L'-'fTp"* S??!A<.        <;''->» .'
           Environmental Protection    and Toxics
           Agency          Washington. DC 20460      EPA 745-R-93-002
&EPA     Assessment of
           Changes in Reported
           TRI Releases and
           Transfers Between
           1989 and 1990
                                  Printed on Recycled Paper

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EPA Contract Number                            RTI Project Number
CR818760-01 -0                                  233U-5126-2 FR
   Assessment of Changes in Reported
   TRI Releases and Transfers Between
                  1989 and 1990

                     Final Report
                        May 1993
                        Prepared for

                        Jim Craig
                      Eun-Sook Goidel
                U.S. Environmental Protection Agency'
               Office of Pollution Prevention and Toxics
                   Pollution Prevention Division
                       401 M St. S.W.
                    Washington, DC 20460
                        Prepared by

                       Gwen J. Riley
                      John L. Warren
                      Rachel D. Baker
                  Center for Economics Research
                   Research Triangle Institute
                Research Triangle Park, NC 27709

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                                       CONTENTS

Chapter                                                                       Page


   Acknowledgments	vii

   1    Introduction	1-1

        1.1   Objectives	1-2

        1.2   Study Overview	1-3

        1.3   Report Overview	1-3

   2    Pilot Study Methodology and Results: Reasons for Changes in TRI
        Submissions, 1987 -1988	2-1

        2.1   Pilot Study Methodology	2-1

        2.2   Pilot Study Results	2-1

        2.3   Pilot Study Conclusions	2-2

        2.4   Implications for Main Study	2-5

   3    Main Study Methodology	3-1

        3.1   Sample Plan	3-1
              3.1.1   Study Population	3-1
              3.1.2   Sample Allocation	3-3

        3.2   Data Collection Procedures	3-4

        3.3   Application of Weights	3-5
              3.3.1   Weighting Design	3-5
              3.3.2   Adjustment to Weights	3-7
              3.3.3   Precision of Weighted Estimates	3-8
                                          111
                                                                               /RTI

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                                 CONTENTS (continued)

Chapter                                                                       Page


   4    Main Study Results:  Reasons for Changes in TRI Submissions,
        1989-1990	4-1

        4.1   Summary Data: National Estimates	4-1
             4.1.1   Frequency Estimates	4-1
             4.1.2   Quantity Estimates	4-2
        4.2   Summary Data: Industry Estimates	4-4
             4.2.1   Frequency Estimates	4-5
             4.2.2   Quantity Estimates	4-5
        4.3   Analysis of Results, by Reason	4-8
             4.3.1   Measurement Change	4-8
             4.3.2   Production Change	4-9
             4.3.3   Source Reduction	4-12
             4.3.4   Other Factors	4-14
        4.4   Analysis of Results, by Size Strata	4-17
             4.4.1   Largest Increase/Decrease Strata	4-17
             4.4.2   Population Estimates with Largest Increase/Decrease Strata
                     Removed	4-20

   5    Conclusions	5-1

        5.1   Summary of Results	5-1

        5.2   Recommendations for Future Research	5-2


   Appendix A: Mail-Out Materials
   Appendix B: Interview Script
   Appendix C: 1989 Form R
   Appendix D: 1990 Form R
/RTI
IV

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                                          FIGURES


Number                                                                         Page

                                                        «
    1-1    Factors Causing Changes in TRI Data Submissions	1-2

    4-1    Net Quantity Change in TRI Submissions, by Reason	4-3

    4-2    Net Quantity Change as a Percent of 1989 Releases and Transfers	4-4

    4-3    Aggregating Increases and Decreases in TRI Submissions, by Reason	4-5

    4-4    Percentage of Facilities Indicating Measurement Change, by Industry	4-9

    4-5    Quantity Change Attributed to Measurement Change, by Industry	4-10

    4-6    Percentage of Facilities Indicating Production Change, by Industry	4-11

    4-7    Quantity Change Attributed to Production Change, by Industry	4-11

    4-8    Percentage of Facilities Indicating Source Reduction, by Industry	4-13

    4-9    Quantity Change Attributed to Source Reduction, by Industry	4-14



                                          TABLES


Number             .                                                            Page


    2-1    Pilot Study:  Reasons for Decreases Reported in TRI	2-3

    2-2    Pilot Study:  Reasons for Increases Reported in TRI	2-4

    2-3    Pilot Study:  Summary of Results	2-5

    3-1    Study Population and Representation  of TRI Universe	3-2

    3-2    Distribution of Facilities into Strata for Study Sample of 1,206 Facilities	3-3

    3-3    Distribution of Facilities into Strata for Study Population of 18,951
          Facilities	3-6

    3-4    Response Rate: Percentage of Facilities Sampled that Volunteered to
          Participate	3-9
                                                                                 /RTI

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                                  ,  TABLES (continued)


Number                                                                        Page

                                                       /
   4-1    Number and Percentage of Facilities and Form Rs Indicating Each Reason
          for Change	4-2

   4-2    Percentage of Facilities Indicating Each Reason for Change, by Industry	4-6

   4-3    Percentage of Form Rs by Reason for Change, by Industry	4-6

   4-4    Population Estimates: Net Quantity Change Attributed to Each Reason,
          by Industry	4-7

   4-5    Population Estimates: Quantity Increase Attributed to Each Reason, by
          Industry	4-7

   4-6    Population Estimates: Quantity Decrease Attributed to Each Reason, by
          Industry	4-8

   4-7    Percentage of Facilities Implementing Each Type of Source Reduction, by
          Industry	4-13

   4-8    Other Factors Contributing to the Change in 1989-1990 TRI Submissions	4-15

   4-9    Percentage of Form Rs with Change Quantified, by Industry	4-16

   4-10   Largest Increases/Decreases Strata:  Net Quantity Change Attributed to
          Each Reason, by Industry	4-18

   4-11   Largest Increases/Decreases Strata:  Quantity Increase Attributed to Each
          Reason, by Industry	4-18

   4-12   Largest Increases/Decreases Strata:  Quantity Decrease Attributed to Each
          Reason, by Industry	4-19

   4-13   Population Estimates with the Largest Increase/Decrease Strata Removed:
          Net Quantity Change Attributed to Each Reason, by Industry	4-20

   4-14   Population Estimates with the Largest Increase/Decrease Strata Removed:
          Quantity Increase Attributed to Each Reason, by Industry	4-21

   4-15   Population Estimates with the Largest Increase/Decrease Strata Removed:
          Quantity Decrease Attributed to Each Reason, by Industry	..4-22
/RTI
                                          VI

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                               ACKNOWLEDGMENTS

       The authors would like to acknowledge all those individuals who assisted with the
research and preparation of this report, including the TRI facilities that volunteered to participate
in this study. We would especially like to thank Eun-Sook Go'idel and Jim Craig of EPA's
Office of Pollution Prevention and Toxics for their guidance over the course of this study. We
also appreciate the dedicated editorial and clerical support of the Publications Support Group of
Research Triangle Institute's Center for Economics Research, including Maria Bachteal, Sharon
Barrell, Andrew Jessup, and Judy Parsons.
                                          vu
                                                                                /RTi

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                                     CHAPTER 1
                                  INTRODUCTION

       The U.S. Environmental Protection Agency (EPA) collects data for the Toxics Release
Inventory (TRI) annually pursuant to Section 313 of the Emergency Planning and Community
Right-to-Know Act of 1986 (EPCRA). TRI includes data on the types and quantities of toxic
chemicals released to all environmental media by manufacturing facilities within the United
States. TRI data submissions have been completed for 1987,1988,1989, and 1990. These data
provide EPA an opportunity to examine the behavior of firms over time as they modify their
practices to reduce releases of TRI chemicals.1

       Over the past four years the quantity reported in TRI submissions has decreased annually.
At the same time, the number of facilities reporting releases has increased annually. These
trends suggest that facilities are successfully reducing the physical quantity of toxic chemicals
entering the environment. However, prior to 1991, TRI did not include sufficient information on
the reasons for changes in releases and transfers for EPA to make  such a conclusion.

       Many  factors contribute to changes in TRI submissions, and they can be categorized as
"real" changes and "paper" changes. Changes in production levels or product lines as well as
materials substitution, procedure modifications, improved management, and other source
reduction activities are considered real changes in chemical releases. Changes in measurement
or estimation methods and changes in reporting requirements, or a firm's understanding of
reporting requirements, are referred to as paper changes because they affect TRI submissions
without physically reducing the quantity of chemicals released. Figure 1-1 illustrates examples
of the types of real and paper changes affecting TRI submissions.

       Research Triangle Institute (RTI), under a Cooperative Research Agreement with the  .
EPA, conducted this study to assess the comparative impact of real versus paper changes on TRI
submissions.  In particular,  the study focuses on the extent to which three factors—changes in
measurement  techniques, production fluctuations, and source reduction activities—affect
changes in reported TRI releases.

       In addition, the results of this study will be used to develop a methodology for assessing
changes over time using the source reduction and recycling data that will become available with
'For the purposes of this report, the terms "submissions" and "releases" are both intended to mean the quantity of
  releases and transfers reported in TRI.

                                          1-1

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     Production Change
      Source Reduction
       Other Reasons
    Measurement Change
    Change in Reporting
       Requirements
       Other Reasons
 "Real*
Changes
                                                                       Change
                                                                      Reported
                                                                        inTRI
"Paper"
Changes
          Figure 1-1. Factors Causing Changes in TRI Data Submissions


the 1991 reporting year. This methodology will help EPA evaluate changes in TRI submissions
annually. Study over time is critical to developing a comprehensive understanding of the effects
of source reduction activities. Many factors can cause releases to vary within and between years,

and the effects of many source reduction projects may not be evident for several years or may

have a cumulative effect that requires time to affect total releases.


1.1   OBJECTIVES

      This study had the following objectives:

      • to understand the factors affecting the change in the quantity of chemicals released and
        transferred, as reported in TRI;

      • to determine the relative effect of each of the following on the overall change:
        measurement techniques, production level, and source reduction;
                                         1-2

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         to estimate the real change in the quantity of toxic chemicals released and transferred
         by selected industries and nationwide; and
         to estimate the quantity of pollution prevention progress achieved by selected industries
         and nationwide.
1.2    STUDY OVERVIEW
       This study was conducted in two phases:
       • Phase I:  pilot study
       • Phase II: main study
       The Phase I pilot study examined reasons for changes in TRI releases between 1987 and
1988. For this study, the 50 facilities with the largest increases and the 50 facilities with the
largest decreases in toxic chemicals released between 1987 and 1988 were contacted by
telephone. Participating facilities were asked to explain differences in their 1987 and 1988 TRI
data as a means of better understanding the factors that affect the data.  No statistical sample was
employed for the Phase I study; therefore, the results cannot be used to make national estimates
of changes in releases. Nonetheless, the results indicate the factors affecting TRI data.  Also, the
results provided information used to develop the procedures for Phase n of this study.

       Phase II was a full study of reasons for changes in TRI data between 1989 and 1990.
Statistical sampling techniques were used to select facilities to be studied. The facilities selected
were asked to explain their changes in measurement techniques, production level, or source
reduction activities that contributed to a change in the quantity of TRI chemicals released or
transferred. The results of this review were used to estimate the change in the quantity of TRI
chemicals released or transferred at both industry and national levels.

1.3    REPORT OVERVIEW
       This report provides estimates of the reasons for changes in TRI submissions and the
methods used to develop these estimates.  Chapter 2 describes the results of the Phase I pilot
study and discusses the implications of Phase I on the design of Phase II. Chapter 3 discusses the
procedures used in Phase n, and Chapter 4 presents the results of Phase n. Highlights of these
results along with recommendations for future studies conclude the report in Chapter 5.
                                           1-3

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                                     CHAPTER!
    PILOT STUDY METHODOLOGY AND RESULTS: REASONS FOR CHANGES
                          IN TRI SUBMISSIONS, 1987 -1988

       A pilot study was conducted to determine the factors causing changes in reported data
between 1987 and 1988.  Facilities with the greatest changes (both increases and decreases) in
TRI releases and transfers were contacted to determine the reasons for these changes, including
the portion of change that was attributed to source reduction activities. This chapter describes
the methodology and results of the pilot study.

2.1    PILOT STUDY METHODOLOGY
       A subset of facilities submitting TRI data in 1988 were identified for analysis based on
the magnitude of each facility's change in the total quantity of toxic chemicals released and
transferred between 1987 and 1988.  Specifically, the study included the 50 facilities with the
largest total increases in the quantity released and transferred and the 50 facilities with the largest
total decreases in the quantity released and transferred. Facility representatives were contacted
by telephone and asked to identify the changes in their operating or reporting procedures
responsible for the changes in data submitted for TRI.

2.2    PILOT STUDY RESULTS
       Over 80 percent of the facilities contacted volunteered to participate. Specifically, out of
the 50 facilities contacted in each category, respondents included 45 facilities reporting decreases
and 36 facilities reporting increases. Although these facilities represent only 0.5 percent
of facilities that submitted Form Rs in 1988, the total change in the quantity of releases for the
facilities studied accounts for 44 percent of the total change in the quantity reported for TRI.

       The explanations for changes have been divided into three categories:
       • No Real Change:  indicates that the change was a reporting change and that the real
        quantity of chemicals released did not change.  Examples of changes under this
        category include changes in measurement or estimation techniques, changes in the
        interpretation of reporting requirements, data entry errors, and calculation errors.
       • Source Reduction: indicates that the quantity of chemicals released actually did change
        and that the change can be attributed entirely to source reduction activities or the
        change can be attributed in large part to source reduction and the portion due to other
        reasons could not be estimated and distributed accordingly.
                                          2-1                                    /RTI

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       • Other Real Change: indicates that the quantity of chemicals released actually did
         change and that the change was not attributed, in whole or in large part, to source
         reduction activities.  Examples of changes under this category include product changes,
         production fluctuations, and recycling.

       If a facility claimed its change falls under more than one category yet emphasized one of
the categories, its response was placed in that category. Thus, a portion of the quantity change
listed under each category may actually be due to a combination of reasons.

       Under each of the three categories, responses have been tabulated by the specific
explanations for change.  Tables 2-1 and 2-2 show these results separately for the increase and
decrease facilities. For each explanation, the tables show the number of facilities providing that
explanation, the total change due to that reason, the average change per facility, and the
percentage of the total quantity of increase or decrease for the facilities studied that was
attributed to that reason. Table 2-3 presents a summary of results.

2.3    PILOT STUDY CONCLUSIONS
       One objective of this pilot study was to draw conclusions about source reduction
progress. The results show that roughly 20 percent of the net change accounted for in the pilot
study was attributed to source reduction activities.  However, only  7 percent of the  total quantity
decrease was attributed to source reduction.  These figures include changes attributed to reasons
other than source reduction for which we were unable to determine the portion of the change due
to source reduction alone.

       The most common reasons given for changes in data reported for TRI were changes in
reporting or measuring procedures. Such changes do not represent actual changes in the quantity
of toxic chemicals released into the environment. Over 60 percent of the decreases studied and
54 percent of the increases studied were attributed to some type of "paper" change.

       One measure commonly used to assess source reduction progress is the "adjusted
measure," which adjusts changes in the quantity released for changes in production activity. This
methodology assumes that the quantity released is directly related to the quantity of production
activity. Facilities responding to this study attributed 6 percent of the decrease and 25 percent of
the increase to changes in production activity.

       This study demonstrates that a wide variety of factors affect the quantity of releases
reported in  TRI and that a small portion of the reported change in data can be attributed to source
reduction progress.

/RTI                                      2-2

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               Table 2-1. Pilot Study: Reasons for Decreases Reported in TRI


Reason for Change
No Real Change
Data entry error
Change in interpretation of
reporting requirements
Improved estimate
Estimate error/variation
Calculation error
Combined reasons, no real
change
Subtotal
Source Reduction
Combined reasons,
pollution prevention
Pollution prevention
Subtotal
Other Real Change
Recycling
Change in production level
Combined reasons, other
real change
Weather change
One-time event
Change in treatment
Subtotal
Total All Reasons
Number
of
Facilities

6
7

8
1
3
1

b

5

2
b

7
4
4

1
3
2
b
b
Total
Decrease
(106 Ibs)

-127.1
-75.6

-53.6
-37.0
-14.9
-2.8

-311.0

-21.3

-16.9
-38.2

-62.3
-32.4
-27.4

-20.8
-17.6
-3.9
-164.4
-513.6
Average
Decrease
(106 Ibs)

-21.2
-10.8

-6.7
-37.0
-5.0
-2.8

b

-4.3

-8.5
b

-8.9
-8.1
-6.9

-20.8
-5.9
-2.0
b
b
Percentage
of Total
Decrease8

24.7%
14.7%

10.4%
7.2%
2.9%
0.5%

60.6%

4.1%

3.3%
7.4%

12.1%
6.3%
5.3%

4.1%
3.4%
0.8%
32.0%
100.0%
a  Percentage of the total decrease for the facilities studied that is explained by the reason indicated.
b  Because a single facility may have provided more than one explanation, the number of facilities cannot be
   summed.
                                                2-3

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                Table 2-2.  Pilot Study:  Reasons for Increases Reported in TRI


Reason for Change
No Real Change
Data entry error
Improved estimate
Change in interpretation of
reporting requirements
Estimate error/variation
Calculation error
Subtotal
Source Reduction
none
Subtotal
Other Real Change
Change in production level
Change in recycling
Change in operating
conditions
Change in product/product
mix
Combined reasons, other
real change
Change in treatment
Subtotal
Total All Reasons
Number
of
Facilities

7
5
6

4
1
b

0
0

13
1
2

2

1

1
b
b
Total
Increase
(106 Ibs)

65.3
47.7
35.0

26.0
2.3
176.3

0
0.0

82.1
24.7
18.5

12.9

7.7

2.9
148.8
325.1
Average
Increase
(10* Ibs)

9.3
9.5
5.8

6.5
2.3
b

0
0

6.3
24.7
9.3

6.5

7.7

2.9
b
b
Percentage
of Total
Increase8

20.1%
14.7%
10.8%

8.0%
0.7%
54.2%

0.0%
0.0%

25.3%
7.6%
5.7%

4.0%

2.4%

0.9%
45.8%
100.0%
a  Percentage of the total decrease for the facilities studied that is explained by the reason indicated.
b  Because a single facility may have provided more than one explanation, the number of facilities cannot be
   summed.
                                                2-4

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                        Table 2-3.  Pilot Study:  Summary of Results

Decreases
No real change
Source reduction and combined source
reduction
Other real change
Total for those facilities contacted
Increases
No real change
Source reduction and combined source
reduction
Other real change
Total for those facilities contacted
Net Change
No real change
Source reduction and combined source
reduction
Other real change
Total for those facilities contacted
Total Change
(106 Ibs)

-311.0
-38.2
-164.4
-513.6

176.3
0.0
148.8
325.1

-134.7
-38.2
-15.6
-188.5
Percentage of Total
Change (%)

60.6
7.4
32.0
100.0

54.2
0.0
45.8
100.0

71.5
20.2
8.3
100.0
Note:  These figures represent the sum of responses from 45 facilities reporting decreases and 36 facilities reporting
      increases in TRI releases and transfers. These facilities were not statistically sampled and may not be
      representative of the TRI universe.
2.4    IMPLICATIONS FOR MAIN STUDY

       The following observations from the pilot study have implications for Phase II of this

study:

       • Almost all the facilities contacted knew the reason for the change in their releases and
         transfers reportable under TRI.

       • Within a facility, reasons for a change were generally specific to each chemical released
         rather than to the facility in general. For example, if a facility released zinc compounds
         and toluene, one reason accounted for the change in zinc compounds and a second,
         different reason for the change in toluene released or transferred.
                                             2-5

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       • If only one reason accounted for the change in the release of a given chemical from a
         given facility, the quantity change could be calculated by facility. However, many
         facilities gave more than one reason for a change in a given chemical, making it
         difficult to quantify the effects of a given chemical change by reason given.

       • Many of the facilities contacted had to research our questions, which required several
         telephone calls over several days or weeks.


       The pilot study observations suggested incorporating the following procedures in the

Phase II study design:

       • Mail a letter explaining the study to facilities prior to contacting them by phone so they
         can prepare for the phone call. This letter would reduce the number of calls made per
         facility and provide the TRI data submissions to the facilities for easy reference during
         the phone call. The letter would indicate when a telephone interviewer will contact the
         facility.

       • Structure questions so that facilities are asked about each chemical they released or
         transferred. During the telephone call, facilities would have to provide release and
         transfer information for each  chemical for each year of the study.

       • Require categories of combined reasons if facilities are unable to distinguish the
         quantity of change due to a single reason when more than one reason accounted for the
         change.
/RTI                                      2-6

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                                     CHAPTER 3
                           MAIN STUDY METHODOLOGY

       The objective of Phase II was to explain changes in reported TRI data submissions from
 1989 to 1990.  Statistical sampling techniques were employed to select a representative group of
facilities from which population estimates could be made. The selected facilities were notified of
the study by letter and then contacted by telephone to obtain their responses.  Participation was
entirely voluntary.  This chapter describes the methods used for Phase n, including the facility
selection, data collection, and sample weighting procedures. The results of Phase n are
presented in Chapter 4.

3.1    SAMPLE PLAN
       The sample plan was designed to estimate the change in the quantity of TRI chemicals
released or transferred for each of the following populations:
       • all  facilities reporting TRI data in both 1989 and 1990,
       • eight selected industries (based on 2-digit SIC code),
       • facilities within each industry or industry group reporting decreases  in TRI releases and
        transfers, and
       • facilities within each industry or industry group reporting increases or no change in TRI
        releases and transfers.

3.1.1  Study Population
       The study population comprises facilities with SIC codes 20 to 39 that submitted TRI
data  for 1989 and 1990. Facilities that reported in 1989 but not in 1990 due to closure and
facilities that reported in  1990 as their first year in business were excluded from the study
population. Facilities that submitted TRI data in 1989 and 1990 but either did not report a SIC
code or reported only SIC codes not between 20 and 39 (and therefore are excluded from TRI
submission requirements under the EPCRA Section 313) were also excluded from the study
population.

       Eight 2-digit SIC codes were studied in detail; all other SIC codes were grouped together
in a ninth category. These eight industries are
       • paper manufacturing (SIC 26),
       • printing and publishing (SIC 27),
       • chemical manufacturing (SIC 28),

                                          3-1                                   /RTI

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       • rubber and plastics manufacturing (SIC 30),
       • primary metals (SIC 33),
       • fabricated metals manufacturing (SIC 34),
       • electrical equipment (SIC 36), and
       • transportation equipment manufacturing (SIC 37).

       For the purposes of this study, facilities reporting multiple SIC codes within the same
2-digit SIC category were assigned to that 2-digit SIC category. Facilities reporting multiple SIC
codes in different 2-digit SIC categories were placed in the "Other" category. This method is
consistent with that used by EPA's Office of Pollution Prevention and Toxics in conducting
analyses using TRI data.

       The study population did not include the chemical terephthalic acid (CAS number
100-21-0). Terephthalic acid was the only chemical to be delisted between the 1989 and 1990
reporting years; thus, the impact of delisted chemicals is not a factor in this study. The impact of
newly listed chemicals is also not a factor since there were no new listings made between 1989
and 1990.

       The resulting study population contains 18,951 facilities reporting a net decrease in TRI
submissions of 866 million pounds between 1989 and 1990.  This quantity change represents
92 percent of the change reported by the universe of TRI facilities at the time of selection.
Table 3-1 provides a summary of the study population and its representation  of the TRI universe.

             Table 3-1. Study Population and Representation of TRI Universe
Number of Facilities, 1990
Number of Form Rs, 1989/1990b
Total Releases and Transfers, 1990
Change in Releases and Transfers
(1990-1989)
TRI Universe8
26,527
100,875
4,888,678,773
-942,529,020
Study Population
18,951
85,780
4,751,204,393
-865,979,506
aThese figures may differ from others published by EPA because of the time and criteria of selection.
'This includes Form Rs that were submitted for either 1989 or 1990. If a facility added or dropped a chemical
  between the two years, its Form R would still be included.
                                            3-2

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3.1.2  Sample Allocation
       The study sample was designed to have equal allocation across the selected industry
groups, allowing us to provide estimates of equal precision for each group. Hence, appropriate
comparisons between industry groups can be made.

       The industry groups were stratified by increases/no change and decreases in TRI releases
and transfers.  Within industry groups an equal allocation sample was used for selecting facilities
with increases/no change and decreases in TRI submissions. In addition, the sample included a
census of the five facilities with the greatest increases and the five facilities with the greatest
decreases in TRI releases for each of the nine industry strata.

       The desired sample size for Phase II was 972 facilities. The actual sample size, however,
was increased to 1,206 facilities to account for an estimated 20 percent nonresponse rate.
Nonresponses included facilities that chose not to participate in the study and those that were no
longer in business or could not be reached during the interview period. The sampled facilities
were allocated to 36 cells in  the 9-by-4 matrix design shown in Table 3-2.

    Table 3-2. Distribution of Facilities into Strata for Study Sample of 1,206 Facilities
SIC
26
27
28
30
33
34
36
37
Other*
Total
Largest
Decreases
5
5
5
5
5
5
5
5
5
45
Decreases
62
62
62
62
62
62
62
62
62
558
Increases/
No Change
62
62
62
62
62
62
62
62
62
558
Largest
Increases
5
5
5
5
5
5
5
5
5
45
Total
134
134
134
134
134
134
134
134
134
1,206
Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20
  and 39.
                                           3-3

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3.2    DATA COLLECTION PROCEDURES
       Prior to being contacted by telephone, the selected facilities received information to
introduce them to this study.  The introductory mail-out package included the following:
       • a cover letter from EPA explaining the purpose of the study,
       • a summary of the questions to be covered and the procedures for conducting the
         telephone interviews, and
       • print-outs from the EPA database of the facility's TRI data for each chemical released
         and transferred.

       These mail-out materials helped facilities prepare  for the interview and served as a
convenient reference during the interview. Thus, when contacted, facilities could complete the
review in a smooth and efficient manner.

       Appendix A includes a copy of the cover letter EPA sent to facilities selected for Phase II
of the study. The appendix also shows the TRI data facilities received for each chemical for
which they submitted TRI data. The example in the appendix includes simulated TRI data for a
fictitious facility.  Appendix B contains the interview script, and Appendices C and D contain
copies of the 1989 and 1990 Form Rs, respectively.

       A computer-assisted telephone interview (CAT!) process was used to collect the data for
Phase II of this study. CAT! interviewers contacted representatives from the 1,206 facilities
selected for this study and asked if the quantity of chemicals released and transferred reported in
TRI changed between 1989 and 1990 because of the following:
       • changes in measurement or estimation techniques,
       • changes in the level of production activity, or
       • source reduction activities.

In addition, facilities attributing change to source reduction were asked to identify which of the
following source reduction activities they employed:
       • equipment or technology modification;
       • process or procedure modification;
       • reformulation or redesign of products;
       • substitution of raw materials;
       • improvement in housekeeping, maintenance, training, or inventory control; or
       • other source reduction activity.
/RTI                                      3-4

-------
       As mentioned in Chapter 2, the results of Phase I of this project suggest that explanations
for changes in TRI submissions were generally specific to each chemical. Therefore, in Phase n
each TRI chemical was reviewed separately. Facilities that had submitted Form Rs for more
than 20 TRI chemicals were exempted from this procedure. To reduce the time needed to
complete the review, these facilities were asked to explain the reasons for change for only those
chemicals making up 80 percent of their total change.

3.3    APPLICATION OF WEIGHTS
       Statistical weights were calculated and applied to the sample data to determine population
estimates. This section describes the methods for selecting the weighting design, the weighting
adjustments that were  necessary once the data had been collected, and the precision of the
resulting weighted estimates.

3.3.1   Weighting Design
       Applying weights to sampled data allows us to make estimates for the entire population
of facilities. A weight is a factor used to escalate from a sample measurement to an estimate for
                                                                 ,'*'
the total population. For example, if a single facility were sampled from a population of ten
facilities, multiplying (or weighting) the responses of the sampled facility by ten gives an
estimate  of the total population.

       The weighting  design is determined by the type of analysis desired. The following types
of estimates for each of the nine industry groups and four change strata of the sample design
were of interest to this study:l
       •  the number of facilities attributing change to measurement change, production change,
         and/or source reduction;
       •  the number of chemical-level changes attributed to measurement change, production
         change, and/or source reduction; and.
       •  the quantity change attributed to measurement change, production change, and/or
         source reduction.

Three sets of weights were needed to make these types of estimates: facility-level frequency
weights, chemical or Form R-level frequency weights, and quantity weights. These are described
below.
1 In addition, the study sample included sufficient coverage to make weighted estimates of the reasons for change for
  chemical-specific quantities (e.g., 33/50 chemicals). However, this type of analysis was not possible given the
  resource and time constraints of this study.
                                           3-5                                    /RTI

-------
Facility-Level Frequency Weights
       Facility-level weights were calculated by industry and change strata so that the weighted
value for each of the cells in the sample design equals the actual number of facilities in the study
population. Table 3-1 shows the distribution of the 1,206 sampled facilities into the industry and
change strata of the sample design.  Table 3-3 shows how the 18,951 facilities of the study
population are actually distributed among the design strata.  Each cell in Table 3-1, when
weighted, takes on the value of the corresponding cell in Table 3-3. For example, the 62
facilities sampled from SIC 26 with decreases in their TRI submissions have a weight or
multiplier that escalates their value up to 302—the number of facilities from the population in the
same industry/change strata.  The total weighted value for sampled facilities is 18,951—the
number of facilities in the study population.

  Table 3-3.  Distribution of Facilities into Strata for Study Population of 18,951 Facilities
SIC
26
27
28
30
33
34
36
37
Other2
Total
Largest
Decreases
5
5
5
5
5
5
5
5
5
45
Decreases
302
156
1,975
779
801
1,406
878
633
3,734
10,664
. Increases/
No Change
237
135
1,576
637
603
1,070
554
381
3,004
8,197
Largest
Increases
5
5
5
5
5
5
5
5
5
45
Total
549
301
3,561
1,426
1,414
2,486
1,442
1,024
6,748
18,951
Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20
  and 39.
       The largest increase/decrease strata include a census of facilities.  Consequently, only a
weight of one was applied. By including these facilities with a weight of one, the behavior of
very large facilities can be studied without distorting the population estimates.
                                            3-6

-------
Form R-Level Frequency Weights
       The Form R-level weights were calculated in the same manner as the facility-level
weights. Sample data for each of the industry and change strata were weighted to represent the
actual number of Form Rs in the population.  Form Rs for the facilities of the largest
increases/decreases strata were given a weight of one. The total weighted value for sampled
Form Rs is 85,780—the total number of Form Rs in the study population.

Quantity Weights
       Quantity weights were applied to sample data so that the 1989 to 1990 change in releases
and transfers for sampled Form Rs would represent the real change in releases and transfers for
the study population. Once determined, these weights could then be applied to the quantity
responses for each of the three change variables (measurement, production, and source reduction)
to make population estimates of the reasons for change in TRI submissions.

       However, study participants were not required to account for the full quantity change for
each of their Form Rs. Rather, participants were asked to estimate, if possible, the quantity
change for each Form R that could be attributed to measurement change, production change, and
source reduction. If respondents attributed the quantity change to other reasons or if they were
unable to estimate the quantity change, then the sum of their responses  would not equal their
change in TRI submissions.  Consequently, a fourth change variable "Other Factors" was
necessary to complete the following equation:
Measurement  +  Production  +    Source   +    Other    =   1990 TRI   -  1989 TRI
   Change         Change       Reduction      Factors      Submission     Submission
Thus, the weighted value of the four change variables equals the change in TRI submissions for
the population—a decrease of 866 million pounds.

3.3.2   Adjustment to Weights
       Once the data had been collected and the interview procedure was complete, the three
weights initially applied to the sample for nonresponse were adjusted (facilities that could not be
reached to complete the interview or facilities that chose not to participate). Eighty percent of
the sampled facilities volunteered to participate in the study. Weights for facilities that did not
participate were reduced to zero, and weights for participants were adjusted so that their
weighted value would represent the entire population of facilities.

                                           3-7                                    /RTfl

-------
3.3.3  Precision of Weighted Estimates
       Confidence intervals are used to measure the accuracy of weighted estimates. The
confidence interval is the range of numbers within which the true value of an estimated number
will fall with a certain known probability based on the statistical design of the survey and the
response rate obtained. A 95 percent confidence interval means that if a survey were conducted
100 times, the estimates would fall within the confidence interval 95 percent of the time.

       The target precision for this study was to produce estimates for a given industry and
change strata with a 95 percent confidence interval of plus or minus 14 percent. This target
would require an 80 percent response rate or 50 participants per industry/change category
sampled.  The largest increases/decreases strata, being a census and not a sample, are not subject
to these precision criteria.  However, an 80 percent response rate, or four participants per
industry/change category censused, was desired.

       Though participation in this study was entirely voluntary, the target response rate of 80
percent was easily achieved. The response rate by strata, however, varies. Table 3-4 shows the
percentage of participants for each of the cells in the sample design. A total of 960 facilities
volunteered to participate in this study.

       Of the 20 percent of the sample that did not participate,  12 percent were still pending (i.e.,
TRI contacts were on vacation or otherwise unavailable at the time of the calls), 7 percent chose
not to participate, and the remaining 1 percent had gone out of business. With an 80 percent
response rate and only a 7 percent refusal rate, response bias should have minimal, if any, effect
on study results.

       Confidence intervals have not been calculated for the estimates provided in the remainder
of this report.  The purpose of the preceding discussion is to demonstrate that, on average,
estimates for each of the industry and change categories have a  confidence interval of 95 percent
plus or minus 14 percent.  Actual confidence intervals would vary by strata depending on the
response rate.
/RTI                                      3-8

-------
Table 3-4.     Response Rate: Percentage of Facilities Sampled that Volunteered to
               Participate
SIC
26
27
28
30
33
34
36
37
Other*
Total
Largest
Decreases
80.0
60.0
100.0
60.0
100.0
80.0
100.0
80.0
40.0
77.8
Decreases
87.1
79.0
80.6
74.2
64.5
87.1
66.1
82.3
74.2
77.2
Increases/ •'
No Change
90.3
67.7
88.7
87.1
82.3
83.9
77.4
88.7
79.0
82.8
Largest
Increases
60.0
100.0
100.0
100.0
80.0
80.0
60.0
40.0
20.0
71.1
Total
87.3
73.9
85.8
80.6
74.6
85.1
72.4
83.6
73.1
79.6
Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20
   and 39.
                                             3-9

-------
                                     CHAPTER 4
    MAIN STUDY RESULTS:  REASONS FOR CHANGES IN TRI SUBMISSIONS,
                                     1989-1990

       In Phase n of the study, data collected from TRI facilities were used to explain the
reasons for changes in TRI releases and transfers between 1989 and 1990. Of the 1,206 facilities
that were randomly selected, a total of 960 facilities, or 80 percent of the sample, volunteered to
participate. Weighting these responses gave population estimates at both the industry and
national levels.  This chapter presents the results of this analysis.

4.1    SUMMARY DATA: NATIONAL ESTIMATES
       The 18,951 facilities of the study population decreased their reported TRI submissions
between 1989 and 1990 by 866 million pounds.  This section provides national estimates of the
extent to which this decrease can be attributed to each of the following reasons:
       • changes in measurement or estimation techniques,
       • changes in the level of production activity, and
       • source reduction activities.

4.1.1   Frequency Estimates: Number of Facilities and Form Rs Indicating Each Reason
       for Change
       The weighting design used for this study allowed us to make two types of frequency
estimates: facility-level estimates and Form R-level estimates. Facility-level estimates are
important in evaluating the behavior of the firm (e.g., the number of facilities that have
implemented pollution prevention programs, or the number facilities that have altered production
activities due to economic or other conditions). Form R or chemical-level estimates are
important in evaluating changes/progress across the TRI universe of chemicals.

       Table 4-1 presents the frequency results of Phase II of this study. Any individual facility
or Form R can be tabulated under each column.  Thus, if all facilities indicated a particular
reason for a change (e.g., measurement change) the total for that reason category would be
18,951—the total number of facilities in the study population. Likewise, if facilities indicated a
particular reason (e.g., production change) for all their Form Rs, the total for that reason category
would be 85,780—the total number of Form Rs in the study population.

       The impact of production fluctuations was  the most common reason for change—
69 percent of all facilities claimed an impact.  Nearly 40 percent of all facilities realized a change
in TRI releases and transfers due to source reduction activities. The actual percentage of
                                          4-1

-------
 Table 4-1.   Number and Percentage of Facilities and Form Rs Indicating Each Reason for
             Change

Number of Facilities
Percentage of Facilities
Number of Form Rsa
Percentage of Form Rsa

Measurement
Change
4,630
24.4%
12,545
14.6%
Reasons
s
Production
Change
13,124
69.3%
38,525
44.9%

Source
Reduction
7,570
39.9%
15,767
18.4%
^hese estimates may be low.  Facilities that submitted more than 20 Form Rs were asked to explain the reasons for
  change for only those chemicals making up the top 80 percent of their total change. Consequently, 4 percent of
  the Form R population was excluded from the interview process.

facilities that have implemented source reduction programs, however, may be even higher
because the results of prevention programs may  not be ev: •'ent for several years after
implementation. A change in measurement or estimation techniques, a form of "paper" change,
was the least common reason for change.

       As expected, the trend in Form R responses follows that of the facility-level responses:
production change was the most common and measurement change was the least common reason
for change. In each case,  however, the percentage response is considerably lower for Form Rs
than for facilities. This difference indicates that each change variable,  though having some effect
on a facility's submissions, did not affect all the  chemicals released or  transferred by the facility.
For example, a new  measurement technique may have been employed  for one but not all of a
facility's reported chemicals.

4.1.2  Quantity Estimates: Quantity Change Attributed to Each Reason for Change
       The quantity estimates resulting from this study are evaluated in two ways. The first and
traditional approach to examining yearly changes in TRI submissions is to evaluate net change.
This approach, however, may mask the dynamics behind the quantity change  figures because
large quantity increases and large quantity decreases may cancel each other out. The second and
more illuminating approach is to examine individually the increase and decrease quantities that
make up the net change.
/RTI                                      4-2

-------
                                                                              f
       Figure 4-1 shows how the 866 million pound net decrease in TRI submissions between
1989 and 1990 is apportioned between measurement changes, production changes, source
reduction, and other factors.  Other factors include changes due to reasons other than the three
change variables of this study (e.g., changes due to recycling, data errors, and technical
                                                       /
guidance). Section 4.3.4 discusses and quantifies the other factors influencing TRI submissions.
       Measurement Change
        -21.9 million pounds
                   (2.5%)
              Other Factors
       -415.7 million pounds
                  (48.0%)
Production Change
-41.2 million pounds
(4.8%)
Source Reduction
-387.2 million pounds
(44.7%)
                        Net Quantity Decrease = 866 Million Pounds
         Figure 4-1.  Net Quantity Change in TRI Submissions, by Reason

       Nearly 45 percent of the net decrease hi TRI submissions was due to source reduction
activities. An estimated 5 percent of the change was due to production change, less than 3 percent
was due to measurement change, and the remaining 48 percent was due to other factors. Thus, at
least 50 percent of the net change (production change and source reduction combined) falls under
the category of "real" change. Only 3 percent of the net change can be labeled with certainty as
"paper" change; however, the remaining 48 percent decrease combines both real and paper changes.

       Figure 4-2 shows the net quantity change in releases and transfers as a percentage of 1989
total releases and transfers where the removed piece of the pie represents the 866 million pound
decrease or 15 percent of 1989 releases and transfers. Source reduction accounted for 7 percent
of the decrease in  1989 releases and transfers, production and measurement change together
accounted for 1 percent, and other factors contributed to the remaining 7  percent.
                                        .  4-3
                   /RTI

-------
           Production and
      Measurement Change
                    1.2%
       Total 1990 Releases
            and Transfers
                   84.6%
Source Reduction
6.9%
                                                                Other Factors
                                                                7.3%
                 Total 1989 Releases and Transfers = 5,617 Million Pounds
  Figure 4-2.  Net Quantity Change as a Percent of 1989 Releases and Transfers


       Both Figures 4-1 and 4-2 represent net changes—the traditional way of presenting
changes in TRI submissions. Figure 4-3 shows how the net change figures are derived from
quantity increases and decreases and illustrates the importance of evaluating change by its
components.

       Although the net change for all three variables is a decrease, both increases and decreases
were attributed to each variable. The greatest absolute quantity change was attributed to
production change, indicating that although the aggregated impact of production change is
comparatively small, large quantity increases and decreases are associated with production
changes.

4.2     SUMMARY DATA: INDUSTRY ESTIMATES
       In addition to national estimates of the extent to which measurement change, production
change, and source reduction affect TRI submissions, we provide similar estimates for the nine
industry strata selected.
                                          4-4

-------
  £
                 Measurement
                    Change
             Materials Bclon^ To-       "!
             OPPT Library    •
  Production  401 M Street', SVSdBgW93)  "
    Change   Washington, £>' Reduction
                   Quantity Increase
Quantity Decrease      Net Change
Figure 4-3.  Aggregating Increases and Decreases in TRI Submissions,
             by Reason
4.2.1   Frequency Estimates: Number of Facilities and Form Rs Indicating Each Reason
       for Change, by Industry
       Table 4-2 shows the percentage of facilities indicating measurement change, production
change, and source reduction for each of the nine industry groups studied. Table 4-3 shows the
same percentage information for chemical-level responses. These data indicate that there is little
variance between industry groups in the percentage of Form Rs and facilities impacted by each
of the three change variables.

4.2.2   Quantity Estimates: Quantity Change Attributed to Each Reason for Change, by
       Industry
       Tables 4-4 through 4-6 show the net quantity change, quantity increase, and quantity
decrease attributed to each of the three change variables for the nine industry groups studied.
                                         4-5

-------
     Table 4-2. Percentage of Facilities Indicating Each Reason for Change, by Industry
SIC
26
27
28
30
33
34
36
37


Industry
Paper
Printing and publishing
Chemical
Rubber and plastics
Primary metals
Fabricated metals
Electric Equipment
Transportation
Other3
Total
Measurement
Change
29.5
12.6
32.6
18.4
27.2
23.0
20.1
30.9
21.4
24.4
Production
Change
•' 68.3
75.4
77.2
70.3
71.7
62.2
63.0
71.1
67.8
69.3
Source
Reduction
52.5
46.2
47.8
34.6
45.0
40.6
42.0
50.1
32.4
39.9
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
Note:  Percentages listed by SIC group represent the number of facilities indicating each reason divided by the total
       number of facilities in each SIC group. Only the total row shows the responses.... a percentage of the total
       population.


            Table 4-3. Percentage of Form Rs by Reason for Change, by Industry
SIC
26
27
28
30
33
34
36
37


Industry
Paper
Printing and publishing
Chemical
Rubber and plastics
Primary metals
Fabricated metals
Electric Equipment
Transportation
Other3
Total
Measurement
Change
16.7
9.3
12.9
22.9
11.8
14.4
10.4
14.4
16.5
14.6
Production
Change
44.9
56.8
45.1
46.9
42.0
45.7
41.4
44.5
45.3
44.9
Source
Reduction
21.1
28.4
17.5
17.6
18.5
17.9
19.3
29.2
16.5
18.4
alncludes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
Note:  Percentages listed by SIC group represent the number of facilities indicating each reason divided by the total
       number of facilities in each SIC group. Only the total row shows the responses as a percentage of the total
       population.


                                                 4-6  .

-------
Table 4-4.   Population Estimates: .Net Quantity Change Attributed to Each Reason, by
             Industry (million pounds)
SIC
26
27
28
30
33
34
36
37
Other8
Total Change
Percentage
Change
Measurement
Change
6.4
-2.1
12.8
2.5
-14.9
-6.4
1.2
9.6
-31.0
-21.9
3%
Production
Change
12.1
0.9
-99.4
7.4
56.6
6.4
0.1
-6.5
-18.7
-41.2
5%
Source
Reduction
f
-16.2
-5:3
-180.9
-5.9
-58.9
-11.0
-7.7
-37.7
-63.5
-387.2
45%
Other
Factors
-33.8
-0.4
-330.1
-17.5
6.2
-11.5
-16.7
-0.4
-11.6
-415.7
48%
Total
Change
-31.5
-6.9
-597.6
-13.5
-11.0
-22.5
-23.2
-35.1
-124.7
-866.0
100%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.


Table 4-5.   Population Estimates: Quantity Increase Attributed to Each Reason, by
             Industry (million pounds)
Measurement
SIC Change
26
27
28
30
33
34
36
37
Other8
Total Increase
Percentage
Increase
25.0
0.7
17.9
2.7
3.2
2.6
2.7
11.8
15.9
82.4
7%
Production
Change
19.6
2.4
46.6
14.0
79.1
26.2
5.9
9.0
23.9
226.5
19%
Source
Reduction
0.1
0.1
0.2
2.6
6.2
1.7
2.2
3.8
4.4
21.2
2%
Other
Factors
16.8
4.2
419.9
25.1
217.3
26.1
20.0
28.4
117.5
875.1
73%
Total
Increase
61.3
7.3
484.6
44.3
305.7
56.6
30.7
53.0
161.7
1,205.2
100%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
                                           4-7
/RTI

-------
Table 4-6.   Population Estimates: Quantity Decrease Attributed to Each Reason, by
            Industry (million pounds)
SIC
26
27
28
30
33
34
36
37
Other3
Total Decrease
Percentage
Decrease
Measurement
Change
-18.6
-2.7
-5.1
-0.2
-18.1
-9.0
-1.6
-2.2
-46.8 .
-104.3
5%
Production
Change
-7.5
-1.5
-146.0
-6.6
-22.5
-19.9
-5.8
-15.5
-42.5
-267.6
13%
Source
Reduction
-16.3'
-5.4
-181.1
-8.5
-65.1
-12.7
-9.9
-41.6
-67.9
-408.4
20%
Other
Factors
-50.5
-4.6
-750.0
-42.5
-211.1
-37.5
-36.7
-28.8
-129.1
-1,290.8
62%
Total
Decrease
-92.8
-14.2
-1,082.2
-57.8
-316.7
-79.1
-53.9
-88.0
-286.4
-2,071.2
100%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
4.3    ANALYSIS OF RESULTS, BY REASON
       Analysis of results for the three change variables that are the focus of this review are
provided below. A discussion and limited quantification of other factors affecting TRI
submissions are also included.

4.3.1   Measurement Change
       Measurement change is the one study variable considered a "paper" change (i.e., a change
affecting TRI submissions without physically altering the quantity of chemicals released). For
example, a facility's chemical releases may have remained the same from  1989 to 1990, yet a
change in estimation techniques from best engineering judgment to a mass balance calculation
may have led to a more accurate, yet significantly different, TRI submission.

       On the national level, measurement change had the smallest impact of the three factors
studied. Only 15 percent of the Form Rs had some change due to new measurement or
estimation techniques. This percentage accounted for an increase of 82 million pounds, a
decrease of 104 million pounds, and a net decrease of 28 million pounds, which is less than
3 percent of the net change.
                                          4-8

-------
       At the industry level, the impact of measurement change was, likewise, relatively small.
However, the net change varied from industry to industry. Four of the SIC groups showed a net
decrease due to measurement change, and the remaining five SIC groups showed a net increase.
The printing and publishing industry had both the lowest percentage of facilities and Form Rs
affected by measurement change.

       Figure 4-4 shows the percentage of facilities indicating measurement change for each of
the nine industry groups studied.  Figure 4-5 shows the net quantity change, quantity increase,
and quantity decrease attributed to measurement change.

4.3.2   Production Change
       Production change had the greatest absolute quantity change.  Over 494 million pounds (a
227 million pound increase and a 268 million pound decrease) were attributed to production
change. This figure supports the estimate that nearly 70 percent of all facilities attributed some
portion of their change to the impact of production fluctuations. Due to quantity increases and
decreases canceling each other out, however, only 5 percent of the net quantity change can be
attributed to production fluctuations.

Paper (26)

Printing and Publishing (27)

Chemical (28)

Rubber and Plastics (30)

Primary Metals (33)

Fabricated Metals (34)

Electric Equipment (36)

Transportation (37)

Other

C

iS ,
1
;.,,,vl

f f * "" f
|
•;. • 1


|
*• "• f
•, •,
1
f A &j)f ff XX "" "" '•
I
••••^•y 	 < 	
' \ "^ *" &? %^-i ^^
 10 2















lea

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s



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'^'



3
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V













0
:e



















4
ntage



















0 5
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)0
 Figure 4-4.  Percentage of Facilities Indicating Measurement Change, by Industry
                                          4-9

-------
                Paper (26)

    Printing and Publishing (27)

              Chemical (28)

      Rubber and Plastics (30)

          Primary Metals (33)

        Fabricated Metals (34)

       Electric Equipment (36)

          Transportation (37)

                   Other
II] Increase/Decrease
   Net Change
                        -50     -40      -30     -20     -10      0      10
                                          Quantity Change (million pounds)
                                            20
30
   Figure 4-5.  Quantity Change Attributed to Measurement Change, by Industry


       Production change was also the most frequently cited reason for change for each of the
nine industry groups. The chemical industry (SIC 28), more than any other industry, cited the
effect of production fluctuations. As with measurement change, the net impact due to production
change varied from industry to industry.  Most industries showed a net increase due to
production change; however, a comparatively large net decrease in the chemical industry of 98
million pounds outweighed the net increase values, resulting in a net decrease at the national
level.

       The impact due to production change may differ between the TRI universe and the study
population. One of the criteria for selecting the study population was that facilities had to have
filed Form Rs for both 1989 and 1990 (if a facility went out of business before 1990, it would
not have been included). Thus, the production estimates resulting from our review do not
include the impact of business start-ups and closures.

       Figure 4-6 shows the percentage of facilities indicating production change for each of the
nine industry groups studied. Figure 4-7 shows the quantity increase, decrease, and net change
attributed  to production change.
                                           4-10

-------
              Paper (26)

 Printing and Publishing (27)

            Chemical (28)

    Rubber and Plastics (30)

       Primary Metals (33)

     Fabricated Metals (34)

     Electric Equipment (36)

        Transportation (37)

                  Other

                     I       r
                                          +
              +
4-
+
                              10     20     30    40     50     60    70    BO
                                         Percentage Indicating Production Change
                                              90
                               100
Figure 4-6.  Percentage of Facilities Indicating Production Change, by Industry
              Paper (26)

 Printing and Publishing (27)

            Chemical (28)

    Rubber and Plastics (30)

        Primary Metals (33)

     Fabricated Metals (34)

     Electric Equipment (36)

        Transportation (37)

                  Other
II] Increase/Decrease
  " Net Change
                      -150
 -100          -50           0           50
        Quantity Change (million pounds)
                              100
  Figure 4-7.  Quantity Change Attributed to Production Change, by Industry
                                           4-11

-------
 4.3.3  Source Reduction
       Approximately 40 percent of all facilities attributed some portion of their change to
 source reduction. This is significantly higher than the 11 percent of facilities that voluntarily
 reported attempts at waste minimization on the optional section of the 1989 Form R. The net
 change attributed to source reduction was 387 million pounds or 45 percent of the total net
 change.  This total represents the sum of a 21 million pound increase and a 408 million pound
 decrease due to reduction activities.

       Surprisingly, respondents indicated an increase due to source reduction for over 7 percent
 of their Form Rs affected by source reduction. The most common reason for this increase was
 materials substitution, whereby facilities reduced their use of certain TRI chemicals by replacing
 them with other (presumably less toxic) chemicals to achieve the same result. This increase in
 the releases and transfers of substitute chemicals is the by-product of reduction activities.

       At the industry level, source reduction accounted for the greatest net decrease for all SIC
 groups. Of the three change variables, source reduction also accounted for the greatest quantity
 decrease for all SIC groups except the fabricated metals industry (SIC 34), which had a larger
 quantity decrease due to production change. The chemical industry (SIC 28), with a net decrease
 of 181 million pounds attributed to source reduction, contributed over one-half of the total net
 decrease due to source reduction.

       Facilities that cited source reduction as a reason for change were also asked to identify
 the types of source reduction that contributed to the change. Table 4-7 presents the results of this
 portion of the analysis.

       Surprisingly, improved housekeeping and management techniques, considered  the easiest
 and least expensive type of source reduction to implement, were not the most frequently cited.
 Instead, the most frequently cited form of source reduction was procedure modification.  The
 least frequently cited type of source reduction, excluding the "Other" category, was redesign of
 product, generally considered one of the more expensive prevention options.

       Study participants were not asked to quantify change attributed to each type of  source
 reduction. Thus, although procedure modification was most frequently cited, we cannot
 conclude that it had the greatest impact on quantity change.

       Figure 4-8 shows the percentage of facilities indicating source reduction for each  of the
nine industry groups studied. Figure 4-9 shows the quantity increase, decrease, and net change
attributed to source reduction.
                                           4-12

-------
Table 4-7.    Percentage of Facilities .Implementing Each Type of Source Reduction, by
              Industry
Equipment
SIC Modification
26
27
28
30
33
34
36
37
Other*
Total
39.2
30.9
49.6
26.4
57.1
48.4
51.3
49.5
65.6
52.5
Procedure
Modification
64.6
51.8
62.1
65.1
59.2
61.7
71.3
60.6
54.2
60.3
Redesign of Materials
Product Substitution
30.9
30.2
22.3
17.4
26.7
16.1
11.1
24.6
22.3
21.3
51.0
38.8
36.0
40.4
47.9
39.3
42.6
49.9
40.0
41.0
Improved
Management Other
20.5
36.0
54.5
37.5
50.7
55.9
40.3
54.2
39.3
46.1
10.1
2.2
18.3
11.6
13.5
15.3
. 9.1
1.2
18.6
14.6
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
Note:  Percentages listed by SIC group represent the number of facilities indicating each type of source reduction
      divided by the total number of facilities in each SIC group that cited source reduction as a reason for change.
                 Paper (26)


    Printing and Publishing (27)


              Chemical (28)


      Rubber and Plastics (30)


          Primary Metals (33)


       Fabricated Metals (34)


       Electric Equipment (36)


          Transportation (37)


                    Other
                                10    20     30     40    50     60    70     60    90    100

                                            Percentage Indicating Source Reduction
   Figure 4-8.  Percentage of Facilities Indicating Source Reduction, by Industry
                                              4-13

-------
               Paper (26)

   Printing and Publishing (27)

             Chemical (28)

     Rubber and Plastics (30)

         Primary Metals (33)

       Fabricated Metals (34)

      Electric Equipment (36)

         Transportation (37)

                   Other
            Increase/Decrease
            Net Change
                       -200    -175   -150    -125   -100    -75    -50     -25
                                          Quantity Change (million pounds)
                                                        25
     Figure 4-9.  Quantity Change Attributed to Source Reduction, by Industry
4.3.4  Other Factors
       A net decrease of 416 million pounds or 48 percent of the total change in TRI
submissions is due to factors other than the three factors that were the focus of this study.
Although study participants were not asked to quantify change due to other reasons, this quantity
was estimated by subtracting responses to each of the three change variables from the known
quantity change in TRI submissions:
 Other    /  1990 TRI
Factors   V Submissions
 1989 TRI  \
Submissions /
/ Measurement    Production      Source  \
V   Change    +   Change     Reduction /
The reasons for change falling under the "Other Factors" category may include, but are not
limited to, the following:
       • initial TRI data from the EPA data base were not correct;
       • facility had revised numbers but had not provided them to EPA;
       • respondent made inaccurate estimates;
       • respondent was unable or unwilling to estimate the reasons for change;
       • CATI interviewer keyed data incorrectly;
                                           4-14

-------
       • respondents changed their reporting methodology for ammonia and ammonium sulfate;
         or
       • chemical-level data were pulled prior to interview for facilities with more than 20 Form
         R submissions (see Section 3.2 on data collection procedures).


Data for making quantity estimates are available for four of these reasons. These are listed in

Table 4-8 and described below. The remaining quantity falls under the "Unexplained" heading.


   Table 4-8. Other Factors Contributing to the Change in 1989-1990 TRI Submissions
                      Other Factors                      Quantity Change
                                                          (million pounds)
         Respondents were unable to quantify
         change                                                -290


         Facilities changed reporting methodology
         for ammonia and ammonium sulfate3                     -250
         Respondents claimed their TRI data did
         not correspond with their submissions3                    +33


         Form Rs were excluded from analysis for
         facilities with more than 20 TRI chemicals                  +1


         Unexplained                                           +90
         Total Other Factors                                   -416
       "Accuracy of these estimates may be low. Only a handful of facilities took advantage of toe
        ammonia reporting option; thus the desired sample size was not available for making population
        estimates. Data on TRI discrepancies were collected manually and not part of the computerized
        script; thus discrepancies may have gone unreported.


Respondents' Ability to Quantify Change

       An estimated 12,290 Form Rs, or 14 percent of the population total, attributed some

portion of the change to one of the three change variables, but participants were unable to

quantify the change.  Participants responded positively to one or more of the three reasons and

were either unable or unwilling to estimate the quantity change due to that reason. Although this

percentage involved only a small portion of the Form Rs, the quantity impact amounted to a net

decrease of approximately 290 million pounds.
                                          4-15

-------
       Table 4-9 shows the percentage of Form Rs for which facilities were able to quantify
 change by reason. Study participants were not expected to perform additional calculations or
 estimates in preparation for the interview. Rather, they were asked to provide their best
 estimates based on existing knowledge. On average, facilities were able to provide quantity
 estimates for over 80 percent of their Form Rs. The ability to make quantity estimates does not
 vary significantly between reasons.

          Table 4-9.  Percentage of Form Rs with Change Quantified, by Industry
SIC
26
27
28
30
33
34
36
37


Industry
Paper
Printing and publishing
Chemical
Rubber and plastics
Primary metals
Fabricated metals
Electric Equipment
Transportation
Other3
Total
Measurement
Change
90.8
65.5
79.8
91.8
88.7
76.1
85.2
67.4
92.9
85.4
Production
Change
74.7
83.6
77.2
83.2
71.5
79.9
64.4
76.2
75.3
75.9
Source
Reduction
77.2
73.1
80.9
83.5
78.5
82.0
87.6
83.5
73.5
79.3
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20
   and 39.
Change in Reporting Requirements
       The only change in reporting requirements between 1989 and 1990 that would
significantly affect the change in releases between the two years was the delisting of terephthalic
acid.  To prevent this reporting change from influencing this study, terephthalic acid was
excluded from the study population.

       However, EPA issued technical guidance on the 1990 reporting of ammonia and
ammonium sulfate, which had a significant impact on the study results. An estimated decrease
or "paper" change of 250 million pounds is attributed to the technical guidance. Approximately
93 percent of this change is the result of a handful of very large facilities in the chemical industry
(SIC 28) taking advantage of this reporting option.


/nn                                     4-16

-------
TRI Data Discrepancies
       As part of the telephone interview process, interviewers were instructed to take note of
                                                              v
any Form R data which study participants claimed did not correspond with their submissions.
The results indicate that less than 2 percent of all Form Rs had'discrepancies. These errors
contributed to a net increase in releases and transfers of roughly 33 million pounds.

Form Rs Excluded for Large Facilities
       Sampled facilities that submitted more than 20 TRI Form Rs in either 1989 or 1990 were
not asked to complete the series of interview questions for all of their TRI chemicals. Instead, in
an effort to limit the time required to complete the review, these facilities were asked to explain
the reasons for change for those Form Rs making up 80 percent of their total change. The
remaining Form Rs were excluded from the review but not from the study population.  Thus,
their quantity change fell into the "Other Factors" category.

       A weighted total of 3,262 Form Rs, or less than 4 percent of the population total, were
excluded from the review process.  These Form Rs accounted for an estimated net increase in
releases and transfers of 1 million pounds.

4.4    ANALYSIS OF RESULTS, BY SIZE STRATA
       Facilities with the very large releases and transfers of TRI chemicals can
disproportionately influence aggregate quantities of TRI submissions.  To study the impact of
very large facilities on the quantity change in TRI submissions between 1989 and 1990, a census
of the five facilities with the largest increases and the five facilities with the largest decreases for
each industry group  was included in this review.  The results of their responses are discussed
below. In addition, population estimates of the reasons for change, with the impact of very large
facilities removed, are also provided.

4.4.1   Largest Increase/Decrease Strata
       The 90 facilities with the largest increases and decreases combined had a net decrease in
TRI submissions of 201 million pounds, or 23 percent of the net change for the population.
Disaggregated, this group contributed to 41 percent of the increases and 34 percent of the
decreases for the study population (18,951 facilities). Tables 4-10 through 4-12 present the net
quantity change, quantity increase and quantity decrease by reasons for change for these strata.
                                          4-17                                    /RT1

-------
 Table 4-10.  Largest Increases/Decreases Strata: Net Quantity Change Attributed to Each
             Reason, by Industry (million pounds)
SIC
26
27
28
30
33
34
36
37
Other8
Total
Measurement
Change
5.2
-1.8
12.8
0.0
-13.7
-1.1
-0.6
5.8
-0.6
6.1
Production
Change
10.9
1.4
3.4
2.3
34.1
-1.0
0.5
-3.9
-6.5
41.0
Source
Reduction
-1.1
0.0
-26.1
-1.0
-6.1
0.5
-1.1
-2.3
-7.8
-45.0
Other
Factors
-24.5
-1.7
-201.8
-8.2
33.3
-0.9
-2.1
2.8
0.1
-203.0
Total
Change
-9.5
-2.2
-211.8
-6.8
47.6
-2.5
-3.3
2.4
-14.8
-200.9
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.


Table 4-11.  Largest Increases/Decreases Strata: Quantity Increase Attributed to Each
             Reason, by Industry (million pounds)
SIC
26
27
28
30
33
34
36
37
Other3
Total
Percentage
Increase
Percentage of
Population Increase
Measurement
Change
14.6
0.6
12.8
0.0
0.0
0.0
0.1
5.8
0.0
33.8
7%
41%
Production
Change
10.9
1.4
6.3
2.4
36.4
0.7
0.6
0.1
0.7
59.3
12%
26%
Source
Reduction
0.0
0.0
0.0
1.7
0.0
0.5
0.1
0.1
0.0
2.4
0%
11%
Other
Factors
7.4
0.8
176.6
5.5
178.2
2.8
4.7
5.9
15.7
397.5
81%
45%
Total
Change
32.9
2.7
195.7
9.6
214.6
4.0
5.4
11.8
16.4
493.1
100%
41%
alncludes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.


/RTi                                     4-18

-------
Table 4-12.  Largest Increases/Decreases Strata: Quantity Decrease Attributed to Each
             Reason, by Industry (million pounds)
Measurement Production
SIC Change Change
26
27
28
30
33
34
36
37
Other3
Total
Percentage Decrease
Percentage of
Population Decrease
-9.4
-2.4
0.0
0.0
-13.7
-1.1
-0.6
0.0
-0.6
-27.8
4%
27%
-0.1
0.0
-2.9
-0.1
-2.3
, -1.7
-0.1
-4.0
-7.2
-18.3
3%
7%
Source
Reduction
-1.1
0.0
-26.1
-2.7
-6.1
0.0
-1.2
-2.4
-7.8
-47.3
7%
12%
Other
Factors
-31.9
• -2.5
-378.5
-13.6
-144.9
-3.6
-6.8
-3.0
-15.6
-600.5
87%
47% .
Total
Change
-42.4
-4.9
-407.5
-16.4
-167.0
-6.5
-8.8
-9.4
-31.2
-693.9
100%
34%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
       A much greater portion of change for the largest increase/decrease strata was attributed to
factors other than measurement change, production change, and source reduction than for the
population as a whole. An estimated net decrease of 203 million pounds (an increase of 398
million pounds and a decrease of 600 million pounds) was attributed to other factors. This
quantity represents nearly 50 percent of the population's net change due to other factors.

       Further analysis of the "Other Factors" category revealed that a change in reporting
methodology for ammonia and ammonium sulfate accounted for a large portion of the total
quantity change due to other factors.  Though only a handful of facilities apparently took
advantage of this reporting option, the impact was significant.  For example, a single facility in
the chemical industry  (SIC 28) had a net decrease in TRI submissions for ammonia and
ammonium sulfate of  142 million pounds. Most of the facilities that reported this paper change
were from SIC 28 of the largest decreases strata.
                                           4-19

-------
 4.4.2  Population Estimates with Largest Increase/Decrease Strata Removed
       Because the relatively small number of facilities of the largest increases/decreases strata
 had a disproportionately large impact on the total reported quantity change in TRI submissions,
 viewing the population estimates with these strata removed gives a better sense of how "average"
 facilities explained their change. Tables 4-13 through 4-15 show these results by net quantity
 change, quantity increase, and quantity decrease.

       The total quantity decrease accounted for by this subset of the population is 665 million
 pounds, or 77 percent of the study population's total change. The percentage quantity change
 due to source reduction is 52 percent, which is 7 percentage points higher than the total study
 population estimate.  The percentage change due to other factors is only 32 percent, which is 16
 percentage points lower than the total study population estimate. The primary reason for the
 percentage decrease in quantity due to other factors is the reduction in quantity change due to the
 ammonium sulfate paper change, which was most prominent in the largest increases/decreases
 strata.

 Table  4-13.  Population Estimates with the Largest Increase/Decr-ase Strata Removed:
             Net Quantity Change Attributed to Each Reason, by Industry (million pounds)

SIC
26
27
28
30
33
34
36
37
Other8
Total Change
Percentage
Change
Measurement
Change
1.1
-0.2
0.0
2.5
-1.2
-5.3
1.7
3.9
-30.4
-28.0
4%
Production
Change
1.2
-0.5
-102.7
5.0
22.5
7.4
-0.4
-2.6
-12.2
-82.2
12%
Source
Reduction
-15.2
-5.3
-154.8
-4.9
-52.8
-11.5
-6.6
-35.5
-55.7
-342.3
52%
Other
Factors
-9.3
1.3
-128.3
-9.3
-27.1
-10.6
-14.6
-3.2
-11.6
-212.7
32%
Total
Change
-22.0
-4.7
-385.9
-6.7
-58.6
-20.0
-19.9
-37.5
-109.9
-665.1
100%
alncludes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
/RTi                                     4-20

-------
Table 4-14. Population Estimates with the Largest Increase/Decrease Strata Removed:
            Quantity Increase Attributed to Each Reason, by Industry (million pounds)
Measurement
SIC
26
27
28
30
33
34
36
37
Other8
Total Increase
Percentage
Increase
Percentage of
Population Increase
Change
10.3
0.1
5.1
2.7
3.2
2.6
2.7
6.1
15.8
48.6
7%
59%
Production
Change
8.6
1.0
40.4
11.5
42.7
25.6
5.3
8.9
23.2
167.2
24%
74%
Source
Reduction
0.1
0.1
0.2
0.9
6.2
1.2
2.1
3.7
4.4
18.8
3%
89%
Other
Factors
9.4
3.4
243.3
19.6
39.0
23.3
15.3
22.5
101.9
477.6
67%
55%
Total
Increase
28.4
4.6
288.9
34.8
91.2
52.6
25.3
41.2
145.3
712.1 .
100%
59%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
                                         4-21                                    /mi

-------
Table 4-15.  Population Estimates with the Largest Increase/Decrease Strata Removed:
             Quantity Decrease Attributed to Each Reason, by Industry (million pounds)
Measurement
SIC
26
27
28
30
33
34
36
37
Other8
Total Decrease
Percentage Decrease
Percentage of
Population Decrease
Change
-9.2
-0.3
-5.1
-0.2
-4.5
-7.9
-0.9
-2.2
-46.2
-76.5
6%
73%
Production
Change
-7.4
-1.5
-143.1
-6.5
-20.2
-18.2
-5.7
-11.5
-35.4
-249.3
18%
93%
Source
Reduction
-15.2
-5.4
-155.0
-5.9
-59.0
-12.7
-8.7
-39.2
-60.1
-361.1
26%
88%
Other
Factors
-18.6
-2.0
-371.5
-28.9
-66.2
-33.9
-29.9
-25.7
-113.5
-690.3
50%
53%
Total
Decrease
-50.4
-9.3
-674.7
-41.4
-149.8
-72.7
-45.2
-78.6
-255.2
-1,377.2
100%
66%
"Includes all other industries between 20 and 39 and facilities with more than one 2-digit SIC code between 20 and 39.
                                          4-22

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                                    CHAPTERS

                                   CONCLUSIONS

       This chapter summarizes the results of the study and makes recommendations for future
studies of TRI data submissions.


5.1     SUMMARY OF RESULTS

       The results of this study provide insight on the reasons for changes in TRI submissions

between 1989 and 1990. At least 50 percent of the net change reported represents a real change

in the physical quantity of chemicals released (i.e., production change and source reduction).
The remaining net quantity change results in part from reporting or paper changes and from other
real and paper changes not covered  by our review.

       This study also serves as a first step in measuring source reduction progress. Results can

be used as a baseline for comparison with Pollution Prevention Act data collected as part of the

1991 Form R reporting.  With these new data, EPA will be better able to track and evaluate

source reduction progress from year to year. This type of longitudinal study is critical for

accurately assessing reduction progress because the effects of many prevention activities may not

be evident for several years after implementation.

       The most significant findings from this study are highlighted below:

       • Source reduction activities resulted in a significant reduction of TRI releases and
        transfers. Approximately 40 percent of all facilities attributed some portion of their
        change to source reduction. The estimated net decrease resulting from source reduction
        activities was 387 million  pounds, or 45 percent of the total net decrease. This total
        represents the sum of a 21 million pound increase and a 408 million pound decrease, or
        2 percent of the total quantity increase and 20 percent of the total quantity decrease.

       • Production fluctuation was the most frequently cited reason for change and
        accounted for the largest absolute change.  Nearly 70 percent of all facilities attributed
        some portion of their change to production-level changes.  The quantity decrease
        resulting from production  fluctuation was  268 million pounds which was only slightly
        higher than the 227 million pound quantity increase.  Because these two cancelled each
        other out, the net impact of production change was relatively low, accounting for only 5
        percent of the total net change.

       • Changes in measurement techniques had a relatively small impact.  Only 24 percent
        of all facilities claimed a reporting change due to changes in their measurement or
        estimation techniques. An increase of 82 million pounds and a decrease of 104 million
        pounds were attributed to measurement change.  This resulted in a net quantity decrease
        of 22 million pounds, or less than 3 percent of the total net change.

       • Reported changes include significant amounts of both increases and decreases. The
        aggregate or net quantity change may mask the true impact of each factor because
        quantity increases and decreases cancel each other out. Production change, for
                                          5-1

-------
         example, had a relatively small net decrease of 41 million pounds, yet it had the
         greatest absolute change. Nearly 500 million pounds in increases and decreases were
         the result of production fluctuations. This illustrates the importance of examining
         quantity increases separately from quantity decreases.

       • Most facilities are able to distinguish real from paper changes. Study participants
         were asked to make quantity estimates based on existing knowledge. They were not
         expected to perform additional calculations or estimates in preparation for the
         interview. Still, respondents were able to provide estimates of the quantity change due
         to measurement change, production change, and source reduction for approximately 80
         percent of their Form Rs. Surprisingly, the ability to make quantity estimates did not
         vary significantly between reasons.

       • Accuracy of estimates distinguishing real from paper changes may be low.  Many of
         the study participants made estimates of quantity change by reason for the first time,
         and many based these estimates on best judgment as opposed to engineering
         calculations or measurements. Consequently, accuracy may be low.  Similarly, data
         quality for the Pollution Prevention Act data now required in Form R reporting may be
         low for the first years of reporting these new data elements.  This should be taken into
         account when assessing progress from year to year.

       • Many factors, both real and reporting changes, affect TRI submissions.  This study
         focused on the extent to which three factors—measurement change, production change,
         and source reduction—affected TRI submissions. Although these variables accounted
         for a large portion of the total change, approximately 48 percent of the total change was
         due to ether factors, such as recycling, one-time spills/accidents, company shutdowns,
         and technical guidance. To fully explain the quantity change in TRI submissions, many
         variables would have to be investigated.


5.2    RECOMMENDATIONS FOR FUTURE RESEARCH

       The Pollution Prevention Act data will provide useful information for assessing changes

in reported TRI  submissions, such as the impact of source reduction activities, changes in

estimation and accounting methods, and production ratios. However, EPA's understanding of

changes in TRI submission data will still be limited. As the results of this study show, numerous

reasons explain TRI reporting changes, only a fraction of which are covered by the Form R.

Also, some reporting options, such as the ammonia/ammonium sulfate reporting option, are

unique to each reporting year. Therefore, the Pollution Prevention Act data cannot completely

substitute for seeking additional details from industry.

       Future research involving direct contact with industry representatives can provide

important insight on how facilities are modifying their practices to reduce releases of TRI

chemicals. As a result of this study, the following enhancements are recommended for future

studies of changes in TRI submissions:

       • Ask participants to explain the total quantity change for each Form R submission.
        Ideally, the questions covered by the review should form an equation with the sum of
        responses equalling the total change in TRI submissions. This format would improve


/RTI                                     5-2

-------
  the accuracy of study results and reduce the quantity change falling under the "Other
  Factors" category. The easiest way to collect the data would be with a written
  questionnaire.  Many of the participants in this study said they would prefer a
  questionnaire to the telephone interview process.

• Consider additional source reduction questions.  Participants in this study claiming to
  have source reduction programs were asked to estimate the quantity impact of these
  programs and to identify the types of source reduction activities implemented.  Because
  realizing the results of reduction programs may take several years, asking participants
  when their programs were implemented and when they  first saw or expected to see
  results would be helpful. In addition, knowing which types of source reduction
  activities proved most effective would be helpful.

• Consider other criteria for the sampling design. The sampling plan for this study was
  designed at the facility level with equal allocation across industry and change strata.
  The same sampling design could be used with the Form R, instead of the facility, as the
  unit of selection. This design would be a more accurate way of making selections by
  change strata (because a facility in the increase strata could have many Form Rs
  showing decreases and only one Form R with a very large increase that outweighs the
  decreases).  Sampling at the Form-R level allows specific chemicals such as 33/50
  chemicals to be selected for review.  Other sampling criteria, such as geographic region,
  size of facility, and toxicity of chemicals, should be considered, depending on Agency
  requirements and objectives.

• Consider selecting other groups to be censused. For this study facilities with the
  largest increases and decreases in TRI submissions were censused to identify the factors
  influencing these large quantity changes. Depending on the type of analysis  desired,
  selecting a different subset of facilities to be censused may be helpful. For example,
  using the Pollution Prevention Act data, the review could census facilities  reporting the
  greatest quantity change (absolute and/or relative) due to source reduction. These
  facilities, with proven success in source reduction, may be able to provide
  recommendations and serve as examples for other facilities in their industries. These
  facilities may also be good candidates for EPA's proposed Environmental  Leadership
  Program.

• Conduct further studies on the effects of materials substitution.  Study participants
  claimed an increase due to source reduction for over 7 percent of their Form Rs affected
  by source reduction. The most common reason for this increase was materials
  substitution whereby facilities substituted one (presumably less toxic) chemical for
  another. It would be helpful to assess the characteristics (e.g. risk, hazard) and relative
  quantities of the substitute chemicals.
                                    5-3                                    /RTI

-------
   Appendix A
Mail-Out Materials

-------
                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                WASHINGTON, D.C. 20460



                                MAY  2 9 1992
                                                                        OFFICE OF
                                                                    PESTICIDES AND TOXIC
                                                                       SUBSTANCES
Dear TRI Technical Contact:

       Research Triangle Institute (RTI), a not-for-profit research institution in North Carolina,
has a Cooperative Agreement with EPA's Office of Pollution Pjnevention and Toxics (OPPT) to
conduct research on economic and related methods for improving environmental quality. As part
of this research effort, RTI is reviewing changes in data submitted under Section 313 of the
Superfund Amendments and Reauthorization Act (SARA), also known as the Community Right-to-
Know Act These data are referred to as the Toxic Release Inventory (TRI).

       As part of this research effort, RTI is seeking to clarify changes reported in TRI data
between 1989 and 1990 that were due to:

              •  changes in estimation/measurement methods;
              •  changes in the level of production activity, or
              •  changes in other related factors.

       This facility has been randomly selected to participate in this review. Your participation in
this review is voluntary. In addition, you are not expected to conduct additional measurement
activity; instead, we would like your best estimate based on your 1989 and 1990 submissions.

       A representative of RTI will telephone you to review changes in your TRI data.  You can
expect to be contacted after June 18,1992.  For your convenience in responding to this review,
we have included with this letter copies of the TRI data we currently have for this facility for 1989
and 1990.

       RTI will compile the information collected in this review into a summary report for EPA.
If you are interested in obtaining a copy of this report, please notify the RTI telephone interviewer
and we will send it to you when it becomes available.

       If you have any questions about this review, please call Rachel Baker at RTI at (919) 541-
5847, or Eun-Sook Goidel at EPA at (202)260-3296.

       Thank you for your help in completing this review.

                                              Sincerely,
                                               jerald F. Kotas
                                              Director, Pollution Prevention Division
Attachments)
                                                                          Printed on Recycled Paper

-------
                 Current TRI Data for 1989 and 1990/ by Chemical
 Facility Name:    ACME CHEMICALS,   INC.
 TRI ID Number:    00617ACMCHROAD9
Chemical name: FREON 113
CAS number: 000076131
1990 Quantity
Type of Releases or Transfer (pounds) a
Fugitive or non-point air
emissions
Stack or point air emissions
Discharges to water bodies
Underground injection on-site
Releases to land
Discharge to POTW
Transfers to other off-site
locations
Total Releases and Transfers
32,770
0
0
0
0
0
11,519
44,289
1989 Quantity
(pounds) a
12,104
0
0
0
0
2,339
107
14,550
Change
(pounds) b
20,666
0
0
0
0
-2,339
11,412
29,739
a Quantities reported as rangres are shown as follows;
          range 1 to 10 pounds	5 pounds
          range 11 to 499 pounds 	250 pounds
          range 1 to 499 pounds 	250 pounds
          range 500 to 999 pounds	 750 pounds

b Change  » 1990 quantity - 1989 quantity

-------
                Current TRI Data for 1989 and 1990, by Chemical
 Facility Name:    ACME CHEMICALS, INC.
 TRI ID Number:    00617ACMCHROAD9
 Chemical name:     ETHYLENE OXIDE
 CAS numbers        000075218
1990 Quantity
Type of Releases or Transfer (pounds) a
Fugitive or non-point air
emissions
Stack or point air emissions
Discharges to water bodies
Underground injection on-site
Releases to land
Discharge to POTW
Transfers to other off-site
locations
1,870
748
0
0
0
2,783
0
1989 Quantity
(pounds) *
6,800
2,720
0
0
0
10,118
0
Change
(pounds) "
-4,930
-1,972
0
0
0
-7,335
0
Total Releases and Transfers          5,401         19,638     -14,237
* Quantities reported as ranges are shown as follows:
         range 1 to 10 pounds 	5 pounds
         range 11 to 499 pounds	250 pounds
         range 1 to 499 pounds	250 pounds
         range 500 to 999 pounds	 750 pounds

*> Change *» 1990 quantity - 1989 quantity

-------
                 Current TRI Data for 1989  and  1990, by Chemical
 Facility Name:    ACME CHEMICALS, INC.
 TRI ID Number:    00617ACMCHROAD9
 Chemical name:    1,1,1-TRICHLOROETHANE
 CAS number:       000071556
                                1990 Quantity  1989 Quantity   Change
 Type of Releases  or Transfer    (pounds) *     (pounds) a    (pounds) b
Fugitive or non-point air
emissions
Stack or point air emissions
Discharges to water bodies
Underground injection on-site
Releases to land
Discharge to POTW
Transfers to other off-site
locations

8,900
3,800
0
0
0
0

0

18,000
7,600
0
0
0
0

0

-9,100
-3,800
0
0
0
0

0
Total Releases and Transfers          12,700         25,600     -12,900
a Quantities reported as ranges are shown as follows:
          range 1 to 10 pounds	5 pounds
          range 11 to 499 pounds 	250 pounds
          range 1 to 499 pounds	250 pounds
          range 500 to 999 pounds 	 750 pounds

b Change = 1990 quantity - 1989 quantity

-------
  Appendix B
Interview Script

-------
                              Script for TRI Study




Hello, can I speak with contact person please?
                                                    t
     If not. When would be a convenient time for me to call back?

Hello, this is	with Research Triangle Institute. We're a not-for-profit research
institute in North Carolina.  We're conducting a research study under a cooperative
agreement with EPA. As part of this research effort, we're studying  changes in data
submitted under Section 313 of the Superfund Amendments and Reauthorization Act, or
SARA, also known as the Community Right-to-Know Act. These data are referred to as
the Toxic Release Inventory, or TRI.

Your facility has been randomly selected to participate in this research effort. Your
participation in this study is voluntary. You should have received a letter from EPA
explaining this research study. Did you receive this letter?

     If not. I'd like to send you a second copy of the letter.  Could I get your mailing
     address, please?

We'd like to ask you a few questions about your TRI submissions. Is now a convenient
time?

     If not. What would be a good time for me to call you back?

Great.  The letter we sent included copies of the TRI data we have for your facility. You
might want to pull out these data. It should make answering these questions a little
easier.

I just have a few questions about each chemical for which you submitted TRI data. In
each question, I'll ask about changes between 1989 and 1990 in your releases and
transfers of each chemical.  Please give me your best estimate based on whatever
information you have available; you are not expected to conduct any additional
measurement activities.

Let's take a look at the first chemical I have, chemical name.

For chemical name, did your facility change the estimation or measurement method it
used to calculate its TRI submissions between  1989 and 1990?

     If yes. What's your best estimate of the change in the quantity  of chemical name
     reported in TRI that was due to your change in estimation method?

     Is this an increase or decrease?

For chemical name, did your facility have a change in production levels that changed the
quantity of this chemical released or transferred between 1989 and 1990?

     If yes. What's your best estimate of the change in the quantity  of chemical name
     released or transferred that was due to your change in production levels?

     Is this an increase or decrease?

-------
(Source reduction is any action or technique that reduces or eliminates the amount of a
toxic chemical entering wastestreams or released directly to the environment.  Source
reduction activities do not include actions taken to recycle, treat, energy recover, or
dispose of a toxic chemical once it has entered a wastestream.)

Did your facility's .releases and transfers of chemical name change between 1989 and
1990 due to source reduction activities?                 ,-

     If yes. Which of the following types of source reduction activities were
     implemented for chemical name ?

          a.   equipment or technology modification
          b.   process or procedure modification
          c.   reformulation or redesign of products
          d.   substitution of  raw materials
          e.   improvement in housekeeping, maintenance,
             training, or inventory control
          f.   other source reduction activity


     If yes. What's your best estimate of the change in the quantity of chemical name
     released or transferred that was due to source reduction?

     Is this an increase or decrease?

Now I'd like to look at your next TRI chemical, chemical name  . (Continue asking
questions for all chemicals).

That's it for my questions. Thank you for your time and help. If you have any further
questions about this study, please feel free to call either the EPA or RTI contact listed on
the letter you received.  Good Bye.

-------
 Appendix C
1989 Form Rs

-------
n
(Important: T\oe or print: read instructions before completing form.i
Form Approved OMB No.:  -0^0-0093


       Approval Expires:.
01 91
•|ep FPA U.S. Environmental Protection Agency
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
Section 313 of the Emergency Planning and Community Rlght-to-Know Act of 1966.
also known as Title III of the Suoerfund Amendments and Reauthorization Act
(This space for your optional use.)
PART 1.
R IDENTIFICATION
INFORMATION
1.
Puohc reporting screen tor tnis
collection of information is estimated to
vary from 30 to 34 nours oer resoonse.
wnn an average of 32 nours per
response, including time for reviewing
instructions, searcning existing aata
sources, garnering ana maintaining tne
data neeoea. tna completing ana
reviewing the collection of information.
Send comments regaroing lf.it buraen
estimate or any otner aspect cf tnu
collection of information, .nciuaing
suggestions for reoucing this buroen. to
Chief. information Policy Brancn
(PM-223). US EPA. 401 M St.. SW
Washington. O.C. 20460 Attn: TRI
Buroen and to the Office of Information
and Regulatory Affairs. Office of
Management and Budget Paperwork
Reduction Protect (2070-0093),
Washington. D.C. 20603.
1 . 1 Are you claiming the cnemtcal identity on page 3 trade secret? 1.2 If "Yes* m 1.1. is this copy: 1 .3 Reporting Year
1 J Yes (Answer Question 1. 2: 1 No (Do not answer 1.2: I J Sanitized J Unsanitized 19 	
Attach instantiation forms. 1 Go to Question 1.3. 1 J
2. CERTIFICATION (Read and sign after completing all sections.)
1 hereby certify that 1 havo reviewed the attached document* and that, to the best of my knowledge and belief, the submitted information is true and
complete and that the amounts and values in this reoort are accurate based on reasonable estimates using data available to the preoarars of this report.
Name and official title of owner /operator or senior management official
Signature Date signed
3. FACILITY IDENTIFICATION
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
Facility or Establishment Name
Street Addre**
City County
State Zip Code
TRI Facility Identification Number
WHERE TO SEND COMPLETED FORMS:
1. EPCRA REPORTING
P.O. BOX 23779
CENTER
WASHINGTON, DC 20026-3779
ATTN: TOXIC CHEMICAL RELEASE INVENTORY
2. APPROPRIATE STATE OFFICE (See instructions
in Appendix G)
This report contain* information tor (Check only one) : f 1 f 1
a. 1 J An entire facility b. 1 J Pan of a
facility.
Technical Contact Telephone Number (include area code)
Public Contact Telephone
SIC Code (4 digit)
a. b. c.
Latitude
Degrees Minute* Second*
Dun & Braostreet Number!*)
a.
EPA Identification Number)*) (RCRA I.O. No. )
a.
NPOES Permit Number!*)
a.
Receiving Streams or Water Bodies (enter one name per box)
a.
c.
e.
Underground Injection Well Code (U1C) Identification Number (s)
a.
d. e.
Number (include area code)
f.
Longitude
Degree* Minute* Seconds
b.
b.
b.
b.
d.
1.
b.
4. PARENT COMPANY INFORMATION
4.1
Name of Parent Company
Parent Company'* Dun &
Bradstreet Number
EPA Form 9350-1 (1-90) Revised - Do not use previous versions.

-------
 n
 (Important:  Type or print; read instructions before completing form.)
                                                                                             n
                                                                                     Page 2 of 5
n (This space (or your optional use.)
A r-nA EPA pORM «•
C* trA PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.1 POTW name
Street Address
City
Slat*
County
Zip
1.2 POTW name
Street Address
City County
Slat* Zip
2. OTHER OFF-SITE LOCATIONS (Do NOT REPORT LOCATIONS TO WHICH WASTES ARE SENT ONLY FOR RECYCLING OR REUSE).
2.1 Off-site location name
EPA Identification Number (RCRA lO. No. )
Street Address
City
StaM
County
Zip
It location under control of reporting facility or parent company?
[ ]v.s [ ]NO
2.2 Off-site location name
EPA Identification Number (RCRA ID. No. )
Street Address
City. County
State Zip
It location under control of reporting facility or parent company?
[ IY.. [ ]NO
2.3  Off-site  location name
                               2.4  Off-site location name
EPA Identification Number (RCRA ID. No.)
                              EPA Identification Number (RCRA ID. No.)
Street Address
                                                                     Street Address
City
County
City
County
Slat*
                                       Zip
                                                                     State
                                                                    Zip
is location under control of reporting facility or parent company?
                              Is location under control of reporting facility or parent company?
                                                                        [  U    [   ]
                                                                                                                                No
2.5  Off-site location name
                               2.6  Off-site location name
EPA Identification Number (RCRA ID. No.)
                                                                    EPA Identification Number (RCRA ID. No.)
Street Address
                                                                    Street Address
City
                                       County
                              City
                                                                                                          County
State
                                       Zip
                                                                    State
                                                                                                          Zip
is location under control of reporting facility or parent company?
[   1 Chock if additional pages of Part n ar« attached. How many?
•^«B^M
 EPA Form 9350-1 (1-90) Revised - Do not use previous  version*.
                                                                    is location under control of reporting facility or parent company?

-------
(Important:  Type  or print; read instructions before completing form.)
                                                                                                               D
                                                                                                        Page 3 of 5
   SEPA
                                        EPA FORM R

                       PART III.  CHEMICAL-SPECIFIC INFORMATION
                                                                                        (This space for your optional use.)
 1. CHEMICAL IDENTITYtDo not complete this section if you complete Section 2.)
 1.1
  [Reserved)
 1.2
       CAS Number (Entor cmiy on* numMr exactly at it appears on the 313 list.  Enter NA if reporting a chemical category.)
 1.3
      Chemical Or Chemical Category Name (Enter only on* name exactly at it appears on in* 313 list.)
 1.4
      Generic Chemical Name (Complete only if Part I. Section 1.1 n cn*cK*d "Yes." Generic name mutt be structurally Descriptive.)
      MIXTURE COMPONENT IDENTITY (Do not complete this section if you complete Section 1.)
 2.
      Generic Chemical Name Provided by Supplier (Limit th* name to a maximum of 70 characters (e.g., numbers, letters, spaces, punctuation).)
 3.  ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY  (Check all that apply.)
3.1
      Manufacture the
      chemical:
                     a. I  J Produce

                     b. [  ] Import
                                                   If produce or import:
                                                         [1 For on-site
                                                         J use/processing

                                                     e.[  J As a  byproduct
                                                       . f  1 For sale/
                                                      °-l  J distribution

                                                      f. I  J As an impurity
3.2
      Process the

      chemical:
                     a. [  J As a reactant ""

                     d.[  J Repackaging only
                                                      T .lAs a formulation-
                                                     '•I  •! component
                                                           II As an article
                                                           J component
3.3
 Otherwise use

 the chemical:
                               [1 As a chemical
                               J processing aid
                       ,[  1
                                                           As a manufacturing aid
..[  1
Ancillary «r other use
 4.  MAXIMUM AMOUNT OF THE CHEMICAL ON-SITE AT ANY TIME DURING THE CALENDAR YEAR
           (enter code)
 5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
 You may report releases of less than
 1.000 pounds by checking ranges under A.1.
 (Do not use both A.I and A.2)
S.I Fugitive or non-point air emissions
S.2 Stack or point air emissions
5.3 Discharges to receiving
    streams or water bodies  s-3
    (Enter letter cod* for stream
    from Pan I Section 3.10 In
    the box provided.)
   ,D

S.3.,D

5.3.3 Q
S.4  Underground Injection on-slte
S.5  Releases to land on-slte

     S.S.I  Landfill


     5.5.2  Land treatment/application farming



     S.S.3  Surface impoundment



     5.5.4  Other disposal
                                      5.1a
                                           5.2a
                                         5.3.1a
                                    5.3.2a
                                         5.3.3a
                                           S.4a
                                    5.5.la
                                    S.S.2a
                                    5.5.3a
                                    5.5.4a
                                                           A. Total Release
                                                             (pounds/year)
                                                     A.1
                                               Reporting Ranges
                                              I     1-409  500-909
                                                                            A.2
                                                                            Enter
                                                                          Estimate
                                                                                     B. Basis of
                                                                                       Estimate
                                                                                            (enter code)
                                                                                       S.2b
                                                                                      5.3.1b  I	I
                                                                                          5.3.2b
                                                                                      S.3.3b
                                                                                            5.4b
                                                                                      5.5.1b
                                                                                          S.Sr2b
                                                                                      5.5.3b
                                                                                      5.5.4b
[   1
(Chick if additional information is provided on Part rv-Supplemental Information.)
 EPA Form 9350-1  (1-90) Revised - Do not use previous versions.

-------
 D
(Important:  Type or print: read instructions before completing form.)
                                                                                                           D
                                                                                                    Page 4 of 5
                                        EPA
                        PART III.  CHEMICAL-SPECIFIC INFORMATION
                                         (continued)
                                                                                    (This space for your optional use.
  6.  TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS  .
 You may report transfers
 of less than 1.000 pounds by
 checking ranges under A.I.  (Do
 not use both A.I and A.2)
  6.1.1
       Discharge to POTW   ,—, ,—,
       (enter local ion numoor I  , I I
    lentei  	   _  _
    from Part II. Section
       Other off-tit* location  ,	
  ... (enter location number  I  ,
  0.2.1 from P«rt n. Section 2.) |  * i
       Other ott-*ite location
 _ _ . (enter location numeer
 6.2.2 from Part n. Section 2.]
       Other off-site location
       (enter location numoer
 6.2.3 worn Pan a. Section:.)
                                        A. Total Transfers
                                           (pounds/year)
                                       A.I
                                 Reporting Ranges
                                0     1-498   500-088
                 [   ]   [
[][][]
                                              A.2
                                              Enter
                                            Estimate
                                                                          B. Basis of Estimate
                                                                             (enter code I
                                                                             C.Type of Treatment/
                                                                                    Disposal
                                                                                                (enter code)
                                                            3.Mb  I	I
                                                                          S.2.1b LJ
                                                                         6.2.2b
                                                                   D
                                                                         6.2.3b
                                                                   n
                                                                    6.2.2C I M|  II
                                                                    6.2.3c|M|
  [   ](Check If additional Information Is provided on Part IV-Supplemental Information.)
  7. WASTE TREATMENT METHODS AND EFFICIENCY

       [I Not Applicable (NA)  - Check if no on-site treatment is applied to any wastestream containing the chemical or chemical
       J          	category.
 A. General
    Wastestream

  (enter code)
                   B. Treatment
                      Method

                    (enter code)
                          C. Range of
                             Influent
                             Concentration
                             (enter code)
                                 D. Sequential
                                    Treatment?
                                    (check If
                                    applicable)
                                           E. Treatment
                                              Efficiency
                                              Estimate
                                                F. Based on
                                                   Operating
                                                   Data?
                                                  '   Yes     No
 7.la
      D
                          7.1c
                 7.Id
                                       [   ]
                                         7.1e
                                                    [   ]  [    ]
 7.2a
      D
        rrn
                7.2c
                         7.2d
                 I   )
                                 7.2e
                  7 2f    I   ]  [    ]
 7.3a
      n
7.3b
                7.3c
                         7.3d
                           7.3e
                                                          i   j  t   i
 7.
"    D
7.4b
n
        7.4c
D
                7.4d
7.4e
i   i i
 7.5a
      D
7.5b
                7.5c
                         7.5d
                           7.5e
                                                   7
 7.6a
                                       7.6c
                                          7.6d
                                                 7.6e
                                                           7 6'    I   I  [   ]
 7.7a
              7.7b
                          7.7c
                      D
                7.7d
                                         7.7e
                                             7 7f    MM
 7.8a
                                       7.8c
                                D
                                7.8d
                                                                           7.Be
                                                                  (
 7.9a
      D
        rm
                7.9c
                        7.9d
                                                                           7.9e
                                             7 9f    [   I  [   I
 7.10a
      n
7.10b
7.10c
                                7.10d
                                [    1
                                                                           7.10e
                                                                             7.10f
                                                    [   ]
  [    ] (Check If additional Information Is provided on Part IV-Supplemental Information.)
  8.  POLLUTION PREVENTION:  OPTIONAL INFORMATION ON WASTE MINIMIZATION
   (Indicate actions taken to reduce the amount of the chemical being released from the facility.  See .the Instructions for coded
   Items and an explanation of what Information to include.)
 A.  Type of
     Modification
     (enter code)
                   B.  Quantity of the Chemical in Wastes
                       Prior to Treatment or Disposal
                                                                               C.  Index
                                                                            D.  Reason for Action
                                                                                 (enter code)
                   Current
                   reporting
                   year
                   (pounds/year)
                                    Prior         I
                                    year         I
                                    (pounds/year) t
                                                 (
                                      Or percent change
                                      (Check (+) or (-))
                                                                            D.I
EPA Form 9350-1  (1-90) Revised - Do not use previous versions.

-------
 (Important: Type or print; read instructions before completing form.)
                                                                                              Page 5 of 5
     PDA
     •— rA*
                                   EPA FORM R
                     PART |v.  SUPPLEMENTAL INFORMATION
       Use this section If you need additional space for answers to questions in Part III.
    Number the lineo used sequentially from lines in prior sections (e.g.. 5.3. 4. 6.1.2. 7.11)
                                                                             (This space for your optional use.;
 ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
 (Part III. Section 5.3)
You may report releases of less than
1.000 pounds by checking ranges under A.I.
(Do not use both A.1 and A.2)
                                                     A. Total Release
                                                        (pounds/year)
                                                  A.I
                                             Reporting Ranges
                                            0     1-*99   SOO-999
                                                                    A. 2
                                                                    Enter
                                                                   Estimate
                                          B. Basis of
                                            Estimate

                                          (enter code
                                            in box
                                           provided)
                                                                                           C.% From
                                                                                            Stormwater
 5. 3 Discharges to
    receiving streams or
    water bodies

    (Enter letter cod* lor stream
    from Pan 1 Section 3. 10 In
    the box provided. )
                        5.3
                           _D
                                   5.3
                                          .3 __ bl_
                                                                                           5.3. _ c
                                   5.3
                1   1   i
                                                                              5.3.
                                      5.3._c
                                   5.3 -- a
                                                                               5-3.
                                                                                           5.3.
                                                                                               _c
 ADDITIONAL INFORMATION ON TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
 (Part III. Section 6)
 You may report transfers
 of less than 1 .000 pounds by checking
 ranges under A.I .  (Do not use
 both A.I and A. 2)
  6,
  .1 •
        Discharge to POTW   .	, .	.
        (enter, location number  I i
        from Part 1. Section
       Other off-site location
f y     (enter location number
°'*-	from Part I. Soctlon 2.)
                                         A. Total Transfers
                                          (pounds/year)
                                      A.1
                                 Reporting Ranges
                                 0     1-4M  500-998
                     A. 2
                     Enter
                   Estimate
                                                                         B. Basis of
                                                                           Estimate
                                                                          (enter code
                                                                             in box
                                                                           provided)
                                                C. Type of Treatment/
                                                       Disposal
                                      (enter code
                                         in box
                                        provided)
                                                                        6.1.
                                                                        6.2.
        Other off-site location
                                                                        6.2.
       Other off-site location  •	1
  69     (enter location number  I y
 •*•	from Part R.  Saction 2.) I  I
                                                                        6.2.
  ADDITIONAL INFORMATION ON WASTE TREATMENT METHODS AND EFFICIENCY (Part III. Section 7)
 A. General
   Wastestream
  (enter code
 in box provided)
                   B. Treatment
                     Method
                    (enter code
                   In box provided)
 C. Range of
   Influent
   Concentration
   (enter code)
                                                      D. Sequential
                                                        Treatment?
                                                        (check If
                                                        applicable)
                 E. Treatment
                    Efficiency
                    Estimate
  F.  Based on
     Operating
     Data?
       Yes    No
  — -D
                                                      —-[
  _-a
                    _*  r m
 —c  a
                                                          --[
                                •—'[   ][
  —•a
              7.	b  rrn
 •—•  n
                                                      •—-[

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                                                      .	d[
                                                —'i   ii   i
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                                                      .	d[
               7._b  LID
                                       •:—•  D
                —-[
                                                                                     .	f [
7.
        a
              7.
7.
7.	d[
	'[
EPA Form 9350-1 (1-90) Revised - Do not use previous versions.

-------
 Appendix D
1990 Form Rs

-------
D
(Important: Type or print; read instructions before completing form.)
                                                                         Form Approved OMB No.:  2070-0093

                                                                                 Approval Expires:	01/94
                                                       D
                                                                                                                Page 1 of 5
      C?DA   U.S. Environmental Protection Agency
      TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
      Section 313 of the Emergency Planning and Community Rlght-to-Know Act of 1986,
      also known as Title III of the Super-fund Amendments and Reauthortzatlon Act	
  EPA  FORM
                          PART I.

                         FACILITY
                      IDENTIFICATION
                       INFORMATION
                                                         (This space for your optional use.)
                          Public  reporting  burden  for  this
                          collection of information is estimated to
                          vary from 30 to 34 hours per response,
                          with  an average of  32 hours par
                          response, Including time for reviewing
                          instructions,  searching existing data
                          sources, gathering and maintaining the '
                          data  needed,  and completing  and
                          reviewing the collection of information.
                          Send comments regarding this burden
                          estimate or any other aspect of this
                          collection  of   information,  Including
                          suggestions for reducing this burden, to
                          Chief,  Information   Policy   Branch
                          (PM-223), US EPA. 401  M St., SW,
                          Washington, O.C. 20460  Attn:  TRI
                          Burden and to the Office of Information
                          and  Regulatory  Affairs,  Office of
                          Management .and  Budget Paperwork
                          Reduction    Project   (2070-0093),
                          Washington, D.C. 20603.
 1.
1.1  Are you claiming the chemical identity on page 3 trade secret?


     I   I Yes (Answer question 1.2;     [  J No (Do not answer 1.2;
	Attach substantiation forms.)	Go to question 1.3.)
  1.2  If 'Yes" In 1.1, is this copy:


       [   J Sanitized [   \ Unsanltlzed
1.3  Reporting Year


      19	
 2. CERTIFICATION (Read and sign after completing all sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted Information is true and
complete and that the amounts and values In this report are accurate based on reasonable estimates using data available to the preparers of this report.
 Name and official title of owner/operator or senior management official
 Signature
                                                                                   Date signed
 3.  FACILITY IDENTIFICATION
 3.1
      Facility or Establishment Name
      Street Address
      City
      State
                                        County
                                              Zip Code
      TRI Facility Identification Number
  WHERE TO  SEND COMPLETED FORMS:


1. EPCRA REPORTING CENTER

   P.O.  BOX 23779

   WASHINGTON,  DC  20026-3779
   ATTN:  TOXIC CHEMICAL RELEASE INVENTORY
                                                            2.  APPROPRIATE STATE OFFICE (See instructions
                                                               in Appendix G)
 3.2
      This report contains Information for (Check only one):
                                            . [   J An entire facility       b.  [  J Part of
                                                                                         a facility.
 3.3
      Technical Contact
                                                                                  Telephone Number (Include area code)
 3.4
      Public Contact
                                                                                  Telephone Number (include area code)
 3.5
SIC Code (4 digit)

a.
                          b.
                                                                  d.
                           Latitude
                                                                                         Longitude
 3.6
              Degrees
                              Minutes
                                              Seconds
                                                                  Degrees
                                                                                        Minutes
                                                                                                            Seconds
 3.7
Dun & Bradstreet Number(s)

a.
 3.8
EPA Identification Number(s) (RCRAI.D. No.)

a.
 3.9
      NPDES Permit Number(s)
      Receiving Streams or Water Bodies (enter one name per box)

      a.
 3.10
 3.11
      Underground Injection Well Code (UIC) Identification Number(s)
4.  PARENT COMPANY INFORMATION
 4.1
      Name of Parent Company
                                                            4.2
                                                                       Parent Company's Dun & Bradstreet Number
 EPA Form 9350-1 (Rev. 1-91) - Previous editions are obsolete.

-------
 D
 (Important: Type  or print; read instructions before  completing form.)
                                                                                                                                     D
__. ___. D (This space for your optional use.)
A CBA EPA FORM •»
t* CKA PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
CHEMICALS ARE TRANSFERRED IN WASTES
1 . PUBLICLY OWNED TREATMENT WORKS (POTWs)
1.1 POTW name


State
County
Zip
1.2 POTW name
Street Address
City County
State Zip
2. OTHER OFF-SITE LOCATIONS (DO NOT REPORT LOCATIONS TO WHICH WASTES ARE SENT ONLY FOR RECYCLING OR REUSE).
2.1 Off-site location name
EPA Identification Number (RCRA ID. No. )
Street Address
City
State
County
Zip
Is location under control of reporting facility or parent company?
1 J Yes L J N°
2.2 Off-site location name
EPA Identification Number (RCRA ID. No. )
Street Address
City County
State Zip
Is loto.ion under control of reporting facility or parent company?
I JYes I JNo
 2.3  Off-site location name
                                                                     2.4  Off-site location name
 EPA Identification Number (RCRA ID. No.)
                                                                    EPA Identification Number (RCRA ID. No.)
 Street Address
                                                                    Street Address
City
                                      County
                                                                    City
                                                                                                           County
State
                                      Zip
                                                                    State
                                                                                                           Zip
Is location under control of reporting facility or parent company?


                                            [   JYes
                                                              NO
                                                                    Is location under control of reporting facility or parent company?


                                                                                                                [   IY.S     [   ]
No
2.5  Off-site location name
                                                                     2.6  Off-site location name
EPA Identification Number (RCRA ID. No.)
                                                                    EPA Identification Number (RCRA ID.  No.)
Street Address
                                                                    Street Address
City
                                      County
                                                                    City
                                                                                                           County
State
                                      Zip
                                                                    State
                                                                                                           Zip
Is location under control of reporting facility or parent company?
                                                                    Is location under control o. reporting facility or parent company?



                                                                                                                I   jYes     I   JNO
[   1
     Check it additional pages of Part II are attached. How many?
 EPA Form 9350-1  (Rev.1-91)  - Previous editions are obsolete.

-------
n
 (Important: Type or print; read instructions before completing form.)
                                                                                                                     D
                                                                                                             Page 3 of 5
                                            EPA FORM
                           PART 111. CHEMICAL-SPECIFIC INFORMATION
                                                                                        
-------
 D
(Important: Type or print; read instructions before completing form.)
                                                                                                                  D
                                                                                                          Page 4 of 5
      ft EPA
                                        EPA FORWl

                      PART III.  CHEMICAL-SPECIFIC INFORMATION
                                         (continued)
                                                                                      (This space for your optional use.)
  6. TRANSFERS OF THE CfHEMICAL IN WASTE TO OFF-SITE LOCATIONS
  You may report transfers
  of less than 1,000 pounds by
  checking ranges under A. 1.  (Do
  not use both A.1  and A.2)
     Discharge to POTW    .—. .	
     (enter location number    .
6.1.1 from Part II, Section 1.) |  1 |-|	
       Other off-site location
    60  , (enter location number
   .2.1 from Part II. Section 2.) |
     Other off-site location  .	.  .
. . . (enter location number  I  9
6.2.2 from Part II, Section 2.) I   II
  6.2.3
Other off-site location  ,
 ienter location number
    Part II, Section 2.)
       (ente
       from
                                           A. Total Transfers
                                               (pounds/yr)
                                          A.1
                                    Reporting Ranges
                                  1-10    11-499  500-999
t   1   I   1   [   1
                                                               A.2
                                                               Enter
                                                             Estimate
                                                                              B. Basis of Estimate
                                                                                 (enter code)
                                                                                                C.Type of Treatment/
                                                                                                        Disposal
                                                                                5.1.1b  I	I
                                                                              3.2.1b LJ
                                                                                6.2.2b
                                                                                     D
                                                                              6.2.3b
                                                                                     D
  [   ] (Check if additional information is provided on Part IV-Supplemental Information.)
  7.  WASTE TREATMENT METHODS AND EFFICIENCY
         DNot Applicable (NA) - Check If no on-site treatment Is applied to any waste stream containing the chemical or chemical
                              catagory
 A. General
    Wastestream

   (enter cocL)
                    B. Treatment
                       Method

                      (enter code)
                                           C. Range of
                                             Influent
                                             Concentration
                                          	(enter code)
                                                       D. Sequential
                                                          Treatment?
                                                          (check If
                                                          applicable)
                                              E. Treatment
                                                Efficiency
                                                Estimate
                                        F. Based on
                                           Opera'ting
                                           Data?
                                             Yes     No
 7.!a
        D
               7.1b
                                     7.1c
                D
7.1d
          7.1e
                   7.1f
 7.2a
        D
               7.2b
                                     7.2c
                D
7.2d
          7.2e
                   7.2f
 7.3a
        D
               7.3b
                                     7.3c
                D
7.3d
[   I
7.3e
7.3f
[   ]  [
 7.4a
       D
                                          7.4c
                                           D
                          7.4d
                  7.4e
                             7.4f
                           MM
 7.5a
       D
               7.5b
                                     7.5c
                D
7.5d
          7.5e
                                     7.5f
                           [   ]  [
 7.6a
       D
               7.6b
                                     7.6c
                D
7.6d
          7.6e
                                                                                                  7.6f
 7.7a
               7.7b
                                          7.7c
                                           D
                          7.7d
                  7.7e
                                                                                                 7.7f
 7.6a
       D
               7.8b
                                     7.8c
                                                             7.8d
                                  [   I
                                                                             7.Be
                                                                                                  7.8f
 7.9a
       D
               7.9b
                                     7.9c
                          7.9d
                                                                              7.9e
                                                                                                 7.9f
 7.10a
       D
               7.10b
                                     7.10c
                D
                                                             7.10d
        [
                                                                             7.10e
                                                                                                  7.10f
                                     I    ]  [   ]
  [    ](Check If additional Information is provided on Part IV-Supplemental Information.)
  8.  POLLUTION PREVENTION: OPTIONAL INFORMATION ON WASTE MINIMIZATION
    (Indicate actions taken to reduce the amount of the chemical being released from the facility.  See the instructions for coded
   Items and an explanation of what Information to Include.)
  A. Type of
     Modification
     (enter code)
                  B.  Quantity of the Chemical In Wastes
                      Prior to Treatment or Disposal
                                                                                  C.  Index
                                                                                               D.  Reason for Action
                                                                                                    (enter code)
   M
                       Current         Prior
                       reporting        year
                       year            (pounds/year)
                       (pounds/year)
                                                        Or percent change
                                                        (Check (+) or (-))
                                                   D +
                                                   D-
EPA Form 9350-1 (Rev. 1-91) - Previous editions are obsolete.

-------
 (Important: Type or print; read instructions before completing form.)
                                                                                                        Page 5 of 5
      EPA
                                       EPA FORM R
                       PART IV.  SUPPLEMENTAL INFORMATION
        Use this section If you need additional space for answers to questions in Part III.
    Number the lines used«sequentially from lines In prior sections (e.g., 5.3.4. 6.1.2, 7.11)
                                                                                     (This space for your optional use.)
 ADDITIONAL INFORMATION ON RELEASES OF THE CHEMICAL TO THE ENVIRONMENT ON-SITE
 (Part III, Section 5.3)
 You may report releases of less than
 1,000 pounds by checking ranges under A.I.
 (Do not use both A.I and A.2)
                                                          A.  Total Release
                                                              (pounds/yr)
                                                       A.1
                                                 Reporting Ranges
                                                1-1Q    11-499  500-999
                                                                           A.2
                                                                           Enter
                                                                         Estimate
                                                                                        B.  Basis of
                                                                                           Estimate

                                                                                        (enter code
                                                                                           in box
                                                                                          provided)
                                                                                                    C.% From
                                                                                                      Stormwater
5.3 Discharges to
    receiving streams or
    water bodies          5-3-

    (Enter letter code from Part I
    Section 3.10 for stream(s) In c 3
    the box provided.)          •».».
                          5.3.
                                       5.3	a
                                                                                       5.3..
                                                                                              .JH
                                                                                                     5.3..
                                       5.3	a
                                                                                       5.3.
                                                                                                     5.3..
                                      5.3	a
                                                                                       5.3.
                                                                                                     5.3.
 ADDITIONAL INFORMATION ON TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
 (Part III, Section 6)
 You may report transfers
 of less than 1,000 pounds by checking
 ranges under A.1.  (Do not use
 both A.1 and A.2)
6.1.
         Discharge to POTW    ,	. ,	.
         (enter location number  I  , 1 I   I
        . from Part II, Section
        Other oft-slte location
         (enter location number
        from Part II, Section 2.)
                                            A.Total Transfers
                                               (pounds/yr)
                                          A.1
                                    Reporting Ranges
                                     1-10   11-499 500-999
                                                                 A.2
                                                                 Enter
                                                               Estimate
                                                                                B. Basis of
                                                                                   Estimate
                                                                                  (enter code
                                                                                     In box
                                                                                   provided)
                                                                                               C. Type of Treatment/
                                                                                                      Disposal
                                                                                                     (enter code
                                                                                                        in box
                                                                                                       provided)
                                                                               6.1.
                                                                               6.2.
         Other off-site location  i	1
 6.2.     (enter location number    2
    	from Part II,  Section 2.) I—i
                                                                               6.2.
         Other off-site location  (
         (enter location number
         from Part II,  Section 2.)
                                                                               5.2.	b EH  6-2-	'
  ADDITIONAL INFORMATION ON WASTE TREATMENT METHODS AND EFFICIENCY (Part III, Section 7)
 A. General
   Wastestream
  (enter code
 In box provided)
                     B. Treatment
                       Method
                      (enter code
                     In box provided)
                                           C. Range of
                                             Influent
                                             Concentration
                                             (enter code)
                                                            D. Sequential
                                                               Treatment?
                                                               (check if
                                                               applicable)
                                                                              E. Treatment
                                                                                Efficiency
                                                                                Estimate
                                                                                  F. Based on
                                                                                     Operating
                                                                                     Data?
                                                                                        Yes
                                                                                                                No
7.
          D
7.
7.
                                                    D
                                                                 --[    1
                                                                                                     •[   ][   1
7.
                7.
                          7.
                                                    D
                                                            •—-t   1
                                                                                               .	•[   it   l
7.
          D
                                          7.
                                                    D
                                                                                                    -
-------