EPA-230-09-89-066
    Risk  Communication
       about Chemicais
     in  Your Community
        A Manual for Local Officials
                December, 1989
      Prepared by Susan G. Madden and Barry V. Bales
        Lyndon B. Johnson School of Public Affairs
            The University of Texas at Austin

        under a cooperative research agreement with

       United States Environmental Protection Agency

               in cooperation with the

      Agency for Toxic Substances and Disease Registry,
Public Health Service, U.S. Department of Health and Human Services

    Federal Emergency Management Agency, Office of Training

       Research and Special Programs Administration,
            U.S. Department of Transportation
                    1989

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                 Table of Contents
Page

    1

    3
   11
    17
   33
   40
Topic

Introduction/Purpose

How to Use This Manual

Introduction to Title III

What is Risk?
    Commonly-Used Risk Descriptions
    Characteristics of Risk

First Scenario: An Unplanned Release of a Chemical
    Procedures with Hazardous Chemicals
    Steps in the Emergency Plan
    Where to Get Information
    Sample news release
    Characteristics of a Good Response

Second Scenario: Learning about Routine Releases
    Emissions, Concentration, and Exposure
    Determining Delayed Health Effects
    Communicating Long-Term Risks
    Enforcement and Citizen Involvement under Title III

Third Scenario: Storing Large Quantities
    Planning for Hazardous Chemical Emergencies
    Citizen Involvement in Community Risk Assessment

Conclusion/Summary
    Seven Cardinal Rules of Risk Communication
    Opportunity for Citizen Involvement
    Personal Action Plan

Appendices
    1. Glossary of Commonly Used Terms
    2. References and Sources
    3. Brief Description of Title  III by Section
    4. State Emergency Response Commission Title III Contacts
    5. List of Extremely Hazardous Substances
    6. Section 313 ToxicChemical List

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               Risk Communication  Resource  Sheet

1.    State Emergency Response Commission:
     Chairperson	Phone	
2.
Local Emergency Planning Committee:
Chairperson      	
Other Members 	
                                                  . Phone
                                                   Phone
                                                  _Phone_
                                                  Phone
3.
Emergency Plan:
Coordinator or Director of Emergency Management for our town/county:
                                	Phone	
     Designated contact for non-emergency personnel who have questions:
                                               	Phone	
4.   Who is authorized to direct citizens to evacuate or take other actions?
5.   What are the elements of our response plan?
6.   What are other resources (local, state, federal, university) on which I  can call
     in an emergency?
7.   Which  state agency/official receives reports  under section 313?
8.   Which  state agency/official receives reports  under section 312?

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Introduction
      &
  Purpose
           Purpose
         "STATE RATES HIGH IN CANCER RISK
              FROM FACILITY EMISSIONS"

           "PLANT CHEMICAL SPILL FORCES
               HUNDREDS TO EVACUATE"

Have you seen headlines like these recently?  Do they raise
questions in your mind?  If someone asked you about them,
could you answer the questions?

People are becoming more concerned about hazardous
materials in their communities and how these materials affect
their health and well being. Their concerns become most
pressing when there  is an accident or a leaking waste site is
discovered, but they are also concerned about hazardous
chemicals they are exposed to every day.  In response to these
concerns, local officials are increasingly called upon to respond
to questions about hazardous materials, including the risks they
pose and how to reduce those risks. For many local officials this
is a new role, one for which they may not be fully prepared.
This workshop manual will help you learn how to respond to
public questions about chemical risks. It also will help you find
additional assistance and information about hazardous
materials.

Recent federal legislation is likely to increase public awareness
and concern especially because of the Emergency Planning and
Community Right-to-Know Act, which is Title III of the 1986
amendments to the "Superfund" Act.

Title III is not a typical regulatory program; it is part of an
innovative approach to managing environmental risk.  It makes
a great deal of information available that has never been
provided before.  The information is available to everyone—to
the public and to governments at all levels—about the presence
of hazardous chemicals in the community, about accidental and
routine releases of these chemicals, and about their storage.
The more citizens know about chemical hazards in their
communities, the better equipped they and their local
governments will be to make decisions and to take actions that
will protect their families and neighbors from unacceptable risks.

                1

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           The new information available under Title III is often complex,
           and its application and interpretation requires work from all
           those involved.  It will cause citizens' existing concerns about
           hazardous chemicals to become more focused, and public
           officials will need to respond to these concerns. Title III
           establishes an ongoing forum at the local level for community
           discussion and action about hazardous chemicals. This forum
           is the Local Emergency Planning Committee, or LEPC.

           LEPC members may be called upon to  respond to public
           questions about the risks they are examining or to participate in
           public meetings about those risks—meetings where people will
           ask what the information means or about its significance for a
           particular person or segment of the community. If you are a
           member of the LEPC or participate in its work, you will be inter-
           acting with the community as you work to analyze and mitigate
           potential chemical hazards.  Since LEPC membership by law
           includes a variety of categories—emergency responders such
           as firefighters and police, health professionals, the media,
           industry representatives, transportation  representatives, and
           public interest groups—many different kinds of people with
           many different backgrounds will find themselves answering
           public questions. This manual is intended to help everyone who
           may have to answer questions develop  some useful strategies.
Preview   The manual begins with a brief overview of the law and local
           responsibilities.  To illustrate situations and suggest ways to
           respond, we will look at three kinds of incidents that cause
           citizens to seek out local officials.  We will begin with an
           accident, then expand our discussion to include more routine
           events. These are not the only circumstances under which
           citizens may seek out local officials and become  involved in
           considerations of risk in the community, but they illustrate ways
           in which public officials might interact with the public.

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How to Use
This Manual
        Objectives
    How the Manual
       is Organized
          Resource
              Guide
The manual can be used in three ways: first, as part of a work-
shop on answering citizen questions about hazardous
chemicals; second, as a stand-alone guide for local officials
unable to attend a workshop; and third, as a reference.

Reading or using the manual will help you:

  •Know what kinds of questions citizens are likely to ask
  —after an accident
  —after learning about routine releases
  —after learning that large quantities of substances are
  stored nearby.

  • Know the characteristics of a good answer to these
  questions.

  • Understand the kinds of information needed to answer the
  questions and where that information may be found.

  •Respond to the questions and identify some people in the
  community who can help answer them.

  • Identify opportunities for all sectors of the community to
   participate in decisionrnaking about potential risks from
   hazardous chemicals.
 The manual is written so that later topics build on material
 presented earlier. Those using the manual for self-study will
 need to identify the local and state resources described in this
 manual.

 This manual should be retained as a resource guide. The
 materials are arranged so that specific information can be found
 easily when needed. Specific times to review this manual would
 be when an accident or a spill happens, when companies
 submit their required Title III reports on hazardous chemicals, or
 when the public or the media has concerns or questions to be
 answered.

 Remember, there are many other resources available to help
 you respond to risk assessment questions and accidents, and
 the early identification of these resources will help you fulfill your
 official obligations in a safe and responsible manner.	•

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Introduction to
     Title III
 The Emergency Planning and Community Right to Know Act
 was included as the third part or title of the Superfund Amend-
 ments and Reauthorization Act of 1986.  For this reason, it is
 often called 'Title III." The law has four purposes (readers
 should not use the following brief descriptions as the basis for
 legal decisions about Title  III):
   (1) Emergency planning. Facilities that store or use any of
   the 366 Extremely Hazardous Substances in excess of the
   threshold planning quantity (TPQ) report this fact to the State
   Emergency Response Commission (SERC) and LEPC. The
   LEPC develops an emergency plan based on this and other
   information.
   (2) Emergency release  reporting.  Facilities must report to
   the SERC and LEPC accidental releases in amounts over a
   reportable quantity of the Extremely Hazardous Substances
   and Comprehensive Environmental Response,
   Compensation and Liability Act (CERCLA) hazardous
   substances (which must also be reported to the National
   Response Center).
  (3) Hazardous chemical reporting. Facilities where any
   hazardous chemicals are present in amounts over certain
   reporting thresholds (often 10,000 pounds) must submit
   Material Safety Data Sheets (MSDSs) or a list of chemicals
   for which MSDSs are required as  well as an annual chemical
   inventory form to the local fire department, LEPC, and SERC.
  (4) Creation of an emissions inventory. Manufacturing
   facilities that use any of a different list of about 300 chemicals
   in excess of reporting thresholds must report emissions to
   EPA and designated state agencies.

As indicated, different sections of the law apply to different
facilities and different chemicals.  Specific sections are listed in
Appendix 3.

In order for the law to work, industry, interested citizens,
environmental and other public-interest organizations, and
governments at all levels must work together to plan for
chemical accidents and to reduce the risk to the public from
releases of toxic chemicals into the environment. The law
represents a path-breaking approach to environmental
protection, because it assumes that the more citizens know
about chemical hazards in their communities, the better
equipped they and their communities will be to make decisions

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     Special
 Provisions
   for Local
Government
    Officials
and take actions to protect their families and neighbors from
risks they feel are unacceptable.

  Provisions of special concern to local officials include:

—The law required states to set up State Emergency Response
Commissions, or SERCs.

—SERCs were then required to establish local emergency
planning districts and Local Emergency Planning Committees,
or LEPCs.

—LEPCs must include among their members local elected
officials and staff with competence in health and emergency
response, industry representatives, media representatives, and
members of citizens groups.

—Facilities having more than certain quantities of any of the 366
Extremely Hazardous Substances must make themselves
known to SERCs and participate in the LEPC.

—As noted, facilities where hazardous chemicals are present in
certain quantities must submit MSDSs and inventories of the
chemicals to SERCs,  LEPCs and local fire departments. An
MSDS describes the physical and chemical properties of the
    substance as well  as its health effects, appropriate safety
    equipment, and emergency response measures.

  —LEPCs must make the chemical inventories and the MSDSs
    available to citizens who want to see them.

  —LEPCs must develop a plan for responding to and avoiding
    emergencies involving hazardous chemicals, drawing upon
    the chemical inventories and other information provided by
    facilities.

  —Manufacturers must report their annual emissions of certain
    toxic chemicals into the air, water, or land. The reports are
    sent to the federal Environmental Protection Agency (EPA)
    and to the designated state agencies. Citizens also have
    access to these reports.

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Defining Terms
                  The information now available to citizens under Title III is one of
                  the driving forces for citizen questions about hazardous
                  materials in the community. Sections below describe three
                  scenarios in which citizens have obtained Title III information.
Title III makes use of three terms that often seem similar.  They
                 are:
                       Toxic - substances that are poisonous or can cause
                       adverse health effects. These are the substances
                       emissions of which are reported under Section 313 of
                       Title III.
                       Hazardous - substances that are toxic, corrosive,
                       flammable, or explosive.  This is a general term, not
                       specific to Title III.
                       Extremely hazardous - a set of chemicals defined by
                       Title III as subject to reporting under Section 302,
                       because they could cause death or irreversible damage
                       after relatively short exposure to small amounts,
                       generally in air.
                 As you talk with citizens, it is important to remember that they
                 may not know the differences among these terms as well as you
                 do. Listen to understand what they mean instead of
                 concentrating on the particular terms they might use.


                 We know that citizens are often very concerned about toxic and
                 hazardous chemicals in all these categories. Title III offers an
                 important new step forward in allowing and encouraging
                 citizens,  working with government and industry, to participate in
                 managing these chemicals in their own communities.

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What is Risk?
      Common Risk
  Characterizations
   "Risk" is a word that is used often when people talk about
      hazardous chemicals in the community.

What is risk? A convenient definition is:

   The likelihood of injury, disease, or death.

Environmental  risk then refers to

   The likelihood of injury, disease, or death resulting from
   human exposure to a potential environmental hazard.

(In addition to human health, the environment itself may also be
at risk. We will not mention these risks below, but the
considerations are the same.)
Experts often use the definitions above. When experts are
asked to describe or characterize a risk, they use statements
like these:

  • There is a lifetime risk of 1 in 65 of dying in a motor vehicle
   accident.

  • The range of risks in humans is between 100 and 1000
   cancers per 1,000,000 people exposed.

  • The chance of getting this disease is 1 x 1Q-7 (1 10-millionth,
   or 1  in 10 million.)

  • The risk to children is  high relative to that for adults.

  • 25,000 people die each year from at-home injuries.

  • The risk of death from leukemia is 1  in 12,500 people per
    year.

  • The risk of cancer from indoor air is 600 times the risk from
    tap water.

  • An airplane crash involving 100 or more deaths is likely to
    occur once in two years.

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  • The risk to this neighborhood from chemical releases at
    Facility A is likely to be higher than the risk to a different
    neighborhood from releases at Facility A.

  • The risk of neighbors getting sick is higher with this waste
    disposal site here than it would be if the waste were not
    disposed here.

Experts tend to focus on the likelihood of a particular risk, but
non-experts tend to think of other characteristics of the risk.

For example, an industry representative at a public meeting
about a proposed new incinerator reported that a person who
spent her whole life downwind of the incinerator would incur a
risk that was smaller than the risk from dying her hair.  A
member of the audience stood up to say, "Yes, but I  choose to
dye my hair, while I don't choose to live downwind of the incin-
erator, and furthermore,  I get some benefit from dying my hair,
while I get none at all from the incinerator." This woman was
reacting to the involuntary nature of the risk and the perceived
balance between risks and benefits.
Table 1 on the next page illustrates some of the other features
of risk that make it seem "riskier" to most people and gives brief
examples.
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             Table 1: Characteristics of Risk
     (Factors on Right increase Perception of Riskiness)
   Voluntary
   Driving a car
   Natural           <-
   Radon in basement
   Familiar
   Household
   cleansers

   Chronic
   Routine small
   releases of chemicals
   from a facility

   Visible
   Benefits
   Dying hair

   Controlled by
   Individuals
   Driving

   Fair
Involuntary
Breathing air polluted
by a neighboring
factory

Man Made
Industrial
chemicals

Exotic
Genetically
engineered organism

Catastrophic
Large accidental
release of chlorine
gas from a plant

No Visible
Benefits
Incinerator effluents

Controlled by
Others
Industrial pollution

Unfair
The notion of "fairness" sums up many of the other aspects of
risk that make people feel special concern or "outrage."  If a
person or community feels that it is bearing a lot of risk while
someone else is getting most of the benefits, then the risk will
seem especially unacceptable.  Risk communicators must
understand these feelings, or they will not succeed in working
with the community to make good decisions about risk
reduction.

We also know that most people seek information about
hazardous chemicals only when something happens to make
them interested or cause them to believe that they are directly
affected.

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c
Scenario 1: Unplanned Release of a Chemical
      Questions citizens
               ask about
              hazardous
               materials
           We will use as examples three kinds of circumstances that may
           cause citizens to become concerned enough about hazardous
           chemicals in their communities to ask questions: during/after an
           incident, when they learn about routine releases, and when they
           learn about the many kinds of substances stored nearby.  Most
           questions will concern human health, but many citizens also will
           ask questions about environmental and other possible effects of
           chemical exposure or release. In addition to these substantive
           questions about health or the environment, citizens also ask
           many "procedural" questions about where they can obtain
           additional information, why it was so difficult to get answers to
           their questions, or how they can get involved in making sure
           risks are managed properly.

           Few public  officials will be able to answer all these questions.
           Some questions have no sure answers, and others can be
           answered only in light of the particular conditions prevailing in
          the community. However, this manual  is intended to help users
           understand the kinds of answers that are appropriate and find
          sources for the factual information that  is available. Keep these
          questions in mind as you think about the scenarios from the
          perspectives of government, industry, or citizen representatives
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          Scenario 1: Unplanned Release of a Chemical
Scenario 1
   Procedures with
        Hazardous
        Chemicals
Unplanned Release of a Chemical

  About 2:30 on a weekday afternoon you receive a telephone call from the
  Director of Emergency Managementtelling you thatachlorine tank in the
  basement of the local school has sprung a leak and that the gas, which
  is very dangerous, has entered the indoor swimming pool area and gym
  and is being sucked into the school's air circulation system. The tank has
  been removed from the basement to the open air and the leak is being
  repaired; emergency personnel are moving rapidly through the school
  to locate and rescue students and teachers; local hospitals have been
  notified; and vehicles are on their way to the school to transport anyone
  suffering impaired breathing.

  Within fifteen minutes, your telephone starts ringing with questions from
  frantic parents and the media. What should you say to them?  As an
  LEPC member, you would refer calls to the appropriate emergency
  response public contact. But what if you are that person? Or what if you
  have to answer "spillover" questions because you are on the LEPC or in
  another position in which people are likely to call you?
To answer people's questions, you must first know about the
plans and procedures for emergencies involving hazardous
chemicals.

1. SARA Title II! requires any facility that stores any of 366
Extremely Hazardous Substances in amounts greater than
specified Threshold Planning Quantities to notify the Local
Emergency Planning Committee (LEPC) and the SERC. (Many
of these substances are also covered by the annual toxic
chemical reporting requirements of Title III described above on
page 4.) A list of the Extremely Hazardous Substances
appears in Appendix 5.

2. The LEPC uses this information to plan for accident
prevention and for emergency response in case of an accident.
Individual facilities also should have their own emergency
response plans.

For some chemicals, including chlorine, there are professional
standards for the kinds of emergency warning systems and
emergency equipment that should be on hand.

3. The local emergency plan developed by the LEPC should:

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c
Scenario 1:  Unplanned Release of a Chemical
       Some Steps in the
         Emergency Plan
     Citizens' Questions
            • Designate a coordinator for emergencies—usually the
             Director of Emergency Management or someone in the Fire
             Department.  (Note that many states have rules about first
             responders that should have been considered as the plan
             was developed.)

            • Provide a means for notifying appropriate authorities.

            • Provide a means for emergency responders to obtain
             information about appropriate responses particular to
             specific chemicals involved in the incident (including needs
             for special equipment and clothing).

            • Identify sources of necessary equipment and trained
             personnel and describe procedures for bringing them to the
             site.

            • Specify the division of duties between the public and private
             sector response personnel. (Many companies insist on
             deploying their own specially-trained staff for accidents that
             do not cross the plant boundary, in part to  limit possible
             liability for damages to non-employee emergency
             responders).

          (Although cities or other jurisdictions smaller than the area
          covered by the LEPC could have their own plans, in this manual
          we focus on the LEPC plan.  The planning principles would be
          the same for the smaller jurisdictions.)

          In the chlorine spill, the plan has worked quite well. Authorities,
          including you, have been notified, equipment mobilized, and the
          problem treated.  Your callers ask:

          a. What's going on?
          b. Am I at risk?
          c. Should I evacuate?
          d. What are you doing to mitigate the consequences?

          Although citizens will call the elected official, he is not
          necessarily the best person to provide answers.  The person
          designated as emergency coordinator should in turn have
          designated a particular person or position in his office to be
          the contact for non-emergency personnel who have

                         12

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      Scenario 1: Unplanned Release of a Chemical
  Where to get
 Information to
  answer these
    questions.
Questions after
      the event
questions. This person's name and especially phone number
should be emphasized to the media before any accidents occur.
(Many facilities are designating a particular contact person and
inviting the media to meet with that person on an informal basis
independent of any particular events.  Public agencies could
adopt this approach, ensuring that the media are aware of
procedures and plans.)  The elected official should refer almost
all calls to the appropriate contact person, since during an
emergency, it is often  impossible to ensure that every office is
kept up to date on rapidly changing events.

Local officials should know about the system in place in their
own communities for emergency planning and response and be
prepared to talk about it with the public.  You should know the
answers to these questions:
    a. Who is the central contact person or where information
    will  be available?         . •     .
 ,   b. Which departments, programs, or offices are responsible
    for emergency response?
    c. Who has authority to direct citizens to evacuate or take
    other action?
    d. What is their relationship to the Local Emergency
    Planning Committee (LEPC)? Who is chairman of the LEPC
    and what is the role of the LEPC during an emergency?
    e. WJiat are other sources of information to answer citizens'
    questions?

In short, officials need to be familiar enough with local
procedures to be able to tell callers where to find the information
they need right away.   It is important to identify the LEPC and
local emergency coordinators in advance. (The State
Emergency Response Commission is a resource that should be
used during the planning period and not during an emergency -
see Appendix 4.)
Another series of questions will arise after the event. Among the
most likely to be asked are:
a. How did this happen?
b. How long will the "short-term" health effects (those that show
   up within a few weeks of the incident) continue to be felt?
c. Will we have other health effects that do not show up for a
   longtime?
d. What are you doing to prevent it from happening again?

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c
Scenario 1:  Unplanned Release of a Chemical
          Sample
       News Release
                               Of course, the answers differ for each incident.  [Appendix 2
                               lists some sources for information about specific chemicals.]  In
                               answering what is being done to prevent a similar accident from
                               occurring, officials may need to refer to state and local laws that
                               give them power to prevent accidents, such as inspections for
                               enforcing the building code.

                                For this incident, an official might issue a statement something
                               like this:
                                                        News Release

                                      For release, Tuesday 9:00 AM.  Office of the Mayor.

                                  About 100 pounds of chlorine gas were accidentally released  in the
                                  basement of North High yesterday when a storage tank began to leak du ring
                                  routine transfer of chlorine to the pool-cleaning system.  The gas was
                                  sucked into the air circulation system of the school, which was turned off five
                                  minutes after the leak was detected.  All 1100 people in the building were
                                  outside within fifteen minutes. Although some people experienced difficulty
                                  in breathing for several hours, and twenty people were  treated  at the
                                  hospital, no one was admitted and no one is experiencing after effects now.

                                  Chlorine can affect human health in two ways. In high concentrations that
                                  may be present during accidents, it causes difficulty in breathing, choking,
                                  coughing, chest pain, and sometimes nausea and vomiting. It also reacts
                                  with moisture, including body moisture, to form acids that are very irritating
                                  to skin, eyes, and mucous membranes. In yesterday's incident, no one
                                  suffered any skin irritation because concentrations except in the basement
                                  were not high enough. Once the symptoms of chest tightness or difficulty
                                  in breathing have disappeared, there are no further health problems that we
                                  are aware of associated with an exposure to chlorine.

                                  Our city has a plan in place for  responding to emergencies involving
                                  hazardous chemicals. This plan worked well, with efficient and effective
                                  response by the Fire, Emergency Management, and Volunteer Rescue
                                  teams, although the first person calling to report the accident had some
                                  trouble finding the right telephone number and right place to report. The city
                                  has had a plan since 1973, but it has been revised and updated recently by
                                  the Local Emergency Planning Committee. This committee was established
                                  under a federal law that calls for emergency planning and public access to
                                  data about hazardous chemicals.

                                  In order to limit the likelihood that any further such incidents will occur, the
                                                14

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         Scenario 1:  Unplanned Release of a Chemical
  Characteristics
of a good answer
                      School Board has agreed that transfer of chlorine will no longer be done
                      during school hours.  Chlorine is also stored in large quantities at city
                      swimming pools and water and wastewater treatment plants.  We have
                      reviewed our systems for detecting leaks and  made sure they are all
                      working properly.  We have also issued  instructions that transfers of
                      chlorine at city pools will only occur when the pools are closed for the day
                      and will be made only by trained personnel. Finally, we have tried to
                      publicize the telephone number to which initial accident reports should be
                      made: it is 333-3333.
To prepare a good answer:

 —describe the incident, the response, and other events

 —describe the chemical itself, including short- and long-term
   health effects of brief exposure at relatively high levels

 —describe the health effects suffered in the incident and any
   longer-term concerns

 —summarize the good and bad points of the response

 —describe actions being taken to reduce the likelihood of a
   similar incident
                     There are a variety of sources of information about chemicals,
                     including their physical properties and possible health effects.
                     Some of these sources are listed in Appendix 2.  Many public
                     libraries and local emergency response departments  have
                     reference books that provide some of this information. The
                     Material Safety Data Sheets (MSDSs) that facilities must supply
                     to the LEPC on request also contain this information.  EPA and
                     several private companies maintain computerized databases
                     with chemical information. CAMEO™, a computer program
                     developed with assistance from EPA, contains information
                     about more than  2700 chemicals. The National Library of
                     Medicine has toxicological information in computer databases
                     called TOXNET.  These sources seldom contain any information
                     about long-term health effects of exposures that may  occur
                     during an accident, because it is often the case that little is
                     known about them.
                                    15

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c
Scenario 1: Unplanned Release of a Chemical
               Summary
           Citizens' concerns about an accidental release of a chemical
           focus first on response to the emergency. Later, citizens want
           to know what is being done to prevent a similar emergency from
           arising again, and they want to know more details about the
           health effects of exposure to the chemicals involved in the
           accident.  Prior to any incidents, local officials should ensure
           that
                               plan has been developed
                           —a central source of information for the public has been
                               designated,
                           —they are aware of the procedures to be followed during an
                               emergency. (Filling out the Risk Communication Resource
                               Sheet at the beginning of the manual will help meet this
                               guideline.)

                           After incidents, local officials should be prepared to

                           —provide an evaluation of the effectiveness of the plan
                           —provide available information about health effects of the
                               chemical
                           —provide information about how citizens can become involved
                               in emergency planning and risk reduction through the
                               LEPC.
                                         16

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                       Scenario 2: Routine Releases
Scenario 2
Learning about Routine Releases

As a result of the incident in scenario 1,  the local media
become very interested in the hazardous chemicals in the
community.  They obtain emissions reports from the state
agency assigned the responsibility of keeping them or from
EPA, which maintains the Toxic Release Inventory (TRI)
database. The TRI can be accessed through the National
Library of Medicine's TOXNET system. The following
newspaper article is an example of the kinds of information
being publicized.
                                             Ourcity Daily News
                          325,000 Pounds of Four Toxic Chemicals Emitted Locally
                                 Benzene, Chlorine, Pyridine, Ammonia Most Prominent
                                            Industry Says, "Risk is Low"

                           Last year, fifteen local manufacturing facilities emitted more than 10,000
                           tons of toxic chemicals into the air, water, and land of Ourcity. The top
                           chemicals  emitted  (in pounds)  were  benzene (200,000), chlorine
                           (100,000),  pyridine (10,000) and ammonia (15,000).

                           Benzene is a known carcinogen. Chlorine is a highly toxic chemical that
                           may cause severe respiratory problems. Chlorine was involved in the
                           recent accident at the North High School, causing evacuation of 1100
                           students and teachers.  Pyridine is a  reproductive toxin, causing
                           possible damage to reproductive organs, as well as having serious
                           effects on the central nervous system. Ammonia, a common household
                           cleaner, is irritating to eyes and the respiratory system.

                           Newspaper staff examined  reports  submitted by fifteen  local
                           manufacturing facilities under the requirements of a federal law, the
                           Emergency Planning and Community Right to Know Act.  The federal
                           Environmental Protection Agency requires facilities to disclose the
                           amount of toxic chemicals they release into the environment each year.

                           In addition to benzene, chlorine, pyridine, and ammonia, local facilities
                           emit more than 500,000 pounds per year of ethylene,  creosols,
                           formaldehyde, and twelve other chemicals.

                           Tom Jones, senior safety engineer for Newtown Chemical Company,
                           noted that the emissions reported do not give cause for any alarm.
                           Benzene emissions by all fifteen companies, he said, are only one-tenth
                           of the benzene given off by automobiles in Ourcity. Jones also pointed
                           to a recent study by the State Environmental Department which showed
                           that total concentrations of benzene and seven other chemicals in
                                         17

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c
Scenario 2: Routine Releases
      Citizens' Questions
              Emissions
                      vs.
               Exposure
     Ourcity are well below state standards.  In Ourcity, they have been
     measured at about 20 parts per billion at the intersection of Broad and
     Main Streets.

     Rodney Smith of the State Environmental Department stated that the
     department will be looking more closely at the emissions to see whether
     they violate any state standards. "For now," he said, "we are just happy
     to see the companies providing the reports, complying with the law.
     Later we will use the data to examine whether we need regulatory
     changes."
 After reading such a news article, the questions that people are
 likely to ask local officials include:
   (1) What risk is posed by these exposures?
   (2) Are these emissions the cause of (various health
      symptoms)?
   (3) Why are the plants allowed to emit these substances?
   (4) Was the facility in compliance with state and federal laws?
   (5) Are there other facilities in the area that have not reported
      that also are emitting these substances? Should they be
      reporting too?
   (6) What other sources might lead to my being exposed to
      these chemicals?

 To answer the first two questions, we need to know about

   • emissions, concentration, exposure, and dose
   • toxicity
   • acute, high-level vs. long-term, low-level exposures
   • immediate vs. delayed risks

 To answer questions 3 and 4, officials should know a little about
 the present system for regulating emissions, the procedures for
 getting information under Title ill, and how citizens can begin to
 work with industry to reduce emissions if that is what they want
 to do.

 An emission or release is the amount of a substance released
 from a facility.  Releases are usually classified either as
 routine—small regularly released amounts that are planned to
 be released as part of a manufacturing process—or as
 accidental.
                                           18

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                Scenario 2;  Routine Releases
Characteristics
of the chemical
                 Just because a facility emits some amount of a substance does
                 not mean that it affects anyone.  Substances are diluted as they
                 are released into the air and water. The concentration is the
                 amount of the substance in a representative unit of the air,
                 water, or land. For example, due to automobile exhaust,
                 benzene may be found in the air of many cities in a
                 concentration of about 8 parts per billion. The concentration is,
                 of course, higher if emissions within a fixed time are higher and
                 other conditions remain the same. Concentrations also will tend
                 to be higher closer to the emission source.

                 Exposure happens when an individual comes in contact with a
                 substance Exposure can occur through breathing, drinking,
                 eating, and by direct skin contact. The amount of exposure is
                 determined by many factors, including the concentration of the
                 substance in the environment, how long the contact lasts, and
                 how often the exposure occurs.

                 Figure 1 shows the paths by which emissions might lead to
                 exposure. At each point, there are difficulties in determining
                 how much a person is exposed.  This makes it hard to estimate
                 the risk.

                  Dose is the amount of the substance that actually enters the
                 body. The dose is related to exposure, but differs according to
                 individual susceptibilities and habits.  The dose received from a
                  hazardous chemical in the environment is influenced by the
                 concentration, route of entry, length of exposure, presence of
                  other chemicals, and the ability of the body to break down the
                  substance.
Toxicity is a measure of how harmful a substance is to human
health or to plants or animals. Highly toxic substances have
adverse health effects at smaller doses.

An acute exposure is one that occurs over a short period of
time. It could be a large exposure such as might occur during
an accidental spill.

Long-term exposure can occur when a substance is present in
the environment over an extended period.
                                 19

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                         Figure  1
           Exposure Pathways for Humans
Deposits on crops -  D    ife Qn ground
                                                „,   ,      ,  Uptake by
                                                Sption /  *>"* foods
                                                from
                                                  Aquatic food ingestion
                                                       /  /    I
                                                       Volatilization from
                                                       water to air   .

                                                               \X
   Dermal
   absorbtion
   from soil
                                                Water ingestion
          From "Assessing Risk at Superfund  Sites,"
          prepared by CH2M HILL
                               20

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                     Scenario 2:  Routine Releases
Determining delayed
       health effects
Acute or short-term exposures may have immediate or acute
effects and may have long-term effects. The immediate effect
of the chlorine was to cause people to gasp and choke. We do
not know about any delayed effects of acute exposures to
chlorine.

Long-term, low level exposures also may cause health effects.
Usually these are delayed health effects that may not show up
for many years.  Cancer and birth defects are often delayed
health effects.

The ways in which we learn  about delayed health effects make
it difficult to discuss them with any certainty.

Most of our information about delayed health effects comes
from laboratory studies conducted on test animals.  Usually
more than one species is used. Animals are exposed to the
substance in different ways, including eating, drinking,
breathing, or on the skin, and different groups are exposed to
different quantities. After some time, animals are examined to
see whether there are abnormal cells or other evidence of harm.
The number of these abnormalities in the test animals is
compared to that in unexposed control animals. Statistical tests
are used to determine whether the difference between the test
animals and the controls is "significant," or suggests that the
substance may have a health effect.

Many people  disregard laboratory studies because animals are
exposed to quantities of the substance that are so much higher
than humans ever would receive. Laboratory studies are done
this way in order to reduce the number of test animals used and
the time needed for the study; otherwise, studies would be
prohibitively expensive. Results from the high doses are used to
predict what would happen at more realistic doses.  These
results may tell us approximately how many people will get sick
or die from particular exposure levels, but they can never tell us
which people will be affected.

Some laboratory studies are conducted on tiny organisms in test
tubes. Scientists have learned that substances that affect the
growth of these organisms often have adverse human health
effects. Usually these "in vitro" ("in glass") studies are used to
screen chemicals; those that seem suspicious are further tested
on animals ("in vivo").
                                      21

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c
Scenario 2: Routine Releases
       Answering health
       effects questions
                            Epidemiological studies use data about humans who have been
                            exposed to a substance and data about their health to try to
                            determine whether a substance causes health problems. Such
                            studies are often difficult to interpret  because people are
                            exposed to so many substances throughout their lives and
                            because the health effects of interest may not occur for many
                            years. Combined with laboratory evidence, however, it is often
                            possible to show that certain exposures cause unwanted health
                            effects in humans.

                            Because the evidence about long-term effects, when it is
                            available at all, is based on laboratory and/or epidemiological
                            studies it is often open to different interpretations. There is
                            never full proof about the cause of such effects.  This may
                            create political controversy between people who believe the
                            chemical creates a risk for those exposed and those who
                            believe that the evidence is not good enough to suggest that
                            there is a risk. Citizens who want to discuss these questions
                            should be referred to appropriate experts. Officials should try
                            not to get caught in such arguments. Instead, they should try to
                            present whatever facts are available and provide ways for
                            opponents to work together to achieve acceptable policy
                            solutions.
  Now we can turn back to some of the questions citizens ask:
   1) What risk is posed by these exposures?
   2) Are these emissions the cause of (various health
      symptoms)?

  1) What risk is posed by these exposures?

  The word "risk" often carries different meanings for different
  people. In communicating with the public, it is usually not
  helpful to say, "the risk is high" or "the risk is low."

  The factors contributing to the risk include:
                           Factor
                           Quantities
                           Concentrations
                           Exposures

                           Probabilities
                     Example
                     How much effluent was released
                     Parts per million
                     How much is likely to be
                     absorbed, inhaled, drunk
                     How likely is it to happen
                                          22

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Scenario 2°. Routine Releases
  Risk levels

  Toxicity
Expected number of deaths or disease per
year
How strong is the effect of exposure on
human health
  (Adapted from Hance, Chess, and Sandman, "Improving Dialogue With
  Communities"  p.  64.)

  In answering questions, people often confuse these factors
  when attempting to put risks into context.  In addition to these
  risk factors, other characteristics we have noted on page 8
  affect people's perceptions of risk, including how fair the risk
  seems to be, who benefits and who bears the risk, and whether
  the risk is voluntary or easy to understand.

  One way to talk about risks of exposures is to provide:

   1) A description of known health effects.

   2) Any information about concentrations or levels of exposure.

   3) Any comparisons of these concentrations with existing
   government standards or other directly comparable
   information. (Caution: Be careful when providing
   comparisons with risks from other chemicals or activities. For
   example, avoid making comparisons between risks such as
   drinking water containing hazardous chemicals and the risk of
   driving an automobile. Comparing dissimilar risks often makes
   citizens angry, especially when the comparison is between an
   involuntary risk such as drinking water containing hazardous
   chemicals emitted by a facility and a voluntary risk  such as
   driving. However, people might find it useful to hear a
   comparison of similar risks of two chemicals, both of which are
   found in drinking water. The Covello, Sandman, and Slovic
   book mentioned in Appendix 2 gives other good examples.)

   4) In addition, people like to know why the chemical is present
   in the community—that is, what it is being used for.
   Remember, familiar risks are likely to be perceived as less
   risky than unfamiliar or exotic ones.  The multi-syllabic name
   of a chemical, in contrast, might increase concern.
                 23

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c
Scenario 2: Routine Releases
           Other Sources
               for Referral
  A public official confronted with questions about benzene
  emissions might state the following:

   "Benzene is a chemical found in many common products such as gasoline
   and often used in making plastics, textiles, rubber, and solvents. It is
   known to cause leukemia if people are exposed to it at levels of hundreds
   of parts per million over many years.  In our town, concentrations in the air
   are about 20 parts per billion. Because  this is about 400 times lower than
   exposures known to cause leukemia, scientists do not know what kinds of
   health effects might result from exposures at this level. In other cities that
   do not have factories emitting benzene,  concentrations in the air average
   about 9 parts per billion, because both automobile exhaust and other
   everyday activities such as pumping gasoline result in benzene emissions
   too."

  For a substance with less well-documented effects, a statement
  might include the following:

   "We have recently found trichloroethylene (TCE) is a chemical that is
   emitted by local facilities into the water.  TCE is used by these facilities as
   a solvent and a compound in cleaning fluid and typewriter correction fluid.
   In some laboratory tests on mice, TCE has been shown to have
   reproductive effects at levels hundreds of times higher than the levels
   found in our drinking water. We just do not know what effects exposure at
   lower levels may have."

  2) Are these emissions the cause of my unwanted health
  effects?

  Causation is the most difficult question officials are called upon
  to consider. Except in well-conducted laboratory experiments,
  causation is almost impossible to prove. Workers who develop
  certain rare diseases after being exposed to relatively high
  concentrations of workplace substances known to be associated
  with those diseases can reasonably say that workplace
  exposure caused their problem.  Otherwise, it is almost
  impossible, since people are exposed to so many different
  substances in  so many different ways. Again, laboratory studies
  suggest the rate at which people will experience the unwanted
  health effects, but can never tell which individuals will get sick.

  Local officials should know how to get more information,
  including specialists to whom they can refer these more specific
  questions.
                                              24

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                 Scenario 2- Routine Releases
     Additional
     Responses
How Safe Am B?
                    • Several books are available in most public libraries. Among
                    them is the Concise Chemical Dictionary. Appendix 2 lists
                    some others.

                    •Local  health department officials may not have the necessary
                    expertise but will know appropriate health officials at the state
                    level.

                    •Local  universities have professors who are familiar with the
                    issues  surrounding identification of long-term health risks.
Technical experts often anger people by emphasizing the
difficulties in establishing causation or the extent of scientific
uncertainty.  Nevertheless, policy or legal decisions must often
be made even when these uncertainties exist. Sometimes it is
useful  to respond to questions about individual symptoms and
emissions or exposures with four kinds of statements:

  • Our scientific knowledge is not good enough for us to say
  whether these exposures cause your symptoms.

  • You can try to reduce the exposures by... (give specific
  relevant directions such as drinking bottled water, keeping
  windows closed, etc.)

  • (If appropriate) Emissions constitute only a small  portion of
  most people's exposures.

  • You have an opportunity to work with industry to reduce
  these emissions through the LEPC.
Perhaps the most common question asked is some form of:

        How safe am I?

As noted, individual exposures differ and individual
susceptibilities also differ. More important, individuals'
willingness to assume risks differ widely. In other words, safety
is a relative term. This is especially true when we consider the
non-quantitative aspects of risk, such as perceived fairness or
controllability.  Local officials can provide information about risk
measurement, but each person must decide for himself or

               25

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c
Scenario 2: Routine Releases
         Other questions
        about Scenario 2
  herself whether a risk is acceptable—that is, whether
  something seems "safe."

  Without supplementary information, the emissions data
  available under section 313 of Title III cannot answer questions
  about safety. The data can help people choose the facilities,
  media (air, water, land), or chemicals about which they would
  like to know more, however. Among the other information that
  would help determine whether the present level of safety is
  adequate (or the present level of risk is low enough) are the
  following things that affect the dose received : stack height, wind
  velocity, temperature, known health effects, concentrations at
  the fenceline, and the nature of the dose-response curve.

  Perhaps the most important thing to remember is that because
  safety is a relative term, community members must be involved
  in decisions about the levels of safety they would like. One
  important feature of Title III is that it provides people with initial
  information to allow them to participate in such decisions,
  especially through the  LEPC.

  One other way a local official can help people make a
  determination about safety or acceptable risk is by "answering"
  as a citizen rather than as an official, describing how he or she
  would act or is acting:

   "I drink the water", or "I let my children play outside."

  An answer such as this is more effective when it includes a
  recognition of people's feelings:

   "I can see that you are very concerned about this. What are
   your concerns and questions?"

  In addition to questions about risk and safety, the newspaper
  article about emissions data is likely to elicit questions about
  existing government programs and enforcement:

   3) Why are the plants allowed to emit these substances?
   4) Is this facility in compliance with state or federal laws.
   5) Are there other facilities in the area that have not
   reported that are also emitting these substances?
                                          26

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                Scenario 2°.  Routine Releases
Present System
 for Regulating
     Emissions
                 To answer question 3, we need to know about the present
                 system for regulating emissions. Answering questions 4 and 5
                 requires obtaining and analyzing new information.
The Present System for Regulating Emissions

It is difficult to answer the question about why plants are allowed
to emit hazardous substances because of the intricacies of the
federal and state laws regulating toxic chemicals. Although the
emissions of many chemicals are indirectly controlled by air,
water, or land disposal regulations, few are subject directly to
specific federal emission permits or standards. Most EPA
regulations deal with ambient levels of chemicals (in other
words, they specify acceptable concentrations in the
community's air or drinking water — not the amounts of the
chemicals that can be released from a particular facility).

Where EPA does have regulations based on emissions, they
generally apply to classes of chemicals (volatile organic
compounds and particulate matter in the case of air; total
suspended solids and certain types of waste streams for water).
And in the handful of cases where EPA has established
emission permits or standards for specific chemicals, they apply
only to certain industries — not to all companies emitting those
chemicals. For example, EPA has established a national air
emission standard,  or NESHAP, for benzene; but it applies only
to certain industries and to certain processes within those
industries. Therefore, to determine whether a particular
company is complying with the benzene standard, you would
need to know first, if the company is among the industries
subject to the standard; second, which of its processes are
regulated; and third, what percentage of the reported releases
are emitted from those processes.
                  Citizens may ask whether all the emissions have been reported.
                  The answer is no.  Some facilities are not covered by the
                  requirements of Title III; others may not know that they need to
                  report; and still others may have decided not to do so.

                                 27

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c
Scenario 2:  Routine Releases
        Enforcement and
      Citizen Involvement
             Under Title III
  Additionally, not all substances are covered - only those on the
  Section 313 list (see Appendix 5.)  In short, the data provided by
  Title III, although better than anything we have had before, are
  still very limited.  However, this question offers a good reason to
  discuss the opportunities for citizens to become involved in Title
  III activities.

  Title III provides penalties for not submitting reports of routine
  releases.  Facilities that do not submit may be sued by citizens
  and fined by EPA.  In the many states that have passed their
  own right to know and chemical reporting laws, state agencies
  may also be able to obtain penalties for non-reporting.  It may
  be difficult for states to determine that a facility has not reported,
  however.  Local residents often have access to information that
  regulatory agencies do not have, so citizens may be able to help
  enforcement officials identify facilities that have failed to report.

  Citizens who suspect that a facility is not reporting all or any of
  its emissions might begin by obtaining the chemical inventory
  lists available under Title III sections 311 and 312, and
  comparing those lists with the lists of chemicals reported as
  emissions on the section 313 report. Just because a chemical
  appears on the inventory does not mean it is emitted, so citizens
  will have to work with industry, local officials, and experts to
  determine whether it is likely that a substance is being emitted.

  It is also important to recognize that the first emissions reports
  were due on July 1,1988.  Not every facility that should have
  reported even  knew of its responsibility. Local officials and
  citizens can help identify facilities that are covered by the law
  and encourage them to report and notify state and EPA officials.

  One answer to question 3—"Why are the plants allowed  to
  emit these substances?" is

   "Not all emissions of toxic substances are harmful. Usually environmental
   or human health problems arise when the substance is present at more
   than a particular concentration.  Government regulations are formulated to
   keep the concentrations at levels that evidence suggests are consistent
   with environmental and human well-being.  If regulations made all
   emissions illegal, little manufacturing could take place.  If new information
   becomes available that suggests that the existing standard is wrong or that
   some  substance for which there is no standard should have one, regulatory
   agencies try to  write new standards.  Under Title III, citizens and regulatory
                                             28

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Scenario 2: Routine Releases
    agencies are learning about emissions they may not have known about
    before. This will provide a better basis for appropriate policy responses.
    Because the information is also available to citizens, they have an
    opportunity to participate in policymaking concerning emissions to a
    greater extent than before.  One way they can participate is by becoming
    active in the Local Emergency Planning Committee."

  To answer question 4—Is a particular facility in compliance
  with state and federal laws? will require review of reports filed
  by the facility with EPA or the appropriate state agency. Local
  officials can provide citizens with telephone numbers where they
  can obtain answers.
  The answer to question 5—"Are there other facilities in the
  area that have not reported that are also emitting these
  substances?"— is largely procedural, although it should have
  some substantive information if available:

    "Probably. The Local Emergency Planning Committee, interested citizens,
    and government agencies can use other information provided under Title III
    and other laws to try to identify facilities that may be emitting substances.
    Industry associations are also trying to get word out to their members
    about the obligation to report. Citizens who live near manufacturing
    facilities can certainly check with EPA or the [appropriate state agency that
    receives reports under section 313] to see whether neighboring facilities
    have reported. If not, they may talk to the facility manager to find out why.
    Remember, section 313 covers only some chemicals, so many facilities
    may have emissions they do not need to report. Also, facilities need not
    report if they use chemicals in amounts below specified quantities. Among
    the kinds of facilities that emit this chemical but are not included in the Title
    III requirement are	.  Because there are many such facilities in our
    community, there may be some  cause for concern."

  6) What other sources might lead to my being exposed to
  these chemicals?

  The answer to this question is related to the answer to question
  5, but can be based more closely on the data available under
  sections 312 and 313.  The  chemical inventories submitted to
  the LEPC under section 312 tell what chemicals are stored in
  the community, thereby providing some indication of the  range
  of possible exposures.  More important, the emissions data
  provided under section 313 provide some basic information
  about which chemicals are disposed to which medium. If
  aggregated for the whole community, these data can suggest
                  29

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c
Scenario 2: Routine Releases
                            the routes by which people might be exposed to particular
                            chemicals. The newspaper article in which the emissions are
                            reported for this scenario does not consider the medium to
                            which the chemicals are emitted, but this information is readily
                            available from the forms submitted to EPA and state agencies.

                            Because the answer to this question rests on considering data
                            for all local facilities at the same time, officials may feel that they
                            are unable to answer it—they lack the time to do the necessary
                            calculations.  In anticipation of such questions and needs,
                            Congress  required EPA to computerize the emissions data. The
                            Toxic Release Inventory (TRI) database is available to the
                            public at modest cost. It contains all the emissions reports and
                            allows users to examine the data in a variety of ways, including
                            adding up all emissions of a particular chemical to a particular
                            medium in a city or county.  Appendix 2 provides information on
                            how to get access to the TRI database.  SERCs also have
                            access to a similar database maintained at EPA, and may be
                            able to provide some data to questioners.
                                          30

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                   Scenario 2: Routine Releases
      Summary of
       Scenario 2:
Routine Emissions
Citizen concerns about the routine emissions reported under
Title III section 313 and described in the newspaper article
cover a broad range of complex issues. Officials without
specific expertise in these areas should not attempt to explain
the details, instead referring questioners to appropriate expert
sources.  On the other hand, they should anticipate questions
and prepare replies, since citizens may become angry if
constantly told, "I cannot answer that.  Please call so-and-so."
But don't make up an answer when you don't know.

Among the strategies for responding to questions about long-
term health effects where there is uncertainty about whether the
particular chemical causes a health effect and/or about whether
the emissions in question are related to particular citizens'
health problems are the following:

1.  Risks or risk levels should be compared at two different
times, compared against a government standard, or compared
with different estimates of the same risk. Note that comparisons
with government standards, which are set using a combination
of political and scientific criteria, may be misleading—it is not
true that everything less than the standard is "safe" while
everything over it is "unsafe." Different risks, especially risks
with different characteristics, should not be compared.  (See
above, page 8.  For more on risk comparison, see Covello,
Sandman, and Slovic, "Risk Communication, Risk Statistics,
and Risk Comparisons.")

2.  Questions of "safety" are difficult to answer, especially on the
basis of section 313 emiissions data alone. Different people
assess safety differently. However, statements describing how
you would or are behaving  in the same circumstances in
combination with a description of the risk provide listeners with a
basis for their own comparisons.  People should have an
opportunity to participate in determining whether existing levels
of safety are sufficient.

3.  Concern about risks may really reflect concerns about power
or other political issues. Try to ascertain people's real concerns
and answer those.  Many concerns are really about whether
procedures are fair and allow for adequate participation. Use
the Local Emergency Planning Committee (LEPC) as a forum
for all parties to work together.
                                    31

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Scenario 2:  Routine Releases
                           4. Where possible, indicate ways people can control risks.
                           They may be able to take some personal preventive action such
                           as drinking bottled water and using pesticides more carefully
                           around the home, or they may be able to join the LEPC or other
                           community groups to act collectively against a risk.

                           5. Help people understand why the substance is present in the
                           community in the first place. Familiar risks seem less worrisome
                           than unfamiliar ones.  Long chemical names are usually
                           unfamiliar. Explaining what familiar items the chemical is used
                           to manufacture may help people balance the risks and benefits.
                                         32

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                 Scenario 3:  Storing Large Quantities
Scenario 3
Storing Large Quantities

About six weeks after publication of the article on emissions
data, the following  article appears in the local newspaper.
                                              Our city Daily News
                                100 of 366 Extremely Hazardous Substances
                                              Present in Ourcity

                                         Possibility of Serious Accidents Great
                                      Emergency planning based on reports, but
                                     only 70 reports filed: How many are missing?

                           More than 100 of the 366 chemicals  the federal government calls
                           "extremely hazardous" are found in our community in amounts greater
                           than 10,000 pounds. Some of the chemicals are so hazardous that just
                           a few pounds released Into the air could kill hundreds of people under
                           the worst conditions.

                           Seventy different facilities in New County have reported that they store
                           these chemicals. Thirty of the chemicals are stored or used in quantities
                           greater than 100,000 pounds. Forty facilities reported using chlorine, the
                           chemical that spilled three months ago in the North High basement
                           causing the evacuation of 1100 students and teachers. The New County
                           Local Emergency Planning Committee, established under a new federal
                           law designed to prevent chemical  accidents, is developing a list of
                           facilities that need to increase safety measures based on the list.

                           Extremely hazardous substances are  chemicals determined by the
                           federal Environmental Protection Agency to have the potential for
                           causing serious human harm. Facilities must report these and many
                           other hazardous chemicals under the federal Emergency Planning and
                           Community Right-to-Know Act. The reports are available at the Ourcity
                           Emergency Department, 110 Main Street.

                           Reporters from this newspaper examined the inventories submitted by
                           local facilities  as  part of a  continuing investigation into hazardous
                           chemicals present in Ourcity. We learned lhat:

                           • Seventy facilities have submitted inventories. The federal law covers all
                           commercial facilities that store hazardous chemicals in amounts greater
                           than 10,000 pounds. There are 400 members of the Ourcity Chamber of
                           Commerce. Charles Smith, president of Ourcity Citizens Against Toxics,
                           stated that it seems likely that not all the facilities have reported that
                           should have.
                                         33

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Scenario 3:  Storing Large Quantities
      Citizens' Questions
                                   • Forty facilities store substances in quantities greaterthan 100 thousand
                                   pounds, and some as much as 1 million pounds. If storage containers
                                   leak, large quantities of chemicals could leach into the airorgroundwater.
                                   Accidents involving many people are  possible,  mostly from fire or
                                   explosion.

                                   • Among the substances stored in large quantities are chlorine, which
                                   produces a highly irritating toxic gas,

                                   • There are at least 50 substances being stored in underground storage
                                   tanks. According to a recent survey conducted bythe State Environment
                                   Department, more than half the underground storage tanks in the state
                                   are improperly built and in imminent danger of leaking.

                                   Industry  spokesmen emphasized the care they  use in storing and
                                   working with the hazardous chemicals.  "We're closer to them than
                                   anyone else, so we have a strong incentive to be careful," said Tom
                                   Thomas  of Generic Chemical. City and county  emergency officials
                                   stated that the annual inspections of facilities storing hazardous chemicals
                                   convinced them that chemicals are properly stored. They are working
                                   with facilities to reduce the possibility of accidents further. They stated
                                   that the emergency response plan updated under the same federal law
                                   that requires submission of chemical inventories also ensures citizens'
                                   safety.

                                   Neighbors of plants are not so sure. "About once a month I hearthe sirens
                                   overthere,"says Sharon Shivers, who lives in the Northridge neighborhood
                                   near the Generic plant. "I think their storage is faulty but they don't want
                                   us to know."
                               After reading this article, citizens might ask the following
                               questions:

                                 1) Are the hazardous materials used by nearby facilities stored
                                 properly? What is the chance of leaks developing?

                                 2) How likely are stored materials to be involved in an
                                 accident?

                                 3) If they are released, what kinds of health or other hazards
                                 do they present?

                                 4) Can we reduce the amounts of these materials that are
                                 stored in order to reduce risk?
                                                34

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                    Scenario 3:  Storing Large Quantities
Planning for Hazardous
 Chemical Emergencies
                           5) What about the danger from chemicals stored by facilities
                           that didn't have to report because they had less than 10,000
                           pounds?

                         Answers to these questions require some understanding of the
                         process by which we plan for hazardous materials accidents
                         and how we assess potential risks posed by facilities that store
                         and use hazardous materials.  Some of the questions raise
                         issues we have already considered—providing information
                         about health effects and opportunities for citizens to participate
                         in planning and risk reduction activities.
Section 303 of Title III requires the Local Emergency Planning
Committees (LEPCs) to formulate a plan for emergency
response.  In order to make a realistic plan, LEPCs must first
learn where and what chemicals are stored. The chemical
inventories submitted under sections 311 and 312 and the lists
of extremely hazardous substances submitted under section
302 provide this information.

To plan for emergencies, LEPCs follow these steps:

  1. Identify Hazards: using information provided by facilities,
  determine the ways in which they store and use hazardous
  chemicals.

  2. Conduct a vulnerability analysis:  using credible worst case
  assumptions, determine a vulnerability zone and identify
  special facilities within that zone such as nursing homes or
  schools or special problems such as a drinking water source.

  3. Work with high-priority facilities to refine and re-evaluate the
  hazards identification and vulnerability analysis.

  4. Complete a risk analysis: make a rough estimate of risks
  based on hazard identification and vulnerability analysis and
  likelihood of releases. Then, integrate this information  into a
  community-wide emergency plan. (The components of a
  community-wide plan are  described on page 12.)

Figure 2 shows a sample hazards analysis for an extremely
hazardous chemical at one site. If such an analysis is conducted
for all hazardous chemicals found in the community, it will

               35

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                                           Figure 2

                             SAMPLE HAZARDS ANALYSIS FOR ONE
                             EXTREMELY HAZARDOUS SUBSTANCE
                                   AT A HYPOTHETICAL SITE

              (REPEAT THIS ANALYSIS FOR EACH EHS AND SITE IN THE COMMUNITY)
INITIAL SCREENING

1. HAZARDS IDENTIFICATION
(Major Hazards)

a. Chemical

b. Location

c. Quantity

d. Properties
2. VULNERABIUTY ANALYSIS

a. Vulnerable zone
b. Population within vulnerable zone
c. Essential services within zone

3. RISK ANALYSIS
   (Initial Evaluation of Reporting
   Facilities—Relative Hazards)
Chlorine

Water treatment plant

800 Ibs.

Poisonous; may be fatal if inhaled. Respiratory
conditions aggravated by exposure. Contact
may cause burns to skin and eyes. Corrosive.
Effects may be delayed.
A spill of 800 Ibs. of chlorine from a storage tank
could result in an area of radius-greater than 10
miles where chlorine gas may exceed the level
of concern (LOG).  This would be a credible
worst case scenario.

Approximately 600 residents of a nursing home;
workers at a small factory; 29 workers at the wa-
ter treatment plant; urban area-400  persons/sq.
mile; total population in vulnerable zone is more
than 125,000.

2 fire stations and 1 hospital
Relative to potential hazards of other
reporting facilites—high
                                                                                              J
                                              36

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REEVALUATION(PLANNING)

1.  HAZARDS IDENTIFICATION

     a. Chemical

     b. Location

     c. Maximum quantity that
        could be released

     d. Properties

2.  VULNERABILITY ANALYSIS

     a. Vulnerable Zone



     b. Population within vulnerable zone


     c. Essential services

3.  RISK ANALYSIS

     a. Likelihood of hazard occurrence




     b. Consequences if people are exposed
      c. Consequences for property
      d. Consequences of environmental
        exposure

      e. Summary: likelihood/severity of
      on site
Chlorine

No change

500 Ibs. (decrease)


No change
Zone decreases (new radius -1.0 miles) due to
smaller quantity released and use of urban dis-
persion model.

Decreases; total population in vulnerable zone is
12:50

None
Low-because chlorine is stored in an area with
leak detection equipment in 24 hour service with
alarms. Protective equipment is kept outside
storage room.

High levels of chlorine gas in the nursing home
arid factory could cause death and respiratory
distress. Bed-ridden nursing home patients are
especially susceptible.  High severity of
consequences. However, gas is unlikely to
reach a nursing home under reevaluated release
conditions.

Possible superficial damage to facility
equipment and structures from corrosive fumes
(repairable).

Possible destruction of surrounding fauna and
flora.

Low/High.  (The community would assess this
on a site- and incident-specific basis.)
                                                    37

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c
Scenario 3: Storing Large Quantities
                           provide answers for many of the questions on page 34. For
                           example, the answer to the question "How likely are stored
                           materials to be involved in an accident" may be found under
                           Part 3 (Risk Analysis) of the Reevaluation section, which
                           assesses risk after a change in the amount of the chemical
                           stored. There, the risk for accidents from chlorine is evaluated
                           as being low because chlorine is stored in an area with leak
                           detection equipment and alarms.

                           Information that the LEPC collects, even extra information such
                           as a worst-case vulnerability analysis or transportation routes, is
                           available to the public. If the LEPC has completed a plan using
                           the steps outlined above, it should be able to assist in
                           answering the question about proper storage.

                           It is difficult to estimate the chance of leaks or accidents. This
                           question is answered by describing the planning process, which
                           both encourages facilities to store their hazardous chemicals in
                           the best way and sets up a plan for minimizing damage that
                           might result if an accident does occur.

                           Again, in answering questions about accidents, it is important to
                           remember the risk characteristics listed on page 8. People feel
                           more confident when it seems that all likely causes of accidents
                           have been considered and planned for, because the risks seem
                           more controllable, better understood, and less likely to be
                           catastrophic.

                           Facility owners and managers have the final say over reducing
                           the amounts  of stored hazardous chemicals.  The LEPC can
                           provide a forum in which citizens can voice concerns to industry
                           representatives and work with them to get these amounts
                           reduced.  Many facilities are willing to do this after they see the
                           results of a vulnerability analysis. They may find out that their
                           inventory costs decrease as well by having less of each
                           hazardous chemical on hand.

                           Information about the health effects of individual chemicals will
                           also be available through the LEPC, health professionals in
                           state and local health and environment departments,  poison
                           control centers, and academic institutions, or through the
                           references listed in Appendices 2 and 4.
                                          38

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Summary
The kinds of questions that storage raises are hard to answer.

Because each facility and each community is different, the
answers can only be obtained by working carefully through the
specific data provided by local facilities.  This is very time-
consuming work. After the data are obtained, citizens will still
have to work with experts to determine whether storage
methods and quantities are appropriate and whether health
effects are worrisome.

Rather than  providing sample answers, as we did in  the other
scenarios, we can offer only general suggestions:

Officials can best answer most of these questions by
    —referring to the plan and the procedures that went into
      creating it, and
    —referring to the sources within government where citizens
      can work with government and industry.
                            39

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Summary &
Conclusion
The "Seven Cardinal Rules of Risk Communication," written by
Vincent Covello and Frederick Allen and available in an EPA
pamphlet are reprinted here. They both summarize and add to
the information presented in this manual.

  1. Accept and Involve the Public as a Legitimate Partner
   *  Involve the community early.
   *  Involve all parties that have an interest or stake in the
       issue.
   *  Remember, you work for the public.

  The goal of risk communication should be to produce an
  informed public that is involved, interested, reasonable,
  thoughtful, solution-oriented, and collaborative.

  2. Plan Carefully and Evaluate  Your Efforts
   *  Begin with clear,  explicit objectives.
   *  Evaluate the information you have about risks and know its
       strengths and weaknesses.
   *  Identify and address the particular interests of different
       groups.
   *  Train your staff — including technical staff — in
       communication  skills.
   *  Practice and test  your messages.
   *  Evaluate your efforts and learn from your mistakes.

  3.  Listen to the  Public's Specific Concerns
  If you do not listen to people, you cannot expect them to
  listen to you. Communication is a two-way activity.

   *  Do not make assumptions about what people know,
       think, or want done.  Take the time to find out what
       people are thinking.
   *  Let all parties with an interest in the issue be heard.
   *   Identify with your  audience.  Put yourself in their place
       and recognize their emotions.

  People are often more concerned about trust, credibility,
  competence, control, voluntary fairness, caring and
  compassion than  mortality statistics or quantitative risk
  assessment.
                                    40

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4. Be Honest, Frank and Open
 *  State your credentials; but do not ask or expect to be
     trusted.
 *  If you do not know the answer or are uncertain, say so.
     Get back to people with answers.  Admit mistakes.
 *  Disclose risk information as soon as possible.
 *  Do not minimize or exaggerate the level of risk.
 *  Lean toward sharing more information, not less — or
     people may think you are hiding something.

Trust and credibility are difficult to obtain. Once lost they are
almost impossible to regain completely.

5. Coordinate and Collaborate with Other Credible
Sources
 *  Take time to coordinate with other organizations or
     groups.
 *  Devote effort and resources to the slow, hard work of
     building bridges with other organizations.
 *  Try to issue communications jointly with other credible
     sources.

Few things make risk communication more difficult than
conflicts or public disagreements with other credible sources.

6. Meet the Needs of the Media
  *  Be open with and accessible to reporters; respect their
     deadlines.
  *  Provide risk information tailored to the  needs of each
     type of media.
  *  Prepare in advance and provide background material on
      complex issues.
  *  Do not hesitate to follow up on stories with praise or
      criticism.
  *  Try to establish long-term relationships of trust with
      specific editors and reporters.

The media are frequently more interested in politics than in
 risk; more interested in simplicity than in complexity; more
 interested in danger than in safety.

 7. Speak Clearly and with  Compassion
 Technical information and jargon are barriers to successful
              41

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   communication with the public.

    * Be sensitive to local norms, such as speech and dress.
    * Use vivid, concrete images that communicate on a
        personal level. Use example and anecdotes that make
        technical risk data come alive.
    * Use simple, non-technical language.
    * Use risk comparisons to help put risks in perspective; but
        avoid comparisons that ignore  distinctions that people
        consider important.
    * Acknowledge and respond (both in words and with
        actions) to emotions that people express — anxiety,
        fear, outrage, helplessness.
   *  Always try to include a discussion of actions that are
        under way or that can be taken. Tell people what you
        cannot do. Promise only what  you can do, and be sure
        to do what you promise.
    * If people are sufficiently motivated, they are quite capable
        of understanding complex risk information, even if they
        may not agree with you.
    * Regardless of how well you communicate risk information,
        some people will not be satisfied.

These rules seern to be only common sense.  Yet it is surprising
how often they are violated when communicating about risk.
Following them does not guarantee effective risk
communication.  On the other hand, it is unlikely that  you will
communicate effectively without them.  There is also an
informal eighth rule, which underlies all the others:

    Know what you are talking about.

Since no one person can be expected to know everything, we
have tried to provide sources for additional information as well
as sample answers to questions in  which you refer citizens to
these sources.

Talking to people about risk is difficult. Certain buzzwords or
ideas such as "cancer often set off reactions that  may be too
strong.  Many familiar chemicals that people use every day may
have more serious effects than some of the  unfamiliar
chemicals they will hear about under Title III.  Public officials
must try to help citizens keep these risks in perspective.
               42

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    Opportunity for
Citizen Involvement
     Plan of Action
One of the most important factors that affects people's
perceptions of risk is whether they feel in control. That is why
several of our suggestions for response to citizen questions,
especially when the questions cannot be answered with
unequivocal scientific information, is to offer people a means for
participating in decisionmaking about chemicals in their
communities. Local Emergency Planning Committees (LEPCs)
offer, or should offer, a logical place for such participation.
Because LEPCs include representatives from government,
industry, and  citizen groups, they offer a good setting for
encouraging the different interests to work together.

Risk communicators should take every opportunity to suggest
direct ways in which individuals can take control to reduce their
exposures to  hazardous chemicals, such as standing upwind
while filling the gas tank of an automobile.

Perhaps the single most important factor in communicating risks
is that the source be perceived as trustworthy and willing to
listen as well as talk. Other kinds of communication also benefit
from these characteristics. Public officials can improve their
effectiveness  in many areas by learning the lessons of risk
communication: develop a relationship of trust with people
before some particular incident (such as a chemical spill)
occurs, and talk with, riot lp_, citizens. Although time-consuming,
this strategy will more than repay the costs when what would
otherwise be a divisive community issue is settled through
compromise and negotiation.
We have covered the things you need to do to more effectively
fulfill your role as a "risk communicator." How can you best use
this information back on the job?

Unfortunately, there  is no "formula" or "master plan" that will
provide rote answers to every question you may ever face in
risk communications. The following steps are suggested,
however, as actions  you can take starting today that will help
prepare you for your responsibilities in this area:

1.  Set a time by which you will have filled in all  of the
information on the "Risk Communication Resource Sheet" in the
front of the manual.  Some of the information you  already have;

               43

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other information might take some "digging." This resource
sheet will provide a quick reference to many of the contact
people who are knowledgeable about emissions, releases,
stored substances, etc.  Update this resource sheet annually.

2. Obtain copies of this manual for persons involved in your
emergency plan.

3. Initiate contact, if you have not already done so, with
members of your Local Emergency Planning Committee, and
learn more about their activities.

4. Keep this manual in an accessible place for periodic review
and/or in case of emergencies.
Please let us know your successes in communicating about risk,
and what works most effectively. Contact:

   Ann Fisher
   Office of Policy Planning & Evaluation, PM-221
   Environmental Protection Agency
   Washington D.C. 20460
   (202)382-5500

   Susan G. Madden
   LBJ School of Public Affairs
   The University of Texas at Austin
   Austin, Texas 78713
   (512)471-4962

   Steve Finefrock
   National Emergency Training Center
   Building N
   Room 242
   Emmitsburg, Maryland 21727
   (301)447-1282
               44

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                                       APPENDIX 1


                        Glossary of Commonly  Used  Terms


Absorbed dose--The amount of a chemical that enters the body of an organism.

Acute-Sharp, severe; having  a rapid onset, severe symptoms, and a relatively short duration.
    Acute exposure: a single exposure of relatively short duration.
    Acute toxicity: the development of adverse health effects soon after a single exposure to a
    substance.

Additive effect-Combined effect of two or more chemicals equal to the sum of their individual effects.

Ambient-Environmental or surrounding  conditions.

Animal studies  (sometimes called "laboratory studies")~lnvestigations using animals as surrogates
    for humans, on the expectation that results in animals are pertinent to humans.

ATSDR-Agency for Toxic Substances and Disease  Registry, part of the U.S. Public Health Service,
    based in Atlanta,  Georgia, 30333.

Carcinogen-A chemical that causes or induces cancer.

CAS  registration number~A number assigned by the Chemical Abstracts Service to identify a
    chemical.

Chronic-Occurring over a long period of time, either continuously or intermittently.
    Chronic effect-effects that last  a long  time even if caused by a single acute exposure. (See also
    delayed effect.)
     Chronic exposure-long-term, low-level exposure to a to a chemical.

Concentration-the amount of the substance in a representative unit of the  medium.

Delayed effect-an effect of exposure that does not occur for some time.  Sometimes called a "chronic"
    effect.

Dose-The amount of the sbustance that actually enters the body.

Dose-response-A quantitative  relationship between the dose of a chemical and an effect caused by the
    chemical.

Dose-response curve-graphical presentation of the relaioriship between degree of exposure to a
    chemical (dose) and observed biological effect or response.

Emission or release-the amount of a substance released from a facility.  Releases  are usually
    classified as routine-small regularly-released amounts that are planned to be released as part of a
    manufacturing process-and accidental.

Endangerment assessment~a site-specific risk assessment of the actual or potential danger to human
    health or welfare and the environment from the release of hazardous substances or waste. The
    endangenment assessment document is prepared in support of enforcement actions under CERCLA or
    RCRA.

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Environmental fate--The destiny of a chemical  after release to the environment; involves
   considerations such  as transport through air, soil, and water; bioconcentration; degradation.

EPCRA--The Emergency Response and Community Right-to-Know Act of 1986; same as SARA Title III.

Epidemiological studies-Investigation of factors contributing to disease or adverse health effects in
   human populations.

Exposure-Trie contact with a chemical or physical agent.   This contact can occur through breathing,
   drinking, eating, and by direct skin contact.

Extrapolation-Estimation of  unknown values by extending or projecting from  known values.

Extremely hazardous substances-Chemicals that have the potential for causing death or irreversible
   toxicity after relatively short exposure to small amounts.  (They  are acutely toxic.)  On the basis
   of toxicity, generally in air, EPA has identified the list of the  chemicals in Appendix 5.

Latency—Time from  the first exposure to a chemical until the appearance of an adverse health effect.

LC50--the concentration of a chemical in  air or water that is expected to cause death in 50 percent of
   test animals  living in that air or water.

LD50-The dose  of a chemical by a specific exposure pathway (eating, breathing, injection, or absorbed
   by the skin) that is expected to cause death in 50 percent of the test animals so treated.

LEPC-Local Emergency Planning Committee.  Local body established under Title III.

LOAEL-Lowest-Observed-Adverse-Effect Level; the lowest  dose  in an experiment that produced an
   observable adverse effect.

Laboratory studies-Studies of the effects of chemicals on animals or cells.
   -In  vitro studies-Studies of chemical effects conducted  in tissues, cells or subcellular  extracts
         from an organism  (i.e., not in the living  organism).
   -in  vivo studies-Studies of chemical effects conducted in  intact  living organisms.

Long-term exposure-This occurs when a substance is present in the environment around a person
   over a long period of time.

MSDS-Material Safety Data Sheet.  A description of the chemical, physical, and health effects of a
   chemical along with  methods for protection and emergency response written for workplace settings.

Materials balance~An accounting of the mass flow of a substance from sources of production, through
   distribution  and use, to disposal or distribution, and including any releases to the environment.

Mutagen--An agent that causes a permanent genetic change in a cell other than that which occurs during
   normal genetic recombination.

NOAEL--No-Observed-Adverse-Effect Level; the highest dose in an experiment that did not produce an
   observable adverse effect.

NRC--National Response  Center, 1-800-424-8802.

Pathogen—Any disease-causing agent, usually  applied to living agents.

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Permissible dose-The dose of a chemical that may be received by an individual without the expectation
    of a  significantly harmful  result.
RCRA--Resource Conservation and Recovery Act.  Another federal statute concerning hazardous
    substances.
Release-see  "Emission."
Reversible effect~An effect that is not permanent; an especially adverse effect that diminishes when
    exposure to a toxic chemical ceases.
Risk--The likelihood of injury, disease, or death.
Risk assessment-A qualitative or quantitative evaluation of the environmental and/or health risk
    resulting from exposure to a  chemical or physical agent (pollutant); combines  exposure assessment
    results with toxicity assessment results to estimate  risk.
Risk estimate--A description of the probability that organisms exposed to  a specified dose of chemical
    will develop an adverse response (e.g., cancer).
Risk factor-Characteristic (e.g.,  race, sex,  age,  obesity) or variable (such as smoking, occupational
    exposure level) associated with increased probability  of an adverse health effect.
Route of exposure-the avenue by which a chemical comes into contact with an organism (e.g.,
    inhalation, ingestion, dermal  contact, injection).
SARA-Superfund Amendments and Reauthorization Act of 1986.
SERC-State Emergency Response Commission.  Established under Title III.
Teratogenicity-The capacity of a physical or chemical agent to cause hereditary congenital
    malformations (birth defects)  in  offspring.
Threshold-The lowest dose of a chemical at which a specifed measurable  effect is observed and below
    which it is  not observed.
Title Ill-the common name for the Emergency Planning arid Community Right to Know Act of 1986,
    which is Title III of the Superfund Amendments and Reauthorization Act.
Toxicity-The quality or degree of being poisonous or harmful to plant, animal, or human life.
TRI-Toxics (or Toxic Chemical) Release Inventory. The database containing annual toxic chemical
    release reports submitted by certain manufacturing facilities, specified in Section 313 of EPCRA.
    The TRI is available to the public in county libraries, through a national computerized database
    maintained by the National Library of Medicine, and through regional EPA offices. See Appendix 2
    for more  information.

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                                     APPENDIX  2
                              References and  Sources
1. Title HI
Environmental Protection Agency.  It's Not Over in October: A Guide for Local Emergency Planning
Committees. September 1988, written by thirteen organizations, representing federal, industry and trade
associations, public interest groups, and others.
Environmental Protection Agency. Chemicals in Your Community. September 1988.
Environmental Protection Agency. Community Right-to-Know and Small Business. September 1988.
Environmental Protection Agency. Toxic Chemical Release Inventory: Risk Screening Guide. July 1989.
Chemical Manufacturers Association. Title III Community Awareness Workbook.
Chemical Manufacturers Association. Community Guide to Title III.
Hadden, Susan G. A Citizen's Right to Know: Risk Communication and Public Policy. Boulder: Colo.:
Westview Press, 1989.
National Wildlife Federation.  Reducing the Risk of Chemical Disaster: A Citizen's Guide to the Federal
Emergency Planning and Community Right to Know Act.
Working Group on Community Right to Know.  What is the Emergency Planning and Community Right to
Know Act?
2.  About Risk Communication
American Chemical Society, Department of Governmental Relations and Science Policy. A Handbook on
Chemical Risk Communication: Preparing for Community Interest in Chemical Release Data.  Draft IV, 1
July 1988.
Covello, Vincent T., David B. McCallum and Maria Pavlova. Effective Risk Communication: The Role and
Responsiblity of Government and Nongovernment Organizations.  Proceedings of the Workshop on the
Role of Government in Health Risk Communication and Public Education. New York:Plenum Press, 1988.
Covello, Vincent,  Peter Sandman, and Paul Slovic.  Risk Communication, Risk Statistics, and Risk
Comparisons: A Manual for Plant Managers. Washington, D.C.: Chemical Manufacturers Association,
1988.
Hance, Betty, Caron Chess  and Peter Sandman.  Improving Dialog with  Communities: A  Risk
Communication Manual for Government. Trenton: New Jersey Department of Environmental Protection,
1988.
Krimsky, Sheldon, and Alonzo Plough.  Environmental Hazards: Communicating Risks as a Social
Process.  Dover, Mass: Auburn House Publishing Co., 1988.
Sandman, Peter.  Explaining Environmental Risk.  Washington, D.C.: Environmental Protection Agency,
April 1986.
U.S. EPA, Office of Toxic Substances. Toxic and Hazardous Chemicals - Title III and Communities: An
Outreach Manual for Community Groups. Washington, D.C.: EPA. September, 1989.

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3. About Specific Chemicals
Chemical Manufacturers Association. Chemical Referral Center.  1-800-262-8200.
CAMEO (Computer-Aided Management for Emergency Operations). (Software-contains descriptions,
health effects information, and emergency response information for more than 2400 chemicals.)
Department of Transportation. Emergency Response Guidebook. Lists about 1,000 substances by
name and DOT identification number, giving hazards and isolation distances. Available from Office of
Hazardous Materials Transportation, DMH-50, RSPA, DOT, 400 7th Street, S.W., Washington, D.C.
20590.
Environmental Protection Agency. Common Synonyms for Chemicals Listed under Section 313 of the
Emergency Planning and Community Right-to-Know Act of 1986.  December 1988.
Illinois EPA.  Chemical Information Sheets. Springfield, III, 1986,1987.
 Massachusetts Department of Environmental Quality Engineering. Layperson's Guide to Reading
MSDSs:  Boston, Mass.
Michigan Department of Natural Resources.  Chemical Summaries. East Lansing, Michigan.
New Hampshire Department of Health and Human Services. Health Information Summaries.  Concord,
N.H.
New Jersey Department of Health. Hazardous Substance Fact Sheets. Trenton, N.J.  (Distributed by
EPAtoSERCs.]
North Carolina Department of Natural Resources and Community Development.  Chemical Profiles of
Toxic Air Pollutants. Raleigh, N.C., 1986.
Virginia Department of Health.  Virginia Fact Sheets. Richmond, Va.
U.S. Coast Guard, Chemical Hazards Response Information System 202-267-1577.
Washington Department of Social and Health Services. Toxic Substances Fact Sheets.  Olympia, WA.
 4.  General  Information about Health Effects
 Agency for Toxic Substances and Disease Registry.  Case Studies in Environmental Medicine.
 Agency for Toxic Substances and Disease Registry.  Toxicological Profiles. Profiles have been
 developed for the hazardous substances that pose a significant potential threat to human health and are
 common at Superfund sites. Each profile contains toxicological and health effects information for the
 substance. (Write for information on how to obtain the Profiles: ATSDR, E-28, Division of Toxicology,
 1600 Clifton Road, N.E., Atlanta, Georgia 30333.)
 Bell, Carolyn.  The Environment in Small Doses: A Layperson's Guide to Understanding Toxic
 Substances. Memphis, Tenn.: Autumn Expressions, 1987.
 Environmental Protection Agency. Chemical Exposures: Effects on Health.  1987. Available from the
 TSCA Assistance Office, TS-799 at EPA.

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Environmental Protection Agency. Toxic Chemicals: What They Are, How They Affect You. Chicago, IL:
U.S. Environmental Protection Agency, no date.

Fischhoff, Baruch, Sarah  Lichtenstein, Paul Slovic, Stephen L. Derby, and Ralph Keeney (1981).
Acceptable Risk. Cambridge: Cambridge University Press.

Liroff, Richard A., Toxics in the Air.  Washington, D.C.: The Conservation Foundation, 1987.

Marczewski, Alice E. and Michael Kamrin. Toxicology for the Citizen, 2nd ed. East Lansing, Ml: Michigan
State University, Center for Environmental Toxicology, 1987. (Write the Center for Environmental
Toxicology, C231 Holden Hall, Michigan State University, East Lansing, Michigan, 48824.)

Moses, Susan .  Chemical Risk: A Primer. Washington, D.C.: American Chemical Society, 1984. A
pamphlet for nonscientists focuses on scientific issues involved in determining the health risks arising
from exposure to chemicals and mentions public perceptions of risk.

National Cancer Institute. Everything Doesnt Cause Cancer. Bethesda, MD: National Cancer Institute,
1984.

Ottoboni, M. ALice. The Dose Makes the Poison: A Plain-Language Guide to Toxicology. Berkeley, CA:
Vincente Books, 1984. A readable and concise introduction to risks from chemicals.

Sasnett, Sam K. A Toxics Primer. Washington, DC: League of Women Voters of the United States, no
date.

Toxicology Data Network System (TOXNET), National Library of Medicine (NLM). Online computerized
databases of toxicological information on specific chemicals. See Section 8 on databases for more
information.

Wexler, Phillip.  Information Resources in Toxicology. New York: Elsvier Science Publishing Co.,1987.
Guide to literature, computer files, organizations, and activiites concerning toxicology.


5.  Evaluation Methods for Use in Specific Communities

Brockbank, Brad, John Cohrsson, and Vincent T. Covello.  A manual on risk assessment techniques for
decisionmakers and citizens.  Washington, D.C.: Council on Environmental Quality, 1988.

CAMEO (Computer-Aided Management for Emergency Operations), (software)

Chemical Manufacturers Association.Cftem/ca/s in the Community: Methods to Evaluate Airborne Levels.
Washington, D.C.: CMA, 1988. Identifies methods used to evaluate emission leels of airborne chemicals
in the community.  Intended for health professionals who can judge the most appropriate approach and
evaluate available data.

Environmental Protection Agency. Guide to Exercises in Chemical Emergency Preparedness Programs.

EPA, FEMA, and DOT. Technical Guidance for Hazards Analysis. December 1987.

National Response Team, Criteria for Review of Hazardous Materials Emergency Plans. (NRT1 -A)
May, 1988

National Response Team. Hazardous Materials Planning Guide. (NRT-1). March 1987.
Available by writing Hazmat Planning Guide, OS-120, EPA, 401 M Street, S.W., Washington, D.C. 20460.

Public Health  Foundation, Environmental Health Program.  Resource Guide for Environmental Health Risk
Assessment.  Washington, D.C.: PHF, 1986. Organizational (Contact and other resource information to
assist professionals who are assessing risks from polluted environments.

-------
Rail, David P. Medicine for the Layman: Environment and Disease. Bethesda, MD: National Institutes for
HeaUh, 1982.

Sherry, Susan. High Tech and Toxics: A Guide for Local Communities. Washington DC: Golden Empire
Health Planning Center, 1985.

Working Group on Community Right to Know. Hazard Assessments and Plume Mapping Documents for
LEPCs.

6.  State and  Local Level  Contacts and Resources  (also see Appendix 4.)


Public Health Foundation, Environmental Health Program. Directory of State and Territorial Environmental
Health Services. Washington, D.C.: PHF, 1987.  Updated annually and in possession of each state's
health department.


7.  Waste  Reduction

Irwin, Frances H. and Edwin Clark. America's Waste: Managing for Risk Reduction. Washington DC: The
Conservation Foundation, 1987.

Mufr, Warren and Joanna Underwood. Promoting Hazardous  Waste Reduction: Six Steps States Can
Take. New York: INFORM, 1987.

Sarokin, David J., Warren Muir, Catherine G. Miller, and Sebastian R. Sperber, Cutting Chemical Wastes:
What 29 Organic Chemical Plants are Doing to Reduce Hazardous Wastes. New York: INFORM, 1985.


8.  Databases.

National Library of Medicine (NLM), 8600 Rockville Pike, Bethesda, MD. 20894. 1-800-638-8480 or
301-496-6193. Databases are available online through a personal computer and modem connection, or
in a medical library.

    TOXLINE.  A collection of online bibliographic information convering the
    pharmacological, biochemical, physiological, and toxicological effects of drugs and
    hazardous chemicals. For information:  MEDLARS Management Section at the NLM
    address given above.

    Toxicology  Data Network System (TOXNET). A computerized system of files oriented to
    toxicology and related areas. The files include the Hazardous Substances Data Bank
    (HSDB), the Registry of Toxic Effects of Chemical Substances (RTECS), and the
    Environmental Protection Agency's Toxic Chemical Release Inventory (TRI). For
    information, contact the NLM at the address given above.

CCINFOdisc. Canadian Centre for Occupational Health and Safety.

    CCINFOdisc is a compact disk with several toxic substances databases, including the
    New Jersey Fact Sheets.

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                            APPENDIX  3

              Brief Description of Title HI by Section

301 - establishes LEPCs and SERCs (State [Emergency Response
    Commissions).

302 - requires facilities to notify the LEPC and SERC if they store more than
    the threshold planning quantity of any of the extremely hazardous
    substances.

303 - requires the LEPC to formulate an emergency plan.

304 - requires facilities that release more than a reportable quantity to notify
    the LEPC and the SERC (and NRC for CERCLA hazardous substances).

311 - requires all facilities that store any hazardous substance in amounts
    greater than 10,000 pounds (for hazardous chemicals) or 500 pounds or
    the threshold planning quantity, whichever is less (for extremely
    hazardous substances), to submit  a chemical list or Material Safety Data
    Sheet (MSDS) to the local fire department,  LEPC, and SERC.

312 - requires an annual report including quantities of chemicals
    characterized  by hazard (Tier 1 report) or as individual chemicals (Tier II
    report) to be submitted to the local fire department, LEPC, and SERC.

313 - An annual report by manufacturing facilities only of emissions to air,
    water, or ground of chemicals on a list of about 300.

321 - in general, Title III does not preempt state laws; states and localities may
    require supplementary information.

322 - allows manufacturers to claim chemical identity as trade secret if they
    meet several conditions.

323 - allows some doctors, nurses, and public health officials to obtain even
    information declared trade secret if they need it for treating patients and
    they promise not to disclose the information further.

326 - provides for lawsuits under certain circumstances by citizens against
    facilities that do not comply with the law and against agencies that do not
    fulfill their duties, and  allows state and local governments to sue facilities.

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              Appendix 4

               Contacts
     The Emergency Planning and
     Community Right-To-Know
            Act of 1986
State  Emergency  Response
    Commission/Title  III
            Contacts
        November  1,  1989
              Prepared by
    The Emergency Planning and Community
     Right-To-Know Information Hotline
           For more information call
             1-800-535-0202
     (or (202) 479-2449 in the Washington, DC metro area)

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               State  Emergency  Response Commission  and
                    State-Designated  Agencies for the
         Emergency Planning  and Community Right-to-Know Act
                             November 1, 1989
This list is the U.S. Environmental Protection Agency's listing of State Emergency
     Response Commissions and State designated agencies for the Emergency
     Planning and Community Right-to-Know Act. The EPA has verified each contact
     individually. All addresses listed under State Commissions receive the Section
     302  emergency planning notification and the Section 304 emergency release
     notification unless otherwise  specified. The State designated agencies receive
     the submissions for the sections listed in their headings. If one address is listed
     with  no heading, the State commission receives all submissions for every section
     of the Act. If an additional address is listed under the heading "Mailing Address,"
     this address is to be used for mailings to the State Commissions other than the
     P.O. boxes used for the form submissions.

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ALABAMA

State  Commission:
    J. Danny Cooper, Co-Chair
    Alabama Emergency Response Commission
    Director, Alabama Emergency Management
      Agency
    520 South Court Street
    Montgomery, AL 36130
    (205) 834-1375

    Contact: Dave White

Section 311/312 Submissions:
    Leigh Pegues, Co-Chair
    Alabama Emergency Response Commission

    Director, Alabama Department of Environmental
      Management
    1751 Congressman W.L. Dickinson Drive
    Montgomery, AL 36109
    (205)271-7700

    Contact:   L.G. Linn (205) 271 -7700
        E. John Williford  (205) 271 -7931

Section 313  Submissions:
    E. John Williford, Chief of Operations
    Alabama Emergency Response Commission
    Alabama Department of Environmental
      Management
    1751-Congressman W.L. Dickinson Drive
    Montgomery, AL 36109
    (205)271-7700

    Contact:    LG. Linn (205)271-7700
        E. John Williford  (205) 271 -7931
ALASKA

    Dennis Kelso, Chair
    Alaska State Emergency Response
      Commission
    P.O. Box O
    Juneau, AK 99811
    (907) 465-2600

    Mailing Address:
    Linda VanHouten
    Alaska State Emergency Response
      Commission
    9000, Old Glacier Highway
    P.O. Box 32420
    Juneau, AK 99803
AMERICAN SAMOA

State Commission:
    Maiava O. Hunkin
    Program Coordinator for the Territorial
      Emergency Management Coordination
      Office
    American Samoan Government
    P.O. Box 1086
    Pago Pago, American Samoa 96799
    International Number (684) 633-2331
Section  311/312  & 313  Submissions:
    Pati Faiai, Director
    American Samoa EPA
    Office of the Governor
    Pago Pago, American Samoa 96799
    International Number (684) 633-2304
ARIZONA

    Carl F. Funk, Executive Director
    Arizona Emergency Response Commission
    Division of Emergency Services
    5636 East McDowell Road
    Phoenix, AZ 85008
    (602)231-6326
ARKANSAS

State  Commission:
    Randall Mathis, Director
    Arkansas Department of Pollution Control and
      Ecology
    P.O. Box 9583
    8001 National Drive
    Little Rock, AR 72219
    (501) 562-7444
    Contact:  John Ward
(501)562-7444
Section  311/312 & 313  Submissions:
    Becky Bryant
    Depository of Documents
    Arkansas Department of Labor
    10421 West Markham
    Little Rock, AR 72205

    Contact: Becky Bryant (501)682-4534

Mailing Address:
Arkansas Department of Pollution Control and
      Ecology
P.O. Box 9583
8001 National Drive
Little Rock, AR 72219
Attn: John Ward
CALIFORNIA

State Commission:
    William Medigovich, Chair
    California Emergency Planning and Response
      Commission
    Director, Office of Emergency Services
    2800 Meadowview Road
    Sacramento, CA 95832
    (916)427-4287

Section 302, 304, 311/312 Submissions:
    California Emergency Planning and Response
      Commission
    Office of Emergency Services
    Hazardous Materials Division
    2800 Meadowview Road

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    Sacramento, CA 95832
    (916)427-4287

    Contacts: Gary Burton
        Michelle LaBella
        Dave Zocchetti

Section  313 Submissions:
    Chuck Shulock
    Office of Environmental Affairs
    P.O. Box 2815
    Sacramento, CA 95812
    Attn: Section 313 Reports
    (916)324-8124
    (916) 322-7236 Completed Form R Information
COLORADO

Stats Commission:
    David C. Shelton, Chair
    Colorado Emergency Planning Commission
    Colorado Department of Health
    4210 East 11th Avenue
    Denver, CO 80220
    (303)331-4880

    Emergency Release Notification:
        (303)331-4858
    After Hours & Weekends (Emergencies Only):
        (303) 377-6326

Section  302,  304,  311/312 &  313
      Submissions:
    Colorado Emergency Planning Commission
    4210 East 11th Avenue
    Denver, CO 80220
    Contact: Judy Waddill
CONNECTICUT
(303)331-4858
    Sue Vaughn, Title III Coordinator
    State Emergency Response Commission
    Department of Environmental Protection
    State Office Building, Room 161
    165 Capitol Avenue
    Hartford, CT 06106
    (203) 566-4856
DELAWARE

State Commission:
    Patrick W. Murray, Chair
    Delaware Commission on Hazardous Materials
    Department of Public Safety
    P.O. Box 818
    Dover, DE 19903

    Contact: George Frick  (302) 736-3169

Section  302 Submissions:
    Dpminick Petrilli, Acting Director
    Division of Emergency Planning and
      Operations
    P.O. Box 527
    Delaware City, DE 19706
    (302) 834-4531

Section  304 Submissions:
    Phillip Retallick, Director
    Division of Air and Waste Management
    Department of Natural Resources and
      Environmental Control
    Richardson and Robbins Building
    89 Kings Highway
    P.O. Box 1401
    Dover, DE 19903
    (302) 736-4764

Section  311/312  Submissions:
    Dr. Lawrence Krone, Chief
    Bureau of Environmental Health
    Jesse Cooper Building
    Federal Street
    P.O. Box 637
    Dover, DE 19903
    (302) 736-4731

Section  313 Submissions:
    Robert French, Chief Program Administrator
    Air Resource Section
    Department of Natural Resources and
      Environmental Control
    P.O. Box 1401
    Dover, DE 19903
    (302) 736-4791

DISTRICT  OF  COLUMBIA

    Joseph P. Yeldell, Chair
    State Emergency Response Commission for
      Title III
      in the District of Columbia
    Office of Emergency Preparedness
    2000 14th Street, NW
    Frank Reeves Center for Municipal Affairs
    Washington, DC 20009
    (202)727-6161

    Contact: Pamela Thurber, Environmental
      Planning Specialist
                        FLORIDA

                            Mr. Thomas G. Pelham, Chair
                            Florida Emergency Response Commission
                            Secretary, Florida Department of Community
                              Affairs
                            2740 Centerview Drive
                            Tallahassee, FL 32399-2149
                            (904) 488-1472
                            In FL: 800-635-7179

                            Contact: Eve Rainey

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GEORGIA

State Commission:
    Mr. J. Leonard Ledbetter, Chair
    Georgia Emergency Response Commission
    Commissioner, Georgia Department of Natural
      Resources
    205 Butler Street, SE
    Floyd Towers East, 11th floor
    Atlanta, GA 30334
    (404) 656-4713

Section  302, 304, 311/312  & 313
      Submissions:
    Jimmy Kirkland
    Georgia Emergency Response Commission
    205 Butler Street, SE
    Floyd Tower East
    11th Floor, Suite 1166
    Atlanta, GA 30334
    (404) 656-6905
    Emergency Release Number (800) 241-4113
GUAM

State Commission & Section 311/312
      Submissions:
    Dr. George Boughton, Chair
    Guam State Emergency Response
      Commission
    Civil Defense
    Guam Emergency Services Office
    Government of Guam
    P.O. Box 2877
    Aguana, Guam 96910
    (671)472-7230
    FTS 550-7230

Section  313  Submissions:
    Roland Solidio
    Guam EPA
    P.O. Box 2999
    Aguana, Guam 96910
    (671)646-8863
HAWAII

State Commission and Section  311/312
      Submissions:
    Bruce S. Anderson, Ph.D., Vice-Chair
    Hawaii State Emergency Response
      Commission
    Hawaii Department of Health
    P.O. Box 3378
    Honolulu, HI 96801
    (808) 548-2076
    (808) 548-5832
    Contact:
Samir Araman
Mark Ingoglia
(808) 543-8249
(808) 543-8276
Section 313 Submissions:
    John C. Lewin, M.D., Chair
    Hawaii State Emergency Response
     Commission
    Hawaii State Department of Health
                                           P.O. Box 3378
                                           Honolulu, HI 96801-9904
                                           (808) 548-6505
                                       State Commission:
                                           Idaho Emergency Response Commission
                                           State House
                                           Boise, ID 83720
                                           (208) 334-5888

                                       Section 311/312 &  313 Submissions:
                                           Idaho Emergency Response Commission
                                           State House
                                           Boise, ID 83720
                                           Attn: Jenny Records

                                           Contact: Jenny Records (208) 334-5888
                                       ILLINOIS

                                       State Commission and Section  311/312
                                             Submissions:
                                           Oran Robinson
                                           Illinois Emergency Response Commission
                                           Illinois Emergency Services & Disaster Agency
                                           Attn: Hazmat Section
                                           110 East Adams Street
                                           Springfield, IL 62706
                                           (217)782-4694

                                       Section  313 Submissions:
                                           Joe Goodner
                                           Emergency Planning Unit
                                           Illinois EPA
                                           P.O. Box 19276
                                           2200 Churchill Road
                                           Springfield, IL 62794-9276
                                           (217) 782-3637
                                       INDIANA

                                           Skip Powers, Director
                                           Indiana Emergency Response Commission
                                           5500 West Bradbury Avenue
                                           Indianapolis, IN 46241
                                           (317)243-5176
IOWA

State Commission  & Section 302
     Submissions:
    Ellen Gordon, Chair
    Iowa Disaster Services
    Hoover Building, Level A
    Room 29
    Des Moines, IA 50319
    (515) 281-3231

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Section  304  Submissions:
    Department of Natural Resources
    Division of Environmental Protection
    Emergency Response Section
    Wallace Building, 5th Floor
    Des Moines, IA  50319
    (515) 281-8694

    Contact:   Ron Kozel

Section  311/312  Submissions:
    Iowa Emergency Response Commission
    Division of Labor
    1000 East Grand Avenue
    Des Moines, IA 50319
    (515)281-6175

    Contact:   Don Peddy

Section  313  Submissions:
    Department of Natural Resources
    Records Department
    900 East Grand Avenue
    Des Moines, IA 50319
    (515)281-8852

    Contact:  Pete Hamlin
KANSAS

State Commission:
    Karl Birns, Staff Director
    Kansas Emergency Response Commission
      and
    Community Right-To-Know Program
    Mills Building, 5th Floor
    109 S.W. 9th Street
    Topeka, KS 66612
    (913) 296-1690

Section  302 & 304 Submissions:
    Karl Birns
    Kansas Department of Hea|th and Environment
    Right-to-Know Program
    Mills Building, 5th Floor
    109 S.W. 9th Street
    Topeka, KS 66612
    (913)296-1690
    Emergency Release Number Only (24 hrs):
      (913)296-3176

Section  311/312 & 313 Submissions:
    Right -to- Know Program
    Kansas Department of Health and Environment
    Mills Building, 5th Floor
    109 S.W. 9th Street
    Topeka, KS 66612
    (913)296-1690

    Contact:   Karl Birns

KENTUCKY

State Commission & Section 311/312
      Submissions:
    Colonel James H. "Mike" Molloy, Chair
    Kentucky Emergency Response Commission
    Kentucky Disaster and Emergency Services
    Boone National Guard Center        .,   '
    Frankfort, KY 40601-6168
    (502) 564-8660
    (502)564-8682

    Contact:   Mike Molloy or Craig Martin

Section  313 Submissions:
    Valerie Hudson
    Kentucky Department of Environmental
      Protection
    18ReillyRoad                        -
    Frankfort, KY 40601
    (502) 564-2150

    Mailing Address:
    Lucille Orlando
    SARA Title III
    Kentucky Department of Environmental
      Protection
    Kentucky Disaster and Emergency Services
    Boone National Guard Center
    Frankfort, KY 60601-6161
LOUISIANA

State Commission & Section 311/312
      Submissions:
    Sergeant Ronnie Mayeaux
    Louisiana Emergency Response Commission
    Office of State Police
    P.O. Box66614
    7901  Independence Boulevard
    Baton Rouge, LA 70896
    (504)925-6113

Section  313 Submissions:
    R. Bruce Hammatt
    Emergency Response Coordinator
    Department of Environmental Quality
    P.O. Box 44066
    333 Laurel Street
    Baton Rouge, LA 70804-4066
    (504) 342-8617
MAINE

    David D. Brown, Chair       /
    State Emergency Response Commission
    Station Number 72
    Augusta, ME 04333
    (207) 289-4080
    (800)452-8735 in ME

    Contact:   Tammy Gould

MARYLAND

State Commission:
    June L. Swem
    Governor's Emergency Management Agency
    c/o Maryland Emergency Management Agency
    2 Sudbraok Lane, East
    Pikesville, MD21208
    (301)486-4422

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Section 302, 304,  311/312  & 313
      Submissions:
    Marsha Ways
    State Emergency Response Commission
    Maryland Department of the Environment
    Toxics Information Center
    2500 Broening Highway
    Baltimore, MD 21224
    (301)631-3800
MASSACHUSETTS

    Arnold Sapenter
    c/o Title Three Emergency Response
      Commission
    Department of Environmental Quality
      Engineering
    One Winter Street, 10th floor
    Boston, MA 02108
    (617) 292-5993
    For LEPC Information: Jack Callahan (508) 820-
      2060
MICHIGAN

    Title III,Coordinator
    Michigan Department of Natural Resources
    Environmental Response Division
    Title III Notification
    P.O. Box 30028
    Lansing, Ml 48909
    (517)373-8481
MINNESOTA

    Lee Tischler, Director
    290 Bigelow Building
    450 North Syndicate
    St. Paul, MN 55155
    (612) 643-3000
MISSISSIPPI

    J.E. Maher, Chair
    Mississippi Emergency Response Commission
    Mississippi Emergency Management Agency
    P.O. Box 4501
    Fondren Station
    Jackson, MS 39296-4501
    (601)960-9973

    Contact:   Bill Austin
MISSOURI

    Dean Martin, Coordinator
    Missouri Emergency Response Commission
    Missouri Department of Natural Resources
    P.O. Box 3133
    Jefferson City, MO 65102
    (314)751-7929
Mailing Address:
Dean Martin
Missouri Emergency Response Commission
Missouri Department of Natural Resources
2010 Missouri Boulevard
Jefferson City, MO 65109
MONTANA

    Tom Ellerhoff, Co-Chair
    Montana Emergency Response Commission
    Environmental Sciences Division
    Department of Health & Environmental
      Sciences
    Cogswell Building A-107
    Helena, MT 59620
    (406)444-6911
    Contact: Guy Youngblood
NEBRASKA

    Clark Smith, Coordinator
    Nebraska Emergency Response Commission
    Nebraska Department of Environmental Control
    P.O. Box 98922
    State House Station
    Lincoln, NE 68509-8922
    (402) 471-2186
    Emergency Number (After-hours): (402) 471 -
      4545
NEVADA

State Commission  and  Section 311/312
      Submissions:
    Joe Quinn
    Nevada Division of Emergency Management
    2525 South Carson Street
    Carson City, NV 89710
    (702)885-4240
    Emergency Release Number (After Hours &
      Weekends): (702) 885-5300
         /
Section  313  Submission:
    Bob King
    Division of Emergency Management
    2525 South Carson Street
    Carson City, NV 89710
    (702) 885-4240

NEW HAMPSHIRE

    Gerorge L. Iverson, Director
    State Emergency Management Agency
    Title III Program
    State Office Park South
    107 Pleasant Street
    Concord, NH 03301
    (603) 271-2231

    Contact:    Leland Kimball

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NEW  JERSEY

State Commission:
    Tony McMahon, Director
    New Jersey Emergency Response
      Commission
    SARA Titte III Project
    Department of Environmental Protection
    Division of Environmental Quality
    CN-405
    Attn: 304 Notification
    Trenton, NJ 08625
    (609) 292-6714
    Emergency Number: (609) 292-7172

Section  302,  311/312 Submissions
    New Jersey Emergency Response
      Commission
    SARA Title III Project
    Department of Environmental Protection
    Division of Environmental Quality
    CN-405
    Trenton, NJ 08625
    (609) 292-6714

Ssction  304 Submissions:
    New Jersey Emergency Response
      Commission
    SARA Trtte III Project
    Department of Environmental Protection
    Division of Environmental Quality
    CN-027
    Trenton, NJ 08625
    (609) 292-6714

Section  313 Submissions:
    New Jersey Emergency Response
      Commission
    SARA Trtte 111 Section 313
    Department of Environmental Protection
    Division of Environmental Quality
    Bureau of Hazardous Substances Information
    CN-405
    Trenton, NJ 08625
    (609) 292-6714

NEW  MEXICO

    Samuel Larcombe
    New Mexico Emergency Response
      Commission
    New Mexico Department of Public Safety
    P.O. Box 1628
    Santa Fe, NM 87504-1628
    (505) 827-9222
NEW  YORK

State Commission:
    Anthony Germano, Deputy Director
    State Emergency Management Office
    Building 22
    State Campus
    Albany, NY 12226
    (518) 457-9996
Section 302,  304,  311/312 & 313
     Submissions:
    New York Emergency Response Commission
    New York State Department of Environmental
     Conservation
    Bureau of Spill Response
    50 Wolf Road/Room 326
    Albany, NY 12233-3510
    (518)457-4107

    Contact: William Miner
NORTH CAROLINA

State Commission:
    Joseph Myers, Chair
    North Carolina Emergency Response
      Commission
    116 West Jones Street
    Raleigh, NC 27603-1335
    (919) 733-3867

Section 302,  304, 311/312  & 313
      Submissions:
    North Carolina Emergency Response
      Commission
    North Carolina Division of Emergency
      Management
    116 West Jones Street
    Raleigh, NC 27603-1335
    (919) 733-3867
    (800)451-1403 (In NC General Information
      Only)
    Contacts:  Vance Kee
               Emily Kilpatrick


NORTH DAKOTA
(919) 733-3844
(919) 733-3865
State Commission:
    Ronald Affeldt, Chair
    North Dakota Emergency Response
      Commission
    Division of Emergency Management
    P.O. Box 5511
    Bismark, ND 58502-5511
    (701)224-2111

Section 302,  311/312 &  313 Submissions:
    SARA Title III Coordinator
    North Dakota State Department of Health and
       Consolidated
      Laboratories
    1200 Missouri Avenue
    P.O. Box 5520
    Bismarck, ND 58502-5520
    (701)224-2374

    Contact:   Charles Rydell

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 COMMONWEALTH  of  NORTHERN
      MARIANA  ISLANDS

 State  Commission  and  Section 311/312
      Submissions:
    Felix A. Sasamoto, Civil Defense Coordinator
    Office of the Governor
    Capitol Hill
    Commonwealth of Northern Mariana Islands
    Saipan, CNMI96950
    International Number (670) 322-9529
 Section 313  Submissions:
    Russell Meecham, III
    Division of Environmental Quality
    P.O. Box 1304
    Saipan, CNMI 96950
    (670) 234-6984
OHIO

State  Commission  and Section  311/312
      Submissions:
    Ken Schultz, Coordinator
    Ohio Emergency Response Commission
    Ohio Environmental Protection Agency
    Office of Emergency Response
    P.O. Box 1049
    Columbus, OH 43266-0149
    (614) 644-2260

Section  313  Submissions:
    Cindy Sferra-DeWulf
    Division of Air Pollution Control
    1800 Watermark Drive
    Columbus, OH 43215
    (614) 644-2266
OKLAHOMA

    Emergency Response Commission
    Office of Civil Defense
    P.O.  Box 53365
    Oklahoma City, OK 73152
    (405)521-2481

    Contact:  Aileen Ginther
OREGON

    Ralph M. Rodia
    Oregon Emergency Response Commission
    c/o State Fire Marshall
    3000 Market Street Plaza
    Suite 534
    Salem, OR 97310
    (503) 378-2885
PENNSYLVANIA

State Commission:
    Richard Rodney
    Pennsylvania Emergency Response
      Commission
    SARA Title III Officer
    PEMA Response and Recovery
    P.O. Box 3321
    Harrisburg, PA17105
    (717) 783-8150
    Emergency Release Number — 24 hours (717)
      783-8150

Section 311/312  Submissions:
    Pennsylvania Emergency Response   ,
      Commission
    c/o Bureau of Right-to-Know
    Rm 1503
    Labor and Industry Building
    7th & Forrester Streets
    Harrisburg, PA 17120
    (717)783-2071

Section  313 Submissions:
    James Tinney
    Bureau of Right -To- Know
    Room 1503
    Labor and Industry Building
    7th & Forrester Streets
    Harrisburg, PA 17120
    (717) 783-2071
PUERTO  RICO

Sliate Commission and Section  311/312
      Submissions:
    Mr. Santos Rohena, Chair
    Puerto Rico  Emergency Response
      Commission
    Environmental Quality Board
    P.O. Box 11488
    Sernades Juncos Station
    Santurce, PR 00910
    (809) 722-1175
    (809)722-2173

Section 313 Submissions:
    SERC Commissioner
    Title III-SARA Section 313
    Puerto Rico Environmental Quality Board
    P.O. Box 11488
    Santurce, PR 00910
    (809) 722-0077
RHODE  ISLAND

State Commission:
    Charles Givens, Acting Executive Director
    Rhode Island Emergency Response
      Commission
    State House Room 27
    Providence, Rl 02903
    (401) 277-3039
    Emergency Release Number (401) 274-7745

    Contact:   John  Aucott

-------
Section  311/312  Submissions:
    Anthony Diccio
    Rhode Island Department of Labor
    Division of Occupational Safety
    220 Elmwood Avenue
    Providence, Rl 02907
    (401) 457-1847

Section  313  Submissions:
    Department of Environmental Management
    Division of Air and Hazardous Materials
    291 Promenade Street
    Providence, RI 02908
    Attn: Toxic Release Inventory
    (401) 277-2808

    Contact:   Martha Mulcahey

SOUTH  CAROLINA

State Commission and Section 302
      Submissions:
    Stan M. McKinney, Chair
    South Carolina Emergency Response
      Commission
    Division of Public Safety Programs
    Office of the Governor
    1205 Pendleton Street
    Columbia, SC 29201
    (803) 734-0425

Section  304  & 311/312  Submissions:
    South Carolina Emergency Response
      Commission
    Division of Public Safety Programs
    Office of the Governor
    1205 Pendleton Street
    Columbia, SC 29201
    Attn:  Purdy McLeod
    (803) 734-0425

Section  313  Submissions:
    Ron Kinney
    Department of Health and Environmental
      Control
    2600 Bull Street
    Columbia, SC 29201
    (803) 734-5200
SOUTH  DAKOTA

State Commission and Section  311/312
      Submissions:
    Clark Haberman, Director
    South Dakota Emergency Response
      Commission
    Department of Water and Natural Resources
    Joe Foss Building
    523 East Capitol
    Pierre, SD 57501-3181
    (605) 773-3151

Section  313 Submissions:
    Lee Ann Smith, Director
    South Dakota Emergency Response
      Commission
    Department of Water and Natural Resources
    Joe Foss Building
    523 East Capitol
    Pierre, SD 57501-3181
    (605) 773-3153
TENNESSEE

    Mr. Lacy Suiter, Chair
    Tennessee Emergency Response
      Commission
    Director, Tennessee Emergency Management
      Agency
    3041 Sidco Drive
    Nashville, TN 37204
    (615) 252-3300
    (800) 258-3300 (out of TN)
    (800) 262-3300 (in TN)

    Contact: Lacy Suiter or Tom Durham
TEXAS

State Commission:
    David Haun, Coordinator
    Texas Emergency Response Commission
    Division of Emergency Management
    P.O. Box 4087
    Austin, TX 78773-0001
    (512) 465-2138

Section  302,  311/312  Submissions:
    Dr. William Elliot
    Texas Department of Health
    Division of Occupational Safety and Health
    1100 West 49th Street
    Austin, TX 78756
    (512)458-7410

Section 313 Submissions:
    David Barker, Supervisor
    Emergency Response Unit
    Texas Water Commission
    P.O. Box 13087-Capitol Station
    Austin, TX 78711-3087
    (512) 463-8527

    Contact:   Priscilla Seymour
State Commission:
    Lorayne Frank, Director
    Comprehensive Emergency Management
    P.O. Box 58136
    1543 Sunnyside Avenue
    Salt Lake City, UT 84158-0136
    (801) 584-8370

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Section  311/312 &  313  Submissions:
    Neil Taylor
    Utah Hazardous Chemical Emergency
      Response Commission
    Utah Division of Environmental Health
    288 North 1460 West
    P.O. Box 16690
    Salt Lake City, UT 84116-0690
    (801)538-6121
VERMONT

State Commission:
    Jeanne VanVlandren, Chair
    Vermont Emergency Response Commission
    Department of Labor and Industry
    5 Court Drive
    Montpelier, VT 05602
    (802) 828-2286

    Contact: Robert McLeod  (802) 828-2765

Section  311/312  & 313 Submissions:
    Dr. Jan Carney, Commissioner
    Department of Health
    60 Main Street
    P.O. Box 70
    Burlington, VT 05402
    (802) 863-7281
    Mail Stop GH-51
    9th and Columbia Building
    Oiympia, WA 98504
    (206) 753-5625

    Contact:   Bill Bennett      (206)459-9191
               (800) 633-7585 (in WA)

Section  311/312 and  313  Submission:
    John Ridgway, Chair
    Washington State Department of Ecology
    Hazardous Substance Information Office
    MS-PV/11
    Oiympia, WA 98504
    (206) 438-7252
WEST VIRGINIA

    Carl L. Bradford, Director
    West Virginia Emergency Response
      Commission
    West Virginia Office of Emergency Services
    State Capital Building 1, Rm. EB-80
    Charleston, WV 25305
    (304) 348-5380
    Emergency Release Number (304) 348-5380

    Contact:    BillJopling
VIRGIN ISLANDS

    Allan D. Smith, Commissioner
    Department of Planning and Natural Resources

    U.S. Virgin Islands Emergency Response
      Commission
    Title III
    Suite 231
    Nisky Center
    Charlotte Amalie
    St. Thomas, VI 00802
    (809) 774-3320 Extension 169 or 170

    Contact:  Gregory Rhymer
VIRGINIA

    Wayne Halbleib, Director
    Virginia Emergency Response Council
    Department of Waste Management
    James Monroe Building
    14th Floor
    101 North 14th Street
    Richmond, VA23219
    (804) 225-2513
WASHINGTON

State Commision:
    Chuck Clarke
    Washington Emergency Response
      Commission
    Department of Community Development
WISCONSIN

State Commission:
    Richard I. Braund, Director
    Wisconsin Emergency Response Commission
    Division of Emergency Government
    4802 Sheboygan Avenue
    P.O. Box 7865
    Madison, Wl 53707
    (608) 266-3232

Section  313 Submissions:
    Department of Natural Resources
    P.O. Box 7921
    Madison, Wl 53707
    Attn: Russ Dumst
    (608) 266-9255

WYOMING

    Ed Usui, Executive Secretary
    Wyoming Emergency Response Commission
    Wyoming Emergency Management Agency
    Comprehensive Emergency Management
    P.O. Box 1709
    Cheyenne, WY 82003
    (307) 777-7566
    Contact:  Brooke Hefner

Mailing Address:
Ed Usui
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
Comprehensive Emergency Management
5500 Bishop Boulevard
Cheyenne, WY 82009

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                                          APPENDIX  5
                                Extremely Hazardous Substances
 CAS Number     Chemical Name
 75865     ACETONE CYANOHYDRIN
 1752303   ACETONE THIOSEMICARBAZIDE
 107028    ACROLEIN
 79061     ACRYLAMIDE
 107131    ACRYLONITRILE
 814686    ACRYLYL CHLORIDE
 111693    ADIPONITRILE
 116063    ALDICARB
 309002    ALDRIN
 107186    ALLYL ALCOHOL
 107119    ALLYLAMINE
 20859738  ALUMINUM PHOSPHIDE
 54626     AMINOPTERIN
 78535     AMITON
 3734972   AMITON OXALATE
 7664417   AMMONIA
 300629    AMPHETAMINE
 62533     ANILINE
 88051     ANILINE, 2,4,6-TRIMETHYL-
 7783702   ANTIMONY PENTAFLUORIDE
 1397940   ANTIMYCINA
 86884     ANTU
 1303282   ARSENIC PENTOXIDE
 1327533   ARSENOUS OXIDE
 7784341   ARSENOUS TRICHLORIDE
 7784421   ARSINE
 2642719   AZINPHOS-ETHYL
 86500     AZINPHOS-METHYL
 98873     BENZAL CHLORIDE
 98168     BENZENAMINE, S-(TRIFLUOROMETHYL)-
 100141    BENZENE, 1-(CHLOROMETHYL)-4-NITRO-
 98055     BENZENEARSONICACID
 3615212   BENZIMIDAZOLE.4.5-DICHLORO-2-
          (TRIFLUOROMETHYL)-
 98077     BENZOTRICHLORIDE
 100447    BENZYL CHLORIDE
 140294    BENZYL CYANIDE
 15271417  BICYCLO[2.2.1 ]HEPTANE-2-
          CARBONITRILE, 5-CHLORO-6-
          ((((METHYLAMINO)CARBONYL)OXY)IM
 534076    BIS(CHLOROMETHYL) KETONE
 4044659   BITOSCANATE
 10294345  BORON TRICHLORIDE
 7637072   BORON TRIFLUORIDE
 353424    BORON TRIFLUORIDE COMPOUND WITH
          METHYL ETHER (1:1)
 28772567  BROMADIOLONE
 7726956   BROMINE
 1306190   CADMIUM OXIDE
 2223930   CADMIUM STEARATE
 7778441   CALCIUM ARSENATE
 8001352   CAMPHECHLOR
 56257     CANTHARIDIN
 51832     CARBACHOL CHLORIDE
 26419738  CARBAMIC ACID, METHYL-, O-(((2,4-
          DIMETHYL-1.3-DITHIOLAN-2-
          METHYL)METHYLENE)AMINO)-
 1563662   CARBOFURAN
 75150     CARBON DISULFIDE
 786196    CARBOPHENOTHION
57749     CHLORDANE
470906    CHLORFENVINFOS
 7782505   CHLORINE
 CAS Number
Chemical Name
 24934916  CHLORMEPHOS
 999815    CHLORMEQUAT CHLORIDE
 79118     CHLOROACETIC ACID
 107073    CHLOROETHANOL
 627112    CHLOROETHYL CHLOROFORMATE
 67663     CHLOROFORM
 542881    CHLOROMETHYL ETHER
 107302    CHLOROMETHYL METHYL ETHER
 3691358   CHLOROPHAC1NONE
 1982474   CHLOROXURON
 21923239  CHLORTHIOPHOS
 10025737  CHROMIC CHLORIDE
 10210681  COBALT CARBONYL
 62207765  COBALT, ((2,2'-(1,2-ETHANEDIYLBIS
          (NITRILOMETHYLIDYNE))BIS(6-
              FLUOROPHENOLATO))
 64868     COLCHICINE
 56724     COUMAPHOS
 5836293   COUMATETRALYL
 95487     CRESOL, o-
 535897    CRIMIDINE
 4170303   CROTONALDEHYDE
 123739    CROTONALDEHYDE, (E)-
 506683    CYANOGEN BROMIDE
 506785    CYANOGEN IODIDE
 2636262   CYANOPHOS
 675149    CYANURIC FLUORIDE
 66819     CYCLOHEXIMIDE
 108918    CYCLOHEXYLAMINE
 17702419  DECABORANE(14)
 8065483   DEMETON
 919868    DEMETON-S-METHYL
 10311849  DIAL1FOR
 19287457  DIBORANE
 111444    DICHLOROETHYL ETHER
 149746    DICHLOROMETHYLPHENYLSILANE
 62737     DICHLORVOS
 141662    DICROTOPHOS
 1464535   DIEPOXYBUTANE
 814493    DIETHYL CHLOROPHOSPHATE
 1642542   DIETHYLCARBAMAZINE CITRATE
 71636     DK3ITOXIN
 2238075   DIGLYCIDYL ETHER
 20830755  DK3OXIN
 115264    DIMEFOX
 60515     DIMETHOATE
 2524030   DIMETHYL
          PHOSPHOROCHLORIDOTHIOATE
 77781      DIMETHYL SULFATE
 75183     DIMETHYL SULFIDE
 99989     DIMETHYL-p-PHENYLENEDIAMINE
 75785     DIMETHYLDICHLOROSILANE
 57147     DIMETHYLHYDRAZINE
 644CJ44    DIMETILAN
 534521     DINITROCRESOL
 88857     DINOSEB
 1420071    DINOTERB
 78342      DIOXATHION
 82666      DIPHACINONE
 152169    DIPHOSPHORAMIDE, OCTAMETHYL-
298044    DISULFOTON
514738    DITHIAZANINE IODIDE
541537    DITHIOBIURET

-------
 CAS Number    Chemical Name
 316427    EMETINE, DIHYDROCHLORIDE
 115297    ENDOSULFAN
 2778043   ENDOTHION
 72208     ENDRIN
 106898    EPICHLOROHYDRIN
 2104645   EPN
 50146     ERGOCALCIFEROL
 379793    ERGOTAMINETARTRATE   i
 1622328   ETHANESULFONYL CHLORIDE, 2-
          CHLORO-10140871 ETHANOL, 1,2-
          DICHLORO-, ACETATE     \
 563122    ETHION
 13194484  ETHOPROPHOS
 538078    ETHYLBIS(2-CHLOROETHYL)AMINE
 371620    ETHYLENE FLUOROHYDRIN
 75218     ETHYLENE OXIDE
 107153    ETHYLENEDIAMINE
 151564    ETHYLENEIMINE
 542905    ETHYLTHIOCYANATE
 22224926  FENAMIPHOS
 122145    FENITROTHION
 115902    FENSULFOTHION
 4301502   FLUENETIL
 7782414   FLUORINE
 640197    FLUOROACETAMIDE
 144490    FLUOROACETIC ACID
 359068    FLUOROACETYL CHLORIDE
 51218     FLUOROURACIL
 944229    FONOFOS
 50000     FORMALDEHYDE
 107164    FORMALDEHYDE CYANOHYDRIN
 23422539  FORMETANATE HYDROCHLORIDE
 2540821   FORMOTHION
 17702577  FORMPARANATE
 21548323  FOSTHIETAN
 3878191   FUBERIDAZOLE
 110009    FURAN
 13450903  GALLIUM TRICHLORIDE
 77474     HEXACHLOROCYCLOPENTADIENE
 4835114   HEXAMETHYLENEDIAMINE, N.N'-DIBUTYL-
 302012    HYDRAZINE
 74908     HYDROCYANIC ACID
 7647010   HYDROGEN CHLORIDE (Gas Only)
 7664393   HYDROGEN FLUORIDE
 7722841   HYDROGEN PEROXIDE (Conc.> 52%)
 7783075   HYDROGEN SELENIDE
 7783064   HYDROGEN SULFIDE
 123319    HYDROQUINONE
 13463406  IRON, PENTACARBONYL-
 297789    ISOBENZAN
 78820     ISOBUTYRONITRILE
 102363    ISOCYANIC ACID, 3,4-DICHLOROPHEN YL
          ESTER
 465736    ISODRIN
 55914     ISOFLUORPHATE
 4098719   ISOPHORONE DIISOCYANATE
 108236    SOPROPYL CHLOROFORMATE
 625558    ISOPROPYL FORMATE
 119380    ISOPROPYLMETHYLPYRAZOLYL
          DIMETHYLCARBAMATE
 78977     LACTONITRILE
21609905  LEPTOPHOS
541253    LEWISITE
58899     LINDANE
7580678   LfTHIUM HYDRIDE
 109773    MALONONITRILE
 CAS Number
Chemical Name
 12108133  MANGANESE, TRICARBONYL
          METHYLCYCLOPENTADIENYL
 51752     MECHLORETHAMINE
 950107    MEPHOSFOLAN
 1600277   MERCURIC ACETATE
 7487947   MERCURIC CHLORIDE
 21908532  MERCURIC OXIDE
 10476956  METHACROLEIN DIACETATE
 760930    METHACRYLIC ANHYDRIDE
 126987    METHACRYLONITRILE
 920467    METHACRYLOYL CHLORIDE
 30674807  METHACRYLOYLOXYETHYLISOCYANATE
 10265926  METHAMIDOPHOS
 558258    METHANESULFONYL FLUORIDE
 950378    METHIDATHION
 2032657   METHIOCARB
 16752775  METHOMYL
 51382     METHOXYETHYLMERCURIC ACETATE
 80637     METHYL 2-CHLOROACRYLATE
 74839     METHYL BROMIDE
 79221     METHYL CHLOROFORMATE
 624920    METHYL DISULFIDE
 60344     METHYL HYDRAZINE
 624839    METHYL ISOCYANATE
 556616    METHYL ISOTHIOCYANATE
 74931     METHYL MERCAPTAN
 3735237   METHYL PHENKAPTON
 676971    METHYL PHOSPHONIC DICHLORIDE
 556649    METHYL THIOCYANATE
 78944     METHYL VINYL KETONE
 502396    METHYLMERCURICDICYANAMIDE
 75796     METHYLTRICHLOROSILANE
 1129415   METOLCARB
 7786347   MEVINPHOS
 315184    MEXACARBATE
 50077     MITOMYCIN C
 6923224   MONOCROTOPHOS
 2763964   MUSCIMOL
 505602    MUSTARD GAS
 13463393  NICKEL CARBONYL
 54115     NICOTINE
 65305     NICOTINE SULFATE
 7697372   NITRIC ACID
 10102439  NITRIC OXIDE
 98953     NITROBENZENE
 1122607   NITROCYCLOHEXANE
 10102440  NITROGEN DIOXIDE
 62759     NITROSODIMETHYLAMINE
 991424    NORBORMIDE
          OORGANORHODIUM COMPLEX(PMN-82-
          147)
 630604    OUABAIN
 23135220  OXAMYL
 78717     OXETANE, 3,3-BIS(CHLOROMETHYL)-
 2497076   OXYDISULFOTON
 10028156  OZONE
 1910425   PARAQUAT
 2074502   PARAQUAT METHOSULFATE
 56382     PARATHION
 298000    PARATHION-METHYL
 12002038  PARIS GREEN
 19624227  PENTABORANE
2570265   PENTADECYLAMINE
79210     PERACETICACID
594423    PERCHLOROMETHYLMERCAPTAN
 108952    PHENOL
97187     PHENOL, 2,2'-THIOBIS(4,6-DICHLORO-

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CAS Number
4418660
              Chemical Name
           PHENOL, 2,2'-THIOBIS[4-CHLORO-6-
           METHYL-
 64006      PHENOL, 3-(1-METHYLETHYl)-,
           METHYLCARBAMATE
 58366      PHENOXARSINE, 10,10'-OXYDI-
 696286     PHENYL DICHLOROARSINE
 59881      PHENYLHYDRAZINE HYDROCHLORIDE
 62384      PHENYLMERCURY ACETATE
 2097190    PHENYLSILATRANE
 103855     PHENYLTHIOUREA
 298022     PHORATE
 4104147    PHQSACETIM
 947024     PHOSFOLAN
 75445      PHOSGENE
 732116     PHOSMET
 13171216   PHOSPHAMIDON
 7803512    PHOSPHINE
 2703131    PHOSPHONOTHIOIC ACID,,METHYL-, O-
           ETHYLO-(4-
                (METHYLTHIO)PHENYL) ESTER
 50782699   PHOSPHONOTHIOIC ACID, METHYL-, S-(2-
           (BIS(1 -METHYLETHYL)AMINO)ETHYL) O-
           ETHYL ESTER
 2665307    PHOSPHONOTHIOIC ACID, METHYL-,O-(4-
 NITROPHENYL) 0-PHENYL ESTER
 3254635    PHOSPHORIC ACID, DIMETHYL 4-
           (METHYLTHIO) PHENYL ESTER
 2587908    PHOSPHOROTHIOIC ACID.O.O-DIMETHYL-
           5-(2-(METHYLTHIO)ETHYL)ESTER
 7723140    PHOSPHORUS
 10025873   PHOSPHORUS OXYCHLORIDE
 10026138   PHOSPHORUS PENTACHLORIDE
 1314563    PHOSPHORUS PENTOXIDE
 7719122    PHOSPHORUS TRICHLORIDE
 57476      PHYSOSTIGMINE
 57647      PHYSOSTIGMINE, SALICYLATE (1:1)
 124878     PICROTOXIN
 110894     PIPERIDINE
 5281130    PIPROTAL
 23505411    PIRIMIFOS-ETHYL
 10124502   POTASSIUM ARSENITE
 151508     POTASSIUM CYAN IDE
 506616     POTASSIUM SILVER CYANIDE
 2631370    PROMECARB
 106967     PROPARGYL BROMIDE
 57578      PROPIOLACTONE, beta-
 107120     PROPIONITRILE
 542767    PROPIONITRILE, 3-CHLORO-
 70699     PROPIOPHENONE.4-AMINO
 109615     PROPYL CHLOROFORMATE
 75569     PROPYLENE OXIDE
 75558     PROPYLENEIMINE
 2275185    PROTHOATE
 129000     PYRENE
 140761     PYRIDINE, 2-METHYL-5-VINYL-
504245     PYRIDINE, 4-AMINO-
 1124330    PYRIDINE, 4-NITRO-, 1 -OXIDE
53558251   PYRIMINIL
 14167181   SALCOMINE
 107448     SARIN
7783008    SELENIOUS ACID
7791233    SELENIUM OXYCHLORIDE
563417     SEMICARBAZIDE HYDROCHLORIDE
3037727    SILANE, (4-
          AMINOBUTYL)DIETHOXYMETHYL-
7631892    SODIUM ARSENATE
7784465    SODIUM ARSENITE
                                                     CAS Number
Chemical Name
                                                   26628228  SODIUM AZIDE (Na(N3))
                                                   124652    SODIUM CACODYLATE
                                                   143339    SODIUM CYANIDE (Na(CN))
                                                   62748     SODIUM FLUOROACETATE
                                                   131Ł>22    SODIUM PENTACHLOROPHENATE
                                                   13410010  SODIUM SELENATE
                                                   10102188  SODIUM SELENITE
                                                   10102202  SODIUM TELLURITE
                                                   900958    STANNANE,ACETOXYTRIPHENYL-
                                                   57249     STRYCHNINE
                                                   60413     STRYCHNINE, SULFATE
                                                   3689245   SULFOTEP
                                                   3569571   SULFOXIDE, 3-CHLOROPROPYL OCTYL
                                                   7446095   SULFUR DIOXIDE
                                                   7783600   SULFUR TETRAFLUORIDE
                                                   7446119   SULFUR TRIOXIDE
                                                   7664939   SULFURICACID
                                                   77816     TABUN
                                                   13494809  TELLURIUM   -
                                                   7783804   TELLURIUM HEXAFLUORIDE
                                                   107493     TEPP          ''
                                                   13071799  TERBUFOS •>.-".."•'
                                                   78002     TETRAETHYL LEAD
                                                   597648     TETRAETHYLTIN
                                                   75741     TETRAMETHYL LEAD
                                                   509148     TETRANITROMETHANE
                                                   10031591   THALLIUM SULFATE
                                                   6533739   THALLOUS CARBONATE
                                                   7791120   THALLOUS CHLORIDE
                                                   2757188   THALLOUS MALONATE
                                                   7446186   THALLOUS SULFATE
                                                   2231574   THIOCARBAZIDE
                                                   39196184  THIOFANOX
                                                   297972     THIONAZIN
                                                   108985     THIOPHENOL
                                                   79196     THIOSEMICARBAZIDE
                                                   5344821    THIOUREA, (2-CHLOROPHENYL)-
                                                   614788     THIOUREA, (2-METHYLPHENYL)-
                                                   7550450   TITANIUM TETRACHLOR1DE
                                                   584849     TOLUENE 2,4-DIISOCYANATE
                                                   91087     TOLUENE 2,6-DIISOCYANATE
                                                   110576     TRANS-1.4-DICHLOROBUTENE
                                                   1031476   TRIAMIPHOS
                                                   24017478   TRIAZOFOS
                                                   1558254   TRICHLORO(CHLOROMETHYL)SILANE
                                                   27137855   TRICHLORO(DICHLOROPHENYL)SILANE
                                                   76028     TRICHLOROACETYL CHLORIDE
                                                   115219     TRICHLOROETHYLSILANE
                                                   327980     TRICHLORONATE
                                                   98135     TRICHLOROPHENYLSILANE
                                                   998301     TRIETHOXYSILANE
                                                   75774     TRIMETHYLCHLOROSILANE
                                                   824113     TRIMETHYLOLPROPANE PHOSPHITE
                                                   1066451    TRIMETHYLTIN CHLORIDE
                                                   639587     TRIPHENYLTIN CHLORIDE
                                                   555771     TRIS(2-CHLOROETHYL)AMINE
                                                   2001958    VALINOMYCIN
                                                   1314621    VANADIUM PENTOXIDE
                                                   108054     VINYL ACETATE MONOMER
                                                   81812      WARFARIN
                                                   1290136     WARFARIN SODIUM
                                                   28347139   XYLYLENE DICHLORIDE
                                                   1314847    ZINC PHOSPHIDE
                                                   58270089   ZINC, DICHLORO(4,4-DIMETHYL-
                                                             5((((METHYLAMINO)
                                                             CARBONYL)OXY)IMINO)PENTANENITRILE)

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                                    APPENDIX  6

         SECTION 313 TOXIC CHEMICAL LIST FOR REPORTING YEAR 1988
                       Toxics Release Inventory Chemicals
                         (including Chemical Categories)
                            Alphabetical Chemical List
CAS Number Chemical Name
                             De Minimus Concentration
                             (percent)
75-07-0
60-35-5
67-64-1
75-05-8
53-96-3
107-02-8
79-06-1
79-10-7
107-13-1
309-00-2
107-05-1
7429-90-5
1344-28-1
117-79-3
60-09-3
92-67-1
82-28-0
7664-41-7
6484-52-2
7783-20-2
62-53-3
90-04-0
104-94-9
134-29-2
120-12-7
7440-36-0
7440-38-2
1332-21-4
7440-39-3
98-87-3
55-21-0
71-43-2
92-87-5
98-07-7

98-88-4
94-36-0
100-44-7
7440-41-7
92-52-4
111-44-4
542-88-1
108-60-1
103-23-1
75-25-2
Acetaldehyde
Acetamide
Acetone
Acetonitrile
2-Acetylaminofluorene
Acrolein
Acrylamide
Acrylic acid
Acrylonitrile
Aldrin
0.1
1.0
0.1
1.0
0.1
1.0
{1,4:5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexachloro-1,4,4a,
5,8,8a-hexahydro-(1 .alpha., 4.alpha.,4a.beta.,5.alpha., 8.alpha.,8a.beta.)-}
Allyl chloride                  1.0                            .
Aluminum (fume or dust)        1.0
Aluminum oxide               1.0
2-Aminoanthraquinone         0.1
4-Aminoazobenzene          0.1
4-Aminobiphenyl              0.1
1 -Amino-2-methylanthraquinone  0.1
Ammonia                    1.0
Ammonium nitrate (solution)     1.0
Ammonium sulfate (solution)    1.0
Aniline                       1.0
o-Anisidine                   0.1                                .
p-Anisidine                   1.0
o-Anisidine hydrochloride      0.1                   ..'....-•
Anthracene                  1.0
Antimony                    1.0
Arsenic                      0.1
Asbestos (friable)              0.1                         *
Barium                       1.0
Benzal chloride               1.0
Benzamide                   1.0
Benzene                    0.1
Benzidine                    0.1
Benzoic trichloride            0.1
(Benzotrichloride)
Benzoyl chloride              1.0
Benzoyl  peroxide             1.0
Benzyl chloride               1.0
Beryllium                    0.1
Biphenyl                     1.0
Bis(2-chloroethyl) ether        1.0                           ,
Bis(chloromethyl)  ether        0.1
Bis(2-chloro-1-methylethyl) etherl .0
Bis(2-ethylhexyl) adipate       0.1
Bromoform                   1.0                         ,

-------
74-83-9

106-99-0
141-32-2
71-36-3
78-92-2
75-65-0
85-68-7
106-88-7
123-72-8
4680-78-8
569-64-2
989-38-8
1937-37-7
2602-46-2
16071-86-6
2832-40-8
3761 -53-3
81-88-9
3118-97-6
97-56-3
842-07-9
492-80-8

128-66-5
7440-43-9
156-62-7
133-06-2

63-25-2

75-15-0
56-23-5
463-58-1
120-80-9
133-90-4

57-74-9

7782-50-5
10049-04-4
79-11-8
532-27-4
108-90-7
510-15-6
75-00-3

67-66-3
74-87-3

107-30-2
126-99-8
1897-45-6

7440-47-3
{Tribromomethane}
Bromomethane
(Methyl bromide}
1,3-Butadiene
Butyl acrylate
n-Butyl alcohol
sec-Butyl alcohol
tert-Butyl alcohol
Butyl benzyl phthalate
1,2-Butylene oxide
Butyraldehyde
C.I. Acid Green 3*
C.I. Basic Green 4*
C.I. Basic Red 1*
C.I. Direct Black 38*
C.I. Direct Blue 6*
C.I. Direct Brown 95*
C.I. Disperse Yellow 3*
C.I. Food Red 5*
C.I. Food Red 15*
C.I. Solvent Orange 7*
C.I. Solvent Yellow 3*
C.I. Solvent Yellow 14*
C.I. Solvent Yellow 34*
Auramine)
C.I. Vat Yellow 4*
Cadmium
Calcium cyanamide
Captan
1.0

0.1
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
1.0
0,1
1.0
1.0
1.0
0.1
1.0
1.0
{1 H-lsoindole-1,3(2H)-dione, 3a,4,7,7a-tetrahydro-2-[(trichloromethyl)thio]-}
Carbaryl                       1.0
{1-Naphthalenol, methylcarbamate}
Carbon disulfide               1.0
Carbon tetrachloride            0.1
Carbonyl sulfide               1.0
Catechol                      1.0
Chloramben                   1.0
{Benzoic acid, 3-amino-2,5-dichloro-}
Chlordane                     1.0
{4,7-Methanoindan, 1,2,4,5,6,7, 8,8-octachloro-2,3,3a,4,7,7a-hexahydro-}
Chlorine
Chlorine dioxide
Chloroacetic acid
2-Chloroacetophenone
Chlorobenzene
Chlorobenzilate
{Benzeneacetic acid,4-chloro-.alpha.-(4-chlorophenyl)-alpha.-hydroxy-,ethyl
ester}
Chloroethane                  1.0
{Ethyl chloride}
Chloroform                    0.1
Chloromethane                1.0
{Methyl chloride}
Chloromethyl methyl ether      0.1      ,
Chloroprene                   1.0
Chlorothalonil                  1.0
{1,3-Benzenedicarbonitrile, 2,4,5,6-tetrachloro-}
Chromium                     0.1

-------
7440-48-4
7440-50-8
120-71-8
1319-77-3
108-39-4
95-48-7
106-44-5
98-82-8
80-15-9
135-20-6

110-82-7
94-75-7

1163-19-5
2303-16-4

615-05-4
39156-4
101-80-4
25376-45-8
95-80-7
334-88-3
132-64-9
96-12-8

106-93-4

84-74-2
25321-22-6
95-50-1
541-73-1
106-46-7
91-94-1
75-27-4
107-06-2

540-59-0
75-09-2

120-83-2
78-87-5
542-75-6
62-73-7

115-32-2

1464-53-5
111-42-2
117-81-7

84-66-2
64-67-5
119-90-4
60-11-7
119-93-7

79-44-7
Cobalt
Copper
p-Cresidine
Cresol (mixed isomers)
m-Cresol
o-Cresol
p-Cresol
Cumene
Cumene hydroperoxide
Cupferron
1.0
1.0
0.1
1.0
1.0
1.0
1.0
0.1
{Benzeneamine, N-hydroxy-N-nitroso, ammonium salt}
Cyclohexane                  1.0
2,4-D                         1.0
{Acetic acid, (2,4-dichlorophenoxy)-}
Decabromodiphenyl oxide       1.0
Diallate                        1.0
{Carbamothioic acid, bis(l-methylethyl)-, S-(2,3-dichloro-2-propenyl) ester}
2,4-Diaminoanisole             0.1
'1-7 2,4-Diaminoanisole sulfate   0.1
4,4'-Diaminodiphenyl ether      0.1
Diaminotoluene (mixed isomers)  0.1
2,4-Diaminotoluene            0.1
Diazomethane                 1.0
Dibenzofuran                  1.0
1,2-Dibromo-3-chloropropane   0.1
{DBCP}
1,2-Dibromoethane            0.1
{Ethylene dibromide}
Dibutyl phthalate               1.0
Dichlorobenzene (mixed isomers)0.1
1,2-Dichlorobenzene           1.0
1,3-Dichlorobenzene           1.0
1,4-Dichlorobenzene           0.1
3,3'-Dichlorobenzidine          0.1
Dichlorobromomethane         1.0
1,2-Dichloroethane            0.1
{Ethylene dichloride}
1,2-Dichloroethylene           1.0
Dichloromethane               0.1
{Methylene chloride}
2,4-Dichlorophenol            1.0
1,2-Dichloropropane           1.0
1,3-DichIoropropylene          0.1
Dichlorvos                     1.0
{Phosphoric acid, 2,2-dichloroethenyl dimethyl ester}
Dicofol                        1.0
{Benzenemethanol, 4-chloro-alpha.-(4-chlorophenyl)-alpha.- (trichloromethyl)-}
Diepoxybutane                0.1
Diethanolamine                1.0
Di-(2-ethylhexyl) phthalate       0.1
{DEHP}
Diethyl phthalate               1.0
Diethyl sulfate                 0.1
3,3'-Dimethoxybenzidine       0.1
4-Dimethylaminoazobenzene   0.1
3,3'-Dimethylbenzidine         0.1
{o-Tolidine}
DimethylcarbamyI chloride       0.1

-------
57-14-7
105-67-9
131-11-3
77-78-1
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
123-91-1
122-66-7

106-89-8
110-80-5
140-88-5
100-41-4
541-41-3
74-85-1
107-21-1
151-56-4

75-21-8
96-45-7
2164-17-2

50-00-0
76-13-1

76-44-8

118-74-1
87-68-3
77-47-4
67-72-1
1335-87-1
680-31-9
302-01-2
10034-93-2
7647-01-0
74-90-8
7664-39-3
123-31-9
78-84-2
67-63-0

80-05-7
7439-92-1
58-89-9
108-31-6
12427-38-2

7439-96-5
7439-97-6
67-56-1
72-43-5
1,1-Dimethyl hydrazine
2,4-Dimethylphenol
Dimethyl phthalate
Dimethyl sulfate
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
n-Dioctyl phthalate
1,4-Dioxane
1,2-Diphenylhydrazine
{Hydrazobenzene}
Epichlorohydrin
2-Ethoxyethanol
Ethyl acrylate
Ethylbenzene
Ethyl chloroformate
Ethylene
Ethylene glycol
Ethyleneimine
{Aziridine}
Ethylene oxide
Ethylene thiourea
Fluometuron
0.1
1.0
1.0
0.1
1.0
1.0
1.0
1.0
1.0
0.1
0.1

0.1
1.0
0.1
1.0
1.0
0.1

0.1
0.1
1.0
{Urea, N,N-dimethyl-N'-[3-(trifluorometriyl)phenyl]-}
Formaldehyde                 0.1
Freon 113                     1.0
{Ethane, 1,1,2-trichloro-1,2,2-trifluoro-]
Heptachlor                    1.0
{1,4,5,6,7,8,8-HeptachIoro-3a,4,7,7a-tetrahydro-4,7-methano-1H-indene}
Hexachlorobenzene            0.1
Hexachioro-1,3-butadiene      1.0
Hexachlorocyclopentadiene     1.0
Hexachloroethane             1.0
Hexachloronaphthalene        1.0
Hexamethylphosphoramide     0.1
Hydrazine                     0.1
Hydrazine sulfate               0.1
Hydrochloric acid               1.0
Hydrogen cyanide             1.0
Hydrogen fluoride             1.0
Hydroquinone                 1.0
Isobutyraldehyde               1.0
Isopropyi alcohol               0.1
(manufacturing-strong acid process, no supplier notification)
4,4'-lsopropylidenediphenol     1.0
Lead                         0.1
Lindane                      0.1
{Cyclohexane, 1,2,3,4,5,6-hexachloro-,(1 .alpha.,2.alpha, 3.beta.,4.alpha.,
S.alpha., e.beta.)-}
Maleic anhydride               1.0
Maneb                        1.0
{Carbamodithioic acid, 1,2-ethanediylbis-, manganese complex}
Manganese                   1.0
Mercury                      1.0
Methanol                     1.0
Methoxychlor                  1.0
{Benzene,  1,1'-(2,2,2-trichloroethylidene)bis-4-methoxy-}

-------
 .0
 .0
 .0
  0.1

 .1
1
109-86-4     2-Methoxyethanol             1.
96-33-3       Methyl acrylate                1.
1634-04-4    Methyl tert-butyl ether          1.
101-14-4     4,4'-Methylenebis(2-chloroaniline)
              {MBOCA}
101-61-1      4,4'-Methylenebis(N,N-dimethyl) 0.
              benzenamine
101-68-8     Methylenebis (phenylisocyanate) 1.0
              {MBI}
74-95-3       Methylene bromide
101-77-9     4,4'-Methylenedianiline
78-93-3       Methyl ethyl ketone
60-34-4       Methyl hydrazine
74-88-4       Methyl iodide
108-10-1      Methyl isobutyl ketone
624-83-9     Methyl isocyanate
80-62-6       Methyl methacrylate
90-94-8       Michler's ketone
1313-27-5    Molybdenum trioxide
505-60-2     Mustard gas
              {Ethane, 1,1'-thiobis[2-chloro-}
91-20-3       Naphthalene
134-32-7     alpha-Naphthylamine
91-59-8       beta-Naphthylamine
7440-02-0    Nickel
7697-37-2    Nitric acid
139-13-9     Nitrilotriacetic acid
99-59-2       5-Nitro-o-anisidine
98-95-3       Nitrobenzene
92-93-3       4-Nitrobiphenyl
1836-75-5    Nitrofen
              {Benzene, 2,4-dichloro-1-(4-nitrophbnoxy)-}
51-75-2       Nitrogen mustard              0.1
              {2-Chloro-N-(2-chIoroethyl)-N-methylethanamine}
55-63-0       Nitroglycerin                  1.0
88-75-5       2-Nitrophenol                 1.0
100-02-7     4-Nitrophenol                 1.0
79-46-9       2-Nitropropane                0.1
156-10-5     p-Nitrosodiphenylamine        0.1
121-69-7     N,N-DimethylaniIine     "      1.0       •
924-16-3     N-Nitrosodi-n-butylamine       0.1
55-18-5       N-Nitrosodiethylamine          0.1
62-75-9       N-Nitrosodimethyiamine        0.1
86-30-6       N-Nitrosodiphenylamine        1.0
621-64-7     N-Nitrosodi-n-propylamine      0.1
4549-40-0    N-Nitrosomethylvinylamine      0.1
59-89-2       N-Nitrosomorphoiine           0.1
759-73-9     N-Nitroso-N-ethylurea          0.1
684-93-5     N-Nitroso-N-methylurea        0.1
16543-55-8   N-Nitrosonornicotine           0.1
100-75-4     N-Nitrosopiperidine            0.1
2234-13-1    Octachloronaphthalene        1.0
20816-12-0   Osmium tetroxide             1.0
56-38-2       Parathion                     1.0
              {Phosphorothioic acid,  o, o-diethyl-o-(4-nitrophenyl) ester}
87-86-5       Pentachlorophenol            1.0,
              {PCP}
79-21-0       Peracetic acid                 1.0
  0
0.1
1.0
1.0
0.1
1.0
1.0
1.0
0.1
1.0
0.1
1.0
0.1
0.1
0.1
1.0
0.1
0.1
1.0
0.1
0.1

-------
108-95-2
106-50-3
90-43-7
75-44-5
7664-38-2
7723-14-0
85-44-9
88-89-1
1336-36-3

1120-71-4
57-57-8
123-38-6
114-26-1

115-07-1

75-55-8
75-56-9
110-86-1
91-22-5
106-51-4
82-68-8

81-07-2

94-59-7
7782-49-2
7440-22-4
1310-73-2
7757-82-6
100-42-5
96-09-3
7664-93-9
100-21-0
79-34-5
127-18-4

961-11-5

7440-28-0
62-55-5
139-65-1
62-56-6
1314-20-1
7550-45-0
108-88-3
584-84-9
91-08-7
95-53-4
636-21-5
8001-35-2
68-76-8

52-68-6

120-82-1
71-55-6
Phenol                       1.0
p-Phenylenediamine           1.0
2-Phenylphenol               1.0
Phosgene                    1.0
Phosphoric acid               1.0
Phosphorus (yellow or white)    1.0
Phthalic anhydride             1.0         v;
Picric acid                     1.0         «Kv
Polychlorinated biphenyls       0.1
{PCBs}
Propane sultone               0.1
beta-Propiolactone             0.1
Propionaldehyde              1.0
Propoxur                     1.0
{Phenol, 2-(1-methylethoxy)-, methylcarbamate}
Propylene                    1.0
{Propene}
Propyleneimine               0.1
Propylene oxide               0.1
Pyridine                       1.0
Quinoline                     1.0
Quinone                      1.0
Quintozene
{Pentachloronitrobenzene}      1.0
Saccharin (manufacturing, no supplier notification) 0.1
{1,2-Benzisothiazol-3(2H)-one, 1,1-dioxide}
Safrole
Selenium
Silver
Sodium hydroxide (solution)
Sodium sulfate (solution)
Styrene
Styrene oxide
Sulfuric acid
Terephthalic acid
1,1,2,2-Tetrachlroethane
Tetrachloroethylene
{Perchloroethylene}
Tetrachlorvinphos
0.1
1.0
1.0
1.0
1.0
0.1
0.1

1.0.
{Phosphoric acid, 2-chloro-1- (2,3,5-trichIorophenyl) ethenyl dimethyl ester}
Thallium                       1.0
Thioacetamide                 0.1  ,
4,4'-Thiodianiline               0.1
Thiourea                      0.1
Thorium dioxide                1.0
Titanium tetrachloride           1.0
Toluene                       1.0
Toluene-2,4-diisocyanate       0.1
Toluene-2,6-diisocyanate       0.1
o-Toluidine                    0.1
o-Toluidine hydrochloride       0.1
Toxaphene                    0.1
Triaziquone                    0.1
{2,5-Cyclohexadiene-1,4-dione, 2,3,5-tris(1-aziridinyl)-}
Trichlorfon                    1.0
{Phosphonic acid,(2,2,2-trichloro-1-hydiroxyethyl)-,dimethyl ester}
1,2,4-Trichlorobenzene         1.0
1,1,1-Trichloroethane           1.0

-------
79-00-5
79-01-6
95-95-4
88-06-2
1582-09-8

95-63-6
126-72-7
51-79-6

7440-62-2
108-05-4
593-60-2
75-01-4
75-35-4
1330-20-7
108-38-3
95-47-6
106-42-3
87-62-7
7440-66-6
12122-67-7
(Methyl chloroform)
1,1,2-Trichloroethane
Trichloroethylene
2,4,5-TrichlorophenoI
2,4,6-TrichIorophenol
Trifluralin
1.0
1.0
1.0
0.1
1.0
{Benzenamine, 2,6-dinitro-N,N-dipropyl-4-(trifluoromethyl)-}
1,2,4-Trimethylbenzene        1.0
Tris(2,3-dibromopropyl phosphate) 0.1
Urethane                      0.1
(Ethyl carbamate)
Vanadium (fume or dust)        1.0
Vinyl acetate                   1.0
Vinyl bromide          .        0.1
Vinyl chloride                  0.1
Vinylidene chloride             1.0
Xylene (mixed isomers)          1.0
m-Xylene                      1.0
o-Xylene                      1.0
p-Xylene                      1.0
2,6-Xylidine                    1.0
Zinc (fume or dust)              1.0
Zineb                         1.0
{Carbamodithioic acid, 1,2-ethanediylbis-, zinc complex}

-------
Reporting thresholds:

Calendar year 1988:  50,000 poinds for manufactured or processed substances; 10,000 pounds for
otherwise used.
Calendar year 1989:  25,000 poinds for manufactured or processed substances; 10,000 pounds for
otherwise used.
                                                           ••;irr.
                                                            -^•r-
                           SECTION 313 CHEMICAL CATEGORIES

Section 313 requires emissions reporting on the chemical categories listed below, in addition to the
specific chemicals listed above. The metal compounds listed below, unless otherwise specified, are
defined as including any unique chemical substance that contains the named metal (i.e., antimony,
copper, etc.) as part of that chemical's structure.  For further definitions of the other compounds, consult
EPA guidance documents.

Chemical categories are subject to the 1 percent de minimis concentration unless the substance involved
meets the definition of an OSHA carcinogen.

Antimony Compounds
Arsenic Compounds
Barium Compounds
Beryllium Compounds
Cadmium Compounds-
Chromium Compounds
Cobalt Compounds
Copper Compounds
Lead Compounds
Manganese Compounds
Mercury Compounds
Nickel Compounds
Selenium Compounds
Silver Compounds
Thallium Compounds
Zinc Compounds

Categories of chemicals with special conditions: see EPA guidance.
Chlorophenols
Cyanide Compounds
Glycol Ether
Polybrominated Biphenyls
                                              U.S. GOVERNMENT PRINTING OFFICE: 1990— 727-890/ 0

-------

-------