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OCR for page 61
7
Collection of Mass Balance Information
on a National Scale
INTRODUCTION
In evaluating the desirability of national
collection of EMB and MA data, the com-
mittee was charged with considering relevant
potential benefits to government and society,
including the potential uses explicitly stated
in SARA Section 313. The committee also
considered (a) the costs of collection and
analysis, (b) the complexity and inter-
pretability of the ciata, (c) the way the data
could enhance the public's and government's
understanding of relationships between in-
dustrial manufacturing activities and the re-
lease of chemicals into the environment, and
(~) potential burdens to facilities providing
the data, including matters of confiden-
tiality. Given the diversity of chemicals and
manufacturing facilities to be considered,
the committee relied on the limited empirical
data available to it, the experience of the
New jersey Industrial Survey, and its pro-
fessional judgment, experience, and reason-
ing to support its analysis. Because MA data
do not provide information on exposure con-
centrations the committee did not make any
specific recommendations concerning risk
communication.
61
BACKGROUND
SARA Section 313 responded to demands
for information that would inform com-
munities about releases of toxic chemicals.
The mechanism proposed was an annual
national report of the quantities of toxic or
otherwise hazardous chemicals released to
the air, water, and land. Congress further
suggested that it should be possible for the
public to retrieve data on specific facilities
as wed} as aggregate data organized, for ex-
ample, by type of chemical and geographic
location (Congressional Record, S 14908,
October 3, 1986~. SARA Section 313(h)
states that information collected under the
TRI Shall be available . . . to inform persons
about releases of toxic chemicals to the en-
vironment; to assist government 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.
During its debate over SARA Section
313, Congress showed awareness of the
potential difficulties of balancing the infor-
mation requirements of a national mass
OCR for page 62
62
balance program against the demands that
such a data inventory might pose for busi-
ness and industry. It directed the NAS to
consider the collection of mass balance in-
formation, evaluating the value of the pro-
gram to the public, regulators, and policy-
makers; the financial and other resources
needed by governments and facilities to im-
plement the program; and possible trade-
secret concerns (Congressional Record, S
1490S, October 3, 1986~.
The information available to the commit-
tee regarding large-scale mass balance pro-
jects was not great. Mass balance informa-
tion collection in federal programs has been
sparse, primarily because agencies have tra-
ditionally dealt with specific parts of the en-
vironment. A survey of the 50 states under-
taken by the NGA at the committee's behest
discovered seven states reporting uses for
mass balance data and five others that are
planning to use such data. To date, only
New Jersey and Maryland have undertaken
extensive collection activities; five other
states have collected mass balance informa-
tion for more restricted applications, such as
regulatory compliance.
USEFULNESS AND LIMITATIONS
OF MASS BALANCE INFORMATION
The committee has evaluated mass balance
information obtained for assessing release
estimates, progress in waste reduction, and
chemical management practices. Although
EMB potentially is more useful than MA in
several applications, the accuracy, precision,
and expense of EMB are not necessary for
achieving most of the three goals. MA ap-
pears to be more promising than EMB for
the uses of mass balance data identified in
this report, when the data are supplemented
with expert technical assistance. MA also
could target applications where EMB data
are potentially useful. EMB could be useful
in calculating the size of a release by dif-
ference when all data but that of the release
are available. It also could serve as a check
on the accuracy of other methods of
estimating chemical releases, but when all
quantities are of comparable magnitudes.
The EMB approach can also be useful in
identifying and characterizing sources of
waste in a facility and in pointing out release
routes from waste-treatment processes that
ABYSS BALANCE INFORMATION
need more complete and direct measurement.
EMB might be useful in identifying points
of chemical release into the workplace and
thus might indicate where mitigation
measures could reduce occupational ex-
posures. Although the benefits and limita-
tions of EMB data collection do not justify
further consideration of a national EMB data
collection program, the usefulness of EMB
in special cases should not be overlooked.
Neither the implementation nor the use
of MA would be simple or straightforward.
The utility of MA information-especially on
a national scale must be examined in the
light of how such information will be useful
in tracking hazardous substances at
manufacturing facilities: How useful will
MA information be, compared with infor-
mation already collected? How should these
annually reported data be used with fre-
quently reported data? Can these data re-
place others?
Proponents of mass balance information
collection emphasize the need for MA data
(e.g., inventories and amounts of chemicals
shipped into and out of a facility) to put re-
lease data (e.g., TRI data) into a proper
perspective. Claims are also made that mass
balance information is useful, for example,
in determining the waste-reduction efficien-
cy of facilities or categories of facilities with
respect to TRI-listed chemicals. Although
some benefits might be realized from the use
of MA data by themselves, a program sup-
ported by technical experts would have
greater benefits.
Evaluating Chemical Release Estimates
MA is generally not useful for assessing
the accuracy of data on releases, because of
the limits inherent in measurement error and
the assumptions or judgments necessary to
implement the analysis. The amount of un-
certainty in MA data would often exceed the
quantities of environmental releases. How-
ever, MA information might be helpful for
assessing the nature of reported releases,
provided that MA data collection is supple-
mented by expert technical knowledge, data
validation, and analysis.
A program with MA data could help
community residents who are unfamiliar
with the specifics of manufacturing proces
OCR for page 63
COLD ACTION OF MASS RELIANCE INFORMATION' ONE NATIONAL SCALE
ses determine why the releases are relatively
high for a particular facility or industry.
MA data can also be used in a more
qualitative way than for assessing accuracy.
It can be used to assess whether releases are
relatively high or low because of the chemi-
cal quantities handled or because the same
quantity of a chemical is handled less effi-
ciently by one facility than by another
similar facility. For many chemicals,
releases that do not occur at the time of
manufacturing or of incorporation into a
product will eventually occur after the
chemical-containing product is purchased
and used. It is therefore important to
understand the release pathways of
hazardous chemicals for example, 1,1,1-
trichloroethane (TCA) in adhesives after
they leave production facilities, as well as
the releases reported by the facilities.
Validation of collected MA data is essen-
tial to their useful application to release es-
timates. Recognizing the complexity of the
information requested and the substantial
potential for inaccurate reporting, New
Jersey in its Industrial Survey made a major
commitment to provide expert assistance to
respondents and to conduct routine field
audits. Engineering staff reviewed all
responses and worked with the respondents
to improve response quality. As a result
of this extensive validation program, it was
found necessary to revise 75% of the original
release estimates; approximately one-third of
the revisions were due to inadequate
estimates of release. New Jersey officials
have stresses! that it was impossible to ensure
the validity of reported release information
without additional MA information, or
follow-up field audits or monitoring data.
For example, knowing the quantities of the
raw materials used and the products
manufactured by a facility could be helpful
in recognizing overestimation of discharges
from a facility that mistakenly includes in its
report the total mass discharged plus the
water that contains it, instead of the mass of
a specific chemical contained in the water.
MA data are, however, of limited utility for
the assessment of underestimates of releases
because of the uncertainty inherent in MA
data. Furthermore, mass balance informa-
tion can be used to estimate releases by dif-
ference only when all the components are of
comparable magnitudes. In this case, it is
likely that each component is within a simi
63
lar range of uncertainty. MA data together
with technical knowledge of the manufac-
turing process can be useful in assessing
releases from facilities where all of a TRI-
listed chemical consumed at a facility is also
released to the environment. This technique
has been used successfully in estimating the
release of gaseous fluorides from aluminum
smelting facilities because the cryolite and
aluminum fluoride consumed by the
aluminum industry are used exclusively to
replace fluorine losses (NAE, 1989~.
MA information could be used by federal
and state regulators and policymakers to set
regulatory priorities for investigating
chemicals of concern, to clarify their likely
exposure pathways, and to disclose where
they are. As the New Jersey Industrial Sur-
vey showed, MA data can provide insights
into important, previously undocumented
release pathways. Virginia and Vermont also
have refined their environmental permitting
processes through the use of mass balance
information collected case by case, which
allowed them to improve their assessments of
releases and to apply more relevant condi-
tions for the issuance of permits.
Evaluating Waste-Reduction Progress
MA data, accompanied by information
that sets the data in a realistic engineering
context, could in some cases contribute to
forming a useful picture of waste-reduction
progress at individual facilities and could
help provide information on reduction tech-
niques. Although neither EMB nor MA
practice is generally applicable to determine
waste-reduction efficiency, MA could be
useful in qualitative applications such as
identifying waste-reduction priorities among
industries and facilities. Reporting of
waste-reduction progress on a chemical-spe-
cific basis is most feasible if a normalizing
factor is used to account for changes in
waste amounts that are due to changes in the
level of manufacturing activity.
Production data used to normalize quan-
tities of generated waste can help account
for changes in manufacturing activity, but
the limitations of such data should be em-
phasized. The diversity of products some-
times makes it difficult to normalize waste
data consistently and comparably among
processes and facilities. Furthermore, waste
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64
and production are not always linearly re-
lated even if waste reduction is ignored.
Nor is there any advantage in normalizing on
the basis of raw-material input, especially if
chemical conversions occur. The greater the
number of chemicals involved in a waste-
reduction assessment, the more difficult the
problem of interpretation and comparison of
progress.
MA data could be used to aid the setting
of national priorities for chemical waste re-
duction, as New Jersey is attempting to do.
If, for example, releases of a toxic chemical
from a manufacturing facility are low, but
the same chemical is released later in large
amounts in its end-use product formulation,
the only effective way to reduce environ-
mental releases substantially is to identify
safer substitutes for the chemical or to re-
formulate the product. For chemicals used
in large volumes, a national priority might
need to be established for research and
development on alternative product formula-
tions.
Waste reduction can be accomplished in
many different ways, but some of them
could worsen toxic releases to the environ-
ment or be undetectable through the use of
raw MA data. The following example
illustrates how a chemical user could reduce
waste by replacing a chemical of known
health effects with a chemical of unknown
health effects. This example is not intended
to hinder waste-reduction efforts, but is in-
tended to indicate one potentially un-
desirable result of a specific waste-reduction
effort. Suppose a lock manufacturer con-
verts an operation to use a terpene hydrocar-
bon solvent that is not on the TRI list. The
solvent only recently was introduced into the
market, and not all of its properties are
known. It is combustible, but no fire
regulations govern its use. It forms precur-
sors that, when released to the atmosphere,
contribute to photochemical smog. Although
air quality regulations in the region are
stringent, the manufacturer can meet the
regulations with this solvent. The solvent is
so new that no workplace exposure levels
have been set. The sanitation department
has not set limits on the solvent's release into
water, and so it can be poured into the sewer
when it becomes contaminated. Although
there has been an apparent waste reduction,
the result could be the trading of one
problem for a similar or worse problem.
AL455 BALANCE INFORMATION
MA practice by itself does not ac-
knowledge past implementation of process
modification or recycling and reuse, and fa-
cilities that have already achieved substantial
waste-reduction successes woulc! be at a dis-
advantage if little opportunity remained for
further reduction at a reasonable cost.
Technical assistance and data interpretation
in the reporting of waste reduction could be
important as they help to put complex data
into a context of past waste-reduction prog-
ress and technically feasible future options.
The following discussion illustrates the com-
plex design decisions that facility managers
must make when they attempt waste reduc-
tion, and it sheds light on the sort of per-
spective on economic and technologic factors
that expert technical assistance and data
analysis could provide. Suppose that the
lock manufacturer's facility has been pressed
by the community to reduce its emissions,
and the facility is anxious to develop a posi-
tive image in the community. Carbon
adsorption could be used to capture the TCA
that the manufacturer uses before it is
emitted from the facility. The TCA could
be desorbed from the carbon with steam and
then reused, but the facility does not have
steam installed. It is expensive to adsorb
TCA on carbon, because the TCA Is unstable
in the presence of water. It forms an acid
that readily corrodes equipment, which must
therefore be corrosion-resistant. If the faci-
lity purchases a carbon-adsorption unit
without steam, the carbon with adsorbed
TCA would constitute a solid hazardous
waste that would require further off-site
treatment or disposal. This would reduce the
air emission problem but increase the haz-
ardous waste problem commensurately; the
waste would now consist of the original TCA
plus the carbon adsorbent. If the facility
decided to install steam to desorb the TCA
for reuse, the capital cost would be extreme-
ly high. The TCA would have to be re-
stabilized on site; some of the chemical
stabilizers are very toxic, and facility per-
sonnel could be endangered. This option of
carbon adsorption with steam for desorbing
TCA, if the facility could afford it, would
reduce the amount of TCA emitted into the
atmosphere without increasing the amount of
waste generated. Its drawbacks are that it is
costly and the risk to the work force would
be increased. Alternative methods for
desorbing TCA could be considered that are
OCR for page 65
COLLECTION OF MASS BAL4NCE INFORMATION ONA NATIONAL SCALE
potentially less costly and of lower worker
risk (e.g., desorption with inert gas and elec-
tric heat).
Recycling is included in the term"waste
reduction" as used in this report. The fol-
lowing example illustrates the complexity of
waste reduction vis-a-vis recycling and the
usefulness of additional technically informed
analysis to augment raw MA data. Suppose
that the lock manufacturer decides to sell the
contaminated solvent to a recycling firm, in-
stead of sending it for incineration as in the
past or buying back the recycled solvent.
The recycled solvent is eventually sold to
another solvent user and is used in a cleaning
operation. The amount of solvent sent off
site remains the same for the lock manufac-
turer, although the reuse of the solvent
results in a net reduction of virgin solvent
production in the nation. If the spent
solvent is considered a waste, it appears in
the reported data that waste reduction has
not occurred, but it has.
The lock manufacturer could further re-
duce waste by purchasing recycled solvent in
place of virgin solvent. The reported MA
numbers would not change, and reports of
purchases and waste sent off site would be
the same. Although there would be ~ net
reduction in waste through reduction of total
solvent production, the MA data would not
show it.
Chemical Management Practice
MA information could be useful in
providing to the public and the government
information on the relationship among
chemical management practices, releases that
occur, and potential releases. MA data on
changes in physical and chemical properties
(e.g., from a liquid to a solid material and
from a more hazardous to a less hazardous
form) or changes in transport methods would
provide valuable information to the com-
munity for assessing the potential hazards
associated with transport practices and for
developing emergency response plans. The
most relevant datum for evaluating toxic
chemical management practices is the annual
quantity of specific chemicals transported
across facility boundaries. Readily available
records, such as invoices and shipping
manifest records, would be used with the
MA approach. The practical usefulness of
65
the MA approach is small for assessing
transportation and storage practices,
however, because large differences among
processes within a manufacturing facility
limit comparability.
Chemical properties and reactivity,
equipment design and safeguards, operating
procedures, operator training, and quality of
maintenance and monitoring all affect the
likelihood of accidental releases, and the
hazard associated with a release is influenced
by the chemicals toxicity, transport charac-
teristics, release location, and receptor loca-
tions. Such detailed information would not
likely be collected through a national MA
reporting program. At least some of it could
be provided to the public, however, by sup-
plementing reported data with information
about chemical management practices at spe-
cific facilities.
Application to Health
Surveillance and Assessments
The New Jersey Industrial Survey infor-
mation has been put to a number of health-
related uses. The data facilitated an occupa-
tional health surveillance that defined the
number of workplaces in which toxic sub-
stances are used and the number of workers
who were potentially exposed. Over 80°h of
the workplaces with potential exposures to
mercury would not have been identified
without MA data (New Jersey Department of
Health, 1988~. A statewide investigation
used MA information from the Industrial
Survey to find several previously undetected
sites of workplace and environmental con-
tamination with 2,3,7,8-tetrachlorodibenzo-
p-dioxin (N]DEP, 1985~.
New Jersey Industrial Survey data were
used with other information to assess poten-
tial human exposure to industrial releases in
a community in Elizabeth, N.~. Facilities
that were major sources of vinyl chloride
monomer were identified, and initial site in-
spections resulted in one facility being
referred for enforcement actions for chemi-
cal spills and discharges (NJDEP, 1984~.
Maryland has linked the Toxic Sub-
stances Registry System with the Statewide
Cancer and Birth Defects Registry and the
Occupational Disease Reporting System
(Khoury et al., 1986~. When geographic
clusters of birth defects or occupational
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66
diseases are observed, these will be com-
pared with the toxic substances database in a
search for correlations.
Regulatory Support and Development
New Jersey reports that MA data helped
provide a focus for the development of the
state's Environmental Cleanup and Respon-
sibility Act, Toxic Catastrophe Prevention
Act, and Pollution Discharge Elimination
System. The state is using survey informa-
tion to assist in the development of the Air
Toxics Strategy to revise regulations con-
cerning the emission of toxic chemicals into
the environment.
Maryland indicates that the Toxic Sub-
stances Registry System has provided it with
a multimedia database that has been a build-
ing block for control and regulation of toxic
substances. Data from the registry system
were used to establish priorities for Mary-
land air taxies regulation and to establish a
list of toxic air pollutants whose environ-
mental releases facilities will be responsible
for reporting. For both states, MA has been
used mainly for qualitative purposes.
Environmental Economic Models
MA data could be used as input data to
environmental economic models that address
the government policy objective of striking a
balance among competing uses of the en-
vironment. Industry relies on the environ-
ment as a receptor for chemical releases, and
the public expects minimal environmental
degradation. The models are designed to
analyze industrial activities, waste genera-
tion, and environmental releases; the effects
of releases on environmental quality; and the
actions that can be taken to manage environ-
mental quality at the regional level. James
(1985) provides a review of the relevant lit-
erature.
NATIONAL ECONOMIC IMPACTS
The collection of MA information on a
national scale could result in the expenditure
of substantial resources by facilities required
to report data and by agencies charged with
processing, storing, and distributing the in
~SS BALANCE INFORMATION
formation. Furthermore, for information
collected by state agencies to be useful to the
EPA (and vice versa), data coding and man-
agement systems must be compatible. Con-
siderable resources likely would be required
to check the data submitted to ensure their
accuracy and compliance. The pilot study
described later in this chapter would provide
valuable information on the economic im-
pacts of a national, technically supported
MA information collection program.
To minimize industry~s financial and
technical burden of TRI reporting, SARA
Section 313 also provided that data collected
in compliance with other regulations may be
used for reporting purposes. The generation
of valid and reliable MA information re-
quires knowledge of materials and material
contaminants, processes, and product and
byproduct uses, as well as mathematical and
engineering skills. Such expertise is most
common among large companies that have
available staff and resource flexibility.
Small businesses with limited staff and ex-
pertise (e.g., a paint-stripper formulator with
fewer than 25 employees) could be at a dis-
advantage in providing MA information,
because many have not previously been re-
quired to report under any national environ-
mental statutes and would need to acquire
reporting expertise. Facilities are required
to report to the TRI if they use a listed
chemical on an average of approximately 30
lb/day throughout the year.
Many data collected under the mandates
of various state and federal regulatory
programs might be unusable for a MA pro-
gram in their current forms, because their
storage and retrieval systems are dissimilar.
States planning to initiate mass balance
information collection programs should be
encouraged to coordinate with EPA to
ensure consistency of nomenclature and data
formats. Attention to data definition and
collection consistency could reduce the costs
of a national data collection program and
improve access to a more extensive database.
CONFIDENTIALITY
A major concern of industry is that re-
quirements to report the TRI-listed chemi-
cals in individual waste streams could make
public the information collected on raw ma-
terials or synthesis routes used to make
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COLLECTION OF MASS BALANCE INFORM,4TION ONE NATIONAL SCALE
products. This disclosure can involve a fair-
ly complete description of operations, yields,
and sales, all of which could be useful to
competitors.
The experiences of the New Jersey In-
dustrial Survey and the first collection cycle
of the New Jersey Worker and Community
Right-to-Know Act showed that less than
1% of the data submitted in each collection
was claimed to be confidential (Alan
Bookman, NJDEP, personal communication,
March 1989~. Nonetheless, the collection
and use of confidential information remain
an issue of great concern in the national col-
lection of MA data. A prudent next step
would be to assess, through the proposed
pilot study of a national MA information
collection program, whether industry's con-
cerns regarding sensitive or proprietary in-
formation can be accommodated in ways that
allow collection of useful data on a national
scale. Experience gained through the
Comprehensive Assessment Information Rule
(Federal Register, l98Sc) data collection
program would also be helpful in addressing
the issue of reporting information that is
considered confidential business information.
NATIONAL MATERIALS ACCOUNTING
DATA COLLECTION
A national MA data collection program
can be useful if it is supplemented by
additional information provided by technical
experts. In such a program, MA data
collection, verification, and analyses would
be directed and performed by technically
knowledgeable and experienced persons who
could supplement the data with information
relevant to chemical releases, waste-reduc-
tion progress, and chemical management
practices. MA data would be the fundamen-
tal information provided by the facilities.
Other readily available information might be
requested initially or after a preliminary
analysis of the initial information to better
explain the relationship between industrial
activities and environmental releases and
waste reduction. General knowledge of the
way toxic chemicals are produced or used at
a facility is necessary information and might
be requested in addition to MA data, if
unknown to the experts. For example, the
committee envisions that the experts might
ask facilities manufacturing a certain type of
67
product to describe the ways that a solvent is
used to better explain why the solvent
releases are relatively high compared to
other manufacturing activities.
These experts should be independent of
regulatory agencies and in a position to pro-
vide interpretative assistance as raw data are
reported to the public. For example, mass
release data do not necessarily enable ac-
curate assessment of exposures, release con-
centrations, as well as other information
(e.g., release height), would be necessary for
accurate exposure assessments. Such aug-
mentation of MA data might reduce the po-
tential for misdirected interpretations of
release data, and would assist risk com-
munication programs.
A technically supported MA program
could be a useful application of MA data
that would enhance the public and
government understanding of relationships
between manufacturing and the environmen-
tal release of chemicals, which in turn might
lead to reductions in the releases of toxic
substances into the environment.
PILOT STUDY RECOMMENDATION
The committee recommends that a pilot
study be conducted to test the feasibility of
the national collection of MA information
and that the study include a technical sup-
port group. This recommendation grows out
of the original plan for this study as
suggested by the NRC, which led to the
present committee's deliberative process and
review. This plan envisioned a two-phase
investigation that would begin with a review
of existing information to evaluate mass
balance options. The present report
completes the first phase. The second phase,
as recommended by the committee, should
involve a pilot study involving a national
MA data collection program; it should be
performed by a contractor or through a
cooperative agreement with one or several
engineering schools or research groups, with
appropriately qualified, independent
oversight of the study design and evaluation
of results.
The pilot study is suggested as a prudent
step in further considering a national MA
data collection for all TRI-listed chemicals
from thousands of facilities. The pilot study
would obtain information to weigh the
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68
benefits and costs of MA information, and
thus enable a reasoned decision on a national
MA program. It also would indicate the fol-
lowing:
~ The general feasibility of a nationwide
collection and public dissemination of MA
data designed, analyzed, and interpreted by
technical experts.
· The utility of such nationwide MA
information (beyond the value of TRI data)
for the applications discussed in this report.
· The potential cost of such a program.
· The feasibility of conducting a national
program that involves the collection of pos-
sibly sensitive or proprietary data for even-
tual public use.
Any collection of MA information, even
at the level of a pilot study, will be time-
consuming and expensive. The data selec-
tion should be a rigorous test of the
complexity and interpretability of MA data.
To maximize the information yield relative
to resources expended, the pilot study should
focus on just two or three chemicals from
the TRI list. (Pilot study investigators
could consider studying more chemicals if
resources are available to support a larger
study; however, adding more chemicals to
the pilot study would not necessarily provide
a more complete answer.) It might be speci-
fied that the selected chemicals have impor-
tant known adverse health or environmental
effects. Or it might be better to select
chemicals used in large volumes, for two
reasons: chemicals used in large volumes
theoretically have a greater potential for
significant amounts of releases, and the
collection of MA information on chemicals
used in large volumes would provide a rigor-
ous test of information collection. Addition-
al chemical-specific questions might be de-
signed to focus on particular risks or
chemical use patterns or to address metro-
politan or regional issues. Comparisons
might be made within a single industrial
category or between industrial categories.
Data collected by the New Jersey
Industrial Survey would be useful to a
national pilot study but, by themselves,
would not provide all of the information
necessary to decide if a national program
should be put in place. First, the New
Jersey Industrial Survey did not have as one
of its goals to provide information that has
been supplemented by expert analysis in
M4SS BALANCE INFOR~fATION
order to make it fully useful to the public.
Therefore, it would be difficult to estimate
the resource requirements for a national
program as discussed in this report by rely-
ing solely on the New Jersey Industrial Sur-
vey. Second, as mentioned in Chapter 3, in
many cases, field audits revealed that
erroneous information was reported, and
audits were not conducted at every facility.
Third, the Industrial Survey response rate
was 43% and may underrepresent releases
from all relevant facilities in New Jersey.
The pilot study should build on the
experience of the New Jersey Industrial Sur-
vey by evaluating a national-scale testing of
all the characteristics of a MA program,
assisted by a technical support group. It
should consider all possible important re-
leases of the few chemicals selected (i.e.,
from chemical uses by consumers and non-
manufacturing industries, in addition to
those currently reporting to the TRI).
The pilot study should include an ex-
perimental public dissemination program de-
signed to maximize the accessibility of an
MA database supplemented with technical
support. In evaluating the potential utility
of such an MA program, pilot study inves-
tigators should solicit public comments on
the disseminated information.
The pilot study should be designed to test
ways to achieve the potential benefits of MA
with technical support as cost-effectively as
possible. Reliance on data that are likely to
be routinely collected is another aspect to be
evaluated. The pilot study should address the
utility of MA data aggregated at the national
or regional level, for example, as inputs to
environmental economic models used to
develop strategies for managing environmen-
tal quality.
Existing, nonconfidential data include all
release-related data currently available to
EPA, such as permit data, TRI data, and
facility management data (e.g., production
and sales information, purchase records, and
waste manifest records). They also include
monitoring data that are already being ob-
rained by federal or state programs, emission
inventories conducted under the Clean Air
Act, water quality information obtained
under the Clean Water Act, information on
The Resource Conservation and Recovery
Act hazardous waste manifests, population
densities, and information from trade
associations (e.g., production volumes and
intermediate commercial uses). MA data
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COLLECTION OF MASS BALANCE I~JEO~TION ONE NATIONS SHE
collected on a regular basis under the New
Jersey Worker and Community Right-to-
Know Act of 1983 should also be considered.
Validation checks are likely to be required
for some of the data. Such checks would
probably include visits to facilities and
interviews of their personnel.
In summary, mass balance information,
and in particular MA supplemented by
expert technical assistance, has potential
utility for addressing the information needs
69
specified in SARA Section 313. However,
the potential usefulness of a national pro-
gram cannot be clearly established without
conducting the recommended second phase
of the study. It is the committees consensus
that a nationwide pilot data collection per-
formed for a few chemicals would be the
appropriate next step in pursuing the
environmental protection and public-infor-
mation goals of Title III of SARA.
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Representative terms from entire chapter:
balance information
