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OCR for page 23
3
Uses of Materials Accounting Data
Other than efforts in New Jersey and
Maryland, little multimedia mass balance
information has been collected by federal
and state government agencies. This reflects
the traditional structure of environmental
programs and their responsibilities as de-
fined by most environmental statutes, which
usually address specific media. For example,
under the Clean Water Act, the potential for
movement of pollutants to air or soil as a re-
sult of water-treatment measures is not con-
sidered in surface-water protection.
In researching mass balance practices by
regulatory agencies, the committee was as-
sisted by EPA and NGA. Many federal and
state programs were examined through in-
formation provided by participants in a
workshop held by the committee on March
24-25, 1988 (see Appendix E), but few uses
of EMB or MA practices by regulatory
agencies could be documented. Likewise, a
limited amount of EMB and MA data were
obtained from industrial representatives
participating in the workshop. All of the
relevant data obtained from industry and
regulatory agencies were analyzed by the
committee and most of these data are de-
scribed in this report.
The focused scope and authority of major
federal environmental statutes have pre
23
eluded EPA from applying EMB or MA
practices to regulatory programs. Some
attempts under the Toxic Substances Control
Act (TSCA) were made to collect mass bal-
ance information for selected substances, but
these data were not widely available because
of confidentiality restrictions (OTA, 1986~.
The committee observed that uses of MA
data have been more qualitative than quan-
titative. MA data were used by New Jersey
and Maryland to help guide and rank efforts
to understand and regulate toxic substances
in the environment.
NATIONAL GOVERNORS' ASSOCIATION
MASS BALANCE SURVEY
The committee was aided by NGA in
conducting a survey to obtain information
from the states about their past or current
mass balance data collection (Johnson and
Gooch, 1989~. A survey questionnaire was
sent to chief environmental protection offi-
cials in each state (Appendix F). A sum-
mary of the responses from NGA's report to
the committee is presented in Table 3.1.
Twelve states have initiated or plan to
initiate a collection of mass balance-oriented
information; nonetheless, respondents com
OCR for page 24
24
AL4SS BALANCE INFORMATION
TABLE 3~1 National Governors' Association Mass Balance Survey of State Governmentsa
States with Mass States That Plan States That Do Not Plan
Balance Oriented Mass Balance Data or Are Undecided on
Information Collection, Collection Mass Balance
Past or Current Data Collection
Connecticut
Maryland
Nebraska
New Jersey
Rhode Island
Vermont
Virginia
aIllinois did not respond to the survey.
Delaware
Massachusetts
Ohio
Utah
Wisconsin
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Fonda
Hawaii
Idaho
Indiana
Iowa
Kansas
Kentucky
. . .
Louisiana
Maine
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nevada
New Hampshire
New Mexico
North Carolina
North Dakota
Oklahoma
Oregon
Pennsylvania
South Carolina
South Dakota
Tennessee
1 exas
Washington
West Virginia
Wyoming
OCR for page 25
USES OFMATERL4LSACCOUNTING DATA
monly expressed uncertainty about the prac-
ticality of mass balance activities and the
value of such activities for agency programs.
Seven states have performed a one-time sur-
vey or regularly collect mass balance data,
and five additional states plan to collect
these data. Eight states do not plan to col-
lect mass balance data. The remaining re-
spondents believed that the cost-effective-
ness of mass balance data compilations needs
to be demonstrated before agency resources
are budgeted for them.
The few mass balance projects conducted
by state agencies range from comprehensive
reporting requirements for an entire industry
to site-specific mass balance calculations
made by state inspectors to determine com-
pliance with air pollution regulations. All
these mass balance efforts relied on MA
data.
The New Jersey Department of Environ-
mental Protection (NJDEP) maintains a pro-
gram to collect mass balance information.
Under the New Jersey Worker and Com-
munity Right-to-Know Act of 1983, the
NJDEP compiles mass balance-related data,
on a regular basis, from selected manufac-
turers as a supplement to reported environ-
mental releases. For each substance on a
specified list of chemicals, manufacturers
must report annually the starting and ending
inventory, in pounds; the quantity produced
on site; the quantity brought on site; the
quantity consumed on site; and the quantity
shipped off site (as a substance or as a prod-
uct). The model for this program was
developed through the New Jersey In-
dustrial Survey, which was initiated ire 1976.
The Maryland Department of En-
vironment conducted a survey of ap-
proximately 1,200 manufacturing sites in
1985 to obtain information on the amounts
of specific chemicals flowing through these
facilities. This information is referred to as
"annual throughput and is used by Maryland
to set priorities for regulatory actions.
Air pollution site-inspection practices
conducted by the Connecticut Department of
Environmental Protection exemplify the use
of mass balance-related data by the five
other states reporting the collection of these
data. Connecticut inspectors use mass bal-
ance data to estimate the quantities of sol-
vents emitted into the atmosphere from in-
dustrial operations. Such calculations are
used to determine compliance with mass
25
emission limits for the hydrocarbons that re-
act in the atmosphere to form ozone.
Air permits issued by the Virginia
Department of Air Pollution Control and the
Vermont Air Pollution Control Division also
rely on mass balance information. In
Virginia, permits to construct and operate a
facility that would be a source of air pollu-
tion carry requirements to demonstrate (by
use of a mass balance calculation) com-
pliance with emission limitations and to
indicate the expected level of solvent emis-
sions. The agency also has a long-term sur-
vey effort under way to obtain detailed
chemical use information from 4,000 to
5,000 sources of toxic chemicals. Mass bal-
ance data are sought in this survey from
facilities where it is believed to be available.
Vermont uses mass balance techniques in its
State Emissions Inventory for planning and
in case-specific permit activities.
The Rhode Island Department of En-
vironmental Management and the Nebraska
Air Quality Division use a form of mass bal-
ance information to support their air pollu-
tion control programs. In Rhode Island, cer-
tain industries are required to complete air
pollution inventory questionnaires involving
mass balance calculations. The questionnaire
for degreasers and dryers, for instance, re-
quires that industries report the amount of
certain volatile organic substances purchased,
the amount removed for disposal or reclama-
tion, and the quantity recovered in carbon
absorbers. The amount purchased minus the
amount removed or recovered is assumed to
have entered the atmosphere through evap-
oration. The Nebraska Air Quality Division
uses mass balance data to estimate toxic
emissions and plans to use mass balance data
in its Toxic Air Emissions Inventory.
Water pollution control programs in state
agencies generally do not use mass balance
information. This is also true of agencies
whose responsibilities involve the regulation
of hazardous wastes under the federal Re-
source Conservation and Recovery Act or
comparable state authority.
New Jersey estimated that $75,000-
$100,000 would be used for fiscal year 1989
to gather and compile mass balance informa-
tion. Other states planned expenditures
ranging from $2,000 to $275,000; however,
the higher expected expenditures had no
breakdown for estimates specific to mass
balance collection. Maryland had no funds
OCR for page 26
26
dedicates! in fiscal year 1989 for collection
of mass balance data. Additional informa-
tion collection of this type is not planned.
USE OF MATERIALS ACCOUNTING IN
NEW JERSEY AND MARYLAND
The potential value and utility of multi-
media information long has been recognized
by EPA. In 1978, under Section 28 of
TSCA, EPA awarded grants to states to im-
prove information on the manufacture, use,
and discharge of toxic substances. Grants
were received by New Jersey for the In-
dustrial Survey Project and by Maryland for
the Toxic Substances Registry System.
Both programs originated in the rising
concerns about environmental and public
health impacts of toxic pollutants (Maryland
Department of Health and Mental Hygiene,
1983; NJDEP, 1986~. In the late 1970s, an
increasing number of epidemiological studies
of the workplace and outdoor environments
indicated potential associations between ex-
posure to toxic substances and chronic dis-
eases such as leukemia (Infante et al., 1977)
and bladder cancer (Cantor et al., 1978~.
The publication of these studies coincided
with the release of the AtIas of Cancer Mor-
tality for U.S. Counties by the National Can-
cer Institute (Mason et al., 1975~. This atlas
graphically presented U.S. cancer mortality
by location for the period 1950-1969 and in-
dicated statistically significant elevations in
mortality in several industrialized areas.
New Jersey led the nation in overall cancer
mortality in white males. The National
Cancer Institute used a geographic informa-
tion system to link cancer mortality maps
with demographic and industrial data at the
county level. This information is used to
generate hypotheses on cancer etiology that
can be pursued by analytical epidemiological
studies (Blot et al., 1979~. This technique
has suggested that, in addition to cigarette
smoking, other environmental determinants
(especially industrial exposures) are involved
to an extent greater than previously thought.
Furthermore, analytic chemistry capabili-
ties were refined greatly in the late 1970s,
allowing identification of trace amounts of
widely used toxic substances and pesticides
in water supplies, air, and food. However,
the cost and difficulty of routinely con
M4SS BALANCE INFORMATION
ducting these analyses could become prohib-
itive.
Although these new data did not demon-
strate unarguable causal links between en-
vironmental exposures and disease, they did
spur a movement by regulators and health
investigators to understand better the manu-
facture, use, and discharge of toxic sub-
stances. Maryland and New Jersey initiated
their MA studies with the goal of identifying
sources of potential exposure to understand
and prevent adverse human health effects
(Maryland Department of Health and Mental
Hygiene, 1983; NJDEP, 1986) and so
pioneered the collection of MA information.
The New Jersey Industrial Survey Project
In 1977, existing information on potential
sources of exposure to toxic chemicals was
evaluated thoroughly by the newly estab-
lished Toxic Substances Program (now the
Office of Science and Research) of the
NIDEP. This evaluation demonstrated the
paucity of useful information in federal and
state environmental databases and led to the
development of the New Jersey Industrial
Survey (N]DEP, 1986~. The survey was fol-
lowed by the passage of the New Jersey
Worker and Community Right-to-Know Act
of 1983, which was the basis of the current
mass balance program.
The objectives of the New Jersey In-
dllstrial Survey were as follows:
· To establish a database about the
manufacture, use, storage, processing, for-
mation, release, disposal, and repackaging of
a group of chemical substances selected on
the basis of their carcinogenicity or other
toxic effects. Of special concern were sub-
stances likely to be produced or used in large
quantities in the state.
· To identify areas of the state and
population groups that might be subject to
an increased disease risk due to environ-
mental exposure to toxic agents.
· To use the database to support the
study of methods aimed at reducing or elim-
inating the release of toxic substances into
the environment.
A list of 155 chemicals was developed for
inclusion in the survey (Appendix G). Three
OCR for page 27
USES OF MATERL4LS ACCOUNTING DATA
major criteria were used to evaluate chemi-
cals for inclusion:
- Evidence of chronic health effects,
such as carcinogenicity, mutagenicity, or
teratogenicity.
· Evidence of U.S. production in large-
volume. commercial Quantities.
LiSt.
.
· Presence on the EPA Priority Pollutant
The New Jersey Industrial Survey focused
on the manufacturing sector and several
other industry types known to handle large
amounts of toxic substances. Approximately
15,000 facilities were surveyed, including
those in Standard Industrial Classification
major group codes 22 through 39 inclusive
(Manufacturing Division), selected facilities
in codes 46 through 49 (including pipelines,
transportation services, communication, and
electric, gas, and sanitary services), code 51
(wholesale, trade, nondurable goods), and
code 76 (miscellaneous repair services).
Facilities with more than five employees
were included.
The New Jersey Industrial Survey con-
tained provisions to protect confidential
business information and specified penalties
for noncompliance. The following list
summarizes the information requested by the
survey:
· Facility location, number of employees,
and general use of selected substances.
· Operations at the facility involving
each selected substance, including the quan-
tities of raw materials used and products
manufactured.
· Selectee! substances released into the
atmosphere and the quantities released.
· Selected substances released into waste
disposal streams, disposal methods, disposal
sites, waste disposal technology employed,
and previous disposal practices.
· Selectee! substances in the waste-water
streams, treatment prior to discharge, and
quantities discharged to publicly owned
treatment works.
· Information on other points of release
of the selected substances.
Companies were to report the use or re-
lease of any quantity of each substance; no
· · · ~
minimum reporting requirement was es
tablished. Respondents that were unable to
27
provide actual figures were required to
supply estimates derives! from engineering
estimates; process-related mass balance
studies; or field tests conducted by the facil-
ity, equipment manufacturers, or govern-
mental agencies. Less than 10% of the
respondents requested confidentiality of
reported information (NIDEP, 1986~.
Validation of Information Reported
Realizing the complexity of the informa-
tion requested and the substantial potential
for inaccurate reporting, New Jersey made a
commitment to provide expert assistance to
respondents and to conduct routine field au-
dits. An engineering staff reviewed all re-
sponses and worked with respondents to im-
prove response quality. At most major man-
ufacturing facilities in the state (several
hundred), field audits were conducted after
the responses were received. Individual pro-
cesses were reviewed, and all points of use
and release were tracked. As a result of this
extensive validation program, original re-
ports were revised for 75% of the survey re-
spondents, which greatly extended the time
necessary to develop accurate information.
The original release estimates for approxi-
mately 25% of the survey respondents were
revised due to gross errors in release
estimates. In some cases, the 90-day report-
ing period was extended for several years
before responses were made final. Revisions
were necessary for a broad range of reasons,
including improper identifications (e.g., per-
mit numbers) as well as gross underreporting
of releases (e.g., such as small facilities using
open tanks of solvents and reporting
negligible releases).
Although the New Jersey Industrial
Survey is the most comprehensive survey
conducted to date, the information has many
limitations. The survey response rate was
43%, which constrained data interpretation.
New Jersey estimates that the response rate
would have been approximately 50°h if pro-
cedural problems had not been encountered
in mailing the survey (e.g., inaccurate mail-
ing lists) (NJDEP, 1986~. And, although
technical reviews and field audits were done
to verify reported information, the collected
data may underrepresent releases from all
relevant facilities in New Jersey, because not
all facilities provided data. In many cases,
OCR for page 28
28
field audits revealed that erroneous
information was reported audits were
not conducted at every facility. New Jersey
officials have stressed that, in the absence of
field audits or monitoring data to follow up
survey responses, it is impossible to ensure
the validity of reported emission and dis-
charge information without additional infor-
mation on the quantities of the raw materials
used and the products manufactured
(Stevenson, 1988~.
New Jersey reports that the Industrial
Survey information has been used for
several, mainly qualitative, purposes,
including the following:
· Occupational health surveillance to
help define the number of workplaces in
which toxic substances are used and the
number of workers who are potentially
exposed. More than 809'o of the workplaces
with potential exposures to mercury would
not have been identified without the survey
(NJDEP, 1986~.
· Identification of specific industrial
activities as potential sources of water con-
tamination in a study of hazardous con-
taminants in New Jersey public water sup-
plies (NIDEP, 1986~.
· A statewide dioxin investigation to
find several previously undetected industrial
sites with workplace and environmental con-
tamination with 2,3,7,8-tetrachlorodibenzo-
p-dioxin. Extensive contamination of soils
near the Passaic River was discovered, which
prompted an investigation of the river and
uncovered contaminated sediment and
aquatic biota (NIDEP, 1985~.
· Refinement of the New Jersey en-
vironmental permit process by allowing the
state to improve its assessment of discharges
and apply more relevant conditions for the
issuance of permits (NIDEP, 1986~.
· Enforcement and regulatory support to
develop the Environmental Cleanup and Re-
sponsibility Act, the Toxic Catastrophe Pre-
vention Act, and the New Jersey Pollution
Discharge Elimination System. The state is
using survey information to assist in the de-
velopment of the Air Toxics Strategy to
revise regulations concerning the emissions
of toxic chemicals into the environment
(NJDEP, 1986).
· As the precursor to the implementation
of the New Jersey Worker and Community
Right-to-Know Act. New Jersey relied on
~45S BALANCE INFORAL4TION
experience gained in conducting the survey
to determine its approach for implementing
portions of this act. For example, two SIC
codes were addecI, because in conducting the
survey, New Jersey found that facilities in
SIC codes 20 and 21 (food and tobacco man-
ufacturers) use considerable amounts of haz-
ardous substances (NIDEP, 1986~.
· By a public-interest group, INFORM,
as a basis for a preliminary characterization
of waste generated at New Jersey facilities
for an extensive study on reduction of waste
generated at chemical manufacturing facili-
ties (Sarokin et al., ~985~.
· Improved information for risk com-
munication (e.g., statewide and community
profiles of chemical use and release). This
has greatly assisted in risk communication
efforts with community groups.
· Focusing and planning hazardous
waste-reduction efforts. New Jersey has
begun to develop a program to use MA
information, collected through the Industrial
Survey and the Worker and Community
Right-to-Know Act, to develop approaches
that consider efficiency of waste reduction
within facilities or across industries. MA
data will be used to set priorities among
facilities of various industries for waste-
reduction attention (Jeanne Herb, NIDEP,
personal communication, March 29, 1989~.
· Assessment of the potential human
exposure to industrial releases within an
Elizabeth, As., community (NIDEP, 1984~.
· Identification of major source
facilities of vinyl chloride monomer. Initial
on-site inspections of these facilities resulted
in one facility being referred for enforce-
ment actions for chemical spillage and dis-
charge problems (NIDEP, 1984~.
The Maryland Toxic
Substances Registry System
Before Maryland had developed its Toxic
Substances Registry System, Baltimore and
its surrounding counties were identified by
the National Cancer Institute as having
elevated mortality rates for several types of
cancer. Concerns were heightened by
incidents involving accidental or uncon-
trolled releases of toxic substances from
storage tanks.
The paucity of information available on
the sources of carcinogens and other toxic
OCR for page 29
USES OF MATERIAI~ACCOUMlING DATA
substances led Maryland to begin a survey of
its industries in 1976 (Maryland Department
of Health and Mental Hygiene, 1983~. In
197S, an EPA grant authorized by Section 28
of the Toxic Substances Control Act enabled
Maryland to expand its survey and combine
other related toxic substances information
into a common database called the Toxic
Substances Registry System.
The system was tested and refined over
the next 7 years; it was fully implemented in
1985 to focus on industries that met any of
the following criteria:
· SIC Code with the first two digits in
the range from 20 through 39.
· Large-scale industries with air pollu-
tion control equipment registered by the
Maryland Air Management Administration.
· Facilities, regardless of size, identified
from Maryland Department of the Environ-
ment records as using exclusively or, to a
large extent, using one or more of the
chemical substances listed in the survey.
· Facilities with a history of violations or
experiencing difficulties complying with
emission regulations and various types of re-
search laboratories.
Conducted in 1985, the survey covered
274 chemicals divided into two groups with
different reporting thresholds in the amounts
of chemicals handled by a facility (Appendix
H). The following criteria were used to
evaluate chemicals for inclusion on this list:
· Evidence of link with carcinogenicity.
· Previously studied as toxic chemicals
by other states.
· Evidence of U.S. production in large-
volume, commercial quantities.
· Record of production within Maryland.
The survey form was sent to 1,200 facili-
ties in 1985 and is referred to as the Chemi-
cal Inventory Report. The response rate was
approximately 90%. This form consisted of
three parts: general information, a chemical
questionnaire, and a storage tank question-
naire. The chemical questionnaire contains
the MA information and requested a des-
cription of how each listed chemical was
used, produced, or handled. Other types of
information requested included means by
which the chemical was transported to the
facility, type of storage used, maximum
29
amount of each listed chemical stored on site
at any time, and total amount of each
chemical used during the reporting year. No
information on chemical releases to the
environment was collected through this
effort. Any information considered to be
confidential by the reporting facility and
Maryland was presented so as not to disclose
trade secrets or proprietary information.
The Toxic Substances Registry System
relied on the use of existing MA-type infor-
mation and did not require facilities to con-
duct monitoring or carry out other data col-
lection to validate reported amounts. Files
for each facility included cross-references of
all permits. Available EPA databases also
were used to compile the information
The Toxic Substances Registry System
has provided useful information to guide the
state's efforts in air, water, and waste clean-
up by providing a means to identify previ-
ously unregistered air pollution sources. The
data from this system were used to establish
priorities for Maryland air toxics regulation
and to establish a list of toxic air pollutants
for which facilities will be responsible for
reporting environmental releases. These reg-
ulations were made final on July 29, 1988.
Maryland has linked the Toxic Sub-
stances Registry System with the Statewide
Cancer and Birth Defects Registries and the
Occupational Disease Reporting System in
support of various epidemiological studies
(Khoury et al., 1986~. When geographic
clusters of birth defects or occupational dis-
eases are observed, these will be compared
with the toxic substances database in a
search for correlations.
SUMMARY
The Maryland Toxic Substances Registry
System and the New Jersey Industrial Survey
together provided the model for the TRI.
Both states claim that these MA data projects
have benefited their regulatory and public
health efforts by providing a focus and
ranking within diverse strategies to under-
stand and regulate toxic substances in the
environment. In New Jersey, the usefulness
of the project would have been reduced
greatly if only release information had been
collected.
The organizational and resource commit-
meets made by New Jersey during its Indus
OCR for page 30
30
trial Survey are a major reason for the qual-
ity and utility of the collected MA in-
formation. This information was accessible
and useful to the environmental and health
agencies, with dedicated staff available to
assist a wide range of applications.
The experiences of New Jersey indicate
that MA ciata can be important, in a qualita-
tive sense, in developing, validating, and as-
sessing information on toxic chemical re-
leases. The New Jersey Industrial Survey
provided a means to confirm in overall terms
chemical release information obtained from
other sources anti, in some cases, to provide
insights into important, previously undocu-
mented release pathways.
Because neither state's effort was
AL4SS RELIANCE INFORhb4TION
conceived with waste-reduction efficiency as
an explicit component, neither state has as-
sessec! the relevance of its approach to quan-
titative waste reflection. The New Jersey
information is an important qualitative com-
ponent of that state's current waste-reduc-
tion efforts.
Efforts in both states support the utility
of MA information for addressing a variety
of issues concerning public and occupational
health. Both states have examples of the
utility of MA information to the public and
policymakers. In addition, with the report-
ing requirements in place, both states report
few requests for confidential business infor-
mation protection, and therefore the overall
utility of the projects were not hindered.
Representative terms from entire chapter:
toxic substances
