United States
Environmental Protection
Agency
Office of Pollution Prevention
and Toxics
(TS-799)
EPA/745-R-93-004
July 1993
oEPA PROCEEDINGS
Toxics Release Inventory (TRI)
Data Use Conference
March 29-31,1993
Chicago, Illinois
Sponsored by the
U.S. Environmental Protection Agency
in conjunction with
Synthetic Organic Chemical Manufacturers Association (SOCMA)
National Electrical Manufacturers Association (NEMA)
National Association of State Title III Program Officials (NASTTPO)
Center for the Great Lakes (CGL)
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Disclaimer
Publication does not signify that the contents necessarily reflect the views and policies of the
US I nvlronmontol Protection Agency or of any other organization represented In these
proceedings. Mention of trade names and commercial products does not constitute endorsement
of their uso
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Toxics Release Inventory (TRI)
Data Use Conference
Proceedings
U.S. Environmental Protection Agency
Office of Pollution Prevention and Toxics (TS-799)
Washington, DC 20460
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1993 TRI DATA USE CONFERENCE
Table of Contents
Acknowledgement i
Introduction iii
Conference Overview v
Plenary Session vi
Break-Out Sessions vii
Demonstrations and Exhibits viii
Plenary Session Speeches 1
Track and Session Summaries
State Programs Track 39
Session 1: Building a State Program, Part I 41
Session 2: Building a State Program, Part n 45
Session 2: EPA-State TRI Partnership 49
Session 4: State Use of TRI Data 61
Data Presentation Track 81
Session 5: Federal and State Waste Minimization
Data Collection 83
Session 6: Use and Interpretation of Federal and
State Waste Minimization Data Collection 89
Session 7: Future TRI Initiatives 109
Session 8: Presentation of the Annual EPA Data Release 121
Session 9: Presentation of the Data to the Public 133
Data Integration Track 145
Session 10: Integration of TRI Data with Other Agency Programs 147
Session 11: Role of Data Integrity Through Compliance
and Enforcement 161
Session 12: Integration of TRI With Other Data Sources 169
Session 13: Integrated Data for Enforcement Analysis (IDEA) 181
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1993 TRI DATA USE CONFERENCE
Track and Session Summaries, continued
Data Application Track 189
Session 14: TRI Links with Voluntary Reporting and
Reduction Programs 191
Session 15: Risk Screening 201
Session 16: Local Use of TRI Data 233
Session 17: Public Use of TRI 251
Session 18: EPA's Geographic Initiative 259
Closing Session 279
Attendee List 283
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1993 TRI DATA USE CONFERENCE
ACKNOWLEDGEMENT
EPA Conference Coordinator: Eileen Gibson, Office of Pollution Prevention and Toxics
EPA Track Coordinators
State Programs:
Data Presentation:
Data Integration:
Data Application:
Eileen Fesco, 17.5. EPA
Ken Mitchell, U.S. EPA
Andrew Wheeler, U.S. EPA
Loren Hall, U.S. EPA
Break-Out Session Coordinators
Tim Crawford, U.S. EPA
Cindy DeWulf, OH EPA
Maria Doa, U.S. EPA
Jan Erickson, U.S. EPA
Eileen Fesco, 17.5. EPA
Joe Goodner, ZL EPA
Loren Hall, U.S. EPA
Sarah Hammond, 17.5. EPA
Steve Hanna, CA EPA
Arnie Kuzmack, U.S. EPA
Gerald Lappan, U.S. EPA
Dorothy McManus, U.S. EPA
Dave Sarokin, U.S. EPA
Sam Sasnett, U.S. EPA
Agenda Steering Committee Members
Allen Amberg, Ford Motor Co.,
Motor Vehicle
Manufacturers Association
Doug Bannerman, National
Electrical Manufacturers
Association
George Bonina, U.S. EPA
Jim Craig, U.S. EPA
Denise Devoe, U.S. EPA
Cindy DeWulf, OH EPA
Jan Erickson, U.S. EPA
Bob Fentress, U.S. EPA
Eileen Fesco, U.S. EPA
Jon Fogarty, £7.5. EPA
Cindy Fournier, U.S. EPA
Ken Geiser, University of
Massachusetts-Lowell
Eileen Gibson, 17.5. EPA
Joe Goodner, ZL EPA
Chris Grundler, Great Lakes
National Program Office
Steve Hanna, CA EPA
Lynne Harris, Society of
Plastics Industries
Bob Hogner, Florida
International University
Fran Irwin, World Wildlife Fund
Arnie Kuzmack, U.S. EPA
Lynn Mackey, Waste Reduction
Institute for Training and
Applications Research, Inc.
Dorothy McManus, U.S. EPA
Kim Mitchell, Abt Associates Inc.
Cheryl Morton, Synthetic Organic
Chemical Manufacturers
Association
Paul Orum, Working Group on
Community Right-to-Know
Dwight Peavey, U.S. EPA
Gerald Poje, National Institute
of Environmental Health
Chris Prins, U.S. EPA
Anning Smith, 17.5. EPA
Hank Topper, 17.5. EPA
Julie Vanden Bosch, 17.5. EPA
Dennis Wesolowski, £7.5. EPA
Andrew Wheeler, £7.5. EPA
Steve Young, £7.5. EPA
Theresa Pugh, American
Electronics Association
Daniel Reck, Abt Associates Inc.
Phyllis Reed, £7.5. EPA
Steve Ross, Columbia University
Graduate School of Journalism
Niki Roy, Environmental Defense Fund
AlRush, £7.5. EPA
Dave Sarokin, £7.5. EPA
Sam Sasnett, £7.5. EPA
Bob Styles, Waste Reduction Institute
for Training and Applications
Research, Inc.
Neil Taylor, UT EPA
Lauren Traister, Abt Associates Inc.
Julie Vanden Bosch, £7.5. EPA
Dennis Wesolowski, £7.5. EPA
Andrew Wheeler, £7.5. EPA
Steve Young, £7.5. EPA
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1993 TRI DATA USE CONFERENCE
11
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1993 TRI DATA USE CONFERENCE
INTRODUCTION
The 1993 TRI Data Use Conference was held on March 29-31, 1993, in Chicago,
Illinois. The conference was sponsored by the U.S. Environmental Protection Agency in
conjunction with the Synthetic Organic Manufacturers Association (SOCMA), the National
Electrical Manufacturers Association (NEMA), the National Association of State Title HI
Program Officials (NASTTPO), and the Center for the Great Lakes.
The conference was successful in bringing together representatives from federal, state and
tribal agencies, the international community, environmental groups, academia, industry, labor,
and the news media. Consequently, the broad range of perspectives and experiences of the
panelists and audience resulted in discussions that were both exciting and informative.
The conference provided an opportunity for EPA to examine the impact of TRI on its
users, i.e. how the data are used, applied, and presented. The Agency will be reviewing all of
the comments and suggestions that were made during the conference and will try to incorporate
these ideas into any future TRI policy/program changes.
The Tuesday break-out sessions were the heart of the meeting and generated a great deal
of discussion and new ideas. Each session focused on one of the four track themes (state
programs, data presentation, data integration, and data application). In addition, each session
addressed the larger issue of "Where Do We Go From Here?", that is, what should be the future
direction of the TRI program? Thanks to the hard work of our track leaders, session
coordinators, and panelists, these sessions provided valuable insight into how the data can be
used and how EPA and States can improve their program. An overview of each track, along
with session summaries and panelists comments are provided in these proceedings.
We were pleased to see the enthusiasm that participants have for the TRI program. It
is our hope that this conference will lead to further exchanges of ideas and to more effective uses
of the TRI data. We hope that these proceedings will be a valuable reference.
usan Hazen Linda Travers
Director, Environmental Assistance Division Director, Information Management Division
U.S Environmental Protection Agency U.S. Environmental Protection Agency
m
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1993 TRI DATA USE CONFERENCE
IV
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1993 TRI DATA USE CONFERENCE
CONFERENCE OVERVIEW
In an effort to promote communication and to discuss the
future direction of the Community Right-to-Know programs, the
1993 Toxics Release Inventory (TRI) Data Use Conference was
held on March 29-31, 1993, in Chicago, Illinois. This conference
brought together representatives from federal, state, and tribal
agencies; the international community; environmental groups;
academia; industry; labor; and the news media. Speakers and
panelists articulated the ways in which TRI data were being used,
as well as what improvements need to be made to increase TRI's
future impact.
The conference was successful in meeting all of the U.S. EPA's
goals:
• To continue to foster and strengthen the links between TRI
managers and the managers of other environmental programs
at the federal and state level;
• To increase awareness of the diverse uses and applications of
TRI reporting;
• To expand the network of TRI users;
• To develop a better understanding of how TRI data are being
used to foster pollution prevention and the data needs for
tracking pollution prevention;
• To develop a better understanding of how TRI data are
influencing environmental legislation;
• To provide a forum for discussion on future directions of TRI.
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1993 TRI DATA USE CONFERENCE
PLENARY SESSION
The goals of the plenary session were to give a broad overview of
the Toxics Release Inventory and pollution prevention efforts at the
state, regional, federal, and international levels. As the public has
become more aware of their rights under the Community Right-To-
Know Act, they have continued to ask more specific and
sophisticated questions that are driving the regulators' applications
of the TRI data. Their participation has focused greater attention
on inspection that has subsequently strengthened compliance at the
state and local levels. Individual states and regions have initiated
aggressive outreach programs to continue to stimulate this
questioning and use of TRI data. The efforts at the federal level
to examine new applications and syntheses of media, technology,
and local data have furthered this growth as well. Supplementing
the national and local efforts are the international initiatives being
undertaken, as represented by the Canadian National Pollutant
Release Inventory. The goals of these initiatives are to learn from
both the mistakes and huge forward leaps in the United States and
to complement and aid the quality and hence the value of the data
received already and yet to come through the Toxics Release
Inventory.
Plenary Session Speakers
Valdas Adamkus
Administrator, U.S. EPA,
Region V
Grant Wilkinson
Deputy Director of Legal Affairs, Ohio EPA
Mark Greenwood
Director, U.S. EPA,
Office of Pollution Prevention and Toxics
Gordon Pope
Special Advisor, National Pollutant Release Inventory,
Environment Canada
VI
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1993 TRI DATA USE CONFERENCE
BREAK-OUT SESSIONS
The break-out sessions focused on four major TRI issues: state
programs, data presentation, data integration, and data application.
The goal of the sessions was to create a forum for the exchange of
ideas through panel discussion and audience participation. In
addition, each session included time for participants to address the
future direction of TRI. Attendees were able to participate in four
out of sixteen sessions. Each session was an hour and a half in
length.
A summary of each session is provided on pages 39-279.
State Programs
Building a State Program, Part I
Building a State Program, Part n
EPA-State TRI Partnership
State Use of TRI Data
Data Presentation
Federal and State Waste Minimization Data Collection
Use and Interpretation of Federal and State
Waste Minimization Data Collection
Future TRI Initiatives
Presentation of the Annual EPA Data Release
Presentation of the Data to the Public
Data Integration
Integration of TRI Data with Other Agency Programs
Role of Data Integrity through Compliance and Enforcement
Integration of TRI with Other Data Sources
Integrated Data for Enforcement Analysis
Data Application
TRI Links with Voluntary Reporting and Reduction Programs
Risk Screening
Local Use of TRI Data
Public Use of TRI
EPA's Geographic Initiative
vu
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1993 TRI DATA USE CONFERENCE
DEMONSTRATIONS AND EXHIBITS
A reception sponsored by SOCMA and NEMA was held Tuesday
evening at which were displayed a wide range of TRI
demonstrations and exhibits. There were approximately fifty
exhibits that illustrated the current uses of TRI data. One of the
exhibits was a video entitled, "Learning About Chemicals in Your
Community." Thirteen participants demonstrated computer
software designed to help users access TRI data, manipulate and
display findings, or link TRI data to other databases. Listed below
are the 13 software demonstrations:
ARC-VIEW Demonstration of TRI
and Other Environmental Data to
Rank Potential Risk and Set
Pollution Prevention Priorities
Pat Cummens, NJ Department of
Environmental Protection and
Energy
Arizona Pollution Prevention Unit
Demonstration
Sandra Eberhardt, AZ Department
of Environmental Quality
Geographic Information Systems
(ARC-VIEW) of Kansas TRI
Facilities and Other Environmental
Data & Title m-TRI Database
Terrence P. Franklin, Kansas
Department of Health &.
Environment
Geographic Information Systems
Visualization Project Covering
Northwest Indiana
George Graettinger, U.S. EPA
High Quality Habitat Geographic
Information Systems to Evaluate
Environmental Stressors
Noel W. Kohl, U.S. EPA
IDEA Data Integration System
Jerry Lappan, U.S. EPA
Maryland Section 313 Software
Patricia Williams, MD Department
of the Environment
National Library of Medicine's
TOXNET System
Jan Erickson, U.S. EPA
RTK-Net On-Line
John Chelen, Unison Institute
Toxics Release Inventory CDROM:
1987-1990
Lisa Capozzoli, Labat-Anderson,
Inc.
TRI and Population Data in
Geographic Information Systems
Loren Hall, U.S. EPA
TRI Data and CAMEO
John Elkmann, U.S. EPA
Toxics Use Reduction Tracking and
Massachusetts Facility Masterflle
Susan Green, MA Department of
Environmental Protection
Vlll
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1993 TRI DATA USE CONFERENCE
PLENARY
SESSION
1. Valdas Adamkus
Administrator, U.S. EPA,
Region V
2. Grant Wilkinson
Deputy Director of Legal Affairs,
Ohio EPA 4
3. Mark Greenwood
Director, U.S. EPA, Office of
Pollution Prevention and Toxics .... 8
4. Gordon Pope
Special Advisor for the
National Pollutant Release Inventory,
Environment Canada 14
Moderator: Linda Trovers, U.S. EPA
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1993 TRI DATA USE CONFERENCE
Plenary Session Speeches
Valdas V. Adamkus, U.S. EPA, Region V
Mr. Adamkus has been the Administrator of the U.S. EPA's Region V since 1981, a post he
attained after ten years as Deputy Regional Administrator. He reports directly to the EPA
Administrator and is responsible for all air, "water, hazardous waste, and other pollution control
programs in Illinois, Michigan, Minnesota, Ohio, and Wisconsin. In addition, he is the U.S.
chairman of the Great Lakes Water Quality Board, an advisory body of the U.S. - Canadian
International Joint Commission. He manages EPA's Great Lakes National Program, and chairs
the U.S. group working with the former Soviet Union on water pollution issues.
Good afternoon...
I understand there have been several meetings dealing with the use of data from the Toxic
Chemical Release Inventory, or TRI. But I also realize this is only the second national get-
together of this type.
I am very pleased that you have chosen Chicago as the site for this conference. We here
in EPA Region V believe strongly in the objectives of the Emergency Planning and Community
Right-to-Know Act. We are proud of our efforts to make it work. And we are proud of our
efforts to put TRI data to the widest use possible. You will get to see the results of some of our
efforts to use TRI data during this conference.
If you recall, right-to-know legislation was passed by Congress in 1986. So it is a fairly
young statute. But it is different from most environmental statutes because it does not regulate
chemical uses or chemical releases. And it does not set up a permitting system. Rather, it
establishes a system to gather, assemble, and make available to everyone the information on
chemical releases.
Of course, there are some limitations on the type and quantity of information that goes
into the system. But, for the first time, a vast amount of multimedia information on
environmental releases is available in one place, to whoever wants it.
It is not surprising that many Federal and State agencies, and their various units, seek
out this information and try to use it wherever it's applicable. Perhaps more surprising were
the results of a 1989 General Accounting Office survey of the general public. The survey found,
for example, that almost half of the public was aware of the existence of TRI. Considering that
the right-to-know act was only three years old at the time, it was noteworthy that so many
people were aware of TRI.
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1993 TRI DATA USE CONFERENCE
I'm sure, in one way or another, you have experienced this public awareness of TRI.
And as a result of this awareness, the public is asking more specific and more sophisticated
questions. This is, at least here in Region V, one impact that TRI has had.
TRI has also had an impact inside EPA itself. I cannot tell you that TRI has
revolutionized everything we do. But I can tell you that the presence of TRI data has been felt
all the way from my office to all the offices in EPA Region V and in the Great Lakes National
Program Office, too. TRI data now form a vital component in many of the activities that we
carry out in EPA Region V and in our Great Lakes office.
This has happened in large part because TRI data are readily accessible. What's more,
TRI includes pieces of information that were previously difficult to put together. Now these
pieces are in one place. This means that certain analyses can be done now — analyses that
previously were thought to be too difficult or too time-consuming to even attempt.
TRI data are easily combined with graphical analysis techniques and geographical
information systems, making it possible to study spatial distributions and trends. The effort that
is put into data management permits us, the data users, to concentrate on data use. We don't
have to put effort into managing somebody else's data.
We have found that data quality is proportional to data use. And TRI is used a lot. As
a result, items of data that are out of line get spotted, questioned, and corrected. In the end,
we all wind up with better, more reliable data. We have also found that the data submitters take
more care in developing the data. Yes, industry is learning that submitting the Form R is more
than a paperwork exercise.
All of these factors enter into our decisions for using TRI data extensively in EPA Region
V and our Great Lakes office. Here are some examples of how we have put TRI data to work:
• TRI is used in our enforcement activities. And programs use TRI to target
facilities for inspection. For example, our Air and Radiation Division uses TRI
in its lead initiative to find out where the largest emissions of lead come from.
It then reviews compliance with the Clean Air Act. TRI data are also used to
identify facilities that are in violation of their clean-air permits.
• TRI is also used in our multimedia activities. TRI is one source of information
used in selecting areas that we emphasize in geographic initiatives. TRI data are
used in targeting multimedia inspections as well.
• Next, TRI data are being used in evaluating submittals for the Early Reductions
Program of the new Clean Air Act.
• TRI is also being used in compiling an inventory for atmospheric deposition of
heavy metals in the Great Lakes.
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1993 TRI DATA USE CONFERENCE
• In another Great Lakes application, TRI is being used to help identify sources of
Great Lakes critical pollutants, both by point-source and by Standard Industrial
Code.
• What's more, TRI was instrumental in developing the Great Lakes Basin Risk
Characterization Study. Our Great Lakes office has been able to apply the data-
analysis techniques developed for this study to other data as well.
• And, TRI has been used in developing a variety of environmental indicators,
which help us measure the results of our work.
• In addition, TRI is the basis for the voluntary 33/50 program to reduce the
multimedia releases of 17 toxic chemicals. I have sent letters to companies in
Region V, asking them to participate. And, so far, over 1,000 companies have
signed up nationwide. The program's success will be tracked using TRI data.
• Finally, enforcement of TRI reporting requirements has allowed us to use
Supplemental Environmental Projects in the settlement of enforcement actions.
In FY 92 alone, for example, companies in Region V have agreed to reduce their
use of toxic chemicals by 1.8 million pounds in Supplemental Environmental
Project provisions when settling TRI enforcement actions.
I have not listed every use of TRI data in EPA Region V and our Great Lakes office.
But these examples, I believe, will give you a good idea of TRI versatility and extent of use.
You will have an opportunity to learn more about some of these — and other — uses during this
conference.
We also need to remember that TRI has limitations. TRI does not contain information
on every chemical that might be of concern. TRI does not contain information on all sources
of chemical releases. But even with these limitations, TRI makes available a tremendous amount
of never-before-assembled information. And it makes it readily available for use.
Shortly, TRI will be presenting even more information to us. That's when the "Source
Reduction and Recycling Activities" data from 1991 become available. These new data, by the
way, are required by the Pollution Prevention Act of 1990. And these new items of information
should provide answers to questions that we could not answer previously. In all probability they
will cause us to ask questions that we did not think to ask before.
This conference is our opportunity to share our successes and our failures in using TRI.
We are all interested in the information these data impart to government, industry, and the
public. Now is the time to discuss, listen, and learn ways in which these data may become even
more useful.
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1993 TRI DATA USE CONFERENCE
Let me conclude by leaving you with a challenge. I know that we have not come close
to discovering all the secrets that TRI holds. But — ask new questions of TRI data. Combine
it with other information. If you find that you need more information from TRI, speak up.
Make your needs known.
If you do these things, I know that you will discover even more ways of using TRI —
and of using TRI in ways that will work for all of us in improving our environment.
Grant Wilkinson, Ohio EPA
Mr. Wilkinson was appointed the Deputy Director of Legal Affairs for the Ohio Environmental
Protection Agency on April 29, 1991, and was appointed to chair the State Emergency Response
Commission in August, 1991. He has been active in rulemaking procedures before the Ohio
EPA, the State Fire Marshal's Office, and the Environmental Board of Review. Mr. Wilkinson's
involvements have included litigation and enforcement actions at the state level involving the
federal RCRA, Ohio's related hazardous waste management laws and regulations, CERCLA,
TSD facility permit renewals, and Ohio's Underground Storage Tank Program. Litigation
activities include the U.S. District Courts for Ohio and Illinois involving CERCLA and the Clean
Water Act, and the Third Circuit Court of Appeals involving the Clean Air Act. Mr. Wilkinson's
involvement in compliance matters include RCRA, the Land Ban Program, the federal and state
Community Right-to-Know programs, and RCRA corrective action and closure matters.
Good afternoon. It is a pleasure to be here in Chicago today with you speaking on behalf
of Ohio EPA's Director, Don Schregardus. It is an honor to be among these distinguished
individuals through whose leadership pollution is being reduced. The purpose of my attendance
here today is to talk to you about the Ohio EPA's perspective on its implementation of SARA
Title m, section 313. Ohio has been a leader in implementing a State TRI program, and I think
that there are a number of reasons underlying this achievement which I would like to share with
you.
My address will be broken up into three parts. First, I will discuss — or I will give you
a brief overview of — the State of Ohio and its TRI program. Second, I will identify Ohio's
TRI program accomplishments. And the third and final part of my address will identify, most
importantly, the reasons that we have such a successful TRI program in Ohio.
Ohio EPA views the TRI program in two ways. First, TRI is based on the premise that
the community has a right to know what toxic chemicals are being released in their community.
TRI is the first comprehensive report that identifies toxic releases to the air, water, land, and,
of course, transfers off-site. Second, TRI is a valuable tool for communities and state and local
regulatory agencies, and plays a vital role in enhancing the Ohio EPA's efforts to improve the
environment. Ohio has over 1600 reporting facilities filing TRI reports, earning Ohio the
ranking of second in the country in number of reporting facilities. We are second only to
California. Ohio is consistently ranked in the top ten nationally for releases to each
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1993 TRI DATA USE CONFERENCE
environmental medium. In 1990, for example, we were third for releases to air, fifth for
releases to surface water, eighth for land on-site, sixth for deep well injection, sixth for public
wastewater treatment plants, third for transfers off-sites. For total releases and transfers we are
behind only Texas and Louisiana. Unfortunately, that is not something to brag about.
Two factors that explain, but do not justify, these rankings are this. First, the chemical
rubber and plastics, primary metals, and fabricated metals industries account for 62 % of the
reporting facilities and 76% of the toxic releases and transfers from Ohio facilities. And second,
the consistently high ranking of the toxic releases from Ohio's facilities reflect the highly
industrialized nature of our state and the types of industries operating in Ohio. With that
introductory information in mind, I will now offer you an overview of our TRI program.
First, with regard to the law itself, we enacted a law in December of 1988. This law did
a number of things. It established the TRI program in Ohio but, more importantly, it established
it under the Director of Ohio EPA. This is an important fact, and I will return to it in the third
part of my speech. Second, it authorized the development of rules that are no more stringent
than U.S. EPA's program. Third, it established funding through a fee program, a $50 base fee
plus $15 per chemical reported. In Ohio, the average facility reports four chemicals ($110).
This program generates approximately $200,000 per year through the funding, and we have
authority to enforce our recording requirements civilly by a $25,000 per day penalty for
violation. And, we can enforce criminally for a reckless violation. These penalties are directed
back to the TRI program. So, we basically have two sources of funding — the fees and the
penalties collected for violation of Chapter 3750.
Now, what about the program activities? In response to this legislation, Ohio's EPA TRI
program was established within our Division of Air Pollution Control. Next, we passed rules
based on legislative authority, again, that are equivalent although no more stringent than the
federal program. The TRI staff currently consists of only four technical people (3 environmental
engineers and a clerk). Most importantly, they conduct an aggressive outreach program to both
the public, focusing on the interpretation of the data, and Ohio's industry, focusing on the
reporting requirements. The program also maintains a computerized data base of the TRI data
from which customized reports and diskettes are distributed free of charge. Most importantly,
the TRI program staff issues an annual TRI report. The report breaks down the data by specific
media and identifies the top facilities discharging to each medium, as well as analyzing the
trends within the state. This report includes summaries for each county within the state and is
distributed to the newspapers, environmental groups, chambers of commerce, legislature,
academia and, of course, industry. This annual report in the TRI data base fulfills the basic
premise of the Right-to-Know Act by distributing the TRI data to the public through the
assistance of the press.
Now, for the purposes of elaborating on the annual report, the timing of this seminar
could not have been better. Just this past week Ohio released its annual Toxic Release Inventory
for 1991. There is both good news and bad news. First the bad news: the inventory showed
that in 1991, facilities across our state manufactured, processed or used 2.4 billion pounds of
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toxic chemicals. Of those 2.4 billion pounds, it is estimated that approximately 256 million
pounds were released into the environment. There is some good news, however. About 90%
of the 2.4 billion pounds of toxic chemicals manufactured, processed or used were recycled,
neutralized by treatment or used as fuel. Second, between 1990 and 1991, toxic chemical
releases fell by 8%. Third, the total amount of toxic chemicals released through smoke stacks,
injection wells, sewer pipes and other pathways has decreased every year since 1988. By 1991,
the state wide pollution total was 51 % of that of 1988. To sum up the report in twelve words,
Ohio is making progress but we have a long way to go.
Next, I want to talk about the accomplishments of the TRI program in the second part
of my paper. I will identify three major accomplishments: enforcement, data quality assurance,
and toxic release reductions. First, a recent survey of state TRI programs identifies that states
would like US EPA to focus efforts on identifying the non-reporting facilities under TRI, and
on improving the quality of the data reported by facilities under TRI. Ohio is addressing both
of these concerns through our state program. First, TRI enforcement. Although non-reporting
is purely an administrative violation, it is not regarded in Ohio as a paperwork violation.
Frankly, failure to report violates the premise of the law by denying the public the right to know
what is being released into the environment. The Ohio Right-to-Know Act allows for Ohio EPA
to enforce the TRI reporting requirements with civil and criminal penalties up to $25,000 per
day per violation. Ohio does not have delegated authority; we enforce our own state TRI
reporting requirement. U.S. EPA conducts inspections in Ohio and enforces the federal
requirements. However, an informal agreement exists between U.S. EPA and Ohio EPA so that
our enforcement efforts do not overlap. This cooperation with Region V is a vital component
of our enforcement program. U.S. EPA has given Ohio an enforcement grant for 1992 and
1993, each consisting of $50,000, under which Ohio has committed to complete 100 inspections
per year. Ohio EPA targets facilities for inspections based on air permits, record reports, and
industrial guides.
•Ohio EPA has conducted over 250 inspections of facilities, which resulted in 120
enforcement actions for non-reporting violations. Nearly one out of two facilities inspected have
resulted in some type of action. We also issue administrative orders to resolve these violations.
The Director of Ohio EPA has been given the authority, through statute, to resolve violations
through the use of administrative orders. This authority has unquestionably expedited the
resolution of enforcement cases. And, Ohio EPA has developed an enforcement policy which
includes a civil penalty equation. This policy is applied equally and consistently to all TRI
violations. The results — over $300,000 — has been collected to date and several penalties.
Through the penalty policy the smallest cash penalty was $315, while the largest was $49,000.
Also important is the fact that Ohio EPA encourages an offset of a portion of the penalty through
Environmentally Beneficial Expenditures. These credit projects reduce or eliminate the release
of toxic chemicals beyond the requirements of environmental regulation.
Now our second accomplishment — Ohio's data quality assurance program. Through a
federal grant in 1991, the Ohio EPA initiated a data quality assurance program. Under this
program, Ohio EPA has attempted to improve the quality of the information reported by Ohio
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facilities. Initially, Ohio EPA requested supporting calculations and threshold determinations
from ten standard industrial code classifications. Calculations from over three hundred
companies were reviewed and thirty facilities were inspected on-site. These calculations were
reviewed for sound engineering principles. Then assistance, which is an important word these
days, was given to industry on how to improve the accuracy of their calculations. No
enforcement resulted from this effort; however, the potential exists for civil penalties for over
— or under — reporting of toxic releases. This effort has continued with calculations requested
and reviewed from targeted facilities, and reviewed for potential enforcement actions. Of
course, voluntary revisions are always excepted. However, Ohio EPA is examining the
revisions to ensure that facilities use the most accurate information available at the time.
Our third accomplishment — reduction of Ohio toxic releases by facilities. As just
mentioned previously, Ohio facilities have reduced toxic releases by over 50% from 1987 to
1991. Between 1990 and 1991, during which time no major modifications were made to the
way in which releases are reported, Ohio facilities reduced releases in transfers by 8 %. Equally
important, 456 Ohio facilities have signed up to participate in the 33/50 program, in which they
committed to reduce releases of seventeen toxic chemicals by 33 % in 1992 and by 50% in 1995.
The participation level in Ohio is the highest in our region and the fifth highest in the country.
The governor has urged 100% participation. The 1991 data have shown a reduction of 38%
from 1988 to 1991 exceeding the 33% goal for 1992.
Finally, the third part of my address identifies the reasons for the success of Ohio's TRI
program. I believe there are five. The first is the fact that we have separate legislation with
clearly defined goals and objectives. TRI was clearly defined as a distinct program separate
from the state emergency response commission and other components of EPCRA. Although the
TRI data are distributed to LEPCs and used within the SERC, the focus of the two programs are
clearly different. As chairman of the SERC, I can tell you that the LEPCs, like any
governmental entity or organization, are worried about funding. But they are also worried about
exercises — planning, first response, having the proper equipment, mapping, and knowing the
facilities in their communities. While they have a concern for TRI, it's not the central focus of
that program. So, I think it was great foresight of our legislature in setting up our own Section
313 statute. Separate funding sources were also established. The TRI program operates a
program consistent with the federal requirements. This narrow program has allowed the
resources to be focused on TRI requirements alone. The intent of TRI has not been diluted with
other responsibilities. For example, separate staff exists for pollution prevention and emergency
planning. Second, we have an aggressive outreach. Ohio EPA provides guidance on
interpreting the data to citizen's groups and news media. Outreaches have been conducted with
the Ohio EPA — within the Ohio EPA headquarters and the five district offices, so that each
media program is familiar with TRI and can utilize the data within each program to share
compliance.
Outreach to industry continues each year through mailings and seminars. Ohio EPA is
really committed to bringing industry into compliance through educational efforts and does not
rely solely on enforcement efforts. Third, as I mentioned earlier, we have our own data quality
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assurance program. Ohio EPA strives to improve the quality of the TRI data through a
comprehensive review of the supporting documentation upon which the toxic release estimates
are based.
Fourth, Ohio EPA has a pollution prevention program. The pollution prevention section
within the Ohio EPA, in conjunction with Governor Voinovich, have encouraged facilities to
reduce toxic releases. This work with Ohio facilities has greatly reduced toxic releases beyond
permanent requirements.
Finally, the fifth reason for the success of Ohio's TRI program is the maintenance of our
TRI computer data base. The Ohio EPA maintains the computerized database, which allows for
the distribution of the TRI data to the public. Let's face it: no responsible, as well as image
sensitive, corporation wants to be anywhere near the top of that list. It has a deterrent effect.
In sum, protection of human health in the environment, the Ohio EPA's charge, requires
a multi-dimensional strategy. One of the predominant dimensions of that strategy must and does
include elimination or, certainly, a mass minimization of releases of toxic chemicals to the
environment. In Ohio, we are working toward that goal through outreach, including awareness
and technical assistance and effective enforcement. In combination with the leadership of, and
a cooperative spirit advocated by, Governor Voinovich and Director Schregardus, I encourage
other states to re-prioritorize — make Section 313 a priority and adopt the Ohio approach.
Simply stated, it is working. Thank you.
Mark Greenwood, U.S. EPA
Mr. Greenwood is the Director for the Office of Pollution Prevention & Toxics. He first came
to the US EPA in 1978, and joined the Office of General Counsel working on a variety of issues
under the Clean Water Act and solid waste matters. In 1983 he became the first Assistant
General Counsel for RCRA. In 1987 he became the Assistant General Counsel for Superfund,
and in 1988 he was named the Associate General Counsel for Pesticides and Toxic Substances.
In addition to his responsibilities for managing the TRI program and for reducing risks
associated with new and existing toxic substances, Mr. Greenwood now is the agency-wide
program head for ensuring that pollution prevention is integrated into all EPA activities.
Thank you, Linda. And thank you all for coming. We love to see this kind of turnout
for any of our programs and TRI is one of them that brings everybody out, so we appreciate
that. I certainly welcome this opportunity to speak to you today. This conference has become
an annual event; it is a reminder for me of the broad community that TRI serves. We have
federal, state, local, and tribal governments represented here. We have industry, labor,
environmentalists, academia, news media and now the international community, which I think
is a new addition that is particularly good to see. It is also a reminder for me of the adaptability
of this program. This is a program that can really be designed to serve many policy objectives.
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And, depending on which year we talk about, there are different issues that seem to be more to
the fore. You will certainly be hearing during the course of the conference many interesting
ideas that people have about how the data can be used. In many ways that is the purpose of the
conference. I know in Washington these days a lot of interest is out there about things like
environmental technology or environmental justice. Both of these are topics that are of great
interest, but we find different ways in which the TRI data can be assembled to try to help people
to think through the ways in which problems can be defined better so we can measure progress.
I think it is an adaptable tool, and we will all find better ways of using it.
I want to emphasize from an EPA perspective that we view this conference as a very
important part of our program. We have been doing the conference for the past several years.
The funding was tight this year but we decided to have it anyway, and we will try to do it as
much as we can in the future. It is important for many reasons. Some of the objectives that are
very important are: it has served as a very useful tool; it helped develop understanding of TRI
and how it can be used; and it always expands our network of TRI users, which is growing
every day. I think the conference is helpful to understand how TRI is playing into other
government programs, particularly at the state level. And there have been a lot of discussions
about that. It is also useful more and more as we think about its role in pollution prevention,
and we will talk about that more in a bit. I think for EPA that the most important point is that
the conference is a great opportunity for us to hear from our customers, and it allows us to
better serve the needs that you have.
In my remarks today, I would really like to emphasize what I consider to be the major
theme of 1993, if you will, for TRI — the issue of expansion. And when I talk about expansion
I want to use that very broadly: the several dimensions on which it takes place and how it will
play out over several years. I think this is the year in which a lot of that expansion activity has
begun. The first of those expansions is the expansion to the Pollution Prevention Act data.
Again, this has been going on in this development for a while, but this is the year we are all
going to start sharing those data. As you probably know, we are going to be seeing data this
year on the numbers of off-site recycling, burning for energy recovery, on-site recycling,
burning and treatment activity, and catastrophic releases. We also are going to be seeing data
on source reduction strategies for the first time, which should be very interesting. We will be
seeing predictions for change in the future, which I think will be a particularly important
dynamic of the TRI program. In order to make predictions it implies that you have a plan. In
order to have a plan, you have got to start sharing that with people, and I think that is going to
be an important development. Also, we are going to get into things like units of production,
what is the company or what is the facility thinking it produces. And we can start relating the
information about pollution to what is going on in production activity, which will be a very
important indicator.
Currently, as you probably know, we plan to release the data in May. We are devoting
a considerable amount of our effort this time to try to explain the data. And I think that is an
important job for us all because we are reaching a point, I think, in the program where we are
achieving critical massive data, and we want to make sure that the right to know or the right to
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know more does not become the right to be confused. And that is a potential we have to all
worry about. Issues like: how do we separate the information about chemicals in waste streams
from that which is actually released? And, I think we are going to have to make sure we all do
a good job in explaining that.
I would also like to put down on marker that I ask you to recognize that there will be
data quality problems for this first round of data. That is, I suppose, inevitable, and in a first
year effort we are all learning. But I think it is important to note that we have had a particularly
difficult year, this time, to try to pull all this information together. As you know, last year we
had a major dispute with OMB about the form, which caused us to have a late form and no
guidance. That was the first step in the process. Delays then made sure that we had to get
more data; we had to go up to 9.6 million data elements. We had to get more data into the
system in less time; that is also exciting. And we also had budget cuts, probably the biggest
budget cut this program has ever faced, for FY93. So I think what is notable is the fact that we
somehow are going to do it anyway despite all those setbacks. But there will be data quality
problems, and we need to work on those in the future.
I would give a special compliment to my staff at EPA who worked very hard to make
this possible. But I think the fact that we have done it pretty well in the first year does not end
the task. I think we have to recognize that it is going to take several years to iron out the
interpretive issues that surround the Pollution Prevention Act data. For example, this great
debate of what constitutes in-process recycling that is part of source reduction and, therefore,
is not reported, and the other forms of on-site recycling that are reported is going to be, I think,
a particularly difficult issue to sort out. But we are starting at it, which is good.
There has been a lot of talk about adding additional chemicals and sources to TRI. I
think we all have a recognition that there is a need to expand and, I think, at EPA we have a
strong commitment to expand this program. From our point of view, it is critical to the integrity
of this system that we have the right set of chemicals and right set of facilities in the system.
TRI is more and more a statement of how we are doing on toxics in this country and, I think,
it is only fair that we get the right set of chemicals and right set of sources. It's also more and
more a mechanism for setting agendas, not just for the government but also for companies. I
have talked to many company officials who say they used the TRI data set to set their priorities.
And, as long as that is the case, we have to be careful about what we put in this system to make
sure we are sending the right signals. But there are many interests these days, I think, including
industry's, to see the need to expand this program, and we are going to try to do that.
There are a number of issues to consider. One of them, which I think is very important,
is to look at the concerns that have been expressed by small business. We now have, after all,
a very complex reporting system for small releasers. And I think there is a question here about
whether that makes sense. Certainly, we have to consider the burden on the small entities but,
also, we have to consider the fact that we are filling the database capacity with small impact
information to some extent when we have a lot of small entities in it. And that has to be
factored in. A second consideration, is we have to look at timing. We are interested in
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expanding now, and we would like to do whatever we can as quickly as possible. At this point,
expansion of chemicals is more ready than an expansion of chemicals and sources. And so, we
will probably look at chemicals first. Chemicals are easier these days because we have more
data on those, and we have clearer criteria about who to bring in the system. We also have to
think carefully about EPA resource limits. The budget cuts I have mentioned are a reality. They
have had an effect on us, and we will have to phase in how we approach expansion.
We are planning to brief our new Administrator, Carol Browner, very soon on our plans
for expansion. I haven't talked to her yet about it, but I will share with you some of our
thoughts about expansion. We are talking about potentially two phases of expansion. The first
one would look at chemical expansion; we would like to link that to some extent with some
relief for small releasers, if possible. Our sense is that if the right package allows us to make
use of the capacity, we would be opening up with the small business relief and adding more
chemicals. The second phase would be an expansion of sources. This will be a major
undertaking. I'm sure the industries we would be reaching out to touch would not be excited,
or should I say they would be excited. But perhaps not in a positive way. So we expect that
to be an exciting effort and that it will take more time to complete.
I would like to talk then about another form of expansion, which is expansion
internationally. More and more countries are showing an interest in publicly available emission
release inventories. I think it is important to recognize that the effort to internationalize
something like TRI is very much in our domestic interests because I think it can put US releases
in peispective. There is a notion, that is sometimes used in the world of quality management,
that you look in terms of bench marking. You look at what others are doing to see how you are
doing. And I think that is an important concept for the US. To see where we are doing a good
job and where we are not. And I think internationally TRI is a good way of doing that. It also,
of course, will help us think better about approaching global problems. Chemicals are related
to global problems after all, and getting a sense of what countries are doing in terms of total
loadings to the planet is extremely important.
I will mention two major activities — as follow-ups to the conference in Rio. There is
a requirement in Agenda 21 to create a guidance to government's document on publicly available
emission inventories. We have recently sponsored an international meeting for planning to look
at that effort. We had good cooperation from several countries, several international
organizations, and I think we have begun to sort out roles about who in the UN agencies, who
in the OECD, and who in other countries are interested in playing a role in this.
The second major activity will be in the North American Free Trade Agreement. There
are efforts afoot as we talk about sharing our borders, sharing our goods, and also sharing our
information. And I know with the folks from Canada we have some very good cooperative
efforts. We want to expand those to our friends in Mexico and try to develop a North American
network. Certainly I look forward to working with those who have been involved in this.
Gordon Pope, whom you are going to hear from in a minute, is a leader in Canada. And we
look forward to working with them.
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Let me mention two other expansions that are a little bit more on the horizon. There has
been a lot of talk about materials accounting as something we should look at carefully. I think
that is something we should examine in the longer term for the TRI program. But I think we
are going to need to watch carefully the efforts in Massachusetts and New Jersey and some other
states to try to devise a system for materials accounting. There are several key questions we all
need to ask. One which has been very salient is the question of how we deal with confidentiality
issues. There are confidential business information issues that get created depending on how
deeply you go into a plant's operations. And I think the experience of those states will be very
useful in trying to figure out how to manage that issue. But I think it is also important to get
a sense of how the data is being used as we get into materials accounting and who are the
principle users. For example, it's not clear that every member of the public will want to know
exactly all of the details of how materials go through a plant. That may be of great interest, but
I think we are going to watch and see who has the greatest interest.
It will also be important as another kind of expansion to look at the ways in which TRI
can be linked with other data. I know we are engaged in stellar efforts within my own office
to see whether we can do a better job in linking up TSCA data. We have collected a lot of
information on chemicals over the last several years about the hazards of chemicals and about
the uses of chemicals. We are exploring several areas now to try to create a better and more
integrated system for chemical information that links TRI to one of these other databases. There
is also the issue of integration of TRI data with other databases at EPA, such as the air program,
the water program, and the waste program.
So, I think you can see this is a very ambitious agenda of expansions. I would like to
lay down a few, if you will, challenges that I think these present to us. We are going to be
looking at tough issues to face to make these expansions successful. There are at least three that
I would like to mention. First of all, I think EPA needs a very strong linkage with our
customers, but customers that talk to each other. We have a great number of what I call
bilateral discussions with interest groups who come in and inform us about what they would like
out of the TRI program. And then we spend a lot of time explaining to them what somebody
else thinks about the program as well. And, I think more and more we have to find ways in
which the various interests around the TRI program talk to each other. This is, after all, a
community right-to-know program. I think the major transactions that occur as a fallout of these
data tend to happen at the plant level, where EPA is not really present at all and that there are
many other actors, many of whom are represented by people in this room, talking to each other.
Again, I think it is very important for them to talk to each other as we design a program.
One example we have recently had with this, is with a group that is called the National Advisory
Council for Environmental Policy and Technology (NACEPT) — it's a group within the Agency
that sponsors advisory groups. We have an advisory group now in TRI; I suppose it has been
a little slow in coming, but we have one now. And we just recently had a meeting of that
group, which was an excellent meeting from our perspective. It was a great opportunity to hear
the views of the various interest groups that have watched the TRI program for some time. But
we found not only the quality of the comments very good but the quality of the exchange and
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the interaction among those interest groups as important as anything. They will be looking at
very important issues; they will be looking at the Pollution Prevention Act data and how to
improve it. They will be looking at the expansion of coverage that I mentioned earlier, and they
will be looking at some data management issues that are increasingly important.
A second challenge that I think we are going to face is that all interested parties have to
recognize and take responsibility for the data management problem that the TRI presents. It is
common to view the data management problem as a problem at EPA or perhaps one division in
my office. But it is not that. It is, I think, everybody's responsibility. We are preparing what
we call a white paper to examine the various options we have for how to deal with expansion,
what some of the issues are. And I think we will have that out soon. I think that will be a useful
document for many of you to look at and get a sense of what some of the issues are. But I think
it has been clear that the actions of others will go a long way to divining our capacity. Let me
mention a couple.
I think more and more we have to look to the states who have fully developed programs
and think about the ways in which our program can be integrated more with the state TRI
programs and see how we can do a better job together. I think we also have to look to industry
more and more and the issue of taking responsibility for making sure that the data are of high
quality. And making sure it gets to us as effectively as possible. One of the issues that makes
a big difference to us, for example, is the use of electronic or magnetic media submissions. The
amount of time it takes to process a written form is much longer than it is for magnetic media.
There is always the issue of accuracy and, I think as we press more and more for expansion,
we have to think more and more about using those magnetic media submissions. And, again,
I think that is a responsibility that is not only ours but also for industry as well. We certainly
want to hear data management suggestions that you have; I would only urge you to make sure
that you think of it as a management problem. There is a great tendency when we express the
data management problems at EPA to have somebody come up after the discussion and say, well
I have this neat piece of hardware that I think you might be able to use better. The truth is, it
is a management problem, not just a technology problem. I note the fact that we have a mail
room that has to handle incredible numbers of pieces of data. We have a storage facility that
has to handle something like two hundred and seventy five thousand transactions where people
come in and take a file out and look at it and put it back in. These are all significant
management problems that one has to think about. And we would like your insights on those
as well.
The third point I would make here is I think we have to have a serious debate among a
community like this about what is the most useful data that we have in the system. I think it is
important to expansion, given the data management capacity questions we have. And we should
consider all the options. There may be data in this system that are not terribly useful. Maybe
we don't need to collect it. We ought to think hard about the question of whether we can use
the existing data we are getting as opposed to talking about the new exciting piece of data we
would like to get some point in the future. There might be better ways of using current data to
answer some of the key questions. I think the ultimate issue is that we need to think better
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together about how we measure progress. If we have some consensus on what it is to measure
progress, both in terms of emission reduction but also pollution prevention, it's going to make
it a lot easier for us all to come together and talk about what is the key data that we need.
I would like to leave you then with those thoughts. Again, on behalf of the EPA, I
welcome you all, I'm glad you are all here, I hope you enjoy yourself, and I hope you learn a
lot. I am certainly looking forward to your insights. I suppose, in a larger sense of things, I
hope that we can all celebrate a program that is, I think, already given this country a lot. But
I think has a lot of promise to give it a lot more in the future. So, thank you.
Gordon Pope, Environment Canada
Mr. Pope is a Special Advisor for the National Pollutant Release Inventory (NPRI) for
Environment Canada. He is responsible for managing the development for the NPRI program.
The NPRI is modelled on — and seeks to improve upon — the U.S. TRI program, as well as the
Canadian Chemical Producers Association's National Emissions Reduction Master Plan.
Good afternoon. Thank you, Linda. And thank you Mark and Linda for inviting me for
a second time to talk at an EPA event. The first time was in a little more exotic location over
in Vienna, but I'm still pleased to be here representing Canada.
Just a few things, I would also want to thank Eileen Fesco, Larry Longanecker, whom
I don't believe is here, Steve Newberg-Rinn, and Sam Sasnett. The support that Canada has had
from EPA has been fantastic. Larry has been up to talk about TRI on two occasions. And, I
guess, about every three or four weeks I'm on the phone talking to Eileen. One comment to the
people from Washington, if you see that certain things are missing, be assured that I am using
them well. I have a feeling that things end up in my office from some of the offices in
Washington. The TRI is, of course, widely known, and I keep getting phone calls asking about
information on Canada's TRI or, recently, letters to the minister responding to Canada's Right-
to-Know Act. I haven't heard anything bad at all or negative about TRI. I guess the most
negative thing that I saw was the General Accounting Office report saying that the TRI covers
only five percent of the releases in the states. But, for a report, it was intended to be a
criticism. I thought that that was pretty weak, since the list of substances was dictated by
Congress. And I thought that it was a pretty good report of the work that EPA has done so far.
What I'm going to be talking about this afternoon are not the benefits of a TRI type
program, but the differences between TRI and our National Pollutant Release Inventory. We
have specifically stayed away from using the word toxic. Under our legislative authority in
Canada, toxic has a very specific meaning, and we thought it would be a little too restrictive.
So, we have cast a very broad net. The origins of the TRI program, as you probably all are
aware, was initiated through an act of Congress. And, I believe the Emergency Preparedness
and Community Right-to-Know Act was enacted in 1986. The coverage was specified as being
only the manufacturing sector, the SIC codes 20-39. The b'st of substances was specified as
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being a total of about three hundred chemicals and twenty chemical categories or groups. The
thresholds, I think, were specified in the Act, starting at 75,000 pounds of use or manufacturing
of a substance in the first year. And it's presently down to 25,000 pounds. And, then, the
reporting deadline was also specified as being July 1 of the year following the reporting year.
For the National Pollutant Release Inventory, the initiative was spelled out in Canada's
Green Plan, which was sort of a general document stating Canada's direction for environmental
issues. We've designed the NPRI through a consultation process. We had a multi-stakeholder
advisory committee of about 27 people. And, we used that group to design the program.
In Canada's Green Plan, it's basically a national strategy and action plan for sustainable
development. The Green Plan was launched in December of 1990, and it was developed through
extensive consultation. Apparently, there were 41 information sessions across the country,
involving more than 6,000 Canadians. It then broke down to 17 consultation sessions in 17
major Canadian cities, involving more than 3,500 people. And, then, finally a wrap-up session
— a two-day session in Ottawa. That was the forming of the Green Plan.
The Green Plan's goal — I'll just read a little bit here from the Green Plan — "To meet
this challenge, the government of Canada has defined specific goals. It is committed to working
toward clean air, water and land, the sustainable use of renewable resources, protection of our
special spaces and species, preserving the integrity of our north global environmental security,
environmentally responsible decision making at all levels of society, and minimizing the impacts
of environmental emergencies." That's the background of the Green Plan. The section in the
Green Plan that got my department working basically says to develop a better understanding of
the nature and quantity of toxic substances being released into Canada. The government will
develop a national data base for hazardous pollutants being released from industrial and
transportation sectors. It also said that the reporting criteria will be developed by the end of
1992, which we did, and that the first reports available to the public will be published before
the end of 1994. So, we have our two milestones. It sounded pretty easy, but it then became
very complicated.
The authority for this program is the Canadian Environmental Protection Act. It became
law in 1988 and what we will be, one of the sections we'll be using in CEPA is a section that
gives us the power to assess whether to control or the manner in which to control a substance.
In order to start the legislative process going, we had published this past Saturday an official
notice in the Canada Gazette, detailing the reporting requirements, so it is now a legal
requirement for facilities to report. The one problem with CEPA has to deal with confidentiality
provisions. It's not the same as your Community Right-to-Know Act, and there is a concern
that facilities claiming confidentiality could really bog the system down. However, we believe
that if companies want to raise a red flag and get the citizen's attention, one good way is to
claim confidentiality about a certain substance. And, I think, they'll really get the attention of
everybody.
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The process that we had for designing the program: first of all, we established a multi-
stakeholder advisory committee consisting of about 27-28 people. We would sometimes break
into work groups to address specific issues. We identified the need for a trial run. Instead of
waiting 2 or 3 years to get the feedback from our first year, we had this trial run that we're
working on right now. And we're looking for feedback on the details of the program, the
reporting requirements, the clarity of our documentation. We don't expect to get any data back.
In fact, we've told facilities that we don't want data. We can't protect it right now, even if they
claim confidentiality. So give us feedback and we'll see if we can make some of these, any
necessary changes before the next reporting year.
We also had discussions with the provinces to find out their thoughts on the NPRI, what
their involvement was going to be and how they could assist in this effort. We released a draft
report last fall, and used that as the focus for regional information sessions. We had, I think,
8 information sessions across Canada open to the public and it was quite well attended, even the
one that we held in Toronto. It happened to be on the same day as the national referendum, and
the big parade celebrating something that the Blue Jays did. I'm not even sure about that. So,
though we had 200 people registered, we had 150 show up, and probably 50 that didn't quite
make it through the parade. They probably didn't try very hard.
The final report was completed at the end of last year and submitted to the Minister. At
the beginning of this month he accepted the recommendations without any changes from his
department. And then, as I mentioned, on Saturday, this past Saturday, we published the
requirements, the reporting requirements in the Canada Gazette.
One thing we did recently, also, is we published a news release. I guess we did that on
March the 12th, when the Minister accepted the program. We sent it out to 400 newspapers,
all of the media, television, radio, and my name and phone number were identified as a contact
person. So, in preparation for that, I went to a media training course, where it taught me what
to say, what not to say, and when to shut up. I got two calls. One was from the Globe in
Toronto, and I had spoken to this individual before. And one was from a radio station. I had
several requests from the media asking for copies of the report, but it really surprised me that
I wasn't inundated with telephone calls, wanting me to be on television.
The advisory committee that I mentioned, I thought I would give you an idea of the
cross-section of the participants. We had the Canadian Chemical Producers Association, the
Petroleum Products Institute, a representative from Motor Vehicles, Mining, Steel, Pulp and
Paper. Then environmental and labor groups, we had a representative from the Canadian Labor
Congress, Great Lakes United Pollution Probe, SODA. And I'm sorry, I don't know what that
stands for. STOP, which I believe is the Society To Overcome Pollution. And then a
representative from an environmental community in Quebec. We have had the province of
Ontario taking part right from the beginning of our consultations, and then we managed to get
Alberta and British Columbia to take part as well, with Manitoba being a corresponding
member.
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From the government, we've been in contact with other government departments,
specifically health and welfare. And then industry, science and technology. So we tried to have
a good balance so one sector wasn't overpowering the other. And we had a facilitator manage
all of our meetings so he could deal with the heat and we could stay away from it.
The reporting conditions for the NPRI are slightly different than what they are for the
TRI. We're not tying ourselves into SIC Codes. We're saying if you use it, you report on it.
So basically any facility would have to report. We're using the 10 or more full-time employees,
or the equivalent of 10 full-time employees. We have, I guess, a similar threshold for the use
of it — the manufacturing process or otherwise use an NPRI substance in a quantity of 10,000
kilograms or more per year. That's a little more than 22,000 Ibs. So it's essentially the same
as TRI.
For the substance list, we basically started with the TRI list. We had any number of
opportunities to go out and get into some really deep trouble. And we looked at the list and then
we figured out how can we cut it down a little bit. We deleted substances that were not found
on our domestic substances list. So that got rid of a big chunk of it, and the DSL is basically
the list of substances in commerce in Canada. It's not totally complete, but it gives us a good
idea.
We then deleted items that were found in quantities of less than 1 ton on the DSL, and
that represented less than 1 percent of the total, I guess, volume of substances reported on the
TRI. We removed pesticides. They're controlled under a different section, so we didn't want
to get involved in somebody else's territory. We removed ozone depleting substances. They're
scheduled for phase out by the end of the year. We thought it just wouldn't be worth our while
to put them on our list. Then we also removed banned and certain regulated substances. So we
started off with a list of 320 and we are at 178.
We also identified certain sectors that possibly wouldn't have any releases, or wouldn't
be able to report because of the size or complexity in calculating reports. So we have excluded
the distribution and retail sale of fuels. We've also excluded facilities involved in the
maintenance and repair of transportation equipment, and I have a question for myself on that one
if that includes paint jobs and so on. I can see them contributing a lot to releases. We're also
excluding the wholesale or retail sales manufactured articles or products. Universities, colleges
and schools will not have to report. Research and testing labs won't. We just don't see that
there's anything out there that's big enough to qualify. The cutting down of trees wouldn't have
to be reported, but as soon as they get into the sawing of the trees or the pulping and paper
making, they would have to report. Mining would not have to report. But as soon as they get
into the beneficiation of the products, then they would. And oil and gas wells don't have to
report either.
The trial run. We were hoping initially for about 20 volunteers to take part in this, and
I was getting phone calls daily for people wanting to get on. So we were up to 78 companies.
This trial run will be completed by the end of April, and the objectives. First of all, we've gone
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out on a printed form for the trial run initially. We're looking for comments on the form in the
manual. It gives the facilities an early look at the national pollutant release inventory. Facilities
can comment on unresolved issues. We have special shaded areas, and they can give us some
additional input. The questions and answers will be used as the basis for subsequent workshops,
and we'll also get some feedback on the cost to industry to work out the calculations and submit
the reports. And we'll also supply a good opportunity for training industry's provincial and
regional staff.
The report will be, in some aspects, similar to the TRI report. Hopefully, not as thick,
or we're going to very quickly run out of money. It's going to be available to the public.
We're still looking at different methods for making it public. The first year for data is going
to be 1993, and the report will be out within 12 months. We'll also be looking at a federal
section in the report and then sections for each of the provinces so they can have some input to
the program as well.
As far as the format, well, it's going to be by province, possibly by ecoregion as well.
And we're also going to have summary sheets by substance showing the origins of releases for
the different substances to try to put the releases into perspective. A number sitting by itself
might look very large being released by a certain facility. It might be rather small compared
to what is released by, I guess, consumers in their homes or what is coming across the borders,
etc. So we're going to try to put in these summary sheets. They're going to be full of holes
for the first couple of years, but we're going to try to fill them in to put things in perspective.
Some of the unresolved issues: confidentiality is one of them. Our environmental
representatives have been quite concerned that if we get inundated with the requests for
confidentiality that it could cause a real problem in our ability to handle these requests. And
also I believe under the TRI, the onus is on the facility to demonstrate that an item is
confidential. Apparently, under our system, we have to prove that it isn't confidential. So the
onus is then on us and not on the facility. As far as the quantities used, we're using that as a
guideline for reporting, but there is a request to get that information. I think if we go out and
ask for that, it will fall under — a lot of people will be claiming confidentiality. There's a
request for high-profile substances to be added on as well. The dioxins and furans and
greenhouse gases. So we're looking at that. There's also I guess a request to obtain information
on the amount of substance in process, and what is stored on-site. So these items will support
emergency response.
And finally, the reporting thresholds. There is a request by the environmental
community that we lower the thresholds. And I'm sure industry would like to see it right where
it is now, if not raised a little bit.
The question of harmonization was something that came up at almost every meeting that
I've attended. Industry has to report to any number of different data bases. And what they
would like is the one window approach, or the income tax approach where they get all of their
requests at one time in the year and they can budget their time. They want to identify all current
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and planned requests and have a common annual cycle, as in the case of the income tax. They
also want to eliminate, or we're going to try to eliminate duplication of requests. We're going
to go out and talk to different facilities to find out who they're reporting to, what they're
reporting on, and from there we're going to talk to different provinces. Stats Canada — they're
going out and collecting information, as well as other government departments. We've also said
that we're going to support our pollution prevention department and their equivalent to the 33/50
program. So we're going to be looking at those aspects.
The final item under harmonization is the one-stop shopping. Apparently now you can
just spend weeks on the phone trying to get some information, and we want to try to create a
system where we'll have easy access to inventory data and also the NPRI could be the nucleus
for wrapping in other inventory data.
Some of the immediate next steps: we're working on completing our mailing list for
potential respondents. That's a lot of fun. Within a couple of weeks we're going to be mailing
out copies of our legislative mailing reporting requirements, the Section 16 notice as we call it.
We're working on developing the computer program for data input. And then we'll of course
be receiving the data from the facilities. We'll have to input and compile that and then produce
our final report.
As I've mentioned, the authority for this program is the Canadian Environmental
Protection Act. And we're saying that any person has to report on any one of 178 substances
and that the parameters of the 10 employees or the 10 ton use threshold. There's been a request
for the future that we have some kind of dedicated regulation for the program. The Canadian
Environmental Protection Act was not designed for annual reporting cycles. Each year we'll
have to publish a new Section 16 notice, which is a bit of a pain in the neck, but it also gives
us the opportunity to change a few things and maybe correct some problem areas. We're still
going to have, I believe, any person reporting. I don't think we're going to change that.
The list of substances is going to be greater than 178. We were looking at supporting
reporting requirements or substances identified in other multi-stakeholder consultation programs.
There's a request that we drop the reporting parameters below 10 employees. That could
possibly change, but we're going to look at that when we get the feedback from that first year
or so of reporting. The existing types of substances that are on the TRI and that are on our 178,
that quite possibly will stay at 10 tons of use. We're probably going to be adding greenhouse
gases. I'm not sure what the threshold will be, but it will be significantly greater than 10 tons.
Then, finally, we're going to be adding on high profile substances, and we'll have to change to
a release threshold in that case. So I can see that our final report will have three major areas,
the large volumes, the common pollutants, greenhouse gases, the standard type TRI substances,
and then a special category for the dioxins and furans. And so I can see that evolving over the
next couple of years.
If you have any questions, please don't hesitate to ask me, as long as they're not too
technical. I have a couple of copies of our Advisory Committee report out on the tables if
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anybody would like one. If they could leave their address or business card, I'd be pleased to
send a copy. Thank you very much.
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Canada's
NATIONAL
POLLUTANT RELEASE
INVENTORY
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ORIGINS
TOXIC RELEASE INVENTORY
• INITIATED THROUGH AN ACT OF
CONGRESS
• EPCRA ENACTED IN 1986
COVERAGE SPECIFIED (SIC 20-39)
SUBSTANCES SPECIFIED
THRESHOLDS SPECIFIED
^
REPORTING DEADLINE SPECIFIED
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ORIGINS (CONT'D)
NATIONAL POLLUTANT RELEASE INVENTORY
• INITIATIVE IN CANADA'S GREEN PLAN
• CONSULTATION PROCESS
• DESIGNED JOINTLY BY ENVIRONMENT
CANADA AND A MULTI-STAKEHOLDER
ADVISORY COMMITTEE
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CANADA'S GREEN PLAN
• THE NATIONAL STRATEGY & ACTION PLAN
FOR SUSTAINABLE DEVELOPMENT
• LAUNCHED IN DECEMBER 1990
• DEVELOPED THROUGH EXTENSIVE
CONSULTATION
• THE GREEN PLAN GOAL
• DEVELOPMENT OF THE NPRI WAS
PROMISED UNDER THE GREEN PLAN
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GREEN PLAN COMMITMENT
"TO DEVELOP A BETTER UNDERSTANDING
OF THE NATURE AND QUANTITY OF TOXIC
SUBSTANCES BEING RELEASED IN CANADA,
THE GOVERNMENT WILL DEVELOP A NATIONAL
DATA BASE FOR HAZARDOUS POLLUTANTS
BEING RELEASED FROM INDUSTRIAL AND
TRANSPORTATION SOURCES"
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CANADIAN ENVIRONMENTAL
PROTECTION ACT
(CEPA)
BECAME LAW IN 1988
TO ASSESS WHETHER TO CONTROL, OR
THE MANNER IN WHICH TO CONTROL
A SUBSTANCE
ANNUAL NOTICE IN GAZETTE
CONFIDENTIALITY PROVISIONS
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NPRI PROCESS
• ESTABLISHED MULTI-STAKEHOLDER ADVISORY
COMMITTEE
• WORK GROUPS
• TRIAL RUN
• BILATERAL DISCUSSIONS WITH PROVINCES
• DRAFT REPORT RELEASED
• REGIONAL PUBLIC INFORMATION SESSIONS
• FINAL REPORT FOR THE MINISTER
• SECTION 16 NOTICE
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MULTI-STAKEHOLDER
ADVISORY COMMITTEE
• INDUSTRY ASSOCIATIONS
CHEMICALS, PETROLEUM, MOTOR VEHICLES,
MINING, STEEL, PULP & PAPER
ENVIRONMENTAL & LABOUR GROUPS
CLC, GREAT LAKES UNITED, POLLUTION
PROBE, SODA, STOP, & UNION QUEBECOISE
POUR LA CONSERVATION DE LA NATURE
• PROVINCES (ACTIVE PARTICIPANTS)
ALBERTA, BRITISH COLUMBIA, ONTARIO
& MANITOBA (CORRES)
• FEDERAL (OGDs)
HEALTH & WELFARE AND ISTC
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NPRI REPORTING CONDITIONS
FOR 1993
"ANY FACILITY" WILL BE REQUIRED
TO REPORT:
TEN OR MORE FULL TIME EMPLOYEES
MANUFACTURE, PROCESS OR OTHERWISE
USE AN NPRI LISTED SUBSTANCE IN A
QUANTITY GREATER THAN 10,000 Kgs
PER YEAR
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NPR! SUBSTANCES
• STARTED WITH TRI LIST
• DELETED SUBSTANCES NOT ON DSL
• DELETED SUBSTANCES ON DSL < 1 TONNE
• REMOVED PESTICIDES
• REMOVED OZONE DEPLETING SUBSTANCES
• REMOVED BANNED AND CERTAIN
REGULATED SUBSTANCES
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EXCLUSIONS
• DISTRIBUTION OR RETAIL SALE OF FUELS
• MAINTENANCE & REPAIR OF TRANSPORTATION
EQUIPMENT
• WHOLESALE OR RETAIL SALES OF
MANUFACTURED ARTICLES OR PRODUCTS
• UNIVERSITIES, COLLEGES & SCHOOLS
• RESEARCH & TESTING LABS
• GROWING, HARVESTING & MANAGEMENT OF
RENEWABLE NATURAL RESOURCES BUT NOT
THEIR PROCESSING
• MINING
• OIL & GAS WELLS
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TRIAL RUN
• 78 VOLUNTEER COMPANIES
• TO BE COMPLETED BY THE END OF APRIL
• OBJECTIVES
• COMMENTS ON PRINTED FORM AND MANUAL
COMMENTS ON AUTOMATED FORM AND
MANUAL
EARLY LOOK AT THE NPRI
FACILITIES CAN COMMENT ON UNRESOLVED
ISSUES
Q&As TO BE BASIS FOR SUBSEQUENT
WORKSHOPS
^ INDUSTRY TO DETERMINE NPRI ASSOCIATED
COSTS
,x TRAINING FOR INDUSTRY, PROVINCIAL &
REGIONAL STAFF
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REPORT
• AVAILABLE TO THE PUBLIC
• BASED ON 1993 DATA
• REPORT OUT WITHIN 12 MONTHS
• FEDERAL REPORT WITH PROVINCIAL INPUT
• FORMAT
BY PROVINCE
BY ECOREGION
SUMMARY SHEETS
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UNRESOLVED ISSUES
CONFIDENTIALITY
QUANTITIES USED
• "HIGH PROFILE" SUBSTANCES
EMERGENCY RESPONSE
REPORTING THRESHOLDS
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HARMONIZATION
• ONE WINDOW
IDENTIFY ALL CURRENT & PLANNED
DATA REQUESTS
COMMON ANNUAL CYCLE
ELIMINATE DUPLICATION
DETERMINE DETAILS OF OTHER
REPORTING REQUIREMENTS
TALK WITH PROVINCES, STATISTICS
CANADA & OGDs
• ONE STOP SHOPPING
EASY ACCESS TO INVENTORY DATA
NPRI COULD CONTAIN INFO ON
RELEASES FROM OTHER INVENTORIES
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NEXT STEPS
• COMPLETE MAILING LIST
• MAIL COPY OF SECTION 16 NOTICE
• DEVELOP COMPUTER PROGRAM FOR
DATA INPUT
• RECEIVE DATA FROM FACILITIES
• INPUT AND COMPILE INFORMATION
• FINAL REPORT
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EVOLUTION
PRESENT
• AUTHORITY - CEPA
• "ANY PERSON" REPORTS
• SUBSTANCES-178
• REPORTING PARAMETERS
10 EMPLOYEES
10 TONNES-"USE"
-------
EVOLUTION (CONT'D)
FUTURE
• AUTHORITY
DEDICATED REGULATION
AMENDMENT TO CEPA
NO CHANGE
• "ANY PERSON" REPORTS
• SUBSTANCES > 178
• REPORTING PARAMETERS
^ 10 EMPLOYEES?
EXISTING TYPES OF SUBSTANCES -
10 TONNES
GHG » 10 TONNES
HIGH PROFILE SUBSTANCES -
1 TONNE RELEASE
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1993 TRI DATA USE CONFERENCE
TRACK AND
SESSION
SUMMARIES
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1993 TRI DATA USE CONFERENCE
STATE PROGRAMS
TRACK SUMMARY
TRACK OVERVIEW 39
SESSION 1: Building a State TRI
Program, Part I 41
SESSION 2: Building a State TRI
Program, Part II 45
SESSION 3: EPA-State TRI
Partnership 49
SESSION 4: State Use of TRI Data ... 61
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1993 TRI DATA USE CONFERENCE
TRACK OVERVIEW
The state programs track consisted of four break-out
sessions. The sessions were:
• Building a State TRI Program, Part I
• Building a State TRI Program, Part n
• EPA-State TRI Partnership
• State Use of TRI Data.
Surveys of state TRI Coordinators conducted by the
General Accounting Office, the National Governors Association,
the National Conference of State Legislatures, and the Ohio EPA
indicate that state TRI programs vary greatly in: 1) the resources
they have to administer their programs, and 2) the breadth and
depth of the services they provide to the public. The recent Ohio
survey indicated that although many states have a TRI program,
the program usually has very few resources attached to it. They
found, for example, that while 20 states have a full-time TRI staff
person, 26 do not employ any staff for TRI, and 29 states do not
have funds allocated for their TRI program. Some of this
variation can be attributed to the number of TRI facilities and
reports that the state manages. However, this characteristic alone
is not a reliable indicator of the strength of a state's TRI program
(i.e., some states with many facilities have few or no TRI
programs). Other variables (political, social, and economic)
contribute to the shaping of a state TRI program. We heard from
a number of state TRI Coordinators who, by sheer creativity,
enthusiasm, and drive, carved a niche for TRI into their state
government agency. The State Programs track at this conference
illustrated the great diversity in the state TRI programs.
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1993 TRI DATA USE CONFERENCE
sr-ssioN 1
SESSION 1:
Building a State
TRI Program, Part I
Introduction
The purpose of this half-day session was to foster
interaction among the states and to identify tools for building
and/or strengthening their TRI programs. Cindy DeWulf (Ohio
EPA) served as the session's facilitator and the following state
representatives gave presentations:
Paul Aasen (MN)
Jeany Anderson-Labar (LA)
John Bums (MS)
Darrell Chisholm (UT)
H. Sam Ebrahim (DE)
Terrence Franklin (KS)
Doug Friez (ND)
Steve Hanna (CA)
Becky Kurka (TX)
Dean Martin (MO)
Jim Saletnik (RI)
Lee Ann Smith (SD)
Dennis Walthall (OR)
The topics that were addressed by the presenters were: 1) setting
program goals and priorities, 2) marketing TRI, 3) effectively
maintaining TRI data, 4) developing and using outreach tools, and
5) potential funding sources.
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1993 TRI DATA USE CONFERENCE
Specific Issues Addressed
Overall themes that came out during this session:
• States are hard pressed for funds. Since this program has
no federal funding attached to it and no specific
requirements, it often is difficult for states to have ready
and reliable access to funds. Future statutory revisions to
the TRI program should specify state responsibilities and
attach resources to those required activities. Fines assessed
by FJPA could be shared with the states.
• Primary role of states or their mission is to educate the
public about TRI and inform the public about the toxic
releases in their states. This fulfills the intent of the Right-
to-Know Act.
• Where the TRI program is located in a state's bureacracy
often dictates how it is used (e.g., if it is in a pollution
prevention office, then it is used as a tool to promote and
monitor emission reductions).
• States would like EPA to provide more analysis of the data
or more guidance to the states so that they may conduct
their own analysis, particularly in the area of risk
assessment or comparative risk assessment.
• Most of the state TRI programs that have viable programs
owe their existence to state TRI or EPCRA fees systems or
EPA grants. Often these monies got their program up and
running enough to make them useful to the state and then
they received funding from state coffers.
• It is important for people to understand that TRI does not
regulate emissions but requires reporting of emissions. The
companies that report are not bad guys and are in
numerous cases reducing their emissions beyond regulatory
requirements, which is an action that should be positively
recognized.
• U.S. EPA can provide a wealth of information to the
states, and we need to strengthen communication links
between EPA and the states. National TRI conferences,
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1993 TRI DATA USE CONFERENCE
SI-SSION 1
Regional meetings, and FOSTTA and NASTTPO meetings
contribute greatly to this communication process.
There is a lot the states can learn from each other and
interactions of this type must continue.
Each state needs to continuously re-evaluate its TRI
customer base and examine how to meet the customers'
needs (e.g., look at high schools, libraries, outreach
packets for industry, etc.) States can share their
experiences to determine the proven methods to fulfill these
customer's needs. Again, the key to this is
communication.
Where Do We Go From Here?
The next steps for "Building a State TRI Program, Parts I
and II" have been consolidated and are found under the section
titled "Where Do We Go From Here?" in the "Building a State
TRI Program, Part IP session summary (page 47).
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1993 TRI DATA USE CONFERENCE
SESSION 2
SESSION 2:
Building a State
TRI Program, Part II
Introduction
The purpose of this session was to identify opportunities for
states to leverage resources to strengthen their programs. Eight
state representatives gave presentations on their own TRI
programs:
Gary Ayers (WY)
Margaret Ballard (ID)
Rudolph Carrier (NH)
Tom Ellerhoff (MT)
Max Johnson (NM)
Michael Juras (SC)
Jim Saletnik (RI)
Pamela Thurber (DC)
After the state presentations, three breakout sessions were
convened to brainstorm on the following topics:
1. How the states are using or could use the TRI data.
2. What EPA can do to strengthen state TRI programs.
3. What state organizations or other TRI interest groups
can do to strengthen state TRI programs.
Specific Issues Addressed
In the presentations and breakout discussions the following
issues were identified:
• If a state has only a few facilities, or if TRI is not a
priority, very little is done beyond giving people copies of
the Form Rs. These states need to find ways to get clients
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1993 TRI DATA USE CONFERENCE
for the data. The increased interest in pollution prevention
augments the value of TRI to other state environmental
agencies.
Need to find ways to get other state agencies to use the
TRI. Their interest will help strengthen the program. One
state representative described how the program was forced
to grow from a box of Form Rs to a fairly sophisticated
program: A group of housewives interested in that state's
data was directed to the box and they video-taped their
futile shuffling of the forms trying to make sense of the
information. They gave the video to a state TV station, the
station aired it, and the government shortly thereafter hired
the state representative.
The national report should include more state-specific data.
It could use more graphic representations of the data, such
as CIS-type release maps. It needs more than the top 10
releasers or state rankings. These data are a necessity for
states with few resources to conduct their own TRI
program. Summary state data sheets are needed to help
states meet FOIA requests.
Need to leverage the resources and communication
opportunities presented by FOSTTA, NASTTPO, the State
Pollution Prevention Roundtable, and NACEPT. These
organizations give states the opportunity to network with
each other and EPA, and a voice to influence federal policy
on TRI.
States need more consistent lines of communication with
EPA on issues such as how to handle revisions, trainings
for industry outreach, compliance consultations with
industrial facilities, public outreach products, and
enforcement inspections. The guidance and training
opportunities are there, but they need to be more
effectively passed along to the states. Also more
coordination by EPA with related state programs is
important, since states organize environmental and TRI
programs differently.
EPA needs to explore ways of empowering the states to
conduct data management.
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1993 TRI DATA USE CONFERENCE
SESSION 2
More data integration (with other data sources) should
occur. Integration of GIS is particularly useful. Also,
more attention to latitude/longitude data quality is needed.
Where Do We Go From Here?
EPCRA mandated roles for both the federal government
and the states', but appropriated monies only for the federal
managers. In light of the present budgetary climate at both the
federal and state level, it is unlikely that either will receive an
infusion of capital. Demand for an expansion of the information
collected under TRI and an increase in availability and the analysis
of existing data will require even more from our governments.
Other "creative financing measures" need to be sought for the
growth and strengthening of the respective TRI programs. This
session identified ways of building up state TRI programs. The
participants will be able to take the ideas and suggestions back to
their own agencies and decide which might be appropriate for their
own situation. This session also identified state peers that people
can contact for follow-up activities and guidance.
Participants afterward agreed that sessions like this should
be replicated in future TRI Regional and National meetings. The
opportunity for the states to discuss what has worked and what has
not worked with one another proved to be very useful at opening
up the dialogue process and inviting observations from all
participants, not simply those with strong TRI programs. We also
are evolving away from the pure EPA-run information sessions
into a more dynamic give-and-take meeting.
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1993 TRI DATA USE CONFERENCE
SESSION 3
SESSION 3:
EPA-State TRI Partnership
Introduction
This session, facilitated by Joe Goodner (EL), focused on
enhancing the EPA-State TRI partnership and, specifically, on data
quality efforts. Seven state TRI managers (Idell Hansen (WA),
Cathy Harris (VA), Kent Howell (GA), Elizabeth Flores (CT),
Valerie Hudson (KY), Ken Zarker (TX), and William Miner (NY)
and one regional coordinator (Mikal Shabazz, Region JOT) shared
their experiences on managing the TRI data in presentations that
touched on a variety of data quality improvement topics. In
addition, EPA data quality staff (including information managers
and compliance monitoring staff) discussed Agency data quality
initiatives during a discussion that followed the presentations.
Specific Issues Addressed
The need for TRI data collection at both the state and
federal level has been challenged in a number of states. Some
have said that the scarcity of resources, particularly at the state
level, points toward eliminating duplicative activities such as dual
TRI data entry. Most states in this session disagreed with this
assessment. They said that state TRI data entry is necessary for
the following reasons:
States are familiar with their industries and communities.
States can take more timely actions against facilities.
States need to be able to respond to questions.
States can have the data available quicker.
States contribute to data quality activities.
To economize on data management, it has been suggested
to eliminate low level reports. States were asked what they
thought of this. They responded negatively, citing the following
reasons:
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SHSSION 3
1993 TRI DATA USE CONFERENCE
• It is all so localized a state can't tell what level is right for
its communities.
• It all depends on what the chemical is and where it is.
• Smaller reporters shouldn't be treated differently. It is
good to get information on overall releases, large and
small.
• The "little" facilities are "big" facilities in little towns.
• The small communities' media will report on those "little"
releases, and it is an incentive for these "little" releasers to
decrease their releases.
• TRI is one of the only ways to capture this emissions
information because it does start small.
Communication between the EPA and the states on their
respective TRI Data Releases is very important. The states have
been excellent data verifiers for the national release. It is
necessary to pay more attention to data reconciliation between the
EPA and states' databases.
EPA guidance, training, grants, and conferences such as
these are important to strengthening both program levels.
States could be encouraged to have a more interactive role
in compliance monitoring. They could receive notification of up-
coming inspection and be invited to participate. States have more
specific information about industries in their states, which can help
focus enforcement resources.
All agreed that magnetic media will strengthen data quality.
States urged EPA to assist them in handling magnetic media
submissions.
Where Do We Go From Here?
As the demand for TRI increases, it becomes important to
not only ensure a good quality product but also to make sure that
the product gets to the customer. The federal government has the
responsibility for maintaining and distributing the national TRI
database, identifying ways of ensuring compliance, and delivering
the information to the public. During this session, the state
speakers and members of the audience had many suggestions for
strengthening this partnership. All agreed that EPA has the
responsibility to assume the national TRI manager role but, as the
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1993 TRI DATA USE CONFERENCE
SESSION
program grows and evolves, it must recognize that the states have
an integral role in the continued vitality of the program.
The states provide data early to their own constituents and
interpret those data for them. This lessens EPA's outreach and
analysis burdens and contributes to a more informed and involved
public.
The states verify the data, conduct trainings, distribute
products, and aid in compliance and enforcement efforts. They
are more attuned to their local industries and can respond in a
more timely and targeted manner to requests for information. This
helps EPA build up the industry response rate and improves the
quality of the data.
The states build pollution prevention or toxic use reduction
programs from the TRI data and identify other "connections" for
TRI with other data sources. While EPA can and has identified
ways of integrating the TRI data with other information pools, the
states greatly broaden the scope of innnovation. EPA is one
agency, and the states are 50+ separate agencies. The more the
data are used, the more they meet the intent of right-to-know and
right-to-act.
The TRI program will benefit greatly once this
interdependence is recognized and program decisions are based on
it. Toward this end, EPA will review the suggestions raised at this
meeting (some of which are listed below) and continue to identify
ways of increasing state input into the national TRI program's
development.
These are some of the areas we will focus on:
• Creative financing/grants
• Involve states in major initiatives
• Seek state input in outreach and assistance programs
• Invite states to trainings
• Involve states in compliance and enforcement activities
• Gain better understanding of state's data management
capabilities and needs
What follows are the presentations by the seven state presenters
and one regional presenter.
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Panelist Presentations
Idell M. Hansen, Washington State Department of Ecology
Washington state received a TRI data quality grant for 1991. This grant was the
beginning of our TRI data quality program. Data quality is a significant issue for us because
TRI release information is used in our pollution prevention legislation both for determining
which facilities must participate as planners, and as part of the basis for planning fees.
Our state can assist EPA in its data capture and quality control by providing the
information much earlier than headquarters is able to. In our analysis of the data, in writing our
state report, we discover data quality problems and are able to report them to the EPA Regional
Office. We also locate reporters who have failed to file a state or federal copy. Our office
serves as the state's Community Right-to-Know resource. EPA Region X is able to refer TRI
requests to our toll-free number.
EPA can best assist our state by making information available to us in a timely manner.
We have particular difficulty with Form R revisions and the long delay from when the forms
are received in July to the data release the following April or May. While we realize that
allowing revisions is important for data analysis, there should be a limit on revisions, perhaps
two or three years. At some point, you should close off the database to further revision.
Secondly, EPA should try to get the data out to the states earlier. We have requests for data
almost as soon as the reports are received. If we knew that it would be available from EPA by
November, we could avoid the problems and expense of duplicate data entry.
EPA could also support the state by providing a PC or LAN-based software
package/program that would be an integrated EPCRA database. This software should be usable
with both the Form R and Tier Two magnetic media packages.
EPA should provide the technical assistance for the states to access TRIS readily.
States can support each other primarily by communicating what they have learned from
their data and analysis and by sharing software programs where appropriate.
Our state is not able to process magnetic media forms. It is frustrating to reporters who
have gone to the expense of going to magnetic media to have to submit hard copy to the states.
We have had reporters who were unable to print their forms. Last year, we appreciated the
Form R software that allowed us to reload the data from a reporter and print the form.
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shssio:
Washington has enjoyed an excellent working relationship with our Regional EPA staff.
They have been helpful and responded quickly to our requests and have included us in their
training and actions where possible. We would like to see the enforcement penalties as a
possible revenue source for the state program.
We recommend the continuation of grant programs to the states. The grant program
allowed us to develop a data quality program that we will continue as long as our resources
allow us. The grants allow states to be innovative.
Cathy Harris, Virginia Department of Waste Management
How Virginia Can Support EPA's Information Management Needs:
Virginia's SARA Title m Program can be of assistance to the U.S. Environmental
Protection Agency in two important respects: (1) we maintain an up-to-date electronic database
for SARA Title m, Section 313/TRI data, which is also integrated with reporting under other
sections of Emergency Planning and Community "Right-to-Know", including 302,304,311, and
312; and, (2) we publish an annual Virginia Toxic Release (TRI) Summary Report, available as
a hard copy, and, on diskette, for the reporting years 1988-1991.
How Can U.S. EPA Support Virginia?
It is important that U.S. EPA continue to develop and promote brochures that provide
technical assistance to the reporting community for SARA Title m, Section 313/TRI. Our
Virginia regulated community has requested that a Question-and-Answer (Q&A) document be
made available, as in the past. Having the regulated community report accurately is essential
in promoting data use by state/local decision-makers who must have confidence in this database.
Also, the Commonwealth of Virginia would like to know, at least 30 days in advance, when
U.S. EPA will be making a new public data release/press release of TRI national data, in order
for us to prepare for the resulting public/media attention.
How Con the States Support One Another?
In October, 1992, Virginia disseminated the results of their 1991-92, U.S. EPA Data
Capabilities Program Grant for SARA Title m, Section 313/TRI, which resulted in a diskette
and user's manual distributed to all of the U.S. EPA Regions, and to all of the State Emergency
Planning Commissions (SERCs), including those in U.S. territories and possessions. We also
provide free examples of our Virginia Toxic Release Inventory Summary Report (hardcopy or
diskette), to interested SERCs/SARA Title m/EPCRA Programs.
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Magnetic Media Submissions:
Because we cannot print out a hard copy, the Virginia Program requests that any
magnetic media submissions from the regulated community also include a hard copy printout for
our archive.
Program Operations: Improving the Federal/State Relationship
Because U.S. EPA, Region m has enforcement responsibility for SARA Title m in
Virginia, they work closely with the Virginia Program to encourage and support voluntary
compliance from the Commonwealth's regulated community. The Region co-sponsors our
annual Section 313/TRI workshops, which will be held May 6, 7, and 10, 1993, in Roanoke,
Charlottesville, and Richmond.
Kent Hovvell, Georgia Department of Natural Resources
• How can Georgia assist in data capture and input, data quality control, and dissemination
of the data to the public?
— Contract with EPA for data entry.
— Provide our State data to EPA for cross checking.
— At this time we publish and distribute a State Toxic Chemical Inventory and
Release Report. Would consider input to a regional report.
• How can EPA support Georgia?
— Resource — State funding and contract for data.
• How can the States support one another?
— The programs from State to State vary so much, data exchange would probably
cause more confusion.
• Impact of magnetic media submission.
— No impact. We do not accept EPA magnetic media.
• Other aspects of program operations that can be unproved.
— More State input to enforcement decisions.
— Reasonable enforcement policies.
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Elizabeth A. Flores, State of Connecticut
Department of Environmental Protection
Retponte to: What are some other aspects of program operations (i.e., compliance and
enforcement) that can be improved by a tighter relationship between EPA and your state?
In the State of Connecticut, we have attempted to integrate the use of TRI data into all
three media programs — Air, Water, and Waste — within existing resources. We have
developed strategic plans on using the data in enforcement, permitting, and pollution prevention
programs. We enter the basic data into a data base and update it as necessary. We are also
gearing up to work with the top 10 emitters to evaluate emissions and gather information on
pollution prevention programs or plans and potential reductions. During the upcoming year, we
plan to work with the priority listed facilities to achieve reductions and employ preferred
management practices for TRI chemicals; and we plan to establish specific reduction goals for
the individual air, waste, and water media.
With regard to assistance from EPA in helping us achieve our goals, I believe it would
be helpful if EPA would:
• Provide funding for coordinating and implementing state use of TRI data;
• Coordinate with state representatives when we approach facilities to discuss pollution
prevention plans and goals (this is currently planned with Region I);
• Continue to communicate with the state on developments in the 33/50 program, including
names of participants, goals set, and reductions achieved;
• Submit a draft copy of TRI data to the state for review prior to publication (this was
done in this cycle, and although the time frame for response was too short, it is a good
idea). This gives the state a "heads up" on what data are being released. It also
provides us with an opportunity to reconcile some discrepancies.
• In particular, reconcile "top ten emitter" lists with the state, and provide the lists in
advance of a press release, as this can be a sensitive subject. States need to be prepared
to respond to the barrage of information requests about these facilities, their permitting
and enforcement status, etc., that are stimulated by a press release. In addition, EPA
should consult with states on how the top ten list should be generated. For example, in
the 1991 cycle, DEP did not include off-site transfers in its overall list of top ten
emitters, because we did not consider transfers a real "release" although we do think it
is important to capture that information, and encourage more source reduction and on-site
recycling of those wastes.
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• Continue to share information, technology, etc., related to the TRI program with the
states. Help us avoid spending our precious, overtaxed resources on "re-inventing the
wheel."
• Continue to provide a forum (at least on an annual basis) for states to share their
approaches and uses of TRI data with each other.
• Provide fact sheets on the top chemicals (their uses, hazards, health impacts, etc.) to help
states respond to public inquiries and concerns.
Valerie Hudson, Kentucky Department of Environmental Protection
What Can EPA and the States Do To Improve TRI Submitter Data Quality?
1) EPA should provide resources ($ through grants) to states to keep qualified staff available
to provide technical assistance to Section 313 filers and to conduct reviews of data
submitted to identify potential reporting errors.
2) Guidance Materials are important.
— EPA should update existing EPA Guidance Documents and the Q&A document.
— EPA and states (industry reps) should identify new guidance documents that are
needed.
— All available guidance documents should be listed in the Form R (guidance
documents for food processors and metal fabricators are still not listed in the
Form R even though they were published by EPA in 1990).
— Section 313 coordinators should get copies when new guidance is developed.
— EPA should develop a clearinghouse for Section 313 technical information and
final reports from state Data Quality and other grant projects. Provide List to
313.
— Additionally, EPA should make it easier for states to get extra copies of Section
313 brochures, Form R reporting packages, and other information for state
seminars.
3) Hold Seminars
— The Regions have been allocated money from headquarters to do outreach during
the last several years.
— KY holds at least one seminar each spring with the help of Region IV.
— EPA pays for the room at a hotel and provides a person to do the Section 313
overview.
— We have had industry representatives go over the Form R and provide
information on where to obtain information and how to do calculations.
— Our waste reduction center is also provided time on the agenda.
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SLSSION
Our seminar this year was in Louisville on April 22. We sent out flyers to all
KY Section 313 Technical Contacts and did a press release. We had 78 industry
representatives registered within 2 weeks of mailing the flyer.
(We put all technical guidance documents out with signing sheets and mailed out
copies after the seminar.)
Ken Zarker, Texas Water Commission
Background
The Office of Pollution Prevention and Conservation (OPPQ at the Texas Water
Commission (TWQ is very supportive of an EPA/State Partnership for TRI data management.
The OPPC is evaluating the development of a state TRI database and will be making
recommendations on the management of TRI data in Texas.
The TWC is dependent upon EPA for the TRI electronic data and uses the Tcxic Release
Inventory System (TRIS) for on-line queries and report generation. The TWC also creates its
state database from data downloaded from the EPA national database at the time of the public
data release. It is important for states and EPA to share the review of the data as early as
possible for those states that do not have their own systems.
Concerning the following issues:
/. What can states/EPA do to improve the quality of TRI data submitted?
Quality Assurance Issues — It would be useful for the EPA to make available to states
the data quality assurance procedures EPA uses to review the national Form R data
submittals. This would help states that have their own databases to maintain a consistent
quality approach to Form R processing.
Training & Outreach — It would be helpful for states to attend the national TRI training
course currently offered to EPA Regional personnel. This would assist the state in
developing an outreach program to the TRI reporters. The TWC would like to develop
more outreach, and it is critical that states receive training to assist TRI reporters in the
state. EPA might consider producing a video tape or software program to help tutor TRI
reporters.
States are also an excellent source to disseminate the data to the public. States can assist
in the distribution of the data release, public information, CD-ROM data, and other tools.
EPA should consider developing or enhancing a public education campaign to increase
availability and knowledge of TRI data.
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Tracking of Non-reporters — States should assist with the identification of TRI non-
reporters. For example, a state could supply the EPA non-reporters' information that
EPA could check against the national database and provide follow-up. States could also
provide knowledge on names and addresses of POTW, TSDs, and other entities to assist
with data quality.
Reviewing TRI calculations & estimates — EPA and states should continue to work
with trade associations to review the accuracy of the TRI data and other types of
emission estimating procedures. EPA should continue to review the accuracy of TRI
estimated data.
Funding State Programs — EPA should consider funding more state programs to assist
with improving data quality.
2. How can states and EPA work together to construct a cooperative and consistent
approach to enforcement based on data quality Issues?
The EPA can support states' efforts by communicating a national strategy for the
management of TRI data, including enforcement-related activities. The TWC is
supportive of national workgroups, such as FOSTTA, to assist with input from the
effective parties.
Training activities for state and EPA personnel are necessary to maintain a consistent
approach concerning compliance and enforcement activities. Training could be conducted
at a national EPA inspector training academy.
The EPA and states should consider offering incentives for accurate reporting by the
regulated community. This could be in the form of awards or recognition.
The EPA and states should continue to develop automated submittal of TRI data.
Because software development costs are high, both the state and federal governments
could benefit by working to increase the use of TRI software.
EPA should consider expanding the scope of TRIS to integrate data from other systems,
such as the Biennial Report System (BRS), RCRIS, NPDES, and emissions data collected
under the Clean Air Act. An assessment of the potential for integration of these systems
would be helpful in seeking efficiency in the collection of pollution prevention data.
EPA can assist states by disseminating the results from the various contractor studies and
state grant projects concerning enforcement strategies funded by the different programs
at EPA.
EPA should continue to support the Total Quality Management philosophy by offering
states funding to train staff.
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William Miner, New York State Department of Environmental Conservation
Question 1: What can States/EPA do to Improve the quality of TRI data submitted?
1. States maintain TRI databases, review incoming data, and produce annual reports that
help to improve the quality of TRI data. The reasoning behind this statement is that state
TRI coordinators are familiar with reporting facilities' track records and should be able
to readily detect common errors or unusual data, then alert the reporting facility so it
may make revisions as appropriate. This process takes a matter of weeks as the
incoming data is entered onto the state database.
Also, since facilities recognize that their data may be published in a state annual report,
they tend to ensure that their data are valid. These reports also provide report cards on
how facilities are reducing the amount of release.
The U.S. EPA could help to sustain this process by providing funding to states that
maintain TRI databases and/or publish annual state TRI reports.
Question 2: How can states and EPA work together to construct a cooperative and consistent
approach to enforcement based on data quality Issues?
2. Without routine Federal funding for state TRI activities, it will be difficult to construct
a cooperative and consistent approach to enforcement bases on data quality issues.
Mikal Shabazz, U.S. EPA, Region III
Region Hi's Data Quality Inspection Strategy
— Industry Standard Chemical Usage
— Industry Standard Chemical Emissions
— Year-to-year Comparisons of Usage and Emissions
How EPA Can Help States
— Inform and Invite States on Inspections
— Provide Cooperative Agreement Grants
— Provide States with TRI Data & Training
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How States Can Help EPA
— Inform EPA on Low Level of Compliance Industries or Areas
— Apply for an Enforcement Cooperative Agreement Grant
— Provide Feedback on TRI Data and other EPA TRI Activities
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SESSION 4
SESSION 4:
State Use of TRI Data
Introduction
TRI data have been used in various ways by state
regulatory programs. Some reasons for the use of TRI data are:
• TRI data have a relatively high level of data quality;
• TRI data report releases to all environmental media;
• Multiple years of data exist for trend analyses;
• TRI data are chemical-specific.
The topics discussed in this session relate to the uses of
TRI data by states in various ways, and include discussions of
comparative risk, integration of TRI with SARA 311 and 312
activities, and expansion of the reporting universe. These
activities may appear to be headed in somewhat different
directions, but all activities indicate a trend toward incorporating
TRI data in ongoing regulatory program activities.
Specific Issues Addressed
Jim Tinney, from Pennsylvania, described his data
management practices. In PA they are spending time identifying
who the customers of the data are and how they are using the data.
These types of activities help them focus their resources on
creating useful TRI products. They have found the "general
public" to be the biggest customers. In the future they hope to
develop remote accessing capabilities for their users so that the
TRI user can directly access the data without a state "middleman."
Marianne Fitzgerald, from Oregon, described Oregon's
efforts to establish a multi-media environmental management
approach. They have found the TRI to be a natural for these types
of activities. They are conducting a comparative risk project using
a variety of inputs on which to make policy decisions — going
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beyond the risk analysis data to include political, social, and
economic data.
Cathy Harris, from Virginia, discussed the great utility of
TRI data for various pollution prevention initiatives being
conducted in the state. They are exploring ways of establishing a
voluntary pollution prevention program. They are pleased with the
numbers they are seeing coming out from their industries already.
She commented that if industry keeps moving in the right
direction, there won't be a need to tighten rules and establish fees.
Joel Lindsey, from Louisiana, discussed the work being
conducted by Southern University on tracking release hi the
Mississippi River Corridor in southern Louisiana. They are
looking at releases, exposures, and possible risks to health. This
is a particularly important effort to tie TRI information to possible
health risks. This area of the U.S. has very large TRI emissions,
particularly to surface water, which is the area's main drinking
water source. Mapping and environmental equity activities are
planned for the near term. We look forward to tracking this
project.
As mentioned in the Introduction, the projects described hi
this session are relatively diverse, yet all indicate a closer
relationship between TRI data and state regulatory programs. The
future of environmental data collection by regulatory programs
must be based upon standardized quantitative chemical-specific
data, and the TRI process has demonstrated its effectiveness in that
regard. Future directions should include:
• Continuation of meetings that allow states and U.S. EPA to
exchange information.
• Continuation of active support, by states and U.S. EPA, of
activities such as the Forum on State and Tribal Toxics
Action (FOSTTA), the National Advisory Council for
Environmental Policy and Technology (NACEPT), and the
various TRI focus groups coordinated by U.S. EPA.
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Continuation of collection and distribution of annual state
TRI survey data, which is currently performed by the state
of Ohio.
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Panelist Presentations
James H. Tinney, Pennsylvania Department of Labor & Industry
Data management in Pennsylvania
I. Events that shaped Pennsylvania's approach
• December, 1984 — PA Right-to-Know Law Enacted
• October, 1986 — SARA, Title m Passed
• April, 1987 — Governor's Executive Order Creates the SERC
• December, 1990 — PA Act 165 Passes
n. Optic Disk Image System
• What is it?
• How is it used?
m. TRI Media Forms
• Optically Stored Images of TRI Reports
• AS/400 Data Base
— Index Data
— EPA Magnetic Tape Data
• EPA's CD-ROM
IV. TRI Data Formats Available
• Copies of Form R
• Topical Index
• Structured Query
• Complete Data Base
V. TRI Data Transmission Methods
By Mail
Via Citizen Access Workstation
By FAX
Via Electronic Bulletin Board
Via Magnetic Media
— Floppy Disk
— Magnetic Tape
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SHSSION 4
VI. What Data Was Requested
• TRI 204
• Tier H 84
• MSDS 16
• Lists 17
• Magnetic Media 17
• Structured Queries 111
VH. Who Requested Data?
• General Public 170
• Government 20
• Lawyers 34
• Interest Groups 70
• Consultants 78
Vm. Pages of Data Produced
• TRI 86,444
MISC 7,962
• MSDS 4,056
• TIER H 9,657
IX. Future Plans for Data Distribution
• Remote Access
- FAX
— Dial-In Data Queries
— Electronics Bulletin Board
• CD ROM Service
• Electronic Filing and Data Exchange
• Citizen Kiosks
X. For More Information
Bureau of Worker and Community Right-to-Know
Room 1503, Labor and Industry Building
Seventh and Forster Streets
Harrisburg, Pennsylvania 17120
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REACH OUT, PA!
(A pilot Toxic Release Inventory outreach project)
WHAT IS REACH OUT, PA!? REACH OUT, PA! is the name of a pilot
outreach program being conducted by the Environmental Protection
Agency (EPA) (in cooperation with participants from your state) to promote
the Toxic Release Inventory (TRI) in Pennsylvania.
WHAT IS THE TOXIC RELEASE INVENTORY? The TRI is a collection
of chemical information reported by certain manufacturing companies to
EPA. The establishment of a toxic release inventory is mandated under
Section 313 of the Emergency Planning and Communrty-Right-to-Know Act,
or EPCRA. (TRI is also referred to as Section 313 of EPCRA.) Companies
reporting to TRI submit the names and estimated amounts of chemicals they
released to the air, land and water during a calendar year. For 1990. the
fourth year of reporting, over 80,000 reports were submitted to EPA on the
300+ chemicals regulated under Section 313 of EPCRA.
WHY IS EPA PROMOTING THE TRI? Because you have a right to
know that this information is available to you and how you can use it. Do
you know that EPA has placed the TRI at thousands of locations across the
country? If you are like so many others, you probably do not know this
information may be in your community! Although the TRI has been publicly
available for nearly four years, the general public does not know this
information even exists - much less that is readily available and easily
accessible.
WHERE IS THE TRI AVAILABLE IN THE STATE? The TRI has been
provided to nearly 100 libraries in Pennsylvania. Reporting companies in your
state also submit their TRI information to you state's Department of Labor and
Industry in Harrisburg. The EPA office in Philadelphia can also assist you with
obtaining TRI information.
HOW CAN TRI BE USED? TRI was intended from its inception to spur
voluntary action by businesses, citizens, and local government to reduce
toxic pollutant emissions, and there is ample evidence that it is achieving this
goal. The TRI is a new source of data for a broad based audience. Citizens
use the TRI to become more educated in the area of toxic chemicals in their
neighborhoods. Many citizens, either individually, or through special
community groups, use the data to facilitate discussions with local
companies about their chemical releases. Public interest groups make
effective use of the TRI data by educating citizens, preparing revealing
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company profiles and urging companies to reduce their chemical releases.
Hospitals, schools and state and local governments use the TRI data for
developing emergency planning and response plans at the state and local
levels. The publicity that has resulted from the public availability of the TRI
has caused many companies to voluntarily pledge to reduce their toxic
chemical releases.
WHY IS EPA CONDUCTING THIS PILOT? EPA Is looking for effective
ways to promote TRI at the local level. Pennsylvania Is being used to test the
effectiveness of working with local groups and organizations. Pennsylvania
is being used as the 'testing ground" to determine if a state's own network
of information providers is an effective way to conduct a TRI outreach
program. The pilot is working with 'multiplier' groups in your state (those who
have the ability to reach a larger and more diverse audience) who have
expressed an interest in being educated about TRI and are willing to share
what they leam with their constituencies. The pilot seeks to build 'information
networks" among local and state organizations, both large and small. The
Pennsylvania pilot may become the model for other states or state groups
who wish to conduct similar TRI outreach efforts.
WHY WAS PENNSYLVANIA SELECTED FOR THE PILOT? Several
factors were considered in selecting Pennsylvania. The demographics of the
state - especially the presence of urban and rural communities - was one
consideration. The state has numerous, varied "interest groups" and active
grassroots organizations. Pennsylvania's TRI profile ranks it 12th in the nation.
It has a regional EPA office On Philadelphia) and most importantly, there was
support from many of your state organizations to conduct the pilot.
HOW CAN I FIND OUT MORE INFORMATION ABOUT THE TRI
OUTREACH PILOT? For more information about the TRI Outreach Pilot or
to get on the mailing list for the newsletter, REACH OUT, PA!, please contact
one of the following individuals: Mikal Shabazz,TRI Coordinator (3A-T31), U.S.
EPA, 841 Chestnut Street, Philadelphia. PA. 19107. (215) 597-3659 or Deborah
Williams, U.S. EPA, OPPT (TS-793), Washington. D.C. 20460, (202) 260-4136.
WHO SHOULD I CONTACT FOR MORE INFORMATION ABOUT
THE TOXIC RELEASE INVENTORY? For more information about TRI,
write or call (202) 260-1531, the TRI User Support Service (TS-793), U.S. EPA,
Washington. DC 20460 or Mikal Shabazz, TRI Coordinator. U.S. EPA, 841
Chestnut Street, Philadelphia, PA 19107. (215) 597-3659.
UPCOMING EVENTS: EPA is planning to sponsor several workshops during the spring
and summer of *93 for various participating groups, in addition to exhibiting TRI at
conferences sponsored by state organizations. Notice of these upcoming events will
be advertised in the newsletter, REACH OUT, PA! which is sent to over 300 groups
and individuals across the state.
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Marianne E. Fitzgerald, Oregon Department of Environmental Quality
Introduction
The Oregon Department of Environmental Quality was awarded a grant from the U.S.
Environmental Protection Agency to develop a methodology for incorporating cross-media risk
assessment considerations into agency programs that traditionally have been focused on single-
media concerns in air pollution, water pollution, or waste management. The project was
designed to develop procedures to ensure cross-media coordination within DEQ, develop a
methodology for evaluating cross-media impacts, and develop a more integrated approach to
problem-solving that enhances our goal of pollution prevention.
The Cross-Media Risk Assessment Project was successful in identifying and developing
several methods for DEQ staff to achieve this goal. This report summarizes the project resumes,
findings, and recommendations. Specific applications will be discussed during the presentation.
Background
The history of environmental regulatory programs in Oregon and the nation centers
around the laws that were enacted to solve specific environmental programs. The Clean Air
Act, the Clean Water Act, the Resource Conservation and Recovery Act, and the Superfund laws
were written to address problems in air pollution, water pollution, toxic waste management, and
clean-up of contaminated properties. The Federal EPA and the Oregon DEQ established budgets
and organizational structures to correspond with the legislative mandates, resulting in each
mandate being administered by separate programs within the regulatory agencies. This
segmentation of regulatory authority, while successful in meeting the mandates, has sometimes
had the effect of regulating discharges to one medium without regard to their effect on others.
The traditional "command and control" approach to controlling pollutant discharges to a single
medium may not adequately evaluate cross-media impacts, and may not adequately allow for
consideration of pollution prevention alternatives. This single-medium approach impedes our
effectiveness in dealing with facilities with multi-media concerns, and in fostering a proactive
preventative approach to environmental management.
The first goal in DEQ's Strategic Plan, adopted in 1990, states that the agency will
"address environmental issues on the basis of a comprehensive cross-media (air, water, land)
approach." It states:
"This goal will require the Agency to revise and update procedures for permit
application and evaluation, permit issuance, review of engineering plans, and
review of technical proposals to assure that the requirements in one environmental
medium (air, water, land) complement the efforts in other media and do not
create new problems. It also calls for special efforts to assure that agency actions
and standards protect health and the environment, are based on uniform
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SESSION 4
acceptable risk factors, appropriately consider cumulative effects of pollutant
exposure through various pathways, and provide an adequate margin of safety.
To support this goal, it will be necessary to establish a data management system
in which ambient environmental data, source emission data, and compliance
information from each program are accessible and useful to other programs."
The Cross-Media Risk Assessment Project was designed to develop procedures to ensure
cross-media coordination within DEQ, develop a methodology for evaluating cross-media
impacts, and develop a more integrated approach to problem-solving that enhances our goal of
pollution prevention. This integrated approach could be applied in several different ways:
• During permit application review, to evaluate long-term fate and transport of toxic
chemicals discharged to the environment, evaluate alternatives for control or treatment
of pollutants, and determine the most environmentally sound approaches for pollution
prevention and waste management and disposal. For example, a particular air pollution
control technology may result in increased discharge to the surface water. The relative
risks would be evaluated to determine if a net environmental benefit would be
demonstrated.
• During the rulemaking process, to consider broad cross-media issues through a
comparative risk approach. One example would be to compare the tradeoffs between air
pollution caused by field burning and water pollution caused by increased fertilizer use
on the fields. Another example would be to compare the relative risk associated with
heat treatment of petroleum-contaminated soil with open aeration of the soil.
• Within enforcement programs, to prioritize compliance and enforcement resources, so
that sites or pollutants representing the greatest cross-program environmental risk are
given highest priority.
In order to accomplish the project goals, project staff needed to develop an internal
communication process, as well as the tools for considering cross-media, human health and
ecological impacts when evaluating alternatives. We did this by researching similar work done
by EPA and other states, and by setting up two advisory committees: an internal steering
committee and an external advisory committee.
Project Results and Findings
Over the course of the past 15 months, the Cross-Media Project staff and committee
members recommended procedures for identifying and discussing cross-media concerns in
rulemaking and permit program activities, and developed a methodology for analyzing cross-
media impacts and comparing relative risks associated with alternative strategies. We are
currently in the midst of a pilot phase to test the appropriateness of the forms and procedures
that were adopted, and to test the utility of the Cross-Media Comparative Risk Model in
different applications.
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Some specific findings and recommendations are summarized below:
Formal rulemaking procedures were revised to incorporate language that prompts staff
to investigate and evaluate potential cross-media impacts associated with a proposed rule
or alternative.
Permit program procedures were revised to incorporate a supplemental form that would
be included with permit applications for new and modified facilities. The forms (one for
new and one for modified facilities) are intended to benefit all parties concerned by
considering overall environmental impacts early in the permit process and avoiding
unnecessary delays during permit review and facility construction. The forms help both
the applicant and DEQ analyze potential impacts of the proposed facility on all
environmental areas of concern, and should facilitate dialogue among DEQ programs.
Specific procedures rely on electronic communication and cross-media workgroups to
identify and discuss issues. The main concern was the amount of additional time it
would take to fill out the form, process the information, and coordinate with other
programs that may have different priorities. The procedures will be re-evaluated after
a pilot phase.
A process for establishing cross-media workgroups was established to facilitate an
integrated approach to rule development or permit review. Some of the specific
recommendations address how to notify other programs, who should participate, what
issues should be considered, and how to document results.
A Cross-Media Comparative Risk computer model was developed that evaluates cross-
media impacts and ranks the relative risks to human health and the environment
associated with pollutant discharges. This model is designed to be used as a screening
tool in place of the more data-intensive traditional risk assessments. The model
qualitatively determines the impact of exposure to a chemical and the hazard of this
exposure through calculation of a human risk index (HRI) and an ecological risk index
(ERI). The model then ranks these indices from low to high. The model also links to
the Geographic Information System (GIS) software, one of EPA's most effective tools
for integrating and geographically analyzing environmental data and displaying the output
on maps.
A number of basic assumptions have been made in the development of the model which
are essential to understanding the utility as well as the limitations of the model. One of
the most important considerations is that the Cross-Media Comparative Risk Model is
merely a tool to provide one piece of information on which to base a decision (that is,
relative risk), but many other factors (such as technical and economic feasibility and
long-term liability) are equally important to the decisionmaking process.
The DEQ is conducting field tests to test the application of the model in several areas:
choosing among pollution prevention alternatives (such as chemical substitutes or
alternative technologies); comparing alternative treatment technologies for petroleum
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contaminated soils; targeting inspections for several facilities within a region based on
multi-media discharges; and choosing priority pollutants of concern at a facility with
multi-media discharges. The field test results will be used to calibrate the model and
evaluate its usefulness as a tool in the different applications.
• One major limiting factor in applying the model is the public availability of chemical-
specific discharge or emission data. DEQ's current single-medium databases do not
contain sufficient chemical-specific data or locational data to conduct the cross-media
evaluation. EPA's Toxics Release Inventory (TRI) database provides the most
comprehensive, multi-media database available at this time. Although the model is
designed to input data from any source, we had to rely extensively on TRI data for field
testing the model. An integrated database such as the one described in the Strategic Plan
is needed to generate a more holistic view of a facility.
• Another limiting factor in field testing the model was a concern about the public
perception of risk and how the model's results would be interpreted. The industry
representatives on the advisory committee were reluctant to participate in the field tests
without the ability to evaluate the results in confidence, prior to release to the public.
The Attorney General's office advised that this is not possible unless the data meets the
tests for confidentiality under Oregon's Public Records Law. The industry
representatives are interested in testing the model independently from DEQ when a PC
version of the model is available for distribution to the public. The advisory committee
acknowledged the seriousness of this concern and recommended additional risk
management and risk communication training for those using the model.
A major key to the success of the project is the institutionalization of the cross-media
approach within DEQ programs. Project staff presented this project at the DEQ Quarterly
Managers Conference on November 17, 1992, in which these findings and recommendations
were reviewed and discussed. Project staff also worked with EPA Region 10 to develop a
workshop on "Pollution Prevention in the Permit Process" on January 28, 1993, in which over
40 DEQ staff members participated. The cross-media project was presented during this
workshop, and participants identified the need for improved cross-media communication among
DEQ programs and among other programs (such as local pretreatment programs) as one of the
most important means to achieve our goals of pollution prevention. The steering committee
recommended that as we gain more experience hi using the cross-media approach to problem-
solving during the current field testing efforts for both the model and the permit forms, these
tools will be re-evaluated and, if useful, assimilated into program implementation.
Conclusions
The Oregon Cross-Media Risk Assessment Project is a first attempt to address the cross-
media transfer of pollutants and qualitatively evaluate impacts to human health and the
environment. The project has led to increased awareness among DEQ staff for the need to
improve communication between staff, the regulated community and the public. The model
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provides us with a simple screening tool for comparing risks associated with different pollutant
discharges and has broad applications both to DEQ and to the regulated community. Because
the model is new, the process of validating and refining the model, as well as developing further
applications, will extend beyond the formal completion of the project grant. There are a number
of areas that can be refined and improved as new information becomes available. The report
to EPA represents a milestone to satisfy a condition of the EPA grant; it is our hope that the
methodology developed as part of this project will continue to be applied and tested within DEQ
programs, and will serve as a starting point for other states that are interested in addressing
similar concerns in their approach to environmental protection.
For a copy of the final report to EPA or the Oracle PC version of the comparative risk
model, please contact Marianne Fitzgerald, Oregon Department of Environmental Quality,
Regional Operations Division, 811 S.W. Sixth Avenue, Portland, Oregon 97204, telephone (503)
229-5946. The report and computer program will be available sometime in April, 1993.
Cathy Harris, Virginia Department of Waste Management
Resources:
The Virginia Department of Waste Management has invested considerable resources in
the implementation of the SARA Title m program, focusing on TRI data management and
reporting:
• $100,000 in computer software and hardware;
• Staff time from all four full-time personnel, and two part-time personnel, for such
activities as:
— Management of the database
— Quality assurance and quality control of the database
— Analysis of the data
— Preparation of the Virginia Emergency Response Council SARA Title m Section
313 Report
— Dissemination of information to government, industry, and the public
— Technical assistance
— Responding to public inquiries
— Co-ordinating data with local governments and state environmental agencies for
planning and policy-making;
• Approximately $67,000 budgeted for Section 313/TRI data management and reporting
activities during the 1992-94 budget period.
Although the SARA Title m Program previously was combined with the Virginia Waste
Minimization Program, this latter activity has become a full program in its own right: the
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Virginia Pollution Prevention Program. SARA Title m, Section 313/TRI data is one of the most
important databases available for information to pollution prevention decision-makers, and the
close working relationship between the two programs is expected to continue.
Perhaps the single, most important change occurring for the SARA Title III Program in
1992-1993 will be the fact that the Virginia Department of Waste Management (in which the
Program resides), the Virginia Department of Air Pollution Control, and the Virginia State
Water Control Board, together with the Virginia Council on the Environment — all will be
combined together into a new, state environmental "superagency": the Virginia Department
of Environmental Quality. This change will occur on April 1, 1993.
Outreach:
Because the Virginia Emergency Response Council (VERC) encourages voluntary Title
HI compliance, the Virginia program is extremely active in the Commonwealth, providing
government, the regulated community, and the public with updated information:
1. Regular mailings of updated changes to SARA Title m to Virginia facilities, LEPCs, and
state agencies;
2. Regular seminars, held regionally throughout Virginia, explaining reporting requirements;
3. The Annual Virginia Solid and Hazardous Waste Management Conference, held in April
each year, in Richmond, which has a section for SARA Title m issues;
4. Regular articles in the Virginia Department of Waste Management Newsletter on SARA
Title ffl for the public;
5. Co-operation with inter-agency Task Forces, Committees, and Work Groups, to promote
SARA Title m issues in state-wide planning, policy-making, and for new or pre-existing
environmental programs or activities; and,
6. Providing information through informal talks, telephone consultation, and assistance to
the public needing information about chemical releases and community planning for
hazardous materials emergencies.
Data management:
Data received from 313 reporting are entered into the computer on d-BASE, using the
Toxic Chemical Release Inventory Form R; this database is used to provide the information
summarized in the VERC SARA Title III Section 313 Report, which is prepared annually.
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The January 1992 report provides such information as: comparisons amongst 1987,1988,
1989, and 1990 TRI data (taking into account the deletion of sodium sulfate, for example);
releases by type of media; an alphabetical list of chemicals reported for 1989; releases by
chemical; total chemical releases for 1989; facility information; and releases by industry
classification by SIC Code, by county, and by city.
As of October 1, 1991, the SARA Title Hi/Waste Minimization Program of the Virginia
Department of Waste Management received a one-year, $25,345 ($19,000 from U.S.
EPA/$6,345 match from VDWM) TRI Data Capabilities Program grant to advance the
management of the Section 313 database. This grant was intended to integrate the reporting
years of Section 313/TRI data with other SARA Title m databases (e.g., Sections 311/312) -
and then use this advancement to promote "33/50"/Industrial Toxics Project (TTP) reductions and
related Virginia pollution prevention efforts.
Use of TRI data in Virginia:
Use of the Section 313 database/reports — available publicly (at cost) as a hard copy
report, and on diskette — has been by those planners and policy-makers in Virginia state and
local government who are interested in hazardous materials response, emergency planning,
environmental enforcement, and/or the minimization of hazardous waste. The Secretary of
Natural Resources (to whom the Director of the Virginia Department of Waste Management and
Chairperson for the Virginia Emergency Response Council reports) takes a special interest in
this report, and in the implications of the data for the progress being made by Virginia
businesses to reduce chemical releases to the Commonwealth's environment.
Partly as a result of this annual report, state agencies responsible for environmental
protection (in particular, the Virginia State Water Control Board and the Virginia Department
of Air Pollution Control) have increased their technical assistance to and regulatory compliance
monitoring of Virginia facilities.
Greater cooperation has been fostered as well, through a $300,000 Interagency
Multimedia Pollution Prevention (IMPP) grant from U.S. EPA, shared among the agencies that
will compose the new Virginia Department of Environmental Quality. This has included: (1)
education of state agency permitting and enforcement staff on how to integrate pollution
prevention into their day-to-day activities; and (2) outreach to the Virginia regulated community
of SARA Title m, Section 313/TRI companies with releases to the air, land, and water.
In Virginia, SARA Title m, Section 313/TRI data have been the focus not only of such
U.S. EPA-sponsored pollution prevention initiatives as "33/50"/the Industrial Toxics Project
(ITP) — but also efforts by these three state environmental agencies and the Office of the
Secretary of Natural Resources to identify Virginia-specific concerns needing to be addressed.
Local governments in Virginia have used TRI data to their advantage, as well. One
example of effective use of the Section 313 data by a Virginia LEPC has been in Fairfax
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County, which is part of the Washington, D.C., metropolitan area. As reported in the EPA
Successful Practices in Title III Implementation: Chemical Emergency Preparedness and
Prevention Technical Assistance Bulletin, December, 1989, the LEPC compared the toxic release
Form R submissions with the list of facilities submitting Tier n forms (as requested by the
County for Section 312 reporting). Based on this comparison, it was determined that all
facilities reporting under 313 had also reported under 311-312. This LEPC has direct computer
access to the 313 data, using the county fire department's hazardous materials response vehicle
link to TOXNET, as well.
References
Understanding SARA Title III: Emergency Planning and Community Right-to-Know in Virginia,
by Cathy L. Harris, Virginia Department of Waste Management, Richmond, Virginia, April,
1992.
1990 Toxic Chemical Release Inventory (TRI) Summary, Virginia Emergency Response Council,
Richmond, Virginia, January, 1992.
Joel Lindsey, Southern University
Using TRI data
Human and economic resources are unevenly distributed along the Mississippi River, yet
they are interconnected. Threats to the integrity or survival of any part of this corridor affect
the whole river. Deteriorating water quality will influence the quality of human health and
impact plant and animal life.
There has been an emerging public awareness of the impacts on man and nature. The
public knows that the Mississippi River provides drinking water, habitats for aquatic wildlife,
irrigation for crops, waterways for transportation, areas for recreation, and a wide variety of
industrial uses, including power generation and cooling water. Unfortunately, it also has
provided a handy receptacle for waste disposal. The river is polluted by municipal sewage,
storm water run-off, industrial wastes, and irrigation of crop land. Fresh water supplies drawn
from the Mississippi must be constantly monitored and treated.
The purpose of the report was to give a review of a community consensus that we
developed to address the environmental problems of the Mississippi River Corridor from Baton
Rouge to New Orleans. The Institute for Environmental Issues and Policy Assessment (ffiPA)
acted as the lead, nonpartisan, facilitator in negotiation sessions to build on the framework
developed in 1991 by the "Leap to 2000 — Louisiana Environmental Action Plan."
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Comparative risk assessment
What was the Leap to 2000 Project?
The "LEAP to 2000 — Louisiana's Environmental Action Plan" was a landmark
agreement to improve the way citizens manage their environment. Members of the planning
group negotiated and ratified the agreement. The federally funded plan was completed in
November of 1991.
Louisiana is one of the first states to embark on this kind of environmental study. This
project involved representatives of 12 state agencies and over 30 interest groups who worked for
over eighteen months to reach a negotiated agreement. The diverse groups included the
chemical and oil industries, various environmental organizations, fish and wildlife interests,
labor and tenant advocates, as well as three federal agencies.
The result of the work is a ranking of the 35 most important environmental issues in
Louisiana. Issues were ranked into one of the three categories: issues of highest state-wide risk,
issues of high state-wide risk, and issues of high localized risk and/or continuing concerns.
Furthermore, the group determined that air toxic releases, wetland loss, and industrial waste
water discharge posed the greatest risk to the health of citizens and the environment.
The ranking took place in three steps. First, a Technical Committee reviewed the most
current environmental data and assessed the risks posed to human health, Louisiana's
ecosystems, and the quality of life. Second, the Public Advisory and the Steering Committees,
known as the PASC, reviewed the results of the Technical Committee's work and completed a
provisional ranking, combining the three types of risks. Third, the PASC considered the views
of Louisiana citizens who participated in a statewide environmental summit and 11 town
meetings to complete a final ranking. The state is committed to continuing the project state-
wide. The governor signed an executive order to carry forward the work.
The "LEAP to 2000 — Louisiana Environmental Action Plan" provided the Institute for
Environmental Issues and Policy Assessment at Southern University and its collaborators with
a springboard for action based on the consensus established, the networks that were developed,
and the personal contacts formed. The Citizens Advisory Committee took the "LEAP to 2000
Project Report" and looked at areas of agreement to provide strategies, solutions, and to focus
on reducing potential obstacles to environmental risk. In particular, committee members looked
at air and water toxics and growth management issues faced along the Mississippi River
Corridor.
The river, which meanders 166 miles from Baton Rouge to New Orleans, is the site of
hundreds of historical places, small and large towns, and a major petro-chemical manufacturing
center. The national press and local residents refer to this area as "cancer alley" due to incidents
of this dreaded ailment. Many suspect toxic chemical discharges contribute to the cancer risk.
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How were the issues selected?
Air toxics emissions, water discharges, and growth management ranked in the top ten in
the LEAP to 2000 Project. In the corridor these three issues are especially acute due to the high
concentrations of chemical facilities located on the banks of the Mississippi. Water discharges
into the Mississippi River from facilities located in the corridor amount to more than 98% of
Louisiana water pollutant releases.
What process did the Citizens Advisory Committee use to link obstacles to reducing
environmental risk with action?
The Citizens Advisory Committee met in two day-long meetings to hammer out an
agreement. The committee reviewed the accomplishments and status of the LEAP to 2000
project.
Three subcommittees analyzed the issues, air emissions, water discharges, and growth
management. Members discussed draft action strategies for reducing environmental risk.
Budget actions in the Louisiana Department of Environmental Quality for state fiscal year 1992-
1993 aimed at curbing air and water emissions were examined. These figures revealed no new
allocations to stem the flow of toxic chemicals into the river. Subcommittee members then
prioritized the strategies and reported to the group.
After lengthy discussions of the major action strategies, each representative voted on his
or her top five approaches to reducing toxic air and water releases and addressing growth
management in the Mississippi River Corridor. In the second meeting they worked out a
detailed approach to tackling these issues in the corridor.
Recommendations to link action strategies with obstacles for reducing environmental risk
to air, water toxics, and growth management:
Issue an Annual Report
The advisory committee recommended that an annual report on the health of the citizens
and the state of the environment specifically focused on the Mississippi River Corridor be
issued. Why is a report needed? Currently the State and Environmental Protection Agency
reports on toxic discharges focus on the state and national picture. There is a need to zero in
on the corridor because of the high concentration of chemical producing facilities in such close
proximity to communities located near the river. This report would provide citizens access to
technical information on toxic emissions on a yearly basis so those living near the giant chemical
complexes could determine the current level of emissions and the success, if any, of planned
waste reductions.
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The annual report should be the work of an independent institution that has the trust of
grass roots organizations, community leaders, industry executives, and government officials.
The report should focus on human and environmental information showing yearly trends. In
addition, the report should review actions and budget allocations of federal and state agencies
who have responsibility protecting the water and air in the corridor. This analysis will pinpoint
budgetary roadblocks to reducing toxic discharges into the river.
An area of special concern to the advisory committee was that the report analyze the
chemical discharge data. This would include an analysis of toxic chemical releases to the water
and air in the corridor and report on trends in pollution reduction efforts by these facilities.
These benchmarks would give policy makers important information for writing legislation and
rules to curb pollution.
The voluntary industry pollution reduction plans for the top 32 dischargers in the corridor
should be reviewed to determine which companies are making progress in reducing waste
discharges. Citizens can use this trend data to keep the pressure on industry to meet their goals
to reduce toxic releases. Calling attention to companies that meet their waste reduction goals
will spur other facility managers to commit time and resources to pollution prevention.
The report should also review the regulatory compliance records of toxics dischargers
in the corridor. Easy access to compliance histories will help citizens make informed comments
on permit applications for expansions or construction of new facilities. Such information would
support citizens' ability to argue for stricter permit conditions or on-line monitoring of toxic
emissions when there is a history of violations or non-compliance.
Continue reduction and control of air and water toxic discharges
The Advisory Committee felt that toxic chemical discharges to the air and water must
continue to decrease. Government regulations to further curb air emissions cannot be delayed.
Non-point water discharge, such as storm water runoff from neighborhood streets, have impacts
that must be identified. Awareness programs are needed to inform citizens that crankcase oil
from cars and fertilizers from lawns contribute to pollution of the river. Proper disposal of
waste is a responsibility of all citizens.
Technical assistance to identify and handle industrial waste is sorely needed by small
businesses that do not have the expertise or the capital to reduce or recycle waste. Seminars for
managers of small manufacturing companies could help to reduce pollution. Financial assistance
to upgrade their facilities also needs to be addressed.
RTK Network as a source of TRI and census data
The RTK Network on-line database is a valuable source of TRI and demographic data.
Making available the TRI data and census information in one file is very helpful. We should
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support this effort to continue enlarging the information base. For instance, the number of jobs
by Standard Industrial Classification (SIC) code would aid in the usefulness of the data.
Future uses of TRI
Researchers are already using TRI data to evaluate the impacts of toxic emissions on
minority and low-income communities. There is considerable debate on whether this should be
defined as environmental justice or environmental equity. The focus should be on pollution
prevention and not the equal distribution of environmental risk in the community.
Another promising area of research is using TRI data to evaluate our economy. The
challenge is to create sustainable jobs in industrial countries. Environmental and economic well-
being are interrelated. As Renner pointed out, "Contrary to the jobs versus owls rhetoric, less
damaging ways of producing, consuming, and disposing of goods are completely consistent with
the goal of full employment because they tend to be more labor-intensive" (State of the World,
1992). One promising avenue of research is using the TRI data to evaluate jobs created versus
toxic emissions. Templet and Farber have used the TRI data to construct a jobs to emissions
ratio, that can, for example, assist policy makers hi granting industrial tax incentives. Daly et
al., in constructing measurements of sustainability, used TRI data also (For the Common Good,
1988).
References
Cendata: The Census Bureau On-Line. U.S. Department of Commerce, Economics and
Statistics Administration, Bureau of the Census, 1991.
Corporate Response Challenge '91. Lindsey, Joel et al. Louisiana Department of
Environmental Quality. Baton Rouge, 1991.
For the Common Good, Daly, Herman, Washington 1988.
Louisiana Benchmarks: Census '90. Laborde, Raymond. Baton Rouge, 1992.
Louisiana Environmental Action Plan to 2000: Project Report. Thompson, Regina. Baton
Rouge, 1991.
Louisiana Environmental Action Plan to 2000: Technical Supplement. Thompson, Regina.
Baton Rouge, 1991.
Louisiana Toxics Release Inventory 1990. Third Edition. Louisiana Department of
Environmental Quality. Baton Rouge, 1991.
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The 1991 State of the Environment Report. State of Washington. Olympia, 1991.
State of the World, 1992. Brown, Lester R. World Watch Institute, New York, 1992.
Steve Hanna, California Environmental Protection Agency
The California EPA (Cal/EPA) has focused upon using TRI data collection as a
mechanism to obtain standardized, multi-media, quantitative, chemical release data. For optimal
use by environmental programs, collection of TRI forms must expand beyond the manufacturing
facilities. California expansion is currently taking two tracks:
• Statutory authority to expand TRI reporting — Legislation effective on January 1, 1993,
gave Cal/EPA the authority to request TRI reports from facilities outside of the
manufacturing SIC codes, with the number of employees and use volume exclusions
remaining intact. The intent of this expansion effort is not to define additional SIC
codes, but rather to expand utilizing lists of major facilities currently regulated by
Cal/EPA programs. This k'st may include such facilities as major hazardous waste
generators, surface water dischargers, and air pollutant releasers.
• Public invitation to report — On March 1, 1993, Cal/EPA publicly invited many federal
facilities to file TRI forms for calendar year 1992 and thereafter. Those facilities that
file and do not file will be subsequently released to the public.
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DATA PRESENTATION
TRACK SUMMARY
TRACK OVERVIEW 81
SESSION 5: Federal and State Waste
Minimization Data
Collection 83
SESSION 6: Use and Interpretation
of Federal and
State Waste
Minimization Data 89
SESSION 7: Future TRI Initiatives . . 109
SESSION 8: Presentation of the Annual
EPA Data Release 121
SESSION 9: Presentation of the Data to
the Public 133
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TRACK OVERVIEW
The data presentation track consisted of five break-out
sessions. The sessions were:
• Federal and State Waste Minimization Data Collection
• Use and Interpretation of Federal and State Waste
Minimization Data
• Future TRI Initiatives
• Presentation of the Annual FJ»A Data Release
• Presentation of the Data to the Public
The track had a threefold purpose. To begin with,
presentations on federal and state waste minimization data
collection, use, and interpretation provided important background
for those involved in TRI data-related presentations. The track
also focused on the impacts of the annual presentation of the TRI
data by EPA as well as an in-depth analysis of the actual
mechanics of providing information to the public. Finally, a
discussion of the impacts and benefits that would result from
changing the current TRI program gave data presenters a "heads-
up" on activities that may influence data presentations in the
future.
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SESSION 5:
Federal and State
Waste Minimization
Data Collection
Introduction
Data on efforts to prevent or recycle chemical wastes at
industrial facilities are collected at both the federal and state level.
At the federal level, the two vehicles through which waste
prevention and management information are collected are the
Toxic Release Inventory and RCRA Biennial Reports. These
databases are also used at the state level. Some states supplement
these data with additional reporting requirements or have
completely separate data collection requirements, such as the states
of New Jersey and Massachusetts, which require throughput data.
Specific Issues Addressed
This session discussed what data are collected under the
various federal and state reporting mechanisms.
TRI release and transfer data were reviewed with a very
brief overview of the new data required by the Pollution
Prevention Act. The presenter believed that the most informative
assessments that can come from TRI data are based on trend
analysis of the releases and transfers. Since the new data have not
been made available, some have a wait and see approach. Use of
other databases, such as discharges to water (NPDES data), was
stressed, as well as looking at total wastes and cross-media impacts
of pollution prevention and waste management programs.
The State of Ohio discussed their collection and use of
RCRA Biennial Reports. These reports provide both qualitative
and quantitative information. The state is looking at both. The state
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is also engaging in an EPA-sponsored project in establishing
techniques for measuring source reduction progress.
The State of MA discussed its Toxics Use Reduction Act.
MA collects throughput data and requires facilities to account for
all amounts of the materials as discussed below for NJ. MA also
requires a production index so that changes relative to production
at facilities can be assessed.
The State of New Jersey discussed its Pollution Prevention
Report, as well as its experience with TRI data collection. NJ
collects data similar to TRI but also collects throughput data.
These throughput data require facilities to account for all amounts
of the chemical brought or produced on-site, shipped off-site in
products, destroyed on-site through treatment, recycled on-site,
and released to the environment or shipped off-site in wastes.
The State of Washington is developing pollution prevention
planning programs and the data that will be collected under it in
the next year. The state is currently developing methods for
measuring progress hi source reduction. These methods may
include TRI data, but there is a general concern for the accuracy
of the TRI data.
Where Do We Go From Here?
A general conclusion of the session is that they would like
to see more emphasis on planning and implementing pollution
programs at the facility level in more states.
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Panelist Presentations
Robert Ginsburg, Independent Consultant
I. Introduction and caveats
A. Indications of what changes have been made
B. Apparent decreases in releases and transfers from one year to next
H. Pre-1991 Data
A. Use information, releases and transfers (POTWs and off-site)
B. How those data are relevant to pollution prevention
C. Example of the kind of data available for a single facility or company
HI. 1991 Data
A. Usage data, "recycling," and "energy recovery."
B. Case study example of the different information that will be reported. Focus on
how that affects trend analyses.
IV. Need for a holistic understanding of waste generation from industrial facilities
A. Hazardous waste and water discharges
B. Industrial waste
Craig Butler, Ohio Environmental Protection Agency
I. Introduction
A. Federal and State Waste Minimization Data Collection
B. State Initiatives in Pollution Prevention Planning
C. Benefits and Limitations of Federal and State Waste Minimization and Pollution
Prevention Data
n. Waste Minimization/Pollution Prevention Data Collection
A. Federal and State Waste Minimization Data
1. Resource Conservation and Recovery Act (RCRA), 1976 and the Hazardous and
Solid Waste Amendments (HSWA), 1984
a. Waste Minimization Package Data (Biennial Report)
2. Examination of Ohio Waste Minimization Data Collection
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3. Benefits and Limitations of Waste Minimization Data in Measuring and Tracking
Reductions
B. State Waste Minimization/Pollution Prevention Legislation
1. States with Pollution Prevention Planning (or related) Legislation
2. Typical Data Collection Mandated by State Laws
3. Benefits and Limitations of State Pollution Prevention Data
Summary and Conclusion
Suzi Peck, Massachusetts Department of Environmental Protection
Facility-Wide Quantities
Amount of 313 chemical:
• Manufactured
• Processed
• Otherwise used
Also, the amount:
• Shipped in product
• Created as byproduct
Production Unit Information
For each chemical in a production unit:
• Chemical usage, in ranges
• Byproduct reduction index
• Emissions reduction index
• How reductions were achieved
Emissions are a subset of byproducts
Reduction Index: 100 x f(A-B)/AJ
A = Emissions or byproduct per unit of product in the base year
B = Emissions or byproduct per unit of product in the reporting year
1987: 10,000 Ibs. of byproduct, 100,000 widgets
1990: 5,000 Ibs. of byproduct, 100,000 widgets
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Andy Opperman, New Jersey Department
of Environmental Protection and Energy
• Foundation/Background: New Jersey Industrial Survey Project (1979-1982)
• Toxic Substance List Development under ISL Project
• Authority: The New Jersey Worker and Community Right To Know Act (New Jersey
Statutes Annotated 34:5A-1 et seq.) (1984)
• NJ Release and Source Reduction Report (DEQ-114)
— covers: Form R population of facilities
— inventory and throughput data section review
— pollution prevention (source reduction) data section review
• Problems of Data Collection
— industry's interpretation/understanding of instructions
— closure in materials accounting data
*• materials accounting data worksheet
— consistency with Form R data reporting
• Problems of Data Collection
— facility-initiated reporting, i.e., burden on facility to generate numbers
— resources for tracking new submissions of Form R and, therefore, DEQ-114
submissions
• Examples of numbers (1991 data)
— samples of throughput data
— materials accounting discrepancies (bar chart & table)
— comparison with Form R data for one chemical
— sample of pollution prevention data
— one example of data application: % shipped off-site as (or in) product relative to
the total output quantities
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Idell M. Hansen, Washington State Department of Ecology
Washington's Hazardous Waste Reduction Act, 1990
The legislation set a goal of reducing hazardous waste generation by 50 percent by 1995.
It required certain hazardous waste generators and hazardous substance users to develop a
pollution prevention plan and pay a planning fee based upon the amount of hazardous waste
generated and hazardous substances released. Only the plan summary must be submitted to the
agency. Annual progress reports are required.
TRI's role in Washington's Hazardous Waste Reduction Act
Hazardous substance releases are defined as those reported under TRI for air, watei,
underground injection, and land. All TRI reporters must do a plan even if they had zero
releases. The planning fee is based on pounds reported released on Form R and hazardous waste
reported on annual dangerous waste reports.
How waste reduction progress will be measured
The primary method of measurement will be the annual progress report filed by the
facility. Data will be extracted based on the plan goals that match actual reductions with
proposed. The state is developing guidance and a workbook approach to measurement. Annual
dangerous waste reports and TRI reports will also be used.
Limitations of using TRI for measurement
There is a long delay in getting the TRI information to us. We have had data quality
problems using the state data. Not all of our planners are TRI reporters, so we do not have data
for all facilities. We will be following the progress with the new data elements to determine
how usable they will be.
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1993 TRI DATA USE CONFERENCE
SESSION 6
SESSION 6:
Use and Interpretation
of Federal and State
Waste Minimization Data
Introduction
Data on chemical waste prevention and management at
industrial facilities that are collected by federal and state agencies
are used by those agencies, local governments, industry, and
citizen and environmental groups. The uses of the data, especially
those collected under the Toxics Release Inventory, vary
depending on the user. As the information collected is both
quantitative and qualitative, the data are used to assess progress in:
(1) the reduction of wastes, (2) the implementation of source
reduction programs, (3) the cross-media impacts of those
programs, and (4) technical assistance and research programs.
Specific Issues Addressed
Discussion centered on ways to identify real reductions in
waste and release quantities, uses of the data, and limitations to the
data.
Real reductions in waste & release quantities. Assessment of real
reductions in TRI from 1989 to 1990 was performed by EPA's
Pollution Prevention Division. Three factors were studied that
could account for changes in releases and transfers: 1) changes in
production, 2) changes in estimation techniques, and 3)
implementation of source reduction. Production fluctuations were
cited most frequently as the cause for changes in releases and
transfers. Implementation of source reduction was cited for 45%
of the change in releases and transfers. The remainder of the
changes in releases were due to production changes and changes
in estimation (including changes in EPA guidance).
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Limitations of the data. RCRA Biennial Reports are being
reviewed by the State of Ohio. They are evaluating progress in
waste minimization, important to wisely allocate scarce resources
($, time, etc.). The RCRA Biennial Reports provide both
qualitative and quantitative data. Qualitative data are good to assess
how widespread waste minimization programs are as well as what
facilities are doing to prevent and manage wastes. The state
initiated a study of waste generators in 35 counties in the Ohio
Great Lakes Basin, but concluded that the quantitative data were
of too poor a quality to perform any assessments.
Uses of the data. A representative of Vulcan Chemicals reported
on the use of TRI data in a pollution prevention strategy to reduce
releases from a facility. The strategy is based on three factors:
annual emissions, long-term risk, and immediate risk. Sources of
emissions are selected for source reduction programs based on
weighting these factors to see which is the source of greatest
concern to Vulcan.
The State of MA collects data under its Toxics Use
Reduction Act. The state uses the data it collects to prioritize
compliance and enforcement activities, technical assistance
programs, and research programs. MA also uses its data to assess
progress in toxics use reduction on a statewide basis, as well as
within and between facilities. Comparisons between facilities are
more difficult to perform because the data provided by two distinct
facilities cannot always be compared. MA has found a high error
rate in the new data collected on Form R, which makes
comparison of the two sets of data almost impossible.
Local use of TRI data. TRI data are used to look at
releases and transfers in the Chicago area. A key element stressed
is that cross-media impacts need to be considered when
implementing pollution prevention because pollution to other media
may be increased. Integration of the TRI data with other
environmental data, such as water discharge data (NPDES), was
emphasized. TRI data were also analyzed to look at the
distribution of releases in the Chicago area based on the racial mix
of local populations.
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1993 TRI DATA USE CONFERENCE
SHSSION
Where Do We Go From Here?
• Guidance is needed for pollution prevention and waste
management data reported in Section 8 of Form R;
• The quality of the data reported needs to be emphasized
and improved;
• Integration and use of TRI with other data bases is
important, especially to put the TRI data in context and get
a more complete picture of waste management and
emissions of toxic chemicals.
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1993 TRI DATA USE CONFERENCE
Panelist Presentations
Eun-Sook Goidel, U.S. EPA
Over the past four years, there has been a pronounced downward trend in the reported
releases and transfers in the Toxics Release Inventory (TRI), which collects data annually on the
types and quantities of over 300 toxic chemicals released and transferred to all environmental
media by manufacturing facilities within the United States pursuant to the Emergency Planning
and Community Right-to-Know Act of 1986.1
The reductions may be due to a variety of factors that can affect the reported quantity
of releases and transfers in any given year including: source reduction, recycling, treatment,
fluctuations in production, changes in reporting requirements, and changes in facilities'
estimation of measurement techniques. However, in the absence of a mechanism in the TRI
database that indicates reasons for change in the amount released and transferred from one year
to the next, the downward trend has been open to divergent interpretations. Allegations by some
citizens groups of "phantom" reductions and "paper" changes (i.e., they affect TRI submissions
without physically reducing the quantity of chemicals released or transferred) have been
countered by companies with examples of real reductions. A recent EPA study sheds light on
some of the "real" progress versus "paper" changes reported by companies between 1989 and
1990, and suggests that source reduction was an important factor.
Background
Prior to the 1991 reporting year, reporting on source reduction activities was voluntary.
Consequently, EPA has had no means to judge the extent to which reported decreases in releases
and transfers were in fact due to such activities. When the new data mandated by the Pollution
Prevention Act of 1990 (PPA) become available, however, the Agency will have an explicit
quantitative measure of the results of source reduction activities undertaken by faculties. In the
interim, the Environmental Protection Agency (EPA), in conjunction with the Research Triangle
Institute (RTT), conducted a study designed to determine the extent to which source reduction,
1A report describing the methodology and results of the study will be published in April,
1993.
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SI-SSION 6
as well as other factors, account for the reported decreases in releases and transfers since the
inception of the TRI program.2
Study Description
In comparing TRI data for 1989 and 1990, the EPA/RTI study examines the extent to
which three factors — source reduction, production fluctuations, and changes in measure-
ment/estimation techniques — might have contributed to reported changes in releases and
transfers between these two years. Since various other factors can also affect reported releases
(e.g., changes in reporting requirements), an attempt was made to delineate these and attribute
their respective contributions to the overall changes in releases and transfers. Due to resource
constraints, however, the extent to which this could be done was limited.
Data for the study were collected through telephone interviews with over 1200 facilities
that were selected using statistical random sampling techniques. The study population from
which the 1200 facilities were selected is composed of those with SIC codes 20 to 39 that
submitted TRI data for both 1989 and 1990. Given these criteria, the number of facilities
included in the study population, and the associated releases and transfers of these, differ from
the universe of facilities included in the TRI database. This can be seen in Table 1.
The sampled facilities were asked to estimate, for each chemical, the portion of their
reported change in releases and transfers from 1989 to 1990 due to the study factors, namely,
source reduction, production change, and measurement change. By weighing the data collected
from the sample, estimates for the total number of facilities in the study population were made.
Results
Participation in the study was entirely voluntary. However, the 80% targeted response
rate was easily achieved. Based on the study results between 1989 and 1990, the following is
indicated:
Of the three study variables, the impact of production fluctuations was the most
commonly cited reason for change, with 69% of all facilities claiming some impact. Nearly
40% of all facilities realized a change in TRI releases and transfers due to source reduction
activities. A change in measurement or estimation techniques, which falls in the category of
"paper" change, was the least common reason for change.
category "Other Factors" includes changes due to reasons other than the three change
variables of the study, such as changes due to recycling and treatment, data entry errors, changes
in EPA's technical guidance, etc. This category also includes facilities that were unable or
unwilling to estimate the change.
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The 18,951 facilities of the study population decreased their reported TRI submissions
between the two study years by 866 million pounds. Figure 1 shows how this net decrease is
apportioned between the three study variables, as well as a category that includes all other
factors.
Nearly 45%, or 387 million pounds, of the total change in TRI submissions was due to
source reduction activities. An estimated 5% of the change was due to fluctuations in
production, less than 3% was due to measurement change, and the remaining 48% was due to
other factors. Thus, at least 50% of the total change (production change and source reduction
combined) falls under the category of "real" change. Only 3% can be labeled with certainty as
"paper" change. The remaining 48% decrease, or 416 million pounds, combines both real and
paper change. A significant portion — roughly -249 million pounds — of this can be attributed
to the impact of the technical guidance EPA issued for 1990 submissions on the reporting of
ammonia and ammonium sulfate.
The values shown in Figure 1 represent net changes, i.e., both increases and decreases
in TRI releases and transfers have been added together. Thus, the actual volume of activity for
any given reason may be masked by large quantities of increases and decreases that have
canceled each other out. This is particularly evident for change due to fluctuations in production
and illustrates the importance of examining the results at a disaggregated level.
Figure 2 illustrates how the net change in releases and transfers for each of the three
change variables is derived from quantity increases and decreases. As this figure indicates, the
greatest absolute quantity change was attributed to production change, supporting this variable
as the most frequently cited reason for change. Yet, the aggregated impact of production change
was comparatively small.
Conclusion
The results of the study provide a snapshot of what happened between 1989 and 1990,
and as such represent a first step toward measuring progress in source reduction. The study
found that all three study variables contributed to both increases and decreases in reported
releases and transfers between 1989 and 1990. Thus, aggregation of results, though informative
in some instances, make comparison among the three study variables difficult and may mask the
true effect, since each variable is affected to a differing degree by increases and decreases.
Special attention will need to be paid to change due to fluctuations in production.
With the availability of the Pollution Prevention Act data, and particularly the production
index ration, it will be possible to normalize the data to take into consideration the fluctuations
in economic activity from one year to the next. This will allow EPA to better track and evaluate
the source reduction progress annually. It is hoped that the results of this study can serve as a
baseline for future analyses and comparisons. Such a longitudinal study is critical to developing
a comprehensive understanding of the effects of source reduction activities. As we have seen,
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1993 TRI DATA USE CONFERENCE
SESSION 6
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.
Figure 1. Net Quantity Change in TRI Data, by Re
Measurement Change
•21 3 million oounos
2.5%)
Z'har Factors
•-15 7 million oounos
•480%)
Production Change
•41 2 million rounds
(4 8%)
Source Reduction
•387 2 million oounos
(447%)
Net Quantity Decrease * 866 Million Pounds
Figure 2. Aggregating Increase* and Decrease* in TRI Data, by R
Measurement
Change
Quantity incna
Production
CAanoa
Source
fteducflon
Quantity 0«cnMM ^j N*l Change
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1993 TR1 DATA USE CONFERENCE
Table 1. Representation
Number of Faculties - 1900
Number of Form Rs - 1989/1990*
Total Releases & Transfers, 1990-1989
Changes in Releases & Transfers, 1990-1989
of TRI Universe
TRI Universe Study
26,527
100,875
4.89 billion
-943 million
Population
18,951
85,780
4.75 billion
-866 million
* This includes Form Rs that were submitted for either 1989 or 1990. If a chemical was
added or dropped by a facility between the two years, its Form R would still be included.
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SESSION 6
Craig Butler, Ohio Environmental Protection Agency
I. Introduction
A. Why Collect Waste Minimization Data?
B. Data Interpretation: One State's Efforts
C. Benefits and Limitations of Waste Minimization Data
n. Use and Interpretation of Waste Minimization/Pollution Prevention Data
A. Why Use and Interpret Waste Minimization and TRI data?
1. Wise allocation of scarce resources
2. Chemical, waste stream, facility and/or geographic area identification,
targeting and/or reductions tracking
EQ. Analysis of Ohio's Waste Minimization Data
A. Qualitative and Quantitative Data Analysis
B. Comparison/Integration with Ohio TRI Data
C. Conclusions
IV. Limitations of Current Data
A. Marginal Data Quality
1. Misreporting and poor recording practices limit conclusions
B. Lack of Data Integration
1. BRS, TRI and State Data Collection Incompatibilities
a. Fundamental differences in data collection
b. Regulatory and logistical boundaries
C. Critical Waste Minimization Data Lacking
1. Significant "gaps" in data collection limit tracking and conclusions on
progress in waste minimization
2. Yearly collection requirement changes negate long-term tracking in key areas
3. Reporting exclusions preclude aggregate minimization calculation
V. Waste Minimization/Pollution Prevention Pilot Project
A. History and Purpose
1. Waste minimization/pollution prevention progress measurement
2. U.S. EPA/state cooperation
B. Project Expectations
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S. Wade Price, Vulcan Chemicals
I. Introduction (see Table 1)
n. Pollution Prevention - A Case Study
m. Interpreting TRI Data
IV. Future Directions
V. Conclusion
Bad Things About TRI
• Manpower Requirements
• Risk Communication
• PPA
Good Things About TRI
• Total Quality Measurement
• Comparative Analysis
• Public Communications
A Pollution Prevention Strategy
• Collecting Data
• Develop Ranking System (see Table 2)
• Reduce Emissions
A Pollution Prevention Strategy
The Ranking System - Basis
• Annual Emissions (0.40)
• Long Term Risk (0.40)
• Immediate Risk (0.20)
A Pollution Prevention Strategy
Reducing Emissions
• Identify Projects
— Use the hierarchy
— Consider cost
• Measure Performance
• Continually Improve
Interpreting TRI Data
• Data Quality Issues
— "Phantom" reductions/increases
— Changes in the "List"
— PPA
• Risk Communications Issues
— Toxicity of the chemical
— Release medium
A Pollution Prevention Strategy
Collecting Data
• EPA approved sampling
— EPA approved calculations
— In-house sampling
— Engineering calculations
Future Directions
Customer Care
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Table 1
Overview of Vulcan Chemicals
Locations and Product Lines
Geismar. LA
Wichita. KS
Pt. Edwards, WI
Chlorine
Sodium Hydroxide
Hydrochloric Acid
Perchloroethylene
Methyl Chloride
Methylene Chloride
Chloroform
Carbon Tet
Methyl Chloroform
Ethylene Dichloride
Chlorine
Sodium Hydroxide
Hydrochloric Acid
Perchloroethylene
Methyl Chloride
Methylene Chloride
Chloroform
Carbon Tet
Calcium Chloride
Chlorine
Sodium Hydroxide
Hydrochloric Acid
Potassium Hydroxide
Table 2
A Pollution Prevention Strategy
Air Emission
Source by
Overall Rank
A (37.5)
B (45.0)
C (47.5)
D (55.0)
E (75.0)
The Ranking System - Results
Annual Long Term
Emissions Risk
3 2
1 1
2 3
7 7
4 4
Immediate
Risk
5
8
7
4
11
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Suzi Peck, Massachusetts Department of Environmental Protection
Uses of TUR Data
Data Elements
• Use
• Byproduct (Waste Prior to Treatment)
• Shipped in Product
Efficiency
• Shipped/Use
• Byproduct/Use
BRI
• % Change in Byproduct/Unit of Product
From Base Year
Use 1: Prioritizing
• Compliance and Enforcement
• Technical Assistance
• Research
Use 2: Measuring TUR Progress
• Statewide
• Intra-facility
• Inter-facility
Data Limits
Production Levels
Accuracy
Baselines
Type of Use
Unit of Product
Statewide TUR
• Reduction in Total Byproduct or Use
• % of Positive BRIs
• Efficiency
Intra-Facitity TUR
• Total Reductions
• % Positive BRIs
• BRI Number
• Efficiency (M&P Only)
Inter-Facility TUR
• Efficiency (M&P Only)
For Inter-Facility Comparisons
One Would Need
• Baseline Data
• Same Measurement Methodology
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Andrew Comai, Lake Michigan Federation
Stimulating Pollution Prevention Through Use of TRI Information
Given the time constraints for this presentation, I hope to throw out a number of ideas
on 1) how the TRI can be greatly expanded (and thus unproved); and 2) how TRI can be more
effectively distributed and promoted, access can be improved, and assistance can be given to
data users.
Presenting these ideas will hopefully generate some thoughts among the audience on how
the pollution prevention initiatives can be stimulated to a greater degree, and how waste
minimization projects can be measured for progress. Also, I hope to suggest ways that the
agency can prioritize work projects to target waste minimization programs.
A number of data sets exist that should be combined with the TRI. By "combined" I
mean "given the same priority for public access, cross referenced with TRI releases, and used
regularly by the regulatory community in the granting of permits." These include:
• Resource Conservation and Recovery Act (RCRA) Biennial Reports
• RCRA Manifest Data
• Publicly Owned Treatment Works (POTW) discharge permit data
• Emergency Response Notification System (ERNS) Data
• Tier n information
• Pollution Prevention Information Exchange System (PIES) case studies
Access to this extra data would greatly enhance our ability to interpret waste minimization
efforts.
RCRA Biennial Reports: Companies are already required to report pollution prevention
activities under RCRA. Even though the information is somewhat cursory, the public
distribution of the information will have a number of benefits. Since RCRA covers a larger
number of facilities than does TRI, increasing access to these data will expand the universe of
companies that will feel the warm glow of public scrutiny. It is interesting to find out from an
earlier speaker that the information contained in the biennial reports analyzed by the Ohio EPA
proved inadequate for the purposes of gauging waste reduction progress. Perhaps public
accessibility and scrutiny will help to improve both data quality (by making industries
accountable) and the structure of the reporting form, as it has with the TRI.
RCRA Manifest Data: Chemicals that are included hi the TRI list tend to disappear into
the various categories of RCRA waste. One example would be the sulfuric acid reported by a
number of steel companies in Illinois, Indiana, and Wisconsin. Millions of pounds of "sulfuric
acid" are transported off-site for reuse by sewage treatment plants. That same waste translates
into hundreds of millions of pounds of waste covered by RCRA as pickle liquor, D006 waste.
What are the other constituents of pickle liquor? Cadmium, hexavalent chromium, lead,
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1993 TRI DATA USE CONFERENCE
mercury. All TRI chemicals, none reported under TRI. There are companies that handle steel
with enough TRI chemical constituents to trigger reporting under TRI. Why aren't these
companies reporting the release of these chemicals leaving the plant under the guise of RCRA
waste?
PIES data: What is more essential to pollution prevention than the easy access to the
combined technical knowledge of other companies who have already solved specific waste
problems? If anyone here has tried to actually use the PIES database you realize what a paltry
attempt at dissemination it is. Fewer than 500 case studies have been uploaded. A user can't
even download these case studies from the system except by the roughshod method of "screen
capture." The system has had these flaws for the two years that I've used it. The number of
studies need to be increased. Companies should be required to report pollution prevention
techniques and case studies to PEES as part of the 33/50 program. One of the barriers to such
reporting includes the hesitancy of some of the larger companies to outfit company computers
with modems for reasons of company security. This keeps company secrets from leaking out,
but it also keeps pollution prevention ideas bottled up. Perhaps the new pollution prevention
data being reported under the new "Section 8" questions can be systematically used to solicit
more pollution prevention ideas from companies.
NPDES permit data: Chemicals that appear on the TRI list of chemicals are regularly
included in the NPDES permits. Oftentimes, these materials are not reported under TRI even
though they are released in the tens of thousands of pounds under the company's NPDES permit.
Increasing public access to the NPDES permit data will help bring these disparities under closer
scrutiny. Oftentimes, the NPDES permits require the implementation of "best management
practices" to control the release of toxics. These BMPs often fail to focus on multi-media
reductions.
POTW discharge permits: In comparing the pretreatment clients of several sanitary
districts to the TRI lists, we have found a number of companies that report POTW releases
under TRI but fail to report these same releases to the POTW. This seems like a simple cross-
referencing of lists that will help bring more chemicals and more companies into the
pretreatment universe.
The pretreatment coordinators of sewer districts have a unique relationship to their
industrial clients. They regularly monitor releases and suggest improvements that can help the
industries meet their discharge limits. Who better, then, to suggest pollution prevention
practices? Well, there is a better solution. That is, coordinated multi-media inspections
focusing on pollution prevention planning. The inspections should be conducted by sewage
treatment plant officials and other state and federal agency inspectors responsible for air
emissions and hazardous waste. Industries actually appreciate these kinds of inspections because
they reduce red tape that can be generated from conflicting requirements issued by different
agency sectors.
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1993 TRI DATA USE CONFERENCE
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Figure 1 demonstrates the need for these types of inspections. The figure shows the
releases of one company, Keil Chemical, shifting from the sewer to the air. The change in the
emissions came about after pressure from the Hammond Sanitary District to reduce discharges
to the sewer.
ERNS data: The Great Lakes Water Quality Initiative specifically points to spill and
accident prevention as a primary method of reducing toxic loadings to the Great Lakes. Just as
the public has a right to know about routine toxic emissions, they should have easy access to
historical information on spills and catastrophic releases.
I am arguing for increased access to data well beyond that currently contained in the TRI.
This argument rests on the premise that the warm glow of public scrutiny is needed to focus the
attention of industry on their internal production practices and focus the attention of regulatory
agencies on problem areas. This runs counter to the argument heard from some of the less
enlightened industry representatives who claim that "The public can't understand information on
toxic chemicals given its technical nature; therefore the public does not have the right to know."
Awareness of TRI needs to be increased. Regulatory officials need to start using it and
citizens need to be made aware of the information in a way that will encourage the use of the
information. The EPA needs to define specific work projects that will increase public
participation. More assistance is also needed to help citizens manipulate and understand the data
with regard to their own neighborhoods. I would like to describe one approach that has been
used to try and generate pollution prevention efforts by reaching out to communities here in
Chicago. Figure 2 shows the city of Chicago divided by zip code. The total TRI releases for
each zip code have been calculated.
Figure 3 is a bar graph demonstrating a correlation between racial makeup of each zip
code and toxic releases.
We focused in on the areas of highest release to hold workshops for local residents
regarding local polluters in their areas. (Figure 4) The idea was to open up dialogue between
local plant managers and members of the community concerning pollution prevention planning.
Several long term dialogues have been established between plant managers and community
residents. Organizing communities around the issue of pollution prevention will be easier when
"Section 8" data on pollution prevention become available. Communities will be able to judge
for themselves the sincerity of their local manufacturing facilities' efforts toward pollution
prevention.
Access to the data is still a problem for citizens as well as agencies that could benefit
from the data. I would argue that the TRI on the National Library of Medicine is too expensive,
complex, and inflexible. The EPA is spending huge sums to provide what is for the most part
industry access to TRI data. A better model of a user-friendly, economical information system
is RTK NET, a computer network run by non-profit groups OMB Watch, and the Unison
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1993 TRI DATA USE CONFERENCE
Institute. My hope is that EPA will continue its support of this method of disseminating toxics
information.
Proper education of the public will translate into pollution prevention initiatives, and help
the EPA improve its enforcement program.
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2000000
1500000
1000000
500000
8) 0
Shifting Pollution to Other Media
1,2 dichtororthane released by KBL CHEMCAL,
Hammond Indiana 1987-1990
Large Sewer
Discharges
Shifted to Stack
sewer stackV fugitive total
Installation of
EDC recovery tower
-------
Chicago Toxics
Toxic Release
IB 1-99,999 (tosyr)
• 100,000-1,000,000 (Ibs/yr)
• greatar lhan 1.000,000 (lba/yr)
zip-code reported releawi
\(606 prefix) (total poindi) -.
\
99,999
©
Numberot
tacililiat repotting
RTKNET
Fig. 2
106
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6000000 -
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a
5? Af\f\f\f\f\f\
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r-
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oc
u
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O
fl
|2 1000000 -
50% OR GREATER 20-49% < 20 %
BLACK OR HISPANIC BLACK BLACK OR HISPANIC
1
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li
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, :•:.
i 1 1 1 1 1 i
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CR
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, i I < i i i i i i i i i i i i i i i 11 i i i i i i i i i i i i i i i i i ii
ZIP CODES IN CHICAGO (sorted by race)
— 1 1 1 1 1 1 1 !
-------
Pollution Sources in Chicago
Zip Codes 60608, 60616, and 60623
KEY
Q FaolHtiw Rapoctbtfl Tudo IUI«aa»a
/\ Prtantlal Hazardous Wast* SKM
h Sohooto, Park, and H
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1993 TRI DATA USE CONFERENCE
SESSION 7
SESSION 7:
Future TRI Initiatives
Introduction
The purpose of this session was to discuss the impacts and
benefits that would result from changing current programs.
Initiatives that were addressed included the Low Release exemption
"SBA Petition", federal facilities, state experiences, and the
expansion of TRI to include additional chemicals and industries.
Specific Issues Addressed
• There was an overall belief that TRI should be expanded.
There was disagreement as to what should be the extent of
the expansion.
• There was disagreement as to whether TRI serve all
environmental information needs.
• Chemical expansion — There was agreement that more
chemicals should be added; the disagreement was as to how
many.
• Industry expansion — Environmental groups, states, and
industries in SIC codes believe that other industries should
be covered.
• TRI was a wake-up call for industries in SIC codes 20-39.
Other industries should also wake up (facilities not in SIC
codes 20-39 were quiet on the subject).
• Exemption for small volume releasers. Although there
were mixed reactions on whether small volume releasers
should be exempted, there was agreement that some of the
ways to achieve this are undesirable (e.g., Form R EZ).
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1993 TRI DATA USE CONFERENCE
• There was disagreement on whether additional data, such
as materials accounting data, should be collected under
TRI.
• There was disagreement on whether the data limits that
EPA says exists, actually exists.
• It was agreed that this is a data management problem, not
a hardware problem.
• Suggestions included minimizing costs by going to 100
percent electronic reports. The states had problems with
that.
• Maria Doa — overview of TRI expansion concepts and
capabilities.
• June Bolstridge — discussion outlined both opportunities
for expanding the data set but also opportunities for burden
reduction on small businesses, particularly elimination of
low-volume reporting.
• Brian Tarrantino — industry perspective both supportive of
expansion (particularly facility) and of some low or no
volume report exemption.
• Susan Green — experience vs. expansion.
• Paul Orum — strong prospect of expansion. More
inclusion than exclusion philosophy on chemical inclusion.
May be hidden costs in apparent burden reduction
involving report-based threshold ideas.
Where Do We Go From Here?
• Add some chemicals and industries; and
• Exempt low releases.
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Panelist Presentations
June C. Bolstridge, GAIA Corporation
A massive amount of chemical release data have accumulated as a result of the
requirements of Section 313 of the Emergency Planning and Community Right-to-Know Act
(EPCRA). These data have had far-reaching consequences for new legislation, additional
regulatory requirements, and revised industry practices. However, as with any regulatory
program, the Toxic Release Inventory (TRI) has received a lot of criticism and numerous
suggestions for altering the data reported, the facilities covered, or the chemicals addressed.
Review and improvement of the Section 313 requirements are appropriate and necessary, due
to the importance of the reported data to everything from regulatory programs to public
perceptions.
Any changes must be considered within the context of the stated goals of the TRI
program, the effort required for reporting facilities to understand and comply with the
requirements, and the volume of information being assembled. There appears to be a strong
misconception that "more data are always better" when considering environmental issues.
However, effort spent to develop estimates, complete forms, process data, maintain the TRI
database, and search for information of interest take resources away from other activities.
Merely keeping up with recent changes in requirements can become a daunting task for both
reporting industries and regulatory personnel who are attempting to review compliance. With
any environmental data collection requirement, data quality will decline as the requirements
become so convoluted and change so frequently that they cannot be readily understood. Above
all, as any change to TRI reporting is being evaluated, its impact on the quality and utility of
the data should be given careful consideration.
This paper describes some pending revisions to the Section 313 program, and identifies
considerations for the possible effects on TRI data and the effort to comply and to evaluate
compliance. It also should be realized that while evaluating interactions from multiple changes
to the program are outside the scope of this discussion, they must be included in more formal
reviews.
The Small Business Administration (SBA) has petitioned EPA to exclude small
releases from the reporting requirements of EPCRA Section 313. Facilities that meet reporting
thresholds would be required to prepare complete release estimates, but only submit a report if
the facility's total releases exceed a specific release cut-off. The petition subdivides the list of
Section 313 chemicals: facilities would not be required to file reports for fewer than 5,000
pounds of releases of chemicals considered to exhibit "high release volumes and low toxicity;"
facilities releasing fewer than 10 pounds of chemicals exhibiting "low release volumes and high
toxicity" could file an alternative "short form" as a substitute TRI Form R report.
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The TRI database already contains thousands of reports for zero or minimal releases
under Section 313, and little value is gained from continuing to collect such reports. An
important benefit of excluding low releases is to avoid the "add-on" requirements that seem to
be considered by all new legislation for application to facilities reporting under Section 313.
Some industry categories consume chemicals in their processes and therefore release very little
throughout the year. Such facilities hardly belong in the Section 313 annual release inventory
requirements, since they are not releasing the chemicals. Additionally, existing regulatory
requirements address the amounts of chemicals stored on-site and the releases from emergencies
or catastrophic events (EPCRA Section 312 annual inventory reporting and CERCLA Section
102(a); EPCRA Section 304 emergency release notification, respectively).
The SBA petition's approach, however, may not be the best means to eliminate unneeded
low-release reports. A release reporting cut-off neither reduces facilities compliance efforts, nor
simplifies EPA's implementation or enforcement. Facilities would still be required to develop
complete release estimates and EPA would need to conduct far more site visits to verify
compliance. The universe of Section 313 covered facilities would not be changed, and there is
nothing to keep "add-on" requirements from being defined as applying to all facilities that meet
the thresholds, regardless of whether they report. Finally, data quality could be severely
impaired as facilities lose track of their reporting requirements, and chemicals shift between
"high" and "low" release status due to pollution prevention and toxic use reduction programs
and "high" and "low'1 toxicity status due to new health effects and environmental studies.
As an alternative approach, the release criterion can be used to exclude facilities from
the Section 313 reporting criteria by modifying threshold activities and SIC codes. EPCRA
Section 313(f)(2) allows EPA to establish reporting thresholds that differ from those set in the
statute, as long as they "obtain reporting on a substantial majority of total releases of the
chemical at all facilities subject to the requirements." Nothing in the statute prohibits exclusion
of facilities with releases below a specified threshold, as long as the majority of releases of the
chemical at all facilities remain within the scope of the requirements. In implementing revised
thresholds, EPA could modify the processing threshold to exclude chemicals intentionally added
in making products for distribution in commerce when the total facility releases and transfers
are a minor percentage of the volume of the chemical used during the year. Such processing
activities provide no pollution prevention opportunities other than reducing production. In
addition, EPA could modify the "otherwise use" threshold guidance to exclude chemicals
contained in closed systems that are not released under normal use activities. Finally, EPA
could exclude entire SIC code classification categories from those required to report based on
specific criteria that would serve as goals for facilities to further reduce the chemicals in wastes
that they release.
The elimination of zero or small release estimates from the Section 313 reporting
requirements will improve data quality by increasing the focus on releases of toxic chemicals.
Release-based thresholds are best applied as one aspect of threshold determinations on an
activity-specific or industry-specific basis to exclude those activities or industries who do not
release the chemicals.
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The Right-to-Know More bill would expand the EPCRA Section 313 reporting
requirements by adding more than 500 chemicals and numerous new types of data. The bill
would also include non-manufacturing (waste recycling, heat recovery, treatment, and disposal)
and federal facilities having more than 10 employees if their releases of listed chemicals exceed
a new "release threshold." The bill expands reporting requirements to include "peak release"
data for the single largest releases to air, water, and land (this parallels EPA's abandoned
reporting option under Section 313, see below). Additional data would be required for the
amount of chemicals transported, consumed, and produced as a commercial product or
byproduct. The bill also requires development of facility-wide mass balance information for
each toxic chemical, and a facility-wide toxic use reduction plan.
Much of the driving force behind the bill is to include non-manufacturing activities in the
annual release reporting requirements to provide more information on community-based
environmental hazards and releases. The requirements are specifically focusing on the need for
information on: utilities, storage facilities, distributors, drum and tank cleaners and
reconditioners, mining industries, photo processing operations, industrial dry cleaners, and
federal facilities.
Inclusion of federal facilities is generally considered to be an improvement in
comprehensiveness of reporting. Some government facilities operate much as manufacturing
operations, and will fit within the requirements. Department of Defense installations, however,
function not as facilities but as small cities with numerous subcontractors and support operations.
EPA will need to give careful consideration to the kinds of reporting that are appropriate for
such operations. The Department of Energy plans to combine reports prepared by each
subcontractor and submit a single report for each site. However, this does not provide useful
information when a site is hundreds of square miles and actual operations are concentrated in
widely separated buildings.
EPA and some industry associations have expressed concern over unnecessary inclusion
of chemicals and overburdening EPA's data processing capacity with hundreds of thousands of
additional reports. EPA estimates the cost of managing the current amount of data to be $5 to
6 million per year.
Of equal concern is the belief that mass balance accounting can accurately reflect all
activities for a chemical at all types of facilities. Mass balance would require throughput data
per year and per unit of product, which would severely jeopardize companies' abilities to protect
capacity and production level information from competitors.
Peak Release data collection was an option authorized by EPCRA. Although EPA has
undertaken extensive studies and regulations were expected in 1990, a recent regulatory agenda
removed peak release data from consideration. Peak release reporting under Section 313 was
to have identified the single largest 24-hour release to air (point or fugitive source) and largest
8-hour release to each water body. Additional data on stack height for peak air point source
releases were to allow the assessment of exposure and risk to communities. However, it has
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become clear to EPA that the data cannot be used in any release or exposure models without
detailed information on: local terrain, weather conditions, temperature of release, other
components of release, and other concurrent releases by nearby facilities. With the addition of
catastrophic release provisions of the Pollution Prevention Act, little value can be expected to
be obtained from peak release reporting. Note that peak release reporting may be revisited in
the Right-to-Know More bill (see description above).
All expansions of the TRI reporting must consider the overall purpose of the
program. For example, there is no appropriate method to reflect aggregate releases from
multiple sources located in a geographic area in any threshold that might be established under
a national reporting requirement such as Section 313. EPCRA Section 313 doesn't focus on
population density, industrial intensity, environmental sensitivity, or any other measure of local
geographic conditions. It is designed as a consistent, national reporting requirement for
estimated releases. Aggregate releases and the potential impacts on local communities are
appropriate to be addressed under regional environmental controls, individual facility release
permits, and local environmental regulations.
In conclusion, information available under EPCRA Section 313 has resulted in increased
public scrutiny, legislation such as the toxic control provisions of the Clean Air Act and the
Pollution Prevention Act of 1990, and are providing a driving force for expansion of the types
of industries and chemicals covered.
The TRI database cannot serve all environmental information needs, and it should not be
expected to provide mass balance, community risk, and chemical storage information. Revisions
can and should be made, however, to limit the reporting requirements to providing useful data
on toxic chemical releases. Properly excluding unnecessary reports can significantly reduce the
effort required to track and manage insignificant data.
Overall, in evaluating revisions to the program, EPA and Congress must balance the
volume of data developed, complexity of the requirements, comparability of reporting between
years, and applicability of the data for all types of facilities. The strength of the section 313
program lies with its consistency.
Brian Tarantino, P.E., Merck & Co., Inc.
What marked the success of the TRI program?
That it provided detailed, meaningful information to the public that was widely used to assess
public and environmental impact?
No! Much of the detailed information reported is generally unused.
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Rather, it provided a baseline of basic information about a sector of industry so that:
— companies were alerted to the amounts of toxic chemicals being lost from their
processes, and
— it provided a public baseline to allow companies to demonstrate good-faith efforts
at reducing releases.
What expansion of the program would repeat this success?
To require more detailed, process-specific information about current reporters?
No! It has never been demonstrated that such additional detailed information would provide any
benefit to the public or the environment.
Rather, EPA should expand the universe of reporters by adding SICs that have been determined
to significantly contribute to releases of toxic chemicals.
EPA should provide additional outreach to the regulated community to obtain more full reporting
compliance.
EPA should more fully educate the public about the meaning of the Form R and pollution
prevention data.
Expanding the 313 Chemical List
Chemicals that are truly toxic should be added to the list.
EPA should promulgate rational, science-based criteria for listing and delisting.
Likelihood of exposure of the chemical at toxic levels to the public should be a determining
factor.
Rare or improbable circumstances should not be basis for listing.
Guiding Principles for TRI Expansion
There is demonstrated benefit for a pledge and review approach, rather than command and
control approach.
Existing economic incentives will produce the best choices for most of industry.
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TRI is only a reporting program; the benefits of additional information should be weighed
against the cost of reporting and managing the information.
Draw on the expertise of industry's process engineers, rather than dictate their activities.
Susan Green, Massachusetts Department of Environmental Protection
I. Massachusetts Experience with SIC Expansion
A. SIC codes 10-14, 40, 44-51, 72, 73, 75, 76
B. Which of the above SIC codes DEP thinks need to file and for what chemicals (e.g.,
utilities, chemical repackages, solvent recovery, resource recovery facilities)
n. Policy Questions — SIC expansion
A. For hazardous waste facilities, resource recovery facilities - Should the waste feedstock
coming into the operation be counted toward reporting thresholds or only the chemicals
used by the facility?
B. For resource recovery facilities — Should chemicals coincidentally manufactured below
de minimum levels be reported (e.g., HC1 produced in an incinerator)?
C. For transportation sector — Are the following EPCRA exemptions appropriate?
1. Vehicle maintenance exemption
2. Fuel oil exemption
Massachusetts Experience with CERCLA Chemical Expansion
A. CERCLA chemicals phased in over 3-year period
B. Which CERCLA chemicals are being reported?
C. Policy questions related to the EPCRA vs. CERCLA lists:
1. Do the EPCRA qualifiers (e.g., zinc fume or dust) hold CERCLA chemicals?
2. Do the rules for reporting EPCRA chemical compounds apply to CERCLA
chemicals?
D. Reporting RCRA F and K Waste (these wastes are at the end of the CERCLA list) -
Should these wastes be reported? How?
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Paul Orum, Working Group on Community Right-to-Know
I. Overall Purpose of TRI:
• Toxic chemicals cause major harm (ozone hole, Superfund sites, chemicals in fish and
adipose tissue, etc.).
• Therefore, a new paradigm exists; companies must understand the chemicals they use and
must be able to publicly report, "we use these chemicals; this is where they go..."
— released to the environment
— transferred off-site
— wasted
— recovered (from that waste)
— put into products
— used up in production.
• This covers the Right-to-Know Law, Pollution Prevention Act and Right-to-Know More.
• Communicating this information must be done simply [example], but today's discussion
should be detailed.
2. Adding Chemicals to TRI
How broad should the TRI list be?
Long-term vision:
• Report 70,000 chemicals in commerce until proven /wn-toxic. (Our "show-harm"
criteria are backwards.)
Short-term vision:
• 320 chemicals covered by TRI.
• 520 chemicals were in the Right-to-Know More bill.
— regulated as toxic
— known/suspected cancer/reproductive harm, and
— EPA review confirmed
• 1,500 chemicals make up 95 % of chemical production.
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The process:
Legislation or EPA authority
Listing/de-listing petitions (most successful)
Cuomo/NRDC "RCRA 82" petition — two options:
— add 68
— add 22 now and others one by one.
3. Adding Industry Types to TRI
Many non-manufacturers release serious toxic pollution:
• Mercury from electric utilities (8 x TRI mercury).
• Mercury from municipal incinerators (3 x TRI mercury).
• Cyanide from gold mining (more than everything in TRI).
• VOCs from oil loading (Alaskan VOCs more than Washington, D.C.).
• Federal facilities (5 billion pounds?).
[note NRDC's Right-to-Know More report]
Approaches to adding facilities:
• Canada's TRI equivalent will cover all industries.
• Add Federal facilities by executive order.
• Tap Clinton technology programs ($350 billion?) for TRI expansion if EPA lacks
resources.
• Right-to-Know More adds between 11 and 17 two-digit SICs.
4. Release-Based Thresholds
Should TRI employ release-based thresholds instead of use-based?
Substantial limitations on reporting exist:
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SHSSION 7
• 10 employees exemption, chemical lists and use thresholds eliminate 83 % of potential
reporters (EPA).
• Only 373 out of 40,000 potential reporters in the printing industry now report
(printing industry comments).
May not reduce burdens much:
• Facilities must still do every step to calculate releases except report to the public.
• Therefore, the hidden work load is significant.
Sometimes clearly inappropriate:
• Persistence, bioaccumulation, acute hazards.
Eliminate useful information:
• Eliminate the most successful examples of pollution prevention and control
(database becomes solely "punitive").
• Eliminate upstream Pollution Prevention Act information on how releases were
reduced.
Approaches:
• Not provided for under current law [313(f)].
• Used in some proposed legislation to broaden reporting.
• Could replace use-based thresholds???
5. Right-to-Know More
Proposals have four main parts:
• More chemicals [covered above].
• More facilities [covered above].
• Planning [requires companies to go in and look for ways to make reductions, set
goals, no penalties.]
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[Show GAO report, also: Federal facilities, inspection authority, 10 employee
exemption]
Materials accounting data:
• Needed to more fully track pollution prevention.
— CFCs or mercury in products
— emissions per unit of product for comparisons
• In Senate bill in 1986 (products only).
• Taken out in favor of a study (National Academy of Sciences), [show report]
• NAS said: mass balance is too detailed, but materials accounting could be useful
(data more accurate, etc.).
• Meanwhile, many states have passed pollution prevention laws.
• Massachusetts and New Jersey collect process-specific throughput data; New
Jersey has collected facility-wide use data since 1987.
• Massachusetts trade secrecy claim rate: <2%.
• New Jersey trade secrecy claim rate: < 1 %.
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SESSION 8:
Presentation of the Annual
EPA Data Release
Introduction
The purpose of this session was to discuss the impacts of
the Agency's annual presentation of TRI data on various
"constituencies," including the public at large, state officials, EPA
and other federal agencies, public interest groups, the news media
and the industrial facilities that must provide the data. Presenting
this national data set each year raises interesting challenges of
trying to identify real trends in the release/transfer numbers and
then explain the forces behind such trends.
Specific Issues Addressed
The discussion focused in large part on the issues of risk
identification and some possible ways EPA could put the data in
a risk context, such as looking at releases in comparison with
employment in those industries reporting. There was diverse
opinion about whether states and EPA should make judgments on
individual facility local risks.
Joe Goodner from Illinois stressed that it is important to
establish a good baseline for comparing the TRI data across.
These trends need to be analyzed carefully based upon selected
chemicals and facilities reporting in each of the comparative terms.
Ed Hopkins from Citizen Action stated that EPA's data
release fails to give answers to some very basic questions. This
is due in part to the fact that EPA is a regulatory agency trying to
explain a non-regulatory program. He stressed the need for more
localized data to make the TRI data seem less abstract. EPA
struggles each year with the questions of risk associated with the
numbers. He stated that EPA should consider not doing a release,
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but make the data available as early as possible and publish a
report. If the release event continues, EPA needs to show more
creativity, e.g., have the administration hold it in a location that
illustrates the importance of the data. The new data should not be
glossed over. It is waste and should be characterized as such.
Donald Robbins from ASARCO stressed the impact that
data releases have in the industry. TRI data are used to set
industry priorities. In attempting to reach reduction goals, not all
operations have the same potential; not all releases reported have
the same risks. For example, ASARCO smelters report high
volumes of releases to land in the form of slag, which in his
opinion represent a very low risk. Yet their reports are
misinterpreted and their high releases cloud their other reduction
program picture.
Ray Tyson of USA Today emphasized the ongoing problem
of trying to sort out real and phantom reductions. Reporters are
doing more positive stories and doing more sophisticated analyses
using other data sources. By and large, reporters are not relying
on EPA's data or release information; they are going to the states
or special interest groups. He stressed the need to improve risk
communication. Also, the lag time between state and EPA data
availability makes for fragmented stories. Suggestions: EPA
should footnote changes from prior years. EPA should put the
data in context, e.g., what percent of the whole of releases or
production do they represent? EPA should highlight what releases
are not regulated and who is not reporting. Also, the press needs
help ahead of time.
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SHSSION 8
Where Do We Go From Here?
• Sorted tables are not analyses. EPA, states, and
others should look carefully into what degree of risk
characterizations can be attached to the numbers,
including perhaps localized examples.
• Think how we can raise awareness that not all TRI
reported releases are treated equal.
• EPA will do a release this year but we will heed the
suggestions; use a more creative media strategy that
is supportive of the news media's requirements and
capabilities.
• EPA will consider carefully the suggestion that a
report on the most recent year's data needs to
follow such a release event.
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Panelist Presentations
Joe F. Goodlier, Illinois Environmental Protection Agency
Q: What is your general perspective on the quality and utility of the information presented
through EPA's data release event?
The quality of the annual data release has greatly improved since its inception.
The annual data release event is of more utility to those states that do not produce their
own annual report. However, the event is very useful as an aid to Illinois in cross-checking and
quality control of our own state data, and provides useful insight on how to most effectively
present the data.
Q: What is EPA doing wrong — what is it doing right?
To use a positive and constructive approach, I don't believe that EPA is doing anything
"wrong," and is doing many things "right." As with any understanding, there is always room
for improvement, just as with our own state report. Two suggestions for improvement is as
follows:
1. In the "national" segment of the report, not the state-specific portion (the summary sheets
for each state), the top, say, 50 facilities or companies nationwide hi appropriate
categories should be listed as in the 1989 release. This would facilitate comparisons
among states.
2. A "baseline" of facilities and chemicals should be established to more accurately portray
what is happening over time. For example, for the annual Illinois report, we have
established a baseline of "X" facilities that have reported all years, and we include for
those facilities only the chemicals that have been reportable in the same form for all
reporting years to date. The form is important to damp out the effects of reporting on
such chemicals and compounds as aluminum oxide, where the reportable form has
changed over time.
Q. Each of you in your own way acts as a TRI data provider. What are your goals in
relating the TRI data to the public?
Our goal is to provide the most accurate and current information to any requester in the
required form at the earliest possible time. To this end, we have created a format that reports
all releases of all chemicals to each media for a single year from one facility on a maximum of
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two pages. We are also communicating with another state agency to place TRI data on an
electronic bulletin board system.
Q. Some await the latest data release with anticipation, others with dread. What are the
impacts of EPA's data release event on your "constituency"?
Each year, for about a week following the data release, we receive a substantial number
of inquiries from the news media. These have not been burdensome, and have actually provided
opportunities to clarify some perceptions. We have occasionally received calls from facilities
where apparent errors were made either in the data provided through the event or in the
reporting of the data.
Q. From your perspective, how far should/can EPA go in drawing conclusions about trends
in the data or potential risks that might be highlighted by the data?
We believe that it may still be too early to infer trends from the TRI data, and definitely
in a gross fashion. As suggested before, baselines should be established over time to support
trend analysis. Also, the impact of the economy must in some way be factored in.
The essence of the TRI program is reporting, not risk analysis. We believe that the TRI
data can be used to target risk analysis efforts based on the kinds, amounts, locations, methods
and sources of toxic chemicals released, but that conclusions about risk cannot be made from
the reported data itself in its present form.
Ed Hopkins, Citizen Action
This discussion will address what people want to learn from the TRI data, EPA's failure to
respond to these concerns, how EPA might improve its handling of the data release, and how
EPA should treat the new information generated by the Pollution Prevention Act.
I. What do people want to know?
• What factories in their neighborhoods are releasing toxic chemicals?
• Is this pollution endangering people's health?
• Why is this pollution allowed? Is it legal?
• What's the plan for solving the problem?
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EPA's annual data presentation fails to give clear, convincing responses to these
questions. This failure is due in part to the difficulties a regulatory agency
experiences in explaining a non-regulatory, informational program, and in part to
the apparent political difficulties the TRI poses for the Agency.
EPA's data release does not provide local data, an important deficiency. This omission
makes TRI seem abstract, limits interest in local data presented later by public interest
organizations, and thus diminishes the great potential value of TRI.
EPA can offer no good response to concerns about the health effects of TRI releases.
EPA struggles with this question, never gives a firm answer, and ends up sounding
indecisive. And in fairness, TRI does not provide all of the information EPA would need
to respond to people's questions.
Many people have difficulty accepting that much of the pollution reported to TRI is
apparently legal. That most of what companies report to the TRI is legal makes EPA
appear to be failing to do its job.
EPA's solution — the voluntary "33/50" program — is a weak response to an
announcement that industries release billions of pounds of toxic chemical wastes into the
environment. Talking about a big problem for which a bureaucracy offers no serious
solution undermines the Agency's credibility.
How can the Agency improve its release of the data?
EPA should consider not doing a public data release and instead making the database
available to the public. Non-profits and the press could use the data as they see fit,
which would probably result in a more informative and attention-grabbing data release,
and EPA can fulfill its statutory obligation by publishing its annual TRI report.
If the Agency continues to issue an annual report, EPA can make the data more
meaningful to people by localizing it.
EPA can gain credibility with the public by acknowledging that the TRI data provide
evidence of a serious national problem. To obtain an even better understanding of this
problem, EPA can announce that it will expand TRI reporting requirements to cover
companies outside the manufacturing sector and toxic chemicals not included on the 313
list but regulated under pollution control laws.
The Agency can develop a more comprehensive solution to the problems TRI poses than
the limited 33/50 program. EPA can show it has a serious plan for dealing with the
problem of toxics releases by developing or supporting pollution prevention planning
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legislation, such as the model included in the so-called "Right-to-Know More" bill
introduced in the last session of Congress by Rep. Sikorski.
EPA could also dramatize the TRI data with a more creative media strategy for releasing
it. Instead of the traditional inside-the-Beltway press conference, the Administrator could
travel to a location that would illustrate the importance of some aspect of the data.
IV. How should EPA handle the new information submitted under the Pollution
Prevention Act?
• The new information generated by the Pollution Prevention Act will probably reveal that
companies are producing far more waste than the previous years' TRI reports suggested.
EPA will face a challenge in figuring out how to account for all this new material. This
is waste. Although it's being recycled or burned for energy, some of it will ultimately
find its way into the environment.
• EPA should not downplay the importance of the new data just because the waste is
recycled or reused. Instead, its further evidence of inefficiency in the industrial process
and waste creation weakens the economy. The reporting facilities and the public would
be better off if this waste were not created in the first place.
• This information gives the Agency important new evidence it can use to advocate the
need for national, multi-media, mandatory pollution prevention programs.
Donald A. Robbins, ASARCO Incorporated
The Superfund Amendments and Reauthorization Act of 1986 sought to provide
mechanisms for advising the public when chemicals were released to the environment. The
mechanism addressed both emergency and routine releases. Providing Material Safety Data
Sheets (MSDS) to local emergency situation managers was viewed as beneficial preparation in
the event of a catastrophic release while the data on continuous releases would make the public
better aware of chemicals being routinely released in their local environment.
Clearly, public awareness is very important but, if the information is not provided in a
meaningful or useful fashion, the community or regulatory concerns may be inappropriately
focused. In my opinion, ASARCO and the nonferrous metals industry have an example that
demonstrates this point.
Copper and lead smelters in the course of producing metal generate large quantities of
slag, which is a high silica- and iron-containing material that actually reflects the natural mix
of elements found with the metal product after the metal of interest is extracted. Slag is glasslike
in its physical and chemical composition and thus chemically holds trace metals associated with
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it very tightly. To put the levels of production in some perspective, ASARCO produces
approximately two tons of slag for each ton of copper. In 1992, ASARCO produced 316,000
tons of copper.
Most slag is piled on the ground near the facility where it is produced. Over long periods
of time the slag is only very slightly altered by weathering and precipitation. Despite the fact
that this material is relatively inert, the 313 reporting rules require ASARCO to report the
contained metals as releases, even though these metals are not significantly released from the
slag.
The impact to mining companies like ASARCO is that our names are prominently and,
we believe, inaccurately displayed high on lists of companies emitting chemicals to the
environment. In the first year of 313 reporting (1988), ASARCO was listed as number 10 in
the nation, while the 1990 Toxics Release Inventory (TRI) indicated ASARCO's rank as 9.
Another essential part of the other story is lost when companies are ranked regardless of
the type of release. In 1989, for example, 98% of the lead released from the eight ASARCO
reporting facilities was in the form of slag. The relatively inert nature of this material, which
constitutes over 80% of ASARCO's releases, is lost in the May 28, 1992 USA Today list that
notes that in total pounds of pollutant ASARCO was the "worst" emitter in the States of Arizona
and Montana. The list and the headline from the Montana Standard also feature ASARCO
prominently (see attached article). To the credit of some of the individuals interviewed in
Montana regarding ASARCO's high ranking, they recognize the unique volume and chemical
nature of slag, but unfortunately these key points go unnoticed in national lists that are
published.
The dilemma that ASARCO and others in the industry face with slag has several facets.
The first and foremost is that ASARCO will continue to produce slag as a by-product of
producing metal. Additionally, there is no substitute for ASARCO's feedstock. The company
depends on ore concentrate as the only form of feed. How can an industry forced to produce
slag and unable to change feedstock be able to demonstrate a conscious effort to significantly
reduce actual emissions to the environment given the present 313 reporting regimen?
ASARCO, as well as many other mining companies, are supportive of the concept of
EPA's Industrial Toxics Program (33/50) which challenges companies to set emission reduction
goals and then to implement these reductions through the most cost-effective process and
management modifications. The factoring in of slag, which comprises over 80% of ASARCO's
chemical "release," makes demonstration of progress difficult indeed in the 33/50 program. As
an example, consider the change in releases between 1988 and 1990. Excluding slag,
ASARCO's reductions between 1988 and 1990 were as follows:
• For 33/50 target chemicals (lead, cadmium and nickel), ASARCO reduced releases by
20% (200,000 pounds).
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• For all 313 chemicals, ASARCO reduced releases by 26% (3.7 million pounds).
If slag is included, the data are:
• For 33/50 target chemicals (lead, cadmium and nickel), releases increased 3.7% (300,000
pounds). The 3.7% increase is production-related, since as more metal is produced there
is a proportional increase in slag production.
• For all 313 chemicals, ASARCO reduced releases by 5.6% (4.9 million pounds).
As a further example of how slag reporting makes it difficult, if not impossible, to show
emission reductions, consider ASARCO's installation of new ConTop flash smelting technology
at the El Paso Smelter. ASARCO's projections for emission reduction after installation are:
• 33/50 target chemical releases (lead, cadmium, nickel) will be reduced by 30%, from
57,160 pounds currently to 39,860 pounds after ConTop.
• 313 chemical releases will be reduced by 14% from 487,234pounds currently to 420,358
pounds after ConTop.
• SO2 emissions will be reduced by 44,000 tons annually due to ConTop. SC^ capture is
expected to be approximately 95% after ConTop, in contrast to approximately 70%
capture currently. (SO2 is not a 313 chemical.)
Production will increase 20%, which will translate in to generation of more slag. Under
the current distortions of the 313 program, the increased volumes of metals contained in the slag
will appear to reduce or overcome the benefits derived in air and water releases.
Is there a solution to this artificial problem created by viewing slag as a release to the
environment? Ideally, if there were a rationale for allowing slag and other similar materials not
to be reported, this would be the most advantageous approach. Failing that, can EPA create a
special category for these materials where their aggregate reportable amounts would not be
considered in the total quantity of listed chemicals released to the environment?
It is critical, in ASARCO's view, that a solution be found to the problem of reporting
slag. Should 313 reporting be extended to other SIC codes (e.g., 14-mining), huge volumes of
other innocuous natural materials, such as overburden and tailings, will need to be reported.
Most importantly, with the present system of reporting and, especially if the universe of SIC
Codes required to report is expanded, large but irrelevant numbers will without any reason make
it hard for many sectors of industry, as well as the EPA, to demonstrate meaningful strides
toward waste minimization and pollution prevention.
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6—The Montana Standard, Butle, Friday, August 11, 1989
Montana
East Helena smelter leads national pollution list
Stauffer Chemical
one state's top ten
pollution sources
by Mite* Dennlson
AMoclUml Pnn WrHw
KEUSNA (AP) - ASARCO'i
laid smeller In East Helen* to one
of (he top-volume polluters In the
nation, according to a list compiled
by (he National Wildlife Federation
— but regulator* and company offi-
cials say that distinction b not be
as harmful ai It sounds.
"Any smelter that produces its
principle byproduct of slag Is going
to rank very highly," Scott Brown
of the Environmental Protection
Agency's Montana office said
Thursday.
Brawn said the slag heaps, al-
though laced with zinc and other
heavy metals, are fairly solid and
probably don't emit much toxic ma-
terial into the air or water.
"Basically that slag to a moun-
tain of material that is Just going to
stay in the slag pile forever," added
Jon Nickel, Industrial quality man-
ager for ASARCO. "It's not going
anywhere.
Nonetheless, regulators acknowl-
edge that the East Helena smelter
Is one of Montana's major environ-
mental headaches. It has never met
«lr-quality standards for lead emis-
sions, and to one of several EPA Su-
perfund haxardous-waste sites In
the state.
"We've been preaching to the
people In East Helena for four
years that they're living In a leaded
environment and they need to take
precaution*," Brown said.
Using EPA data, the wildlife fed-
eration compiled • Ust of Industrial
sites nationwide and ranked them
according to volume of toxic mate-
rials released Into the environment.
The East Helena smelter plant
ranked 41st la the nation, with 31.4
million pounds of toxins released In
1X1. The only other Montana site
among the top 500 was the Colum-
bia Fails Aluminum Co. plant, in
473rd place with 18 million pounds.
CFAC's major pollutant was
aluminum oxide. Company spokes-
man Jack Canavan said the plant
has a filler system to reduce alumi-
num oxide participates.
"We're well within (air-quality)
limits." he said. "I can't see where
it poses a problem to workers or
anyone or anything else."
Rich Day, executive director for
the Montana Wildlife Federation,
said the group wants people to know
which Industries are releasing toxic
materials, In hopes that business
and the public will press for reduc-
tions.
"We're not trying to put anybody
out of business," be said. "We feel
people should be made aware of
what industry to doing. We're hop-
ing this report will prompt them to
reduce those toxins as much as they
possibly can."
The bulk of ASARCO's toxic re-
lease was 17.1 million pounds of
sine, a byproduct of lead smelting.
Almost all of the zinc was In the
slag neaps.
The EPA's Brown said regulators
were more worried about concen-
trations of lead, cadmium and arse-
nic, which have been deposited Into
the air and on the ground during loo
years of (melting.
Yet he said It would be prema-
ture to say the slag heaps are en-
tirely safe. EPA Superfund studies
on the slag heaps, groundwater,
surface water, ore storage and pro-
cess ponds are under way, and Ini-
tial reports from ASARCO are ex-
pected Nov. IS. The studies will In-
clude samplings of pollution by
heavy metals and proposals for
cleaning up the mess.
ASARCO also Is building a 115.6
million enclosed ore-storage build-
Ing to help get Its lead emissions In
compliance with state and federal
law. The ore has the consistency of
crushed rock and can be dispersed
by wind If left outside.
Nickel said the lOO-feet-by-600-
feet building will be able to hold
65.000 tons of ore.
Bob Ralscb of the slate Air Qual-
ity Bureau said the building should
help ARARCO approach compliance
on lead emissions, but may not be
enough.
Top twenty polluters
listed by federation
Helena(AP)- This list is according to data from the Wilderness
Ffedcra Uon.
1. ASARCO Inc., East Helena - 31.4 million
S. Columbia Falls Aluminum - 2.8 million
3. Exxon Refinery, Billings — l million
4. Conoco Refinery, Billings - 960.850
S. Pioneer Concrete & Fuel Inc., Butte - 282,000
6. Plum Creek Timber Co., Columbia Falls - 269,750
7. Cenex Refinery, Laurel - 254,667
I. Western Sugar Co., Billings —186,000
9. Louisiana Pacific Corp., Mlssoula - 125,950
10. Stauffer Chemical Co., Silver Bow - 95,765
11. Holly Sugar Corp., Sidney - 80,219
12. Eagfe-Picber Industries Inc.. Sidney -10,000
13. Montana Refining Co., Black Eagle - 44,320
14. Transbas Inc., Billings - 44,000
15. Borden Inc., Mlssoula - 39,150
16. Plum Creek Timber Co.. Kallspell - 37,500
17. Stone Container Corp.. Mlssoula - 37.000
18. American Chemet Corp.. East Helena — 16.390
19. Country Classic Dairies, Bozeman — 16,250
20. Beall Trailers of Montana, Billings -15,745
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Rae Tyson, USA Today
1. Overview of Media Usage
2. Response From Our Readers
3. What the TRI Data Does and Doesn't Do
4. Suggestions For Improvements
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SESSION 9
SESSION 9:
Presentation of the Data
to the Public
Introduction
The session presented three perspectives of how TRI data
are disseminated to the general public by non-governmental
organizations. While the government, both federal and state, is
the primary distributor of TRI data, in order to most effectively
reach the grass roots, or private citizens, other individuals and
organizations must assist in the dissemination. While in some
cases government information products will adequately meet the
needs of the user community, other times it is necessary for
secondary suppliers, or third parties, to take the data and present
them to their intended audience in a slightly different format or
with additional information, such as integration with other data
sets.
The session panelists offered three different perspectives on
providing information to a public audience. The first perspective
was that of a public interest group, Gary Bass of OMB Watch,
which provides the TRI data on a computer network system. The
second perspective was from Dale Kalina of the R.R. Donnelley
Company, a printing company that produces a press release based
on their TRI release figures. The last perspective was from a
journalist, Chris Isidore of the Gary, Indiana Post-Tribune.
Specific Issues Addressed
The session panelists offered three different perspectives on
providing information to a public audience.
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Gary Bass, of OMB Watch, first laid out some basic
principles and assumptions of public access.
• The public has a right to know not only about government
actions but also the contents of government collections of
data and information.
• The government has an affirmative responsibility to
disseminate information and make it available in the most
equal and equitable manner possible.
• The government has a responsibility to interpret
information in order to protect public health and safety and
enforce laws, and to make accessible uninterpreted data.
• The government does not have a responsibility to interpret
or manipulate information for specific individual needs.
Dr. Dale Kalina, with R.R. Donnelley & Sons, provided a
viewpoint of dissemination by industry. Since the first year of
reporting in 1987, R.R. Donnelley has filed TRI data for 21
domestic facilities, covering 17 different chemicals.
For the first three years that TRI reports were filed,
Donnelley made no formal attempts to prepare or respond to the
public release of the TRI data. The data were used by
environmental groups and were the subject of several newspaper
articles and television and radio reports highlighting toxics in the
community. Donnelley believed the media reports of the first
years' data failed to address several points necessary to put the
TRI data in perspective.
These points include:
• the releases represent operations that are operated under
permits,
• numbers alone provide no information on the efforts made
by facilities to limit releases,
• many of the reports have alleged health effects that are not
documented in EPA or scientific reports, and
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• the reported numbers fail to acknowledge other sources of
the TRI chemicals in the environment.
Donnelley decided in 1992 to make information on their
toluene releases public prior to EPA's release of the TRI data.
The idea was to provide some of the information that was lacking
in the media reports of the TRI data. In particular, they wished
to highlight the significant reductions achieved over the years
despite the fact that the levels of production at these facilities had
increased over the same period.
This information was included in a package sent to each of
the printing facilities and provided to the local media, with
guidelines on effectively responding to media and public inquiries,
along with background information on the use, release, and health
effects of toluene.
After making all these preparations for the anticipated
questions on the releases, Donnelley was somewhat surprised to
find very little interest in the 1990 data release. Some local
newspapers carried edited versions of the press release that had
been prepared. There were no inquiries for follow-up or
additional information. Despite this apparent diminished interest,
it is Donnelley's intent to make this information available and
continue efforts to communicate the successful release reductions
to the public.
Chris Isidore of the Gary Post-Tribune provided some
insight on how the media presents the TRI release data to the
public. He worked on a seven-month project detailing the extent
of pollution in Northwest Indiana, using TRI figures extensively.
In preparing the series, Mr. Isidore first defined his audience,
which included lifelong residents of the area who have experienced
great improvement in environmental conditions in recent years and
who depend upon the area plants for employment.
The goal of the series was to try to give readers a context
for the releases in the region, comparisons to other areas, and the
consequences of the pollution. Graphics were crucial in offering
the comparisons. In addition, in order to keep people's interest,
the stories had to rely not only on figures and statistics but had to
incorporate interviews with area residents, government officials,
and environmental activists.
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Although there were virtually no problems with the quality
of the data, industry was still critical of some of the conclusions
reached. The biggest problem was the relative age of the data.
Although the companies had to file the 1991 data with the EPA,
only one company, Amoco, agreed to make full disclosure of its
most recent data to the newspaper.
Where Do We Go From Here?
All three panelists highlighted the necessary role and
importance of nongovernmental players in the dissemination of
government information to the general public. Both the suppliers
of information, in this case industry, and the users, for example
public interest groups and the media, need to actively participate
in the characterization and analysis of important data and
information. It is also important for the EPA to understand their
role in facilitating the active participation of all constituents. The
EPA must make information available to the public in a flexible
manner that promotes greater access and use.
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Panelist Presentations
Gary D. Bass, OMB Watch
I. Public Access Principles and Assumptions
• The public has a right to know about government actions and collections.
• The public uses information in a responsible manner.
• Government has an affirmative responsibility to disseminate information.
• Government has a responsibility to make the information available in the most equal and
equitable manner possible, which includes pricing, format, and presentation, in order to
facilitate use and understanding of the information.
• Government has a responsibility to interpret information in order to protect public health
and safety and enforce laws, but does not have a responsibility, itself, to interpret or
manipulate information for specific individual needs.
• Improving public access and use of government information will assist agencies in
meeting responsibilities to carry out their mission.
n. How the TRI is Used: Case Examples from RTK NET
• Influencing public policies.
• Changing corporate behavior.
• Educating the public.
• Teaching tools.
HI. What EPA Still Needs to Do
• Develop a public access agenda for the agenda.
• Involve the public in all steps of the process — planning through implementation.
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Improve access to EPA information, including assurance of timely release and search for
effective distribution channels. Types of information to make available — information
collected by EPA (e.g., surveys, monitoring, research); information not now compiled
at EPA headquarters, but routinely reported to local, state, or federal governmental units;
analyses and reports developed by EPA; and commonly requested FOIA requests that
have been made public.
Set up an information locator within the agency.
Make data available in a variety of formats and through systems that permit widespread
use and analysis.
Revise trade secrets/confidential business information policies.
Coordinate public access within the agency so that all constituencies can maximize the
power of data linkages and integration.
Coordinate data collection and dissemination with other relevant federal and state
agencies.
IV. The Future
• Interest and NREN.
• EPA elevation bill & public access.
• Making information available in a flexible manner that promotes greater access and use.
Dale G. Kalina, Ph.D., R.R. Donnelley & Sons Company
Introduction
R.R. Donnelley & Sons Company ("Donnelley") is the world's largest commercial
printer, with more than 30 printing facilities in 22 states, as well as international operations in
countries including Mexico, England, and Ireland. Since the first year of reporting in 1987, we
have filed TRI data for 21 of our domestic facilities, covering 17 different chemicals from the
list of 300-plus chemicals on the TRI list. Donnelley's total TRI releases amounted to less than
0.28 % of the total 4.8 billion pounds of reported TRI releases in 1990. Of all the reports filed,
the bulk of our releases are accounted for by toluene, which accounts for more than 93 per cent
of the total TRI-reportable releases over the 1987-1991 period from the eleven rotogravure
printing facilities operated by Donnelley.
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Toluene
Toluene is the primary ingredient in the solvents used in the publication rotogravure
printing process. The solvent is essential in the printing of high-volume publications such as
catalogs, advertising inserts, and newspaper supplements. Although significant effort has been
expended to find alternatives for the organic solvent-based inks currently used in rotogravure
printing (such as water-based inks), there exist no practical substitute materials that provide the
quality and performance necessary for the production of printed materials in the publication
rotogravure industry.
The toxicity of toluene has been extensively studied, since it is a very large volume,
commercial chemical product. Total annual domestic production of toluene is 6.8 billion pounds
(1991 figures). Approximately half the toluene is used to increase the octane rating of gasoline.
It is also used as a solvent for paints and other consumer products and in the formulation and
synthesis of a number of commercial chemicals. Nationwide, annual toluene emissions from all
sources are estimated at 990 million pounds, with gasoline evaporation and vehicular emissions
as the primary emission sources. Total TRI emissions for 1990 were 275 million pounds. The
most recent summary of the lexicological effects of toluene was prepared by the American
Conference of Government Industrial Hygienists (ACGIH) in 1991. The report documents no
chronic or acute health effects at ambient concentrations. Evidence of chronic health effects or
birth defects have been documented only in cases where deliberate abuse of toluene (i.e., glue
sniffing) has occurred.
Toluene Use at Donnelley
As indicated above, the toluene used at our facilities is used as the primary component
in the inks used in the rotogravure printing process. As the inks are dried, the vapors from the
drying process are collected and recovered as clean, reusable solvent by activated carbon solvent
recovery systems. The use of solvent recovery systems in this process can be thought of as an
extremely large-scale recycling operation. We purchase ink concentrate and dilute it with
solvent at our facilities before use. The solvent from the recovery system is used to dilute other
inks, with the excess recovered solvent being sold to the ink manufacturers for reformulation
of additional inks. Every effort is made to recover as much of the toluene-containing solvent
as possible.
Obviously, no control system can be 100% efficient. However, since 1987, the first TRI
reporting year, we have increased the efficiency of our solvent recovery systems from
approximately 88 percent to the 1992 level of greater than 93%. In other words, for every 100
gallons of solvent in inks used for printing, over 93 gallons are recovered and reused or sold for
reuse. Of the remaining quantity (less than 7%), a portion remains in the printed product, with
the balance becoming reported releases, either shipped off-site as waste (where it is used as fuel)
or released as emissions. Through more extensive on-site reuse and recycling, we have reduced
the quantity of waste material. Through the significant increase in solvent recovery efficiency,
we have been able to effect the substantial reduction in toluene emissions.
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Replacement solvent systems for toluene have been formulated using other organic
solvents or solvent mixtures that contain fewer TRI constituents. Inks prepared with these
solvents may result in the releases of smaller quantities of TRI-reportable materials. However,
these solvents are still volatile organic compounds (VOCs) subject to the same air pollution
regulations and control requirements, and pose similar concerns for air quality as do the toluene-
based systems. Thus, they merely substitute non-TRI solvents for TRI solvents. Donnelley has
not revised its ink formulation simply to reduce its TRI releases. We have continued to use the
toluene-based ink systems combined with state-of-the-art controls and pollution prevention
activities to reduce our toluene releases to the greatest extent possible.
The Environmental Affairs Department at Donnelley works closely with personnel at our
facilities to verify the values reported as releases under TRI. Because we have systems in place
to recover the solvents, we can very accurately determine the quantity of solvent received,
recovered, sold, and shipped as waste. This leaves a simple and accurate calculation to
determine the quantity of toluene in emissions. Because we know quite accurately the quantity
of material consumed and the quantity recovered, we can very closely follow the progress we
are making in minimizing releases. Donnelley is proud of its record of reducing the releases
to the environment. We are committed to further reducing these releases.
Public Response
For the first three years that TRI reports were filed, Donnelley made no formal attempts
to prepare or respond to the public release of the TRI data. The TRI data were used by
environmental groups and were the subject of several newspaper articles and television and radio
reports highlighting toxics in the community. On several occasions, individual facilities were
approached by the media to comment on or respond to the release data. We also received
inquiries from our employees on the data. To the best of my knowledge, we have received only
one request from a private (non-employee) citizen for information on the release data.
Donnelley believed the media reports of the first years' data failed to address several
points necessary to put the TRI data in perspective. These points include:
• The releases represent operations that are operated under permits issued to ensure
compliance with state and federal air, water, and waste regulations.
• Although the pounds of releases reported are correct and in fact are the numbers that we
calculated and submitted to EPA, numbers alone provide no information on the efforts
made by facilities to limit releases. For example, a 25,000-pound release of a chemical
may mean a facility used 25,000 pounds and released it all, or may mean 250,000
pounds was used but 90% was controlled.
• Numbers alone also do not reflect changes in production levels. If a facility increases
its production while at the same time increasing the efficiency of its control measures,
the pounds released give no indication of the increased efficiency, and may be interpreted
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to mean the facility is actually doing a poorer job if the released quantity shows an
increase over the previous year.
Many of the reports have alleged health effects that are not documented in EPA or
scientific reports. The association of birth defects with toluene is one example.
The reported numbers fail to acknowledge other sources of the TRI chemicals in the
environment. For example, toluene released from evaporation of gasoline, from
household products, from facilities using fewer than 10,000 pounds of the chemical, or
from sources with fewer than 10 employees will not appear in the reports, even though
these may account for a significant portion of the total releases to the environment.
Donnelley's Approach for Presenting TRI Data to the Public
In the spring of 1992, it was decided that information on toluene releases from Donnelley
facilities for the 1990 reporting year would be made public prior to EPA's release of the TRI
data. The idea was to provide some of the information that was lacking in the media reports of
the TRI data as discussed above. In particular, we wished to highlight the significant reductions
we had achieved over the years despite the fact that the levels of production at these facilities
had increased over the same period. We also wished to point out that the level of toluene
emissions reductions at our facilities is well above that required by state and federal air pollution
regulations, that the vast majority of toluene emissions is from gasoline and automobiles, and
that studies on the toxicology of toluene have not implicated it as posing a health risk in cases
other than intentional abuse.
This information was assembled and distributed to each of our rotogravure printing
facilities in a package including a press release to be provided to the local media, guidelines on
effectively responding to media and public inquiries, and background information on the use,
release, and health effects of toluene. The purpose of this package was to aid the facility
personnel in promptly and effectively communicating information of the toluene releases to
anyone wishing greater detail than was available in other news releases.
After making all these preparations for the anticipated questions on our releases, we were
somewhat surprised to find very little interest in the 1990 data release. Some local newspapers
carried edited versions of the press release that had been prepared. There were no inquiries for
follow-up or additional information.
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Plans for the Future
Despite this apparent diminished interest in the TRI data, we continue to make
improvements in our systems to further reduce the quantities of chemicals released to the
environment. We are currently assembling our 1992 data for the July 1, 1993, filing deadline.
Preliminary analysis indicates the trend of significant reductions in TRI releases will continue.
It is our intent to make this information available and continue our efforts to communicate our
successful release reductions to the public.
Chris Isidore, Gary, Indiana Post-Tribune
Background
I worked on a seven-month project detailing the extent of the pollution in Northwest
Indiana last year. The series used information from TRI extensively.
Definition of Audience
Newspaper readers in Northwest Indiana. The Post-Tribune has about 75,000 readers
daily, and about 90,000 Sunday, virtually in Lake and Porter counties in Northwest Indiana.
Many of the readers are lifelong residents of heavily industrialized regions who have
learned to take the discharges from industry for granted. Many remember a time when things
were significantly worse, and many still have jobs that depend upon the industry in the region.
The goal of the series was to try to give readers a context for the amount of the ongoing
pollution in the region, letting them know how the amount of toxic discharges compares to other
areas, what was being discharged, how it was being released, and what some of the
consequences of the ongoing pollution are for the region.
Presentation Strategy
It was important that the stories not be built totally around the various numbers and
statistics available through TRI. We had to incorporate people into the stories, average residents
of the region as well as experts, officials and environmental activists whom we spoke with.
It was crucially important that the numbers be given some context, so that readers would
have a sense of how much pollution was being generated. That is the reason comparisons were
made to the amount of chemicals released in various accidents; how much of a chemical that is
being released would be used in a common, everyday manner; or how much was being released
by other geographic areas, or different types of industry in the region.
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Graphics that ran with the stories were crucial to setting off these types of comparisons.
The stories were spread out over four days in the paper in the first week of December last year.
It took up most of the front page, and four pages inside the A section of the paper each day.
Sources and Format for the Information
We used information from the TRI's CD-ROM for data from 1987 through 1989,
building databases in a PC with all the releases and transfers in the region and in the state, and
all the releases and transfers nationwide for certain chemicals of concern, such as benzene. We
got the 1990 data on disks from EPA in September, and added them, where we could, to the
other databases. We compared some of the numbers we were getting to EPA runs of
information, in publications such as Toxics in the Community, as a form of verification. And
with companies we were highlighting in the stories, we checked the numbers with them directly,
both to get explanations as well as verification of the amount of discharges.
Once we pulled the necessary information from the CD or disks, we were able to do the
analysis of the data using a database program. We use a program called Q&A, from Symantic,
mostly because of ease of operation and the fact that the program was already available in-
house. I would not recommend using it to others looking at crunching these types of numbers,
though. It was far too limited in its sorting capabilities, and was not a true relational database
program. There are several better database programs readily available on the market. But the
fact is that even using a limited database program, it was possible to do the necessary analysis.
Data Quality
Overall, we found virtually no problems with data quality. None of the numbers or facts
in the series were challenged by any of the industries we wrote about, although they were often
critical of some of the conclusions reached on the editorial pages.
The biggest problem we had with the data was the age of it. We would have much
preferred 1991 data. Even though all the companies had to file that data with EPA by Sept. 1
of last year, only one of the companies we contacted, Amoco Oil Co., agreed to make full
disclosure of their SARA numbers in advance of them being released by the EPA. Clearly, it
would have been better for us to get all those numbers for the series. Even though data
collection would have been far more difficult and time-consuming that way, it would have been
worth the effort for us. Many federal regulations, such as those governing the 990 financial
forms filed by not-for-profit organizations, must be released to the public by the group filing it
to the federal government. The information can also be obtained from the federal agency, in
that case the IRS, but such requests for information are, of course, far more time consuming.
From the point of view of the media, it would be far better to have access to the information,
at the source of the information, as well as having it supplied in a more complete and digestible
form by the federal government.
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Costs
The costs of the project were surprisingly small, other than the time that I and other
staffers spent on the project. The CD-ROM cost was only $45, and the updated information was
provided for free. We could have used one of the onVline systems, for example, if we wanted
national 1990 that we didn't have access to otherwise. But it was decided to concentrate on
Indiana statistics for that portion of the series. This type of project is within the budget of all
but the smallest daily newspaper that is willing to commit the internal resources to it.
Audience Feedback
Response to the series from the readers was very good. We received hundreds of letters
and phone calls from readers, and dozens of requests for hundreds of copies of reprints of the
series. There has been very little criticism of the series from industries in the region, as the data
that was used as the basis was for the most part their own. Some released their 1991 TRI
numbers after the series had run, as a way of showing that there had been improvements. I only
wish they had done so before.
Plans for Future
I was not an environmental reporter, but a projects reporter, when I was asked to work
on this series. I can't say that we plan to do this type of series every year. But I would
imagine, and hope, that as the data from future years are released, we would be able to update
the series, building on the information that is already in our databases.
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DATA INTEGRATION
TRACK SUMMARY
TRACK OVERVIEW ............. 145
SESSION 10: Integration of TRI Data
with Other Agency
Programs .......... 147
SESSION 11: Role of Data Integrity
Through Compliance
and Enforcement
SESSION 12: Integration of TRI
With Other Data Sources 169
SESSION 13: Integrated Data
for Enforcement Analysis
(IDEA) ............. 181
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TRACK OVERVIEW
The data integration track consisted of four break-out
sessions. The session were:
• Integration of TRI Data with Other Agency Programs
• Role of Data Integrity though Compliance and Enforcement
• Integration of TRI Data with Other Data Sources
• Integrated Data for Enforcement Analysis (IDEA)
The two main themes of the track were the use of the TRI
data for integrated enforcement purposes and the linkage of the
TRI data with other programs and data sources. As the EPA and
other users are becoming more familiar with the TRI data we are
discovering that the data are most beneficial when linked and
integrated with other information and data sources. As the program
matures, new and exciting uses of the TRI continue to be
developed. These developments have occurred at all levels,
including the Federal Government, Regional Offices, States, Local
Governments, and private organizations.
Part of this interest in the Toxic Release Inventory has been
fueled by the many types of analyses that can be performed by
matching TRI against other data sets. The explosive growth in
geographic information systems has led to many applications that
overlay TRI with other data to show relationships and present
information in new, more meaningful ways.
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SESSION 10:
Integration of TRI Data
With Other Agency Programs
Introduction
When the Toxics Release Inventory data set first became
available a few short years ago, it was new and exciting. There
were two major innovations: that a more or less comprehensive
inventory of toxic releases would be available, independent of the
particular regulatory programs, and that the information would be
available to the public. The consequences of public availability
was the focus of many of the other sessions at this conference.
But the TRI is also a resource that was not previously available
internally, as well as within the federal and state programs charged
with implementing specific regulatory programs.
The session examined the expanded use of the TRI data.
When the Toxic Release Inventory first became available, the
Agency started asking the question: how can we use this new
resource? Now, the question has changed somewhat, and we are
asking ourselves: how can we solve a particular programmatic
problem, and the Agency is looking to the TRI as part of the
answer.
Since TRI is only part of the answer, the Agency and
others have realized the need to integrate the TRI with other
sources of data. Three of the speakers, representing two programs
in EPA's Region V office and one State, described their
experiences in integrating TRI with other types of data — their
difficulties and their successes. The fourth speaker described the
opportunities that exist for using TRI and similar data in
preventing toxic accidents.
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For the Region V Water Program, TRI provides a list of
critical toxic chemicals and their sources that is integrated across
programs — air, water, and land disposal. It is this Potential
Source Identification function that is of most utility for the Water
Program. TRI data related to environmental problems provide a
prioritization method unavailable in individual media programs.
The TRI data have been employed in the Region V Water Program
to provide a relatively uniform baseline data set for a variety of
purposes. TRI data provide a more complete and uniform data set
than other available Agency databases.
The Region V Air and Radiation Program uses the Toxic
Release Inventory (TRI) in four areas: 1) the Lead Initiative, 2)
Enforcement Case Support, 3) Early Reductions Program (ERP)
support, and 4) Great Lakes studies.
TRI is used to identify the largest lead emissions sources in
Region V for addition to the Lead Initiative. Sources added to the
initiative's list are reviewed for compliance with the Clean Air Act
(CAA) requirements and considered for their potential for
voluntary reductions. TRI data also provide a means of checking
on the accuracy of emissions data supplied by air pollution sources
to U.S. EPA or the States. Region V has found violations of the
Clean Air Act using TRI data. TRI helps to evaluate submittals
from companies seeking to receive compliance extensions through
the Early Reductions Program. Region V has compared emission
estimates reported under TRI with the estimates provided in their
Early Reductions Program. Finally, for the Great Lakes studies,
the TRI and the Interim Air Toxics Emission Inventory were used
to compare heavy metal deposition in the Great Lakes.
The third speaker discussed the efforts of the State of
Wisconsin in linking the TRI data with several other databases.
The combined database linked facilities in several existing
databases by using the Wisconsin Facility Number. This linkage
allows users of the system to create comprehensive reports for
specific facilities.
The final speaker explored how to integrate TRI with
accident-oriented data and efforts to prevent accidents from
occurring. Occasionally, there is a trade-off between pollution
prevention and accident prevention; an example would be a facility
switching from a high toxicity chemical to a chemical with high
flammability properties. The potential uses of a linked database
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between accident data and the TRI include: documenting hazards
and tracking progress in their reduction; involving more users,
including workers and consumers; identifying priorities and their
potential impacts; and analyzing existing production systems.
Where Do We Go From Here?
EPA and its State partners have only begun to explore the
opportunities for combining TRI with other sources of data to help
us understand the nature of the problems we seek to solve. We do
not have a list of such opportunities, nor do we know how useful
they will be in the end. Our experiences have shown that the
payoffs are real and significant, so we need to continue to search
for them as we continue to work on the wide variety of
environmental problems we face at various levels of government.
We do know that integrating different sources of data is
difficult and requires solving many detailed problems. There are
no magic bullets, but integration can help solve problems.
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Panelist Presentations
George D. Graettinger, U.S. EPA, Region V
TRI provides a multi-media list of facilities and their toxic effluent that contribute to the
overall degradation of the Region 5 and Great Lakes ecosystem. These pollutants may or may
not be tracked by the EPA's regulatory or special initiatives. TRI provides a list of critical toxic
chemicals and their sources that is integrated across programs, Air, Water, and Land disposal.
It is this Potential Source Identification function that is of most utility for the Water
Program. TRI data related to environmental problems provide a prioritization method unavailable
in individual media programs.
TRI data have been employed in the Region 5 Water Program to provide a relatively
uniform baseline- data set for a variety of purposes. TRI data provide a more complete and
uniform data set than other available Agency Corporate data.
In the regulatory environment, TRI data are used as a reference in our NPDES permitting
program for both known and regulated, as well as unknown and unregulated, facilities that
discharge effluent to surface waters and their related media.
In the Permits program, TRI data provide a checklist for pollutants, and their estimated
loads that are used to ensure that reported pollutants are being addressed adequately, through
regulation or enforcement. This helps provide more accurate and complete data monitoring and
reporting, which results in better estimates of critical pollutant loads for the Great Lakes point
source dischargers.
In non-regulatory water programs, such as the Great Lakes Lakewide Management Plans
(LaMP) and Remedial Action Plans (RAPs), and the Geographic Initiatives in Northwest Indiana
and Southeast Michigan, TRI data are used as a baseline data set for assessing and targeting the
multi-media regulatory programs for existing effluent limitation, as well as for pollution
prevention activities identifying pollutants not currently limited or monitored.
In 1992, the Office of Pollution Prevention and Toxics contracted to have the locational
data in TRI developed into Geographic Information Systems (GIS) Thematic Coverages. A
quality control process was developed and applied to the TRI locational data from 1987-1990.
These data all carry a data item that reflects the method and the accuracy of a facility location.
The most important development in TRI has been the application of a locational quality
control effort much like the effluent data quality control process that is standard procedure.
These locational data, unlike any other EPA managed data, have undergone a thorough and
standardized locational data QA/QC process. We now know better the location of our
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permitees. This has directly assisted in the Watershed approach to environmental regulation and
protection.
For Geographic or Watershed approach programs, such as LaMPs, RAPs, and
Geographic Initiatives, the integration of spatial data (latitude/longitude) has assisted these
programs in identifying potential sources of Critical Pollutants to an individual Great Lake
drainage basin and to the specific sub-watersheds themselves. This allows Great Lakes drainage
basins and sub-watersheds to be ranked and prioritized based on relative watershed loadings of
our Pollutants of Concern.
While TRI data may have their limitations, these data provide a functional set of baseline
information that may be applied to many environmental problems. TRI is an excellent source
of indicator data to be used as a Regional management tool.
Michael Leslie, U.S. EPA, Region V
1) The Lead Initiative: ARD uses TRI to identify the largest lead emissions sources in
Region 5 for addition to the Lead Initiative. Sources added to the initiative's list are
reviewed for compliance with the Clean Air Act (CAA) requirements and considered for
their potential for voluntary reductions. Data from TRI and (AIRS) Facility System are
compared, and discrepancies in emissions quantities are investigated. Similarly, when
lead sources are missing from one data base, an effort is made to identify whether the
sources are meeting all reporting requirements.
2) Enforcement Case Support: TRI data provide a means of checking on the accuracy of
emissions data supplied by air pollution sources to U.S. EPA or the States. ARD has
found violations of the CAA using TRI data. For example, a manufacturer of synthetic
organic chemicals was found to be emitting volatile organic compounds many orders of
magnitude above allowable levels in its State permit. In addition, the Civil Air Penalty
Policy allows a penalty increase where it can be shown that violations involved pollutants
listed under air toxics provisions of the CAA. TRI greatly improves ARD's ability to
identify specific air toxics at a source.
3) Early Reduction Program: TRI helps to evaluate submittals from companies seeking to
receive compliance extensions through the ERP. ARD has compared emission estimates
reported under TRI with the estimates provided in their ERP submittals. Any
discrepancies are highlighted in our ERP review process.
4) Great Lakes Heavy Metal Emissions Inventory: Two emission inventories, which were
considered for use in quantifying atmospheric deposition to the Great Lakes, have been
compared for heavy metals. The first inventory, the TRI, is based on annual estimated
releases reported by industry. The second inventory, the Interim Air Toxics Emission
Inventory (LATEI), is based on the application of speciation and emission factors to the
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1985 National Acid Precipitation Assessment Program emission inventory. The
estimates are smaller than the IATEI estimates by a factor of 100 to 1000. Estimates for
specific sources will be refined to achieve the best possible inventory.
Wes Taylor, Wisconsin Department of Natural Resources
I. Planning For Data Integration
A. Consult end users about needs from integrated system.
B. Determine whether the integration is to be for a single year or span several years.
C. Select data sources (satellite data bases) to integrate.
D. Select structure of integration (3 options determined by existing data base formats):
1. Read directly from satellite data bases.
a. Requires forethought and planning in designing satellite data bases
b. Less time required for data manipulation and output formatting
c. Can only read data currently in file (can't access old archived data)
2. Create extract file.
a. Faster report generation
b. Potential for data quality checking
c. Potential to introduce errors into calculated data fields
d. Extracts capable of storing multiple data years
3. Manipulate extract file.
a. Can accommodate diverse satellite data bases and formats
b. Can more easily adapt to changes in satellite data base structure
E. Select linking data fields or elements common to all data sources.
F Select data unique but analogous to each satellite data base to create comprehensive
and overlapping picture.
G. Select elements common to a given theme (or themes) included from all satellite
data bases — for example, draw pollution prevention data from all the data sources
or waste generation data from all sources — it makes no sense to gather only
pollution prevention data from one data source, waste generated from another and
waste treated from the third — there is no comparative connection among these sets
of data.
H. Select default data base to display common but non-linking elements (e.g.,
address).
I. Determine which users will have what level of access to the data.
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J. Output reporting structure.
1. Canned output reports vs. custom output reports.
a. Reporting software choice
• ease of use
• flexibility
• expandability
• computational power
• importing into other software formats
• graphing abilities
b. Consult end users about reports
c. Storage of and access to output reports
d. Printing reports
e. User manuals
K. Determine who will maintain the data .
L. Maintenance.
1. Period (monthly, quarterly, annually).
2. Staying current with changing satellite data base structure.
3. Expansion.
n. Methods, Problems and Solutions in Data Base Linking
A. Convert files to common format.
B. Link files with common facility identifier.
1. Importance of master facility identification file.
a. Facility identification number
b. Name, address and city
C. Convert (calculate) common data elements data to common units.
D. Store in common location.
E. Storage space, cost, accessibility and data retrieval speed.
m. Obstacles in Data Integration
A. Incompatible field types (CAS vs. RCRA).
B. Conversion to like units (mg/l/hr vs. Ibs/year).
C. Missing data elements.
D. Conflicting data (e.g., addresses).
1. Multiple facility identifiers for a single facility (data recording error).
2. Multiple facility identification numbers per facility in one program vs. a single
facility identification number for the same facility in another.
3. Integration of incompatible file types and storage media.
IV. Distribution of Data to Other Organizations and the Public
A. Responsibility for data quality.
B. Access to data.
C. Prohibitive size of integrated data bases.
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V. Improvements and Enhancements
A. Public access.
B. Increase agency use.
C. Increase breadth of data on system.
1. New data
2. Existing data
D. Increase breadth of canned output reports.
1. Identify gross changes from one year to the next.
2. Identify gross discrepancies across programs.
Hillel Gray, National Environmental Law Center
Can the Right-to-Know Be Useful in Preventing Toxic Accidents?
Chemical Accidents are a Problem. Every day, on average, there are a dozen accidental
chemical spills, fires, explosions, or releases in the United States. Accidents can harm workers,
communities, the environment, and the economy. For example:
• Phenol tanks explode at a steel company, killing two workers and sending nearby
schoolchildren to the hospital;
• A spill of benzene and other toxins contaminate a Great Lakes waterway; air emissions
force a town to evacuate;
• An extremely toxic chemical spills into a river, killing the aquatic life and making
cleanup workers sick;
• A leak at a plastics factory forms a vapor cloud and explodes in a blast equivalent to 10
tons of TNT. Workers are killed and the cost is more than $750 million.
This talk will explore how to integrate TRI — and Right-to-Know approaches to prevent
toxic pollution — with accident-oriented data and efforts to prevent accidents from occuring.
Accident Data are Fragmented and Poorly Used. Compared to TRI, there is scant public or
governmental attention to data on chemical accidents and accident hazards. Such data include:
• Events. Chemical spills, fires, explosions and other accident release notifications are
compiled in the Emergency Response Notification System (ERNS) and other databases
scattered among federal and state agencies.
• Impacts. Human, environmental, and economic consequences of toxic accidents are
recorded by insurance firms, ad hoc case studies, and government projects such as EPA's
Accidental Release Information Program and ATSDR surveillance work.
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• Inventory and Chemical Flow Amounts. Accidents mostly involve quantities of chemicals
that are transported, stored, or processed. Quality and access of such data (e.g., Tier
n inventories) is weak compared to TRI waste amounts.
• Hazard Assessments. "Plume maps" and other assessments of potential accident
scenarios should be done by Local Emergency Response Committees. Industry and
LEPCs hardly ever make their hazard assessments public. (EPA, PEF, Millar)
Learning from TRI, accident data need to be more (1) systematically developed, (2)
centrally managed, (3) adequately enforced, and (4) publicly accessible. Moreover, (5) link
accident data to TRI and other regulatory and chemical information systems.
Policies and Institutions are Fragmented. Unfortunately, our institutions reflect the disarray in
the information. People who deal with environmental pollution — whether in industry or
government — seldom collaborate with occupational safety and accident management
professionals. Even in the same agency, the staff dealing with toxic pollution under EPCRA
may seldom talk to the staff responsible for EPCRA emergency planning.
Policies dealing with toxic accidents and pollution are not integrated either. For example,
single-media pollution rules tend to overlook the hazards from accidents that occur before toxic
wastes are generated, such as accidents before or during their toxic chemical use. (EPA Pulp
& Paper.) Waste treatment and recycling systems designed to reduce toxic emissions could
worsen the probability or impact of an accident. (Casada 4/92.)
The lack of coordination in data, institutions, and policies should be overcome toward
a shared purpose: prevention (e.g., can LEPCs promote P2, or pollution agencies advance
safety?).
Prevention: A Unified Approach to Toxic Accidents and Pollution
Our society has a haphazard patchquilt of stopgap measures to control, manage, and clean
up toxic wastes and toxic accidents. But toxic pollution and chemical accidents share a common
source: the production systems that use toxic chemicals. We need unified policies and strategies
to achieve prevention. (SAB Risk Report.)
"Pollution prevention" (P2) activities change production systems by modifying
technologies, products, or raw materials. P2 is also known as source reduction (when evaluated
for reduced wastes) and, more precisely, toxics use reduction (when evaluated for reduced use).
P2 excludes add-on measures, such as waste treatment and recycling. (Poll. Prev. Act; 12 State
TUR laws.)
"Inherent safety" or "primary accident prevention" activities change the intrinsic safety
of production systems. Like P2, this involves redesigning a product, changing a chemical input,
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or improving a production process. It might involve reduced toxic chemical inventories.
Inherent safety excludes extrinsic accident mitigation systems, such as sprinklers, leak detectors,
and double-walled vessels. Spill response is not prevention, though protective of the
environment. (See Ashford, Kletz.) (Note: OSHA process safety mgt. and CAAA risk mgt.
plan rules mostly address extrinsic approaches; this should be changed.)
P2 and accident prevention do not simply overlap (there may be some trade-offs). Yet,
they share a common mission: fundamental changes in technologies, products, and raw materials
to reduce toxic hazards at the source. This common agenda is one reason for fuller integration
of TRI and accident-related information.
Linking Toxic and Hazardous Chemical Information. What would an integrated TRI and
accidents data system look like? The foundation should be built around the core elements of
TRI:
• Chemical characteristics: Linked access to toxicity and safety data, including worker
exposure levels and accident frequencies by chemical and industrial process.
• Chemical quantities: Chemical storage and use quantities are essential to both P2 and
the evaluation of accident potential; also improve data quality and auditing.
• Facility and geographic information: Link accident reports to TRI and other facility or
site identifications.
• Destinations: Transportation spill data should identify the intended uses, and known
recipients, to help trace impacts to the underlying production systems using the chemical.
• Production system description: Both P2 and accident prevention focus on technology
change, so data should specify the technologies and products that are the source of either
toxic pollution or accident events. (NJ PPA, Mass. TURA)
• Prevention goals and progress: Need goals for reducing the storage and use of toxic
chemicals. Report reductions in throughput, accident frequency, and impacts (e.g.,
injuries).
Covered facilities and chemicals. We recommend that TRI reports, site inventories, and
accident notifications be required for a unified chemical list. Any facility subject to emergency
planning requirements/thresholds should provide modified TRI-style data on throughput
quantities and emissions.
Accidents should be followed by verified reports that include toxic release quantities (by
media) and human, ecological, and economic impacts. Current reporting is inadequate.
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Uses of Integrated TRI and Accident Data
These uses are presented to advance the dialogue about how to unify toxic
accident/pollution data and prevention programs.
Track toxic chemical flows and substitutions
• To monitor and evaluate chemical substitutions (e.g., from toxic to flammable
chemicals).
• To determine when toxics shift into products or workplaces.
• To educate communities, consumers, and workers.
Identify impacts and risks
• Toxic chemical use, storage and accidents data to improve:
— TRI risk screening, and
— systematic vulnerability zone screening (Note: TRI emissions are not used in CAMEO
estimations.)
• Identify priorities based on historic accident frequency, accident potential, and routine
toxics use and wastes.
Understanding and promotion of cleaner production
• Does a just-in-time inventory system reduce accidents (by reducing storage) for a given
chemical, or is it offset by accidental or routine releases due to increased transfers?
• Do the accident and worker exposure problems of recycling and treatment provide an
impetus for source reduction?
• Can sound prevention techniques be found among production processes with lowest
accident or toxics use rates?
Analysis of prevention options
• Costs. More complete cost accounting by adding the costs of accidents associated with
current production systems. This includes "upstream" losses due to transport to the
facility.
• Risks. Would accident frequency rates or potential severity be useful in choosing new
processes or chemicals?
Stronger Impetus for Prevention
• Metrics. What measures would set up a TRI-style dynamic, with public reporting and
goal-setting, to motivate accident prevention? [Storage and use of EHS chemicals;
incident frequency; size of vulnerability zones; process specifics?]
• Management. Do repeated accidents reflect total quality management problems relevant
to pollution prevention?
Reforming institutions
• Agency coordination. LEPCs and P2 programs can integrate "inherent safety" and toxics
source/use reduction planning.
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Collaboration. Industry, environmentalists, and labor have mutual interests in safer,
cleaner, and profitable production systems. Right-to-Know is the cornerstone of worker,
consumer, and citizen participation, and Right-to-Act.
Recommendations
1. Resources. Full funding for accident data programs and linkage to TRI. Equitable fees
can be based on accident factors, such as presence of EHS chemicals, storage and
throughput quantities, transported amounts, and numbers of transfers.
2. Materials accounting for facilities on EHS/TRI chemicals. Process-level reporting of
facility accidents and toxic chemical use reduction rates. (NJ PPA, MA TURA) The
proposed federal Right-to-Know More Act is a starting point.
3. Transportation data on chemical shipments and the industrial sources/destinations of
transport accidents. Public access.
4. Methods to apply unified data sources and evaluate the safety and environmental impact
of product and technology options.
5. Research on linkage of inherent safety to P2. Pilot projects to apply data toward unified
prevention policies.
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ShSSION 10
Prevention: A Unified Approach to Toxk Accidents and PoUution
Prevention
Method
Product redesign
Process
improvement
Raw material
substitution
Pollution Prevention
Yes
Yes
Yes
In-process recycling Generally
Closed loop
continuous
processing
Out-of-process
recycling
Storage/reuse of
remnant of batch
process
Pollution controls
Inventory reduction
Operating at
ambient temp, and
pressure
Smaller scale
operations
Multistream
operations
Generally
No
No
No
Generally
Generally
Uncertain
Uncertain
Inherent Safety
Yes
Yes
Yes
Uncertain
Generally
No
No
No
Generally
Yes
Potential
Potential
Sample
Considerations
Toxk amount in
product
Venting vs. closure
Toxicity vs.
fianunability
Equipment failure
rate
Increased handling
Treatment
chemicals
Transport
increased?
External tracking
method?
Source: Natl. Env. Law Center, Ashford et. al. Feb. 1993.
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SESSION 11
SESSION 11:
Role of Data Integrity
through Compliance
and Enforcement
Introduction
The overriding purpose of this session was, generally, to
communicate the seriousness of U.S. EPA and some states in
ensuring the integrity of data submitted through the reporting
mechanisms of the various environmental statutes and, in
particular, EPCRA Section 313.
For example, the Agency's introduction of data quality
inspection training and its development of a Section 313 data
quality inspection manual show that data quality enforcement is
being constructed on a solid foundation. At the same time, the
increasingly multi-media focus of EPA's enforcement efforts
demonstrate the "horizontal integration" of the process — the
Agency's growing ability to cross-check compliance data bases and
target facilities — and entire industries — with a history of non-
compliance.
Several Section 313 data quality cases brought by the
Regions illustrate some of the practical issues in litigating such
cases, and point the way for future enforcement actions. As data
quality enforcement gets fully underway, the Agency will be going
beyond individual cases to an approach that targets particular
industries or categories of violators through the use of enforcement
initiatives.
Risk assessment is assuming an increasingly important role
at EPA. To conduct accurate and meaningful risk assessment, it
is critical that the data collected by the Agency be as accurate as
possible. Enforcement is perhaps the most important means we
have to ensure that the regulated community takes its
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environmental data reporting obligations seriously and submits only
accurate information.
Specific Issues Addressed
Panelists highlighted the multiple fronts on which the
Agency is pursuing enforcement against those who submitted
information which does not meet statutory and regulatory standards
of accuracy. The overall themes of the discussion were: (1) small
business compliance, (2) revisions of forms to ensure data quality
in past years, (3) continuation of industry and EPA to search for
joint projects on release estimation, and (4) multi-media focus. A
large portion of the discussion was focused on the assertion that
small businesses are not receiving outreach on the TRI program
and are being scared away by the larger firms. Participants
discussed creating an amnesty program for the small businesses to
get them involved with TRI.
The participants suggested several future intiatives to
enhance the integrity of the TRI data:
consolidate reporting requirements
exempt or provide more help to small businesses
make results of state grants publically available
streamline compliance outreach
create an amnesty program
Where Do We Go From Here?
As EPA's enforcement efforts continue to evolve toward a
multi-media approach, and more and more environmental statutes
require the reporting of emissions data, the Agency's ability to
cross-check media-specific emissions data reported under more
than one statute will be enhanced. This is particularly true given
the growing sophistication of EPA's integrated multi-statute
compliance data base. Greater data integrity will result because of
decreased opportunities for "gaming" the reporting system by
reporting different emissions figures to take advantage of the
particular perceived or real advantages of individual statutory
programs.
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In the Toxics Release Inventory program, the availability
of data reported under new air toxics emissions monitoring
requirements of the Clean Air Act will in the next three years alter
the nature of reporting under EPCRA Section 313, by shifting the
reporting burden from the calculation of "reasonable estimates" of
emissions to reliance on actual monitoring data. This will allow
less "wiggle room" to the regulated community and should
enhance the accuracy of the TRI data base.
Many (if not most) businesses report accurately on their
emissions of various pollutants. But it is believed that a significant
minority do not. Eventually, it is hoped that Agency enforcement
efforts will encourage accurate data reporting to the point that
corporate behavior is altered and data integrity ceases to be a
major enforcement concern. When that time comes, EPA's risk
assessment will become a better and more powerful tool for
achieving the next major goal: risk reduction.
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Panelist Presentations
Robert D. Fentress, U.S. EPA
I. News from the front: the first data quality cases
A. Bethlehem Steel Corporation (Region n)
B. Other, on-going Regional data quality cases
n. The Clean Air Act
A. Increased ability of Agency to cross-check between data bases under different
statutory programs (IDEA)
B. The New Operating Permits Program under the Clean Air Act
C. Other CAA issues
m. Multi-Media: 1993 Data Integrity Enforcement Initiative
A. Importance of accurate data to risk-based regulatory approach
B. Role of TRI data in the initiative
Julie Vanden Bosch, U.S. EPA
The Data Quality Compliance Program
Data quality is emerging as a new, important focus for all the compliance and
enforcement programs both at Headquarters and in the Regions. Now that our §313 non-
reported compliance and enforcement programs have matured, we are beginning to concentrate
more on the quality of the TRI data that are submitted to EPA and the States.
The Office of Compliance Monitoring (OCM) is responsible for developing many of the
compliance and enforcement tools that ensure the integrity of the TRI data base through the
inspection process. The following is a synopsis of the tools EPA is using in the emerging data
quality compliance/enforcement program:
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SESSION 1 1
EPCRA §313 Inspector Training
OCM is in the process of developing EPCRA §313 program-specific training for federal
and state inspectors. Currently, we expect that the training modules will be developed and
delivered in FY 1994.
As part of this program-specific training, we will be delivering "advanced techiiical
training" on data quality issues to experienced inspectors. As part of this advanced technical
training, state and federal inspectors will learn about: 1) pollution prevention/source reduction
methods and practices; 2) industrial processes and chemistry; 3) fraud detection; 4)
environmental criminal investigations; and 5) inspectors' relationship to voluntary programs and
multi-media/cross-inspection programs.
The goal of this training is to: 1) enhance and standardize the inspection process; 2)
provide inspectors with the latest information on the regulated universe's ability to ensure the
quality of §313 data; and 3) help the inspector provide appropriate compliance assistance to the
myriad of covered facilities.
EPCRA §313 Data Quality Inspection Manual
As a companion to development of this training, EPA has prepared the Interim Final
EPCRA §313 data quality inspection manual. It was distributed to the Regions for their review
and comment in November, 1992. This manual outlines the data quality inspection process
(from targeting to closing conference) and provides guidance to inspectors on preparing for a
data quality inspection, and gathering evidence, and materials needed to develop a strong case.
It also provides checklists to help inspectors check the quality of data while on-site and after the
inspection.
Industrial profiles for seven different industries have also been developed to aid the
inspector in understanding the various industrial processes and chemistry of seven SIC codes
(including furniture manufacture, electroplating, and paint formulation). We anticipate
developing more profiles for different SIC codes if resources are available.
OCM will be obtaining feedback from the field, in approximately three months, on the
Interim Final guidance. OCM will then finalize the manual for release in FY 1994.
Compliance Assistance
OCM and the Regions are actively including compliance assistance in many facets of our
mission. The concept of compliance assistance has been included in most of our operating plans
and, given the obligation of facilities to provide EPA and the states with quality Form R data,
is an integral part of the emerging data quality focus.
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For years, the Regions and Headquarters have been offering compliance assistance
through: 1) Form R training sessions; 2) interpretive guidance offered by the TRIMS staff; 3)
personnel available at the Regional level to answer complex engineering/chemical compliance
questions; and 4) assistance provided in order to comply with a settlement agreement (just to
name a few examples). Headquarters is now actively encouraging Regional inspectors, if not
already doing so, to use the closing conference and an opportunity to offer data quality
compliance assistance to facility officials. Other opportunities to provide compliance assistance
may also be offered at other points during or after the inspection. We are asking inspectors to
disseminate both general (e.g., TRI Questions and Answers and/or a copy of §313 regulations)
and industry-specific (e.g., Section 313 Release Reporting Guidance) literature to a facility when
appropriate.
Multi-Media Focus
Data quality inspections conducted by the Regions are occurring most frequently as pan
of multi-media inspections. This has proved beneficial for a number of reasons: 1) the quality
of data can be checked with other program inspectors and compared with monitoring data for
permitted releases; 2) it sends a message to the regulated community that we are concerned
about the quality of data across all program lines and statutes; and 3) it helps us to concentrate
on chemicals or processes of concern across program lines.
Headquarters is also actively encouraging the use of TRI data by non-EPCRA §313
inspectors (e.g., RCRA, CAA and CWA) before, during and after an inspection. We believe
that this will help inspectors in other program areas identify possible discrepancies between
permitted releases and TRI data.
Purpose for Cooperative Agreements
The Office of Compliance Monitoring cooperative agreement funds are made available
to assist states with the development of their own EPCRA §313 enforcement programs.
Program activities that are considered for funding include compliance monitoring activities in
support of EPA's EPCRA §313 program; continuation of existing state compliance programs;
and development/implementation of state authority in this area. It is hoped that as states develop
and implement these programs the threat of toxic releases into the environment within their states
will be reduced to acceptable levels or eliminated where possible. The projects should assist
states in developing continuing programs to uncover potential non-reporters and/or inaccurate
reporting of TRI data submissions and to bring enforcement actions.
On September 19, 1992 the Administrator signed a delegation authorizing the Office of
Compliance Monitoring (OCM) the ability to provide funding to states, tribes, and tribal
organizations to develop their own EPCRA §313 enforcement program. The Office of
Compliance Monitoring has provided a total of $300,000 to five states from FY 1991 through
FY 1992. These funds were limited to those states that had active grants with the Office of
Pollution Prevention and Toxics for FY 1990 and FY 1991. As a result of this limited pool of
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SliSSION
eligible applicants many states were unable to apply for the OCM enforcement funding. The
new delegation of authority now permits all states and tribes who are interested in the
enforcement funds to apply for this funding.
FY1993 Agreements
The Office of Compliance Monitoring (OCM) has designated $95,000 to fund
approximately two state cooperative agreements (approximately $47,500 each). Proposals are
due to the Regional Offices by April 19, 1993. Final selections for FY 1993 will be complete
by the end of June 1993.
FY 1994 Agreements
The award cycle for FY 1994 will be altered so that final selections will be made in the
December/January time frame. This is being done to alleviate time constraints experienced by
the states and regions during the period of time when the Form R is being completed by industry
and received by the states and regions. The funding available for FY 1994 is not known at this
time.
Cindy DeWulf , Ohio Environmental Protection Agency
I. Ohio Right-to-Know Law 1988
a. TRI was separated from the other parts of SARA
— separate from the SERC
b. TRI rules equivalent to U.S. EPA
c. TRI Fee Program funds full-time TRI staff
d. Enforcement authority
— both civil and criminal
n. Data Integrity — 2 aspects
a. Non-reporters
— bring as many people into the system as possible
b. Data quality assurance
HI. Non-Reporters/Late Reporters
a. Mailing each year to remind people to file
— include negative report
— follow-up in 1 month if we don't hear from company
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IV. Data Quality
a. Started with 1991 grant
— reviewed calculations from 10 SIC codes
— provide guidance on what estimates are being used within an industry
• did not find any major errors in estimates
b. Requested calculations
— review threshold determinations
— review release estimates
— errors commonly found in air releases due to lack of test data
— request permit applications from Division of Air Pollution (look at what
companies put down as actual verses allowable air emissions).
— call company with any questions
V. Use Results of Efforts
a. Target industries that need assistance (i.e., plating facilities, foundries)
b. Hold training for industries
c. Develop outreach material for industries
d. Contact trade organizations and volunteer speakers
e. Put notice in trade organization newsletter
VI. SeU TRI Within Environmental Regulatory Agency
a. POTW releases in 1 county resulted in a task force to review releases to that POTW
b. Let inspectors know what TRI can do for them
— how they can use TRI to check permits
c. Tell inspectors how they can help the TRI program
— identify discrepancies, non-reporters
d. Internal cooperation and cooperation with region is the key to success
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SESSION 12:
Integration of TRI
With Other Data Sources
Introduction
Two factors that have characterized the TRI program since
the first data were released in 1989 are the myriad ways in which
the data are used and the diversity of the audience that has found
ways to use it. Interest by the public as well as special interest
groups far exceeded initial expectations.
Part of this interest was fueled by the many types of
analyses that can be performed by matching TRI against other data
sets. The explosive growth in geographic information systems has
led to many applications that overlay TRI with other data to show
relationships and present information in new, more meaningful
ways. The emergence of the environmental equity movement can
be traced to the ease with which TRI and permitting data can be
matched with health effects and socioeconomic information.
Creation and dissemination of data files resulting from the 1990
census have also played a role in sparking new data integration
efforts.
The purpose of this session was to explore ways in which
TRI is being used in combination with other data sources, and how
data integration affects its value, usage, and the potential audience
of users. The format of the program allowed for three speakers to
describe specific applications, followed by a discussion of the
issues in which all attendees were invited to participate.
The facilitator for the session was Jerry Poje from the
National Institute of Environmental Health, National Institutes of
Health. Drawing on his extensive experience in using TRI and
working with the environmental and health communities, Jerry
introduced the program and moderated the discussion of the issues
that followed the panelists' presentations.
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Specific Issues Addressed
The purpose of the session was to explore ways in which
TRI is being used in combination with other data sources, and how
data integration affects its value, usage, and the potential audience
of users. Three speakers described specific applications of
integrating the TRI, with health effects data, census data for
environmental equity, and toxic chemical production data.
The TRI data were used by the New York State Department
of Health to determine geographic "hot spots" due to TRI release
clustering, and to incorporate TRI data in environmental health
studies. This was used to prioritize areas where further
environmental data are needed and to prioritize areas to conduct
environmental health investigations. In order to accomplish this,
the department first corrected geographic coordinates for reporting
facilities to ensure all New York facilities were identified in their
correct location. Next, a ranking of the facilities by risk was
completed. Third, population estimates were figured to determine
possible public health impacts. Finally, screening was completed
for geographic hot-spots.
The Chicago and Minnesota offices of Citizens for a Better
Environment (CBE) has correlated the TRI data with zip code and
census data. The group has also developed neighborhood maps
that plot TRI facilities in relation to things like sensitive
populations (e.g., schools and health care facilities), parks, and
suspect hazardous waste sites. Examples of its use include one
community group that is using the TRI data to screen candidates
for a local industrial development corridor and another group that
has used the TRI data to find out what kinds of wastes are being
shipped to a local hazardous waste treatment facility.
The final speaker conducted a study comparing the TRI
data to production data collected under the Toxic Substances
Control Act or TSCA. Most of the TSCA data are not available
to the States or the general public, based upon confidential
business information claims filed by the reporting industries. The
comparison found that of 53 Illinois facilities that completed the
TSCA forms, 85% of them also filed TRI forms. However, on
the chemical basis, less than 10% of the chemicals covered on the
TSCA forms were also found on the facility's TRI filings. The
speaker noted that there is a definite need to better coordinate the
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linkage between the different chemical data bases in order to
obtain a complete picture of available chemical information.
Where Do We Go From Here?
Data quality is of paramount importance when integrating
data from multiple sources. Fields used for matching data from
different sources must often match exactly in order to produce
correct and complete results. The increased use of GIS systems
has highlighted the problem of incorrect or missing latitude and
longitude coordinates.
The new pollution prevention data and the pollution
prevention movement in general may present new opportunities for
integrating TRI data and using it in different ways.
The level of awareness of TRI is perhaps one of the most
significant factors affecting the extent to which the data base is
used as a secondary data source by non-traditional audiences or
merged with other information sources.
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Panelist Presentations
Thomas Talbot, New York State Department of Health
Integration of Toxic Chemical Release Inventory Data
With Public Health and Census Data
New York State Interagency TRI Project (October 1991-March 1993), funded by USEPA
includes the following agencies;
• NY State Emergency Office
• NY State Department of Environmental Conservation
• NY State Department of Health
• NY State Parks Management and Research Institute
• NY City Department of Environmental Protection
Objectives
• Verify and correct geographic coordinates of all New York State TRI facilities
• Estimate populations living near TRI facilities
• Determine geographic areas that may be "hot spots" due to TRI clustering
• Incorporate TRI data in environmental health studies
• Risk ranking of New York TRI facilities based on air releases
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Verify & correct geographic coordinates
• NYS Parks Research Institute verified or corrected 906 NY TRI facility coordinates by
using ARC/INFO software to link TRI facilities with geographic data from other sources.
US Census TIGER files provide address locations
Air Permit Data (NYSDEC)
Hazardous Waste Sites (NYSDEC)
Water Permit Data (NYSDEC)
Land Parcel Location (NYS Div. Equalization and Assessment)
Planimetric Maps (CD-ROM from NYSDEC)
Facilities not found using other data sources contacted directly
• Produce atlas of TRI facilities in New York
• Accuracy of coordinates submitted by TRI facilities
Correct coordinates
Coordinates < 1 mile off
1-5 miles off
>5 miles off
No lat/long submitted
24%
41%
12%
12%
7%
Coordinates transposed 4%
Estimate populations living near TRI facilities
• Reason
Determine possible public health impacts
Population size for epidemiological studies
• Estimated population within 1 and 2 mile radius of all NY TRI facilities
Linked TRI Facilities with 1990 Census Blocks (dBase IV software)
270,000 census blocks in NY, median census block size = 7.4 acres
• Developed methods to estimate rural populations using individual land
parcel data. 4,500,000 land parcels in NY. (Mapinfo Software)
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Risk ranking of TRI facilities
• Linked TRI chemicals to toxicity data
Cancer Potency Factors
References doses (chronic exposure non-cancer)
Annual Guidelines Concentrations (NYS DEC)
Threshold limit values (ACGIH)
• Ranked all facilities on quantity and toxicity of air emissions
Geographic "Hot Spot" Screening
• Simple area source model predicts air concentrations for a series of points on a grid
Assumptions of model
Emissions are continuous
Plumes do not rise but move to the ground
RI site-specific meteorological conditions are not a factor
• Concentrations for same chemicals are added together if multiple TRI facilities in area
• Concentrations are converted to risk scores
• Risk scores from different chemicals are added together for similar health outcomes
• Grid is shaded based on risk scores for health outcomes such as cancer or acute
respiratory problems
Mapinfo Software
Roads and water bodies are also shown
• Results of screening
Prioritize areas where further environmental data are needed
Prioritize areas to conduct environmental health investigations
Incorporate TRI data into environmental health studies
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• Congenital heart defects and exposure to volatile organic compounds (funded by ATSDR)
Household sources
Occupational sources
Drinking water
Commercial sources (dry cleaners, gas stations etc.)
Industrial sources (TRI)
Waste sites
• Congenital malformations and exposure to toxic chemicals from inactive hazardous waste
sites (funded by ATSDR)
TRI emissions data used to control for confounding exposure variables in case-
control epidemiology study
Kevin Greene, Citizens for a Better Environment
Integrating TRI Information with Other Databases
to Foster Environmental Action
The Chicago and Minnesota offices of Citizens for a Better Environment (CUE) have
been comparing TRI information databases in an effort (1) to make this information more
meaningful to the general public and (2) to foster environmental change. For example, CBE has
correlated the TRI data with zip code and census data. The group has also developed
neighborhood maps that plot TRI facilities in relation to things like sensitive populations (e.g.,
schools and health care facilities), parks, and suspect hazardous waste sites. This presentation
will outline the methods that have been used by CBE to introduce people to the TRI information
at community workshops, using an integrated approach. The reaction of workshop participants
will be discussed along with the follow-up activities.
While many community groups understand the significance of TRI information, they are
looking for ways to incorporate it into their ongoing programs. For example, one community
group would like to use the TRI data to screen candidates for a local industrial development
corridor. Another group has used the TRI data to find out what kinds of wastes are being
shipped to a local hazardous waste treatment facility.
Other groups see the long-term potential of the TRI data as a way to improve their
understanding of local environmental hazards. Many of them have spent a long time dealing
with more visible environmental problems, such as fly dumping, lead poisoning and abandoned
lots. They want to see these issues receive more attention as part of a broader community
development agenda that includes using the TRI data to press for cleaner industrial operations.
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Roger Kanerva, Illinois Environmental Protection Agency
Integration of TRI and TSCA Data
Submitted by Facilities in Illinois
Introduction
Since the early 1980s, the Illinois EPA (IEPA) has been interested in gaining a better
understanding of the general utility of certain TSCA information for state toxics control
programs. Because of complications caused by CBI provisions, no protocol exists for regular
and convenient access by state agencies to facility-related TSCA information at headquarters,
USEPA. In the view of this author, at least, it is in the best interest of progressive
environmental protection to maximize cooperative data sharing about facilities that manufacture,
use, or handle toxic chemicals.
In the spring of 1991, this author was asked by the USEPA to be a charter member of
the new Forum on State and Tribal Toxics Action, FOSTTA for short. This event opened up
fresh opportunities for better communication and information exchange among the state, tribal,
and federal participants. Within this forum, the author has pursued the issue of cooperative data
exchange. In this spirit, the Illinois EPA agreed to conduct a pilot project to assess the
availability of TSCA information on a request basis from certain regulated facilities in Illinois.
Purpose and Scope of Project
The purpose of this project was two-fold:
1. To assess the availability of certain TSCA information on a request basis from
facilities in Illinois; and
2. To evaluate the utility of such information for the toxics control program in
Illinois.
The scope of this project was determined via an informal dialogue with the Information
Management Division (IMD) of the OPPTS. It was recommended that the IEPA seek copies
of the 1990 Inventory Update Rule Reports (IUR) as well as other related information. Selection
of facilities to contact in Illinois became a key step. After submitting a written request to the
IMD, the author was furnished with an alpha listing of facilities/addresses for IUR filers in
Illinois. This list contained 93 facilities. Upon checking, we found various problems, and so
only 86 facilities were selected for the study. In addition, we were advised that a number of
facilities were excluded from the list because the company had marked the location of the facility
as CBI on the report.
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Response Results
In early February, 1992, the author sent an information request letter to each one of the
86 facilities. A preference was stated in the letter for responses to be received within 30 days
after the receipt of the letter. This letter was not sent via certified mail as is usually the case
for enforcement or other formal actions.
The initial response to this letter was many phone calls asking what this was all about,
expressing confusion over the type of information or stating concerns about confidentiality. The
following table presents a summary of these contacts:
Nature of Call
Number of Contacts
Questions about the letter or what
information we wanted
Questions about CBI and later on the
labal analysis was sent
Did not have information and wondered
what to do
Representative of industry associations
that was asked to inquire about letter
Total
16
12
33
*Note: These companies were given a contact person at
USEPA to get hold of so that a copy of their report
could be sent to them.
Because of the many questions and concerns about confidentiality, the author asked our
legal counsel to prepare a legal analysis regarding the relationship between Illinois'
confidentiality provisions and the CBI process under TSCA. This analysis was sent out to 12
requestors and, as a result, some companies did ask for confidential status. It should also be
noted that other parties asked for this status on their own accord or simply altered or "sanitized"
the copy of the forms in some way.
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table:
The ultimate responses to the request letter (86 mailed) are summarized in the following
Category of Action
Number
1. Response letters from facilities
• Provided information
• Refused to provide information
• Information promised
• Inappropriate facility
2. No response at all
3. Contacted IEPA about response but
nothing received
Total
60
[53]
[2]
[0]
[3]
19
86
With respect to some written response, we managed modestly well — about 70%. Since
some companies refused to provide the information or did not respond, the actual information
response rate is lower — about 62%
Analysis of information
An analysis was done of the information that was received in an effort to evaluate its
utility. The attached data summary (Table 1) provides a sense of the information that was
submitted. A cross-comparison to other relevant data, such as toxic chemical releases (Form
R-TRI) in Illinois, and activities under the Illinois Chemical Safety Act, was also done. Based
on this analysis, several findings most relevant to this conference are provided as follows:
1. Cross-comparison grind — It turned out that our staff had to do a manual comparison of
the TRI and IUR information. This data-crunching process was time consuming and
tedious. The relatively small number of facilities was die only thing that kept this project
in the manageable category. Down the road, we've got to figure out more efficient ways
to handle these data.
2. Seeing the chemical landscape — Since the IEPA has worked for years with the annual
TRI data, we used this information as a sort of benchmark for comparison purposes. On
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a facility basis, we saw about an 85% match-up, but on a chemical basis, we saw less
than 10% overlap. This pattern gave us some sense of the high data enrichment potential
that would be associated with routine access to the IUR information for Illinois.
3. Spin-offs for TRI arena — It appears that the IUR information may be of some use in
identifying non-filers for TRI. Chemicals of interest or concern are another area of
potential value. Staff at IEPA identified 54 such chemicals from the IUR information.
Of these 54 chemicals, 22 were on the TRI list and 32 were not. On the IUR, many
chemicals were referenced as intermediates that could be a part of environmental releases
at times. We have little working knowledge about the potential hazards that these
chemicals may represent. At this point, however, we do have a sense of the need and
value of better linkages between major chemical databases.
Conclusion
All things considered, this project turned out to be a worthwhile adventure. We learned
some useful things at the IEPA and so did the USEPA. From all appearances, we've got a long
way to go before workable integration of chemical databases is a reality. Perhaps most
importantly, this project has helped to convince us that we should seriously pursue the
development of an integrated toxics chemical database for Illinois.
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Table 1
Summary Information for Special Project Report
Analysis of Submittals
Number of Submittals
No. of
Replies
60
Origin of
Facility
25
No. of No. of No. of
Forms Refusals Promises
53 2 0
Submittals
Corp. US EPA
Office HQ
25 3
Submitted Data
No. of
Chemicals
at Facilities
628
No. of No. of
Substantial Health &
Risk Safety No. of
Notices Studies MSDSs
17 11 402
Cross Comparisons
(Subset of Submitter)
TRI Data
No. of
Inapprop.
Facilities No. of Filers
3 50
No. of
Chemicals
542
TRI vs. IUR
No. of
Chemicals on
IUR & TRI
37
No. of
No. of
Chemicals Chemicals
on IUR
Only
591
Illinois Chemical Safety
No. of
Significant
Release
Facilities
10
No. of
Submitters
with
Contingency
Plan
33
on TRI
Only
505
Act
CBI Status
No.
Claimed on
Update
19
No.
Claimed to
ffiPA
8
No. of
Chemicals of
Concern at
Facilities
79
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SESSION 13:
Integrated Data for
Enforcement Analysis (IDEA)
Introduction
IDEA is an interactive, high-speed data retrieval system
that integrates facility-based information from EPA Program
Offices' data base systems. IDEA currently links data from twelve
EPA systems including the Toxic Release Inventory. IDEA
supports facility profile queries, which show what EPA data
currently exist for a given facility or company, and inspection and
enforcement targeting queries, which show which facilities exhibit
specific criteria such as location, chemical release, or industry
category. IDEA is at the forefront of the multi-media enforcement
initiative at the EPA.
Specific Issues Addressed
The session provided an overview of the IDEA system: its
purpose, functionality, and application to the environmental
enforcement community. The discussion was followed by a
demonstration of the system's capabilities.
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Where Do We Go From Here?
IDEA is an accepted tool to assist EPA in meeting its
enforcement objectives. It will continue to be enhanced to make
it easier to use, provide access to additional data sources, and
increase its analytical capabilities. In addition, it is anticipated that
the user community will be expanded over time to include other
regulatory agencies (both federal and state).
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Panelist Presentations
Jerry Lappan, U.S. EPA
Background/Purpose
The Agency's Enforcement 4-Year Strategic Plan (Plan) and the Enforcement in the
1990's Project identified the need for an integrated data capability. The Plan emphasized the
importance of data integration efforts to support enforcement targeting activities, case screening,
case development, litigation support, and settlement negotiations. Developing the Integrated
Data for Enforcement Analysis (IDEA) capability to meet these information needs for the
enforcement community has been, and will continue to be, the Office of Enforcement's (OE) top
priority for system development and implementation.
The inability of environmental personnel at the federal and state levels to readily integrate
factual compliance and enforcement information contained in the Agency's various national
mainframe data systems through an automated means also was identified to the Congress by the
President for FY 1990 as an Agency material weakness under the Federal Managers Financial
Integrity Act (FMFIA). OE, with cooperation from the Office of Information and Resources
management (OIRM), the media program offices, and the Regional offices, have worked over
the past three years to develop and enhance IDEA. A succinct description of IDEA is that it is
a computerized data retrieval capability that integrates data from a variety of national
enforcement and compliance databases in an interactive, on-line environment for the purposes
of multi-media evaluations, enforcement targeting, case development, and case screening. The
capability operates on the EPA's central mainframe computer system.
Functional Requirements
IDEA'S technical design included a number of functional requirements that enhance its
utility as an enforcement tool. Of primary importance was that IDEA be able to support
interactive queries. IDEA can process most complex multi-media queries in a matter of seconds.
This quick response time encourages "what-if1 querying (e.g., the exploration of different
targeting scenarios where multiple variables and selection flexibility exist). This type of data
analysis was simply not practical using the traditional batch query available before IDEA.
It was important that IDEA be readily available to the EPA user community, which is
geographically dispersed and which has computer hardware ranging from extremely simple to
quite sophisticated. As a consequence, IDEA was designed to run on the simplest of PCs via
a modem link to EPA's National Computer Center (NCC) mainframe (IBM 3090). This allows
any authorized user to dial into IDEA from almost anywhere. IDEA also supports data sharing
without geographic restrictions. IDEA users have access to all of the integrated data at the
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national level. This feature is useful for trend analysis (e.g., by pollutant or Standard Industrial
Classification (SIC) codes), and in developing corporate compliance profiles.
IDEA is a "facility-based" data integration capability. Data from the different program
data systems are linked together based on a common facility identifier. This permits the
information to be retrieved and presented in a fashion that is familiar and readily useful to
enforcement and compliance personnel.
IDEA Usage
IDEA is designed to support the EPA enforcement and compliance community by
answering two basic types of questions:
• Case Screening — what is the enforcement/compliance profile for a specific facility or
company; and
• Targeting — which facilities share certain attributes (e.g., location, industrial category,
compliance status, enforcement history, et cetera).
In each case, data from any or all of the IDEA-linked databases can be queried and
displayed in IDEA reports, all in a matter of seconds.
The automated data systems accessible through IDEA do not contain all of the
information that an individual needs in order to assess program performance, or the
environmental status or significance of a particular facility, corporation, or industry accurately.
The data accessible through IDEA are a useful subset of information on program performance,
but the use of other non-automated information, and a dialogue with appropriate EPA
Headquarters and Regional enforcement program personnel, as well as state officials, would be
helpful to make accurate conclusions about performance. Also, due to the dynamic nature of
the automated databases that form the basis of this capability, and due to the timing of data
retrievals, data may not precisely match data reported in other EPA reports. In addition, the
system update frequencies for several data systems, especially those that rely on information
from the States, may result in data lags.
IDEA is not intended to replace any EPA automated information system or reporting
procedures. Existing quality assurance/quality control procedures for each program information
system will not be duplicated or altered. For management accountability reports and other
official displays of quantitative enforcement information (e.g., tallies of administrative actions),
OE will continue to rely on the Agency's Strategically Targeted Activities for Results System
(STARS) reporting process. The quantitative STARS reports are based on well-established and
defined State and Regional reporting processes, data retrieval dates, and discrepancy
reconciliation processes that cannot be duplicated or replaced by IDEA.
OE intends to make use of IDEA as we strive to improve targeting of our enforcement
resources. IDEA is, however, a recently developed tool and will be used in the four major
stages in the targeted compliance and enforcement analysis process: (1) selecting the areas for
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study and establishing the computer selection criteria; (2) retrieving the information; (3)
verifying and analyzing the information; and (4) following predictable and systematic procedures
for feeding the results into the Agency's (both Headquarters and Regions) short-term and long-
term enforcement program planning process. At this time, IDEA addresses the fundamental
needs of the second stage, and the Agency, led by OE, is working to address the other three
stages of the targeting process.
Databases Linked by IDEA
The national data systems linked through IDEA are:
the AIRS Facility Subsystem (Clean Air Act):
the Permit Compliance System (Water — NPDES);
the RCRA Information System (RCRA);
the CERCLA Information System (Superfund);
the Superfund Enforcement Tracking System (CERCLA PRPs);
the Toxic Chemical Release Inventory System (EPCRA);
the National Compliance Database (Toxics);
the Enforcement DOCKET;
the Contractor Listing DOCKET;
the Federal Facilities Information System (Federal facilities);
the Dun and Bradstreet Marketing Index; and
the Facility Index System.
IDEA queries against copies of the data bases from these systems. These data base
copies are updated by OE on a monthly basis to keep IDEA'S data current.
User Community/Access
IDEA'S user community consists principally of personnel from the enforcement and
environmental services (inspection) offices. These people are attorneys, inspectors, and analysts.
In some cases, the same person accesses IDEA, runs the query, and analyzes the data; in others,
there are users of IDEA data/reports who do not know (or care) how to run a system, but find
great utility in the output. Once analyzed and verified, IDEA data may play a role in
management decision-making.
While IDEA represents a major step forward in making information accessible, it is
important to keep in mind that IDEA has been designed primarily to provide factual information
to experienced enforcement personnel in enforcement targeting, case screening, case
development, litigation support, and settlement negotiations. It is also important to remember
that there is significant potential for misinterpretation of information obtained through IDEA.
As each program system accessible through the integration capability is unique, knowledge of
statutory provisions, program definitions, data relationships, and sound professional judgment
will be essential to interpret accurately the information that is retrieved.
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EPA is not planning to rely on IDEA as the means for providing responses from the
public or other requesters. IDEA does not contain any new data; all of its data is duplicative,
obtained from other sources. Much of the "compiling" of information gathered through IDEA
is done by the computer; however, verifying and analyzing the information is labor intensive.
Verification must be coordinated with affected Headquarters and Regional Offices and no
resources are currently available to support this work. For the foreseeable future, EPA will
continue to rely on the various Headquarters enforcement program offices and Regional Offices
to provide information to external requests.
Data Integration Issues
In developing the IDEA capability, a number of technical and political issues had to be
addressed. These included:
• Software Environment — in order to support interactive high speed data retrieval
processing, rather sophisticated original program codes had to be developed using a
programming software that would support the design requirements. PL/1 was selected
as the programming software for its flexibility and speed (as compared to ADABAS or
FOCUS), and because OE had PL/1 programmers on staff to lead the system
development.
• Data Ownership — IDEA integrates data from a number of EPA program areas. The
data are "owned" by the program offices and their regional and state components.
Obtaining access to die data was a negotiated process between OE and the programs.
• Data Access — IDEA was initially designed to provide real-time data access. However,
concerns raised by NCC over the implications of direct real-time data access forced the
development of the data base copy, or "shadowfile" approach. Once the data files were
provided to OE, they were evaluated for retrieval speed, and when necessary normalized
and optimized to improve retrieval performance. This enhances IDEA'S performance,
but increases the maintenance overhead.
• Data Confidentiality/Security — most of the data files provided to OE by the program
offices contain some data that are considered enforcement confidential (i.e., unauthorized
release of the information could compromise planned or ongoing enforcement activities).
These data were identified through discussions with each contributing program office.
Because the enforcement confidential data are mixed with non-confidential data, the
entire set of data files are RACF (Resource Access Control Facility) protected.
• User Access — the data confidentiality issue requires that user access to IDEA be
controlled. IDEA access is restricted to EPA personnel, and even then, only to those
who have formally requested access to support compliance and enforcement work. IDEA
also maintains detailed audit trails of user activity, both authorized activity and
unauthorized attempts to gain access.
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sr-ssioN
User Support — data integration presents some unique problems regarding user support
due to the fact that it accesses so many different data sources. The principal challenge
is in training users to take advantage of IDEA'S query flexibility, and then in
appropriately interpreting the query results. A proficient IDEA user tends to become an
EPA database "Jack of all Trades."
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DATA APPLICATION
TRACK SUMMARY
TRACK OVERVIEW 189
SESSION 14: TRI Links With Voluntary
Reporting and Reduction
Programs 191
SESSION 15: Risk Screening 201
SESSION 16: Local Use of TRI Data . 233
SESSION 17: Public Use of TRI 251
SESSION 18: EPA's Geographic
Initiative 259
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TRACK OVERVIEW
The data application track consisted of five break-out
sessions. The sessions were:
• TRI Links with Voluntary Reporting and Reduction
Programs
• Risk Screening
• Local Use of TRI Data
• Public Use of TRI
• EPA's Geographic Initiatives
This track was designed to provide an overview of the current
range of TRI applications.
The individual sessions focused on the federal, regional,
state, and private uses of the TRI data, such as using the data for
worker protection, for the 33/50 program, for the Geographic
Initiatives, and for exploration into the extent of potential risks and
methods for setting priorities.
An underlying theme for discussion was how to broaden
and increase frequency of communication of results, techniques,
assumptions, and uncertainties of applying TRI to different
programs.
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SESSION 14:
TRI Links With Voluntary Reporting
and Reduction Programs
Introduction
In the two years since its creation, the 53/50 Program has
become a major stimulus for industrial pollution prevention.
Beginning with just a handful of participating companies,
enrollment in 33/50 has grown to more than 1,100 companies that
have collectively committed to reduce toxic wastes by at least 354
million pounds by 1995. All of this has been achieved through
voluntary action. Thousands of other companies are eligible to
participate in 33/50 and have been invited to join the program. A
major activity of 33/50 is the continuing dialogue between EPA
and these undecided companies to encourage them to join the
program.
There have been several key impacts of 33/50. First, the
program is meant as a demonstration project, as an experiment to
learn if voluntary programs can achieve real and rapid
environmental results. So far, the answer appears to be "yes,"
although a full evaluation of the 33/50 Program is still to come.
Secondly, 33/50 has focused the attention of the industrial
community on concrete goals — a 50% national reduction by 1995
— and on a high-priority set of 17 toxic chemicals. Thirdly, but
certainly no less important, 33/50 has emphasized one of EPA's
primary themes for environmental protection — pollution
prevention; the program's recognition and awards activities will all
focus on accomplishments achieved through reductions at the
source, rather than through treatment or other waste management
options.
33/50 is not just a dialogue between EPA and industry.
States have gotten actively involved with spinoff programs such as
Minnesota-50. The public has taken an active interest in 33/50;
environmental organizations, schools and universities, community
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groups and the news media all actively request information on who
participates in 33/50 and what types of commitments companies
are making.
The panel presentations will take a detailed look at how
three companies have responded to 33/50, and what their response
has meant in terms of internal goal-setting, managerial
organization, and identification and implementation of pollution
prevention opportunities.
Specific Issues Addressed
The session focused on the impact of EPA's 33/50
program. The program is data-driven and TRI provides the
yardstick for measuring progress. Since its creation two years
ago, the program has become a major stimulus for industrial
pollution prevention efforts. This session focused on how three
companies have responded to 33/50 and how their response
affected internal goal setting, managerial operations, and
identification and implementation of pollution prevention
opportunities.
One of the most common themes addressed by participants
was how easy it is to reduce TRI releases, the tremendous
opportunities for pollution prevention, and the cost savings that
companies are realizing as a result.
Briefly, some of the other issues discussed were:
• The impact of TRI in focusing attention on pollution
prevention.
• The importance of making sure that the 33/50 program
remains flexible.
• And, the availability of pollution prevention opportunities
once companies begin to review their past and current
emission levels.
Participants also stressed the need to move beyond 33/50,
expanding the list of chemicals and establishing larger reduction
goals and more current benchmark dates.
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They noted that EPA needs additional information regarding
genuine innovations in pollution prevention to help the Agency
recognize the achievements made by companies.
EPA needs to find more companies to participate in the
program. Regions, states, trade associations, and environmental
groups can be used to more effectively target companies to
encourage greater participation.
EPA needs to do a more thorough evaluation of the
program to determine just how effective it has been.
An established method is particularly important for tracking
the real progress on the international front, since many of the
participating companies have international facilities. This will
pose a challenge not only to EPA but also to the international
environmental community.
Where Do We Go From Here?
Several significant issues related to data will greatly affect
the direction of the 33/50 Program between now and 1995:
• Pollution prevention data: TRI data collected as of 1991
(and just now becoming available) greatly change the
overall picture of national toxic waste generation, by
including information that was formerly omitted on
quantities of wastes recycled or treated. On the one hand,
the data provide a much more detailed picture of the role
of pollution prevention in achieving reductions. On the
other, they create the appearance of large increases in
generation that will need to be put in careful context.
• Recognition: The 33/50 Awards Program, and other
efforts at public recognition, hinge on being able to
distinguish genuine innovations in pollution prevention
from other types of reductions that result from treatment,
economic impacts, "paper" reductions, and so on. TRI
data only take us so far in allowing for these distinctions;
additional information will be needed.
• Outreach: More than a thousand companies participate in
33/50, but there are thousands more potential participants.
Creative use of TRI data may allow EPA Regions, States,
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trade associations, environmental groups and others to
more effectively target companies to encourage greater
levels of participation.
Evaluation: How effective has the 33/50 Program been in
reducing releases and in promoting pollution prevention?
Answering this question will be the key to understanding
the effectiveness of the voluntary approach. Although it is
clear that many 33/50 participants are making dramatic
reductions in their TRI waste numbers, it is also the case
that this reduction trend began prior to the creation of
33/50, and is occurring in both participating and non-
participating companies. Careful analysis of TRI and other
data sources will allow for a more thorough evaluation of
the overall impact of the 33/50 Program.
International: International interest in both TRI and 33/50
has grown tremendously, due in large part to the
endorsement of right-to-know included in Agenda 21 from
the Earth Summit in Rio. Many companies have already
extended their 33/50 commitments to include international
facilities. Finding a meaningful way to track progress on
the international front will pose a challenge not only to
EPA, but to the international environmental community.
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SliSSION 14
Panelist Presentations
Mark Bindbeutel, Chrysler Corporation
I. Chrysler Corporation's voluntary reduction of toxic chemical releases
A. Driving forces behind Chrysler's participation in Voluntary Pollution
Prevention Initiatives
B. EPA's 33/50 Program (formerly the Industrial Toxics Project)
C. The Auto Industry Pollution Prevention Project (Auto Project)
H. Chrysler's Perspectives on Pollution Prevention and 1987-1991 TRI data
A. Thought process Chrysler went through to target substances for reduction
B. Programs put in place to cost-effectively reach the goals we had set
1. Source Reduction Programs were implemented, such as increased
application efficiencies, coatings reformulation, innovative solvent/cleaner
processes, etc.
2. Costs and Benefits associated with voluntary reduction initiatives
m. How Chrysler responded institutionally to Voluntary Pollution Prevention
Initiatives that go beyond compliance
A. Outreach program to solicit supplier involvement in toxic release reductions
B. Involvement of Corporate organization in overall program goals
C. Role of Corporate disciplines in implementing a Life Cycle Management
program for pre-screening materials of concern
D. Industry interaction with Environmental Groups and other stakeholders
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Robert M. Currie, Baxter Healthcare Corporation
Who is Baxter Healthcare Corporation?
Baxter Healthcare Corporation is the world's leading manufacturer and marketer of
health-care products and services for use in hospitals and other health-care settings. Baxter's
1992 worldwide sales were $8.5 billion. Baxter's core business, hospital products and services,
manufactures and distributes products ranging from bandages, intravenous solutions, and latex
gloves to precision surgical instruments, respiratory products, and nonwoven drapes/gowns. The
research-intensive medical systems and specialties business provides specialized products used
to treat blood and cardiac disorders and to diagnose disease. In all, Baxter manufactures or
distributes over 120,000 products. The diverse nature of manufacturing and distribution
operations makes it especially challenging to implement state-of-the-art environmental programs,
such as pollution prevention initiatives.
Baxter's toxic release inventory (TRI) for 1987 reported over 8.2 million pounds of
releases. Forecasted TRI releases reported for 1992 should total around 2.5 million pounds —
a 70% decrease. Our 33/50 commitment, synergistically coupled with existing programs and
goals, helped Baxter focus on reducing the TRI releases.
Baxter's 33/50 Program Commitment
Baxter committed to participate in the 33/50 Program in May, 1991. We committed to
voluntarily achieve an overall reduction of 80-percent of releases of the 17 chemicals covered
by EPA's 33/50 Program by 1995. The overall reduction targeted is based on 1988 data
(releases to all media) and on the aggregate releases of all 17 chemicals. The goal is applied
on a corporate-wide basis of all domestic facilities.
Baxter committed to rely on source reduction or pollution prevention technologies to the
maximum extent feasible (based on technological and economic factors). For toxic releases that
cannot be prevented through source reduction, recycling will be used wherever feasible. Also,
where source reduction and/or recycling are not feasible, treatment will be used to help achieve
the goal.
In addition to committing to the reduction of the 17 target chemicals as described above,
Baxter extended its commitment to include all toxic substances regulated by Title ffl of the Clean
Air Act Amendments and all chlorofluorocarbons. We will reduce air releases of these
substances by 60% and 80% by 1992 and 1996, respectively, over 1988 levels based on
equivalent product output. This goal applies to all Baxter operations worldwide.
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Baxter's 33/50 Program Achievements
A 90-percent reduction of releases of EPA's 33/50 Program chemicals was achieved in
1991 by our domestic facilities, compared to 1988 levels. Baseline year releases approaching
one million pounds were reduced to less than 70,000 pounds hi 1991. Furthermore, Baxter's
1991 total releases of 33/50 chemicals worldwide were reduced by 84%, a reduction of over one
million pounds since 1988. Worldwide releases for 1992 are currently being compiled, and we
expect further reductions.
Significant progress has also been made in efforts to reduce other toxic air contaminants.
Ethylene oxide releases have been reduced by about 500,000 pounds since 1988 by instituting
a combination of source reduction and emissions control projects. Chlorofluorocarbon (CFC)
air emissions have been reduced by 75%, or almost 2.5 million pounds since 1988 largely due
to source reduction initiatives. Baxter's air toxic reduction achievements resulted from important
institutional programs, as well as team-oriented implementation of pollution prevention and
recycling projects as described below.
33/50 Program Implementation
• 1988 1,1,1-trichloroethane air releases of over 800,000 pounds at Baxter's Bentley
Laboratories Division in Irvine, California were reduced by over 80% in 1990 by making
modifications to process leach tanks and instituting operational changes. Cost savings
exceeded $400,000, with minimal capital requirements. These releases were reduced to
zero in 1991 by changing to a new proprietary technology to manufacture the product
without using 1,1,1-trichloroethane or any CAAA listed air toxic.
• All releases of 1,1,1-trichloroethane were eliminated at Baxter's V. Mueller Division
facility in St. Louis, Missouri by installing an aqueous-based cleaning system. This
source reduction project eliminated almost 8,000 pounds/year of releases.
• Methylene chloride emissions at Baxter's Euromedical facility hi Malaysia were reduced
by two-thirds, almost 200,000 pounds, by making material handling changes and
equipment modifications to reduce evaporative losses.
• Methyl ethyl ketone (MEK) air emissions at Baxter's Mexicali facility in Mexico (a
"maquiladora") were reduced by modifying tanks to minimize evaporative losses.
Emissions of 39,000 pounds in 1988 were reduced by over 40% through these source
reduction efforts.
• MEK releases at our facility hi Mannford, Oklahoma were reduced by 60% by enclosing
a process to reduce fugitive losses. Almost 7,000 pounds/year of MEK releases are
averted by this project
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At another Baxter facility in Mundelein, Illinois, MEK and toluene emissions in a coating
process have been substantially reduced by installing a state-of-the-art capture and control
system. The capture system meets EPA's requirements for 100% capture, while the
catalytic afterburner destroys 99+ percent of the volatiles. Meanwhile, efforts to find
suitable water-based alternative coatings continue.
Several Baxter facilities have made considerable progress in minimizing ethylene oxide
(EO) emissions used in product sterilization. Many product lines previously sterilized
with EO have been converted to a radiation sterilization process. Also, sterilization
cycles have been modified to minimize fugitive emissions. Finally, packaging
modifications have been made to allow more product to be sterilized per cycle, thus using
EO more efficiently.
All but one Baxter facility sterilizing products with EO have converted from an EO/CFC-
12 sterilization mixture to 100% EO or an EO/nitrogen mixture. This reduced CFC-12
emissions by over 1.5 million pounds annually worldwide and, at current CFC prices,
the savings exceed $4.5 million per year. The one facility still using the EO/CFC-12
mixture captures and recycles both chemicals.
Facilities across the U.S. and Puerto Rico have switched to a "clean" parts injection
molding process, thus eliminating the need for degreasing these parts with CFC-113.
The reduction of CFC-113 emissions is on the order of several hundred thousand pounds
per year, with corresponding savings approaching a million dollars.
In addition, parts degreasing with CFC-113 has been replaced with aqueous wash systems
at several locations. Our V. Mueller facility in Niles, Illinois has completely eliminated
CFCs in cleaning stainless steel instruments by using a new aqueous system. In Costa
Rica, several CFC degreasing machines were eliminated by cleaning parts with water and
a biodegradable detergent. At a Renal Division facility in Largo, Florida, an aqueous
detergent system is to used to remove fluxes from printed circuit boards, replacing
CFCs.
Baxter's Renal Division facility in Mountain Home, Arkansas, has had an aggressive
program to reduce CFC emissions for several years. Efforts include detailed CFC usage
accounting by department, plant-wide awareness via monthly meetings and a waste
minimization committee, enhancing fugitive emissions capture in an existing carbon
adsorber recycling system, clean molding of parts, and various process changes. As a
result, CFC-113 emissions have been reduced by over 350,000 pounds annually. Based
on current CFC-113 prices, annual cost savings exceed $1,000,000 as a result of these
efforts.
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Institutional Pollution Prevention Initiatives
Baxter has found that communication and awareness are key to implementing successful
pollution prevention and waste minimization programs. Total quality management (TQM)
principles are also successfully integrated into our environmental programs. Several vehicles
to foster communication are used to support facility programs. Examples are presented below.
• Waste minimization abstracts summarizing various projects are collected and catalogued.
The abstracts not only cover projects to reduce 33/50 chemicals, other toxics, and CFCs,
but solid waste reduction efforts as well. The abstracts are made available to Baxter
personnel worldwide to communicate ideas and foster technology exchange.
• Waste minimization efforts are often highlighted in Baxter's quarterly environmental
publication, the Baxter Environmental Journal. Also, waste minimization efforts have
been publicized throughout the organization by two recent articles that have appeared in
PACE, a bimonthly magazine for all 60,000 Baxter employees.
• Quarterly regional meetings for Baxter's facility environmental managers are held.
Agendas often include presentations on waste minimization.
• Training sessions for facility and division upper management is conducted periodically,
with special attention given to the importance of waste minimization programs.
• Baxter's annual environmental conference has focused on waste minimization the last few
years. Last year's sixteenth annual environmental conference was attended by over 170
facility environmental managers and others from across the U.S., Puerto Rico, and
Canada. The 1992 conference included a dedicated symposium on reducing CFC usage.
International environmental conferences held last year in Brussels (for European
facilities) and in Miami (for facilities in Central and South America), as well as in
Singapore (for Pacific Rim facilities) just this past February will increase awareness
worldwide.
In summary, Baxter's involvement with the 33/50 program has been a success. We
encourage similar cooperative, voluntary efforts with the EPA. We find the flexibility offered
in such programs to be beneficial to us and, as we have shown, of great benefit to the
environment as well. Our TRI releases reported have dropped dramatically. This is due in part
to our 33/50 program involvement as well as other internal commitments. In all, since 1988
Baxter has expended $9 million to reduce worldwide toxic and CFC emissions by 14 million
pounds annually. Many of the projects, particularly source reduction projects, save Baxter
hundreds of thousands of dollars per year in operating costs.
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Tom Barnett, Inland Steel
Inland Steel Company, located in East Chicago, Indiana, is situated on 2,400 acres and
employs approximately 15,000 people. The plant, which started production at the turn of the
century, has 27 distinct operating facilities at the East Chicago Indiana Harbor Works (IHW)
plant. Operations include coke-making, iron making, steelmaking, hot rolling mills, cold rolling
mills, and numerous support facilities.
Inland signed on at the inception of the 33/50 program. Of the 17 targeted chemicals,
eight are found at the IHW: Benzene, Chromium, Cyanide, Lead, Nickel, Tetrachloroethylene,
Toluene, and Xylene.
Benzene, Toluene and Xylene releases are mainly the result of air releases at the coke
batteries. Due to the imposition of the benzene NESHAP, benzene releases have been reduced
from 1,250,000 pounds in 1988 to 186,000 pounds in 1991.
Tetrachloroethylene has been reduced from over 400,000 pounds in 1988 to fewer than
200,000 pounds in 1991 as a result of work practice changes, less reliance on vapor degreasing
of parts, and the elimination of unneeded uses of this solvent.
Metal releases have also been reduced by over 50% since 1988, mostly due to lessened
landfilling of slags. Overall, the eight chemicals found at the IHW have been reduced on
average by over 50%.
Efforts at the IHW at emissions reductions are now being focused on pollution
prevention. For example, as part of an agreement with EPA Region V on a supplemental
environmental project, Inland is eliminating the use of tetrachloroethylene vapor degreasers at
the Electric Repair Shop and replacing them with power washers that use a simple detergent
solution.
Plantwide, we are focusing on other materials such as ethylene glycol and mineral spirits.
All ethylene glycol used in mobile equipment in the plant is now recycled, and we are replacing
mineral spirits with natural biodegradable solvents.
The TRI Toxics Annual Report and the 33/50 Program have enabled us to focus and
identify the pollution problems present in the plant. Inland has now initiated a plantwide
pollution prevention program. Each operating facility within the plant is being evaluated in an
effort to prevent releases before they are created and to minimize them once they are. We
expect to reap great benefits hi terms of toxics reductions from this effort in the following years.
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SESSION 15
Risk Screening
Introduction
The Risk Screening session presented three examples of
using the TRI data to explore the extent of potential risks and
methods for setting relative priorities. Risk screening is a frequent
and expanding use of TRI data. It is used to support many types
of risk-based decisions and to establish priorities for follow-up
investigations. In particular, it is being used to target facilities,
chemicals, industries, or geographic areas for voluntary reduction
efforts, enforcement, or regulation.
Risk screening techniques range from simple to
sophisticated, but generally do not constitute "risk assessment"
because of data gaps and uncertainties in the TRI data. Risk
screening is a qualitative process that may be based on limited data
or data estimates; it expresses risk in relative terms, e.g., high,
medium, low. Risk assessment is quantitative and is more precise;
it estimates risk factors in amounts, concentrations or probabilities,
e.g., number of people exposed above a threshold or number of
predicted additional cancer cases. An emerging type of risk
screening that lies in between these extremes is "semi-quantitative"
risk screening. This approach uses techniques such as scoring
systems to generate risk-based numbers that are used in relative
ways, such as in ranks or ratios. All of these approaches include
a major role for data evaluation and judgement, especially in
characterizing uncertainties and understanding the limits of
applicability.
Risk evaluations and characterizations need to consider
several major components. Broadly characterized, these are
hazard identification and dose-response, fate, exposure and dose
potential, and the number and characteristics of potential receptors.
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Hazard identification examines inherent toxicities of
chemicals at various dosage levels. For some effects, low doses
may be tolerated without any impact. Other effects are thought to
have no threshold for the effect (i.e., some impact (however small)
is thought to occur at any dose). The dose-response function
describes how the effect may vary with levels of exposure.
Exposure/dose characterization involves assessing the
concentration to which one or more organisms may come in
contact (exposure), and which is ingested or absorbed in the
organism (dose). The characterization of receptors may include
estimating the number, nature, and physical or behavioral
characteristics of organisms exposed to the substance, e.g.,
humans, other animals, and plants. All of these evaluation steps
have significant uncertainties that should be considered in any risk
screening effort.
Some risk screening systems incorporate a few of these
elements; others incorporate most or all of these elements. There
are four general classes of risk screening approaches: simple
combinations of releases/transfers; weighted combinations;
approaches based on toxicity and exposure evaluation; and those
that feature some aspect of these plus receptor evaluation. The
selection of a particular approach to use depends on the type of
decision being supported, the degree of acceptable uncertainty, the
ease of application and communication of results, and available
time and resources. In all cases, it is important to consider
implied assumptions, such as assumed default values for hazard,
exposure, and receptor impact.
Simple combinations of TRI emissions data are by far the
most frequently used approach, and generally involve summing
releases or releases and transfers by facility, geographic area,
industry sector, or chemical. When used for relative ranking, this
approach includes some implied risk screening assumptions, e.g.,
equal hazard potential for all chemicals, equal exposure potential
for each medium, and no significant site features affecting
exposure.
Weighted combinations usually feature weights based on
toxicity potential. These weights may be based on a toxicity
ranking, such as qualitative (high-medium-low) or quantitative
(e.g., 6 on a scale of 1-10). Weights may also be based on
toxicity values, such as a cancer potency slope factor, acceptable
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dose level, or regulatory exposure limits (such as reportable
quantities (RQ), or OSHA permissible exposure limits (PEL).
Approaches incorporating exposure and/or receptor
evaluation are mostly still being developed, since they often
require significant commitment of expertise. Some incorporate
one or more aspects of chemical fate, environmental dispersion,
and receptor size and characterization.
There are many examples in EPA and in states. EPA
Headquarters examples include:
• the TRI Risk Screening Guide (which is not computerized)
• the proposed TRI Environmental Indicator
• the ORD/OE enforcement targeting system
EPA Regional approaches have been or are being developed
in at least Regions ffl, IV, VI, and Vn. Dr. Deborah Forman on
this panel described Region DI's approach and initial results. This
project has initially focused on a toxicity weighted approach, with
extensions planned for chemical fate and exposure potential, and
receptor characterization.
Another avenue of approach is represented by the ORD
environmental equity study described in this panel by Dr. Susan
Perlin. This approach focuses on developing methods for
assessing population characteristics and potential exposure based
on proximity to one or more sites.
There are many examples of systems developed by states.
Other sessions at this conference included presentations by New
York and Oregon, and a poster presentation by Wisconsin, as well
as other risk screening applications. This panel discussion includes
an overview of New Jersey's development of a geographic
information system (GlS)-based emission, toxicity and receptor
size ranking system, with extensions planned to better address
potential exposure elements.
Specific Issues Addressed
Much of the discussion focused on the variety of
approaches used in developing toxicity ranks. Developing such
ranking schemes requires investment and increased sharing of the
existing approaches would be very helpful. More interaction on
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what issues were considered in the development and how
problems, ambiguities, and data gaps were addressed would also
help developers and others create and effectively apply these
techniques.
An underlying theme of the discussion was communication:
of results, of techniques, of assumptions, and of uncertainties.
Questioners and panelists often focused on the need to share
information, and described particular audiences (e.g., health care
professionals, the public) and tools (PC-based viewing systems)
that could foster broader understanding of risk screening utility as
well as limitations.
Where Do We Go From Here?
The panelists gave the following advice regarding "Where
do we go from here?":
• EPA should provide separate release information for the
volume of chemicals released in routine operation and the
volume released accidentally.
• EPA should provide more interpretive information about
the data regarding the relative risks. The risks should be
reported at two levels: 1) community exposure from all
area facility releases, and 2) worker exposure risk for each
facility. Risk information is most useful when there is
some benchmark for determining the relative risks of the
chemicals, which participants hope EPA will provide.
• EPA should foster "Local Community Risk Reduction
Committees" to complement Local Emergency Planning
Commissions.
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SESSION 15
Panelist Presentations
Dr. Debra L. Forman, U.S. EPA, Region III
Region m Toxicity Index Prototype for Targeting TRI Chemical Releases
Scope and Objectives
This report presents a prototype indexing system that ranks chemical releases from
stationary sources (TRI) in terms of their relative toxicity. The project is intended to utilize the
TRI database for the general purposes of programmatic strategic planning and enforcement in
the Regional Air Toxics program.
The scope of this project is limited to a single TRI reporting year (RY) and focused
geographic area due to the one-year time frame allocated for the demonstration project. The
TRI release data for RY1990 was chosen, since the mainframe TRI database for 1990 was
complete at the start of the project, and to provide a best estimate of current conditions. The
State of Maryland was chosen as the focused geographic area because additional information
from this area will coincide with other initiatives ongoing in Region m.
Preliminary Methods
In order to estimate the relative toxicity of the TRI chemicals released in Region m, a
consistent criterion for comparison is required. The IRIS database was selected as the baseline
for toxicity comparison for several reasons. First, the database contains both oral Reference
Dose (RfD) and Cancer Potency (CPF) toxicity factors. The IRIS database also provides
quantitative estimates of toxicity; these values are derived using consistent, established
procedures. Second, the RfD and CRAVE approval processes are endorsed by the EPA and are
nationally recognized as a source of relative toxicity data.
For each TRI release category, the IRIS database provides oral toxicity factors for §313
chemicals ranging from 21 % to 85% for each release medium in Maryland for RY1990. The
present analysis highlights the air point and air nonpoint source emissions that account for
approximately 55% of the total TRI mass released hi Maryland for RY1990.
For these TRI release categories, approximately 80 % of the air point emissions and 42 %
of the air nonpoint source emissions possess oral toxicity factors. Those compounds that do not
possess oral toxicity factors are termed "Residual Releases" and are expressed only in terms of
the mass released. Subsequent development will include the consideration of acute toxicologic
effects of TRI chemicals and will serve to improve the percentage of TRI releases measured by
the prototype indexing system. Moreover, it is understood that the RfD and CRAVE
workgroups approve new chemicals monthly; these will be included in the analysis.
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The Indices — RJD, CPF, and Composite
Data handling and analysis will be accomplished using LOTUS spreadsheets that are
currently under development. Mathematically, each TRI release datum is divided by the
corresponding IRIS-approved oral RfD value to obtain an index value for noncarcinogenic
toxicity of the TRI release. This value is termed the Single Component Toxicity ^^ Index;
resultant indices are ranked from lowest to highest in order to obtain target chemicals. As stated
above, those chemicals that do not possess IRIS oral RfDs are included as "Residual Releases"
and are ranked according to the mass released for each TRI category.
A similar analysis is performed to account for the carcinogenic effects of §313 chemicals.
The TRI release data are multiplied both by the corresponding IRIS-approved oral CPF value
and by a weighted value to account for the carcinogenic weight of evidence (WOE). The WOE
classifications of A, Bl, B2, and C are represented by the values 1.00, 0.85, 0.60 and 0.30,
respectively. Class D carcinogens generally do not possess cancer potency factors and are
assigned a value of 0. The resultant value is termed the Single Component Toxicity (CPF) Index
and the indices are ranked to obtain target chemicals.
A composite index of chronic toxicity is derived by scaling the results obtained by each
of the Single Component Indices. Each index is expressed as a percent of the sum of its
respective Single Component Indices. The resultant percent values for each TRI datum are
summed and the final value is termed the Chronic Toxicity (composite) Index (Chronic Index).
The Chronic Indices are ranked and target chemicals are identified that simultaneously account
for both carcinogenic and noncarcinogenic toxicity. It is important to note that the results of the
individual Single Component Indices can also be ranked to identify target chemicals for specific
endpoints of concern.
Facility Targeting: LOTUS spreadsheets that utilize the Chronic Index to identify specific
facilities are also under development. The results will include a ranked list of facilities
responsible for the highest toxic releases indicated by the Chronic Indices. For the purposes of
illustration, the facilities emitting the top 5 chemicals identified by the ranked Chronic Indices
are presented. The totals for each Maryland county are also summed, ranked, and those
facilities responsible for the largest contribution to each country's emissions are identified.
These facilities can also be characterized by related data including SIC codes and descriptions,
parent company names, and participation in the 33/50 program.
Risk Assessment: Upon identification of specific facilities, risk assessment methodology
for human health is recommended to evaluate specific exposure scenarios, including fate and
transport modelling of targeted chemicals. The epidemiologic literature should also be consulted
to support evaluations concerning possible cause and effect relationships. This aspect provides
additional support during the assessment of perceived vs. actual adverse health impacts of TRI
emissions. In addition, ecological considerations are included in the overall assessment of the
predicted impact of the TRI release.
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Susan Perlin, U.S. EPA
Introduction
The terms "environmental equity," "environmental justice," and "environmental racism"
have been used in conjunction with the ongoing debate about unequal distribution of
environmental health risks across different segments of society. Most of the current focus is on
disproportionate exposures to hazardous pollutants potentially experienced by disadvantaged
minority groups, especially African Americans, Native Americans, and Hispanics. Data from
several ecologic (descriptive) studies have shown consistent, systematic differences in residential
proximity to potential toxic emission sources based on ethnicity/race and, to a lesser extent,
socioeconomic status (SES). It is well established, for example, that certain minorities are more
likely than their affluent white counterparts to live near waste sites and industrial plants, and to
live in areas that violate one or more of the National Ambient Air Quality Standards (NAAQS).
The extent to which these conditions cause environmental exposure differentials, let alone
increase environmental health risks, is unknown.
In 1990 EPA established the Environmental Equity Workgroup, which produced a
comprehensive report to the Administrator in 1992 that reviewed the evidence and made
recommendations for Agency action. These recommendations included the need for research
and data collection to provide an objective basis for assessment of risks by race and income.
Because of the increasing importance of environmental equity, especially in the context
of risk-based priority setting, it is critical to understand the scientific basis for concern and be
cognizant of the implications for both research and policy decisions. The current work was
undertaken to review key studies, identify some of the important issues that must be taken into
account when evaluating potential inequities, and then use demographic data and industrial air
emissions data (from the Toxics Release Inventory, TRI) to illustrate a screening approach to
start examining potential differentials in residential proximity to airborne chemical releases by
ethnicity/race and household income. In contrast to TRI risk screening, which emphasizes
emissions and their toxicity, our approach emphasizes emissions and the demographics of
geographical areas associated with the emissions.
In the absence of appropriate exposure and health effects, the data needed to fully
evaluate environmental equity issues. We have used demographic (e.g., race and class) and TRI
air emissions data to develop an approach for generating testable hypotheses about the following
critical question: Is a non-white and/or low-income person more or less likely than a middle-
class white person to live near potential sources of pollution (or, more to the point, to experience
higher potential exposures to ambient air pollutants)? The approach we have developed is a
screening tool that allows us to integrate industrial emissions data with demographic data in
order to start examining potential differentials in residential proximity to airborne chemical
releases.
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Key Methodological Issues
1. An important methodological issue common to virtually all environmental equity studies
is the selection, use, and interpretation of appropriate exposure estimators. When
suitable exposure measurements or models are unavailable, indirect measures, such as
production volumes, emission inventories, or proximity to release points, often are used
to estimate exposures. Because these exposure surrogates are far removed from the real
point of contact between people and pollution, they necessarily incorporate a variety of
explicit and implicit assumptions about such things as meteorological dispersion of
pollutants and human time-activity patterns. The resulting human exposure estimates can
be highly uncertain, depending on the exposure surrogate.
2. When interpreting the significance of these studies, it is imperative to keep in mind that
residing near a pollutant source or in a county, zip code, etc. with an elevated level of
estimated pollutant emissions only suggests the possibility of potential elevated
exposures. In many instances, there may be no direct relationship between estimated
ambient releases and actual pollutant levels experienced by residents living nearby. The
only way to determine if actual exposures are elevated is through direct measurement of
personal exposure or dose.
3. Many of the TRI chemicals have insufficient data to develop dose-response curves for
humans for the health effects of concern. In the absence of appropriate dose-response
and human exposure information, we have treated all chemicals as if they have equivalent
toxicity.
Project Overview
The work was started January, 1992, and consists of two phases.
Phase I: National Analysis
Purpose: To perform screening studies of the relationship between race/class
characteristics of county populations and estimated air emissions from a subset
of U.S. manufacturing industries. The results of this screening study will help
identify needed follow-on studies.
Demographic data: 1990 county-level race/ethnicity data (for whites, blacks,
Native Americans, Asian and Pacific Islanders, Others and Hispanics) from the
Census, and household income data from the Donnelley Marketing Information
Services.
Emissions data: 1990 TRI total air emissions data for all chemicals and for the
17 high priority chemicals listed in EPA's 33/50 Program.
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Approach: A Population-Emission Index (PEI) was calculated for each
demographic group, for the nation as a whole, and for both urban and rural
counties for all EPA regions. The PEI is a population weighted average emission
for the county. To examine whether potential disparities in emissions exist, we
calculated Population-Emission Ratios (PERs) (i.e., the ratio of the PEI for any
demographic group to the PEI for a reference group, such as whites or
households with the median income for the nation). PER values much greater or
much less than 1.0 suggest the possibility of disparities in emissions and
inequitable potential exposures to TRI chemicals at the county level.
Status: Analysis of national data completed; paper written for publication and
currently in peer review. Analysis of regional data completed but not yet
evaluated; paper for publication should be ready by late spring or early summer
of 1993.
Overview of Findings from Phase I
1. Different demographic groups and TRI facilities are not uniformly distributed across the
country. Because of these geographical differences, the number of counties that may be
contributing to disparities in emission distributions may be very small (and primarily
urban), while the proportion of minority populations involved may be large.
2. Population-Emission Ratios (PERs) calculated on a national basis for total air emissions
of all TRI chemicals are as follows: blacks, 1.6; Native Americans, 0.7; Asian/Pacific
Islanders, 2.0; Other races, 2.6; and Hispanics, 2.2. This means, for example, that the
average black person in the U.S. lives in a county with roughly 60% more TRI air
releases than the county in which the average white person lives.
3. PERs for household income were calculated using the category $25-35,000 (which
contains the national median household income) as the reference group. The range of
PERs for the different income categories was very small, i.e., 0.9 for incomes less than
$7,000 to 1.2 for incomes over $75,000; actually increasing slightly with increasing
income.
4. Because of the geographic distribution of people and facilities, our calculation of single
race-specific PEIs or PERs for the whole country need to be interpreted with caution and
evaluated further. This heterogeneous distribution of populations and sites will impact
study results, more or less, depending on the level of data aggregation (e.g., Census
block or tract, county, zip code) used. Because there is much variation in the
demographics of populations both within and among counties, there is a need to verify
and further explore our findings by reevaluating the data on a much smaller geographic
scale. We currently are doing this by conducting Phase-Q site-specific studies in smaller
geographical areas having high densities of TRI facilities. The demographics of these
areas are being evaluated at the Census block group level. Given the availability of more
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detailed Census data at the block group level, we will be able to evaluate the possible
interaction of income and race/ethnicity.
Phase II: Site-Specific Analysis
Purpose: To develop a Geographic Information System (GlS)-based approach for
studying the relationship between race/class characteristics of populations
surrounding industrial sites and surrogate measures of exposure (e.g., proximity
to sites, emissions from site). GIS is used to integrate TRI and detailed
demographics data. Three sites have been selected as test areas. The approach
will be adaptable to other geographic areas and scales and to other types of
pollution sources.
Demographic data: 1990 Census data, by block group, for race/ethnicity (whites,
blacks, Native Americans, Asian and Pacific Islanders, Others and Hispanics),
household income by race/ethnicity, and poverty status by age and race/ethnicity.
Emissions data: 1990 TRI total air emissions data for all chemicals and for the
17 high priority chemicals listed in EPA's 33/50 Program.
Approach: For each facility, look at demographics within 0.5 mile-radius rings,
up to 2.0 miles, surrounding the facility. For each demographic group, evaluate
proximity to single and multiple facilities and association with total air emissions.
Assume potential exposures are proportional to total emissions.
Status: Development of approach completed and analysis of data from Site #1
almost completed. Data from Site #2 processed into GIS and ready for analysis.
Papers describing approach and results from Sites #1 and 2 should be ready for
publication by summer, 1993. Many of the GIS techniques we are developing are
being incorporated into EPA's Office of Information Resource Management
(OIRM) products that will be readily available.
Some Lessons Learned
1. Project is far more expensive and time consuming than we anticipated, particularly
considering that the approaches we have developed are only for screening purposes (i.e.,
to develop hypotheses and target areas that may warrant further examination for potential
environmental inequities).
2. When this project began, 1990 Census data were not available. EPA has now purchased
some of the data (PL94-171 and STF3A), some of which will be processed into GIS to
make it readily available.
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1993 TRI DATA USE CONFERENCE
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3. Purchasing data and processing them into GIS has required a large investment of time
and money. This includes costs to improve the accuracy of the TRI lat-long coordinates
for Phase n. Many of the project delays were due to time needed to obtain and process
data.
4. Very complicated and time-consuming to develop an approach that is appropriate for the
level of environmental data (i.e., source location, emissions data) and yet help to move
beyond just evaluating proximity to a single potential source.
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[MENTAL
. Unequal distribution of environmental
exposures and potential environmental health
risks across different segments of society
. Most studies show systematic differences in
residential proximity to potential pollutant
sources
. Unknown if this is associated with
exposure differential or increased
environmental health risks
. 1990 EPA established Environmental Equity
Workgroup
. 1992 Report to EPA Administrator
reviewed evidence and recommended
agency action
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IPOSE OF OFFICE OF HEALTH RESEA]
ENVIRONMENTAL EQUITY WORK
1) Response to EPA's Environmental Equity
Report recommendation -
research and data collection to provide
objective basis for assessment of risks by race
and income
2) Review key studies
3) Identify important issues in evaluation of
environmental equity
4) Develop screening tools to integrate
industrial emissions with demographic data in
order to start examining potential
differentials in residential proximity to
airborne chemical releases
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KEY METHODOLOGICAL ISSUES
. Selection, use and interpretation of exposure surrogates
to
Emission Sources
. Pollutant Type
. Amount Released
. Geographic
Location
Environmental
Concentrations
. Air
. Water
.Soil
. Food
Human
Exposure
. Route
. Magnitude
. Duration
. Frequency
Internal Dose
. Absorbed Dose
. Target Dose
. Biomarkers
Health Effect(s)
. Cancer
. Non-cancer
- Damage/Disease
- Signs/Symptoms
. Residing near a pollutant source or in county, zip code, etc. With elevated emissions only
suggests the possibility of potential elevated exposures
. Need direct measurement of personal exposure
Treatment of chemicals based on toxicity
-------
PROJECT OVERVIEW
PHASE I: National analysis
County-level screening studies
relationship between race/class and TRI
air emissions
. DATA:
1990 TRI air emissions
1990 Census for race/ethnicity
. Whites, blacks, Native Americans,
Asian and Pacific Islanders, Others
and Hispanics
1990 Donnelley Marketing Information
Services for household income
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PHASE I; National analysis, contim
APPROACH:
1) Calculate population-emission index (PEI)
by demographic group
. PEI is a population weighted average
emission
2) Calculate population-emission ratios (PER)
. Ratio of the PEI for any demographic
group to the PEI for a reference group
(e.g., whites)
. PER values » 1.0 or « 1.0 suggest
possibility of disparities in emissions and
inequitable potential exposures to TRI
chemicals at the county level
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PHASE I: National analysis, continued
PROJECT STATUS:
. Analysis of national data completed; paper in
peer review
. Analysis of regional data completed; not
evaluated. Paper ready by summer of '93
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PHASE I; NATIONAL ANALYSIS, continued
FINDINGS;
TRI AIR EMISSION DISTRIBUTIONS DIFFER BY
RACE/ETHNICITY
Native
Americans
Whites
Hispanic*
Blacks
Asians
Other
104
10'
6
10'
TOTAL EMISSIONS OF ALL TRI CHEMICALS (LB/YR)
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DEMOGRAPHIC GROUPS ARE NOT EVENLY DISTRIBUTED ACROSS THE U.S.
to
H-*
VO
SHADED AREAS: ,
COUNTIES WHERE RATIO OF BLACK:WHITE> NATIONAL RATIO
-------
TRI AIR RELEASES ARE NOT EVENLY DISTRIBUTED ACROSS THE U.S.
to
WHITE COUNTIES: EMISSIONS< NATIONAL MEDIAN •
GREY COUNTIES: EMISSIONS = MEDIAN - 90th PERCENTILE FOR NATION
BLACK COUNTIES: EMISSIONS>90th PERCENTILE FOR NATION
-------
KJ
-------
DISPARITIES IN TRI AIR EMISSIONS ARE RELATED TO URBANIZATION
Counties where the ratio of minority:white exceeds the national ratio; and
where total air releases of all TRI chemicals exceeds the national median for whites
Minority
Black
Native
American
A/P Islander
Other Races
Hispanic
Rural Cpunties
No. of
Counties
45
18
1
10
5
Population
in Counties
(xlOOO)a
571.1
37.9
0.6
40.2
56.8
% National
Minority
Population
2
2
0
0
0
Urban Counties0
No. of
Counties
92
35
34
34
32
Population
in Counties
(xlOOO)b
13,168.4
274.2
3,140.0
4,779.7
10,337.3
% National
Minority
Population
44
14
43
49
46
to
to
N>
a. Total population of specified minority within those counties
b. Percent of national population of specified minority who live in those counties
c. Counties are considered urban if they are within a Metropolitan Statistical Area (MSA)
-------
THE NATIONAL POPULATION-EMISSION RATIOS (PERs) SUGGEST THE
POSSIBILITY OF DISPARITIES IN EMISSIONS BASED PRIMARILY ON RACE
PERs BY RACE/ETHNICITY
3
PERs BY HOUSEHOLD INCOME
1.8
LESS TMAN «75OO • S7SOO TO 810OOO • tlOOOO • tIBOOO • tISOOO . tZSOOO
$23000 - $38000 D S3SOOO • SOOOO E3 f 10000 • tTBOOO D MOM THAN $79000
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NEXT STEPS
1) Complete Phase-I for regions by
urbanization
2) Phase-II: Site-specific Studies
a) Develop GIS-based approach for
studying relationship between race/class
of population surrounding TRI sites and
exposure surrogate
b) Three test areas
c) Demographics within 0.5 mi Radius
rings (.5 -2*2.0 mi) surrounding facilities
d) Evaluate proximity to single & multiple
facilities and association with total air
emissions
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1993 TRI DATA USE CONFERENCE
SESSION
Pat Cummens, New Jersey Department of Environmental Protection and Energy
Project Objectives
Within the New Jersey Department of Environmental Protection and Energy (NJDEPE)
the Governor created an Office of Pollution Prevention (OPP) in 1989. The mission of this
office is to implement measures to reduce the state's waste at its source. To achieve this goal,
NJDEPE has been conducting pollution prevention research utilizing the department's
Geographic Information System (GIS) in concert with EPA's Toxic Release Jjiventory (TRI)
database and information collected through New Jersey's Right to Know (RTK) program.
The overall objectives of this study are to 1) use chemical inventory databases with a GIS
to identify facilities, processes, and geographic areas where pollution prevention measures are
likely to be most effective; 2) prioritize facilities for actions to reduce total emissions to the
environment; 3) develop and document a cost-effective, computerized method that can be used
by other states to identify such facilities and processes.
Several key steps in the project are outlined here and will be addressed in the
presentation. In addition to the discussion of items, such as locating facilities, establishment of
chemical groups, and development of a ranking scheme, on-line demonstration of this system
will be available at this conference.
/. Facility locations
Quality locational information was critical to this project, making it important to track
the origin and accuracy of each facility location. To enhance the coordinate information found
in the TRI database, a series of steps were taken to acquire the best available locational
information possible, short of manually mapping each individual facility. The methods used
included: retrieval of coordinates from other NJDEPE databases (i.e., hazardous waste status
file, APEDS, industrial survey), address matching, and municipal centroids. The origin of each
facility's locational information has been carefully tracked in the data file, allowing for a
targeted effort in the future using Global Positioning System (GPS) technology for updating the
least accurate first.
Similar mapping techniques were applied to generate locations for publicly owned
treatment facilities (POTW) and off-site land disposal sites. To analyze the impacts of combined
releases from multiple facilities, it was necessary to include locations of these waste receivers.
2. Creation of chemical groups
It was not feasible to look at all releases of TRI chemicals at once due to the density of
release points in New Jersey (over 860). On the other hand, releases of individual chemicals
were not dense enough to discern any pattern of impact. Since many chemicals exhibit similar
effects on the environment or on populations near the release points, and this project's purpose
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1993 TR1 DATA USE CONFERENCE
was to study the cumulative impact of several releases, the TRI chemicals were assigned to
special groups. These chemical groups were based on health and environmental effects (e.g.,
carcinogenicity, reproductive toxicity, developmental toxicity, aquatic toxicity), statutory
definitions (e.g., OSHA Permissible Exposure Levels, ACGIH Threshold Limit Values), and
environmental persistence and bioaccumluation. These chemical groups were defined based on
a series of available references, mainly from EPA and ICF. The chemicals assigned to each
group and appropriate references are documented in the project reports.
3. Comprehensive view using grid cells
Since a primary goal of the project was to get away from looking at facilities individually
and take a comprehensive look at geographic areas, a new approach was needed. Using the GIS
and EPA guidelines, generalized release zones were defined. A grid of 2 mile by 2 mile cells
approximating the recommended 1 mile radius zone for air and land releases was superimposed
over the map of releases for all of the chemical groups. Using this technique, all releases within
the same grid cell could be aggregated. In this way both the density of releases and an
approximate areal extent could be represented.
Minor watershed boundaries, already mapped in the NJDEPE GIS, were used to
approximate the areal extent of water releases. The average size of each watershed was 2.5
square miles. The minor watersheds were used because they represented a homogeneous and
relatively small area of potential impact. Using a method similar to the grid cell overlay, the
minor watersheds were used to aggregate and map the water releases.
For the purpose of mapping and analysis, off-site transfers were treated as releases and
summarized in the grids or watersheds that received the transfer.
4. Priority setting/risk ranking
Having mapped the facilities and defined the general release patterns, much time was
spent considering methods for comparing facilities. A method was devised for prioritizing
geographic areas or groups of facilities and for targeting pollution prevention efforts. This
prioritization scheme incorporated both volumes of chemical releases, toxicity score of each
chemical, and occurrence of environmentally sensitive areas in close proximity to the release
points.
To better address the comparison of releases from one group to another and begin to
identify priority areas, releases were mapped by grid cell according to quartile. That is, all grid
cells that contributed to the top 25% of the total releases were highlighted most intensely,
followed by the next 25 % at a lower shading intensity, and finally the bottom 50% were grouped
together for display. While the cutoffs for each quartile were different for each chemical group,
they represented a normalized view of the releases and allowed a comparison of maps from one
group to another, providing a way to identify the grid cells that posed the greatest potential risk.
Using this quartile approach, maps were ultimately generated comparing results based on:
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1993 TRI DATA USE CONFERENCE
SESSION
amount of release by itself (map 1), releases by chemical group (map 2), toxicity of chemical
(map 3) and a combination of amount and toxicity of release (map 4).
To incorporate the idea of individual chemicals having multiple effects into a ranking
scheme, the combined effect of toxicity had to be considered. For example, it could be argued
that chemicals that were carcinogens and reproductive toxins were more hazardous than
chemicals that were only one or the other. Several attempts have been made to define toxicity
numerically; however, no consensus has been reached for a ranking scheme that includes all the
TRI chemicals. For the purposes of this project, a numerical ranking scheme was developed for
each chemical within the defined chemical groups. Total toxicity for each chemical was defined
as the sum of each score assigned in the various chemical groups. Releases of the resulting high
ranking chemicals could then be aggregated by grid cell and mapped showing the areas of most
toxic chemicals.
This approach was helpful but considered only toxicity, not volume of release. To
simultaneously consider toxicity and amount of release, the two numbers were simply multiplied
together resulting in a combined score. An interesting observation was that this ranking scheme
produced results very similar to EPA's 33/50 program. This scheme also addresses the issue
of balance between toxicity versus volume of release, i.e., which is worse, a small amount of
highly toxic chemical or a large amount of a lesser toxic chemical?
Using the GIS, boxes were drawn around areas with high concentrations of release (i.e.,
those where a high volume of chemicals were released into multiple media and from many
different facilities). The total amount of releases to each medium were summed for each target
area to estimate a priority among them.
Volumes and toxicity of releases formed only half of the criteria for selecting areas for
further study. The other half was dictated by environmental factors that were particularly
sensitive to releases of chemicals in the various groups. A matrix was developed to record how
many of the sensitive environmental factors were present in each of the ten priority zones. By
totaling the factors present and combining this information with the volumes of and numbers of
releases in each chemical group, a score was assigned to each box.
5. Dispersion modeling
To test the utility of this quick but somewhat generalized approach to prioritizing areas
subjected to chemical emissions, one of the priority areas had to be studied in more detail. The
purpose was to use a dispersion model to approximate the zone of impact for each facility
release and compare those zones to the ones generated more quickly using the GIS method
outlined above. This comparison would provide insights as to whether the added cost, in time
and resources, to run the dispersion models resulted in a significantly better product.
The Industrial Source Complex Long-Term (ISCLT) model has been selected for
estimating concentration gradients. This selection was based on reviewing numerous models and
evaluating the anticipated outputs and input requirements. The selection of the model needed
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1993 TRI DATA USE CONFERENCE
to balance the available data with the goals of the model. In addition to reviewing model
documentation, input was solicited from professionals experienced in spatial modeling. The
execution of this model has been marred with technical difficulties and is still in progress.
When completed, the dispersion zones will be compared to the areas defined by the simplified
GIS method and incorporated into the user interface discussed below.
6. Throughput analysis
A throughput analysis of facilities in two of the priority areas was conducted. Release
data recorded hi the TRI database were compared with chemical use data reported in the NJRTK
database to obtain a measure of throughput efficiency for each chemical used within the target
area. Those facilities whose chemical processes indicated that most of the chemicals used were
also released, for example, could point to potential targets for waste reduction measures.
To perform the throughput analysis, five steps were taken. These steps involved data
corrections to allow the necessary correlations and an analysis of pollution prevention
alternatives.
7. Designing a user interface to the TRI data and modeling results
One of the reasons for placing the TRI data on DEPE's GIS was to make this useful
database available to the Department as a whole. The project participants believed that a user
interface would make access to the data easier, especially to people who are not regular GIS
users.
ARC/INFO's new PC package ArcView provided an ideal vehicle for viewing the data
and the results of this project. Arc View's query and data organization capabilities would let
users easily access and manipulate the TRI data and examine them in light of both other facilities
regulated by the Department, and environmental factors that might be particularly sensitive to
TRI emissions.
228
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1989 TOTAL AIR RELEASES BY GRID CELL
485
HP Releases contr .but i r~>g to
top 25X of toto1
Releases contr : but ; ng
^ 2S-S0X of total
|i|jl Releases contributing to
-^ bottom 50'/, of total
Total Ai-~ Releases =
30,918.669 ibs
Meon per 9- id cell = 113,255 Ibs
Gr i d ce I ' s u i tK re' eases greate>-
than mean are o«jt I ined
Median per grid cell = 28,336 lb«
Ouart.le Cutoffs
Top 25X > 900,000
Top 50*X > 390,000
229
Fi
i gure
-------
1989 AIR RELEASES
AND
ur ^PRODUCTIVE TOXINS,
DEVELOPMENTAL TOXINS,
HERITABLE GENETIC
TOXINS
Fjg&j Releases contributing to
top 25X of total
jjjjjjl Re I eases cohtr i but i ng
25—50X of total
l|| 11 Releases contributing to
i-L> bottom 50X of total
Total Air Releases -
17,257,954 Ibs.
Mean per grid cell =73,438 Ibs
Gr i a' ce I I s w i th re I eases greater
tKan mean are out Iined
Median per grid cell = 19.660 >bs
Quartile Cutoffs
Top 2SX > 700,000 Ibs.
Top 50X > 299,000 Ibs.
230
F i gur e 2
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989 AIR R
OST
OXIC CHEMICALS
USING EMSL CRITERIA
231
Releases contr ibut irig to
top 25'A of total
Re I eases contr i buting
25-50X of total
Releases contributing to
bottom 50X of total
Total Air Releases^, 507,879 Ibs
Mean per g- id eel I = 33,146 Ibs
Gr i d ceI Is w i th re I eases greater
than mean are out I ined.
Media-, per grid eel I = 7178 Ibs
Toxicity is calculated by total
score in careinogen•city, repro-
ductive toxici ty, and neurotoxi-
ci ty only.
Qiemicols included ore those scoring S0X or more
of the total posaib'e maxi nun scare. These are-
vinyl chloride, ethylene ox.de, propylene o*ide.
maVcel, benzene, arsenic, ni trogan mustard,
I 2-dibromoethane, cadmium, ocryloniIri'e. lead,
tr ichloroethylene. tetraahloroethy lene, 1 3-buta-
diene, PC8c, deCZ-vthylhexyOphthalate, ' 2-d>-
chioroethane. chloroprene. ethylene thioureo.
mercury, carbon disulfide, methyl ethyl kotone.
cHloroform. thiourea. end moneb.
Quartile Cutoffs
Top 25X > 200,000 Ibs
TOP 50X > 110,000 Ibs.
-------
i989 AIR RELEASES
WITH HIGHEST SCORE
tr i bu 11 ng to
top 25% of total
Releases contributing
25-50X of total
Releases contributing to
bottom 50X of total
Sum of Scores = 94,706,400
Meon score/or id eel I = 346,909
Grid ce\\s above mean are
out Iined.
Toxicity is calculated by total
score in ccrcenogenici ty, recra
ductive toxicity, acute toxicn
chronic toxicity, neurotox.ci ty
and OSHA-defined toxicity.
Quarti le Cutoffs
Top 25X > 2,500,000
Top 50Ji > 1.220,000
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1993 TRI DATA USE CONFERENCE
SESSION
SESSION 16
Local Use
of TRI Data
Introduction
One of the main purposes of gathering TRI data is to make
them available to the public. EPA was mandated by Congress to
prepare the data in an electronic format accessible to the public.
This was done in the TOXNET system available through the
National Library of Medicine. TRI data are also available on
diskette, CD ROM, and through state agencies.
However, it is one thing to make the information available,
but quite another to actually use it. Who uses it? Who is the
"public"? How is it used? How useful is it? What are the
problems and difficulties in accessing and using it? What potential
does it still hold?
This session addresses these questions by hearing from
people who used the data. Individuals and groups located in
communities affected by chemical releases are in the unique
position of telling EPA what their experiences were in using the
data. They are also the ones who can recommend modifications
to the system that will improve its usefulness.
Specific Issues Addressed
There was a general feeling that EPA needs to provide
more context for the data, especially at the local level. One
suggestion for achieving this goal was for EPA to provide
comparisons of similar industries across states and counties. A
number of participants suggested that the EPA should provide
information regarding the relative risk of the chemicals in the
inventory.
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SliSSION 16
1993 TR1 DATA USE CONFERENCE
Some of the panelists felt that local groups would benefit
greatly from access to technical support for accessing and
analyzing the data. Participants stated that ease of access is a
major factor in whether community groups and individuals will use
the data.
Participants spent some time discussing the perceived
conflict in objectives between unions and local public interest
groups. It was noted that in Louisiana and Ohio, many of the
chemical workers do not trust their local environmental groups
because environmental activity could threaten union jobs.
However, this tension will always occur.
Participants also addressed use of the data for worker
protection. One example was a case in Northfield, MN. The
local unions realized that simply controlling pollution would not
reduce the health hazards faced by workers, although the controls
would reduce emissions to the local environment. The unions
were responsible for changing the focus of their companies from
pollution control to source reduction.
Where Do We Go From Here?
The information exchanged and the questions and
suggestions discussed will be reviewed by EPA. Specific
workgroups within EPA charged with examining modifications to
TRI will receive the suggestions and concerns generated in the
session.
Participants will be able to build a network of data users
with similar concerns. They will be able to determine if any of
the suggestions for improved data usefulness are implemented in
the coming year. Hopefully, we will all gain greater insight into
the successes and failures of TRI data in addressing environmental
concerns in communities.
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1993 TRI DATA USE CONFERENCE
SESSION
Panelist Presentations
Paul Templet, Louisiana State University
The author would like to acknowledge the help ofR-T-K Net for gathering the data used in the
case study.
Abstract
An emissions-to-job ratio is calculated from EPA's Toxic Release Inventory and Census
Bureau data and used to evaluate pollution control programs in facilities, industries, and states.
The ratio allows direct comparisons between facilities and industries of different types and sizes
and states with different mixes of industry. Information on the U.S. and Louisiana's emission-
to-jobs ratio is presented at national, industry, media, and state levels. A comparison between
U.S. averages and Louisiana ratios is carried out to two-, three-, and four-digit SIC categories.
Large variances across states and industry types may involve structural differences in the
industry, degree of externalized costs and environmental policies. The ratio indicates areas for
improvement and can be a useful tool in evaluating pollution control programs and policies at
local, state, and national levels.
Introduction
Techniques for evaluating a state's progress in pollution control were given a boost with
the publication of the first Toxics Release Inventory (TRI) (U.S. EPA) in 1989. The TRI
contains reports on 328 toxic chemicals discharged into the air, land, and water, as required by
Section 313 of the Emergency Planning and Community Right to Know Act of 1986 (Title m
of the Superfund Amendments). For the first time, meaningful comparisons can be made of the
levels of discharges among states, industry types, facilities, and environmental media. The data
provides impetus for states high on the list to implement programs and policies to lower
emissions, and it gives citizens facts to use in demanding accountability of their pollution control
agencies. However, measuring gross emissions by facility, industry, county, region, or state
says more about the type of industry, mix of industries, and level of industrialization within a
county or state than it does about the effectiveness of a state's pollution control programs and
policies. Therefore, a method of discriminating among pollution control strategies and policies
is needed.
The purpose of this paper is to present the TRI emissions-to-jobs ratio (E/J) for 1990 as
a means of normalizing the TRI data (US EPA, 1992) so that comparisons can be made among
facilities, industries, and states by pollution control managers, environmental professionals, the
regulated community, and the public. Currently, there are no other objective standards available
235
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SESSION
1993 TRI DATA USE CONFERENCE
for evaluating policies and programs. The author1 used an E/J ratio in an "Environmental
Scorecard" developed and implemented in Louisiana to condition a facility's tax exemptions
(Templet et al., 1991) because it focused attention on two things the state was trying to achieve:
fewer emissions and more jobs. An added incentive for using the E/J ratio is that a regression
analysis conducted across the 50 states shows that E/J decreases are significantly associated with
increases in the environmental and economic quality of the state and with a decrease in energy
use (Templet and Farber, 1993).
A National Perspective
The E/J ratio varies across the 50 states (Fig 1) and by industry Standard Industrial Code
(SIC) when averaged for US industry (Fig 2). Employment data were taken from Census
Bureau publications (Bureau of the Census, 1991, 1992). A state's ratio is determined by its
mix and extent of various types of industry. For that reason, it is instructive to examine the
Chemical Industry (SIC 28) alone, since it contributes 44% of US TRI emissions. Figure 3
shows those states with a high proportion of chemical industry emissions and/or employment
greater than 12,000 jobs. As the graph indicates, there is wide variation in the chemical
industry E/J ratio, which ranges from several hundred Ibs/job in New Jersey, California, and
Pennsylvania to greater than 14,000 Ibs/job in Louisiana. Some of this variation can be
explained by structural differences in the chemical industry across these states due to automation,
bulk chemical production, nearness to raw materials (oil and gas), etc., but it is unlikely that the
structural differences alone explain a more than 50-fold difference in the ratio. For example,
of the five states with E/J ratios above the U.S. average, all are in the southern U.S. where
environmental policies have traditionally been weak (Hall & Kerr, 1991-92).
The Louisiana E/J Ratio
As Figs. 1 and 3 indicate, Louisiana's E/J ratios are the highest in the U.S., both when
considering all manufacturing (SIC 20-39, E/J = approx. 2500 Ibs/job) and when considering
only chemical industry manufacturing (SIC 28, E/J = approx. 14,000 Ibs/job). A more detailed
review of the chemical industry E/J ratio provides information on the sectors in need of
improvement. Figure 4 contains the Louisiana and U.S. E/J ratio for three- and four-digit SIC
28 sectors for 1990. It is clear that the Louisiana Industrial Inorganic Chemicals (SIC 281)
sector with a ratio of approximately 36,000 Ibs/job, and Agricultural Chemicals (SIC 287) sector
with a ratio of approximately 47,000 Ibs/job, are the largest dischargers relative to both the U.S.
averages and the Louisiana SIC 28 average (E/J = 14,108). An additional level of detail is
available by extending the analysis to 4 SIC digits. Both nitrogenous (SIC 2873) and phosphatic
(2874) fertilizer sectors and Industrial Inorganic Chemicals (SIC 2819) E/J ratios are
substantially above the U.S. average E/J. The major agricultural chemical producers have
1The author was appointed Secretary of the Louisiana Department of Environmental Quality
and served from March 1988 until January 1992.
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1993 TRI DATA USE CONFERENCE
SESSION
announced plans within the past two years to reduce emissions in Louisiana significantly. It is
not clear that Louisiana SIC 281 companies are planning significant reductions. The analysis
can also be carried out by determining the E/J ratio for each media, air, land, water, etc. for
a state and comparing to national averages. In Louisiana the high discharges, relative to U.S.
averages, are to air, surface water, and ground water.
Conclusion
The availability of emission and employment data yearly and in good detail has opened
up areas for analysis that can be used to evaluate numerous aspects of pollution control.
Normalizing the emissions data through the use of the E/J ratio allows interested parties to
evaluate a state, an industry, or facility's efficiency in processing materials and reducing
emissions relative to other states, industry type, or the nation. It provides independent guidance
to program managers in pollution control agencies who seek a means of discriminating among
those who are doing an adequate job of pollution control and those who are not.
In Louisiana, a pollution reduction program that focused on reducing discharges to air,
water, and ground water by the SIC 287 and 281 sectors would yield the greatest reductions in
TRI emissions and probably at least cost. The alternative is to attempt reductions across the
board, which may not be as effective and may put unnecessary burdens on those segments of
the industry who are already doing a good job of controlling emissions. A refinement of the
ratio would consider risk factors, e.g., air pollution may pose the highest risk to citizens but
would not necessarily stand out in the E/J analysis unless risk was factored in.
The role of evaluation in encouraging effective policies and proper functioning in state
regulatory programs is important for both environmental and economic reasons. The E/J ratio
can play a significant role in promoting equitable and effective environmental management.
References
Bureau of the Census (1991), Employment and Wages Annual Averages, 1990; U.S. Department
of Labor, Bureau of Labor Statistics, Bulletin 2393, Washington D.C.
Bureau of the Census (1992), 1990 Annual Survey of Manufactures, Geographic Area Statistics,
U.S. Dept. of Commerce, Economics and Statistics Administration, Bureau of the Census,
Washington D.C.
Hall, B. and Kerr, M.L. (1992-1992), Green Index, Institute for Southern Studies, Durham, NC,
Island Press, Suite 300, 1718 Connecticut Ave., NW, Washington D.C. 20009
Templet, P.H.; Glenn, J.; Farber, S. (1991), Environmental Finance, Autumn, pp. 211-211.
Templet, P.H.; Farber, S. (1993), Ecological Economics, in press.
237
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SESSION
1993 TR1 DATA USE CONFERENCE
US EPA, 1989. The Toxics Release Inventory, A National Perspective, 560/4-8-005, U.S. Govt.
Printing Office, Washington DC 20402.
US EPA 1992. In Toxics in the Community, National and Local Perspectives, the 1990 Toxics-
Release Inventory National Report, EPA 700-S-92-002, US Govt. Printing Office, Washington
DC 20402.
238
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Total Releases/Manufacturing Jobs (Ibs/job)
VERMONT
MASSACHUSETTS
HAWAII
COLORADO
NEW JERSEY
CALIFORNIA
RHODE ISLAND
NEW YORK
CONNECTICUT
MARYLAND
WISCONSIN
PENNSYLVANIA
NEW HAMPSHIRE
SOUTH DAKOTA
DELAWARE
OREGON
WASHINGTON
ILLINOIS
NEVADA
NORTH DAKOTA
MICHIGAN
MINNESOTA
GEORGIA
MAINE
NORTH CAROLINA
KENTUCKY
OHIO
> MISSOURI
H NEBRASKA
IOWA
SOUTH CAROLINA
VIRGINIA
US
IDAHO
OKLAHOMA
FLORIDA
ARKANSAS
INDIANA
ALABAMA
ARIZONA
TENNESSEE
MISSISSIPPI
TEXAS
WEST VIRGINIA
KANSAS
NEW MEXICO
WYOMING
UTAH
ALASKA
MONTANA
LOUISIANA
(0
239
-------
Total Releases/Sector Jobs (Ibs/job)
Apparel (23)
Food (20)
Machinery (35)
Printing (27)
Measure/Photo (38)
Textiles (22)
S
SJ Lumber (24)
c
£ Electrical (36)
c
Tobacco (21)
B>
O
3
(Q
a
c
(0
240
-------
Chemical Industry E/J (Ibs/job)
NEW JERSEY
CALIFORNIA
PENNSYLVANIA
NEW YORK
CONNECTICUT
MISSOURI
MICHIGAN
ILLINOIS
GEORGIA
CO
> VIRGINIA
™ OHIO
KENTUCKY
WEST VIRGINIA
NORTH CAROLINA
US AVERAGE
TENNESSEE
FLORIDA
TEXAS
ALABAMA
LOUISIANA
Tl
(Q*
C
-t
(D
O
(D
3
o'
0)
3
Q.
C
o
10
00
tO
tO
o
m
3
(0
o
o
i
o
or
to
i-+
o'
2.
(D
o
r+
<0
Q.
0)
»*
-------
E/J (Ibs/job)
O
Ind. Inorg. (281)
Alk. and Chlorine (2812)
Ind. Inorg. Chems. (2819)
Agrlc. Chems. (287)
Nitrogenous Fert. (2873)
•5 Phosphatlc Fert. (2874)
Misc. Chem. Products (289)
Adheslves & Sealants (2891)
Carbon Black (2895)
Chem. Preparations (2899)
Petroleum Refining (2911
31
(5*
c
3
CO
to
o
m
o-
«<
w
fio
Jk
o
^m»
(O
o
0)
(D
O
r+
O
^
(0
o
£
5T
3'
0)
D)
3
a
242
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1993 TR1 DATA USE CONFERENCE
SESSION 16
Pat Esposito, The Greater Cincinnati Chamber of Commerce
Background
Cincinnati is a commercial-industrial city located in rolling hill country on the banks of
the Ohio River. The city dates back more than 200 years, tracing its beginnings as a major river
port for boat traffic moving up and down the Ohio between Pittsburgh and New Orleans, and
points in between. Because of its age, many of the city's buildings and much of its
infrastructure (roads, bridges, water lines, sewers) are more than 100 years old.
Cincinnati's industrial base was established in the 1800s and continues to be a vital
economic factor. Today the industrial business sector provides more than 70,000 jobs and over
$2 billion in wages to local residents. Major industries located in Cincinnati include
transportation products manufacturing, metal fabrication and finishing operations, consumer
products manufacturers, and chemical production. These businesses continue to provide a rich
mixture of opportunity and economic vitality to the Cincinnati area. Cincinnati is widely known
as the "Queen City of the West" and "The Blue Chip City." It is also famous for its many fine
dining establishments and as a cultural center for music and the arts.
The city of Cincinnati lies entirely within the boundaries of Hamilton County, Ohio,
which has an area covering 414 square miles and a population of about 900,000. Cincinnati is
the largest metropolitan unit in Hamilton County and is the second largest metropolitan area in
the state.
Beginning in the late summer and fall of 1991, the news media of Cincinnati began to
pay close attention to the subject of toxic pollution in the local environment, particularly in the
sewer system. One after another, news reports appeared in the papers and on TV highlighting
the news that millions of pounds of so-called "toxic" chemicals were being released into the
sewers of Greater Cincinnati. Newspaper headlines read "Toxic County U.S.A.," "Sewers Brim
with Toxins," "Our Sewers are the Pits," and "Sewer District a Cheap Dump." TV reports said,
"Something Stinks at the MSD" (Metropolitan Sewer District), and "Danger Down Below." In
fact, the subject of a city bogged down in its own pollution was so hot that it was picked up by
the national CBS evening news and further glamorized by Dan Rather.
The stories presented by the press and the media hurt Cincinnati, both locally and
nationally. They made the Queen city look like a dirty and possibly deadly place to live. They
suggested that local residents were at risk and that the environment was damaged. They also
suggested that toxics were being "dumped" indiscriminately into the sewers, causing a large
portion of the sewer system to crumble and collapse and leak pollutants into the soil and
groundwater. Some claimed that the toxic chemicals were fuming out of the sewers and into the
air through manhole and drain covers, posing unknown dangers to the health and well-being of
people on the streets and in the buildings above. Some even suggested that the toxics in the
sewers were responsible for neighborhood cancers. Local professors, lawyers, citizen activists,
and public officials made numerous public statements on the subject such as, "Cincinnati's sewer
243
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SI SSION Id
IW3 TRI DATA USB CONFBRKNCB
system is the cheapest toxic dump in the nation," "toxic offenders in Cincinnati flush millions
ol pounds of chemicals into thousands of miles of sewers," and "this is a nightmare on every
street in Cincinnati." Edited film clips of interviews with representatives of the Chamber and
MSP made both orgaiii/alions look foolish and incompetent.
The TV and newspaper reports were based primarily on the Toxic Release Inventory
(TRI) Form R reports from 1987-1989 that had been submitted to the Ohio Environmental
Protection Agency from Ohio facilities. These reports showed that, indeed, about 20 million
pounds of assorted chemicals listed by EPA as "toxic" were being released to the local Hamilton
County sewer system annually. The TRI data also showed that Cincinnati's sewer system
handles over 2/3 of all toxic chemical releases to sewers in the state of Ohio, a situation that one
report called "appalling."
Chamber Response
In the spring of 1992, in the wake of this media blitz, the Greater Cincinnati Chamber
of Commerce decided to take action to find out if the allegations were true and to reassure the
community through careful analysis of the situation and presentations of the facts. First, the
Chamber established a special task force of environmental scientists, wastewater engineers,
chemists, toxicologists, and others known collectively as the Wastewater Resources Advocacy
Project, or WRAP. These experts were charged with the technically difficult effort of bringing
balance, clarity, facts, and a higher level of public understanding to the heated issue of toxics
in the sewers, and in the Hamilton County environment in general.
WRAP began the effort in June of 1992 by conducting a comprehensive review of all TRI
reports submitted to Ohio EPA since 1987 by local businesses. Data that had been submitted
for the years 1987, 1988, 1989, and 1990 were readily available from the OBPA in
computerized form and were used first for study and analysis. More recent reports covering
releases during calendar year 1991 became available for review at OEPA's offices in October,
following their submission to OBPA in September 1992. Thus, the Chamber individually
reviewed all of the 1991 TRI reports filed at OBPA and entered the data into the database
covering the previous years. Chemical release data taken from over 700 individual Form R
reports for 1991 and from 129 local companies were reviewed and tallied.
WRAP made a special effort to understand how the TRI reporting system had changed
over the years since it was first established, and how these changes impacted the numbers that
were being reported by local businesses for toxic chemical releases. This understanding was
essential for distinguishing bonafide reductions or increases in toxic chemical releases from
apparent or system-related changes. Changes in the list of chemicals requiring reporting (i.e.,
deletions and additions to the chemical list), changes in threshold reporting values, and changes
in calculation and de minimus reporting procedures were studied in order to gain a complete
understanding of their influence on the chemical releases reported from year to year. For
example, the deletion of sodium sulfate from the TRI list of toxic chemicals in 1988 had a
244
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IW3 TRI DATA USK rONPHRKNCI-
SI SSION Id
dramatic effect. The total amount of reported toxic releases to the sewers in Hamilton county
dropped by over 50% between 1987 and 198H as a result of the deletion of this single chemical.
WRAP analyzed the entire database for each year by company and by chemical. Through
this effort, WRAP was able to learn how many of the 300+ listed chemicals arc being released
in the area and in what amounts. For those chemicals being released in the largest amounts to
the sewers, toxicity. corrosivity, and treatability data were gathered in order to understand the
associate risks to public health, the collection system, and the treatment works. Information
about the prevalence of certain high priority chemicals in the TRI reports, such as the YV50
chemicals and known or suspected carcinogens, was also gathered and analyzed.
In November 1992, WRAP publicly announced the findings of its study to its members
and the public. A special one-hour briefing was held at the Chamber's conference facility.
Public officials from city and county government and local media representatives were invited
to attend and ask questions. A special briefing package containing key findings and conclusions
of the study was distributed at the meeting and mailed to those who could not attend.
Key Findings
Overall, the WRAP study found that in Hamilton County:
• About 22.5 million pounds of chemical substances listed as toxic arc currently being
released to the land, water, or air, or sent off-site for treatment and disposal. Another
3.4 million pounds are being sent off-site for recycling or energy recovery. These values
are based on the most current TRI release reports from 129 local facilities for calendar
year 1991.
• Over 60% of the chemicals in the reports (14.4 million pounds) are going to the MSD
sewers for treatment and removal before release to the Ohio river.
• The large majority of releases involve methanol and ammonia or ammonium salts, which
are biodegradable, noncarclnogenlc, and among the least toxic on EPA's list.
• The large majority of the releases are both legal and benign.
• Release patterns are showing a strong steady decline since 1988, despite certain TRI
reporting system changes that could have led to the opposite result. The downward trend
is due primarily to the voluntary efforts of local industries to reduce releases through the
elimination of certain TRI chemicals, alterations of manufacturing practices, installation
of pollution control devices, and increased usage of recycling and energy recovery
options.
• Direct releases of toxic chemicals in the air, water, and land in 1991 were less than half
the amount reported 5 years ago in 1987. Less than one quarter of the total releases and
245
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SESSION
1993 TRI DATA USE CONFERENCE
transfers reported in 1991 are being released directly to the air, water, and land. Most
of the chemicals (.75% by weight) are going to sewers or other off-site facilities for
treatment, disposal, recycling, or energy recovery.
• Only 100 of the 300+ chemicals appearing on the TRI list are released in the Greater
Cincinnati/Hamilton County area. Only 10 of the 37 known or suspected carcinogens
were reported, and most of that was for metals (chromium and nickel) that were
recycled, not released.
• The companies reporting TRI releases in Hamilton County are highly valued in the
community. They provide over 70,000 jobs and $6 billion in local economic value.
Noreen Warnock, Allen County Citizens for the Environment
Allen County Citizens for the Environment (ACCE) is a non-profit grassroots
organization dedicated to education and research relating to environmental problems in Allen
County, Ohio. ACCE was founded in 1987.
ACCE first gained access to Toxic Release Inventory (TRI) data in 1989. This was
accomplished with help from a helpful staff worker at the Ohio EPA (EPA) and help from other
Ohio environmental groups.
TRI data from 1989 revealed that British Petroleum Chemical, Inc. (BP) in Lima, Ohio
(county seat of Allen County) was the largest source of chemical releases in the northeast United
States. This statistic, as well as other TRI data, added valuable credibility to ACCE. The
organization gained moral and energetic force to further educate ourselves and the public to
potential problems associated with the TRI information. The TRI also provided some necessary
data for ACCE to hold BP, state and local health departments, city and county officials, and
EPA accountable regarding health and safety issues related to toxic releases at BP. Because of
the extremely high emissions documented by the TRI, other environmental organizations outside
Ohio became interested in our pursuit for solutions to our environmental problems. They have
provided much needed expertise.
Although TRI data give ACCE necessary information, there are areas associated with the
TRI that are disappointing. Among others, EPA's response to the high numbers in our country
are not commensurate with the seriousness of the problem. EPA's attitude and lack of
involvement remain of concern to us. Another concern we have deals with the lack of
information available on accidental releases of toxic emissions. The TRI forms do not cover this
adequately. The unavailability of technical assistance to community groups regarding TRI data
is also a problem. Another drawback to TRI data is that they are not ranked according to which
facilities emit the most toxics. Knowing where a local company stands in relation to other
companies is very helpful.
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1993 TRI DATA USE CONFERENCE
SI-SSION 16
We have several suggestions with regards to changes we would like to see made in the
TRI reporting system. A specific change we recommend is that TRI forms include a section that
deals individually with accidental releases, clean-up releases, and routine manufacturing.
Differentiation among these releases is vital to a community's understanding of exposures it may
be experiencing. Establishing EPA programs that react to or follow up on companies with high
TRI numbers would improve the use of TRI data in community groups. Also, an aggressive
stance by EPA on source reduction and less pandering to political pressure — such as wrangling
over delisting of chemicals or compromising the permit process — would go a long way to
improve relations with community groups. An organized plan by EPA to deal with follow-up
on TRI data in counties with high emissions would help everyone from the Chamber of
Commerce to industry to the environmental group know exactly what a community needs to do
to clean up and would help end a lot of conflict among these groups. TRI data in and of itself
is not enough but it is a good beginning toward the goal of making our communities healthier
and safer places to live and raise our families.
Barry M. Casper, Carleton College and University of California, San Diego
In June 1989, when the Toxics Release Inventory (TRI) database first went on line,
residents of Northfield, Minnesota, a small rural community, received a big surprise. According
to the Natural Resources Defense Council, Sheldahl Corporation, with 700 workers, the
community's largest employer, located on the north edge of town, was the 45th largest emitter
of airborne carcinogens in the nation. Unbeknownst to the community, for decades Sheldahl had
been releasing large amounts of a colorless, odorless chemical into the Northfield air, and for
several years that chemical, methylene chloride, had been classified by the EPA as a "probable
human carcinogen."
Soon thereafter two new organizations were created: (1) a group of concerned citizens,
Clean Air in Northfield, and (2) a committee of local scientists, the Air Toxics Study Group.
The citizens soon discovered that the Minnesota Pollution Control Agency (MPCA) was about
to issue Sheldahl a new five-year emissions permit; they seized on the permitting process as an
opportunity to curtail the company's methylene chloride emissions.
As chair of the Air Toxics Study Group, I worked closely with both these groups and,
eventually, with plant workers and their union officials as well. Over the next year and a half,
the Air Toxics Study Group also developed an excellent working relationship with MPCA
officials and participated in many discussions and meetings with company managers and
technical staff.
From this experience, I learned some things about TRI information in actual practice,
including how it may affect company policies, how well it interfaces with the general public,
whether or not it helps to answer the important questions people immediately ask, and how it
biases the politics of public response in a surprising way because of a gaping hole in its
coverage. Briefly:
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1993 TRI DATA USE CONFERENCE
1. The TRI made information available to the public that the company had withheld. EPA
had designated methylene chloride as a "probable human carcinogen" in 1985, but
Sheldahl never told the Northfield community and continued to emit 400 tons a year from
its upwind location. At the same time, however, probably in part because of the
anticipated public release of this information by the TRI, the company sought urgently
to develop non-toxic substitutes for methylene chloride so as to have an emissions
reduction plan prepared when the people of Northfield did find out. So, in Northfield,
the TRI had very important positive effects: in bringing information to citizens that they
needed to know to influence policies that directly affected their lives, in piercing the cozy
relationship between the company and the institutions of government that were supposed
to protect public health and safety, and in prompting the company urgently to pursue
ameliorative changes in its practices.
2. The Natural Resources Defense Council played a crucial mediating role between the EPA
and the public. By focusing on eleven airborne carcinogens among over 300 TRI
chemicals and listing the 125 largest emitters of those carcinogens in the United States,
with Sheldahl ranked 45th, NRDC created a "story" that drew press attention in
Minnesota. At that time, the TRI was not easily accessible to the public and there was
nothing in its voluminous lists that indicated the toxic effects of the chemicals. For
instance, once alerted by the press, my students had to travel forty miles to the
Minneapolis Public Library to access the data, and nothing in what they found indicated
that methylene chloride was a carcinogen. Without the NRDC report, it is problematic
that citizen concern in Northfield would have been triggered. This suggests it is very
important that TRI be augmented by government support of both public and private
mediating institutions dedicated to proactive efforts to alert the press and the public and
to help them interpret the implications of the data.
3. The TRI failed to provide information to answer what are obviously the crucial questions
that citizens will ask immediately. Among these questions are: What are the toxic effects
of the chemical? What is my family's exposure? What is the risk? What they really want
to know is, "Is this something I should be wormed about?" If the public does not have
credible ways of addressing those questions, the TRI is like crying "Fire!" in a crowded
theatre. Not only did the TRI not provide answers, it did not provide any guidance as
to how to go about finding the answers. Our group of chemists, biologists, physicists,
and mathematicians spent weeks tracking down the scientific evidence that would shed
light on the answers to those questions for methylene chloride in Northfield, and much
more time developing primitive models and then pressing for the appropriate modeling
efforts that needed to be performed. This suggests it is important that TRI be augmented
by easily accessible guidance about where to find the best scientific data currently
available and, every bit as important, to provide government support for public and
private efforts to assist the public in interpreting that data and assessing its implications
for public health and safety.
4. The TRI provided no information at all about exposure and risk to those citizens of the
community who were most exposed and most at risk — the workers at the plant. In a
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curious and very important way, this biased the politics of the protest toward demanding
pollution control solutions and away from what the national environmental community
consensus sees as the most appropriate response: toxic use reduction.
This became evident in Northfield because from the beginning, Sheldahl had proposed
a five-year plan to reduce methylene chloride emissions by 90% by introducing non-toxic
substitutes. Initially, most citizens in CAN rejected that as too slow and demanded recapture
and, possibly, re-use technologies. And the safety criterion the MPCA used was even more
perverse, encouraging higher stacks and wider dispersal of toxic chemicals. It was only when
we built an alliance with the plant workers, and heard the recapture approach derided as "putting
the cork in the bottle and leaving us in there with the methylene chloride" were many of us
sensitized to the workers' concerns about toxic risks and job security and more sympathetic to
toxic use reduction as an appropriate response.
While I understand the institutional reasons responsible in the past for the separation of
exposure-related data for citizens inside and outside the plant, I believe the Northfield experience
constitutes a powerful argument for combining the TRI database with worker exposure
information and releasing that information to the community at the same time. It is likely to
have a profoundly positive effect on the politics of citizen response to the data.
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SESSION 17:
Public Use of TRI
Introduction
The Public Use of TRI Data panel brought together a
diverse group of organizations, all of whom are current TRI users.
Representatives from labor, corporate and facility level industry,
academics, and environmental organizations joined the panel to
provide an overview of the current range of TRI applications.
Panelists provided a survey of TRI use in organizations similar to
their own and presented detailed information on important
examples of TRI data use. The panelists also addressed the issue
of building coalitions among organizations as a means for making
TRI data more accessible.
Specific Issues Addressed
Bob Hogner, from the Center for International Business/
Environment Studies at Florida International University, described
the use of TRI data in teaching, research, and community
activities. He also described specific student projects on military
contractors/ozone depletors, Puerto Rico, the Caribbean, and
business response to TRI.
Charles Griffith, from the Ecology Center of Ann Arbor,
described the history of the Center's use of TRI, including reports,
training sessions, and a citizen's lawsuit for non-reporting. He
then detailed an ongoing project comparing TRI releases with
income and race information at the county level.
Sharon Eisel, Issue Manager SARA/Pollution Prevention
for Dow Chemical USA, described her company's use of the new
data in Section 8 of Form R. She discussed the difficult issue of
defining waste, the varying interpretations of "quantity recycled,"
and the multiple reporting of the same chemicals in recycling
loops. She then identified the amounts reported as "into
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treatment" both on- and off-site and the amounts "used for energy
recovery" as the most valuable numbers in the new data. Ms.
Eisel described how this new data can be used as a supplement to
SARA emission data to look for source reduction opportunities.
Donna Carville, from the Plaquamine, Louisiana, Dow
Chemical facility, described the usefulness of TRI data as a tool
for grading the commitment and performance of a facility in
reducing emissions. Ms. Carville described the integrated
approach to emissions reduction at the facility level, the necessity
for communication with the surrounding community, and the value
of cooperation with neighboring chemical companies. She
explained the role of the parish LEPC as a forum for
communication and the annual emissions report of the Louisiana
Chemical Association.
Larry Davis, from the United Steelworkers of America,
focused on how TRI information is used with regards to worker
health issues and worker chemical exposure. Mr. Davis described
what the common worker and community interests are surrounding
TRI data. He also explained that this data can be employed in
early warning evaluations of health and employment impacts.
Where Do We Go From Here?
Panelists agreed that the public needs more outreach to
make them aware of TRI data and more help to interpret the data.
Outside of the large companies, the use of TRI data is still
undeveloped.
This session also discussed the need to build coalitions that
would allow organizations representing different segments of
society to share their resources for using and interpreting the data.
Individual panelists highlighted important future goals:
• using the new Section 8 data to identify opportunities for
source reduction;
• using TRI data to monitor continuous improvement in the
community;
• integrating TRI with income and nationality data as a tool
to involve communities in environmental issues;
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making labor more aware of the value of TRI as an
indicator of health concerns and company viability;
promoting research on TRI's role in society; and
expanding programs in primary and secondary schools.
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Panelist Presentations
Robert H. Hogner, Florida International University
I. The TRI in University Teaching
• The Toxics Release Inventory in Business School Classes
— Classroom Projects
— Team Projects
• Useful Teaching Dimensions of the Toxics Release Inventory
— Integration with Developing Public Policy Issues
— Business/Society Relations
— Management Strategy
— Global Environmental Policy
n. The TRI in University Social Issues Research
• Management Issues
— Corporate Reaction to 33/50 Programs
— Corporate Reaction to Interest Group "TRI Studies"
— Alternative Toxic Chemical Control Systems
• Theoretical Issues
— Rorty "Social Conversation"
— Social-Cultural Dimensions of Economic Activity
— Public Issue Development
ni. The TRI in University Community Activities
• Community "Release" Studies
— Local Service
— Regional/State Studies
— Training Community Groups
• Children's Education/Action Projects
— Enviro-cops/Enviro-mentors
— Secondary School Science/Government Studies Projects
— Children's "Community Action" Projects
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IV. Specific TRI-Related Activities
— Student Project on Military Contractors/Ozone Depletors
— Puerto Rico Project
— Caribbean TRI Project
— Business Responses to TRI and TRI-Related Stimuli
Charles Griffith, Ecology Center of Ann Arbor
The Ecology Center has been involved in the public application of TRI data since they
were first made available. It has published various reports, conducted training sessions, and
even engaged in a citizen lawsuit for non-reporting of required TRI information. Most recently,
the Center has been completing research for a report that will compare TRI releases with income
and race information at the county-level. The presentation made at the conference will include
a discussion of how that study has been conducted, results of the analysis completed to date, and
methods (such as GIS-mapping) that will be used to illustrate those results. The presentation
will then describe ways that the Ecology Center plans to involve representatives of the
community in communicating the information of the report to the public.
Sharon Eisel, Dow Chemical, USA
Pollution Prevention Act/Section 8 Data
• The tremendous amount of data in the new Section 8 of the Form R can be very
confusing — we need to focus on key numbers.
• Because of the difficult issue of defining what is a waste and because the word "waste"
was left off of the Section 8 form, the way the form was filled out varied. Much of what
is not considered a "waste" was reported.
• There were widely varying interpretations by companies and facilities about what should
be reported as "quantity recycled," especially in Section 8.4: "quantity recycled on-site."
• Often the same molecule of a chemical was reported hundreds of times as it repeatedly
went around a recycling loop.
• So where should we focus? The amounts reported as "into treatment" both on- and off-
site and the amounts "used for energy recovery" are the most valuable numbers. This
is where industry can use the data as a supplement to the SARA emissions data to look
for source reduction opportunities.
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• Care must be used with this data. Addition of the numbers when companies have
reported multiple passes of the same molecules of a chemical makes no sense in trying
to quantify "total waste."
Donna Carville, Dow Chemical, USA
The TRI database has given us an excellent tool to grade our commitment and
performance in reducing emissions as a chemical company and have our commitment and
performance graded by our community as well. Since 1988 a 35% reduction in total SARA
emissions have been made with a continued commitment of 50% reduction by 1995.
First comes the commitment, but then comes the real work of implementing the strategy
of reduction. Communications of that commitment have been made to all of our employees and
their role in making it a reality. Projects have been prioritized along with an employee
participation program to encourage reductions by implementing corrective actions they may find
in the production units. It is a totally integrated approach to making emission reductions happen
with everyone participating. This program also includes the contractors at our site.
Communicating to the community around us is just as important so that we may address
their concerns as well. Accessibility to the data and other information has been made through
the tour program, information center, and the Community Advisory Panel members. There is
a 24-hour Dow hot-line for answering questions, as well as an interactive television program
called "Dow Live."
Networking with the neighboring chemical companies has helped all of us in reducing
emissions. The Iberville Chemical Council, an 11-member team, meets regularly to implement
programs to ensure that performance improves, as is called for in the Responsible Care
initiative. Communication of emissions as a group of companies occurs yearly with information
about specific environmental projects released throughout the year. The parish LEPC is an
excellent forum for communication and is one of the most active groups in the state of
Louisiana.
The Louisiana Chemical Association also publishes a state report each year to ensure that
the emissions data is communicated to the public. This communication occurs whether the news
is good or bad, although there is strong commitment among the members to reduce emissions
as quickly and as much as possible.
Are we doing a good job? We hope so! We are certainly trying to open more doors to
be as accessible as possible, to address the concerns of not only our employees but the public
as well. Can we do more? Certainly! Building more bridges of understanding can be and will
be a priority this year.
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Larry Davis, United Steelworkers of America
Discussion topics centered around the following:
• TRI Information and Workplace Chemical Exposure
• TRI Pollution Prevention/Waste Minimization Information and Worker Health Issues
• TRI and Facility Waste Audits
• TRI and Early Warning Evaluation of Health & Employment Impacts
• Common Worker and Community Interests Surrounding TRI
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SESSION 18:
EPA's Geographic Initiative
Introduction
EPA's geographic initiative programs provide an integrated
view of a specific area or ecosystem. This approach varies greatly
from the traditional approach of dealing with air, water, and land
emissions through separate program activities.
Specific Issues Addressed
Three major points arose during the session:
First, there was a general consensus that the inventory
should be expanded to include more chemicals and industries that
are relevant to the geographic initiative program. To ensure that
this goal is accomplished, those involved with geographic
initiatives should be actively involved with the decision to expand
the chemicals listed on the Form R. Such a process will have to
address the reality that each program is region-specific, and the
needs of one program may not meet the needs of other programs.
Second, it was pointed out that data quality is essential to
effective and comprehensive geographic analyses. Without proper
data checking and quality assurance, additional chemical and
industry information will not contribute to the program.
Third, there needs to be a stronger partnership among all
TRI users — EPA, regions, states, industry, and the public.
Closer working relationships and better communication will
contribute substantially to the effectiveness of the geographic
initiative program.
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Where Do We Go From Here?
Participants provided several suggestion as to where EPA
should head with the geographic initiative program:
• EPA should recognize, or continue to recognize,
geographic initiative programs as a valuable and powerful
source of information about a particular area or region.
The information should be harnessed to empower pollution
prevention efforts by the regions, states, or specific
industries.
• The Agency should work to integrate the various
geographic initiatives.
• In addition, the public should have greater access to the
information and results the program produces.
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Panelist Presentations
Steve Hanna, California Environmental Protection Agency
TRI Spatial Data Quality in California
The California TRI program has had an ongoing interest in the spatial coordinates of
reporting facilities and their potential for poor data quality. Latitude-longitude were first
considered mandatory data elements for 1988 TRI reports. At that time, we examined the spatial
data quality issue in two ways:
• Seven professional staff calculated the latitude-longitude for our building, using the 1988
form instructions and the requisite USGS maps. We agreed upon the degrees latitude-
longitude before beginning the calculations, removing possible transposition errors of
switching latitude and longitude or substituting minutes for degrees. A plot of the
resulting points covered a 1 by 3 mile rectangle.
• The reported TRI coordinates were mapped by a GIS system and plotted on a global
scale. While 90% of the data points were within California boundaries, some California
TRI facilities appeared in the Atlantic Ocean, the middle of the Pacific Ocean, and at the
North Pole.
As a portion of a 1990 U.S. EPA TRI grant, we examined a possible mechanism to
improve the quality of spatial coordinates. This approach utilized a GIS system and enhanced
1990 census data to calculate latitude and longitude based upon the facility address. We first
identified 100 facilities from this GIS-based address determination, then contracted with an
engineering firm to determine spatial coordinates to 50 feet. A comparison of the results
indicated that the GIS-based system was accurate to approximately 300 feet, while the reported
data from TRI forms showed a much higher level of variability and inaccuracy. The only
apparent drawback to using the GIS-based address determination is that some spatial coordinates
cannot be determined for TRI facilities located in rural areas.
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Helen Burke, U.S. EPA, Region IX
GIPPP: Government-Industry Pollution Prevention Project
• Purpose
— To describe Region IX's efforts to form a partnership with industry and other
agencies to reduce pollution.
— To identify issues raised by partnership.
• Background
— Wanted to expand 33/50 concept to all TRI emitters.
— Focus on geographical area of highest concentration of TRI emissions.
Concept
Partnership with obligations.
Geographically based on all TRI emitters.
Need community involvement.
Develop incentives for industry to participate.
Develop coordination among agencies.
Process
LA County — highest TRI emissions in Region LX.
Focus on SW sector of LA County — 211 companies.
Develop partnership with industry and other agencies by first identifying three
core agencies and three core industries to work with.
Get support of top management of core agencies and industries.
Announce project to all 211 companies in targeted area at press conference.
Get community input early in process.
Develop guidelines that companies and agencies sign onto to join program.
Get some pilot pollution prevention projects going early in the process.
Issues
How to structure a partnership among EPA, agencies, and industry to promote
pollution prevention.
How to coordinate agencies.
How to coordinate within EPA.
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Pranas Pranckevicius, Great Lakes National Program Office
Good afternoon, my name is Pranas Pranckevicius. I am the data integration manager
of USEPA's Great Lakes National Program Office in Chicago. It's a pleasure to be here to talk
with the users, the developers and supporters of the Toxic Chemical Release Inventory database.
I'd like to share with you some ideas about information management that we are working on in
the Great Lakes Program in cooperation with OERM and Geographic Initiatives in the Gulf of
Mexico and in the Chesapeake Bay.
How are Geographic Initiatives Different
For the next 10 minutes I am going to present the new way of doing business that is
essential to the success of environmental protection and restoration in the Great Lakes, in the
Gulf of Mexico and in the Chesapeake Bay, and tell you how TRI has impacted our program.
Our program emphasizes geographic approaches to ecological problem solving (i.e.,
ecosystem management), targeting sources of the greatest environmental risk, and the use of
information as the common currency in this process.
Recognizing that we can't solely rely on environmental statutes as a basis for action, we
convened 18 federal, state, and tribal agencies last year and have hammered out a set of
environmental objectives and specific steps to move us toward meeting those objectives.
Eliminating the release of toxics, particularly persistent, bioaccumulative toxics to
eliminate concerns for human health and wildlife.
Protecting and restoring critical and important habitats to ensure the survival of
important' species.
Protecting human health and restoring biological diversity of the region.
Recognizing our joint responsibility to foster our partnership with other feds and states
in order to achieve the above goals by rebuilding our infrastructure for research and monitoring
and information management.
New Approach
Thus, we are shifting from a purely regulatory emphasis to an ecosystem emphasis, one
that places our regulatory capabilities and responsibilities in a richer context.
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This approach focuses on our ability to apply our efforts on assessment, diagnosis, and
implementation of activities to improve the environment, and in turn to not only communicate
the results to the public but also enlist their involvement in the process.
Very simply, we are trying to access information in a geographic context at a variety of
spatial scales.
We want to point and click and see both what data are available and the data themselves.
We want to link, i.e., overlay source information in a geographic setting to
evaluate/understand relationships, and see facility/site level information in terms of the potential
for release and the actual releases.
By understanding associations and relationships through the use of descriptive and
predictive models, we want to influence and direct actions to address the problems. This is the
essence of comparative risk management.
Public participation in the ecosystem management process is a cornerstone of our efforts.
We need to empower the public through access to information as well as secure their trust and
confidence in our joint ability to make environmental improvements and to be relevant to the
process.
Finally, we need to do a better job of tracking all our indicators, not the least of which
are some key administrative indicators including investments and expenditures. With increased
finding comes increased accountability.
Initial System Concept
The five-year strategy calls for the initiation by January 1993 of an environmental data
storage and retrieval system that will support the activities that we are undertaking to meet the
goals of the strategy.
Discussion with our key cooperators helped us to determine the key attributes of the
"system solution":
Data standards — ensuring or at least identifying the quality of information accessible
by providing access to "meta-data." Ultimately we want agreed-upon quality assurance/quality
control at the sampling and analysis stages as well as the data input and transfer stages.
Standard data structure accessible by standard SQL queries would result in a common Great
Lakes Environmental database.
Directory of sources — given the tremendous network existing within the Great Lakes
basin, we need to provide users with a directory for "one-stop shopping."
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Access — "transparent" access to both the repositories of source and ambient information
for which EPA is custodian, but also access to the broader network of environmental information
available from other agencies and universities that greatly enrich and, in fact, are essential to
our capabilities for analysis and understanding. To link ambient monitoring data with
source/cause data, and to do so within a geographic context.
Models — the ability to develop and operate descriptive as well as deterministic models
in order to evaluate "what if scenarios, project future trends, and estimate times to recovery.
(Broaden to common analytical tools).
We believe that providing desk-top level access to environmental information in a way
and on a scale never accomplished before will empower individuals at all levels — public,
private, local, state, and federal. This empowerment will lead to a synergistic reaction for
improvement and protection that extends far beyond legislative directives.
The impact of TRI on the Great Lakes Program has been significant:
We first made use of The Toxic Chemical Release Inventory in production of our Great
Lakes Basin Risk Characterization Study. The data analysis and presentation approaches
developed for use with TRI data were applied to other data in the Great Lakes Basin. Thus, it
was a catalyst that helped to develop a more information-oriented approach to our decision-
making process.
TRI data accessibility and availability allowed environmental scientists, not just
information managers, to analyze the data in a comfortable computing environment. We saw
that available, accessible data would be analyzed by others outside the program generating the
data.
TRI data quality changed our approach to data analysis. Data analysts were freed from
many of the difficulties encountered by using someone else's data because of the effort put into
data management. It became obvious that data quality is proportional to the use that the data
got.
TRI is a relevant environmental indicator used in our reporting:
Several drawbacks of TRI, however, prevent it from being a Great Lakes ecosystem
indicator of prime importance:
• TRI does not represent all processes having significant impacts upon the Great Lakes.
Important processes, including waste treatment facilities and mining, are not represented.
• TRI chemicals lists do not include many of the persistent toxic chemicals that have been
identified as problems in the Great Lakes.
Thank you for your time.
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Michael Marshall, BF Goodrich and the Council of Great Lakes Industries
Great Lakes Industry and Regional Priorities
The Council of Great Lakes Industries (CGLI) is a bi-national, multi-industry
organization founded in 1990. CGLI promises the economic vitality of the region in harmony
with its human and natural resources, a mission consistent with the concept of sustainability.
Since its inception, CGLI has focused primarily on regional environmental issues and promoted
pollution prevention, environmental stewardship, and the use of sound scientific and economic
methods for policy, planning, and decision-making.
In 1991, for example, we sponsored pollution prevention and remedial action plan forums
at the International Joint Commission's Biennial. We presented positions on virtual elimination
and zero discharge of toxic chemicals to DC's Water Quality Board and Task Force. We have
also worked with organizations that provide technical information to regional stakeholders, such
as a public television consortium under the umbrella of Chicago's WTTW that will produce a
series on the Great Lakes. We assisted a regional, technology-focused organization, the
Cleveland Advanced Manufacturing Program, in producing a teleconference series on pollution
prevention for mid- and small-sized companies. In 1990, we began working with the Council
of Great Lakes Governors to develop a regional total quality environmental management
(TQEM) award. We are also working with universities to integrate TQEM into their curricula,
including continuing education for business managers. CGLI's focus on stewardship and
pollution prevention reinforces activities underway by other stakeholders.
Now that CGLI has been introduced to this audience, it is time to explore the topic of
regional issues. Let's begin first with a question: why are organizations such as Ameritech,
Argonne National Laboratory, BF Goodrich, Canadian Pacific Forest Products, Dow Chemical,
Ford, the Federal Reserve Bank of Chicago, Grand Trunk Railroad, Kodak, Upjohn, Xerox, and
other companies formally working together on broad economic and environmental issues?
First of all, this region has a unique natural resource base including abundant and high
quality water. It is also unique as the heartland of North American manufacturing, with 20%
of U.S. and 50% of Canadian manufacturing. Over the past two decades, this base has been
declining due to increased global competition. The region is also deeply immersed in improving
environmental quality. We recognize that the region's environment, its economy, and its social
infrastructure are tightly interlinked in many ways: its resources and abundant fresh water
provide materials, transportation, power, and a high quality of life. For these reasons, it is clear
that when we manage — we must manage in an integrative way as we develop policy, make
plans, and implement those plans. It is therefore critical that business contribute its knowledge,
expertise, and perspectives, so that policy development can be based upon the broadest and
soundest information base.
Second, the need for business involvement becomes even clearer in light of the existence
of 650 Great Lakes organizations, virtually all of which are environmental or natural resource-
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focused. This provides opportunities to link common objectives and to share resources, an
option to which we are committed.
Third, over the past three decades, the region has experienced multiple cycles of public
policy formation and implementation, reflected in an overwhelming number of laws, regulations,
plans, and initiatives. It has become increasingly clear that rather than continue to play "catch-
up" at implementation, we need to anticipate and, in time, get ahead of this ongoing cycle. To
do this, we will need to become proactively involved in the policy process at a much earlier
stage. We will also need to work much harder to communicate a business perspective, as well
as to understand the perspectives of others, if we are to participate in this process and shape
policy that integrates rather than deals separately with economic, social, and environmental
issues.
Let me now briefly mention a few specific regional environmental management
approaches that in some respects have not fully achieved the attributes of a completely
integrative approach. For example, uniform standards have been proposed for the Great Lakes
under EPA's Great Lakes Water Quality Initiative. Yet, the five lakes, their tributaries, and
their connecting channels are not uniform with respect to physical, chemical, or biological
parameters. Compare for example the cold waters of Lake Superior with the shallow warm
waters of Erie, and the different life-forms that each favors. While we appreciate the need for
an ecosystem-based management approach, in this case we are not dealing with one ecosystem
but with a number of them. Thus, attempting to apply a single set of standards (and the most
restrictive standards) to the entire Basin will impose economic costs (estimated for municipalities
and industry at about $10 Billion) and their effects on society without corresponding benefits to
either environment or health.
Let's consider a second example. Canada and the U.S. signed the Great Lakes Water
Quality Agreement in 1972. Through this agreement and its several revisions, the two countries
established a goal to protect the Great Lakes environment and human health, and agreed to adopt
a philosophy of zero discharge and a management strategy of virtual elimination of persistent
toxic chemicals. However, a literal interpretation of zero discharge, such as now proposed for
Lake Superior, and in time for the entire set of Lakes, would again incur great costs without
accompanying benefits to environment and human health. Recently, proponents have moved
toward even more prescriptive approaches: zero use or bans on chemicals. In 1991, LFC
recommended bans on persistent toxic chemicals, extending this even to chlorine. While the
effects of some persistent organichlorines on the environment are recognized, the blanket
extension of such concerns to all organichlorines, as well as to chlorine itself, is hardly realistic
— nor are the economic and social hardships justified that such a management approach would
bring.
Another issue of concern is the area of remediation, where there is pressure to restore
contaminated areas to pristine conditions. Once more, an integrative approach needs to be taken
when developing both cleanup standards and specifying cleanup technologies.
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While there are other regional issues that could be mentioned in this context, it is now
time to briefly touch upon some of the proactive voluntary accomplishments of regional industry
that should in time obviate the need for highly prescriptive approaches. One example of such
a voluntary program is the chemical industry's Responsible Care program. This program
provides guidelines for stewardship of chemicals during manufacture, use, and transportation,
and further requires members to commit to and track waste reduction. The Responsible Care
program also provides a framework to weigh benefits, costs, and risks of any such approach
before committing to action. In the U.S., voluntary commitments to reductions in toxic
chemical emissions have been announced by hundreds of U.S. firms in response to EPA's
"33/50" TRI reduction program, and significant progress has been reported by many firms that
committed to pollution prevention. Reductions in discharge levels by industry in the Sarnia,
Ontario area into the St. Clair River also provide evidence of industry commitment, as does the
Dow Canada Chemical Company's River Separation Project.
As you may be aware, in Northern Ontario the pulp and paper industry has been faced
with a difficult economy, workforce reductions, and plant closings, yet the commitment of that
industry to resolving environmental concerns remains high. Huge sums have been invested to
upgrade process technology to improve environmental performance in both Canada and the U.S.
In Canada alone, this has amounted to more than $30 billion since 1980. Firms in both
countries have invested significantly to reduce dioxin levels and other chlorinated organics from
mill effluents. The U.S. industry has invested $1 billion, and reports that between 1985 and
1993, emission levels of dioxin will have been reduced by 99%.
Stelco, a steel manufacturing firm, has constructed a greenfield plant on Lake Erie that
it regards as state-of-the-art in the environmental area: water discharge volumes, a large
component of waste from large integrated mills, have been reduced by 90%. Contaminants are
virtually eliminated from water discharges through multi-stage treatments. The extent to which
recycled materials are used today in some sectors is also noteworthy. In the area of steel
manufacture, fully 50% of steel used is recycled material. Today, 30% of paper and paperboard
manufactured in the U.S. is recycled. In the U.S., a 40% recycling goal was set for 1995, and
in Canada, there is a 50% goal for 2000.
Another important driver — the total quality management movement, or TQM — has also
contributed to waste reduction success. TQM instills a philosophy of continuous improvement
and empowers the workforce at all operation levels. As ownership and responsibility are
transferred onto the shop floor into the hands of knowledgeable workers, waste levels plummet.
The Great Lakes Governors TQEM award developed by CGLI will recognize such
achievements.
None of the many initiatives described above would be possible without sustained will,
cooperative action, and the application of significant resources. While there are no easy
solutions, many of the options available to us are being pursued with energy. However, many
other compelling issues face us, such as energy, education, introduction of exotic species,
preservation and restoration of natural habitat, and health care. Given the tradeoffs in managing
broad sets of issues in a climate of shrinking resources, we expect that this process and our
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1993 TRI DATA USE CONFERENCE
SESSION
choices will continue to be difficult. Responsible decision-making will continue to depend on
credible science, valid risk/benefit methodologies and data, and the broad dissemination of such
data to all potentially affected stakeholder groups.
How can we all contribute in a more positive sense to this needed evolution?
Government, business, and the public need to work together to develop sound public policy that
provides a positive atmosphere for change and removes barriers to progress. Government can
contribute by not over-institutionalizing approaches such as pollution prevention, but instead
allowing businesses and municipalities the needed flexibility to implement change. The decision
to invest capital in redesign of products and processes is facilitated by wise public policy that
encourages such flexibility. Government, business, and academia need to increasingly
collaborate in providing objective public policy education. This is true in many areas, including
the area of toxic chemicals effects and management choices. A number of outreach vehicles
already exist that can provide collaborative support. These include, for example, new national
Pollution Prevention centers at the University of Michigan and in Sarnia, Ontario, as well as an
established outreach vehicle, the U.S. Department of Commerce's Sea Grant Great Lakes
Research Network, already active in toxic chemicals research.
In the area of regional management, government needs to ensure that its management
approaches are truly integrative in design; consider economic, environmental and social inputs;
and do not create inequities that place the region at a competitive disadvantage with respect to
other regions, or on world markets. Government can also formally recognize and reinforce
those sectors that practice sound environmental management.
Business will need to better communicate to the public its commitment to stewardship,
its successes in pollution prevention and TQEM, its goals, and its future plans. But, at a higher
level, business will need to work with others to develop a credible information base that
facilitates sound public policy development and that can be used to set sound priorities and
develop realistic implementation vehicles.
Only through such changes can the public policy development process become a truly
consensus-based one. Only through such collaborative approaches will we be able to allocate
our limited resources in a way that is consistent with the greatest good of society.
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1993 TRI DATA USE CONFERENCE
Andrew Comai, Lake Michigan Federation
TRI and the Geographic Initiative
Given the time constraints for this presentation I hope to throw out a number of ideas on
1) how the TRI can be greatly expanded (and thus improved); and 2) how TRI can be more
effectively distributed and promoted, access can be improved, and assistance given to data users.
Presenting these ideas will hopefully generate some thoughts among the audience on how
pollution prevention projects can be integrated into the Geographic Initiatives. Also, I hope to
suggest ways that the agency can prioritize work projects to target pollution prevention programs
for specific areas.
The first overhead demonstrates a major barrier to the Geographic Initiative on the
Southern end of Lake Michigan (Figure 1). Regulatory boundaries divide ecosystems. Here you
can see the Calumet river system flowing through toxic hot-spots (reflected in the TRI totals
broken out by zip code) in two different states. If you look at the way the TRI data have been
compiled in most reports, Lake County, Indiana, and Cook County, Illinois, occupy separate
universes instead of sharing not just a boundary but a river and a lake.
In the draft of the Lakewide Area Management Plan (LAMP) for Lake Michigan,
published in draft version in January 1992, one finds the TRI information buried way in back.
On closer scrutiny the reason for its placement is obvious; it is an inadequate attempt at
compiling the TRI data. The information is from 1988; there are no off-site transfers to
locations within the basin included in the data tables. Also, specific compounds are not included
in the search. These flaws are acknowledged in the document, but the fact that the flaws were
not eliminated points to a lack of attention to the TRI with regards to the LAMP geographic
initiative.
A number of data sets exist that should be combined with the TRI. By combined I mean:
given the same priority for public access, cross-referenced with TRI releases, and used regularly
by the regulatory community in the granting of permits. These include:
• Resource Conservation and Recovery Act (RCRA) Biennial Reports
• RCRA Manifest Data
• Publicly Owned Treatment Works (POTW) discharge permit data
• Emergency Response Notification System (ERNS) Data
• Tier n information
• Pollution Prevention Information Exchange System (PIES) case studies
Access to this extra data would greatly enhance our ability to stimulate activities
surrounding the Geographic Initiative.
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1993 TRI DATA USE CONFERENCE
SESSION
RCRA Biennial Reports: The extent of the pollution prevention projects in a particular
region should be monitored and made public for given regions covered by the geographic
initiative. Since RCRA covers a larger number of facilities than does TRI, increasing access
to this data will expand the universe of companies that will feel the warm glow of public
scrutiny.
RCRA Manifest Data: Chemicals that are included in the TRI list tend to disappear into
the various categories of RCRA waste. One example would be the sulfuric acid reported by a
number of steel companies in Illinois, Indiana, and Wisconsin. Millions of pounds of sulfuric
acid are transported off-site for reuse by sewage treatment plants. That same waste translates
into hundreds of millions of pounds of waste covered by RCRA as pickle liquor, D006 waste.
What are the other constituents of pickle liquor? Cadmium, hexavalent chromium, lead,
mercury: all TRI chemicals, none reported under TRI. To get a true picture of waste shipments
into an area of concern, we need public access to the manifest data available under RCRA.
ERNS data: The Great Lakes Water Quality Initiative specifically points to spill and
accident prevention as a primary method of reducing toxic loads to the Lakes. Increased public
access to historical spill data can help focus attention on where improvements should be made.
POTW discharge permits: In comparing the pretreatment clients of several Sanitary
Districts to the TRI lists, we have found a number of companies that report POTW releases
under TRI but fail to report these same releases to the POTW. This seems like a simple cross-
referencing of lists that will help bring more chemicals and more companies into the
pretreatment universe.
The pretreatment coordinators of sewer districts have a unique relationship to their
industrial clients. They regularly monitor releases, and suggest improvements that can help the
industries meet their discharge limits. Who better, then, to suggest pollution prevention
practices?
Well, there is a better solution. First, the Sanitary district inspectors need access to
technical pollution prevention data, and increased access to TRI. Also, in a perfect world,
coordinated multi-media inspections of industries by both the sewage treatment plant officials
and other state and federal agency inspectors responsible for air emissions and hazardous waste
would be the norm instead of a rare occurrence. Industries appreciate these kinds of inspections
because they reduce red tape that can be generated from conflicting requirements issued from
different agency sections. Without multi-media inspections situations like this might occur as
it has in Northwest Indiana.
Figure 2 demonstrates the need for these types of inspections. Thirty-two percent of all
stack emissions in Lake County, IN, came from this facility in 1990. The huge shift of 1,2
dichloroethane from the sewer to the air came about after the installation of an EDC recovery
unit. The change in the emissions came about after pressure from the Hammond Sanitary
district to reduce discharges to the sewer. With proper consideration of cross-media transfers
perhaps this shift could have been avoided.
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SESSION 18
1993 TRI DATA USE CONFERENCE
I am arguing for increased access to data well beyond that currently contained in the TRI.
This argument rests on the premise that the warm glow of public scrutiny is needed to focus the
attention of industry on its internal production practices and focus the attention of regulatory
agencies on problem areas. This runs counter to the argument heard from some of the less
enlightened industry representatives who claim that, "The public can't understand information
on toxic chemicals given its technical nature; therefore the public does not have the right to
know "
Awareness of TRI needs to be increased. Regulatory officials need to start using it and
citizens need to be made aware of the information in a way that will encourage the use of the
information. The EPA needs to define specific work projects that will increase public
participation. More assistance is also needed to help citizens manipulate and understand the data
with regard to their own neighborhoods. Here is one approach that has been used here in
Chicago. It is a "geographic initiative" at the neighborhood level.
Figure 3 shows the city of Chicago divided by zip code. The total TRI releases for each
zip code have been calculated.
Figure 4 is a bar graph demonstrating a correlation between racial makeup of each zip
code and toxic releases.
We focused in on the areas of highest releases to hold workshops for local residents
regarding local polluters in their areas (Figure 5). At this point input of local citizens has to be
gathered. Instead of using TRI information to create an agenda, we sought to gather the
concerns of local residents and develop strategies that were suitable for each community. The
idea was to open up dialogue between local plant managers and members of the community
concerning pollution prevention planning. Several long-term dialogues have been established
between plant managers and other community members.
One of the lessons learned from this project is that access to the data is still a problem
for citizens. I would argue that the TRI on the National Library of Medicine is too expensive,
complex, and inflexible. The EPA is spending huge sums to provide what is for the most part
industry access to the TRI data. A better model of a user friendly, economical information
system is RTK NET, a computer network run by non-profit groups OMB Watch and the Unison
Institute. My hope is that the EPA will continue its support of this method of disseminating
toxics information.
Proper education of the public will translate into pollution prevention initiatives and help
the EPA improve its enforcement program.
272
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South Cook County Illinois/
Lake County Indiana Toxic Releases
by Zip-Code
D 0 Ibs/yr Q 1 00.000- 1 .000.000 Ibs.
D 1 -99,990 Ibs/yr • greater than 1 .000.000 Ibs/yr
Lak« County
(Q
-------
2000000
1500000
1000000
500000
-------
Chicago Toxics
IMtToxicI
1-88.999 (festyr)
100,000-1.000,000 {Ibs/yr)
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275
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Zip Codes 60608, 60616, and 60623
KEY
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Highway
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SESSION 18
1993 TRI DATA USE CONFERENCE
278
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1993 TRI DATA USE CONFERENCE
CLOSING
SESSION
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1993 TRI DATA USE CONFERENCE
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1993 TRI DATA USE CONFERENCE
The Internationalization
of Citizen Right-To-Know
Frances H. Irwin, World Wildlife Fund-U.S.
Implementing the Rio Commitment to Right-To-Know
The Rio commitment to the right-to-know is quite extraordinary. Public inventories are
mentioned at least half a dozen tunes in Agenda 21's chapter on toxic chemicals. This is a
tribute to the insight and persistence of those who started and continue to build this unusually
effective program in the U.S. It also means that we in the U.S. are likely to learn a lot in the
next few years as other countries make this concept their own.
1. What is WWF Doing to Make the Rio Commitment to Public Inventories Real?
WWF has national organizations or representatives in nearly 40 countries around the
world. World Wildlife Fund is the U.S. affiliate of the international WWF family and is the
world's largest private conservation organization with over 1.2 million members in the U.S.
As part of its mission, WWF works to achieve maximum reduction of pollution as a
means of conserving nature. As one way to do this, WWF is working at both the national and
international levels to spur development of public toxic chemical inventories that:
1) Give businesses the responsibility to provide periodic, multi-media, facility-
specific data on toxic chemicals to the public;
2) Use structured, standardized forms and computer databases that allow data to be
easily analyzed by chemical, industrial sector, and region;
3) Actively disseminate the data to multiple users.
WWF work focuses on the following six areas:
a. Preparation of international guidance. Encourage OECD Pollution Prevention
and Control Group (hi cooperation with several other international organizations)
to develop guidance, called for in Agenda 21, with the three characteristics
outlined above. Such guidance should be prepared with broad participation hi the
process by countries representing the spectrum of economic development and by
environmental and business NGOs. It should develop a core set of data to allow
279
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1993 TRI DATA USE CONFERENCE
comparisons among countries and regions and rough assessments of global
loadings of toxics into the environment. It should include information on
materials flows and source reduction as well as environmental release. Countries
should be encouraged to collect data of particular use beyond the core set.
b. Study on Low-Cost Inventories. Work with Hampshire Research Associates, Inc.,
to prepare and distribute paper called "The Right-to-Know: The Promise of Low-
Cost Public Inventories of Toxic Chemicals" on process of establishing
inventories and the costs of doing so. Paper concludes that with the exception of
the largest countries, most countries could establish an inventory with two
microcomputers and from 5 to 8 people the first year and IVi to 5 people to
operate it in subsequent years.
c. Reporting and Data Management Software. Encourage technical assistance to
support preparation of reporting and data management software to stimulate
smaller countries to establish inventories and ensure comparable data. Study on
Low-Cost Inventories shows sharing costs for such software could reduce the first
year's costs by a quarter to a half.
d. National Inventories. WWF-India will release a feasibility study in April that
examines legal, political, and economic issues involved in establishing a toxic
chemical inventory for India based on the rights of workers and communities to
know. WWF-UK is urging expanded coverage in the UK's planned Chemical
Release Inventory.
e. Inventories in Regional Seas Conventions. WWF-U.S. is working with others in
the Caribbean region to explore opportunities to incorporate the concept of public
inventories for toxic chemicals to stimulate prevention into a protocol on land-
based sources.
f. Source-Based Greenhouse Gas Inventories. Under a German Marshall Fund
Fellowship this spring, WWF Research Fellow Mary Frances Repko will
investigate how greenhouse gas inventories are being developed in Europe and
how they might relate to toxic chemical inventories that are facility-based.
2. What Will the Agenda for an International Conference on Toxic Chemical Inventories Be
In Five Years?
What might the contribution be to this annual conference in three years by people from
other countries? What questions would panelists address at an international inventory conference
in five years? A long-time international organization manager on toxics noted that so far it has
taken 14 years to get the prior informed consent process off the ground internationally and
suggested that toxic chemical inventories should be looked at as requiring a commitment of a
decade. That may be realistic. Where would we like to be half-way into that decade — at a
conference in 1998?
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1993 TRI DATA USE CONFERENCE
1. Will UNEP describe how it is supporting development of inventories and training
for their use as part of its national registers program in 15 to 20 countries? Will
two or three regional centers be providing advice on software for reporting and
data management as well as analysis of the data?
2. Will the guidance developed by OECD be ready for its first revisions after three
years of experience? Will it be time to transfer the discussion to a broader
forum?
3. Will Canada be able to report how including agriculture in an inventory works?
4. Will there begin to be trends analysis of data from the Great Lakes Basin and
from the Mexican border that show how inventories can be used by cross-border
groups?
5. Will Sweden and some other chemical "user" countries explain how including
materials accounting data is working for them and how their system links to their
products register?
6. Will the European Community report on implementation of an inventory directive
and its first analysis of data under it?
7. Will Australia (and several other countries) demonstrate how to include
greenhouse gas emissions in an inventory?
8. Will labor and community leaders from India exchange experience with leaders
from other parts of Asia on using inventories? Will there be similar panels from
other regions?
9. Will panels of users ranging from investors to citizen groups to clean production
advocates suggest how to improve inventories?
10. Will panelists from New Jersey and the United Kingdom exchange perspectives
on the use of inventory data in multi-media permits?
11. Will all major chemical companies publish annual environmental reports that
include facility-specific inventory data about their facilities worldwide? Will
some companies be providing full materials accounting data?
Who will participate in such a conference in five years? Will the technical assistance
community be a major player? What will the balance be among local, regional, and national
level participants? Among business, NGOs, and government? Between data managers and data
users? One could also speculate about the countries that might be competing to host an
international conference on inventories: Australia, Brazil, Canada, Finland, Slovakia, Thailand?
281
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1993 TRI DATA USE CONFERENCE
Inventories clearly have potential. It is probably realistic to think of an embryonic
network of national inventories emerging within five years from which the U.S. will be learning
as well as contributing its experience. However, there are significant barriers to overcome.
How can the right-to-know concept of public accountability as a tool that levels the playing field
within and among communities, governments, and companies itself be translated most
appropriately in other cultures? Where can we find the limited resources needed to provide the
training and to fund the staff and equipment needed to create and operate the systems?
282
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PARTICIPANT
ADDRESSES
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1993 TR1 DATA USE CONFERENCE
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to
oo
Aasen
Actorto
Adamkus
Albino
Alton
Alton
Alvarez
Anderson
Anderson-Labar
Atencto
Ayers
Bailey
Bollard
Balkiz
lanrterman
Bamett
Barney
Barrett
Bash
Bass
Bearden
teeman
Btorman
Bindbeutel
Btoch
Blumberg
Bolka
Bolstridge
Bowen
Boyd
Burke
Bums
Bumskto
Butler
Sapozzoli
Carter
Carter
CarvlUe
Casper
Cheten
Chfsholm
Comal
Cormaughton
Corey
Cummens
Currto
Dale
Damon
Davidson
Davis
Davis
Dawson
Day
Day
DeWull
Devilttor
Oiks
Paul
Leon
Valdas
lyram
Bob
Cathy
ose
Frank
earry
Kathy
Gary
Bonnie
Margaret
Una
Doug
bm
onathan
Rick
antes
Gary
Janet
Perry
Robert
Mark
Pam
Amy
tarry
June
Chris
Ruby
Helen
John
Rob
Craig
Lisa
Keith
Rudolph
Donna
Barry
John
Darren
Andrew
Doraen
Olga
Pat
Robert
Stonewall
Lisa
Rudy
John
Larry
Cheryl
Ron
Susan
Cindy
Patrick
Diane
Dan/1
TITLE
Executive Director
Chief
Administrator
Geologist
Acting TRI Program Manager
Reg. Pollution Prev. Coordinator
Engineer
Technical Assistant
TRI Coordinator
TRI Program Manager
Hazardous Material Planner
Grand Cal Task Force
Chtot of Staff
invironmental Scientist
•wlronmental Consultant
ientor Engineer
Invironmental Chemist
Principal Air Pollution Control Specialist
Associate Director
Executive Director
Chief. Toxics Enforcement Policy Branch
Staff Writer
Senior Environmental Manager
Pollution Prevention Manager
Research Assistant
Senior Environmental Scientist
GIS Analyst
President
Coordinator Waste Minimization
Chief, TRI Systems Section
Chief, Toxics Prevention Section
Projects Officer
Hazardous Material Coordinator
Environmental Specialist
TRI User Support Librarian
Environmental Scientist
3BTAP Program Manager
Responsible Care Manager
Visiting Scholar
Executive Director
Information SepciaHst
Toxics Program Specialist
Research Engineer
Outreach
GIS Manager
Senior Staff Environmental Engineer
Public Relations Consultant
Database Assistant
Environmental Coordinator
EPS
USWA«6787
Documentation Specialist
Environmental Engineer
Economist
TRI Program Coordinator
Environmental Quality Specialist
Environmental Programs Coordinator
Associate
AFFUATION
Minnesota Emergency Response Commission
US. EPA
U.S. EPA, Region V
U.S. EPA, Region II
US. EPA, Region V
U.S. EPA, Region V
The Upjohn Company
U.S. EPA, Region VI
.outelana Dept. of Env. Quality
U.S. EPA, Region VIII
Vyoming Emergency Management Agency
Midwestern Center for Labor Research
daho Emergency Response Commission
.ouisiana Department of Health
National Electrical Manufacturers Association
nland Steel Company
U.S. EPA, Region V
Colorado Department of Health
University ol Illinois at Chicago
OMB Watch
U.S EPA
Des Moines Register
Indiana Dept. of Env. Management
Chrysler Corporation
The Ecology Center ol Ann Arbor
Morton International Inc.
U.S. EPA
GAIA Corporation
Mississippi Dept. of Env. Quality
U.S. EPA
U.S. EPA, Region IX
Mississippi Emergency Management Agency
Umatilla Tribal Rre Department
Ohio EPA
Label-Anderson Inc.
Alabama Emergency Response Commission
New Hampshire Dept. of Env. Services
Dow Chemical USA
University of California at San Diego
Unison Institute
Utah Dept. of Env. Quality
Lake Michigan Federation
Amoco Oil
U.S. EPA
New Jersey Dept. ol Env. Protection and Energy
Baxter Healthcare Corporation
Freeport-McMoRan Inc.
Hazardous Waste Research and Information Center
Amoco Oil
U.S. EPA, Region X
United Steetworkers of America, Local «6787
Morton International
Amoco Oil Company
AM Associates Inc.
Ohio Environmental Protection Agency
Louisiana Dept. ol Env. Quality
Amoco Chemical Company
World Resources Institute
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.AST NAME
Doa
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trufurnlngs
Duffy
Ebemardt
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an
Carat
Katfiy
Pal
Cardan
Georgia
Wlliam
Mary
Robert
Eileen
Bill
Marianne
Elizabeth
Mario
Debra
Rosanne
Gary
Terrence
Doug
OdeNa
Ken
Eileen
Robert
Eun-Sook
Eugene
Joe
George
HM
Daniel
Susan
Kevin
Mark
Richard
Charles
Ruth
Judy
W.James
Loren
Camlte
Stephen
Mel
Guy
Cathy
Abeer
Susan
Rebecca
Mamaret
HUE
'honest
r. Env. Sciences Specialist
Senior Evalualor
Chief, Compliance Evaluation Branch
Manager, Pollutton Prevention Unit
ndustrial Hygierist
ssue Manager SARA/Pollution Prevention
ir. Environmental Specialist
Technical Assistant
Administrative Officer
Chief, TSCA Enforcement & TRI Section
Computer Systems Analyst
Public Affairs
SARA Tide III Program Officer
General Manager
Analytical Services Division Manager
Senior Regulatory Analyst
•nvlronmental Engineer
Evaluator
Attorney
Env. Protection Specialist
Env. Scientist
Cross Media Project Coordinator
Assist. Dlr- Engineering and Enforcement Dry.
Environmental Engineer
Senior Regional Toxfcotogist
Professor
Prof, ot Geography. Dlr. Qrad. Stud.
Chief, Systems Development
Deputy Director
Branch Chief
Director/Professor
Env. Protection Specialist
Environmental Health Consultant
C II ull J 1 1 m*mti*l Pf/^Mj^bm Cf^M*t*ll*»l
ciivuuivnonuu rroiQCiion opvcMitsi
Regional Environmental Officer
Illinois 31 3 Coordinator
QIS Coordinator Water Division
Toxics Policy Director
Co-President
Environmental Analyst
Research Director
Director. OPPT
Environmental Specialist HI
Director, Toxics Reduction Project
Environmental Control Engineer
Research Assistant
Information Systems Developer
Environmental Protection Specialist
Environmental Coordinator
Assist, for Environmental Information
Community Rlght-to-Know Supervisor
GIS Programmer
Program Manager, SARA Title III
Chief, Chemical Control Section
Director
Director
TRI Secretary
MTUATTON
.8. EPA
Environmental Quality Board
.S. General Accounting Office
.8. EPA
Arizona Department of Environmental Quality
E Dept. of Natural Resources and Env. Control
Dow Chemical USA
Oklahoma State Department of Health
U.S. EPA, Region V
Montana Emergency Response Commission
U.S. EPA, Region III
U.S. EPA
(oNer Company
State of Nevada Emergency Management
Pak/ Teem, Inc.
ATEC Associates
Amoco Corporation
Missouri Air Pollution Control Program
U.S. General Accounting Office
U.S. EPA
U.S. EPA
U.S. EPA
Jepartmenl of Environmental Quality
State of Connecticut Dept. of Env. Protection
U.S. EPA. Region V
U.S. EPA, Region III
Ohio State University
University of Illinois - Chicago
(araas Department of Health and Environment
North Dakota Division of Emergency Management
U.S. EPA
UMass-Lowell/Toxics Use Reduction Institute
U.S. EPA
Independent Consultant
U.S. EPA
U.S. Department of Housing and Urban Development
Illinois Environmental Protection Agency
U.S. EPA. Region V
National Environmental Low Center
Sodete pour Valncre la Pollution
VIA Department of Environmental Protection
Citizens for a Better Environment
U.S. EPA
Maine Department of Environmental Protection
Ecology Center of Ann Arbor
Amoco Oil Company
Citizens for a Better Environment
Texas Water Commission
U.S. EPA
Amoco Oil Company
California Environmental Protection Agency
Washington Department of Ecology
Wisconsin Department of Natural Resources
Virginia Department of Waste Management
U.S. EPA, Region V
U.S. EPA
Dept. of Env. and Infrastructure Services
U.S. EPA. Region VIII
TREET
(Ot M Street, SW
.O. Box 11488
ZOO W.Adams
(01 M Street, SW
3033 N. Central Avenue
39 Kings Highway. P.O. Box 1401
2030 Dow Center
000 Northeast 10th Street
77 West Jackson Boulevard
Capitol Station
841 Chestnut BMg.
401 M Street, S.W.
444 Highland Drive
626 South Carson Street
1500 Roc Wield Court
646 Highway Avenue
200 E. Randolph Drive
OS Jefferson Street
200 West Adams
401 M Street, SW
401 M. Street, S.W.
401 M Street, SW
81 1 SW 6th Avenue
65 Capitol Avenue
77 West Jackson Boulevard
841 Chestnut Building
2021 Cottsy Road
Dept. of Geography, Mall Code 183
109 SW 9th
P.O. Box 6611
401 M Street, SW
1 University Avenue
401 M. Street. S.W.
1925 Waveland Avenue
401 M Street, SW
77 West Jackson
2200 Churchill Road, P.O. Box 19276
77 W.Jackson Blvd.
28 Temple Place
445 SI-Francots-Xavier
One Winter Street
407 S. Dearborn
401 M Street, SW
State House Station 17
41 7 Detroit Street
474 West 800 North
3413-F Foxboro Drive
P.O. 80X13087
401 M. Street, S.W.
200 East Randolph Drive
555 Capitol Mall
P.O. Box 47659
P.O. BOX 7921
101 North 14th Street
77 West Jackson Blvd.
913 Forest Terrace
101 N. Fourth Avenue, P.O. Box 8645
4686 South Kalamath Street
CITY
Washington
Santurce
Chicago
Washington
'hoenix
lover
Mktand
Oklahoma City
Chicago
Helena
Philadelphia
Washington
Kohter
Care on City
Cincinnati
Highland
Chicago
efferson City
Chicago
Washington
Washington
Washington
Portland
Hartford
Chicago
Philadelphia
Columbus
Chicago
Topeka
Bismarck
Washington
.owell
Washington
Chicago
Washington
Chicago
Springfield
Chicago
Boston
Montreal, Quebec
Boston
Chicago
Washington
Augusta
Ann Arbor
Salt Late City
Woodrtdge
Austin
Washington
Chicago
Sacramento
Ofympia
Madison
Richmond
Chicago
Annapolis
Ann Arbor
Enolewood
STATE
DC
PR
X
AZ
DE
Ml
OK
MT
PA
DC
Wl
NV
OH
N
to
ta
DC
DC
DC
on
CT
L
PA
OH
L
KS
ND
DC
MA
DC
L
DC
IL
IL
IL
MA
Canada
MA
IL
DC
ME
Ml
UT
IL
TX
DC
IL
CA
WA
Wl
VA
IL
MD
Ml
CO
IP
20460
00910
50606
20460
5012
9903
48674
73117
60604
59620
9107
0460
53044
89710
45241
46322
60601
65102
60606
20460
20460
20460
97204
06106
60604
19107
43210
60660
66612
58501
20460
01854
20460
60613
20460
60604
62794
60604
02111
H2Y2T1
02108
60605
20460
04333
48104
84092
60517
78711
20460
60680
95814
98504
53707
23233
60604
21401
46107
80110
PHONE
202)260-9592
809) 766-2823
312) 220-7719
202)260-3130
602)207-4210
302) 739-4791
517)636-6291
406)271-7353
312)886-1964
406)444-3948
215)597-9937
202) 260-9389
414) 457-4441
702) 687-4240
513)772-4777
219) 972-5252
312)856-6054
314) 751-4817
312) 220-7650
202)260-9501
202) 260-7232
202)260-0030
503) 229-5946
203)566-5369
312)886-6703
216)597-3176
614)292-9826
312)996-3116
913) 296-5659
701)224-3300
202)260-9702
508) 934-3275
202)260-6449
312)935-7794
202)260-3296
312) 886-7353
217) 524-1008
312) 866-5266
617)422-0880
5t4) 844-5477
617)292-5582
312) 939-1 530
;202) 260-3810
(207)287-2437
313) 663-2400
1801) 521-4873
70S) 910-0942
[512)463-8827
(202) 260-3931
(312) 856-4491
(916)324-9924
(206) 438-7252
(608)267-2416
(804) 225-2631
(312)886-1331
(202) 260-1024
(313) 994-6361
(303)294-7682
-------
JUT NAME
Hirtz
Hogner
Hopkins
Howell
Hudson
rwin
Isidore
Jackson
Johnson
Johnson
Joseph
Juras
Jurka
Kaeser
Kagte
Kale
Kate
Kallna
Kanefva
Kean
Kowalski
KraH
KuchdnsH
Kurka
Kuzmack
Lappan
Layne
Leslie
Lewis
Undsey
Loomls
Lopez
Lowery
Luly
Marinilli
Markowttz
Marshall
Martin
McAvoy
McCabe
McCann
McCuftough
McLeod
Mefrakis
Mikol
Miler
Miner
Mitchell
Morton
Mosely
Murdock
Murray
Newburg-Hinn
NlWlng
Nissan
Opperman
Orum
Passow
war
James
Robert
Ed
Ken)
Valerie
Frances
Chris
John
Max
Thomas
Lorenz
Michael
Vtaki
Frederic
Georgia
Jennifer
Jerry
Date
loger
Owen
Mary Ann
Cartel
.aura
Becky
Amok)
Gerald
Warren
Michael
Cynthia
Joel
Jim
Nora
Richard
Keri
Unda
Judith
Michael
Dean
Richard
Ann
Ken
Michael
Walter
Relaat
Yves
Rhonda
Wlllam
Kim
Cheryl
Beverly
Richard
Martin
Steven
Nancy
Nathan
Androw
Paul
Nancy
ULE
313 Coordinator. Region VII
Assoc. Prol. of Business Environment
Environmental Director
Environmental Specialist
Principal AssL/KY THI Coordinator
Director, PolluUon Prevention
Reporter
Past President
Chemical Safety Office Chief
Research Scientist I
Director at Earth Network
Environmental Manager
Member
Env. Project Engineer
Solid Waste Program Specialist
V.P. Training
President
Environmental Supervisor
Environmental Policy Advisor
Manager, Media Relations
Environmental Scientist
Chief, Toxic Substances Section
Environmental Engineer
TRI Coordinator
Senior Science Advisor
Program Analyst
313 Coordinator
Environmental Engineer
Attorney
Institute Manager
Planner (V
Regional 31 3 Coordinator
Environmental Coordinator
PolluUon Prevention Facilitator
Section 313 Enforcement Coord.
Ptttsktent
V.P. -Env.. Health, and Safety
EPCRA Coordinator
Project Manager
Regulatory Issues Manager
Environmental Toxicologist
Member of Faculty
Manager, Pollution Prevention
Environmental Engineer
Dir., Community Env. Programs
Senior Technician)
Env. Emergency Coordinator
Research Assistant
Manager, Government Relations
Public Affairs Specialist
Env. Program Specialist II
Co-Director
Chief, TRI Info. Management Branch
Technical Information Specialist
Supervisor - Hazardous & Solid Waste
Environmental Scientist
Coordinator
Coroorate Manaoer. Env. Allaire
IFFUATtON
U.S. EPA. Region VII
Florida International UnivJCenter for International Business
Citizen Action
Georgia Emergency Planning Division
Kentucky Department for Environmental Protection
Work) Wildlife Fund
Gary Post Tribune
Great Lakes Untied
New Mexico Department of Public Safety
NY State Department of Health
Earth Network
S. Carolina Dept. of Health and Env. Control
Lake Michigan Federation
United Technologies Corporation
Pennsylvania Dept. of Env. Resources
Regulatory Consultants, Inc.
Regulatory Consultants, Inc.
R.R. Donnelley & Sons Company
Illinois EPA
Chemical Manufacturers Association
U.S. EPA, Region V
U.S. EPA, Region II
Amoco OH Company
Texas Water Commission
U.8. EPA
U.S. EPA
U.S. EPA, Region VI
U.S. EPA. Region V
U.S. EPA, Region V
Southern UnrvVlnsl. for Env. Issues and Policy Assessment
Florida Department of Community Affairs
U.S. EPA. Region II
AMOCO Oi Company
Illinois Environmental Protection Agency
U.S. EPA, Region 1
J. Markowttz, Consultants
BF Goodrich
Missouri Department of Natural Resources
B&V Waste Science and Tech. Corp.
Amoco Corporation
Illinois Department of Public Health
Brooklyn College Political Science Department
Chemical Manufacturers Association
Missouri Air Pollution Control Progam
NYC Department of Environmental Protection
McLaren/Hart Engineers Midwest, Inc.
New York State Dept. of Env. Conservation
AM Associates Inc.
SOCMA
U.S. EPA, Region IV
New York Stale Depl. of Env. Conservation
Broken Arrow
U.S. EPA
U.S. EPA
Kohler Company
New Jersey Depl. of Env Protection and Energy
Working Group on Community Right-to-Know
Lonza Inc. (SOCMA)
STREET
726 Minnesota Avenue
CBA/MBE, BA307a
11 20 18th Street, NW
7 Martin Luther Kkj Drive, »1 42
14 Reilly Road
126024th Street, NW
2600 Roosevelt Road
17 Major Street
4491 Ceriltoe Road
2 University Place
1037 South Stone
2600 Bull Street
4622 W. 122nd Street
1 Financial Plaza
P.O. Box 8472
202 N. Morrill
202 N. Morrill
750 Warrenvllle Road
2200 Churchill Road
2601 M Street, NW
77 West Jackson Blvd.
2880 Woodbridge Avenue
2401 5th Avenue South
1700 N. Congress Ave., P.O. Box 13087
401 M Street, SW
401 M Street, SW
1446 Ross Avenue
77 West Jackson Blvd.
77 West Jackson Street
P.O. Box S764
2740 Centervlew Drive
2800 Woodbridge Avenue
200 E. Randolph Drive
2200 Churchill Road
1 Congress Street
8439 W. Catherine
61 00 Oak Tree Boulevard
P.O. Box 176
101 North Wacker Drive
200 E. Randolph Drive
525 W. Jefferson
610E.20thSt. #MH
2501 M Street
206 Jefferson Street
5fi-17Juct!onBlvd.
1000 Town Center
60 Wolf Road
65 Wheeler Street
1330 Connecticut Ave, N.W.
345 Courtland Street
SO Wolf Road
P.O. Box 323
401 M Street, SW
P.O. Box 26227
444 Highland Drive
401 E. State Street
215 Pennsylvania Ave, S.E.
17-1 7 Route 208
CITY
Kansas City
Miami
Washington
Atlanta
Frankfort
Washington
Valparaiso
Kitchener, Ontario
Santa Fe
Albany
La Grange
Columbia
Alsip
Hartford
Harrlsburg
Hiawatha
Hiawatha
Lisle
Springfield
Washington
Chicago
Edison
Texas City
Austin
Washington
Washington
Dallas
Chicago
Chicago
Baton Rouge
Tallahassee
Edison
Chicago
Spring Held
Boston
Chicago
Cleveland
Jefferson City
Chicago
Chicago
Speld
New York
Washington
Jefferson City
Corona
Southlield
Albany
Cambridge
Washington
Atlanta
Albany
Willow Springs
Washington
Denver
Kohler
Trenton
Washington
Fairlawn
STATE
KS
FL
DC
GA
KY
DC
IN
Canada
NM
NY
IL
SC
IL
CT
PA
KS
KS
IL
IL
DC
IL
NJ
TX
TX
DC
DC
TX
IL
IL
LA
FL
NJ
IL
IL
MA
IL
OH
MO
IL
IL
IL
NY
DC
MO
NY
Ml
NY
MA
DC
GA
NY
IL
DC
CO
Wl
NJ
DC
NJ
HP
66101
22199
20036
30334
40601
20037
46383
N2H4R1
87604
12203
60525
29201
60668
06101
17105
66434
66434
60532
62794
20037
60604
08837
77590
7S701
20460
20460
76202
60604
60604
70813
32399
08837
60601
62794
02203
60656
44131
65102
60606
60601
62761
10009
20031
65101
11368
48076
12233
02138
20036
30365
12233
60480
20460
80225
63044
08625
20003
07410
PHONE
(913) 551-7472
(305) 348-2671
(202)775-1680
(404)6564905
(502)664-2150
(202)7784646
(219)881-3127
(519) 744-7603
(606) 827-9223
(518)458-6373
(70S) 352-2923
(803) 935*336
(708)597-0314
(203) 7284394
(717)787-7382
(913)742-3900
(913)742-3900
(708) 7194709
(217) 766-5735
(202) 887-1201
(312) 3534872
(908)3214669
(409)945-1158
(512)463-4119
(202) 260-5821
(202)2604123
(214) 655-7574
(312) 3534680
(312) 886-3542
(504)771-4723
(904) 488-1472
(908)9064890
(312) 856-7505
(217) 624-1846
(617) 565-3276
(312) 6934129
(216) 447-7726
(314)626-3371
(312)683-7837
(312)856-2997
(217)782-5830
(212)254-3582
(202)887-1366
(314)751-4817
(718)505-4431
(313)3584400
(518)457-4107
(617)349-2860
(202) 8224758
(404) 347-1033
(518) 457-2480
(708)8394855
(202) 260-3757
(303) 236-2380
(414)457-4441
(609)633-1154
(202) 546-9707
(201) 794-2701
-------
LAST NAME
'attereon
Peavey
Pack
Pertin
'errodln
Pgraky
Petltjean
Poje
Pope
Pranckevicius
Price
Pridgeon
Puchalsky
Pyrillls
Read
Reck
Read
Raid
Rellly
Repko
Robbins
Rougeau
Satetnik
Sailers
Santos
SaroUn
Sasnetl
Schneider
Schwab
Sellers
Shabazz
Shannon
Shorey
Smith
Smith
Son!
Steinauer
Stlriand
Talbot
Tar anti no
Taylor
Templet
Thielke
Thurber
Tin nay
Titus
Topper
TraJslor
T ravers
Tsal
Tyson
Vail
Vanden Bosch
Waflgett
Walker
WalthaD
Wang
Ward
1H8T
Kym
Dwkjht '
Suzi
Susan
Brian
Harold
Herb
Gerald
Gordon
Pranas
S.Wade
Ronald
Rich
Rita
Norman
Daniel
Phyllis
Fred
Bill
Mary
Donald
Debbie
Jim
Jack
Luis
David
Sam
John
James
Doug
MiKal
Becky
J.Duncan
Anning
Lee Ann
Htten
John
Meade
Thomas
Brian
Wes
Paul
Margaret
Pamela
James
Barry
Henry
Lauren
Linda
Pam
Rae
Janet
Julie
Caryl
Michael
Dennis
Hua
John
ITLE
rogrammer
Rl & 33/60 Coordinator
Xractor, Toxics Use Reduction Implementation
Invlronmental Health Scientist
Invlronmental Engineer
oxlcologlst
=nv. Eng. Tech-31 3 Data Quality Assurance
oxfcologist
Special Advisor
Geologist
ES tntormatlon Systems Supervisor
jivironmentAl Engineer
RTK-NET Research Coordinator
Stafl Consultant
nformation Systems Coordinator
Invfronmental Policy Analyst
Chief, Pesticides & Toxics Substances Branch
Program Assistant
33/50 Coordinator
lesearch Fellow, Pod. Prev. Program
Environmental Sciences Manager
Research Specialist
'echnlcal Assistance Coordinator
'rogram Assistant
Environmental Scientist
Director, 33/50 Program
Chiel. TRI Branch
Environmental Scientist
Senior Research Associate
Chief, TRI Data Administration
TRI Outreach Coordinator
Environmental Specialist
Supervisor, Env. Health and Safety
Environmental Protection Specialist
TRI Coordinator
Environmental Engineer
EPCRA Coordinator (SARA Title III)
Director Environment
Research Scientist
Senior Engineer
Data Integration Project Manager
Associate Professor
Environmental Scientist
Environmental Planning Specialist
Director, Right to Know
Chief. Data Support Section
Industry Uason
Research Assistant
Director. IMD
TRI Program Manager
Environmental Editor
Research Associate
EPRCA Sec. 313 Compl. Coordinator
Research Assistant
Enforcement Counsel for Toxic Sub.
Manager
Project Manager
Program Support Manager
fFUATtON
Arkansas Industrial Development Commission
U.S. EPA, Region I
Massachusetts Dept. ol Env. Protection
U.S. EPA
CIBA-GEIGY Corporation
U.S. EPA, Region III
(entucky Dept. lor Env. Protection
National Inst. ol Env. Health Sciences
4PRI • Environment Canada
Great Lakes National Program Office
Vulcan Chemicals
North Carolina Office of Waste Reduction
Unison Institute
The Bureau ol National Affairs
Oregon Department of Environmental Quality
AM Associates Inc.
U.S. EPA, Region V
U.S. EPA, Region VIII
U.S. EPA. Region III
Work) Wildlife Fund
ASARCO Incorporated
exas Water Commission
Ihode Island Dept. of Env. Management
U.S. EPA, Region VIII
U.S. EPA, Region II
U.S. EPA
U.S. EPA
U.S. EPA. Region V
American Planning Association
U.S. EPA
U.S. EPA, Region III
Missouri Department of Natural Resources
Oglebay Norton Co.
U.S. EPA
Dept. of Env. and Natural Resources
Illinois EPA
Nebraska Dept. of Env. Quality
Echo Bay Management Corporation
New York State Dept. of Health
Merck & Co., Inc.
Wisconsin Department of Natural Resources
Louisiana State University
U.S. EPA. Region V
Office ol Emergency Preparedness (D.C.)
Pennsylvania Dept. of Labor and Industry
Indiana Dept. of Env. Management
U.S. EPA
AM Associates Inc.
U.S. EPA
U.S EPA, Region IX
USATODAY
Grand Valley State University
U.S. EPA
AM Associates Inc.
U.S. EPA
Oregon State Fire Marshal
B&V Waste Science and Tech. Corp.
AR Dent, of Pollution Control A Ecotoov
STREET
State Capitol Mall
One Congress Street
Winter Street
401 M Street, SW
P.O. Box 11
841 Chestnut BMg
4RotllyRoad
9000 Rockville Pike
41 Cite des Jeunes
77 West Jackson Blvd.
Metroplex Drive
3825 Barrett Drive, P.O. Box 27687
731 Connecticut Avenue, NW
824 West 18th Street
81 1 SW 6th Avenue
c/o 361 1 University Drive, Apt. 8A
77 West Jackson Boulevard
988 18th Street
841 Chestnut Street
1250 24th Street, NW
3422 South and 700 West
1 700 N. Congress Ave.
83 Park Street
9991 8th Street
1413 Fernandez Juncos Avenue
401 M Street, SW
401 M Street. S.W.
77 West Jackson Blvd.
1313 E. 60 Street
401 M Street, SW
841 Chestnut BMg.
P.O. Box 176
11 00 Superior Ave.
401 M Street, SW
523 East Capitol
2200 West Churchill Road
1200 N. Street, P.O. Box 98922
5401 Longtoy Lane
2 University Place
One Merck Drive, P.O. Box 100
101 South Webster Street, P.O. Box 7921
42 Atkinson Hall
77 West Jackson Boulevard
2000 14th Street, NW
7th and Forster Streets
105 S. Meridian Street
401 M Street, SW
65 Wheeler Street
401 M Street, SW
75 Hawthorne Street
1000 Wilson Blvd.
Water Resources Institute
401 M Street, SW
55 Wheeler Street
401 M Street, SW
4760 Portland Rd., NE
101 North Wacker Drive
8001 National Drive
CITY
Little Rock
Boston
Boston
Washington
St. Gabriel
Philadelphia
:rankfort
Bethesda
Hull, Quebec
Chicago
iirmlngham
Raleigh
Washington
Chicago
Portland
)urham
Chicago
Denver
Philadelphia
Washington
SaH Lake City
Austin
'rovtdence
Denver
Santurce
Washington
Washington
Chicago
Chicago
Washington
Philadelphia
Jefferson City
Cleveland
Washington
Pierre
Springfield
Lincoln
Reno
Albany
Whitehouse Station
Madison
Baton Rouge
Chicago
Washington
Harrisburg
Indianapolis
Washington
Cambridge
Washington
San Francisco
Arlington
Allendale
Washington
Cambridge
Washington
Salem
Chicago
Utlle Rock
iTATE
AR
MA
MA
D.C.
LA
PA
KY
MD
Canada
L
AL
NC
DC
L
OR
NC
L
CO
PA
DC
UT
TX
Rl
CO
PR
DC
DC
L
L
DC
PA
MO
OH
DC
SD
IL
NE
NV
NY
NJ
Wl
LA
IL
DC
PA
IN
DC
MA
DC
CA
VA
Ml
DC
MA
DC
OH
IL
AR
:B>
72201
02203
02108
20460
70776
9107
40601
20892
K1AOH3
60604
35209
27611
20009
60608
97204
27707
60604
80202
9107
20037
84119
78701
02903
80202
00919
20460
20460
60604
60637
20460
19107
65102
44114
20460
57501
62794
68509
89511
12203
08889
53707
70803
60604
20009
17120
46206
20460
02138
20460
94105
22229
49401
20460
02138
20460
97305
60606
72209
•HONE
501)682-7332
517)565-3230
617)292-6870
202) 260-5877
504)842-1774
215) 697-1260
502)564-2150
301)496-3511
819) 953-1654
312)353-3437
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90S) 302-7820
1608)2644043
;504) 3884428
312)886-6683
1202)72741 61
717) 783-1826
[31 7)2324423
[202) 2604750
(617)349-2860
(202) 260-3939
(415)744-1116
(703)2764424
(616) 8954048
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LAST NAME
Wamock
WesolowsW
Wheeler
Wilkinson
Willams
Wind
Wong
Young
Zarker
FIRST-
Moreen
Dennis
Andrew
Grant
Patricia
Jay
Phil
Steve
Ken
TITLE
Steering Committee Member
Chief, Lab. Scientific Support Section
Special Assistant
Deputy Director ol Legal Affairs
Environmental Specialist
Vice President
Region XTRI Coordinator
Special Assist, lor Env. Info. Integration
Mananer
AFFUATON
Allen County Citizens for the Environment
U.S. EPA, Region V
U.S. EPA
Ohio EPA
Maryland Department of the Environment
American Environmental Institute
U.S. EPA. Region X
U.S. EPA
Texas Water Commission
STREET
1 00 N. Lawn Avenue
536 S.Clark Street
401 M. Street, S.W.
1800 Watermark Drive
2500 Broenlng Highway
61 1 South Ivy Street
1200 6th Avenue
401 M Street, SW
1700 N. Congress Ave., P.O. Box 13087
CITY
Blufflon
Chicago
Washington
Columbus
Baltimore
Arlington
Seattle
Washington
Austin
STATE
OH
IL
DC
OH
MD
VA
WA
DC
TX
ZIP
45817
60604
20460
43215
21224
22204
88101
20460
78711
PHONE
(419) 358-4334
(312)886-1070
(202) 260-3080
(614)644-2782
(410)631-3425
(703)020-5103
(206)553-4016
(703) 235-5503
(512) 463-8032
to
es
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CASSETTE ORDER FORM
1993 TOXICS RELEASE INVENTORY
DATA USE CONFERENCE
MARCH 29-31, 1993 • CHICAGO, ILLINOIS
ALL PROGRAMS ARE $10.00 PER CASSETTE, UNLESS OTHERWISE NOTED
D TRI300 1993 Toxics Release Inventorys
Introduction and Opening Session
$20.00 ... two cassettes
D TRI 301 TRI Links with Voluntary Reporting and
Reduction Programs
D TRI 302 Federal and State Waste Minimization
Data Collection
D TRI 303 Presentation of the Annual EPA Data
Release
D TRI 304 Role of Data Integrity Through
Compliance and Enforcement
D TRI 305 Risk Screening
D TRI 306 Presentation of the Data to the Public
D TRI 307 Local Use of TRI Data
D TRI 308 EPA - State TRI Partnership
D TRI 309 Integration of TRI Data with other
Agency Programs
D TRI 310 Use and Interpretation of Federal and
State Waste Minimization Data
D TRI 311 Future TRI Initiatives
D TRI 312 State Use of TRI Data
D TRI 313 Public Use of TRI
D TRI 314 Integration of TRI Data with Other Data
Sources
D TRI 315 Integrated Data for Enforcement Analysis
(IDEA)
D TRI 316 EPA's Geographic Initiatives
D TRI 317 International Panel, Track Summaries,
and Closing Remarks
$20.00 ...two cassettes
BONUS OPTIONS
BUY 6 CASSETTES RECEIVE THE 7TH FREE!
BUY THE ENTIRE SET OF TRI CASSETTES
RECEIVE A 10% DISCOUNT
AND A FREE STORAGE ALBUM!
HOW TO ORDER:
Check desired cassettes. Fill in information below.
Send to: Teach'em, 160 E. Illinois St., Chicago, IL 60611
or Call: (312) 467-0424 or Toll-Free 1-800-225-3775. Fax:1-312-467-9271
Amount of Order (IL residents add 8.75% sales tax) $_
Foreign Country: Add $2.00 per tape outside the U.S.$_
D Check enclosed payable to Teach'em
Shipping and Handling S $4.00
TOTAL (in U.S. funds) $_
D
D
VISA
MC
NOTE: Defective tapes will be replaced, but tapes are nonreftmdable.
Name:
D AMEX
Title:
$25 MINIMUM ON CREDIT CARD ORDERS
CARD*:
EXPIRATION DATE:
Organization:
Address (NO P.O. Boxes):.
Signature:
City:.
State:
Telephone: (
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