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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
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
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
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
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
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
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
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
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.
