P .

IRI S IRIS NUMBER 69 LAST REVISION DATE 93060 2 UPDATE HISTORY 06/02/93, 2 field s IRIS STATUS Oral RfD Assessment (RDO) on-line 05/01/9 3 IRIS STATUS Inhalation RfC Assessment (RDI) on-line 07/01/92 IRIS STATUS Carcinogenicity Assessment (CAR) on-line 12/01/89 IRIS STATUS Drinking Water Health Advisories (DWHA) no data IRIS STATUS U .S . EPA Regulatory Actions (EXSR) on-line 01/01/9 2 IRIS REVISION HISTORY 03/31/87 RDO Documentation corrected IRIS REVISION HISTORY 03/01/88 RDO Paragraph 2 clarifie d IRIS REVISION HISTORY 07/01/89 CAR Carcinogen assessment now under revie w IRIS REVISION HISTORY 07/01/89 REFS Bibliography on-line IRIS REVISION HISTORY 12/01/89 CAR Carcinogen assessment on-line IRIS REVISION HISTORY 12/01/89 CREF Carcinogen references added IRIS REVISION HISTORY 04/01/90 RDI Inhalation RfC now under review IRIS REVISION HISTORY 06/01/90 RDO Oral RfD summary noted as pending chang e IRIS REVISION HISTORY 06/01/90 RCRA EPA contact change d IRIS REVISION HISTORY 08/01/91 RDO Withdrawn pending further review IRIS REVISION HISTORY 08/01/91 OREF Oral RfD references withdrawn IRIS REVISION HISTORY 01/01/92 EXSR Regulatory Action section on-line IRIS REVISION HISTORY 07/01/92 RDI Inhalation RfC on-lin e IRIS REVISION HISTORY 07/01/92 IREF Inhalation RfC references on-line IRIS REVISION HISTORY 08/01/92 IREF Inhalation RfC references clarified IRIS REVISION HISTORY 10/01/92 RDO Work group review date adde d IRIS REVISION HISTORY 12/01/92 RDO Work group review date added IRIS REVISION HISTORY 05/01/93 RDO Oral RfD summary replaced ; RfD change d IRIS REVISION HISTORY 05/01/93 OREF Oral RfD references replaced IRIS REVISION HISTORY 06/01/93 CREF Minor correctio n RECORD LENGTH 4843 3 NAME OF SUBSTANCE Methyl ethyl ketone (MEK) CAS REGISTRY NUMBER 78-93- 3 SYNONYMS aethylmethylketon SYNONYMS 2-butanone SYNONYMS butanone-2 SYNONYMS ethyl methyl ceton e SYNONYMS ethylmethylketon SYNONYMS ethyl methyl ketone SYNONYMS ketone, ethyl methyl SYNONYMS meetco SYNONYMS MEK SYNONYMS methyl acetone SYNONYMS Methyl Ethyl Ketone SYNONYMS metiletilchetone SYNONYMS metyloetyloketon SYNONYMS RCRA waste number U159 SYNONYMS UN 119 3 SYNONYMS UN 1232

------------------------------------------------------------------------------- REFERENCE DOSE FOR ORAL EXPOSURE o ORAL RFD SUMMARY : Critical Effect Experimental Doses* UF MF RfDp . 2

-------------------- ----------------------- ----- --- --------- Decreased fetal NOAEL : 1771 mg/kg-day 3000 1 6E-1 birth weight (it 2-butanol solution) mg/kg-day Multigeneration/ LOAEL : 3122 mg/kg-day Developmental Rat (201 2-butanol solution) Feeding Study Cox et al ., 1975

------------------------------------------------------------------------------ *Conversion Factors and Assumptions : Based on actual consumption data for the NOAEL and regression analysis for the LOAEL of exposure to 2-butanol, a metabolic intermediate of methyl ethyl ketone .

------------------------------------------------------------------------------- o OPAL RFD STUDIES : Cox, G .E ., D .E . Bailey and K . Morgareidge . 1975 . Toxicity studies in rats with 2-butanol including growth, reproduction and teratologic observations . Food and Drug Research Laboratories, Inc ., Waverly, NY, Report No . 91MR R 1673 . The identification of the critical effect for methyl ethyl ketone (MEK), also referred to as 2-butanone, is based on its metabolic intermediate, 2- butanol
. A detailed rationale for use of this intermediate of MEK can be found in Additional Comments/Studies . Weanling FDRL-Wistar stock rats (30/sex/group) were given 2-butanol in drinking water at 0, 0 .3, 1 .0, or 3 .Ot solutions and a standard laboratory ration ad libitum . Weekly feed, fluid intakes and body weights were recorded to determine the efficiency of food utilization and to calculate the average daily intake of 2-butanol . The average daily intake of 2-butanol for males was 0, 538, 1644, and 5089 mg/kg-day and for females was 0, 594, 1771, .and 4571 mg/kg-day for the 0, 0 .3, 1 .0, and 3 .Ot solutions, respectively . At the highest exposure level (3 .0t), net weight gain was reduced compared with controls both in males (229 g vs . 269 g in controls) and females (130 g vs . 154 g in controls) during the 8 weeks of initial monitoring . However, no differences were found in the efficiency of food utilization . After 9 weeks of exposure, parental matings were made with one male and one female from each of the respective treatment groups (P generation) . Following birth of the first litter (FlA) of the parental generation, various reproduction and lactation responses were measured . This study design incorporated a multigeneration protocol with measurement of developmental toxicity endpoints . Significant effects were noted in the litters from the 3 .Ot 2-butanol dose group vs . the control group, including the number of pups/litter cast alive (8 .46 vs . 10 .3), the number of pups/litter alive at 4 days before culling (8 .12 vs . 10 .3), the number of pups/litter alive at 21 days (6 .85 vs . 7 .68), the mean body weight/pup after culling at 4 days (8 .2 g vs . 10 .3 g) and the mean body weight/pup at 21 days (28 .4 g vs . 49 .5 g) . Based on results found in the 3 .Ot (high-dose) 2-butanol FlA generation, the treatment of all high-dose parents and offspring was reduced to 2 .Ot 2- butanol for the remainder of the experimental protocol . Following a 2-week interim adaptation period to allow the FlA generation animals to attain a more normal weight, the P generation was subsequently remated to produce a second litter (F1B), and the FlA generation selected for an F2 mating . Therefore, a new high dose of 2 .Ot 2-butanol was calculated to be equivalent to 3384 mg/kgday in males and 3122 mg/kg-day in females based on regression analysis of the 8 week water intake data . The FlB litters receiving 2 .0*- . 2-butanol showed a slight reduction in average fetal weight compared with controls (3 .74 g vs .p . 3

4 .14 g in controls) . Nidation, early fetal deaths, and late fetal deaths were not detectably affected . Skeletal findings also were reported for the FiB generation . The 2 .0% group showed apparent increases in missing sternebrae, wavy ribs, and incomplete vertebrae ossification when compared with both the 0 .3 and 1 .0% groups . However, because of the rather high incidence in the control group for these findings, these effects could not be determined to be compound-related . The 2 .0% group also showed a reduction in the mean body weight per pup at day 4 following culling (9 .48 g vs . 10 .0 g in the control) and in the mean body weight at 21 days (34 .9 vs . 41 .1 g in the control) . Although these reductions were not as great in the high dose (3 .0%) FlA generation, the percent body weight reduction in the FlB high dose (2 .0%) was doubled at 21 days (reductions of 5% at 4 days and 11% at 21 days) . This generation showed the same doubling trend in fetal weight reduction as was reported in the FlA group exposed to 3 .0% 2-butanol throughout (reductions of 21% at 4 days and 43% at 21 days) . These results are also presented in abstract form by Gallo et al . (1977) . At the 2 .0% level of the F2 generation, there were a number of histopathologic changes noted in the kidney of the male rats only . These changes were characterized by nonreactive tubular degeneration in the outer medullary zone, tubular cast formation, foci of tubular degeneration and regeneration, microcysts in the renal papilla, glomerular fibrosis, and focal epithelial calcification . These findings are consistent with the pattern of early stages of alpha 2u-globulin-associated rat nephrotoxicity as set forth by the Risk Assessment Forum (U .S . EPA, 1991) . As per the Agency's guidance, it is not appropriate to use these specie-and sex-specific renal effects to establish a critical effect . Administration of 2-butanol resulted in the occurrence of developmental effects . Decreased pup survivability and fetal weight were seen in the 3 .0% group, and in the F1 offspring (FlA and FlB, whose parents received 3 .05 and 2 .0% 2-butanol, respectively) . The decrease in fetal weight continued to be demonstrated in the F2 generation at the 2 .0% level . Therefore, based on these developmental toxicologic endpoints, a LOAEL of 3122 mg/kg-day (2 .0% solution) and a NOAEL of 1771 mg/kg-day (1 .0% solution) are identified .

------------------------------------------------------------------------------- o ORAL RFD UNCERTAINTY
UF -- Four uncertainty factors of 10 each were applied, one to account for interspecies extrapolation and intraspecies variability (extrapolation to sensitive human populations) ; one to adjust for subchronic to chroni c extrapolation since long-term effects in the dams during the exposure period were not reported in the principal study ; one for incompleteness of the data base, including a lack of both subchronic and chronic oral exposure studies for MEK ; and one to account for the absence of data for a second rodent specie for either MEK or 2-butanol . As is usual practice, the application of four full areas of uncertainty generally results in a total uncertainty factor of 3000, given the interrelationship among and overlap between the various areas of uncertainty described above .

------------------------------------------------------------------------------- o ORAL RFD MODIFYING FACTOR
MF -- None

------------------------------------------------------------------------------- o ORAL RFD COMMENTS : Data on toxic effects in humans or laboratory animals following oral exposure to MEK are restricted to a limited number of acute studies . Oral LD50 values for MEK include 5522 and 2737 mg/kg in rats (Smyth et al ., 1962 and Kimura et al ., 1971, respectively) and 4,044 mg/kg in mice (Tanii et al .,,p . 4
1986) Single gavage doses of 15 mmol/kg MEK in corn oil (1082 mg/kg) produced no deaths or histological alterations in the livers of male Fische r 344 rats, but produced tubular necrosis in kidneys (Brown and Hewitt, 1984) . Pre-administration of single gavage doses of MEK (or other ketonic solvents) enhanced the liver and kidney damage produced by a 0 .5 mL/kg intraperitoneal dose of carbon tetrachloride (Brown and Hewitt, 1984) . This MEK potentiation of carbon tetrachloride hepatotoxicity was also observed in similar experiments with male Sprague-Dawley rats (Dietz and Traiger, 1979) . At present there are insufficient oral exposure data of MEK from which to derive an oral RfD . Availability of oral exposure data of a metabolic intermediate of MEK, i .e ., 2-butanol, was used to derive the RfD of MEK . The following is an explanation of the rationale for using the oral data of 2- butanol rather than attempting a route-to-route extrapolation of the available inhalation data for MEK . Traiger and Bruckner (1976) have estimated that approximately 96%~ of an administered dose of 2-butanol is oxidized in vivo to MEK . The data from the Dietz et al
. (1981) study support this estimation . Administration of 1776 mg/kg 2-butanol by gavage shows peak blood 2-butanol concentrations (0 .59 mg/mL) within 2 hours ; the compound is barely detectable after 16 hours . As the blood concentrations of 2-butanol fall, the peak concentrations of MEK (0 .78 mg/mL) and 2,3-butanediol (0 .21 mg/mL) occurred at 8 and 18 hours respectively . Ultimately, 2-butanol and MEK are metabolized through the same intermediates
. Additional metabolism of the ketone occurs by oxidation to hydroxylated intermediates such as 2,3-butanediol, all of which can be eliminated in the urine (DiVincenzo et al ., 1977) . DiVincenzo et al
. (1976) have previously identified MEK, 2-butanol, and other oxidative metabolites of MEK in the serum of guinea pigs following administration of MEK . A pharmacokinetic model was presented by Dietz et al . (1981) to describe the biotransformation of 2-butanol and MEK in rats when given a dose calculated to produce an equivalent calculated adjusted urinary concentration . When MEK is administered by gavage at a dose of 1690 mg/kg, the detection of the formation of 2-butanol and the oxidative metabolites corresponds to that previously reported in the guinea pig . By 18 hours post administration, MEK is barely detectable in the blood (peak concentration of 0 .95 mg/mL at 4 hours), but a peak blood concentration (0 .26 mg/mL) of the oxidative metabolite 2,3-butanediol can be detected . Peak blood concentrations of 2- butanol (0 .033 mg/mL) occurred after 6 hours
. Although it is not known if the effects reported by Cox et al

. (1975) are due to either 2-butanol directly or indirectly through another common metabolite, the weight of evidence of the available data argues for using the butanol data as a surrogate approach to the development of the RfD for MEK . It is assumed in this surrogate approach that 2-butanol is not the active metabolite causing the effects reported by Cox, given the profile of metabolism for both 2-butanol and MEK . Therefore, it is appropriate to utilize data from the oral administration of 2-butanol in order to derive an RfD for MEK in lieu of appropriate oral data for MEK . Decreased fetal body weight was also reported in pregnant mice exposed by inhalation to 0, 398, 1010, or 3020 ppm MEK (0, 1174, 2978, or 8906 mg/cu .m, respectively, assuming 25 C and 760 mm Hg) 7 hours/day during gestational days 6-15 (Schwetz et al ., 1991 ; Mast et al ., 1989) . The only maternal effect observed was a concentration-related increase in relative liver and kidney weight . The difference was statistically significant in the dams exposed to 3020 ppm MEK . The biologic significance of this increase has not beenp . 5
ascertained . The decrease in fetal body weight was observed in the 3020-ppm group, however the difference was statistically significant only in the males . There was a statistically significant (p<0 .05) trend with increasing concentration in the incidence of fetuses with misaligned sternebrae, but this trend was not apparent in the incidence of litters with misaligned sternebrae . Although increased incidence of fetuses and litters with malformations were observed in exposed groups compared with controls, the increases were not statistically significant . The observed fetal malformations (cleft palate, fused ribs, missing vertebrae and syndactyly) present in the exposed groups were not observed in concurrent or contemporary control groups of the same strain of mice . The Schwetz et al . (1991) study identified a NOAEL of 1126 ppm and a LOAEL of 3020 ppm for the occurrence of significant, developmental effects in mice including a decrease in fetal body weight, thereby corroborating the effects observed by Cox et al
. (1975) . Sprague-Dawley rats were exposed to 0, 1126, or 2618 ppm MEK (0, 3320, or 7720 mg/cu .m, respectively, assuming 25 C and 760 mm Hg) 7 hours/day during gestational days 6-15 (Schwetz et al ., 1974) . The following endpoints were used to assess exposure-related effects : maternal (body weight, food intake, liver weight, SGOT levels, number of implantations/litter size) and fetal (examination for anomalies, incidence of fetal resorptions, fetal body measurements) . No maternal effects or effect on the incidence of fetal resorptions were observed . A decrease in fetal body weight and crown-rump length were observed in the 1126 ppm offspring, however, these effects wer e not observed in the offspring of the rats exposed to 2611lenges made to a satura enzymatic detoxification mechanism . Therefore, it cannot be assumed that the pulmonary retention value will be the same at exposures of less than 180 ppm or at greater than 1800 ppm . For this reason, it is inappropriate to estimate the pulmonary retention value at these effect levels, thereby precluding derivation of an oral RfD based upon extrapolation from inhalation effects .

------------------------------------------------------------------------------- o ORAL RFD CONFIDENC E Study -- Low Data Base -- Low RfD -- Lo w Confidence in the principal study is low . The multigeneration/ developmental study for 2-butanol defined a critical effect that is corroborated by inhalation exposure data . Although the study employed an adequate number of animals and examined appropriate endpoints, lowering the high-dose group from 3 .0 to 2 .0% confounded determination of the critical effect . Confidence in the data base is low . This RfD is based on a K in a shor developmental effects as seen by inhalation exposure to MEK . However, the lack of oral data for MEK itself and the absence of data in a second specie precludes any higher level for data base confidence . This assessment for ME K is based upon the strength of data supporting the use of the 2-butanol multigeneration study and the concurrence of developmental effects for inhalation exposure to MEK and assumes that 2-butanol was not responsible for the fetal toxicity . There is a lack of data on the metabolism of 2-roach . Ther

------------------------------------------------------------------------------- o ORAL RFD SOURCE DOCUMENT : Source Document -- This risk assessment is not presented in any existing U .S . EPA document
. Other EPA Documentation -- U .S . EPA, 1984, 1985

------------------------------------------------------------------------------- o REVIEW DATES 06/24/85, 07/08/85, 05/16/90, 07/17/91 , 09/23/92, 11/05/92p . 6

o VERIFICATION DATE 11/05/9 2 o EPA CONTACTS : Kenneth A . Poirier / OHEA -- (513)569-7553 Harlal Choudhury / OHEA -- (513)569-7536

------------------------------------------------------------------------------

-------------------------------------------------------------------------------

------------------------------------------------------------------------------- REFERENCE DOSE FOR INHALATION EXPOSURE o INHALATION RFD SUMMARY : Critical Effect Exposures* UF MF RfC
-------------------- ----------------------- ----- --- ---------- Decreased fetal birth NOAEL : 2978 mg/cu .m 1000 3 1E+O weight (1010 ppm, nominal) mg/cu . m NOAEL(ADJ) : 2978 mg/cu .m Mouse Developmental NOAEL(HEC) : 2978 mg/cu .m Study LOAEL : 8906 mg/cu .m Schwetz et al ., 1991 ; (3020 ppm, nominal ) Mast et al ., 1989 LOAEL(ADJ) : 8906 mg/cu .m LOAEL(HEC) : 8906 mg/cu .m

----------------------------------------------------------------------------- *Conversion Factors : MW = 72 .1 Assuming 25 C and 760 mm Hg . NCAEL (mg/cu .m) 1010 ppm x 72 .1/24 .45 = 2978 mg/cu .m . Currently, the approach for doseresponse analysis of developmental endpoints does not duration-adjust exposure concentrations
. NOAEL(ADJ) = NOAEL = 2978 mg/cu .m . The NOAEL(HEC) was calculated for a gas :extrarespiratory effect assuming periodicity was attained . Since the b :a lambda values are unknown for the experimental animal species (a) and human (h), a default value of 1 .0 is used for this ratio . NOAEL(HEC) = NOAEL(ADJ) x (b :a lambda(a)/b :a lambda(h)) = 2978 mg/cu .m .

-------------------------------------------------------------------------------- o INHALATION RFD STUDIES : Schwetz, B .A ., T .J . Mast, R .J . Weigel, J .A . Dill and R .E . Morrissey
. 1991 . Developmental toxicity of inhaled methyl ethyl ketone in mice . Fund
. Appi . Toxicol . 16 : 742-748 . Mast, T .J ., J .A . Dill, J .J . Evanoff, R .L . Rommereim, R .J . Weigel and R .B . Westerberg
. 1989 . Inhalation developmental toxicology studies : Teratology study of methyl ethyl ketone in mice . Final Report . Prepared by Pacific Northwest Laboratory, Battelle Memorial Institute, for the National Toxicology Program, Washington, DC . PNL-6833 UC-408 . Pregnant Swiss mice were exposed to 0, 398, 1010 or 3020 ppm methyl ethyl ketone (0, 1174, 2978 or 8906 mg/cu .m, respectively, assuming 25 C and 760 mm Hg) 7 hours/day during gestational days 6-15 . The Schwetz et al
. (1991) and the Mast et al
. (1989) reports are the same developmental mouse study presented in different formats and are hence considered as one single study . The number of dams exposed to methyl ethyl ketone ranged from 23-28 mice depending upon exposure group . The dams were killed on gestational day 18 . The only maternal effect observed was a concentration-related increase in relative liver and kidney weight . The difference was statistically significant only in the dams exposed to 3020 ppm methyl ethyl ketone . The biological significance of this increase has not been ascertained . A decrease in fetal body weight was also observed in the 3020 ppm exposed group ; however, the difference was significant only in the males . There was a significantp . 7
(p<0 .05) trend in the incidence of misaligned sternebrae present in fetuses but not reflected in a similar analysis of litters of the animals exposed to 3020 ppm . Additionally, although no significant increase of any single malformation was found, there were several malformations (cleft palate, fused ribs, missing vertebrae and syndactyly) present at low incidences in exposed groups . Neither maternal nor developmental toxicity was observed at exposures at or less than 1010 ppm (2978 mg/cu .m) . At 3020 ppm (8906 mg/cu .m), an equivocal maternal effect was reported ; however, mild developmental effects (decreased fetal body weight and misaligned sternebrae) were found . Based on the absence of both maternal and developmental toxic effects, a NOAEL of 1126 ppm (HEC=2978 mg/cu .m) is established . The LOAEL is established at 3020 ppm (HEC=8906 mg/cu .m) based on the appearance of mild, but significant developmental effects
. Groups of 21-23 pregnant Sprague-Dawley rats were exposed to 0, 1126 or 2618 ppm methyl ethyl ketone (0, 3320 or 7720 mg/cu .m, respectively, assuming 25 C and 760 mm Hg) 7 hours/day during gestational days 6-15 (Schwetz et al ., 1974) . The following endpoints were used to assess exposure-related effects : maternal body weight, food intake, liver weight, SGOT levels, and number of implantations/litter size ; and fetal anomalies, incidence of resorptions, and fetal body measurements . No maternal effects or effects on the incidence of fetal resorptions were observed
. A decrease in fetal body weight and crown-to-rump length was observed in the offspring exposed to 1126 ppm ; however, these effects were not observed in the offspring of the rats exposed to 2618 ppm There were no gross, soft tissue or specific skeletal anomalies that occurred at a significantly increased incidence among litters of dams exposed to 1126 ppm methyl ethyl ketone . However, the total number of litters containing fetuses with anomalous skeletons was increased significantly compared to contr
'ols . In the fetuses exposed to 2618 ppm methyl ethyl ketone, there was a significantly increased number of fetuses and litters having gross anomalies (two acaudate fetuses with an imperforate anus and two brachygnathous fetuses) compared to the incidence among controls . No single soft tissue anomaly occurred at a statistically significant increased incidence, but the total number of litters containing fetuses with soft tissue anomalies was significantly greater than in controls . The study by Deacon et al
. (1981) was conducted to determine the repeatability of the fetotoxic effects observed in the Schwetz et al . (1974) study . Groups of 25 pregnant Sprague-Dawley rats were exposed to 0, 412, 1002 or 3005 ppm methyl ethyl ketone (0, 1215, 2955 or 8861 mg/cu .m, respectively, assuming 25 C and 760 mm Hg) 7 hours/day during gestational days 6-15 . Decreased maternal body weight gain and increased water consumption were observed in the group exposed to 3005 ppm . No other maternal effects were noted . No statistically significant differences in the incidence of external or soft-tissue alterations were observed among exposed fetuses . A significant decrease in the incidence of delayed ossification of interparietal bones of the skull and an increase in the incidence of extra lumbar ribs and in the occurrence of delayed ossification of cervical centra were noted at the 3005 ppm exposure level
.

------------------------------------------------------------------------------- o INHALATION RFD UNCERTAINTY : UF -- An uncertainty factor of 1000 reflects factors of 10 to account for interspecies extrapolation, sensitive individuals, and incomplete data base including a lack of chronic and reproductive toxicity studies
.

------------------------------------------------------------------------------ 4 Z~p . 8

o INHALATION RFD MODIFYING
MF -- A modifying factor of 3 was used to address the lack of unequivocal data for respiratory tract (portal-of-entry) effects . FACTOR

------------------------------------------------------------------------------- o INHALATION RFD COMMENTS : Slight nose and throat irritation was observed in 10 human volunteers exposed to 100 ppm methyl ethyl ketone (HEC=295 mg/cu .m) for 5 minutes
. Exposure to 300 ppm (HEC=885 mg/cu .m) was judged to be intolerable by the subjects (Nelson et al ., 1943)
. Male andters wer e measured for a single exposure concentration . Similarly, 15 guinea pigs were exposed to methyl ethyl ketone at the same concentration as were the rats . No adverse effects were reported for the exposed guinea pigs . However, this information is only presented qualitatively in the report . Furthermore, it was reported that the guinea pigs experienced a vitamin deficiency possibly contributing to two deaths during the exposure period . Male Wistar rats (8/group) were exposed to 0 or 200 ppm methyl ethyl ketone (0 or 590 mg/cu .m, assuming 25 C and 760 mm Hg) 12 hours/day, 7 days/week for 24 weeks . A slight increase in motor nerve conduction velocity and mixed nerve conduction velocity and a decrease in distal motor latency were observed at 4 weeks of exposure . However, no difference was observed after 4 weeks (NOEL(HEC)=295 mg/cu .m] (Takeuchi et al ., 1983) . Groups of 12 Sprague-Dawley rats were continuously exposed to 1125 ppm methyl ethyl ketone (3318 mg/cu .m, assuming 25 C and 760 mm Hg) for 16-55 days . Paicted by peripheral neurotoxins such as n-hexane . Results from other functional-deficit studies in humans (Dick et al ., 1988) have been negative and in baboons (Geller et al ., 1979), inconclusive, perhaps due to experimental design problems . At present, there is no convincing experimental evidence that methyl ethyl ketone, by itself, is neurotoxic to either experimental animals or humans other than possibly inducing CNS depression at high exposure levels . the data base is low . There are n o multigenerational studies and only one subchronic study . Furthermore, these studies do not adequately address portal-of-entry effects given that short-term exposure to higher concentrations than that established for the LOAEL cause nasal and throat irritation in both human and experimental animal species . Reflecting medium confidence in the principal study and low confidence in the data base, confidence in the RfC is low . o INHALATION RFD SOURCE Source Document -- This is not presented in any existing U .S . EPA document
Other EPA Documentation -- Non e DOCUMENT

------------------------------------------------------------------------------- o REVIEW DATES : 04/21/88, 05/26/88, 03/22/90, 05/16/90 , 07/17/91 o VERIFICATION DATE : 07/17/91 o EPA CONTACT S Kenneth A . Poirier / OHEA -- (513)569-7553P . 9

Gary L . Foureman / OHEA -- (919)541-118 3

------------------------------------------------------------------------------- EVIDENCE FOR HUMAN CARCINOGENICITY • CLASSIFICATION : D ; not classifiable as to human carcinogenicity • BASIS FOR CLASSIFICATION : Based on no human carcinogenicity data an d inadequate animal data .
• HUMAN CARCINOGENICITY DATA
None .

------------------------------------------------------------------------------- o ANIMAL CARCINOGENICITY DATA : Inadequate . No data were available to assess the carcinogenic potential of methyl ethyl ketone by the oral or inhalation routes . In a skin carcinogenesis study, two groups of 10 male C3H/He mice received dermal applications of 50 mg of a solution containing 25 or 29% methyl ethyl ketone in 70% dodecylbenzene twice a week for 1 year . No skin tumors developed in the group of mice treated with 25% methyl ethyl ketone . After 27 weeks, a single skin tumor developed in 1 of 10 mice receiving 29% methyl ethyl ketone (Horton et al ., 1965) .

------------------------------------------------------------------------------- o SUPPORTING DATA : .Methyl ethyl ketone was not mutagenic for Salmonella typhimurium strains TA98, TA100, TA1535, or TA1537 with or without rat hepatic homogenates (Florin et al ., 1980 ; Douglas et al ., 1980) . Methyl ethyl ketone induced aneuploidy in the diploid D61, M strain of Saccharomyces cerevisiae (Zimmermann et al ., 1985) . Low levels of methyl ethyl ketone combined with low levels of nocodazole (another inducer of aneuploidy), also produced significantly elevated levels of aneuploidy in the system (Mayer and Goin, 1987) .

-------------------------------------------------------------------------------

------------------------------------------------------------------------------- CARCINOGENICITY ASSESSMENT DOCUMENTATION AND REVIE W o CARCINOGENICITY SOURCE : U .S . EPA . 1985 . Health and Environmental Effects Profile for Methyl Ethyl Ketone . Prepared by the Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH for the office of Solid Waste and Emergency Response, Washington, DC . U .S . EPA . 1988 . Updated Health Effects Assessment for Methyl Ethyl Ketone . Prepared by the Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH for the Office of Solid Waste and Emergency Response, Washington, DC .

The 1988 Updated Health Effects Assessment for Methyl Ethyl Ketone has received Agency review
. DOCUMENT

------------------------------------------------------------------------------- o REVIEW DATES : 05/30/8 9 o VERIFICATION DATE : 05/30/89 o EPA CONTACTSP . 10

Dharm V . Singh OHEA -- (202)260-595 8

-------------------------------------------------------------------------------

------------------------------------------------------------------------------- REPORTABLE QUANTITIE S Value (status) -- 5000 pounds (Final, 1985 ) Considers technological or economic feasibility? -- NO
Discussion -- The final 5000-pound RQ takes into consideration the natural biodegradation of this hazardous substance . The lowest primary criteria RQ for methyl ethyl ketone (1000, pounds based on chronic toxicity and ignitability/reactivity) has been adjusted upward one RQ level . Reference -- 50 FR 13456 (04/04/85) ; 54 FR 33418 (08/14/89)
EPA Contact -- RCRA/Superfund Hotlin e (800)424-9346 / (202)260-3000 / FTS 260-3000

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------------------------------------------------------------------------------- RCRA REQUIREMENT S Status -- Liste d Reference -- 52 FR 25942 (07/09/87 )
EPA Contact -- RCRA/Superfund Hotline (800)424-9346 / (202)260-3000 / FTS 260-3000

------------------------------------------------------------------------------

-------------------------------------------------------------------------------

------------------------------------------------------------------------------- TOXIC SUBSTANCES CONTROL ACT REQUIREMENT S No data available

------------------------------------------------------------------------------

------------------------------------------------------------------------------- ORAL REFERENCE DOSE Brown, E .M . and W .R . Hewitt . 1984 . Dose-respons e REFERENCES relationships in ketone- induced potentiation of chloroform hepato- and nephrotoxicity . Toxicol
. Appl . Pharmacol
. 76 : 437-453 . ORAL REFERENCE DOSE Cox, G .E ., D .E . Bailey and K . Morgareidge
. 1975 . REFERENCES Toxicity studies in rats with 2-butanol including growth, reproduction and teratologic observations . Food and Drug Research Laboratories, Inc . , Waverly, NY, Report No . 91MR R 1673 . ORAL REFERENCE DOSE Deacon, M .M ., M .D . Pilny, J .A . John et al
. 1981 . REFERENCES Embryo- and fetotoxicity of inhaled methyl ethyl ketone in rats . Toxicol
. Appl . Pharmacol
. 59 : 620-622 . ORAL REFERENCE DOSE Dietz, F .K . and G .J . Traiger
. 1979 . Potentiation REFERENCES of CC14 of hepatotoxicity in rats by a metabolite of 2-butanone : 2,3-butanediol . Toxicology . 14 : 209- 215 . ORAL REFERENCE DOSE Dietz, F .K ., M . Rodriguez-Giaxola, G .J . Traiger, REFERENCES V .J . Stella and K .J . Himmelstein . 1981 . Pharmacokinetics of 2-butanol and its metabolites,~,P . 1 1
in the rat
. J . Pharmacokin . Biopharmacol
. 9(5) : 553-576 . ORAL REFERENCE DOSE DiVincenzo, G .D ., C .J . Kaplan and J . Dedinas
. REFERENCES 1976 . Characterization of the metabolites of methyl n-butyl ketone, methyl iso-butyl ketone and methyl ethyl ketone in guinea pig serum and their clearance . Toxicol
. Appl . Pharmacol . 36 : 511-522 . ORAL REFERENCE DOSE DiVincenzo, G .D ., M .L . Hamilton, C .J . Kaplan and REFERENCES J . Dedinas . 1977 . Metabolic fate and disposition of 14C-labeled methyl n-butyl ketone in the rat . Toxicol
. Appl . Pharmacol . 41 : 547-560 . ORAL REFERENCE DOSE Gallo, M .A ., B .L . Oser, G .E . Cox and D .E . Bailey
. REFERENCES 1977 . Studies on the long- term toxicity of 2-butanol . Toxicol
. Appl . Pharmacol . 41 : 135 . (Abstract ) ORAL REFERENCE DOSE Kessler, W ., B . Denk and J .G . Filser
. 1988 . REFERENCES Species-specific inhalation pharmacokinetics of 2-nitropropane . In : Biologically Based Methods for Cancer Risk Assessment, Series 159, C .C . Travis, Ed . NATO Advanced Science Institute . p . 123-1xicol . 452-464 . ORAL REFERENCE DOSE Schwetz, B .A ., T .J . Mast, R .J . Weigel, J .A . Dill REFERENCES and R .E . Morrissey
. 1991 . Developmental toxicity of inhaled methyl ethyl ketone in Swiss mice . Fund
. Appl . Toxicol
. 16 : 742-748 . ORAL REFERENCE DOSE Smyth, H .F ., Jr ., C .P . Carpenter, C .S . Weil, U .C . REFERENCES Pozzani and J .A . Striegel
. 1962 . Range-finding coxicity data : list VI . Am . Ind
. Hyg . J . March-April : 95-107 . ORAL REFERENCE DOSE Tanii, H ., H . Tsuji and K . Hashiomoto . 1986 . REFERENCES Structure-toxicity relationship of monoketones . Toxicol . Lett . 30 : 13-17 . ORAL REFERENCE DOSE Traiger, G .J . and J .V . Bruckner
. 1976 . The REFERENCES participation of 2-butanone in 2- butanol-induced potentiation of carbon tetrachloride hepatotoxicity
. J . Pharmacol . Exp . Ther
. 196 : 493-500
. ORAL REFERENCE DOSE U .S . EPA . 1984 . Health Assessment Document for REFERENCES Methyl Ethyl Ketone . Prepared by the Office of Health and Environmental Assessment, Environmenta l Criteria and Assessment office, Cincinnati, OH for the office of Solid Waste and Emergency Response, Washington, DC . (Final Draft ) ORAL REFERENCE DOSE U .S . EPA . 1985 . Health and Environmental Effects REFERENCES Profile for Methyl Ethyl Ketone . Prepared by the office of Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH for the office of Solid Waste and Emergency Response, Washington, DC . ORAL REFERENCE DOSE U .S . EPA . 1991 . Alpha 2u-globulin : Association REFERENCES with chemically induced renal toxicity and neoplasia in the male rat . Risk Assessment Forum
. Washington, DC . EPA/625/3-91/019F . INHALATION REFERENCE DOSE Altenkirch, H ., G . Stoltenburg and H .M . Wagner . REFERENCES 1978 . Experimental studies on hydrocarbon neuropathies induced by methyl-ethyl-ketone (MEK)
. J . Neurol
. 219 : 159-170 . INHALATION REFERENCE DOSE Broderson, J .R ., J .R . Lindsey and J .E . Crawford
. REFERENCES 1976 . The role of environmental ammonia in respiratory mycoplasmosis in rats . Am . J . Pathol
.p . 12
85 : 115-130 . INHALATION REFERENCE DOSE Cavender, F .L ., H .W . Casey, H . Salem, J .A . REFERENCES Swenberg and E .J . Gralla
. 1983 . A 90-day vapor inhalation toxicity study of methyl ethyl ketone
. Fund
. Appl . Toxicol . 3(4) : 264-270
. INHALATION REFERENCE DOSE Deacon, M .M ., M .D . Pilny, J .A . John, et al
. 1981 . REFERENCES Embryo- and fetotoxicity of inhaled methyl ethyl ketone in rats . Toxicol
. Appl . Pharmacol
. 59 : 620-622 . INHALATION REFERENCE DOSE DeCeaurriz, J ., J .P . Desiles, P . Bonnet, B . REFERENCES Marignac, J . Muller and J .P . Guenier
. 1983 . Concentration-dependent behavioral changes in mic e following short-term inhalation exposure to various industrial solvents . Toxicol
. Appl . Pharmacol
. 67 : 383-389 . INHALATION REFERENCE DOSE Dick, R .B ., W .D . Brown, J .V . Setzer, B .J . Taylor REFERENCES and R . Shukla
. 1988 . Effects of short duration exposures to acetone and methyl ethyl ketone
. Toxicol . Lett . 43 : 31-49
. INHALATION REFERENCE DOSE Geller, I ., E . Gause, H . Kaplan and R .J . Hartmann . REFERENCES 1979 . Effects of acetone, methyl ethyl ketone and methyl isobutyl ketone on a match-to-sample task in the baboon . Pharmacol . Biochem . Behav
. 11 : 401-406
. INHALATION REFERENCE DOSE LaBelle, C .W . and H . Brieger
. 1955 . The vapor REFERENCES toxicity of a composite solvent and its principa l components . Am . Med . Assoc . Arch . Ind . Health . 12 : 623-627 . INHALATION REFERENCE DOSE Mast, T .J ., J .A . Dill, J .J . Evanoff, R .L . REFERENCES Rommereim, R .J . Weigel and R .B . Westerberg
. 1989 . Inhalation developmental toxicology studies : Teratology study of methyl ethyl ketone in mice
. Final Report . Prepared by Pacific Northwest Laboratory, Battelle Memorial Institute, for the National Toxicology Program, Washington, DC . PNL-6833 UC-408 . INHALATION REFERENCE DOSE Nelson, K .W ., J .F . Ege, M . Ross, L .E . Woodman and REFERENCES- L . Silverman . 1943 . Sensory response to certain industrial solvent vapors
. J . Ind
. Hyg . Toxicol
. 25 : 282-285 . INHALATION REFERENCE DOSE Patty, F .A ., H .H . Schrenk and W .P . Yant . 1935 . REFERENCES Acute response of guinea pigs to vapors of some new commercial organic compounds
. U .S . Public Health Reports
. 50 : 1217-1228 . INHALATION REFERENCE DOSE Saida, Kh and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH for the office of Solid Waste and Emergency Response, Washington, DC . CARCINOGENICITY U .S . EPA . 1988 . Updated Health Effects Assessment ASSESSMENT REFERENCES for Methyl Ethyl Ketone . Prepared by the Office of Health and Environmental Assessment, Environmental Criteria and Assessment Office, Cincinnati, OH for the office of Solid Waste and Emergency Response, Washington, DC . CARCINOGENICITY Zimmermann, F .K ., V .M . Mayer, I . Scheel and M .A . ASSESSMENT REFERENCES Resnick
. 1985 . Acetone, methyl ethyl ketone, ethyl acetate, acetonitrile and other polar aprotic solvents are strong inducers of aneuploidy in Saccharomyces cerevisiae . Mutat . Res . 149(3) : 339-351 .p . 13

HEALTH ADVISORY Non e REFERENCES [IRIS] SS 2 /cf? USER :

### p. 14

APPENDIX 1


### 1988 EPA MEMORANDUM FROM J .V. NABHOLZ TO EPA CHEMICAL REVIEW AND EVALUATION BRANCHp . 15
UNITEO STATF-S ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D .C
. ZOAG O



## ~W 2!988 P93TIC30as AONO'"roxic 3W@j'rANCZ2 ~~EXCRANDU M
SUBJECT : Review of Oelisting Petition for Methyl Ethyl Ketone

(,M E K )
FROM : J . Vincent Nabholz, Ph .o .

Senior Biologist Environmental Effects Branch health and Environmenta l Review Division (TS-796) TO : Elbert Dage, M . Engr .

Technical Integrate r Chemical Review and Evaluation Branch Health and Environmenta l Review Division (TS-796)
THRU : James H . Gilford, Ph .D .

Chie f Environmental Effects Branch Health and Environmental Review Division (TS-796) SUMMARY methyl ethyl ketone is a neutral organic chemical used as a solvent ; has low bioconcentration potential ; rapidly evaporates from water and soil ; moderately biodegrades under aerobic conditions in aquatic environments, but is more persistent in aerobic soils ; and shows low toxicity to fish, aauatic invertebrates, and green algae . mammalian and avian acute and chronic toxicity are also expected to be low based on test data for laboratory mammals submitted with the petition
. SUPPOR T
L . Physical/chemical parameters (attributes not referenced were found in the petition) for methyl ethyl ketone are :

CAS#78-93-3 ; Chemical formula : C4 H8 0 ; MW - 72 .11 ; Liquid ; SH20 353 g/L @ 10 C ;

268 9/L @ 29 C (USEPA 1984) ;p . 16

log Kow = 3 .261 (CLOGP V3 .3) ; aCF (fish) = 0 .64 (Clements 1989) ; vow 77 .5 tar : ~2 20C ; Henry's Law Constant = 3 .98X!3-4 atrn-m3/ --nole ; evacaration t 1/2 (rivers) 3 d ; lakes) L d

12 hydrolysis is very slow (US7-pA 1995) ; oxidation (aquatic) is stable (USEPA 1995) ; ulti-nate biodegradation t 1/2 (aerobic) a 5-19 d ; biodegradation (anaerobic) occurs but t 1/2 i s unknown ; direct photolysis t 1/2 = 1 .6 d ; = 13 .4 h (USEPA 1985) ; atmosoheric t 1/2 = 14 In (USEPA 1984)
. 2 . The bioconcentration potential of methyl ethyl keton e is oredicted to be low because of log Kow's and log SCFs of less than one
. 3 . The oersistence of methyl ethyl ketone is .expecied to be low . in the aquatic environment . Methyl ethyl ketone doe s not sorb to suspended particulate matter ; has low bioconcentration potential ; is easily biodegraded under aerobic conditions ; evaporates quickly from water ; and is rapidly degraded in the atmosohere
. Methyl ethyl ketone is more persistent in aerobic sail, but not very much more . Methyl ethyl ketone is very water soluble and does not sorb to soil particles ; it easily travels thru the soil with water to underground aquifers . Methyl ethyl ketone also is known to easily volatilize from soil surfaces and is expected to undergo direct photolysis on or near the soil surface
. 4 . The toxicity of MEK to aquatic organisms is expected to be low . SAR analysis using Clements (1988) predicts to following toxicity values to alga*, daphnids, and fish :

fish (FW) 96-h LC50 2399 . mg/L ; fish (SW) 96-h LC59 239 . ng/L ; fish (FW) 14-d LC50 3299 . mg/L ; fish 28-d BCF 0 .6 4 fish 28-d log BCF -0 .2 daphnid 48-h LC59 Z 2299 . mg/L ; mysid 96-h LC50 = 2390 . mg/L ; daphnid 16-d LC59 99 . mg/L ; daohnid 16-d ECSO 52 . mg/L ; green algal 96-h ECSO logo . mg/L ; and green algal 96-h NEC 260 . mg/L
.

2p . 17

5 . Measured toxicity values support the SAR analysi s ,Fish acute toxicity values (LC_50) 560 to L0,399 mg/L ; invertebrate acute values (LC50) 520 to 8899 mg/L ; and Algal toxicity values >500 mg/i . (as reported in petition) USEPA (1985) reoorted 8-d NECS 06' 129 mg/L for cyanobacteri a and 4309 mg/L for freshwater green algae ; Dojlido (1979) reported an 7-d NOEC of 896 mg/L for the treshwater gree n alga, Chlorella ; Srooke et al . (1984) reoorted a 96-h LC59 for fathead minnow of 3220 . mg/L (flow-through method and measured concentrations) ; and 0ojlido (1979) reported a guppy 24-h LC59 of 5700 . mg/L
. E . Methyl ethyl ketone are not expected to be toxic to wild mammals and birds . The following toxicity information was cited

. . in the petition : small mammal acute inhalation LC59 values from >5000 to 33,099 mom ; rat subchronic (99-d) inhalation NOEL a 1,250 opm ; rat acute oral L059 values from 2 .5 to 5 .6 g/kg ; rabbit acute dermal L050 values form 6 .4 to 8 .0 g/kg ; and rat developmental toxicity (inhalation) NOEL = 1,000 p9m
. 7 . Methyl ethyl ketone is not expected to be toxic to terrestrial plants . Chemically, this compound is a neutral organic solvent and is expected to have very low potency with respect to plant herbicidal activity
. 8 . Comparison of information for methyl ethyl ketone to Toxic Emissions Listing Crit*ria : Sufficient For Listing (Table 1, Clement Associates 1986) and Toxic emissions Listing Criteria : May Be Sufficient For Listing (Table 2, Clement Associates L986) : None of the criteria in Tables I or 2 for : toxicity only ; toxicity and persistence ; or toxicity and bioconcentration were met for the aquatic environment . However, no information about avian toxicity was available and mammalian information was used
. However, for the terrestrial environment, MEK may hav e a half-life of >14 days in aerobic soil, but acute and chronic toxicity values to terrestrial plants and animals are expected to be low
.

3p . 18

REFERENCE S Brooke LT, 0i Call, oL Ceiger, CE Northcott (eds) . L984 . Ac,,Ite toxicities .'Of organic chemicals to fathead minnows (Pimenhales oromelas)
. volume 1 . Superior, WI : Center for Lake Superio,, Environmental Studies, University Of Wisconsin-Superior
. --Lement Associates, Inc
. L986 . Guidelines for human hazard identification for emissions inventory listing . Version 4, dated L2/29/86 . Washington, OC : Clement Associates, Inc

. Ciements RG (ed)

. 1938 . Estimating toxicity of industrial chemicals to aquatic organisms using structure activity relationships . Volume 1 . EPA .-569/6-88-991 . Washington, OC : Environmental Effects Branch, Health and Environmental Review Division (TS-796), Office of Toxic Substances, United States Environmental Protection Agency 20460-9091 . Available from NTIS, Springfield, VA 22161
. oojlido JR

. 1979 . Investigations of biodegradability and toxicity of organic compounds . Cincinnati, O-K : Municioal Environmental Research Laboratory, office of Research and Development, United States Environmental Protection Agency
. EPA-690/2-79-163 . Available from NTIS, Springfield, VA 22161 PS80-17933-6 . united States Environmental Protection Agency (USEPA) . L984
. Health effects assessment for methyl ethyl ketone . Washington, DC* office of Emergency and remedial Response, Office of Solid Waste and Emergency Response
. EPA/540/1-86-993 . Available fram N -11S, Soringfield, VA 2216L . United States Environmental Protection Agency (USEPA) . 1985 . Health and environmental effects profile for methyl ethyl ketone
. Cincinnati, OM : Environmental Criteria and Assessmen t office, Office of Health and Environmental Assessment , office'of Research and Development
. EPA/609/X-85/363 . Available from NTIS, Spzingfield, VA 22161 .

4

### P . 19

APPENDIX J



### TABLE SUMMARIZING ACUTE TOXICITY OF MEK TO AQUATIC ORGANISMSp . 20

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. . . . . . . .. . . . . . . . . ..p . 21

APPENDIX K

EPA MEMORANDUM FROM ACTING ASSISTANT ADMINISTRATOR FOR AIR

AND RADIATION TO EPA OFFICE OF TOXIC SUBSTANCESp . 22 UL,
"If-D ST4" 

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

PA017 

# OCT 18
OFFICE OF MR AND "MIAMON

V 

### MEMORANDUM SUBJECT : SARA 313 Requirements for Ethylene and Propylene FROM : on R . Clay, Acting Assistan t

for Air and Radiation (ANR- 4 TO : 11_~Charles L . Elkins, Director ~m --

Office of Toxic Substances (TS-792 ) I am in complete agreement with your proposal to deny the Chemical Manufacturers Association's petition to remove ethylene and propylene from the reporting requirements of SARA 313 . Ethylene and propylene are both high-volume, reactive volatile organic compounds (VOC's) . Although evidence of direct 'toxicity of these compounds is ambiguous, both compounds have adverse effects on the environment . They are both precursors of ozone, which is one of the most pervasive air pollution problems facing the nation today . Further, both compounds react in the atmosphere to form other compounds, such as formaldehyde, which are toxic . Our current emission inventories of VOC's are of questionable accuracy, being based primarily on source specific activity levels but generic emission factors : knowledge of site specific emission rates for individual compounds would help validate and improve our VOC emission inventories . Also, current VOC emission inventories are often restricted to the immediate vicinity of ozone nonattainment areas : these are of no valu e in assessing the problem of secondarily formed toxic compounds in other areas . Both the regulatory agencies and the public have an interest in emissions of these high-volume VOC's throughout the nation . Despite the foregoing discussion, I do not believe it is necessary or prudent to list all of the thousands of VOC's in SARA 313 . Even that action would not give us a comprehensive VOC inventory, since the majority of the VOC's are emitted by mobile sources and small stationary sources which are not subject to the SARA 313 requirements . I believe the appropriate balance is nearly achieved in the current 313 list, which contains most of the high-volume reactive VOC's . We can refine that balance, and correct any anomalies, on a case-by-case basis in the future .

### p. 23

2 

## We, and the publi-c, are interested primarily in high releases o f VOC's to the environment . High production volume is not a perfect surrogate for high releases ; but, based on our current knowledge, I believe it is an adequate surrogate and is probably the best that is reasonably available . We may want to revisit this issue in several years after we (and the public) have gained some experience with use of the SARA 313 data
. cc : Mike Shapiro, OTS Di ck Rhoads, OAQPS Jeanette Wiltse, OAR

### p. 24

APPENDIX 1 , 

### EPA TRI INFORMATION COLLECTION REQUEST REPORT (EXCERPTS)

### p. 25

TO)aC CHEMICAL RELEASE INVENTORY EXPANSION OF THE LIST OF INDUSTRIAL GROUPS SUBJECT TO REPORTING UNDER SECTION 313 OF EPCRA



### INFORMATION COLLECTION REQUEST AMENDMENT

SUPPORTING STATEMENT (EPA#1784 .01 ) June 27,1996

CONTENTS 

### I (a) Title of the Information Collection Request I (b) Short Characterization 2 NEED FOR AND USE OF THE COLLECTION 2(a) Need/Authority for the Collectio n 2(b) Use/Users of the Data Use of the Data by the Office of Pollu tion Prevention and Toxics Use of the Data by the Office of Air and Radiatio n Use of the Data in Enforcement Activitie s Use of the Data by the Office of Solid Waste and Emergency Response Use of the Data by the Office of Wate r Use of the
'Data by Community and Public Interest GROUP S Use of the Data by National, State, and Local Government Agencies Use of the Data by the Financial and Business Communities Use o * f the Data by the Regulated Community Use of the Data by the States Use of the Data by Education and Research Institutions 3 THE RESPONDENTS AND THE INFORMATION REQUESTED 3(a) Respondents/SIC Codes 3(b) Information Requested (1) Data Items Reporting Requirements for Form R Reporting Requirements for Toxic Chemical Release Inventory Certification Statement Recordkeeping (ii) Respondent Activitie s 4 THE INFORMATION COLLECTED--AGEN(tY ACTIVITIES, COLLECTIONp . 26

METHODOLOGY, AND INFORMATION MANAGEMENT 4(a) Agency Activities 4(b) Collection Methodology and Management 40 Small Entity Flexibility 4(d) Collection Schedul e 5 NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 5(a) Nonduplicatio n Fugitive/Non -'Point Air Emissions and Stack/Point Air Emissions Direct Discharges to Receiving Streams or Water Bodies Underground Injection and Land Disposal On-Sit e Discharges to a POTW Transfers to Other Off-Site Locations Review of State Right-to-Know Programs Inventory Data Pollution Prevention Data 5(b) Consultations 50 Effects of Less Frequent Collection 5(d) General Guideline s 5(e) Confidentiality and Sensitive Questions (i) Confidentiality (ii) Sensitive Questions 6 ESTIMATING THE BURDEN AND'COST OF THE COLLECTION 6(a) Estimating Respondent Burden 6(b) Respondent Costs 60 Estimating Agency Burden and Cos t 6(d) Bottom Line Burden Hours and Costs/Burden Tables 6(e) Reasons for Change in Burde n 6(f) Burden Statement ATTACHMENT S A Relevant Statutes (EPCRA Section 313 and PPA Section 6~07) B Current Information Collection Requests (ICR # 13 63 and ICR # 1 704) C EPA Forms (EPA Form R and Toxic Chemical Release Inventory Certification Statement D TRI Chemicals Reported to Non-TRI Databases and Public Access to EPA Databases E State TRI Program Assessmen t F EPA Outreach Activities

-ii-

### p. 27

facilities in their area release, transfer, or otherwise manage as waste-, industries will have an additional tool for monitoring efficiency and progress on their pollution prevention goals

. 

### The burden estimates contained in this ICR relate to the burdens that would be imposed if the proposed amendments are finalized as currently presented . These estimates are based on an extensive analysis of the individual industrial groups, which can be found in the Regulatory Impact Analysis that is included in the docket for the proposed facility expansion rule . The addition of the industrial groups identified above is anticipated to generate an estimated 33,463 additional Form R reports and an additional 4,251 Certifications, The proposed rule would result in an estimated 6,428 additional respondents . This will involve a total incremental burden of approximately 3 .1 million hours in the first year and 1 .9 million hours in subsequent years, at a total cost of $191 million in the first year and $119 million in subsequent years . Facility owners and operators affected by this proposed rule will be subject to : determining the need to comply with the statute, familiarizing themselves with the reporting package and reporting requirements, calculating the requirp,4 data, completing and submitting the appropriate reportin& form, and maintaining the necessary records and documentation . Included in the Form R completion and associated recordkeeping estimates provided in this ICR is the information required to be collected on Form R as mandated by section 6607 of the PPA

.

Once EPA issues a final rule, these burdens will be adjusted as appropriate and would need to be added to the existing burdens associated with overall TRI reporting and recordkeeping (i .e., associated with both Form R and the Certification) . As such, EPA would need to amend both of the existing ICRs to include this new burden . Specifically, EPA would amend the Certification ICR (EPA ICR # 1 704) by submitting an Information Correction Worksheet to ONIB that adjusts the burden hours associated with that ICR to include the new burden hours imposed bythefinalrule . In addition, EPA would also need to amend the Form R ICR (EPA ICR#1363) to include the increase in burden hours associated with that ICR to include the new burden hours imposed by the final rule . However, since OMB's approval of an amended Form R ICR would serve as a replacement to the current Congressional Approval, EPA will need to submit a new Form R ICR to ONM that reflects all the burden amendments that have been made to date, as well as those associated with the final rule

. Given this inter-relationship between this ICR and the two existing TRI ICRs, EPA has included copies of the last OMS-approved ICRs for the Form R ICR (EPA ICR #1363) and the Certification ICR (EPA ICR 91704), see Attachment B . In addition, in order to assist the public in commenting on the burdens contained in this ICR amendment, as they relate to existincy burdens, EPA has included a discussion of the final net burdens associated with the overall TRI reporting and recordkeeping requirements (i .e ., associated with both of the existing forms)

. In accordance with OMB regulations at 40 CFR § 1320 . 11 (b), this proposed ICR will be submitted to ONS no later than the day upon which the proposed rule is expected to publish in
-3-p . 28,

the Federal Re2ister, which is expected to be on June 27, 1996 . Un'der 40 CFR § 1 '20

. 11 (c), within 60 days of the proposed rule's publication, but not before 30 days, OMB may file public comments on the ICR . These comments will be submitted to the Agency in the form of an OMB Notice of Action and will be made part of the Agency's rulemaking record . Since OMB's action at the proposed stage is to provide comments on the proposed ICF, ONM's action will not have any effect on the current approvals for the existing requirements . In fact, the approval for the Form R ICR (EPA ICR 9 1363) will remain in effect until EPA finalizes the proposed amendments referenced in this ICR, or otherwise promulgates changes to the Form R and instructions, and the approval for the Certification ICR (EPA ICR#1704) will remain in effect until September 30, 1996 or in accordance with OMB's approval of the renewal request which is expected to be submitted to ONM by July 3 1 . 2 NEED FOR AND USE OF THE COLLECTION 2(a) Need/Aut' ;ority for the Collectio n EPA believes that expanding the universe of industrial groups required to report will provide citizens with a more complete picture of chemical impacts on their communities and help focus these industries' attention on pollution prevention and source reduction opportunities

. EPA believes the public has a right-to-know about releases from facilities in these industrial groups and what facilities are doing to manage wastes containing toxic chemicals

. Although current TRI reporting has been successful in providing communities with important information regarding releases and transfers of toxic chemicals, this information has not provided a complete picture . EPCRA section 313 facility coverage is currently limited to facilities in the- manufacturing sector, i .e ., in SIC codes 20 through 39. According to the Department of Commerce, facilities currently covered by EPCRA section 313 account for only 0 .4 percent of the facilities in the United States . And .in 1989, the Office of Technology Assessment estimated that the TRI represents 5 percent of toxic releases to the environment . Adding non-manufacturing industries to the EPCRA section 313 list of facilities will provide basic information to millions of Americans on releases and other waste management information on toxic chemicals from additional industrial facilities in their communities

. EPA is proposing this addition of industrial groups under section 313(b)(1)(B) of EPCRA (42 U .S .C . 11013(b)(1)(B))
. Under 313(b)(1)(B), the Administrator of EPA has the authority to add SIC codes as long as their addition is "relevant to the purposes" of EPCRA section 313 . Under EPCRA section 313(h), submitted data are intended to "inform persons about releases of toxic chemicals to the environment ; to assist governmental agencies, researchers, and other persons in the conduct of research and data gathering, to aid in the development of appropriate regulations, guidelines, and standards ; and for other similar purposes

. " Section 6602 of the PPA establishes a national policy that pollution should be prevented or reduced at the source whenever feasible . To further this goal, EPA is to establish a source
-4-

### p. 29

reduction program which, among other responsibilities, is to collect and disseminate information

. The information collected under section 6607 is intended to fulfill that responsibility in part and to provide a basis for measuring progress in pollution prevention in certain industrial groups

. 

### 2(b) Use/Users of the Data The data collected under EPCRA section 313 and section 6607 of the PPA is required to be made available to the public . In addition to EPA making the data available through NLllvfs TOXNET, TRI data are available through the Community Right-to-Know Network (RTK Net), which is supported by the Unison Institute, a non-profit public interest group . The use and users of the data collected on the new facilities will generally be similar as for the manufacturing facilities already reporting . Since EPA first made the TRI data available in April 1989, it has been used by extensively by EPA and numerous other institutions . Environmental groups, public interest research groups, industry, journalists, individuals, and state, county, and local governments have used TRI for various analyses . At least 22 states produced an annual report

. The following are some examples of how the TRI data are used, both by EPA and others

. Use of the Data by the Office of Pollution Prevention and Toxics With the voluntary cooperation of respondent facilities, EPA has established the Industrial Toxics Project, also known as the 33/50 Program . EPA's 33/50 Program targeted 17 priority TRI chemicals for ernissions reductions of 33% by 1992 and 50% by 1995, from 1988 levels . More than 1200 companies nationwide have joined this program . The program provides recognition to participating companies, including Certificates of Appreciation to all companies upon enrollment, as well as Certificate's of Environmental Achievement to a select group of facilities that have achieved noteworthy reductions . The program reached its interim 33% reduction goal one year early, and reductions by 1993 totaled 46%

.
The Office of Pollution Prevention and Toxics'(OPPT) Existing Chemicals Program continues to use the TRI data for risk screening, determining testing needs and priorities, and considering and developing pollution prevention activities . TRJT data serve as a major input to exposure and risk assessments in OPPT . The TRI is especially important to OPPT's new initiatives on pollution prevention . TRI data are used for targeting chemicals, uses, and facilities for pollution prevention assessment and for evaluating pollution prevention actions . TRI data also are used in OPPT outreach efforts in responding to inquiries from a variety of sources

. OPPT"s Environmental Assistance Division (EAD) has developed software that contains health and ecotoxicity information on most of the section 313 chemicals . This software, called PC-TRIFACTS, enables the TRI data user to better understand the potential health and ecological effects of chemical releases identified in the TRI . TRIFACTS was made available in January, to a wide audience of TRI data users, and has had a very positive response

. -5-p . 30

From 1989 to 1991, OPPT has prepared annual reports that summarize and compare current and historical TRI data . Beginning in 1992, the TRI data are presented through annual comprehensive data releases . Also, EAD develops two summary reports to distribute to the public at the time the complete national TRI database is first released . One report summarizes the national TRI data, while another report provides more detailed information on a state-by-state basis . These reports help raise public awareness of the TRI data and provide ready access to aggregate information that facilitates tracking of national, state, and industry progress in reducing emissions . Many states prepare similar summary reports for their TRI data each year
. OPPT's Pollution Prevention Division (PPD) has used TRI data as a screening tool to prioritize proposed regulations and industrial source categories to promote pollution prevention in rulemaking . As a result, the Pollution Prevention Senior Policy Council has identified a number of regulatory development efforts that should consider inclusion of pollution prevention measures

. Furthermore, PPD has used the TRI data to conduct a study of the reported differences in releases of TRI chemicals from 1989 and 1990 . The study has helped to indicate the relative effect of source reduction, recycling, treatment, production level, and data estimation techniques on the reported change in releases and/or transfers between the two years . This project is being used to further develop the methodology to assess changes over time using the waste management and source reduction data that have become available from the 1991 reporting year

. OPPT is nearing completion of its TRI "Environmental Indicators Model", which provides year-to-year indicators of the potential impacts of TRI chemical releases on human health and the environment . The indicators consider TRI release and transfer volumes, chronic toxicity, exposure potential, and size of receptor populations . Both generic and sitespecific exposure characteristics can be incorporated . The model will allow targeting and prioritization of chemicals, industries and geographic areas . Facility scores also may be tracked from year to year to analyze trends

. Use of the Data by the Office of Air and Radiatio n The Office of Air and Radiation (OAR) has used the TRI data for a variety of tasks related to the implementation of the Clean Air Act Amendments of 1990 (CAAA)
. Title III of the CAAA requires EPA to develop Maximum Achievable Control Technology (MACT) standards for major sources of 189 hazardous air pollutants, all but 16 of which were on the TRI list of toxi c chemicals prior to EPA's expansion of the EPCRA section 313 list of toxic chemicals . TRI was used to estimate the number of major sources (greater than 10 tons per year of any single hazardous air pollutant or 25 tons per year of total toxics) of hazardous air pollutants in each of 700 source categories . This information helped to prioritize the source categories for regulatory development . In addition, the impacts of a potential lower major source definition for 47 highly toxic compounds also were analyzed using TRI data

.

-6-p . 3 1

TRI was used to help identify the 30 hazardous air pollutants to be included in the Urban Area Source Program mandated by Section I I 2(k) of the CAAA
. OAR also has used TRI to expand the coverage of our "Locating and Estimating" series of documents, which help State and local air agencies identify potential source categories of air toxics in their communities . Similar data have been incorporated into the Crosswalk database, which identifies which source categories emit which toxic compounds . OAR is developing a series of air quality indicators to track progress in implementing the CAAA
. Trends in the TRI data are envisioned to be a part of those indicators , Use of the Data in Enforcement Activities The Office of Enforcement and Compliance Assurance (OECA), and EPA Regions continue to use TRI data as a tool in inspection targeting and enforcement . In addition, TRI data are constantly evaluated with an eye towards sector-wide EPCRA initiatives . Finally, the data are included in a new enforcement database system which is being used to develop and implement multi-media/multi-statute cases and initiatives

. OECA cross-checks data collected under EPCRA and other environmental statutes to identify those facilities or types of businesses which reported for some but not all of the reporting rules . Enforcement personnel are able to identify additional facilities owned by the same corporation or by the same parent company that may be subject to liability, by using TRI data and the Facility and Company Tracking System (FACTS)
. OECA uses the TRI data in its EPCRA Targeting System (ETS), which provides local access to TRI and FACTS data for all facilities subject to EPCRA section 313 requirements

. ETS supports creation of prioritized inspection targeting lists, generated from a wide array of selection criteria, and daily targeting activities such as contacts with facilities and tracking tips an d complaints . Currently, nine out of ten Regional field offices have been introduced to this new system

. OECA also uses TRI data through the Integrated Data for Enforcement Analysis (IDEA) System

. IDEA provides integrated data on individual facilities' compliance records for most of the statutes administered by EPA through access to approximately ten separate databases , including the Toxic Release Inventory . System (TRIS) . The TRI data aid OECA in developing enforcement initiatives .by providing a point of departure for distinguishing between industrial sectors based on potentia l TRI data continue to be extremely helpful in identifying pollution prevention projects

. Enforcement staff use data on releases and transfers to identify (or evaluate) projects that will significantly reduce emissions, or those that will help prevent or minimize the release of extremely hazardous substances under EPCRA section 302 . OECA places a high priority on enhancing the use of TRI data among Regional field personnel . Additional guidance has been provided during FY1996 to the field offices on the

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'lable to their inspectors in identify* it y 

### resources aval I I i ing non-reporters, late reporters and data quali errors . These resources provide the inspectors with valuable information extrapolated from the Toxic Release Inventory, such as facility reporting rates, processes, and releases

. Use of the Data by the Off-ice of Solid Waste and Emergency Respons e TRI data may assist in priority setting for waste minimization efforts by the Office of Solid Waste and Emergency Response (OSWER) . In combination with other information OSWER collects on waste minimization, TRI data are useful in analyzing long-term trends and identifying particular industry practices that warrant attention by the program . These are some of the ways in which TRI data can serve OSWER pollution prevention goals

. With respect to enforcement, TRI data supplement other existing data sources and can be called on to assist in the development of OSWER enforcement priorities . TRI data also are valuable as a means tr -1 .ssist in establishing liability under both the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) and the Resource Conservation Recovery Act of 1976 (RCRA) statutory authorities

. ' Another site-specific function of the TRI database relates to its role in providing emission information that can be used when developing emission inventories for the Superfund site discovery program and when undertaking Superfund preliminary assessments of sites . In the reportable quantity (RQ) program, TRI data could be used in analysis to support future rulemaking under CERCLA (e .g . designation of additional hazardous substances) . In addition, states will be using the TRI data in conjunction with other data obtained under EPCRA for accident prevention planning

. Use of the Data by the Off-ice of Wate r The Office of Water (OW) has used TRI data for identifying candidat

,es for the National Primary Drinking Water Regulations . Chemicals were identified-that had a dramatic overall increase (doubling or more) of discharges and releases . These discharges and releases were considered to have direct potential for drinking water contamination and are good candidates for development of regulatory controls

.

. TRI data were used as a screening mechanism for possible sources of wellhead contamination . Using TRI and other relevant data in a Geographic Information System (GIS) potential contamination'sources have been identified . These sources may affect community ground-water systems in the development and implementation of wellhead protection programs

. Regions are continuing to coordinate ground-water programs, using GIS as a cross-program tool

. OW also is using the TRI data in development of management plans to identify the sources of toxic discharges into selected estuaries and coastal waters . In addition, the data are

-8-p . 33

being used to identify sources of toxic discharges that may contaminate sediments that are proposed for ocean dumping

. Under the Watershed Protection Approach, the Regions are using TRI data along with other data in assessing loadings to their watersheds . They are identifying multimedia sources of toxic discharges to receiving waters

. Office of Water Enforcement and Compliance (OWEC) identified industrial users with the greatest contribution of toxic pollutants to city sewer systems . The industries were identified and facility names were provided to the Regions for further evaluation

. OWEC used TRI data to identify industrial users subject to pretreatment standards that are located in cities which are not required to have pretreatment programs . Further work will compare location of users to cities without approved pretreatment programs and may be a way of identifying industrial users for which EPA has regulatory responsibility. The data also w,

. - used in compiling the Report to Congress on -the Nation~l Pretreatment Program

. The data and analysis were used to examine what the next steps of the national pretreatment program should be . TRI data were used in providing a broad picture of the types and sources of pollutants discharged to POTWs, and in setting priorities

.

. OW used TRI data to understand which pollutants are released from pesticide manufacturing facilities and the pattern of releases when developing effluent limitations guidelines and standards for an industrial category . However, the Effluent Guidelines Program screens for a number of pollutants not in TRI . Many pollutants and industries that ,krill be addressed by effluent guidelines are currently reported in TRI

. OW used TRI data and other water emissions data in its National Sediment Contaminant Source Inventory, an evaluation of sources of sediment contamination in the U .S
. This project identified point source pollutant discharges that may result in sediment contamination an d analyzed these releases based on their potential sediment hazard . Chemical release amounts were weighted by the compound's relative toxicity to aquatic or human health-, as well as relevant fate and transport factors . The study identified chemicals, geographic areas, and industrial categories of greatest concem for sediment contamination

. Use of t : .e Data by Other EPA Offices and Region s Three EPA Regional offices are developing a screening process that will allow decisionmakers to focus pollution prevention efforts, exposure and risk assessments, or epidemiological studies on areas of greatest concern . The first phase of the process produce~ a "Chronic Index" which ranks TRI releases in terms of their relative toxicity . The results of this Index ar e aggregated by facility, by chemical, and by geographic area using a grid system . The second phase of the process, now under development, will produce a "Vulnerability Index", which

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### p. 34

describes the susceptibility of populations by scoring demographic attributes such as age , 

### economic status, and minority status

. Researchers from EPA's Office of Health Research recently published a study of national and regional differences in county-level TRI air emissions according to the ethnicity or race and household income of the populations . Using a measure known as a "Population Emissions Index", a population-weighted average emission for each county, the study found that all minority groups except Native Americans tend to live in counties where TR_1 air emissions levels are higher than they are in counties where whites live . However, the data also suggest that household incomes tend to be higher in counties with higher TRI air releases
. EPA!s Office of Information Resources Management sponsored the development of a Population Estimation and Characterization Tool, which uses GIS technology and demographic data for fisk-based and environmental justice applications . The too] allows users to estimate and characterize populations within a given radius of a single TRI facility or multiple facilities and to identify areas of multiple potential exposure

. EPA's Office of Research and Development and Office of Enforcement and Compliance Assurance are developing a "Multi-Media Ranking System" to prioritize sites for enforcement actions and to evaluate the effectiveness of environmental laws in reducing risks from sites . The system ranks sites based on their multi-media releases of pollutants, their potential risk to human health and the environment, and the history of legal violations by the'facility . The system combines TRI data with data from EPA air and water databases . For each site, the system develops a Chemical Ranking Factor based on chemical toxicity and fate information, a Vulnerability Ranking Factor based on the climate, soil type, and other environmental properties surrounding the site, and a Population Ranking Factor based on the demographic characteristics surrounding the site

. Use of the Data by Community and Public Interest Group s Communities use TRI data to begin dialogues with local facilities and to encourage them to reduce their emissions, develop pollution prevention plans, and improve safety measures

. Public interest groups use the data to educate the public about toxic chemical emissions and potential risk

. A bibliography prepared by the Working Group on Community Right-to-Know i n the summer of 1994 lists well over 100 state and local reports and more than 30 national TRI reports compiled by public interest groups (Orum and Wohlberg, 1994)

. A few of these reports, and other activities conducted by public interest groups, are described below

. "Manufacturing Pollution", a report produced by Citizen's Fund in August 1992, aggregated 1990 TRI data from different facilities by their parent company, in order to hold corporations more accountable for the full extent of their toxic pollution . The report summarized releases of all TRI chemicals, as well as subsets of chemicals that could cause cancer or birth defects (Citizens Fund, 1992)
. _10-p . 35

"Poisons in Our Neighborhoods", a report produced by Citizen's Fund in November of 1993, summarized 1991 TRI data nationally and by state . The report attempted to measure the progress of manufacturers in preventing pollution and included report cards evaluating the pollution prevention efforts and performance of the top 50 waste generating facilities in the chemical industry (Citizens Fund, 1993)
. "Troubled Waters : Major Sources of Toxic Water Pollution", a report released by the U .S
. Public Interest Research Group in June 1993, examined TRI releases to surface waters and to publicly-owned sewage treatment plants and identified the nation's top releasers of toxics to those water sources . The report made recommendations for amending the Clean Water Act to provide the public more information about toxic releases to waterways and to strengthen enforcement (Hartmann, 1993)
. "Where the Wastes Are", a report released by OMB Watch and the Unison Institute . in April 1994, examines facilities receiving the largest quantities of shipments of TRI chemicals in waste . The report identifies the largest off-site recipients overall and in particular categories, such as incinerators and landfills . The report also profiles certain companies active in the operation of these toxic waste management facilities (MacLean and Puchalsky, 1994)

. The Georgia Environmental Policy Institute provided TRI data to a family in southwest Georgia who needed information about toxic releases from a nearby plant to assist their doctor in determining the need for medical testing . Following an incident and evacuation, this same group also provided TRI data to a citizen who inquired about toxic releases from a plant located next to a school .(McLure, 1994)

. After an analysis of 1987TRI data revealed that an IBM plant in the "Silicon Valley" area discharged the largest quantities of ozone-depleting chlorofluorocarbons (CFCs) in Califomia, a public interest group organized a campaign to reduce those emissions

. Within months, senior management at IBM had pledged to completely eliminate the use of CFCs in their products and processes at the plant by 1993 (Tryens el al ., undated)

. Following the release of an environmental gr oup's report identifying a local facility as the 45th 4argest emitter of carcinogens to air in the nation, community activists in Northfield, Minnesota worked with the Amalgamated Clothing and Textile Workers Union to call for emissions reductions . Contract negotiations between the union and the facility resulted in an agreement for a 64% reduction in the use of toxic chemicals by 1992, and a 90% reduction in toxic emissions by 1993 (Settina and Orum, 1991)
. In 1993, the Minnesota Citizens for a Better Environment released a report profiling the state's "top 40 toxic polluters" based on emissions of certain priority chemicals . In addition to TRI data, the report provided other information such as : the facilities'p . 36

compliance histories ; maps of major streets, schools, health care facilities, and wate r bodies in the area ; information about local populations ; contact information for facility representatives, government representatives, civic associations, and other organizations ; and toxicity information . The report was designed to provide enough information to support local efforts to negotiate with facilities for emissions reductions . Since publication, activists have worked with 18 of the 40 facilities identified in the report (Doer, 1995)
. After TRI -data identified Syntex Chemicals in Boulder as a top Colorado polluter, extensive publicity led to negotiations between local activists and the facility concerning emissions reductions . After a lengthy process that involved the facility's corporate headquarters, the facility signed a good neighbor pledge to reduce its air toxics emissions 50% by 1994 from 1989 levels . The facility also agreed to set up a community advisory panel to facilitate communications between the facility and the community (Settina and Orum, 1991)
. In March 1993, the Texas Network for Environmental and Economic Justice published a report entitled "Toxics in Texas and Their Impact on Communities of Color" . This report used TRI and other data to document disproportionate environmental impacts on racial and ethnic minority communities in Texas . The report includes case studies, maps, relevant legal and institutional information, and recommendations (Texas Network for Environmental and Economic Justice, 1993)
. Use of the Data by National, State, and Local Government Agencies National, state and local governments use TRI data to set priorities and allocate scarce environmental protection resources to the most pressing problems . Regulators use the data. to set permit limits, measure compliance with those limits, and target facilities for enforcement activities

. Twenty-one states use TRI data to target permit compliance inspections of facilities (National Conference of State Legislatures, 1995)
. The U-S
. Internal

' Revenue Service used TRI data to identify companies releasing CFCs in order to enforce a tax imposed on releases of CFCs (Smith, 1992)
. Use of the Data by the Financial and Business Communitie s Increasingly, TRI data are being used in financial decision-making . Investment analysts useTRI data to provide recommendations to clients seeking to make environmentally sound investments . Insurance companies look to TRI data as one indication of potential environmental liabilities . Consultants and others use the data to identify business opportunities, such as marketing pollution prevention and control technologies to TRI reporting facilities . Demand for environmental performance information by investors, insurance companies, and the public has led many companies to develop environmental annual reports similar to annual reports on financial performance traditionally prepared for investors

.
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# 5p . 37



### The Clean Yield Group, an investment portfolio management group, compares companies' TRI release data to their industry averages of pounds of toxic chemicals per dollars of sales . This serves as a rough yardstick to gauge how the company measures up against other companies in its industry, and allows the investment firm to track how the company's release performance is improving from year to year (Hausman, 1993)
. The Investor Responsibility Research Center, Inc ., a not-for-profit research or-eanization for institutional investors, uses TRI data in developing its CoEporate Environmental Profile Directoa

. This directory presents quantitative, consistently-derived data that allows investors to evaluate and compare corporate environmental performance . The corporate profiles include TRI release and transfer data, as well as an "Emissions Efficiency Index" which compares toxic chemical emissions to the company's domestic revenue (Chines, 1994)

. A leading popular business magazine used TRI data as a central element in compiling a "green index" of America's biggest manufacturers . The magazine examined companies' environmental records and developed a relative ranking system that assigned companies scores from zero to 10 in 20 different performance categories, including the amount of toxic emissions per dollar value of sales, and their percent reduction in toxic chemical emissions . The article included lists of 10 leading companies, 10 "laggard" companies, and 10 most improved companies (Rice, 1993)
. Use of the Data by the Regulated Community The public availability of the TRI data has led many corporations to commit publicly to voluntary emissions reductions . The first of these pledges was Monsanto's 1989 commitment to reduce its worldwide air emissions of toxic chemicals by 901/6 by 1992. Many other companies, including AT&T, Dow Chemical, Dupont, Merck, and 3M, soon followed with their ow n reductions goals (MacLean and Orum, 1992)
. In addition to providing the impetus for these reductions pledges, the TRI data also provide the public with the measurement tool needed to track companies' progress, as well as providing the companies a means of demonstrating their commitment and success

. As another example, the Iowa Association of Business and Industry coordinate s a community-wide pollution prevention initiative in the Des Moines-Polk County area . The group has adopted goals of a 60% reduction of all TRI chemicals by 1992 and a 70% reduction by 1995 (U .S . EPA, 1993b)
. Use of the Data by States TRI data has provided the impetus for passage of pollution prevention laws in many states . However, states have used TRI data in many ways other than regulating industry . The following are some examples of how various states have use the TRI data . For more informationp . 38

on how states collect and use the TRI data, see Attachment E for the results of an assessment of state TRI programs conducted by the National Conference of State Legislatures

. 

### Louisiana's Environmental Leadership Pollution Prevention Program is a statewide emissions prevention and reduction program that seeks a 45% reduction in toxic chemical emissions by 1997, using 1992 data as a baseline . The program sponsors the Governor Awards for Environmental Excellence to promote public recognition of industry achievements (U .S . EPA, 1993b) A researcher in Louisiana developed a. method for normalizing the TRI data to allow comparisons among facilities, industries and states to help evaluate the comparative effectiveness of pollution control strategies, policies and programs . The method calculate s an "emissions to jobs ratio", the number of pounds of emissions per job in a given industry and location . This ratio is then compared to a national or other average to determ . e relative performance . It also can be tracked over time to evaluate improvement . The "environment-to-jobs" ratio was included in an environmental scorecard which was developed and implemented to modify tax exemptions granted to facilities to encourage and reward job creation . If a facility's environmental score (including the "environmentto-jobs ratio") was low, the amount of the tax exemption could be decreased (Templet, 1993). The states of Kentucky, Ohio, and West Virginia have joined together in a "Tri-State Initiative" to identify, prevent and remediate environmental threats in an area known for its industrial base and its susceptibility to air inversions . Program coordinators are using a risk assessment process to focus on sources of greatest concern . The program will use voluntary industry commitments and cooperative efforts between industry, the public and government to achieve reductions in releases of TRI chemicals and criteria air pollutants (U .S . EPA, 1993b)
. The Pollution Prevention Program of the Colorado Department of Public Health and the Environment used TRI data, in combination with other air and water emissions data and hazardous waste data, to identify 10 industry groups which are responsible for the largest quantities of hazardous waste generation or toxic emissions in the state . This study will serve as the basis for establishing priorities for pollution prevention activities and for distribution of technical assistance grants . The report also will be used to target large companies for participation in a Governor's Pollution Prevention Challenge Program to reduce toxic emissions and hazardous waste generation (Kolwey and Lynch, 1994)

. The New Jersey Department of Environmental Protection and Energy used TRI data in a computerized Geographic Information System (GIS) in order to prioritize facilities and . geographic areas for implementation of pollution prevention measures

. A grid system of 2 mile by 2 mile cells was used for aggregation of air releases and land releases . Minor watersheds were used to aggregate and map water releases . In order to study the

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cumulative impact of many releases in the area, chemicals were grouped based on health and environmental effects (Cummens, 1993)
. The Pollution Prevention Division of the state of Georgia's Department of Natural Resources used TRI data in the process of identifying the technical assistance needs of manufacturing sectors that generate chemicals posing the greatest relative risk to public health and the environment . First, the Division prioritized chemicals based on toxicity and regulatory factors . The Division then examined manufacturing sectors releasing the highest priority chemicals and identified particular subsectors for further assessment . The program is now conducting in-depth manufacturing sector assessments, including focus groups and site visits, to determine what processes produce the wastes, what multi-media waste problems exist, what pollution prevention activities are currently being undertaken, and what additional opportunities exists (Donaghue, 1995)
. TR1 data helpee spur the Louisiana state legislature to require the state Department of Environmental Quality to issue regulations identifying 100 priority pollutants, setting emissions standards for those pollutants, and targeting a 50% emissions reduction from 1987 levels by 1994 (Tryens, et al ., undated)

. I
A public interest group report on unregulated air toxics emissions in North Carolina led the state's Environmental Management Commission to set limits for 105 air pollutants (Tryens, ef al., undated)

. New York State's Department of Health developed a risk screening protocol which uses TRI air release data to produce relative risk rankings for facilities and chemicals within the state . The procedure combines air emissions data and toxicity potency data to give a quantitative risk screening score for each facility . Three separate rankings were developed, based on carcinogenicity, non-cancer endpoints, and a combination of both factors . The results of these rankings suggested to the Department of Health that there is a need for more careful evaluation of potential health effects resulting from large releases of noricarcinogenic compounds such as respiratory irritants and small releases of very potent inorganic carcinogens (Recer and Johnson, 1995)
. Used of the Daza by Education and Research Institution s The TRI data are being used in many environmental education programs, particularly at the high school and university levels . Students learn about toxic chemical releases, the potential health and environmental effects of those releases, pollution prevention activities and opportunities, and the social and political aspects of environmental protection . Some organizations also are conducting educational outreach programs using TRI data . For example : Students in the Environmental Studies Department at Dickinson College (Pennsylvania) use TRI data to conduct toxic waste audits on communities or facilities . Students identify

'2p . 40

epidemiological and environmental health effects, occupational exposure standards, and other relevant information . Students arrange plant tours which focus on toxic chemical use reduction and "good neighbor" agreements between facilities and communities

. Students also meet %rith local citizens, environmental organizations, labor unions and others ("Notes From the Field," 1992)
. The John Snow Institute Center for Environmental Health Studies has developed a tutorial entitled "Environment and Health : How to Investigate Community Environmental Health Problems" . This tutorial introduces the public to TRI and other resources which can be used to identify and address local pollution sources . Audiences include librarians, local officials, members of the media, environmental advocates, the general public, and students from high school to graduate level (Greene, 1995)
. Researchers at the University of California, Santa Barbara's Center for Geogrdphic Information and Analysis used .1989 TRI data and 1990 U .S
. Census data to examine and map significant relationships between the race and income of populations and their proximity to TRI sites in Los Angeles (Burke, 1993)
. The data use examples presented above illustrate the current widespread use of TRI data by a broad array of constituents . Interest in and use of the data are continuing to grow . More than 500 people attended the most recent TRI Data Use Conference sponsored by EPA in December 1994, by far the most participants ever

. A new initiative to standardize reporting of facility identification information across all major EPA databases will allow better integration of environmental data from a variety of sources . Eventually, this work may lead to "one-stop" environmental reporting for industry, easing their reporting burden while simultaneously improving the accessibility of the information to all users

. 3 THE RESPONDENTS AND THE INFORMATION REQUESTED 3(a) Respondents/SIC Codes The statute applied the reporting requirement to owners and operators of facilities that have 10 or more full-time employees, manufacture or process more than 25,000 pounds or otherwise use more than 10,000 pounds of a listed chemical, and are in Standard Industrial Classification (SIC) codes 20 through 39 . . As discussed in Section 2(a) of this ICR, EPCRA section 313(b)(1)(B) allows the Administrator to expand the universe of industrial groups required to report . The proposed rule would expand the TRI reporting requirements to the following industrial groups

. SIC Code Industry Covered by Proposed Rule

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## ATTACHMENT D TRI CHEMICALs REPORTED To NON-TRi DATABASE S
The first two tables in this attachment compare chemical coverage between TRI and three media-specific databases~ AFS (AIRS Facility Subsystem), BRS (Biennial Reporting, System), and PCS (Permit Compliance System) . These three databases were chosen for analysis because they contain media-specific chemical release information comparable to TRI . The third attachment discusses the accessibility of the data in each of these sources

. The 627 chemicals currently *in TRI are listed in Attachment D-1, while the 28 TRI chemical categories are listed in Attachment D-2 . For each TRI chemical or category, there is a table entry which contains its name as listed in TRI, its CAS number or TRI-assigned category number, and indicators as to whether or not that particular TRI chemical is tracked by AFS, BRS, and/or PCS
. Chemicals with a star in th~ column marked "Newly Listed" were added to TRI in 1994 . The first reports for these chemicals were made for the 1995 reporting year, and will be available to the public in the Spring of 1997 . A dot in the AFS, BRS, or PCS columns indicates that the chemical listed at that row is either tracked by that database or is speciable using data from that database . While a dot means that the particular chemical is tracked by both TRI and the database in question, it does not necessarily mean that a facility releasing the chemical reports that .specific chen-dcal to both systems . In other words, the same facility may not be reporting the same information to different programs

. AFS matches are based on ermssions data "speciated" from limited industry profiles, and are not derived from directly reported data . Speciated chemical emissions are estimated using SPECIATE and are based on actual reported PM-10 and VOC emissions . Please see section 5(a) of the ICR for a description of SPECIATE
. Because data categorized by BRS waste codes can be only partially translated into chemical -specific information, chemicals have been tagged in the table as reporting to BRS only where there is CAS-specific data that can be matched . Other wastestreams may contain ~Ldditional TRI chem~icals, but because their waste codes are not CAS-specific, it is difficult to determine which chemicals (as well as how much of them) are actually in the wastestream
. PCS chemicals are tagged in the table if at least one PCS facility reports the chemical as part of its Discharge Monitoring Report (DIVIR) . Therefore, because a chermicat is tagged does not necessarily mean that it is significantly represented in PCS
. In addition, because the list of chemicals a facility reports depends heavily on the language of the permit, facilities releasing identical chemicals may not be required to report the same set of C'hernlicals to PCS
.p . 42 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCS Chemical Name CAS Number Newly AFS BRSTPCS Listed 1 1,1,1,2-Tetrachloro-2-fluoroethane (HCFC-121a) 354-11- 0 2 1,1,1,2-Tetrachloroethane 630-20-6 3 1, 1 . 1 -Trichloroethane 71-55-6 4 1,1,2,2-Tetrachloro-l-fluoroethane (HCFC-121) 354-14-3 5 1, 1 2,2-Tetrachloroethane 79-34-5 6 1, 1,2-Trichloroethane 79-00-5 7 1, 1 -Dichloro-1,2,2,3,3-pentafluoropropane (HCFC-225cc) 13474-88-9 8 1, 1-Dichloro-1,2,2-trifluoroethane (HCFC-1 23b) 812-044 9 1,1-Dichloro-1,2,3,3,3-pentafluoropropane (HCFC-225eb) 111512-56-2 10 1,1-Dichloro-l-fluoroethane (HCFC-141b) 1717-00-6 11 1, 1 -Dimethyl hydrazine 57-14-7 12 1,1-Methylene bis(4-isocyanatocyc1ohexane) 5124-30- 1 13 1,2,3-Trichloropropane 96-18-4 1 14 1, 2,4-Trich lo ro benzene 120-82- 1 15 11, 2,4-Tri m ethyl benzene 95-63-6 16 1,2-Butylene oxide 106-88-7 17 1,2-Dibromo-3-chloropropane 96-12-8 18 1,2-Dibromoethane 106-93-4 19 1,2-Dichloro-1,1,2,3,3-pentafluoropropane (HCFC-225bb) 422-44-6 20 1,2-Dichloro-1, 1,2-trifluoroethane (HCFC-1 23a) 354-234 21 11, 2-Di ch loro- 1, 1, 3,3,3-pentafluo ropro pane (HCFC-225da) 431-86-7 22 1,2-Dichloro-1,1-difluoroethane (HCFC-132b) 1649-08-7 23 1,2-Dichlorobenzene 95-50-1 24 1,2-Dichloroethane 107-06-2 25 1,2-Dichloroethylen e 26 1,2-Dichloropropane 78-87-5 27 11,2-Diphenylhydrazine 122-66-7 28 1,2-Phenylenediamine 95-54-5 29 1,2-Phenylenediamine dihydrochloride 615-28-1 30 1,3-Bis(methylisocyanate) cyclohexane 38661-72-2 31 1,3-Butadiene 106-99-0 32 1, 3-Dichloro-1, 1,2,2,3-pentafluoropropane (HCFC-225cb) 507-55-1 33 11,3-Dichloro-1,1,2,3,3-pentafluoropropane (HCFC-225ea) 136013-79-1 34 1,3-Dichlorobenzene 541-73-1 35 1, 3-Dichloropropylene 542-75-6 36 1,3-Phenylene diisocyanate 123-61-5 37 1,3-Phenylenediamine 10845-2 38 .1,4-8is(rnethylisocyanate) cyclohexane 10347-54-3 39 1,4-Cyclohexane diisocyanate 2556-36-7 40 1,4-Dichloro-2-butene 764-41-0 41 1,4-Di6hlorobenzene 106-46-7 42 1,4-Dioxane 123-91-1 43 1,4-Phenylene diisocyanate 104-49-4 44 11,4-Ph nylenediamine dihydrochloride 624-18-0 45 1,5-Naphthalene diisocyanate 3173-72-6 46 1-(3-Chloroallyl)73,5,7-triaza-l-azoniaadamantane chloride 4080-31-3 47 1-Amino-2-methylanthraquinone 82-28-0 48 1-Bromo-l-(bromomethyl)-1,3-propanedicarbonitrile 35691-65-7 49 1 -Chloro-1, 1,2,2-tetrafluoroethane (HCFC- 1 24a) 354-25-6 50 11-Chloro-1,1-difluoroethane(HCF -lT2 -b)- 75-68-3 51 1-Nitro yrene, 5522-43-0 52 2,2,4-Tri m ethyl h exam ethylene diisocyanate 16938-22-0. 53 2,2-Dibromo-3-nitrilopropionamide 10222-01-2 54 2,2-Dichloro-1,1,1,3,3-pentafluoropropane (HCFC-225aa) 128903-21-9 1 55 2,2-Dichloro-1, 1, 1 -trifluoroethane (HCFC-1 23) 1 306-83-2

D-2p . 43 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Newly Chemical Name CAS Number .AFS BRS PCs Listed 56 2,3,5-Tri rn ethyl ph enyl methylcarbamate 2655-15-4 57 2,3-Dichloro-1, 1, 1,2,3-pentafluoropropane (HCFC-225ba) 422-48-0 58 2,3-Dichloropropene 78-88-6 59 2,4'-Disocyanatodiphenyl sulfide 75790-87-3 60 2,4,4-Trimethylhexamethytene diisocyanate 15646-96-5 61 12,4,5-Trichlorophenol 95-95-4 62 2,4,6-Thchlorophenol 88-06-2 63 2,4-D 94-75-7 0- 64 2,4-D 2-ethy 1-4-m ethyl pentyl ester 53404-37-8 66 2,4-D 2-ethyihexyi ester 1928-43-4 66 2,4-D butoxyethyl ester 1929-73-3 67 12,4-0 butyl ester 94-80-4 68 2,4-0 chlarocrotyl ester 2971-38-2 69 2,4-D isopropyl ester 94-11-1 70 2,4-0 ropylene g(ycol butyl ether ester 1320-18-9 71 2,4-D sodium salt 2702-72-9 72 2,4-DB 94-82-6 73 12,4-Diaminoanisole 615-05-4 74 12,4-Diaminoanisole sulfate 39156-41-7 75 12,4-Diaminotoluene 95-80-7 76 12,4-Dichlorophenol 120-83-2 77 12,4-D im ethyl phenol 105-67-9 78 2,4-Dinitrophenol 51-28-5 79 2,4-Dinitrotoluene 121-14-2 80 2,4-Dithiobiuret 541-53-7 81 2,4-DP (Dichlorprop) 120-36-5 82 2,6-Di m ethyl ph enol 576-26-1 83 12,6-Dinitrotoluene 606-20-2 r84 2 .6-Xvlidine 87-62-7 85 2-Acetylaminofluorene 53-96-3 86 2-Aminoanthraquinone 117-79-3 87 2-Bromo-2-nitropropane-1,3-diol (Bronopol) 52-51-7 88 12-Chloro 1,1,1,2-tetrafluoroethane (HCFC-124) 2837-89-0 89 12-Chloro-1, 1, 1 -trifluoroethane (HCFC-1 33a) 75-88-7 90 2-Chloroacetophenone 532-27,4 91 2-Ethoxyethanol 110-80-5 92 2-Mercaptobenzothiazole (MBT) 149-304 93 2-Methoxyethanol 109-86-4 94 2-Methyllactonitrile 75-86-5 95 2-Methylpyridine 109-06-8 96 2-Nitrophenol 88-75-5 97 2-Nitropropane 79-:46-9 98 2-Phenylphenol 90-43-7 99 3,3'-Dichlorobenzidine 91-94-1 100 3,3'-Dichlorobenzidine dihydrochloride 612-83-9 101 3,3'-Dichlorobenzidine sulfate 64969-34-2 -TO -2 -~, -3'-Dimethoxybenzidene dihydrochloride (a-Dianisidine dihyd 20325-40-0 103 3,3'-Dimethoxybenzidine 119-90-4 104 13,3'-Dimethoxybenzidine hydrochloride (o-Dianisidine hydroch 111984-09-9 105 13,3'-Dimethoxybenzidine-4,4'-diisocyanate 91-93-0 106 3,3'-Dimethyl diphenylmethane-4,4'-diisocyanate 139-25-3 107 3,3'-Dimethyl-4,4'-diphenylene diisocyanate 91-974 108 3,3'-Dimethylbenzidine 119-93-7 109 3,3'-Di rn ethyl benzid in e dihydrochloride (o-Tolidine dihydroch 612-82-8 110 3,3'-Di m ethyl benzidin e dihydrofluoride (o-Tolidine dihydrofl 41766-75-0
D-3

# t4p . 44 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Newly Chemical Name CAS Number I isted AFS BRS PCs 111 3,3-Dichloro-1, 1,1,2,2-pentafluoropropane (HCFC-225ca)

- 422-56-0 112 3,4-Dichloropentafluoropropane 127564-92-5 113 13-Chlo o-1, 1, 1-trifluoropropane (HCFC-253fb) 460-35-5 114 13-Chlo o-2-methyl-l-propene 563-47-3 115 13-- hioropropionitrile 542-76-7 116 3-lodo-2-propynyl butylcarbamate 55406-53-6 117 4,4'-Diaminodiphenyl ether 101-80-4 118 4,4'-Diisocyanatodiphenyl ether 4128-73-8 119 4,4'-Isopropylidenedighenol 80-05-7 120 4,4'-Methylenebis(2-chloroaniline) 101-14-4 121 4,4'-Methylenebis(N,N-dimethyl)benzenamine 101-61-1 122 4,4'-Methyienedianiline 101-77-9 123 4,4'-Thiodianiline 13M5-1 124 4,6-Dinitro-o-cresol 534-52-1 125 14-4-m

-inoazobenzene 60-09-3 126 4-Aminobiphenyl 92-67-1 127 4-Dimethylaminoazobtnzene 60-11-7 128 4-Methyldiphenylmethane-3,4-diisocyanate 75790-84-0 129 4-Nitrobiphenyf 92-93-3
- 130 4-Nitrophenol 100-02-7 131 .5-Methylchrysene 3697-24-3 132 5-Nitro-o-anisidine 99-59-2 133 5-Nitro-o-toluidine 99-55-8 134 7,12-Dimethyl benz(a)anthracene 57-97-6 135 7H-Dibenzo(c,g)carbazole 194-59-2 136 Abamectin 71751-41-2 9 0 137 lAcephate 30560-19- 1 8 138 lAcetaldehyde 75-07-0 139 Acetamide 60-35-5 140 Acetonitrile 75-05-8 141 Acetophenone 98-86-2

1 4 1

142 Acifluorfen sodium salt 62476-59-9 143 Acrolein 107-02-8 0 144 lAcrylamide 79-06- 1 1 145 lAcrvlic acid 79-10-7 0 146 Acrylonitrile 107-13-1 6 147 Alachlor 15972-60-8 148 Aldicarb 116-06-3 149 Aldrin 309-00-2 150 Allyl al ohol 107-18-6 151 Allyl chloride 107-05-1 152 Allylamine 107-11-9 153 alpha-Hexachlorocyclohexane 319-84-6 154 alpha-Naphthylamine 134-32-7 155 Aluminum (fume or dust) 7429-90-5 156 Aluminum oxide (fibrous forms) 1344-28-1 157 Aluminum phosphide 20859-73-8 158 Ametryn 834-12-8 159 Amitraz 33089-61-1 160 Amitrole 61-82-5 161 Ammonia 7664-41- 7 Ammonium nitrate (solution) 6484-52-2 163 Ammonium sulfate (solution) 7783-20-2 164 Anilazine 1 101-05- 3 1 62-53-3
D-4p . 45 EXHIBIT D- 1
TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Number Newly AFS BRS PCs Listed 166 Anthracene 120-12-7 167 Antimony 7440-36-0 168 lArsenic 7440-38-2 169 lAsbestos (friable) 1332-21-4 170 lAtrazine 1912-24-9 171 Barium 7440-39-3 172 Bendiocarb 22781-23-3 173 Benfluralin 1861-40-1 174 Benomyl 17804-35-2 175 1 Benz(a)anthracene 56-55-3 176 18enzal chloride 98-87-3 177 1 Benzamide 55-21-0 178 lBenzene 71-43-2 179 1 Benzidi 92-87-5 180 Benzo(a)phenanthrene 218-01-9 181 Benzo(a)pyrene 50-32-8 182 Benzo(b)fluoranthene 205-99-2 183 Benzo(j)fluoranthene 205-82-3 184 Benzo(k)fluoranthene 207-08-9 185 Benzo(rst)pentaphene 189-55-9 186 Benzoic trichloride 98-07-7 187 18enzovl chloride 98-88-4 188 Benzoyl peroxide 94-36-0 189 Benzyl chloride 10044-7 190 Beryllium 7440-41-7 191 beta-Naphthylamine 91-59-8 192 beta-Propiolactone 57-57-8 193 1 Bifenthrin 82657-04-3 194 lBiphenvi 92-52-4 195 1 Bis(2-chloro-1 -m ethyl ethyl)ether 108-60-1 196 18is(2-chloroethoxy) methane 111-91-1 197 Bis(2-chloroethyl) ether .111-44-4 198 Bis(2-ethylhexyl) adipate 103-23-1 199 Bis(chloromethyl) ether 542-88-1 200 IBis(tributyltin) oxide 56-35-9 201 1 Boron trichloride 10294-34-5 202 1 Boron trifluoride 7637-07-2 203 lBromacil 31440-9 204 lBromacil lithium salt 53404-19-6 205 lBromine 7726-95-6 206 Bromochlorodifluoromethane (Halon 121 11 353-59-3 207 Bromoform 75-25-2 208 Bromomethane 74-83-9 209 Bro m otrifl uoro methane {Halon 13011 75-63-8 210 Bromoxynil 1689-84-5 211 Bromoxynil octanoate 1689-99-2 21 .2 Brucine 357-57-3 213 Butyl a6rylate 141-32-2 214 Butyraldehyde

. 123-72-8 215 1C. I. Acid Green 3 4680-78-8 216 1C.1 . Acid Red 114 6459-94-5 217 C . I . Ba ic Green 4 569-64-2 218 C .I . Basic Red 1 989-38-8 219 C .I . Direct Black 38 1937-37 7 220 C. 1 . Direct Blue 218 28407-37-6
D-5p . 46 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCS Chemical Name CAS Number Newly AFS 8R`SPCS isted 221 C. 1 . Direct Blue 6 2602-46- 2 222 C. 1 . Direct Brown 95 16071-86-6 223 C. 1 . Disperse Yellow 3 2832-40-8 224 C. 1 . Food Red 15 81-88-9 225 C. 1 . Food Red 5 226 C. 1 . Solvent Orange 7 3118-97-6 227 C. 1 . Solvent Yellow 14 842-07-9 228 C. 1 . Solvent Yellow 3 97-56-3 229 C . 1 . Solvent Yellow 34 492-80-8 230 C. 1 . Vat Yellow 4 128-66-5 231 Cadmium 7440-43-9 232 Calcium cyanamide 156-62-7 233 Captan 133-06-2 234 Carbaryl 63-25-2 235 Carbofuran 1563-66-2 236 Carbon disulfide 75-15-0 237 Carbon tetrachloride 56-23-5 238 Carbonyl sulfide 463-58-1 239 Carboxin 5234-68-4 240 Catechol 120-80-9 241 Chinomethionat 2439-01-2 242 Chlora-mben 133-90-4 243 Chlordane 57-74-9 244 Chlorendic acid 115-28-6 245 Chlorimuron ethyl 90982-32-4 246 Chlorine 7782-50-5 247 Chlorine dioxide 10049-04-4 248 Chloroacetic acid 79-11-8 249 Chlorobenzene 108-90-7 250 Chlorobenzilate 510-15-6 251 Chlorodifluoromethane (HCFC-22) 75-45-6 252 75-00-3 253 Chloroform 67-66-3 0 T-0 254 Chloromethane 74-87-3 0 0 255 Chloromethyl methyl ether 107-30- 2 256 Chloropicrin 76-06-2 257 Ch loroprene 126-99-8 258 [Chlorotetrafluoroethane 63938-10-3 259 Chlorothalonil 1897-45-6 260 Chlorotrifluoromethane (CFC-1 3) 75-72-9 261 Chlorpyrifos methyl 5598-13-0 262 Chlorsulfuron 64902-72-3 263 7440-47-3 264 Cobalt 7440-48-4 265 Copper 7440-50-8 266 Creosote 8001-58-9 267 Cresol (mixed isomers) 1319-77-3 268 Crotonaldehyde 4170-30-3 269 Cumene 98-82-8 270 Cumene hydroperoxide 80-15-9 271 Cupferron 135-20-6 272 C ana ine 21725-46-2 273 Cycloa e 1134-23-2 27 ~4Cyclohexane 110-82-7 275 Cyclohexanol 108-93-0
D-6p . 47 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Number Newly AFS BRS PCs Listed 276 Cyfluthrin 68359-37- 5 277 Cyhalothrin 68085-85-8 278 d-trans-Allethrin 28057-48-9 279 Dazomet 533-74-4 280 Dazomet sodium salt 53404-60-7 281 Decabromodiphenyl oxide 1163-19-5 282 Desmedipham 3684-56-5 283 _D~2-ethylhexyl) phthalate 117-81-7 284 Diallate 2303-16-4 285 Diaminotoluene (mixed isomers) 25376-45-8 286 Diazinon 333-41-5 287 Diazomethane 334-88-3 288 Dibenz(a,h)acridine 226-36-8 289 Di*benz(a,j)acridine 224-42-0 290, Dibenzo(a,e)fluoranthene 5385-75-1 .291 Dibenzo(a,e)pyrene 192-65-4 292 Dibenzo(a,h)anthracene 53-70-3 .293 Dibenzo(a,h)pyrene 189--64-0 .294 Dibenzo(a,l)pyrene 191-30-0 295 Dibenzofuran 132-64-9 296 Dibrom .otetrafluoroethane (Halon 24021 124-73-2 297 Dibutyl phthalate 84-74-2 298 Dicamba (3,6-Dichloro-2-methyoxybenzoic acid) 1918-00-9 .299 Dichloran (2,6-Dichlor;-4-nitroaniline) 99-30-9 300 Dichloro-1, 1,2-trifluoroethane 90454-18-5 301 Dichlorobenzene (mixed isomers) 25321-22-6 302 Dichlorobromomethane 75-27-4 303 Dichlorodifluoromethane (CFC-12) 75-71-8 304 Dichlorofluoromethane (HCFC-21) 7543-4 305 Dichloromethane 75-09-2 306 Dichloro
'phene (2,2'-Methylenebis(4-chlorophenol) 97-23-4 307 Dichlorotetrafluoroethane (CFC-1 14) 76-14-2 308 Dichlorotrifluoroethane 34077-87-7 309 Dichlorvos 62-73-7 .310 Diclofop methyl 51338-27-3 311 Dicofol 115-32-2 312 Dicyclopentadiene 77-73-6 313 Diepoxybutane 1464-53-5 314 iDiethanolamine 111-42-2 315 Diethatyl ethyl 38727-55-8 316 Diethvl Phthalate 84-66-2 0 0 317 Diethvl sulfate 64-67-5 31 .8 Di ethvld i isocya nato benzene 134190-37-7 319 Diflubenzuron 35367-38-5 320 Diglycidyl resorcinol ether 101-90-6 321 Dihydrosafrole 94-58-6 322 Dimethipin 55290-64-7 323 Dimethoate 60-51-5 324 Dirnethyl chlorothiophosphate 2524-03-0 .325 DimethVI phthalate 131-11-3 326 Dimethyl sulfate 77-78-1 327 Dimethvlamine 124-40-3 328 Dimethylamine dicamba 2300-66- 5 1 329 Dimethylcarbamyl chlori de 79-44-7 No I 11330 1 Dim ethyldich lorosilane 75-78-5
D-7p . 48 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Nu.mber Newly AFS BRS PCs Listed 331 Dinitrobutyl phenol (Dinoseb) 88-85-7 332 Dinitrotoluene (mixed isomers) 25321-14-6 333 Dinocap 39300-45-3 334 Diphenamid 957-51-7 335 Diphenylamine 122-39-4 336 Dipotassium endothall 2164-07-0 337 Dipropyl isocinchomeronate 136-45-8 338 IDisodium cyanodithioirnidocarbonate 138-93-2 339 Ouron 330-54-1 340 IDodine (Dodecy[guanidine monoacetate) 2439-10-3 341 1 Epichlorohydrin 106-89-8 342 Ethoprop 13194-48-4 343 Ethyl acrylate 140-88-5 344 Ethyl chloroformate 541-41-3 345 Ethyl dipropylthiocarbamate (EPTC) 759-94-4 346 Ethvlbenzene 100-41-4 347 Ethylene 74-*85-1 348 Ethylene glycol 107-21-1 349 Ethylene oxide 75-21-8 350 Ethylen ; thiourea 9645-7 351 Ethyleneimine 151-56-4 352 Ethylidene dichloride 75-34-3 353 Famphur 52-85-7 354 lFenarimol 60168-88-9 355 IFenbutatin oxide 13356-08-6 356 1 Fenoxaprop ethyl 66441-23-4 357 lFenoxycarb 72490-01-8 358 IFenpropathrin 39515-41-8 359 Fenthion

. 55-38-9 360 Fenvalerate 51630-58-1 361 Ferbam 14484-64-1 362 Fluazifop butyl 69806-50-4 363 Fluometuron 2164-17-2 364 Fluorine 7782-41-4 365 Fluorouracil (5-Fluorouracil) 51-21-8 366 Fluvalinate 69409-94-5 367 Folpet 133-07-3 368 Fornesafen 72178-02-0 369 JFormaldehyde 50-00-0 370 1 Formic acid 64-18-6 371 Wreon 113 76-13-1 372 Heptachlor 76-44-8 373 Hexachloro-1, 3-butadien e 374 H exach loro benzene 118-74-1 375 Hexachlorocyclopentadiene 77-47-4 376 11-lexachloroethane - 67-72-1 377 Hexachloronaphthalene 1335-87-1 378 Hexachlorophene 70-304 379 Hexamethylene-1,6-diisocyanate 822-06-0 380 Hexamethylphosphoramide 680-31-9 381 Hexazinone 51235-04-2 2 Hydramethylnon 67485-29-4 383 Hydrazine 302-01-2 384 Hydrazine sulfate 10034-93-2 385 Hydrochloric acid

D-8p . 49 EXHIBIT 0- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Number Newly AFS BRS PCs Listed 386 jHydroqen cyanide 74-90-8 387 Hydroq n fluoride 7664-39-3 388 Hydrogen sulfide 7783-06-4 389 Hydroquinone 123-31-9 390 Imazalil 35554-44-0 391 1ndeno(1,2,3-cd)pyrene 193-39-5 392 Iron pentacarbonyl 13463-40-6 393 lsobutyraidehyde 78-84-2 394 Isodrin 465-73-6 395 Isofenphos 25311-71-1 396 Isophorone diisocyanate 4098-71-9 397 Isopropyl alcohol (man ufacturi ng-strong acid process)+E3493 67-63-0 398 Isosafrole 120-58-1 399 Lactofen 77501-63-4 400 Lead 7439-92-1 401 Lindane 58-89-9 402 Linuron 330-55-2 403 Lithium carbonate 554-13-2 404 m-Cresol 108-39-4 405 m-Dinitrobenzene 99-65-0 406 1 m-Xvlene 108-38-3 407 Malathion 121775-5 408 Maleic anhydride 108-31-6 409 Malononitrile 109-77-3 410 Maneb 12427-38-2 411 , Manclanese 7439-96-5 412 Mecoprop 93-65-2 413 Mercury 7439-97-6 414 Merphos .150-50-5 415 Methacrylonitrile 126-98-7 416 Metham sodium (Sodium methyidithiocarbamate) 137-42-8 417 Methanol 67-56-1 418 Methazole 20354-26-1 419 Methiocarb 2032-65-7 420 Methoxone 94-74-6 421 Methoxone sodium sait 5653-48-3 422 Methoxychlor 72-43-5 423 Methyl acrylate 96-33-3 424 Methyl chlorocarbonate 79-22-1 425 Methyl ethyl ketone 78-93-3 426 Methyl hydrazine 60-34-4 427 Methyl i dide 74-88-4 428 Methyl isobutyl ketone 108-10-1 429 Methyl isocyanate 624-83-9 430 Methyl isothiocyanate 556-61-6 431 Methyl mercaptan 74-93-1 432 Methyl methacrylate 80-62-6 433 Methyl Parathion 298-00-0 434 Methyl tert-butyl ether 1634-04-4 435 Methylene bromide 74-95-3 Methylenebis(phenyl isocyanate) 101-68-8 43 Methylt ichlorosilane 75-79-6 438 Metira 900642-2 Metribuzin 21087-64-9 440 Mevinphos 7786-34-7
D-9p . 50 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Number Newly AFS BRS PCs Listed 441 Michler's ketone 90-94-8 442 Molinate 2212-67-1 443 1 Molybdenum trioxide 1313-27-5 444 Monochloropentafluoroethane {CFC-1 15) 76-15-3 445 Monuron 150-68-5 4 t46 Mustard gas 505-60-2 447 Mvclobutanil 88671-89-0 448 N, N-0i methylan i line 121-69-7 449 N . N -D i rn et hylfo rm a rn i de 68-12-2 450 n-Butyl alcohol 71-36-3 451 n-Hexane 110-54-3 452 N-Methyl-2-pyrrolidone 872-50-4 453 N-Methylolacrylamide 924-42-5 454 N-Nitroso-N-ethylurea 759-73-9 455 N-N itroso-N-m ethyl u rea 684-93-5 456 N-Nitrosodi-n-butylarnine 924-16-3 457 N-Nitrosodi-n-propylamine 621-64-7 458 N-Nitrosodiethylamine 55-18-5 459 N-Nitrosodimethylamine 62-75-9 460 N-Nitrosodiphenylamine 86-30-6 461 N-Nitrosomethylvinylamine 4549-40-0 462 N-Nitrosomorpholine 59-89-2 463 N-Nitrosonornicotine 16543-55-8 464 N-Nitrosopiperidine 100-75-4 465 Nabam 142-59-6 466 Naled 300-76-5 467 Naphthalene 91-20-3 466 INickel 7440-02-0 469 Nitrapyrin 1929-82-4 470 Nitric acid 7697-37-2 471 Nitrilotriacetic acid 139-13-9 472 Nitrobenzene 98-95-3 473 Nitrofen 1836-75-5 474 1 Nitroqen mustard 51-75-2 475 1 N itroq Iyceri n 55-63-0 476 Norflurazon 27314-13-2 477 Octachloronaphthalene 2234-13-1 478 ortho-Anisidine 90-04-0 479 ortho-Anisidine hydrochloride 134-29-2 480

. ortho-Cresol 95-48-7 481 ortho-Dinitrobenzene 528-29-0 482 ortho-Toluidine 95-53-4 483 ortho-Toluidine hydrochloride 636-21-5 484 ortho-Xylene 95-47-6 485 Oryzalin 19044-88-3 486 10smium tetroxide 20816-12-0 487 Oxydemeton methyl 301-12-2 488 Oxydiazon 19666-30-9 489 Oxyfluorfen 42874-03-3 490 Ozone 10028-15-6 491 p-Anisidine 104-94-9 4 p-Chloro-o-toluidine 95-69-2 493 p-Chloroaniline 106-47-8 494 p-Chlorophenyl isocyanate 104-12-1 1 495_ p-Cresidine -+120-71-8
D-10p . 51
EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCs Chemical Name CAS Number Newly AFS SRS PCs Listed 496 p-Cresol 106-44- 5 497 p-Dinitrobenzene 100-25-4 4 P98 p-Nit oaniline 100-01-6 499 o-Nitrosodiphenylamina 156-10-5 500 p-PhenvIenediarnine 106-50-3 501 D-Xvlene 106-42-3 502 Paraldehyde 123-63-7 503 1 Paraquat dichloride 1910-42-5 504 Parathion 56-38-2 505 Pebulate 1114-71-2 506 Pendimethalin 40487-42-1 507 Pentachloroethane 76-01-7 508 Pentachlorophenol 87-86-5 509 Pentobarbital sodium 57-33-0 510 Peracetic acid 79-21-0 511 Perchloromethyl mercaptan 594-42-3 512 Permethrin 52645-53-1 513 Phenanthrene 85-01-8 514 Phenol 108-95-2 515 Phenothrin 26002-80-2 5 K16 Phenytoin 57-41- 0 517 Phosaene 75-44-5 518 Phosohine 7803-51-2 519 Phosphoric acid 7664-38-2 520 1 Phosphorus (yellow or white) 7723-14-0 521 Phthalic anhydride 85-44-9 522 Picloram 1918-02-1 523 Picric acid 88-89-1 524 Piperonyl butoxide 51-03-6 525 Pirimiphos methyl 29232-93-7 526 Polychlorinated biphenyis 1336-36-3 527 Potyme ic dipheny[methane diisocyanate 9016-87-9 528 Potassium bromate 7758-01-2 529 Potassium dimethyldithiocarbamate 128-03-0 530 Potassium N-methyldithiocarbamate 137-41-7 531 Profenofos 41198-08-7 [532 Prometryn 7287-1 M 533 Pronamide 23950-58-5 5 5 534 ProDachlor 1918-16-7 35 Propane sultone 1120-71-4 536 Propanil 709-98-8 537 Propargite 2312-35-8 538 Prop rgyl alcohol 107-19-7 539 Propetarnphos 31218-83-4 540 Propiconazole 60207-90-1 541 Propionaldehyde 123-38-6 542 Propoxur 114-26-1 543 Propylene (Propene) 115-07-1 544 Propylene oxide 75-56-9. 545 Propyleneimine 75-55-8 546 IPyridine 110-86-1 547 Quinoline 91-22-5 548 Quinone 106-51-4 549 Quintozene 82-68-8 550 QuizaLafop-ethyl 76578-14-8 1

D-Itp . 52 EXHIBIT D- 1
TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCS Chemical Name CAS Number N i~w_l _y AFS BRS PCS Listed 551 Resmethrin 10453-86-8 552 S,S .S-Tributyltrithiophosphate (DEF) 78-48-8 553 Saccharin (manufacturing) 81-07-2 554 Safrole 94-59-7 555 sec-Butyl alcohol 78-92-2 556 Selenium 7782-49-2 557 Sethoxydi m 558 ISilver 74051-80-2 7440-22-4 559 Simazine 122-34-9 560 Sodium azide 46-628-22-8 561 Sodium dicamba 1982-69-0 562 Sodium dimethyldithiosarbamate 128-04-1 563 Sodium fluoroacetate 62-74-8 564 Sodium nitrite 7632-00-0 565 Sodium o-phenylphenoxide 132-27-4 566 Sodium pentachlorophenate 131-52-2 567 Styrene 100-42-5 568 Styrene oxide 96-09-3 569 Sulfuric acid 7664-93-9 570 Sulfuryl fluoride (Vikane) 2699-79-8 571 Sulprofos 35400-43-2 572 Tebuthiuron 34014-18-1 573 Temephos 3383-96-8 574 Terbacil 5902-51-2 575 tert-Butyl alcohol 75-65-0 576 Tetrachloroethylene 127-18-4 577 Tetrachlorvinphos 961-11- 5 Tetracycline hydrochloride 64-75-5 579 Tetramethrin 7696-12-0 Thallium 7440-28- 0 581 Thiabendazole 148-79-8 582 Thioacetamide 62-55-5 .583 Thiobencarb 28249-77-6 584 Thiodicarb 59669-26-0 585 Thiophinate ethyl 23564-06-9 .586 Thio ph a nate-m ethyl 23564-05-8 587 Thiosemicarbazide 79-19-6 .588 Thiourea 62-56-6 589 Thiram 137-26-8 590 Thorium dioxide 1314-20-1 591 Titanium tetrachloride 7550-45-0 592 -Toluene 1-5 --88-3 593 Toluene-2,4-diisocyanate 584-84-9 594 To(uene-2,6-diisocyanate 91-08-7 595 Toluenediisocyanate (mixed isomers) -26471-62-5 .596 Toxaphene 8001-35-2 .597 trans-1,3-Dichloropropene 10061-02-6 .598 trans-1,4-Dichloro-2-butene 110-57-6 599 Triadimefon 43121-43-3 600 Triallate 2303-17-5 .601 Triaziquone 68-76-8 -2 Tribenuron methyl 101200-48-0 603 Tributyltin fluoride 1983-10-4 .604 Tributylt n methacrylate : : :±2155-70-6 605 Trichlorfon 52-68-6
D-12p . 53 EXHIBIT D- 1 TRI Listed Chemicals Directly Reporting to AFS, BRS, and/or PCS Chemical Name CAS Number Newly AFS BRS 

# FP 'CS Listed 606 iTrichloroacetyl chloride 76-02-8 607 Trichloroethylene 79-01-6 608 Trichlorofluoromethan {CFC-111 75-69-4 609 Triclopyr triethylammonium salt 57213-69-1 610 Triethylamine 121-44-8 611 Triflurafin 1582-09-8 612 Triforine 26644-46-2 6-1-3 -Tri m ethyl ch loras i Ia n e 75-77-4 614 Triphenyltin chloride 639-58-7 615 Triphenyltin hydroxide 76-87-9 6 k 616 Tris(2,3-dibromopropyl) phosphate 126-72- 7 617 ITrypan blue 72-57-1 618 1 Urethane 51-79-6 6

1 619 IVanadium (fume or dust) 7440-62-2 6
620 Vinclozolin 50471-44-8 .621 Vinvl acetate 108-05-4 622 Vinyl bromide 593-60-2 623 Vinyl chloride 75-01-4 624 Vinylidene chloride 75-35-4 ,xylen (mixed isomers) 1330-20-7 626 IZinc (fume or dust) 7440-66-6 627 JZineb 12122-67-7 I Source : Toxics Release Inventory (1995)

D- 13p . 54 APPENDIX D- 2
TRI Listed Chemical Categories Directly Reporting to AFS, BRS, and/or PCs CAS Chemical Category/Constituent (see notes) NumberfTRI AFS BRS PCs Reference 1 lAntmony Compounds N01 0 2 Arsenic Compounds N020 3 Barium Compounds N040 4 Beryllium Compounds N050 5 Cadmium Compounds N078 6 Chlorophenols N084 7 Chromiurn Compounds N090 8 Cobalt Compounds N096 9 Copper Compounds N100 10 Cyanide Compounds N106 11 Diisocyanates N120 12 Ethylenebisdithiocarbamic acid, salts and esters N171 13 Glycol Ethers N230 14 Lead C mpounds N420 15 Manganese Compounds N450 16 Mercury Compounds N458 17 Nickel Compounds N495 18 Nicotine and salts N503 19 Nitrate compounds (water dissociable) N511 20 Polybrominated Biphenyls (PBBs) N575 21 Polychlorinated alkanes N583 22 Polycyclic aromatic compounds (following chemicals only) N590

- Benz(a)anthracene 56-55-3

- Benzo(a)phenanthrene 218-01- 9 Genzo(a)pyrene 50-32-8 Benzo(b)fluoranthene 205-99-2 Benzofl)fluoranthene 205-82-3 Benz (k)fluoranthene 207-08-9 Benzo(rst)pentaphene 189-55-9 Dibenz(a,h)acddine 226-36-8 Dibenz(a,j)acddine 224-42-0 Dibenzo(a,h)anthracene 53-70-3 0 0 Dibenzo(a,e)fluoranthene 5385-75-1 Dibenzo(a,e)pyrene 192-65-4 Dibenzo(a,h)pyrene 189-64-0 Dibenzo(a,l)pyrene 191-30-0 7H-Dibenzo(c,g)carbazole 194-59-2 7,12-Dimethylbenz(a)anthracene 57-97-6 0 lndeno[1,2,3-cdlpyrene 193-39-5 5-Methy1chrysene 3697-24-3 0 1-Nitropyrene 5522-43-0 23 Selenium Compounds N725 24 Silver Compounds N740 25 Strychnine and salts N746 alium Compounds N760 27 Warfarin and. salts N874 28 Zinc Compounds N982 [Source : Toxics Release Inventory 0 995) The 19 chemicals in the PAC category are ir~dividually listed to show which ones are tracked in the three non-TRI databases . For the metals categories, although often the metal itself is tracked in the nonTRI databases (see Appendix Q. 1 . 1), information on which metal compounds are tracked was not available . So as to not be misleading, the metals categories above are not indicated as being tracke d in the three non-TRI databases

.

D- 14p . 55


## ATTACHMENT D-3 PUBLIC ACCESS To EPA DATABASE S
The public accessibility of databases is an important factor to consider when determining their effectiveness and usefulness . This section describes some of the various avenues of access available to public users of TRI and other databases . Electronic as well as conventional information sources are included in the discussion

. TOXICS RELEASE INVENTORY (TRI) EPA has spent considerable effort and resources to make TRI available to the public . The multitude of methods .through which a concerned citizen can access TRI include : On-Line Resources The National Library of Medicine (NLM) TOXNET System is an on-line system offering state-of-the-art on-line searching of the TRI database . The System was designed to be easy to use by persons with limited computer experience . On-line costs for TOXNET range from $18 to $20 per hour . The system contains the . complete national TRI data for all reporting years . An NLM password is required to access the system, which is up 7 days/week, 24 hours/day

. TOXNET can be reached via either dial-up or Internet

. The Right-to-Know Computer Network (RTK NET) provides free public access to TRI as well as several other environmental and governmental databases . Access is free, but users must register with RTK NET before they can use the databases . RTK NET can be reached via dialup or Internet

. Internet Access to TRI data is available from three different EPA sources : the EPA Go pher server, the EPA FTP file server, and the EPA World Wide Web (WWW) server . The following information is available via Internet :

• TRI Public Data Release document --ASCII Text format and Lotus spreadsheet files corresponding to the data tables in the document

. • ARC/INFO GIS files for all 50 states--TRI data, written in ARC/Info format for geographical information system (GIS) applications

. The information available through the EPA servers is identi cal ; the most convenient server will depend on the preferred method of access . Internet users are advised to consult with their system administrators for specific access procedures . The address of each EPA server is given below: EPA GOPHER SERVER Address : gopher.epa .gov

EPA FTP SERVER Address : ftp .epa .gov EPA WWWSERVER Address : http ://www.epa .-,ov/

### p. 56

Electronic media 

### The TRI CD-ROM contains the complete national TRI, starting with the first inventory in 1987. Chemical Fact Sheets (formerly TRI-FACTS) containing reference material on the health and ecological effects of the regulated substances are also available on the same CD-ROM

. Contact/Availability: NTIS, Government Printing Office (GPO), Federal Depository Libraries, EPA Regional Offices

. The NESE-DB (National Economics, Social and Environmental Data Bank) CD-ROM includes the TRI state data and the national public data file on CD-ROM . The disc is produced quarterly by the Department of Commerce and provides access to socio-economic as well as environmental statistics and information . The data are gathered from over 15 federal agencies

. Contact/Availability~ Department of Commerce, selected federal depository libraries

. Diskettes : Requesters can select either 5 .25 or 3 .5 inch diskettes by state or for the entire US in DBASE III PLUS or Lotus 1-2-3 (version 2 .0) . Diskettes are accompanied by documentation . Contact/Availability : NTIS, GPO . Printed media TRI Reports : EPA assembles several detailed annual reports providing summaries, analyses, and comparison of TRI data by year . The reports summarize data on total releases and transfers of TRI chemicals ; geographic distribution of TRI releases and transfers ; industrial patterns of releases and transfers- the interstate and intrastate transport of wastes and other kinds of analyses . Contact : EPCRA 1~~O'rmation Hotline

. OTIIER .ENVERONMENTAL DATABASES On-Line Re,,~ources ENVIROFACTS is a relational database maintained by U .S . EPA that integrates data from four major EPA program systems, as well as the Facility Indexing System (FINDS) and the ENVIROFACTS Master Chemical Integrator (ECMI), which is a cross reference index of chemical data reported in the program systems . ENVIROFACTS allows the user to perform

. queries that integrate facility data from the-four databases based on their FINDS IDs .' ENVIROFACTS includes monthly-updated data available under the Freedom of Information Act

. No enforcement or budget- sensitive information is contained in ENVIROFACTS
. Databases include :PCs C ERCLIS2 TRI S

See Section 8 .7 of Chapter 8 for a more detailed discussion of FINDS
. CERCLIS, or the Comprehensive Environmental Response Compensation and Liability Information System, tracks information collected under CERCLA

. CERCLIS contains Superfund data on hazardous waste site assessment and remediation, including data on active sites from point of discovery to listing on the National Priorities List through completion of remedial and response actions

. (U .S . EPA, 1995f)p . 57

RCRIS ' FINDS ENVIROFACTS Master Chemical Integrator (EMCI ) To access ENVIROFACTS, users must have TCP/IP Internet access and an application that can communicate with an ORACLE database . To query ENVIROFACTS, users also need SQL*NET from ORACLE Corporation . ENVIROFACTS is accessible through the EPA's WWW site . Direct telnet to ENVIROFACTS server is not available to the public

. In addition to ENVIROFACTS, The EPA World Wide Web (WWW) Site provides access to other release and transfer databases, including : AIRS Executive : AIRS Executive is a software package designed for easy access and presentation of some of the most frequently used data in AIRS . The whole software package and the monthly data updates are downloadable from the EPA WWW site (http-//www.epa .gov/airs/aexec .htrffl) . However, it does not contain the extensive air pollution data found in AIRS proper, and is not a substitute for AIRS

. BRS Hazardous Waste Reports and Data Files for 1991 and 1993 : The BRS data is contained in self-extracting zipped flat files and are also downloadable from the EPA WWW site

. At the time of this writing, the most current version of the report is based on the 1993 BRS data and can be accessed at http ://www .epa .gov/docs/OSWRCRA/hazwaste/dataibr93/ . The data files themselves are also available on the WWW site, although expanding a year's worth of BRS data requires over 200 MB of disk space . In addition, a software package such as SAS is necessary for manaaeable data manipulation . Hard copies of the National Biennial RCRA Hazardous Waste Report are also available from NTIS

. These two databases, while accessible from the EPA WWW site, are not currently linked to ENVIROFACTS
. The Right-to-Know Computer Network (RTK NET) is an online service run by OMB Watch and the Unison Institute . RTK NET offers free access to more than thirteen different health and environmental databases, including : BRS Biennial Reporting System DOCKET Criminal and Enforcement Dockets FINDS Facility Indexing Syste m PCs Permit Compliance System TRI Toxics Release Inventory CERCLIS CERCLA Information System : RTK NET contains 20 fields out of

hundreds

. Cus
. Chemical Update System : Because roughly 50% of this database is CBI

(Confidential Business Information), RTK NET asks EPA to blank out any CBI but to leave the fields intact with CBI flags

. ERNS Old data is complete, but because RTK NET is no longer receiving tapes
RCRIS, or the Resource Conservation and Recovery Information System, is used primarily to track entities regulated under RCRA Subtitle C (hazardous waste handlers) . RCRIS includes data on'general handler information, permit or closure status, compliance with federal and state regulations, and cleanup activities

. (U .S . EPA, 19950

### p. 58

from ERNS, new data is downloaded from the Net and therefore i s 

### considerably more limited

. Data within RTK Net is only that which is publicly accessible by other means . In other words, no CBI is included . Most databases are complete, but note the above exceptions . Access is free, but users must register with RTK NET before they can use the databases . RTK NET can be reached via dialup or Internet

. The EPA Mainframe, at the National Computer Center (NCC), provides the primary mainframe computing resources through which EPA's staff at Headquarters, Regions, and Laboratories access EPA's databases . In addition, selected EPA databases can be accessed on the NCC computer systems by EPA's data sharing partners, such as state and local governments, contractors, and grantees . Private companies, corporations, and individuals can request online access to some EPA databases through the National Technical Information Service (NTIS)
. To access the various EPA computer systems, users must first obtain a user ID and password by submitting a'request to the appropriate EPA Account Manager or ADP Coordinator, who then requests registration from the Time Sharing Service Management System JSSMS) office at the NCC
. Upon approval of the request, the user is sent an ID, a password, and general use r information . Access is granted only to those persons who demonstrate a need for EPA mainframe resources, such as EPA contractors and other information sharing partners . The general public cannot access the EPA mainframe

. Resources on the EPA Mainframe include the following databases : AFS AIRS Facility Subsyste m BRS Biennial Reporting System CERCLIS CERCLA Information System DOCKET Criminal and Enforcement Docket s DUNS Dun and Bradstreet Marketing Services
-- Identifier File ERNS Emergency Response Notification Syste m FFIS Federal Facilities Information System FINDS Facility Indexing System PCs Permit Compliance Syste m RCRIS Resource Conservation and Recovery Information System TRI Toxics Release Inventory Selected data fields from these and other databases are linked together at the facility level through IDEA (Integrated Data for Enforcement Analysis)

. A more detailed description of IDEA can be found in Section 8 .7 of Chapter 8 of this report

. ERNS can also be reached through the Department of Transportation's (DOT) VAX minicomputer in Cambridge MA . Online access is restricted to EPA and other authorized federal governmental personnel . EPA's Emergency Response Division in the Office of Emergency and Remedial Response provides fact sheets, hard copies, diskettes, or tapes of requested information

. Certain EPA syst ems utilize tihe resources ofthe National Library of Medicine (NLM) to make information ava*ilable tothe public

. NLM provides access to information through the Medical Literature Analysis and Retrieval System (MEDLARS), an online computer system . Most EPA systems are maintained on one component of MEDLARS, TOXN`ET (TOXicology Datap . 59

NETwork), which is oriented to information on hazardous effects and toxicology of variou s chemical substances

. TOXNET, which runs on a series of mini-computers, is managed by NLM's Toxicology Information Program . Resources on TOXCNET include TRI as well as a number of other toxicological databases, such as EPA's -Integrated Risk Information System (HUS)
. TOXNET was designed to be user-friendly and offers many modules for building and reviewing records and many sophisticated search and retrieval features, including free text searching . Extensive online user assistance is available, and the TOXNET Gateway allows access to other files in MEDLARS
. Additional features, including cross-file searching and printing and special menus for users with little computer experience, are under development

. TOXNET is available 24 hours/day, 7 days/week, with the exception. of a brief daily maintenance period .'TOXNET fees are currently $18-320/hour

. TOXNET may be accessed using any standard telecommunications software package, including Grateful-Med, or through CompuServe, TELENET, INFONET, or TYMNET telecommunication networks . To access TOXNET, users must register by contacting theTNLM

. Other Resources The Freedom of Information Act (FOIA) is another mechanism that can be utilized by the public to request information from EPA. A FOIA is a written request for records held or believed to be held by EPA where a record is defined as any existing document, memorandum, report, photograph, sound or magnetic recording, computer tape, drawing, or other medium in which information has been preserved . FOIAs are usually utilized when there are not other direct methods, such as hotlines or clearinghouses, ava

' ilable through which the public can request the information

. EPA will release the requested information unless it falls under one of the following nine exemptions :

Matters of national defense or foreign policy

. Internal Agency rules

. ' Information exempted by other statutes

. Trade secrets, commercial, or financial information--Confidential Business Information (CBI)

. Privileged inter- or intra-Agency memoranda

. Personal privacy

. Records or information compiled for law enforcement purposes

. Records of financial institutions

. Geographical or geophysical information and data concerning wells

. FOIA authorizes EPA to charge requesters the direct cost for any searching, reviewing, and duplication required to respond to the request if these costs exceed $25 .00 . The National Technical Information Service (NTIS), a component of the Department of Commerce, is used extensively by many EPA system managers to make information available to the public . NTIS, by law, is self-supporting and sells its products and services to users on a costrecovery basis . NTIS reproduces and .sells the material . created by EPA which include s publications, diskettes` CD ROMs, magnetic tapes, and video tapes . To search online for environmental reports, NTIS's Bibliographic Database is offered through various commercial services . In addition, NTIS publishes a twice monthly subscription, the NTIS Alert on

### p. 60

Environmental Pollution & Control . This subscription provides summaries of newly issue d 

### environm ental reports and studies released by Government agencies

. NTIS offers several EPA databases on computer tape and CD-ROM . Some of the databases are text only, requiring the user to provide their own search and retrieval software

. Available databases include : CERCLIS CERCLA Information System (text only ) ERNS Emergency Response Notification System (text only) FINDS Facility Indexing System (text only ) ISI Information Systems Inventory (an inventory of inventories) IRIS Integrated Risk Information Syste m PCs Permit Compliance System RCRIS Extracts RCRA Information Syste m TRI Toxics Release Inventory (CD-ROM ) TSCA Inventory Toxic Substances Control Act Chemical Substances Inventory

### p. 61

APPENDIX M


### GAO REPORT ON EPA USES OF TRI DATAlp 

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rAmptrourr Grarm of the United States B-243145 Jw-le 27, 1991 -To the pre , k

_%K %U of the Smate =0 the .Sptmkff of the House of ReTresentatives Tak Ill . section 313 . of the Superfund ANWAMents and Reaulhori=ion Act of 19fk rcquires manawritm- to report annually on their toxic chemical emlssi= to . the Environmental protec--jon Agency (EPA) and the states. Section 313(k) of the act requires tne US. Geiwral Accounting Office to review m%*s and the states' impkmientation of the To%k Release Inventory Proown. Accordingly, this report discusses the purposes for whkh and tie extent to wldch EPA. other federal agencim states and the pub0fic have umd the emi:sxions data; the st, ._ps taken, to make the inventory available and amvssible to the public, and Iegigative and 3dminisa-alve optirns to improve the usefulness of the inventory
. Vie are sending copies of this repon to the appropriate House and Senate committem ; the AdnunLitraw

. ErA; the Director, Office of Managesneitt, and Budget; and other buciev .,ed partim We will make copes available to othem upon request
. .

. This work vvw performed under t1w direction of Richard L Ifembra, rhrector, FAvironmental Pluection Isates, who may be reached at (202) 275-6111 . Other major comibutors are listed In appendix VII

.

Charles A . Bowsher fo-J4 Comptroller General of the United Statesp . 64 Z Af - 2 % 

# ia,L ~,dve Suiinnirnw

.

chemical disasters--such as the accidental release of a deadly gas in 

## Purpose Bhopal, India, in 1984 . that killed ard irCiured thousands of people have increased demand for better information about toxic chemical the Emergency PI g emissions . In response, the Congress passed anni n -nd Community Right-to-Know Act of 1986, requiring manufacturers to report each year on their toxic chemical emissions to the Environrwrital ProtecZion Agency (EPA) and the states

. Ep.% compiles these reports into an annual inventory. In 1990, EPA reported that over 19,000 faclutie; reported f67 the 1988 inventory and had emitted about 6.2 billion pounds of toxic chemicals
. As required by the act, GAo aawssed how EPA and the states have irnplemented the Tox1c Release Inventory Program . GAo reviewed (1) the purpcv&s for which &-ld the ext-ent to which EPA, othe. federal agencies, states, and the public have used the data ; (2) the efforts to make the inventor-y available and accessible to the public-, and (3) waY3 to make the inventory more useful

. The Congress cnvisioned that the Toxic Release Inventory would give 

## Back--tround the public unprecedented access to environmental data that it could use to prompt industry to control emissions . The data were also to serve as atool for government regulators to better measure the success of environmental programs and to help them work with inaustry to identify ways to reduce -,jollution

. The act requires manufacturers that produce, import, process, or use specified amounts of I or more of over 300 chemicals to report their emissions to EPA and 'he sta . Facilities must estimate the quantity ofchemicals emitted directly into the air, land, and water or sent to locations that treat, store, or dispose of toxic waste . Additionally, the act requires that EPA make the inventory available and accessible to the public through an on-line computerized data base and by other means

. Results in Brief Although the inventory has been available only since 1989, it has become a valuable source of environmental information . For example, federal and state govemments have used the data to enact laws designed to control and reduce toxic emissions . Also, the public availability of the data has prompted some companies to set emissions reduction goaiz

.

r"O 2 GAO/RCZD41-121 Tozk Rel~ 1~uw7 Fngmm5

EzemtJve SUMALM7

Segments of the publile-predorrzinantly enviroranental and public interest groups- -use the datz extensiVC13r . FRA, states, and manufac turers reported, however, that tht-1 have r-eceived fewer requests for th e data from individual ciLtizens
. A GAO poll diseclosed that more than half ofthe residents in three counties with high levels of emissions were unaware that the data were available to the ptiblic . EPA~s public outreach efforts have been limited because of other progxarn priorities
. The inventory would be more useful to regulators and the public if it were comprehensive. At present, it does not include data on many toxic chemicals or on emissions from nonmanufacturers,--induding federal facilities-which are not required to report. The inventory also does mx include data from at least 10,000 facilities that have notmet their reporting obligation . The quantity of tox:ic,.~rnissions not reflected in the inventory is unknown but could be substantial--as much as 95 perrent of total emission% according to estimates by the Office of Technology Assessment. Finally, because most of the dau are not venfled, their reliability is questionable

. 

# Principal FIndings Use of the Inventory Is Within a short time, the inventory has become an important source of Extensive environmental data . Sponsors of the 1990 Clean Air Act Amendments, for example, used the data on air emissions to show the need to regulate more a;r pollutants

. EPA is working with industry to halve the emission of 17 inventory chemicals by 1995. States, such as - tts and Oregon, have used the data to pass more stringent laws to reduce the use and the emission of toxic chemicals . Moreover, puNdcity concerning the inventory has prompted some major companies to set polhition reduction goals. For example, one hirge nationwide chemical firm plans to reduce its emissions by almost 90 percent by 1992. Individual Citizens' The inventory data are available to the public through an on-line data Demand for Inventory base, a national repo -it, a computer diskette, and other formats . Certain Data Is Limited groups-chiefly environmental and pubUc interest groups-use th e data extensively . However, a%, state, and industry representativeshave received fewer requests for this information from individual citizens

. A GAO Poll found that more than 50 percent of the residents in three counties that reported high levels of emissions were unaware tha t

Page 3 C640/10CED401-121 Tozk RW~wm 1wv=twy fteg~-NEiLecutive Summary

the data were publicly available, although inany expressed intere .-A ir learning about toxic emissions Li their communities

. EPA has worked with several groups of professionals, such &% librarians and journalists, to publicize the availability of the data and to educate these groups about the invenLory . However, other program deman&% have linuted EPA's public outreach efforts . In addition, program officiak have disagreed about whether EPA should be engaged in interpreting the significance of the data for the public

. 

### Inventory Could Be Jmproved in Several Ways Include 'Aore Fznissions %urces The inventory would be more useful if it wer? more comprehensive . At and Chemicals present, it oinits datta from many sources of toxic emissions

. Nonmanufacturers and facilities with fewer than 10 employees are not required to report. Nor are federal facilities required to report, although EPA has idertified about 850 federal facilities subject to other federal environmental laws. The inventory also omits data on many toxic Owniicals, including some known or possible human carcinogens, and data are lin-dted on pesticides used by the agricultuml sector. Although EPA hasthe authority to expand the report-ing requirements, it has not comprehensively identified and prioritized which sources and chemicals should be added

. EPA would need legislative authority before it could require federal facilities and facilities with few employees to report

. Increase Compliance With The inventory would also be more comprehensive if more facilities met Reporting Requirement their reporting requirements

. Ena and states estimate that at least 10,000 facilities are not complying with their legal obligation to reporL On the basis of data from 39 states, GAO estimates that nationwide at least 36 percent of facilities required to report did not do so for the 1988 inventory . In GAds view, problems with EPA's enforcement efforts are partly responsible. For example, several EPA regions are using inefficient strategies to identify nonreporters, and as of March 1990, EPA had resolved only 68 of 209 civil complaints issued against nonreportemMoreover, the absence of explicit authority under the Emergency Planning and Conununity Right-to-Know Act to inspect facilities for compliancL may make it difficult for EPA to enforce the program . At present, EPA has to rely on inspection authorities granted under other envirwimental laws

.

Page 4 GAO/RCED81-121 Tojdc Rolease Inventory P giExecutive SOMMM7

Verify Moi-e &missions Data Users would have greater confidence in the inventory if EPA veffied more of the emissions data

. k --A has limited knowledge of the data7s quality, having reviewed the 14ata from only a few of the more than 19,000 facil ; ties that subn-dtt--Pd reports . Problems identified included tE w failure to submit required reports for all chemicals and the under- or overestimation of emissions . To date, EF-A has used its resources to idemtify facilities that have not repo, ted ral :her than to evalu te the ial i 4 4t t-W of the reported data
.

9AO recommends that the Congress amend the act to (1) require federal 

## Recommendations to facilities to submit emissions reports, taking into account the national 

## the Congress security implications of having to report on some toxic chemicaK and (2) provide EPA with explicit authority to insped facilities
. 

## Recommendations to GAo recommends that the Administrator of EPA, among other things, (1) identify which sources of toxic emissions, i=luding norimanufacturers 

## EPA and facilities with fewer than 10 employees, should be required t o report and which to3dc chemicaL3 should be added to the inventory, (2) develop a public outreach strategy that more effectively publicizes the availabWty of the data, (3) develop an effective regional inspection strategy to better identify nonreporters and issue national guidance foir implementing this strategy ; and (4) place greater emphasis on verifying the data, especially the emissions estimates

.
Ep .% generally agreed with GAo's findings and recommendations, statingAgency Comments that the report presents a fair and balanced evaluation of the programEPA recognized the desirability of expanding the reporting requirementsbut had several concerns, including the potential burden on small businesses and the national security implications for federal facilities . In GAO I s view, these are legitimate concerns that Emand the Congress should consider in nxx1ifying the program However, GAo believes that these concerns should not override efforts to expand the inventor3%Policymakers and the public need more comprehensive data to set environmental priorities and measure progress in reducing pollution
.

Page 5 GAO/20M .91-121 Toxic Rdo~ Lnmentory P s

# Contents

Executive Summary 2! 

## Chapter ICD 

## Introduction 7%e ToxiclRellease Inventory : What IL L- and How It 10) Works

. Program Administration 

### Toxic Releases Nationwide- An Overview Objectives, Scope, and Methodology Chapter 2 2M 

## Inventory Is Useful, Inventory Helps Federal Agencies Manage EnvironmenlaI 20) Propams 

## but More States Use Data to Regulate Toxic Chemicals 2Z 73ompreheivrisive Inventory Motivates Industry to Establish Pollution 24 Informatio'll Is Needed Reduction Goal s Enviromnental and Public Interest Groups Use Invertory 25 Extensively Comprehensive Data Would Make thie Inventory More 26 Useful Conclusions Recommendation to the Congress 30 Recommendation to the Administrator EpA 3 1 

### 31 Agency Comments and Our Evaluation 31 ,hapter 3 32 

## .nvento .7 Is Produced Citizens' Demand for Inventory Data Is Limited 32 

## n Multiple Formats

. EPA and States Are Using Various Public Outreach 35 1 Strategies )ut Individual IndustrY Is Primary User of Public Data Base 37 Users Are Generally Satisfied With the Public Data Base ,itizens' Demand for EPA Has Not Assessed the Value of Various Data Formals 38 )ata Is Limited Conclusions 401 Recommendations to the Administrator, UA 41 Agency Comments and Our Evaluation 42 42 

## ,'hapter 4 43 

## nventory Data Need Little Is Known About Data Quality 43 

## o Be Verified EPA Is Correctly Transcribing Information InW the Data 4T Base Conclusions 4 9 pav 6 GA0/2CW*i-in T03dc Reb~e hmmemy PkV_

# ~ AR

Contents

Rucommenda Lions to the Administrator, EPA 48 -Agenry .Corar .nents and Our Evaluation 4 8 

## ,hapter 5 49 

## mproved Many Facilities Are Not ReportingTheir Relensies 49 EPA's Compliance and Enforcement Actions Against 52 

## P,nforcenient Would Nonreporters 

## felp Fmsure a More ERA Is Not Taking Enforcement AcUon Against Late 58 

## 3omplete Inventory Reporters Conclusions 60 Recommendations to the Administrator, EPA 60 Recommendation to the Congress 60 Agency Comments and Our Evaluation 60 

## ~ppendixes Appendix 1: Technical Methodology .62
7 Appcndix II : Standard Industrial Classification Codes 66

Covered by Reporting Requirements Appendix IU : Inventory Chemicals for Reporting fear 67 1988 Appendix IV : Description of Data Formats 72 Appendix V: List of Selected Publications by the Fc- deral 73 Government, State Govenunents, and Envireaunental and Public Interest Groups Appendix VI : Comments Prom the Environmental 77 Protection Agency Appendix VII : Major Contributors to This Report 89 "'ables Table 4

. 1 : Results of Regions' Data Quality Reviews Table 4 .2 : Results of Transcription Accuracy Test 47 Table 5 . 1 : EPA's Estimates of Nonreporting 50 Table 5 .2 : Estimates of Nonreporting, by State 51 Table 5.3 : Length of Time Taken to I&nue Complaints 56 Table 1 .3: Final Status of Random Digit Dialing Sample 64 Table TV. 1 : Availability of Inventory Data Formats 72 

# ?igures Figure 1 . 1 : Steps in Making Inventory Available 12 Figure 1 .2 : Program Expenditures 14 Figure 1 .3: Percentages of Total Releases and Transfers of 15 Toxic Chemicals Figure 1 .4 : Geographic Distribution of Releases and 16 Transfers

PaSe 7 GAO/IKZD.01-121 Tecdc Releaw hmstory P"W~ON A, Contents

Figure 2

. 1 : Uses of Inventory by the States 23 Figure 2 .2: OPerational and Administrative Chan" by 25 Industry P-gure 3 . 1 County Residents' AwarerFss That Feports 34 Are Publicly Available Figure 3.21 : -:7,ounty .Resident.-,' Interes*6 in -Learning About 35 Toxic Releases Figure 3 .3: Users of Public Data Base 37 Figure 3 .4- Factors Affecting Future Use of Data Babe 39 Figure 5. 1 : Inspections to Identify Nonreporters 53 Figure 5.2: Success of EPA Regions'Targeting Strategies .54 in Identifying Nonreporters Figure 5.3 : Complaints Lisued and Settled by EPA Regions 56 Figure 5 .4: Late Emission Reports for the 1988 inventory 59

Abbreviations ATSDR Agency for Toxic Substances and Disease Registry CD-Rom Compact disk-read only memor y CFC Chlorofluorocarbons EPA Environmental Protection Agency EPCRA Emergency Planning and Community Right-to-Know Act GAO General Accounting Office GPO Government Printing Office IMD Information Management Division NIJV National Library of Medicin e NOAA National Ocearuc and Atmospheric AdministraZion NRDC Natural Resources Defense Counci l N"ns National Technical Information Service 0CM Office of Compliance Monitoring MS Off ice of Toxic Substances sic Standard Industry Classification mxNEr Toxicology Data Network Page 8 GAO/RCZD*1-121 T-dc Vele- 1--t-y FmW-

### 67

BLANK PAGE

ftse 9 GAO/RCMOI-121 Tadc Rek~ L~tmy Pnw~IMT ~K

5.7 7

. L



# g!'M 

# Int T .odudion

Chemical discastem-such as the accidental release of a deadly gas if, Bhopal, Jr.dia-

-9&4 that killed and injured thousandbof people-- along with a b. Ir environmenta: problems-polluted air and water, toxic waste siL.- Azone depletion-have increasi-d demand for better information about toxic chemical emissions . Policymakers and the public need adequate information or . industrial pollution to determine where the need for action is greatest and t6 better measure the results of current environmental policies and programs so that limited resources can be used effectively

. In 1986, the Congress responded to these information needs by enacting the Emergency Planning and Community Right-to-Know Act (UCRA) (P.L 99-499), which required thousands of industrial facilities to report on their use ard release of hundreds of chemicals

. A key provision of n~m required manufacturers, starting Ln 1938, to report annually to the Envirorunental Protection Agency (EPA) and States tht- estimated quantities of toxic chemicals emitted directly into the environment ci transported to waste treatment, storage, or disp-dal location-

. . I FTA is required to collect this information, compile it into a Toxic Release inventory, and make it available to the public through various fonnats, including a computerized data base

. 

## Phe To3dc Release The Toxic Release In-entory contains nationwide information cn toxic hemicals emitted by manufactucing facilities .2 The in-,,-ntory provides 

## nventory : What It Is cinformation on roubne releases to the air, ground, and water ; cn acci

## md How It Wor'ks dental spilIs and leaks ; and on toxic waste sent to treatment, storage, or disposal facilities.3
:eporting Requirements Under Ewmm, all iacilities in the manufacturing sector-Standard Industry Classification (sic) codes 20 through 39-that have 10 or more full-time --mployees must report if, during a calendar year, they (1) prod-_

..e, Lmport, or process 25,000 pounds or more of I or more of over 300

"I' .'ie act~ sornewnes referred to as taw M of the Simerfiind Amendments and ReauthLwization Act of 1986, dr. zwgWrecl the creation of state and local phaining organizations to prepare rnr chemical accidents anC remuired bKhistrial facilities to repor . their hxmrdous awnural inventories annually to local planning org-umns . Our report does not examint these aspects of the lesislackwi

. 2a,cM Covers f%dI in the ManufaMtring sector in thr 50 statm the District of Columbia . Puerto .%cu. Arnencan F inics. Guarn, and the Northern Mariana Islands. Appendix 11 lists the industries
. 3Appendix In Has the reIxirtable cheirkah for the 19M irmwitory

.

Pase 10 GAO/WED-91-121 Toccle Releam Inventory Pnommfor--12) aw HUM vmwr-U cr mwrGO %mod f*rm-a orpwa' wv, dw-rw LML-r than MY I affAw Mmww CA$?*~ . Ve w Fan-WjmUW swel Lhr*rrpwtftvM- .ftvmwKwA#--,O a rn"ri few -or* iiwa*~d to cm and to thr musr NOWI cint (ACAXI so bwUP4 Amww rw$wnmg bb bwd cm dmft~d padw or uw. wpwu awe be mip- =am r"s if $w ow h or catimaud cc aw m"Alm bwib 4 =no) wj* 20 eve 11 - I - I laws Md PffmmL raeftmm my dn ch"r emmusm by awd i rmgp - wM k dau at by swow amadwd dwwong woomrnma %w=uim Ow a6samw MWORM" ci tbr fmgw# awapOWW ip I Tbpy awe kWbme *%vJw t* tm* A - 1 1 , -- m cmiwd ma Ow air dW*w*d Jav rm" awl wwww &we" of w 40-M& IKSMA26 tnmwfmud in vfvdewuo
- . I* VA*ik- wviav uro-mm pON" . or h" it" WWWWWONS %POT . b"WOM OM LK*WS Vwd bw aw (1) M"~ W"" *A aw4ON" mum **W the yrw, 121 pwVran kw%%di dw dmwk:m am amid

. mW 92 ; dnft W*g W 9MAt thP dw MmUix Prrvvaow AA1 4 low . *Ah nVarUng pW ISM, fadMin wO Ambr MOSIPA to mmxvww the we"Wift of W11Wwww ~ 

### T)w prwra by ui*fi a% devoiVs m mmal bwvwy=4 mkm K PaWic AveibibWty of pubekly mvaAMP ma"sofwwW OPVL &Wfs& IT) A (&-Agy EmiWons Inventory dgm"w" M4 m1w to frpllm cumpmm d3w wokaw ftvwuj6 Mad we& m nvwu to m arml to Ow amw wivir K is kraw. w% frmsftraft rmh repwt ma an mda1w foopmowd dam baw 7~w Pm4arwim i 

### f& mVA4A& toaw VW& dwamo aw Team%& twa Mww% batUN&M of "U&jd fVpWL' IH fk*w . ampawdwack% Md cumm's As Omm "MO am "WANAr

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ftV of 6" as"M %awb*~bWom POWs&NJ Ins

nW Am ROGMA ID SN&A t

a" Few"" cm a" G" FOM AsubUt 0 Chem "

"it VAMP%" Pon* pie ommu

CPA &am %Umwam

PWSMO valfts



## AntidpaW Swents of In fmw6u**v Ow w9le emw*m rvpwum nqL*Pmmw

. aw ckwwm "I"Imd thO thPimbvmmY lebrard "164yooomm NW"wptltmwwvtm pwwfts"fwol

---- P W-M 1 ro*WOWbol PkIWVI OWqo&%Xyat UM r Sir

. IF, W-- ww WNW fma vw to Y~ . no w" ow4kwty 

### %WP MWWIV brMw cuwW pWkem wo, am" to ftw ""m bwma" hopm

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## - .'....llj~ . ~ I -

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### wrl 

## 7 N ;

zjw_ mfmwwjoncL*Sd be med to iwrLify tLcrftd optrwomW cfws4,--% . Fluruwwowe

. lc%Waars md cAhnes. lacWu* en%wmn9fterlW -advormer, bdw%,cxt Lbat the invauory wouW five indlvidcab md coc*-nu=y s unprece&PA-d acmw to &71a rmx,&d to wtxk VnKh fachaW ties to &n ** effmxive strauglo_% f"Tedudog the emroamem

. twafth ru" powd by V"ck mkasm
VA's Economics wW TechrAAo& Dkvkka, OGW of To%Jc Subwanm P"W= -(am), is reopmeible for overWI h, p1 m, tencadon or the T036C Belear 

# A&ninistradon hn-ritory Prow=L A suwU toe Kaffovettees the plog 'sdmy-U),- day oM=mm wuncted by itaff fmm othrr rM &vWAiw ind"W Ow Wanna&~= Njazov

.wnt Diviskn the Ficancedc Assiouvice Division
. the Exieuva CWraia" Ammmunt -,Xvkwm . the Expoet" L'*-&%Mkm Dsvkswa md the fkvfth wW FAvktomeaW Effem Divisim FW4J W

ycovWedby Ok-Offteof klmkidessxO Toide-SobvAsices' OffkV cc CaMPUADW Y"Aaflng0")
. the Office of Enrar"MMMt

. ard rj%'* jq reSkeW affimm In racal yew IM, abiout 52 full4hakCqW-PA*W =ff XbdnLqWW the FVgMM . KCY=UVKM b-*J& nfJt wly waMpdift dw InventorywW makft U tv ad" to thka pub& bLa abso mWdrg facilims awsm of reporting Tv-quitenwnts. promotft their mnMUwxr

. and Ukift enf"muma w0w gainat uww fWW . to
wt*VM fwcal yeam Igo MW 1990. MSpeft appMxwMdy &W melkin to bapienwm the progriam. huressft anmml expendivAres from $8 nuMcm to about 6 19 mililorL ( .See fkg. 1 .2.) Abmd half of the pmVwn*s rewurtm haw bom uwd to cWled wW proem the data siabiamed by%



# oil IN

- C

Fro" 1-2: PWj= EzPD-%dftW" W 0649M In OEM"

as 24- 22 38

$4 13 10

Sourm GAO's anslon d EPA data

. 

# Toxic Releases According to the more than 130,000 individual chemical emissions reports submitted in the prograrWs first 2 year . roughly 19,000 fadli- 

# Nationwide : An ties emitted more than 13 billion pounds of toxic chemkalss in 1988 

# Overview alone, approximately 6 .24 billion pounds of toxic chemicals were reportedly emitted Into the air, land, and water or transferred to waste treatment, storage, or disposal locations . Overall, 73 percent of the cimmicals were emitted directly to the environment and 27 pet cc t transported to other locations . (See fig . 1 .3.)

4D" am bawd an Uw A" 6. IND. wo of Lhe dam Mw in T=dM in Me Cmmmity- %Mond and UWW Ent MCPL ino~

ftV 14 GAO/MCZDSI-ISI Task Rd~ Invummy IP coP . 7 4

Chapter I Introdned-

~'F'We 1 .3 : ftfcenta"s of Tctd Relesses and T(ansfom of Tomic Underg= ;O O%Omicais % 6% Surfacewatr I ROOM

Ak

18% Off-Ske LOOSM
Transfers 9% Public Sewage SotKee: EPA . Most facilities that submitted information for the 1988 inventory weree located in the industrial Mid-Atlantic, the Midwest, the Gulf Coast states, and California . Relatively few of the reporting facilities were from the Rocky Mountain ares, southwestern states, and northern New England . (See rig . 1 .4

. )

paw Is GAO/RCE"1-121 Toxic Release Inventory Ffolp 

# AM-p . 7 7

Chapter I IntroductJon

1 .4: Geographic Distriboution of Release* and Transfers

... .. . . . .. ..

4,PTM~,
M12

. . . N

.

Greaw Thm 2W Mm PwAs 

# EE 100-249.00 Wkn Pounft 50-90.00 ~ion ftwda "9.N &4ftn Pmft

Source EPA .

Page 16 GAO/RCEDOI-121 Toxic Keb~v --twyPmqpChapter I Introductio n

This ;s the last of five reports we were mandated to prepare under the 

## 11jectives, Scope, and, Superfund Amendments avid Reauthorization Act of 1986 .- Az required 

## Methodology by title 111, section 313(k), of the act, we reviewed and the states' implementation of the Toxic Release Inventory Program, including the steps taken to make the irr~ entoi3r available and acce&sible to the public: the purpo---,es for which and the extent to which EPA, other Weral agertcies, states, and the public have used the dam ; and the legislative and administrative optiows to improve the usefulness of the inventory

. To examine EPA's and the states' implementation of the program, we focused on the efforts to (1) make the inventory avaiL-.b!e and accessi to the public, (2) ensure that facilities submit reliable information, (3) accurately and efficiently process the data, and (4) enforce program requirements to increase the number of facilities reporting . To assess the progress in making the inventory available and accessible to the public, we interviewed officials in F .PA and thz National library of Medicine (NI .M) . We surveyed state environmental officials," reviewed EPA's various data format studies, and obtained information from the Government Printing Office (GPO) and the National Techrucal Inforniation Service (N-ris) on the distribution and sales of the data formats
. Additionally, we surveyed users of the public data base to determine whether they were satisfied with the system and whether they desired changes to make it more useful for their purposes . We contracted with a private research firm to poll residents in three counties . Furthermore, we obtained the perspectives of state officials and representatives of public libraries in Illinois, Pennsylvania, and Texas-4he three stat that we selected for detailed review . Finally, we convened a panel with

~d I~ Availka77*he o&

.er mandated reports we nsued were Hxmrdous Waste : issues tiaLty (GAO/RCFZ4;&2 . Oct

. 16, 198n G , M ---- ment (GAO/RCED438-1 . Oct

. 26, 1987~ ~uM - U Ud Tam"( RCENOW9, Jan. 15. 1988); Cauramors Are Being Too LAwally Didenuutwd by Goveffumnt(GAO/RCELmvlivw,se=pL*m, 190)
. mWe did not send our state queKxmnaires to offkiab in American Samoa . GoavL and the Northern Mariana Islands . The Alaska Deparunent of Enrbvnmental Conservation d5d not respond so our questionnaire

.

Page 17 GAO/RCEI)601-121 To3dc I&Wkwe Umestmy ftwop. 80
1 4111,

Inaviducti m

representatives of seven environmental and public interest orgmimtions to obtain their views )n the program, including their e .%im eums using various data formats

.9 To assess EPA's efforts to obtain quality data from facilities, we Akahwd information from EPA and states on their strattlies for helping fargh prepare their reports. We also sent questionnaires ., to facilities ths I=dsubmitted reports to obtain their perspectives on program implenentation, including their degree of satisfaction with the tech--dea l they had received . In addition, we also reviewed the results of EWs data quality reviews and data quality studies prepared by contractors and obtained the views of EPA and state officials on the accuracy of fw-fitiesr release estimates

.To assess EPA's efforts to accurately transcribe the information im endssions reports, we tested whether ail the reports submitted were on&- tained in the 1988 data base and whether key information %-as owrectly transcribed . We observed the entry of data, interviewed EPA and owtractor officials, and reviewed various system documents, inchmEmg guidance on data entry

. In focusing on EPA's compliance and enforcement efforts to ensme that all required facilities submit emissions reports, we interviewed mod/or corresponded with officials in EPA headquarters and 10 regional afficesWe also reviewed a sample of inspection and enforcement caw filles inthe three reg-ons visited and obtained summary statistics from dxseven other regional offices not selected for detailed review . Fhr&ffmore, we obtained information from EPA and states on the stmegoes they used to increase industry's awareness of the program . Three& our nationwide survey and field vir, its, we obtained the views of facWkies on various topics germane to compliance

. To examine how the public, states, EPA, and other federal agencks have used the inventory data and the extent to which they have done sm we sent questionnaires to states, individuals, and organizations that accessed the public data base, and a mndom sample of facilities tka submitted rJease reports . We supplemented these efforts with lesiers of inquiry to EPA regional offices and 13 other federal agencies that we
9'The orgarawbons; were the Ciesn WaW Action PmjeM the EnvironmenW Actim Famodosaw the Envirmmental law Institute, the Envininn .mW Policy Institute, Greenpeace IntemanosooLdbeNetural Resources Defense Courted, wd the Workft Group on Community Right-to-KnowPaee is GAO/RCED-91-121 To3dc Release- -!L~ .Vu

AChaptpr I introduction

beheved could probably use the information contained in the inwntory .111 We contracted with a private research tim to conduct seven focus group sessions composed of industry, loc :-&l commumity, and starz government representatWes to obtain their - . iews or program iWlemersktation and to learn how they used the data . Furthermore, we interviewed EPA headquarters and regional officials. statem-olwanumW awd i)ub!ic health officials, and staff at selected local libraries . We also reviewed the relevant literature

. To identify options for improving the usefulness of the inventoM wereviewed its comprehensiveness, completeness, and accuracy--,20 faLtors we believed would influence how useful the inventory is to &verw users. Vie reviewed thm- factors in the cw%L--,e of addmziirV.g t1w athertwo objectives

. Appendix I contains details on our survey metbods and our metbodology for testing the data bases, reliability
. Our reView was conducted at EPA headquarters in Washingon, D.C
. ; the National Library of Medicine in Bethesda, Maryland ; a private cmitractor's telephone polling facility in Frederick, Marylan~ EPA reoonaO offices in Chicago, Philadelphia, and Dallas ; state environmental and public health agencies and nine judgmentally se)e .ted facilities in Illinois, Pennsylvania, and Texas . Localities were selected an the basis of various factors, including geographic diversity, types, and numbers of reporting facilities . We visited facilities that varied in manufactisring category, size, and number of reports subn-dttedL We also contacted staff affiliated with three randomly selected public libraries in each ofthe three states

. EPA's comments on a draft of this report are included in apperiffin VI . We have incorporated the conunents and our evaluation, where appropriame, in the final report . Our review was conducted between August 1989 amd May 1991 in accordance with generally accept* :d government awfiting standards

.

10riw asencies wet e the Deparanents o(As&n*um Ckawnerim . Defense. Enna. Hed&md Hmooss Semms, Housug -4 Urtan Developoent . hftnw Labor Stawllr~~ and Vaerars Affairs; the Council on Envumnvental Q=Hty; mid the Nabonal Science Foundabon

. Ilm Deparumon of Defense did not respond to our inquig

. Page 19 GAO/RCMOI-121 Toxic Relsonebmemmory P4
Y4 

# -:, .-NE N 1nventory Is UsefW, but More Comprehensive Infor-ril-ation Is Needed

Since the Toxic Release Inventory wasmade publicly availabL- in ISM
. it hvs bec -ome a useful source of environmental information for fedn7al and state agencies and for various nongovernmental groups

. Air enis, sions; data frorr the inventory contributed to the Corgress' decision to regulate more toxic chemicals under the 1990 Clean Air Act Arnendments . Within EPA, where "pollution prevention" is now the watchwor& this new environmental data base has become a useful analytic tooL Some states have used the data to enact stricter pollution control IMM Environmental and public interest groups have publicized the names of manufacturers that the inventory showed emitted large quantities of toxic chemicals . The publicity has spurred some companies to comnk ihernselves publicly to pollution reduction goals

.Although the inventory has been useful, it does not provide a comprehensive picture of toxic pollution nationwide. It does not include fifformation on emissions from many sources of pollution outside of themanufacturing sector-including federal facilities-or from manufacturing facilities with fewer than 10 employees. Furthermore, the inventory does not include data on many widely used toxic chemicals . Tints, although the total quantity of tox :ic substanccs that is emitted but not reflected in the inventory is unknown, it could be substantial-perbaps as high as 95 percent, according to the Office of Technology Assessment (OTA)
. EF-cRA authorizes EPA to revise the chemical list and to require norunanufacturers to report their emissions . Requiring federal facirkies or facilities with fewer than 10 employees to report their emissions, however, would require legislative changes . To date, EPA has not acted swiftly to expond the reporting requirements significantly

. 

## hventory Helps The success of federal environmental programs has been difficult to measure, in part, because environmental managers have lacked com- 

## Federal Agencies plete, long-term data on toxic pollutants in the air, land, and water .' For 

## danage EPA, the Toxic Release Inventory helps fill this information gap, especially with respect to toxic air emissions . Other federal agencies with~nvironmenW environmental and public health missions are not yet using the inven3rogrm-ts tory data extensively, but several agencies reported that they expect to use it in the future

.

' Envirmmental Protmion AA= ltjt~Hum ~jtn Heakh and the Enwomm" Thnxigh Improved MaraMefnent(UAU/XUED43&1 M406,1=1
Page 20 GAO/RCED491-121 Toxic Bcl~e Invenawy P7~ -7

chapter Z inventory Is U3eftLL but More ComprehenWv-2 information In Needed

EPA Uses Inventory for EPA, has, made significant use of the -ventory to support, the enactment New Approaches to of new clean air legislation, develop polluticn prevention and reduction Environmental strategies, and adopt a new approach to enforcement encompassing al l environmental media-air, land, and water

. EPA ., working with the ConManagement gress, used the inventory data on toxic air emissions as evidence of the need to regulate more air pollutants under the 1990 Clean Air Act 'ans to use the inventory's air emission data Amendment-, . The agency pt to support various agency projects required by the acL For exampleEPA's Off ice of Air Quality Planning and Standards intends to use annual emissions data to assess the incidence of cancer and other long-terra .health problems in areas near facilities that report emissions

. E?A is using the inventory in its Industrial Toxics Project, a major component of the agency's pollution prevention strategy . The project involves developing prevention stzrategies for 17 of the inventory chemicals- that are believed to present significant risks to human health and the environment. The goal of the project is to reduce aggregate nationwide emissions of the selected chemicals by W percent by 1992 and by at least 50 percent by 1995 . EPA . hopes to use the annual emissions invemtory to gauge the progress being made to reduce the emissions of these chemicals

. EPA has also used the inventory to target specific facilities, industries, and geographic areas for studies on pollution prevention . For example, Region 11's Air and Waste Management Division contacted 19 companies in New York and New Jersey to seek reductions in their facilities' toxic air emissions. At the time of our review. the region was working with five of the companies to identify reduction straegies . According to regional officials, one facility had installed a vapor recovery system , and another had agreed to use less chlorine, an inventory chemical, in its manufacturing process

. Finally, the inventory has enabled EPA to adopt an innovative cross-environmental media approach for enforcing its programs . In fiscal year 1990, EPA's Office of Enforcement and EPA's regional offices initiated pilot projects to target reporting facilities for cross-media compliance inspections . For instance, Region I planned to use the inventory in conjunction with other environmental data bases to identify facUities for these inspections

. EPA would then inspect selected facilities for compliance with various federal environmental stattiltes . According to EPA officials, the agency may assess reduced penalties for facilities found in violation if the facilities agree to undertake pollution prevention activities

.
Page 21 GAO/BCEDOI-121 Toode Rekwe hmemary FnenmChapter 2 Inventswy Is Useral . but M~we Cowpr--I~enwve Infomation Is Needea



### iventory Is Used by Of the 12 federal agencies that responded to our survey, five have used werall Other Federal the inventory forvarious envi-orarental and public beafth projects

. These five agenC

-!es, plus one aeditional agency, plan to use the informa- gencies ; tion in the future

. The federal agencies outside of EPA that a. e
. - usingorplantouselt-- inventory most extensively are the Agency for Toxic Su~--tances - :,, .i Disease Registry (AMR) and the National Oceazuc and AtMoSpWeric * Administration (NoAA"1 . AIMR, whose mission is to prevent or mitigateadverse human health effects resulting from exposure to hazardous substances in the environment, uses the emissions data to assess the present ahd- future impact of these substances. It also uses the data to prepare toxicological profiles of hazardous chemicals

. NoAA is working with EPA's Office of Chemical Emergency Preparedness and Prevention to incorporate the data into a computer program that fire fighters and other emergency workers use to deal more safely and effectively with accidental releases of hazaretous substances . According to NoAA, the data will help the agency identify high-risk geographic areas-for example, localities Y, here toxic chemicals could be released close to high-density residential areas, schools, and hospitals

. 

### ates Use Data to IAke the federal government, state agencies are using the inventory to help manage environmental programs . As shown in figure 2 .1, many ~gulate Toxic states have used it in various ways, including tracking toxic chemica l emissions, enforcing environmental programs, and regulating toxic .tendcals chemicals

.

Page 22 GAO/RCED-01-121 Toode Release Invommy Prognm

## -40

Chapter 2 brventory is UeefuL but More Comprehensive into-mation Is Needed

igure 2.1 : Uses of irwntory by th& W39 J2 Nwvbwof 9tNes 46 44

12

4 1

Note : AN 50 states were surveyed, as well as Puerto Rico and the District ol Coluirbia. Alaska did not respond

. Source : GAO*s analysis of questionnaires from states
. 

### Various EPA, state, and environmental organizations we contacted have credited the inventory with having stimulated the enactment of more stringent pollution control laws in some sta . In 1989, for example, Oregon and Massachusetts enacted the rim laws in the nation requiring reductions in the use of toxic chemicals . The legislation was largely brought about by the efforts of public interest research groups . In Oregon, all compartics that submit reports, as well as hazardous waste generators, must set goals to reduce pollution by 1991 or, for smallquantity generators, by 1992 . The Massachusetts legislature estab'- zhed a goal of reducing the amount of toxic waste generated statewide by 50 percent by 1997. Massachusetts facilities that use Large quantities of toxic chemicals must develop plans for reducing chemical use . In addition, Illinois environmental officials said that OW are using the inventory data from facilities in their state to develop a list of toxic ai r

Pue 23 QW/NCED61-121 Tode Release PnW~p" Cbapter 2 Investor) is Ubeful . kout Mai 2 Comprehensive Infnrinttion IsNe"Ied

contaminants, as required by the Illinois Ewvt osunental Protection Act

. T~le act requires the developmeat %if regulations for these air poilutar.Ls

. Som .- states have found that the invent-ry is an important source of ;nformacion for environmental enfam .entent. For exampie, EPA Region I officizis told ts that Massachusetts environmental agencie7i had use d

- .-s that em, the data to e!ect '46 facili it largS quantities of toxic chemicals in the state's Blackstone River area . These faciliLies were selected to test the feasibility of inspecting industrial facilities for compliance with various state and federal environmental I egulations. This project resembles EPA's new cross-environmental-media, enforcement approach

. According to EPA officials and selcct environmental groups and industry 

## iventory .DvIcifivates representativtm-, the pub!ic availability of the inventory data has 

## idustry to Establish prompted tt- . senior management of some companies to make public 

## oBution Reduction commitments to meeting corporate pollution reduction goals . Those we 

## naLs contacteff noted . for example, that some large manufacturers have established .iignifica-rit pollution reduction goals partly because the inventory is available to the public. One large chemical corporation listed in the 1987 inventory as a t;op air polluter pledged to cut its release of in, entory chemicals to 90 percent of their 1987 levels bly 1992- Similai ly, a representative of another large chemical corporation said that, using 1987 as a benchmark year, the company had established a corporate goal of reducing its toxic air releases by 70 percent by 1993 . On the basis of our nationwide survey, we estimate that over half of anreporting facilities made one or more operational changes as a consequence of the inventory program-2 Representatives of the Chemical Manufacturers Association, which represents many of the nation's largest chemical companies, viewed the inventory as a tool to help facilities identify equipment leaks and other inefficiencies that increase tl Ar emissions . Representatives of several facilities we visited stated that because they had to estimate their c missions levels, plant managers made changes to reduce emissions

. A fiberglass company in Texas installed vapor recovery equipment that i eportedly cut total releases of one of its two inventory chemicals by 90 percent Similarly, a represantative of a large Texas petmIleurn company stated that a new pollution control system reduced emissions by 50 percent. Figure 2 .2 shows tne 2Approiomately 71 peivvitt of the survey's respondents numime operationai changm Our lomw bound esumate. assuming no cluingm were made among nonrespondents, was 61 pet m . 71*samphng error was 3 percent

.
Page U GADACED-91-121 Toxic Release Inventory Pnnnio

## - A&

-A

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29

*MW So WO VW IV SO SOWFAMO 0 f I OWANO so ~ 

# Environmental and Public Interest Groups Use Inventory OF*& M" puwad Ow ~w of up PUMM twoum Ow witab, tnm I%w pub"Y ku ho*d NaUvow aampaunwWwt 

## Extensively towwdordmw taw "60 M 

## rawA tow wrtemy 4" mesww md ff&vwm" anwaahm" wow twnwrv4 awknw, d", md kww fvPwu kw" ftV Pw*Am to No i

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. '"d cc=mmOd tha thejwA-Ponshad s;xnTed waw t7x-6xr2- Lom W CIA=W ttxvtwqvts PLfts- to fvducww 

### Uwir t=x r'leme. caaVa%y Tczkm Cawgim

. fcr v=mpk. four ,,d thut Smu Offa CAUmy had diadwraed dw bw" quantitIgsd cNDrO-OhWOcWbrA= (CFC) to tjw staw . The cm -S hK ofthe -Dkty D=m--(&c1lKJft euwlb* Ove lattiom qumakin o( javenjory hnnka& in the state-received wideipread mw covenW md mW hsvr nmXj- "'a" am Q( the c=uPmdm to aVm to 990P USM9 CIC nma 10 by UK- cad of I M

. 

### 7be MXAW MedL2 hWe Ah" CBS rePOCU A&A19 tile OUUn aad tnm&,,,t U"9$C Pallutka nxtimww WA locoly. In low. for eznn*
. :he natJonel . ewvpuW USA TroUy umed the 1987 javengary dua to pt&Wkb a vprcW 34my wrks dZiUm OR tOlic W&OW tkft mv*ed 2 mWimm dialy rradm., The wrks dawribed L* j&. Vmmd, L .Od mma mdnkm in e*cb sUde arid, the 5W ammilm wbere tjx relmw 0( goac cjm*,& wm Otstru WA MOW the kVPAk*m in tJ* =&bm Tbc imw&Ay h" slao rftvhed R&MOW teiniWon mvmV. In Nmrch md jww IW for "Umpler. AWTV*s World Newb =Ade LW ftmury (mm of nn" "rk, hWjj-O"- 0 tOXIC PonoLim Problem

. 

# CM1PWherW#*?e Data MOMUO " lawd tha 9* Tuxk Reinm Inv"&" ig =dW, j, dam adkk*kk blibraudim from nunmamfmcturem

. ff&VW facgitim. W A 

# Would hialm the numawturtrig fsdlkks with fewer am I o emp ;oyms. lnw bwenuory 

# hiventory More Useful Aw dam " Afteltide Warnuakm on many widely awd toac dwP*ajL Thmforr

. while Ow qmmmy onaxk cheadcob emxW mmuWrbut ncK incladcd in the knvatory is not spLidfkay kmmm t* &mmg catild bip mWK&nMft Wher thm Ow npA&y6.2 billim p mut or "*"IN" "Pa"alin Ow I m wvmtwy . Amwd*g to cyrA. the wverpgmwy nNkw

.U wily a ansil SPINUM Of the UKRI InkrWftm nKWftwj&, Although the 1087 unvatory ww 2o bolm pawl& of cmdu6ma. MA hm rAtimatod -psi kveb dwr go 4W No= Pmmb6 own OMM wxmv c*ff*x%m WW kWc dwa9cab mm no, r --, ot gi in ttmp In,v",ory", Wh* cm mqmim tjw WVarta" a(expamm aw mvew 'My 'a P"r X NWV UGrftd, thV ROOCY 11W rAt)V9 CMPVjW"Vdy two It *i" Otwustian IN to bir akW mid wtw &am ft @& to, br udam , '""0 b"m J* 31- AN& L IVA% '"ammmw 60 dft 606- Or umblammm 40 **W%W . ebww OW *~,m POW. .&,a tk,,,Mw

me U%N%& 1*04 MAL,* ftwamp, m" 04, I ~
ftep INI04~ _%s-_

I .- . Nuir -1-12 ,

V n 4e substanti-VE industrics ouWde the manufixturing sector that tL 

## N'onminufacturerS

. Federal Facilities, and quantities of Unic chemicals annually are not currmWy required tA) SaWl Fadlities Not repon tt-&ir emkLMcm . According to Er-,A, source c2tegme3 not CITTe'21O." required to report include mine .ral mining and processing- od =d gas Required to Report exvwtion

. and agricultura! operations . 7be agriCUIEUral -sector alone used about 8W.000 pounds of pegicidts in I N8. In a May 1991 reP='- the Natural Resources Defense Counicil ( .%ItDC) also tftWightad what it believes are critical information gaps in the inventory, noting that fac& tin that are not pan of the manufacturing sector use subazatial quanimties of toxic chemicals that are not reflected in the inventory.~ %1WC cOwd hwhLitries exempted from the reporting requiremen~ts~ other th2s thoise mendioned above. induiling chtmical storage and transfer fnEgies
. .7 indwstrial dr) cleaners, electric utility pW" . and photo-procemng, Plant& &-cause of Owse reporting em-apttions, many persons whcen we con wted during our review believed ttiat the inventory's rePortnV mnnsre inents should be revised. We found strong support among goveraffME officials, st.-Aft, reporting facilities, and envizwwxmW and pubi3c interest groups for expanding the program's reporting requ ;kremients to cover industries outside the manufacturing sector . Moreover, we foumd that 2s staus and about half of all reporting facilities favored . for example. requiring reporting by hazardous waste treatment, storage

. and disposal facilities. In its 1991 report, NRDC also favored the inclusim of thme Source$, WdAg that such wage management facilities recerve large quantities of toxic chemicals for disposal or treatment mid thmx, fore are among the Important sources of environmental contiminatim we also found support within EPA. where officials in several program offices told us that expanding the inventory to cover large usfts of Made chemicals outside the manufacturing sector would make the inventocy anos e useful to their progranm zPA has the authority to require facilities outside the manufacucring sectortairrpo their emisswm While it has studied the poosibdity ofexpanding the reportft requirements to include sevieral r4nmanufacturing uxhistries, the agency has not yet decided which, If any . should mjxa their taxic m4eases . In fiscalyear IM, for example . zm studied the wMe treatment wWdisposal industry, as well as petroleum arml chemical distributors and trade-related hulustries, and plartned to examine other industries . such as those involved in mining mW extrarUm . Thew studies estimate the quantities and types of chemicals suie b

-rVv %Wd W Koww Wwr Tom Orbuft LVD dw EW#V=WW"9- NUDC Mat&WOM DC- MMV UM)

Few 27kA



# *4 _24fn ~A V"M

Chapter 2 Lnvenuwy Im UseftL, but Mom Compmhensive infornuLumi Is N ed

industries pm-,ess or use but do not recommend which industries sho, .dd be required to report

. Forty stat , 67 percent 3 percent) of reporting fac- es an d .Iitj , other data users strongiy supported requiring federal facilities to report their releases . In its 1991 report -%WX also supported tbz inclusion oal federalfacilities, stating that the disclosure of information on the enviroramental releases from these facilities was important to fulflU the public's right to know and provide comprehensive environmental information to government regulators

. EPA has not estimated the level of toxic emissiorm from federal facilities

. However, in March 1990, the agency issued a study concluding that about 850 federal facilities are sukiect to other environmental btatutes and therefore probably would be obligated to report their emissions if Epm were revised to make federal reporting mandatory . Currently, government-owned and contractor-operated facilites are required to report. However, other federal facilities that use large quantitiFs of toxic chemicals are not, such as army maintenance depots that use large quantities of paints and chemical solvents

. Currently, facilities owned and operated by the federal government cannot be required to report their releases without a legislative change because, unlike other environmental laws, EPmA does not include federal facilities under the definition of "person ." The act's legislative history does not explain why federal facilities are exempL In 1988, EPA requested that federal facilities voluntarily report their releases, bu t few facilities have done so, according to EPA . Although EPA favors making federal facilities subject to amm, it has not taken any action yet because revision of the law is not a high priority, according to an M official . In addition, EPA also believes that federal facilities present a special concern because of the potential national security implications of their emissions data . While we recognize that this is a legitimate concern, in our view, not all the facilities would pose national security concerns, and for those that may, exemptions could be provided

. The states and data base users in our survey familiar with the inventory program generally favored requiring facilities with fewer than 10 employees to report their toxic emissions . In addition, 41 .7 percent (± 3 percent) of facilities also favored this change . In commenting on the need to expand the scope of the Toxic Release Inventory, NRDC pointed out that although citizens have the right to know what toxic chemicals are being emitted by facilities in their communities, their information is

Paw is GAO/BCM@1-121 To3de nd~e invwawy Pnw~

### P. 9T,

Chapter 2 inventory Is Uilerui, but More Comprehassive laormadon Is Needed

limited because small businesses are not required to report their endssions. Although EPA is sensitive that reporting mig' ht impose a burden on small businesses, several m officials stated that, in their view, such facilitiL--, could be responsible for releases .at least equal to those from larger facilities
. in its 1988 regulatory impact analysis for the inventory program, EPA estimated that there were about 164,500 manufacturing facilities nationwide with fewer than 10 employees. How many of these facilities would actually be obligated to report is, however, unknown because iiiformation is not available on how manyuse inventory chemicals in quantities greater than the designated thresholds . EPA has not examined whether the reporting requirements shoWd be legislatively changed to cover facilities with fewer than 10 employees. am officials believe that EPA will assign lower priority to this issue than to determining whether certain nortmanufacturers and federal facilities should report their emissions
.
EPA H&s Authority to The inventory program's present list of over 300 chemicals omits many Expand Inventory toxic chen-dcals used and released nationwide . The Congress derived the original chemical list from list-, of toxic chen-dcals, developed for Ne w Chernicals Jersey's and Maryland's community right-to-know programs-both implemented before the federal inventory program . Marryland7s list included chemicals subject to other federal environmental programs and chemicals known or likely to be carcinogens. New Jersey listed chemicals that were used or imported into the state and the United States in excess of 10,000 pounds per year and those known to cause cancer and other adverse health effects

. The inventory also does not include many chemicals regulated under other federal environmental statutes . For example, officials in EPA's Office of Water told us that the inventory omits 32 of the 126 chemicals fisted in the Clean Water Act's Priority Pollutant List-chemicals that are considered when guidance for water quality standards is developedl . According to an official in EPA's Office of Air, the inventory also omits 16 of 189 hazardous air pollutants regulated by the 1990 Clean Air Act Amendments, although information on these chemicals would be usefulfor projects the agency is obligated to carry out under this new legislation- NRDc has also identified many chemicals regulated under other statutes that are not covered by the inventory . For example, %-RDC found that the inventory does not include information on 41 of 129 chemicals

Pao 29 GAO/RCM81-121 Toxic Release invemmy P .ow

LI2 i 9 N:i A -7~

cm~ 2 -wenuwy U UzefuL but More Comprehemive fafornmtion Is Needed

cited by EP.A's Cancer Amessment Group as, known or probable human carcinoger4 . Additionally,,% 'RDC found that 69 pesticides that have undergoite or are wndergoing examination through FYA's Special Re-, iew process aLso are not reportable cheiaicals

. EPA has the statutory authority to add or dilete chemicals from the inventory list. The agency has added nine cheadcals to the list on its own initiative, but mnst changes have resulted from petitions from industry, environmental and public interest groups, and states

. EFA has olso added seven 3zone-depleting chemicals to the list in response to a petition from NRDC and the governors of New York, New Jersey, and Vermont, and has deleted six chemicals as a result of industry petition& In May 1991 EPA stated that work was under way to establish criteria and priorities for expanding the list. The agency is also planning to add chemicaLc regulated under the Clean Air Act Amendments of 1990. An mrs of ficial responsible fcr processing these petitions told us that it would be beneficial for EPA to comprehensively compare the chemicals on the list with the toxic chemicals regulated by other EPA programs to determine whether any of these chemicals should be added . At the time of our review, however, EPA had no plans for a comprehensive assessment and was focusing its resources on responding to additional petitions for revising the chemical list

.
Condusions In the 3 years since the Toxic Release Inventory first became available,it has become an important tool for government regulators, various nongo-vernmental groups, and industry to use in gauging the extent of thenation's toxic pollution problems and to setting iiational and state environmental regulatory agendas . The inventory would be stdI more useful if it included information from nonmanufacturing facilities, federal facilities, and facilities with fewer than 10 employees and if it included data on additional toxic chen-dcals . Although EPA has the authority to change some of the reporting requirements, it has taken little action

. Such changes have not been a priority in the programs first 3 years and Om have not been pursued . We believe that EPA needs to comprehensively review which other industrial facilities should report their emissions and which other toxic chemicals should be added to the inventory to make it more comprehensive . In its analysis, EPA needs to estimate the potential magnitude of the pollution from these sources and chemicals and the potential health and environmental effects . Moreover, it would be prudent for EPA to establish goals, objectives, and fime frames and determine the resources needed to complete this review

.

ft3e 30 GAO/RCEDOI-121 To3de Bek~ lxvmtwy Pww~p . 93

W Chapter 2 Inventory Is Useful, but More Compreherdve Information Is Needed

To make the- Toxic Release Inventory a incre emprehensive and useful 

## Recornmendati-on to picture of the level of toxic chemical emissicm- . nation-Aride, we recom .- 

## the Congress mend that the Congrese amend EPM to require that ffederAl facilities meeting the reporting criteria submit annua! ixWrts on their toxic emis, sions

.. taking into consideration the national sexwity implications of having facilities report on the emission of some toxic chemicals

. 

## Recommendation to To make the Toxic Release Inventory more comprehensive and usefuL we recommend that the Administrator, EPA. seview which additional 

## the Administrator, sources of toxic emissions should report and which additional toxic 

## EPA chemicals should be added to the inventory. lUs review should considw (1) the volume and type of toxic emissions from nonmanufacturers and from facilities with fewer than 10 employees, (2) eirdssions of widely used toxic chemicals not currently reported, and (3) the health and environmental effects of these emissions

. EPA should establish goals, objectives, and time frames and determine the resources needed to complete this review

. 

## Agency Comments and EPA agreed that an expanded Toxic Release Inventory would be a mo m useful source of environmental information . However, the agency did 7 

## Our Evaluation not specifically state whether it planned to implement our recommendation that it comprehensively review additional emi i sources that might be required to repcrt and additional t chemicals that might be included in the inventory
. EPA pointed out, however, that several issues regarding the inventory's expansion present special concerns, includingthe potential reporting burden placed on smaller facilities and the limited benefits likely to be gained by requiring the agricultural sector to report on its use of pesticides

. We believe that to maximize the inventozys usefulness to policymakersand the public, the inventory data must be as emprehensive as possible, with the data from additional emissions sources and on additional toxic chemicals

. The concerns EPA expressed should be carefully co-sidered. However, these concerns should not override efforts to make the inventory more comprehensive-especially polleymakers and the public need the data to establish 1prionties and to better measure progress in reducing pollution

.

PaSe 31 GAD/VCEDOI-M Tbide Releme bwentary P

F,v ~ 

# inventory JL9 Produced in MultPle Formats, but aJividual Citizens' Demand for Data Is Limited T

The underlying premise of EpcRA is that the public has a right to labow --about the toxic chemicals released by facilities in their conimunitit-, Asdiscussed in chapter 2, segments of the general public, especially _airirorumental and public interest groups, are widely using the datuL indi vidual citizens, however, have submitted fewer requests for the inventory data, according to EP,,,, states, and manufacturing facilities
. EPA and state officials attributed this level of demand to citizens' limited awareness of the inventory and its potential significance . In three counties with high levels of toxic releases, we found that more than half of the residents were unaware that the data were available to the public, although many individuAls expressed interest in learning more about the inventory data from the government

. EpcRA does not require that EPA publicize the inventory's availability err teach the general public how to interpret the data. However, given the Tox~c Release Inventory Program's aim of reaching the public, EPA offlcials recognize the importance of these activities . Accordingly, EPA has been working with states, journalists, environmental groups, and libraries to bring the inventory to the public's attention . Neverthek-m, EPA has not assessed the various strategies it has used to determine which ones have been effective and thus should be continued
.Emm is innovative in that, for the first time, a statute mandates affederal agency to make data direct1y available to the public through an online computerized data base and other formats. Users of the public data base are generally satisfied with the system's usefulness, features, and cost . The merits of some formats developed by EPA remain questio=blehowever, especially in light of development problems and resulting delays in their availability
. 

# Offizens' Demand for mostEPA regional officials, states, and manufacturing facUitie.-~ thatresponded to our surveys reported mild or weak demand from indi

## Inventory Data Is vidual citizens for the inventory data, although environmental and 

### Limited public interest groups are using the data extensively
. EPA and state officials speculated that individual citizens may not be aware of the inventory and may have a limited understanding of its relevance. Our telephone poll of the residents in three counties that have some of the highest levels of emissions nationwide tended to confirm this view

.

Page32 GAO/RCED-91-121 Tomic Releme Inventory humpk- -In 5

, w
Chapter 3 inventory Is aced in Maltiple Forsmat96 but buflyidwd Citkwnie Demanci for Do" is Unilted



### in most FYA regions, 31 states, amd about 83 percent ±3 per-- . Respoiise to Availability Of Offic'P's 0 cent) of reporting facilities reported a "mild ortt-'eak" public response to Inventory the availability of the inventory data- We estimate that about 77 percem (t3 percent) of all reporting facilities nationwide had not received any direel inquiries for information on their toxic emissions
. EPA and state officials speculated that severa! factors may explain ttwlimited response to the inventory d2tra Officials in EPA Regions 1, IV, amdIX attributed it to the newness of the inventory program and individuals' lack of awareness about the data's public availability . Program officials in Regions 1, 11, and VIII believed that unless the data directlyaffected individual citizens-either because the inventory reported information on releases in their neighborhoods or on the health risks at these releases-then they probably would not be very interested in the inventory. State officials in Texas and Pennsylvania believed that the public did not fully understand the hazards the inventory chemicals could pose

.

GAO Poll of Public In a telephone poll of residents in three counties with high levels of AwarenessofInventory reported emissions, we attempted to gauge the public's awareness of the Toxic Release Inventory ., About half of the residents in these three counties-ranging from 47 to 58 percent-had read or heard reports about local to3dc chemical emissions, primarily from television, radio, CW newspapers . We estimate that most people-ranging from 69 to 83 peL-- cent in each county-knew or assumed that the federal government required industries to report their toxic emissions . However, about haff or more of the residents in these counties-ranging from about 54 to 60 percent-did not know that emissions reports were publicly availablen- (See fig. 3 . 1 . )

Appendix I descnbes our pdh" medwdohigy. SonqAmg errors for aU esuntstes are :5 5 pmwmL

Page 33 GA0,12CED81-121 To3de Beiesse Invesitary F'z~

4

Chapter 3 L,ventory Is Produced in Multiple Formats, but Individaa CjawniV Demand for DatA 1z Limited

3.1 : Counq ReSWeTft' jwgr.,j@" Th&t Rqpco ;- .s Am Publizly

so 70 60
so 40 30 20 10 0

/4 /

C-Ndy DeftloyKimE W Aspon*WwOPLMC~

Asuand S do" PApoft Wwa Pojbkly M Did No Knw EndeWons Rwo Vim Pubk 4
Note: SamplLng errors lor all estrnates were :S 5 percent

. Sowce: GAO*s teleplvne PON . Despite this limited awareness, our survey disclosed that most people in these counties-69 to 75 percent-would be interested in leaming about toxic chemical releases from the government. (See fig

. 3 .2.)

Page 34 GAO/BCgD411-121 TWk Aei~ hgvewOwY Pp . 97

-4~ outi- h Chapter 3 Inventory Is Produced in hlu ;tiote Formts, but IndhridualCltizens'Dema forData Is Untited

Figure 3 .2: Cousity Residents' Interest i n Learning About Toxic Releases 140 poicerta" ot PAMr4ndsaft

so 70

so 40 30 aD 10
MMJ M

/41

Cower Note : SamMing errors lor aN estimates are s 5 percent . SoLwce GAO's tekowe pol. 

## EPA bnd States Are Althou%h EPCRA did not require EPA to implement a public outreach campaign, program officials recognize that a successful Toxic Release Inven- 

## Using Various Public tory Program demands such an effort since its aim is to inform the 

## Outreach Strategies public about toxic pollution

. EPA is worldng with librarians, joumalists , and others, to bring the inventory to the public . Althoutli EPA has initiated several public outreach projects, the agency has not thus far emphasized these activities or assessed their effectiveness . Instead,according to program officials, the agency has concentrated on its statutory obligations, such as establishing the public data base . We also found that EPA program officials disagree about the agency's role in irmerpreting the data for the public. Some states have also sponsored public outreach activities, but have been constrained by a lack of funding

. 

## EPA's Public Outreach EPA's primary public outreach strategy is to inform publicActivities intermediaries-librarians, journalists, and officiaLs from trade associations, environmental and public interest groups, and states-about the
Page 35 GAO/BCE"I-121 Toxic Releame Inv*u2my Program93% *A

Chapter 3 Inventory is produced in Multiple Fonsats, but Individual Citt-us' Demand for Data Is Umited

program . For example, the agency has started to work with the Arnerican 11brary Association to familiarize librarians with the progmun . In fiscal year 1990, EPA sponsored several se-minars for journalists and pub-_ lished a guide to help journalists prepare reports using the inventory data.2 The agency also developed a videotape to inform the public about the Toxic Release lnventory~3 At the time of our review, the agency was distributing the videotape to federal agencies, libraries, and a video rental chain
. Enk has offered se,~,e-4 risk-screening sessions to help regions and states interpret the data7s meaning and lin-dtations . ,Although EPA has sponsored various public outreach activities, a prograin official told us that the agency has, to date, placed less emphasis oin public outreach than on other activities
. EPA has also not assessedwhich of these strategies has been the most effective in -eaching citizens . on officials told us that tney recognize the importance of outreach and intend to devote more resources to outreach in the future . We found, however, that um officials disagree about whether E3,A is responsible for interpreting the inventory data for the public . Several o7s officials told us that interpreting the data is the responsibility of public intermediaries, such as environmental and public interest groups, not EPA. Other officials said that it was indeed EPA's role, given the agency's environmental protection mission and the public nature of the inventory program

. Nonetheless, we found strong support among 36 states and almost half of all reporting facilities surveyed for EPA to place greater emphasis on data interpretation to help improve the usefulness of the program . Some industry representatives surveyed were concerned that stories in the press focusing on the high levels of emissions reported by facilities may mislead the public about the potential risks . Others we contacted during our review, inclading several state officials, expressed uncertainty about the meaning of the data~ consequently, they felt uncomfortable responding to public inquiries
. 

### tates' Public Outreach like EPA, states are not required to implement a public outreach cam- 

### .cfxvities paign, although some states have done so . However, 42 of the states we surveyed indicated that funding had a "great . to very greaf' effect on

k7hmbcals, the P

. and the Public, Envirmnental Health Center. NaborW Safety Czuncil (Washhwton"D.C: Oct

. lgffi ~ 3-Wbat It Means to Ym- EPA (Washington

. D.C : Oct

. IN K
Page 36 GAO/RCE3) .91-121 To3dc Releame Inventory Programn99

Chapter 3 lnventm7 Is Produced in bialtiple Forzuats4 but Individual Citiaeta Demaud for Data la Limited

the extent of their efforts . Despite theso funding consti--unEs, 24 states had sponsored public meetings, workshops, or other tra :iniag to publicize the availability of the data. Also, 22 states had sporsored or planned to sponsor lectures, and 23 states responded that they had distributed or planned to distribute EPA information on inventory chenticals . States that undertook multiple public outreach strategies tended to report (1' ) more outside requests for data, (2) requests front a broader range of people, and (3) a greater variety of data uses

. According to statistics from NLM, industry representatives constituted 

## ndustry Is Primary the largest group of users of the public data base during the first 15 

## Jser of Public Data months of rperation- (See fig

. 3.3 .) 

## lase

itare 3.3: Usem of Pubtic Data Race Flesearch Ceftem

125A% 4 482%

8

Fedwal Govwnrlwit

7 .7% PrWate MWIM -5 .5%

Stme GOW11MOrIf

t Note: Percentages are ba an ft total number of user codes that ac4essed #* public data bow from June IM to September 1990. Source: GAO's analyw of NLM data

.

Page 37 GAO/JK3001-121 Ts4c Relowe Inventoiry ProgreasP . 100 C .!- A - s Put R~ 5 8_0 S
. -4t k. ChapLer3 Lriventory Is Produced in Multiple Formats

. but Individnal Citizens' Dem" for Data IS

Users of the public data base we surveyed were geneT-dlly satisfied with 

## Jsers Are GeneraUy asonabIc.11 A ma rity considered its features and found its cost to be re

. jo 

## `)'atisfied W-1401-h the the data bas#- . 'moderately tA_ extrenteiy useful .- However, they indi- 

## :>Ublic Data Base cated that their continued use of the Jata base would depend greatly on the quality and timeliness of the data . Because some early data base us rs voiced concerns that the inventory file on IDY-vL -r was not "user friendly," EPA has continued to make systerr improvements

. Nperiences With the Data Sixty-seven percent of the data base users responding to our survey lase ~ound the system "moderately to exerei .tely useful" ; 54 percent reported that they would likely in,-r,?ase their use of the data base . Most respondents-about 65 percent-also found the system's direct access to other toxicological files on mxr%Tr to be "moderately to extremely useful ."Those respondents who rated systern features were, on average, generally satisfied with, for example, (1) the on-line "help" function, (2) Lh e

. .calculate" function, which can be used to'calculate such things as the total quantity of a specific toxic chemical emitted by fa(ilities in a particular geographic area, and (3) the "ranging7' function, which can be used to (ietermine, for example, whether a specific chemical was einitted in certain locations in amounts ranging between specific numerical values -for example, from I million to 3 million pounds

. Additionally, respondents, on average, indicated that two factors would greatly affect their decisions to continue using the system : the quality and the timeliness of the data . As shown in figure 3.4, other factorsincluded the availability of alternatives, new system features, the availability of system training, and the cost of obtaining the data

.

4Sw,vey was based on user code accowt3 that accessed the data base from Jure 1989 to NovernLwr 1969 .

Page 38 CIAO/W=41-121 Toxic Relowe inwentory Program

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