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Tracking Toxic Substances at Industrial Facilities Engineering Mass Balance Versus Materials Accounting Committee to Evaluate Mass Balance Information for Facilities Handling Toxic Substances Board on Environmental Studies and Toxicology Commission on Geosciences, Environment, and Resources NATIONAL ACADEMY PRESS Washington, D.C. 1990

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NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance This report has been reviewed by a group other than the authors according to procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Frank Press is president of the National Academy of Sciences. The National Academy of Eng~neenng was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Robert M. White is president of the National Academy of ~ . . engmeermg. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal goverrunent and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Samuel O. Thier is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy purposes of furthenng knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agent y of both the National Academy of Sciences and the National Academy of Engineering in providing seances to the government, the public, and the scientific and engineering communities. Lee Council is administered jointly by both Academies and the Institute of Medicine. Dr. Frank Press and Dr. Robert M. White are chairman and vice chairwoman, respectively, of the National Research Council. This study was supported by Contract No. 6~02~292 between the National Academy of Sciences and the Environmental Protection Agency. Library of Congress Catalog Card No. 89~2948 International Standard Book Number ~309 040~8 A limited number of copies of this report are available from the Board on Environmental Studies and Toxicology, 2101 Constitution Avenue, N.W., Washington, D.C. 20418 First Printing, July 1990 Second Pnniing, May 1991 S011 Printed in the United States of America

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COMMITTEE TO EVALUATE MASS BALANCE INFORMATION FOR FACILITIES HANDLING TOXIC SUBSTANCES Clayton F. Callis, Chairman, American Chemical Society, Washington, D.C.; and Chelan Associates, St. Louis, Missouri Glenn Paulson, Vice Chairman, Illinois Institute of Technology, Chicago, Illinois Marilyn C. Bracken, Metcalf & Eddy Companies, Inc., Wakefield, Massachusetts Thomas Burke, The Johns Hopkins University, Baltimore, Maryland Richard A. Conway, Union Carbide Corp., South Charleston, West Virginia Kenneth DemerJian, State University of New York, Albany, New York Robert Harris, Environ Corp., Princeton, New Jersey James D. Idol, Jr., Rutgers University, Piscataway, New Jersey Donald W. Koepp, Ventura County Environmental Health Department, Venturaj California Merle S. Lefkoff, ARS Publica, Santa Fe, New Mexico Cynthia Markert, Sparkletts Drinking Water Corp., Los Angeles, California Michael Overcash, North Carolina State University, Raleigh, North Carolina Philip A. Palmer, E.I. du Pont de Nemours & Co., Newark, Delaware James W. Patterson, Patterson Schafer, Inc., Chicago, Illinois Katy Wolf, Institute for Research and Technical Assistance, Los Angeles, California Project Staff Karen L. Hulebak, Program Director Raymond A. Wassel, Project Director Carolyn Fulco, Staff Associate Lee R. Paulson, Editor Ruth E. Crossgrove, Copyeditor Felita S. Buckner, Project Secretary Shelley A. Nurse, Senior Project Secretary Warren R. Muir, Consultant . -

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BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY Gilbert S. Omenn, Chairman, University of Washington, Seattle, Washington Frederick R. Anderson, Washington College of Law, American University, Washington, D.C. John Bailar, McGill University School of Medicine, Montreal, Quebec Lawrence W. Barnthouse, Oak Ridge National Laboratory, Oak Ridge, Tennessee David Bates, University of British Columbia, Vancouver, British Columbia Joanna Burger, Rutgers University, Piscataway, New Jersey Yoram Cohen, University of California, Los Angeles, California John L. Emmerson, Eli Lilly & Co., Greenfield, Indiana Robert L. Harness, Monsanto Agricultural Co., St. Louis, Missouri Paul J. Lioy, UMDN}-Robert Wood Johnson Medical School, Piscataway, New Jersey Jane Lubchenco, Oregon State University, Corvallis, Oregon Donald Mattison, University of Arkansas for Medical Sciences, Little Rock, Arkansas Duncan T. Patten, Arizona State University, Tempe, Arizona Nathaniel Reed, Hobe Sound, Florida William H. Rodgers, University of Washington, Seattle, Washington F. Sherwood Rowland, University of California, Irvine, California Liane B. Russell, Oak Ridge National Laboratory, Oak Ridge, Tennessee Milton Russell, Oak Ridge National Laboratory, Oak Ridge, and University of Tennessee, Knoxville, Tennessee I. Glenn Sipes, University of Arizona, Tucson, Arizona Staff , ~ James J. Reisa, Director Robert B. Smythe, Program Director for Exposure Assessment and Risk Reduction David J. Policansky, Program Director for Natural Resources and Applied Ecology Richard D. Thomas, Program Director for Human Toxicology and Risk Assessment Lee R. Paulson, Manager, Toxicology Information Center 1V

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COMMISSION ON GEOSCIENCES, ENVIRONMENT, AND RESOURCES* M. Gordon Wolman, Chairman, The Johns Hopkins University, Baltimore, Maryland Robert C. Beardsley, Woods Hole Oceanographic Institution, Woods Hole, Massachusetts B. Clark Burchfiel, Massachusetts Institute of Technology, Cambridge, Massachusetts Ralph J. Cicerone, University of California, Irvine, California Peter S. Eagleson, Massachusetts Institute of Technology, Cambridge, Massachusetts Lawrence W. Funkhouser, Chevron Corp. (retired), Menlo Park, California Gene E. Likens, New York Botanical Gardens, Millbrook, New York Scott M. Matheson, Parsons, Behle & Latimer, Salt Lake City, Utah Jack E. Oliver, Cornell University, Ithaca, New York Philip A. Palmer, E.I. du Pont de Nemours & Co., Newark, Delaware Frank L. Parker, Vanderbilt University, Nashville, Tennessee Duncan T. Patten, Arizona State University, Tempe, Arizona Denis J. Prager, MacArthur Foundation, Chicago, Illinois Larry L. Smarr, University of Illinois at Urbana-Champaign, Champaign, Illinois Sir Crispin Tickell, United Kingdom Mission to the United Nations, New York, New York Karl K. Turekian, Yale University, New Haven, Connecticut Irvin L. White, New York State Energy Research and Development Authority, Albany, New York James H. Zumberge, University of Southern California, Los Angeles, California Staff Stephen Rattien, Executive Director *This study was begun under the Commission on Physical Sciences, Mathematics, and Resources, whose members are listed in Appendix K; and completed under the successor Commission on Geosciences, Environment, and Resources. v

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Preface The taxies right-to-know movement in the' United States stems from increased demands by broad segments of the public for information about the potential for routine and accidental releases of toxic substances into the environment, especially releases from industrial facilities. Citizens have organized advocacy groups, become educated about environmental health and contamination, and begun to participate more actively in environmental decision making. Mass balance information has been thought by some to be a means'of understanding and accounting for actual and potential releases of chemicals from industrial facilities. Others doubt that collection of mass balance information could provide data of sufficient certainty and value to justify its cost. The potential usefulness of mass balance information surfaced as an issue during the 1986 reauthorization of the Comprehensive Environmental Response, Compensation, and I~iability Act (CERCLA) of 1980. The reauthorized legislation, the Superfund Amendments and Reauthorization Act 'tSARA) of 1986, includes a free-standing section Title IlI- known as the Emergency Planning and Community Right-to-Know Law. This law established several federal, state, and local programs for reporting and emergency planning with regard to hazardous or toxic substances. One of those programs is the Toxics Release Inventory (TRI), which was devised to help governments and communities on the local,'regional, and national levels obtain knowledge . Title III requires manufacturing facilities that handle more than specified amounts of any of more than 300 specified chemicals or 20 chemical categories to submit information on environmental releases to the U.S. Environmental Protection Agency (EPA). . ~ about releases of toxic substances The congressional negotiations that led to SARA also demonstrate interest in other kinds of information, including mass balance information. As a result of conflicting views on the usefulness of nationally collecting mass balance data, the House-Senate Conference that led to SARA eliminated a Senate requirement to report mass balance data and directed EPA to obtain independent advice from the National Academy of Sciences about the potential usefulness of mass balance information and the feasibility of its collection. In response to a request from EPA, the National Research Council (NRC) Board on Environmental Studies and Toxicology convened the Committee to Evaluate Mass Balance Information for Facilities Handling Toxic Substances and charged it to evaluate issues relevant to the collection and use of mass balance information. The NRC suggested two phases of study: the first phase was to use currently available data to . . V11

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- V111 MISS BAI-4NCE INFORMATION address the utility of mass balance information for the following information needs: Judging the accuracy of information on toxic chemical releases. Determining the waste-reduction efficiency of facilities. Evaluating toxic chemical management practices at facilities that report to the TRI. In addition, the committee was to determine the implications of collecting mass balance information on a national scale and using the information in connection with the TRI. The second phase would be carried out if additional data and analyses were needed to address adequately the questions remaining from the first phase of the study. This report presents the results of the first phase. In producing this report, the committee tackled an ambitious charge, encompassing small and large manufacturing facilities of a diverse nature that provide information to the TRI on a chemical-specific basis. In carrying out this study, the committee recognized the concern of society for protecting human health and the environment, which in turn leads to questions about human exposure, health risks, and environmental effects. To address such questions, data in the form of concentrations in environmental media are more useful and accurate than are data in the form of mass. Therefore, concerns regarding actual exposures of people living or working in the vicinity of facilities handling toxic substances could not be addressed in this report. Also, the committee did not include considerations of fate and environmental effects of the chemicals released by manufacturing facilities in its analyses and evaluations. The 1987 NRC report, Multimedia Approaches to Pollution Control: A Symposium Proceedings, noted that public interest in a unified approach to pollution control is emerging. The present committee recognized that the TRI is a step toward a multimedia approach and considered the capabilities and limitations of mass balance data in tllis light. The committee evaluated the potential benefits of mass balance reporting against the cost of collection, burdens on reporting facilities, and how the data could provide society with a greater understanding of relationships between industrial facilities and the release of chemicals into the environment. It compared the usefulness of mass balance data for various applications with the magnitude of data uncertainties, using what can be considered rudimentary error analyses~eemed necessary and sufficient for these comparisons. More rigorous quantitative methods (e.g., probability density functions) were not considered necessary. 'The committees analysis focused on engineering and technical issues; a detailed economic analysis of costs and benefits was not within its purview. The committee's efforts were greatly facilitated by the many individuals who 'submitted information and participated in an information-gathering workshop held in Washington, D.C., in March 1988. A list of the participants is presented in Appendix E of this report. This report would not have been possible without the diligence of the committee members and the dedicated efforts of the staff, particularly Raymond A. Wassel, Karen L. Hulebak, and James I. Reisa. The report also had the great benefit of editorial revision and review by Lee R. Paulson and layout and proofreading by Ruth E. Crossgrove. Felita S. Buckner is thanked for her dedicated and able administrative and report-production skills. Warren R. Muir provided valuable input as a consultant to the committee during its deliberations. The National Governors' Association, the New Jersey Department of Environmental Protection, and the Maryland Department of Environment all provided useful information on experiences with the use of mass balance information. Clayton F. Callis, Chairman

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Contents EXECUTIVE SUMMARY General Conclusions, 3 Assessing the Accuracy of Chemical Release Estimates, 3 Evaluating Waste-Reduction Efficiency, 4 Evaluating Chemical Management Practices, 5 Collecting Mass Balance Information on a National Scale, 6 Pilot Study Recommendation, 7 1 INTRODUCTION SARA Section 313, 9 Purpose of This Study, 11 Organization of This Report, 13 2 APPROACHES TO OBTAINING MASS BALANCE INFORMATION Introduction, 15 Engineering Mass Balance, 15 Materials Accounting Practices of Potential Utility, 18 Summary, 19 3 USES OF MATERIALS ACCOUNTING DATA National Governors' Association Mass Balance Survey, 23 Uses of Materials Accounting in New Jersey and Maryland, 26 Summary, 29 4 ACCURACY OF TOXIC CHEMICAL RELEASE ESTIMATES Engineering Mass Balance, 31 Materials Accounting, 34 Conclusions, 37 5 ASSESSING WASTE-REDUCTION EFFICIENCY Introduction, 39 Data for Assessing Waste-Reduction Efficiency, 40 Reporting Requirements, 41 Normalization of Waste-Related Data, 42 Aggregation of Waste-Reduction-Efficiency Data, 48 Conclusions, 55 6 EVALUATING TOXIC CHEMICAL MANAGEMENT PRACTICES Introduction, 57 1X 1 9 15 23 31 39 57

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x Chemical Management Practices, 57 Conclusions, 59 7 COLLECTION OF MASS BALANCE INFORMATION ON A NATIONAL SCALE Introduction, 61 Background, 61 Usefulness and Limitations of Mass Balance Information, 62 National Economic Impacts, 66 Confidentiality, 66 National Materials Accounting Data Collection, 67 Pilot Study Recommendation, 67 GLOSSARY APPENDIX A: TRI (TOXIC RELEASE INVENTORY) CHEMICALS SUBJECT TO THE REPORTING REQUIREMENTS OF SARA SECTION 313 APPENDIX B.: STANDARD INDUSTRIAL CLASSIFICATION CODES WITHIN THE MANUFACTURING DIVISION APPENDIX C: U.S. EPA FORM R: TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM APPENDIX D: CHARGE TO THE NATIONAL ACADEMY OF SCIENCES IN SUPERFUND AMENDMENTS REAUTHORIZATION ACT (SARA) SECTION 313(1) AND U.S. CONGRESS, 1986. SARA CONFERENCE REPORT ON MASS BALANCE STUDY APPENDIX E: MASS BALANCE WORKSHOP PARTICIPANTS AND PRESENTATION TITLES APPENDIX F: NATIONAL GOVERNORS' ASSOCIATION MASS BALANCE SURVEY OF STATE GOVERNMENTS APPENDIX G: NEW JERSEY INDUSTRIAL SURVEY APPENDIX H: MARYLAND STATE TOXIC REGISTRY SYSTEM CHEMICAL INVENTORY APPENDIX I: DEFINING WASTE AND WASTE REDUCTION APPENDIX J: UNIFORM WASTE REDUCTION STANDARD APPENDIX K: COMMISSION ON PHYSICAL SCIENCES, MATHEMATICS, AND RESOURCES REFERENCES CONTENTS 61 71 73 83 87 111 117 123 139 153 177 181 183 185