United States Office of Pollution EPA/749-R-95-001
Environmental Protection Prevention and March 1995
Agency Toxics (7407)
&EPA PROCEEDINGS
Toxics Release Inventory (TRI)
Data Use Conference:
Building TRI and Pollution
Prevention Partnerships
Boston, Massachusetts
December 5-8, 1994
Sponsored by the
Northeast Waste Management Officials' Association (NEWMOA)
In conjunction with the
U.S. Environmental Protection Agency (EPA)
and
American Petroleum Institute (API)
Chemical Manufacturers Association (CMA)
INFORM, Inc.
National Association of State Title Three Program Officials (NASTTPO)
National Pollution Prevention Roundtable (NPPR)
New England Interstate Water Pollution Control Commission (NEIWPCC)
Northeast States for Coordinated Air Use Management (NESCAUM)
Toxics Use Reduction Institute, University of Massachusetts Lowell
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Toxics Release Inventory (TRI)
Data Use Conference
1994 Proceedings
Maureen Hart, Editor
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (7407)
Washington, DC 20460
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Publication does not signtfy that the contents necessarily reflect the views and policies
of the Northeast Waste Management Officials' Association or the U.S. Environmental
Protection Agency or of any other organization represented in these proceedings.
Mention of trade names and commercial products does not constitute endorsement of
their use.
-S Gowrame* Mo* Office
dSiapSSOP.Watavai.DC 2MOZ4328
I SB* O-16-04*184-8
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1994 ~RJ Data Use Conference
Table of Contents
Acknowledgements [[[ *
Introduction [[[ 1
Conference Overview ............................................ ........... 1
Keynote Addresses [[[ 3
Opening Plenary [[[ 11
Track 1- Pn^tMTB Prevention
Session 1 How TRI Can Drive Pollution Prevention ................................ 23
Session 2 Using TRI Data for Pollution Prevention Planning .......................... 32
Session 3 Using TRI to Identify Industry Pollution Prevention Technical Assistance
Oppordurities ................................................. 39
Session 4 Measuring Pollution Prevention Progress: Building a Better Yardstick .......... 48
Sessions Beyond TRL How Additional State Data is Used .......................... 59
Track 2 - PartnerAips
Session 1 Local Emergency Planning and TRI .................................... 72
Session 2 Crossmedia Use: TRI Partnerships within Agencies ......................... 82
Session 3 Indnstty-CuiiMuuiiky Relationships ..................................... 94
Session 4 International PaiUua ships with TRI .................................... 107
5 Compliance Assistance, Enforcement and TRI ............................ 115
Track ? - Jfrmiffvative Uses
Session 1 Risk Targeting and Screening Using TRI 122
Session 2 Is TRI Useful in die Environmental Justice Movement? 132
Session 3 TRI and Data integration 141
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1994 TRI Data Use Conference
Acknowledgements
We would like to thank all those who contributed to the success of this conference:
Sponsor: Northeast Waste Management Officials' Association (NEWMOA)
In Conjunction With: U.S. Environmental Protection Agency (EPA)
Co-sponsors
American Petroleum Institute (API)
Chemical Manufacturers Association (CMA)
INFORM, Inc.
National Association of State Title Three Program Officials (NASTTPO)
National Pollution Prevention Roundtable (NPPR)
New England Interstate Water Pollution Control Commission (NEIWPCC)
Northeast States for Coordinated Air Use Management (NESCAUM)
Toxics Use Reduction Institute, University of Massachusetts Lowell
Internet ACCeSS Provider: Software Tool and Die, Brookline, Massachusetts
Steering Committee
Mike Aucott, NJDEP Office of Pollution Prevention; Sarah Bauer, U.S. EPA; John Chelen, Unison Institute/RTK Net;
Paul Clark, Portsmouth Naval Shipyard; Cindy DeWulf (FOSTTA Representative), OH EPA DAPC; Bob Eisengrein,
Acton Citizens for Environmental Safety; Jan Erickson, U.S. EPA; Jon Flint, Kansas Emergency Response
Commission; Terri Goldberg, NEWMOA; Susan Green, MA DEP Bureau of Waste Prevention; Terry Greene, John
Snow Institute/Center for Environmental Health Studies; Lena Mann-Ferris, U.S. EPA; Maureen Hart, NEWMOA;
Susan Hazen, U.S. EPA; Maureen Heraty Wood, Chemical Manufacturers'Association; Bob Hogner, Florida
International University, Center for International Business; Gary Hunt (NPPR representative), NC Department of the
Environment; Mike Leedie, Citizens For a Better Environment; Cindy Lewis, U.S. EPA-New England; Sanford Lewis,
Good Neighbor Project; 3oe\Lin.dsey, Institute for Environmental Issues and Policy Assessment; Russ Lopez,
Environmental Diversity Forum; Carol Macko, Bureau of National Affairs; Kevin McDonald, MN Office of Waste
Management; Walter McLeod, American Petroleum Institute; Cheryl Morton, Synthetic Organic Chemical
Manufacturers Association; Dick Murdock, NTS DEC Pollution Prevention Unit; Dwight Peavey, U.S. EPA-New
England; John Pinkerton, National Council of the Paper Industry for Air and Stream Improvement; Barbara Reilry,
U.S. EPA; Mary Sherwin, CTDEP Bureau of Waste Management; Rex Tingel, AFL-CIO; Andrew Wheeler, U.S.
EPA; and Phil Wong, U.S. EPA Region 10.
Special Thanks To
Terri Goldberg, NEWMOA, Conference Manager
Maureen Hart, NEWMOA, Conference Coordinator
Jan Erickson, U.S. EPA, Conference Coordinator
Dwight Peavey, U.S. EPA-New England, Conference Coordinator
Monica Becker, NEWMOA, Conference staff
Cindy Lewis, U.S. EPA-New England, Track Leader
Lena Harm-Ferris, U.S. EPA, Track Leader
Doug Sellers, U.S. EPA, Track Leader
Andrew Wheeler, U.S. EPA
Eileen fesco, U.S. EPA
OdeliaFunke, U.S. EPA
Sam Sasnett, U.S. EPA
Carole Madsen & Staff, Madsen Marketing Strategies
KimberlyFelton.ffTV
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1994 TRI Data Use Conference
Introduction
The 1994 Toxics Release Inventory (TRI) Data Use Conference brought together the
members of the many different constituency groups using TRI under the theme of Building TRI
and Pollution Prevention Partnerships. The sessions in the conference were organized into three
different tracks: using TRI in pollution prevention efforts, partnerships using TRI, and innovative
uses of TRI data. The conference was designed to support several important goals:
• strengthen the relationship between TRI users and managers, including members of all the
different constituency groups;
• increase awareness of the diverse uses of TRI data;
• expand the network of TRI users;
• share information on how states and others are using the pollution prevention data
elements in TRI; and
• provide a forum for discussing the future direction of TRI.
The fact that the conference had almost doubled in size from the 1993 conference shows that the
goal of expanding the network of users was achieved. Not only were there more attendees than
any prior year, there was also a greater number of representatives from industry and
environmental and other nongovernmental organizations.
Conference Overview
The opening session included keynote addresses from Linda Murphy, the Director of the
Air, Pesticides and Toxics Management Division, U.S. EPA New England and from Dr. Lynn
Goldman, the Assistant Administrator for Prevention, Pesticides and Toxic Substances, U.S.
EPA. This was followed by a plenary panel that discussed the expansion of the Right-to-Know
concept in environmental programs.
Following the opening session, there was a reception sponsored by the Chemical
Manufacturers Association, which allowed attendees to network as well as view demonstrations
of TRI-related computer applications and environmental programs. Descriptions of the
demonstrations are included at the end of these proceedings.
The breakout sessions were all related to one of three tracks: Pollution Prevention,
Partnerships with TRI, or Innovative Uses of TRI. The Pollution Prevention Track was the most
popular track in terms of attendance. The sessions included: an introduction to pollution
prevention and TRI; discussions on how TRI can be used for pollution prevention planning from
an industry viewpoint and for targeting technical assistance from an Agency viewpoint; how TRI
can be used for measuring progress in pollution prevention; and what is being done with
additional data collected by some states.
The Partnerships Track addressed the many different types of partnerships that exist
between TRI and other programs. These sessions included how TRI can be and is used by local
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1994 TRI Data Use Conference
emergency planning committees (LEPCs), other media programs, community groups, and for
enforcement and compliance.
The Innovative Uses Track examined the many different ways that TRI is being used.
These sessions included how TRI is useful in the environmental justice movement, uses of TRI by
communities and workers, integration of TRI with other related data sources, and geographical
information systems (GIS) and other tools for analyzing TRI.
Papers were prepared by most of the speakers. An index in the back of these proceedings
shows where to locate papers submitted for inclusion in these proceedings.
For the first time since the annual TRI Data Use Conferences began, attendees were
invited to present posters relating to TRI at two sessions on Tuesday, December 6th. Thirty-three
abstracts were submitted and accepted. The poster sessions proved to be a valuable addition to
the conference and allowed more information to be presented than was possible with a limited
number of breakout sessions.
The closing plenary was a discussion of the future of TRI. Representatives from a
national environmental organization, a state agency, and industry presented their views on how
the TRI should or should not be expanded.
These proceedings include all the papers that were submitted by speakers and presenters.
Immediately following this introduction are the presentations of the keynote speakers. Next are
the papers submitted by the opening plenary speakers, with an introductory remarks by the
moderator, Joseph Carra, Acting Director, Office of Pollution Prevention and Toxics, U.S. EPA.
Following those papers are the papers submitted by speakers in the breakout sessions with an
introduction describing each session. The sessions are grouped by tracks in the following order:
Track 1 - Pollution Prevention,
Track 2 - Partnerships
Track 3 - Innovative Uses
Papers for the closing plenary speakers are found after the breakout session papers with
introductory remarks from the moderator, Susan Hazen, Acting Deputy Director, Office of
Pollution Prevention and Toxics, U.S. EPA.
Following the closing plenary papers are brief descriptions of the computer
demonstrations presented during the reception on Monday night. These are followed by abstracts
for the posters presented Tuesday during the morning and afternoon poster sessions. An index of
all presenters is provided to allow readers to easily locate a particular paper or poster abstract.
Finally, after the index is a list of all those who registered for the conference.
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1994 TRI Data Use Conference Keynote Addresses
Keynote Addresses
Speakers
Linda Murphy, Director, Air, Pesticides and Toxics Management Division, U.S. EPA-New England
Lynn K Goldman, M.D, Assistant Administrator, Office of Prevention, Pesticides and
Toxic Substances, U.S. Environmental Protection Agency
Linda Murphy, Director, Air, Pesticides and Toxics Management Division, U.S. EPA-New England
It is really a privilege for me to open this conference. There are so many distinguished members of
business and industry in the audience, distinguished environmentalists, and members of state and local
governments. And of course, I also want to extend a sincere welcome to Dr. Lynn Goldman, our Assistant
Administrator in Washington. Among this esteemed group of people, I am truly honored to open this conference.
I feel like if s really a celebration. A couple of years ago, I would not have envisioned that we would have over
five hundred people registered for a conference like this. So, I am truly heartened by the response that we've had
to the conference, and I do think it's a celebration that we all can take pride in. I do want to thank NEWMOA
again, and members of the EPA headquarters staff and of course, my own staff in EPA-New England for all then-
hard work'in putting on this conference. Ks through their efforts that people like me get to trot around and open
conferences with little to worry about, except opening remarks. So again, thank you very much.
We're here today to talk about change. Change in the way we do business and change in the way we
think about the environment There are many environmental reasons for this transformational change. But there
are compelling social and economic reasons as well. These reasons are national, regional and local in scope. On
the national front, thirty years after Silent Spring, we have doubled our use of pesticides in this country. Twenty-
five years after the Cuyahaga River caught fire, forty percent of the rivers and lakes are still polluted - too
polluted for us to fish and swim in. Last year, as you probably heard on the talk shows, people in Milwaukee,
New York City, and Washington, D.C., were ordered to boil their water before drinking it. Four-hundred
thousand got sick in Milwaukee alone, and one hundred died. So you can see, the national picture still shows
we have many environmental problems.
On the regional level, one billion pounds of the TRI chemicals in the waste stream were emitted from
New England facilities. In the shell fishing industry alone, over 100,000 acres were closed - more than three
times what it was in 1970. There are 94 Superfund sites in this region and many more sites that are on the
equivalent of state Supertund lists throughout the region. We, in EPA New England, are responsible for the six
New England states and we have problems that are unique to each of these states as well.
In New Hampshire this summer, ozone exceedences occurred on eleven out of twenty-one days on the
top of Mount Washington, which is the highest peak in New England. In Massachusetts, within five miles of
this very hotel site, in Roxbury, which is an inner-city community, there are fifty-four hazardous waste sites in
a single square mile area known as the Dudley neighborhood. In Maine, a land that prides itself on being
I'Vacationland," in fact, I think they have that written on their license plates, there were recent mercury warnings
in fish that warned pregnant women and children to limit their intake drastically. In Vermont, for those of you
who live in New England and are shopping for Christmas presents, there was a lead scare in Vermont maple
syrup recently, that hit all the papers. Moving on to Rhode Island, Narragansett Bay, which is one of the premier
bays in our region, the fecal-cdiform bacteria level doubled within the past year. And in Connecticut, one billion
tons of sewage flow into Long Island Sound daily. So, for those of you who are from outside our region, I've just
tried to capture state specific problems to give you just a flavor of the kinds of environmental problems that we
still face in our region.
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Keynote Addresses 1994 TRI Data Use Conference
These are tough problems and all the tougher, given the economic and social context. Our economy
depends heavily upon natural resources. This is particularly so in New England. Til give you just two examples,
the fishing industry, for one. Currently, this is a half a billion dollar industry. It used to be four times that much,
a two billion dollar industry, as short as fifteen years ago. You can see the effects of the down-turn in this
industry in the fishing communities along the coast - the people who are out of work and the people who have
had to find other work because they no longer can sustain a living through fishing. Tourism is a $14 billion
industry in this region; 4.5% of the gross regional product. Part of the reason that attracts tourists to our area
is the clean and unique environment that we share. So, it is worth protecting.
EPA-New England is meeting these economic and social challenges. We are focusing our attention on
four areas. With the new Regional Administrator, John DeVillers, we have tried to focus on limiting our
attention to the most important problems. First of all, we're promoting environmental technology and with it,
environmental industry. We are truly blessed in New England with a large variety of academic institutions,
consulting businesses and environmental products that we feel could be used to improve the environment
throughout not only New England, but the United States and the world as well. Our second priority is a strong,
targeted enforcement effort EPA is and always will be a regulatory agency and we certainly have not abandoned
our attention and our priority towards a strong enforcement program. We want to be flexible, but we will use
our enforcement authorities to ensure that federal laws are maintained and obeyed.
Our third priority is re-inventing the way EPA does business. This is really a cultural change thaf s
going to occur over many years. Ifs been difficult for us in the regional office undergoing this cultural change,
as I speak, and I think that we will be involved in it for many years to come. It's a cultural change not only in
how EPA is organized (we're streamlining like the rest of the government and we're trying to reduce layers of
management that we feel are unnecessary). But also, it's a cultural change in the way we do business with our
customers. I hope that you have already seen the results of a more customer focused agency in New England,
dealing with our customers, the states, the environmental community and the industrial and business community.
And we intend to continue that effort to meet the needs of our customers.
Our final priority is environmental empowerment and education. I think this is probably the most
important — personally speaking — of the four priorities. If we are to actually change behavior, we have to
educate and empower people to take control of their own lives and to make changes for themselves. We also have
to focus attention on the education of students, particularly students in the lower elementary grades. We have
spent a lot of time on education in our regional office. A lot of people who work for EPA volunteer their time
educating teachers in teach-the-teacher programs and educating and tutoring students. I think that obviously,
as with any social change, the future is with the children and I think this is time well spent. But in the area of
education, we don't always just focus on children. We obviously focus on the regulated community.
TRI is one of the central approaches we are using to address toxics issues and the toxic problem.
Through efforts like the 33/50 program, we're empowering businesses to help themselves. Fundamentally, this
is about people recognizing the importance of pollution prevention and the advantages that pollution prevention
poses for both the environment and a company's bottom line: its profits. While saving money, companies are
finding they can save the environment as well by reducing the use and emission of toxic chemicals. It goes to
prove that a healthy environment is truly consistent with a healthy economy.
New England is proud to lead the nation in reducing toxic emissions. Our success is due to a new spirit
of cooperation between industry and government, as evidenced by the results of voluntary programs like the
33/50 program, and progressive state toxic use reduction acts, such as the trendsetting law passed in
Massachusetts in 1990. I think you'll be hearing about that later on in this conference. These reductions do not
come from fewer business, but from fewer emissions from a comparable number of businesses. That's an
important fact because, like all environmental improvements, we try to scientifically quantify whether the
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1994 TRI Data Use Conference Keynote Addresses
improvements came from external forces, from down turns in business, or truly from the results of pollution
prevention in environmental control. We think, in this case, it's from the latter.
I would like to give you a little TRI-specific information before I close. Since 1988, New England
facilities have reduced environmental releases and emissions to the air, land, and water by forty-seven percent.
I mink that's a tremendous success. The national average was thirty-five percent, so we're better than the national
average, but I think the national picture is a great success as well. The vast majority of environmental releases,
eighty-six percent of them, are to the air, while water and land discharges equally account for the remaining
twelve percent. Since 1988, New England facilities have reduced waste sent off-site for treatment or disposal
by over sixty percent And again, if you want to compare that to the national average, the national average was
thirty-five percent.
We have achieved this terrific success rate, again, thanks to EPA-New England's and the states'
emphasis on pollution prevention as a way of doing business, as a change in the behavior of how we do business.
Again, there are many progressive state laws that have been passed and progressive state programs that are in
place now to assist industry with their pollution prevention efforts. Since the Pollution Prevention Act of 1990,
we have a more complete picture of the waste management practices through TRI In New England, facilities
recycled fifty-three percent of their total toxic chemicals that are in their waste streams. There are still currently
one billion pounds of TRI chemicals in the waste streams of New England facilities. So, there is still obviously
a lot of work to be done.
Fve mentioned 33/50 several times in these remarks. For those of you who may not be familiar with the
program, 33/50 is a voluntary program whereby companies reduce their emissions from a base line year of 1988.
There are seventeen pollutants that are targeted. The name 33/50 comes from a target goal of reducing the
emissions from the base line of 1988 by thirty-three percent in 1992, and fifty percent in 1995. So, 1992 has
already passed. How did we do? In New England, 370 facilities and 193 parent companies are part of the 33/50
program. Participants in the 33/50 program ranged from small facilities to Fortune 100 corporations. By 1992,
these New England faculties obtained a fifty-five percent reduction. That's well over the thirty-three percent
target So, we did great in New England. Half of the Region's TRI reductions are associated with facilities and
parent companies that committed to the 33/50 program. So, 33/50 does work, education does work, and people
do want to do the right thing. These New England facilities reduced their emissions and waste generated fifty
percent faster than the national rate among 33/50 facilities. We don't have a scientific explanation of why this
happened in New England, of why New England was a little bit ahead of the rest of the country. But, again,
possibilities include the efforts of strong state and interstate programs that we have in New England and a high
public concern for pollution prevention and the environment here.
Gillette — and I hate to mention specific companies, because you always slight other companies that are
just as good — but Gillette is truly an exemplary company and it is a company that's based in Boston. Gillette
has recently made an impressive commitment to go far beyond the 33/50 goals. Gillette has set a voluntary goal
of a ninety-nine percent reduction in TRI emissions by moving away from their use of ozone depleting chemicals
to de-grease razor blades. This commitment applies to all eleven world-wide facilities. Gillette obviously is a
profitable company. They do national advertising and sponsor many programs on television. Gillette isnt
reducing its emissions by ninety-nine percent solely to be a good corporate citizen. Obviously, pollution
prevention is good business as well. Again, I would like to close by reiterating the fact that if s appropriate that
we meet in Boston during the holiday season because this conference is a celebration. I'm very privileged to
have opened this conference today.
D
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Keynote Addresses 1994 TRI Data Use Conference
Lynn R Goldman, M.D, Assistant Administrator, Office of Prevention, Pesticides and Toxic Substances,
U.S. Environmental Protection Agency
Good afternoon. I am very pleased to be here to discuss the newly expanded Toxics Release Inventory
and the opportunities for partnerships in pollution prevention. This conference is an important building block
in the construction of one of the most vital and successful environmental programs in the United States ~
ensuring the public's right to know about toxic chemical releases to their communities.
It is significant that you who are participating in this 1994 conference on TRI data are such a diverse
group. You represent federal, state, and local agencies, the international community, environmental groups,
academia, industry, labor, citizen organizations, and the news media. All of you play a role in the public's
becoming aware of environmental releases and participating in avenues for response. With your involvement,
I am confident this conference will lead to new relationships, new insights, and new possibilities for preventing
the pollution reflected in the Toxics Release Inventory.
In 1986, when the Emergency Planning and Community Right-to-Know Act established a public process
for identifying potential chemical hazards at the community level, few anticipated the dynamic events that would
unfold in a very short time. This comprehensive national inventory of toxic chemical releases has developed into
a valuable tod for identifying potential environmental problems and stimulating pollution prevention. In 1990,
the Pollution Prevention Act added major new reporting elements to the Toxics Release Inventory or TRI form,
which increased the ability of TRI to identify pollution prevention opportunities.
As you know, TRI gathers information on toxic chemical releases and other pollution prevention data
from more than 23,000 manufacturing facilities on an annual basis. This information includes routine release
data and not emergency response data.
Until recently, more than 300 chemicals have been subject to the reporting requirements. I am pleased
to note that, last week, the Environmental Protection Agency added another 286 chemicals to the TRI, including
several chemicals used in pesticide formulations. These are chemicals that have hazards in the same range of the
existing TRI list and thus may pose similar risks to communities. Because of our action, more communities than
ever before will be better equipped to identify and respond to the full range of potential environmental risks from
chemical releases.
At the same time as we expanded TRI, we made reporting of low volumes of chemical releases easier
and less time-consuming, saving limited resources while still protecting the public's right to know. Later in my
talk, I will discuss these steps in more detail as well as our plans for future measures.
If past is prologue, last week's action to expand the Toxics Release Inventory to include 286 additional
chemicals will help drive the pollution prevention movement. Consider what happened at the outset of the
program. The first year's data were something of a revelation to government and industry. In 1988, the
benchmark year for comparisons, nearly 4.8 billion pounds were reported. The eye-opening data have spurred
a steady decline in releases. Since 1988, there has been a reduction of 1.6 billion pounds of toxic releases into
the environment.
Our actions to strengthen the TRI are part of this administration's dedication to safeguarding the
environmental health of all Americans. Information is fundamental to the functioning and well-being of a
democracy. Informing communities about potential environmental risks empowers them to influence the
environmental management decisions that will affect their lives and those of their children. It is vital that we do
so for what we see with increasing clarity is the link between healthy environments and healthy communities -
safe food, safe water, and safe air.
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1994 TRI Data Use Conference Keynote Addresses
The United States is at an important juncture in the history of environmental protection. In many ways,
we have reached the limits of the tools we have traditionally used. Traditional approaches deal with pollution
at the end of the pipeline, rather than before and during the manufacturing process, and they address effects on
air, water, or land separately when, in fact, these different parts of the environment are interrelated.
Among the reasons for the shift toward pollution prevention is the expanding awareness both of
environmental releases and of the environmental costs incurred over the life cycle of a product coupled with the
opportunities for reducing them. Environmental managers today are beginning to look at the expense involved
in the whole product cycle, from raw materials, manufacturing, and transportation through use and ultimate
disposal, recycling, and/or reuse. There is growing recognition that life-cycle analysis can lead to economically
wiser choices for reducing environmental exposure and future liabilities. In the United States, chief financial
officers are becoming more involved in environmental management decisions and their effects on quality,
productivity, and profits. Rightly so.
Command-and-control regulatory approaches are necessary to provide strong goals to achieve, but at
the same time they leave little room for flexibility or innovation. By themselves, they are insufficient. In 1992,
U.S. businesses spent close to $30 billion on environmental compliance. Yet the manufacturing and chemical
sector alone released a total of 3.2 billion pounds of toxic pollutants. And too often our regulatory process is
bogged down in litigation. Can't we do a better, more efficient and effective job of protecting public health and
the environment? The answer is yes, by adding pollution prevention and community right-to-know to our tool
box for environmental protection.
Today, everyone engaged in environmental management in the public and private sector is challenged
to use the limited resources available to do a better, cheaper, smarter job of protecting the environment Can we
achieve the environmental protection we need in a more common sense way? Again, the answer is yes, and the
Agency has launched a new program called the Common Sense Initiative to approach regulation on an industry-
by-industry basis rather man poUutant-by-pollutant Six major U.S. industries are participating in the pilot phase
of the project - auto manufacturing, computers and electronics, iron and steel, metal finishing and plating,
petroleum refining, and printing. Together, they spent more than $8.2 billion in 1992 on compliance with
environmental laws, according to the Department of Commerce, and their combined release of toxic pollutants
into the environment totaled 395 million pounds that year, 12.4 percent of the reported emissions nationally.
These six industries employ almost 4 million Americans.
Our Common Sense Initiative will bring together government officials at all levels, environmental
leaders, industry executives, and others to create strategies mat will work cleaner, cheaper, and smarter to protect
the health of the people of this country and the natural resources we share. Pollution prevention will play a major
part The goal is a new generation of environmental protection — a cleaner environment at less cost. In this way,
we will be better able to achieve the interdependent goals of environmental protection and a sustainable economy.
Last year mis administration took a significant step forward with its commitment to right-to-know and
pollution prevention. In August 1993, President Clinton signed an Executive Order requiring federal facilities
mat manufacture, process, or use toxic chemicals to report them under the TRI. At the same time, he set a goal
for all federal agencies to reduce toxic emissions by SO percent by the year 1999. I am pleased to report that our
federal agencies are stepping forward to lead the way. They are required to report TRI data by July 1995, and
this information will become available to the public in the spring of 1996.
As I mentioned earlier, EPA last week greatly expanded the number of toxic chemicals subject to
reporting requirements, bringing the total to more than 600. This expansion of TRI is a crucial step because the
initial list, gathered from a variety of sources, represented less than 20 percent of the toxic chemicals in U.S.
commerce today. Notably absent were toxic chemicals used in pesticide formulations. More than half of the 286
chemicals added to the TRI list were active ingredients in pesticides. To add chemicals, we conducted an
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Keynote Addresses 1994 TRI Data Use Conference
extensive search for chemicals of concern across the federal government. More than 1,000 chemicals were
screened, and 383 underwent thorough toxicologjc analysis to identify the 313 that we proposed for TRI listing,
of which 286 were finalized last week. We are requiring that releases of the additional chemicals be reported for
the 1995 calendar year, with the first reports submitted to EPA and state agencies by July 1,1996.
We also made final a rule to streamline TRI reporting requirements for small quantities of emissions and
waste. This should reduce the more than 80,000 reports currently received under the TRI each year by about
20,000, with considerable savings to industry and to government. Currently, whether a plant reports 10,000
pounds or 10 pounds, they have to use the same extensive reporting process. Now, a facility can take advantage
of the streamlined and simplified reporting form - often compared to the IRS's E-Z tax form ~ if the total amount
of die releases and waste required to be reported each year is below 500 pounds. This less detailed information
will be available to the public in the TRI database.
These two rules strike a positive balance between enhancing the need for communities' right-to-know
about toxic chemical releases and controlling regulatory costs. We estimate that the chemical expansion rule will
increase the annual number of Form Rs by about 14,000 forms. This figure includes about 1,225 new data
reporters. The total estimated annual cost to industry is $48.8 million, with the first year cost estimated at $99
million. But the alternate reporting threshold reduces the regulatory burden by a total estimated savings to
industry of $21.5 million a year.
Completion of this first phase of TRI expansion will provide new opportunities for right to know and
pollution prevention. High on our agenda at EPA is the need to address environmental justice concerns.
Minorities and low-income groups who too often have borne a disproportionate share of potential environmental
risk especially need access to toxic release data and to the environmental management process. More than $5
million is available in fiscal 1995 for our new Pollution Prevention for Environmental Justice Grants Program.
These projects can range from using TRI data to bring about lower industrial emissions to encouraging resource
efficiency in communities. Potential recipients include community groups, service providers, non-profit
organizations, and academic institutions. This and other grant programs at EPA will help ensure that
environmental justice groups are at the table when environmental management decisions are made.
An expanded TRI will also provide new opportunities for developing voluntary programs with industry.
The Agency's 33/50 program targeting 17 high-priority toxic chemicals on the TRI helped accelerate the process.
Approximately 1,300 companies, including a high percentage of the "top 600" largest firms, are voluntarily
reducing the release or transfer of these chemicals. Companies voluntarily participating in the 33/50 program
include AT&T, BF Goodrich, Dow, Du Pont, Lockheed, Martin Marietta, Republic Engineered Steels, FMC, and
Shell Petroleum, among many others. Program goals call for reducing the release or transfer of these priority
chemicals 33 percent by 1992 and 50 percent by 1995. The program brought about a 40 percent cut by 1992,
which amounted to a total of nearly 600 million pounds. And it is on track for meeting the 1995 objective.
But with 1995 comes the program's completion. Any action to extend the program, in its current or a
redesigned form, depends on the consensus and support of stakeholders like you. We are asking for your
thoughts on whether mere should be a next generation of the 33/50 program and, if so, what it should look like.
The following are some of the questions we are trying to resolve and ask you to think about. What chemicals
should be targeted in a next generation program? Who should be invited to participate? What measures should
be included? Should it focus on source reduction or efficiency of use? Should it also embrace environmental
improvements achieved through recycling, recovery, treatment, and remediation? Our plan is to make a formal
announcement in the summer of 1995. Let us hear from you.
Now that we have expanded the Chemical Expansion Project, we are looking to increase the universe
of facilities that are required to report beyond the current manufacturing sector. We call this "Phase II" of the
TRI expansion project Several major sectors of the economy have facilities that have significant releases of TRI
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1994 TRI Data Use Conference _ Keynote Addresses
chemicals and are engaged in activities directly related to the manufacturing activities currently covered by TRI
requirements. These are sectors that supply the raw materials or energy needed for manufacturing, distribute
finished products as well as raw materials, and treat and dispose of wastes generated in the manufacturing
process. The close alignment of activities guides our approach to facilities expansion.
We have been conducting a series of focus groups to encourage extensive public review and comment
before we prepare a proposed rule. The first was held May 23, with a preliminary meeting for representatives
of the utility industry. Additional focus group sessions have included mining, airports, publicly owned and
commercially operated waste treatment facilities, oil and gas exploration and production, and freight and
warehousing facilities. Another focus group was held with environmental organizations. The informal and
substantive discussions have surfaced a number of issues that merit further discussion. One is the practical
capacity of EPA and states to handle the increased data from new facilities. Another is whether the de-minimis
exemption for me manufacturing sector is applicable to other types of facilities. We plan to propose a facilities
expansion rule by mid-1995.
Phase in of TRI expansion is looking at the possibility of adding data elements that would give a more
complete picture for pollution prevention. TRI data and the information added by the Pollution Prevention Act
offer an important view of waste stream creation, waste management practices, and source reduction measures,
if they exist. But there are still missing pieces.
A materials accounting approach would show how much of a toxic chemical is brought on site, how
much is consumed, and how much is put into products, thus allowing measurement of efficiency of use, rather
than just emissions and transfers. Consideration is also being given to requiring information on occupational
demographics to better understand the potential for exposure. Together with the current TRI data, this
information would allow better accountability of toxic releases and offer a better handle on pollution prevention
opportunities. Not surprisingly, Phase HI is controversial, and key decisions on whether to propose a national
materials accounting strategy and if so, in what form, are still to be made. We will use an open and inclusive
public process to shape this part of the TRI enhancement work. On September 28 we held the first public
meeting on the issue. Approximately 125 people, representing state and federal agencies, trade associations,
environmental and public interest groups, labor organizations, environmental justice groups, and law firms, were
in attendance. Before the agency resolves the issues involved in Phase IE, we will make sure that all parties work
together to forge areas of consensus and develop mutually acceptable strategies.
So we are doing much to improve TRI now and in the future. But improvement of TRI won't be
accomplished just by adding chemicals and consideration of additional facilities and data. We must all become
much more sophisticated in how we use the data in TRI. It is because TRI is such a powerful tool that we must
all take care to use it in as responsible a manner as possible, to drive the right kinds of actions for protection of
public health and communities.
Let me give some examples of what I mean. One core communications issue is that the basis of TRI is
hazard, not risk. What I mean by this is that TRI gives information about potential exposure but does not
measure exposure. This can be useful but we need to guard against misinterpreting TRI numbers as actual
exposure numbers.
A second issue is that although we are certain that all the chemicals on TRI are important environmental
and/or health hazards, we are just as certain that they are not of equal toxicity. How can we do a better job
taking that into account when we summarize and report TRI data on multiple chemicals?
Even more complex is that many of the chemicals on the TRI are important in some but not all media
For example, nitrates, which we just added last week, are of human health concern because of the potential for
drinking water contamination. And they can also be of ecologic concern in certain nitrogen limited aquatic
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Keynote Addresses 1994 TRI Data Use Conference
ecosystems. But under appropriate conditions, they can actually be beneficial in other aquatic environments and
when applied to land. How can we do a better job communicating about media-specific hazards on TRI?
And, not all activities reported under TRI confer equal risk. For example, proper recycling may be
preferable to waste disposal which is in turn preferable to releases to the environment. Total data on emissions,
disposal, and recycling may tend to mask these differences and inappropriately target our efforts for reductions.
Because our interpretations of TRI data change behavior and drive investments by communities,
government and the private sector, we have the responsibility to develop more sophisticated ways of using the
data than simply totalling up chemicals across media EPA has already made a number of improvements in how
we report data And we are working to add lexicological information sheets to the TRI data base. But much
more work will need to be done by all of us in order to maximize the benefits from TRI and maintain the
effectiveness of TRI as a driving force for pollution prevention.
This administration's commitment to right-to-know and pollution prevention extends to the international
level as well. For example, we at EPA are supporting an international effort to promote the concept of toxic
chemical release inventories. At the Earth Summit in Rio de Janeiro in 1992, more than 1 SO countries agreed
to an action plan called Agenda 21, which proposed, among other goals, the development of Pollutant Release
and Transfer Registers, which is the international term for chemical inventory systems like TRI
Today, in working to make the Earth Summit's goals a reality, EPA is helping to sponsor a toxic
chemical inventory release effort through the OECD or Organization for Economic Cooperation and
Development. In 1994, the Agency participated in an OECD effort to create a Guidance to Government
document that will recommend right-to-know approaches to interested governments. The first of three work
group conferences planned for 1995 is scheduled for January 24-26 in Basel. We firmly believe that publicly
available chemical release inventories can have widespread international environmental and public health benefit.
Here at home, we are witnessing the rapid evolution of the TRI program and pollution prevention
activities. Prevention is central to EPA's new Environmental Technology Initiative. The $60-million-plus
program was launched in 1994 to identify and fund innovative technology development and pilot projects. We
are also supporting state pollution prevention work directly and at a higher level than ever before. In 1994,
EPA through its regional offices offered states $6 million in Pollution Prevention Incentive Grants. We have
allocated another $6 million for 1995.
Pollution prevention is becoming a major factor in the Agency's media grants awarded in support of air,
water, and solid waste programs delegated to states to operate. These program grants total approximately $628
million a year. EPA Administrator Carol Browner moved to ensure that these consider prevention as part of
traditional inspection and compliance strategies.
The range of pollution prevention activities Agency-wide is without parallel. It speaks to our strong
commitment to empowering communities with environmental data so they can more fully participate in shaping
cheaper, cleaner, smarter strategies that reduce and prevent pollution.
In closing, let me say I believe your work here this week in Boston will be significant. It can lead to new
and expanded partnerships to advance the public's right to know the environmental dangers it faces and to
undertake measures to prevent potential risk from toxic chemicals, hi the long run, the work done here can help
safeguard the environmental health of this generation and the generations to come. Thanks to the organizers of
the conference and thanks to all of you for attending the conference today.
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1994 TRI Data Use Conference Opening Plenary
Opening Plenary
Moderator
Joseph Carra, Acting Director, Office of Pollution Prevention and Toxics,
U.S. Environmental Protection Agency
Speakers
Stephen D. Hanna, Ph.D., Assistant for Environmental Information, Col/EPA
John A. E. Hannum, Head of Pollution Prevention andEPCRA Policy Section, Environmental Protection
Safety and Occupational Health Division, Office of Chief of Naval Operations, Department of the Navy
Nancy Ekart, Advanced Environmental Representative, Eastman Chemical Company
Gary Bass, Executive Director, OMB Watch
Joseph C*rn, Acting Director, Office of Pollution Prevention and Toxics, U.S. Environmental Protection
Agency
Good afternoon. In this opening session, we're going to be talking about expanding the right-to-know.
We're fortunate to have several very knowledgeable speakers here with us. Before I introduce them, I would like
to set the stage for the discussion and share with you some perspective from my office, the Office of Pollution
Prevention and Toxics. As the office that runs the Toxics Release Inventory for EPA, we have been a leader in
EPA on behalf of right-to-know. We pushed this movement within EPA because we are convinced that it can
lead to real environmental results, especially pollution prevention, and that it can do it in a way that is cheaper
and fester than the traditional approaches. Our attitude has been greatly influenced by a couple of factors.
First, there have been dramatic changes in public expectations about corporate environmental behavior.
That in turn has resulted in changes in business attitudes toward environmental issues. The second factor is
increasing demands on EPA, coupled with continually-and we expect it to get worse—shrinking resources. That
has caused us to search for more effective ways to change corporate behavior. These factors can and do come
together in a way that suggests a different model for government role in environmental protection. A model
where government sets goals, enlists the participants in achieving those goals, provides help as need and as
appropriate, measures progress, sets up systems to measure progress, and reports to the public on progress and
recognizes success.
The TRI has relied on two of the elements of this model: measuring progress and reporting to the public.
When the 33/50 Program was bom, which you've heard about several times today already, we added the other
elements into the TRI system. We set goals and hence the name, 33/50. We enlisted participants, as you heard
today, about 1,300 of them. Then, we measured progress and continue to measure progress and report results
using TRI systems. We will be recognizing final results but we've been akeady recogmang interim results. Just
a few months ago, we had an awards program that we held in Williamsburg.
The 33/50 Program is a national program. But on any day, citizens and corporate officials can and do
use the same approach at grass roots level. Using TRI data, citizens have increased their knowledge of toxics
in their communities and have demanded and gotten improvements. Using TRI reporting systems, corporate
officials have educated themselves about the environmental activities of their facilities. They, too, have'demanded
and gotten results. Thafs why we also refer to the Toxics Release Inventory as the CEO's right-to-know.
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Opening Plenary 1994 TRI Data Use Conference
In this session, we'll be talking about expanding the right-to-know concept. You've heard us refer to
Phase I, which we've just finalized, nearly doubling the number of chemical. We are working on Phase n,
expansion of industries. Federal facilities are being added by executive order into TRI. And Phase m, exploring
the idea of extending the data collection into chemical use reporting. The right-to-know concept can also be
extended beyond the EPCRA mandated programs into giving greater access to other EPA databases — and not
just singularly, but in an integrated way, so that the public can, at some point, get a facility profile that has all
of the environmental information in one place. That would truly make some common sense.
D
Stephen P. Hanna, Ph*D., Assistant for Environmental Information, Cal/EPA
Expanding TRI in Environmental Programs
Background
The Toxic Release Inventory program (TRI) of U.S. EPA was implemented in 1987, with the first reports
due in July of 1988. To my knowledge, this was the first environmental reporting program developed with the
primary purpose of collecting and distributing information on environmental releases. Given the prior history
of many U.S. EPA environmental data systems, few observers felt that the TRI system would succeed. However,
the TRI system was implemented on time and must be viewed as a success given the purpose and limits within
which it was developed. In viewing the future of TRI, it is useful to examine the development of TRI and its
relationship to U.S. EPA programs.
Reasons for TRI Success
One reason for the success of TRI is its development specifically for the purposes of information
collection and dissemination. Most regulatory data systems are developed in support of specific regulatory
programs and must compete with program activities for funding.
Some comments/observations on the success of TRI
One important factor in the successful implementation of TRI was the adequate initial funding of the
information management system.
TRI has had widespread impact and use.
Data quality of TRI is relatively high because its widespread use and dissemination has utilized the
public sector as reviewers of data quality.
States receive copies of the forms and have been included in policy discussions by OPPTS since the
beginning of the program.
TRI is one of the few existing systems that contain cross-media environmental release data
Some comments/observations which have been critical of TRI
TRI has no direct link to regulatory programs and data are not audited for accuracy.
TRI is not comprehensive enough - not enough chemicals or facilities.
Submittal of forms to both U.S. EPA and states creates some data system synchronization problems.
TRI and U.S. EPA Priority Issues
TRI has assumed a major role as a source of data in most U.S. EPA initiatives developed since TRI
began. While most of these initiatives have probably not been established with TRI specifically in mind, many
have a clear link to TRI. As a repository of quantitative chemical release data from 1987 to 1993, TRI has
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1994 TRI Data Use Conference Opening Plenary
become an increasingly important source of data for high-visibility U.S. EPA programs. Examples of such
initiatives are:
Pollution prevention - Pollution prevention measurements must be multi-media in nature to be effective.
TRI remains the only national source for quantitative multi-media data
Multi-media regulatory perspective - As described for pollution prevention, TRI is the only national
source for quantitative multi-media data.
Environmental justice - TRI is one of the few sources of data available for spatial analyses of exposure
to chemical releases.
State partnerships - U.S. EPA has maintained an effective dialogue with states since the inception of
TRI.
Voluntary initiatives - A major factor in the success of the 33/50 program has been the availability of
TRI data to measure the quantitative reductions in the releases of 33/50 chemicals.
Environmental indicators - Any discussion of environmental goals and indicators by U. S. EPA or states
includes TRI data as a source of chemical release volumes.
Future Directions
As mentioned previously, TRI is the only national source for quantitative multi-media chemical release
data Current efforts by U.S. EPA to increase both the number of chemicals and the size of the reporting universe
will potentially enhance the utility of the data However, there is currently no direct link to the traditional media
program areas such as air, water, and hazardous waste. Development of these links could be one of the most
productive future developments regarding the TRI program. The incorporation of TRI reporting into the
regulatory activities of these programs could result in the creation of a comprehensive and integrated multi-media
view of chemical releases to the environment. Accompanied by a reduction in the collection of other
programmatic data, this effort could also result in a simplification and consolidation of reporting requirements
which would increase data quality while reducing the industry reporting burden.
D
John A. E. Hanmnn, Head of Pollution Prevention and EPCRA Policy Section, Environmental Protection
Safety and Occupational Health Division, Office of Chief of Naval Operations, Department of the Navy
I was asked at the last moment to speak at this conference, the original intent was to have Sherry
Goodman up here. I admit to not being the absolute substitute for Sherry Goodman, but I will try. However,
I would like to talk to you a little about what's happening in the Defense Department. I don't pretend to speak
for all the federal agencies. That would be disingenuous on my part. Quite frankly, obviously, my piece of this
is the Department of the Navy. But, in terms of expansion of TRI, an event took place in August of 1993 which
significantly expanded TRI. The signing on the third of August of Executive Order 12856 brought us kicking
and screaming into the whole realm of EPCRA and pollution prevention, somewhere we had never formally been
before. Now, that isn't to say that we were not doing pollution prevention. We were certainly doing it in many
cases at our facilities. This was the first time in which the Department of Defense had been formally tasked to
do this. The key provisions are listed for you here. There are a number of other things ongoing, including things
like environmental justice and public participation. But those are the principal ones which are causing a great
deal of activity on our part. Some of the time lines that we're under are quite short. We had to begin with
calendar year 1994; actually, some of our actions began before that in late 1993. The emergency planning
notification part in March of this year, the emergency response plans in August, along with the MSDS's and the
TRI finished by the end of this year. So, we're winding up our baseline year as I speak.
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Opening Plenary 1994 TRI Data Use Conference
Our first TRI report, based on the '94 data is due in July of '95 and, as Lynn said earlier, will be reported
out by EPA in the spring of '96. There are a number of things that we have done in order to make this work.
For one thing, the Department of the Navy has put together a pollution prevention strategy that went up to the
Secretary of Defense office in August and is being incorporated into the DOD Pollution Prevention Strategy,
which will be issued in December. In fact, next week I understand, the plan is to sign the strategy but it may be
a bit closer to the end of the year. We have Installation Pollution Prevention Plans, which are due by 31
December 95. Part of what we have done in that regard is put together a standard operating procedure for
installation pollution prevention plans. That document has been completed. We developed a generic plan so that
our facilities could have a framework in which to operate. The draft and generic plan will prototype in two sites;
one in the east coast and one on the west coast A final plan, a Standard Operating Procedure (SOP) was issued
in June of 1994. So, all the Navy facilities now have a way of developing a standardized plan that will look,
within the context of their business, more or less alike. It will have the same elements in it.
Under Standardized Document Review, which is a major problem for us, much of what we do is driven
by standardized documents. Mil specs, mil standards, things of that kind. It makes it much more difficult. You
cant go in and say, "Well, substitute A for B," because you may wind up killing somebody if you do that. The
example that I have used before, if I take a recycled product and I put it onto a forklift and that forklift fails, I may
lose the forklift, I might lose the material on the forklift, but I probably haven't done a whole lot of other damage.
If I put that same recycled product in an F-14,1 run the risk of not only losing the plane, several million dollars
worth of aircraft, but worse, I risk losing the pilot and the ASO. Those are irreplaceable. We cannot afford to
do that kind of thing.
The other misconception that I need to correct right here is, I heard recently again for the umpteenth time
is, that commanders of military bases are worlds unto themselves. Yes, ladies and gentlemen, up to a point, they
are. However, when it comes to controlling their resources, they are not. That is one of the problems that we're
going to have to face, both collectively and separately, as far as meeting this challenge is concerned. Money is
programmed two, three, four years ahead of time. We are working right now on the 1997 budget. That won't
be completed until some time after the first of the year. The consequence of that is, when an executive order
comes down in August of 1993, we have no money to work with. We took everything that's been done up to
now, out of operating funds. That means that there was a ship, a tank, an aircraft or a troop somewhere that
didn't get as much as they needed to do their job because we had to take it out of mission requirements.
Obviously, that impacts our readiness and our operability as a military force and we can't afford to do very much
of that In 1995 we were able to reprogram some money into the '95 budget from other areas, principally from
some compliance areas, where we had a little bit we could use. It gave us an edge and we're going full steam on
this.
We are emphasizing the technologies for significant reduction. Many of these have been identified, a
lot of them are currently available and being put into place. We're looking right now for short payback life, less
than two years, and good return on investment. That ROI is important because the way you can sell these
programs to people who have short budgets is to prove to them that they can save money. Our technology
transfer program is being significantly strengthened. We've got about $50 to $60 million in off-the-shelf projects
in the works right now. We are emphasizing principally off-the-shelf technology.
We still have a problem here, that is, defining what our role is. Keep in mind that when the Executive
Order was written, it removed all the SIC code restraints from federal facilities. So, we don't have the same
boundaries that industry does. In a sense, everything that we do is fair game. So, in order to put some
boundaries on mis, we are defining what we mean by primary mission. That's what the business of the Defense
Department is and what the business of the individual facilities is. That's important because we want to equate
this somewhat, to what industry does. Even though we don't have any SIC codes, we can put some finite
boundaries on here to allow some relief for small and ancillary uses of chemicals, but also to be sure that we
include any major uses which we have, which would support the mission of the Defense Department. We have
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1994 TRI Data Use Conference Opening Plenary
a working group, including all of the services and the Defense Logistics Agency, looking at defining what we
mean by primary mission and a lot of this is being done by inclusion, by example of what we are actually doing.
We have another unique problem here and that is base realignment and closure (BRAC). This is not
something that any other federal agency ever participates in. For those of you who are reading your newspapers
regularly, you'll see BRAC coming up every couple of years, another BRAC Commission meets and it decides
what bases to close down or realign. This has been a difficult problem. The question came up as to how do you
justify spending the resources to do pollution prevention plans and do TRI reporting for a base that's going to
close in a couple of years, and which has the bulk of its operating capability already removed from the facility?
The answer is, that we negotiated an arrangement with EPA which allowed us to report in December of 1995.
That gives us another six months for our closing bases, using an estimation technique based on work load,
similar facilities and other available data That is, we're not going to go out and dig up new data, we're going to
use what's already available, and put our pollution prevention planning into the base closure plans.
We still have some issues remaining with EPA that have not been brought to closure. One is inclusion
of releases from the remedial actions. Another is mobile sources. There is an on going discussion right now
about whether mobile sources in fact are part of — should be part of ~ TRI reporting. Our reading of both
CERCLA and EPCRA indicates not, but there are factions who see it otherwise. Stand-alone medical facilities
are unresolved. Currently, hospitals in the civilian community do not report. We have an exemption for base
medical facilities at the present time, but we're concerned about some of the stand-alone ones, such as Bethesda
Naval Hospital, Walter Reed Army Hospital and so forth, and the lack of fit within the SIC codes because what
we do does not fit. If s a square peg in a round hole.
Joe had asked me to talk a little bit about the data that we are gathering right now and which will be
finished at the end of this year for the first year's data. Anybody in industry already knows what the first bullet
is, if s difficult, it's costly. We estimated that for many of our industrial facilities, it would be approximately $1
million a year. Now, that's somewhat out of line with some of the EPA estimates, but I can tell you that one of
the reasons is, that we do over two hundred processes a year at each of our major industrial facilities. Those two
hundred processes are not done continuously. Most of the time, they're done intermittently. Sometimes, once
a week, once a month, sometimes once a quarter, or once a year, even. It makes it very, very difficult to keep
track of some of these materials when you're doing that.
We're on a learning curve. I will caution you that the data thaf s going to come out in 1995 will be like
the data that came out the first year from industry. Use it judiciously. Don't take it entirely to heart because we
are like everybody else, it's going to take us some time to get this thing spun up and final. It will cause some
skew. We're reporting on materials and processes not currently included in SIC codes. So, there will be some
skewing and there will be significant amounts of material such as MEK, methylene chloride, TCE, things like
that which will rise significantly in the numbers when we start reporting.
As far as expanding - by this, Tm not talking so much about right-to-know expansion, as the idea of
chemical use inventory as opposed to TRI. We will have our use data once we complete the baseline. If s being
used as we speak to prioritize our source reduction efforts. However at the moment, we've got several sensitive
areas; chemical munitions, special weapons, and ordnance in general, all of which cause some difficulty as far
as additional reporting is concerned. We've entered into the public participation effort in a fairly large way. Just
recently, weVe completed atwo day meeting that was Keystone facilitated and included a whole range of people
- Physician's For Social Responsibility, Sierra Club, Greenpeace was supposed to be there but weren't - but
a large number of environmental organizations of various political views, which turned out to be, I think, a very,
very good effort on both sides. There was a lot more understanding than I had gone into the meeting expecting
to find.
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Opening Plenary 1994 TRI Data Use Conference
We're developing public affairs guidance on TRI data reporting and we're encouraging our installation
commanders and public affairs officers to go out and talk to the community. Many communities have no idea
what the installations that are near them do, what kind of materials they use, why they use the materials and what
they are actually doing. They may be repairing airplanes, but that doesn't mean anything to them. We're
suggesting that they go out and actively talk to their communities and let them know what's going on. And
address potential concerns about the DOD TRI versus industry TRI reports, because they're going to see different
figures coming from us than they are used to seeing from industry.
Some things that have been driven by some of our efforts to date include the painting of ship parts using
carbon dioxide, a marvelous technique. It allows us to do a certain kind of de-painting operation with an
essentially benign agent and what you get is just the paint chips left over. IVD, which is Ion Vapor Deposition,
is a method using what looks like a huge vacuum crucible in which you put everything up to wheels and landing
gear and put ion bond aluminum onto the metal. It replaces a lot of hard chrome and cadmium plating. It's been
very useful and it turns out to last seven times longer than hard chrome plating. We're using aqueous parts
washers in a lot of places to replace TCE and methylene chloride and we are recycling a lot of grit from steel shot
blasting of ships' hulls to get rid of some of the copper and problems that we've had with some of other materials
that we were using.
One last one, which I am particularly pleased about is Consolidated Hazardous Material Reutilization
Inventory Management Program (CHRIMP). It was based on an internally developed software, HMICS, which
is Hazardous Materials Inventory Control System, which centralizes our hazardous material and hazardous waste
for control and management It's been prototyped now on sixty-three ships in the Pacific and Atlantic fleets. We
are distributing a Navy-wide manual and lessons learned have been incorporated. We just put out Change One
in November of this year, to bring those lessons learned into sync with reality. Just to give you an idea; on one
typical carrier in one six month period, we reduced thirty-five to fifty percent of hazardous material and thirty-
four to seventy percent of the waste, about $200,000 of disposal cost avoidance. That's for one single ship. Now
unfortunately, you can't see that very well, but thaf s my final one and I should be playing "Anchors Away" here.
But in point of fact, this is exactly how we see pollution prevention as the primary means of the Department of
the Navy and the Department of Defense to meet compliance with the environmental requirements to preserve
our access to sea and land. Thank you.
D
Nancy Ekart, Advanced Environmental Representative, Eastman Chemical Company
Expanding Right-to-Know in Environmental Programs
The TRI, as originally enacted under the Emergency Planning and Community Right-to-Know Act of
1986, has been of benefit to both the public and industry. Information on releases and transfers of specific
chemicals from manufacturing facilities is available to the public, with minimal effort. From an industry
perspective, the TRI has been a stimulant for reduction projects involving TRI chemicals, and it is also a good
measure of the chemical industry's success in carrying out its Responsible Care® program.
Under Responsible Care,® members of the Chemical Manufacturers Association are required to
subscribe to three goals which require (1) ongoing reductions in releases of chemicals, (2) ongoing reductions
in the amount of wastes generated, and (3) managing remaining wastes and releases in a manner that protects
the environment and the health and safety of employees and the public. During the 1988 to 1992 period, the
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1994 TRI Data Use Conference Opening Plenary
chemical industry reduced releases of TRI chemicals by 34 percent. So the TRI has been, and continues to be,
one good measure of whether, as an industry, we are succeeding in meeting the goals Tve just outlined.
pirection and Focus of Current TRI Program
Before considering how right-to-know issues might be expanded into other environmental programs,
we should reflect on the direction and focus of the existing TRI program, given recent and future expansions.
We need to think about what is gained or lost from such expansions, how the public and industry will benefit
from the expansions, and what right-to-know information is lacking in the EPCRA program that could more
suitably be picked up by other programs.
Phase 1
Phase I of EPA's planned expansion has just been enacted, with the promulgation a few days ago of a
final rule which nearly doubles the list of chemicals for which manufacturing facilities must annually report. The
addition of several other chemicals were deferred for listing, until the Agency has a chance to conduct further
analysis. If s likely, then, that the list of chemicals will continue to grow. The chemical industry supports adding
to the TRI those toxic chemicals that meet the statutory criteria for addition and that pose some reasonable
expectation of exposure to the public. Industry takes exception, however, to some of the chemicals on the
original TRI list as well as some that were added under Phase I, but this is not the forum to discuss that issue.
Rather, I'd like to discuss some of the potential problems that may result from such a significant expansion of
the chemical list, particularly from the addition of just a few specific chemicals.
As the TRI list of chemicals becomes increasingly long, the significance of the release numbers may be
diluted. EPA estimated in its proposed rule mat adding 313 chemicals to the list would expand the TRI database
by 26,000 reports. [If and when] the criteria air pollutants, i.e., carbon monoxide, sulfur oxides and nitrogen
oxides, are added, the total release numbers will be several orders of magnitude larger than in the past,
significantly distorting the current baseline. One question then is whether the very size of the revised database
will dilute the significance of the TRI.
Another question relates to whether the public will question the validity and relevance of the TRI
database, once it's understood that manufacturing facilities are not the major emitters of some of the chemicals
on the TRI. For example, based on 1991 data from EPA on the criteria air pollutants, if carbon monoxide is
added to the TRI, industrial sectors will report about 5.9 million tons of emissions. Sulfur oxide industrial
emissions will total about 5.6 million tons and nitrogen oxides, 4.3 million tons. Considering that the 1992 total
air emissions from manufacturing sectors were only 0.9 million tons and total releases to ajl media (air, land and
water) were 1.2 million tons, the emissions data relevant to just those few criteria air pollutants will dwarf current
emissions data Adding up the numbers, instead of about 0.9 million tons of air emissions, one can project about
17 million tons. What will the natural response from the public be, considering that the new emissions numbers
will dwarf the old numbers? It likely wont be favorable to industry unless the public understands that industry's
criteria air pollutant emissions account for only a small fraction of all such emissions.
Industry accounts for less than 9 percent of all carbon monoxide emissions. Seventy percent of all
carbon monoxide emissions come from automobiles and other transportation vehicles. Even forest fires account
for a greater level of carbon monoxide emissions than does industry. Whereas the 9 percent of carbon monoxide
emissions from industry are dispersed well up into the atmosphere through tall stacks, the CO emissions from
automobiles are dispersed at street level, with much greater exposure to the public. If the public knows that they
are the major emitters of a TRI toxic chemical, if they don't think of CO from cars as a major problem, and if they
aren't willing to pay higher costs for "cleaner" cars, then they might question why CO is on the TRI list in the
first place, as well as question the relevance of other chemicals on the TRI. Electric utilities account for 68
percent of all sulfur oxide releases, compared to industry's 25 percent, and electric utilities and transportation
vehicles account for nearly 75 percent of all nitrogen oxide emissions, compared to industry's 20 percent. Thus,
we will need to educate the public so that they become aware that the manufacturing sectors which report TRI
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Opening Plenary 1994 TRI Data Use Conference
data do not account for their true environmental exposure to these chemicals. A concern is that the public may
simply question the overall validity and relevance of the expanded TRI database.
Phase II
How can these concerns be addressed? One way is to include all major sources of the new chemicals
in the Phase n expansion, i.e., expand the list of sectors that must report TRI data to include all major emitters
of the expanded chemical list. To do anything less is to mislead the public. Information I have seen indicates
EPA is considering adding electric utilities, metal and coal mining facilities, materials distribution facilities, waste
management facilities and elements of the transportation sector (primarily airports). While not wishing this
costly reporting burden onto nonmanufacturing sectors, out of fairness to current reporting sectors and to comply
with the public's right-to-know, the Phase n expansion is likely the right thing to do. However, if the Agency
doesn't include readily available information on automobile emissions, the public will still be misled as to the
major sources of several TRI chemicals, and EPA Administrator Carol Browner's goal to "provide citizens with
a more complete picture of chemicals that impact their communities" will not be met Further, if industry were
to spend millions of dollars on economically infeasible technologies in order to reduce its emissions of carbon
monoxide and the other criteria air pollutants, the overall effect on nationwide releases would be so insignificant
that neither industry nor the public would be well-served.
Phase UI
EPA's Phase in expansion would add new data elements to the Form R, the form on which TRI data are
submitted. The new data being discussed are mass balance information (sometimes referred to as materials
accounting data or throughput data) and worker exposure information. First, the EPCRA statute doesn't give
EPA the authority to collect such data Secondly, from industry's perspective, requiring mass balance
information is treading into dangerous waters and is not an appropriate expansion of right-to-know. We have
trade secrets to protect from our competitors, both at home and abroad, and if we were required to provide mass
balance data, those secrets could be jeopardized. The "competitive intelligence" community is very active and
very good. Through the use of reverse engineering, many secrets can be uncovered and unit efficiencies
jeopardized.
For example, catalysts are used to "speed up" a process, to make it more efficient. Our competitors
frequently know which catalyst is used in a given process. But the form of the catalyst used and how much is
used is information we do our best to protect. If the catalyst we use makes us more efficient than our
competition, then we can price the product lower and capture a greater portion of the market. If required to report
mass balance information, key use data will no longer be protected, our competition can figure out what we're
doing, and potentially serious economic impacts could follow. We would, in effect, be giving away our
technology to other companies at home as well as to those in foreign countries. This would also provide a good
incentive for U.S. companies to locate new facilities abroad, for the purpose of utilizing new technologies, rather
than building them in the U.S. By choosing a country without such stringent reporting requirements, a company
could recoup their research and development costs through protection of trade secrets.
It's unlikely that the general public has any real interest in knowing which process or processes account
for each chemical use, how much is consumed in a process and similar mass balance information. Simply using
and managing basic process chemicals in a responsible manner doesn't imply any significant element of risk to
the public. The public is already receiving information on releases and transfers of the chemicals, and
information is also available on which chemicals are stored on-site.
Having taken a snapshot view of the significant expansions of right-to-know under EPCRA, it's now
appropriate to discuss whether a need exists to expand right-to-know into other programs. There are extensive
reporting requirements under all the major statutes, e.g., the Clean Air Act, the Clean Water Act and RCRA
Much of that data is available to the public. Not all such information may be as easily attainable as TRI data,
but it certainly can be obtained from a number of sources. Perhaps rather than looking at ways to collect more
18
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1994 TRI Data Use Conference Opening Plenary
data for right-to-know purposes, we should be looking at ways to make currently reported data more accessible
to the public. This may be simply an educational process, in alerting the public to what information exists and
how it can be accessed. Or it may mean mat EPA needs to reformat currentfy collected data in a form more easily
understood by the public.
It's important to keep in mind that industry is spending enormous sums of money to comply with
existing regulations. We're all operating in a global economy, and it's not an even playing field out there, relevant
to environmental expenditures. Many of our competitors are working under regulations less stringent than ours.
So as we look for opportunities to expand the public's right-to-know, let's allow our industries to remain as
competitive as possible by utilizing to the greatest extent that we can the data we already collect. Lefs ensure
that our trade secret information is not jeopardized, and let's ensure that the public wants and will benefit from
any expansion. We need to be aware that while the public has a right-to-know, they don't have a right-to-know-
all. We have to know where to draw the line so that the best interests of both industry and the public are served.
D
Gary Bass, Executive Director, OMB Watch
I kiddingly said to Nancy beforehand that she was going to be night and I was going to be day. I didn't
realize how stark the differences really are, until she completed her speech. I don't have any pretty charts. I'm
just going to tell you, as I see it, the world in terms of expanding the right-to-know. Let me start from a view
that says, access to government information is an essential citizen right. All the years in which we were missing
data, people were dying. Such government information has an impact on knowing whether it was lack of OSHA
regulation or whether it was due to lack of data, such as the TRI data We are talking about human lives
compared to the cost of product, as well as the cost to provide information and/or regulate chemicals.
The TRI is a major success story. I remember back when the law passed. Industry complained that it
was going to be too burdensome, too much paperwork. The public would misunderstand the data. It was too
technical. All of which proved to be false. The public interest community and the public at large has used the
data effectively. Steve put up some slides on how it's used. Examples that weren't there are good neighbor
agreements. Examples that aren't there are public education efforts. Examples that aren't there are toxic use
reduction efforts. There were many successful stories. So I congratulate the EPA today on moving forward with
Phase I, and I congratulate President Clinton on requiring federal facilities to report And to tell you the truth,
Tm looking forward to Phase n and Phase m.
Phase m, which adds the chemical use component, is going to be a royal battle with some industry
sectors, ft strikes me that we have to acknowledge the value of perusing the expansion of the TRI You know,
there is belief that when accurately reflected, mat release reductions clearly do not equal source reductions. Lynn
Goldman highlighted some of those very reasons for thinking about the expansion of the TRI regarding chemical
use. When you have release data, you don't necessarily know if a result is something that happened in the
product stage or in the planning or life cycle stages. You don't know where this has occurred. Paul Orum asked
a question earlier - Paul is with the Working Group on Community Right-To-Know in Washington, D.C. The
Working Group has identified three pathways in which chemicals can be released. One being consumed during
the production, the other is in the waste stream, and the third is in the product itself. The TRI tells us the middle
piece, the waste stream. We dont know the other components. If we are going to be responsible, if we are going
to deal with accountability, then the TRI must be expanded. We should be working as a community to find ways
to do it effectively, but to do it in a way that does not impose unnecessary burden on business.
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Opening Plenary 1994 TRI Data Use Conference
Now, let me turn and point to a broader agenda I think the TRI should be teaching us lessons about
right-to-know in the broader sense. OMB Watch has promoted for a number of years, that access to government
information is an essential quality. I think that the TRI can teach us how to do that within and throughout the
EPA. We should begin perusing that, if not just for the reason to enhance democracy, if not just for the reason
of creating greater public accountability, then for the very hardcore environmental reasons. We heard from Steve
about using multi media analysis and cross media analysis. Enforcement analysis has been thwarted because
we don't have the ability to cross link or find out information by cutting across different EPA regulatory
programs. On top of that, industry has complained about burdens imposed on them. It is very difficult to begin
even addressing innovative or clear ways for reducing burden unless you have access across the different
regulatory programs to identify areas where reductions can occur. So, it's essential to move in that way. It will
cost money initially, but when stacked up to the long term benefits that all of us as a community will incur,
whether it's industry, whether if s public interest, or whether it's government, the costs are minimal.
I'm going to give you five ways in which EPA should pursue a broader light-to-know agenda I use five
because we can go one, two, three, four, five and still count on the desk. First of all, I think that they should
adopt a general right-to-know principle. The Office of Management and Budget, about a year and a half ago,
published something called "Circular A-130." It talks about management of information resources. It
fundamentally shifted the policies of the past decade away from privatizing government information, away from
the thrust of "don't collect information," away from the notion, "even if you collect, don't disseminate
information," to, "encouraging agencies to actively disseminate information." EPA should embrace that in a very
broad way by putting, as principle and objective, making the Freedom of Information Act a vehicle of last resort
instead of first resort. We should be able to get information and EPA should have the responsibility to
affirmatively put it out to us, and put it out in ways that makes sense. There was a comment earlier today about
building the capacity of all of us to use this data I think EPA has some responsibility to ensure there are ways
of building that capacity. And, I mink EPA has the responsibility to ensure that cost is not a barrier to the public
getting access to the data If not just because of the environmental justice issues, but because of the public's
right-to-know.
The second point, just as Nancy said, "protect confidential business information(CBI)," I say, "revise
CBI." There is a Hampshire Institute study just on the Toxic Substances Control Act (TSCA) showing that,
depending on which part of TSCA you look at, twenty percent of health and safety reports that generated are
exempt automatically as confidential business information. Ninety percent of pre-manufacturer notices from new
chemicals are exempt under CBL And how do you claim CBI? You check off a form for certain parts of TSCA.
For a couple of bucks, you can check it oft
The right-to-know is meaningless if there are huge gaps of information. An empty box is not worth
much. CBI needs to be revised, and I must say that EPA again deserves to be congratulated. On November
23rd, the EPA published a proposed revision to Freedom of Information requests related to confidential business
information. One of the principles in there is up-front substantiation. That is, when the request for confidential
business is made, it should be the industry's responsibility to identify why the request is being made. It should
not be the EPA's responsibility to verify the request. It has worked extremely well under the TRI law. By the
way, I think that there are other components under the CBI issue, but we'll hold on them.
The third point, besides incorporating the RTK concept and the CBI revisions; is to involve all of us in
the design, implementation, and coordination of all parts with state and local governments. I am really tired of
public access agendas not involving the public. The EPA has now done this for a number of years.
There is something called the "Solomon's Island Group." This group, which met in Solomon's Island,
Maryland, met to discuss public access. Nobody from the public was invited. When we requested it, we were
turned down. I'm tired of that! OMB is going to announce on Wednesday of this week, a new initiative called
the Government Information Locator System, which is going to allow all of us access to an inventory of
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1994 TRI Data Use Conference Opening Plenary
government information. There are going to be Government Information Locator Systems (GILS). There is
going to be a GILS Board. Well, in me draft of the notice, it wasn't going to involve the public. The GILS Board
was going to evaluate public access. But the compromise is, to make the GILS Board recommendations subject
to at least public notice and comment. Hooray! From now on, we must — and EPA should — incorporate all of
our views. I dont say that just from an environmentalist's perspective. I say it from industry's perspective, and
I say it from state and local government's perspective. One of the biggest problems is the coordination that Steve
alluded to. Coordination must be ongoing with state and local governments and the federal government in data
collection:
The fourth point is that the EPA has to adopt and encourage a variety of formats and access to
government information. In other words, provide multiple pathways to the same information. Paper is good and
paper is needed. CD-ROMs are happening as well as diskettes and on-line services. What we have is the
"Information Superhighway." We have got to capitalize on the whole new information infrastructure. Internet
in and of itself is not a solution. Internet may turn into the people's democracy, but today, it is costly,
cumbersome, and difficult to use. When we have the adult's version of Internet, then we can have democracy.
We don't have it today. EPA should make good use of intermediaries, whether they are the non-profit
community, whether they are libraries, whether they are state and local governments. However, intermediaries
should not become a substitute for the EPA not doing the activity. In other words, EPA, too, has responsibility.
The fifth point involves data linkage and integration. We at OMB Watch, along with the Unison
Institute, run something called RTK Net, the Right-To-Know computer network. In fact, I think we're going to
be doing a demonstration and training. We discovered when we put the TRI data up on RTK Net that users
started saying, "MORE! It doesn't help to just have this. It's important to link it up with this." For example,
we posted, after putting up the TRI data, census data so that the environmental justice community can begin
looking at any potential disproportionate impact of toxic releases. People said we need water permit data We
need the civil suits. We need a number of other databases. EPA does have something called FINDS database,
which is a facility index system. Just as Steve's humorous slide showed, we went and plotted some of FlfJDS
longitude data and ended up also in the ocean. Data quality is very important.
The five points again are: right-to-know agenda; CBI revisions; public input and public involvement;
variety of formats and pathways; and data linkage and integration. On that last point, EPA could easily take the
lead and provide a real meaningful public access system.
I mentioned that OMB is going to be implementing its GILS on Wednesday. EPA can go well beyond
the vision of GILS to provide access to information itself, instead of access to inventories about information.
Now, all of this is not going to be easy. I gave two other speeches this morning about the 104th
Congress that's coming to Washington, DC. I have an analysis called "Eye of the Newt" I probably don't need
to say more, nonetheless, I will. We. are talking about expansion of information. We heard at least one sector
of the industry raise deep concerns about expansions and access issues. The House Republicans' Contract with
America makes it very difficult to collect information. In fact, they require a five percent cut in information per
year for four years. They make it very difficult for agencies to issue regulations. In fact, they make a requirement
of 6-1/2% cut in regulations per year, which means changes in laws. They make no bones about it They are
going after things like Superfund, safe drinking water, clean water, the list goes on. Also included is another
good sounding rhetoric-a balanced budget amendment We're talking about resources that are required to do the
things we saw today. A balanced budget amendment would be an across-the-board, twenty percent cut in all
government programs. Trust me, it will not be across-the-board. The point is, it's going to be very difficult.
Let me conclude by telling a story. Maybe that's the best way of expressing my theory of what is likely
to come with the new Congress and potentially trying to achieve this new found right-to-know agenda that many
of us in this room care about There is a story about a tiger and a Christian. The tiger was chasing the Christian.
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Opening Plenary 1994 TRI Data Use Conference
The Christian got backed into a corner. The tiger is licking his chops and getting ready to pounce on the
Christian. The Christian quickly says a prayer and says, "Lord, make that tiger a Christian. Let him understand
the ways." Miraculously, as the tiger got ready to leap he fells to the ground and looks up and says, "Lord, thank
you far the meal I'm about to eat!" In many respects, the Contract with America is licking its chops and saying,
"Thank you, Lord. Look at the meal Tm going to eat." Thafs the environmental programs. Thanks.
D
22
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1994 TRI Data Use Conference Pollution Prevention Track - Session 1
Session 1 - How TRI Can Drive Pollution Prevention
Session Leader
Kevin McDonald, Coordinator, Pollution Prevention Program, Minnesota Office
of Environmental Assistance
Speakers
Michael Aucott, Research Scientist, Office of Pollution Prevention, New Jersey Department
of Environmental Protection
Lisa Doerr, Minnesota Program Director, Citizens for a Better Environment
Ivan Kuzyk, ConnTAP
Tova Reinhorn, Environmental Specialist, Occidental Chemical Corporation
This session set the stage for the conference by providing the reasons for addressing pollution prevention
in the context of TRI. The speakers discussed how state, industry, and communities are using TRI data to
advance pollution prevention efforts. They also provided an overview of how TRI and Section 8 data help to
target efforts and measure progress in preventing pollution.
Michael Aucott, Research Scientist, NJ Department of Environmental Protection, Office of Pollution
Prevention
How TRI Can Drive Pollution Prevention
A discussion of how the TRI can drive pollution prevention requires, first, an agreement on what is
meant by pollution prevention. In New Jersey's Pollution Prevention Act, pollution prevention is defined as:
"..changes in production technologies, raw materials or products, that result in the reduction of the demand for
hazardous substances per unit of product manufactured and the creation of hazardous products or nonproduct
outputs..." The definition states further that pollution prevention includes, but is not limited to, raw material
substitution, product reformulation, production process redesign or modification, in-process recycling, and
improved operation and maintenance of production process equipment."
Under New Jersey's pollution prevention rules, TRI companies must prepare pollution prevention plans
and submit summaries of these plans to the NJ DEP. These summaries must include five-year goals for the
reduction of use and nonproduct output of TRI chemicals. The goals are determined by each facility, and can be
zero. Implementation schedules also are determined by the facilities. Nonproduct output is, essentially, everything
that leaves a process that is not product. Use is clarified in the rules as encompassing quantities (of TRI
chemicals) produced on site and brought on site, adjusted for changes in inventory.
How can the TRI drive pollution prevention, as so defined?
Few would argue that, since the inception of the TRI, much attention has been focused on the quantities
of TRI chemicals entering environmental media from TRI facilities. It also is apparent that, generally, such
quantities have decreased since 1987, the year of the TRTs inception. It can be argued, however, that at least
some of this decrease has been the result of changes in measuring these quantities, or to reductions in actual
industrial production.
Punuant to the federal Pollution Prevention Act of 1990, new data elements were added to the TRI Form
R which make the TRI better able to measure actual reductions in nonproduct output, and to account for any
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Pollution Prevention Track - Session 1 1994 TRI Data Use Conference
changes in TRI quantities which result from changes in production. These data elements appear in Section 8.
They include, for each facility and each chemical above threshold quantities, the following data elements:
quantity released
quantity used for energy recovery on-site
quantity used for energy recovery off-site
quantity recycled on-site
quantity recycled off-site
quantity treated on-site
quantity treated off-site
production ratio or activity index
identification of source reduction activities
The first seven of these items, in total, can be considered to encompass nonproduct output (as long as
the recycled on-site quantity does not include quantities recycled in-process). The production ratio can enable
the adjustment for quantities to account for changes in production from one year to the next. Thus, the TRI is
now capable of measuring, at a facility-wide level, at least the nonproduct output part of what is meant by
pollution prevention, as defined above.
It seems evident that what is not measured is not as likely to be managed as what is measured. To the
extent that the focusing of public attention on the nonproduct output quantity of a facility will encourage it to
reduce that quantity, the present TRI will drive such reductions.
Often, however, the value of information depends as much on what it doesn't reveal as on what it does.
By showing part of a pie, data can indicate that there is a part of the pie which is not visible. The TRI, when it
first revealed quantities of toxics released to the environment, led to the realization that there could be large
quantities of substances leaving industrial processes which were not products. It thus helped clarify that a focus
on the improvement of industrial efficiency would necessitate the actual measurement of such quantities.
Now, the TRI does include a measure of nonproduct output. Does it therefore show a complete picture
of reductions in actual quantities of toxic chemicals entering the environment? A look at other databases reveals
that, for some chemicals, it may not.
As will be discussed in an upcoming article by this author in Pollution Prevention Review, the
augmentation of the present TRI with chemical throughput information would greatly increase its ability to
present an accurate picture of pollution prevention activities and the progress that facilities are making on
pollution prevention. Methylene chloride (dichloromethane), provides a case in point. This example, and several
others, are discussed in more detail in the upcoming article.
This chemical was, according to other data sources1-2, produced in a quantity approximating 375 million
pounds in 1992. Much of it was apparently incorporated into products such as paint strippers and aerosols, and
thus could be expected to enter the environment at point of use of these products, with significant human
exposure possible. The 1992 TRI Section 8 data indicates that approximately 287 million pounds of the chemical
was managed as production-related wastes by TRI facilities. As is discussed in the article, this quantity may be
inflated due to multiple-counting. However, it is clear that, assuming that most of the activity with the 375
million pounds produced is accounted for by TRI facilities, at least 375 - 287, or 88 million pounds of methylene
chloride, is unaccounted for by the TRI.
The TRI, in conjunction with these other data sources, leads to questions about the fate of this 88 million
pounds. How much of this quantity enters the environment? How quickly, or directly, does it do so? Are there
significant human exposures or environmental risks associated with this quantity? And, are there pollution
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1994 TRI Data Use Conference Pollution Prevention Track - Session 1
prevention approaches such as raw material substitution or product reformulation which can be instituted, or are
already underway, which can reduce concerns over methylene chloride exposures in a cost-effective manner?
Once again, the TRI, partly due to what it does not show as well as because of what it does, can help
drive pollution prevention to a higher level, and can point out areas where additional information, such as
industrial throughput, could be useful in encouraging pollution prevention.
End Notes
1. United States International Trade Commission, "Synthetic Organic Chemicals: U.S. Production and Sales,
1992," Publication 2720, USITC, Washington, DC, February, 1994.
2. Chemical Marketing Reporter, "Chemical Profile: Methylene Chloride," Volume 241, Number 8, March 2,
1992.
D
Lisa Doerr, Minnesota Program Director, Citizens for a Better Environment
How TRI Can Drive Pollution Prevention
Introduction
Citizens for a Better Environment (CBE) was founded in 1971. We are a midwestem environmental
organization involved in local, state, and national policies. We have offices in three states - Minnesota,
Wisconsin, and Illinois ~ and have more than 170,000 contributors around the region.
Unlike many environmental groups, CBE's program focuses on protecting the public health in urban
industrial areas, not on preserving wilderness or building new parks. We believe that every place on this planet
is sacred, not just those which have been set aside by Congress. For us, environmental issues are very much
justice issues. Decisions made about where and how much to pollute impact families and workers, as well as
the air, land, and water.
Pollution prevention has been amajorfocus of CBE's work for nearly a decade. In Minnesota, we helped
author and lobby the 1990 Toxic Pollution Prevention Act (TPPA). We have also succeeded in amending it
several times. These changes include:
Expanding TPPA and the Community Right to Know Act to include non-manufacturers;
Creating a Community Assistance Program that provides technical support to local communities on
pollution prevention; and
Removing a cap on the pollution prevention fee which unfairly rewarded large toxic polluters.
In addition to these successes, CBE has worked for five years to require that Minnesota toxic polluters report
their use of toxic chemicals. This data is needed to provide public accountability that pollution prevention is
happening.
CBE also serves on two national pollution prevention projects. These include the U.S. Environmental
Protection Agency's (EPA) Common Sense Initiative and the Great Printers Project.
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Pollution Prevention Track - Session 1 1994 TRI Data Use Conference
Minnesota Good Neighbor Project
I am here today, however, to talk about our work in Minnesota on the Good Neighbor Project. This
project is designed to increase the effectiveness of Minnesota's Toxic Pollution Prevention Act (TPPA) and the
federal Community Right to Know Act, specifically the Toxic Chemical Release Inventory (TRI). We begin by
raising community awareness of local TRI facilities and stressing the importance of pollution prevention. From
there we provide the technical assistance needed for local citizens to work positively and proactively with toxic
polluters to maximize pollution prevention efforts. Our staff includes two seasoned community organizers and
a chemical engineer.
The vehicle for this positive interaction is the Good Neighbor dialogue. The goal of these dialogues is
to establish mutually agreed upon pollution reduction goals that go beyond the requirement of the law.
Like most state-level pollution prevention legislation, Minnesota's TPPA is based on TRI data. Under
TPPA, more than 500 facilities required to report TRI data must develop toxic pollution prevention plans every
three years and submit annual progress reports. Pollution prevention plans remain confidential. Annual progress
reports, based on information in the plan, must be submitted to the Minnesota Pollution Control Agency
(MPCA) and are available for public review.
While companies are not required at this time to include communities in the planning process, the law
provides an excellent vehicle for focusing discussions between these parties. Bringing community pressure to
bear in the planning process plays an important part in implementation of TPPA. The law provides for no
enforcement of the goals set by a company in its plan. With no state authority to answer tor community
involvement offers the only real leverage available for holding a company to its stated goals.
Get to Know Your Local Polluter: Profiles of Minnesota's Top 40 Toxic Polluters
To begin our work on the Good Neighbor Project, we published a report in 1993 called, Get to Know
Your Local Polluter: Profiles of Minnesota's Top 40 Toxic Polluters. The Top 40 were chosen based on 1990
TRI emissions of the 17 chemicals targeted by the EPA's 33/50 program. This 300-page report filled several
roles. First, the individual profiles supply communities with the basic information they need to begin positive
discussions. While all of this data is available to the public, this is the first time it has been compiled in one
accessible format Second, CBE staff used this information to set our staffing priorities. Finally, in the process
of developing these profiles, the state's first qualitative look at TRI reporters emerges. Information included for
each of the 40 facilities includes:
1.) Maps of the major streets, schools, health care facilities and water bodies within a one and two mile
radius of the facility;
2.) Business information, and company and labor contacts;
3.) History of a facility's compliance with environmental regulations;
4.) Community Right-To-Know data on the amount and types of chemicals stored on-site and released to
the environment, and reported accidental releases;
5.) Known potential human and environmental effects of Toxic Release inventory (TRI) chemicals;
6.) Local climate information;
7.) Local population analysis based on 1990 census, including total population, sensitive populations, and
people of color; and
8.) Community resources in the area, including health facilities, religious organizations, business
associations, civic associations, schools, citizen organizations and Minnesota regional review
Committees, and municipal government contacts.
Community Organizing
Since publishing Get To Know Your Local Polluter in January 1993, CBE staff have been active in
communities surrounding 18 of the 40 facilities. These run the gamut from large multi-nationals such as 3M,
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1994 TRI Data Use Conference
Pollution Prevention Track - Session 1
Ford, and ICI Fiberite, to family-owned outfits such as Superior Plating and Crystal Cabinets. They are also
spread evenly between urban, suburban, and small town communities. See the Table 1 for a summary of the
types of communities we have worked in and the response we have had as of November 15,1994.
As the table below indicates, the response from communities to our project has been excellent. There
have only been two places where we could not pull together a committee. Responses from facilities have come
in many different forms. Several have simply refused to have any discussion at all, one company has published
a brochure in response, five are meeting with us at this time. We plan to continue work on this project for one
more year, at which time we will have a more thorough analysis.
for a Better Environment Summary of Minnesota Good Neighbor Project
Facility Name
3M
Alliant
American Naf 1 Can
Andersen Windows
Ashland Oil
Boise Cascade
Crown Cork Seal
Crystal Cabinets
3M-DFP
Federal Hoffinan
Ford
ICI
Mentor
Onan
Superior
S.B. Foot
Thermo King
Waldorf
Location
StPaul
Arden Hills
Mpls.
Bayport
StPaul Park
Infl Falls
Faribault
Princeton
Stillwater
Anoka
StPaul
Winona
Stewartville
Fridley
Mpls
RedWing
Bloomington
StPaul
Community Type
Urban
Suburban
Urban
Suburban/rural
Suburban
Rural
Rural
Rural
Suburban/rural
Suburban
Urban
Rural
Rural
Suburban
Urban
Rural
Suburban
Urban
Ownership
Multi
Multi
Multi
Family
Nafl
Nafl
Multi
Family
Multi
Nafl
Multi
Multi
Nafl
Nafl
Family
Local
Multi
Nafl
Response
Community
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
In Progress
Yes
Yes
No
Yes
Yes
Response
Facility
No
In Progress
No
La Progress
La Progress
N/A
Yes
Yes
No
In Progress
Yes
Yes
N/A
No
No
N/A
In Progress
Yes
Ivan Kuzyk, ConnTAP
I work with the Connecticut Technical Assistance Program (ConnTAP) which is a non-regulatory,
quasi-public organization that has been actively promoting multi-media waste minimization and pollution
27
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Pollution Prevention Track - Session 1 1994 TRI Data Use Conference
prevention (P2) among Connecticut manufacturers since 1987. ConnTAFs efforts in Connecticut are currently
mirrored, to a greater or lesser extent, in every other state.
In Connecticut, we have noticed interesting changes over the last seven years. One of the most
remarkable and pleasant changes is the tremendous difference that P2 elicits from the business and manufacturing
community. As recently as five years ago, P2 was often given short shrift by some manufacturers, who
considered it to be basically unrealistic, and its exponents to be somewhat naive. Tilings have changed. Today,
many of Connecticut's largest manufacturers have already dedicated resources to pollution prevention initiatives
and many smaller companies are anxious to get on board. Enough case studies have been published in the past
few years to convince even the greatest skeptics that reducing the volume and toxicity of waste not only makes
good environmental sense, but good business sense as well.
Now mat we find ourselves in agreement over the benefits that can be realized through P2, groups like
ConnTAP often find themselves disagreeing with industry over what P2 actually is. Many generators, for
example, consider recycling and P2 to be synonymous. They define pollution prevention broadly enough to
include any activity that results in a reduction in the quantity of waste going to disposal. They consider more
exclusive definitions of P2 to be nothing short of pedantic. A recent article by Karen H. Rasmussen in Pollution
Prevention Review (Summer 1994) offers a good discussion of this issue.
At ConnTAP, we cannot afford to let definitions become obstacles to the work we do with industry. We
do, however, adhere to a rather strict interpretation of what P2 is. We agree with the EPA's waste management
hierarchy, which identifies source reduction as the most preferred method of waste management, followed by
recycling, treatment, and disposal. In this hierarchy, P2 is defined as: Practices that reduce, avoid or eliminate
the generation of pollution which is released into the environment, prior to recycling, treatment, or disposal,
so as to reduce risk to health and the environment.
From this definition, it follows that P2 has only one component: source reduction. Accordingly, only
closed-loop recycling falls within the bounds of this definition. Source reduction is defined as any activity that
reduces or eliminates the generation of hazardous -waste at the source, usually within a process. This might
include: equipment or technology modifications, process or procedure modifications, reformulation or redesign
of products, the substitution of raw materials, or improvements in housekeeping, maintenance, training or
inventory control.
At ConnTAP, we believe that by relying on a rather strict interpretation for what does and does not
constitute P2, we have maintained a consistent approach as our programs and outreach have expanded. Over
the last seven years, ConnTAP has grown and now offers a variety of programs that provide technical and
financial assistance to companies interested in P2 opportunities in Connecticut.
In addition to its presentations and sponsorship of seminars and workshops, ConnTAP provides
speakers to address P2 and environmental issues to business, industry and trade groups. From its Hartford office,
ConnTAP operates a resource library, which is open to the public, where an extensive collection of pollution
prevention and waste minimization materials are maintained. In addition, ConnTAP publishes a quarterly
newsletter, with over 2,000 subscribers, dealing with P2 issues and case studies of local industry. ConnTAP also
operates a technical assistance and referral telephone-hotline that handles up to 700 calls yearly. ConnTAFs
technical staff is able to provide answers to a variety of questions relating to P2 as well as offer financial analysis
to companies considering implementing pollution prevention projects. ConnTAP's financial assistance also
comes in the forms of grants and low-interest loans to industries seeking to capitalize or test new technologies.
ConnTAP's most exciting project, the Site Visit Program, employs six retired engineers. They operate
in two man teams, visiting plants and factories, offering on-site assessments of pollution prevention
opportunities. The site-visit engineers have been well received at over 75 companies in the state over the last
28
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1994 TRI Data Use Conference Pollution Prevention Track - Session 1
three years. They have prepared reports on P2 opportunities to a variety of companies ranging from brass platers
to chocolate makers.
ConnTAPs programs, while unique in Connecticut, are currently mirrored in a variety of other states.
According to a compendium, recently published by the National Pollution Prevention Roundtable, there are
currently about 130 organizations performing services similar to ConnTAPs at the state, county and municipal
level across the country.
Returning to the topic of our session: How TRI can drive pollution prevention, it is difficult for us, and
I mink for groups doing the work we do, to imagine TRI driving P2 at all. From our perspective, a complex mix
of economic and regulatory factors are what generally drive companies toward P2. This does not mean, however,
that the TRI has no potential worth with respect to what P2 assistance groups do.
ConnTAP has used TRI data in the past, and we see two possible uses for it in the future. In the first
instance, ConnTAP could use the TRI data as a tool that would allow us to target industries and companies for
specific forms of P2 information or assistance. In the past, ConnTAP has used computerized data to target
assistance to either specific industries or to generators of specific waste streams. Biennial hazardous waste report
data, in particular, has been a rich source for this kind of information.
Secondly, ConnTAP would use TRI if we could use it to accurately measure the scope of source
reduction and waste minimization activity currently taking place in Connecticut. As such a measure, TRI would
be an invaluable asset by allowing us to evaluate our P2 successes and plan our future activities.
D
Tova Reinhorn, Environmental Specialist, Occidental Chemical Corporation
How TRI drives Pollution Prevention at OxyChem
The Toxic Release Inventory (TRI) - Releases and Transfers data, when first reported for 1987, alerted
companies to the amount of toxic chemicals being lost from their facilities. Estimates, calculation and
monitoring used for filing the Form R reports became more focused and successfully determined trouble spots,
sources of high emissions, mat subsequently were addressed by tight control or appropriate waste minimization
methods.
The TRI provided direct public access to release data, which increased accountability of companies.
Enhanced communication between companies and the public allowed for better understanding of issues of each
side and raised the level of responsibility. The TRI provided a public baseline that allowed companies to
demonstrate good faith efforts at reducing releases.
As a result of the TRI, the EPA, the states and companies initiated voluntary, publicly stated
commitments to release reductions via programs such as:
33/50 - Industrial Toxics Program that has targeted seventeen high risk chemicals for 50% reduction
by 1995, with an intermediate goal of 33% by 1993. This is one of the most reliable programs to
measure progress because mere were no changes in the list of chemicals or the data points included over
me years. OxyChem achieved the intermediate goal of 33% reduction in 1992, and the 50 % reduction
in 1993, two years ahead of the schedule.
EPA/CEO Voluntary Emission Reduction Program - fbrmerUS EPA Administrator, W. Redlry,
personally asked the CEO's of nine chemical companies to participate and OxyChem was one of them.
29
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Pollution Prevention Track - Session 1 1994 TRI Data Use Conference
The goal was to achieve 82% reductions of five TRI targeted chemicals between 1988 and 1992. The
program has been completed; OxyChem has achieved the goal by initiating projects at seven of our
facilities, at a total cost exceeding $10 MM
Individual company goals. OxyMin is OxyChem's Pollution Prevention (P2) and waste minimization
program that was initiated in 1984. The program has evolved during those years and gradually it has
stressed more and more the TRI data as one of the major measurable parameters.
OxyChem publishes an annual corporate wide internal TRI status report, which highlights specific
facilities contributions to reductions or increases in the TRI data The report is distributed to all manufacturing
management and is highlighted in numerous corporate and facility wide communications, such as the "Annual
Environmental Report", departmental monthly reports, monthly environmental report "EnviroNews" etc.
Some of the problem areas that have not yet been solved are that there was minimal scientific study to
select chemicals or data elements. This resulted in a dilution of our pollution prevention efforts since we targeted
300 chemicals and will be targeting 600 chemicals instead of concentrating on the high risk ones.
Companies, regulators and the public are still trying to determine how to accurately measure progress.
The TRI database, including the baseline, is continually changing, and users have been attempting to adjust the
data in order to account for all the regulatory, reporting and production changes.
The Pollution Prevention Act (PPA) of 1990 significantly expanded the reporting requirements with the
newly required data (mostly included in the Sec 8 of the Form R), such as quantities of wastes on site and
off-site fix energy recovery and recycle and a comparison of four years of data, including estimates for two future
years.
The PPA has encouraged the pollution prevention efforts by shifting the emphasis to reduction of all
wastes not onry those released to the environment Releases of toxic chemicals into die environment are bad
and should be reduced. Wastes must be reduced since they drain our resources. When waste creation can not
be avoided it must be properly managed and should follow the hierarchy of recycling, energy recovery, treatment
and disposal should be only as a last resort Concentrating the efforts on the releases and waste reduction has the
additional benefit that use of toxic material becomes more efficient.
CMA member companies PPA data (million Ibs/year) for 1992 indicate that only 7% of all wastes have
been released to the environment OxyChem's 1993 data (million Ibs/year) indicates that only 8% of all wastes
have been released to the environment
CMA OxyChem
1992 1992 1221
Releases to Environment 868 27.0 23.2
On Site Recycle 6,293 61.3 29.5
Energy Recovery 919 21.6 22.3
Treated 3,844 179.7 181.6
Off Site Recycle 640 0.7 0.9
En Recovery 181 11.5 10.3
Treated 209 9.5 14.5
Total wastes 311.3 2822
30
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1994 TRI Data Use Conference Pollution Prevention Track - Session 1
As an example of how the PPA data requirements has effected OxyMin, our Pollution Prevention (P2)
program, we revised the goal setting format to reflect the Form R, specifically the Section 8 data We emphasize
the multimedia aspect of P2 efforts, in addition to media specific goals that we had in prior years. OxyChem
stresses the waste management hierarchy of recycling whenever possible with treatment and disposal being a
last resort We also requested additional information on how the goals will be achieved, such as specific project
information, personnel involvement and costs analysis.
A major roadblock in our compliance with the PPA requirements, as well as P2 efforts, is the lack of
definitions for data requirements such as wastes, recycling etc.,. This has caused variability in interpretation,
which has taken a lot of effort to resolve before submission.
The PPA data is difficult to understand because of duplication of data Same release data is reported in
different sections of the same Form R, for example there are different quantities released: Quantity released (in
Sec 8.1) include all Quantities released reported in (Sec 5) except for one time events (Sec. 8.8) but includes also
Quantity transferred off-site for disposal (Sec 6). All the data reported as off-site transfers is potentially
duplicated because the receiving facility is also reporting the same quantity as an on-site activity.
A final rule for implementation of the PPA of 1990 is still not available in spite of significant efforts from
regulators, the public and me industry. The proposed rule issued in September 1991 was rejected by the OMB
due to significant problems such as requiring data that was not based on the Act The reporting package for 1991
was delayed creating confusion and significant unwarranted work in the regulated community. Significant work
has been done in the EPA's TRI Data Reporting NACEPT subcommittee and in an EPA Internal Workgroup.
Draft Guidance was expected in Nov. 30,1994 with Final Guidance to be available in 1995 for 1995 Calendar
Year, but there should also be a timetable for Final Rule for PPA of 1990.
In summary, the TRI data, including the PPA data, have a significant impact on industry's P2 efforts that
is obvious in the continuous decrease in releases and transfers of toxic chemicals. The current reporting should
be fine-tuned to provide a consistent and more accurate method to measure progress. Regarding the TRI
expansion efforts by the EPA, I firmly believe that use of toxic material becomes more efficient when industry
concentrates its efforts on reducing the releases and waste. Use should not be targeted for reduction in the same
way as the TRI chemicals' releases have been targeted.
31
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Pollution Prevention Track - Session 2 1994 TRI Data Use Conference
Session 2: Using TRI Data for Pollution Prevention Planning
Session Leader
Tim Greiner, Greiner Environmental
Speakers
Eric Berliner, Environmental Specialist, Martin Marietta Armament Systems
Bob Lemcke, Hazardous Substance Information Office, Washington State Department of Ecology
Ron Robbing, Environmental Compliance Coordinator, United States Postal Service, Northeast Area
Brian Towns, Facilitator, Environmental and Maintenance Services, Galileo Electro-Optic Corporation
Tim Greiner, Greiner Environmental
Speakers in this session discussed how EPCRA data aids in pollution prevention planning. The speakers
focused on the following topics: (1) motivating employees to aid in data collection efforts, (2) using data to
introduce greener products and technologies, (3) working with data to set reduction priorities and measure
success, and (4) the utility of TRI data from one state's perspective.
The first speaker, Brian Towns, outlined his firm's use of total quality management (TQM) tools to
shape its pollution prevention program. Using TQM, Galileo brought environmental concerns into the
company's profit making equation. Galileo followed the classic TQM strategy — first organizing a task force of
upper management to define global priorities and then setting up teams comprised of employees from all areas
of the corporation. After performing a pareto analysis of pollution sources, the team set out the firm's three
largest sources. The environmental manager played a key role in compiling team progress, securing needed
resources for team activities, and shepherding team initiated policy changes through the task force. Moreover,
the environmental manager kept employees actively interested in the process, ordering pizza for team meetings,
broadcasting the success of team efforts, and seeking ways to make the pollution prevention planning efforts fun
and rewarding.
Galileo's efforts paid off quickly. In six months, the company reduced methanol usage 40%, acetone
60% and eliminated Freon and trichloroethane while increasing production output. The task force estimates the
changes have saved the company nearly $150,000 annually on production operation costs.
Building on Brian Towns' data collection talk, Ronald Robbins (second speaker) discussed the US Postal
Services (USPS) comprehensive chemical inventory data base. In an effort to comply with Executive Order
12856: Federal Compliance with Right-To-Know Laws and Pollution Prevention Requirements, the Northeast
Area Office complied chemical information on the products and substances stored or used at 65 major Postal
Service facility sites throughout the Northeast Area Using a contractor, USPS developed a database of all
products used at the major sites. Chemical components, excerpted from material safety data sheets, were entered
into the database.
USPS then targeted key chemicals for reduction and elimination from its operations. These chemicals
include ozone depleting substances and die 17 chemicals targeted by the U.S. EPA in its 33/50 program. USPS
used its EPCRA inventory database as a tool for pollution prevention by querying the database to identify those
products containing the targeted chemicals. Of the approximately 6,000 products identified as part of this
inventory roughly 263 were found to contain ozone depleting substances and roughly 1,122 contained at least
one of the 17 U.S. EPA 33/50 chemicals. Using the database, USPS targeted products for reduction and
replacement. To offer alternative products to its 65 sites, USPS tested replacement products and developed at
least two alternative products for every product set for elimination.
32
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1994 TRI Data Use Conference Pollution Prevention Track - Session 2
After completing his presentation, a number of audience participants were interested in the
transportability of the data base to other applications. Audience participants saw the database as a rich source
of information on environmentally preferable products.
Next, Eric Berliner from Martin Marietta Armament Systems described his company's internal chemical
tracking system. Built by in-house staff, the tracking system has the capability of monitoring the use of
chemicals through out the plant The system identifies where chemicals may be used, has a screening mechanism
to prevent misuse, and enables the environmental manager to screen all incoming materials for hazards. Martin
Marietta set up the tracking system as part of its efforts to establish waste reduction goals and measure progress
against those goals. The company prepares an annual evaluation of waste generation data, TRI data, cost
disposal data, and process knowledge. Since 1989, Martin Marietta has reduced its waste 62% (normalized for
employee hours). The company has reduced its number of TRI-reportable chemicals from 5 to 1 over the same
time period and hopes to eliminate the final chemical before the next reporting period.
The session's final speaker, Bob Lemcke, presented his state's research on measuring pollution
prevention. The research focused on two objectives - to evaluate the usefulness of several measurement methods
and to examine and to compare TRI and non-TRI data sources. Washington selected nine volunteer facilities.
For each facility, data sets were reviewed for completeness and then tested with alternative measurement
methods. Washington's study found that using different normalization measures — such as labor hours, sales,
or employees — yielded different results. The study concluded that absolute measures of pollution prevention
make sense on a state-wide or industry scale whereas normalized measures make sense at the facility level. In
evaluating different data sources, Washington found that indicators of pollution prevention such as TRI data,
RCRA waste data, air pollution data, and the state's dangerous waste data, were often not in agreement. The
over-riding lesson from a policy perspective was the need for chemical use data to facilitate more accurate
measurement. From a practical standpoint, researchers found that looking at data alone gave a poor picture of
facility pollution prevention progress. But by reviewing the TRI and other data sources before visiting a facility,
the researchers were able to ask questions of facility managers that brought out and clarified reporting
inconsistencies and errors.
D
Eric Berliner, Environmental Specialist, Martin Marietta Armament Systems
Using TRI Data for Pollution Prevention
The objective of Martin Marietta Armament Systems is to strategically align the business for long term
success. In developing a blueprint for longevity, Martin Marietta has established realistic pollution prevention
and waste minimization goals. Indeed, Martin Marietta has taken an extremely aggressive approach to
preventing pollution and reducing waste, accelerating the programs, in many cases, to achieve waste
minimization mandates ahead of industry as a whole. Martin Marietta recognizes the necessity of 100%
compliance with regulations and, more importantly, understands that the way to achieve compliance is to
significantly reduce the potential for waste generation at the front end of the process. This makes sense from an
environmental as well as a financial standpoint since Martin Marietta understands that to successfully compete
within today's tough economic market, the customers are looking for, and demanding "green11 product.
Martin Marietta defines pollution prevention as"... preventing or minimizing the generation or release
of wastes and pollutants, to the extent technically and economically feasible, throughout the lifecycle of the
product, including its design, production, packaging and ultimate fate in the environment." There are two
important elements to Martin Marietta's definition - the scope of the pollutants covered and the methodology
which can be used to achieve the reductions.
33
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Pollution Prevention Track - Session 2
1994 TRI Data Use Conference
Martin Marietta believes that goals for waste reduction should be established. Goals are important to:
1. Facilitate tracking and reporting;
2. Establish a target against which progress can be measured;
3. Demonstrate commitment and results to management, employees and the local community;
4. Provide the target necessary to motivate employees and maintain their interest.
Since Martin Marietta's ultimate goal is to eliminate wastes and releases to the maximum extent feasible, the
goals reflect a strong commitment towards aggressive reductions. Goals are established in quantifiable terms
(i.e. percent reduction in the production index) and include a time frame for implementation.
. In order to facilitate the quantification of goals, each year an evaluation of waste generation data, TRI
data, cost disposal data, and process knowledge is completed. Based on the analysis of the data, Martin Marietta
is able to prioritize the sources/generators of waste for minimization. Since 1989, as shown in Table 1, Martin
Marietta has been able to reduce its waste by 62% based on a production index. Furthermore, Martin Marietta
had to report on eight chemicals under TRI in 1988. In 1993 only one chemical met the reporting requirements.
Year
1989
1990
1991
1992
1993
Hazardous Waste
Generation (Ibs)
1302374
834785
652604
483000
259226
Total Std. Hours
Worked
2,678,158
2,112,216
1,922,219
1,700,000
1,410,460
Year
1989
1990
1991
1992
1993
Ratio
(lb/200,000hrs)
97264
79051
67908
56890
36757
Table 1: Hazardous Waste Reduction Since 1989
Bob Lemcke, Hazardous Substance Information Office, Washington State Department of Ecology
Washington State is one of four states participating in the U.S. Environmental Protection Agency's
(EPA) "Waste Minimization Measurement" project. The project is national in scope and, in addition to
Washington, includes pilot projects in Alaska, Ohio, and Oregon. The purpose of the national project is to
evaluate practical ways to measure pollution prevention (P2). Washington has two principal objectives in the
study:
1) To evaluate several measurement methods for their usefulness in measuring P2; and
2) To evaluate the available data resources for their adequacy in measuring P2.
This study represents the third phase of measurement efforts in Washington state. Work has been in
progress since 1990 to define principles applicable to quantifying P2 and to establish a computer system to
manipulate existing data for the purpose of measuring P2 progress.
Washington selected nine volunteering facilities from standard industrial classification (SIC) codes 20,
24,26,28,33,36,37, and 38 and reviewed a broad range of currently available data provided by these facilities
per federal and state reporting requirements. The data sets were reviewed first for compatibility and then
measurement methods were applied to each data set The TRI data were selected for more comprehensive study.
34
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1994 TRI Data Use Conference Pollution Prevention Track - Session 2
Data trends were graphed and several measurement methodologies were applied to a combination of the various
data sets. Washington considered direct measures, normalized measures, and measures of relative toxicity.
Washington Department of Ecology staff met with facility representatives and shared the graphs and
analyses. The facility visit provided enhanced understanding of data trends and insight on the reliability of the
numbers reported The facility visit was also an opportunity to learn more about P2 activities at the facility and
to gain industry perspectives on P2 measurement and data reporting.
A profile on each facility was compiled. Where available, the following information was included in the
profile: the driver behind implementing P2 at the facility, the techniques which have proven to be most effective
in achieving source reductions, the benefits realized from P2 activities, and the barriers encountered in pursuing
P2 initiatives.
The findings of the study conclude that absolute measures are most appropriate for measuring progress
towards state and national goals. Normalized measures may be very useful for measuring P2 progress and
identifying successful P2 techniques within an industry. The most appropriate normalization factor varied
between industries. It appears unpractical to develop an index that could be used state-wide or nationally for all
industries. If data are to be compared between facilities, or if data will be aggregated at the state or national level,
men the normalization factor must be consistent within the industry and all facilities must calculate the activity
index in the same way.
Ideally, a standardized activity index that could be applied to all facilities within an industry should be
developed coUaborativeh/ by industry and government The TRI activity index (or production index) is currently
reported in a different way for each facility, eliminating the possibility of normalizing aggregate release data The
TRI activity index would be most useful for national comparisons if a standard method for calculating the activity
index were determined for each four digit SIC code or smaller industry grouping.
Of the available data sources, the TRI and Washington state pollution prevention plans (plans) and
annual progress reports (APRs) proved to be the most useful for this project. The least useful data sources were
the Biennial Reporting System Form WM and Tier n reports.
One difficulty encountered in completing the project was the absence of available information on
chemical use. State policy has established P2 goals in terms of chemical use reduction. Current literature
suggests that chemical release cannot be considered an adequate surrogate for chemical use. Clarifying the
relationship between chemical release and use at the nine facilities went beyond the scope of the current project,
however, mis is an issue mat should be addressed further in Washington state. If the state determines that release
is indeed inadequate in describing chemical use, then the data collected should include information on chemical
use, or the state policy goal should be expressed in terms of chemical releases.
Facilities had several suggestions for improved data reporting, principally, that government make greater
attempts to simplify the process of reporting. Forms should be more user-friendly and, to the greatest extent
possible, the number of contacts at each level of government should be minimized. The burden of distributing
information within each level of government should fall on government itself. Multi-media permitting efforts,
EPA's Common Sense Initiative and integrated regulation by industry represent a more holistic approach to
environmental management mat is welcomed by industry. Industry also supports government efforts to prioritize
chemicals of greatest concern and establish state and federal goals.
D
35
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Pollution Prevention Track - Session 2 1994 TRI Data Use Conference
Ronald Robbing, Environmental Compliance Coordinator, United States Postal Service, Northeast Area
Beth Secor, Project Chemical Engineer, TURP, Rizzo Associates, Inc., Natick, MA
Using Emergency Planning and Community Right-To-Know Act Inventories as a Tool for Pollution
Prevention
Overview
In an effort to comply with the Emergency Planning and Community Right to Know Act (EPCRA) and
Executive Order 12856; Federal Compliance With Right-To-Know Laws and Pollution Prevention
Requirements, the United States Postal Service (USPS) Northeast Area Office has prepared comprehensive
inventories of the chemicals used at its major mail processing and vehicle maintenance facilities. These
inventories involve the compilation of chemical information on the products and substances stored or used at
65 major Postal Service facility sites throughout the Northeast Area. The USPS accomplished this initial
draconian task by contracting the bulk of the work to an environmental consultant. Rizzo Associates, under
contract to the USPS, performed product inventories using portable computers which support the database
program created for this project Once the product inventory was collected, the chemical composition for each
product was entered into the database. Chemical compositions were determined from the Material Safely Data
Sheets obtained for each product. A number of query options were built into the database to produce EPCRA
inventory reports for each Postal Service site.
Concurrently, the USPS Northeast Area also has an aggressive pollution prevention program underway.
For the past two years the USPS Northeast Area and the United States Environmental Protection Agency (U.S.
EPA), Region 2, have been working together to implement the findings in two pollution prevention studies
completed for vehicle maintenance and processing and distribution operations. These jointly sponsored studies
were conducted in Buffalo, New York. As stated in the federal Pollution Prevention Act of 1990, 'There are
significant opportunities to reduce or prevent pollution at the source such changes offer industry substantial
savings in reduced raw material, pollution control, and liability costs as well as help protect the environment and
reduce risks to worker health and safety."
TABLE 1
OZONE DEPLETING SUBSTANCES
Class I Substances
Chlorofluorocarbons (various types)
Halons (various types)
111-trichloroethane (Methyl Chloroform)
Carbon tetrachloride
Class II Substances
Hydrochlorofluorocarbons (various types)
As part of the USPS
Pollution Prevention Program,
primary key "chemicals"
have been targeted for
reduction and elimination,
wherever possible. The
primary chemicals include
ozone depleting substances
(refer to Table 1) and the 17
chemicals targeted for
reduction by the United States
Environmental Protection
Agency (refer to Table 2).
The basis for this decision was
taken from Tide VI of die Clean Air Act Amendments which set into motion die phase out of die production of
ozone depleting substances (ODSs). and U.S. EPA's national goals to reduce emissions of 17 targeted chemicals
in its 33/50 Program. The 33/50 Program is a voluntary initiative which takes its name from EPA's national
reduction goals of 33% by 1992 and 50% by me end of 1995. The EPA is using 1988 as die base year to record
diis reduction.
The USPS was able to use its EPCRA inventory database as a tool for pollution prevention by querying
the database to identify those products containing die targeted chemicals noted. The tool has manifested itself
in die form of a document made up of detailed lists which include diose products used by die USPS dial contain
36
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1994 TRI Data Use Conference Pollution Prevention Track - Session 2
ozone depleting substance (s) and/or one or more of the 17 U.S. EPA targeted chemicals. Products are listed by
vendor name and include a list of the targeted chemical(s) identified in the product.
TABLE
i.
1. Benzene
2. Cadmium & cadmium compounds
3. Carbon tetrachloride
4. Chloroform (trichloromethane)
5. Chromium & chromium compounds
6. Cyanide compounds & hydrogen cyanide
7. Lead & lead compounds
8. Mercury & mercury compounds
9. Methylene chloride (dichloromethane)
10. Methyl ethyl ketone
11. Methyl isobutyl ketone
12. Nickel and nickel compounds
13. Tetrachloroethylene
14. Toluene
15. 1,1,1-trichloroethane
16. Trichlorethylene
17. Xylenes (all xylenes)
Of the approximately 6,000 products identified as part of this inventory, approximately 263 were found
to contain ODSs and approximately 1,122 contained at least one of the 17 U.S. EPA targeted chemicals. By
virtue of this database the USPS is now able to target "products" for reduction and replacement to achieve its
pollution prevention goals.
D
Brian D. Towns, Facilitator, Environmental and Maintenance Services, Galileo Electro-Optics Corporation
Galileo in the last two years has transformed from a top down management format into a total quality
team management style. During this transition, the activities to comply with pollution prevention goals were
shaped by the TQM philosophy. The environmental manager was transformed into an environmental facilitator
with a goal to incorporate environmental concerns into the profit making equation. Outside agencies such as
DEP and EPA were viewed as customers with requests that could contributed to the profit making ability of the
corporation. Pollution prevention through source reduction was recognized as a way to reduce operational costs
and enhance Galileo's competitive edge.
The environmental facilitator, as all other facilitators within the corporation, is authorized to use any
resource necessary to accomplish corporate goals. A task force of upper management (facilitators) was created
to define global needs such as data collection, report formats and material tracking. The task force also defined
the top three contributors to pollution and the potential savings associated with reductions in each.
The formation of teams, comprised of employees from all areas of the corporation, is encouraged under
TQM guidelines. The teams set goals and short term objects men divide up tasks to achieve the objectives. From
the analysis of the top three contributors of pollution, sub-teams were formed to address each of the three
contributors. The sub-teams were comprised of employees whose working knowledge of specific processes or
background would significantly contribute to the success of the team. Each team was given a general goal from
the task force and a time frame to achieve the goal. Other goals and objectives were set by the teams with no
interference from the task force.
To ensure communication between the task force and sub-teams, the environmental facilitator was
responsible for compiling team progress reports and converting the information into dollars saved. The task force
37
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Pollution Prevention Track - Session 2 1994 TRI Data Use Conference
would then be up-dated cm the progress of each team and the over all cost reduction. Any resource needs or
policy changes would be brought to the task force by the environmental facilitator.
Chemical usage reports were generated by the environmental facilitator and provided to each team.
Through the reports, each team was able to target specific areas and concentrate on the most cost effective
solutions in each target area The reports also provided a running score card on the effectiveness of their
activities. Within six months, each team had identified and implemented several simple solutions to reduce
chemical usage while maintaining production levels and product quality.
The success of the team approach to accomplish environmental goals can be demonstrated by the large
improvements in chemical use efficiency within a very short time frame. Methanol usage was down 40%,
acetone use down 60%; Freon virtually eliminated from Hie production process and trichloroethylene usage was
eliminated all together. The time span from the formation of the teams to implementation of reduction ideas was
six months.
Galileo reported five chemicals on the annual TRI form R reports before pollution prevention activities
were initiated In 1994, Galileo will report on two chemicals and in 1996 will not reach any TRI reporting
thresholds. The cost of implementing changes and the labor hours at team meetings and action items was
estimated at $15,000. The task force has estimated that the changes have saved nearly $150,000 annually on
the operational cost of production.
D
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1994 TRI Data Use Conference Pollution Prevention Track - Session 3
Session 3: Using TRI to Target Pollution Prevention Technical
Assistance Opportunities
Session Leader
Dave Thomas, Director, Hazardous Waste Research and Information Center, Illinois
Department of Natural Resources
Speakers
Bob Donaghue, Assistant Director, Pollution Prevention Assistance Division, Georgia Department
of Natural Resources
Sharon Johnson, North Carolina Pollution Prevention Program
Chris Tirpak, Acting Director, The 33/50 Program, U.S. Environmental Protection Agency
In this session, panelists discussed how state and federal staff are using TRI to identify pollution
prevention opportunities, including prioritizing chemicals and industrial sectors of concern. Speakers addressed
using TRI in conjunction with other databases on industrial waste. Other issues addressed include identifying
industrial processes of concern, research priorities, and impediments to implementing pollution prevention.
Bob Donaghue, Assistant Director, Pollution Prevention Assistance Division, Georgia Department of
Natural Resources
Prioritizing Pollution Prevention Assistance Needs Using the 1992 Toxic Release Inventory
Phase 1 - Preliminary Manufacturing Sector Analysis
Core Strategies for Assistance
A core strategy of the Pollution Prevention Assistance Division (P'AD) of the Georgia Department of
Natural Resources (DNR) is to be responsive to requests for assistance by all manufacturing groups and the
public. However, this approach win not ensure that needed information and support is available to manufacturers
that may be the most significant waste generators. To reach this audience, another core strategy of P2AD is to
identify technical assistance needs of manufacturing sectors that generate chemicals posing the greatest relative
risk to the public and the environment. P2AD is seeking their voluntary involvement in its non-regulatory
pollution prevention programs.
Prioritization Approach
This effort represents the first phase of an on-going approach which evaluates waste generation
characteristics of Georgia manufacturers producing toxic and hazardous chemical wastes. A preliminary
prioritization of the manufacturing sectors (Standard Industrial Classification Codes 20 through 39) was
undertaken using a two-step process: prioritization of toxic chemicals generated and prioritization of
manufacturing sectors that generated the highest priority chemicals.
Chemical Prioritization
The primary chemicals used to prioritize assistance efforts are those included on the Toxic Release
Inventory (TRI), which is part of Section 313 of the Emergency Planning and Community Right-to-Know Act
In Georgia, mere are 321 chemicals included on the TRI Since all of the chemicals listed on the TRI do not pose
the same degree of risk, the chemicals were placed into three groups based on various toxicdogical and
regulatory factors. The highest priority chemicals were generally those exhibiting carcinogenic or ozone-
depleting characteristics, or were released to the environment in large quantities. The high priority chemicals
generated in 1992 and their environmental fate are shown in Figure 1.
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Pollution Prevention Track - Session 3
1994 TRI Data Use Conference
Figure 1
High Priority Chemicals
Distribution and Environmental Fate
Total 1992 High Priority Chemical Generation Was 99 Million Pounds
Copper
Methanol
Lead
Zinc
Ammonia
Xylene
1,1.1 Trichlorqethane
Hydrochloric Acid
Methyl Ethyl Ketone
Toluene
Styrene
Methyl Iso Ketone
Dichloromethane
Chloroform
Chromium
Nickel
Trichloroethylene
Chlorine
Formaldehyde
Tetrachloroethyfene
Freon 113
0
• Air
D Water
H Land
H Transfers
10
15
20
Million Pounds/Year
Figure 2
Georgia Manufacturers
High Priority Chemical Generation
Total 1992 High Priority Chemical Generation Was 99 Million Pounds
Primary Metals
Paper Products
Chemicals
Transportation
Electronic Equipment
Rubber & Plastics
Fabricated Metals
Miscellaneous
Wood Products
Textiles
Stone, Clay, Etc.
Food Products
Furniture
Industrial Machinery
Printing
• Air
D Water
H Land
ffl Transfers
Million Pounds/Year
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1994 TRI Data Use Conference Pollution Prevention Track - Session 3
Prioritization of Manufacturing Sectors
Following the chemical prioritization step, manufacturing sectors were identified that generated and
released the high priority chemicals. Bach sector was examined in terms of their generation characteristics, the
environmental fete of the chemicals, the number of companies reporting environmental releases, and the number
of companies within the state with similar waste-generating processes. These manufacturing sectors were then
prioritized from high to low. High priority chemical generation in 1992 by Georgia manufacturers and the
environmental fate of the chemicals are shown in Figure 2.
High Priority Manufacturing Sectors
High priority manufacturing sectors were selected primarily due to environmental releases of high
priority chemicals and include the following sectors:
Paper and Paper Products (SIC 26) - Rubber and Plastic Products (SIC 30)
Chemical and Allied Products (SIC 28) - Fabricated Metal Products (SIC 34)
Transportation Equipment (SIC 37) - Printing and Publishing (SIC 27)
The printing sector was included despite relatively low reported releases, because over 1,000 small printers fall
below TRI reporting thresholds and are not required to report releases. Cumulatively, solvent releases from small
printers are significant.
Medium Priority Manufacturing Sectors
Medium priority manufacturing sectors may generate significant levels of toxic chemicals; however, most
are not released to the environment. Other medium priority manufacturing sectors may have only a few
companies reporting TRI releases; however, many smaller companies that are below TRI reporting thresholds
conduct business in Georgia within these SIC Codes. Sectors considered medium priority include:
Primary Metals Industry (SIC 33) - Stone, Clay and Glass Products (SIC 32)
Electronic Equipment (SIC 36) - Industrial Machinery (SIC 35)
Furniture and Fixtures (SIC 25)
Low Priority Manufacturing Sectors
Finally, industries within low priority manufacturing sectors include those with either small toxic
chemical wastestreams, or whose primary wastestreams consist of non-hazardous solid waste or wastewater.
Manufacturing sectors considered low priority with respect to toxic chemical releases include:
Food and Kindred Products (SIC 20) - Petroleum Refining (SIC 29)
Textile Products (SIC 22) - Leather Products (SIC 31)
Apparel Products (SIC 23) - Measuring Equipment (SIC 38)
Tobacco Products (SIC 21)
Subsector Analysis
After prioritizing the manufacturing sectors, a more in-depth analysis of each sector was undertaken.
Each sector was examined to determine which subsectors reported high priority chemical generation and releases,
and also the quantities and environmental fate of the chemicals generated. Figure 3 provides an example of a
subsector analysis for the Transportation Equipment Sector (SIC 37). It indicates that the most significant
generators of high priority chemicals within this sector are the aircraft and aircraft parts manufacturers (SIC 372)
and the motor vehicle bodies and motor vehicle parts manufacturers (SIC 371). The sector was then assessed
to see which high priority chemicals were generated and their environmental fate. Figure 4 provides an example
of this analysis for the sector.
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Pollution Prevention Track - Session 3
1994 TRI Data Use Conference
Figure 3
Transportation Equipment
Manufacturing Sector Analysis
SIC Code 3700 High Priority Chemical Generation
(11.9 Million Pounds in 1992)
Aircraft and Parts
Motor Vehicles
Boat Building
Railroad Equipment
Miscellaneous
Guided Missiles
24 6
Million Pounds/Year
• Air
D Water
® Land
13 Transfers
Figure 4
Transportation Equipment
Distribution of High Priority Chemicals
Lead
Xylene
Methyl Ethyl Ketone
Methyl Iso Ketone
Nickel
1,1,1 Trichloroethane
Toluene
Chromium
Tetrachloroethylene
Styrene
Methanol
SIC Code 3700
1234
Million Pounds/Year
• Air
D Water
HLand
m Transfer
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1994 TRI Data Use Conference Pollution Prevention Track - Session 3
Phase 2 - In-depth Manufacturing Sector Assessments
The next phase of the needs identification program will consist of establishing manufacturing sector
focus groups to identify key pollution prevention issues of the high priority sectors. In-depth assessments of
manufacturing sectors will then be conducted to determine the processes producing the wastes, multi-media
waste problems (e.g. solid waste, wastewater, excessive energy and water consumption, etc.), current pollution
prevention activities, impediments to implementing pollution prevention measures, and opportunities for
additional pollution prevention efforts by the sectors. On-site assessments will be undertaken at selected
companies which volunteer to participate in the program. The research and assessments will be accomplished
using staff engineers as the project managers working closely with industry experts, university personnel, and
others with expertise in the manufacturing sectors.
This program is designed to better use P2ADls resources to identify and reduce the most significant toxic
waste generation in order to minimize potential public health and environmental risks while improving the
efficiency of industrial operations. Although this program element focuses on hazardous and toxic wastes
primarily from manufacturing sectors, other P2 AD programs address areas such as agriculture, service industries,
and non-toxic industrial solid waste and wastewater.
These planning efforts will establish a baseline of information on pollution prevention activities by
Georgia industries. They will be used by P2AD in developing its program, provide information needed to assess
the progress of P2AD'S programs, and monitor environmental waste trends to improve the effectiveness and
responsiveness of P2AD to changing technological and environmental conditions.
n
Sharon Johnson, North Carolina Pollution Prevention Program
Using TRI as a Pollution Prevention Tool
The SARA 313 Form R reporting requirements of the Emergency Planning and Community Right to
Know Act of 1986 have gone a long way towards increasing the awareness by industry, government, and the
general public of the releases to the environment from the facilities that are required to report. For some
facilities, this was the first time they had looked at waste generation from a multimedia perspective. As the only
source of information on multimedia releases to the environment, the North Carolina Office of Waste Reduction
(OWR) has found numerous ways to use this information to promote waste reduction efforts in our state.
In 1989, the N. C. Pollution Prevention Program (now a part of the OWR) received a grant from EPA
to develop a Multimedia Waste Reduction Management System (WRMS). The goal of this project was to
develop a multimedia waste reduction assessment database which would merge data from national and state
databases that contained waste generation and reduction information. From this information, the Pollution
Prevention Program (PPP) would be able to access multimedia releases and target waste reduction techniques
to those releases. The targeting effort would include providing information on the services of PPP to specific
faculties and developing specific materials for identified industry sectors.
Because the TRI was the only multimedia database available, it was chosen as the primary database to
be used in the WRMS system. The TRI data were supplemented with data from the North Carolina State Annual
Report on Hazardous Waste Generation, Airs Facility Subsystem Air Quality data, National Pollutant Discharge
Elimination system data, and North Carolina Pretreatment data The WRMS was developed as a relational
database using dBASE IV. The combination of this information provides a broader picture on environmental
chemical releases and waste generation than could be provided by the TRI data alone, although the TRI data
comprise by far most of the data in the WRMS system.
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Pollution Prevention Track - Session 3 1994 TRI Data Use Conference
While the WRMS system has proven to be a useful source of information, there have been several
problems in utilizing the system. First, the large database requires an extended amount of processing time and,
due to a lack of funding, the system is currently outdated. Since the data are being pulled from several different
systems, it is time consuming to keep the system updated. The OWR does have plans, however, to evaluate and
update the system soon. Other agencies within North Carolina's Department of Environment, Health, and
Natural Resources have also expressed an interest in using the WRMS system to get an overall picture of the
multimedia waste generation at a facility.
In spite of the current problems with the WRMS system, the Pollution Prevention staff has still been
able to use this information as a pollution prevention tool. This information gives staff the ability to access more
environmental parameters for a selected facility and provides a larger picture on chemical releases and waste
generation as a whole. PPP also uses the data to make comparisons of industry releases between reporting years.
This comparison includes analysis of trends at a specific facility, within an SIC code, within a geographic area,
or on a statewide basis. The data are useful for looking at potential cross-media transfers of pollutants among
reporting years at a facility. One of the most useful applications for the data is that the PPP staff can evaluate
a facility's wastestreams prior to conducting a waste reduction opportunity assessment on site. This information
can help staff be much better prepared for the visit.
In addition to its use in the WRMS system, the N. C. PPP staff also uses the TRI data in many of its
efforts to target resources and as an information tool to give others a perspective of waste generation in N. C.
An initial targeting effort involved a letter from the governor to the facilities in N. C. that reported releases on
off-site transfers of the 17 chemicals identified for EPA's 33/50 Program. This letter encouraged these facilities
to participate in the 33/50 Program and to use pollution prevention as the preferred method to reduce these
releases. Information on the services available through the PPP to assist facilities was included, and the letter
encouraged facilities to use these services. Within a few weeks, PPP was flooded with requests for on-site
assistance, and, since that time, the Program has maintained about a six month backlog. We are not sure how
much of this activity could be attributed to our targeting efforts, although they certainly were a factor. Because
of the continued backlog since that effort, PPP has not been able to pursue many of the targeting efforts that were
initially planned when the WRMS system was developed.
The TRI data have been a valuable source of information this past year as the OWR has worked with
the Pollution Prevention Advisory Council. This Council was created in 1993 by the North Carolina General
Assembly to look at the potential to promote greater waste reduction practices in the state, the regulation of
hazardous waste generation and management in North Carolina, and the hazardous waste management capacity
needs of North Carolina business and industry. In the Council's first meeting, the TRI data were used to present
to the members an overall picture of multimedia waste generation in the State. Throughout the year, TRI data
were referred to as the Council developed its recommendations on these issues.
One of the final Council recommendations is to set a state-wide goal of reducing releases and off-site
transfers of TRI chemicals by 50 percent by the year 2005. The goal includes a challenge to reduce TRI
chemicals requiring waste management by 25 percent by the year 2005 through source reduction and
environmentally sound recycling. To determine this goal, TRI data were used to track reductions since 1988 and
to make predictions on reductions for total releases as well as reductions through source reduction and
environmentally sound recycling. If this recommendation is accepted by the General Assembly, statewide
progress towards the goal would be tracked by the TRI data submitted by companies hi SIC codes 20-39 for the
1992 list of reportable TRI chemicals. Achievement would be measured as percent reductions from a 1992 base
year. The Council also recommended that OWR publish a biennial report that provides statistics on progress
toward the goals and recognizes facilities with the highest reductions in waste generation.
TRI data have also been used in PPP's efforts to become more efficient in material and information
development and dissemination. PPP has used the data to determine the SIC codes that have the greatest waste
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1994 TRI Data Use Conference Pollution Prevention Track - Session 3
generation and the chemicals they are generating. This information has resulted in the development of fact sheets
for processes such as painting and coating operations. The data have also been used to identify potential sources
of pollution problems in a geographical area.
OWR plans for using TRI data in the future include targeting a geographical area (probably a county)
as a pilot project for providing intensive waste reduction information on reducing air emissions, wastewater
pollutants, solid and hazardous waste. This project would involve coordination with the local POTW and solid
waste managers as well as other local government authorities. The TRI data, along with solid waste annual
report data would be the primary data analyzed to determine the targeted area. As the TRI data are expanded,
there will be more opportunities to use them to promote waste reduction in North Carolina
D
Chris Tiryak, Acting Director, The 33/50 Program, U.S. Environmental Protection Agency
Using TRTs 33/50 Program to Target Industry P2 Technical Assistance Opportunities
Whflt is the 33/50 Program?
A 5-year experiment in voluntary pollution reduction, the 33/50 program aims to cut 1.5 billion pounds
of toxic waste across the nation by 33% in 1992 and 50% in 1995.
More than 1,300 companies currently participate in the 33/50 Program. Unlike most Federal
Government programs, participation in 33/50 is simple and flexible. The only requirement is a letter to EPA.
The 33/50 Commitment Tracking System (CTS) summarizes these letters in a repository of valuable information
on pollution prevention and reduction — available upon request.
The 33/SJ) Approach To TRI
The 33/50 Program sets national pollution priorities by targeting 17 chemicals (and categories) for
reduction. The Toxics Release Inventory (TRI) is a chemical reporting — not reduction — requirement. The 17
priority pollutants were selected by the 33/50 Program on the basis of three criteria.
1. known environmental and health risks
2. high volume industrial use
3. potential for reduction through pollution prevention
The 33/50 Program measures progress against the 1988 TRI reports filed annually by American companies under
the Emergency Planning and Community Right to Know Act (EPCRA) section 313.
TRI and 33/50 Timelines
As 1995 draws near, the 33/50 Program is entering its last TRI reporting year, just after the 1994 data
have been received by EPA, but well before the 1993 TRI data are made available for public release in the Spring
of 1995. Meanwhile, the 1995 TRI reports will come to EPA in the summer of 1996, for public release in the
Spring of 1997.
There is a two year time-lag between TRI reporting and public disclosure of TRI data. When coupled
with the use of the 1988 TRI reports as a baseline for calculating 33/50 chemical emission reductions, this time
lag affects both ends of the 33/50 experiment Thus the five year (1991-1995) 33/50 Program stretches to cover
a 10-year (1988-1997) span in the public eye.
Preliminary 33/50 Results
The 1992 TRI reports already reveal a 600 million pound (40%) decline in toxic emissions from the
levels reported in 1988. These results suggest that voluntary pollution reduction is, indeed, working - faster
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Pollution Prevention Track - Session 3 _ 1994 TRI Data Use Conference
and cheaper than the standard legislation-regulation-litigation framework. The 50% goal appears to be well
within reach of the 33/50 Program in 1995.
Technical Assistance - 3?/50 Company Profiles
The 33/50 Program sets the stage for technical assistance upon request. Most recent among a series of
reports available from 33/50 are Company Profiles. Fourteen 33/50 Company Profiles describe pollution
prevention and reduction activities to date: Acme Metals, Aladin Industries, Aldan Rubber, Anchor Fence,
Carpenter Technology, Dexter Shoe, Douglas & Lomason, Hadco Electronics, Johnson & Johnson, Olin, Parker
Hannifin, Printed Circuit, Raytheon, and U.S. Steel. The profiles are drawn primarily from each company's
communications with the 33/50 Program and the annual TRI reports submitted by their facilities.
A summary, as well as copies of the complete company profiles, can be obtained by contacting either
EPA's Hotline at (202) 554-1404 or the 33/50 Program Staff at (202) 260-6907.
Technical Assistance in the 33/50 "Home Stretch"
The 33/50 Program actively challenges companies to think about technical assistance in new ways by
focussing on goals. Building on the momentum established with the early achievement of the interim national
33% pollution reduction goal — a year ahead of schedule - nearly 1 ,300 companies are now being asked to boost
their commitment to a cleaner environment in a healthy economy in a number of ways:
pushing beyond the limits of initial goals for reducing toxic releases and off-site transfers;
bringing more of their facilities into the 33/50 Program;
expanding pollution reduction commitments to include chemicals other than 33/50's 1 7 target pollutants;
reducing chemical emissions in international operations; and
reducing toxic wastes at the source.
The 33/50 Program approach shifts from adversarial court-orders towards voluntary collaboration and
partnerships — stronger than either post-regulatory volunteerism or regulations alone.
33/50 Public Recognition
The 33/50 Program engages the power of public awareness and peer pressure to draw corporate America
inexorably towards environmental stewardship. As a first step, company participation in the 33/50 Program is
recognized officially in 33/50 Certificates of Appreciation. Then, as companies reach their pollution reduction
goals, they receive 33/50 Certificates of Achievement. This creates a common ground for government-industry
partnerships from which to develop a new way of doing business.
Right now, the 33/50 Program is working with EPA Regional Offices and other outside groups to
identify specific categories and criteria for the final 33/50 Awards in the summer of 1996. US-EPA's 33/50
Certificates and Awards serve as powerful public symbols of doing more than just meeting the requirements of
environmental regulations. Like good housekeeping seals of approval, 33/50 certificates are held by "cleaner
companies."
33/50 Proram
Is the 33/50 Program working?
Evaluations are emerging from the US General Accounting Office (GAO), INFORM, the Manufacturer's
Alliance, Citizen's Action and other organizations. Although these may be somewhat premature, they hold great
potential for reshaping improved variations on the 33/50 program after 1995. Voluntary pollution reduction
partnerships between government and industry, such as the 33/50 Program, hold real potential for faster and less
expensive pollution reduction than the current conventional legislation-regulation-litigation cycles.
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1994 TRI Data Use Conference _ Pollution Prevention Track - Session 3
- The Next Generation
As general consensus on a clean environment in a sound economy emerges between government and
industry, voluntary partnerships are cropping up throughout the country. The momentum for working
collaboratively — two way technical assistance - is happening on a national scale.
EPA is asking environmental stakeholders from industry, trade associations, environmental groups,
States — critics and supporters alike — to come together to frame die debate on the next generation of 33/50 by
mid-1995. With minimal taxpayer investment, the 33/50 Program is working to reverse a growing trend toward
spending more money on environmental lawsuits than cleanups. Court agendas are overcrowded. Clearly, the
time has come to streamline expensive and time-consuming regulatory programs with more economic voluntary
initiatives like 33/50.
D
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
Session 4: Measuring Pollution Prevention Progress: Building
a Better Yardstick
Session Leader
Kathiyn Barwick, Source Reduction Unit Chief, California Department of Toxic Substances Control
Speakers
Craig Butler, Environmental Specialist, Office of Pollution Prevention, Ohio EPA
Elizabeth Harriman, Research Associate, Massachusetts Toxics Use Reduction Institute, University of
Massachusetts Lowell
Robert T. (Tim) Hawes, Corporate Environmental Manager, Polaroid Corporation
Ed Hopkins, Environmental Director, Citizen Action
Kathryn Barwick, Source Reduction Unit Chief, California Department of Toxic Substances Control
This session focused on how to measure pollution prevention. The principal challenges of measuring
pollution prevention include problems with data quality, establishing baselines, and normalization. The
presentations and discussion led to the following observations:
individual facilities can quantitatively measure the effects of the implementation of source reduction on
the amounts/concentrations of hazardous pollutants produced (this is most effectively accomplished at
the process level);
data from individual facilities cannot be aggregated to give an overall indication (within a geographical
area or political entity) of how industry as a whole is progressing toward pollution prevention; and
existing data sets are inadequate for the purpose of measuring industry's progress toward pollution
prevention (TRI data being the best and Biennial Generator Report the worst). Such data can be and
are used at the facility level to assess progress, but normalization is still a problem.
D
Craig Butter. Environmental Specialist, Office of Pollution Prevention, Ohio EPA
Ohio's Waste Minimization Measurement Pilot Project
As public and private organizations focus their attention and resources on pollution prevention,
understanding the effectiveness of these efforts has become increasingly important. Indeed, it is generally
accepted that pollution prevention is making a positive environmental impact. However, if environmental
management strategies are to continue to shift toward pollution prevention, a reliable system of measurement
is critical.
From a government perspective, measuring pollution prevention helps evaluate the success and impact
of current policies, as well as direct new policy and allocate scarce public resources. Likewise, many businesses
work to measure pollution prevention to document program success to internal and external customers and
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1994 TRI Data Use Conference _ Pollution Prevention Track - Session 4
document regulatory compliance. Others work to measure pollution prevention to increase public awareness and
foster environmental accountability.
U.S. EPA has actively supported research in pollution prevention measurement and is currently
sponsoring measurement projects by the states of Ohio, Washington, Oregon, and Alaska Each state is
completing pollution prevention measurement pilot projects based on a series of workshops and roundtable
meetings which identified the measurement needs of various stakeholders (i.e., federal and state government,
business, and public and research organizations). Each pilot project incorporated state-specific measurement
research goals.
In 1991 U.S. EPA Region 10 and Region 5 formed a workgroup on measurement to assist in the
development of practical ways to measure progress in pollution prevention. Of specific interest to the workgroup
was the utility of currently collected data in measuring pollution prevention. Based on the needs identified by
die workgroup, U.S. EPA sponsored a roundtable tided "Measuring Progress in Source Reduction, Recycling,
and Waste Minimization" in 1992. Roundtable discussions centered on the goals identified by the workgroup
(U.S. EPA, 1992). Following die roundtable, state workgroup participants developed pollution prevention pilot
project proposals which incorporated workgroup needs, roundtable findings and state measurement goals.
Goals and Objectives
The three specific objectives of the Ohio Waste Minimization Measurement Pilot Project (OWMMPP)
are: 1) to assess the suitability of currently collected non-confidential data in measuring pollution prevention;
2) to assess the impact of complementing currently collected non-confidential data with additional facility data
(i.e., construction of a facility profile); and 3) to compare and assess the suitability of currently collected non-
confidential data with the data needs of materials accounting or throughput measures.
To complete the first objective, Ohio EPA selected seven facilities from the top toxic waste releasing and
hazardous waste generating Standard Industrial Classifications (SIC) as hosts for data collection. Ohio EPA
identified and collected the following from 1988 through 1992 for each facility: RCRA Generator Annual
Hazardous Waste Report data, RCRA Facility Annual Hazardous Waste Report data, RCRA Hazardous Waste
Minimization data, EPCRA Toxic Release Inventory data, EPCRA Emergency Hazardous and Chemical
Inventory data, Clean Air Act Emission Inventory Statement data, and Clean Water Act data, National Pollutant
Discharge Elimination System (NPDES) Discharge Monitoring Report data
Ohio EPA also completed a review of measurement methods from current pollution prevention literature.
Several different measurements were evaluated, however, only those measures that could be completed using the
data selected for this study were used in the OWMMPP. Ohio EPA selected, and applied where applicable,
actual and adjusted quantity measures in an attempt to measure pollution prevention.
To complete the second study objective, Ohio EPA worked closely with each of the seven facilities to
collect additional information regarding facility pollution prevention efforts. Facility profiles were completed to
1) develop an overview of facility pollution prevention activity, and 2) see if additional facility data provided
additional insight on pollution prevention efforts, or clarified results compiled from only evaluating currently
collected non-confidential data
To satisfy the final objective, Ohio EPA compared me data needs of a materials accounting methodology
with Ohio's currently collected non-confidential data This was done to evaluate the feasibility of applying
currently collected non-confidential data to a materials account to measure pollution prevention.
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
Measurement Results
Actual Quantity Changes
Although the usefulness of actual quantity changes is limited, oftentimes it can provide quick results or
spur additional measurement questions. The actual quantity change measure is the only measure available for
data which do not include a method to normalize or adjust yearly data.
This measure was applied to RCRA Annual Generator and Facility Hazardous Waste reports, TRI
releases to air, water, land, POTW, and deepwell injection, as well as off-site transfers for recycling, energy
recovery, treatment and disposal. Off-site transfers for recycling and energy recovery were also measured for
actual quantity changes, but are displayed separate^ to avoid skewing data analysis. Other data sources selected
for this study were not subject to actual or adjusted quantity measures because of data incompatibility or other
conditions related to data collection. However, this data was evaluated separately where appropriate.
Measuring actual quantity changes proved to be effective in identifying the types of wastes which are
predominantly generated at each facility, as well as the amounts of those wastes and whether or not reductions
have been achieved during the period of evaluation. However, since the data is not normalized for production
or other activity, actual quantity changes do not provide information as to why reductions have occurred or
whether waste generation or release decreases can be attributed to prevention.
One benefit of using the actual quantity change measure in this study was that it prompted the
development of questions to be asked during facility profile interviews. Additional information from facility
representatives often proved useful in linking yearly waste generation or release figures with pollution prevention
activity. However, it is important to note that many changes were also attributed to other non-prevention
activities.
Normalized and Adjusted Changes
Adjusted measures were reserved for Toxic Release Inventory (TRI) release and source reduction data
because the TRI included an activity index after 1990. This index was important because it allowed for yearly
adjustment of release figures. A drawback of the TRI index is that the method or process used by each facility
to develop the index is not provided Although the index is supposed to be calculated by using the activity which
is most directly linked to each chemical release, there is no way for researchers to identify if activity calculations
vary yearly.
Ohio EPA developed normalized and adjusted release information for each facility. Results provided
yearly adjusted release totals. This enabled Ohio EPA to examine if releases were proportionately higher or lower
than the 1990 base year. Some facilities experienced wide fluctuations, whereas others showed decreasing trends
in adjusted releases. These results were more comprehensive than actual quantity measure results, but still did
not provide sufficient information for Ohio EPA to measure pollution prevention.
Materials Accounting Research
Materials accounting is regarded as an effective tool to measure pollution prevention because it uses
front-end data and quantitatively tracks materials as they flow through a facility. The State of New Jersey,
through the Community and Worker Right to Know Act of 1983, has the authority to collect"... complete
inventories of hazardous substances at the facility... [and] establish an annual environmental survey concerning
the use and presence of hazardous substances throughout the state."
In 1987, and annually thereafter, specified manufacturing facilities and chemicals manufacturers were
required to report the following: Starting Inventory; Quantity Produced On-site; Quantity Brought On-site;
Quantity Consumed On-site; Quantity Shipped Off-site (as a substance or as a product); and Ending Inventory.
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1994 TRI Data Use Conference Pollution Prevention Track - Session 4
New Jersey uses this front-end information in conjunction with information collected under the federal TRI to
establish a materials accounting measurement system. Analysis of the utility of this information in measuring
pollution prevention activity was completed in 1993 (New Jersey Department of Environmental Protection and
Energy, 1993).
Ohio EPA was interested in comparing currently collected non-confidential data with a materials
accounting method of measurement. Ohio EPA examined two options. The first compared all study data with
a facility-wide materials accounting model (i.e., material flow across facility boundaries) to identify if this data
could be used to measure pollution prevention. The second option examined the feasibility of substituting
EPCRA Emergency Hazardous and Chemical Inventory data for the additional data collected by New Jersey to
complete a materials account.
In examining the first option, Ohio EPA compared the data sources used in this study with the data
needs of a facility-wide materials account. Results of this comparison showed that Ohio EPA data sources are
incomplete and could not be used to develop a facility-wide materials account. Data incompatibility also played
a major role in this determination. Finally, since both the Office of Technology Assessment and the National
Academy of Sciences concluded in separate studies that facility-wide materials accounts are not sufficient to
measure pollution prevention, Ohio EPA did not continue to pursue this option.
In option two, Ohio EPA examined the possibility of supplanting facility input data collected by New
Jersey with the data collected under the EPCRA Emergency Hazardous and Chemical Inventory Report to
complete a materials account Based on previous investigations, Ohio EPA determined that EPCRA Emergency
Hazardous and Chemical Inventory data only provide maximum and average quantities of chemicals stored on-
site throughout the year. When compared with the New Jersey data, it was determined that these data sources
are not comparable. Therefore, Ohio EPA determined that this data cannot be used as a surrogate for data
collected on facility inputs by New Jersey.
Facility Profiles
Facility profiles were derived from facility promotional materials, site visit information and
correspondence. Facilities were asked to provide information regarding pollution prevention activities, including,
but not limited to facility goal statements, descriptions of past and future pollution prevention projects, and other
facility activities that had led to a greater concentration on pollution prevention.
The facility profile proved to be an invaluable resource. It was the critical link in explaining many of
the trends identified in the data. Facility profiles provided expanded information in the form of narrative
explanations of pollution prevention activities, waste generation trends, and other related pollution prevention
activities. Without this data, Ohio EPA could only speculate on the origin of such data trends. Although the
facility profile information cannot provide absolute conclusions on all data trends, it proved to be extremely
beneficial in many cases. Ohio EPA believes that finding a way to collect this type of information from all
facilities will be critical in accurately measuring pollution prevention. The challenge will be to do this without
causing "data overload."
Conclusions
Overall, this study provided Ohio EPA with significant results on the utility of currently collected non-
confidential data in measuring pollution prevention activity. Ohio EPA believes that the results will prove useful
in guiding how data and information is collected to measure pollution prevention. In addition, it is hoped that
this study will be of use to states that have a similar regulatory structure to Ohio.
D
51
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
Elizabeth Harrunan, Research Associate, Massachusetts Toxics Use Reduction Institute, University of
Massachusetts Lowell
Measuring Progress in Massachusetts
Introduction
In 1989, Massachusetts passed the Toxics Use Reduction Act (TURA), which is a toxics use reduction
(TUR) planning and reporting law. The toxic chemical use and byproduct generation data collected under TURA
supplements waste and release information submitted under the federal Toxics Release Inventory (TRI) program.
Massachusetts has been collecting data under TURA since 1990. TURA has multiple goals, one of which is:
"...to achieve by 1997, through toxics use reduction, a fifty percent (50%) reduction from 1987
quantities of toxic or hazardous byproducts generated by industry in the Commonwealth of
Massachusetts." (MGL Ch.211 §13(A))
The Massachusetts TURA program, consisting of the Toxics Use Reduction Institute (TURI), the Office
of Technical Assistance (OTA) and the Bureau of Waste Prevention at the Department of Environmental
Protection (DEP), have embarked on a cooperative project to measure progress toward that goal. This project
will be supported in part by a PPIS grant from EPA. In addition, TURI has recently performed some analysis
of industry's experience with TURA as part of a chemical restrictions policy report to TURA's Administrative
Council.
Challenges
There are four principal challenges to measuring progress in Massachusetts. The first hurdle to
overcome is data quality. We have, at this point, only examined five Standard Industrial Classification (SIC)
codes in detail. During that examination, many obvious data errors were discovered. They included errors made
by facilities in reporting, errors made during input of the data into DEPs Facility Master File (FMF) database,
and errors introduced during the extraction of the data from FMF to our PC-based system. In one instance, it
was a combination of all three. A large quantity user had entered an outdated SIC code in their report. While
DEP has done an admirable job of converting the old SIC's during data entry, this one was not corrected and,
therefore, FMF left the field blank. During the downloading of the data (creating "extract files"), because this
field was blank, the entire production unit was lost. As a result, reports run for that particular SIC code showed
a total byproduct of approximately 4.3 million Ibs, when the actual byproduct was approximately 22 million Ibs!
The second challenge is to establish a 1987 baseline for measuring the state-wide goal. This will be a
creative exercise at best. DEP will use TURA, TRI and other media-specific data in order to make an estimate
of reductions from 1987 to 1990.
Normalization is always a challenge. However, because the goal is to reduce "through toxics use
reduction" we must factor out use and byproduct quantity changes which resulted from changes in level of
production. TURA requires facilities to report a byproduct reduction index (BRI) for each chemical at the
production unit level. This is the percent change in byproduct generation per unit of product and so is already
normalized for production. However, there is no way to aggregate the BRTs, because quantity information is
given at the facility level, not at the production unit level.
The last challenge is to determine if the reported data actually reflects what is really happening at
facilities. The best data analysis in the world means nothing if the data does not accurately characterize what
is happening in the real world. We need to get an idea about whether reductions that appear to be due to TUR
or pollution prevention (P2), are actually due to those kinds of activities.
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1994 TRI Data Use Conference Pollution Prevention Track - Session 4
Project Status
We have now performed some preliminary analysis in an effort to describe the Massachusetts experience
with toxics use reduction for the upcoming Chemical Restrictions report.(Shapiro, et al, 1994) Several possible
metrics for measuring progress have been laid out, and have been tested on five SIC codes (2672,2821,3089,
3471,3679) for 1990-1992. Absolute quantitative measures included quantity of chemical use and byproduct
Normalized measures were calculated using employment data as a proxy for level of production. In addition,
qualitative analyses were performed using the BRTs, TUR technique codes, and other supplemental information
which provides an indication of P2/TUR activity.
What We Have Learned
The preliminary analysis showed no clear trends in P2/TUR progress within or across the five SIC codes.
Use and byproduct generation decreased in most cases over the 1990-1992 period, but not in a uniform manner.
The 1991 quantities went against the overall trend in many cases. Qualitative measures (BRTs, TUR technique
codes) many times supported the overall quantitative trends, but not the year to year trends. Normalization using
employment rarely affected the trends in absolute quantities. One SIC (3089) showed dramatic increases in use
and byproduct quantities, however, this trend is believed to be due to data errors.
We hypothesize that this "muddy" picture is due to three primary causes. The first of those is data
quality. Numerous examples of errors in facility reporting, data input errors, and errors introduced during the
downloading and transfer to PC-based systems, were discovered. In many cases, these errors were large enough
to completely mask any TUR/P2 progress.
Secondly, mere exist seemingly endless "anomalies" in the data Some, such as the changing universe
of reportable chemicals and SIC codes, can be corrected for by holding a constant list of chemicals and SIC codes
for all years. But there are many others which cannot be accounted for; they are introduced by activities such
as recycling, product changes, metals exemptions, varying product mix, changes in measurement or reporting
methods, etc.
The third cause lies in the attempt to normalize quantities to account for level of production. I believe
that mis study showed the weakness of employment as a proxy for production. Its strength is in its availability.
It is available frequently, in a timely manner, statewide and on a 4-digit SIC code basis. However, the many
confounding factors, including lag time in hiring and firing, prior hiring of R&D, marketing and other personnel
when there is a positive business forecast (without a simultaneous increase in production), and changes in the
productivity of employees, all combine to make employment a poor indicator of year to year changes in level of
production. In examining the complexity of the data, and the impact that large changes at just one facility can
have on overall trends, it would seem that the best metric for level of production will be least facility specific, and
preferably, process specific.
As a result of this, we have begun a normalization analysis using the TRI production ratio/activity index.
A comparison for each of the five SIC's has been made between the percent change in total employment and the
percent change in reported production ratio from 1990-1992. There was poor correlation between the two
metrics. Only SIC 3089 showed a strong correlation (1% difference). Differences for other SIC's varied between
7% and 36%. While it would seem logical that a facility/chemical-level measure would be more accurate, there
are many inconsistencies in reported production ratios. For example, zeros and N/A's are all listed as zeros, and
companies are allowed wide latitude on the choice of production level indicator. One would assume, and some
in industry have confirmed, that Massachusetts companies use their unit of product measurements to compute
the production ratio. For smaller facilities with only one production unit per chemical reported, this value is,
therefore, potentially very good. For large facilities, however, this is a very approximate number, based on a
combination of operations in several different production units.
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
Where Do We Go From Here?
Hie year-long project for measuring progress in Massachusetts will focus initially on the following areas:
data quality, normalization using TRI activity index, incorporating 1993 data, estimating a 1987 baseline, and
the evaluation of the reality of what the data is showing. In addition to the above normalization effort, the
possibility of collecting an additional TURA Form S data element will be investigated. This would essentially
be a facility-wide BRI. This reporting of a facility "weighted average BRI" would allow the Commonwealth to
aggregate all BRTs by performing a similar weighted average. While the limitations of the BRI are recognized,
this would still be the most accurate way of obtaining a state-wide normalized measure of progress.
This paper is based on work done by the author and other project participants, including TUR1 members
Maureen Hart, Mark Rossi and Tettus Institute (under contract to TURI), and DEP members Suzie Peck and
Walter Hope. The opinions and observations given are the author's, and do not necessarily represent those
of other project members.
References
Harriman, E, J. Markarian, J. Naparstek, and J. Stolecki, 1991. Measuring Progress in Toxics Use Reduction,
Tufts University Capstone Report prepared for Commonwealth of Massachusetts Department of Environmental
Protection, Tufts University Department of Civil and Environmental Engineering, Medford, MA.
Shapiro, K., A. Dierks, and A. White, 1994. Taking Stock: Measuring Toxics Use Reduction Progress in
Massachusetts, prepared for the Massachusetts Toxics Use Reduction Institute by Tellus Institute, Boston, MA.
Robert T. (Tim) Hawes, Corporate Environmental Manager, Polaroid Corporation
Polaroid's Toxic Use and Waste Reduction Program and its Applicability to Toxics Release Initiatives
Pollution Prevention is certainly not a new concept. I can recall some of Polaroid's early Toxic Use and
Waste Reduction (TUWR) efforts as far back as the mid-70's. My old division, the Chemical Operations group,
began working with people in the process development laboratories to prioritize and work on key candidate
waste streams for recycling and waste reduction efforts. The problem was that this was an adjunct to the primary
job of developing chemical synthesis processes which made better and cheaper film products rather than better
waste streams.
Waste minimization didnt become an important concept until the mid' 80's nationally with efforts such
as a study by the Office of Technology Assessment in Washington, a project Polaroid participated in. Using the
OTA. work as a model, we began coalescing our program in early 1987. I was fortunate to participate as a
member of the team which developed the framework for the TUWR Program, working with our CEO Mac Booth
towards the planned announcement of the program at the 1987 Annual Meeting.
We developed an early version of the reporting format based upon the following concepts:
1. The reporting system should serve as an overall chemical material balance around the reporting unit
2. It should include all chemicals, regardless of toxicity or their inclusion on any Federal or State lists
(remember this predated SARA Title m).
3. It should track all waste streams in extreme detail (drum versus bulk, physical state, TSDF destination
and ultimate treatment technique).
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1994 TRI Data Use Conference Pollution Prevention Track - Session 4
The team then began the task of setting appropriate goals and began addressing such questions as:
1. Should we aim for reductions of 10% per year or 50% over 5 years? More? Less?
2. Do we reduce usage or wastes?
These and other questions resulted in compromise whereby chemicals would be slotted into four
categories by a team of experts and recycle/reuse counted as waste reduction depending upon category. It was
easy to agree that the reduction index be calculated on a per unit basis to account for changes in production
schedule.
Finally, it was decided that the reduction goal would be corporate-wide and the accounting system
developed to afford tracking of progress at all levels of the corporation.
The accounting system dubbed EARS (Environmental Accounting and Reporting System), was
developed for reporting quarterly via the corporate-wide VAX system already in place to allow data entry at the
divisions and data base administration at the corporate level.
Chemical categories were assigned initially to -1300 chemicals and a few hundred more have been
assigned since. Those chemicals having the highest environmental risk were placed into Category 1 and include
substances such as acrylonitrile and Freon 11. Category 2 contains dichloromethane, ammonia and silver nitrate
among others while Category 3 contains such materials as toluene, ethylene glycd and hydrochloric acid.
Category 4 includes most alcohols, ketones and zinc dust and is the largest chemical category. A Category 5 was
later added to track solid, non-chemical wastes such as paper, plastics and molded metal products.
The final product, announced in 1987, set a 5 year goal of 10% reduction per year in usage of Category
1 and 2 Chemicals and 10% per year reduction of waste by-products of Category 3,4 and 5 materials. The
Category 3 reduction allows credit for on-site recycle (off-site for Categories 4 and 5) providing the generating
division actually reuses the recycled materials. The program also established a waste management hierarchy with
preference shown to recycle over disposal and internal disposition over external handling. At the bottom of the
hierarchy are emissions and land disposal.
The final goal established was a "virtual" elimination of emissions of Category 1 chemicals at the end
of 5 years.
The program was initiated with 1988 as the baseline year and was to be voluntary in nature with
corporate-wide (international) scope and local autonomy over accountability. I was among the early skeptics
and there did not seem to be much going on well into 1989 in many areas until a Polaroid "Earth Day" was
established in the Fall of 1989. It was hosted by Polaroid's Vice President of Worldwide Manufacturing and
attended by the CEO and -200 officers and other operations, research, engineering and environmental types.
Plant Managers had to present their TUWR progress reports to this corporate-wide forum. In my opinion, this
was the first time many of them thought much about their waste minimi ration efforts. I think we turned the
corner that day.
Polaroid has made an annual event of this "Earth Day" process and has instituted several other waste
reduction forums such as "Waste Reduction University" (an all day exchange of ideas held at Bentley College),
a waste reduction newsletter issued periodically to all employees, a grassroots "Waste Reduction Now" program
and an annual awards program where ~20 employees are awarded plaques by a senior Officer at a luncheon he
or she hosts.
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
In order to achieve successful waste reduction, a cooperative effort was needed involving operations,
R&D and engineering representatives. The company is now committing significant capital spending to the
program, encouraging toxic use reduction via process changes and funding installation of solvent recovery
systems. It has been recognized that different TUR techniques are required in the varied divisions with such
diverse products as chemicals (dyes and polymers), photographic negative, cameras, film (assembly), coated sheet
and the film pack battery. Thus, each division is encouraged to manage its own program while drawing on the
resources of the corporation as needed.
Polaroid is prioritizing SARA TRI reductions via our EARS reports and has modified the data base to
allow us to cull the SARA Form R reports directly out of EARS. In addition, we "signed up" for EPA's
voluntary Industrial Toxics Program (33/50), recommending to the EPA that we use our existing program to
generate the data Of course, the EPA's program is emissions reduction oriented while ours measures reductions
in total "toxics" used or generated as wastes, depending upon the category.
When the 5 year program ended 12/31/93, a cross-sectional group had Redesigned TUWR for the next
several years. We have broadened the program to include such areas as energy usage and have decided to give
selected additional "credits" for recycling Category 5 solid wastes. The concept of "one set of books" was
incorporated into the TUWR Redesign so as to assure all reported data (TUWR, SARA TRI, MA TURA, 33/50
etc.) are consistent and drawn from the same data base.
We have achieved approximately 6% reduction per year per unit of product corporate-wide during the
original TUWR Program and have set an annual goal of 7% for the next phase. This puts the company in a
position to deliver performance comparable with the statewide MA TURA goals and, in turn, is used as the driver
to continued reducing SARA TRI releases.
D
Ed Hopkins, Environmental Director, Citizen Action
Using the Toxics Release Inventory (TRI) to measure pollution prevention is a little like trying to analyze
the efficiency of your car's engine without knowing how much gas is in the tank. In both cases, critical pieces
of information are missing. I hope to suggest why the TRI is deficient for tracking pollution prevention and
recommend what additional information would be needed to enable the public to know when facilities are
preventing their pollution.
We know that, according to the TRI, many facilities have made significant reductions in their reported
releases and transfers. While the TRI is the best available mechanism for tracking manufacturing facilities' toxic
waste, it is incapable of answering the most important question: how are facilities reducing their releases and
waste?
A few examples from previous studies Citizen Action has done illustrate how little TRI can inform us
about pollution prevention. All of these examples, which are quite typical of year-to-year changes facilities report
to the TRI, come from the 1992 TRI reports.
• Magnesium Corp, Rowley UT - Cut chlorine air emissions by 27 million pounds.
• Inland Steel, East Chicago, IN - Cut its magnesium transfers by 11 million pounds.
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1994 TRI Data Use Conference Pollution Prevention Track - Session 4
• American Cyanamid, Westwego, LA - Cut its underground injection of sulfuric acid by 10
million pounds.
These examples suggest that these three facilities are doing a great job preventing their pollution. But we talked
to representatives of these facilities and learned that the numbers don't tell the entire story.
• The Magnesium Corporation facility did not prevent pollution; it installed a chlorine burner.
While an improvement over releasing chlorine to the environment, this is pollution control, not
prevention.
• Inland Steel didn't prevent pollution, it sold the waste as structural fill material rather than
landfilling it
• American Cyanamid didn't cut pollution, it changed the way the it calculated the sulfuric acid
in its wastestream.
None of this information is available from the TRI alone. Citizen Action discovered the causes of the changes
reported to the TRI only by contacting the facility representatives.
In theory, a reduction in reported production-related waste may suggest source reduction when the level
of production stayed the same, but one cannot make that assumption from the TRI data alone.
For a variety of reasons, the TRI is inadequate to measure pollution prevention:
• Just as knowing how much gasoline is in your car's tank is critical to computing your car's
efficiency, tracking the amount of chemicals used in a production process is key to determining
progress toward preventing pollution. Information the TRI provides on chemical storage at a
facility is expressed in such broad ranges that it is of no value for tracking pollution prevention.
Knowing mat a facility had on-site somewhere between 50,000 pounds and 99,000 pounds of
a chemical does not provide useful information.
• It's impossible to determine by examining its TRI forms if a faculty changed its method of
calculating its waste and to what extent the changes in the amount of the facility's production-
related waste were due to different estimation methods. Some of the facilities reporting the
largest amounts of waste entering on-site recycling processes in 1991 subsequently revised their
estimating technique. Instead of reporting billions of pounds of chemicals being recycled on
site, the facilities now consider the chemical to be entering a process which is integral to the
manufacturing system. They are no longer reporting any chemical as being recycled on-site,
thereby appearing to achieve a reduction in waste of billions of pounds when, in reality, nothing
has changed.
• Thanks to the Pollution Prevention Act, facilities now report whether they have taken any new
steps to reduce a chemical at the source. But one cannot determine how many pounds of waste
have been reduced by the source reduction activity a facility undertook. There is no opportunity
for facilities to report the results of their pollution prevention efforts. That information would
enable one to understand how much of the change for the chemical could be accounted for by
an active prevention measure.
• While useful at the aggregate level, the TRI production index is inadequate to normalize
production levels because individual facilities may have many production processes and
products and the production index covers the entire facility. Large chemical manufacturing
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Pollution Prevention Track - Session 4 1994 TRI Data Use Conference
plants may use common chemicals such as chlorine or toluene in a dozen different production
processes.
• The measure of pollution prevention is not limited to what takes place at the production facility
itself; it also includes, or should include, the products the company makes. Products containing
volatile organic compounds, for example, contribute to pollution when consumers use them and
dispose of them. Companies have prevented pollution by removing toxic chemicals from their
products, as Gillette did when it reformulated its White Out correction fluid to eliminate
trichloroethylene. The TRI collects no information about toxic chemicals in products, so one
cannot determine if a facility is making progress toward pollution prevention.
• Facilities which eliminate the use of a listed toxic chemical are not required to report
information on a substitute chemical which is not on the TRI list. With the recent addition of
almost 300 chemicals, the TRI list will be a lot larger in the future, but thousands of chemicals
which are in use do not have to be reported. One cannot assume that these unlisted substitutes
are benign.
If preventing pollution at the source is the nation's top environmental policy priority, as it should be, we
must have a mechanism to track pollution prevention. We agree with the CMA slogan:' don't trust us, track us.'
EPA should collect the following information to enable the public, regulators and companies themselves to track
pollution prevention:
• any change in methods for calculating waste;
• how many pounds of waste were prevented by a source reduction activity, and;
• process-specific materials accounting data ~ chemical use, chemicals consumed in the
manufacturing process, and chemicals in products — in addition to TRI data;
EPA should also provide better guidance on estimating methodologies, particularly regarding the calculation of
on-site recycling waste.
Until we develop methods of tracking pollution, it will be impossible to give public recognition to those
facilities which are making progress in preventing their use of toxic materials and generation of waste. By adding
the data requirements Fve suggested, everyone will be better able to determine whether we're making progress
toward national pollution prevention goals, and at the local level, the public will be able to know which facilities
are doing the most to reduce their pollution.
D
58
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1994 TRI Data Use Conference _ Pollution Prevention Track - Session 5
Session 5: Beyond TRI: How Additional State Data is Used
Leader
Natalie Roy, Executive Director, National Pollution Prevention Roundtable
Speakers
Ken Gedser, Director, Toxics Use Reduction Institute, University of Massachusetts Lowell
Carolyn Niinley, Research Associate, Chemical Hazards Prevention Program, INFORM, Inc.
Susan Peck, Director, TUR Reporting and Planning Program, Massachusetts Department of Environmental
Protection
Andrew J. Opperman, Environmental Scientist, Bureau of Hazardous Substances Information, New Jersey
Department of Environmental Protection
Paul A, Wright, Senior Attorney, The Dow Chemical Company
Natalie Roy, Executive Director, National Pollution Prevention Roundtable
Because it covered a significant amount of new ground, this panel served as a fitting conclusion not just
to the pollution prevention track of the TRI conference, but to the entire conference. Whereas risk targeting,
emergency planning, and data integration were issues that arose frequently during many of the other sessions,
the issue of materials accounting, and its significance to businesses, and the trade secret implications of reporting
this data were almost the exclusive domain of this panel. The discussion was followed by a lively question and
answer session.
Suzie Peck from the Massachusetts Department of Environmental Protection and Andy Oppennan from
the New Jersey Department of Environmental Protection were very thorough in discussing how Massachusetts
and New Jersey use materials accounting data Carolyn Nunley from INFORM, advocated the expansion of TRI
to include chemical use. Paul Wright, a Senior Attorney with the Dow Chemical company and the panel's
industry representative, rigorously defended a company's right to withhold data from the public in order to protect
trade secrets. He noted several instances where a state regulatory agency's nature of storing industry data nearly
led to serious information leakages. Ken Geiser, Director of the Massachusetts Toxics Use Reduction Institute
refuted these arguments and suggested that businesses express concern about trade secret implications in order
to avoid releasing data that Geiser said should be public.
The discussion became particularly spirited when industry representatives pointed out the irrelevancy
of materials accounting data, while state regulatory proponents and nongovernmental advocates noted that
materials accounting data is much more revealing than end-of-pipe measurements.
D
Ken Geiser, Director, Toxics Use Reduction Institute, University of Massachusetts Lowell
The Benefits of Chemical Use Data: Suggestions from Early Massachusetts Experience
The Massachusetts Toxics Use Reduction Act provides for a mandatory chemical use inventory reporting
system. Each year, as firms prepare their "Form R" for the federal Toxics Release Inventory (TRI) they also
prepare a "Form S" for the state Toxics Use Reduction program. A page from the state Form S is presented here
as Exhibit A. In addition to the chemical release data required under the TRI, Massachusetts
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Pollution Prevention Track - Session 5 1994 TRI Data Use Conference
Massachusetts Department of Environmental Protection
TURA REPORT - FORM S
Toxic Use Reduction Act • Chemical Usage Faculty-Wide &. by Production Units
I/. Seaion 1: facuity-Wide Usage of Listed Chemical
u
Chcmiol Abona Semce (CAS) Number (if appbaole) «^"-<—I i/t»«ti«i>.t
L2 Facility-Wide Unje of Chemical Idcaofied in 11 above. Eater tool amount (b POUNDS) far aeh applicable caiejory.
NOTE: Byproduct (item L3J) tCTtnlhr mem all v*xca. ctmiaiainc ttt« toed eternal befarg th»««g« a treated or recycled. Read the
janrucDoat carefully, hoiro*.i, bc£on eomplctu| llui I
L2» Muutmnicd: .^_____^___^__ 12tf Geaowed •« Byprodace
L2b Pnxcsed:
L2c Olbeiwise Used:
13, stiff* in or u fiodoec
L3 OPTIONAL QUESTION. Wbea the unouna reporudin t2l.Ub.ad L2e«ic mUtd tofctbez. the mm wfll- in aunjr eases- equal
the cum of L2d cad Ue. la oU>eri0 the icuooi that ffftf.
____ demioJ wai recycled en cite.
^__ Qfx-j--*! wu held ia iaveaioiy.
Other topUint
L4 OPTTONAJL QUESTION: Did a>yibia( aoo-ioatnw oeeyr Bt ^v adlbf duraf <^ "Fan»I ^v whkh affected Ibc dau icponed?
YES _^ NO
Seaion 2: Chemicals Used in Waste Treatment Units
U Is tlu» caenueal med to neat -nac at control pollution? YES NO
If YES. cater the quantity of cheoaal code for the amount wed to treat woe or control pollution: ; ',
OPTIONAL - You may eater tne amount: i___________
; Section 3: TURA Repon On Production Unit #: (Enter * from tne Form S Cover Sheet.)
il P"- Year _______ W Byproduct Rnrtumnn ladcc
<•? Quality of Q**"""' Caic ; { 15 c~*~**~* Reducnon Indee ____
13 TooaUttRediicuoaTecluuqueiCode: ; • ; ! I ! ! ! ! ! ! ! ! ! , ! '. • • • •
If their ha» been a chiojt from one icpomn( year to tac current jar ia a (1) bate year, ud/or (2) ecojnatmr i~>inods float upiiiieantr/
alter prctnouiiy reponed dau) (or thn PRODUCTION UNIT REPORT, docabc tne cfiaa|e
Exhibit A
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1994 TRI Data Use Conference
Pollution Prevention Track - Session 5
firms reporting on the Form S must report on each listed chemical over a threshold amount used at the facility
during the previous year. For the facility as a whole, each firm must report the following for each chemical:
• amount manufactured,
• amount processed,
• amount otherwise used,
• amount generated as by-product (all non-product output),
• amount shipped in or as product.
As a means of verifying the numbers reported the state encourages firms to set up a materials accounting
procedure in such a way that the total of the first three categories equals the total of the last two. Where this does
not occur (e.g. the chemical was recycled on site, or the chemical was consumed in the production processes),
the state provides for an optional explanation.
TOXIC CHEMICAL USE AND RELEASE IN MASSACHUSETTS, 1990-1992
(in thousands of pounds—chemicals and SIC Codes are held constant)
1990
1991
1992
Toxics Release Inventory Data
Released
Transfered
Releases and Transfers
Toxics Use Reduction Data
Manufactured
Processed
Otherwise Used
Total Used
Byproduct
Shipped in/as Product
20,819 17,065 14,359
20,315 35,966 40,986
41,134 53,023 55,346
25,586 10,672 11,004
739,756 748,388 677,264
113,101 112,927 111,564
878,445 871,988 799,833
92,054 98,177 95,581
325,783 368,351 331,563
Exhibits
This data was first gathered in 1991 for the year 1990, and it has been gathered for each subsequent
year. Exhibit B provides a record of the aggregate data reported for the state during the first three years of
reporting. This data indicates that in 1990, the Massachusetts firms reporting under the state Toxics Use
Reduction program used 878 million pounds of reportable toxic chemicals. This compares to a release and
transfer of 55 million pounds reported for the same year under the federal Toxics Release Inventory. If this is
accurate, this comparison would mean that these firms used nearly 16 times more toxic chemicals than they
released in 1990.
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Pollution Prevention Track - Session 5 1994 TRI Data Use Conference
Comparable figures for more recent years are more difficult to assess because the list of chemicals and
the list of firms required to report under the state law expanded over these years while the list for the TRI
remained constant. The data presented in Exhibit B has been adjusted to include data only from comparable
firms and comparable chemicals. Still in 1992 the TURA data report that these Massachusetts firms released
nearly 800 million pounds of toxic chemicals. Of this 800 million pounds reported as used by these
Massachusetts firms, 11 million pounds was manufactured in the state, 677 million pounds was processed into
products, and 112 million pounds was otherwise used.
Aside from the value of chemical use data in better documenting the volume of toxic chemicals actually
existing in a state like Massachusetts, there are several other important benefits of gathering use data. These
include:
• Improved Targeting for Pollution Prevention Programs
• Indicators of Worker Exposure
• Assistance in Emergency Response Planning
Validating (TRI) Release Data
• Improving Corporate Management of Chemicals
Providing Common Basis for Finn-to-Firm Technology Transfer
These six points are discussed in the following sections.
1 Improved Targeting for Pollution Prevention Efforts
The TRI has served as an important data base for assisting state programs in setting priorities for state
pollution prevention programs. As states try to assess their progress in these pollution prevention programs it
is likely they will try to identify reductions in releases and transfers as indicators of success. Both priority setting
and measuring progress could be better targeted if use data were employed rather than release data. As the
Massachusetts data suggests, the release data will tend to reveal only a small fraction of chemical use in the state
and measuring progress based on release data may not identify undesirable firm behavior such as increasing the
amount of toxic chemical released in products, the amount converted in production processes, or the amount
treated on-site in waste treatment operations.
In Massachusetts chemical use data has provided an important redirection in the state pollution
prevention program. The largest TRI chemical reported as released in Massachusetts is toluene. This substance
is used ubiquitously throughout several industry categories, but significantly in the electronics industry, for
which the state is well known. While toluene emissions are of concern, the use data reveled another chemical
wormy of concern. When the state chemical use data was released by the Toxics Use Reduction program, the
staff of the Toxics Use Reduction program found that this data drew attention to an industry than that the TRI
data had not drawn attention to. Exhibit C demonstrates that the largest chemical reported as used in
Massachusetts is styrene. Styrene, a suspected carcinogen, is not used in the electronics industry, but rather in
the plastics and polymer industries. With this new information, the staff at the Toxics Use Reduction Institute
began to redirect some program focus to the plastics and polymer industries.
2. Indicators of Worker Exposure
Neither the federal Occupational Safety and Health Administration nor the Massachusetts Department
of Labor and Industries requires firms to report annually on chemical use in such a way that government
authorities might be able to predict potential worker exposure to chemicals of concern on a state-wide basis. In
feet, most occupational risk mapping is based on after-the-fact worker illness data, and only indirectly provides
a data source that could be used lor risk prevention. The TRI release data has provided state agencies with some
indicators of value in predicting potential exposure. But, release data does not accurately reflect the chemicals
actually used or converted in a facility that can lead to substantial workplace exposure. While it is true that
"fugitive emissions" can indicate potential worker exposure, such fugitive emissions often occur at roof level or
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Pollution Prevention Track - Session 5
TOP 20 CHEMICALS USED IN MASSACHUSETTS, 1590
Chemical Name
1 STYRENE MONOMER
2 COPPER
3 SULFURIC ACID
4 TOLUENE
5 COPPER COMPOUNDS
6 HYDROCHLORIC ACID
7 METHANOL
8 METHYL ETHYL KETONE
9 1,1,1-TRICHLOROETHANE
10 NICKEL
Total Top Ten
11 ACETONE
12 ZINC AND COMPOUNDS
13 CHROMIUM
14 FORM ALDEHYDE
15 DIETHYLHEXYL PHTHALATE
16 DICHLOROMETHANE
17 XYLENE MIXED ISOMER
18 AMMONIA
19 GLYCOL ETHERS
20 METHYLENEBISPHENYL
Total tl-20
TOTAL TOP 20
TOTAL USE
Total Number of Chemicals
Used
Total Use
395,273,010
98,662,696
41,872,305
40,948,447
35,430,681
28,565,200
22,304,516
20,191,339
15,865,068
15,270,342
14,654,517
13,420,141
12,968,445
9.230,184
8,586,024
7,892,822
7.742,997
7,452,764
6,481,661
6,446,773
809.759,932
915.347.795
128
Percent of
Total Use
43.18
10.78
4.57
4.47
3.87
3.12
2.49
2.21
1.73
1.67
714,883,604 78.10
1.60
1.47
1.42
1.01
0.94
0.86
0.85
0.81
0.71
0.70
94,876,328 10.37
88.46
Exhibit C
at the top of vents and stacks and fugitive emissions estimated from emission factors are not sensitive enough
to capture the minuscule levels of release that may put workers at risk.
While use data can never be viewed as an accurate record of exposure (because it does not account for
exposure control features in place at the facility) it does provide a better indicator than release data because it
reflects the chemicals actually employed on the shop floor. The chemical use data collected under the
Massachusetts program provides occupational health agencies the first state-wide data on chemical use that can
assist in targeting preventive occupational health programs.
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Returning to the case of styrene, much of this chemical used in Massachusetts is converted in process
in chemical reactions to make polymers. While the controlled nature of these processes may not result in unusual
risk levels for workers, the identification of styrene as a commonly used toxic chemical in Massachusetts has
raised state interest in boat hull fabrication and in the manufacturers of plastic tanks and pipes where worker
exposure may be much higher.
3. Assistance jjn] Emergency Response Planning
Section 311 and 312 of die federal Emergency Response and Community Right to Know Act requires
firms to report on chemicals stored on site at facilities. But, this data is reported to Local Emergency Planning
Committees in the context of emergency response planning. There is no requirement that this data be tied to
Section 313 release data or validated by material accounting procedures. Further, the data is not reported in a
manner that can be easily aggregated for State Emergency Response Commission (SERC) program planning or
targeting. While some state SERCs have effectively used the state-wide TRI release data to assist in program
planning, release data does not provide an accurate inventory of chemicals used on-site that could be the source
of a potential release of concern.
Following the identification of styrene as the largest volume chemical used in Massachusetts, the Toxics
Use Reduction Institute conducted a study of styrene and discovered that since 1987 there have been 28
accidental releases of chemical mostly due to malfunctioning equipment or human error. The largest release
occurred in 1987 when 2,500 gallons was spilled in a transportation accident. Again, the Massachusetts use data
provides the state SERC with the first state-wide inventory of where hazardous chemicals are used, potentially
stored ("held in inventory"), and potentially released under emergency conditions.
4. Validating, (TR.D Release Data
Section 313 release reporting has certainly improved over the several years of program implementation.
Firms today, are more conscientious and estimation techniques have been substantially improved. Yet, the
validity of the data can only now be assessed by a sampled audit program. Reporting use data along with release
data would provide both the firm and the government with an convenient data source for using materials
accounting as a means of validating the reported releases and transfers.
When the first year of Massachusetts program data was compared with state TRI release figures there
was a surprising level of incongruity. While much of the discrepancy may have resulted from problems
Massachusetts firms had in learning how to report under the state program, the Massachusetts data today
provides a means of checking on the accuracy of the TRI release data.
5 Improving Corporate ManffiPOTent of Chemicals
By now one of the most often touted benefits of the TRI reporting requirements has been the heightened
attention corporate management has given to facility releases and to improving the management (and reduction)
of facility releases. While there are hundreds of cases documenting how firms reduced their emissions by
implementing true source reduction programs these illustrations are an indirect result of release reporting,
however, measuring reductions in release tends to encourage firms to assess their performance by end-of-pipe
accounting practices. The gathering of use data within the firm is likely to have the same positive effect of
focusing management attention as was experienced under TRI reporting, but, in this case, the focus will be
directly on chemical selection and materials use efficiencies. Measuring progress based on use data should
encourage efficiencies in the use of materials which should ultimately benefit the financial health of the firm as
well as its environmental performance.
The experience in Massachusetts is primarily anecdotal and case specific. Some firms have certainly
reduced their hazardous waste streams by changing processes that use targeted chemicals, but others have done
so by improving their waste management systems. A great deal of attention has been paid to changing the
materials and processes of cleaning and degreasing parts. Many firms are actively exploring conversions from
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1994 TRI Data Use Conference Pollution Prevention Track - Session 5
chlcfofluorocarbons and trichloroethane to alternatives such as aqueous and semi-aqueous cleaners. Determining
the role use reporting plays as a motivating factor in such cases is confounded by the fact that these substances
are targeted internationally for phase out.
g Providing Common BflSJS for Firm-to-Firm Technology Transfer
The gathering of TRI release data has not been credited much with advancing production systems
technology transfer among firms. This is not surprising as release data conveys little about production processes
or performance, two fundamental conditions for encouraging technology transfer. Use data, on the other hand,
provides firms and governments with a means of identifying common production units among firms and across
industries and assessing performance in a manner that indicates comparative advantage among production and
materials technologies. This is the heart of the concept of benchmarking, a recent development in technology
assessment mat permits firms to compare themselves to industry norms. Thus improvements in parts cleaning
technologies that are identified in the electronics industry may provide models for improvements in the tool
plating industries, in the painting and coatings industries, or in the cosmetic jewelry industries. The development
of supercritical fluid cleaning chemistries in precision parts cleaning provides just such a possibility. A focus
on release data would not necessarily encourage this type of cross sector diffusion, while a focus on use data
would more directly highlight such possibilities.
The Massachusetts law will eventually require the state to identify common "user segments" among
industries specifically in order to compare performance and encourage the transfer of the most effective
technologies among similar firms or firms with similar production processes. Such a sectoral approach that aids
in technology transfer would not be possible without the process specifics that use data provides.
D
Carolyn Nunley, Research Associate, Chemical Hazards Prevention Program, INFORM, Inc.
The Value of Comprehensive Data For Measuring Industry Progress in Pollution Prevention
This presentation provided an overview of a recent INFORM analysis of the comprehensive data on toxic
chemical use and waste (throughput data) that industries in New Jersey are required to report annually as
compared to the much narrower waste generation and release data reported to the federal Toxics Release
Inventory (TRI). INFORMS analysis highlights a single chemical at eight different facilities to show how relative
quantities of a given chemical produced, used, released, and generated as waste vary significantly, making
reporting of the full range of data essential to monitoring pollution prevention progress. The federal TRI data
revealed mat in 1992, New Jersey facilities generated more than 203 million pounds of the 300-plus reportable
chemicals as -waste. However, die throughput data reported to the New Jersey program show mat these same
facilities used a total of nearly 15.2 billion pounds of these same chemicals in their processes and products;
chemical use may pose substantial risks of chemical release and exposure. INFORM's presentation included a
discussion of the value of comprehensive data as a basis for assessing risks to workers, the community, and the
environment; as a means for tracking regional and national trends mat may reveal current or future damage to
public health and the environment; as an aid to assessing problems related to the use of toxics in commercial
products; and as a tool for monitoring progress on toxics use and source reduction.
D
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Pollution Prevention Track - Session 5 1994 TRI Data Use Conference
Susan Peck, Director TUR Reporting and Manning Program, Massachusetts Department of Environmental
Protection
Using Additional Pollution Prevention Data Elements to Measure Progress in Pollution Prevention:
Massachusetts Toxics Use Reduction Program
The Massachusetts Toxics Use Reduction Act (MGL 211) requires industrial firms that use certain toxic
chemicals in excess of 10,000 pounds to report on their toxic chemical use and progress in pollution prevention.
This information builds on the Federal EPCRA transfer and release reporting requirements.
What Additional Pollution Prevention Data Elements Are Reported
Specifically, Massachusetts Large Quantity Toxics Users (those facilities with more than 10 FTEs, in
SIC codes 10-14,20-39,40,44-51,72,73, or 75, who manufacture or process more than 25,000 Ibs or otherwise
use more than 10,000 Ibs of a listed chemical per year) must report the following information in addition to the
information included on the Federal Form R:
Facility Wide Information:
• Quantity of the Chemical Used
Quantity of the Chemical generated as "byproduct" (waste prior to treatment or recycling)
Quantity of the chemical shipped as or in product from the facility
• The projected change in the quantity used 2 and 5 years in the future
• The projected change in the quantity generated as byproduct 2 and 5 years in the future
If the materials balance Use = Byproduct + Shipped in Product does not balance, why not (optional)
• Why a chemical reported in a previous year is no longer being reported (optional)
For each Production Unit (Product/Process Combination) in which the chemical is used:
Description of the Production Process (unit operations, SIC code, product description).
Whether 0-5000,5000-10,000 or >10,000 Ibs are used in the production process.
• Current and projected "byproduct reduction index" (a measure of progress in pollution prevention — the
BRI is the percentage change in the amount of byproduct generated between 1990 and the present,
normalized for production level).
• Current and projected "emissions reduction index" (a measure of progress in the reduction of transfers
and releases from the facility - the ERI is the percentage change in the quantity of the chemical released
directly into the environment or sent oflsite for recycling, treatment, or disposal, between 1990 and the
present, normalized for production level).
• TUR techniques that led to the current and projected "byproduct reduction index."
The projected items are based on Toxics Use Reduction Plans that the Large Quantity Toxics Users (LQTU) are
required to prepare biannually. July 1994 was the first year in which the plans were required and the projections
submitted to the department.
Using the Additional Data Elements
Ken Geiser of the Toxics Use Reduction Institute at University of Massachusetts at Lowell discusses
several of the "other" uses of the "additional" data elements submitted to DEP in a companion presentation. This
paper focusses on how they can be used to measure pollution prevention progress.
The first statistic is changes in use. LQTUs in the manufacturing SIC codes have had to report on
Section 313 chemicals since 1990. Comparing the quantity of 313 chemicals used by this group between 1990
and 1993 reveals that use dropped by 19 % from 1.2 billion pounds to .9 billion pounds. The quantity of 313
chemicals used by LQTUs in the manufacturing SIC codes is projected to decrease by 7% between 1990 and
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1994 TRI Data Use Conference Pollution Prevention Track - Session 5
1998. (Absolute numbers are not provided because a small percentage of the LQTLTs have not yet completed
their TUR plans and submitted their projections. These facilities are under enforcement order.) The quantity of
313 chemicals projected to be generated as byproduct by the LQTUs in the manufacturing SIC codes dropped
by 14% between 1990 and 1993, from 125 million pounds to 108 million pounds. The quantity of byproduct
is projected to drop by 15% between 1990 and 1998.
Since these raw numbers can be affected by changes in production in addition to pollution prevention,
it is important to look at measures that "normalize" for production level. For example, about half of the drop in
use between 1990 and 1993 is attributable to the closure of two large facilities in the state.) Two such measures
are possible with the TURA data: an efficiency measure and the BRIs.
The efficiency of chemical use can be evaluated by determining what percentage of the chemical does
NOT end up as waste. That is, the percent incorporated into the product or consumed in production. In 1993,
the efficiency of chemical use was 89%. This number is unchanged from 1990. By 1998, overall efficiency is
projected to be 92%. This represents a significant increase, and is independent of production levels.
The other way to measure progress is to look at the BRIs. In 1993,14% were negative, 29% were equal
to zero, and 57% were positive. (Positive BRTs mean that a chemical is being used more efficiently in a
production process. BRTs equal to zero mean that the efficiency is unchanged and negative BRIs indicate that
a particular chemical is being used less efficiently in a production process.
In 1998, the distribution of negative, zero and positive BRTs is projected to be 14%, 20%, and 65%.,
respectively. Thus, by 1998, the number of chemical/production unit combinations that are expected to be less
efficient is unchanged, fewer will have made no progress, and more production unit/chemical combinations will
become more efficient than they are today.
D
Andrew J. Opperman, Environmental Scientist, Bureau of Hazardous Substances Information, New Jersey
Department of Environmental Protection
New Jerseys Materials Accounting Approach to Environmental Release and Pollution Prevention
Reporting
Introduction
New Jersey is a highly industrialized as well as a densely populated state. The proximity of industrial
facilities, manufacturing, processing, and storing toxic chemicals, to population centers leads to concerns
regarding potential toxic chemical exposures to human health and the environment. New Jersey's Industrial
Survey Project (ISP), conducted by the DEP between 1979 and 1982, was considered to be one of the first and
most successful attempts by any state [at the time] to use a cross-media approach to materials accounting for
toxic chemicals.
The Project was designed to identify the types and quantities of toxic chemicals used by manufacturing
industries in the state as well as to determine the fate and effects of those chemicals on human health and the
environment. The ISP also laid the foundation for the development and implementation of the New Jersey
Worker and Community Right to Know Act of 1983 which provides for the consistent performance of
comprehensive toxic chemicals accounting in New Jersey. And it is generally well known that New Jersey's
program, along with a program implemented in the state of Maryland, was recognized by the U.S. Congress as
a model in the development of the federal Emergency Planning and Community Right to Know Act of 1986.
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MfltCTJals Accounting Process
The State of New Jersey requires additional information from those facilities subject to the reporting
requirements of Section 313 of the federal Emergency Planning and Community Right-to-know Act The
information is reported on the New Jersey Release and Pollution Prevention Report (RPPR). The same chemicals
that are reported on Form R are reported on the RPPR.
Facilities are required to provide chemical throughput data, and environmental release and off-site
transfer data, as well as information regarding pollution prevention activities. The RPPR, therefore, is the tod
to identify the types and quantities of toxic chemicals used by manufacturing industries in the state. The
throughput, release and transfer data are then analyzed as chemical "inputs" and "outputs" at the facility level.
The input component includes: 1) the starting inventory of the chemical for the year; 2) the quantity produced
on site; and 3) the quantity brought on site. The output component includes: 1) the quantity of the chemical
consumed (chemically reacted) in process on site; 2) the quantity shipped off site as (or in) product; 3) the
quantity destroyed through on-site treatment; 4) the quantity destroyed through on-site energy recovery; 5) the
year end inventory; and 6) all environmental releases and off-site transfers for further management.
A quantitative materials accounting of the chemicals is established by conducting a simplified mass
balance. The approach is considered simplified since the data are summarized at the facility level for the
reporting year using the best estimates available. An assessment of the general data quality is then performed
by calculating the difference between the input and the output for each chemical record. The difference provides
an assessment of the balance, or closure, achieved in the materials accounting process. The resultant
discrepancies are then addressed as a quantitative difference or a percent error.
Data Quality
Large quantitative discrepancies become the first priority in the review process. Large differences are
observed for both excess inputs and excess outputs. However, for many chemical records, large percent errors
are observed and can be just as significant as large quantitative errors. (In the early years, recognizing that large
differences were being reported, a materials accounting worksheet was developed and included in the reporting
package.) The variety of reasons for large discrepancies include:
understanding and interpretation of the instructions
• lack of attention to reporting details
• lack of use of the materials accounting worksheet
• continued misunderstanding with respect to the reporting of metals, particularly the compound
categories
• difficulty in quantifying throughput data (e.g. in the Petroleum Refining Industries)
• data entry errors (on the form and in the database)
Data Issues
As an integral component of the data quality analysis, there arise other issues relevant to mass balance
data collection. The one that seems to be the most controversial is trade secret implications. New Jersey's
program allows for confidentiality claims with respect to any data not in the public domain with the exception
of environmental release and off-site transfer data. For the seven years that New Jersey has collected this type
of data, there has been a regular core of facilities that have made trade secret claims (TSC). However, the
requirements have not been demonstrated to present a hardship to industry and there has not been an
exploitation of the provisions by industry to keep information from the public. Historically, less than two percent
of die reporting facilities have submitted TSCs for less than one percent of the total chemical records reported
by all NJ facilities.
Commencing with reporting year 1993, facilities are required to report "non-product output" (NPO).
NPO is a pollution prevention concept defined as "all hazardous substances or hazardous wastes that are
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1994 TRI Data Use Conference Pollution Prevention Track - Session 5
generated prior to storage, out-of-process recycling, treatment, control, or disposal, and that are not intended fix
use as a product" At best, the value for this data field should be zero. Otherwise, it would be some positive
value including all environmental releases and off-site transfers for farther management Interestingly, some
facilities have reported negative values derived from the mass balance data.
Other data issues that come to the surface in the mass balance analyses, particularly when conducting
data quality reviews, are:
• Throughput reporting of metals - Can they be produced and/or consumed (consider fume or dust forms)?
Can they be destroyed through treatment? Do they have a BTU value, as many are reported under
energy recovery?
• Double counting - Observations have shown that some facilities double count: 1) quantities "consumed"
and quantities "shipped as (or in) product;" and 2) quantities released to POTWs and quantities
"transferred to other off-site locations."
Data Applicability
Despite the appearance that there are too many limitations to the data for it to be of value, just the
opposite is true. While limitations do exist, they are more of an artifact of the reporting requirements and do not
apply to all records in the database. Actually, much of the data is of exceptional quality considering that facilities
are not required to monitor or measure activities to any extent beyond that currently required by state or federal
laws, permitting programs, etc.
There are many uses of and applications for the data that have been demonstrated to date:
• First and foremost, for public awareness as Community Right to Know information
• Provide an assessment of the environmental and commercial fate of the chemicals
• Assist facilities in assessing a "cradle-to-grave" concept of the chemical (not just the waste); and in
evaluating quantities processed and otherwise used (facilities must have a knowledge of this information
in determining if TRI thresholds are exceeded)
• Provide for Pollution Prevention analyses and trends (e.g. Is NPO decreasing as a percent of total use?)
It may provide direction for a future federal chemical use inventory (e.g. TRI Phase ID)
• Provides for a focus on specific chemical groups or types (e.g. carcinogens, metals, etc.)
Paul A. Wright, Senior Attorney, The Dow Chemical Company
Beyond TRI: Confidential Business Information
The Value of Confidential Business Information
The American Chemical Industry was built on innovation — innovation which gave the American
Chemical Industry the ability to become the global leader in a global chemical business. The American Chemical
Industry has developed to become one of the very few industries with a positive balance of trade — more
chemicals are exported from the United States than are imported into the United States each year.
While U.S. patent laws give some protection to the innovation which has allowed this industry to
develop, the protection is limited in scope and time. And the protection is limited to the United States. Other
countries may not honor the patent. When the patent expires, anyone is permitted to exploit the innovation
contained within the patent. Therefore, in order to fully realize the benefit from much of the technology
developed by the chemical industry, the developer must maintain the technology as Confidential Business
Information — known to no one outside the company.
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For many companies, the technology they develop is their very lifeblood. Without adequate protection
for the confidential information, the companies will not be able to continue in business. If another person capable
of manufacturing the same product were to learn of the new technology, the competitor would likely steal the
entire market, or at least sufficient share of it to prevent the originator to compete. It is not an exaggeration to
say the in many instances, the value of the confidential business information is the entire value of a business or
company.
The Threat to Confidential Business, information
While this industrial development has progressed, so too has the development of environmental laws
which require an ever increasing amount of disclosure by the U.S. chemical industry — laws which apply only
to the U.S. chemical industry and not to foreign competitors. Many of these environmental laws appear at first
glance to require disclosure of only information necessary to inform a public about the environment in which they
live. However, a study conducted by CMA showed that when taken together, the information disclosed under
seemingly unrelated laws can be and are collected by industry intelligence groups in order to deduce the
technology used by the submitter. The techniques used by the intelligence groups is not complicated. These
firms conduct these investigations for various clients, including competitors in the industry — foreign and
domestic. Thus, one must view each requirement to disclose information in the context of all other requirements
to disclose information in all jurisdictions.
As the requirements to disclose information continue to grow, so too does the ability of foreign and
domestic competitors to discover the technology used in the U.S. chemical industry. This will inevitably erode
the competitiveness of the U.S. chemical industry. Without a cooperative effort among the industry, government
and the public, the growth of the U.S. chemical industry will be threatened.
The Need for Cooperation Among Industry. Government & The Public
The chemical industry recognizes the need for an informed public and the need to share information with
die government in order that die public health and die environment can be preserved. However, die public and
government must recognized that it is not necessary for die general public to know everything that die
government knows in order diat health and die environment is protected. The government must play an
important role in collecting, digesting and analyzing information. Then, die government, under die appropriate
statutory authority, can act as necessary to protect health and die environment The public must rely upon die
government to fulfill tiiis role. The common goal can be achieved - to protect healdi and die environment while
allowing U.S. industry to compete in the global economy. It is important to recognize that die goal is NOT toxic
use reduction. Industry does not, as a whole, support die concept of toxic use reduction. Rather, many, if not
most, in industry believe diat performance standards, radier than command and control standards, are die
appropriate approach to risk management.
The industry is committed to providing government with die information necessary to cany out its role.
ft is important to keep in mind diat disclosure to die government is not die key issue in maintaining Confidential
Business Information. The key issue is disclosure to competitors. Generally, die government has demonstrated
its ability to maintain die confidences entrusted to it. Even so, experience and study have shown diat in some
instances, state governments are not well equipped to protect die sensitive information required to be submitted
under some state and federal laws. If die level of protection can be achieved at die state and local government
level mat is provided at die federal level, then die fears of inadvertent disclosure of die confidential information
could be eased.
Industry also recognizes diat die pressure is increasing on federal and state government agencies to
disclose or to limit die ability of industry to make claims of confidentiality. The pressure comes from many
different sources including healdi professionals and special interest groups. Because some of these entities have
a special need for additional information, a solution must be found diat will satisfy die need of die group while
maintaining all aspects of die common goal.
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1994 TRI Data Use Conference Pollution Prevention Track - Session 5
An investigation by CMA indicated that the entities most likely to seek information from the
governmental files are not the general public or even public interest groups. Rather, the most common entity
seeking the information submitted by the chemical industry are foreign competitors, law firms representing
industrial clients, and industrial intelligence firms working for domestic and foreign competitors. This tells the
U.S. chemical industry that submission of information to the various governmental units can be very useful to
competitors in their attempts to gain competitive advantages.
One should keep in mind that one easy method for avoiding CBI claims is for the government to avoid
asking that confidential information be submitted in the first place. Government should evaluate carefully
whether additional information will actually provide increased protection of the public's health or the
environment Alternatives to reporting information to the government should be explored.
Alternatives that work
One such alternative is the fostering of the relationship between a facility and its neighbors. Most
responsible companies now have community out-reach programs in which they meet with local governmental
officials and citizens to talk about the plant and the emergency planning. Some have chemical information
available to the public at the local library or other facility. These programs can provide the level of comfort
necessary for the local residence without jeopardizing the disclosure of confidential information to competitors.
This fits well with the common goal I stated earlier — to protect health and the environment while allowing U.S.
industry to compete in the global economy. In this type of program, government can avoid the necessity of
collecting and protecting confidential information, while still providing the protection to the public and the
environment.
Other countries have addressed this concern differently than in the U.S. In Japan and in Western
Europe, the governments recognize the value of the confidential information to their economies. Thus, those
governments are more likely to resist the pressure to disclose the information, thus preserving the competitive
position of their industry.
Conclusion
Reiterating, the industry believes that the common goal ~ to protect health and the environment while
allowing U.S. industry to compete in the global economy — can be achieved. What the public and government
must be willing to recognize is that confidential business information has high value to the industry and to the
national economy. Protecting that information from competitors is, therefore, important to everyone.
D
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Partnership Track - Session 1 1994 TRI Data Use Conference
Session 1: Local Emergency Planning and TRI
Session Leader
Carol Macko, EnvironmentalJournalist, Bureau of National Affairs
Speakers
John Ferris, Chemical Emergency Preparedness and Prevention Office, U.S. Environmental
Protection Agency
Elizabeth Gonzalez, Deputy Coordinator, Emergency Preparedness, City of Pasadena, Texas,
LEPC Coordinator, Pasadena, Texas LEPC
John Pine, Associate Professor, Louisiana State University
JanR. Taylor, Ph.D., National Institute for Chemical Studies, Charleston, WV
Carol Macko, EnvironmentalJournalist, Bureau of National Affairs
The Emergency Planning and Community Right-To-Know Act provides communities access to a wealth
of information, including TRI data But most local emergency planning committees (LEPC) do not make use of
TRI data, according to panelists at the 1994 TRI Data Use Conference.
Some LEPCs report using TRI data to: identify facilities to be covered by the local emergency plan; make
the data available to the public under EPCRA's right-to-know provisions; identify facilities that may not be
reporting hazardous materials (for enforcement); include the data to construct hazards analyses for specific
facilities; conduct risk assessments; assign priorities to facilities to be included in the emergency response
planning process; initiate discussion with facilities about reducing the amount of hazardous materials they use;
assist a city planning office in making zoning decisions; assist the fire department in fire inspections; prioritize
response preparedness; update local emergency response plans; and supplement the fire department's computer
dispatch.
The fact that a few LEPCs have found TRI reports useful in these ways suggests that others might want
to explore ways to use them in their communities.
Some of the reasons given by LEPCs for not using the data include: Tier n data is more useful for
emergency planning; TRI data underestimates risks; the data is too complicated to interpret; the delay in public
distribution of the data to states and the public; not readily available to LEPCs; does not differentiate between
uncontrolled releases and other types of releases; too much information to handle; and lack of resources to do
anything with the data.
Several audience participants called on EPA to develop computer programs that would assist LEPCs
in the manipulation of the TRI data. Others said EPA needed to do a better job of outreach to show LEPCs the
potential of unking TRI data with chemical inventory information compiled under EPCRA Sections 302,311
and 312.
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John Ferris, Chemical Emergency Preparedness and Prevention Office, U.S. Environmental Protection
Agency
EPCRA provides local communities with the authority to receive almost any information they want.
TRI gives communities the amount of toxic chemicals that is being released; Section 311 and 312 provide an
inventory of all the chemicals at a facility; section 304 provides the amount released and possible harm caused
by releases of hazardous substances; and, section 302 provides the community with the means to receive any
information regarding hazards from facilities that EPA or the state dictate.
During the Spring and Summer of 1993, torrential rains throughout the Midwest caused the largest
flood disaster in United States history. Over 500 counties in nine states were affected by flood waters. The
damages were estimated at $12 million.
In the initial hours of the response, we sought out any information we could get that showed where there
could be the greatest risk of hazardous chemical releases. We pulled together the TRI reports, CENSUS Bureau
reports, RCRA facility lists, and Superfimd site lists. For states that had their hazardous chemical inventory
(TIER II) reports computerized, the responders were able to use those reports as well.
Doing this, we realized that EPA has a wealth of information that could be useful to local emergency
planning committees (LEPCs). This accelerated a program we were working on called LANDV1EW. Using this
program, you can make maps. We are now finalizing ways to make this map making ability available to
communities.
While doing this project, we learned an important lesson. The information in the database is close, but
by no means perfect For example, some Superfund sites were located by a zip code centroid. This may be close
enough for some purposes, but a local community would want to know exactly where the site is
All of this information can provide an awareness of the operations of facilities in the areas. Change
comes facility by facility. If a community sees that a facility in their area is performing well, they should make
an example of the facility for the other facilities. If they find a facility that is not performing well, they could
make an example out of it as well. It all begins with awareness, and bringing that awareness to the right people.
D
Elizabeth Gonzalez, Deputy Coordinator, Emergency Preparedness, City of Pasadena, Texas, LEPC
Coordinator, Pasadena, Texas LEPC
Use of TRI Data for Emergency Planning
By profession I am an Emergency Planner for the City of Pasadena, Texas. By virtue of that
responsibility, my office has maintained an active role in the Local Emergency Planning Committee for Pasadena
I am addressing you today as a representative of the ten (10) LEPCs that surround the Houston Ship Channel
and my counterparts in the same area in Emergency Management. We comprise the southeast portion of Harris
County and are highly industrialized due to the proximity of the Houston Ship Channel. Our municipal
boundaries are contiguous so that if one did not know where the boundaries were, one would not be aware of
passing from one city into the next.
To understand how we have 10 LEPCs in that one section of Harris County, you must be made aware
that Texans are different. While we have county government, that government has no jurisdiction within the
boundaries of the cities and the cities do not answer to the county in any manner. A county, in Texas, has
jurisdiction only over unincorporated areas unless it is specifically granted to them by local government. A
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county has no emergency response capability beyond law enforcement. Being of an independent sort, each
municipality in Harris County elected to form its own LEPC.
Being practical, those of us who do the work (and most times carry no lofty title) know that what we
do affects one another. Our highest concern being the safety and lives of our citizens, we have elected to work
together on many things that are common while maintaining our separate identities.
When I was approached to participate in this panel about the uses of TRI data in emergency plans and
LEPCs, I talked to representatives of other ship channel LEPCs. You see, my LEPC does not use TRI data
While I knew that we did not find a value in the TRI data, I wanted to find out if we were missing the boat Was
there a use for this data that we had not seen? Would it improve our emergency planning? Perhaps we just didn't
know how to read the data. The survey of the other LEPCs in our area told me that if my LEPC was missing
out, then so were they. None of the LEPCs in our area have ever used the data submitted in the TRI reporting.
The data is a year old when it's submitted and isn't released for a up to one and one-half years in addition to that
The data is subjective, cumulative, making no distinction in the areas in which it is important for emergency
planners. The total numbers, as we understand them, includes amounts lost due to leaky valves, permitted
releases, stack emissions, discharge into the waste stream, and other things that it is not important for an
emergency planner to know along with the "unpermitted releases" that can be classified as emergencies.
Emergencies are reported immediately and under other provisions of EPCRA Quite often, an emergency
response must be made immediately. The information on what chemicals are on site are reported on the chemical
inventory reports. The vulnerability to our citizens from uncontrolled releases of these chemicals are determined
through our vulnerability analysis. The information on total amounts released into the environment do not
concern us from the emergency planning aspect.
Please don't misunderstand. We are concerned about the environment and about what is released into
the environment If it can affect our citizens who live and work in the area, we are concerned. We are also
concerned because we, too, are citizens and we are concerned about our long term welfare and that of our
families.
As an LEPC we can use the general information that comes from the cumulative reporting to convince
the community that SARA Title HI does work and is of benefit for us. Because of the reports we can point out
that, in Region 6, the environment has sustained 41% reduction in chemical pollution since the beginning of the
required TRI reporting because it pointed out to industry where they were losing a significant amount of their
chemical inventory. While this is an excellent tool for community relations, it is the effect of the cumulative
information released, not specific reports from specific industries.
The data accumulated from TRI submissions can be used by local governments, but it is in a regulatory
area, not emergency planning. While some LEPCs may try to get into the regulatory area, most LEPCs have
everything they can do to accomplish the tasks set out for them under EPCRA One of the reasons the data is
not used in our area has to do with the boundaries of our LEPCs and cities. I gave you a brief overview of the
boundaries in the Ship Channel area. Most of our heavy industry - those who must file TRI release data, are
along the ship channel. The "Port Authority" extends from a center line of the Houston Ship Channel 1/2 mile
which includes the major portion of most of the industries. Technically, only parts of most of the industries
reporting to our LEPCs are in our jurisdictions. As mentioned before, the county has no emergency response
capability. The municipalities provide immediate emergency response to the industries, therefore, they (the
industries) report to and participate in the LEPC that they would effect first in an incident, and who provides the
response to their emergencies. The municipalities have no regulatory authority over the industries who file Form
R. While our LEPCs may seem strange to people outside the state of Texas.... they work!
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We have coordinated our emergency planning between municipality and industry, industry and industry,
and municipality and municipality. We have increased the training of municipal responders using industrial
resources to increase their knowledge and capabilities. We exercise these plans - together.
We have improved the warning capability of the cities - with the help of our industry. To date, five cities
have installed outdoor warning systems. Plans are in place to complete these systems in three more cities., .with
industries financial help. Telephone alerting systems are used in two cities, low band AM radio stations are in
place in four cities.
We have increased the communities awareness of LEPCs through a Community Telephone System to
give citizens a number to call to get information about incidents on-going along the channel. When there are no
incidents, it gives them an avenue to gain information about the area LEPCs. The level of cooperation between
industry and cities cannot be rivaled. But TRI data is still not utilized in any of these efforts.
D
John tint, Associate Professor, Louisiana State University _
Risk Assessment in High Hazard Areas
Introduction
Chemical processing is a major part of the Louisiana economy. The Transportation and Environmental
Safety Section of the Department of Public Safety and Corrections (DPS) reports that approximately 25% of
regulated hazardous materials in the United States are either produced, used, stored, or transported within the
boundaries of the State of Louisiana. In addition, major transportation routes including rail lines, interstates,
pipelines, waterways, and ports are located within the boundaries of the state. Because of the extensive volume
and scope of chemicals processed within the state, Louisiana faces a significant need to enhance its state and local
planning and response systems relating to hazardous chemical emergencies.
The Louisiana SERC with assistance from EPA identified high hazard areas in the state and assisted the
LEPCs in these communities in improving hazardous materials emergency response plans. The high hazard
parishes were identified by analyzing hazard indicators which reflected the extent of hazardous chemicals in the
community. These hazards indicators formed the basis for ranking the parishes as to the relative risks associated
with processing hazardous chemicals.
Hazards within the "High Hazard Parishes" were analyzed by teams composed of the LEPC members.
The LEPC teams conducted a comprehensive analysis of Tier 2 inventories and identified those chemicals that
pose the greatest risk to the community. After identifying and ranking the risks present in the parish, the teams
determined the potential impact of an accidental release of the hazardous chemical. A vulnerability analysis was
then conducted to determine who could be affected by the release.
With the results from the analysis of local hazards, the LEPCs could determine if the current emergency
operations plan were focused on the greatest risks in the community. The LEPC could determine what changes
must be made to the parish emergency operations plan and agency annexes to minimize the adverse impact of
the hazards present in the parish.
Local
Hazard indicators are tools used to identify and measure the risk of emergencies associated with
processing of hazardous chemicals. These indicators are specific, measurable, and enable planners to compare
relative risks in the local community. The examination of risks were based on specific facility location in the
parish. During this initial look at TRI data as an effective indicator of risk in the local community, an analysis
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of the Tier 2 and TRI data by geographic classification system established by the U.S. Bureau of the Census was
not used Further analysis will be made to determine if analysis of TRI data by Census block group and postal
service ZD? Codes are an effective means of identifying high risk in the local community. The location of Tier
2 and TRI facilities has been geocoded in two GIS mapping programs in this study. Maplnfo and Arc View n
are both being used to analyze relative risks in Louisiana communities. Block group boundaries were not
available at the time the initial phase of this study was completed. Further analysis of facility incidents and
transportation incidents will be completed using Maplnfo and Arc View n.
Sources of information for hazards identification in this study included local Tier 2 records and Toxic
Release Inventory Reports. These records were obtained from the Transportation and Environmental Safety
Section of the Louisiana State Police and the Louisiana Dept of Environmental Quality. The TIER 2 Report and
Toxic Release Inventory provide an excellent basis for evaluating risks associated with processing hazardous
chemicals.
Identification of High Hazard Areas
Hazard indicators drawn from Louisiana's Tier 2 reports and the Toxic Release Inventory were used to
determine if the total amount of air emissions recorded in a facility's TRI report was a good predictor of relative
risk in a local community when compared to high risk rankings determined by using Tier 2 EHS inventory
records and EHS accidental release records.
The Tier 2 and TRI records used in this study were selected based on a statewide comparison of risks
in each of Louisiana's 64 parishes. An analysis of all 64 parishes in Louisiana showed that parishes with highest
number of Tier 2 facilities also had the greatest number of TRI facilities. The same relative ranking also occurred
when the parishes were compared using the number of EHS and TRI chemicals. The parishes selected for this
study to determine if the TRI data is an appropriate indicator of high risk at the local level were selected from the
top ten high risk parishes in the state.
The following findings were drawn from an analysis of the relative risks associated with the 64 parishes
in Louisiana. The ten high hazard parishes used in the present study have the following characteristics.
• The high hazard parishes tend to have the lowest unemployment rate.
• The high hazard parishes tend to be in the most industrialized urban and rural areas of the state.
• The high hazard parishes included all urban industrialized areas.
• The rural high hazard parishes are also on the Mississippi River (St. James, St. Johns, St Charles, and
Iberville Parishes). The population of these parishes range from 20,000 to 45,000 residents.
• The urban industrialized areas have the highest average weekly wage of parishes in the state and are also
on major transportation routes including rail, shipping, and highway.
The unemployment rate is low in the urban industrialized centers (East Baton Rouge, Jefferson, and
Orleans parishes).
• One rural industrialized parishes has an unemployment rates of less than 8% (St Charles). High hazard
rural industrialized parishes with an unemployment rate of 8% or greater include St Johns, St James,
and Iberville).
The TRI total emissions is the best indicator for high hazard parishes (Toxic Release Inventory
Database).
The parishes with high numbers of TRI facilities have a positive relationship when compared with
parishes with high numbers of EHS chemicals and EHS facilities. The comparison of TRI facilities with
EHS facilities and chemicals provide good indicators of high hazard parishes.
• The parishes with large inventories of Tier 2 chemicals and large numbers of Tier 2 facilities have a
positive relationship with parishes with large numbers of EHS facilities and EHS chemicals. The
comparison of parishes with Tier 2 chemicals and Tier 2 facilities with EHS facilities and chemicals are
thus good indicators of high hazard parishes.
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• The high hazard parishes included Ascension, Caddo, Calcasieu, East Baton Rouge, Iberville, Jefferson,
Orleans, St. Charles, St. James, St John the Baptist parishes.
An initial assessment of risks using these indicators was used to identify high risk areas in Louisiana
The data presented a clear picture showing that the industrialized areas of the state had the most facilities,
chemicals, and greatest volume of hazardous chemicals. The fifteen parishes with the greatest relative risk will
be provided special assistance in hazards analysis with the intent of enhancing local emergency planning and
response efforts.
findings
An initial assessment of these indicators was used to identify high risk parishes in Louisiana. The data
presents a clear picture mat for communities with established industrialized economies, the TRI data is a useful
indicator of risk, hi Louisiana, the industrialized areas of the state also have the most chemical process
operations, chemicals, and greatest volume of hazardous chemicals.
• TRI facilities with the greatest number of TRI chemicals recording air emissions were also the facilities
with the greatest number of EHS chemicals
• TRI facilities with the largest volume of permitted and non-permitted air emissions also had the largest
volume of EHS chemicals
• Some facilities with a large volume of Tier 2 reportable hazardous chemicals may not be included in the
TRI list Public funded operations or utilities were among the facilities reporting large volumes of
extremely hazardous chemicals; these facilities are not included in the TRI program. Since these
facilities are not a part of the TRI Program they would not be expected to be included in the TRI data.
Water treatment plants, sewerage treatment facilities, pipelines, and electrical utilities (Louisiana Power
and Light / Entergy) would be the type of high risk facility in a local community not reflected in the TRI
Program.
Wholesale trade operations such as Delta Distributors, Fuselier and Thompson Stores, Dowell
Schlumberger Inc., and Diversified Foods, which distribute hazardous chemicals were in the Tier 2 high
risk category of facilities at the local level but were not included in the TRI Program.
Service industries that use hazardous chemicals would not be covered under the TRI Program
and be reflected as a high risk facility in the TRI data. St John Well Booster and Matheson Gas
Products both are involved in providing industrial services to the chemical processing operations in
Louisiana These business may not be included in the TRI Program.
• Caution should be taken to use TRI facilities as indicators of high risk in local communities. It should
be noted that the number of EHS chemicals identified by the U.S. Environmental Protection Agency
(EPA) include 435 chemicals. A total of 436 chemicals are identified by the EPA in the TRI Program.
The list of chemicals is not the same and include only 96 common chemicals. This means that only 96
chemicals are listed by EPA as both a TRI chemical and an EHS chemical.
The use of the TRI data as an indicator of relative risk in a local community is an appropriate tool for
emergency planning. The user of the data, however, must realize that the absence of a reporting facility's name
from the TRI list does not mean mat the facility has an excellent record of safety nor that large amounts of
hazardous chemicals are not present at the facility. The list of TRI facilities simply point the way to further
analysis and provide a quick focus on selected facilities in the United States. Extreme care should be taken not
to assume mat the presence of a business on the TRI report is not a reflection of the effectiveness of management
The TRI data is simply a useful tod in focusing attention at the local level on chemical process or manufacturing
operations.
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Conclusions
A year long project has focused on helping state and local emergency planning and response agencies
to develop and maintain information relating to hazardous chemical emergencies. Hazard indicators were used
to identify high hazards parishes and were used to form a basis for analyzing risks in each of the high hazard
parishes. LEPC members reviewed Her 2 and TRI data. High hazard areas in the parishes were identified and
comprehensive emergency plans for these high hazard areas were examined to ensure that the plans were an
appropriate response to the identified risks.
The TRI Program includes manufacturing facilities with 10 or more full time employees. It also involves
business operations with a Standard Industrial Classification Code from 20 through 39. This includes the
manufacturing of durable and non-durable goods. The TRI Program also focuses on business operation that use
10,000 pounds or more of a reportable toxic chemical in a year. Louisiana's Tier 2 threshold reporting
requirements are much lower that the TRI Program and lower than other state Tier 2 threshold reporting
programs. Caution should be taken when comparing the results of this study to other states. High Tier 2
thresholds could result in different relative ranking of facilities.
Analyzing risks in high risk areas leads to more effective emergency planning at the local level. LEPCs
may develop the capacity to use local data to assess local plans and focus on the development of emergency
response plans in high hazard areas. Data relating to the social and economic characteristics of the local
community may be used in analyzing the impact of hazards. Facilities in the high hazard areas may use local
social and economic data to ensure that the facility emergency response plan is sensitive to the local population
that could be affected by an accidental release of a hazardous chemical.
The high hazard project demonstrated that a SERC and LEPCs can use hazardous chemical emergency
information to enhance emergency plans at the local (including facility) level. LEPC and facility plans may also
be more sensitive to the impact of hazards on local population and accommodate the special needs of local
residents.
D
Jan R. Taylor, Ph.D., NationalInstitute for Chemical Studies, Charleston, WV
Toxic Release Inventory and Emergency Planning: Feasibility and Utility for LEPCs
Introduction
In 1985, the National Institute for Chemical Studies (NICS) began working with the chemical industry
and the public to build credible information for environmental decision-making. Since the enactment of
provisions set forth under the Emergency Planning and Community Right-to-Know Act (EPCRA), Local
Emergency Planning Committees (LEPCs) have been formed and have utilized the information made available
by EPCRA, in many cases, to write emergency plans, transfer technology, redirect financial resources, and set
priorities. Likewise, states and the federal government have used the information to assess pollution trends, write
regulations and lobby for funds. Citizens have become involved in plant-level decision-making and communities
have been the benefactor. But not all areas have the access and the ability to take advantage of the broad array
of information available.
There are a myriad of databases and sources of environmental, public safety and emergency response
issues which could be investigated by LEPCs to form a more comprehensive view of environmental data. For
the purposes of this pilot study, however, NICS is focusing on sections 311/312 and 313 for the inherent value
of collectively assessing environmental issues. In other words, we are investigating not only the mechanism by
which this information may be linked but also the questions of influence and impact. Does Toxic Release
Inventory data collected under Section 313 help emergency planners with interpretation of Section 311/312
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chemical storage data and emergency planning? Conversely does the chemical storage information provide added
value when assessing toxic chemical releases and transfers? Interestingly, these data fall into an array of local,
state and national repositories. Thus, one challenge in this assessment will be to identify channels for linkages
such that public and private access to the information will be improved.
The Project
Linkages can be defined in two ways: access and relationship. First, how does one, especially in the
public sector, readily access EPCRA information in an efficient fashion? And, how might this process be
improved? Second, what is the relationship or link between the data sets: i.e. what does one tell us about the
other and vice versa? Here lies the true potential for a comprehensive right-to-know package.
In order to identify access routes and complete an assessment of relationships and access, NICS has
collected data from two geographic areas. NICS research is focusing on two LEPCs and two SERCs actually
utilizing SARA Tide ffl data We are specifically focusing on industrial communities for this study. EPCRA data
from reporting facilities in the jurisdictions of the Kanawha/Putnam LEPC and West Virginia SERC and the
Cuyahoga County LEPC and Ohio SERC are being compiled for analysis. A dBase program has been written
to link the data and extract reports containing data of interest to LEPCs. The years 1991 and 1992 were targeted
for assessment since these are the most recent available for both Section 311/312 and Section 313 data sets.
Our Hypothesis
Linking the two data sets through common identifiers will allow identification of certain data elements
that will assist LEPCs, SERCs, U.S. EPA and the public in identification of and response to chemical risks. This
linkage of data will allow us to assess the utility of providing new data to these potential users as well as the form
the data should take.
Questions
Through the analysis of the chemical storage and TRI data sets and through meeting with the LEPCs
and SERCs, we are gathering information that addresses several questions that we seek to answer regarding TRI,
chemical storage data and emergency planning. At this stage of the project, we have some preliminary answers
to some of the questions posed in the pilot project. As we continue to analyze the data and consult with LEPCs,
SERCs, federal agencies and the public, we will refine and finalize the project report and recommendations.
1) Does knowledge of chemical storage data improve utilization of TRI?
At the local level, chemical storage data can be paired with TRI to paint a fuller picture of risk to the
public from industrial operations. Linking facility data through common identifiers can assist the public in
interpreting the magnitude of risk posed by chemicals. However, looking at the large amounts of data received
by LEPCs can be a daunting task. If LEPCs or SERCs utilize Tier n software or some other data management
system, the chemical storage data can be sorted in a variety of ways. One way is to identify potential TRI
reporters by chemical storage amounts with TRI thresholds and SIC codes. The LEPC and SERC can then match
the potential filers with the list of faculties that have reported TRI. For instance, in Kanawha County (WV), our
linking program identified 14 facilities currently filing Form Rs and 9 additional faculties within SIC codes 20-39
that filed Tier IIs but not Form Rs. Further inquiry could easily establish the TRI status of these facilities.
Additionally, Tier n data can be used to identify facilities that may need to file Form Rs with the expansion of
the TRI chemical and SIC lists.
Knowledge of the amount of a chemical stored on a site can add perspective to the releases reported by
the facility. Although TRI reporting requires maximum storage codes for each chemical reported, the universe
of TRI chemicals is smaller man those reported under Sections 311/312. Relying solely on TRI can underestimate
potential risk to the community. LEPCs can assist the public in understanding risk and their responsibility in
emergency response by providing the public with summary information about both aspects of hazardous
chemicals in the community.
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2) Does knowledge of Toxic Release Inventory data improve local emergency planning capabilities?
TRI in general provides a range of information useful to emergency response planners. Specific aspects
of the Form R that can assist in emergency response planning for the community include maximum storage
information, offsite transfer data and pollution prevention and source reduction elements. In our analysis of Tier
n and TRI data from the pilot sites, we found several instances in each jurisdiction where storage codes for the
same chemical differed on the two forms. Identifying discrepancies can be an important emergency planning tool.
Contact with the facilities can clarify the discrepancies and initiate an LEPC contact and visit to the facility. We
also found instances where facilities filed Form Rs, but had never filed a Tier n form with the LEPC.
Examination of offsite transfer information from the TRI database can assist LEPCs in beginning or
reassessing hazardous materials transportation emergency plans for the community. The Form R provides total
amounts of TRI chemicals shipped away from covered facilities within the LEPC jurisdiction. The Form also
gives the name and location of the facility to which the chemical is shipped. Assessment of hazards posed by
these shipments may encourage LEPCs to improve planning for hazardous materials incidents on highways,
railways, and rivers.
The pollution prevention data found in Section 8 of the Form R presents an opportunity for better
understanding of the management of hazardous chemicals and their potential hazards. Storage information alone
may not present the entire magnitude of risk, e.g. companies may not store nearly as much as they process via
"just in time" delivery of raw materials. Examination of these data can also give LEPCs a glimpse into future
plans of the facility for handling the hazardous chemical since facilities must project releases and management
into the next two years.
3) Do pollution prevention opportunities also represent emergency response and risk reduction opportunities?
Conversely, do emergency response/planning opportunities also represent pollution prevention opportunities?
Pollution prevention opportunities can and have been identified by examination of TRI data Many state
pollution prevention programs have targeted industry sectors based on reported releases, treatment and transfers
of toxic chemicals. Large releases of chemicals often imply large storage or large processing capacity. In either
case, pollution prevention assistance can be piggybacked with risk reduction elements. Pollution prevention
audits could include local emergency planners and responders so that they could learn more about the process
units and their potential risk.
TRI data can also be used by LEPCs, SERCs and EPA to target and prepare for chemical safety audits.
LEPCs will be receiving large amounts of information when the Risk Management Planning (RMP) rule under
Section 112(r) of the Clean Air Act becomes effective. Even though finalization and implementation are several
years in the future, it is not too soon for LEPCs to begin interacting with those facilities likely to fall under the
requirements of RMP. These include not only the larger traditional facilities like chemical plants that report TRI
but also small businesses that may currently be exempt from many reporting requirements. NICS has also
written a program to identify potential RMP filers. The program marks facilities that report Tier n storage of
RMP chemicals in ranges of pounds that include or exceed RMP thresholds. These facilities can be targeted for
outreach, education and pollution prevention prior to implementation of the RMP. A similar technique can be
used to notify facilities that they may be subject to TRI reporting due to chemical expansion. LEPCs can take
the opportunity to begin to understand the RMPs that will be submitted by learning more about covered facilities
now.
4) What are the problems with access and availability? Is data volume a deterrent?
Although TRI data are available to those with the knowledge and/or equipment to obtain it, many
citizens and LEPCs are lacking in these areas. Through risk communication research conducted at NICS, we
know that availability does not always equal access. The sheer volume of data creates a barrier to access and
understanding. This necessitates some outreach program to improve accessibility for the general public and
LEPCs.
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Both TRI and chemical storage data create problems in interpretation for both assessing risk and
planning for emergency response. Groups involved in outreach activities must take care to provide an intelligible
interpretation of the often complicated rules that govern reporting under these sections of EPCRA.
5) Would summaries expedite utilization of both data sets?
NICS believes that specifically crafted summaries can improve access and utility of both chemical storage
and chemical release data. The NICS' West Virginia Scorecard O was developed prior to the implementation
of Superfiind Amendments and Reaumorization Act (SARA) Title in in response to citizen need for information
about hazardous and toxic chemicals in their neighborhoods. With the passage of EPCRA, it became possible
to fairly assess the progress in reducing releases of these chemicals. While a few large environmental
organizations are interested in and peruse national TRI statistics, most US citizens identify with and more
actively engage local data. Scorecard O has been organized to meet the needs of local communities in West
Virginia
A selective summary of selective TRI data elements linked with critical elements of Tier n data could
provide a succinct tool for LEPCs to improve emergency planning. LEPCs have little need for release data, per
se, in emergency planning activities. They have even less time to deal with information of little use to their
primary responsibility. Summaries provided to LEPCs that distill bom TRI and Tier n data to strictly those items
that directly affect emergency planning could improve the breadth and increase the effectiveness of local planning
efforts.
§ummqry
NICS believes there is inherent value in Unking EPCRA Section 311/312 and 313 information for a
variety of users. While Congress created separate reporting mechanisms, and thus disjunct sources of
information, we are working to compare and contrast this information for possible values to local, state and
federal programs. The important tasks and challenges of LEPCs cannot be overlooked, but by selectively
providing linked Tier n and TRI data to these LEPCs, and to state and federal agencies on a pilot project basis,
NICS is assessing the advantages and disadvantages of mis approach. LEPCs and program managers at the state
and federal level could benefit enormously from the increased depth and breadth of comprehensive information.
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Session 2: Crossmedia Use: TRI Partnerships Within Agencies
Session Leader
Dick Murdock, Pollution Prevention Unit, New York State, Department of Environmental Conservation
Speakers
Robert A. Boisselle, Branch Chief, Information Group, Division of Air Quality Control, Massachusetts
Department of Environmental Protection
Joseph E. Kowalczyk, Multimedia Enforcement Council, New York State Department of Environmental
Conservation
Paul Orum, Coordinator, Working Group on Community Right-to-Know
Wesley Taylor, Waste Management Information Specialist, Wisconsin Department of Natural Resources
Dick Murdock, Pollution Prevention Unit, New York State, Department of Environmental Conservation
The experience of three states provided the basis for a discussion on the broad range of uses of TRI
within agencies. Wes Taylor and Tom Nowakowski of the State of Wisconsin Department of Natural Resources
(DNR) highlighted the Southeast Wisconsin Toxics Reduction Project, a pilot cooperative effort among the
Wisconsin DNR regulatory programs, the University of Wisconsin - Extension Solid and Hazardous Wastes
Education Center (SHWEC) and private industries. The Project focused on 10 facilities and the development
of a good description of possible pollution prevention tools for each, based upon existing data from regulatory
programs that had been integrated into a common format. The project combined education and environmental
regulations into an effective method of providing tools for industries to apply pollution prevention strategies to
minimize waste and decrease environmental impacts.
Robert Boisselle, of the Massachusetts Department of Environmental Protection, then highlighted the
problems encountered when comparing TRI data with AIRS data. There were significant differences
demonstrated, often due to different individuals completing forms, misinterpretation of instruction, or timing
in filling out forms. There were instances given where the data were widely disbursed for the same facility. Mr.
Boisdle clearly outlined the need for a more uniform collection approach if data from different systems are to be
compared.
Next, Paul Orum, of the Working Group on Community Right to Know discussed effective management
of information resources across different media As a member of the Environmental Information and Assessment
subcommittee of the National Advisory Council for Environmental Policy and Technology, Mr. Orum gave
suggestions for better design and flow of information resources. Significant barriers to progress in this area were
identified (including parochial programmatic structures) and recommendations for bridging the barriers through
organizational culture changes were offered.
Finally, Joe Kowalczyk, an Enforcement Attorney for the New York State Department of Environmental
Conservation, provided insight into NYS efforts at multimedia enforcement efforts including using TRI data as
a resource for baseline information. The topic included the departments approach towards multimedia
enforcement, identified the need for local and state involvement, and the need for complete up-to-date information
when looking at a facility's progress towards compliance.
D
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Robert A. Boisselle, Branch Chief, Information Group, Division of Air Quality Control, Massachusetts
Department of Environmental Protection
Comparing TRI Data With AIRS Data Within SIC Codes
Introduction
The Superfund Amendments and Reauthorization Act (SARA), Public Law 99-499 has required various
industries to supply information on the releases to the environment including air since the calendar year 1987.
The submission of EPA Form R, the Toxic Chemical Release Inventory (TRI) reporting form, assist in this
requirement of section 313 of the Emergency Planning and Community Right-to-Know. These reports are
required to provide the public with information on the releases of listed toxic chemicals in their communities and
to provide EPA with release information to assist the Agency in determining the need for future regulations.
Massachusetts Air Quality Section in 1994 embarked upon the task of reviewing databases for toxic
chemicals in Massachusetts. During this exercise a question was asked about the amount of toxic chemicals at
a facility in one database versus the amount in a second database which should contain the same information.
It was necessary to answer several questions in addressing this task:
What type of facilities are in the databases?
What pollutants are included?
• What databases exist that contain similar and recent information?
• What are the acceptable means of receiving the data into the databases?
• What coding method is used to identify processes within a facility using the toxic chemical ?
The Massachusetts Air Quality Section decided to review the Toxic Release Inventory (TRI), required
annually by SARA 313, and the Aerometric Information Retrieval System (AIRS>Air Facility System (AFS),
required to be updated annually by the Clean Air Act (CAA).
Inventory Overview
Toxic Release Inventory (TRI)
The TRI was mandated by Section 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA), also known as Tide HI of the Superfund Amendments and Reauthorization Act of 1986, signed in
October of that year. The Pollution Prevention Act, passed into law in October, 1990, added additional reporting
requirements to Form R. This law has two main purposes: 1) to encourage community/facility planning for
response to accidental chemical releases; and 2) to provide government agencies and the public with information
about possible chemical hazard exposure in their community. The law requires the collection of specific
information about the use of chemicals by industrial manufacturing facilities and the release of those chemicals
to the environment.
Section 313 of EPCRA requires manufacturing facilities with 10 or more employees and having a
primary Standard Industrial Classification (SIC) code between 20 and 39 to file an annual report. The facility
must manufacture or process more than 25,000 pounds or otherwise use more than 10,000 pounds of any listed
toxic chemical during a calendar year.
TRI contains information such as name, location, type of business, contact names, name of parent
company, environmental permit numbers, information about the manufacture, processing, and use of the listed
chemical and the maximum amount on site during the year, releases and transfer estimates. For this review, only
air emissions (Form R, Section 5.2) were evaluated. Air emissions estimates for stack/point releases are made
through engineering estimates, mass balance calculations using purchase records, inventories, engineering
knowledge or process specifications.
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Aerometric Information Retrieval System (AIRS)
Congress passed the Clean Air Act (CAA) of 1970 and for the first time air quality standards were set
for the country. By the mid 1970s it became apparent that not all air quality standards would be attained. Many
states remained out of compliance and air quality in some regions deteriorated. In 1977, Congress amended the
Act. While basic programs were retained, sources in nonattainment areas were stringently regulated and
requirements were put into place to prevent the deterioration of air quality in attainment areas.
Many inventory programs were established to track the regulated sources and quality of air. These
programs lack sufficient funding and at times the data deteriorated. By the late 1980s, these inventory programs
were done away with and AIRS was created. The Aerometric Information Retrieval System (AIRS) was
developed to replace five (5) existing federal EPA systems. The submission of information to AIRS, which
includes air quality, emissions, enforcement and related data, is required by the state and local Air Quality
agencies under the Clean Air Act. The AIRS Facility System (AFS) is contain within the AIRS and this
program is the warehouse of information about the facility. The AIRS-AFS contains a great deal of information,
such as name, location, contact names, telephone numbers, environmental permit numbers, type of business,
enforcement actions, emissions, combustion information, underground storage tanks, and process information,
which contains throughputs, seasonal activity, chemical quantity and emission control equipment.
The 1977 Amendments were no more successful in attaining the goals of the Clean Air Act It was not
until October, 1990, however that a second set of amendments emerged from Congress and was signed into law
on November IS, 1990 by then-President George Bush. Although the 1990 Amendments do not alter the basic
regulatory structure of the Clean Air Act, they dramatically increase the number and types of businesses subject
to its regulatory requirements.
Tide I of the CAA covers emission reduction programs for volatile organic compounds (VOC) to meet
ambient air quality standards. Chemicals (VOCs) that participate in the atmospheric photochemical reactions
to produce ozone are coded into AIRS. Title H, section 112(b) of the CAA, lists hazardous air pollutants
(specifically 189 hazardous air pollutants (HAPs). These pollutants are expected to be coded into AIRS at a later
date.
Data Evaluation
The TRI and AIRS databases were evaluated by comparing the following criteria:
1. Pollutants
2. Type of facilities reporting
3. Reportable quantities
4. Estimation methods
5. Emission points
I. Pollutants
Toluene and acetone were selected as the pollutants for evaluation from the databases. These chemicals
are coded in both databases. Toluene and acetone have many uses in the manufacturing of organic chemicals and
as a solvent in paints, gums, resins, adhesives and printing inks. Reaction of these chemicals in the atmosphere
contribute to the formation of ozone in the lower atmosphere.
2. Type of Facility
AIRS evaluates information from all facilities subject to the Clean Air Act which are regulated under
state programs and file reports annually. The TRI requires manufacturing facilities with ten (10) or more
employees and having a primary Standard Industrial Classification (SIC) code between 20 and 39 to file annual
reports
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3. Reportdble Quantities
TRI requires only those facilities which manufacture or process more than 25,000 pounds or otherwise
use more than 10,000 pounds of any listed toxic chemical during a year to file an annual report. AIRS has no
cutoff limit on reportability but this may vary from state to state depending on attainment status.
4. Estimation Methods
TRI and AIRS suggest that monitoring data, engineering estimates, and mass balance calculations may
be used to determine stack/point air emissions. AIRS has default calculations using emission factors that have
been generated through research. These factors have been assigned to a Standard Classification Code (SCC)
system. This coding mechanism will identify the Industry category, source category within the industry and a
particular process within the category.
Example: Chemical Manufacturing 3-01
Explosives -010
Fume Recovery -11
SCC # = 3-01-010-11
5. Emission Points
Both AIRS and TRI agree that all emissions come from any stack, venting or ducting mechanism. TRI
considers the air emission to be coming from a particular stack/vent when it is reported on Form R for a chemical.
AIRS can identify each process line with air emissions coming from it and bubbling that number to the facility
level. This identification is done through the SCC system.
Summary of AIRS/TRI Evaluation
A number of facilities were identified to contain acetone or toluene in their 1990 inventory. One facility
(021641CPCR156OA) indicated 20,000 pounds of acetone being emitted into the air. The AIRS facility
(1190424) indicated 20,000 pounds of acetone being emitted from three (3) paper coating operations (40200902)
using the acetone as a solvent thinner in the printing section of the process. The retrieval of other facilities (20)
showed similar correlation but there were a large number (15) that the difference between reported air emission
in TRI and AIRS varied from 1,000 pounds to 156,000 pounds for specific chemicals.
A facility (01220WRGRCCHARWO) in TRI indicated 100,000 pounds of toluene being emitted into
the air and the AIRS (1170078) facility indicated 124,000 pounds of toluene being emitted from a coating
operation. Another facility (02106THGLLGILLE) in TRI listed 126,000 pounds of a chemical being emitted but
the AIRS (1190033) database indicated only 26,000 pounds being released into the air. Upon closer review of
the AIRS data, I found the source was emitting 126,000 pounds before being controlled by an activated carbon
adsorption unit with 80% efficiency on the air stream resulting in 26,000 Ibs of the chemical being emitted. The
use of control equipment in the air process stream seems to play a major difference in the air emission
concentration but there were some facilities that AIRS had higher emissions than TRI. Upon reviewing the data,
it seems that different people are filling out the forms, which could lead to possible errors in the interpretation
of data into the forms. It was also noticed that chemicals in AIRS are being incorporated into "Miscellaneous
VOC categories" which made it difficult to track a specific chemical in the facility.
Conclusion
Comparison of the AIRS and TRI database revealed a number of differences. The problem of combining
chemicals has to be addressed by the AIRS user community so that specific chemicals are identified in the
process stream. The control equipment in a facility has to be addressed by the TRI user community to give credit
to the facility for the installation of the equipment and the reduction of emissions. The user community for both
systems may need additional guidance to confirm emission numbers. The facilities selected were accounted for
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in both databases with the chemicals but quantities varied in amounts. Facilities were identified with correct
chemical amounts and it was possible to show how the chemical was being used in the facility.
These databases are only a starting point for industrial interaction for all concerned. TRI and AIRS
should be looked at as a tool for learning about the contents of a facility. But there is a need for continuous
improvement in coding information and streamline the reporting process.
References
U.S. Environmental Protection Agency, "1992 Toxics Release Inventory," EPA 745-F-94-001, Office of
Pollution Prevention and Toxics, Washington, D.C., April 1994.
U.S. Environmental Protection Agency, "1992 Toxics Release Inventory-Public Access Release," EPA 745-R-
94-001, Office of Pollution Prevention and Toxics, Washington, D.C., April 1994.
U.S. Environmental Protection Agency, "Toxic Chemical Release Inventory Reporting Form R-Revised 1992",
EPA 745-K-83-001, Office of Pollution Prevention and Toxics, Washington, D.C., August, 1993.
U.S. Environmental Protection Agency, "1987-1992 Toxic Release Inventory-CD Rom," EPA 749/C-94-001,
Office of Pollution Prevention and Toxics, Washington, D.C., August 1994.
U.S. Environmental Protection Agency," AIRS-AFS On-Line Computer System," OAQPS, Research Triangle
Park, North Carolina
Joseph £. Kowalcxyk, Multimedia Enforcement Council, New York State Department of Environmental
Conservation
Using TRI and Other Department Data For Environmental Enforcement
Introduction
It is the policy of the State of New York to conserve, improve and protect its natural resources and
control pollution and the responsibility of the Department to promote and coordinate management of natural
resources, taking into account the cumulative impact upon all resources when making enforcement
determinations. This comprehensive approach to enforcement is designed to advance the State's policy to
enhance the health, safety and welfare of the people of the State by protecting its natural resources and the
environment and controlling pollution. The enforcement process generally, and multimedia enforcement
specifically, is utilized so that the State's policy and the Department's objectives and responsibilities are carried
out to the fullest extent possible.
The primary goals of multimedia enforcement are to ensure full compliance at all facilities and advance
pollution prevention and risk reduction at facilities that have the potential to significantly impact public health
and the environment It also addresses cross-media transfers of pollutants and significant compliance problems
due to inadequate environmental management systems.
Multimedia enforcement not only enhances the Department's ability to produce significant orders but
provides facilities with the flexibility and certainty needed for both long-term planning and successful operation.
Prosecution of violations in multiple programs increases the likelihood that orders fully address the universe of
violations, as well as significant public health and environmental issues at certain facilities. Multimedia orders
also include integrated compliance schedules addressing appropriate sanctions and/or remedies. Significant
multimedia enforcement orders should also produce significant publicity within the regulated community and
a corresponding increase in deterrence.
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Background
Successful implementation of multimedia enforcement is essential for the Department to carry out its
responsibilities more effectively. Consequently, the Department has increasingly modified its approach to
enforcement by supplementing its traditional single-medium method and continuing to build a multimedia
perspective into its enforcement effort. The Department has brought a multimedia enforcement perspective to
all appropriate facets of its enforcement process, from priority setting and inspection planning to case screening,
prosecution and settlement.
Over the past several years, the Department has increasingly developed a more comprehensive,
integrated approach to facility management and environmental protection. Organization and Delegation
Memorandum #92-13 Policy: Pollution Reduction and Integrated Facility Management ("O&D Memo #92-13")
calls for a coordinated development of regulatory programs to ensure that the regulations of the environmental
quality programs are integrated to form a more coherent framework. Moreover, O&D Memo #92-13 further
directs implementation of integrated facility enforcement, or in other words, multimedia enforcement. O&D
memo #92-13 also acknowledges that it is the law of the State of New York and the policy of the Department
to reduce the generation and release of hazardous substances to all environmental media.
Multimedia enforcement is the latest component of the Department's strategy to ensure that the
enforcement program: (1) is implemented consistently across the State; (2) produces clear environmental gains;
(3) punishes violators and deters future violations; (4) prevents egregious violators from operating in New York
State; (5) ensures that environmental harm is remediated; and (6) creates a level playing field for companies that
operate lawfully. Specifically, multimedia enforcement will be utilized to advance the State's environmental
policy by: i) detecting violations and requiring their correction; and ii) deterring violations.
Multimedia enforcement actions normally include: 1) enforcement actions involving more than one
program or one medium; 2) enforcement actions rising out of multimedia inspections; 3) enforcement actions
which result in compliance activities (such as pollution prevention programs) that impact other media; and 4)
enforcement actions which include progressive sanctions and remedies such as those discussed under "case
resolution" below.
Implementation
Case Selection
Successful implementation of multimedia enforcement must effectively combine common sense,
innovation and flexibility. Multi-program cases addressing all of a facility's outstanding violations will generally
be utilized except when other strategies will more effectively advance the Department's objectives. Generally,
the decision as to whether the Department's goals can best be accomplished through single program or
multimedia enforcement activity will be made on a case-by-case basis, pursuant to regional docketing and
screening procedures approved by the Commissioner. The docketing process includes a system for identifying
violations in more than one program and for weighing the merits of consolidating cases into multi-program cases
before a decision is made to pursue administrative or judicial enforcement in a single program. Identifying and
pursuing multimedia enforcement requires effective case screening which integrates staff from different programs.
Case screening is a component of docketing designed to evaluate potential cases for "strategic value" (extent to
which the case, when resolved, reduces risk, protects the environment, prevents pollution or enhances deterrence)
and to decide upon the most appropriate response.
The following factors are considered in determining when to utilize the multimedia approach to
enforcement:
• Environmental and Public Health Issues: Facilities with the potential to impact natural resources,
including but not limited to, particularly sensitive or important resources such as sole source aquifers and
wetlands, or densely populated residential communities, should be subject to thorough multi-program review.
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Multimedia enforcement is also well-suited to implementing pollutant-specific, geographic, or other risk-based
targeting strategies.
• Appropriateness of progressive sanctions, remedies and compliance tools: The desirability and/or
potential for committing facilities to certain progressive sanctions, remedies and compliance tools often indicates
that multimedia enforcement is appropriate.
• Significant foxic jpqdjpg' Integrated facility management (including enforcement) is primarily utilized
to regulate the State's largest polluters. Many significant contributors of toxics to New York State Environment
can be identified by reviewing Toxic Release Inventory information submitted pursuant to SARA Title HI and
Hazardous waste generation data submitted pursuant to Article 27 of the ECL.
• Compliance history: Potential facilities are subject to a comprehensive review regarding compliance
history, including electronic databases such as the Environmental Enforcement Data System (BEDS). A poor
record of compliance regarding a company or facility is often indicative of more significant problems than those
identified and suggests that coordinated enforcement activity is appropriate.
• Multimedia impacts of proposed order conditions: Violations may involve only one program, but the
sanctions and remedies may trigger cross-media transfers or impact other media Inter-program coordination is
essential in such circumstances.
• Selection of the best statutory authority: Some environmental problems, such as groundwater
contamination, may be best addressed by using statutory provisions other than those available within the
program which identified a violation or problem;
• Opportunity to increase deterrence: High profile cases present the potential for widely influencing the
regulated community and deterring future violations. Deterrence is particularly important when addressing
violations that are difficult for the Department to detect;
• Access: Multimedia inspections are encouraged when performing investigations under administrative
search warrants; and
• Multimedia. Inspections- Facilities such as those which present either significant risk or the potential
for violations in multiple programs, or result in significant releases of pollutants or significant generation of
hazardous waste, are selected for planned multimedia inspections.
Case Resolution
Administrative orders are effective in advancing the Department's policy to encourage pollution
prevention and risk reduction when actionable violations exist Traditional enforcement orders are principally
aimed at gaining compliance and deterring and punishing violators. In addition to the foregoing, multimedia
orders will continue to be used to advance important Department objectives. Specifically, multimedia enforcement
has been utilized to achieve results including i) significant operational improvements resulting in compliance
with all applicable environmental laws; ii) pollution prevention or risk reduction measures; and iii) equitable
penalties. Consequently, all multimedia enforcement orders in significant actions include integrated compliance
schedules and pollution prevention and/or risk reduction programs as appropriate.
The Department has also successfully used the enforcement process to advance the following preferred
environmental management hierarchy: 1) source reduction; 2) reuse/recycling; 3) treatment; and 4) disposal or
release. Reasonable and appropriate pollution prevention conditions are generally appropriate and should be
included in administrative orders where (1) elimination or substitution of chemicals may end recurring violations
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or reduce the potential for adverse impacts; (2) there would be no unacceptable cross-media impacts; and (3)
there are known technically feasible and economically practicable pollution prevention options available.
The Department will continue to take swift and appropriate action against violators, as well as
demonstrate that environmental protection and economic success are complementary objectives. The Department
will continue to use the enforcement process to address underlying problems leading to poor compliance records
and to commit respondents to improving operations resulting in environmental compliance through the use of
progressive sanctions, remedies and compliance tools. Examples of such progressive sanctions and remedies
include independent environmental audits, risk management programs, accident prevention/response plans,
comprehensive best management practices, toxic chemical reduction plans, fugitive emissions reduction plans,
energy audits, community awareness programs or other pollution prevention or risk reduction measures. In
appropriate circumstances, independent audits are used to evaluate compliance, environmental management
effectiveness, toxic loading and pollution prevention options.
The Department's Civil Penalty Policy provides that adjustments to the gravity portion of penalties will
provide the flexibility and equity needed in the Department's penalty system. Specific factors that are identified
for penalty adjustments include culpability, violator cooperation, history of non-compliance, ability to pay, and
other "unique factors." It is the Department's policy to strongly encourage the use of progressive sanctions and
remedies which advance the State's environmental policy. Therefore, such sanctions and remedies may be viewed
as unique factors and examples of violator cooperation and staff is expressly authorized to exercise its discretion
to adjust the gravity portion of penalties downward. The Department will continue to ensure that any economic
benefit that violators gain is addressed and that resolution of enforcement actions sufficiently deters both the
respondent at issue and the larger regulated community from committing future violations.
In conclusion, effective multimedia enforcement enhances the Department's ability to induce violators
to operate in compliance with environmental requirements and commit to pollution prevention and risk reduction.
The resulting improvement in the operation of facilities will maximize both competitiveness and environmental
benefits. Consequently, multimedia enforcement actions will often demonstrate that environmental protection
and economic competitiveness are compatible.
D
Paul Orum, Coordinator, Working Group on Community Right-to-Know
Information Resources Management: Building on the Lessons of TRI
Introduction
The Toxics Release Inventory (TRI) has taught us an important "lesson" for improving information
resources management (TRM): organizing dispersed information around natural data integration points makes
it much more accessible.
The Environmental Protection Agency (EPA) is beginning a project to organize data around one such
natural data integration point: facility identification. Under the project, facilities will report basic identifying
information (such as name, address, and location) just once to the agency across all programs. The initiative
takes a successful "lesson" of TRI and writes it large across all EPA programs.
The "Lessons" of TRT
TRI is what I call the first "prevention era" environmental law. TRI established the first on-line, publicly
accessible data base of environmental information required under Federal law. Consequently, the data are
"designed for data management." TRI data are:
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facility specific;
chemical specific;
• multimedia; and
• publicly accessible.
In other words, the TRI data are organized around several natural data integration points, or "key data
identifiers." This design has resulted in basically successful management and dissemination of information.
The data are of course subject to limitations. The TRI:
• doesn't measure source reduction;
• doesn't address chemicals in products (for life cycle assessment);
• doesn't include opportunities to participate in decisions to reduce risks; and
• is less direct than options such as labelling (active dissemination frequently requires interpreters such
as advocacy groups or reporters).
But, there is a basic level of success in the TRI program, based on its design (for data management). This is the
most overlooked "lesson" of TRI.
By comparison, the Clean Air Acts chemical accident prevention provisions (§112(r)) will require over
100,000 facilities to publicly disclose their worst-case chemical accident scenarios as part of a broad accident
prevention program. Such disclosure may have an impact comparable to TRI. But, data collection plans may
not include:
computerization of registrations;
• Dun & Bradstreet number (to link facilities across organizations);
• permit numbers from other programs (for pollution prevention); and
• common order and units of measure.
• But probably will include latitude and longitude (if s EPA policy).
Key Data Identifiers
Dispersed data sources are functionally inaccessible. By organizing information around key data
identifiers, one makes it accessible (at least to those with the resources and knowledge to use it).
During 1994, a Task Force established under the National Advisory Council for Environmental Policy
and Technology's Environmental Information and Assessment Committee was formed by EPA to provide
recommendations on the agency's IRM strategic plan. (This was not the full committee as indicated in the
conference brochure, rather it was a Task Force during 1994.)
The Task Force's report, Using Information Strategically to Protect Human Health and the
Environment, makes recommendations for information management, partnerships, infrastructure, and
organization. Its overall message is that EPA must change its information resources management or fail in
transition from single media programs to a cross media, comprehensive focus.
The report explains that EPA's existing infrastructure was designed to support a series of "stovepipe,"
specific-media programs and not to exchange or link information across programs.
"[F]or example, EPA's information does not allow EPA to combine data on ecosystems, industrial
sectors, chemicals, and facilities across programs." (page 5)
Further, current data systems were not designed to serve secondary users (other program offices and agencies,
states researchers, the general public, industry, and others).
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The Task Force recommended using "key data identifiers" to link information a across EPA programs,
and lists six (on page 8):
facilities/sites (a facility ID);
spatial coordinates (latitude and longitude);
regulated substances;
industrial sectors (Standard Industrial Codes, SIC);
chemicals (CAS number and name); and
organizations (Dun and Bradstreet).
The Task Force urged EPA to develop integration policies and tools that would organize information around
these natural data integration points to create what I would call a modern map of environmental information.
EPA's Information Integration Initiative
The U.S. EPA has dedicated $1 million in fiscal 1995 (and an additional amount the following year) to
a systems redesign initiative for facility ID (among other reforms). The initiative will allow facilities to report
basic identification information just once (just as people don't put their entire address on each tax schedule
attached to their 1040 form). The project starts with a new regulation that will consolidate all facility reporting
under one central authority. This will go through a proposed and final rule in the Federal Register.
This is an important initiative that has mutual benefits for all stakeholders:
the public gets better access to information and government;
industry gets reduced reporting burden through consolidated reporting and electronic reporting methods;
and
regulators get a more effective mission.
To succeed, the project must be designed with secondary users in mind. Of course, success will make
apparent a more fundamental problem: currently collected data do not add up to a cohesive whole. And, there
is no natural constituency or specific mandate for the initiative. So it will need support to be realized.
References
Using Information Strategically to Protect Human Health and the Environment [EPA 270-K-94-002], August
1994, is available through EPA's Public Information Center at (202) 260-2080 or the Agency's Morris Altschuler
at (202) 260-9752 (no cost).
D
Wesley Taylor, Waste Management Information Specialist, Wisconsin Department of Natural Resources
Tom Nowakowski,y4i> Manqgemgnf Specialist, Wisconsin Department of Natural Resources
Developing Pollution Prevention Tools from Wisconsin's Integrated Toxics Data System
Southeast Wisconsin Toxics Reduction Project: A PPIS Grant
More than twenty years of pollution control regulations in all environmental media have shown that
while these traditional measures have made a significant impact, continued progress in protecting and preserving
the environment will require apreventative approach. The southeast region of Wisconsin maintains a significant
manufacturing base and is currently designated non-attainment for the ozone standard under the reauthorized
Clean Air Act and subject to numerous air and water toxics regulations. The Southeast Wisconsin Toxics
Reduction Project (The Project), a pilot cooperative effort among the Wisconsin Department of Natural
Resources' (DNR) regulatory programs, the University of Wisconsin - Extension Solid and Hazardous Wastes
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Education Center (SHWEC) and private industries, developed tools and strategies which will result in positive
impacts on the environment and promote inter-agency and inter-industry working relationships.
A significant portion of The Project was dependent upon selecting ten facilities, representing a portion
of southeast Wisconsin's industrial base, with significant cross-media environmental impacts from their waste
streams. Selected facilities were evaluated from a whole facility regulatory perspective. In order to complete a
whole facility description, data from individual regulatory programs were integrated into one common format.
These facility descriptions were used in conjunction with on-site pollution prevention assessments completed
by SHWEC to identify site-specific pollution prevention opportunities.
Data gaps (either missing or incorrect information) were the most common impediment to creating an
accurate facility description and suggesting specific pollution prevention activities. In all cases, these gaps were
addressed to complete the most comprehensive facility description possible and yield the most appropriate
pollution prevention strategies.
All ten participating facilities were generous with their time and comments regarding this pilot project.
A major emphasis of The Project was placed on providing individual facilities with tools to assess the costs of
creating and disposing of waste products and evaluating potential pollution prevention strategies. As a follow-up
to this project, a return visit to the participating facilities in the future would provide valuable information needed
to evaluate the effectiveness of the tools and suggest pollution prevention strategies developed over the course
of The Project.
Setting
The Project targets the southeast region of Wisconsin and includes industrial facilities in the following
counties: Milwaukee, Waukesha, Racine, Kenosha, Walworth, Sheboygan and Manitowoc. This region
maintains a manufacturing base of approximately 2,200 facilities covering a wide spectrum of industrial
categories. In addition to the current ozone non-attainment designation under the reauthorized Clean Air Act,
industries within this region are subject to numerous environmental requirements including new air and water
rules for the control of toxic pollutants. Further, the State of Wisconsin must certify that it has the capacity to
accommodate all the hazardous wastes generated over the next twenty years. Most regulations have focused on
treatment and disposal, but now strategies for developing a more sensible approach, assessing costs associated
with waste treatment and disposal and preventing or limiting waste generation, are being evaluated - shifting
the focus of environmental protection strategies from treatment to prevention.
Pollution prevention information and education efforts, by themselves, often have limited effectiveness
in changing behavior. The Project combines strengths of education and environmental regulations to encourage
industries to consider tools and strategies which can be used to identify unnecessary wastes, avoid cross media
shifts of pollutants and decrease environmental impacts.
Scope of Study
Ten facilities were used to represent a portion of the industrial base in southeast Wisconsin. Private
sector participation was voluntary. Using the State of Wisconsin's Integrated Toxics Reporting System (TTRS)
system, we selected potential facility candidates. A initial list of fifty-two candidates was screened from
approximately 2,200 industrial facilities in southeast Wisconsin. After eliminating ineligible facilities, we
separated this list into three categories: high, medium and low priority using SHWEC's Pollution Prevention
Protocol. The eleven high priority and fourteen medium priority facilities were our initial targets during our
outreach. Selected facilities were evaluated from a whole facility regulatory perspective. Regulatory documents
from all major regulatory programs were examined and condensed to develop a whole facility "picture". A
review of the facility's individual waste streams was completed in conjunction with representative raw materials
formulate waste cost estimates to enhance the whole facility picture. In addition, on-site pollution prevention
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assessments were conducted by SHWEC to provide participating facilities with useful suggestions pertaining
to specific pollution prevention opportunities observed at each facility.
The DNR's ITRS is an independent stand-alone database comprised of data extracted from six DNR
environmental program master databases. The ITRS combines selected data fields by facility from the Master
Facility File, the Air Emissions Inventory file for air toxins, the Waste Water DMRS file for chemical pollutants,
the Hazardous Waste Annual Report which lists the annual quantity of RCRA wastes generated, the Hazardous
Waste Manifests, and the Toxic Release Inventory. The ITRS is an invaluable tool as it offers the side by side,
multi-media display of a given facility's environmental releases off-site transfers of toxic chemicals and wastes.
Conclusion
The Wisconsin Department of Natural Resources plans to continue to use and refine the tools developed
during The Project The whole facility description template developed as part of this project will be a useful tool
to identify potential cross-program overlaps to all environmental media permitting staff. The voluntary aspect
of The Project and the one-on-one contacts with individual facilities provided a good opportunity to develop
individualized pollution prevention strategies and fostered a personalized working relationship with project
participants. As a separate project, SHWEC will be following up with site visits to each facility to measure the
effectiveness of the pollution prevention information provided. We hope that making the tools we developed
available will have a positive impact on the environment by promoting integration of pollution prevention
concepts and strategies and existing pollutant databases.
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Session 3: Industry-Community Relationships
Session Leader
Hank Topper, US EPA
Speakers
Harold N. Hicks, Jr, Plant Manager, Ashland Chemical Company
PaulL. Hill, Ph.D, President, National Institute for Chemical Studies, Charleston, WV
Sanford Lewis, Director, The Good Neighbor Project for Sustainable Industries, and
Instructor in Environmental Law at Tufts University, Department of Urban and Environmental Policy
Phillip Muessig, Community Assistance Coordinator, Minnesota Office of Environmental Assistance (OEA)
Ellie Skokas^ Assistant to Chair, Department of Biological Sciences, Wichita State University and Member
Community Involvement Group, Vulcan Chemical Co.
Hank Topper, US EPA
Local communities are more and more becoming a focus for the use of TRI information. Given limited
national and state resources, the ability of local communities to turn TRI data into effective plans for action will,
to a large extent, determine the success of the TRI program as a tool for promoting pollution prevention and risk
management.
This is a time of learning and experimentation for community use of TRI data The relationships that
are developing between industry and their surrounding communities are at the center of this activity. Hundreds
of communities have now established some form for regular dialogue between industry and the community. How
these relationships develop will be key to progress in turning TRI into a tool for pollution prevention and risk
reduction at the local level. The presentations of the panelists, based on their own direct experiences, provided
the following important insights for building effective community/industry relations:
• Assistance to help communities turn TRI data into understandable information is needed. Programs
such as the annual "Scorecard" produced by the National Institute for Chemical Studies, the Minnesota
State program providing technical assistance to communities, and the programs using retired engineers
as technical resources for communities provide an essential ingredient in the use of TRI data
Communities need to continue to find new ways to draw on all available resources to interpret and use
TRI information.
• Forums for regular dialogue between industry and communities, such as the Community Advisory
Panels organized by the Chemical Manufacturers Association, can be effective. Inclusion of participants
in discussions about facility policy in the early stages before decisions are made and access to
independent expertise for participants in technical discussions are essential. The uneven effectiveness
of existing groups argues for more interaction between groups and for more widespread use of outside
resources to assist groups to develop effective programs.
• Pre-dialogue agreements with companies on the provision of resources for independent technical
expertise, on selection of participants, and on methods for setting agenda for discussions are key to
successful dialogues.
Special attention (training/coaching) paid to helping both industry and community representatives learn
how to communicate with each other can be essential. Both sides in these dialogues have preconceived
notions that can be barriers to effective communication.
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• Industry openness in discussing all issues affecting the community is key to success of dialogue. Open
discussion of worst case scenarios as required by the Clean Air Act, development and discussion of a
third party risk assessment on facility releases, inclusion of community in development and review of
pollution prevention planning, and developing forums for considering impacts of all facilities in an area
are opportunities for developing meaningful dialogue.
Harold N. Hicks, Jr, Plant Manager, Ashland Chemical
Building TRI and Pollution Prevention Partnerships
It's a pleasure to have this opportunity to review some of the ongoing industry/community partnerships
in the Tri-State area of Kentucky, Ohio and West Virginia My employer, the Ashland Chemical Company,
strongly encourages facility managers to be involved in our respective communities. Ashland also is an
enthusiastic supporter of the Chemical Manufacturer's Association Responsible Care1 initiative. Today I am
going to focus on our involvement with the Local Emergency Planning Committee and a Community Advisory
Panel - jointly sponsored by Ashland and Aristech.
Background
Historically a major center for refining and primary metals, the Tri-State area has suffered major
economic decline due to the loss of industrial jobs. Many industries have closed their doors and others have
undergone major force reductions. The population of West Virginia declined 10% between 1980 and 1990 and
this same population and job decline is also characteristic of Southern Ohio and Eastern Kentucky. The
population is aging as young adults are forced to leave the area to find work.
The area is now an attainment area for all priority pollutants except ozone which is moving through
redesignation actions in West Virginia and Kentucky. The redesignation, when My implemented, will put the
area in an attainment status for ozone as well.
Environmental concern is focused on air quality issues. There are several large quantity dischargers with
NPDES permits and several Superiund sites but because of good compliance history and/or low risks, water and
solid waste issues don't get much attention in the print or broadcast media
Community Advisory Panel
Aristech Chemical and Ashland Chemical organized a Community Advisory Panel or CAP early in
1992. Ann Green, who now facilitates 21 CAPS across the Eastern United States, worked with the two plant
managers to develop a list of candidates and Mowed up with recruiting. The CAP started with 15 members and
attendance at bimonthly meetings is typically 12-15. The two small plants have excellent safety and
environmental compliance histories. SARA 313 emissions are down more than 90% from the 1987 base year.
The CAP members live close to the plants except for a couple of emergency responders who live about five miles
away. CAP members have been interested in learning about safety, emissions and noise but none have expressed
great concern regarding the two specific plants.
CAP members have been on a couple of plant tours and each plant has held an open house since the
CAP was formed Plant Managers share SARA 313 data in July for the previous year - the first public release.
Clearly were the CAP activities limited to tours and reviews, the members would lose interest and for
that reason we have worked to identify CAP projects which would involve hands on activities. As of today, the
Neal CAP has two important projects in progress with a third in the formative stages.
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In the Spring of 1993, the CAP published a newsletter which was mailed to all households in the Kenova
VFD District along with a VFD Newsletter and an emergency information questionnaire. The questionnaire
included a diagram of a house and asked for the location of:
• Natural gas cut off valve
• Water cut off valve
Incoming electrical switch box
• Likely location of invalids, if any, in the house
The mailing included a stamped return envelope which was to provide a means for returning the marked
up diagram to the VFD. Response to the first mailing was about 15%. Obviously this needs to be repeated with
some new wrinkle.
In the Fall of 1993, the CAP discussed the need for E-911 in Wayne County with County
Commissioners eventually leading to a commitment from the commissioners to proceed with public meetings
and a commitment from the CAP to assist in getting a representative sample of public opinion. Postal patron
mailings to the 15,000 Wayne County households provided information about the public meetings, a map of the
state highlighting the counties with E-911 service, a list of VFD chiefs (all) supporting E-911 and a questionnaire
to be completed and dropped at the Water Company Office (or mailed to the commissioners) indicating support
for or opposition to an E-911 system.
Public opinion with the questionnaire and at the public meetings was 95% favorable and the
commissioners are proceeding with implementation of a system.
A third project, in formative stages, involves the communication of emergency information to the public.
In the Tri-State area, hurricanes, tornados, tidal waves, earthquakes, civic unrest and even floods are low
probability risks. Transportation accidents involving hazardous materials are more likely, however, there is
almost no history of this kind of event. The same goes for major releases from refiners, chemical plants,
terminals, and warehouses. The CAP will search for ways to communicate risk and training needs to the public
which make sense.
In summary, we have an unusual situation with the Neal CAP— no troublesome plant issues, no
environmental justice issues but significant emergency response and public information needs. The CAP has
been interested in helping to enhance emergency response and CAP involvement has made a big difference.
Local Emergency Planning Committee
Active committees are in place in Lawrence County, Ohio, Boyd County, Kentucky, and Cabell/Wayne
County, West Virginia. These committees are seconded by KIMAC - a three state mutual aid group of
emergency responders and industry — and by KEPRA — a three state group formed by the U. S. Coast Guard
to deal with marine emergencies on the Ohio River.
The Cabell/Wayne LEPC benefits from broad participation from print and broadcast media, area
hospitals, full time and volunteer firefighters, Huntington Police, EMS, E-911, local industry, U. S. Coast Guard
and citizen activists.
The LEPC has an emergency operations plan which is updated annually. During the past four years
traffic diversion plans for both counties have been developed and tested. The LEPC has purchased Emergency
Information System hardware and software for the E-911 Center in Huntington. The resource list and plume
mapping features of this system are operational.
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The LEPC is working on an emergency operations center and funding is in place. The center will be a
combination employee lunch room/EOC in the Huntington City Hall Building near the E-911 Center.
Current efforts are focused on evaluating the two county early warning systems and developing a
prioritized upgrading plan. The first step will be to negotiate an agreement with the National Weather Service
to broadcast all risks over the weather frequency - this process is ongoing. The next step will be to provide tone
alert weather radios to day care centers, hospitals, schools, and nursing homes in the two counties. Longer term,
the committee is looking at sirens positioned selectively along major highway and rail corridors.
The keys to an active LEPC program are having a plan with priorities and using positive reinforcement
to solicit and maintain involvement of the public sector. Media coverage is a major asset in recognizing
contributions of the various agencies.
Private sector support is needed for funding program initiatives -- again with media coverage to
recognize the contributors. Private sector members need to be active in sub-committee "sweat equity" work —
providing a positive example to public sector sub-committee members.
The LEPC needs to be opportunistic. Funding and in kind "sweat equity" opportunities arrive at
unexpected times. With a prioritized plan in place, it is much easier to achieve the rapid consensus needed to
move quickly in capitalizing on opportunities.
The LEPC also needs to be pragmatic. Local officials can establish levels of preparedness which are
appropriate and for which funding is available. Building a top notch response capability takes many years so
patience is essential.
End Notes
1. Responsible Care is a registered servicemark of the Chemical Manufacturers Association.
Paul L. Hill. Ph.D, National Institute for Chemical Studies, Charleston, WV
Improving Community - Industry Relationships with TRI
Without question, the advent of Toxic Release Inventory (TRI) information has greatly enhanced the
opportunities for industry/public dialogue. Key to these opportunities are (a) attitude and (b) a process to engage
the information for mutual benefits.
The National Institute for Chemical Studies (NICS) has worked on both the reporting of better
information and improving community relationships since 1985. With the multitude of commonalities between
EPCRA and the NICS charter, we became a "Title m" agency. An array of data management, communication,
planning, responder training, pollution prevention and risk assessment projects have been undertaken, both
before and after the passage of EPCRA
Today, the ScorecardO report on TRI and Community Safety Assessment (CSA) Committees are two
tangible outgrowths of the combined NICS/EPCRA effort in West Virginia. First, ScorecardC is the statewide
program for reporting TRI and increasing community access to the annual reports of emissions.
Making TRI more readily available and utilizing existing and creative outreach mechanisms have
obvious benefits. Collective efforts and the effects of TRI availability have led to increased opportunities to work
cooperatively on goals for increased environmental protection and risk reduction.
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ScorecardC enjoys positive support from the State of West Virginia, U.S. EPA, industry and
dtizen/environmental groups. Contrary to reports from several states regarding the low to non-existent level of
requests for TRI, NICS distributes in excess of 500 reports annually. All 52 LEPC's in the state receive copies.
ScorecardO provides hard data as well as various summaries, trends analyses and geographic groupings.
Unique to the report, facility narrative statements cover ongoing pollution prevention initiatives, reduction goals
and specific activities resulting in reduced waste discharges. While the report summarizes releases from all 151
TRI filers in the state, 26 narrative profiles from the largest emitter category (SIC 28 Chemical Manufacturing)
are provided annually. Each facility receives a "Scorecard" charting its performance since 1987.
The development cycle for the report, however, is as important as the data itself. A public advisory panel
of citizens, environmentalists, agency and industry representatives reviews the report and makes
recommendations for public presentation of various trends and statistics. This group also helps to prioritize sub-
groupings such as carcinogenic emissions and volatile air pollutants (VHAPS). In so doing, TRI facilities have
reduced these categories accordingly with carcinogenic releases (a top priority) 83% lower than in 1987.
Additional outreach is carried out through direct contact with TRI filers, holding Pollution Prevention
Roundtable meetings annually and issuing the Pollution Prevention Newsletter on a quarterly basis. NICS uses
a variety of risk communication principles and techniques to enhance the broader public's ability to access the
information.
A primary outlet for further presentation and discussion of annual reports is through various community
groups including LEPCs, Citizen Advisory Panels (CAPs), religious and civic groups, as well as NICS1 own CSA
committees. This latter group functions much like a community advisory panel, is focused usually on a specific
location (industrial site), and engages in open-ended debates of various environmental, safety and community
issues. TRI information is anticipated annually and well received.
Community groups provide an ideal mechanism for discussing data implications in greater detail. These
face-to-face discussions result in improved relationships, TRI prioritizing and coalitions to address data
implications.
Sanford Lewis, Director, The Good Neighbor Project for Sustainable Industries, and Instructor in
Environmental Law at Tufts University, Department of Urban and Environmental Policy
Independent Technical Resources Are Key to Community-Corporate Partnerships for Pollution
Prevention
Models of Citizen Review for Pollution Prevention
A number of impressive examples of community-corporate partnerships for pollution prevention have emerged
in recent years. To cite a few:
o Citizens for a Better Environment (CBEX a statewide organization in California, has helped citizens'
groups in Contra Costa County to win three "Good Neighbor Agreements" with refineries, securing
specific pollution prevention improvements such as the installation of leakless valves.
o After a serious 1992 chemical accident Rhone-Poulenc jn Manchester. Texas entered a binding
settlement agreement with concerned citizens. They allowed an independent review of their plant, by
an expert selected and supervised by community residents and Texans United (a statewide organization).
The firm has implemented housekeeping and safety recommendations from the audit.
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o At the Ravenswood Aluminum plant in West Virginia, a labor-community-management committee
which includes the plant's union, the United Steelworkers, is searching worldwide for the most
advanced, environmentally sound technologies of the future for aluminum production and to avoid the
use of chlorine compounds.
Independent Technical Resources as Key to Success
The key to success in community-corporate partnerships for pollution prevention is the availability of
independent technical resources for the community. When local residents have their own experts, they can ask
questions and make recommendations leading to action. Various technical assistance acquisition strategies are
possible. In the Rhone Poulenc audit, the company paid for the work of the independent auditor. CBE's efforts
were supported by a technical advisor from the Environmental Careers Organization, a national organization
that has trained 17 retired engineers and chemists to assess toxics use reduction opportunities for environmental
groups. The state of Minnesota has a program which has provided technical assistance grants to ten community
pollution prevention efforts.
Other Features of Strong Partnerships
Other features of the stronger partnerships are exemplified in the agreements. In the R-P agreement,
important procedural rights include: 1) disclosure of company environmental documents in a public library file,
2) a right of citizens to conduct plant inspections, and 3) the establishment of fenceline monitoring for air
pollutants. An agreement negotiated with Chevron in Contra Costa County, California demonstrates another
set of important commitments that can be addressed in the partnerships — economic concerns. The firm
committed to increasing its donations to nonprofit organizations benefiting near neighbors of the facility to $5
million, and to conduct job training and hiring from the community.
Labor Expands on Health and Safety Monitoring to Integrate Environmental Concerns
Labor unions have a vital role to play in partnerships for pollution prevention, based on their long history
of tracking corporate performance on occupational safety and health issues. Unions' "safety stewards" are rank
and file workers with the training to watchdog occupational health and safety issues that arise on the shop floor.
Stewards are aided by professional industrial hygienists who work for the local or international unions. Union
health and safety committees discuss any problems identified, and raise the issues in negotiations with
management or in communications with appropriate government oversight bodies.
While organized labor has been involved in promoting environmental policies since the outset of the
modem environmental movement, strides have been made in the last decade to expand workforce oversight to
the environment beyond the plant gates. The use of toxics place both workforce and community at risk of
ongoing or sudden emissions, thereby Unking indoor and outdoor environments. So does a likely solution —
reducing the use and storage of those chemicals. Labor unions at a number of plants have begun to actively
investigate, and to inform the public when management resists making necessary improvements.
One of the most advanced environmental precedents for organized labor occurred at Harvard Industries,
in New Jersey. There, the United Auto Workers local negotiated the establishment of a "hazard prevention"
committee in 1991 which examines HES issues. The union has a right to shut down any operation in the plant
which presents a danger to worker health or safety or to the outside environment. Monitoring is ongoing.
At many nonunion plants, environmental committees have been established to solicit participation of
workers on pollution prevention and chemical accident safety. However, the ability of these nonunion workers
to truly "audit" and advocate for change at nonunion plants is more limited than at the unionized plants. While
management may be willing to solicit the workers' money-saving ideas, workers who lack a bargaining unit to
deal independently with the management or the community often risk management retaliation (firing or
harassment) if they are vocal about the environmental shortcomings of a plant. While the federal Whistleblower
Protection Act provides some protection, some states have also passed special whistleblower laws to give more
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protection to such workers; the pending OSHA Reform Act would extend whistleblower rights and establish
health and safety committees at all covered plants.
Rhone-Poulenc Agreement in Texas as National Model for Strong Process
The Rhone-Poulenc agreement in Manchester, Texas is a model for a strong process in regard to
partnerships for pollution prevention. Manchester sits along the notorious Houston Ship Channel, home to the
nation's largest concentration of petrochemical companies. Like so many communities under the stacks of major
polluting industries, Manchester is a predominantly minority community (Hispanic). In June 1992, a serious
accident occurred at the plant — a release of sulfur dioxide. At least 27 people were sent to area hospitals. The
Manchester community decided to take action. With the assistance of the environmental organization Texans
United, the community confronted the company. After months of negotiations, they won an agreement which
gave the community specific rights never before recognized in Texas.
The 1992 agreement reached by Texans United, local citizens groups, and Rhone Poulenc exemplifies
the potential for more in-depth community review of a plant's HES performance. Rhone Poulenc agreed to pay
for an independent environmental audit by an expert selected and supervised by a panel of community residents
and a statewide organization, Texans United. Among the features of the agreement are:
A broad audit which includes review of regulatory compliance, safety training, accident prevention,
emergency response, waste analysis and information systems, monitoring programs, and waste
minimization practices.
• Public disclosure of company documents, including hazard assessment and risk analysis, lists of
accidents/upsets/near-misses/corrective actions, and waste minimization and reduction plans.
• Rhone-Poulenc committed to "negotiate in good faith" on the audit recommendations.
• Citizens are entitled to accompany the auditor and conduct other inspections by appointment.
• The agreement is legally binding because it is integrated to the firm's operating permit.
Even before the negotiations which led to this agreement began, the community had enlisted the support
of a state legislator and a city council member who were present to voice support for the community's position.
By the time the agreement was finally reached, there had been an intensive community campaign which included
a public challenge to the firm's water pollution discharge permit Numerous neighborhood plant inspections have
occurred in other communities as a result of similar campaigns.
Weaker "Partnerships" Demonstrate the Dangers Where Rights and Commitments are Absent
The experience at the grassroots level is replete with innumerable instances of corporate public relations
which are lacking in the kinds of rights and resources necessary for effective citizen and worker participation.
A few examples of recent grassroots experiences should suffice to demonstrate why government must aid
stakeholder participation to create a more fairly structured relationship.
Firms are often willing to give local citizens sanitized summaries of plant evaluations, but refuse to share
actual data and studies. Chemical companies willingly prepare and distribute vague self-evaluation
"report cards" under the industry's so-called Responsible Care program. For example, Union Carbide
asserted in a 1992 report that at 100% of its plants: "Senior management leads continuous improvement
through policy, participation and resource commitments." But the same report noted that less than 10%
of Union Carbide plants were sharing "safety information/lessons with industry, government,
community." Instead of vague, undocumented characterizations of firm performance and safety,
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stakeholders need real documentation on safely that they can scrutinize along with independent experts.
• Stakeholders have often been manipulated into believing they had won more than they had by
nonbinding corporate "promises" to share information, which are later freely violated due to their
unenforceable nature. At the DuPont plant in Montague, Michigan, corporate officials told the local
organization, Citizens United for the Environment, that they would share worst case accident
information and internal corporate safety audits. Instead of providing worst case information, they gave
only their interpretation of likely "credible" accidents. They reneged entirely on their written
commitment to provide internal safety audits.
• Firms often attempt to redefine the "public" by handpicking the membership of official "advisory
committees," and asserting such committees as their principal mechanism for public interaction and
accountability. Many of these community advisory panels are so heavily stacked with people friendly
or even financially connected to the firm that they are not able to effectively watchdog the firm. On other
panels, a single "bona fide" activist is allowed into such a grouping, where they have been outvoted and
otherwise intimidated against raising their legitimate concerns and criticisms. Perhaps the ultimate
demonstration of the skewing of this committee process is the CMA's own survey, which found that
while most of the public remains seriously concerned about the industry, 86% of the panel members
surveyed viewed the industry favorably.1
• Firms often attempt to dictate who citizens can use as experts, or refuse to provide the needed funding
of experts. For instance, Union Carbide in Seadrift, Texas declined to allow the Calhoun County
Resource Watch to bring any of a list of the citizens' chosen experts to the plant in meetings with the
citizens group.
Government's Vital Role
These recent experiences with strong and weak participation models demonstrate that government can
and must play a role in promoting community partnerships for pollution prevention. Government's role can
include:
• Providing grants for independent technical assistance by staffers as is done in the Minnesota program.
• Setting groundrules for relationships such as document disclosure requirements and committee
decisionmaking and participation rules.
• Providing direct technical assistance or facilitation of the local relationships.
• Providing citizens with leverage to convince companies to negotiate - e.g. withholding permits and
enforcement settlements until the relevant firm has negotiated an acceptable process or set of
commitments with the local community.
Conclusion
Partnerships are in a period of experimentation, but the value of the stronger relationships is already
clear. By establishing a strong and focused process to negotiate priorities for study and action, community and
corporate partners can prevent pollution, protect health, bring diverse local interests and agendas into closer
alignment, and save time and money that might otherwise be expended in conflict.
End Notes
1. CMA News, November 1992, page 4.
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Phillip Muessig, Community Assistance Coordinator, Minnesota Office of Environmental Assistance
Background
A 1992 amendment to Minnesota's facility planning statute expanded the provision of pollution
prevention assistance to citizens and community groups. Minnesota Office of Environmental Assistance (OEA)
new community assistance program provides information and education, referrals to and coordination of others,
meeting facilitation and mediation, and matching grants. A fact sheet on the program is available today, and a
full report on the program can be mailed to interested people.
I come from 8 years of economic development work with the Seward Neighborhood Group in
Minneapolis, where I also staffed the local business association which had gone into dormancy and welcomed
my offer of assistance. As staff to both groups, I was accepted as a mediator in dozens of business-citizen
conflicts over pollution, noise, and trucks. Mostly the companies in question employed between 5 and 50
employees, though I did work with a few companies in the 100-300 employee range. My successful mediation
of most conflicts informs many of the suggestions below.
At the OEA, part of my time is spent coaching citizens, citizen groups, and businesses to meet face to
face to discuss pollution issues and to use pollution prevention as a tool in solving disputes. Though emergency
planning and accident prevention are sometimes being sought by citizens, I strongly promote a more holistic
pollution prevention focus in discussions.
Typical Business-Citizen Pattern
Business-citizen conflicts over hazardous and toxic chemical use and emissions often involve each side
"demonizing" the other. This natural and understandable dynamic tends to play out in this sort of dialogue:
Citizen: "I can't believe you're doing this to me."
Business: "For the 10th time, I told you I'm not breaking any laws. The EPA says its safe."
Citizen: "I don't care what it takes, just stop."
Business: "What do you want me to do, go out of business?"
Over time, this dialogue will repeat itself over and over, or a citizen or citizen group will sue the company, or
citizen action will try to obstruct a company's action by becoming involved in regulatory permit battles.
A More Productive Pattern
The case of Flour City Architectural Metals in the Seward neighborhood is instructive of this last course
of action, which took an unexpected and favorable twist. Citizens had complained of MEK odor from Hour City
for over a decade, with little change in emissions. When a company proposal to raise the height of the emissions
stack reached the state's pollution control agency, a public hearing was held. Angry neighbors glared at the
manager, one wore a gas mask, and one effectively challenged the company engineer's assumptions underlying
air dispersion modeling. Productive discussion was nowhere in sight. But then a city council member, and the
executive director of Citizens for a Better Environment (CBE: a state-wide environmental group) suggested to
both the citizens and company officials that a small group of neighborhood members meet with company officials
and CBE to discuss the issue in a more structured and rational manner. Seeing nothing but a permit battle ahead,
the Flour City manager agreed, on the condition that the proposed "Good Neighbor Agreement" discussion take
place formally with the official citizen participation organization for the neighborhood. Subsequent discussions
focused on pollution prevention, with the company agreeing to phase out a vapor degreaser and beginning a plan
for further reductions.
Another example of productive business-citizen interaction involves the owner and fleet manager of a
trucking company, where fumes, noise, lights, and vibration had been a problem to neighbors for years. Around
the time of an underground storage tank leak, the company invited neighbors for 3 blocks around to a beer and
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bratwurst party on the boulevard outside the facility's front door. With both the owner and manager fully
occupied at the barbecue, neighbors had a captive audience and spent the first half hour venting all their anger.
The next half hour, however, was quite different. Real discussion about how to prevent some of the problems
and how to keep the jobs at the company took place. The lasting impact of the barbecue was that neighbors had
the direct dial number of the manager, who agreed to take all complaints and resolve them promptly.
How to Steer Conflicts Toward Productive Communication
Direct contact between affected citizens and top management is absolutely worth trying. The disputants
must see each other as real people living in the same community. But for best results, I recommend two tactics:
(1) that there be a mediator, or some third party neutral, to facilitate that most difficult hurdle of getting both
sides to the table to talk in anything but hostile terms; and (2) that someone, and a mediator is trained in this,
coach each party so that the meeting is focused and productive.
Tips for Businesses
In workshop training for businesses I elaborate upon six "tips," which take off from "The Seven Cardinal
Rules of Risk Communication" by Vince Covello, writing in a 1988 EPA pamphlet for TRI reporters. The tips
also rely heavily on "Getting to Yes" negotiation theory. The six tips are:
* Get to know your neighbors.
* Accept and involve your neighbors.
* Set the stage so everyone is listening.
* Be open, honest, frank, and compassionate.
* Connect with a local community group.
* Avoid arguing relative health risks.
Tips for Citizen Groups
Similarly, I do workshops with citizen groups and elaborate upon these tips:
* Partner with others.
* Know your role; keep your eyes on the prize.
* Know thy business; data is your resume.
* Set the stage so everyone is listening.
* Believe that "community" includes business.
* Be open, honest, frank, compassionate.
* Listen; meet people at their level of awareness.
* Exploit your common sense.
* Avoid quantitative health risk assessments.
* Focus on pollution prevention.
* Realize that public discussion of private technology is touchy.
* Push for action, and be patient.
Effie Skokan, Assistant to Chair, Department of Biological Sciences, Wichita State University and Member
Community Involvement Group, Vulcan Chemical Co.
The Community Involvement Group: An Opportunity for Citizen Participation in Industry Decision
Making
The Community Involvement Group (CIG) was initially formed in 1988 in response to Vulcan
Chemicals' plan to build a hazardous waste incinerator at their Wichita, Kansas facility. In response to
suggestions from the local environmental community, the CIG was formed by a Steering Committee who worked
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with industry representatives and a neutral facilitator to select the members of the group and to draft a set of
ground rules under which the CIG would operate.
Within a few months, Vulcan withdrew their incinerator plans. However, six years later the group
continues to meet. Contributing factors to the CIG's continuance include a history of environmental problems
(including groundwater contamination) at the facility, the company's position as the only U.S. producer of
pentachlorophend (a wood preservative listed as extremely hazardous by the EPA), the release in early 1989 of
the first Toxic Release Inventory (TRI) data which placed Sedgwick County, Kansas in the top fifteen counties
in the USA in total amount of reportable emissions (largely due to deep well injection of hydrochloric acid at the
Vulcan facility)1, and impetus from the Chemical Manufacturers Association (CMA) Responsible Care ®
program obligating member companies to make a public commitment "to improve performance in response to
public concerns about the impact of chemicals on health, safety and environmental quality."2 In addition, by the
time the incinerator plans were withdrawn, all participants (both industry and community) felt that the dialogue
initiated by the group had been beneficial and should be continued.
The members of the group represent academia, the environmental movement, public health and safety
officials, the League of Women Voters, rural and suburban plant neighbors, other industries, and the
metropolitan area at large. The meetings are facilitated by a neutral third-party and are open to the public with
a period of time set aside at the end of each meeting for observer comments. The plant manager attends all
meetings and acts as the corporate liaison. Other company employees attend meetings to present information
as requested by the group. The company funds the meetings and the CIG has the right to negotiate with the
company for additional funding to hire outside consultants. The primary topics of discussion during the past six
years have been the proposed incinerator, waste minimization, underground injection of hazardous waste, RCRA
facility investigation, a groundwater pumping program, TRI, two new production faculties, emergency response
and notification systems, and meeting the standards of the 1990 Clean Air Act.
About one-half of the current members of the CIG were members of the original group. As one of those
original members, it is interesting to reflect on why I became a member and why I continue to be involved.
Originally I saw it as an opportunity to address environmental concerns in a new manner. Previous opportunities
had often consisted of public forums at which little meaningful dialogue took place, regulatory agency hearings
usually held after the decision making process was completed, media events which called attention to perceived
problems but did little to alleviate them, and activities aimed at changing legislation or regulations. While I felt
that each of these activities had a role to play in bringing about change, the idea of sitting down at the table with
industry representatives seemed to fit my personal style. I felt that the chance to exchange information in a non-
confrontational manner filled my need as a scientist to seek accurate information and a personal need to have my
opinions heard and considered by others. Overall, the CIG process demands accountability on the part of all
participants due to the long term relationship of the members. It also gives those of us in the environmental
movement the opportunity to show that we can have our facts straight, can do our homework and that we can
understand the science upon which environmental decisions are made.
Being an effective member of such a group is a demanding endeavor. It requires a commitment to the
process, and of time to study the issues. It also requires an understanding of the concerns in the community and
the ability to bring those concerns to the table for discussion. It requires a combination of inquiry and
responsiveness. Members should be able to ask pertinent questions based on background information and must
always be able to listen and respond to other points of view. Finally, membership requires the ability to evaluate
information presented and the duty to disseminate that information to interested parties outside the CIG.
As with any process, this one is not perfect. The CIG, one of the first of CMA's Community Advisory
Panels, has been criticized by some members of the community, particularly by some environmental activists,
as one more attempt by industry to buy-out the public. To them, the process is perceived to be fraught with
power imbalance, issue distortion, and the chance of co-optation. For the most part such critics have refused to
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participate in the CIG and I believe the lack of their inclusion somewhat limits the GIG'S perspective. The lack
of representation of the extreme views on issues discussed makes for a good working relationship within the
group, but in some cases prevents the group from adequately dealing with perceptions of the company which
are prevalent in the community. la an attempt to address such criticism, the CIG does an annual self-evaluation,
welcomes members representing all interested groups and citizens, and conducts its meetings in a formal,
professional manner.
Other issues which impact the effectiveness of the CIG are the technical nature of the discussions and
the hesitancy of the company to include the CIG early in decision making processes. Because we have dealt with
many environmental and chemical process issues in our discussions, those members without a strong science
background are sometimes at a disadvantage at the table. On two occasions the CIG has successfully negotiated
with the company to finance consultants of the CIG's choosing for expert opinion, an option which tends to level
the playing field, particularly for those members without scientific expertise. The inclusion of the CIG in the
early stages of decision making has unproved during the time of the CIG's existence. Whereas originally we were
informed of decisions after the fact, more recently the company has asked for our input during the planning stages
of most changes in operation. In recent years, we have reviewed plans for new process units, helped write
informational brochures about changes in operation, participated in a process hazard analysis (HAZOP),
reviewed options and made recommendations for meeting Clean Air Act regulations, toured process units under
construction, and continuously monitored the company's TRI data and their commitment to toxic waste
reduction.
I would foresee the most important upcoming roles of groups such as the CIG to be related to the
ongoing implementation of the Clean Air Act and the Responsible Care program. One of the possible new roles
of the CIG will be involvement in making worst case scenario information available to the public in accordance
with the Clean Air Act The question of what represents a worst case must be carefully determined and the CIG
should be able to provide valuable input to the company as to what the community perceives that scenario to be.
Another potential new role of the CIG will be in third party verification of Responsible Care. I would foresee
the inclusion of CIG members in this process to be vital to the group's continued effectiveness. If the public is
to "track us, dont trust us,"3 groups like the CIG must be involved in the verification process if such groups are
to maintain their credibility in the communities they represent This inclusion will of course bring to the forefront
the need to balance the community's right to know with the corporate right to proprietary information.
In the near future I would expect that groups like the CIG will face other issues, which are likely to be
contentious. Such topics as the expansion of the list of chemicals reported in TRI and the growing evidence of
the adverse environmental effects of organo-chlorines come to mind. Additionally, CMA members should be
facing questions from their advisory panels regarding the perceived dichotomy between the Responsible Care
initiative and other CMA activities such as lobbying. For example, it becomes difficult to accept Responsible
Care's commitment to public disclosure when CMA is active in fighting proposed increased reporting
requirements under Right-to-Know. If industry is serious about public disclosure and including the public in
decision making, it must listen to what the public is saying and respond accordingly. To do otherwise, is to lose
credibility with groups like the CIG, which at its best has accomplished much both for the public and the
industry. It would be sad to see such groups lose effectiveness after we have come so far.
End Notes
1. Rae Tyson et al., "The Top 500 Counties: The Most Common Chemicals," USA Today, 1 August 1989, sec.
A.6.
2. Chemical Manufacturers Association, Responsible Care: A Public Commitment, (Washington, D.C.:
Chemical Manufacturers Assoc., n.d.).
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3. Peter M. Sandman, November 1990, as quoted in Karen Heller, "Listening to -and Taking on - the Skeptics,"
Chemicahveek 148 (26) (1991): 88.
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Session 4: International Partnerships with TRI
Cession Leader
Fran Irwin, World Wildlife Fund
Edan Dionne, Corporate Environmental Systems, IBM
Susan B. Hazen, Acting Deputy Director, Office of Pollution Prevention and Toxics, U.S. EPA
Francis Lavallee, Head, National Pollutant Release Inventory, Pollution Data Analysis Division,
Environment Canada
Victor Hugo Paramo Figueroa, Director, Administration and Environmental Quality,
National Institute of Ecology, SEDESOL, Mexico
Fran Irwin, World Wildlife Fund
Each country-and company-is taking a distinctive approach to reporting. At the same time, building
reporting systems with a set of core data elements across national borders is a high priority. These two messages
came out of the presentations by governmental leaders from Canada, Mexico, and the U.S. and a representative
of the business reporting initiative known as the Public Environmental Reporting Initiative (PERI).
While the U.S. established the TRI through a legislative initiative based on the right-to-know, Canada's
NPRI was developed through a stakeholder process. Existing legislation was used. Rather than requiring
reporting from facilities within a particular set of SIC codes, Canada reverses the process and requires reporting
from all facilities with some exceptions. In Mexico, 16 governmental, nongovernmental, business, and academic
organizations are taking part in a coordinating group. A consultant's report reviewed existing databases and
potential for a comprehensive approach as one early step toward a PRTR strategy.
When a questioner asked whether there will be a North American TRI, the Canadian and Mexican
panelists stressed their distinctive approaches. At the same time, however, the Canadian director of NPRI
pointed out that Canada's form requests reporting companies to use the U.S. as well as the Canadian codes for
industrial sectors to ease cross-border comparisons. The Mexican program, the director noted, is being developed
in close relationship with the UN Institute for Training and Research (UNITAR) and the series of international
workshops on guidance for Pollutant Release and Transfer Registers (PRTRs) being sponsored by OECD. The
Mexican proposal and the international guidance will both be completed in January 1996. Although PERI
stresses that each company should decide how to report, the guidance encourages consistent reporting on
environmental management among companies.
The U.S. panelist suggested that a step toward reporting of common core elements among countries
would be to compare data from similar facilities in a particular sector or look at facilities in a border region. A
California manager pointed out the difficulty California had in getting an accurate list of names and addresses
of U.S. companies operating across the border in Mexico. The panel's business participant said she thought data
would be available for facilities operated by American companies in other countries on a voluntary basis. She
pointed out that detailed data may not be included in a company's environmental report because such reports
serve broader purposes but that the data were likely to be available on request.
An NGO representative asked how PRTRs might be related to the Nordic proposals on persistent
organic substances and to the action plan likely to come out of the Washington conference on land-based sources
of marine pollution in November 1995. The Canadian panelist said that international agreements in the control
of particular chemicals would have an important influence on which chemicals are added to the NPRL
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A consultant with UNTTAR stressed the usefulness of PRTRs in providing baseline data on
environmental releases.
Another questioner asked about the relationship of PRTRs to the environmental standards being
developed under the International Standards Organizations (ISO). Panelists indicated they were keeping an eye
on the relationship to the ISO standards on environmental performance.
In response to a question, the Canadian panelist said that as Canada deals with its first year of reported
data, six staffers are working on the NPRI. Additional personnel are working at the regional office level.
D
Edan Dionne, Corporate Environmental Systems, IBM
Guidelines For Effective Environmental Reporting: PERI Guidelines
An organization's environmental performance is increasingly viewed as an essential part of good
citizenship. Consequently, environmental reporting continues to grow, as does its value as part of an
organization's environmental management system.
Recognizing the growing importance of environmental reporting, several companies began exploring
effective ways to publicly share information on programs and performance. The group produced a set of
voluntary guidelines, first released in 1993 and updated in 1994, as a helpful tool for organizations to use is
initiating or improving their environmental reporting. The document is called the Public Environmental
Reporting Initiative (PERT) Guidelines.
The ten key environmental reporting areas covered by the PERI Guidelines are:
* Organizational Profile: Helps audiences interpret and understand the context of all information contained
in the report.
Statement of Policy: A statement of the organization's environmental policy, including overall goals to
be achieved.
Management System: Discussion of environmental management systems and how those programs are
implemented.
• Environmental Releases: This covers information on air emissions, greenhouse gas emissions,
ozone-depleting substances, water effluent, hazardous waste disposal and management, and
company-wide reduction targets or goals.
• Resource Conservation: This category addresses materials, energy and water conservation, as well as
forest, land and habitat conservation.
• Risk Management: This covers auditing programs, remediation programs, emergency response programs
and work place hazards.
• Environmental Compliance: This category requests information on organization's record of compliance.
• Product Stewardship: This category covers a wide range of items, focusing on the degree to which a
company evaluates the environmental impact of its products or processes; packaging reduction, reuse
or recycling; use of recycled materials; energy efficiency; post-consumer materials management activities
(product take back programs, etc.); supplier-based programs for reducing environmental impact; criteria
for selecting environmentally responsible suppliers; any specific product stewardship targets, goals and
performance against the goals.
Employee Recognition: Particularly programs to encourage or reward environmental responsibility
among employees.
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• Stakeholder Involvement: This final category requests information on efforts to work with stakeholders,
including efforts with research or academic institutions, policy groups, non-government organizations
and industry associations.
D
Susan B. YLaztn, Acting Deputy Director, Office of Pollution Prevention and Toxics, U.S. EPA
It is a pleasure to be here today with representatives from our states, from industry, local community
groups, academia, the environmental community and other Federal Government users.
TRI is a Program that tends to bring people together and this conference is one of the most successful
examples of how bringing all users, or customers, together can help to enhance and build a product that meets
as many customer needs as possible. After each of these conference, EPA has gone back and reassessed what
we are providing in terms of information, how we are providing it and laid the course for changes and additions
as appropriate and as possible.
Today I am here to talk about International TRL Moving forward beyond our national program does not
mean that we believe we are done here — what it means is that we believe we have a tool that is essential in the
development of good sound environmental management practices. It means we believe we have stepped out
ahead and need to bring other nations along. It means that we believe our experiences — yours, mine and all U.S.
users are relevant and important to the rest of the environmental community.
At the Rio Summit, Agenda 21 was drafted and identified the collection and dissemination of information
as one the highest priority activities for follow-up. Given the enormous number of issues that were raised at this
Earth Summit, it seems surprising that information was identified as a priority. Why is that?
Information about the flow and movement of chemicals through the environment, the economy and the
workplace is essential to understanding the potential dangers, the areas of greatest concern, the areas where
special care needs to be applied and the areas where critical risk decisions need to made — risks accepted or
rejected as unreasonable. And these acceptances or rejections need to be made not just by the industry or the
government but by the public — the workers, the neighbors, the children. Those who often bear the risk with
no financial benefit, those who often have been unaware that there is a risk to be evaluated. People for whom
decisions have been made by federal and state agencies who don't live in their neighborhoods, or by plant
managers who find a risk acceptable mat you or I may not. The public lost trust in the decision makers long ago
and information allows them to be part of today's decision making- and hopefully part of rebuilding the trust.
We all know about TRI and Right-to-Know in the United States - but why an International TRI? Well,
just as we learned here in the U.S. — pollution, chemical hazards and industrial diseases know no boundaries.
We are at present trying to understand the contaminants that flow through the New River into the U.S. Trying
to assist a population who is being adversely impacted by chemicals and wastes that they clearly did not generate,
nor did they choose to accept.
We and they are hindered in our search for answer. We do not know and the Mexican government does
not know what facilities in Mexico are releasing into the air and water that could be causing significant public
health issues. Facilities in Mexico do not report on releases and transfers of chemicals into the environment.
Even U.S. companies in Mexico do not provide that information. Yet pollution has moved across the border,
people are getting ill, and information is not forthcoming.
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When the catastrophe in Seveso, Italy occurred, the toxic chemicals released did not stay within a
confined area They moved and dispersed across borders. People many miles away had no idea what was stored,
used or routinely released at Seveso. They had no choice, no right to accept or refuse the risk.
Until just recently, there was nothing to even restrict the purposeful movement of hazardous waste
across borders from developed to developing countries.
Nations do not exist within bubbles, and as we become even more and more technologically advanced,
the need to share critical health and environmental impact information across oceans and borders is essential.
So, what are we doing?
In February 1993, the U.S. EPA, under the auspices of the International Programme on Chemical Safety
(IPCS), convened a workshop in Washington D.C. to explore issues relating to the implementation of Agenda
21 Chapter 19 recommendations concerning chemical release inventories. This was the first step in moving
towards an international programme. As a follow-up, a small steering committee was formed to lay out what was
needed and to find the means and the mechanisms for moving forward. This small group consisted of members
from the IPCS, the WHO, UNEP, OECD, UNTTAR, and U.S. EPA
Much has grown from this small group.
The OECD took on responsibility for crafting a Guidance to Governments Document that would serve
both developing and developed countries. This document would serve as a guide for creating small inventories
and start up programmes. The document is being developed through a series of workshops. Two have been held
already and the third will be held this January in Basel, Switzerland. The effort has been quite successful to date
and we expect to have a completed document in 1995. This document is exploring such critical issues as Right-
to-Know, pollutants to be covered, measurements data systems, facilities to be covered — and so on.
The US and the IPCS drafted a "Benefits Document" as the starting point for "advertising" the benefits
of an international TRI. The Project was called Pollutant Release and Transfer Registries.
UNTTAR has taken on the sizeable task of developing and testing training materials for developing
countries. Mexico, the Czech Republic and Egypt are pilot countries for this effort. All reports are that this
exercise is progressing well. UNEP has been working with UNEP has been working to evaluate existing
hardware and software at the IRPTC. The IRPTC is one possibility for a repository of international data.
And lastly, but certainly not least:
Many OECD member countries have forged forward aggressively and have developed their own
inventories. Canada has completed their first year of data collection and is well on the way to year two. The
United Kingdom published their first inventory results this year with much the same findings as the first U.S.
inventory — large releases that had not been expected.
The Dutch have had pollutant inventories for many years while the Japanese, the Australians and the
E.G. are moving towards developing systems. Within the OECD we are at the early stages of sharing information
across borders with the U.S., Canada and, if possible, Mexico.
Hopefully a similar effort will emerge in Europe.
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The U.S. is strongly supporting all of these efforts through both in-kind services as well as financial
support where possible. We believe that only when we can access information globally will we have a real sense
of the chemicals in our environment.
D
Francois Lavallee, Head, National Pollutant Release Inventory, Pollution Data Analysis Division,
Environment Canada
Canada's National Pollutant Release Inventory: An Overview of Its Development and Implementation
This presentation outlines the development of Canada's National Pollutant Release Inventory (NPRI)
and highlights differences and similarities between the Canadian inventory and the United States Toxic Release
Inventory (TRI). It closes with a brief review of progress to date and future direction for the National Pollutant
Release Inventory.
Genesis
In the United States, the Emergency Planning and Community Right-to-Know Act provided the
foundation of the Toxics Release Inventory, and later, other elements were added as a result of the Pollution
Prevention Act The TRI was, to a large extent, specified by these acts of Congress and was enacted as a result
of the environmental incidents at Bhopal, India and, closer to home, in West Virginia.
The basis for Canada's NPRI is a strategic document, known as Canada's Green Plan, which is a
framework for environmental remediation and sustainability. The Green Plan specifically refers to the need to
improve our understanding of toxic substances and their health risks in Canada In this way, the NPRI does not
exist per se as part of a Community Right to Know initiative. It can be seen as a first step in that direction but
it is foremost an essential part of overall toxics management in Canada. The need for Community Right to Know
provisions in Canada, of which the NPRI is considered one important element, is part of the current review of
the Canadian Environmental Protection Act (CEPA).
It is important to note that no specific separate legislation was enacted to establish this new national
database, the NPRI. Instead, the program was implemented using existing provisions of the Canadian
Environmental Protection Act, specifically subsection 16 (1) of the Act which allows the Minister of the
Environment to request information by publishing a notice in the Part 1 of the Canada Gazette. CEPA applies
to all Canadians, unless they are specifically exempted in a notice, and those subject to the notice are only
required to provide information to which they have access or to which they can reasonably be expected to have
access.
The NPRI Reporting Criteria
To assist in the development of the NPRI, Environment Canada established a multi-stakeholder advisory
committee (MSAC) composed of representatives from governments - both federal and provincial, from a number
of industry sectors, as well as representatives from environmental and labour organizations. The Committee
worked for 18 months and consulted with other Canadians across the country to produce recommendations for
baseline reporting criteria for the NPRI. These recommendations were submitted to the Minister of the
Environment in December 1992. The program was officially launched in March 1993, with 1993 identified as
the first reporting year for the NPRI.
The NPRI reporting criteria specify that anyone in Canada who manufactures, processes or otherwise
uses 10,000 kgs (10 metric tonnes) per year of a listed NPRI substances, in concentrations of 1% or more, and
who has 10 or more employees in a given year, must report releases or transfers of the listed substances unless
an individual is specifically exempted in the Canada Gazette notice from reporting to the NPRI.
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It will not be surprising if these criteria appear familiar to those who also know the U.S. TRI. In
developing the baseline criteria for the NPRI, the members of the advisory committee turned to examples of
existing programs, particularly the TRI, and the Canadian Chemical Producer's Association National Emissions
Reduction Masterplan (NERM), a voluntary industry initiative.
The list of 178 NPRI chemicals also reflects the example of these programs. The list of substances in
the NPRI was essentially derived from the 1990 TRI list of substances. Those substances already regulated in
Canada and substances scheduled for bans or phaseout were eliminated from the potential NPRI list and, as a
result, pesticides and Chlorofluorocarbons (CFCs) do not appear on the list. In addition, substances that were
on our Domestic Substances List in quantities below 1 tonne were eliminated, since it was logical to assume that
no reports would ever be filed for these substances under the current reporting criteria. The committee also
reviewed 10 other major lists, from which it derived a list of 78 "candidate" substances which are expected to
be reviewed in future years for possible addition to the NPRI list of substances.
Other Similarities and Differences
In addition to differences in underlying legislation and in the list of substances, it is important to note
that the TRI reporting requirements apply only to industries within the Standard Industrial Codes (SIC) 20 to
39. As noted, in Canada, anyone who owns or operates a facility that meets the NPRI reporting criteria must
report exce/rt if specifically exempted. The application to all Canadians is a basic underlying principle of the
Canadian Environmental Protection Act and is not specific only to the NPRI. As a result, a specific list of
exempted sectors needed to be developed for the NPRI The current exemptions were recommended based on
the expected level of releases, the undue reporting burden which might be imposed, and the availability of
information from other sources. Federal and Provincial Government facilities are not exempted unless they fall
under the specified exemptions, which include facilities used for:
Education or training of students, such as universities, colleges, and schools;
Research or testing;
The maintenance and repair of transportation vehicles, such as automobiles, trucks, locomotives, ships
or aircraft;
The distribution, storage, or retail sale of fuels;
The wholesale or retail sale of articles or products which contain listed substances, as long as the
substances are not released to the environment during normal use at the facility;
The retail sale of substances listed in Schedule I to this notice;
Growing, harvesting, or management of renewable natural resources, such as fisheries, forestry or
agriculture, as opposed to facilities which process or otherwise use their products;
Mining of materials, but not those facilities engaged in further processing of these mined materials;
Drilling or operating wells to obtain oil and gas products, but not those facilities engaged in further
processing of these oil and gas products.
Other similarities between the NPRI and the TRI are apparent in the information being collected. As
with the TRI, the NPRI requires that facilities report information identifying the facility and its location, the
quantities of listed substances released to air, water, land or by underground injection or transferred off-site in
waste. However, there are also important differences. Since "emergency preparedness" is not a stated purpose
for the NPRI, information is not requested on the quantities of listed substances stored on site. In addition,
because no agreed definition of "pollution prevention" could be developed for the NPRI by the advisory
committee, no information related to pollution prevention, such as recycling on site, is being collected.
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plectronic Reporting
Based on information provided by the EPA on the costs and time associated with the processing of TRI
reports filed on paper, Environment Canada decided to encourage electronic reporting as much as possible. A
"Clipper", user-friendly, reporting form was developed for the NPRI program by Environment Canada staff. The
quality of this software was quite good and problems have been minor. Approximately 70 percent of respondents
used the electronic form rather than paper. User feedback overall has been overwhelmingly positive. A number
of changes are being made to the improve this product and increase its usefulness to users. Environment Canada
found that the quality of the reports filed on disk was much higher than those filed on paper, primarily due to
"error" checks built into the reporting software which required reporting facilities to correct reporting errors in
order to complete their reports for Environment Canada We have found that electronic reporting has greatly
reduced the number of follow up calls required to complete missing or erroneous information on reports filed with
theNPRL Electronic reporting packages will automatically be sent for the next reporting cycle to anyone who
has already filed with the NPRI and we will continue to work to increase the percentage of reports filed
electronically.
Environment Canada has received over 1200 reports for 1993 and is in the process of reviewing the
reports. The first annual NPRI report will be a summary of the information provided and will include
Environment Canada estimates for mobile sources and fuel distribution. Estimates from other sources also will
be included in future years. Because we intend to make the information reported to the NPRI publicly accessible
through Internet, only a summary report will be published in paper format.
While the TRI has served as a useful model for the NPRI, we can expect that other differences between
the programs will be introduced as the NPRI evolves in response to Canadian environmental priorities. Many
changes have been made or proposed to the TRI and, as with the initial development of the NPRI, these changes
will be evaluated for their applicability in Canada Changes to the NPRI list of substances must also be
considered in terms of outstanding issues identified by the Advisory Committee which included the need to
consider high profile micro- (choxins, furans) and macro- (CO^ pollutants on the list of NPRI substances. These
issues and the review of reporting thresholds which such changes would entail will form the basis of future work
for the NPRI.
D
Victor Hugo Pa"ramo Figueroa, Director, Administration and Environmental Quality, National Institute
of Ecology, SEDESOL, Mexico
Development of a PRTR in Mexico
Mexico is considering a Pollutant Release and Transfer Register (PRTR) to achieve a range of goals.
Some relate to developing a more integrated approach: provide comprehensive emission records for individual
facilities; avoid duplication in reporting at the local and federal levels; provide basis for comprehensive inspection
and enforcement; and provide information for future integrated regulations or rules.
In principle, Mexican industries agree that a PRTR can be a cost/efficient way to report emissions to
authority. Industry also agrees that a PRTR offers the opportunity to identify unnecessary emissions to the
environment. NGOs support a PRTR as public information to inform communities about risk and help the
population protect itself. In addition, the PRTR is important in joining international agreements, in efforts to
standardize environmental management tools, and in making national environmental reports.
The United Nations Institute for Training and Research (UNTTAR) and the Mexican Government,
through the National Institute of Ecology, initiated a Pilot Study on the establishment of a National PRTR in
Mexico in 1994. In support of this pilot study UNITAR has developed a document entitled, "Guidelines for the
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Implementation of PRTR Pilot Studies." In addition, consultancy support was provided by the National Institute
of Ecology to assist in the preparation of a National PRTR Research Report entitled, "Assessment of the Mexican
Legal, Institutional, and Administrative Infrastructure Related to PRTR: A First Report."
The first step was selecting a national focal point. The focal point is the Mexican National Institute of
Ecology under the Secretary of Social Development. The Institute of Ecology develops and conducts Mexican
environmental policy. It is responsible for developing federal regulations and rules. It is also responsible for
integration of the air pollution emission inventories and hazardous waste management data files.
The second step was six informal meetings with representatives from government agencies, industry,
academia, and non-governmental representatives. At these meetings, traditional objections such as how
integration might occur, handling of confidential data, and legal changes were discussed. Agreement was reached
to conduct the pilot study.
Sixteen groups participate in the monthly meetings of a national coordinator group, which was set up
through a formal agreement The members include the National Water Commission, Secretary of Commerce
and Industry, Secretary of Foreign Affairs, Secretary of Health, Secretary of Social Development, National
Institute of Ecology, Federal Attorney for Environmental Protection, National Autonomous University of Mexico,
National Center for Disaster Prevention, the National Chamber for the Transformation of Industry, the National
Association of the Chemical Industry, National Council of Environmental Industrialists, Ecological Liaison, Civic
Committee on Ecological Disclosure, and the Border Environmental Education Project.
The next steps are a revision of the consultant's report, comments on the OECD's guidance, and
UNTTAR's Pilot Study Guidelines, exchange of information on PRTRs, and development of a PRTR Pilot Study
Workplan for 1995.
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1994 TRI Data Use Conference Partnership Track - Session 5
Session 5: Compliance Assistance, Enforcement and TRI
ftession Leader
Maureen Lydon, Deputy Director, Toxics and Pesticides Enforcement Division, Office of Regulatory
Enforcement, Office of Enforcement and Compliance, U.S. Environmental Protection Agency
Speakers
Jon Jacobs, Office of Enforcement and Compliance Assurance, U.S. Environmental Protection Agency
David Monsma, Environmental Action Foundation
Charlie Tebbutt, Western Environmental Law Center
Steve Tomfyaaavich, Minnesota Emergency Response Commission
Philip Wong, EPCRA 313 Regional Coordinator, U.S. Environmental Protection Agency, Region 10
This section explored the different enforcement tools being used to increase compliance with EPCRA
Section 313 TRI reporting requirements. U.S. Environmental Protection Agency representatives discussed the
distinction between compliance and enforcement in the new Office of Enforcement and Compliance Assurance.
U.S. EPA Regional representatives described how different kinds of Supplemental Environmental Projects are
being used in EPCRA Section 313 settlements. The role of citizen groups and how citizen suits can help increase
industry compliance with EPCRA reporting requirements was discussed by representatives from the Western
Environmental Law Center and the Environmental Action Foundation. A state representative focused on how
states can increase compliance with EPCRA without the threat of enforcement.
David Momma, Toxics Counsel, Environmental Action Foundation
Beyond TRI
The Toxics Release Inventory (TRI) data, collected under Section 313 of the Emergency Planning and
Community Right To Know Act or SARA Tide HI, continues to evolve in its public right-to-know and pollution
prevention mission. Because of the Pollution Prevention Act of 1990, the TRI now logically collects information
on recycling, energy recovery, treatment methods, and self-reported source reduction activity (Form R, Section
8). As EPA moves toward expanding the Inventory (Phase I - chemical expansion, Phase n - facility expansion,
and Phase HI - Chemical Use Inventory) and disseminating TRI data through new information technologies, new
questions arise about the purposes TRI serves.
Data use for TRI has been successfully linked to pollution prevention goals, and to a lesser extent, the
practice of source and use reduction. There have been appreciable reductions in TRI emissions, but this
reduction does not represent a trend leading away from the heavy industrial use of TRI chemicals. In some
cases, emissions have been cut but overall use remains steady or at slightly reduced levels. For many reporters,
TRI still acts like an end-of-pipe control rather than a pollution prevention tool to reduce or eliminate the use
of toxic TRI chemicals at the source. It is not clear whether the regulated community relies on TRI to achieve
source reduction goals or not.
Toxics use reduction and its perception is reliant upon the accuracy of the reporting data. To get an idea
of the accuracy of this data, Environmental Action conducted a case study on data submitted by a single industry.
Surveying 873 Form Rs for the years 1991 and 1992 filed by 14 PVC feedstock manufacturers revealed average
technical error rates for completing the forms accurately of 24% in 1991 and 26% in 1992. Moreover, our
assessment indicated that technical accuracy does not in any way assure full compliance, that source reduction
reports have no correlation to any reduction in waste, nor do they have any apparent accuracy, and the overall
reductions in waste related by EPA hi their TRI data reports were not borne out in this survey.
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Ibis data quality study is in no way definitive, but indicates a need to measure the accuracy of TRI data
as reported to U.S. EPA. Environmental progress claims based on TRI should probably be avoided and any
claims that are made by the U.S. EPA must be thoroughly evaluated and documented. Aggregating emissions
data and charting presumable reductions is not the best use or purpose of TRI. Rather, environmental progress
should be based on objective accounting criteria that measures real reductions in the use of chemicals of concern.
This is the rational basis for collecting materials accounting information. In the absence of collecting materials
use information, TRI will continue to be troubled with invalid environmental claims and the public will be less
informed than it should be.
The Toxics Release Inventory must be put to work acting on known risks. Environmental protection
programs such as TRI can ill-afforded to passively suggest environmental progress. The criteria for determining
the status of a TRI listed chemical communicates some baseline level of risk. This determination should alert us
to concerns about the continued use of particular TRI chemicals.
In this sense, TRI cuts across multi-media barriers without regard to specific control technologies or
performance levels. TRI acts as an effective preliminary screening tool toward limiting the production or use of
certain toxic substances that have been rationally determined to present environmental and health risks. The
logical next step to take in this evaluation is to determine whether individual TRI chemicals or classes of
chemicals present an unreasonable risk—unreasonable, not irrefutable. This is the articulated and legitimate role
of the Toxics Substance Control Act (TSCA), which has been quelled by Agency neglect, the Asbestos court
ruling, and unsuitable standards within the Act (e.g. "least burdensome alternative" & "substantial evidence"
restraints).
The future of TRI is now being driven by information technologies that provide innovative retrieval and
presentation tools. This creates new data users and broadens the public's right-to-know. The challenge for EPA
now is to advance the purposes of the TRI program and pollution prevention. This will be accomplished by
reconciling the Emergency Planning and Community Right-To-Know Act (EPCRA) with the Pollution
Prevention Act and the Toxics Substance Control Act (TSCA). These Acts are unnecessarily segregated by
purpose and operation.
The Pollution Prevention Act enunciates a principle that pollution ought to be reduced by avoiding its
creation. EPCRA helps focus attention on what chemicals should be avoided. The Toxics Substance Control
Act (although in need of correction) is the existing mechanism for ensuring that the production and use of the
most dangerous substances is limited. The potential interactive relationship between these Acts, however, is
thwarted by the absence of a commitment toward harmonizing their purposes and acting on known risks.
The Pollution Prevention Act supports but does not require pollution prevention, EPCRA documents
releases but not use, and TSCA is impeded by a lack of regulatory will to limit the production of bad chemicals.
Clearly, the Agency should seek to conciliate this process and drive toward a synthesis of regulatory purposes.
Moreover, the Agency must adopt a mature attitude about the fact that some toxic chemicals ought not to be
manufactured. Until source reduction and production limits are recognized as legitimate purposes of pollution
prevention, the Agency will continue to communicate risk but fail to act on it.
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Charlie Tebbutt, Western Environmental Law Center
Introduction
The importance of the Emergency Planning and Community Right-to-Know Act cannot be easily
exaggerated For the first time ever, citizens and the government have an idea about the volume of toxic wastes
that are constantly being dumped upon us all. Using the power of knowledge created by EPCRA, citizens have
forced industries into reducing use of toxic substances, both by community pressure and litigation; industries
have "voluntarily" reduced chemical use and/or releases into the environment out of fear of public outcry; and
legislative and regulatory entities have reshaped their agendas.
A More Holistic Approach
EPCRA TRI reporting has, among other things, been the catalyst for the Clean Air Act Amendments
of 1990, the Right-to-Know More activities in this country and numerous other national and international
pollutant inventories. Canada is now implementing a similar TRI program.
EPCRA has begun to close the loop on chemical usage through its multi-media reporting requirements.
For the first time, TRI analysis underscored the urgency of dealing with fugitive air emissions that have been
directly affecting workers on the line. The past compartmentalization of pollution into air, water and solid waste
is yielding to facility-wide focus. By viewing industrial polluters on a facility-wide basis, regulatory focus is
slowly shifting towards source reduction and other pollution prevention measures and away from traditional end-
of-the-pipe controls. Clearly, this more holistic focus is long overdue. Future regulatory emphasis must move
towards redefining BACT/MACT as pollution prevention rather than bigger, more complex, and more capital
intensive, end-of-the-pipe controls.
Citizen Action
Citizens have used the TRI and toxic substance storage information to leverage companies to become
better corporate citizens through direct communications, "Good Neighbor" processes and enforcement of
reporting violations. This discussion will focus on using citizen enforcement to achieve not only compliance,
but also pollution prevention commitments by violating facilities.
Atlantic States Legal Foundation, a not-for-profit environmental organization for whom I have been
counsel, has negotiated over twenty settlements with EPCRA violators which have included comprehensive,
long-term pollution prevention programs as major settlement requirements. Atlantic States has identified
facilities that have failed to report under sections 311,312 and 313 of the Act and used the citizen suit provision
of EPCRA to compel compliance and payment of civil penalties, in addition to pushing pollution prevention
programs. In lieu of higher civil penalty payments, violators have made payments to EPCRA related projects.
The project payments have, in large part, gone to Local Emergency Planning Committees, State Emergency
Response Commissions and HAZMAT teams. Monies have also gone to other third party entities to promote
local, regional and national right-to-know educational projects and campaigns.
Cooperation Among Citizens. States and EPA
Central to the effectiveness of EPCRA compliance tracking is the sharing of information between and
among agencies and citizens. With agencies being undersourced, citizen enforcement adds a critical element to
attainment of compliance both for non-reporters and inaccurate reporters. Citizens, however, generally do not
have the same ready access to information as do the agencies, ft is imperative for citizens to have access to Clean
Air Act, Clean Water Act, RCRA and EPCRA information in order to ferret out non-reporters and be able to
check the accuracy and completeness of facility reports. Agencies should work cooperatively with citizens to
inform them of the availability of various databases and make those information sources readily available. While
some antagonism naturally exists between agencies and citizens, achieving compliance is a shared goal that could
bridge some of the differences.
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Sharing information need not be a one way street. Citizens often discover problems that they either do
not have the resources to tackle or cannot feasibly pursue because of limited rights to inspect facilities. Working
from the citizen leads, agencies may be able to better document these leads and build stronger cases.
In certain cases, it may be advantageous for citizens and agencies to pursue joint enforcement actions.
Citizens can, and often do, take tougher environmental stands than agencies. Citizens also have more flexibility
in fashioning progressive settlement agreements. Agencies often feel constrained in their ability to go outside
their statutory or regulatory obligations. By working together, agencies may be able to provide much-needed
technical expertise while citizens can push for agreements with facilities that advance environmental protection
beyond compliance.
Conclusion
Getting more information in the hands of citizens through an expanded right-to-know program along
with more accessibility to the available databases will further the national movement towards the promotion of
pollution prevention.
Steve Tomlyanovich, Minnesota Emergency Response Commission
TRI Data Quality Assurance Project
Introduction
The office of the Minnesota Emergency Response Commission (MERC), as part of the Department of
Public Safety, is responsible for implementing the Emergency Planning and Community Right-to-Know Act in
the state. The Emergency Response Commission itself is made up of 22 members which include representatives
of fire, law enforcement, medical services, business and industry, labor, community groups, and citizens. The
Commission was established in Minnesota Statutes through enactment of the Minnesota Emergency Planning
and Community Right-to-Know Act in July, 1989. This state statute also gave the MERC specific inspection
and enforcement authority.
In 1991, the Minnesota Emergency Response Commission (MERC) received a grant from the U.S. EPA
to conduct a TRI data quality assurance project The grant focused primarily on identifying facilities which failed
to report their toxic releases and transfers on EPA Form R, and on enhancing the quality of the data submitted.
Both of these factors were critical to ongoing activities in the state. The project was developed to create a
framework for future compliance with technical assistance efforts that will be components of information
processing and pollution prevention programs within the MERC and other state agencies.
Databases/Other Source Review
MERC staff reviewed a number of possible databases and information sources to identify potential
non-reporters. These included:
National Enforcement Information Services Center (NEISC)
The MERC contacted the U.S. EPA's NEISC and requested a data sort. The sort identified facilities in
the state which had never reported under Section 313, had 10 or more full-time employees, were included in SIC
Codes 20XX through 39XX, and had been assigned a Dun and Bradstreet Number. The NEISC provided the
MERC with a computer printout listing approximately 3400 facilities which met all of the above criteria. Upon
review of the printout, staff eliminated for consideration those facilities which it believed were not likely to meet
the applicable usage thresholds. Examples of facilities deleted from the listing included small printing operations,
machine shops, and metal fabricators. This source was used to identify 63 non-reporters.
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Minnesota Directory of Manufacturers (MDOM)
The MDOM lists several thousand manufacturing facilities in the state. It identifies these facilities by
location, SIC Code, and number of employees. Staff used the directory to compare current reporters with
non-reporters in the same SIC Code. This source was used to identity 37 non-reporters.
Section 312 Reports
Facilities storing Extremely Hazardous Substances (EHS) at 500 pounds or the Threshold Planning
Quantity, whichever is less, must file reports with the MERC and the local fire department. In addition, a facility
must file if they store 10,000 pounds or more of a chemical for which they are required to have or prepare a
Material Safety Data Sheet under the Hazard Communication Standard. Section 312 data assisted staff in
identifying some Section 313 reporters, however, some commonly used chemicals are not found on the EHS list.
For example, Xylene and Toluene are not on the EHS list and are not likely to be stored at the 10,000 pound
threshold. Correlation between on-site storage and annual usage information can often be difficult. This source
was used to identity 14 non-reporters.
Hazardous Waste Inventory
The Hazardous Waste Division of the Minnesota Pollution Control Agency (MFCA) maintains a
computer database consisting of all licensed hazardous waste generators in the state. The MERC requested a
printout of all generators included in SIC Codes 20XX through 39XX. This disclosure included facility
identification information, along with the type and volume of waste generated per calendar year.
The amount of a Section 313 chemical reported by a facility as being transferred off-site is based only
on the percentage of that chemical in the entire waste stream. In contrast, hazardous waste may include water,
other chemicals, and impurities. Therefore, a direct correlation between the amount of a hazardous waste
generated and Section 313 chemical usage cannot be made. For this reason, it was often difficult to determine
whether a facility would be required to report under Section 313. Even though volumes cannot be compared,
the generator list does give an indication of which Section 313 chemicals are being used at a facility. This source
was used to identify 7 non-reporters.
Air Emission Inventory
The Air Quality Division of the Minnesota Pollution Control Agency maintains a database of all point
source emitters in the state exceeding the threshold of twenty-five tons per year of Volatile Organic Compounds
(VOC). Facilities exceeding this threshold must submit an annual criteria pollutants emission inventory to the
MPC A Emission Inventory Point Source System. Using this system, the MFC A retrieved all facilities included
in SIC Codes 20XX through 39XX, with VOC emissions at five tons or greater and not listed in the 1988 and
1989 state TRI annual reports. Since all VOC's are aggregated together for permitting, it is difficult to determine
the actual emissions of a specific Section 313 chemical. This source was used to identify 6 non-reporters.
Miscellaneous
A small number of facilities were surveyed based on information received from other state and county
agencies and the general public. These sources were used to identify 1 non-reporter.
Voluntary Submittals
During the course of the grant project, fourteen facilities which were not surveyed, reported for the first
time. We believe that this was a direct result of our outreach efforts.
Survey Process
A brief cover letter, survey, and Section 313 Toxic Chemical List was sent to approximately 1500
facilities identified as being potential non-reporters. The survey asked the facility if they met the employee, SIC
Code, and chemical usage criteria which may require them to file an EPA Form R.
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Results
By the end of the grant project, 165 facilities indicated through the survey that they met all of the criteria
for reporting. Through technical assistance provided by MERC staff, 142 of these facilities filed an EPA Form
R during the period of the grant project. The remaining 23 came into compliance as a result of an EPA
Enforcement Grant the MERC received from the U.S. EPA in 1992.
The 142 reporters represented 16 different SIC Codes. They submitted 268 Form R's covering 44
different chemicals and chemical categories. The total quantity of reported releases and transfers was 3.6 million
pounds, 2.8 million of which was stack and fugitive air emissions.
Conclusions
The Data Quality Assurance Project allowed the MERC to identify and obtain compliance from facilities
which had never reported in the state. Temporary staff hired during the grant period, allowed the MERC to
contact a large number of faculties in a timely manner. Not only were these additional facilities brought into
compliance, but through technical assistance, we were able to achieve good data quality.
A close working relationship with the regulated community can greatly enhance compliance rates and
ensure data quality. This excellent rate of compliance continues today. For example, during the last three
reporting years, the MERC has had a 100 percent response rate from known reporters. In other words, the
facility has submitted a Form R or a letter indicating they are no longer subject to the reporting requirements.
The MERC does have enforcement authority under the state Act. To date, we have not issued any civil penalties
under Section 313 of the state Act.
State staff does cooperate with U.S. EPA in its compliance and enforcement efforts within the state. This
includes providing facility specific information to U. S. EPA inspectors and accompanying them on data quality
and compliance inspections.
D
Philip Wong, TRI Coordinator, U.S. EPA Region 10
James Pearson, Environmental Engineer, U.S. EPA, Region 10 and
James Stkor, Pollution Prevention Technical Specialist, U.S. EPA, Region 10
Review of Supplemental Environmental Projects
Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), known as the
Toxics Release Inventory (TRI), is a requirement for the reporting of chemical releases and transfers by certain
facilities. The present regulations require that manufacturers with more than ten employees who manufacture,
process or otherwise use more than threshold amounts of specified chemicals report their releases and transfers
on EPA Form R. The list of chemicals subject to reporting and the types of facilities which must report are being
revised and expanded to increase the level of information available to the public.
Failure to report as required may subject a noncomplying company to administrative actions including
the payment of penalties. Typically, in settling penalties, Environmental Protection Agency (EPA) permits the
penalties to be mitigated when a respondent agrees to perform an action which provides some tangible
environmental benefit. Such actions are called Supplemental Environmental Projects (SEPs).
A project was undertaken in Region 10 to evaluate the SEP process. 55 TRI settlements with SEPs in
Region 10 were reviewed during the summer of 1994. No comprehensive review or audit of SEPs had previously
been conducted. The goal of the project was several-fold: to gather information as to the effectiveness of the SEP
process; determine which types of SEPs were the most effective; review which industries and processes were
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amenable to pollution prevention; examine the long term gains available through pollution prevention; and
discover difficulties in implementing pollution prevention.
To the extent that pollution prevention is accomplished as a result of the implementation of SEPs, the
process should be considered successful. Not surprisingly, all facilities visited agreed that the SEP process is a
more equitable way of encouraging compliance with environmental regulations than simply to assess and collect
a penalty.
More than half of the SEPs were deemed to have actually resulted in environmental benefits as measured
by TRI releases and transfers. Other environmental benefits were accrued but are not discernable through TRI
data Some successful SEPs included process changes which also resulted in decreased use of and dependence
on chemicals which would not be reflected in the Form R. Many SEPs have inherent value but simply cannot
be quantified (i.e., environmental audit, chlorine alarm system, appointment of environmental coordinator).
A wide cross section of industries and SEPs were involved the project. The industries and processes
most amenable to pollution prevention were those having a using coatings and solvents in their process. The
key to success in this area is certainly the availability of suitable alternatives and widespread use.
Types of SEP's No.
Substitutions for Solvents
- Aqueous (subst. for Trichloroethylene) 2
- Aqueous (subst. for Dichloromethane) 2
- non CFC Cleaners 2
- Dibasic ester (subst. for acetone) 1
- Mechanical cleaning 2
- Caustic tank (for TCE vapor degreasing) 1
HVLP/ high efficiency sprayers for coating 11
Powder coating bake oven and spray booth 3
Water based coating systems 2
Solvent recovery still 10
Installed new bulk storage tank 2
Installed sulfuric acid recovery system 5
Mechanically cleaning foam machine 2
Environmental Coordinator 4
Installed recycling center for oil/metal chips 1
Installed chlorine gas alarm system/auto shutoff 1
Installed Dust Collection System 3
Conducted Environmental Audit 1
Nutrient chemical reduction 1
Caustic wash recycle 1
Cooling water recycle 1
There were many difficulties discovered in accomplishing pollution prevention through the SEP process.
The types of problems encountered can include insufficient capital, lack of dependable information and
experience with new products, an entrenched production culture, and inadequate training. The potential for
successful pollution prevention within the groups varies by facility, and requires a flexible and supportive
management which is receptive to the need for change.
* Complete text of this report will be available from the authors in March, 1995.
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Session 1: Risk Targeting and Screening Using TRI
Session Leader
Margaret Round, Program Analyst, Northeast States for Coordinated Air Use Management
Speakers
Michael J. DiBartolomeis, Ph.D., Chief, Pesticide and Food Toxicology Unit Office of Environmental
Health and Hazard Assessment, Col/EPA
Dr. Debra L. Forman,^4/r, Radiation and Toxics Division, U.S. Environmental Protection Agency,
Region III
Gregg Recer, Center for Environmental Health, New York State Department of Health
Amit Sachdev, Counsel, Chemical Manufacturers Association
Margaret Round, Program Analyst, Northeast States for Coordinated Air Use Management
The focus of this session was to present a variety of innovative approaches used by state and federal
agencies and private industry to analyze TRI data to determine potential public health impacts, and efficacy of
existing methods for regulatory decision making.
Dr. Michael DiBartolomeis discussed the implication for environmental priority-setting using TRI data
for identifying target populations at risk in California. An approach for using TRI data in the risk-ranking part
of the California Comparative Risk Project, sponsored by the California Environmental Protection Agency,
provided an innovative approach in formulating environmental policy and future strategies. Taking into account
exposure of toxic discharges (specifically, air emissions from selected manufacturing facilities) to population
subgroups within a defined geographical area, the project investigated whether exposure is unevenly distributed
among racial and economic groups in California Using an EPA derived measure, the project illustrated how per
capita air pollutant loading varies across different subpopulations, defined in terms of their race or economic
class. For a number of environmental threats defined in the project, potentially hazardous exposures to some
pollutants were found to be concentrated in certain geographical areas in California. Noting the preliminary and
uncertain nature of this analysis, the project found that groups with different income levels do not appear to
experience substantially different TRI air pollutant loading, although there was a trend toward a decrease as
annual incomes exceeded $75,000. In contrast, the data seem to indicate that African American and Hispanic
subpopulations experience higher loading of TRI air pollutants than Caucasians, Asians, or American Indians.
However, the statistical significance of these results cannot be ascertained. The challenge in using TRI data is
to evolve and expand data collection to fill gaps in knowledge and collect data that are more applicable to risk
assessment. Risk assessors must develop methods that incorporate geographical and population-specific data
on toxic releases to define the distribution of risk across population subgroups.
Dr. Debra Forman presented an overview of the U.S. EPA Regional Approaches to Hazard Screening
that are used in numerous applications including resource prioritization and pollution prevention targeting. This
iterative process focuses on hazard identification and dose-response. The first phase of the screening process
produces the Chronic Index which describes chemical releases in terms of relative toxicity using TRI data The
results of the Chronic Index are aggregated by facility, chemical and geographic grids. Phase n of the projects
included development of the Vulnerability Index which describes the susceptibility of populations by scoring
population demographics including age, economic status and minority status. With this information, a decision-
maker may determine if additional information is warranted with regard to the exposure population, set of
chemicals or industrial groups within the grid. In this way, opportunities for pollution prevention as well as
resource intensive exposure and risk assessments may be pursued in sectors of greatest interest.
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Greg Recer, from the New York State Department of Health, presented the findings of the state-wide
screening study using TRI data to identify those facilities and chemicals most likely to have significant adverse
public health impacts for priority setting. The risk screening protocol was developed as part of a project in which
TRI data were combined with environmental, toxicdogjcal, geographic and demographic data to enable the DOH
to better assess health risks and patterns of disease. The ranking of all NYS TRI facilities was done by deriving
a risk-screening score for each facility based on both the quantity of air emissions reported and toxic potency of
each chemical. The results found that inorganic chemical emissions, particularly chromium and arsenic
compounds, predominated among those facilities ranked at the top of the carcinogen-based ranking. Conversely,
respiratory irritants such as hydrochloric acid and chlorine dioxide were the predominant chemicals emitted by
the highest ranking facilities in the non-cancer ranking. These results contrast strongly with the predominant
chemical emissions among the highest-ranking facilities based solely on emissions quantity, which were
primarily organic solvents. Again, DOH cautions on the interpretation of these results in light of the
uncertainties in exposure estimates which assumes that exposure is directly related to emission quantity,
accuracy of the data, and inability to distinguish between stack and fugitive emissions, since both are reported
under the TRI. Uncertainties also arise from the chemical's toxicity assessment and gaps in the toxicology
database. However, despite these limitations, risk-screening of TRI data allows new information to be extracted
about TRI facilities and emissions which would not be allowed by considering total chemical emissions. The
results also emphasize the need to carefully evaluate health effects from non-carcinogenic compounds such as
respiratory irritants.
Amit Sachdev of the Chemical Manufacturers Association (CMA) discussed improving the use of TRI
data for risk communication. CMA believes that TRI has gone a long way in meeting the statutory requirement
to provide information about releases that could be useful in allowing the public to better understand and make
decisions about the potential hazards that may be posed by those releases. However, only recently has EPA, the
business community, and the public, begun to consider how to more effectively communicate this potential
hazard based on the raw data As a result the TRI program scores poorly as a risk communicator because it treats
all listed chemicals as equally toxic, does not rank or prioritize decision-making based on risk, and does not
provide information on toxicity or relative risks posed by the listed substances. In order to make TRI a more
effective risk communicator, EPA could provide information in the database that the public can use for risk-based
decision-making. This information could include, for example, relative risks posed by the listed chemicals, type
of harm posed, routes of exposure and affected media and degree of certainty associated with this information.
CMA recommended that EPA establish community advisory panels in order to better assess public data needs
and aggressively explore new models for adapting TRI to provide the public with information not only about
releases, but also risk.
The major issue raised during the question/answer period was how CMA reconciles the recommendation
to expand the information available to the public to improve risk communication and the position presented the
previous day regarding withholding of information to protect trade secrets.
D
Michael J. DiBartolomeis, PhJX, Chief, Pesticide and Food Toxicology Unit Office of Environmental
Health and Hazard Assessment, Col/EPA
Using TRI Data for Identifying Target Populations at Risk: Implications for Environmental
Priority-Setting
California recently completed a "comparative risk project" spanning two and one-half years that
examined the State's environmental decision-making process and its environmental priorities.1 This project,
sponsored by the California Environmental Protection Agency, was intended to help the Agency shape its
environmental protection strategies for the future. Although several states and the U.S. Environmental Protection
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Agency (U.S. EPA) had found that ranking risks was usefiil for focussing on the most important environmental
issues, the majority of participants in the California project were skeptical that environmental priorities should
be set on the basis of risk alone. In part, this concern was driven by the realization that the current practice of
risk assessment has several important methodological shortcomings.
As one of its objectives, the California Comparative Risk Project (CCRP) determined that some
questions raised in California and nationally concerning the current practice of using comparative risk analysis
(and risk assessment) for priority-setting should be addressed and evaluated. To manage this task, the CCRP
was uniquely organized into three parts: 1) a ranking of environmental threats according to impact on (or risk
to) human health, ecological health, and social welfare; 2) a critique of the risk-ranking model and an evaluation
of other decision-making models; and 3) overall recommendations for environmental priority-setting by
integrating the results of the first two components. Because the CCRP evolved this approach early on, several
innovative ways to address priority-setting emerged at the completion of the project. A possible approach for
using TRI data in risk-ranking is briefly described here.
One major shortcoming of comparative risk analysis is that the results of a ranking exercise are typically
"total population-based" Previous comparative risk projects were grounded in the assumption that risks ought
to be ranked unidimensionalK/ in a way that reflects only the magnitude of their impacts on society as a whole.2
That is, standard comparative risk methodology averages risk over an entire population, rather than focussing
on individual or subpopulation risk. The use of aggregate statistics and a population burden of risk tends to
erroneously characterize a population as homogeneous in ethnicity, age, gender, income, and health status, and
ignores the significance of "toxic hot spots," or locations where multiple exposures and compounding risks occur.
Furthermore, the use of only total population as a measure of risk masks high individual risks, and ignores how
they are distributed. To complement the conventional emphasis on total population impacts in comparative risk
projects (i.e., threats are ranked high only when a large number of people are exposed), the CCRP considered
information about population distributions when identifying environmental hazards. Therefore, in the CCRP,
environmental threats might also rank high when relatively few people are exposed to very high levels of
toxicants.
To help address the issue of environmental protection inequities, the CCRP Human Health Committee
(HHC) adopted a "distributional" approach to risk assessment which facilitates describing how risk levels vary
across individuals in a population because of either exposure patterns or increased susceptibility to pollutant
effects. The HHC, which was charged with ranking risks of environmental threats to human health, and the
Environmental Justice Committee, which helped critique the risk-ranking process and explore other
priority-setting models, worked cooperatively to describe die concept on which the methodology was based. That
is, by relating total toxic discharges to population subgroups within a defined geographical area, an exposure
map can be developed on which to assess and compare human health impact for each environmental threat. The
concept of relating environmental exposure data to individuals in specific geographical areas may not be novel,
but its application to environmental priority-setting has not yet been fully developed.
Population subgroups can be defined by any number of parameters as noted above. Environmental
justice activists have identified race and income as two important markers for environmental inequities.
Therefore, to examine whether the environmental loading of pollutants is unevenly distributed among
subpopulations, the HHC conducted a statistical analysis of statewide TRI air emissions to characterize the
average per capita air pollutant loading for different racial and economic groups in California The analysis was
limited because data were only available on air emissions from selected manufacturing sources, while it is clear
that emissions from mobile sources would also likely to be inequitably distributed. Land and water releases of
toxicants could also be used if data are available.
It is also important to emphasize that for some people, health effects might be experienced at lower doses
than those causing responses in the general public. In an effort to evaluate potential impacts on such susceptible
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subpopulations, the HHC identified groups known to be at heightened risk due to specific toxic substances and
collected exposure information on these groups whenever possible (e.g., number of asthmatic children exposed
to criteria air pollutants). However, relating geographical distribution of these susceptible subpopulations with
manufacturing releases was presumed to be very difficult because of unavailability of data, and was not attempted
during the CCRP. Nevertheless, the HHC did identify qualitatively two characteristics of more susceptible
populations, that is, health status (e.g., preexisting disease) and exposure considerations (e.g., activity patterns).
The HHC used a measure developed by the U.S. EPA called the Population Emissions Index (PE1)3 to
illustrate how per capita air pollutant loadings vary across different subpopulations, defined in terms of their race
or economic class. The PEI is the result of dividing the sum of the amount of toxicants released in a geographical
area with members of a defined subgroup by the sum of the number of members in that population subgroup.
If toxic releases (or put another way, enforcement of environmental protection) were equitable, all groups would
have the same PEI regardless of the parameter in question (in this case race or income). General information
about the age, race, and gender distribution of the California population was based on 1990 census data When
possible, census tract levels were used rather than zip code levels in order to obtain better geographical definition
of pollutant loading.
The PEI should only be considered a surrogate measure for examining whether pollutant exposures or
pollution-related health risks vary across population subgroups3. To interpret the PEI as a measure of potential
health risk from exposure to air pollutants, it is necessary to make several simplifying assumptions: 1)
concentrations of toxicants that people are exposed to are directly proportional to the amount reported released,
and 2) all individuals in a given area will be exposed to the same concentration of an emitted toxicant,
independent of the number of exposed individuals in an area or any differences in their activity patterns (e.g.,
sedentary versus exercising). Both of these assumptions can be challenged, but until air pollutant monitoring
systems can provide spatially-refined ambient concentration data, analyses of distribution of risk across
population subgroups must rely on pollutant loading data.
For a number of environmental threats defined by the CCRP, the HHC found that potentially hazardous
exposures to some toxicants are concentrated in certain geographical areas of California4. Specifically for air
pollutants, and selecting for individual race and economic status, the results of the preliminary HHC analysis
indicate that groups with different income levels do not appear to experience substantially different TRI air
pollutant loadings, although there was a trend toward a decrease in PEI as annual income levels exceeded
$75,000. In contrast, the data seem to indicate that African American and Hispanic subpopulations experience
higher loadings of TRI air pollutants than Caucasians, Asians, or Native Americans. However, the statistical
significance of these results cannot be ascertained because of the high level of inherent uncertainty of the
population and emission data.
Because of the preliminary and uncertain nature of this analysis, and the general unavailability of data
for specific releases of toxicants in a given geographical area, these results were not included in the final
risk-rankings of the CCRP. Nevertheless, several recommendations for improving the database and
methodology, for enforcing environmental protection laws equitably, and for incorporating the concept of
disproportionate burden of risk into environmental decision-making received consensus approval.
There are a number of important limitations to using TRI data alone to identify areas and populations
that may be experiencing high pollutant exposures and resulting health risks: 1) the location of emissions and
resultant exposures may not always correlate; 2) pollutant loading analyses do not take into account the toxicity
of different compounds in the release; 3) occupational exposures would be ignored; and 4) TRI data are limited
to the scope of its reporting requirements and the number of chemicals, although the impending expansion of
TRI reporting will help to increase the usefulness of the data. Eyen acknowledging these limitations, the CCRP
concluded that using TRI data and the distributional analysis approach to risk assessment, a number of
interesting hypothesis about the distribution of health risks can be examined.4
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The challenge for TRI practitioners it to evolve and expand data collection to fill gaps in knowledge,
make data more readily accessible and user friendly, and most importantly, collect data that is directly applicable
for risk assessment and priority-setting. Risk assessors must develop methods that incorporate geographical and
population-specific data on toxic releases to define the distribution of risk across population subgroups.
Identification of hot spots, or areas of cumulative risk, would be one benefit of this type of analysis which can
ultimately lead to more equitable environmental decision-making and enforcement.
End Note$
I California Comparative Risk Project (1994). Toward the 21st Century: Planning for the Protection of
California's Environment.
2. California Comparative Risk Project (1994). Toward the 21st Century: Planning for the Protection of
California's Environment, Report of the Environmental Justice Committee, pages 233-254.
3. Bois, P., Pease, W., Morello-Frosch, R., Flatt, S., and Hanna, S (1994). An Assessment of Environmental
Equity in California. Presented at NIEHS Environmental Justice Symposium, Research Triangle Park, NC,
2/10/94.
4. California Comparative Risk Project (1994). Toward the 21st Century: Planning for the Protection of
California's Environment, Report of the Human Health Committee, pages 73-138,
D
Dr. Debra L. Forman,Air, Radiation and Toxics DMiion, Region III, Philadelphia, PA.,
Solomon Pollard, Water Division, Region IV, Atlanta, GA., and
Dr. Gerald Carney, Office of Policy and Management, Region VI, Dallas, 7%
U.S. EPA Regional Approach to Hazard Screening
The U.S. EPA Regions IE, IV and VI are currently developing a universal process for Hazard Screening
for use in numerous applications, including resource prioritization and pollution prevention targeting. The
process is iterative, based on the first two steps of the National Academy of Sciences risk assessment paradigm:
hazard identification and dose response. As a result, the process provides critical decision points for
consideration by risk managers. The first phase of the screening process has been developed by Region ffl and
produces the Chronic Index which describes chemical releases in terms of their relative toxicity. The Chronic
Index is based on a combination of TRI emissions data and an estimate of relative dose, rather than an ordinal
or categorical scoring system. This approach produces a continuous distribution of toxicity-weighted chemical
releases and preserves the mathematical intervals within the original data sets.
The Chronic Index is based on the best available scientific information, thus, the selection of toxicity
data is commensurate with the most rigorous level of peer review. The system primarily utilizes the EPA's
Integrated Risk Information System (IRIS) and Health Effects Assessment Summary Tables (HEAST),
Secondary sources of toxicity information include provisional factors derived by the EPA's Environmental
Criteria and Assessment Office (ECAO) and studies performed by the National Toxicology Program. The results
of the Chronic Index are aggregated by facility, by chemical and within 8x8 mile geographic grids. The
geographic representation is independent of political boundaries and permits evaluation of cumulative hazard.
Refinement of the grid to 1 x 1 mile may be performed for specific areas of concern. Details of the derivation of
the Chronic Index are presented in Region Ill's Technical Guidance Manual.'
Phase n of the process includes the Vulnerability Index developed by Region VI, which describes die
susceptibility of populations by scoring critical attributes. Population demographics are presented in terms of
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1994 TRI Data Use Conference Innovative Uses Track - Session 1
age, economic status, and minority status. Areas of concern are delineated and, for each variable, an average
value is calculated and compared to the state average.
With the information from Phase I and n, the decision maker may determine if additional investigation
is warranted either in more narrowly defined geographic areas or with a more focused set of chemicals or
industrial groups. In this way, opportunities for pollution prevention as well as resource intensive exposure
assessments, risk assessments, and epidemiological studies may be pursued in sectors of greatest concern.
Region IV has emphasized the requirement for clear communication of the indexing process to diverse
audiences, providing distinctions between the concepts of hazard and risk as well as indexing and assessment.
In particular, community involvement is encouraged in an effort to foster cooperation in implementing specific
strategies for targeted communities.
This iterative indexing process provides a standard method for screening TRI release information for
relative hazard, permitting decision-makers to focus resources on the most toxic chemicals and most vulnerable
populations. In addition, the regionally based GIS maps are used to explore opportunities for pollution
prevention among the SIC codes governed by the Emergency Planning and Community Right to Know Act
(EPCRAft313).
End Notes
1. US. EPA (1993) Chemical Indexing System for the Toxic Chemical Release Inventory, Part I: Chronic Index,
Region ffl Technical Guidance Manual, Risk Assessment, EPA/903/R-93/002.
a
Gregg Recer, Center for Environmental Health, New York State Department of Health
Thomas Johnson, Center for Environmental Health, New York State Department of Health
Ride Screening In New York State Using Toxic Release Inventory Data
Introduction
There is a large variety of industrial chemical emissions from a large number of facilities which could
have the potential to adversely impact public health in New York State (NYS). A statewide screening procedure
to identify those facilities and chemicals most likely to have significant adverse public health effects would help
avoid expending limited resources on relatively unimportant chemical emissions. The Toxic Release Inventory
(TRI) database, although not a comprehensive compendium of all chemical-emissions data in the state, does
identify emissions from most large manufacturing facilities to all media and provides a data set collected in a
uniform manner across the state. Therefore, the TRI data appear well suited for use in the development of a
statewide risk-based screening protocol.
We have developed such a risk-screening protocol, utilizing TRI air-release data, to produce relative
public-health risk rankings for facilities and chemicals in New York State. This protocol was developed as part
of a project in which TRI data were combined with environmental, toxicological, geographic and demographic
data to enable us to better assess health risks and patterns of disease (NYSDOH, 1994). The screening
procedure combines TRI air-emissions data with toxic potency data in a quantitative manner to produce risk-
based rankings of industrial facilities in New York State which could be used to focus risk assessment and
pollution prevention activities on the facilities and chemicals in the state with the greatest potential for adverse
public-health impact.
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Methods
NYS TRI air-emissions data reported to U.S. EPA for 1989 were used in the development of the risk-
screening methodology. The ranking of ail NYS TRI facilities was established by deriving a risk-screening score
for each facility. The facilities were then ranked based on their screening scores. The score was developed to
reflect both the quantity of chemical air emissions reported by each TRI facility and the toxic potency of each
chemical. In particular, the score was derived to be directly proportional to both emission quantity and toxic
potency, giving equal weight to these two measures
A database of chemical toxic potency values was developed for use in the derivation of screening scores.
One-hundred and fifty-eight chemicals or chemical classes were reported among 1989 NYS TRI air emissions.
A toxicdogical potency assessment was developed for each TRI chemical based largely on previously developed
health-based criterion values — primarily Cancer Potency Factors and Reference Doses/Concentrations found
in U.S. EPA's Integrated Risk Information System (IRIS; USEPA, 1992a). Values for cancer and non-cancer
end points were obtained for each chemical. A brief list of health effects associated with exposure to each
chemical was also developed.
TRI facilities were ranked in order of decreasing screening score. Rankings were produced for three
different endpoint classes. One ranking was based only on carcinogen emissions reported in the database. The
second ranking was based on all non-cancer endpoints. Facilities were also ranked using a hierarchical rule for
combining both cancer and non-cancer endpoints.
This risk-screening process has features in common with the U.S. EPA Risk Screening Guidelines
(USEPA, 1989). However, the risk-screening method developed for this project employs quantitative
characterizations of chemical air emissions and toxicity while the U.S. EPA risk-screening process uses a
qualitative approach to characterize these variables.
Results & Discussion
Some unexpected results were obtained when the risk rankings were examined. Inorganic chemical
emissions, particularly chromium and arsenic compounds, predominated among those facilities ranked at the top
of the carcinogen-based ranking. Emission quantities for these chemicals were generally quite low, with most
below 1000 Ibs./year, but the chemicals had very high cancer potencies. Conversely, respiratory irritants such
as hydrochloric acid and chlonne dioxide were the predominant chemicals emitted by the highest ranking
facilities in the noncancer ranking. These chemicals have relatively low noncancer toxicity but were often emitted
in very large quantities. Chemicals from both of these classes appeared among the highest ranked facilities in
the combined-endpoint ranking. These results contrast strongly with the predominant chemical emissions
among the highest-ranking facilities based solely on emissions quantity, which were primarily organic solvents.
The public-health implications of these results should be interpreted with caution. It is easy to assume
that the highest-scoring emissions have significant potential to affect public health. However this ranking
method does not include an estimate of individual exposure. Instead, we have assumed that exposure is directly
related to emission quantity. In fact, emissions from even the highest-scoring facilities may not be sufficiently
large to result in significant exposure to nearby populations. Moreover, this analysis does not distinguish
between fugitive and stack air emissions, both of which are reported under the TRI. Whether a particular
chemical release is a fugitive or stack emission can strongly affect the degree of exposure nearby populations
experience from that release. In principle, mis analysis also does not differentiate between continuous or regular
emissions and infrequent releases. However, the TRI is intended to provide information on routine or continuous
chemical emissions rather than accidental releases, so these results speak more to the former situation.
The accuracy of the rankings is clearly dependent on the accuracy of the TRI emissions data and the
toxicity information. The TRI program only requires emissions reporting from certain types of industrial facilities
handling sufficiently large quantities of a limited number of chemicals (roughly 300). Therefore, any statewide
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1994 TRI Data Use Conference Innovative Uses Track - Session 1
ranking of facilities or chemicals based only on TRI reporting will exclude consideration of some facilities and
chemicals in the state. Much of the TRI air-emission data is based on engineering estimates which may vary
considerably in quality among facilities and chemical processes. Stack-emission and fugitive-emission estimates
may differ in reliability, and facilities differ in the proportion of their emissions which are fugitive. Data-entry
errors were common in the geographic component of the TRI database (NYSPMRI, 1993) although the majority
of these errors were transpositions of latitude and longitude and, therefore, an error type unique to this data field.
Uncertainties in a chemical's toxicity assessment result from gaps in the toxicology database and from
assumptions made concerning dose-response, species and exposure-route extrapolations. The inherent
uncertainty in the toxicology information has been characterized and is taken into consideration by U.S. EPA
in their derivation of the toxicity values (i.e., CPF and RfD) which were emphasized in construction of the toxic
potency database. For non-cancer effects, the comparisons of toxic potency based on RfDs or RfCs is strongly
influenced by the wide range in uncertainty factors used to derive these criteria. The toxic potency assessment
of chemicals with relatively sparse toxicology databases may be artificially inflated because such chemicals will
generally have a 1000-fold or 10,000-fbld uncertainty factor. Establishing non-cancer criterion values based
either on no-observed-effect- or lowest-observed-effect-levels (NOEL or LOEL), combined with type and severity
of effect (e.g., USEPA, 1992b) or on a benchmark-dose approach (e.g., Crump, 1984) might improve the
comparability among chemicals in a non-cancer ranking.
Despite the limitations noted above, the risk-screening work described here has shown that including
toxicity information along with the chemical air-emission data available in the TRI database allows new
information to be extracted about TRI facilities and TRI chemicals which would not have been identified by
simply considering total chemical emissions. In particular, our results suggest the need to more carefully evaluate
the potential for health effects from both noncarcinogenic compounds such as respiratory irritants and from small
emissions of very potent inorganic carcinogens such as chromium and arsenic compounds. Further refinements
of the general approach used in this project, particularly developing rankings for more specific toxicotagical
endpoints, should increase the usefulness of TRI risk-screening for directing more detailed investigations.
References
Crump, K.S. 1984. A new method for determining allowable daily intakes. Fund. Appl. Toxicd. 4:854-871.
New York State Department of Health (NYSDOH). 1994. Applications of Toxic Chemical Release Inventory
Data in Risk Screening, Health Studies and Geographic Information Systems. Final Report. Center for
Environmental Health, Albany, NY.
New York State Paries Management and Research Institute (NYSPMRI). 1993. Locational verification and
correction of 1989 New York State TRI Facilities. Final Report
United States Environmental Protection Agency (USEPA). 1989. Toxic Release Inventory. Risk Screening
Guide, Yds. 1 and 2. USEPA 560/2-89-002.
United States Environmental Protection Agency (USEPA). 1992a, Integrated Risk Information System (IRIS)
On-line.
United States Environmental Protection Agency (USEPA). 1992b. Health effects and dose-response assessment
for hydrogen chloride following short-term exposure. Air Risk Inform. Supp. Cntr. USEPA 450/3-92-003
D
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Innovative Uses Track - Session 1 1994 TRI Data Use Conference
Kathleen Kwatr, Assistant General Counsel, Chemical Manufacturers Association
Amit Sachdev, Counsel, Chemical Manufacturers Association
The Right to Know about Risk: Improving the TRI
Introduction
The Toxic Release Inventory (TRI) was created by the Emergency Planning and Community Right-to-
Know Act of 1986 (EPCRA). EPCRA Section 313 mandated EPA to create a public information database
containing annual data on emissions of toxic chemicals which meet the appropriate criteria and are designated
on the TRI list Since its inception, the TRI program has been hailed as one of the most successful environmental
regulations to date. Facilities subject to TRI reporting have accomplished dramatic reductions in listed emissions.
Because of its past success, there has been added pressure and activity to expand the TRI program in various
different directions, including increased chemical and facility coverage. This presentation briefly examines the
TRI program and focuses on how it can be more effective as a tool for improving risk communication, hi order
for the TRI to be successful, it must offer concise, understandable data about the risks posed by "toxic"
emissions.
The TRI Program
The TRI was established by EPCRA Section 313 in 1986 to inform the general public and communities
surrounding covered facilities about releases of toxic chemicals. The TRI was not explicitly designed to
communicate risk information. Rather, the database provides information about releases that could be useful in
allowing the public to better understand and make decisions about the potential hazards that may be posed by
those releases. In this manner, the TRI has gone a long way to satisfy a community's right-to-know about
releases, but has yet to develop into an effective risk communication tool. While the existing TRI program
provides the public with raw data about releases, only recently has EPA, the business community, and the public,
begun to consider how to make the TRI a more effective risk communicator.
The TRI Program Presently Scores Poorly On Risk
Effective risk communication can help decision-makers to identify and assess potential hazards, to set
priorities, and to take steps to manage and reduce the risks that may be associated with those hazards. Carol
Browner recently stated that a goal of TRI expansion is to "provide citizens with more comprehensive
information to better assess potential risks to health and the environment in their communities." (EPA Press
Release, January 12, 1994.) With this goal in mind, the current TRI database, scores poorly as a risk
communicator.
The TRI program scores poorly as a risk communicator because it:
• treats all listed chemicals as equally "toxic;"
• makes no attempt to rank chemicals or prioritize decision-making based on risk;
• does not provide available information about toxicity or exposure;
• provides no information about the relative risks posed by listed substances; and
• does not link existing information databases, such as the IRIS database, to assist public in
understanding the hazards posed by releases.
Making the TRI A More Effective Risk Communicator
In order to make the TRI a more effective risk communicator, EPA could provide information hi the
database that the public can use for risk-based decision-making. This information could include information
about the:
• relative risks posed by the listed chemicals;
• type of harm posed;
• routes of exposure and media affected;
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1994 TRI Data Use Conference Innovative Uses Track - Session 1
• degree of certainty associated with listing; and
• seriousness of the identified effects.
EPA could also consider a chemical ranking system to rank chemicals on the TRI not only based on total pounds
released, but also on toxicity and potential for exposure. The Agency could also use information management
technology to link relevant EPA databases. EPA could establish TRI community advisory panels in order to
better assess public data needs. Finally, EPA could aggressively explore new models for adapting the TRI to
provide the public with information not only about releases, but also about risk. The Chemical Manufacturers
Association is very interested in working with the Agency and other TRI users to explore options for making the
TRI database a better risk communication tool.
D
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Innovative Uses Track - Session 2 _ 1994 TRI Data Use Conference
Session 2: Is TRI Useful in the Environmental Justice
Movement?
Session Leader
Russ Lopez, Environmental Diversity Forum
Linda M. Brown, Louisiana Department of Environmental Quality
Benjamin A. Goldman, Ph.D., Research Director, Jobs and Environment Campaign
Theodore S. Glickman, Center for Risk Management, Resources for the Future
Idell Hansen, Washington Department of Ecology
Environmental justice advocates are studying how environmental problems affect minorities and low
income communities. TRI data was not designed to address these types of issues and there can be problems in
interpreting TRI to render it useful. However, TRI can be a valuable source of information for researchers and
individuals seeking insight into national and local problems. Panelists presented studies that have used TRI to
identify environmental inequity and described community right-to-know outreach programs to low income
communities and communities of color.
Linda M. Brown, Louisiana Department of Environmental Quality
TRI Outreach: A Role in Environmental Justice
The Louisiana Department of Environmental Quality began its Environmental Justice Program
approximately two years ago. The program focuses on cooperation, communication, and issue resolution
between the residents of industrial communities and representatives from the neighboring industrial facilities.
As part of the state program, Environmental Justice Panels are being created throughout industrial
communities along the Lower Mississippi River Corridor between Baton Rouge and New Orleans. As part of
TRI Outreach, these panels are being targeted for presentation of the TRI Program in Louisiana and how it can
be utilized as a tool to assist them in their endeavors to build community/industrial relationships.
Our first workshop targeted an Environmental Justice Panel created in St. James Parish. The community
representatives were residents of the Lyons, Mount Airy, and Garyville areas. The industrial representatives were
Nalco Chemical Company, Marathon Oil Company, and Cargill Grain Elevator Company. These facilities are
located in close proximity to the above mentioned communities. We met with the residents of these communities
to introduce them to TRI and briefly explain what type of information is available. Several more workshops with
the communities and industrial representatives are anticipated.
The goals and objectives of the workshops are to: provide the communities a historical perspective
which will allow them to more fully understand why the Emergency Planning and Community Right-to-Know
Law came into being; describe the facility reporting requirements; provide specific information on the facilities
in close proximity to the communities, such as developing data trends; describe how the information can be used
as a tool to promote discussion between community and industrial representatives; describe other available
resources, such as the public health department and the public library that are easily accessible without cost;
discuss the limitations of the data especially when considering risk; describe other data resources available such
as TOXNET; and describe other available chemical information, such as Toxicological Profiles by the U.S.
Department of Health and Human Resources.
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1994 TRI Data Use Conference Innovative Uses Track - Session 2
The TRI outreach to the Environmental Justice Panels is only a portion of what the Environmental
Justice Program is attempting to pursue. We plan to provide as much assistance as possible to facilitate the
program.
D
Benjamin A. Goldman, Ph.D., Research Director, Jobs and Environment Campaign
Is TRI Useful in the Environmental Justice Movement?
Is TRI useful in the environmental justice movement? Let me guess...ril bet you want me to say:...YES.
But let me instead play the loyal opposition. There's more than one "right" answer to this question. One thing
the environmental justice movement stands for is its respect of diversity. I would venture that among people
within the movement, there are as diverse opinions about this issue as about any other. So Til try to present both
sides of the debate based on a decade of my work in the fields of both right-to-know and environmental justice.
First, let's take the easier position and say: "sure it's useful."
Society generally doesn't address a problem until it can be measured. The revolution in information
technologies that occurred during the 1980s helped bring the issue of environmental justice to national attention.
Reductions in computer processing costs and increases in the availability of computerized data enabled
researchers for the first time to quantify disparities in the nationwide distribution of environmental hazards. TRI
is part of this trend.
About a dozen studies have crossed my desk in the past year or two that use TRI data to document
environmental disparities by race or income. They examine various places across the country, including.
Richmond, CA; Detroit; St. Louis; Los Angeles; Cleveland; all of Florida; the entire Southeast, and a couple
national analyses. They use various methods and measures, including census tracts, ZIP codes, counties, and
states. (See Table 1.)
Some are more complicated man others. Most find racial disparities in the release of toxic chemicals are
more pronounced than income disparities, but some find greater income disparities. Others look more deeply
into the relationships between these variables, finding, for example, that states with most toxic releases per job
have the worst economic welfare, as measured by disposable incomes, unemployment, and poverty.
These findings clearly have significant implications for the environmental justice movement. And in
some cases they have led to policy changes. A few factories, for example, have entered into "good neighbor"
agreements with host communities after negative publicity over their toxic releases. At least one state has tried
linking tax incentives to reduced toxic releases per job. Nationally, there have been legislative proposals to use
this kind of information for identifying "high impact areas" in order to target remediation and prevention funds.
This all sounds great so far, but lef s put a slightly more critical eye on these developments.
How significant has TRI really been in this trend of using information for environmental justice? First,
Td say that its data is less important than its public access mandate. There were plenty of data at EPA before
TRI, and EPA's other major data systems continue to dwarf TRI in comparison. The most significant work in
this field has used information collected under other sections of the Superfund law and under other environmental
laws entirely. There are EVEN plenty of other data sources on toxic releases.
My book The Truth About Where You Live, for example, used EPA's other major data systems for air,
water, hazardous waste, radiation, etc. to create national maps of a variety of industrial toxic releases, all of which
were correlated significantly with people of color and elevated mortality rates across the country.
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1994 TRI Data Use Conference
But TRI represents the first time such information was collected solely for the purpose of providing
public access through state of the art communications systems. Given this feet, ifs surprisingly how little
environmental justice work has in fact been done with this database.
A few years ago, for example, I floated a proposal to look at which industries, companies, regions of the
country, cities, and chemicals exhibit the greatest disparities in toxic releases by race and class. To date, no one
has funded or undertaken this baseline work—or if they have, they've done so rather quietly.
Table 1 Listing of 11 Empirical Studies of Toxic Release Disparities by Income and Race in the United States
YEAR AUTHOR
'89
'91
-92
'93
•93
'94
Belliveau et aL
Pfaflf
Brown
Kay
Attah
Goldman
Nieves
Burke**
BowenetaL**
Templet & Farber
Vrttes& Pollock
TYPE/
METHOD*
NP
JO
LW
JO
SO
GE
GT
GE
GE
EC
PS
/
/
/
/
/
/
/
/
/
/
/
CO
CO
CO
CO
CO
CO
HE
CO
CO
CO
CO
CO
ENVIRONMENTAL
CONCERN
Toxic releases
Tn
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1994 TRI Data Use Conference Innovative Uses Track - Session 2
dozen studies Tve seen that actually use TRI for environmental justice research, not one was done by a people
of color or low income group.
If right-to-know laws provide equal access to toxics data, this information will likely be used more
aggressively by better equipped and better educated communities and organizations. Hence, on their own,
information systems such as TRI may actually EXACERBATE rather than diminish existing disparities in the
distribution of toxic hazards.
So now let's get rgal depressing...
In the last few years there has been an explosion of information on environmental injustices, including
HUNDREDS if not THOUSANDS of articles, studies, papers, conferences, media reports, etc. The latest study
to receive front-page coverage around the country, was an update I prepared of the original Toxic Wastes and
Race report In this latest study, we found that despite the increased availability of information, people of color
are today even MORE likely than whites to live in communities with commercial hazardous waste facilities than
they were a decade ago.
In short, increased public knowledge of toxic hazards, combined with increased difficulties in siting new
facilities, may contribute to even greater environmental disparities by race and class. As more communities try
to block sites and prevent pollution in their backyards, those with the least political and economic power and with
the least technical know-how will be left with an even greater share of the toxic residues from our modern
society.
This is a sad conclusion indeed, given that demands for the right to know are rooted in a long history of labor
and civil rights struggles
While the release of deadly gases at Union Carbide's Bhopal facility is credited with galvanizing support
for the federal right to know law in the mid-1980s, labor and community activists had already been fighting for
decades to get toxics data from the government and corporations. Fifty years ago, it was not only hard to come
by information about the deadly chemicals that Carbide and other companies were handling, but it was often
illegal to disclose such data-in fact, for certain toxins, such as fissionable materials, DISCLOSURE was
punishable by DEATH under U.S. law.
Forty years ago, the United Steel Workers of America began making some of earliest demands for risk
information on behalf uranium miners in Canada-many of whom, by the way, were Native Ojibwa people. Just
thirty years ago, the U.S. Freedom of Information Act passed-but not because of grassroots struggle, rather,
because the legislature wanted to constrain the executive branch. Twenty years ago, wildcat strikes at the
uranium mines in Canada led to the first toxics right-to-know law in North America — including a clause
providing the right to refuse unsafe work, which remains a model for the continent. In the U.S., decades of civil
rights battles led to passage of the Home Mortgage Disclosure Act, forcing banks to reveal information about
discriminatory lending practices.
Now, its been about a decade since the first worker and community right-to-know laws appeared in the
U.S., and what do we see?
• No right to refuse unsafe work like our neighbors in Canada, but instead a gutted OSHA bureaucracy, with
little enforcement capabilities, despite continued hazards on the job.
• As much redlining and segregated housing as ever.
• A Freedom of Information service dominated by businesses requests.
• And as far as I know-though maybe IT! learn otherwise here-there's as much toxic pollution as ever, it's
still distributed inequitably across the population, and it's likely in the future to become ever more
concentrated in communities with people of color and lower incomes.
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Meanwhile, Secretary of Labor Robert Reich can praise the emergence of a class of "symbolic analysts,"
like ourselves, who will use technical information such as TRI to rule the world, as the anxious middle and lower
classes fall ever farther behind.
So where's the hope?
The need-to-know secrecy and nuclear production systems of the Cold War are rapidly collapsing. To end
the toxic poisoning of communities across the country, the same kinds of massive changes that our military is
now experiencing need to occur in our CIVILIAN methods of production as well.
What force will be powerful enough to cause the formidable changes we need to produce goods and
services without relying on toxic chemicals, to rechannel the efforts of displaced workers, and to reduce the
injustice to future generations left by decades of toxic production?
In just one little place in the forests across Lake Huron, for example, where those miners once breathed
uranium deep under the bedrock of Northern Ontario, there are no workers anymore. The mine towns there have
crumbled, and thousands whose livelihoods were the first step in the lifecycle of our nuclear technologies must
seek other lines of work. Left behind are 300 billion pounds of toxic waste—50 times TRTs annual total for all
U.S. industries. The uranium tailings fill ten lakes, covering 4 square miles, 4 stories high, exposing residents
of the entire Northern Hemisphere to millions of increased cancer fatalities over thousands of years into the
future.
So when we talk about TRTs usefulness to environmental justice, the tough question is...
How will information about toxic releases contribute to the broad social, economic, and political changes
that are needed to end our country's dependency on toxic methods of production? My work suggests that
right-to-know laws in and of themselves are unlikely to cause significant reductions in disproportionate
exposures.
Good data didn't cause the momentous social change in Russia that ended the Cold War. But we can't just
stand by and wait for the groundswell needed to eliminate environmental injustice. At least three conditions are
needed for information tools such as TRI to be useful to the environmental justice movement:
• first, sufficient resources and training must be targeted to disproportionately affected communities to
enable them to use such information effectively;
• second, research that uses TRI must be done under the direction of or in partnership with
disproportionately affected communities; and
• third, right-to-know laws must be coupled with specific powers to act that end the release of toxic
chemicals in the most disproportionately affected communities.
The bottom line, of course, isn't to report toxic releases or their disparities, but to stop them. Unless one
act leads to the other, TRI won't be known for its contribution to environmental justice, but rather, for its ability
to document the continued presence of the opposite.
References
Attah, E.B. "Presentation notes on draft preliminary findings: demographics and siting in EPA Region IV."
Atlanta, GA: Presentation for the Conference on Environmental Equity, September 14-15,1992.
Belliveau, Michael; Kent, Michael; Rosenblum, Brant. Richmond at Risk: Community Demographics and Toxic
Hazards from Industrial Polluters. San Francisco, CA: Citizens for a Better Environment, 1989.
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1994 TRI Data Use Conference Innovative Uses Track - Session 2
Bowen, William M; Sailing, Mark 1; Cyran, Ellen J.; Moody, Heather A. "The spatial association between race,
income and industrial toxic emissions in Cuyahoga County, Ohio." Atlanta, GA: Presentation for the Annual
Meetings of the Association of American Geographers, May 1993.
Brown, Kevin L. "Environmental discrimination: myth or reality." St. Louis, MO: supervised research paper,
Washington State University School of Law, March 29,1991.
Burke, Lauretta M Environmental Equity in Los Angeles. Santa Barbara, C A: National Center for Geographic
Information and Analysis, 1993.
Goldman, Benjamin A Not Just Prosperity: Achieving Sustainability with Environmental Justice. Washington,
DC. National Wildlife Federation, 1994.
Goldman, Benjamin A. The Truth About Where You Live: An Atlas for Action on Toxins and Mortality. New
York, NY: Times Books/Random House, 1992.
Kay, Jane. "Minorities bear brunt of pollution." San Francisco Examiner, April 7,1991.
Nieves, Leslie A. "Not in whose backyard? Minority population concentrations and noxious facility sites."
Chicago, IL: Presentation for the American Academy for the Advancement of Science, February 9,1992.
Pfaff, Dennis. "Pollution and the poor." Detroit News, November 26,1989, p. Al.
Templet, Paul H.; Farber, Stephen. "The complementarity between environmental and economic risk: an
empirical analysis." Ecological Economics, 9(2), February 1994.
Vittes, M Elliot; Pollock, Philip H. IE "Race and ethnicity, income and potential pollution exposure: an analysis
of environmental equity." Orlando, FL: University of Central Florida Department of Political Science, April 1994.
D
Theodore S. Gtickman, Center for Risk Management, Resources for the Future
Robert Hersh, Center for Risk Management, Resources for the Future
A Case Study of Industrial Hazards and Environmental Justice
This case study deals with environmental equity related to industrial hazards in Allegheny County,
Pennsylvania, where the city of Pittsburgh is located. The objective was to evaluate any inequities borne by
minority, low-income, or elderly people due to the actual or potential impacts of facilities that emit toxic
substances or store extremely hazardous substances. It was motivated by concerns raised by civil rights
advocates and their supporters in the environmental community, and by the steps being taken by the federal
government to respond to their concerns. The study's primary focus was on developing appropriate, readily
transferable methods that can be used to identify and measure environmental inequities, especially in highly
industrialized urban areas. Such information is essential for establishing priorities to correct existing
environmental injustices and prevent future ones from arising.
The study analyzes census statistics and hazard data using a geographical information system (GIS), and
evaluates inequities based on a subgroup's proximity to the facilities and the associated risks. The risk
calculations take into account not only the distance between the subgroups and hazard sources, but also the
probability of exposure and the associated consequences. Weather conditions, inhalation toxicities, and
susceptibility to health effects are important factors in determining the level of risk. Because of the last factor,
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Innovative Uses Track - Session 2 1994 TRI Data Use Conference
and because Allegheny County has an unusually high proportion of elderly people, people over 65 were included
among die subgroups of concern. Hie other four subgroups, all of which relate to race and poverty, were blacks
(Ae census term for African Americans), people living below the poverty line ("the poor"), poor blacks, and poor
whites. The last two were included to examine the influence of race on any income-related inequities, and vice
versa
Blacks are by far the largest minority in Allegheny County, accounting in 1990 for about 11% of its
population and about 26% of the population of Pittsburgh, which is the only large city in the county. The poor
and the elderly account for about 11% and 17% of the county population, respectively. The corresponding
figures fix Pittsburgh are 20% and 18%. The hazards are air emissions from TRI facilities and accidental toxic
releases from "EHS facilities." The latter facilities are the ones which report the storage of extremely hazardous
substances under EPCRA. There are 88 TRI facilities in the county and 62 (out of 128) EHS facilities that
represent a significant hazard.
Proximity was evaluated by superimposing the facilities on census block groups using the GIS and
calculating the incidence of each subgroup's population in one-half mile and one mile radius circles constructed
around each facility. This was compared to the corresponding incidences outside the circles to determine whether
inequities existed. Among the five most hazardous TRI facilities, the inequities were largest for the poor and the
elderly in the case of one facility. For two other facilities the inequities were very large for blacks and the poor,
and even larger for poor blacks in particular. And for the remaining two facilities, the only inequities were
moderate ones for the elderly. Inequities were found for every subgroup when all TRI facilities were considered
collectively. The inequities were all about the same at one-half mile, but the inequity for poor blacks jumped up
as the radius increased, indicating that poor blacks tend to be concentrated between one-half mile and one mile
from the facilities, whereas poor whites tend to be concentrated within one-half mile of the facilities' centers.
For the five most hazardous EHS facilities, the results were somewhat different. For four of these facilities
the largest inequity was for poor whites, but for the fifth one the inequities were large for blacks and the poor,
and larger still for poor blacks. For all 62 EHS facilities together, the burden of inequity was found to fall more
on the poor than on blacks. At the smaller radius, the inequity was largest for poor whites but at the larger
radius it was largest for poor blacks, reflecting the same tendencies observed for the TRI facilities.
Thus, from the viewpoint of proximity to hazardous facilities, inequities were found to vary substantially
from one facility to another, depending primarily on the racial and class composition of the neighborhood. In
general, it appears that environmental equity tends to be as much a problem for the poor as it is for blacks in
Allegheny County, and at close proximity to the plants, it is more of a problem for poor whites than poor blacks.
To examine environmental equity from the viewpoint of risk, a risk model was formulated that contains
a probability factor, a population impact factor, and a mortality rate. For both types of facilities, the model
yielded estimates of the number of premature deaths in each subgroup, depending on the size and orientation of
the impact areas and how they overlapped with the spatial distribution of the subgroup populations, adjusted for
workday variations in population patterns. County-wide impact areas for the emissions from the largest TRI
facilities and three other major sources of PM10 and SO2 were estimated using standard air pollution models
(ISCLT2 and COMPLEX1). Impact areas for the toxic plumes associated with accidental releases from EHS
facilities were estimated using NOAA's ALOHA model.
For the TRI facilities, the average individual risk for each subgroup was calculated and compared to the
average individual risk for the rest of the population. These comparisons revealed inequities for every subgroup.
The inequities for blacks and the poor were similar to one another, but the inequities for poor blacks were larger
man for poor whites. They were smallest for the elderly. For the EHS facilities, the only risk-based inequities
found were for poor whites and the elderly, but in both cases they were small.
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1994 TRI Data Use Conference Innovative Uses Track - Session 2
In summary, we found that risk-based and proximity-based equity evaluation can lead to different
conclusions, indicating the importance of doing both. We also found that the chronic risks associated with the
TRI facilities in Allegheny County were greater than the acute risks associated with EHS facilities, and that time-
of-day population adjustments had a significant influence on the risk estimates.
D
Idell Hansen, Washington Department of Ecology »
Environmental Equity Study
The Washington State Department of Ecology (Ecology) is currently in the process of building a better
understanding of environmental justice and equity issues. Agency attention to address this arena is being
pursued through a variety of efforts, one of which is the completion of a statewide environmental equity study.
Ecology's focus on environmental justice issues is primarily due to proposed Senate Bill 6401 and
Resolution 1994-8692, both presented during the 1994 legislative session. This joint legislation stated that
Ecology and the Washington State Department of Health (DOH) would conduct a study relating to environmental
equity. Even though neither the bill nor the resolution formally passed out of the legislature before the session
ended, $29,000 of the Worker and Community Right-to-Know fund was appropriated to Ecology to provide
solely for conducting an environmental equity study for fiscal year 1995. The Hazardous Substance Information
Office (within Ecology's Hazardous Waste and Toxics Reduction Program) manages the Community Right-to-
Know data and has taken the lead on the study.
As directed in the legislative appropriations for fiscal year 1995, the environmental equity (EE) study will
be designed to include information on the distribution of environmental facilities and toxic chemical releases in
relation to low-income and minority communities.
What The Study Will Try to Accomplish
Given a limited budget and time frame, the EE study will attempt to cany out the following:
1) use 1990 census data to identify census block groups according to A) percentage of people of color, and
B) percentage of people below the poverty level;
2) to map the following six types of facilities and sites using the Geographic Information System (GIS): Toxic
Release Inventory reporters (TRI); Hazardous Sites List; Treatment, Storage, & Disposal Facilities; Major
Waste Water Discharges; Active Municipal Solid Waste Landfills & Incinerators; and Major Air Releases;
3) to assess the distribution of facilities and sites in relation to communities of color and low-income
populations;
4) to identify the census block groups which appear to be exposed to the highest amounts of reported
chemical wastes in the last five years (using TRI data); and
5) in conjunction with DOH, to develop recommendations for further studies or actions that could be taken
by the legislature or the two agencies to address EE.
What The Study Will Not Trv to Accomplish
The study will not attempt to determine:
• a comprehensive assessment of toxics in the localities;
• relative risk between the various types of facilities identified;
• a risk assessment for any of the localities identified; or
• reasons for possible disproportionate distributions of facilities relative to population groups.
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Innovative Uses Track - Session 2 1994 TRI Data Use Conference
Status of the Study and Milestones
1) A profile for each Block Group in Washington, regarding the population's race, ethnic, and poverty
characteristics, has been established by inputing data from the 1990 U.S. Census Summary Tape Files into GIS.
This provides a database map for each of the State's 39 counties. Communities of color have been identified as
block groups that have A) a percentage of people of color higher than the county percentage and B) a percentage
of people of color 20% higher than the county percentage. A Low-income community has been identified by
block groups that have A) a percentage of people below the poverty level that is higher than the county
percentage and B) a percentage of people below 200% of the poverty level that is higher than the county level.
This step of the project has been completed.
2) Currently, Ecology staff is in the process of verifying the six site lists to be used for the EE project. Address
matching software is being used to both generate and double-check latitude/longitude coordinates for most
locations. When applicable, locations will also be compared with EPA and DOH information. Completion date:
mid-December.
3) The next step will be to enter these sites into the GIS system and begin to count and compare the distribution
of the various facilities over Washington communities as defined by block groups. Next, the relative
distributions of the facilities and sites in relation to the various block group characteristics will be determined.
This will be done primarily by ranking the block groups according to the number of facilities and sites within
each area Completion date: January, 1995.
4) In addition, block groups will be ranked by total pounds of waste released for each Toxic Release Inventory
facility within a block group. Time permitting, block groups may also be ranked by other data that can be
reasonably used to compare total wastes released (e.g. total volume of landfills). Totals should be based upon
the accumulated releases during the previous five years (1989-93). Completion date: February, 1995.
5) A map will be printed of each county, identifying the location and type of facilities and sites, and then-
respective communities. Completion date: February, 1995.
If possible, this study will also be mapped according to the State's drainage basins. This will assist
Ecology, the legislature, and the public, in better understanding this data in relation to natural boundaries.
However, it has not been determined whether the census data can be conveniently conveyed in a drainage basin
format.
6) Once the comparison and ranking is done, Ecology will note the many strengths and limitations of the analysis
and begin working with DOH and other interested parties (both Agency and Community groups) to jointly
generate recommendations for follow-up studies and/or actions to be pursued. Completion date: May, 1995.
7) Reviewer's comments will be consolidated into the study's text during June, with the final study going to the
legislature by June 30,1995.
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1994 TRI Data Use Conference Innovative Uses Track - Session 3
Session 3: TRI and Data Integration
Session Leader
Gerry Brown, Senior Analyst, Information Access Branch, U.S. Environmental Protection Agency
Speakers
Gayle Alston, Health Education Specialist, ATSDR
John Chelen,fl77s:Net
Stephen D. Hanna, Ph.D., Assistant for Environmental Information, Cal/EPA
Gerry Brown, Senior Analyst, Information Access Branch, U.S. Environmental Protection Agency
TRI is a useful and valuable information tool—a potentially powerful and unique information source.
It is a cornerstone for the Common Sense Initiative—a beginning for cross-media perspective—the experiences
gained and lessons learned are the basis for common sense. But is only one piece of the information puzzle. As
all have faced resource constraints, and will continue to do so in the coming years, we must actively work
together to learn what other pieces of the information puzzle are available, bring them together, and create the
tools to make it useful to stakeholders and constituents. Partnerships must be developed and fostered to learn
and share-share knowledge, technology, and resources—to get the products of these tools to our publics. Alone
we will be limited in our success; together we can succeed.
Gayle Alston, Agency for Toxic Substances Disease Registry (ATSDR), presented the use of TRI in
health assessment and as one source for site assessment efforts of the ATSDR. Ms. Alston presented sources
of health information and its pathways to the public through many sources and distribution channels
Steve Hanna, Cal/EPA, discussed California's lengthy data integration activities, multiple data collection
efforts and sources. Dr. Hanna emphasized the need for data integration and regulatory change to work together
to reduce burden on government and industry, and provide relevant and timely information to all constituents.
i
John Chelen, RTK-Net, stated that the technical challenges of data integration are clear and the real
challenges are cooperation for mutual benefits. He presented three goals: integration critical to better public
access; foster more efficient, effective government; reduce industry burdens and reporting requirements.
Additionally, needs were presented to move towards these goals.
D
Stephen P. Hanna, Ph.D., Assistant for Environmental Information, Cal/EPA
Use of the Cal/EPA Facility Inventory Database
Purpose
The Facility Inventory data base has been created within the California Environmental Protection
Agency (Cal/EPA) to facilitate the identification of the complete environmental regulatory profile for a given
facility. Currently, regulatory records on a given facility may exist in multiple data bases located within multiple
regulatory agencies at federal, state, and local levels. These separate data bases do not typically communicate
with each other, which complicates the development of a complete regulatory history on a facility.
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Innovative Uses Track - Session 3
1994 TRI Data Use Conference
Function
The Facility Inventory integrates data from many different sources by matching data records on the basis
of facility location. When a facility record is loaded into the data base, the county, street name, and street number
of the facility are compared to the same data elements of other facilities. Facilities sharing the same county, street
name, and street number are then linked to one another. For each location, printouts from the Facility Inventory
include entries for each regulatory data base, including the identification of the regulatory ID, SIC code, and
contact person or comments. Further detail can be obtained by contacting the reference for each individual data
base and referencing the appropriate regulatory ID.
Use
1.
2.
4.
5.
When searching for information at a particular address, the following steps are recommended:
Locate the appropriate street name, then the street number. The street number is listed in parenthesis
immediately following the street name.
Check for duplicates. Due to some data anomalies, some street addresses are repeated. The data
associated with these duplicates is not redundant, and should therefore be combined to obtain a more
complete regulatory profile for the address in question.
Check for possible occurrences of the address when the street name is spelled differently. Examples are
the substitution of a single letter such as "q" for "g" and "s" for "z", and elimination of spaces in a name
(remember that these are computer-based matches: "Del Paso" and "DelPaso" are not the same to a
computer).
Check for possible occurrences with no street number. These are typically listed at the beginning of a
street name, with the street number written as "(NO STREET NBR)".
PLEASE REMEMBER: Lack of an entry at a given location does NOT necessarily mean lack
of contamination or regulatory activity at that location.
A list of data bases currently integrated into the Facility Inventory follows.
Name
AREMS
ARCPL
AG500
AGT25
A1025
ATANK
ATEDS
Number
of Records
19,242
2,335
142
1,736
1,761
1,902
3,650
Source and Contact Information
US EPA, Office of Air, (415) 744-1182
Cal/EPA, Air Resources Board,
(916)322-5716
US EPA, Office of Air, (415) 744-1182
Cal/EPA, Air Resources Board
(916)322-5716
Cal/EPA, Air Resources Board
(916)322-6021
Cal/EPA, Air Resources Board
(916)322-6021
Cal/EPA, Air Resources Board
(916)322-6021
Cal/EPA, Water Resources Control
Board, (916) 227-4364
Cal/EPA, Air Resources Board
(916) 322-6021
Description
Stationary source facilities in the federal Aerometric
Information Retrieval System (AIRS) Facility
Subsystem with emissions activities.
Stationary source facilities in the federal AIRS Facility
Subsystem with compliance and/or enforcement
activities.
Facilities in the Emissions Data System (EDS) which
release greater than 500 tons of criteria pollutants per
year.
Faculties in the Emissions Data System (EDS) which
release greater than 25 tons of criteria pollutants/ year.
Facilities in the Emissions Data System (EDS) which
release between 10 and 25 tons of criteria pollutants per
year.
Faculties having above ground petroleum storage tanks.
Contains Sites specific air toxics emission data for
faculties throughout California
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1994 TRI Data Use Conference
Innovative Uses Track - Session 3
Name
CALSI
CALNF
CERCL
CERNF
DTSCD
FDOCK
FINDS
HAZNT
IUR
LTNKA
LTNKI
M1984
M1985
M1986
M1987
M1988
M1989
M1990
M1991
M1992
Number
of Records
8,032
18,488
738
2^74
724
148
61,755
265,099
104
18,155
4,927
8,938
11,776
14,743
20,834
24,359
30,676
34,236
34,204
36,386
Source and Contact Information
Cal/EPA, Department of Toxic
Substances Control, (916) 323-3378
Cal/EPA, Department of Toxic
Substances Control, (916) 323-3378
US EPA, Office of Emergency and
Remedial Response, (703) 908-2066
US EPA, Office of Emergency and
Remedial Response, (703) 908-2066
Cal/EPA, Department of Toxic
Substances Control, (916) 324-2437
US EPA , Office of Enforcement
(202)260-2614
US EPA , Freedom of Information
Office, (202) 260-4048
Cal/EPA, Department of Toxic
Substances Control, (916) 324-1781
US EPA, Office of Prevention,
Pesticides and Toxic Substances
(202)260-1536
Cal/EPA, Water Resources Control
Board, (916) 227-4400
Cal/EPA, Water Resources Control
Board, (916) 227-4400
Cal/EPA, Department ofToxic
Substances Control, (916) 324-0658
Cal/EPA, Department ofToxic
Substances Control, (916) 3244658
Cal/EPA, Department ofToxic
Substances Control, (916) 324-0658
Cal/EPA, Department ofToxic
Substances Control, (916) 3244658
Cal/EPA, Department ofToxic
Substances Control, (916) 3244658
Cal/EPA, Department ofToxic
Substances Control, (916) 324-0658
Cal/EPA, Department ofToxic
Substances Control, (916) 3244658
Cal/EPA, Department ofToxic
Substances Control, (916) 3244658
Cal/EPA, Department ofToxic
Substances Control (916) 3244658
Description
Contaminated or potentially contaminated hazardous
waste sites listed in the CaLates data base (formerly
known as ASPIS).
Sites in the Calsttes data base which have been
identified as needing no further action.
Known and potential hazardous waste sites in the
federal Superfund data base (CERCLIS).
Sites in the federal Superfund data base which have
been identified as needing no further action.
Enforcement docket records.
Federal enforcement docket records.
Federally regulated facilities inventoried in the US EPA
Facility Index Data System (FINDS).
Hazardous waste generators and treatment/storage/
disposal faculties and transporters listed in the
Hazardous Waste Information System (HAZNET).
Chemical manufacturers who submitted an Inventory
Update Report to the OPPTS (required every four
years).
Active leaking underground storage tanks listed in the
Leaking Underground Storage Tank Information
System (LUSTIS).
Inactive leaking underground storage tanks listed in the
Leaking Underground Storage Tank Information
System (LUSTIS).
Faculties which manifested hazardous waste offshe
during 1984.
Facilities which manifested hazardous waste offsite
during 1985.
Faculties which manifested hazardous waste offsite
during 1986.
Faculties which manifested hazardous waste offsite
during 1987.
Faculties which manifested hazardous waste offsite
during 1988.
Faculties which manifested hazardous waste offsite
during 1989.
Faculties which manifested hazardous waste offsite
during 1990.
Faculties which manifested hazardous waste offsite
during 1991.
Faculties which manifested hazardous waste offsite
durinBl992.
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Innovative Uses Track - Session 3
1994 TRI Data Use Conference
Name
PCS
RCRDE
RCRIP
RCRIS
SA302
SA304
STRMC
STRMI
SWISE
SWISP
SWISU
SWRCB
S1987
S1988
S1989
S1990
S1991
Number
of Records
193
2,840
505
33,605
859
461
2,667
8361
56
676
361
6,714
1,873
2,066
2,071
2,064
1,906
Source and Contact Information
US EPA, Office of Water
(202)260-8313
Cal/EPA, Department of Toxic
Substances Control, (916) 324-1809
Cal/EPA, Department of Toxic
Substances Control, (916) 324-1809
Cal/EPA, Department of Toxic
Substances Control, (916) 324-1809
CA Office of Emergency Services
(916) 262-2868
CA Office of Emergency Services
(916)262-2868
Cal/EPA, Water Resources Control
Board, (916) 657-1395
Cal/EPA, Water Resources Control
Board, (916) 657-1395
Cal/EPA, integrated Waste
Management Board, (916) 255-2460
Cal/EPA, Integrated Waste
Management Board, (916) 255-2460
Cal/EPA, mtegrated Waste
Management Board, (916) 255-2460
Cal/EPA, Water Resources Control
Board, (916) 657-1395
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916)322-2793
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916)322-2793
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916)322-2793
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916)322-2793
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916) 322-2793
Description
Facilities identified as major, which have had discharge
monitoring reports filed with the Permit Compliance
System.
Faculties within the Resource Conservation & Recovery
Information System (RCRIS) which have an
enforcement history. [RCRIS is maintained at both the
state and federal level.]
Faculties within RCRIS that are subject to hazardous
waste permitting requirements.
Federally regulated generators, transporters and
treatment/storage/disposal facilities tracked by RCRIS.
Faculties which have reported the presence of extremely
hazardous substances under SARA Tide HI Section
302.
Faculties which have reported releases of extremely
hazardous substances under SARA Tide m Section 302
or CERCLA.
Companies issued stormwater construction permits.
Companies issued stormwater industrial permits.
Exempt (from permit) sanitary landfills in the Solid
Waste Information System.
Permitted sanitary landfills in the Solid Waste
Information System.
Unpernritted sanitary landfills in the Solid Waste
Information System.
Facilities regulated for discharge to surface water,
tracked by me Waste Discharger System (WDS).
Manufacturing facilities which filed the Toxic Release
Inventory (TRI) under SARA Tide in Section 3 13 in
1987. The TRI forms list quantitative chemical releases
to air, water and land.
Manufacturing facilities which filed the TRI in 1988.
Manufacturing facilities which filed the TRI in
1989.
Manufacturing facilities which filed die TRI in
1990.
Manufacturing faculties which filed the TRI in 1991.
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1994 TRI Data Use Conference
Innovative Uses Track - Session 3
Name
S1992
TPPBR
TPCA
TPCE
UTNKA
UTNKI
WB-LF
WDSE
Number
of Records
1,609
357
515
1,896
40,024
11,245
42
630
Source and Contact Information
Cal/EPA, Office of Environmental
Health Hazard Assessment
(916) 322-2793
Cal/EPA, Department of Toxic
Substances Control, (916) 327-6110
Cal/EPA, Department of Toxic
Substances Control, (916) 327-61 10
Cal/EPA, Department of Toxic
Substances Control, (916) 327-61 10
Cal/EPA, Water Resources Control
Board, (916) 227-4400
Cal/EPA, Water Resources Control
Board, (916) 227-4400
Cal/EPA, Integrated Waste
Management Board, (916) 255-2460
Cal/EPA, Water Resources Control
Board, (916) 657-1395
Description
Manufacturing facilities which filed the TRI in 1992.
Penrrit-by-rule facilities regulated under the tiered
permitting program
Conditionally authorized facilities regulated under the
tiered permitting program.
Conditionally exempt facilities regulated under the
tiered permitting program.
Active underground storage tank locations.
Inactive underground storage tank locations.
Sanitary landfills which have evidence of groundwater
contamination.
Facilities in the Waste Discharger System (WDS) with
an enforcement history.
n
145
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Innovative Uses Track - Session 4 1994 TRI Data Use Conference
Session 4: Acting Locally: How Affected Communities and
Workers Are Using TRI
Session Leader
Terry Greene, J57 Research and Training Institute
Speakers
R. H. (Bob) Eisengrein, TechnicalManager-ACES, Inc., Acton, MA
Kathy Grandfield, Spokesperson, Good Neighbors
Michael K. Heiman, Dickinson College
Diane Heminway, Western New York Director, Citizens'Environmental Coalition
Terry Greene, JSI Research and Training Institute
The general public's active use of TRI data is necessary to achieve local pollution prevention goals, and
lies at the heart of Congress1 mandate to generate and widely disseminate the data. Whether we have successfully
achieved this goal for broad scale use of the TRI arose as a key concern during this year's Conference, as requests
by the general public for TRI data appear to be minimal.
Nancy Ekart, in her statement during the opening plenary, stressed the chemical industries' concern that
the public is just not interested in this information. Panelists in this session, however, dispelled that notion, hi
communities they work with, affected workers and residents not only have been interested in the TRI, they have
relied upon this data source as an essential tool for launching innovative efforts to protect their health and
environment The panelists presented case studies on how TRI data have been used to great effect, particularly
when community/labor partnerships, working with industries and regulators, have been successfully forged.
It is true that many communities and workplaces, however, have not been fully using the data. Lack of
interest is an unlikely cause. Panelist Michael Heiman pointed out that the broader public's interest in pollution
prevention is clear, as evidenced through such prominent movements as that for environmental justice and the
numerous health campaigns focussing on the role of a healthy environment. He observed that lack of general
awareness of the existence of the TRI hampers its use for these efforts. Diane Heminway has found from her
union trainings that even workers are largely unaware of TRI data for their own facilities. The general public
may know even less about the existence of the TRI.
Citizens can do a great deal to increase awareness of the TRI as a resource, as demonstrated by the
efforts of panelists Kathy Grandfield and Bob Eisengrein to share data with communities in their areas.
Nonprofits and universities also have a significant role to play. Students of Professor Heiman, with EPA support,
have set up TRI access centers and trainings in the heart of Philadelphia communities. The students target areas
which have potentially significant opportunities for exposure and few resources of their own to devote to
outreach. Unfortunately, resources for such efforts is limited. Industries and government (not just the
Environmental Protection Agency, but all relevant levels of government) must do more to initiate and support
outreach efforts, in partnership with community, health, and labor organizations.
Beyond needs for increasing public awareness and access to TRI data, the experience of the panelists
also highlighted the need to support the public in interpreting and making use of the data once they have it. They
laid out valuable suggestions, including technical assistance, trainings and materials, to help make the data
understandable and provide a context for how the information can be used. Expanded efforts can ensure that
everyone knows they have a right to know and can use it effectively.
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1994 TRI Data Use Conference Innovative Uses Track - Session 4
The panelists also outlined ways the TRI data can be improved to help workers and citizens. Bob
Eisengrein, for example, called for more detailed information such as the data on toxics use in production
processes that are available in Massachusetts. This information provides an even better base of knowledge for
informed public involvement. Toxics use data have allowed him, as a retired engineer, to facilitate dialogue
between communities and facility managers on opportunities to reduce the use of toxic chemicals where
reasonable alternatives exist. Panelists also highlighted the need for better, more accessible information on
potential exposure scenarios and health effects of chemicals. Health effects information needs to be easy to
understand and in formats which allow for simple presentation in combination with TRI data More detailed
health data from primary sources also need to be readily available in understandable form.
Finally, suggestions were made on how regulators can best work with affected workers and communities.
Panelists urged officials to recognize the public as central to the success of the TRI. They asked that officials take
the time to walk people through the data, lead them to further resources, and be sensitive to the fact that it is the
health of their families and communities at risk, In an October 4,1993 memorandum, President Clinton, while
discussing the Freedom of Information Act, reminded agencies that"... our commitment to openness requires
more than merely responding to requests from the public." To make the TRI a true success, panelists would like
agencies to establish working partnerships, the theme of this year's conference, as an appropriate goal. They
caution that "true" success cannot be measured solely by numerical trends in limited reported data; rather, it is
actual improvements in the daily lives of workers and community residents which needs to be the central gauge
of our progress.
Lively discussion followed the panel presentations. The issue was raised of the public's responsibility
as consumers in reducing demand for products dependent on toxics. This was seen to indicate a need for more
information about the toxic content in products. The impact of corporate advertising on demand was
acknowledged as a complicating factor. Toxic use fees were suggested as a market-based mechanism to
internalize the costs of toxic use in consumer products. At the same time it was recognized that consumer choice,
at its best, is a limited tool which is unlikely to secure pollution prevention of adequate scope.
D
RJL (Bob) Eisengrein, Technical Manager-Acton Citizens for Environmental Safety
(ACES), Inc., Acton, MA
A Local Health Effects Study Using TRI phis MA TURA Data
Introduction
This report focuses on community and worker HEALTH and SAFETY as related to the use of toxic
chemicals in the eight towns around Acton, Massachusetts. Three towns, Acton, Concord, and Westford had
facilities using toxic chemicals.
EPA's Roadmaps database was a primary source of information relating toxic usage to adverse health
effects. Roadmaps cited literature which confirmed the adverse health effects; abstracts of the literature are
available from the National Library of Medicine's Toxicology of Information Program. New Jersey's Department
of Public Health Facts was another source of information.
In these three towns toxic chemicals usage rose from about two million pounds in 1990 to about four
million pounds in 1992. Exposure to certain of these chemicals contributes to serious health conditions such as
cancer, birth defects, infertility, learning and developmental disorders, respiratory disorders, heart conditions,
liver disease, immune system damage, and physical injuries through fire and explosions. The health hazards of
toxic chemicals used by local manufacturing industries are found in products we use, and emissions released into
the environment as waste.
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Resources for Analysis
MA TURA data
Massachusetts' Toxic Use Reduction Act (TURA) requires public disclosure of toxic chemical use by
industries with at least 10 employees who process or manufacture at least 25,000 pounds, or otherwise use at
least 10,000 pounds a year of listed chemicals. Major details of the MA TURA legislation included:
-Amount of chemicals used by three categories
-Amount by chemical output in two categories, shipped in product, and byproduct
-Production Unit Description and Product Description
-Emissions as reported to EPA on Form R
The data is available to the public in a series of 14 files; over 600 MA facilities report this data
EPA Roadmaps data
This data relates toxic chemicals to health literature citations according to a variety of adverse health
effects. ACES interest was in four categories, carcinogenic, neurological, reproductive, and chronic. The
Roadmaps System was version 2.2 dated 9/1/91.
EHSdata
Extremely Hazardous Substances are classified as such by EPA due to their high toxicity and reactivity
which can lead to dangerous fumes, explosions, or other accidental releases. A database of EHS chemicals was
created from information in EPA'S publication "Technical Guidance for Hazard Analysis".
Methodology
Using a relational database system, it was possible to query these databases of information to create data
subsets and graphs to provide insights as to potential adverse HEALTH and SAFETY effects in our community.
The common database fields used most frequently in relating databases were facility ID, chemical CAS number,
facility production unit number, and facility zip code. The following are typical examples of important relations:
-MA TURA zip codes were related to facility IDs in that zip code.
-Facility IDs were related to chemical CAS numbers to obtain chemical amounts used.
-CAS numbers were related to Roadmaps CAS numbers to find health cited literature.
-CAS numbers were related to EHS CAS numbers to find EHS chemicals used.
-MA TURA zip codes were related to TRI zip codes to obtain detailed Form R data on byproducts and recycling.
Results Achieved
Toxic Chemicals Used-Haw and Where
A check of both TRI and MA TURA files by zip code revealed for the years 1990,1991, and 1992 that
seven facilities in our three-town area reported toxic chemical usage; four facilities were in Acton, two in
Westford, and one in Concord. Table 1 lists the facilities, towns, chemicals, amounts used, plus fugitive and
point air emissions. Similar data was obtained for 1991 and 1990.
Figure 1 shows two graphs; the top one reveals the mass-balance of all chemicals in the three towns over
a three year period. Total chemical input produced output distributed between emissions, shipped in product,
and consumed. For example, consumed output might be chemicals transformed in a process, or incinerated in
an energy waste program.
The bottom graph shows fugitive and point air emissions over the same three year period. The 1992
increase was caused by over 2.5 million pounds of calcium carbide reported for the first time by one facility in
Acton.
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Table 2 lists each facilitys description of individual production units or processes within the plant.
These data sets provide a clearer picture of chemicals used and what the processes do. The common production
unit number in Tables 1 and 2 allow one to understand how chemicals are used in a process. For example, Airco
in Acton uses production unit 2 to combine calcium carbide with water to create acetylene gas. In production
unit 2, acetone is added to cylinders of acetylene gas. In contrast, Haartz Auto Fabrics in Acton has one
production unit in which five different chemicals are used to extrude elastomer onto fabrics and gravure print the
coated fabrics. These details provide valuable insights to aid in evaluating processes for health and safety risks
for the community and the worker.
Health and Safety Issues
There were 11 different chemicals used in these three communities. They provide a means for comparing
existing information from chemical use data with possibilities for exposure and information on the known health
effects of these chemicals. The effects include cancer, reproductive, neurological and chronic health effects, and
exposures associated with accidents and spills.
Relating the CAS numbers of the chemicals used with the Roadmaps and EHS databases produced Table
3. It lists for each of the five health categories those companies using the chemicals, and the literature citation
found.
The rating codes for each of the health effects headings indicate the literature reference for a particular
type of health effect. Reference sources include the following:
GENE-GENETOX on-line data base
IARC—International Agency for Research on Cancer
EPA—EPA Carcinogenic Classification
NTP—National Toxicology Program
ATSD-Agency for Toxic Substances and Disease Registry profile
HEEP-Health and Environmental Effects Profile
HSDB—Hazardous Substances Data Bank
HEA—Health Effects Assessment
Potential Health and Safety Problems
In addition to the general literature citations of health effects, the N. J. Department of Public Health is
"quoted" when statements seem applicable.
General Comments
No facilities in the three towns use chemicals listed in the Roadmaps carcinogenic database. Although
none of these chemicals have a rating, with over 70,000 chemicals in commercial use in the U.S. only 7,000 have
ever been studied for carcinogenicity. However, chemicals were used in many facilities in all four other health
categories- chronic, reproductive, neurologic, and extra hazardous chemicals. The symptoms of these effects are
discussed in some detail; for workers, they might include problems from inhalation or dermal contact. For EHS
chemicals, the problems could vary from high reactivity to water, sulfuric acid, or the caustic nature of ammonia
Problems might arise within a plant, or in a transportation accident when delivering the chemical.
Conclusions
It is encouraging to see that total usage of most chemicals used in Acton have decreased over the three
year period 1990 through 1992. From past experience, ACES members have maintained a healthy dialogue with
local facilities and been invited to visit these facilities. It is ACES plan to discuss the contents of our research
with individual facilities; our goal is to work with them to implement TUR programs. There is too much at stake
not to do this.
D
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Michael K. Homaa, Dickinson College
Building Bridges Between the Campus and the Community: TRI Training Sessions for Local
Residents in Impacted Neighborhoods Using the CD-ROM Format
Despite political rhetoric, we live in an era of limited state and federal commitment to environmental
monitoring and enforcement. Fortunately, citizens can be trained to directly access, for themselves, the regulatory
and reporting data required from hazardous chemical generators, handlers, and emitters. With further assistance
and access to laboratory facilities of the type common on many college and university campuses, citizens can also
assist in the detection and monitoring of contaminants in their local communities.
Congress specifically intended the Emergency Planning and Community Right-to-Know Act of 1986
(EPCRA) to enable citizens to learn more about the hazardous chemicals stored, used, and released in their
communities. The EPCRA (TRI) data base provides the major vehicle whereby thousands of citizen activists
are finally gaining a handle on the chemical risks to which they are exposed. The result has been a flurry of local
activity leading to support for toxic use reduction, more democratic participation in local planning and zoning
decisions affecting facility location and expansion and, at the national level, political pressure necessary to
strengthen federal environmental acts, as with list expansion for regulated chemicals under the Clean Air and
Clean Water Acts.
The Environmental Studies Program at Dickinson College in Carlisle, Pennsylvania is committed to this
goal of grassroots empowerment through faculty and student outreach to affected communities. This is
demonstrated through our Community Toxic Waste Audit Program and the Alliance for Acid Rain Monitoring
(ALLARM), both employing Dickinson students working with community volunteers to address requirements
for hands-on training in data acquisition and environmental monitoring. The toxic waste audit process is
initiated each spring as the 75 students in our introductory environmental science course prepare audits on
communities or facilities of their choosing. As a result, we now run one of the largest campus-based toxic waste
audit programs in the nation drawn from the TRI data base, and our activities have attracted regional and even
national attention to the program and the college.
It has been our experience as community consultants, that rural and urban locales with high proportions
of low-income residents and people of color, tend to be less active when accessing the TRI data base than have
groups in more affluent suburbs. This is not due to any lack of concern over environmental pollution, for we have
seen a powerful grassroots movement emerge in many such communities targeted for waste management
facilities. Rather, knowledge about, and access to, the training and equipment necessary to use the TRI data base
is limited in the impoverished communities where toxic release is often the greatest, while many national-based
environmental advocacy groups with entree to the important data have tended to use the information to mobilize
support for expansion of federal environmental legislation and for broader campaigns instead of for direct local
training and assistance.
Fortunately, access to TRI data is now improved, with hundreds of county and federal depository
libraries holding the CD-ROM format. Although somewhat dated, the CD-ROM data provides by far the best
avenue both in terms of cost and ease of access for the general public. Following introduction to the CD-ROM
format, interested citizens are often inspired to seek more current release data in hard-copy format from state
reporting centers, or on-line via RTK-NET and the National Library of Medicine (NLM) systems.
Supported since June of this year through the EPA's Environmental Justice Grant program administered
by EPA Region TTT, and working with student interns, I have conducted a series of TRI-access workshops in
communities of color and low-income neighborhoods across Pennsylvania To date we have held nine sessions
in impacted urban areas such as Philadelphia, Pittsburgh, and Allentown/Bethlehem, as well as hi more rural
industrial districts as, for example, in Bedford, Union, and Beaver counties, hi the coming months we will
expand this series to impacted communities in West Virginia, Virginia, Maryland, and Delaware.
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Hie workshops are held under the sponsorship of local grassroots environmental groups already involved
with struggles to get a handle on the chemicals to which the residents are exposed. Here our two- to three-hour
session centers on accessing the CD-ROM format of the TRI data base, together with the accompanying chemical
feet sheets also available on the disks. Although most of the participants have little or no computer background
skills, all receive sufficient training to go into their local depository library the next day ready to request and start
using the data disks. Where possible, our workshops are held right in the county or local academic library where
me data are stored, or at some other public place arranged for by the sponsoring local organizations. Where the
library does not yet have a copy of the disks, we arrange for a free copy available for non-profit community
outreach groups through the office of the EPA's TRI-US librarian. We bring with us the CD-ROM reader,
supporting computer, overhead projector, and screen display monitor sufficient to project the computer screen
for audiences ranging from 25 to 85 participants. Manuals providing line-by-line access information, depository
library addresses, and other regional, state, and federal TRI-access resources, are also provided, as are contacts
for good neighbor, toxic-use reduction, and union/labor-outreach programs.
Workshop participants include community environmental leaders; local librarians who may have the data
base, or access to it, but often do not know how to load or use it; and members of the active public who, from
our experience, are already very knowledgeable about local environmental conditions, yet are eager for
documentation of the type available through the TRI data base and support materials. In addition, we strongly
suggest mat the local sponsors invite the environmental and health and safety managers from nearby industries
represented on the data base. Most manufacturing concerns prefer to converse with a knowledgeable and
informed public, and the dialogue is greatly enhanced when each side is apprised of the level of information
already available to the other. This strategy of inviting all affected business and community members to the
workshop has been very successful, with industry representatives present at most of our meetings.
Public response has been overwhelming, so much so that we are now in the process of producing a
videotape to be sent out where our presence is no longer feasible. The data accessed is being put to good use.
Already community participants in Southwest Philadelphia, working through Clean Water Action, our local
sponsor there, have used the TRI data to begin a dialogue with the major oil refineries in the region on emissions
reduction. Here the local library serves an ethnically mixed community downwind from the refineries. With
our assistance it has installed the data disks so that the residents do not have to travel to Center City or beyond
for access. Similar installation is now occurring in Northeast Philadelphia with assistance from the Clean Air
Council in a community impacted by release from nearby chemical firms. In Bedford and Beaver counties,
Pittsburgh, and the Allentown/Bethlehem areas, local TV and press coverage of our workshops led to greater
public awareness of the data base, helping to empower resident groups in their dialogue with industry.
We are convinced that the TRI data base remains the most powerful, yet accessible, single source of
information in the quest for environmental justice, toxic use reduction, and community environmental
empowerment. Encouraging our students to work as multidisciplinary research teams in a real-world setting,
helping them acquire both technical skills and social self confidence as they network with industry, citizen, and
regulatory personnel, and building bridges between the campus and the wider community; are critical goals for
our program. The skills acquired by the students in this project-both technical and social-are those often
required for the professional work toward which many aspire. Indeed, it is no fluke that a number of our former
students, already familiar with the TRI data base and its application in the waste audit process, now work at the
EPA's own EPCRA hotline in Washington, DC, staffed by Booze Allan.
Our wish list for improved data access and availability includes the following:
1. The CD-ROM format should be made available on a more timely basis, as soon as possible after release of the
data by the EPA. Why did it take more than two years to finally release the 1991 data in October of this year
after it was reported in July of 1992 and nearly two years after the data was available on-line?
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2. The EPA should endeavor to get the CD-ROM discs in as many libraries as possible, and not just those that
are official federal depositories. Most county libraries still do not have the discs, even if they do have the
computer/ROM capabilities to display them. The data must be publicized and available locally for the public
to use it.
3. The EPA must continue to devote the requisite resources necessary to train local librarians in the availability
and use of the data base, preferably in CD-ROM format. This effort seems under-funded at present, even in so-
called 'test target1 states, such as Pennsylvania.
4. We would like to see an EPA-sponsored or contracted manual for general public distribution on accessing
the TRI data base. At present, we are forced to refer the participants at our workshops to the Form R reporting
package itself, available through the EPCRA hotline, for the most thorough and useful text available. We
supplement mis manual with our own handouts. At a minimum and in the interim, the EPA Reporting Center
should publicize availability of the reporting manual yet does not have to send out data entry disks for those
inquiries only involving the manual itself. Other manuals, available from groups such as the Citizens
Clearinghouse for Hazardous Waste, and INFORM, while useful, are either dated or do not devote sufficient
attention to the TRI data base for our purpose here.
5. The EPA should sponsor a detailed hour-long TRI-access video, again focusing on the CD-ROM format, with
line-by-line (or keystroke-by keystroke) instruction. This may suffice for wide distribution at depository libraries
with the data base, and for interested citizen groups where workshops are not feasible or members of the public
cannot attend a regularly scheduled workshop.
6. Additional workshops and videos addressing the needs of specific interests, as with labor representatives,
emergency response personnel, and planning and zoning officials, can be adapted from the master format referred
to above (item#5).
In conclusion, the Environmental Studies Program at Dickinson College is committed to science by the
people, and not just for the people! We believe that environmental organizations and non-profit or service and
response groups must not do for the public what the public can be empowered to do for itself. This idea forms
the very base for our strong commitment to direct citizen access to the TRI data in the CD-ROM format. At
Dickinson we are now moving from data retrieval to actual monitoring. This year we will use a new head space
sampler for hydrocarbon detection, an atomic adsorption spectrometer for heavy metals, and other analytical
equipment recently acquired through an NSF grant, to conduct rudimentary water and soil quality analysis for
the presence of TRI chemicals. Samples will be gathered by the citizens themselves under quality-control
supervision. This Toxic Fingerprints Project will be conducted in cooperation with the on-going Alliance for Acid
Rain Monitoring (ALLARM), incorporating over 500 citizen volunteers across the State of Pennsylvania already
engaged with stream monitoring for acid deposition.
As envisioned through EPCRA, knowledge leads to power and even furthers democracy, where
democracy entails control over the forces, including environmental risks, affecting one's life. The Environmental
Studies Program at Dickinson College is ready to assist with this effort. We welcome further inquiry.
D
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Diane Heminway, Western New York Director, Citizens'Environmental Coalition
Good afternoon. My name is Diane Heminway and I am the Western NY Director of Citizens'
Environmental Coalition (CEC) and member of United Steelworkers of America. CEC is a coalition of 90
community, environmental and labor member groups and over 6,000 individual members. Established in 1983,
CEC has been working primarily at a grassroots level to address and prevent pollution problems in New York
State.
For the past six years, CEC has worked closely with a number of unions and other labor groups; three
years ago, CEC staff organized with United Steelworkers of America Before I go into detail about my work with
labor, Id like to give you a little background on myself
My personal involvement began ten years ago on November 15,1984. On that day, my five year old
daughter and seven year old son were attending their elementary school in Middleport, NY when the FMC
pesticide plant adjacent to their school had a 50 gallon accidental chemical release. The school was evacuated
and nine children and two adults were sent to area hospitals and over 100 children were treated with oxygen
and/or eye packs. When I phoned FMC to ask about the long and short term health effects associated with the
chemical, I was told "there are none."
Eighteen days later, on the other side of the world, there was another accident involving this same
chemical, methyl isocyanate. This time, in Bhopal, India, the chemical immediately killed thousands of people
and left thousands more permanently injured. The Bhopal tragedy allowed me to learn more than I ever wanted
to know about methyl isocyanate—a poison for which, in 1984, there was almost no toxicological data because,
as was reported in TIME magazine, researchers stated that it was too dangerous to study in the laboratory.
Middleport was extremely fortunate on that 40 degree autumn day. An industrial toxicologist
mathematically calculated that with a 20 degree increase in temperature, the school children would have easily
received an exposure three times the life threatening level for an adult. Had the thermometer read 60 degrees, we
would have undoubtedly been burying hundreds of dead children.
In 1984, there was no Emergency Planning and Community Right To Know Act and it was no easy task
to learn that FMC had been inappropriately storing 140 tons of methyl isocyanate next to my children's school.
And certainly, there was no data base to learn what poisons were being emitted into the air my children breathed
daily. What I did learn was that at the time of the spill, the company sent workers out to "monitor" the area
They were given no personal protective equipment and were instructed to rely on their eyes and noses to detect
the presence of methyl isocyanate-even though the manufacturer clearly warned that this should not be used as
a detection method since lung damage can occur before the eyes and nose can sense its presence.
In 1984, workers were still being used as canaries in the coal mines-and they still are in 1994. That is
why 100,000 workers die every year from occupational illness — that means that 11 workers die every hour as
a result of workplace diseases. That is why we are so strongly committed to helping workers reduce their toxic
assaults.
As I mentioned earlier, CEC staff are members of USWA, While unionized environmental groups are
still somewhat unique, it is a natural and logical alliance-it is only good sense to join forces with those with
whom we share common goals and visions. It is an alliance that for years, industry successfully prevented, by
pitting workers against those who cared about safe and healthy communities. We have to stop allowing the issue
to be framed in a jobs versus the environment context because the only way that we can ever hope to achieve
a safe and healthy environment is by first having safe and healthy workplaces. The most logical way to
accomplish that is through the reduction or elimination of poisons in the Workplace. Obviously this wont
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happen overnight, but we must continue to strive toward that end by working together and learning from one
another.
For the past two years, in addition to my work as an environmental activist, I have had the honor of
serving as a Health and Safety Trainer for workers through a training program sponsored by United Steelworkers
of America We teach workers about their various rights and about the inadequacies of worker protection laws
and the uncertainties of science. They learn that there are about 70,000 chemicals used in commerce today and
that about 35,000 of those chemicals are known to be associated with some type of hazard. Then they learn that
OSHA regulates only 460 chemicals. They learn that permissible exposure limits are the legal exposure limits
and not necessarily safe levels of exposure. In feet, for some chemicals, health damage has been documented well
below the permissible exposure level. They learn that NIOSH, the research arm of OSHA, recognizes 150
carcinogens but mat OSHA, their worker protection agency, recognizes only 21 chemicals as capable of causing
cancer. They are taught about the inadequacies of Material Safety Data Sheets, which is the only source of
chemical information that their employers are required to provide. And they begin to realize that just maybe they
need to take on some of the responsibility for knowing what they are working with to protect themselves as well
as their families.
In addition to providing various technical resource materials and instruction on their use, we also teach
workers about available tools that can be used to make changes in their workplaces. One of these tools is the
Toxic Release Inventory. Bear in mind that for the most part, workers are totally unaware that this law exists.
After going over the basics of the Emergency Planning and Community Right-To- Know Act, I provide workers
with their company's TRI data and Tier n forms. It's always interesting to hear the comments when they have
the data in hand. They range from "Oh my God, I had no idea!" to "This is a lot of crap—I know we release a
whole lot more than that!" I often spend a fair amount of time discussing "fugitive" releases which I refer to as
"unpermitted releases." I point out that workers are usually the most exposed to these releases. Often, with
volatile chemicals, the fugitive air releases are higher than the permitted stack releases.
In two instances over the past year, workers strongly questioned the data that had been reported. My
suspicion had been triggered by the fact that the Tier n forms showed huge inventories of chemicals reportable
under TRI but for which that had been no TRI reports. (Form Rs). I did foUowup work with them and learned
that both companies were in violation of reporting requirements. While it is true mat a lawsuit could have been
initiated, it might not have in the long run, been the best approach. One company was suffering economically,
and a financial burden just might have forced them to close down, putting a good number of workers out of jobs.
Instead, we decided to use the information in another way. You see, the company was not only in violation of
reporting requirements, they were also severely out of compliance in many ways, They had not been supplying
proper personal protective equipment to their employees and they had been burning toxic wastes onsite without
a permit According to the worker, this is how the story played out: The union president presented the TRI data
to the plant manager by tossing it on his desk, prompting the manager to ask "What's this?" "You tell me, I
know it's a lie," replied the worker.
The next thing the plant manager said was "What do you want?" The worker was able to make several
demands including getting personal protective equipment for workers, a promise that the company would stop
the illegal burning as well as a promise that the company would look into replacing their chlorinated solvents for
safer substitutes.
At the other plant, the worker presented plant officials with the data and told them he knew it was
inaccurate but was willing to cut a deal with them. If they would agree to establishing a joint health and safety
committee that truly stressed worker education and safety, he would not report them for their TRI violations.
The company agreed and the safety committee has reportedly established a progressive safety program focusing
on toxics use reduction.
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I know of one other facility where workers took the initiative to investigate their own TRI releases.
Although the company was thought to be honestly reporting, what startled workers were the huge quantities of
chlorinated solvents reported as fugitive releases. {Recognizing that this probably meant severe worker exposure,
the workers took it upon themselves to find alternatives for most uses in the plant and convinced management
that it would be in the company's best interest to make the changes.
Informed workers can and do force change. TRI data is one tool that belongs in their hands to help them
shift away from toxics. This is public information - why aren't employers automatically giving this data to their
workers when annual reports are submitted? All workers should have the courtesy of this data - these are the
people who are frequently receiving the highest exposures!
The buzz words of the 90's seem to be "partnership" and "volunteerism." Employers should adopt these
principles in-house by developing partnerships with their workers and voluntarily providing them with data
Id like to touch briefly on ways that I believe TRI can be improved. First, TRI must be expanded in a
number of ways. Of course the list of reportable chemicals should be increased as should the types of facilities
required to report It is absurd that over 70,000 chemicals are commonly being used with 35,000 of them known
to be associated with some type of hazard - yet the public is supposed to feel good about the fact that some
industries are required to report on the released on some 600 chemicals!
Reporting of chemical use, or materials accounting is also needed.
Clearly the time is long overdue for such information to be shared with the public. As we all know,
several states have taken the initiative to collect use data and EPA has the opportunity to gain from the
experiences of the great programs in New Jersey and Massachusetts. What cannot happen, however, is for EPA
to leave such reporting requirements up to the individual states to initiate. We need a federal program. Right
now, for example, in New York, there is an ongoing effort to gut current environmental regulations under the
guise of "making New York aggressively more hospitable for business." New York is just one of many states
that would not initiate this much needed program unless federally required.
Having use data would give a much more accurate perspective of the "big picture." We could and should
have a "cradle to grave" view of chemicals. This would help tremendously in assessing worker exposure.
Paul Orum, for who I have the utmost respect and admiration, was credited yesterday with identifying
three possible paths for a chemical at a facility:
1) It can be consumed during production.
2) It can become part of the waste stream, or
3) It can become part of the product.
But mere is a 4th path that is too often ignored - chemicals find their way into the bodies of workers. Perhaps
if use data reporting was required, we would not have to count quite so many dead worker bodies before learning
about the hazards of a chemical. Had materials accounting been in place years ago, perhaps we would have
known much sooner about the dangers of vinyl chloride, or carbon tetrachloride, or DBCP or aniline or glycol
ethers or any of the other chemicals which have cost the lives and health of millions of workers.
I know that I'm about out of time, but while I have the opportunity, I'd like to leave you with one last
thought to consider.
Yesterday, Lynn Goldman commended industry for their voluntary efforts in the 33/50 Program. Tm
sorry, but I just can't get real excited about companies who voluntarily reduce 12 chemicals - not that these
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reductions aren't commendable, but these are many of the same companies who REFUSE to clean up the
hazardous wastes in their backyards and continue to release millions of pounds of toxics to the environment
every year.
Dr. Goldman mentioned FMC as one of these voluntary companies. This is the same company that tried
to litigate their way out of cleaning up over 75 Superfund sites - including their site in Mddleport, NY where
they dumped 16,000 tons of pesticides and pesticide wastes and 250 tons of arsenic next to my children's school.
They have refused to clean it up even though the school yard is contaminated and the cancer risk is 900
additional cancers per million on the athletic field where children play. I'm sorry, but I can't sing the praises of
a company like mis. Please dont misunderstand, I'm willing to work cooperatively, but we need companies that
are willing to be honest and ethical. We're at five to midnight—and we have to move much faster that reducing
17 chemicals at a time on a voluntary basis.
D
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Session 5: CIS and Other Tools for Analyzing TRI Data
Session Leader
Dave Wolf; US EPA
Speakers
Bowden Quinn, Pollution Prevention Coordinator, Grand Cal Task Force
Janet Vail, Water Resources Institute, Grand Valley State University
Len Wallace, U.S. EPA-New England
This session presented several applications of GIS using the TRI data. Len Wallace of the US EPA
Regional Laboratory presented LANDVIEW. Bowden Quinn, of the Grand Calumet Task Force presented how
TRI was being used with GIS on the small budget available to a grassroots organization. Finally, Janet Vail
discussed the many different ways to get access to the TRI data.
Bowden Quinn, Pollution Prevention Coordinator, Grand Cal Task Force
GIS mapping offers exciting new avenues to promote pollution prevention in heavily industrialized
communities and to help plan for sustainable redevelopment of these areas. Unfortunately, operating on the low
budget of a grassroots environmental organization, I have found the start of this journey to be full of obstacles
and bumps, but I have high hopes that GIS will eventually lead to communities that are healthier both for the
people who live in them and for the environment around them.
The Grand Calumet Task Force works on environmental problems in the Grand Calumet River
watershed in Northwestern Indiana, one of the most contaminated areas in the country. Discharges from
industries along the river and adjoining canal and harbor have led to the creation of more than 20 feet of
contaminated sediments that threaten Lake Michigan, a source of drinking water for millions of people. Steel
mills, coke ovens and an oil refinery, along with many smaller plants, contribute to an air-quality region that is
in non-attainment for several criteria pollutants. The loss of many of the region's industries has left a legacy of
unused and contaminated land, the so-called "brownfields," which hamper attempts at economic renewal.
Most pollution prevention efforts by environmental groups have focused either on individual facilities
or legislative campaigns at the state or federal level. Our project is exploring the potential of using local
government initiatives to promote pollution prevention. These may include, among many other possibilities, new
zoning ordinances, toxic chemical storage and handling fees, or increased penalties for industrial accidents
requiring community emergency response.
The initial focus of our project is the City of East Chicago, a small, heavily industrialized city with a
deteriorating infrastructure and economy. More than half of its area is zoned for industrial use, but this large tax
base has not translated into benefits for the people who live in the city. The population and housing stock have
shrunk for the past twenty or thirty years, and those who remain grow poorer. Next year the city will revamp
its Master Plan to try to reverse this trend.
The Grand Cal Task Force will be part of that planning process. Using RTKNET and local sources, we
are assembling a manual with profiles of TRI facilities in and around East Chicago along with discussions of
various approaches to pollution prevention. We think that city officials will have a better idea of the impact of
industrial pollution not only on human health but also on economic development if we can make it visual, so we
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have contracted with the Metro Chicago Information Center, a not-for-profit research consultant, to do GIS
mapping of the area to illustrate the pollution problems.
Unfortunately, the use of TRI data from RTKNET for the GIS map has not been as easy as we had
expected. Even after several months of work, facility sites on the map do not correspond with their actual
locations. However, we hope soon to have die TRI facilities for East Chicago manually located on our base map
of die area. We will then proceed to locate sensitive population centers (schools, hospitals, churches, etc.) on the
map and show demographic information (race, income, age).
Eventually we hope to use the map to plan for sustainable redevelopment of the community, adding
layers on brownfields and critical habitats, as well as locating other businesses. Meanwhile, I hope to start using
risk assessment software to analyze the impact of the TRI emissions on the community as the next step in this
process.
D
Janet Vail, Wafer Resources Institute, Grand Valley State University
Accessing and Analyzing the Toxics Release Inventory (TRI)
Since the enactment of the Emergency Planning and Community Right-to-Know legislation (EPCRA
or SARA Title HI) in 1986, information on releases and transfers of toxic chemicals from manufacturing facilities
to the air, water, underground injection, land, and off-site locations has become publicly available through the
Toxics Release Inventory (TRI). This information source can be a powerful tool for revealing the magnitude of
toxic chemical releases in a specific geographic area as well as a resource for tracking chemicals at an individual
facility.
Access to TKI data
The Toxics Release Inventory data are available to the public in a number of formats. This information
is widely distributed to libraries throughout the country and can be accessed by computer modem. Sources of
information include:
1987, 1988, 1989, 1990, 1991, and 1992 Toxics Release Inventory National Reports and Data
Releases from the U.S. EPA,
TRI User Support Service,
Magnetic tape from NTIS, GPO, and TRI User Support Services
Microfiche (for 1987-1990 data) available at major libraries
Subsets of state data on diskettes
CD-ROMS with search and retrieval software and chemical fact sheets
Computer access through the National Library of Medicine's Toxicology Data Network (TOXNET) and
through RTK-NET
Individual state listings from the State Emergency Planning Coordinators
Regional TRI Coordinators
Documents
U.S. EPA has made a concerted effort to provide TRI summary information to the public. Each year it
has published TRI reports available to the public (1987,1988, and 1989 Toxics Release Inventory National
Reports and 1990,1991 and 1992 Toxics Release Inventory Data Release). In the National Reports and
Data Release series, data on the amounts and the geographic, media, industry, and chemical distribution of TRI
releases and transfers are summarized. The 1991 report has a special section on the prevention and management
of toxic chemicals in wastes as well as a comparison of data with previous years and reporting profiles for the
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33/50 Program chemicals. State Fact sheets for 1990,1991, and 1992 have also been published which contain
a brief profile of releases for each state.
A number of other TRI support documents can be obtained through the U.S. EPA hotline [Phone: (800)
535-0202, Fax: to request documents (703) 412-3333]. The publication "Public Access to the Toxics Release
Inventory" is a comprehensive listing with ordering information for TRI products, services, and documents.
Other sources of documents are:
1) National Technical Information Services (NTIS)
[Phone: (703) 487-4650 or (800) 553-NTIS, Fax: (703) 321-8547]
2) U.S. Government Printing Office (GPO)
Superintendent of Documents
[Phone: (202) 512-2250, Fax: (202) 512-2250]
Actual photocopies or computer-generated facsimiles of Form R reports can be obtained through the TRI
information branch [Phone: (202) 260-1609, Fax: (202) 260-4655].
Various Media
Raw data are available in spring for the previous reporting year (i.e. Spring of 1995 for the 1993 data
submitted in Jury, 1994). Tapes, microfiche, CD-ROM, and diskettes are some ways that TRI information can
be accessed. The U.S. Government Printing Office Electronic Products Sales Coordinator (GPO-E) should be
contacted to order diskettes, magnetic tapes and for access to bulletin boards [Phone: (202) 512-1530, Fax: (202)
512-1262]. NTIS also has these media available but the cost tends to be higher than GPO-E.
Magnetic tape and Microfiche
Magnetic tapes containing the complete national data are available for all reporting years. Tapes are
standard 1600 or 6250 bpi, 9-track, ASCII or EBCDIC and come with tape documentation. Microfiche contains
the complete TRI data for the early reporting years along with indices to help locate specific facility reports.
Microfiche will not be provided for the 1991 and subsequent reporting years. It has not been a popular TRI data
format.
Diskettes
State-specific diskettes include only selected data from the Form Rs. They are available in high density
525 and 3.50 inch diskettes. There is a choice of data format: Lotus 1-2-3 (version 2.0), dBASE ffl Plus, and
ASCII for DOS microcomputers and Excel (version 2.1) for Macintosh (for 1989 only). State diskettes may not
be available from GPO-E or NTIS until Fall or later. Diskettes have the advantage of allowing the user to
manipulate, sort, and group the data for analysis. Sometimes the state EPCRA Coordinators can assist in
providing data on diskette.
NTIS has a "roadmap database" diskette that provides assistance to TRI users for identifying regulations
and risk assessment information for TRI chemicals.
CD-ROM
Compact disc - read only memory (CD-ROM) is one of the least expensive and less time consuming
ways to access the TRI data. The CD-ROM contains facility specific data, listings of Section 313 chemicals,
indices, and information related to health, ecological effects, and safety of these chemicals (TRI-FACTS). The
data base is easily searched and information can be retrieved rapidly for screen viewing, printing, or archiving
to a file.
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Online Computer Access
To access electronic databases, the user must have access to a computer with a modem. Files can be
viewed on screen, printed, or downloaded to the computer. Online access can be expensive and a fast modem
is recommended for downloading files.
TRI User Support Service (TRI-US)
Before an online search of TRI data is made, there is a source to contact regarding the best format for
the search. Online access can be expensive and it is best to have a search strategy prior to going online. U.S.
EPA has established a TRI User Support telephone number [(202) 260-1531] where requests for data can be
made. The service provides a limited amount of online searches and comprehensive search assistance for the TRI
online and CD-ROM applications at no charge. TRI-US also conducts training through individual sessions and
workshops.
National Library of Medicine (NLM)
The Toxics Releases Inventory is one of a series of online databases on the National Library of
Medicine's TOXNET system. Many libraries have access to the National Library of Medicine (NLM) and the
individual user can set up an account with the NLM A demonstration diskette showing the structure and the
search strategies for TOXNET is available. On-line and off-line printing of entire or specific portions of records
is possible. The data can be sorted and calculations performed before printing or downloading a file. The system
has both a menu driven search package and a flexible command language.
The cost of using the NLM system is about $18 to $25 per hour depending on the time of day. The
system is available 24 hours per day, 7 days per week. However, to comply with new federal regulations, there
is toll-free access to NLM provided by CompuServe, Telenet (SprintNet), and Tymnet. Users receive the NLM
Technical Bulletin which contains helpful hints about the system.
Right-to-KnowNetwork (RTK-NET)
RTK-NET is a telecommunications computer service originally started by OMB watch in 1989 and now
run by OMB Watch and Unison Institute [Phone: (202) 797-7200, Fax: (202) 234-8584]. The primary purpose
of the service was to explore the use of online services to promote pollution prevention strategies. TRI data for
1987 through 1992 are available on RTK-NET along with other environmental data, all civil cases brought by
the U.S. EPA, and a portion of the 1990 census. RTK-NET users can communicate with each other via
"computer" conferences. There is not a public toll free number for RTK-NET. Unison Institute needs to be
contacted for access information. A periodic newsletter keeps users informed of latest additions to the network.
State and Regional Resources
Each state has a designated Emergency Planning and Community Right-to-Know coordinator.
Individual states can provide a hard copy Listing of TRI reporters. Often states have TRI data available before
EPA has compiled its data Also, many states (i.e. Louisiana, Minnesota, New York, New Jersey) are producing
state reports on the Toxics Release Inventory. There is a Listing in the 1992 Toxics Release Inventory Data
Release - State Fact Sheets about individual state services. Each of the 10 U.S. EPA regional offices has a TRI
coordinator. The TRI coordinators are knowledgeable about TRI and other EPCRA issues. The regions often
sponsor TRI conferences to help businesses comply with EPCRA
Analysis of TRI Data
Reports prepared by the Grand Valley State University Water Resources Institute (GVSU-WRI) have
included compilations of TRI data by Standard Industrial Classification Code, county, chemical, and
environmental media State diskettes have been the easiest to use when raw data are needed. RTK-Net and
TOXNET have provided summary data that can be quickly accessed. CD-ROM has been of use for quickly
obtaining information on an individual facility. The hard copy reports have provided valuable background
information on the Toxics Release Inventory.
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Generally, a simple spreadsheet/database program like Microsoft Works has been adequate for analysis.
However, data may have to be reformatted so that the program can accommodate it. Also, very large files are
difficult to manage in Works. Graphics programs such as Harvard Graphics have been useful for data display.
Combinations of pie charts, bar charts, and maps all contribute to an understanding of the data trends.
Specific locations of TRI facilities can be determined by the latitude and longitude coordinates reported
on the Form Rs. Unfortunately, some of the facilities have reported incorrect locations (e.g., the middle of the
Atlantic Ocean). The GVSU-WRI has used plat books to locate facilities on U.S. Geological Survey maps that
are digitized. Alternatively, GVSU-WRI uses a Global Positioning System (GPS) for the most accurate
characterization of a site.
SviDMiflfy
Many types of media (hard copy, diskettes, CD-ROM, online databases) have been used by GVSU-WRI
to produce its reports on the Toxics Release Inventory. Most of the TRI information is free and the computer
software needed for analysis and display has been relatively simple.
References
Grand Valley State University Water Resources Institute. May 1992. Toxic Releases in the Grand River
Watershed, 1987-1989. GVSU-WRI, Allendale, Michigan. MR-92-3.
U.S. Environmental Protection Agency. 1988. Chemicals in Your Community, A Guide to the Emergency
Planning Community Right-to-Know Act. U.S. EPA, Washington, D.C.
U.S. Environmental Protection Agency. June 1989. The Toxics-Release Inventory, A National Perspective,
1987. U.S. EPA, Washington, D.C. EPA 560/4-89-005.
U.S. Environmental Protection Agency. Sept 1990. Toxics in the Community: National and State Perspectives
- the 1988 Toxics Release Inventory National Report. U.S. EPA, Washington, D.C. EPA 560/4-90-017.
U.S. Environmental Protection Agency. Sept 1991. Toxics in the Community: National and State Perspectives
- the 1989 Toxics Release Inventory National Report. U.S. EPA, Washington, D.C. EPA 560/4-91-014.
U.S. Environmental Protection Agency. May 1992.1990 Toxics Release Inventory Public Data Release. U.S.
EPA, Washington, D.C. EPA 700-S-92-002.
U.S. Environmental Protection Agency. May 1992.1990 Toxics Release Inventory Public Data Release - State
Fact Sheets U.S. EPA, Washington, D.C. EPA 700-S-92-003.
U.S. Environmental Protection Agency. May 1993.1991 Toxics Release Inventory Public Data Release. U.S.
EPA, Washington, D.C. EPA 745-R-93-003.
U.S. Environmental Protection Agency. May 1993.1991 Toxics Release Inventory Public Data Release - State
Fact Sheets U.S. EPA, Washington, D.C. EPA 745-F-93-002.
U.S. Environmental Protection Agency. April 1994.1992 Toxics Release Inventory Public Data Release. U.S.
EPA, Washington, D.C. EPA 745-R-94-001.
U.S. Environmental Protection Agency. April 1994.1992 Toxics Release Inventory Public Data Release -
State Fact Sheets. U.S. EPA, Washington, D.C. EPA 745-F-94-001.
D
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Closing Plenary 1994 TRI Data Use Conference
Closing Plenary: TRI-The Next Phase
Moderator
Susan B. Hazen, Acting Deputy Director, Office of Pollution Prevention and Toxics, U.S. EPA
Speakers
Jeanne Herb, Director, Office of Pollution Prevention, New Jersey Department of Environmental Protection
Edward S. Jsaxao, Manager, Environmental Protection, Monsanto
Hillel Gray, National Environmental Law Center
Linda A. Travers, Director, Information Management Division, Office of Pollution Prevention
and Toxics, U.S. EPA
Susan B. Hazen, Acting Deputy Director, Office of Pollution Prevention and Toxics, U.S. EPA
I would like to welcome you to this final and closing session of the TRI Data Use Conference. I think
this has been one of the most successful data use conferences that we've had, and it is mostly because of you, the
folks who attended. Your attendance here is not only important for us to understand what the needs of our users
are, but I think it's essential for us to hear from you and for us to have a forum so that this program can keep
growing and can keep growing in the directions that are important to you, the users. We'll spend the next hour
and a half discussing the future of TRI. Then at the end of that Linda Travers will close the session by telling
us what the next steps in terms of this type of activity are and the major issues.
The agenda calls this session, TRI: The Next Phase. Quite frankly, TRI is being broken into so many
phases right now, it's difficult to keep track. I'd prefer to think about TRI: How do we get there from here? We
know where we are. I think our job is to define where the 'there' is. As Terri Goldberg said, I think this is going
to be an interesting discussion. This issue, the next steps for TRI, is an issue that is very emotional for some
folks, very important for others. I think we will hear some very different points of view.
In the past few years, in terms of the TRI program and in many ways as a result of conferences like this,
we have expanded the data set of TRI with the pollution prevention information. We have expanded facility
coverage by including federal facilities. And just recently, within the past two weeks, we have expanded the set
of chemicals to be covered, almost doubling the initial set of chemicals that we were given. Today as a result of
feedback from users like yourself we have a program that collects chemical release and transfer information from
over 28,000 facilities, and starting next year, on 600 chemicals. We collect pollution prevention data as identified
by the Pollution Prevention Act of 1990, and this year we will collect information on federal facilities.
As Pve said at past data use conferences, we continually find ourselves at a crossroads with TRI, trying
to make very strategic choices about what directions to follow next. This time we are looking at some very
strategic choices for the next set of projects that will define the next directions for TRI. I think it's important to
recognize that these choices need to be made with extreme care, that TRI is no longer a fledgling program.
Changes that we make are extremely expensive. They're expensive in terms of government implementation.
They're expensive in terms of the people who participate and devote their time to these efforts. And they can be
expensive in terms of implementation from the industry side. We need to make sure that we collect what is useful
to the majority of users. We need to make sure that there is a purpose and a clear direction that we are following.
The issue before us today, and I'm sure the issue that will be before us for many months to come, is the issue of
materials accounting information, worker exposure data and demographic information, and the role that TRI can
play in the collection of that information on a national basis.
Mark Greenwood mentioned, or actually he stated quite clearly at an earlier meeting we had on the issue
of materials accounting, that this issue is clearly going to redefine what we currently know as the outer edges of
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the right-to-know program. Over the past few months as I have heard from people who have positions on many
sides of this issue, I think that statement is truer than ever. This is truly one that is going to push and redefine
those boundaries. From the perspective of somebody who has been with this program for many years, this is
probably the most contentious issue that I have heard debated in terms of this program. That includes the
original debate over the passage of this statute, the original implementation plans. The only thing that even comes
dose, in terms of the contentious nature of what we are moving towards here, is the debate over, what is a waste?
We haven't come to closure on that. So that will tell you how contentious I think this one is going to be. I say
contentious not because I'm trying to make this negative. I say contentious because it is an issue like this that
can polarize people. It can polarize the different users of this data. It can polarize our constituents out there.
I think if s important that we not let that happen. It's EPA's job to hear all sides of this issue and to try and
prevent polarization from happening. Ifs our job to hear, to balance the needs of what we hear, and then to move
forward and hopefully bring all the players along with us, not leaving folks out of the dialogue just because they
don't happen to agree with the exact position that*s been taken.
I mentioned Mark Greenwood's statement at a public meeting. Just to bring folks up to date a little bit
on that, we did have a public meeting in Washington on the issue of materials accounting and TRI. I think we
had more people at that public meeting than I have seen at any other public meeting in the toxics program. There
was a great deal of information provided to the agency. We are still in the process of going through that
information. We are going through an analytical exercise. There was a great deal more information presented
in papers than actually got presented on the floor. I made a request at that meeting and I will make the same
request at this meeting. That is the following: What was provided to us was a great deal of information about
the potential uses of materials accounting data, how the information could be used, theoretically what the
information can tell us, and even some good examples of what information that had been collected in
Massachusetts and New Jersey did tell us. But what was not presented at that meeting, and what I have yet to
see, and what I am asking for once again, are concrete examples of how materials accounting data that has been
collected at a facility has been used by a worker, an individual, a state, anyone, to actually bring about a change.
It is critical that if that information exists that we have it. So I raise that issue here one more time. It has been
a number of months since that meeting, so perhaps some case studies have been done.
While EPA is very much in the listening mode on this issue, there is one thing which I believe EPA can
and should add to this debate. That is that we do know from our experience with the Pollution Prevention Act
data that we currently collect on TRI that we do not have the information which we, the federal government, need
in order to actually track and measure pollution prevention progress at the facility level. For those of you who
are familiar with the Form R, you know that we have the ability to ask facilities to tell us if source reduction
played any part in any reductions that occurred at their facility, but the form does not collect quantitative
information about what those source reductions activities were and how much of the reductions that show up
on Form R were as a result of source reduction. Consequently, when companies in good faith make claims to
have moved forward on pollution prevention, we have nothing to share with the public in terms of quantitative
information about how that has happened. For those of you who have been involved in the 33/50 Program, you
will know that one of the major criticisms of the program is that we cannot tell the public exactly how much of
the reductions that have occurred at any facility have occurred because of source reduction. If we had the ability
to measure that, we would be in a much better position to give credit to companies and to facilities who have
moved actively forward. So what Fm saying to you is that if we are to measure and if we are to track and
recognize source reduction, men we need something more man what we currently have. I don't know if materials
accounting is it, but I can tell you that what we do have doesnt help us get to that answer.
We have three speakers with us today who have had experience in collecting and providing and looking
at materials accounting information. Tm hopeful that they will shed some light on some of the issues which I've
raised, but I'm sure this will not be the end of this debate. It will be a long one.
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Jeanne Herb, Director, Office of Pollution Prevention, New Jersey Department of Environmental
Protection ^
The reason that I was asked to talk today was because in 1979 New Jersey did a one shot survey of
manufacturers in the state that then became the model for the state's 1983 Worker and Community Right to
Know law, which then became the model for TRI. So a lot of the issues that people are dealing with nationally
regarding chemical use information we in New Jersey have been dealing with for a few more years. Now that
certainly doesn't mean that I have any answers to give to you today. More I think what I can offer, based on a
couple extra years of experience, is being able to ask some more questions. What I decided to do with this little
talk was, instead of going into nitty gritty technical details about the whole issue of materials accounting, Im
going to sort of wax philosophic in terms of general directions on TRI, including materials accounting. Two of
the folks from my agency, Andy Opperman and Mike Aucott, have given presentations over the last two days
on more detailed issues related to materials accounting as collected by our state.
I think that it's real clear what some of the significant impacts of TRI have been. Those have been
relatively well documented. First of all, it made the nation aware of the need to look at multimedia issues.
Second, TRI also made the nation aware of the need to look at pollution prevention. You have to really start to
look back and think about the world of environmental regulation prior to TRI and even prior to the New Jersey
program, when there really wasn't even much of a bent at all towards multimedia. I would argue that we don't
see much of that now, ten years after New Jersey started its program. But you certainly saw almost nothing prior
to the New Jersey program and prior to TRI. Third, TRI certainly pointed the innovative approach of not using
a traditional regulatory stick to bring about, not only compliance in terms of paperwork, but general innovation
on the part of industry to look at ways to move forward in terms of reducing emissions and generation of
hazardous substances. Please note that I make an intentional distinction between multimedia environmental
efforts and pollution prevention. They are not necessarily the same thing. Pollution prevention is always
multimedia; it cannot be medium specific. However, multimedia initiatives are not necessarily pollution
prevention. I repeat, pollution prevention is always multimedia, but multimedia environmental protection is
not necessarily pollution prevention.
The New Jersey definition of the term pollution prevention is consistent with the federal definition of
pollution prevention which EPA interchanges with the term source reduction, in other words, reducing the use
and generation of hazardous substances prior to recycling, treatment, controls, storage and disposal per unit of
product.
The definition of the term pollution prevention must drive the future of TRI, including the question of
whether TRI should collect materials accounting information. If the federal definition of pollution prevention or
a state's definition of pollution prevention was essentially release reduction, (i.e., reductions post-treatment), then
you could probably live with TRI the way it is today, and call it a tool for measuring pollution prevention.
However, the federal definition of the term pollution prevention as well as that in many states, including New
Jersey and Massachusetts, involves reducing the generation and the use of hazardous substances prior to
treatment, prior to control, prior to storage, prior to recycling. That1 s the top of the hierarchy before recycling
and treatment. So if you think about the future directions of TRI, then you need to look at your definition of
pollution prevention, because you want TRI to be your tool for pollution prevention. Therefore, if, like New
Jersey and Massachusetts, you are operating with a definition of pollution prevention that involves reductions
of chemicals at industrial sources and if TRI is one of your tools for measuring pollution prevention, then it
becomes necessary to use a measurement tool that accurately tracks reductions at the source, not at the end-of-
pipe. We would argue that materials accounting is a critical tool for making TRI such a tool.
We've learned a lot from TRI, but there are a lot of places where TRI has not taken us. I guess that's
where I want to focus right now. The first place is that we in New Jersey and, I think ifs safe to say the folks
in Massachusetts, argue that ifs not a sufficient enough tool for measuring pollution prevention progress -
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1994 TRI Data Use Conference Closing Plenary
pollution prevention being defined the way I just went through it In order to be able to call TRI the national
measure of pollution prevention you need to be able to make some changes. Those changes are adding materials
accounting.
In New Jersey and Massachusetts, materials accounting information contains four basic elements, the
amount of the substance used, the amount of the substance consumed, the amount of the substance produced,
and the amount of the substance shipped as (or in) product. In addition, New Jersey collects the beginning and
ending inventory of the substance which, although not part of materials accounting, does contribute to a "whole
facility" perspective.
EPA has been using the term "chemical use information" in its efforts to look at whether it should
expand TRI in the direction of materials accounting information. As much as materials accounting information
does include strict "use" data, I personally do not think of materials accounting data as a distinct measurement
of chemical use. Rather, I see the materials accounting information as "whole facility" information. Materials
accounting information collects critical data about the flow of a chemical through a production process or a
facility, depending on the level at which it is collected. Coupled with release information already collected by
TRI, materials accounting information provides a fuller picture of the trends of hazardous materials use and
release at industrial facilities. Without materials accounting information, TRI only tells one side of the story, the
release side. Again, depending on your definition of the term "pollution prevention," that one side of the story
(e.g. release reductions) may be sufficient. However, if you are operating under a definition of pollution
prevention that involves the top of the environmental management hierarchy, reductions at the source, then the
TRI side of the story becomes clearly insufficient.
In New Jersey we see three elements as the core of our public pollution prevention information package.
The first is certainly TRL The second is the facility level materials accounting information that our state has been
collecting for several years, hi addition, the state's newer Pollution Prevention Law, for which we only have one
year's reporting, collects pollution prevention related information at a production process level. By combining
the facility-level materials accounting data with facility-level TRI data, we believe we have a facility-level
aggregate of the process level information collected at a production process level. We believe that these three
elements are so linked mat we do not conduct analysis of pollution prevention trends without analyzing all three
sets of information because they are truly an integrated package. I believe that, regardless of the fact that EPA
is not planning to collect process level pollution prevention data, one major future direction for TRI is to integrate
facility-level materials accounting data with release data to become the national measure of pollution prevention
trends.
The other direction I think TRI must head in is being the vehicle to make pollution prevention
mainstream. I think there's a growing frustration with the lack of states integrating pollution prevention into the
environmental regulation overall. I've been hearing this a lot from a lot of other states. State agencies have "air
people" and "water people" and "waste people" and now there's a whole new set of "pollution prevention people."
We have not been successful in terms of transforming environmental regulation, in general, towards a prevention
ethic. I was trying to think, why is that the case? I think part of the reason is because regulatory agencies, and
in my experience, facilities as well, really work based on what they measure, what numbers are in front of them.
In a regulatory agency you've got a world of people who collect air data, you've got a world of people who collect
water data and now you've got a world of people who are collecting pollution prevention data Those folks really
haven't seen the way to the long term approach to pulling it all together.
Now, I know mat there was some discussion during the conference on data integration. I guess my take
on it is a little bit different. Im not talking about trying to have our computers talk to each other. Instead, I see
TRI (if integrated with materials accounting information) as being a promising tool for pulling together
disjointed, medium-specific efforts and giving it a prevention focus. The future of where pollution prevention
in this country is going to go is directly linked to the kind of data that is reported. To date pollution prevention
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in this country is going to go is directly linked to the kind of data that is reported. To date pollution prevention
has been measured through TRI and various state pollution prevention requirements. The next wave is going
to be integrating TRI and pollution prevention data with the mixing pot of data that companies are reporting for
their air permit requirements, their water permit requirements, their hazardous waste requirements. One project
that we're working on in New Jersey is we have a requirement to develop for a small set of companies a single
permit. The single permit covers all their regulatory requirements including their pollution prevention
requirements. We have learned that the data that the companies will report to the agency is going to be an
incredible tool for prompting the companies to look at their whole facility and for looking at pollution prevention.
So to that extent, we're attempting to develop a single spreadsheet that would cover all major reporting and
monitoring regulatory requirements for a facility and also build in pollution prevention so that it has the pollution
prevention basis. This also necessitates looking at how all those different data sets interact and interrelate. I am
optimistic that, using TRI as the basis, we can start to look at the idea of trying to develop a single data set that
crosses medium lines and that uses materials accounting to have a pollution prevention focus.
In closing, I think that TRI offers great promise for the future of pollution prevention in this country in
three ways. First, I think that the addition of facility-level materials accounting will make TRI a good stand-alone
measure of pollution prevention trends nationally. Second, with the addition of materials accounting, pollution
prevention offers an effective complement to production process-level pollution prevention planning and
reporting efforts underway in many states. Third, I think that TRI has the potential to be the best tool for making
pollution prevention mainstream in environmental policy by Unking disjointed reporting in medium-specific
programs and by giving this integrated system a materials accounting, pollution prevention basis. The
fundamental key as to the value of materials accounting in these efforts is the nature of the definition of pollution
prevention. I think that we have had the "pollution prevention definition" debate for too long and that the
National Pollution Prevention Act and subsequent EPA guidance on this subject has made the nation's policy
clear. Pollution prevention is the top of the environmental management hierarchy and, in order to make it
mainstream, we need to effectively measure it. Materials accounting will improve TRTs ability to measure
pollution prevention as well as promote TRTs promise for making pollution prevention mainstream in
environmental policy.
D
Edward S. Jamro, Manager, Environmental Protection, Monsanto
Chemical Use Data Is Not Needed to Track Pollution Prevention
Monsanto representatives helped negotiate the Toxics Use Reduction Act (TURA) in Massachusetts in
1989. We are still active in trying to keep TURA focused on by-product reduction. By-product reduction is still
the only numerical goal contained in TURA. Massachusetts wants to achieve a 50% reduction in hazardous by-
products (wastes) by 1997, using TUR methods. While we do report on usage in Massachusetts, this data is not
needed to assess a production unit's, a facility's, nor the state's status in meeting by-product reduction goals. The
same is true for assessing Pollution Prevention (P.P.) progress.
As defined in Massachusetts, TUR is NOT only input substitution. la fact, there are six methods (or
techniques) which qualify as TUR in Massachusetts. These methods are: (1) input substitution, (2) product
reformulation, (3) production unit modification, (4) production unit modernization, (5) improved operation and
maintenance, and (6) recycling, reuse, or extended use integral to the generating production unit. It must be
stressed that TUR methods 1 and 2 are "use related" while TUR methods 3,4,5 and 6 are "by-product (waste)
related." Also, if a by-product becomes a raw material for another production unit without needing any
additional processing, die material is not considered a by-product in Massachusetts. Note that Massachusetts
TUR methods are really the same as EPA's Pollution Prevention (P.P.) methods.
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In late 1988, the Associated Industries of Massachusetts (AIM) filed a Pollution Prevention bill which
did not contain use reporting. While AIM - eventually after six months of negotiation - did agree to facility-wide
use reporting in the final consensus TURA bill, AIM has never recommended use reporting as necessary for
tracking Pollution Prevention, nor the Massachusetts By-product Reduction Index. AIM is still concerned with
the issue of having confidential information hi public files. To address this concern and to protect the
competitiveness of Massachusetts business; recently (12/94), AIM helped to file a bill to change the use reporting
requirements in Massachusetts from an actual number to a reporting range as used in SARA 312 - Tier n
reporting.
Use information can be key business information for many companies (whether they realize it or not).
To protect our confidential business information (CBI) Monsanto has asserted TURA CBI claims every year
since 1990. To do this, we have had to submit duplicate copies of our Form R/S reports (250 plus pages) at
considerable time, expense, and paperwork. Despite this effort to protect our CBI, some of our CBI was
inappropriately sent outside of DEP. Unless State P.P. programs are already set to handle CBI, there will be
considerable responsibility on them to develop systems to protect CBI. However, because this information is
not needed to track pollution prevention, states should not be burdened with this data. It should also be noted
that there is tremendous pressure on states to publish data as soon as possible. This pressure makes it more
likely that CBI would be compromised at some point in time.
An additional point to make about CBI is that many business people are not sensitive to who can and
does look at information in government files. If more business people were aware that their competitors or
consultants working for their competitors can and do look at these files, there would be more CBI claims. This
assumes, of course, that business people are appropriately trained and sensitized to these possibilities. Perhaps
states and EPA should consider CBI sensitivity training as part of their pollution prevention efforts. This would
help to alert the facility people responsible for reporting the data that their business leaders need to give input
on CBI before the information is sent outside the company.
Many states (Minnesota in particular) have looked at use reporting. They rejected the concept partly
because they did not need the data to show pollution prevention progress. The Minnesota Office of Waste
Management held hearings and a forum in late 1992 to examine the use reporting issue - among others. They
published their findings in January, 1993 and recommended against use reporting in Minnesota.
Many people are saying that current TRI reporting is inadequate to track pollution prevention. They say
that use information is an absolute necessity for P.P. tracking. However, as facility people looked at Form R -
Section 8 reporting, they realized that there is enough data there to adequately and appropriately track pollution
prevention. It is as simple as comparing current year waste (CYW) (Column B) to prior year waste (PYW)
(Column A) and using the Production Ratio (P.R.) to "normalize" the data. A Pollution Prevention Index (PPI)
can be calculated by the equation: (Remember to add up the entire column in Section 8 on the Form R).
PPI = 100 - [(CYW/PYW)/P.R.] x 100
This equation has been tested on several chemicals in several facilities and IT WORKS to show
pollution prevention progress. A positive PPI when combined with the source reduction methods shown in
Section 8.10 is useful in demonstrating pollution prevention.
Because use reporting is not needed to show pollution prevention, advocates of use reporting make other
claims regarding its usefulness. Claims about enhanced worker safety and enhanced emergency response
planning due to use reporting cannot be substantiated at the facility and local levels. Use reporting advocates
also claim that use data can be utilized to validate current TRI reporting. Upon close inspection, even this claim
is not true for most chemicals reported on Form R's.
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In conclusion, it is obvious that use reporting is not and has never been needed to track pollution
prevention. Even in Massachusetts, which has use reporting, that data is useless in tracking the state's status
in meeting its 50% by-product goal. Advocates of use reporting ought to admit that the main reason they want
the data reported is so they can track use reduction and use elimination. This is pure toxics use reduction; not
pollution prevention.
D
Hillel Gray, Policy Director, National Environmental Law Center
Thank you very much. It's a great honor to be here today and to speak with three people who I have
worked with for a number of years, and respect a great deal for the work that they have done. I also want to
thank everybody here. Thank you for the work that you're doing. No matter what your perspective, or what kind
of institution you are working for, we truly appreciate the work that you are doing.
Let me also mention at the outset that we actually do recommend toxics use reporting to other states,
unlike the previous speaker, Mr. Jamro. I have been talking to activists around the country about toxics
problems, pollution prevention and use data. In any other state, activists would be happy to have Ed Jamro as
the representative of the chemical industry. Just the fact that Mr. Jamro and Monsanto believe that when they
negotiate a program — such as the Massachusetts Toxics Use Reduction Act — they stand by it (which is not how
the chemical industry is acting in New Jersey) is greatly appreciated. Ed Jamro, while he recognizes that toxics
use data is controversial at some level, has acted with integrity and helped us improve the TUR reporting in a
number of significant ways.
You have been through a jam packed conference dealing with CD-ROMs, GIS, pilot projects, data
evaluation and other practical matters. As the conference conies to a close, it makes sense to step back and
acknowledge that the work you are doing is important beyond your day-to-day work and to look at how our
varied efforts fit into a global challenge.
Our civilization, our species, is grappling with a very sobering public health and environmental problem
because of the production, use and dispersion of toxic chemicals. We face a crisis that involves a persistent and
pervasive contamination of our biosphere, our work places, our homes and our bodies. It is a crisis that involves
the kind of toxic threats that scientists already recognize and that you can read about in the literature about toxic
substances: higher cancer rates, depletion of the ozone layer, lead poisoning, and birth defects are among the
problems that sound science already identifies as properties or potentialities of these chemicals. At the same
time, we are learning about new threats associated with toxic chemicals. For example, there is considerable
research now on estrogenic effects, infertility and reproductive system dysfunction, and neurological effects and
disorders.
Again, thank you for doing the work to make information accessible on toxics. Why is this information
so important? Because our society is running an uncontrolled experiment on us and on the biosphere by
dispersing toxic chemicals with relatively little restraint These chemicals, to a large degree, are fundamentally
incompatible with biological systems and they are surely incompatible with biological systems at the rate that
we produce and disperse them.
The conventional way that people looked at the burgeoning of the toxics crisis is represented in this New
Yorker cartoon from the 1970's. The man is praying, "Grant that I may take into my system only acceptable
levels of mercury, cadmium and lead." Of course, it is not possible. I would posit that it is impossible to
somehow manage our toxic pollution in a way that will only give us acceptable levels. Let me cite two of the
many reasons that we cannot manage toxic waste in this manner. First, waste management systems, treatment
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systems, incinerators, and so on are intrinsically flawed and cannot entirely work. We have definitely seen that,
for instance, in the dioxin debate. Secondly, we are learning that levels once thought acceptable by scientists are
not acceptable. If people are familiar with childhood lead poisoning, they are probably familiar with this
constraint on the efficacy of the risk assessment approach. Controlling pollution to a level justified as
"acceptable" by risk assessments is the old mindset.
The TRI and the work that you are doing is already shifting the thinking in industry and government
towards a different approach, a different mindset: a viewpoint that is more precautionary, more centered on
prevention. Since Jean Herb described the prevention issue fairly well, I would want only to underscore an
important point about a "multimedia" perspective.
There is a sense that TRI constitutes a major leap above the other environmental single-media programs
because TRI is based on releases to multiple environmental media That is very true and a key to the usefulness
of TRI.
However, it is crucial to remember that the releases and exposures that people confront in our society
are by no means fully documented by TRI releases. If the source is the industrial facility that uses or
manufactures toxic chemicals, you can measure through TRI a number of routes of pollution, like air emissions,
water discharges and POTW discharges. But there are a couple of main pollution routes that are never discussed
in TRI, never shown in TRL Notably, the use of toxic chemicals in consumer products, which are later disposed
of and dispersed, are absent from TRI The Inventory also fails to account for the feedstocks that are coming into
facilities and occasionally causing accidental rail, truck or storage spills, fires, and explosions.
There are three compelling reasons why EPA is seeking to address TRTs gaps through a "chemical use"
expansion. The first reason for toxics use information is that there are enormously high volumes of toxics in
products mat we cannot monitor through TRI. The second reason is that there are toxics used in the workplace,
or brought into the workplace, mat create an array of hazards and risks associated with chemical use and are not
reflected by the TRI release data. The third reason for chemical use data is that TRI cannot measure pollution
prevention, which several of the speakers have already mentioned.
When a company manufactures or brings onto its site a toxic chemical, there are three things that can
happen. The business can either (1) "consume" the chemical (and thus convert it into another chemical or
another type of pollutant), (2) put it into a product, or (3) put it into the waste stream. Today, TRI only gives
us information about the waste stream.
Therefore, you see companies above the reporting thresholds for TRI that report zero or virtually zero
in this area So all the TRI data may be reported as zero. Yet in a state like Massachusetts or New Jersey, the
public begins to see a very different picture. Here is an example of a company that reported all zeros in their TRI
filing, but they reported in the state form that they put more than 100,000 pounds of the toxin into a product.
Let me give you another clear example of toxics in products. Universal Forest Products is a lumber
products company in Massachusetts. As shown by the TRI filing, UFP's arsenic and chromium waste amounts
to about eight pounds. Some people may think 8 pounds annually is not especially significant. But when you
see the Massachusetts data, you will learn that UFP is making a arsenic-based registered pesticide treated onto
the wood. What will eventually happen is that wood will either be burned or disposed of (and carpenters may
be exposed to it through woodworking). Thus, the facility is actually the source of 300,000 pounds or more of
toxic emissions and dispersion — as well as upstream impacts.
Other examples include: lead in paints, solvent based inks, offgassing from carpets and building
materials, cleaning products, automotive supplies, fuels, lubricants, spray paints, aerosols, household pesticides,
adhesives, sealants, mercury in batteries, formaldehyde in cosmetics. How significant are toxic chemicals in
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products? Just think of some of the major challenges in reducing toxic risks - indoor air pollution, household
hazardous waste, so-called "non-point source" pollution (where the "points" are the industrial makers of
products), poison runoff pesticide runoff. These are problems in environmental management where the source
is the dispersion of a toxic product stream.
The second major area that is not covered entirely by TRI is the worker safety, as well as the community
safely, associated with toxic chemical accidents. Yesterday, for instance, there was an accident at a PVC factory
in Alabama; about 2,000 people were evacuated. The hazard from that facility was represented by the millions
of pounds of vinyl chloride (VC) used or stored. By contrast, the routine emissions from that facility which
might be measured by TRI in the thousands of pounds. TRI does not reflect the accident risk.
So, citizens and agencies in Massachusetts and New Jersey are provided information relevant to accident
hazards. As shown in this chart, Eastman Gelatine reports about 1,700 pounds in their TRI, but report more
than 100,000 pounds of toxic materials that they are processing through their facility, hi the event of an
accidental release, a spill or a fire (which could have generated dioxins at yesterday's PVC factory incident), it
is the amounts stored and processed that represent the types of risks and hazards. Chemical use information at
a facility is needed, therefore, to track and spur prevention of the risks associated with consuming, processing,
or importing toxic materials.
How significant is the missing data in TRI? Let me preface the answer by saying that the National
Environmental Law Center has been deeply involved in Right-to-Know and share your belief that TRI is an
important and valuable program. So I do not want to be discouraging in stating the cold truth that there are
extremely crucial and sizable pieces of missing information. Massachusetts industries, for instance, use about
12 billion pounds of toxic chemicals, as shown in the pie chart. The amount in white on the chart is what the
public can analyze through the TRI data The shaded amount is the amount converted to other materials or
pollutants; and the dark amount is actually put into products, hi New Jersey, petrochemical firms and other
industries use about 15 billion pounds of toxic substances each year. Note that New Jersey business has a very
different proportion of quantity put into products vis a vis the quantity consumed.
In the United States as a whole - looking only at the top 100 TRI chemicals and not counting metals -
industrial throughput is about 400-500 billion pounds (assuming rough equivalency to production].
Unfortunately, TRI enlightens us about only a fraction of that. Maybe 6%, at best, of the country's toxics flow
is captured by TRI We do not have basic information on 94 percent of toxic chemical production and use. We
do not even know where to gauge the relative amounts consumed or going into products. We do know from the
Massachusetts and New Jersey data that the amount going into products, for instance, is many times the TRI
waste data.
Besides giving us a more complete picture of toxics flow in society and in commerce, TRI could be doing
a much better job of providing legitimate ways to measure pollution prevention.
Measurement is the key to accountability, to setting priorities and to stimulating change in industry.
Many of you are working in very good faith on trying to shoehorn some kind of measurement of pollution
prevention or source reduction into your programs based on the TRI information. This well-intentioned effort
is not working very well from a technical or policy standpoint. I have seen some valiant efforts here at the
conference and people are quite upfront about the struggles that they are having because they do not get the
correct available information. We should be concerned that our scrambling to make TRI work in pollution
prevention (P2) is creating a mythology that somehow TRI represents source reduction or helps measure P2 in
a constructive way. To perpetuate such myths, there are some inaccurate and misleading representations of how
TRI relates to source reduction.
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Closing Plenary
Massachusetts
1.2 billion pounds
03 Consumed
| In Product
D Waste stream
New Jersey
15 billion pounds
D
Consumed
In Product
Waste stream
United States: 100 TRI chemicals
Not reported 93.6%
Waste stream 6.4%
400 billion pounds
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To complement Jeanne Herb's remarks about the need for measurement and accountability, I would like
to emphasize that there is a litmus test to know whether you are measuring pollution prevention in a technically
sound way. This "litmus test" ~ addressed at least ten years ago in the OTA report on Serious Reduction of
Hazardous Waste - is to measure reduction per unit of product. If you want to measure P2 adequately you need
to be able to normalize or adjust the data for fluctuations in production level. As Jeanne Herb mentioned, the
way to do this properly is with information disaggregated and analyzed at the process level.
An AT&T facility in Massachusetts is a good example of how process-level analysis works. AT&T
divided up their facility into different product/process clusters, for which they then analyze for both their
pollution prevention planning and some process level reporting under the Massachusetts Toxics Use Reduction
Act They do not disclose a process-level materials accounting, but they provide some process level reporting,
including a production unit description and a measure of waste reduction change from a base year. AT&T, for
instance, has a soldering unit that they measure in terms of the substrates that are processed. They also make
foam, which they measure in terms of pounds of foam. Any facility, — and there are many — that has multiple
product clusters, processes or toxic chemicals being used to make multiple products, would logically need to
measure these production units differently.
A Raytheon facility that uses ammonia in three different product clusters is a example of why to start
to study and measure source reduction by production operation. Raytheon makes circuit boards, blueprints and
microwaves. The circuit board production unit had about a 26% achievement of source reduction. The
blueprints unit was about even and the microwaves operation was less efficient (increased waste per unit of
product). We also know from the Massachusetts TURA process level data that the circuit board operation
accounts for the greatest amount of use of ammonia at the Raytheon facility. This suggests that the company
targeted the right production process for reductions.
Raytheon's process level data gives us two other lessons. First, it allows us to track how the company
is making P2 achievements suitable to different technologies. It gives Raytheon a level of accountability to the
public. Even more important — it allows the company and the public to analyze any significant component of
the facility in a valid way, in this case on a per unit of product basis. There is no scientific way that Raytheon
could add up circuit boards, blueprints and microwaves to derive some production index for their facility as a
whole.
Again, credit should be given to people like Ed Jamro (and especially his predecessor) at Monsanto who
negotiated this type of chemical use information with us in Massachusetts and New Jersey. We recognize that
if we are talking about a future with materials accounting, and process level information and descriptions, there
are many issues to consider thoroughly. What is the appropriate level of specificity? How many new data
elements will there be, and how can we minimize the reporting burden? How will the agency administer the
data? Agencies in both New Jersey and Massachusetts were very involved in trying to make this a manageable
reporting program. We understand these considerations.
In fact, we also have had years of experience in understanding the confidentiality and trade secrets
concerns with right-to-know. Business lobbies raised it in the mid-eighties over TRI expansion. It remains a
constant issue. We understand that. There are legitimate trade secret concerns, but obviously you know that
these issue are blown completely out of proportion. Sometimes trade secrets are used, as one of the speakers said,
to polarize issues and sometimes as a red herring.
We are interested in negotiating at the national level - or at any level, any facility, or any industry sector
- for the types of information that Jean and I discussed, while explicitly protecting trade secrets. Monsanto's
staff helped us design the process level reporting so as to protect confidential business information in a manner
that was acceptable to broad industry coalitions in two states.
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To conclude with, there are three basic reasons for chemical use information: We envision a different
future for TRI because toxics in products pose risks far above the releases and emissions that are now reported
in the waste stream. We deserve to get a better picture of toxic chemicals that are consumed and brought into
a facility because of upstream, lifecycle pollution and the concomitant worker exposure and chemical accident
risks. And we need changes in TRI, particularly at the process level, so we can begin to measure source
reductions in a valid way. Thank you very much.
Linda A. Travers, Director, Information Management Division, Office of Pollution Prevention and Toxics,
U.S. Environmental Protection Agency
One of the goals that we had when we began designing this conference nine months ago was to broaden
the audience and bring in the pollution prevention community and the emergency planning community with the
TRI community. The other goal was to move away from it being an EPA conference with EPA making most of
the presentations and turning it into more of a participatory process where we had speakers that were not EPA
speakers. I think you've experienced that over the last several days. I think we accomplished our goals as Fve
participated in the conference and attended various sessions.
One of our major accomplishments is that we've doubled the size of participation from the last
conference. That is a major accomplishment. We feel very good about that. The other thing that I think is
significant is the pollution prevention track was the track with the largest attendance. This may be an indication
that TRI and pollution prevention are being seen as an integrated program.
As I said, in tile past we asked EPA people to be the primary speakers. We have broadened the agenda
and have asked NGO's, industry, state and local representatives to participate in many of the sessions. I think
this approach has broadened our knowledge of TRI and its uses. Fve seen new uses of the data that I had never
imagined when I started working in this program seven or eight years ago. Im sure there are going to be many
more new uses. Thank you again for participating in the 1994 TRI Data Use Conference and I hope to see you
at our next conference in the Spring of 1996.
D
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Demonstrations
Demonstrations of the following TRI-related computer programs were given during the reception
sponsored by the Chemical Manufacturers Association on the first night of the conference. These
demonstrations were very helpful in showing attendees what software is available to work with TRI and TRI-
related information.
CAMEO Ken Ferber, £/.£
CAMEO (Computer-Aided Management of Emergency Operations) is designed to provide Local
Emergency Planning Committees (LEPCs) with a tool to manage information about hazardous substances in or
near their communities, and to help emergency teams and first responders plan for the safe handling of chemical
accidents. The program contains a chemical database of over 4,000 chemicals, 60,000 synonyms, identification
numbers and labeling conventions, and emergency response information. MARPLOT maps contain latitude and
longitude coordinates, roadways, waterways, railroads, shorelines and other features from U.S. Census
Tiger/Line map files and 1990 demographic data
Hazardous Substance Management System Kim Hubby/Paul Park, Portsmouth Naval Shipyard
HSMS (Hazardous Substance Management System) keeps track of each chemical part of mixtures,
compounds and alloys, in storage, use, and release to the environment and tracks hazardous waste. HSMS
identifies chemicals that exceed threshold values, calculates TRI release quantities, and provides important data
in support of pollution prevention. This demonstration walked through the computer application of cradle-to-
grave control of hazardous and toxic material. The demonstration showed how hazardous materials are ordered,
received and converted within the computer to track chemical weight equivalents and product in parallel.
IDEA Jerry Lappan, OECA, U.S. EPA
IDEA (Integrated Data for Enforcement Analysis) is an interactive, high speed data retrieval and
integration system developed by EPA's Office of Enforcement and Compliance Assurance. Through IDEA,
experienced enforcement personnel can retrieve data for performing multimedia analyses of regulated facilities
for inspection targeting, facility or corporate screening, case development, litigation support, and settlement
negotiations. ODEA overcomes the integration problem with EPA's media specific database management
systems. While these systems frequently manage data on the same facilities, they are not easily integrated or
relatable. IDEA acts as a universal interface for accessing and integrating data from several of these systems.
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Internet Access to EPA Data Gcff King, Labat Anderson
Access to data through the Internet has increased markedly in the past year, with a wealth of information
becoming available through a variety of sources. This demonstration showed some of the basic functions of
Internet (telnet, ftp, gopher, e-mail, web, and WAIS) as well as how to access currently available EPA data
sources.
JSI Community Outreach Project Terry Greene, JSI Center for Environmental Health Studies
Staff from the John Snow Institute Center for Environmental Health Studies demonstrated their tutorial,
"Environment and Health: How to Investigate Community Environmental Health Problems." The tutorial is used
in community outreach efforts to introduce the TRI and other resources useful to identifying and addressing local
pollution sources. It is being used in training programs for diverse audiences, including librarians, local officials,
members of the media, environmental advocates, and members of the general public. It has also been
disseminated by state and federal health and environmental agencies and used in high school to graduate-level
classes.
LAND VIEWn Len Wallace, £7.3.
LANDVIEW n is a CD-ROM system designed to integrate census data with demographic, economic,
and environmental data organized in a geographic context. Information in the system includes digital map files
of the U.S. and its territories; economic information at the block, place, county, Metropolitan Statistical Area
(MSA) and state levels from the 1990 Census. Environmental data are taken from published and electronic EPA
program offices. The system can pinpoint locations of CERCLA and RCRA sites, TRI facilities, drinking water
facilities, areas of high or low income and more.
Population Estimation and Characterization Tool Dave Wolf, U.S. EPA
The Population Estimation and Characterization Tod (PECT) provides desktop access to GIS and ready-
to-use geo-demographic data for estimating and characterizing populations in buffered areas around locations,
including hazardous waste sites, toxic release facilities and monitoring sites.
RTKNet John Olden, Unison Institute/RTKNet
The RTK Net is a free system that allows users to access TRI data as well as other databases, such as
U.S. Census and EPA CERCLIS and Biennial Report data The system also offers a conference facility and
electronic bulletin board.
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South Carolina 1992 TRI System Michael Juras, SC Dept. Health & Env. Control
SC TRIS92 is a user-friendly TRI database system that performs a wide range of searches and reports.
South Carolina's entire 1992 TRI data is featured The data base files follow the EPA's GPO/NTIS structure and
are searched by a Clipper program. Users can access the Ad Hoc Report and Label Writer for further
combinations and report definitions.
TOXNET Dr. Dorothy Stroup, National Institutes of Health, National Library of Medicine
The National Library of Medicine's TOXNET is a publicly available system that enables searching of
TRI data from 1987 to 1992. Users can perform online calculations of release values, data sorting and ranging,
as well as other data manipulation tasks. TOXNET has other online databases with toxicity and environmental
fate information for the chemicals reported in TRI files.
TRI on CD-ROM Michelle Cavanaugh, Labat Anderson
TRI on CD-ROM contains emission and transfer information for more than 300 chemicals and 20
chemical categories reported by manufacturers since 1987. Starting in 1991, pollution prevention information
is included. The database has more than 80 searchable fields. The system provides sorting and calculating
features, TRI chemical fact sheets, field descriptions, and 4-digit SIC code translations (for SIC codes 20-39).
The data can be read by other computer software packages for additional analysis and reporting.
TRBPQUIC LorenHaU,£/.S.£/M
The TRIPQUIC system offers a number of analysis and display tools for TRI data, such as maps, charts,
cross-tabulations, rankings, and simple statistics. This demonstration introduced the current features of this EPA
mainframe system to help users explore TRI data in a variety of ways.
8(e) Triage Information Product Richard Wormeli, U.S. EPA
This PC-based information system provides a way to search indexed terms for health and safety studies
submitted to the U.S. EPA under the Toxic Substances Control Act (TSCA). It also contains chemical substance
fact sheets published by the U.S. EPA.
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Poster Session
Posters presentations were included in the 1994 TRI Data Use Conference as a way to increase the
exchange of information on the many different uses for TRI data Posters were available for viewing during the
second day of the conference. Two one-hour sessions, one in the morning and one in the afternoon, allowed
conference attendees to discuss the posters with the presenters. The abstracts submitted by the poster presenters
are presented below. An index at the end of the proceedings has an alphabetical list of all the presenters and the
pages on which their abstracts can be found.
Michael Aucott, Office of Pollution Prevention, New Jersey Department of Environmental Protection and
Andrew J. Oppennan, Bureau of Hazardous Substances Information, New Jersey Department of
Environmental Protection
New Jerseys Materials Accounting Approach to Environmental Release and Pollution Prevention
Reporting
Statement of the problem
New Jersey is a highly industrialized as well as a densely populated state. The proximity of industrial
facilities storing and utilizing toxic chemicals to population centers leads to concerns regarding potential
exposures to human health and the environment.
Objective of the project
Identify the types and quantities of toxic chemicals used by manufacturing industries in the state.
Establish a quantitative materials accounting of the chemicals by conducting a simplified mass balance. Assess
the environmental and commercial fate of the chemicals.
Approach to solving the problem:
• NJ Legislature passed a law requiring certain facilities to report annual materials accounting on a select
group of toxic chemicals
• NJ DEP prepared a reporting form and explicit instructions.
1) defining the data elements to be reported
2) providing a materials accounting worksheet for facility self-verification of chemical mass balance
• NJ DEP conducts annual employer outreach workshops
• NJ DEP established and maintains a database of facilities' annual reports
• NJ DEP conducts computer analyses of materials accounting on submitted data
• NJ DEP provides technical assistance via telephone or facility site visit when gross reporting errors are
identified
Project results and outcomes
The development and implementation of an annual data collection process that includes toxic chemical
materials accounting, that provides data on environmental and commercial fate of those chemicals, and that
allows for the tracking of pollution prevention trends and analyses.
Q
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Janet Park and Jodie Siegel, Massachusetts Toxics Use Reduction Institute
Moving from the TRI to Cleaner Alternatives: TURTs Technology Transfer Center is Your Gateway
Access to the Toxics Release Inventory is a great tool of empowerment for those who access and use the
available data. The TRI provides information on the quantities of listed chemicals released by a facility in a
certain SIC code. Often, however, this information is not sufficient to allow the receiver to apply and/or practice
prevention and reduction techniques. Further information, about properties and toxicity of the chemical of
concern, current process information, and alternative processes and chemicals, is often critical to pollution
prevention success and progress.
The Technology Transfer Center (TTC) at the Massachusetts Toxics Use Reduction Institute (TORT),
located at the University of Massachusetts Lowell, provides users with a wide variety of tools to access practical
information on pollution prevention technologies. The research library was assembled through the acquisition
of technical papers, case studies, reports from trade journals, conference proceedings, and newsletters. Papers
and reports from state, national and international pollution prevention programs are also included in the TTC
collection. This collection is constant and ongoing, maintaining an up-to-date source of information. Research
reports by the Institute have reviewed various subjects, and fact sheets on subjects like alternatives to solvent-
based paints and non-cyanide plating processes provide concise overviews as well as selected bibliographies on
the subject.
The TTC provides access to its holdings through a searchable electronic database. External databases
available include bibliographies, chemical toxicity data, the Solvent Alternatives Guide (SAGE), and vendor
databases. Materials are organized to focus searches on a particular production process or use sector, on a
specific chemical or chemical class, or on various methods for approaching pollution prevention. TTC staff are
available to assist visitors in their searches and to respond to telephone inquiries.
Since its opening in 1990, the TTC has served over 1500 users. In October 1994, there were seventy
visitors to the TTC, and the numbers are ever-increasing, as a result of consistent customer satisfaction. The TTC
provides a lay or professional person with "one-stop-shopping" - one library that can take the user from raw data
to applicable technologies.
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Paul Park, Portsmouth Navel Shipyard
Hazardous Substance Management System
SUMMARY: In October 1991 representatives of many Navy Commands participated in a Process Action Team
(PAT) to develop the functional requirements for a computer based system that would assist our activities in
meeting the hazardous communication requirements of OSHA, the chemical tracking and reporting requirements
of EPA, and the pollution prevention and chemical reduction goals of the Department of Defense. Such a system
would need to track and control products and materials containing hazardous and toxic substances from initial
ordering through RCRA disposal of the waste generated. It would need to convert product chemical content into
chemical weight at receipt, continuously track chemicals stored, and calculate each chemical release based on a
computer model (algorithm) of the specific industrial process used. The Navy has identified more than 400 of
these processes.
SYSTEM FEATURES:
* Maintains local MSDSs * Lists chemical constituents
* Lists product chemical hazards * Authorized use list
* Process algorithm dictionary * Waste profiles
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* Tracks product usage * Tracks waste streams
* Generates waste manifests * Calculates TRI chemical releases
* Tracks all chemicals ordered, received, stored, used, recycled, treated, including disposal through off-site
recycling, reuse, or treatment
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Ihab H. Farag, Sc.D., P.E., Carey Fillman, Jason Garland, and Anna Waller, Chemical Engineering
Department, University of New Hampshire, Durham, NH; CWO Gerald A. Upton, Environmental and Safety
Manager, U.S. Coast Guard Base South Portland; Rachel Marino, Chief, Civil Engineering Unit (CEU)-
Providence; Dwight Peavey, Ph.D., Environmental Scientist, Project Officer, U.S. EPA Region I; and
Leonard B. Wallace, Environmental Scientist, EPA's Emergency Response Section, Lexington, MA.
EPCRA & Pollution Prevention Project with U.S. Coast Guard
Statement of the Problem
On August 3,1993, President Clinton signed Executive Order 12856, entitled "Federal Compliance with
Right-To-Know Laws and Pollution Prevention Requirements." It requires all federal agencies to comply with
the Emergency Planning and Community Right-to-Know Act and the Pollution Prevention Act (PPA). The
President set a voluntary goal of 50% reduction in toxic releases and waste generation for federal facilities by
1999.
Objective of the project
The U.S. EPA - New England, through a Cooperative agreement, has entered into a collaborative
partnership with the University of New Hampshire and the Coast Guard. The pilot project is focused at the
Coast Guard Base located in South Portland, Maine. The goal is to share resources, training, and expertise in
the development of a "model" facility pollution prevention (P2) plan. The implementation of the facility P2 plan
will involve the use of the Computer Aided Management of Emergency Operations (CAMEO) software in
chemical tracking and system audit P2 training and specific source reduction projects will also be implemented.
The project may provide a "model" for other federal facilities.
Approach to solving the problem
The specific tasks include an on-site environmental audit to assess P2 opportunities, compliance with
all mandates of EO12856, and all regulations under EPCRA and PPA.
Project results
To date, Phase one has been completed. It included initial communication, introductory meeting with
Coast Guard personnel at the Base and at the Civil Engineering Unit (CEU), Providence, identifying
opportunities, forming a team involving several UNH students, planning the CAMEO training, planning the
chemical inventory, assembling a group of UNH students, Coast Guard personnel and reservists, and EPA
personnel to execute the physical inventory and bar code every item, and developing instructions.
Outcomes an^ Conclusions
The outcome is to create a document which other Federal facilities can use as they implement their P2
plans.
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Ihab H. Farag, Sc.D., P.K, Jason Gariand, and Anna Waller, Chemical Engineering Department, University
of New Hampshire, Durham, NH, and Vincent Perelli, Waste Management Specialist, N.H. Department of
Environmental Service (DBS).
New Hampshire's Pollution Prevention Internship Program
Statement of the Problem
The Pollution Prevention (P2) Partnership between the N.H. Department of Environmental Services
(DBS) and the University of New Hampshire (UNH) was initiated by an EPA grant. An important goal of the
Partnership was to establish an innovative internship program which combines its curriculum development
efforts with a student training program focused on P2.
Objectives of the project
We defined die following primary objectives of the pollution prevention internship (P2I) program:
• To provide N.H. business with well-developed options for pollution prevention.
• To develop new information on pollution prevention that can be used to build educational modules and
assist other businesses.
• To provide students with valuable opportunities to gain practical experience in industrial pollution
prevention.
• To create educational materials on pollution prevention.
Approach to solving the problem
To effectively establish the P2I Program, generate interest in companies, and start the interns by 6/1/94,
we identified the following tasks:
• Publicize/market the P2I program
• Generate interest in companies, and meet with interested ones
• Recruit qualified students
• Train the interns in P2
Industry sponsor guidelines were prepared and sent out to over forty interested companies. Student guidelines
were also developed and distributed throughout the Chemical Engineering Department. We met with companies
that expressed a high level of interest in the P2I program to answer questions and finalize the companies'
commitment.
Project results
Eleven Chemical Engineering students took part in the Internship Project at nine NH facilities
representing diverse industry types. Each intern was required to develop, in cooperation with his facility, a
project proposal, emphasizing P2. To prepare the interns, a comprehensive four day training session was
conducted to provide the students with an overview of federal and state regulations, pollution prevention
definition, pollution prevention assessments, pollution prevention cost accounting, Toxic Release Inventory (TRI)
database. It included a site visit at one of die participating companies.
Outcomes and Conclusions
The P2I was initiated. Industrial participants became college extensions for die interns. The program
has been well received. The recommendation is to expand die scope of die program in future years.
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Tern Goldberg. Manager, Pollution Prevention Program, NEWMOA
Northeast Waste Management Officials' Association Pollution Prevention Program
This poster provided an overview of the Northeast States Pollution Prevention Roundtable (NE
Roundtable), a project of the Northeast Waste Management Officials' Association (NEWMOA). The NE
Roundtable was established in 1989 by NEWMOA to enhance the ability of the Northeast states to implement
source reduction programs. NEWMOA is a non-profit interstate governmental organization dedicated to
coordinating activities among the six New England states, New York and New Jersey. NEWMOA has pollution
prevention, hazardous and solid waste and waste site cleanup programs. NEWMOA organized the 1994 TRI
Data Use Conference under a grant from the U.S.EPA as part of their pollution prevention program.
Currently the group is involved in a number of activities, including: organizing quarterly meetings to
provide training to the states on pollution prevention (P2) and share information; publishing a quarterly
newsletter that provides updates on state and EPA Regional activities; maintaining an information clearinghouse;
publishing research reports and other materials; and organizing workshops and other training activities. In
addition, the NE Roundtable has three committees: P2 Information Dissemination (ID) Committee, P2 Policy
and Legislation Committee, and P2 Training Committee.
The P2 ID Committee is involved in developing a model regional information clearinghouse network in
the Northeast in coordination with a group in the Great Lakes area This project is exploring ways of reaching
small and medium size business to address their environmental questions and concerns and methods of packaging
P2 information in a useful format. The P2 Policy and Legislation Committee is pulling together information on
P2 progress in the Northeast states as background and support for discussions with EPA on the future direction
and funding of the state P2 programs. The P2 Training Committee has been focused on developing training
sessions for state environmental regulators on P2.
NEWMOA's recent reports cover such topics as: measuring P2 progress at facilities; financial
assessment of P2 projects; compendium of case studies; and pollution prevention planning. For more
information on the NE Roundtable, call (617) 367-8558.
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Robert Gufflemin, Coordinator, Pollution Prevention Consortium of New England Universities, NEWMOA
Pollution Prevention Consortium of New England Universities
As pollution prevention (P2) emerges as a leading environmental management strategy, industry and
government rely increasingly on institutions of higher education for technical guidance, basic research and
pollution prevention training. Although New England universities have responded to this demand by developing
innovative P2 programs, educators and government officials realized that a regional network would help to
nurture individual P2 programs and guide broad based P2 initiatives. The idea to develop such a network was
formalized in 1993 with a meeting of New England universities and colleges sponsored by the Environmental
Protection Agency (EPA) and the Northeast Waste Management Officials' Association (NEWMOA).
By the Spring of 1993, the Pollution Prevention Consortium of New England Universities was founded
with the mission to facilitate collaborative pollution prevention research and education/training projects among
New England universities and colleges. More specifically, the P2 Consortium works:
1) To promote the incorporation of pollution prevention at all educational levels.
2) To identify pollution prevention opportunities and develop solutions through results-oriented research.
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3) To collaborate with local, state, and regional pollution prevention programs in developing research and
education programs.
4) To develop muln'disciplinary ties among academic programs and professions involved in pollution prevention.
5) To promote networking, collaboration, referrals, and exchange programs among universities.
The Pollution Prevention Consortium of New England Universities is managed by NEWMOA and
sponsored by the EPA and member colleges and universities. Recent Consortium projects include:
- The publication of a resource directory of member universities.
The presentation of a two day, student-faculty conference on pollution prevention at the Massachusetts Institute
of Technology.
The acquisition of a P2 research and educational grant from the Department of Defense.
The P2 Consortium's twelve members include:
Brown University University of Connecticut
Dartmouth College University of Maine
Massachusetts Institute of Technology University of Massachusetts Lowell
Merrimack College University of New Hampshire
Roxbury Community College University of Rhode Island
Tufts University University of Vermont
HUlel Gray, National Environmental Law Center
Pollution Prevention Network
What is the Pollution Prevention Network? We are organizing a national multi-constituency network
on toxics pollution prevention. We are focusing on industrial sources of pollution in order to prevent further
toxic contamination of workplaces, communities, products, and the environment.
State and local actions on toxics prevention have skyrocketed in the recent years — and now EPA is
making source reduction a top priority. But toxics prevention is innovative, untested, and faces tough
opposition. We need to pursue common goals, and deal with potentially divisive issues, to ensure a transition
to cleaner and safer industries.
Our constituencies include environmental, environmental justice, labor, consumer and occupational
health activists. The draft goals of the Pollution Prevention Network are to:
Promote industrial toxics pollution prevention (source reduction and toxics use reduction) at the
national, state, regional, and local level.
Provide information, education and resources to activists.
Strengthen local toxics prevention work and mutual support.
Analyze policies and coordinate our responses.
Facilitate networking and group building.
Track federal toxics prevention activities and resources.
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The activities of the Network include:
sharing and networking through our newsletter At The Source and by disseminating
concise information on model policies and campaign strategies. We also manage a clearinghouse and
foster issue-specific working committees.
Policy analysis and input to government officials on national pollution prevention decisions. A
current focus is EPA's proposed expansion of the Toxics Release Inventory to provide public access to
toxics use data.
Policy and strategy meetings on cutting edge policies, emerging local or industry-sector strategies, and
development of the Network Recent topics included defense of New Jerseys Pollution Prevention Act,
chemical accident prevention, and chlorine phase-out efforts.
Our work on TRI
Thirty public interest representatives from around the country testified on September 28th at EPA's
public hearing on the toxics use expansion of the Toxics Release Inventory (TRI). Network participants
generally believe that adding toxics use data to TRI would educate the public (and CEO's, media, government,
etc.) with information to create the impetus for safer and cleaner products and processes. Toxic chemicals at a
facility end up in three places - 1) in a product; 2) converted into another material; 3) in the waste stream.
Currently, TRI only covers the waste stream, which is by far the smallest of the three. Therefore we need to focus
on the problems associated with toxics use, not just wastes, mainly: product-related problems, accidents,
occupational exposure, and gaps in waste data
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Tim Greiner, Greiner Environmental
Normalizing P2 Data for TRI Reports: A Statistical Test for Choosing a Normalization Method That
Accurately Reflects P2 Progress
Companies that file Toxic Release Inventory (TRI) reports are required to adjust their pollution
prevention data for year-to-year changes in production. This adjustment, or "normalization," is required to be
based on what is known as a "production ratio" or an "activity index." However, choosing the wrong
normalization method can generate an inaccurate picture of a company's pollution prevention progress that either
overestimates or underestimates the true results.
EPA provides scant guidance on how to select an appropriate ratio or index, leaving environmental
managers to guess which measure of production best reflects changes in their firm's business activity. The
Agency simply advises firms to use a variable that has the "primary influence on the quantities of the toxic
chemical recycled, used for energy recovery, treated, or disposed."
This poster session describes a normalization method developed by the Massachusetts Office of
Technical Assistance (OTA) that produces a more accurate picture of a firm's year-to-year pollution prevention
progress. This technique uses regression analysis to determine the statistically significant normalization factors
mat best measure a facility's year-to-year pollution prevention progress. The poster reviews the complexity of
normalizing P2 measurements and the corresponding issue of inaccurate progress reporting. It also presents a
case study applying this technique to an automated spray paint line.
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Michael K. Heiman, Environmental Studies, Dickinson College, Carlisle, PA
Student Use of EPCRA (SARA Tide m) Data To Conduct Community Toxic Waste Audits
Congress intended the Emergency Planning and Community Right-to-Know Act of 1986 to enable
citizens to learn more about the hazardous chemicals stored, used, and released in their communities. The
Environmental Studies Program at Dickinson College is committed to furthering this goal through instructional
use of the data base generated through EPCRA. Each year 75 first-year students prepare toxic waste audits on
communities or facilities of their choosing. As a result, we run one of the largest campus-based audit programs
in the nation, and our activities have attracted wide interest.
Students work with reporting forms available on-line via RTK-Net and through the EPA's CD-ROM
format Using a wide variety of reference tools, they uncover reported epidemiological and environmental health
effects, exposure standards, census data, and pertinent chemical profile information. Upper-division students
in our policy class arrange plant tours focusing on toxic use reduction and 'good-neighbor1 agreements.
Additional interviews with residents, labor unions, and the Local Emergency Planning Committees profile
incidents of high chemical exposure.
In an attempt to bring the program off-campus and directly to the impacted citizens, students and faculty
are conducting toxic release inventory access workshops using the CD-ROM format in communities of color and
low-income neighborhoods across EPA Region IE (PA, MD, WV, VA, DE, and DC). This outreach is supported
through a grant from the EPA's Environmental Equity Grant Program for the 1994-5 academic year.
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Maureen Heraty Wood, Manager, Waste and Pollution Prevention Issues, Chemical Manufacturers'
Association
Pollution Prevention in the Chemical Industry
As manufacturers and distributors of chemical products, the chemical industry manages a large volume
of TRI chemicals every year. The industry recognizes that pollution prevention is a core principle of responsible
management. In 1992 CMA member companies managed over 12,000,000 pounds of TRI chemicals, but less
than 7% of these chemicals were released to the environment. Industry implementation of sound pollution
prevention practices helps to reduce the impact of industry on human health and the environment; serves to
advance its own efforts, and those of others, to improve the environment; and reduces the potential for future
degradation.
The poster describes the progress of the chemical industry in preventing pollution over the past five
years. From 1988-1992 CMA member companies reduced releases of toxic chemicals to the environment by 35
percent During the same time period, chemical industry production rose 8%. Examples of successful member
company pollution prevention projects, featured in the poster, illustrate the many ways in which companies apply
technological and human resources to reduce emissions to the environment.
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1994 TRI Data Use Conference Poster Abstracts
Maureen Heraty Wood, Manager, Waste and Pollution Prevention Issues, Chemical Manufacturers'
Association
Through the Form R Process
Each TRI-eligible facility must submit a Form R for each TRI-listed chemical that it manufactures,
processes or otherwise uses in excess of the statutory thresholds. In 1993 chemical manufacturers submitted
over 10,000 Form Rs, representing emissions from approximately 1,400 different facilities. Facilities devote
considerable time and resources to assuring that Form Rs are completed in an accurate and timely manner. This
poster walks viewers through the process that facilities follow to prepare and submit a Form R. A flow chart,
illustrated with pictures and text, shows the steps involved in determining TRI eligibility, types and volumes of
chemical emissions and transfers, types and volumes of chemicals by pollution prevention activity, and other
steps necessary for a facility to complete the Form R properly.
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Arpad Horvath, Chris Hendrickson, Lester Lave, Francis McMichael, and Tse-Sung Wu, Engineering
Design Research Center, Carnegie Mellon University
Toxic Emissions Indices for Green Design and Inventories
The Toxics Release Inventory (TRI) summarizes plant, industry, county and state data by the total
weight of toxic chemicals released to the environment, implicitly assuming that a discharge of substance A is
equivalent to an equal weight discharge of substance B. However, the toxicity of the TRI chemicals vary
tremendously. Different indices of the toxicity of the 370 TRI chemicals to humans indicate that the worst are
more than 1,000,000 times more toxic than the most benign. The typical TRI rankings and time trends of
facilities, industries, counties and states as sources of toxic releases measured only in pounds can be misleading
because they have neglected relevant lexicological data We contrast the ranking of the TRI data based on the
weight of releases with a ranking based on the relative toxicity of the discharges, using ACGffl Threshold Limit
Value (TLV) indices. We find that for the computer and office equipment industry, weighted discharges fall less
than the number of pounds. We also show that Arizona, ranked 21st by weight of releases, has more toxic
discharges per pound than Louisiana, ranked 1st. We discuss the limitations of our approach, and illustrate the
use of toxicity weighted emissions indices in green engineering design and manufacturing changes.
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Sanford Lewis, Director, The Good Neighbor Project For Sustainable Industries
Rights and Resources for Public Participation in Pollution Prevention
PROBLEM: Much of the current policy discourse regarding pollution prevention related to the Toxic
Release Inventory revolves around the need to provide firms with flexibility to achieve pollution prevention and
chemical accident prevention. In the context of this flexibility, stakeholder involvement on a plant by plant basis
is increasingly important as a means of advancing, watchdogging, and legitimizing the choices made. However,
effective stakeholder involvement necessitates access to information, access to facilities and access to expertise.
Lacking such rights and resources, dialogue with relevant companies is often a shallow public relations exercise,
not an even-handed review.
SOLUTION: Locally negotiated Good Neighbor Agreements provide stakeholders with the needed
rights to documents, expertise, and facility access, (e.g. Rhone-Poulenc agreement in Manchester, Texas,
appended to hazardous waste facility permit). Other arrangements have granted access to expertise that was
secured elsewhere (e.g., Environmental Careers Organization advisors, Minnesota Technical Assistance
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Program). Citizens groups are also empowered by some citizens' lawsuit settlements, and have been working
to encourage EPA to use its SEP program to empower citizen oversight.
CONCLUSION: Empowering nongovernmental organizations is an effective way to supplement existing
regulatory approaches to pollution prevention. Government can play an important role in accomplishing this
empowerment by using its roles of permitting, enforcement, technical assistance and industrial relations to
facilitate the needed rights and resources for stakeholders.
Ihab H. Farag, Sc.D., P.E., Chemical Engineering Department, University of New Hampshire and Vincent
Perelli, N.H. Department of Environmental Service (DES), Pollution Prevention Program
DES-UNH Pollution Prevention Partnership (P3)
Problem Statement
Pollution prevention (P2) requires change in fundamental waste management/business practices. All
sectors of society must reevaluate the current system and look towards a new approach to "business as usual."
Learning institutions play a key role in this "change equation." It is imperative that the next generation of
professionals emerge from the educational system properly trained in P2 concepts. Innovative partnerships can
bring stakeholders (who have historically not worked cooperatively) together to establish common ground and
enhance information exchange.
Objectives
Created through an EPA Grant, P3 goals include:
• supporting hands-on learning opportunities and classroom curricula in P2;
• promoting P2 and economic competitiveness through student internships at NH companies;
• fostering regional networking/information exchange.
Approach
To accomplish the above goals, we initiated:
• Student Internship Program
• P2 Curriculum Development
• P2 Advisory Committee
• P2 Case Studies
• Technology Transfer
Results
• Student Internship Program
• Developed 7 P2 case studies
• Organized Annual P2 Conference
• Compiled existing P2 curricula
• Established P3 Advisory Committee
Outcomes/Conclusions
• Learning institutions play a key role in P2
• Hands-on experience through internships is a valuable learning tool
• A viable economy cannot be gained at the expense of a healthy environment & vice-versa
• Collaborative efforts are important mechanisms for lasting change
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Natalie Roy and Warren Weinstein, National Pollution Prevention Roundtdble
The National Pollution Prevention Roundtable
The National Pollution Prevention Roundtable (NPPR), formerly the National Roundtable of State
Pollution Prevention Programs (NRSPPP) is the largest membership organization dedicated solely to pollution
prevention. The Roundtable provides a national forum for promoting the development, implementation, and
evaluation of efforts to avoid, eliminate, or reduce pollution at the source.
The Roundtable's voting membership is comprised of state and local government's pollution prevention
programs. Affiliate members include federal agencies, non-profit groups and private sector interests. Public
sector members located in 80 program offices and in nearly every state, operate programs that provide pollution
prevention information and technical assistance to thousands of industrial, commercial, and agricultural facilities
each year. The information provided helps many of these facilities reduce the cost of production and the cost of
environmental compliance; this translates into improved competitiveness and jobs.
A small annual dues fee makes the non-profit Roundtable as inclusive as possible. The central office
located in Washington D.C., provides members with access to pollution prevention information including state
and local pollution programs. The Roundtable hosts two semi-annual conferences which provide members the
opportunity to share pollution prevention information and expertise with each other. The organization is
governed by a ten person board of directors from state and local pollution prevention programs. Each board
member is situated in one often EPA regions and serves a three year term.
The Roundtable has just finished publishing a Pollution Prevention Yellow Pages and is working on the
Clearinghouse Project to determine the pollution prevention information needs of selected industries. The RCRA
National Waste Minimization Plan, the Common Sense Initiative (CSI), Toxic Release Inventory, and Toxic Use
Reduction are among the many issues the Roundtable has extensively worked on over the past year. For more
information about the Roundtable or to find out how to become a member call: (202) 543-P2P2; the fax number
is: (202)543-3844 or write to: NPPR, 218 D St. SE, Washington D.C. 20003.
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Jeff Scott, Arizona Department of Environmental Quality
Toxic Release Inventory (TRI) is an important part of the Arizona Department of Environmental
Quality's (ADEQ) Pollution Prevention (P2) Program. The three components required by facilities that meet the
reporting thresholds are a Pollution Prevention Plan, a Form R, and a Pollution Prevention Progress Report
which updates the plan every year.
Arizona Revised Statutes bring facilities into the P2 program based on the amount of hazardous waste
generation/shipment and toxic substance thresholds, creating many different filing categories. The categories
used to define and track facilities will become more complicated with the new regulations (lowering toxic
substance and waste generation thresholds) which become effective in the 1994 and 1995 reporting years.
The two primary uses of Arizona's TRI data consist of producing annual toxic data reports and as a
database to anyone who requests toxic chemical, hazardous waste or facility information. Now that three years
of data are in the database, more informative analyses into the influence of Pollution Prevention on changes in
toxic chemical reductions can be investigated.
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Poster Abstracts 1994 TRI Data Use Conference
Beth A. Secor, Janina J. Curtis, Alan D. Parr and Elizabeth C. Bunyon, Rizzo Associates, Inc.
Use of Chemical Inventory Databases as a Tool in Toxics Release Inventory Planning and Pollution
Prevention
As a result of E.0.12856, many federal facilities which have not previously been required to closely
track their inventories and use of hazardous materials are facing the daunting task of having to quantify this
information. Rizzo Associates, Inc. has developed a database program to collect product inventories on-site and
subsequently identify chemicals targeted by various federal and state programs and their source products.
The USPS Northeast Region approached us to perform chemical inventories of 65 vehicle maintenance
and mail processing facilities in New England and New York. The primary goal was to compile chemical
inventory data to identify EPCRA compliance activities at each facility. Rizzo Associates conducted the
inventories by entering product data directly into laptop computers. Product chemical composition information
was obtained from MSDS sheets. Using this data, a report presenting EPCRA compliance activities and
complete, current sets of MSDSs were prepared for each facility. The reports tabulated products observed on-site
and detailed which products contained chemicals regulated under EPCRA or CERCLA.
The database can be customized to identity other sets of chemicals such as state listed hazardous
substances or flammables. The USPS requested data on EPA's 33/50 Program target chemicals and ozone
depleting substances to support their pollution prevention program. The use of the database provided
information that would be difficult to acquire and manipulate using any other means. Specifically, it included
the number of chemical products in use at each facility, which products contained targeted chemicals, and the
aggregate quantities of each chemical at the facility. The surprising variety and number of products in use has
given renewed impetus and direction to USPS's ongoing pollution prevention focus
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Karen Shapiro, Tellus Institute
Taking Stock: Measuring Pollution Prevention Progress
Four years after passage of the Federal Pollution Prevention Act and passage of similar legislation in
many states, what progress is being made in preventing pollution? This question was examined hi a recent Tellus
Institute study examining toxics use reduction (TUR) progress by Massachusetts industries. Measuring progress
presents several challenges — are qualitative or quantitative indicators preferable? How can progress due to
explicit prevention efforts be distinguished from other, unrelated factors such as changes in a company's product
mix or changes in production levels.
Because methods for measuring TUR progress are in the nascent stage, Tellus developed and applied
a methodology to 5 industry sectors using a combination of qualitative and quantitative measures available from
the Toxics Release Inventory and additional facility data required by Massachusetts' Toxics Use Reduction Act.
Tellus' assessment of TUR progress by five industrial sectors indicates limited and mixed progress to date - while
some sectors have decreased their generation of toxic byproducts over the two year period for which data are
available, progress on a yearly basis is more mixed.
One interesting observation is that normalization appears to have little or no impact on measurement.
Trends in manufacturing, processing, and otherwise using toxic chemicals, as well as generation of toxic
byproducts, were typically not altered when these data were normalized by employment (an indicator of level of
production). This result suggests that either: (1) measures of production have little or no effect on TUR
measurement or (2) employment data are not well-correlated to chemical quantities. Since only five industry
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categories were assessed in this study, further application of our normalization techniques are necessary before
definitive conclusions are possible.
Measuring progress is an ongoing activity that should be repeated yearly. As more data become
available, the methodology developed in this study will be increasingly useful for reliably taking stock of P2 and
TOR progress.
a
Tom Neltner and Paula Smith, Indiana Department of Environmental Management (IDEM) Office of
Pollution Prevention and Technical Assistance (OPPTA)
Pollution Prevention Measurement Using the Toxic Chemical Source Reduction and Recycling
Report (TCSRRR)
Unlike any other state, the Indiana Department of Environmental Management (IDEM) has a
legislature's mandate to measure pollution prevention progress among all industries. To develop a quantitative
assessment, the Indiana Department of Environmental Management determined that the purpose of this mandate
is to measure industry's progress on pollution prevention rather than to measure the effectiveness of the state's
pollution prevention program. The Indiana Department of Environmental Management evaluated the databases
available for this type of assessment based on six selection criteria and chose the federal Toxic Chemical Source
Reduction and Recycling Report (TCSRRR). This database goes beyond release information previously available
from the Toxic Release Inventory (TRI). Progress on pollution prevention is measured as reductions in the total
generation of toxic chemicals in environmental wastes. IDEM has also developed a weighted activity index for
the agency to factor in changes in production rates when measuring pollution prevention progress. After an
analysis of statewide data, the Form Rs for 1991 indicated that Indiana facilities generated 120 million pounds
less toxic chemicals in their environmental waste from 1990 to 1991. This is a 8.5% reduction despite an 8%
increase in production of products directly associated with the use of the toxic chemical. In addition, IDEM
divided more than 300 toxic chemicals into three categories: metals, solvents, and other toxic chemicals and
prepared analysis based on these categories. The comparison of 1992 data to the previous years is still in
progress.
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Leslie Winik, Manager, Product Stewardship, Chemical Manufacturers Association
TRI Phase ffl: A Chemical Industry Perspective
Regulators, environmental groups, and industry continue to grapple with the question of how to measure
pollution prevention progress accurately. In particular, various groups differ on whether the Toxics Release
Inventory, as currently structured, provides an adequate measure of and incentive for pollution prevention. As
a result, the US EPA has proposed expanding the Toxics Release Inventory (TRI) to require facilities to report
chemical use information.
This poster discusses the proposal to collect data on chemical use from TRI-etigible facilities. The use
and effectiveness of TRI data, the need for additional data, and the potential impact of the proposal on industry
competitiveness serve as focal points for the discussion. The poster also describes how the industry is working
to increase community involvement in pollution prevention planning and improve the credibility and accuracy
of pollution prevention reporting under its Responsible Care® program.
D
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Poster Abstracts 1994 TRI Data Use Conference
Michael EUenbecker, Karen Thomas, Mark Rossi, and Arjan VanVeldhinzen, Toxics Use Reduction
Institute University of Massachusetts, Lowell
Clean Alternatives Project: The Use of TRI and TUR Data to Identify Industry Partners for
Collaborative Research
I. THE CLEAN ALTERNATIVES PROJECT
The Clean Alternatives Project was funded by EPA's Risk Reduction Engineering Laboratory (RREL)
in 1994 as part of its Pollution Prevention Strategy. The goal of the project is to perform technical, financial, and
substitution analyses of alternatives to chlorinated hydrocarbon solvents used in metal degreasing.
The project is divided into six phases:
Phase 1: Uses and Users of the 33/50 Metal Degreasing Solvents
Phase 2: Identification of Participating Firms
Phase 3: Technical Evaluation
Phase 4: Total Cost Assessment
Phase 5: Substitution Analysis
Phase 6: Technology Transfer
The first two phases and the majority of the fourth phase have been completed. Current work is focusing
on the third and fifth phase of the project. The sixth phase will be implemented after the first five phases have
been completed.
n. THE USE OF TRI AND TUR DATA IN PHASES 1 AND2
The research in the first phase involved identifying the key uses and Massachusetts users of metal
degreasing solvents. This work was accomplished by assessing the 1991 Toxics Release Inventory data, Toxics
Use Reduction Act data, and by conducting interviews.
From the companies identified in Phase 1, agreements to participate in the project were secured with
three firms. One company manufactures lubricating oil pumps for aircraft engines . Another company
manufactures cooking equipment for use in restaurants. The third company is a job shop electroplater. All three
firms are located within the greater Boston metropolitan area.
D
Theresa Hodges, Office of Pollution Prevention, Kansas Department of Health and Environment
Interaction Between State Regulatory Programs and University-Based Technical Assistance Programs
The Kansas Department of Health and Environment (KDHE) has designated an Office of Pollution
Prevention to integrate and promote pollution prevention as the environmental ethic. Pollution prevention is
being integrated into all areas of rulemaking, permitting, compliance, and enforcement in the regulatory
programs.
A survey initiated by the KDHE and conducted by the Institute for Public Policy and Business Research
at the University of Kansas revealed that there is a reluctance by industries to contact regulatory agencies for
technical assistance. Technical assistance, including confidential on-site audits, is provided by contracts from
KDHE with Kansas State University Engineering Extension Program. Pollution prevention workshops and
seminars are provided by both Kansas State University and the University of Kansas Center for Environmental
Education and Training. Additionally, the Small Business Assistance Program established in compliance with
the Kansas Air Quality Act is provided through contractual arrangement with the University of Kansas with
subcontracts with Kansas State University and Wichita State University. This arrangement for providing
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1994 TRI Data Use Conference Poster Abstracts
technical assistance has proven vety effective in Kansas and bridges the gap between the "regulators" and the
"regulated community".
D
Theresa Hodges, Office of Pollution Prevention, Kansas Department of Health and Environment
Response of Kansas' Small Businesses to Environmental Regulation: Implications for Training
A survey of 506 small businesses in Kansas revealed that most firms rely heavily upon vendors, trade
groups, and newsletters for information concerning environmental regulations. A telephone survey was
conducted by the Institute for Public Policy and Business Research, University of Kansas under the direction of
the University Center for Environmental Education and Training and the Office of Pollution Prevention, Kansas
Department of Health and Environment.
The four objectives outlined for the project were to determine: 1) how Kansas firms are organized to
deal with environmental regulation and compliance; 2) where firms currently obtain information regarding
environmental regulations; 3) what issues and barriers are faced by firms in obtaining information regarding
current and future environmental regulations; and 4) prioritize unmet needs for information and training related
to environmental regulation and compliance.
Firms have trouble dealing with regulations due to lack of knowledge about where to obtain information,
difficulty in understanding the regulations, and/or inconsistent or conflicting information. The biggest barriers
to achieving and maintaining compliance are cost of compliance and difficulty with keeping up with changes.
Manufacturers indicating that they were impacted by reporting requirements of the Emergency Planning
and Community Right-to-Know Act were equally divided in organizational structure between functional area
and regulatory program focus. Approximately one-third indicated that additional information was needed
regarding these regulations by ranking its importance as 1 or 2 on a 5 point scale, with 1 having highest priority.
D
Nora Lopez. U.S. EPA Region II and Blanche Krubner, NCSC
Establishing a TRI Outreach Program for High Schools
Statement of the Problem
Information garnered under EPCRA is publicly available. However, the common citizen does not know
this. Targeted audience has been highly educated citizens. The program has not succeeded in effectively in
attracting the attention of the common citizen.
Approach to solving the problem
Refocus the targeted audience. High School students should be targeted as they are ready to go into the
workforce. By alerting them concerning their rights under EPCRA, what information exists, and where they can
obtain this information, we would be significantly enhancing public knowledge in this area
The following steps need to be followed in order to have an effective program:
1. Gathering of educational materials.
2. Development of lesson plan or curriculum.
3. Develop a network list of contacts within the Educational Departments.
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Poster Abstracts 1994 TRI Data Use Conference
4. Conduct mailings to Superintendents of Schools of with materials developed providing importance to
the issue of how EPCRA applies to the different school organizations.
5. Participate in teachers workshops, seminars and national or state meetings to provide the information.
Project Results
Region n is testing this approach in the State of New Jersey. Materials needed for an effective outreach
have been drafted and will be provided to those interested for comment. Mailings to schools have been done.
Invitation to conferences and seminars have been forthcoming.
Outcomes and Conclusions
Numerous requests have been received Teachers are interested in having speakers address their classes
and provide the information to the school library for the students to use.
D
Betty Szudy and Michde Gonzalez Arroyo, University of California at Berkeley, Labor Occupational Health
Program
The Right to Understand: Making Technical Materials Easier to Understand
How can we design materials that meet the needs of workers and communities with varying literacy
levels? How can we make technical materials more understandable? UC Berkeley educators developed a manual
that includes guidelines and practical tips for developing material and training activities with literacy in mind.
The guidelines are based on the experiences of health and safety trainers and workers with limited reading and
writing skills.
The authors reviewed a variety of health and safety educational materials and concluded that most were
missing the mark. They interviewed over 25 workers and incorporated their ideas and suggestions for developing
effective materials into the manual.
The 200 page manual includes over 60 illustrations. Chapters discuss how to learn more about the kind
of material that will work with your target audience, how to develop visually appealing and easy-to-read
materials, participatory training activities and alternative testing methods.
Richard Wormefl, Analysis & Information Branch, Chemical Screening & Risk Assessment Division, Office
of Pollution Prevention and Toxics (OPPT), U.S. EPA
OPPT Fact Sheet Project
EPA's Office of Pollution Prevention and Toxics (OPPT) is currently developing information summaries
(two page feet sheets) for TRI chemicals. The effort began in March of this year and to date has completed fact
sheets for twenty chemicals. The plan is to complete fact sheets for approximately twenty additional TRI
chemicals every three to four months during the 1995 calendar year. Information included in each fact sheet is
obtained from secondary sources only, including those developed within OPPT under various sections of the
Toxic Substances Control Act. Copies of drafts of existing OPPT fact sheets will be available for review. A
sign-up sheet will be provided for those interested in receiving existing fact sheets as well as additional fact
sheets as they are completed.
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1994 TRI Data Use Conference
Poster Abstracts
The benefits of the Fact Sheets are:
* Provides the reader with an overview of what is known about a chemical's production & use; its releases
to the environment; its fate in the environment; and its health & environmental effects.
* Directs the reader looking for additional information to specific offices in EPA and to other federal
departments/agencies that regulate or that are in some other way responsible for the chemical.
The benefits of the Supporting Documents are:
* Synthesizes information from a diverse set of secondary sources into understandable, comprehensive
statements about a chemical.
* Provides a more detailed, more technical informationed discussion of what is known (and, in some cases,
what can be reasonably inferred) about a chemical. It outlines the bases for statements included in the
fact sheet.
* Points the reader, looking for additional information, to key technical documents in each area of interest.
Together the Fact Sheet and its Support Document:
* Provide a link, a point of reference, or, in some cases, a starting point for internal OPPT technical
information needs.
* Provide a link to OPPT chemical specific information storage and retrieval.
* Provide a link to disseminate information about chemicals of interest to the public.
FACT SHEETS (HIGH RELEASE TRI CHEMICALS)
Group L Completed By 1 October 1994
Chemical
CAS Number
Chlorine
Methylene chloride
Methyl-tert-butyl ether
Perchloroethylene
Toluene
Acetaldehyde
Carbon disulfide
Freon 113
Methanol
1 ,2,4-Trimethylbenzene
Acetonitrile
1-Butanol
Carbonyl sulfide
Methylchloroform
2-Methoxyethanol
Acrylamide
Acrylic acid
Cyclohexane
Methyl ethyl ketone
Methyl isobutyl ketone
7782-50-5
75-09-2
1634-04-4
127-18-4
108-88-3
75-07-0
75-15-0
76-13-1
67-56-1
95-63-6
75-05-8
71-36-3
463-58-1
71-55-6
109-86-4
79-06-1
79-10-7
110-82-7
78-93-3
108-10-1
Group n. To Be Completed Within Four Months
Chemical Name
Acrylonitrile
Aniline
Biphenyl
107-13-1
62-53-3
92-52-4
Bisphenol A (Isopropylidenediphenol)
80-05-7
Butyraldehyde 123-72-8
Cumene 98-82-8
Chlorine dioxide 10049-04-4
Chlorobenzene 108-90-7
Decabromodiphenyloxide 1163-19-5
1,4-Dioxane 123-91-1
Ethylene 74-85-1
Ethylene oxide 75-21-8
Formaldehyde 50-00-0
Methyl methacrylate 80-62-6
Nitrobenzene 98-95-3
Phthalic anhydride 85-44-9
Propylene 115-07-1
Propylene oxide 75-56-9
Sryrene 100-42-5
1,2,4-Trichlorobenzene 120-82-1
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Poster Abstracts 1994 TRI Data Use Conference
The following hierarchy of information sources was used by the contractor in preparing the fact sheets:
HEALTH
"IRIS
* FACT SHEETS/ANALOGUE PROFILES PREVIOUSLY COMPLETED
* RMX/TRI ASSESSMENTS
* SECTION 4/8(e) INFORMATION/DATA REVIEWS
* EPA ASSESSMENTS
*ATSDR PROFILES
* NIOSH/OSHA PUBLICATIONS
* US AIR FORCE TOXICOLOGY GUIDE
* IPCS/TARC MONOGRAPHS
* NTP MONOGRAPHS
* PATTY'S
* ITC PROFILES
* GENETOX
*HSDB
ENVIRONMENTAL EFFECTS
* FACT SHEETS/ANALOGUE PROFILES PREVIOUSLY COMPLETED
* RMX/TRI ASSESSMENTS
* SECTION 4/8(e) INFORMATION/DATA REVIEWS
* EPA ASSESSMENTS
* IPCS DOCUMENTS
* ITC PROFILES
*AQUIRE
*HSDB
ENVIRONMENTAL FATE
* RMX ASSESSMENTS
* SECTION 4/8(e) INFORMATION/DATA REVIEWS
* EPA ASSESSMENTS
* CHEMFATE
*HSDB
D
Pat Ausman, Susan Kulstad, Janine Landroche, and Deborah McKie, USEPA Region I and Deborah
Cohen, and Ailing Hsu, R.O.W. Sciences, Inc.
Integrating Environmental and Demographic Databases to Support Environmental Justice
Consideration Across EPA Programs: A Demonstration Using TRI
Heightened consciousness at environmental management agencies of environmental justice is spawning
government policies to address concerns about the equity of environmental protection where minority and low
income communities exist. In order to ensure environmental justice, consideration of community impacts need
to be built into ongoing practices and decision making throughout these organizations.
The U.S. Environmental Protection Agency (EPA) Region I office has developed maps and listings
locating minority and/ or low income communities throughout the six New England states for ongoing program
planning purposes. The New England office developed a database using 1990 U.S. census data. Employing
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1994 TRI Data Use Conference Poster Abstracts
geographic information systems (CIS), this data was then used to depict and relatively rank communities within
each state based upon socioeconomic factors.
Identifying where communities of potential interest exist, along with their relative ranking based on
demographics, is an important first step in database development to support environmental justice goals. The
next step was to integrate data on polluting sources with the socioeconomic database. The TRI database was
selected based on a survey of existing Regional databases because it provides complete New England coverage,
is in a ready state for integration with census data, and provides a fair risk surrogate.
New relative risk rankings were generated based on pollutant loadings, toxicity and population exposure,
then combined with the demographic rankings to identify potential areas of concern. The next step is to determine
whether a statistically significant difference exists in exposures to pollutants, as described in this study, between
minority and/or low income communities and other New England communities.
D
Terry Greene, Gretchen Latowsky, Bob Eisengrein, and Carol Rougvie, JSI Center for Environmental
Health Studies
The Value of Toxics Use Data in Promoting Public Health in Massachusetts
In 1992, approximately 650 Massachusetts companies used more than 1 billion pounds of toxic
chemicals in manufacturing. The industrial use of toxic chemicals introduces possibilities for potentially harmful
exposures to workers, consumers, and the public at various points in the use cycle, including shipment, handling,
storage, use, treatment, and disposal. Workers are exposed to toxic chemicals on the job, consumers use
products that are toxic in homes and offices, and toxic chemicals end up hi air, water, and land from both
accidental and routine releases.
To raise public awareness of toxics use in Massachusetts and its potential to affect public health, we
examined the possible health risks associated with exposure to toxic chemicals used in Massachusetts industry.
Chemical use information was drawn from the data base of industrial toxic chemical use generated by the
Massachusetts Toxics Use Reduction program, through which large-quantity industrial users of toxic chemicals
report annually on their use of these chemicals and develop plans to achieve toxics use reduction.
While uncertainties about the health effects of chemical exposure preclude precise characterization of
risks for Massachusetts workers and residents, our analysis underscores the importance of toxic chemical use
reporting and provides sufficient information to justify a unified effort to reduce potential exposures by reducing
toxic chemical use. Industry, government, and the public must work in partnership to promote broad scale toxics
use reduction efforts to protect public health and the environment.
This work was done as part of the Toxics Use Reduction Implementation project. The project was funded
with grants from the Jesse B. Cox Charitable Trust and the Charles Stewart Mott Foundation and is being
conducted in collaboration with the Environmental League of Massachusetts and MassPIRG.
D
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Poster Abstracts 1994 TRI Data Use Conference
N.W. Bouwes, ST., SJVL Hassur and L.H. Hall (S.E. Keane and B. Firlie, Abt Associates), U.S. EPA, Office
of Pollution Prevention and Toxics
U.S. Environmental Protection Agencys TRI Environmental Indicators Model
An environmental indicators model based on the Toxics Release Inventory (TRI) has been developed
by the Office of Pollution Prevention and Toxics (OPPT) of EPA. The TRI Environmental Indicators utilize an
algorithm that integrates weighted toxicity scores with a surrogate dose based upon TRI reporting of release and
transfer data (including both generic and site-specific exposure characteristics). The output is a relative risk-
based value which takes into account the potentially exposed population. OPPT is nearing completion of the
development of this national risk-based indicator designed to track year-by-year changes in the multi-media
impacts of TRI chemicals on chronic human health and ecological well being. A Microsoft Windows based
computer application of the TRI Chronic Human Health Indicator is currently being evaluated by OPPT. The
model's adaptable design lends itself to targeting and prioritization of chemicals by media, Standard Industrial
Code (SIC) classification or geographic region; and may aid the investigation of environmental justice issues.
D
John Shea, Louise Hamilton, Sylvia Hobbs, and Ngozi Oleru, Office of Environmental Health, City of
Boston, Massachusetts
Database Methodology to Enhance Inner-City Hazardous Material Follow-up: An Innovative Multi-
Agency Approach to Hazardous Materials Site and Receptor Mapping
Recent data have suggested an interrelationship between race, poverty, and exposure to environmental
toxins. While these studies have gradually brought about increased recognition that minority and low-income
areas are inordinately affected by environmental pollution, they have not led to the development of community
models for systematic source and receptor identification. An active partnership between the Dudley Street
Neighborhood Initiative (DSNI) (a grassroots neighborhood organization), and the Office of Environmental
Health (OEH) (an agency of the Department of Health & Hospitals), along with federal, state, and other local
groups initiated the DSNI Hazardous Waste Work Group. The goal of this partnership is to pool expertise
and data sources to expedite identifying, prioritizing, and computerizing hazardous materials sites and receptors
in a densely populated minority district plagued by environmental hazards. To improve identification,
surveillance, and remediation of sites, a computer database was created by OEH with a mapping link to overlay
hazardous sites and sensitive receptors for human exposure such as schools, elderly housing, day care centers,
parks, development projects, and health care facilities. Toxic Release Inventory (TRI) data, and other data
sources are used to prioritize, assess, and manage risk. Public meetings for residents are planned within the
target area to provide feedback, focus site cleanup objectives, and facilitate community development goals.
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1994 TRI Data Use Conference Poster Abstracts
Steve Tomlyanovich, Minnesota Emergency Response Commission
Minnesota TRI Expansion
Minnesota recognized a need to provide even more TRI data. This resulted in an amendment to the
Minnesota Emergency Planning and Community Right-to-Know Act to expand toxic chemical release reporting
requirements. The facilities covered included those in one of 14 non-manufacturing SIC Codes which meet the
employee and chemical usage criteria, as well as the exemptions available under the federal Act, must report
chemical releases and transfers to the Minnesota Emergency Response Commission (MERC). The first reports
for the expanded group of facilities were due on July 1,1994, covering the 1993 reporting year.
There were problems because Section 313 was written for the manufacturing sector. In order to
effectively implement the new legislation, the MERC had to make certain interpretations of the federal Act as it
applied to the expansion. The legislation has some differences compared to the federal Act:
Substances that are associated with or incidental to the combustion of fossil or other fuels for the
generation of electricity or the production of steam are exempted.
A person may petition the MERC to exempt a specific SIC Code from the reporting requirements.
A facility meeting the reporting requirements under the expansion, but reporting no releases or transfers,
may submit a written certification to the MERC exempting itself from the reporting requirements.
As a result of the expansion, the MERC received Form R submissions from 16 facilities resulting in over 17
million pounds of reported releases and transfers.
Data received under the expansion indicate that there is a substantial amount of releases and transfers
of Section 313 chemicals from outside of the manufacturing sector. TRI expansion legislation should include
reporting requirements written specifically for each of the non-manufacturing SIC Codes being considered.
D
Dr. Warren Layne, TRI Coordinator, U.S. EPA Region 6 (Dallas), Loren Hall, Office of Pollution Prevention
and Toxics, U.S. EPA, and Jay Jacob Wind, ViGYAN
TRIPQUIC (Toxics Release Inventory Quick Response Tool Kit): An Innovative Way to Analyze
TRI Data
Statement of the Problem
EPA Region 6 staff and State TRI Coordinators in Arkansas, Louisiana, New Mexico, Oklahoma, Texas
needed to analyze TRI geographically, by chemical, by industry, and by medium.
Objective of the Project
We wanted quick, accurate profiles of TRI data nationwide and by Region, State, Geographic Initiative
Area, county, ZIP, and facility. We wanted to enable Region 6 and State staff to use TRIPQUIC.
Approach to Solve the Problem
We used TRIPQUIC tools including tables, charts, and maps to develop State-specific profiles and to
alert Region 6 and the States to possible misreporting. We provided TRIPQUIC training at Region 6 offices and
on-site at all five State capitals to EPA staff and all Region 6 State TRI Program Coordinators.
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Poster Abstracts _ 1994 TRI Data Use Conference
Outcomes and Conclusions
Regional users found TRIPQUIC's maps and tables effective to analyze patterns of reporting. Some
states plan to use TRIPQUIC to analyze their own state data State TRI Coordinators are enthusiastic and
prepared to use TRIPQUIC.
to Be Included
oMaps
o Drill-downs by state, county, ZIP
o Data tables
o Calendar of completed and planned TRIPQUIC training
D
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1994 TRI Data Use Conference
Presenter Index
Presenter Index
The following people participated in the conference either as speakers, session leaders, moderators, or
poster presenters. Some people presented papers and posters. Below is listed the page on which a paper or a
poster abstract begins. Not all speakers and session leaders submitted a paper for incluion in the proceedings,
as indicated by (Not Submitted) following the name.
Alston, Gayle, no paper submitted
Ausman, Pat, 194
Aucott, Michael, 23,177
Barwick, Kathryn, 48
Bass, Gary, 19
Berliner, Eric, 33
Boisselle, Robert, 83
Bouwes,N.W., 196
Brown, Gerry, 141
Brown, Linda, 132
Bunyon, Elizabeth, 188
Butler, Craig, 48
Carney, Gerald, 126
Carra, Joseph, 11
Chelen, John, no paper submitted
Clark, Janet, 178
Clark, Paul, 178
Cohen, Deborah, 194
Curtis, Janina, 188
DiBartolomeis, Michael, 123
Dionne.Edan, 108
Doerr, Lisa, 25
Donaghue, Bob, 39
Eisengrein, R.H. (Bob), 147,195
Ellenbecker, Michael, 190
Ekart, Nancy, 16
Farag,ttab, 179,180,186
Ferris, John, 73
Fillman, Carey, 179
Firlie,B.,196
Foreman, Debra, 126
Garland, Jason, 179,180
Geiser, Ken, 59
Glickman, Theodore, 137
Goldberg, Terri, 181
Goldman, Benjamin, 133
Goldman, Lynn, 6
Gonzalez, Elizabeth, 73
Gonzalez Arroyo, Mchele, 192
Grandfield, Kathy, no paper submitted
Gray, Hfflel, 168,182
Greene, Terry, 146,195
Greiner, Tim, 32,183
Guillemin, Robert, 181
Hall, L.H., 196
Hall, Loren, 197
Hamilton, Louise, 196
Hanna, Stephen, 12,141
Hannum, John, 13
Hansen, Well, 139
Harriman, Elizabeth, 52
Hassur, S.M., 196
Hawes, Robert (Tim), 54
Hazen, Susan, 109,162
Hearty-Wood, Maureen, 184,185
Heiman, Michael, 150,184
Heminway, Diane, 153
Hendrickson, Chris, 185
Herb, Jeanne, 164
Hersh, Robert, 137
Hicks, Harold, 95
Hill, Paul, 97
Hobbs, Sylvia, 196
Hodges, Theresa, 190,191
Hopkins, Ed, 56
Horvath, Arpad, 185
Hsu, Ailing, 194
Irwin, Fran, 107
Jacobs, Jon, no paper submitted
Jamro, Edward, 166
Johnson, Sharon, 43
Johnson, Thomas, 127
Keane, S.E., 196
Kowalczyk, Joseph, 86
Krubner, Blanche, 191
Kulstad, Susan, 194
Kunzer, Kathleen, 130
Kuzyk, Ivan, 27
Landroche, Janine, 194
Layne, Warren, 197
Latowsky, Gretchen, 195
Lavallee, Francois, 111
199
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Presenter Index
1994 TRI Data Use Conference
Lave, Lester, 185
Lemcke, Bob, 34
Lewis, Sanford, 98,185
Lopez, Nora, 191
Lopez, Russ, no paper submitted
Lydon, Maureen, no paper submitted
Macko, Carol, 72
Marino, Rachel, 179
McDonald, Kevin, no paper submitted
McKie, Deborah, 194
McMichael, Francis, 185
Monsma, David, 115
Muessig, Phil, 102
Murdock, Dick, 82
Murphy, Linda, 3
Neltner, Tom, 189
Nowakowski, Tom, 91
Nunley, Carolyn, 65
Oleru,Ngozi, 196
Opperman, Andrew, 67,177
Omm, Paul, 89
Paramo Figueroa, Victor Hugo, 113
Parr, Alan, 188
Peavey, Dwight, 179
Pearson, James, 120
Peck, Susan, 66
Perelli, Vincent, 180,186
Pine, John, 75
Pollard, Solomon, 126
Quinn, Bowden, 157
Recer, Gregg, 127
Reinhora, Tova, 29
Robbins, Ron, 36
Round, Margaret, 122
Rossi, Mark, 190
Rougvie, Carol, 195
Roy, Natalie, 59,187
Sachdev, Amit, 130
Scott, Jeffrey, 187
Secor,Beth, 36,188
Sekor, James, 120
Shapiro, Karen, 188
Shea, John, 196
Siegel, Jodie, 178
Skokan, Ellie, 103
Smith, Paula, 189
Szudy, Betty, 192
Taylor, Jan, 78
Taylor, Wesley, 91
Tebbutt, Charlie, 117
Thomas, Dave, no paper submitted
Thomas, Karen, 190
Tipton, Gerald, 179
Tirpak, Chris, 45
Tomlyanovich, Steve, 118,197
Topper, Hank, 94
Towns, Brian, 37
Travers, Linda, 173
Vail, Janet, 158
VanVelhuizen, Arjan, 190
Wallace, Len, 179
Waller, Anna, 179,180
Weinstein, Warren, 187
Wind, Jay Jacob, 197
Winik, Leslie, 189
Wolf, Dave, no paper submitted
Wong, Philip, 120
Wormell, Richard, 192
Wright, Paul, 69
Wu,Tse-Sung,185
200
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Friday, March 10,1995
1994 TRI Conference Registrants
Page A-1
Last
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Alan
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Staff Engineer
Environmental Engineer
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Environmental Activist
Environmental Englneer-
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US EPA
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Tech.Asst
Branch Chief- Info. Mgmt
President
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Senior Economist
EOF- Kennedy School
Asst. Editor
EH&S Technical Manager
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Plait Communications
Director of Environmental
Chief, ISS
Regional Director
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MA Dept of Environmental Prot
Clean Air Count*
Idaho Emergency Response C
MA Dept. of Environmental Prot
OMB Watch
1550 Wilson Blvd., Suite 300
Wehnran Emcon
MA Office of Technical Assteta
Toxics Use Reduction Inst
Naval Undersea Warfare Cente
CT Dept of Environmental Prot
US EPA Region IV
TEC. Inc.
MN Office of Env. Assistance
ICF, Inc.
Environment Canada
CmilFvwtmAntal Pjml ilg)l*m A«4m
environmental Keguiation Aam
NH DES Pollution Prevention P
USEPA(NCSC
Air Quality Control
GAIA Corporation
US EPA Region IV
US EPA/OPPT
Island Press
Coore Brewing Company
Arkansas Department of Labor
Cleveland-Cliffs. Inc.
US EPA
Jewish Labor Committee
JB/A Inc. Zephyr Tech. Dtv.
LA. Dept of Environmental Qu
NEEA
MA Office of Technical Assteta
CT Dept of Environment Prote
CO Dept. of Public Health and
Street
3225 Main St
1890 AA Congressman WL
RR1*3739
503 OBn Eng. BkJg.
P.O. Box 38
1600 Clifton Rd E33
1 1 InfuaraVu Aua
i uniWiaHj nw.
200 Bowdoin St
JFK Federal Bidg. (PAS)
150 TremontSt, 8th Floor
4*yY\ 1 C* UYAS
i£Aj L oL, NW
CN423
80 E. Concord St
Dartmouth Cotege
436DwlgrrtSt.
135 S. 19th St Suite 300
1109 Main St, Suite 250
75 Grove St
33MtVemonSt
P.O. Box 806
1742 Connecticut Ave., NW
MallCode3495
6 Riverside Dr.
100 Cambridge St, Suite 21
UMass Lowell. 1 Univ. Ave.
1176HowellSt, BkJg. 11 C
571 Bee St
79 Elm SI
345 Courdand St., NE
33 Thompson St.
Lakeside Ave.
1350 Energy Lane
1781 Highland Ave.
2909 N. Sheridan #1003
224 West Esplanade
401 M Street, SW (2245)
O4IVI KJI \t AIM CC GidftA O
ziuu MLK Ave., sc, oune *.
6HazenDr.
2890 Woodbridge Ave.
1 Winter St
8630 Fenton St., Suite 226
345CourtJandSt, NE
401 M St., SW (7406)
285 Harvard St. #102
1718 Connecticut Ave., NW,
BC395
10421 West MarkhamSt
1615 Poydras St.
110 Superior Ave.
401 M Street, SW
33 Cynthia Rd.
33 Broad St., 4th Floor
P.O. Box 82263
P.O. Box 2394
100 Cambridge St., Suite 21
79 Elm St.
4300 Cherry Creek Dr. Sout
City
Bamstabte
MontQOfnery
Cnichester
Hsmpton
Ervtng
Atlanta
1 nunll
uiwmi
Dorchester
Boston
Boston
IA/oehlnj^An
wasnington
Trenton
Boston
Hanover
Springfield
Philadelphia
Boise
Worcester
Boston
Sacramento
Washington
Rosryn
Andover
Boston
Lowell
Newport
Meriden
Hartford
Atlanta
Winchester
Burlington
St. Paul
Cheshire
Chicago
North Vancouver,
Washington
VA/aehlnjwtAn
wasnington
Concord
Edison
Boston
Silver Spring
Atlanta
Washington
Cambridge
Washington
Golden
UttieRock
New Orleans
Cleveland
Washington
Needham
Boston
Baton Rouge
Concord
Boston
Hartford
Denver
State
MA
AL
NH
VA
MA
GA
UA
nfln
MA
MA
MA
no
Uw
NJ
MA
NH
MA
PA
ID
MA
MA
CA
DC
VA
MA
MA
MA
Rl
CT
CT
GA
MA
VT
MN
CT
IL
Canada
DC
n/*
DC
NH
NJ
MA
MD
GA
DC
MA
DC
CO
AR
LA
OH
DC
MA
MA
LA
NH
MA
CT
CO
Zip
02630
03263
23668
01344
30333
nftic%4
UO lO*f
02122
02203
02111
«xvmc
AJUQO
086254)423
02118
03755
01103
19103
83720-3401
01605
02108
95812-0806
20009
22209
01810
02202
01854
02841
06450
06106
30365
01890
05401
55108
06410
60657
V7M8H7
20460
*WWl
20020
03301
08837-3679
02108
20910
30365
20460
02139
20009
80401
72205
70112
44114
20460
02194
02109
70884-2263
03302-2394
02202
06106-5127
80220
Phone 1
(508)362-3828
(205)260-2777
(603)435-6039
(804)727-5819
(508)544-2711
(404)639-6205
/eftO\oo>i oooe
\3njv) 03^-3&9v
(617)825-9800
(617)565-3346
(617)727-2735
/OfV3\ fifiO-fldlfi
\AJ£) OO2-ODUD
(609)777-4323
(617)638-8841
(603)646-2064
(413)784-1100
(215)567-4004
(208)334-3266
(508)792-7692
(617)742-4950
(916)323-9560
(202)2344494
(703)235-5591
(508)682-1980
(617)727-3260
(508)934-3294
(401)841-4752
(203)534-9110
(203)424-3244
(404)347-1033
(617)729-8450
(802)657-6669
(612)649-5765
(203)272-8874
(312)8360304
(604)666-3221
/OAO\ ttAK. £t£t4 7
(202) O4O-661 7
(603)271-6460
(908)9064842
(617)292-5630
(301)608-9459
(404)347-3555
(202)260-1622
(617)547-1844
(202)232-7933
(303) 277-2196
(501) 682-4541
(504)582-1743
(216)694-5414
(202)260-7248
(617)449-1786
(617)367-4321
(504) 765-0720
(603)224-4773
(617)727-3260
(203) 424-3274
(303)692-3009
Fax
(508)362-3136
(205)260-2795
(804)7275091
(508)544-2102
/cno\ 4eo_c74 4
\3UO/ ^3>vvf 1 1
(617)825-1898
(617)565-3346
(617) 727-6584
/*W)\ M3*VJ5TW1
(fSf£) yttt-o/ou
(609)777-1330
(617)638-8841
(603)646-1308
(413)784-1149
(215)567-5791
(208)334-3267
(508)792-7621
(617)742-4953
(916)327-4494
(202)2344584
(508)975-2066
(617) 727-3827
(508)9343050
(401)841-4747
(203)5664924 -
(404)347-1681
(617)729-8450
(612)649-5749
(203)272-2804
(312)6364082
(604)6664800
/*Wi\ JU\A 4 4 At
(202)404-1141
(603)271-2456
(908)3214788
(617) 556-1049
(301)6084470
(404)347-1681
(202)260-1551
(202)234-1328
(303)277-2463
(501)682-4508
(504)582-4936
(216)694-4073
(202)260-4659
(617)3674581
(504)7654742
(603)228-5329
(617)727-3827
(203)5664255
(303)782-4969
-------
Friday, March 10.1995
1994 TRI Conference Registrants
Page A-2
Last
Burnt
turns
Bums
BusflekJ
Butter
CahHtane
Catoy
*••»..!, all
/ampDefl
sftntwml
Caro
Cans
Carty
Cavanaugh
Cetaya
^etenza
f*i — i —
wnvKn
Mvistman
CMzik
l^biitUiMJln
omtagno
^inrtokowsM
Ctapp
Clark
Clark
Clausen
Cobas
Codina
Cohen
Cootey
Dord&no
Costa
Couteon
Couto
Crawford
Crtpps
Crystal
Cummlngs-Sex
Curtis
PAgostino
ffEramo
Damon
Darrey
Darveau
Davto
Day
DeBrew
DeMeo
DeMteco
DeShnone
DeWulf
Dean
Detaney-Mufca
Daramo
Dewey
CHBartokxnels
Dkjgs
Dtenne
DHz
Doa
First
Carol
JohnDavM
Tom
If—nirfnii
WWKtK
Craig
Matt
Joanna
Rich
Betsy
Lute
Joseph
Steve
Mfchefe
Fred
lAMkAA
lames
John
Mark
Scot
!•..>••
JomOS
John
Richard
Janet
Paul
JudMi
E. Elisa
Thebna
Deborah
James
Mark
Robert
Atene
Mfce
Jan
Cotoen
Roy
Jomos
liiMarm
joranq
Stephanie
Tony
Usa
Sua
Linda
Eric
Susan
Rod
Teny
Dan
Blanche
Cindy
Joe
Martha
Joanne
Robin
Mfctael
Emfe
Edan
Daryt
Maria
Addressl
Principal
THta III Pmnrom Itamnor
)irector of Operations
Manager, Polkjbon Preven
Onto EPA Office of PoRutl
NH Division of Pubic Heal
Elnvironmeiiuil Specialist
tnwonmentHi Analyst
Computer Programmer
Acting Director, Office of
Supervisor, Ntagra Escarp
TRI-US Ubrarian
Senior Environmental Mgr.
Director
Executive Director
Senior Counsel
Environmental Issues Man
Corp. Env. Safety Hlth.
Assttant Director
Asst Professor
Director of Environmental
Chemical Engineer
TRI Program Manager
CIS Analyst
Natural Resources
PHD Candidate
Senior Associate
EMS III. Bureau of Waste
ESU/TID
Research Associate
Bureau of Waste Mgmt.
Manager, Env. Planning
Principal
Pollution Prevention Coord
General Engineer
Database Assistant
Managing Editor, Pestfck)
environmental soenusi
Environmental Protection
Senior Analyst
BDM Federal, Inc.
Natural Resources
Sr. Admin. Analyst
Env. & Safety Info. Mgmt
TRI Program Coordinator
Systems Analyst
Rl Department of Environ
DE Dept Natural Resourc
MA DepL of PubDc Health
Chief, PesUddes&Food T
Environmental Specialist
Prog. Mgr Air Issues Corp
Associate
Acting Branch Chief
Address2
ccB Enterprises
Mississippi Emergency Manag
WV Office of Emergency Servl
Aquateira Environmental Sen/fc
Box 163669
Sherwin-WDBams Co.
jwrence Uvermore Lab
3R Environmental Quality Boar
Environmental Protection Agen
Ministry of Environment & Ener
.abat-Anderson, Inc.
Magma Copper Co.
RICOSH
Unison Institute
DuPont Company
Eastman Kodak Company
/vestvaco Corporation
CT DepL of Environmental Prot
BU School of Public Health
Toxics Use Reducton Inst., U.
Portsmouth Naval Shipyard
P.O. Box 400
Camagte MeHon University
US EPA Region 5
ROW Sciences- C/O US EPA
ICAD/UGA
Univ. of Pittsburgh, Kate Schoo
ICF, Inc.
NV Division of Env. Protection
DOT/FAA
B307, JFK School of Govt.
Division of Env. Protection
GEC
Industrial Economics
Rtzzo Associates, Inc.
NH Dept. of Env. Services
US DOT (Voice Center)
Hazardous Waste Research an
CRC Newsletters
US EPA
Portsmouth Naval Shipyard
AM Associates
ICAD/UGA
NYS Dept of Env. Conservatto
American Cynamld Company
Ohio Environmental Protection
Versar, Inc.
Dlv. of Air 4 Hazardous Materta
Air Quality Mgmt. Section
Occ. Health Surveillance Progr
CA EPA - Office of Env. Health
US Coast Guard Grp WOods
IBM Building 2 Mall Drop 2393
Work) Resources Institute
OPPT/EADm*IB
Street
P.O. Box 336
P.O. Box 4501
Main Capitol Building 1 , Rm
79 5th Ave, 12th Floor
1600 Watermark Drive
6HazenDrtve
101 Prospect Avenue
1824 Beacon St. *6
P.O.BoxBOe, L-627
40 50 1558. La Rivera
401 M St (MC7401)
250 Davtevaie Ave., 3rd Fkto
401 MSt.SW 7407
200 South Reddlngton Rd.
741 Westminster St
1731 Connecticut Avenue, N
D-8078- 1007 Market St.
1 100 RkJgeway Avenue
2001 Roosevelt Ave.
79EknSt
80 E. Concord St
1 UnlverslyAve., Penn. Bid
Code 120; 879
5000 Forbes, CMI & Env. E
77 W. Jackson Blvd.
JFK Federal BWg.PIM
1234S. LumpktnSt.
144l8oktaDr.
9300 Lee Highway
333 W.Nye Lane
79JFKSL
333 W.Nye Lane
1K Bmt**Ha Dttrtr nriu»
2067 Mass. Ave.
235 W. Central St
P.O.Box95,6HazenDrive
Kendal Square
1 E. Hazdwood Drive
1101 Penn. Ave., SE
1 Congress St(ATO)
Code 920 IH
55 Wheeler Street
20300 Century Blvd.
1234S. LumpHnSt.
50WolfRd..Rm53B
One Cynamld Plaza
1800 Watermark Drive
9200RurrmeyRd.
291 Promenade Street
89 Kings Highway, P.O. Box
ISOTremontSt
2151 Berkeley Way Annex 1
Engineering Support Activity
Route 100
1709 New York Ave, NW
4425 Fessenden St, NW
City
North Sdtuate
Jackson
Charleston
New York
Columbus
Concord
Cleveland
BrooMlne
Uvermore
RtoPletras
Washington
Toronto, Ontario
Washington
San Manuel
Providence
Washington
Wilmington
Rochester
Springfield
Hartford
Boston
Lowell
Portsmouth
Lexington
Pittsburgh
Chicago
Boston
Athens
Pittsburgh
Fairfax
Carson City
Nashua
Cambridge
Carson City
Randolph
Cambridge
Natfck
Concord
Cambridge
Champaign
Washington
Boston
Portsmouth
Cambridge
Germantown
Athens
Albany
Wayne
Columbus
Columbia
Providence
Dover
Boston
Berkeley
Woods Hole
SofTWfB
Washington
Washington
State
MA
MS
WV
NY
OH
NH
OH
MA
CA
PR
DC
Canada
DC
AZ
Rl
DC
DE
NY
MA
CT
MA
MA
NH
MA
PA
IL
MA
GA
PA
VA
NV
NH
MA
NV
MA
MA
MA
NH
MA
IL
DC
MA
NH
MA
MD
GA
NY
NJ
OH
MD
Rl
DE
MA
CA
MA
NY
DC
DC
Zip
02060
39296-4501
25305
10003
43266-1049
03301
44115
02146
91703
00981-1415
20460
20460
85631
20009
19898
14652-6263
01104
06106
02118
01854
03804-5000
02173
15213
60604
02203
30602
15209
22031
89701
03060
02138
89701
02368
02140
01760
03302-0095
02142
61820
20003
02203
03801-5000
02138
30602
72233
43215
21045-1934
2908
19903
02111
94704
02543-1099
10589
20006
20016
Phone 1
(617)545-9556
(601)960-9975
(304)558-5380
(212)675-8200
(614)644-3257
(603)271-4664
(216)566-1768
(510)424-2687
(809)766-2883
(202)260-3810
(416)440-3778
(202)2604568
(602)385-3581
(401)751-2015
(202)797-7200
(302)774-6443
(716)477-5584
(413)787-0797
(202) 424-3919
(617)63^4731
(508)934-3275
(207)438-5020
(617)862-9391
(412) 268-6634
(312)8864219
(617)565-3659
(706)542-3350
(412)492-9417
(703)934-3544
(702)687-4670x3
(617) 496-6218
(702)687-4670
(617)961-1200
(617)3544074
(508)651-3401
(603)271-6398
(617)494-3387
(217)244-5776
(202)544-1980
(617)565-4993
(207)438-2857
(617) 349-2768
(301) 212-6233
(706)542-3350
(518)457-2480
(201)872-7927
(614)644-3606
(410)964-9200
(302)739-4791
(617)727-2735
(510)540-2665
(508)457-3316
(914)766-2729
(202)662-3498
(202)2604592
Fax
(601)352-8314
(304)344-4538
(614)644-2329
(510)422-1395
(202)2604575
(416)440-7039
(202)260-4659
(602)385-3486
(401)751-7520
(202)234-8584
(302)774-1189
(716)722-3695
(413)767-9749
(617)638-4857
(508)934-3050
(207)438-5173
(412)268-7813
(312)353-4342
(617)565-3736
(706)542-6189
(702)6874860
(617)495-8963
(702)8854860
(617)961-6546
(617)3544463
(506)651-1169
(603)271-2867
(617)49403387
(217)3334944
(202)546-3890
(617)565-4939
(207)438-3650
(617)349-2660
(301)2124251
(706)5424189
(5180457-2570
(201)872-7944
(614)6444681
(410)9644156
(302)739-3106
(617)727-2929
(510)5404408
(508)457-3313
(914)766-2824
(202)6384036
(202)4014142
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A- 3
Last
Door
UORBK
DOMOftlUA
Donnely
Dn*\
DraMg
DuPute
Dube
Duff
Dumont
Ounn
Durat
Dwyer
Dyer
Dymon
EJsel
Eisengrein
Ekart
Elder
Ensnder
Erickson
r^nharthanh
cvcnenmcn
fuatrm
Fafeanberg
Faraa
r«m
Farm
Fessinger
Fertw
C^MtMMiwv
rS1IIBlMJS£
Farrera
Ferris
Fente
Feaco
Flman
Fbn
*-•
rose
Fteck
Fletcher
FtocMwt
FOfWIHafl
Fotter
•» — j —
rovvni
rOK
Cfearfj
FlOSt
Frydryk
Funto
r*«JI»naSair
Oatagher
Gail alien
Gaiaar
George
Gayer
(MDeMffl
firsts* sW
fMmfMfil
Gfcfcman
First
Uaa
DnttAit
Kooen
Bob
David
John
Metanto
DavW
Jason
Reed
Timothy
RUBS
Rod
Ron
DevU
Sharon
Bob
Nancy
Monty
Kicnara
Jan
Many
WHffnm
Georgia
lhab
Anorea
Joan
Ken
Luta
Randy
John
Lena Ham
ENeen
Carey
Kristin
IfvloHn
Andrew
Tom
Dtoa
Debra
Chariot
!*•••
KODen
Karen
Teresa
Alda
Odefla
rWmrfi
Pat
G. Terence
Kan
Sam
Greg
nano
fllrtimrrl
If^tti
Theodore
Addressl
MN Program Director
tinVuOiinienCal AnflTyw
rrWwWii
Progrsni Msneger* Tochnt
Environmental Policy Anal
Plant Engineer
Process Engineer* Envfro
Student
Environments! Engineer
Wl 313 Coordinator
American Mining Congres
Director. Office of PolPr
FAA
Issue Manager SARA/Poll
Technical Manager
Eastman Chemical Comp
EPCRACooralnator
Rl Dept of Environmental
U.S. EPA
Director- Health. Safety, &
T«r*inlr
/fi17\ TOTJWflO
(202)424-3919
(617)482-9485
(809)7674129
(202)2604702
(617k 292.6572
(307)7774105
(508)6514993
(508)9344275
(812)2734000
(518)457-2480
iar\1\ mi-OOPR
(401)277-3434
(617) 786-274S
(202)3284127
Fax
(612)8244506
(zua) ozi yjj /
(404)651-5130
14U1 ) //O-«»W
(617)241-2301
(603)271-4664
(518)4734748
(617)389-2831
(317) 477-4180
(603)862-2304
(207)438-1535
(608)267-5231
(202) 861-7535
(207)287-7826
(517)6384933
(615)229-4864
(405)271-7339
l*M) il l-£3a\
(202)260-4659
(617)6834183
m?) 3K3-43A')
(312)6164152
(603) 662-3747
(O(U) fOvOUOO
(313)556-7629
(617)860-4397
(809)7564906
(901)7584201
(202)2604927
(202)2604178
(icuZ; /QD-AIB
(617)695^732
/O4 T\ T»V\Jff^%
\Ol f ) fAr9f4&
(717)772-2303
(617)8914553
(215)597-3156
(302)834-7496
/44A\ CtftJ fi4fia
\*1U) UM O19D
itnt\-rrr itm
(808)7564006
(202)260-4659
(R1 7\ «WA_1 fMO
(307)7774873
(506)6514393
(508)453-2332
(812)2734002
(518)457-2570
mm\mi ocuw;
(401) 277-2SB1
(202)8394460
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A- 4
Last
Goldberg
SoWman
Gonzalez
Goodner
Gosselin
Grandfteid
Gray
aresno
Gregory
Greiner
GremUHon
Grey
Grtffln
Srtffln
Graver
GuBtemin
Guo
Gurflnkel
Gurkewicz
GutowsM
Guzman
Madden
Hagevik
Hall
Hall
Hamilton
Hammett
Hanna
htannon
rtannum
Hartsen
Hardage
Harriman
Marring
Hp-t
rlcuTlS
Hart
Hassur
H&WB8
Hazen
Helm
Hebnan
Hnl»Mf
mnvBy
Hembiway
Hereto
Henson
Herb
Hicks
HBer
HI
HI
1 II •
HITWuGDergGr
1 Ihuihrahawwl
nilfMMnfWAI
Hktz
• !-»-«--
nODDS
Hodgst
* «^_i
nOuy6*
1 1 llMll 1 ••!
1 HIIIIIWI
1 InrMiar
nOynCT
First
Terrl
Ben
Elizabeth
oe
Alain
Kathy
Hiltel
Terry
Michael
Tim
Keith
Jeff
Bill
lennlfer
Terry
Robert
Glna
Alex
Sandy
Tessa
Rafael
James
George
Andrea
.oren
Louise
Nancy
Stephen
Robert
John
IdeU
Jim
Uz
Paul
Charles
Maureen
Steven
Robert
Susan
Steven
Michael
Lynn
Diane
Jody
Susan
Jeanne
Harold
Margaret
Jay
Paul
Jeff
dwinn
^^M^^MI
James
Sylvia
Jerry
Theresa
Jo
Robert
Addressl
NEWMOA
obs and Environment Ca
TRI Coordinator
Senior Engineer
Spokesperson
Policy Director
Center for Env. Health Stu
Director
Public Relations Specialist
Student
Engineer TUR
Doctoral Candidate
Environmental Complianc
NEWMOA
environmental Quality Spe
Project Manager
OR Dept of Env. Quality
Management Analyst III
Student
reformation Systems Deve
rrogram rnncipai
Editor
Environmental Protection
Sr. Toxteotogist
President
Assistant for Environment
Supervising Environmenta
P2 and EPCRA Policy Se
Pollution Prevention Plann
Pollution Prevention Progr
MA Toxics Use Red. Inst
Consultant
UOmmanOer- Uo ATTTiy tn
cnVtrOnfTicrKal Uata KG86
U.S. EPA OPPT/EETD/I
Corporate Environmental
Acting Deputy Director, 0
Assoc. Professor
Regional Planner
Western NY Director
Training Associate
flrtfilnjJ t*r>lo»-Jfa-i>
rTO)6Cl odcfKISl
Director, Ofc. of Pollution
Plant Manager
Asst to TRI Program Man
fill Jiniiicii ii ill ill linnnnnr fl
cnVUUfUIIUilUII MBflBycr, *
President
Researcher
CAninr rnuhnoniiMMiliil ^A!A
wdl^M dlvnUllllldllfll w^m
313 Coorolnator, Region
l"lfll^J. jj ElU-fe>lflHlilfrflll 1 1
ornoBoi tnvtronmeniai n
Project Manager
Director- Office of PoNutto
environmental spedaHsi
Florida International Uirtve
Address2
LEPA
Environment Canada, Quebec
Good Neighbors
National Environmental Law Ce
JSI Research and Training Insti
AZ Toxics Information, Inc
Greiner Environmental
Platt Communications
Dept of Civil Engineering
MA Office of Technical Assteta
US Postal Service
TX Natural Resource Conserve
Innovated) Associates
CTDEP
SUNY Environmental Science
TX Natural Resources Cons. C
Nat. Conf. of State Legislatures
Community Right to Know
U.S.EPAOPPT
Boston Dept of Health & Hospi
Environmental Profiles, Inc.
Cal/EPA
CT DEP- Waste Mgmt. Bureau
Dept of the Navy
Dept of Ecology
MS. Dept of Env. Quality
U. Mass. Lowell
Regeneration oystems
Attn: SFIM-AEC-ECP
Mai Code 7406 Room E-349A)
Polaroid W2-MEZZ/32
US EPA
Dickinson College
Mass. DEP /TURA
Citizens Environmental Coaimo
Toxics Use Reduction Institute
RoyF.Weston
New Jersey Department of Errvi
Ashland Chemical
USEPA/NCSC/ntJelll
Ashland Petroleum Co.
National Institute for Chemical
Clark University
Amntam Envfnwwmftfil Soruic
m|u
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A- 5
Last
Holder
Honey
LbtMMn*
noprans
Horvath
Horwte
Howel
HowM
Hsu
Hubby
Hubwhman
Hunter
Hutton
IbiKunfe
Irwln
tsnor
Jsckson
Jacobs
Jamro
Jansssn
Javeflo
Johnson
Johnson
Jones
Joreey
Jover
Juras
Kaeser
Kate
Kamden
tanner
Karger
Karrer-Rueedl
Katz
Kefley
Kesstor
Keywortn
MevK-Kytar
Wlberg
King
King
Kingsbury
KlrMand
Klebi
V^PBHI
Ko
Kocher
Kbwatezyk
KowateW
KowateW
Kraft
KronopoKis
Krubner
Kuraer
Kurka
Kuzyk
Langtoy
Uuignar
Lappan
Latowsky
First
Jack
Lawrence
GA
to
Arpad
Marie
Frank
Kent
Afflng
Kfrnb6f1y
Jonathan
Meal
Eric
Ade
Fran
B—AU.A
KODeTt
Robert
Jon
Edward
Jim
Mark
Brent
Sharon
John
Davtd
Tony
Michael
Frederic
Fred
Ruth
Josh
Eva
Ema
Robin
Barbara
Mathew
Chris
Doug
Eric
Geff
Kathryn
Paula
Garrett
Hakfl
ncRfl
Jimmy
Pwn
Joseph
Mary Arm
Norb
Daniel
John
Blanche
Kathleen
Becky
Ivan
Burt
Marian
Gerald
Gretchen
Addressl
President
n|| nnr4 rjl f— iMifmitiwiniJul
PA uept. or environmental
Environmental Director
Graduate Research Asstta
Chief, Office of Chemical
Sociologist
Environmental Specialist
GIS Analyst
Chemical Engineer
Policy Analyst
Staff Engineer
TN Dept Of Env. Protect!
President
Director, Pollution Prevent!
cnvironmetnai Analyst
Environmental Engineer S
Eastern Branch Chief
M&n&06r- Environmental
Technical Advisor
President
Deputy Director
TRI Coordinator
SERC Coordinator
PREPAREDNESS STAF
TRI Coordinator
Environmental Project En
Buzzards Bay Project
loiorinauon apeciausi
Research Asst
Corporate Mgr. of Health
Vtetting FeBow
Student
Director
Madsen Marketing Strateg
Sr. Project Manager
W Dept Env. Cons.
Pi¥\fii'jinfi ^AMnrfliurffv
rnjyioin WWUIUHMIWT
Ubrartan
Labor Educator
Boeing Company
Multimedia Enforcement
Environmental Scientist
Community Relations
Chief Toxic Substances S
Chief, CompHance & Enfo
Outreach
Texas Natural Resources
Analyst
Georgia Emergency Resp
PHD Candidate
U.S. EPA
Director- Community Tech
AddressZ
Redtoh Associates
P.O. Box 8471
^Itl •« 1 1 AjxiLnJi
cmzen Acnon
Dept. CMl and Env. Eng
US EPA Region 5
Mississippi State University
GA Environmental Protection D
R.O.W. Sdeces/EPA
Portsmouth Naval Shipyard
MNOEA
SC Dpet of Health & Env. Cont
Division of Pollution Prevention
OCF Environmental Technotogl
World Wildlife Fund
^T f\AM^ l*f Cn-ulflJULIBI^LILlill Pi^J
UT uept. or environmental rrot
Michigan Dept. of Natural Peso
US EPA/OECA/ORE/Toxtes &
Monsanto
ILEPA
Aquatena Environmental Servto
NC Office of Waste Reduction
UT Dept of Environmental Qual
CTDEP
OSWER
SC Dept. of Health & Env. Cont
United Technologies Corporate
C2MEOEA-MA
Industrial Economics
AM Associates
Polaroid Corporation
Yale University- School of Fore
Dept of CMl Engineering
MA Office of Technical Assists
Energy Consulting & Engineer!
P2 Division
MN Pollution Control Agency
Labat-Anderson, Inc.
Berrttey College
AM Associates
MASSCOSH
Matbvul ABIUH* nf HnaHh Offal
naumwu fwow?. wi nvaiui WHIM
National Environmental Law Ce
NYS Dpt. Env. Cons.- Drv. of E
US EPA, PTSB/TSS
US EPA Region 9
U.S. EPARegion II
MA Dept. of Environmental Prat
NCSC/EPA
Chemical Manufacturers' Asso
Office of Pollution Prevention a
Connecticut Technical Asstetan
MIT Rm 16-315
Office of Enforcement
JSI Research & Training Instttu
Street
1030 Massachusetts Ave.
| • -yi * nil Cl 1 U\A/
ii2u lain street, NW
Carnegie Mellon University
77 W.Jackson Blvd.
P.O. Box 5287/103 Researc
7 Martin Luther Wg Drive, #1
JFK Federal Bldg., GIS Rm.
Code 106.2; B22
1350 Energy Lane
2600 Bull St.
401 Church St.. 8th FI..L&
285LynnshoreDr.#611
1250 24th Street, NW
TO C|M G*
fabim SL
P.O. Box 30457
1200 Pennsylvania Ave., N
730 Worcester St.
2200ChurchM
79 Fifth Ave., 12th Floor
3825 Barrett Drive, 3rd Floor
168 North 1950 West
79 Elm St.
WH-562A.401 M ST SW
2600 Bull St.
1 Financial Plaza, UTC Bull
2 Spring St.
2067 Massachusetts Ave.
55 Wheeler St.
1265 Main St- MEZZ
205 Prospect St
University of New Hampshlr
100 Cambridge St
31 (Odder Ave.
35MagooPark
103 South Main Street
520 Lafayette Road, North
c/o Oppt Library, US EPA 4
P.O. Box 1449
15 Wheeler St.
555 Armory St.
440 1st St NW Suite 500
•ffW lOt vt<| I^IVVi wUHO *A^V
P.O.BOX3707.MS7E-EH
29 Temple Place
50 Wolf Rd.
2890 Woodbridge Ave.
75 Hawthorne St
2890 Woodbridge Avenue
75 Grove St.
3 W. Connecticut Concours
2501 M Street NW
P.O. Box 13087
SO Columbus Blvd. 4th Floor
205 Butter St., S.E.
77 Massachusetts Ave.
401 M Street, SW, Mall Cod
210 Lincoln St.
City
Cambridge
Harrisburg
IHfuj.j.t-.lfcl j...
Washington
Ptttsburg
Chicago
Mississippi State
Atlanta
Boston
Portsmouth
St. Paul
Columbia
Nashville
Lynn
Washington
IJailf-Jtf4
narnora
Lansing
Washington
Springfield
Springfield
New York
Bangor
Raleigh
Salt Lake City
Uj..4f JlJLfi
narnora
WASHINGTON
Columbia
Hartford
Marion
Cambridge
Cambridge
Waltham
New Haven
Durham
Boston
SomervNIe
Acton
Waterbury
St. Paul
Washington
Orleans
Cambridge
Boston
Washington
Seattle
Boston
Albany
Edison
San Francisco
Edison
Worcester
Jackson
Washington
Austin
Hartford
Atlanta
Cambtrdge
Washington
Boston
State
MA
PA
n/*
DC
PA
IL
MS
GA
MA
NH
MN
SC
TN
MA
DC
Ml
DC
MA
IL
NY
ME
NC
UT
CT
DC
SC
CT
MA
MA
MA
MA
CT
NH
MA
MA
MA
VT
MN
DC
MA
MA
MA
DC
wv*
WA
MA
NY
NJ
CA
NJ
MA
NJ
DC
TX
CT
GA
MA
DC
MA
Zip
02138
17103
'VWAfi
20036
15213
60604
30334
02203
03804-5000
55108
29202
37243-1551
01902
20037
ftd/^t
UDIUD
48909-7957
20004
01151
62706
10003
27609
84116
06108
20460-
29201
06101
02738
02145
02138
02174
06511
03824
02202
02144
01720
05671-0404
geftf-B*
OOtPO
20460
02653
02138
02130
20001
AWW I
98124-2207
02111
12233-5500
08837
94105-3901
08837
01605
08527
20037
78711-3087
06106
30334
02139
20460
01867
Phonejl
(617) 491-8315
(717)787-9870
y*w>t TTC 4 con
(202)775-1560
(412)268-5666
(312)353-9045
(601)325-2014
(404)656-6905
(617)565-4895
(207)438-1501
(612)649-5771
(803)734-5254
(615)532-8005
(617)598-5452
(202)778-9646
/*W9\ A*$A *3/V>Q
(203)424-3023
(517) 373-2731
(413)7303397
(217)782-6700
(212)675-8200
(919)571-4100
(801)536-4113
(203) 424-3373
(803) 89641 17
(203)728-6394
(508)748-3600
(617)3544074
(617) 349-2485
(817)432-3751
(203)432-3751
(003) 862-1433
(617)727-3260
(617)628-9297
(508)635-9500
(802)241-2888
(612)296-8643
(202)260-3944
(508)2400905
(617) 349-2771
(617)524-6686
(2021783-5550
1 4bVf& J f VJNJwvU
(206)393-4702
(617)422-0880
(518) 457-0090
(908)906-6815
(415)744-1108
(908)321-6669
(508) 792-7692
(908) 321-4352
(202)887-1118
(512)239-3147
(203) 241-0777
(404)6566905
(617)253-0285
(202)564-5024
(617)482-9485
Fax
(617) 491-2135
(404)657-7893
/*wi\ ****-•• jAnfA
(202)296-4054
(412)268-7813
(312)8806064
(601)325-7966
(404)651-9425
(617)565-3736
(207)438-1591
(612)649-5749
(803)734^407
(615) 532-0231
(617)599-2787
(202)293-9345
/*VVS\ g^g fW"f
(203)566-5255
(517) 335-4729
(413)730-3299
(217) 782-9142
(212) 242-0368
(919)571-4135
(601) 536-4242
(203)566-5255
(803)935^322
(203)728-6570
(508)748-3962
(617)3544463
(617)349-2660
(617)3800880
(203)432-5912
(603)862-2304
(617)6601431
(508)635-9180
(802)2413298
(202)260-4659
(508) 240-1622
(617)349-2660
(617)524-3508
ron3\7M-i
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A- 6
Last
Latthmr
avatee
Le
eclair
erocke
eonardos
McNnsky
e&sard
,0WIS
Lewis
Un
Lomasney
HIMlllllBui II
xxnoaroo
Lopez
Lopez
Luskin
ydenberg
.ydon
Lynch
Mackte
Macto
Madsen
Mah
tfann
tansur
ktarinRIi
Marino
Martin
Maraneffl
Matttta
vtaurer
McBrten
McCarthy
McCaughey
McCoy
McDonald
McGowan
McKenna
McLaughOn
McLeod
McMartin
Meatey
Mehta
Metendez
MeMBe
Mendolla
| luinljtl.
MclTHCK
Meyer
Mlgltore
Miktuk
Mler
MMs
RnMV
MBmoe
nrtwicr
Miner
Mkwtt
Monsma
First
Rick
:rancote
Lan
Brian
Bob
Gregory
Al
James
Cindy
Sanford
Gene
Rita
Massimo
Nora
Russ
Jack
Steven
Maureen
Thomas
Donald
Carol
Sarol
Terry
William
Sally
Unda
rrank
Jonnte
Laurie
Richard
Steve
Gregory
Glna
James
Km
Kevin
BIH
Stephen
BIH
Walter
Dan
Marsha
Prem
Ltebeth
Ann
Connie
Michael
Ingrid
John
Kathy
Cflthorino
Dick
J8ck
Phi
Lee
William
Joseph
David
Addressl
Senior Project Engineer
Head, NaU. Pollutant Rete
FAA
Senior Advisor
P2/CRK Supervisor
Principal
•echnlcal Assistant
invironnrwnt&l M0r.
US EPA Region 1
Director
PHD Candidate
National Pollution Prevent!
EH&S Supervisor
Regional 31 3 Coordinator
Environmental Diversity F
Associate Director
Research Director
Compliance Branch
Assistant to the President
Environmental Scientist
Senior Editor
President
Project Engineer
FAA
P2 Coordinator
EPCRA Section 313 Enfo
3orp. Env. Specialist
Environmental Engineer
Director of Safety Lab Ser
Environmental Scientist II
Environmental Engineer
Exec. Dh> Toxics Use Re
P2 Manager
Environmental Engineer
Principal Environmental PI
Chief of Technical Service
Assistant Coordinator
Staff Engineer
Senior Regulatory Analyst
Environmental Engineer
EPCRA Coordinator
Senior Environmental Engi
Labor Educator
Tftvi/v^^vihrf
Environmental Analyst
Program Manager
inronrauon Management
Inspector
Environmental Services
Inspector
MIS Coordinator
Systems Analyst
Consultant
NYS Dept Env. Conserve
Executive Director
Staff Counsel
Address2
Ell-Lilly & Co.
Environment Canada
Ontario Ministry of Environment
WA Dept. of Ecology
Environmental Odor Consultant
US EPA
'ortsmouth Naval Shipyard
Office of Regional Counsel. RC
Good Neighbor Protect
MITRm. 16-315
Connecticut Technical Asstetan
ATC Diagnostics, Inc.
U.S. EPA Region II
Toxics Use Reduction Institute
Wdor Lydenberg Domini
Office of Compliance MonKorin
National Tank Truck Carriers
US EPA
Bureau of National Affairs Inc.
Madsen Marketing Strategies
Environment Canada- EPB
US EPA Region I
U.S. EPA Region I
Raytheon Company
Texaco
Housatonlc River Initiative
Genzyme Corporation
AL Dept of Environmental Mg
U.S. Dept of Energy (EM-334
MAEDEA
Narragansett Bay Commission
Dept. of Environmental Protect!
MN Office of Environmental As
MA Offices of Technical Sen/to
Buzzards Bay Project/ Toxics U
MA Office of Technical Assteta
American Petroleum Institute
Abt Associates
HI Dept of Health Haz Eval&E
AkzoNobte Chemicals Inc.
MASSCOSH
ME Dept, of Environmental Prot
CT Dept. of Env. Pollution
US Dept of Energy
US EPA
EPA Region 1
Associated Industries
USEPA6T-PT
MA Water Resources Authority
MA Office of Technical Assteta
Letand Miner Consulting
Bureau of Spill Prevention and
CteanAlrCouncH
F iln» mi 1 A «4I
cnvuwiMneiiuu ACuon
Street
Jlly Corporation Center
Place Vincent Massey, 10th
135St.ClalrAve.West
P.O. Box 7600
43 Ronald Rd.
2890WoodbridgeAve.
Code916E
JFK Federal Bldg.
P.O. Box 79225
77 Massachusetts Ave.
50 Columbus Blvd., 4th Ftoo
31 New York Ave.
2890 Woodbrtdge Avenue
67 Batterymarch St. 4th Flo
UMass Lowell, One Unlversl
1 29 Mt Auburn St.
401 M Street. S.W.
2200 Mill Rd.
60 Westvtew St.
1231 25th Street, NW, Roo
31 (Odder Ave.
25 St. Clair Ave. East, 7th Fl
JFK Federal Bldg. (HERCA
1 Congress Street, JFK Fed
141 Spring St.
Old Glenham Rd.
67 Cteymoss Rd.
1 Mountain Rd.
1751 Congressman WL Die
12800 MkJdtebrook Drive Su
100 Cambridge St. 20th Fto
235 Promenada St.
75 Grove St.
1350 Energy Lane
100 Cambridge St., Rm 210
2 Spring St.
100 Cambridge St., Rm 210
1220LStNW
55 Wheeler St.
919 Ala Moana Brvd.Room 2
5 Livingstone Ave.
555 Armory Arewwr
State House Station #17
79 Elm St
One Congress St.
401MSt,SW(3405R)
1 Congress St.
920 N. Washington St
1073 Whitney Avenue
1445 Ross Ave.
Cartestown Navy Yard. 100
100 Cambridge St #2109
71 Springfield St
50 Wolf Road, RM 340
135 S. 1 9th St, Suite 300
6930 Carrol Ave., Suite 600
City
Indianapolis
Ottawa, Ontario
Boston
Toronto, Ontario
Olympla
Arlington
Edison
Portsmouth
Boston
Waverty
Cambridge
Hartford
Framlngham
Edison
Boston
Lowell
Cambridge
Washington
Alexandria
Lexington
Washington
Somerville
Toronto, Ontario
Nashua
Boston
Boston
Lexington
Glenham
Brighton
Framlngham
Montgomery
Germantown
Boston
Providence
Worcester
St. Paul
Boston
Marion
Boston
Washington
Cambridge
Honolulu
Dobbs Ferry
Boston
Augusta
Hartford
Boston
Washington
Boston
Spokane
Hamden
Dallas
Boston
Boston
WWxaham
Albany
Philadelphia
TakomaPk
State
IN
Canada
MA
Canada
WA
MA
NJ
NH
MA
MA
MA
CT
MA
NJ
MA
MA
MA
DC
VA
MA
DC
MA
Canada
NH
MA
MA
MA
NY
MA
MA
AL
MD
MA
Rl
MA
MN
MA
MA
MA
DC
MA
HI
NY
MA
ME
CT
MA
DC
MA
WA
CT
TX
MA
MA
MA
NY
PA
MD
Zip
46285
K1AOH3
M4C1P5
98504-7600
02174
08837
03801-5000
02203
02179
02139
06106
01701
08837
02110
01854
02138
20460
22314
01219
20037
02144
M4T1M2
02203
02203
02173
12527
02135
0701-9322
36109
20874
01507
02908
01507
55108
02202
02738
02202
20005
02138
96813
10522
02130
04333
06106
02114
20460
02203
99201
06517
75202
02129
02202
01095-2224
12233-3510
19103
20912
Phone 1
(317) 276-1204
(819)994-4073
(617)561-5709
(416)314-3878
(206) 407-C730
(617)646-4687
(908)9064175
(207)438-3836
(617)565-9096
(617)489-3686
(617)253-0285
(203)241-0777
(508)935-1261
(908)906-6890
(617)737-3214
(508)934-3262
(617)547-7479
(703)838-1960
(617)868-4396
(202)452-4030
(617) 628-9297
(416)973-1085
(603)886-7728
(617)565-4523
(617)565-3276
(617) 860-2590
(914) 838-7238
(617)742-4340
(508) 872-8400
(205)270-5626
(301)903-1385
(508) 767-2770
(401)277-6680
(506)767-2770
(612)649-5744
(617)727-3260
(617)748-3600
(617)727-3260
(202)682-8493
(617)349-2775
(808) 586-4249
(914)674-5543
(617)524-6686
(207)287-7822
(203)424-3022
(617)565-9714
(703)235-5602
(617)565-3151
(509)326-6885
(203)498-9697
(214)667-7216
(617)241-2329
(617)727-3260
(518)457-4107
(215)567-4004
(301)891-1100
Fax
(819)953-9542
(416)314-7930
(206)407-6715
(617)646-4687
(908)321-6788
(207)438-3526
(617)565-1141
(617) 489-2482
(617)258-5042
(203)244-2017
(508)872-3420
(908)321-6788
(617) 737-3464
(508)934-3050
(617)354-5353
(703)684-5753
(617)868-4396
(202)452-5331
(617)666-1431
(416) 973-7509
(617)565-3346
(617)565-4939
(617)860-2210
(617)742-0170
(508)872-9080
(205)271-7950
(301)903-1397
(508)792-7621
(401) 277-2584
(508)792-7621
(612)649-5749
(617) 748-3827
(617)748-3962
(617)727-3827
(202)682-8031
(617) 349-2660
(808)586-7537
(914)693-0836
(617)524-3508
(207) 287-7826
(203)566-4924
(617)565-9723
(703)557-3186
(617)565-4939
(509)328-6832
(203)498-2501
(214)665-2164
(617)241-2301
(617)727-3827
(518)457-4332
(215)567-5791
(301)891-2218
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A-7
Last
vtoore-Boone
Morton
Moure-Eraso
Muestig
iAMrahif
Mufti
Murphy
Murphy
Nathan
Nelson
Meson
Newburg-Rinn
rKAMlUaf)
MlMOn
tllnhart
IWDBfl
ft*
Moonan
NowakowsM
tttrm . Ji-ilr
nfOmCK
Noyes
filifcnlaif
OMeara
O*Nel
fU-nn
Onoyan
Orum
Owens
Paksl
OM&MM*
rBwnar
Paramo Flguar
t^wabMW
rVnBi
» — • —
rVKBi
Part
Pattal
PMRMy
Pock
Pttnnty
fWMji
rontn*
n^iMiiii
i"Mi\y
rwnwn
Patten
Phbps
Pfette
rwm
Hne
Pistol
Ptuntett
Poftta
flnnlna
room
Press
Puchalsky
Qukvt
Recsr
First
Cynthia
Cheryl
Rafael
Ptflap
airiaifnntiM-
Atoert
Dfck
Jean
Robert
Tom
P«8
Leslie
Steven
A!
Brian
MariePe
Sharon
Jim
Tom
Paula
Don
f*an*m
Teresa
Kathleen
tflrtw
iMcny
Harry
Andrew
Paul
Paul
C. Roland
Kim
Larry
Victor Hug
LaDoma
Stephen
Tim
Vlnod
OwigM
Sude
jenrwer
Uhrw*
Ralph
• • — • _•
naroH
COjWn
Kkn
Erica
Jbn
uarotyn
John
Ann
Bud
Ron
Edward
MKchefl
Rich
Bowden
Gregg
Address!
Senior Staff Env. Reg. Sp
Manager, Government Rel
Associate Professor/OSH
Communly Asstance Co
A b- D^Jh iHnn /^ju^ml Hflflbl
Technical Asst
NYSDEC
R6868fCn AMCC.
Repre&entsttVB
Associate
LAI Regional Manager
Environmental Planning S
Branch Chief- TRI Inf. Mg
Environmental Engineer-
Director
National Pollutant Release
Environmental Services S
Assistant Director
P2 Project Manager
Manager- PubHe Relations
Associate Environmental
Clark University
NJDEP
Coordinator
Professor
SARA TOe III Env. Progra
Michigan Dept of Natural
CEPP
SEOESOL-lrattutoNad
Environmental Engfneer-
ConauRant
Community Media Special
Tech Metate, Inc.
Pesticides and Toxics Bra
MA Department of Environ
Work Environment Progra
\AlMtoUhvMnamnnt nhjhd
Group Environmental Spe
Cm/jnwnonhil QctenHst III
TrtMWvJjMlJMt
Bunlneas DevBtopment Sp
Senior Environmental Engl
US EPA
VK3YAN
Envhonmental Engineer
Pubic Administration Instl
Technical Assttance Good
FnukrwunMitiil ^^btnHot
SpacW Assistant
SARA TUe III Program Di
Technical Engineer
Research Coordinator
Pollution Prev. Coordinato
Research Scientist
Address2
1501 ALCOA BMg.
SOCMA
UMasa Lowell - Work Env. Pro
Office of Environmental AssMa
T^r* nf r'nuknnmAnfnl DmtmMt
US EPA Region II
Djklll rftjut n»«iM««litM«l 1 I.%M
ronuDon rrevemnn unit
Health Effects Institute
Unitarian Unrverealist Assoctatt
Hampshire Research Associate
US EPA Region 1 Library
DC Office of Emergency Ptennl
US EPA Office of Pollution Pre
US EPA Region IV
Ministry of Environment & Ener
Environment Canada
DuPont Company
IN Pollution Prevention Inst.
WIDNR
Nowlck Environmental Assodat
ASARCO
INFORM
Hoffmann La Roche
Bureau of Hazardous Substanc
Working Group on Community
Dept. of CM Engineering
VA Dept of Env. Quality
EPA Region 4
Direccton General de NatMdad
Cytec Industries
S A Parker ft Associates
Center for Farrfy. Work, 4 Co
U.S. EPA Region I
Bureau of Waste Prevention
rOrWnoUUi rwmu oulpyttfu
MS Deal Env Quafitu* Office o
US EPA Region III
Naoonai i ecruitcai inromwuon
Antoco Corporation
uo crA Kegnn i
3200 CEBA BMg
MEDEP
US EPA f AARPl
Waste Watch Center
AL Dept Env. Mgmt
E. I. DuPont (P2)
Unison Institute (RTK NET)
Grand Cakiment Task Force
NYS Dept of Health
Street
42SethAve.
1330 Connecticut Ave, N.W.
One University Ave.
1350 Energy Lane
TO Pkn Cf
2890 Woodbrkkje Ave. (MS
50 Wolf Road
141 Portland St. Suite 7300
188 Morris Ave.
1600 Cameron St. #100
JFK Federal Bldg.
2UUU 1 4ui oL NVV, am rtOdt
401 M Street, SW
345CourtiandSt,NE
250 Davtovne Ave., 3rd Floo
351 St Joseph Blvd., 10th F
1007 Market Si
1291 Cumberland Ave.
101 S.Webster
P.O. Box 1770
180 Maiden Lane
920 WaB St
340 Nngstand St
60X2120
TMLKJr Or #139
25CartgateRd.
401 E. State Street CN 405
2180 Street SE
University of New Hampshlr
P.O. Box 10009
P.O. Box 30457
345CourUandSt
Rio Elba No. 20 -ler.Pteo
10800 River Rd.
2009 Trent Park PI.
UMassLowel
PO Box 1266
One Congress Street, JFK F
1 Winter Street
A1 UV/InHaw Oft
AHazenDrivB
PO Box 10385
841 Chestnut Bldg
580 Westtake Park Blvd.
401M.St,SW(MC7408)
5203 Leesburg Pike
teif PoHaral RMn
Louisiana State University
State House Station 17
SOWestvtawSt
16HaverhMSt
1751 Cong. W. L Dickinson
Chambers Workds, Route 1
1742 Connecticut Ave., NW
2400 New York Ave.
BTSA 2 University PI.
City
Pittsburgh
1*1,-^^-^.— i-.—
wasrungion
Lowell
StPaul
Ul-jtf.ULl
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MA
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NH
VA
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GA
Mexico
LA
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MA
OH
MA
MA
UA
NH
uu
MS
PA
I/A
TX
DC
VA
MA
LA
ME
MA
MA
AL
NJ
DC
IN
NY
Zip
15146
20036
01854
55108
rvMmt
08837
122334010
02139
22314
02203
^UOUa
20480
30365
K1AOH3
19898
47906
53707
01101-1770
10038
10005-4001
07110
01610
30341
02760
08625-0405
20003
03824
23240
48909-7957
30365
06500 Mexfc
70094
37084
01854
45401
02203
02108
AO4CC
03301
nooftji c/w\
39289-0385
19107
994 f\ C£c; on£C
(504)388-1075
(207)287-7681
(617)660-4396
(506)470-3044
(205)260-2717
(609)5404330
(202)797-7200
(219)473-4246
(508)4584373
Fax
(412)553-4822
(202)659-1699
(508)4524711
(612)6494749
/«yV9l EOAft+AA
(908)3214788
(518) 457-2570
(617)6214267
(703)684-7704
(617)5654067
(202) DfS-ZcaU
(202)260^655
(404)347-1681
(416) 440-7039
(819)9534542
(802)7744110
(317)4944422
(608)2674560
(212)510-1835
(2121 361-2412
(201)235-7930
f 404) 657-7891
(609) 633-7031
(202)546-2461
(603)862-2304
(804)762-4453
(517)335-4729
(404)347-1681
(525)2864371
008)9344026
(617)565-4939
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jjimji. ^«M ««4«A
(2070438-2430
ffi011&61-£37R
(215)5974156
(fUO) ^Of-^lO4
(713)3667556
(202)260-2219
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(508)470-3384
(205)2728131
(609)540-2991
(202)2344584
(219)473^288
(518) 4584372
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A- 8
Last
Relbstein
Reid
leffly
Neuter
Rhodes
Rhymer
Richard
Robbins
Rondeau
Rossi
Rougvto
Round
Rowe
Roy
Russakow
Rutherford
Sachdev
Safl
SaJamone
Satetnlk
Sams
Sanchez
Sapenter
Savbman
Schaefer
Scott
Secor
Setters
Servkflo
Settles
Shahazz
^INUJWeb
Shaknis
Shannon
Shapiro
Shaughnessey
ShavsMon
Shea
Shea
Shearer
Shepherd
Sheruda
Shfpps
Slegel
O^MUbl
SRka
SBva
Skokan
Smith
Smth
SmRh
SmRh
SmRh
SmRh
SmRh
Snyder
Sokaris
Spetaer
First
Rick
Fred
Barbara
*OV8
Alex
Karen
Ruth
Paul
Ron
Karen
Gina
Carol
Margaret
Laura
Natalie
Stefan
Barbara
Amtt
M. Hashlm
Lee
Jim
2huck
Karen
ARNOLD
Ann
Russell
Jeffrey
Beth
Doug
Lucy
Trish
MHcal
VHIUU
Khnberiey
Becky
Karen
Joan
Robert
John
Michael
David
Susan
Mary
John
Gary
Jodie
v^AM?
Unda
Mike
Elfie
Arming
Bruce
Lee Arm
Maureen
Paula
Rebecca
Stephanie
PhUp
Jerry
Shariene
Address!
Asst Director
Rl Program Asst.
US EPA
JO r Ht)i| | y i|| M >|ll nl ^fMaf>lllll
tL bllVH WHimilCII wDwdCUI
Compliance Inspector
cnvnonmonuH engineer
SARA- Environmental Sp
Team Leader
cnvironmenuu oompwnc
Project Engineer, Technte
Environmental Engineer
Consultant
NESCAUM
Planning Coordinator
Executive Director
f* £nuimnmftfttal Unntlh C
*. envuonmeniBi neann o
Toxics Coordinator
Counsel
National Council of Senior
Manager
Rl Department of Environ
P2 Coordinator
Montana P2 Coordinator
DIRECTOR OF PROGR
Research Associate, Env.
Fleet Manager
PoButton Prevention Unit (
Project Engineer
Chief, TRI Data Admlnlstr
Senior Environmental Sde
environmental urgaruzer
TRI I™ IllflMlf ll f^nf\fMnatf\f
Madsen Marketing Strateg
Pollution Prov. Coordin&to
Associate Scientist
Associate
Executive Director
Assistant Director
Manager, State Federation
Senior Environmental Sde
Labor Educator
P2 Coordinator
PtBskfent
Vice President Englneerin
Director
Senior Environmental Engl
Dept of Biological Sdenc
U.S. EPA
GIS Section Supervisor
TRI Coordinator
TRI Coordinator
Info, M0tfiL SpocraBst
PubBc Health EpWemtotog
Sr. Staff Regulatory Sped
Corp. Ind. Hyglenist
Comptonce Officer
Address2
OTA/EOEA
U.S. EPA Region VIII
Office of Enforcement and Co
jccKwntfll Cnomicol Corp*
US EPA Region VIII
AT&Tnb2209100
El LHIy& Company
MA Office of Technical Assista
US Postal Service NE Area Offi
MA Water Resources Authority
Westover Air Reserve Base
JSI Center for Env. Health Stud
MADEP
National P2 Roundtabte
NDDH
WWF for Nature Intl., c/o WW
Chemical Manufacturers' Asso
US EPA Region 4
Chemical Manufacturers Assoc
Dfflce of Environmental Coord!
Foreyth Co. Env. Affaire Dept
Montana State Univ. Ext. Servte
MADEP
Natt. Assoc. of Health Officials
US Postal Service
AZ Dept. of Env. Qualy
Rlzzo Associates, Inc.
US EPA/OPPT
Capacdo Environmental Engln
Dudley Street Neighborhood Inl
1 1 C CPA Ranlnn III
U.w. Crn r«UyiUf1 III
MO Dept of Natural Resources
Tellus Institute
The Cadmus Group
Atlantic States Legal Foundatto
Office of Env. Health, Dept of
Chemical Manufacturers Assoc
Aerovlronment, Inc.
Mass COSH
CT Dept of Environmental Prat
Shlpps, Inc.
Goldman Env. Consulting
Tnvtai 1 tea Rarfirtbin Inslihihi
1 UBUwO UoO I\^U^^IWI III lOtnUlw
Center for Family, Work & Com
BDM
Campus Box 26
OPTS/ETD
VK3YAN, Inc.
Dept of Environment and Natur
IDEM, Office of P2 and Tech.
EPA Region 9
Office of Public Health
Shell Oil
Albany Intl.
US EPA Region 1
Street
100 Cambridge St.
999 18th Street, Sutte 500
401 M Street, SW(2245A)
W\ Dalnhnu/ Rturt
vOU rxeuniWW Dnru.
999 18th Street, Sutte 500
1600 Osgood St.
P.O. Box685TL15
100 Cambridge St., Suite 21
Chariestown Navy Yard, 100
250 Patriot Ave Sutte 1
210 Lincoln St
129 Portland St.
1 Winter St., 4th Floor
210DSt.,SE
P.O. Box 145, 182 S. Main
90EglintonAve.,E. Suite 50
2501 M Street NW
345 Courttand St
2501 M St, NW
83 Park Street
537 N. Spruce St
Taylor Hall
1 WINTER ST., 4TH FLOO
4401 1 st St., NW Suite 500
171 KennebecSt.
3033 N. Central Avenue
235 W. Central St
401 M Street, SW,(MC 740
40 75 Union Ave.
513 Dudley St
tlA.4 f* *"***itii if DL4/1
31 Wdder Ave.
P.O. Box 176
11 Arlington St
135 Beaver St
658 West OnondagaSt
1010 Mass. Ave., 2nd Floor
2501MSt,NW
222 E. HunUngton Dr.
SSSAmorySt.
TOEImSt
21 University Rd.
15PacellaParttDr.
IJMflfts 1 MAM(| 1 UnhMfffittv
UIVWO9 LJv¥WII| 1 WIHVdVHy
UMass Lowell
1133 North Main Street
Wichita State University
401 M Street, SW
5203 Leesburg Pike, Sutte 9
523 East Capitol
27811 Hawthorne Blvd.
P.O. Box 6075
75 Hawthorne St, MC H-2 1
234 Loyola Ave., Sutte 620
P.O. Box 9320
P.O. Box 1907
Office of Enforcement, (4EO
City
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uufvm
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»m ,11 -_ _,,, ii «•
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CO
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MV
n T
CO
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IN
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MT
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ME
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m
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MA
DC
CA
MA
CT
MA
MA
MA
MA
UT
KS
DC
VA
SD
CA
IN
CA
LA
TX
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Zip
02202
80202
20460
80202
01938
47905
02202
06006-7030
02129
01022
02111
02114
02108
20003
06234
M4P2Z4
20037
30365
20037
02903
27103
597174312
02108-
20001
04101
85012
01760
20460
01776
02119
19107
191 wf
02144
65102
02116
02154
13203
02118
20037
91017
02130
06106
02021
02368
01854
01854
84041
672604026
20460
22041
57501
90275
462064015
94105
70119
77210
12201
02203
Phone 1
(617)7274260
(303)293-1749
(202)564-4176
/71KI TflA^VSTlR
^f IWJ AOWNW\AJ
(303)294-7460
(512)8914970
(317)477-4210
(617)7274260
(203)285-7197
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(413)557-2464
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(617) 4424670
?21 51 597-3659
^A 1 wj wOf ^^M«O
(617)6284297
(314)5264627
(617)266-5400
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(315)475-1170
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(202)887-1265
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Fax
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(314) 526-5808
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(415)744-1044
(504)568-7035
(713)241-2494
(518)4474308
(617)565-4939
-------
Friday, March 10,1995
1994 TRI Conference Registrants
Page A-9
Last
Spiegel
St. Charte*
Stansbury
Stekmn
Stelnauer
Stetagraber
QtanhMiBfln
wW|JI Id HNM 1
StoecMe
Strattopouloe
Straub
Stroup
SuBvan
Szudy
Taddeo
Taylor
Taylor
Taylor
Tebbutt
ThM
Thin*
Tnom&s
Thomas
Thomas
Hckner
^n— ^i jlrin
1 llnDenine
Tlnney
Tipton
Tirpak
TnniHanwirlr-r
omsszewicz
Tomlyanovfch
Topper
Torres-Leon
Towns
Travere
Teal
Tschang
Tseng
Tucker
Twtektor
Van
Vatente
Valis
Vetrand
Wales
Wallace
Wallace
Wallace
Walsh
Warren
Weinstein
Wennerberg
Wesseto
West
Wheeler
White
Whtttemore
Wlgmore
WHcox
First
Gary
Edward
Bemto
Howard
John
Sandra
Karen
Andrew
DbnRri
Alton
Dorothy
Jim
Betty
Uz
Ann
Jan
Wesley
Charlie
Dbrme
Steven
Dave
John
Karen
Joel
HauM
uaviQ
Jarnes
Jerry
Chris
Don
Steve
Hank
Genaro
Brian
Unda
Pam
Ted
Tom
Connie
Donna
Janet
Maria
Edwin
Bill
Curtis
Arthur
Len
Yvonne
William
Mike
Warren
Unda
Joseph
Madeflne
Andrew
Jerald
Ray
Dorothy
Meg
Addressl
Vice President
Fadtttes Manager
Deputy cnvironinenuf u»
Senior Environmental Engi
EPCRA Coordinator
Biologist & Author
Senior Analyst
Research Assistant
NOAA Sea Grant Fellow
TRI File Manager
environmental opectaiist
c/bLOHP
Assistant P2 Coordinator
Analyst
Ph.D.
Wisconsin Department of
Western Environmental L
Federal Faculties Coordin
Manager. CERCLA Site A
Illinois Haz Waste Resear
Associate Professor
MA Toxics Use Reduction
Policy Analyst
rtiitratt/»h f^/wrilnaffnr
UUuBBCn l/QOlUin&lDr
PA Dpmt of Labor and In
Environmental Safety Man
Acting Director 33/50 Pro
Process Associate
MN Emergency Response
U.S. EPA
Director- Emergency Res
Galiteo Electro Optics. Inc
Division Director
TRI Program Manager
Research Assistant
Senior Advisor
Executive Director
Environmental Engineer
Research Associate
Physician for Social Resp
Staff Scientist
Environmental Coordinator
Environmental Engineer
Manager. Env. Audits
U.S. EPA Regional Labor
Librarian
Vice President
MUtary Exchange Officer
P2 Policy Analyst
EBS
Senior Planner
Project Assistant
U.S. EPA
Community Liaison Direct
Regional Mgr
Center for Family, Work &
MA Dept. of Public Health
Address2
Goldman Environmental Cons.
Accurate Metal Finishing. Inc.
US Army
Boson Edison Co.
Nebraska DEQ
Women's Community Cancer P
World Wildlife Fund
AbtAssoc.
MPT 1 ouj 9. PiujfiuuiiHuijLl BBWUIIUI
MI i Law & environment rrogra
Great Lakes Task Force
National Library of Medicine
EP Lilly & Company
MD Dept of the Environment
United States Trust Company
National Institute for Chemical
Office of Technical Services
US EPA Region 8
UT Division of Env. Response
Texas A&M University
U. Mass. Lowell
National Environmental Law Ce
\IA npn
vn ucw
Bureau of Right to Know
US Coast Guard
US EPA
E.I. DuPont
B-5 State Capitol BkJg.
OPPT/EAD
Pu6fto Rico Environmental Qus
US EPA
U.S EPA Region 9
Harvard University
Environment Canada
Southern Organizing CommRte
US EPA
Grand Valley State University
Wehran/EMCON Northeast
US Army Research Lab
Motorola, Inc.
EG & G. Inc.
JSI Center for Env. Health Stud
VGA Nozzle Co.
US EPA
National P2 Roundtabte
Delaware Emergency MgmL
Versar, Inc.
OPPT/IMD
Sierra Club Legal Defense Fun
NCASI
UMass Lowell
Street
15PacellaParkDr.
41 4 South Street
800 Boyteton St
Po Box 98922, Suite 400 the
56 Walnut St #6
1250 24th St, NW
55 Wheeler St.
1 AmheretSt
503 Hart Senate Office Bkkj
8600 Rockville Pike
Lilly Corporate Center
251 5 Charming Way
2500 Broenlng Highway
40 Court St. 7th Floor
2300 MacCorkte Ave SE
P.O. Box 7921. 101 South
44 West Broadway, Suite 20
9991 8th St. Suite 500
168 North 1950 West
1 East Hazekrood Drive
Dept. of Rural Sociology
One University Ave
29 Temple PI.
PO R/winnnQ
rw DVA HAJVRJ
Labor and Industry BkJg. Rm
259 High Street
401MSt.SW(MC7408)
Cheesquake Rd.
75 Constitution Ave.
401 M Street, SW, MC 7408
P.O. Box 11488
P.O. Box 550
401 M. Street, S.W. - (MC 7
75 Hawthorne Street
CSIA.79JFKSt
25 St. Ctelr Avenue East, 7t
P.O. Box 10518
77 W.Jackson Blvd.
1 04 Water Resources Inst
11 Garden St
6 Riverside Dr.. Suite 101
AMSRL-of-RT, 405 Arsenal
6501 William Cannon Dr..
45 William St
60 West View St
210 Lincoln St.
250 No. Bay St.
JFK Federal BkJg. (PAS)
218DSt,SE
347 Centre Street
P.O. Box 527
9200 Rumsey Rd.
401 M. Street S.W. (7407)
400 Magazine St, Suite 401
Tufts University 001 Ander
1 University Ave.
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City
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02368
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25304
53707
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84114
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77843-2125
01854
02111
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17120
04106
20460
08859
55155
20460
00910
01566
20460
94105
02138
M4T1M2
10518
60604
49401
02138
01810
02172
78735
02181
02173
02111
03104
02203
20003
02122-1127
19706
21045-1934
20460
70130
02155
01854
02111
Phone 1
(617)961-1200
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Friday, March 1 0, 1 995 1 994 TRi Conference Registrants Page A- 1 0
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Wfitari
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Dam
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Maureen
Richard
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Paul
Sandra
David
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Man
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Glenn
Addressl
TRI Coordinator
Environmental Engineer
P2 Coordinator
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Manager, Product Stewar
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Manager. Waste and P2
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Director
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Address2
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Chemical Manufacturers Assoc
Office of Pollution Prevention &
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The Dow Chemical Company
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Hazardous Health Wkrs. Train!
Office of Pollution Prevention a
US EPA Region II
US Navy
Street
JFK Federal Bldg.
2500 Broenlng Highway
GM Bldg. 9-261. 30400 W.
75 Hawthorne St.
304 Cornwall Dr.
611 South Ivy Street
2501 M St., NW
1850 KSt.NW #1000
129 Hampton Rd.
401 M Street, SW
1200 6th Avenue
2501 M St., NW
401 M St. SW
7325 Palmetto SL Bos45b
2030 Dow Center
113 East Grand Ave.
386MetacomAve.
Kttson 200. UMass Lowefl, 1
P.O. Box 13087
2890 Woodbridge Ave., Bid
Naval Air Station. Code O1 E
City
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02206
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78711-3087
08837
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Phone 1
(617)565-3265
(410)631-3800
(313)556-7607
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•U.S. GOVERNMENT PRINTING OFFICE: 1995-397-379/30891
ISBN 0-16-048184-8
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