additional data will be resolved with the
help of the public. EPA is currently providing as much guidance as possible through training
courses and workshops held across the country.
From analyses performed for the 1991 TRI Data Release, four of the top twenty-five
chemicals reported as treated on-site are metal compounds: zinc, copper, lead, and
chromium. Because the amounts reported should reflect only the parent metal portion of
the metal compound and because the parent metals are not destroyed in on-site treat-
ment, the metal compounds should not be reported as treated on-site. If a facility
interprets the quantity treated on-site to represent the amount of the toxic chemical
removed from wastes and not the amount of toxic chemical in wastes destroyed, the
facility may double-count the amount of toxic chemical in wastes and incorrectly
categorize the ultimate disposition of the toxic chemical in wastes. Quantities of metals
undergoing on-site treatment are not destroyed, but are either released on-site or
transferred off-site, and should be reported as such. If a facility reports a metal as both
treated on-site and released or disposed, this results in the double-counting of the quantity
of the metal in waste. Because of this problem, metals should not be reported as treated
on-site. Metals can, however, be reported as sent off-site for treatment. This is acceptable,
because facilities are only required to report the ultimate known disposition of toxic
chemicals transferred off-site and because quantities reported as treated off-site represent
the quantities leaving the facility for the purposes of treatment, not the amount actually
destroyed off-site. However, it should be realized that parent metals sent off-site for
treatment will not be destroyed and will ultimately be released or disposed to the
environment.
Further complicating this is the issue of how to report a quantity that is treated and
subsequently disposed. In reporting transfers off-site, facilities should report the ultimate
known disposition of the toxic chemical. In a situation where a metal is sent off-site and
stabilized prior to disposal in a landfill, the quantity of the metal sent off-site should be
reported as disposed, not treated, off-site in both Sections 6 and 8 of Form R. There may,
however, be situations where the facility transfers the toxic chemical off-site and does not
know that it is being landfilled or where it is being landfilled and the only information avail-
able to the facility is the treatment prior to disposal. While the quantity can be reported as
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a quantity treated off-site, this makes it difficult to clearly categorize or assess the difference
between the treatment and release/disposal categories of the waste management
hierarchy.
The new information reported on Form R may not match exactly the release and
transfer information in Sections 5 and 6 that has been collected since the inception of the
TRI program (see Figure A-2). In some cases, information on the quantities of toxic chemi-
cals transferred off-site as reported in Section 6 does not match with the new information;
some facilities have reported quantities as sent off-site but did not provide a code indi-
cating the activity to which the quantity was subject (recycle, energy recovery, treatment,
or disposal). Some facilities reported quantities sent off-site, but provided codes that are
not in the instructions for Form R; these codes cannot be assigned to any particular off-site
activity and, along with the quantities that have no codes, are identified as "other" off-site
activities.
Even with the use of valid codes, however, there still may exist some discrepancies.
For example, the quantity released (including disposal) as reported in Section 8.1 of Form R
may not equal the sum of the quantities reported as released on-site and the amounts
reported as sent off-site for disposal (reported in Sections 5 and 6 respectively). EPA
believes that this is a problem in relating the data that should be reported in different
sections of Form R that will be reduced over time.
The largest discrepancy in the new information is the difference between what is
reported as recycled off-site in Section 8 and what is reported as sent off-site for recycling in
Section 6. This discrepancy may be due to factors beyond just relating the data reported in
different sections of Form R. Facilities may have interpreted what was to be reported as
recycled off-site for the new information (Section 8) differently from what was to be
reported as sent off-site as a transfer in wastes (Section 6.2).
To resolve these and other complex outstanding issues, EPA has initiated a public
dialogue process, in which members of environmental groups, industry, States, and aca-
demia are being brought together. The representatives of these groups will discuss the
issues associated with reporting this new information and provide EPA with advice and
recommendations as to how to resolve them. This process will insure that the intent of the
PPA is met and that the users of TRI data are provided with meaningful information on the
management of toxic chemicals in wastes.
-A8-
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1991 Form R
On-site Releases
(Section 5)
On-site
Releases
3,386 million
824 million
1991 Form R
Source Reduction and
Recycling Information
(Section 8)
On-site Releases
and Off-site Disposal
3,771 million
846 million
On-site
Energy Recovery
3,187 million
770 million
Off-site
Energy Recovery
498 million
241 million
On-site
recycling
16,379 million
4,267 million
Off-site
Recycling
3,262 million
638 million
On-site
Treatment
9,783 million
574 million
Off-site
Treatment
874 million
77 million
Non-Production
Related Releases
31 million
4 million
1991 Form R
Off-site Transfers
(Section 6)
Off-site
Disposal
299 million
45 million
Off-site
Energy Recovery
438 million
276 million
Off-site
Recycling
2,354 million
523 million
Off-site
Treatment
352 million
92 million
POTWs
412 million
77 million
Other Off-site
Waste Management
10 million
2 million
Figure A-2. Relationship of Data from Various Form R Sections (all TRI chemicals; 33/50 chemicals;
amounts in pounds).
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1990 Form R
Parti
Sections 1-4
Facility
Identification
1991 Form R
Parti
Minor
Reorganization
Part II
Part II
Sections 1 and 2
POTW and Other
Off-site Location
Identification
Now part of Part II.
Section 6.1 and 6.2
Chemical-Specific
Information
(see below)
Part III
Chemical-Specific Information
Part III
Chemical Specific Information
Sections 1. 2. 3. and 4
Chemical and Mixture-
Component Identity, Activities
and Uses of the Chemical,
and Maximum Amount On-site
Section 5
Releases of the Chemical
to the Environment On-Site
Section 6.1
Transfers to POTWs
Section 6.2
Transfers to Other Off-site Locations
for Treatment or Disposal
Section 7
Waste Treatment Methods
and Efficiency
No Corresponding Element
in 1990 Form R
Section 8
Pollution Prevention Optional
Information on Waste Minimization
(see next page)
Sections 1.2.3. and 4
No Change
Section 5
No Change
Section 6.1
Amounts sent to POTWs
now aggregated into one number
Section 6.2
Transfers to Other Off-site Locations
for Treatment, Disposal, Energy
Recovery, or Recycling
(new)
Section 7A
Reorganized
Section 7B
On-site Energy Recovery Processes
and
Section 7C
On-site Recycling Processes
New
Section 8
Mandatory Source Reduction and
Recycling Activities
(see next page)
Figure A-3. Relationship of 1990 and 1991 Form R's.
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1990 Form R
Part III (continued)
Section 8 — Optional
1991 Form R
Part III (continued)
Section 8 — Mandatory
Section 8A
Type of Pollution Prevention
Modification
Section 8B
Quantity of the Chemical in Wastes
Prior to Treatment or Disposal
No Corresponding Element
in 1990 Form R
Section 8C
Index
Section 8D
Reason for Action
No Corresponding Element
in 1990 Form R
No Corresponding Element
in 1991 FormR
Section 8.1
Quantity Released
Section 8.2
Quantity Used for
Energy Recovery On-site
Section 8.3
Quantity Used for
Energy Recovery Off-site
Section 8.4
Quantity Recycled On-site
Section 8.5
Quantity Recycled Off-site
Section 8.6
Quantity Treated On-site
Section 8.7
Quantity Treated Off-site
Section 8.8
Quantity Released to the Environment
as a Result of Remedial Actions,
Catastrophic Events, or
One-Time Events Not Associated with
Production Processes
Section 8.9
Quantity Production Ratio or
Activity Index
No Corresponding Element
in 1991 FormR
Section 8.10
Source Reduction Activities and
Methods to Identify Activity
-AH-
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(IMPORTANT: Type or print; read Instructions before completing form)
Form Approved OMB Number: 2070-0093
Approval Expires: 11/92 Page 1 of 9
United States
Environmental Protection
Agency
FORM R
TOXIC CHEMICAL RELEASE
INVENTORY REPORTING FORM
Section 313 ot the Emergency Planning and Community Right-to-Know Act of 1986,
also Known as Title III of the Superfund Amendments and Reauthorizatton Act
TRI FACILITY ID NUMBER
Toxb Chwrical. Category, or Q*n«ric Nwm
WHFRF Tft <*FNn 1- EPCRA Reporting Center i 1 2. APPROPRIATE STATE OFFICE
rrtMDI PTPn PARMQ. P-0. Box 23779 ^ (See instructions in Appendix F)
UJMKLtltUI-UHMb. Washington, DC 20026-3779 TT=T
ATTN: TOXIC CHEMICAL RELEA^P^TVENTORY
IMPORTANT: See instructions to determine_3rfjien "Not
Applicable (NA)" boxes shouldbe checked.
Enter "X" here «
this is a revision
For EPA uu only
PART 1. FACILITY IDS&IFI CATION INFORMATION
/x\
SEC
REPC
Y
n »/
Timj1 SECTION 2. TRADE^PRET
>RTING 2.1
EAR g|; ;.
19 Si
SS
Are you claiming tr^e/xic che
DYes (Answer question 2.2
Attach substapCSEpn form
f*f~\
If yes in 2.1 , is thi^Sepv:
LULJ
INFORMATION
mical identified on page 3
>; No (Uonotar
^5^"
t~~-i
Sanitize^ •*"
Q^
trade secret?
swer 2.2;
3)
Unsanitized
SECTION 3. CERTIFICATION (Important^gad and sign after corseting all form sections.)
I hereby certify that I hailTreviewed the attached d&Djbnts and that, to the be^ of my knowledge and belief, the
submitted information is frujaland complete and thawBa amounts and values in |MfflJreport are accurate based on
reasonable estimates using aaia available to the prepa^£pf this report.
Name and official title of owner/operatowx: sen
/«s
Signature
\^
kx management official |
^=u
^
0
DateSigrMK
S^
•_ _j r^**1
SECTION 4. FACIL|-?SbENTIFICATION §£) E=2
i"-"1
\ 4,1
\
Facility or Establishment Name
Street Address
City |
Slate |
Ln/y
(g)
sn ^
55J
={] 2*
=
Mailing Address (if different from street address) | <^-\
©
c"y I
Slate j
Zip Code |
TRI Facility ID Number)
unty |
Code |
PUT LABEL HERE
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
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Page 2 of 9
^ CDA EPA FORM R
united states PARTI. FACILITY IDENTIFICATION
E_nta, Protean |NFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical Category, or Generic Name
SECTION 4. FACILITY IDENTIFICATION ftleritinued)
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
This report contains
(Important: check <
Technical Contact
Public Contact
SIC Code
(4-digit) ^
§§)
Latitude c^pegr«
«JI1U r**^
Longitude 5J2
Dun & Brad-sVeet h
EPA Identification
Facility NPIg| Per
§
nformation for. ^ ^ eptire facj|jty b p^ Qf fl facj|jty
Name
^TJ
Name /f*^)
^1
b. /?^te. d. ^^
Telephone Number (include area code)
Telephone Number (include area code)
e. f.
Latitude ^^ ^^ Longitude
>s Minutes ^/j ) Seconds Degreesfr^i
Lorj p
Minutes Seconds
Jumbcrfs) (9 diwlas) c^_i
^rj) L)y|J
Number(s) (RCRA I.D. No.) a
(12£haracters) "l/ll
mit Number(s) r—-, a 5H]
(9 characters) . c^)
1 ,-JUI ^~™
Underground Injection Weil CodejftflC) I.D. a.
Number(s)
(J^glf)
(g)
SECTION 5. PARENT COMPANY INFORIv&BQN
n
5.1
5.2
Name of Parent Company
DNA
^
^
Parent Company's Dun & Bradstreet Number /?^\
n NA (9 digits) ^^
EPA Form 9350-1 (Rev. S/14/92) - Previous editions are obsolete.
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Page 3 of 9
United States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION
TRI FACILITY ID NUMBER
Toxic Chamcal. Category, or Generic Name
QFPTinN 1 TOXIC CHEMICAL IDENTITY ^(Important: DO NOT complete this
SECTION 1 . TOXIC CHEMICAL IDEN ll I Y ^^a^ if you complete Section 2 below.)
1.1
1.2
•^
CAS Number (Important: Enter only one number exactly as it ^j»e^
rs on the Section 31 3 list, Enter category code if reporting a chemical category.)
•-ll
Toxic Chemical or Chemicat Category Name (Important: Enter-only.
nil
(3s
Generic Chemical Name (Important: Complete only If Part I, $B&
Frame exactly as it appears on the Section 31 3 list)
- -
n 2.1 is checked "yes." Generic Name must be structurally descriptive.)
SLJ
^r-^-^.s-M. « .«iwi-nr*iy>»sM
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Page 4 of 9
^EPA EPA FORM R
gJSSS, Protection PART II. CHEMICAL-SPECIFIC
Agency INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical, Category, of Genef c Name
SECTION 5. RELEASES OF THE TOXIC ggEMICAL TO THE ENVIRONMENT ON-SITE
m
5.1
5.2
5.3
^^^^^^^^^^^^^^^^^^^^^^^^^^%
Fugitive or non-point air
emissions
Stack or point air
emissions
ill
R?,
tt«T
f.;j||
tys. <
W%
1
Discharges to receiving ,- —
streamsf&j^y/ater bodies \£^
(enter orte-oame per box) ftfr
5.3.1 Stream offi&ater Body Name fmn
ft 'in
5.3.2 Stream oJ4Water Body Name /^
\{~j
5.3.3 Stream Cif-Water Body Name
+~m n
uU l—f
© ^
5.4
5.5
5.5.1
5.5.2
5.5.3
5.5.4
UndergcLSnd injections
on-site £jj3
Releases to land on-site
Landfill
Land treatment/
application farming
Surface impoundment
Other disposal
c=
NA
(nil
$
6s
, — i
^
^
)A. Total Release (pounds/
, year) (enter range code from
instructions or estimate)
B. Basis of
Estimate
(enter code)
r^?'- ;g'v$p'
&^
m
[r
Dvi
"m
©
&
^
C. % From
Stormwater
$fs?-
::Uv «
< •. f '•
Check here only if additional Section 5.3 information is provided on page 5 of this form.
EPA Form 9350-1 (Rev 5/14/92) - Previous editions are obsolete
Range Codes A = 1 -10 pounds, B = 11 - 499 pounds,
C = 500 - 999 pounds
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Paae 5 ol 9
wEPA EPA
United States PART II. CHI
B—nta, Protection |NFORMATH
TRIFACHITY IDNIIMHFB
L FORM R
rMICAL-SPECIFIC T«« «*-«-. C-W..G«.CN«,
ON (CONTINUED)
SECTION 5.3 ADDITIONAL INFORMATION!
ENVIRONMENT ON-SITE 2
5.3
5.3.
Discharges to receiving V^
streams or water bodies c=
(enter one name per box)
Stream or Water Body Name *-[
€
5.3._
Stream or Water Body Name ^1
5.3._
Stream ^f^ater Body Name (£
Jfe &
UpN RELEASES OF THE TOXIC CHEMICAL TO THE
;j
x
/k. Total Release (pounds/ B. Basis of c. % From
f] year) (enter range code from Estimate ' Storm water
TJ instructions or estimate) (enter code)
il
&
n
= ®)
^ 5^^
j — i 1 n 1 1 r i
SECTION 6. TRArfpfeRS OF THE TOXIC CHEMICAL IN WASTEsSS OFF-SITE LOCATIONS
*"IO| ^n Hnl
6.1 .A To
6.1 Dl^ffARpES TO PUBLIC^
1 — -I V»^
tal QuantUyl [Transferred to POTWjs
DOWNED TREATMENTJWORKS (POTW)
I _ _ I
jTind Basis of Estimatfjljij
6.1 .A.1 Total Transfers^pOLinds/year) 6.1. A.2 Basis of Estimate
(enter range co2Je"jr estimate) ^ f| (enter codejjjj]
© m ©
6.1. B POTW Nam«TJd Location Information c^p
6.1. B._
Street Address
POTW Namrf-| — ' p C
frir
J| HUlWNft^
•• b.i.b.
Ln/u
** — •
' Street Address
iy
City |
Stale |
County ^j [
{—^
c~^
Zip Code j —
1 -^£
| uty | Oouniy |
^ State | Zip Co*
?
_ 1 .
If additional pages of Part II, Sections SSLa-nd/or 6.1 are attached, indicate the total number of
and indicate which Part II, Sections 5.3/6.1 page this is, here. I
(example: 1,2,3, etc.)
pages in this box
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete
Range Codes. A = 1 -10 VJ.-K. 8 = 11 - 499 pounds
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Page 6 of 9
<&EPA
United States
Environmental Protection
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
Toxic Chemical. Category, or Generic Name
SECTION 6.2 TRANSFERS TO OTHER OFJ^ITE LOCATIONS
Off-site EPA Identification Number (RCRA ID No.}| t^-=
6.2..^.
Off-Site Location Name ]
Street Address j
City |
Stale |
={)
C^l
Zip Code 1
A. Total Trar^ef5(pound?/yeat) ;
1. ^
2. eg
3. tTnl
4.
V.V
t=
u u County
^S)
^ 1 s location under control of re
2, 1/acility or parent company?
B. Basis of Estimate
(enter code) y-n
• 'nviivf * f -^ $.\ •."•-. % s T _
EPA Fom 9350-1 (Rev. W-MK) • Previous edfons are obsolete.
Range Codes: A «1 -10 pounds; B »11 - 499 pounds;
C« 500-999 pounds.
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Page 7 of 9
Agency
EPA FORM R
protection PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
TRI FACILITY ID NUMBER
Toxic Chemical, Category, or Generic Name
L|J
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Page 8 of 9
^EPA
United States p A
Environmental Protection " ^
Agency (ty
TRI FACILITY ID NUMBER
EPA FORM R
RT II CHEMICAL-SPECIFIC T«««n«i.c-w,..Q«nBH«
FORMATION (CONTINUED)
g
SECTION 7B. ON-SITE ENERGY RECOVE^ffiPROCESSES
f~l Not Applicable (NA) - Check here if no on-site energy recovery is applied to any waste
stream contampr g the toxic chemical or chemical category.
Energy Recovery Methods [enter 3-character code(s)] (O)
•j
&
SECTION 7C. ONg|j§
2 g= 3 4
m ^
^ 1
o f^
E RECYCLING PROCESSES Hyjl
<-^
Q Not ApplicabteiNA) - Check here if no. on-site recycling is gPRlied to any waste
j£LI stream contamftig the toxic chemicalifUchemical category.
/
Recycling Methods [enter 3-cnwacti
1 '~~
6
»r code(s)] 5oj ^^
2 §^ 4 ^^ 5
m
7 ^3J 9 10
1
=a
EPA Form 9350-1 (Rev. 5/14/92) - Previous editions are obsolete.
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Page 9 of 9
&EPA
United States
Environmental Protection
Agency
EPA FORM R
PART II. CHEMICAL-SPECIFIC
INFORMATION (CONTINUED)
TRI FACILITY 10 NUMBER
Chemical. Category, or Generic Name
SECTION 8. SOURCE REDUCTION AND R^CLING ACTIVITIES
All quantity estimates can be reported
using up to two significant figures.
8.1
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
Quantity released *
Quantity used for energy
recovery on-site
Quantity used for energy
recovery off-site
Quantity recy
1
Quantity recy
^
i
Quantity treat
Quantity trea
5URf on-site
!J^?D
Et® off-site
£y
Kgfcn-site
td-off-^ite
Colunmx)
I99o-*^
(poundaQBao
^
©
22J
— i
5^3
^
fe
C\2J
frvfl
1
i
"1
i
— i
ie<
arl
Column D
1993
(pounds/year)
UW f
*V]
s — •
&
isc
^ this chem
W^riswer Sect
ical during
ion 8.11.
ITLTK
£- — i Methods to Identify Activity (enter codes)
a. © b.
a. ^ b.
|J
a. t^> b.
a. @) b.
c.
c.
c.
c.
Is additional optional information on source reduction, recycling, or
pollution control activities included with this report? (Check one box)
YES NO
* Report releases pursuant to EPCRA Section 329(8) including "any sp Iling, leaking, pumping, pour ng, emitting, emptying, discharging,
injecting, escaping, leaching, dumping, or disposing into the environment." Do not include any quantity treated on-site or off-site.
EPA Form 9350 -1 (Rev. 5/14/92) - Previous editions are obsolete.
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FOR MORE INFORMATION
Anyone interested in obtaining additional information about the 33/50 Program can
do so by calling EPA's TSCA Assistance Hotline at (202) 544-1404 Monday through Friday
between 8:30 a.m. and 5:00 p.m. EST. Or contact us directly at EPA headquarters at
(202) 260-6907 or by directing letters to Mail Code TS-799, Office of Pollution Prevention and
Toxics, U.S. EPA, 401 M Street, SW, Washington, DC 20460. Written communications from
companies are maintained in a publicly available 33/50 Program Administrative Record.
Copies of company communications and computer-generated lists of participating
companies are available upon request.
Information about the 33/50 Program can also be obtained from 33/50 Program
Coordinators in EPA's ten Regional offices:
Region I
33/50 Program Coordinator (MS: ATR)
US Environmental Protection Agency
Pesticides & Toxics Substances
1 Congress Street
Boston. MA 02203
Phone: (617)565-3230 Fax:(617)565-4939
Connecticut, Massachusetts, Maine, New Hampshire,
Rhode Island, Vermont
Region II
33/50 Program Coordinator (MS: 105)
US Environmental Protection Agency
Environmental Services Division
2890 Woodbridge Avenue, Building 10
Edison, NJ 08837-3679
Phone: (908)906-6890 Fax: (908)321-6788
New Jersey, New York, Puerto Rico, Virgin Islands
Region III
33/50 Program Coordinator (MS: 3AT01)
US Environmental Protection Agency
841 Chestnut Street
Philadelphia, PA 19107
Phone: (215)597-9302 Fax: (215)580-2011
Delaware, District of Columbia, Maryland, Pennsylvania,
Virginia, West Virginia
Region IV
33/50 Program Coordinator
US Environmental Protection Agency
Title III & Toxics Section
345 Courtland Street, NE
Atlanta, GA 30365
Phone: (404)347-1033 Fax: (404)347-1681
Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina South Carolina Tennessee
Region V
33/50 Program Coordinator (MS: SP-14J)
US Environmental Protection Agency
Pesticides & Toxic Substances Branch
77 West Jackson Blvd.
Chicago, IL 60604
Phone: (312)353-5907 Fax: (312)353-4342
Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin
Region VI
33/50 Program Coordinator (MS: 6T-PT)
US Environmental Protection Agency
1445 Ross Avenue
Dallas, TX 75202-2733
Phone (214) 655-7582 Fax: (214)655-2164
Arkansas, Louisiana, New Mexico, Oklahoma, Texas
Region VII
33/50 Program Coordinator (MS: ARTX)
US Environmental Protection Agency
Air & Toxics Division
726 Minnesota Avenue
Kansas City, KS 66101
Phone: (913)551-7600 Fax: (913)551-7065
Iowa, Kansas, Missouri, Nebraska
Region VIII
33/50 Program Coordinator (MS: 8ART-AP)
US Environmental Protection Agency
999 18th Street, Suite 600
Denver, CO 80202-2405
Phone: (303)294-7684 Fax: (303)293-1229
Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming
Region IX
33/50 Program Coordinator (MS: A-4-3)
US Environmental Protection Agency
75 Hawthorne Street
San Francisco, CA 94105
Phone: (415)744-1069 Fax: (415)744-1073
Arizona, California, Hawaii, Nevada, American Samoa,
Guam, Commonwealth of the Northern Mariana Islands
Region X
33/50 Program Coordinator (MS: AT-083)
US Environmental Protection Agency
Toxics Substances Section
12006th Avenue
Seattle, WA 98101
Phone: (206> 553-4762 Fax: (206) 553-8338
Alaska, Idaho, Oregon, Washington ,' -
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