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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

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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

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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

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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

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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 50h 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,

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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

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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

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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.