.3 £4?” 1 5.:- . . r .3. 2h 2 . t . .5 cr!‘ 'E: z .03; {3.2 I .11) , 5 {it :ttll. . THESIS JIllllllllllllllllllllllllllllllllllllllll L 3 1293 01564 4598 This is to certify that the dissertation entitled COMPARATIVE RISK ANALYSIS OF TOXIC RELEASE INVENTORY DATA FOR CARCINOGENS: DOES QUANTITY REDUCTION NECESSARILY MEAN LESS RISK? A MICHIGAN CASE STUDY presented by MICHAEL ALOYSIITS MCMENAMIN has been accepted towards fulfillment of the requirements for PILD. ENVIRONMENTAL TOXICOLOGY & RESOURCE DEVELOPMENT degree in '5 / Major professor Date AZJIPLI; {ffé MSU is an Affirmative Action/Equal Opportunity Institution 0- 12771 ’—v~v 'v—w LIBRARY Michigan State Unlverslty PLACE IN RETURN BOX to remove this chodtout from your record. TO AVOID FINES return on or baton data duo. DATE DUE DATE DUE DATE DUE MSU II An Affirmative MlonlEqud Oppommlty Instltwon wm1 DOE COMPARATIVE RISK ANALYSIS OF TOXIC RELEASE INVENTORY DATA FOR CARCINOGENS: DOES QUANTITY REDUCTION NECESSARILY INDICATE LESS RISK? A MICHIGAN CASE STUDY By Michael Aloysius McMenamin A DISSERTATION Submitted To Michigan State University in partial fulfillment of the requirements for the degree of DOCTOR OF PHILOSOPHY Department of Resource DeveIOpment 1996 '.'~. -‘.C.. F O ‘ ABSTRACT COMPARATIVE RISK ANALYSIS OF TOXIC RELEASE INVENTORY DATA FOR CARCINOGENS: DOES QUANTITY REDUCTION NECESSARILY INDICATE LESS RISK? A MICHIGAN CASE STUDY By Michael Aloysius McMenamin In recognition of the disastrous effects of the accidental release by industry of toxic chemicals around the globe, the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA) was enacted. The EPCRA requires owners and operators of manufacturing facilities to submit reports on toxic chemical storage and release. One purpose of the EPCRA is to decrease total quantities of toxic chemicals and to provide local citizenry with the information necessary to protect themselves from the hazards presented by toxic chemicals. Under the EPCRA, toxic chemical data is presented in quantities, without the incorporation of critical factors such as toxicity and exposure. Presenting data in this format is inaccurate and misleading and does not allow the average citizen to assess potential risk presented by the toxic chemicals. Further, with data presented in this format, accurate assessment of efforts to decrease total toxic chemicals is difficult. Fundamental principles of toxicology illustrate that a direct correlation between quantity and risk, without consideration of other critical factors, does not necessarily exist. Therefore, a reduction in chemical quantity may not correspond to a decrease in the potential risk posed by that chemical. Recognition of this concept indicates that factors any ' kS—ADI A-‘fl. “I. . .I ~ I.- .r‘ A w is“. \ ~.~-... ‘ I u._ ~~ Q}... "w r '3'. '- i._ V! ! .. l.‘\ other than quantity must be used in determining whether the efforts to decrease toxic chemical quantities are directed appropriately. Using Michigan as a case study, the dissertation focuses on specific carcinogens and extracts chemical data for reporting years 1987 through 1994. A hazard valuation algorithm, that integrates quantities with known toxicity values and accepted exposure ’ assumptions to arrive at an estimated “hazard value,’ is applied to the Michigan data for the specific carcinogens. Evaluation of the correlation between the total quantities reported under the EPCRA and the total hazard values as calculated by the algorithm illustrates the EPCRA’S limitations for both evaluating toxic chemical data and assessing whether the efforts to decrease toxic chemical quantities are directed appropriately. It is the thesis of this dissertation that analysis of the EPCRA toxic chemical data, using total quantity as the only analysis parameter, is not usefiJl in assessing whether efforts to decrease toxic chemical quantities are directed appropriately. Copyright by MICHAEL ALOYSIUS MCMENAMIN 1996 The stars seemed to get brighter the more we climbed . . . . Flat on my back, I stared straight up at the magnificent firmament, glorying in the time I was making, in how far I had come from sad Bear Mountain after all, and tingling with kicks at the thought of what lay ahead of me . . . -whatever, whatever it would be. JACK KEROUAC, ()A'THERO.11) This dissertation is dedicated to my Mom, who has been ABD for more than 20 years. While she was always ahead of her time, she only recently got a computer! She taught me to put the sad times behind me, to keep climbing and to keep looking forward to what lay on the road ahead of me. Thanks Mom. You are more than I can ever hope to be! =-) rL ACKNOWLEDGMENTS My sister Mary, brother Tommy and the rest of my family have supported me for all my life (even when others would not have) and were a constant source of encouragement. During this process they were only eleven digits away and always in my heart. Daniel Bronstein and Michael Kamrin have supported me on every imaginable level and at every turn in the road since my first visit to the campus in the summer of 1992. While I often stumbled through the process or got lost completely, they have consistently been a source of wisdom and guidance. Without their patience, help and good humor I would not have realized this goal. I owe them my fiIture. Mackenzie Davis and David Favre generously assisted as members of my dissertation committee. I appreciate their willingness to participate with little notice. Their critical thoughts, comments and editorial assistance had a distinct impact on my work. Though I never sat in his class, Bill Cooper taught me more about policy than any lawyer I have ever met. It has been my good fortune to know him as he is truly an enigma and therefore a constant source of inspiration. I will be better at everything I do in life because of his lessons. vi Ifiie k Sung 3 one: On Rages "P—| ~. ‘L"; UK: Dr. Barry Hart Dubner has been a constant source of advice and counsel during this process. As a mentor he kept me constantly grounded in reality and helped me to keep writing. The friends I have made deserve more than simple acknowledgment. Their tolerance, humor, advice and friendship are more important to me than they can ever know and I would not have completed this undertaking without them. John Abbott is a better friend than I deserve who has taught me alot about myself and what is important in life. Paul Groll is a good friend who’s humor and advice are only surpassed by his ability to keep my computer working with voodoo and Band-Aids. Dr. Marsha Crawford deserves special thanks for having the decency to have gone through the doctoral process before me so that she could provide sound counsel in my moments of existential angst. Mike Kaplowitz is the best rabbi a doctoral student could hope for. Dan, Sue & Bob, Steve & Cheryl, and Robb & Chris through their fiiendship, have all made the project less onerous than it could have been and are responsible for my sanity. Thanks, guys. Everyone at the Institute for Environmental Toxicology who helped with the early stages of my doctoral work. My wife Nina deserves all my gratitude. She tolerated my dreams by just allowing me to apply for the doctoral program and she has been more than supportive during the process. She is many things to me, but mostly she is my best friend. I love her for all she is and all I am when I am with her. Vii TABLE OF CONTENTS LIST OF TABLES ....................................................................................................... xi LIST OF FIGURES .................................................................................................... xv INTRODUCTION ........................................................................................................ l A) Study Purpose and Objectives ..... . ....................................................... 2 B) Study Organization and Data Collection ............................................... 4 M BACKGROUND, PROBLEM STATEMENT, AN 1_) METHODS CHAPTER ONE: BACKGROUND A) Background ........................................................................................ 7 1. 1984 Bhopal Disaster ............................................................... 7 2. Toxic Chemicals in the US. ..................................................... 7 3. The Political Debate .................................................................. 9 B) Right-to-Know Lgislation in the United Statg ................................ 10 C) Emergency Emiggand Community Right-to-Know Act (SARA, Title III; 42 USC 65 11001 et seq.) ............ 12 D) Toxic Relgtse Inventory Conceptual F rageworlgand Structure ......................................... 19 1. Reporting TRI Data ................................................................ 19 2. Compilation of Data into TRI Database ................................... 22 3. TRI Framework ...................................................................... 22 E) Use of TR] Dat_a ................................................................................ 23 CHAPTER TWO: PROBLEM STATEMENT AND METHODS A) Problem Lutement ........................................................................... 27 B) Study Design and Approach ............................................................... 31 viii I P Part II LITERATURE REVIEW CHAPTER THREE: APPLICABLE RISK ASSESSMENT LITERATURE A) General Msflssessment Concepts .................................................... 34 B) Alternative Hazard Value Scoring Methods ...................................... 36 I. Interagency Testing Committee Workshop (We/ch & Ross) 37 2. U.S.E.P.A. Conference (Forman, et a1.) ................................. 40 3. University of Tennessee Study (CCPC T; Davis, et a1.) ............ 41 4. Carnegie Mellon University Study (Horvath, et a1.) ................ 47 5. University of Toronto Study (Jia, et a1.) ................................. 49 C) Multi-media Fate Models (SETAC Review) ....................................... 51 D) Selection of Ha_zaer Value Scoring Method ...................................... 53 l. The CCPCT System ........ . ...................................................... 53 2. University of New Orleans (Lea, et a1.) .................................. 53 Part HI DATA COMPILATION CHAPTER FOUR: TRI DATA A) Method of Data Collection ............................................................... 57 l. TRI Data Availability .............................................................. 57 2. INTERNET Collection of TR] Data ........................................ 58 B) Collection and Compilation of Michigan TRI Quantity Data .............. 59 1. Carcinogens ........................................................................... 59 2. Selection of Specific Carcinogens for Analysis ........................ 63 3. Compilation of TRI Quantity Data for Specific Carcinogens 65 CHAPTER FIVE: HAZARD VALUE SCORING METHOD A) Adaptation of CCPCT Study Algorithm to Michigg Specific m .......................................................... 68 1. Hazard Values (HVs) ............................................................. 68 2. Release Weighting Factors (RWFS) ......................................... 70 B) Compilation of Hagard Value Dataana Michigan TRI Quantity Daga for Specific Carcinogens ................ 72 C) Application of Modified Hgard Value Scoring Method to Specific Carcinogaps ................................................. 73 1. Weighted Human Health Effects (WHHE) ............................... 73 2. Weighted Environmental Effects (WEE) .................................. 75 3. Exposure Factor (EF) .............................................................. 76 4. Total Hazard Value (THV) ..................................................... 77 D) Compilation of Total Releases and THVs .......................................... 79 ix B B Part IV DATA ANALYSIS AND CONCLUSIONS CHAPTER SIX: ANALYSIS OF MICHIGAN TRI DATA A) Comparison of TRI Quantity Data (Quantity Analysis)a_n_d Computed Michigan Hgard Value Data (:Risk”) for Specific Carcinggag ............................................................. 82 1. Total TRI Releases .................................................................. 82 2. Total Releases of Carcinogens ................................................. 84 3. Total Hazard Values .............................................................. 85 4. Compilation and Comparison of All Data ............................ 86 B) Statistical Analysis of Correlation Between Quantity and “Risk” ........ 89 1. Linear Regression Analysis and the Correlation Coefficient ..... 89 2. Analysis of Correlation Coefficient .......................................... 91 C) Summagy ..................... . .................................................................. 91 CHAPTER SEVEN: CONCLUSIONS AND RECOMMENDATIONS A) Conclusions ...................................................................................... 93 B) Recommendations for Future Research ............................................. 96 1. Study Containing More Complete Detail ................................ 96 2. Focusing on Local Areas of Concerns .................................... 97 3. Review of the Utility of Chemical Use Initiatives ..................... 97 4. Refocusing on Risk Issues by the U.S.E.P.A ............................ 98 APPENDICES Appendix A - EPCRA Form R ........................................................................ 105 Appendix B - TRI Releases of Known or Suspect Carcinogens (1993) ............ 1 14 Appendix C - Known or Suspect Carcinogens in Michigan .............................. 117 Agipendix D - CCPCT Compatible Summaries for Specific Chemicals ............... 120 Appendix E - Primary Chemical Data With Hazard Values ............................... 143 Appendix F - Calculated Hazard Values for Specific Carcinogens ..................... 151 BIBLIOGRAPHY ..................................................................................................... 100 . . . . I I Q o N I . I ‘ -\ u n I I L s z» s“ .u s ..L u\. his t... .p\ u.\ t\ h\ H . . . .. , ... ...H .. .. . H ... ... .. . .... ... . --.... ... .. .... “a. u; ...: .... 2: r: ..1: .... -..fi... A”: r.w.\ ESL {nut . ., . . r T; r ._ T r; T i T; TIL TL TIL. Tl T. T1 LIST OF TABLES Tam - TRI Releases of Known or Suspect Carcinogens (1993) ............................... 1 15 1%; - Known or Suspect Carcinogens With Reported Releases in Michigan ............ 1 18 Iable_3 - Known or Suspect Carcinogens With No Reported Releases in Michigan ...... 120 Table—4 - Total Acetaldehyde Releases ........................................................................ 121 @151; - Total Acrylamide Releases .................................................. . ................ . ....... 121 Iab_l_e_6_ - Total Acrylonitrile Releases ......................................................................... 122 legal - Total Arsenic Releases ................................................................................. 122 T_ab_le__8_ - Total Asbestos (friable) Releases .................................................................. 123 Iatiej - Total Benzene Releases ................................................................................ 123 Table—10 - Total Beryllium Releases ............................................................................ 124 T_a_bl§_1_1 - Total Bis (chloromethyl) ether Releases ...................................................... 124 Table 12 - Total 1,3-Butadiene Releases ...................................................................... 125 Iab_le_1_3 - Total Cadmium Releases ............................................................................. 125 w - Total Carbon Tetrachloride Releases ........................................................... 126 T_ab_lal_5 - Total Chlorofonn Releases ......................................................................... 126 BELGIQ - Total Chloromethyl methyl ether Releases ................... . .............................. 127 Ia_ble_17 - Total Chlorophenols (mixed isomers) Releases ........................................... 127 Tgblfl - Total Chromium Releases .......................................................................... 128 . . I - . . I . a . a . . ._ . _ . I I I ~5 .rL. ...rx. ...»: ....w .\ . .s. ...‘ .u w r . . . .n in. n. .n. ..c. ... a: .... ..n. ... ... ih.. .h... .n.. Tim .....u fink 9h- V..-. Th. nah. .Au. .qo‘. 54.. .JH .4.u\ ...AH Elba ..A1; ”I“. A . . I ll: II TII. Till. Tl I \ . . T L T: Tl Tl ..l Tl\ TL Table 19 - Total Creosote Releases ............................................................................. 128 _T_alfle_2_Q - Total Diaminotoluene Releases .................................................................. 129 T_ab_le_2_l_ — Total 1,2-Dibromoethane Releases .............................................................. 129 M - Total 3,3’-Dichlorobenzidine Releases ................. . ..................................... 130 T_ab_la;3_ - Total 1,2-Dichloroethane Releases ......... . ................................................... 130 M - Total Dichloromethane Releases ................................................................ 131 Iable_2_5_ - Total 1,3-Dichloropropylene Releases ........................................................ 131 mag - Total Di-(Z-ethylhexyl) phthalate Releases ................................................. 132 Laple_2_Z - Total Dimethyl sulfate Releases .................................................................. 132 M - Total Epichlorohydrin Releases .................................................................. 133 M - Total Ethyl acrylate Releases ...................................................................... 133 W - Total Ethylene oxide Releases .................................................................... 134 Iablgfl - Total Ethylene thiourea Releases ................................................................ 134 labial; - Total Formaldehyde Releases ............................... . ................... . ......... . ....... 135 T_able_33_ - Total Hydrazine Releases ........................................................................... 135 Laie_34_ - Total Lead Releases ................................................................................... 136 M - Total Nickel Releases .................................................................................. 136 W - Total Nickel Compounds Releases .............................................................. 137 la_b_le_3_7 - Total 2-Nitropropane Releases .................................................................... 137 M - Total Polychlorinated biphenyls Releases ..................................................... 138 m - Total Propylene oxide Releases .................................................................. 138 M - Total Styrene Releases ............................................................................... 139 Db_le_4_l - Total Tetrachloroethylene Releases ............................................................ 139 xii ..I I . _ . a . I .:._ .C I. at. .3 . .1 .2, 1 . .. .. . . . . .. . . : . \ t t . . . . .. . . . . .. . .. . -h . .u... I». l t. In... I... ..i .>.:_ “.‘m . Mp. . ”A. . mi; “1: ..uph. -‘¢_ “4:. “it. .1: “>4. Ham. .A 1 in. ... «Q .54.}. .Au.\ .C\ ..Arh\ .4‘ . . r. . _. . r .. T; 71 l. TL Tl. T; TIL +l\ Ti T1 T TL Tl\ T. T1 $l Table 42 — Total Thiourea Releases ............................................................... . ............. 140 Ia_bl_e_43_ - Total Toluene-2,4-diisocyanate Releases .................................................... 140 MIC—4:1 - Total Toluene-2,6-diisocyanate Releases .............................. . ..................... 141 EbLeLS - Total Toluenediisocyanate Releases ............................................................ 141 M - Total o-Touidine Releases .......................................................................... 142 Iab_la4_7 - Total 2,4,6-Trichlorophenol Releases ......................................................... 142 11M - Total Urethane Releases ......................................................... . ................... 143 T_ab_1_a4_9 - Total Vinyl Chloride Releases ............................................. _ ..................... 143 M - 1987 Primary Chemical Data With Hazard Values ....................................... 144 Ta_blej - 1988 Primary Chemical Data With Hazard Values ...................................... 145 Iabjafl - 1989 Primary Chemical Data With Hazard Values ....................................... 146 Taipei; - 1990 Primary Chemical Data With Hazard Values .................................. 147 T_ab_le_54 - 1991 Primary Chemical Data With Hazard Values ....................................... 148 Iaiflaéfi - 1992 Primary Chemical Data With Hazard Values ...................................... 149 M - 1993 Primary Chemical Data With Hazard Values ....................................... 150 Table—57 - 1994 Primary Chemical Data With Hazard Values ...................................... 151 Ial_3_1_e_5§ - 1987 Calculated Hazard Values for Specific C arcinogens ........................... 152 mag - 1988 Calculated Hazard Values for Specific Carcinogens ........................... 153 Ta_ble_69_ - 1989 Calculated Hazard Values for Specific Carcinogens ........................... 154 RM - 1990 Calculated Hazard Values for Specific Carcinogens ........................... 155 Ia_bl_e_6_2 - 1991 Calculated Hazard Values for Specific Carcinogens ........................... 156 M - 1992 Calculated Hazard Values for Specific Carcinogens ........................... 157 xiii Table 64 - 1993 Calculated Hazard Values for Specific Carcinogens .................. . ........ 158 T_ablg6_5 - 1994 Calculated Hazard Values for Specific Carcinogens ........................... 159 M - Total Releases and Hazard Values for All Reporting Years .......................... 80 Tab—kg - Total Hazard Values for All Reporting Years (Minimum HV) ...................... 80 Ta_ble_6§ - Observed Numerical Changes in Releases ...................................................... 86 xiv Figure 1. Figure 2. Figure 3. Figure 4. Figure 5. Figure 6. Figure 7. Figure 8. Figure 9. Figure 10. Figure 11. Figure 12. Figure 13. Figure 14. Figure 15. Figure 16. Figure 17. Figure 18. LIST OF FIGURES Determining Applicability of the EPCRA Section 313 ................................... 18 Conceptual Model of Chemical Ranking Hazard Method ....... . ...................... 42 Yhe CCPCTAlgorithm ................................................................................. 48 Release Weighting Factor Equation .............................................................. 71 1987 Release Weighting F actors for Lead .................................. .., ................ 72 WHHE Equation ........................................................................................... 73 Human Health Hazard l' 'alues for Lead ......................................................... 74 1987 WHHE Calculation for Lead ................................................................ 74 WEE Equation Total TRI Releases ................................................................ 75 Environmental Hazard Values for Lead ...................................................... 75 1987 WEE Calculation for Lead ................................................................. 76 EF Equation ............................................................................................... 76 Exposure Potential Hazard Values for Lead ................................................ 77 EF Calculation for Lead ............................................ _ ................................ 77 T H V Equation ............................................................................................. 78 Algorithm Variables for Lead ..................................................................... 78 T H V Calculation for Lead ........................................................................... 78 Total T RI Releases ...................................................................................... 83 XV ...... .bl . .Bb .V\ vi fl v . a L . A. . .... ... .... FA rlrt Phi phi, Figure 19. Figure 20. Figure 21. Figure 22. Figure 23. Figure 24. Total Releases of Carcinogens ..................................................................... 84 Total Hazard Values for C arcinogens .......................................................... 85 Total Hazard Values for Carcinogens (high and low range H V) .................. 85 Comparison of Quantity and “Risk " ............................................................ 88 Comparison of Quantity and ”Risk ” (high and low range H l") .................... 88 Linear Regression Analysis .......................................................................... 9O INTRODUCTION Mr. President, I would like to continue my commentary with a few remarks about the Community Right-to-Know provisions of this bill. *** The Bhopal disaster focused public attention on the fact that extremely dangerous chemicals are present at chemical manufacturing plants and other facilities in communities all across America. The title of the Superfund bill recognizes a basic fact: that citizens have a right to know about these chemicals-what they are, where they are, and how much of them is present.1 Senator Stafford’s commentary on how right-to-know principles apply to “extremely dangerous chemicals” (i.e., toxic) is deficient in one fundamental concern. A plain reading of the Senator’s comments concerning this specific piece of legislation, and indeed the congressional record concerning right-to-know issues prior to the enactment of the legislation, clearly lacks any commentary on risk.2 Lacking this direct commentary, it is possible to infer that this specific right-to-know legislation was not intended to incorporate factors of risk and therefore should not be used as a tool for risk assessment. ‘ 132 Com. REC. S14895-02. (daily ed. Oct. 3, 1986) (statement of Sen. Stafford). 2 Commentary on risk in relation to right-to-know issues during these debates and testimony is conspicuous in its absence. The reasons for this lack of commentary can not be known, and may range the fill] gambit from simple oversight to political dealmaking. K31" \I. u IIF ‘1. “ML '.\ I 5L I: v.- .../ “—1 1,; 2 However, since the enactment of the right-to-know legislation concerning “extremely dangerous chemicals,” it has been commonly recognized that this specific right-to-know legislation incorporates factors of risk. Also, the use of this right-to-know legislation is assessing risk is commonly recognized. For example, Senator Kerry stated: In 1986, Congress passed the Emergency Planning and Community Right- to-Know Act, or EPCRA, which is also known as Title III of the Superfimd Amendments and Reauthorization Act. This recognized the public's right to know about the risks that are posed by a number of private-sector facilities which produce certain toxic chemicals.3 Further, this specific right-to-know legislation only addresses “extremely dangerous chemicals.” Therefore, factors of risk are inherently incorporated into the selection process for determining which chemicals fall within the confines of the law. Regarding “extremely dangerous” or toxic chemicals, citizens have the right to know what, where and how much, but they also need to have some degree of understanding of the relative potency (i.e., how toxic) of each of these chemicals in order to determine both the absolute and the relative risk presented by possible exposure to each chemical. A) Study Purpose and Objectives It must not be inferred from the thesis of this dissertation that the reporting requirements of the EPCRA are of no value. Quite to the contrary, the reporting requirements of the EPCRA are the foundation for the production of the TRI database 3 139 CONG. REC. 83411-01. (daily ed. Mar. 23, 1993) (statement of Senator Kerry). ‘.—"" 4v;. 0" \ .— .6~- c ...g. 5-7-.15 w: an '5‘ .. .c ....» .r 1 u \\. O .s M4. :4 U r»... it... ..tl. .... n "We 3 which is a resource of almost immeasurable value. It is not the purpose or objective of this dissertation to criticize the structure of the EPCRA, the infrastructure on which it relies or the use of the TRI as a tool to decrease toxic chemicals in the environment. Further, this dissertation does not propose a new paradigm for community right-to-know in the arena of toxic chemical reporting similar to that currently existing under the EPCRA. The purpose of this dissertation is to show that the implementation of the EPCRA’S reporting requirements does not succeed in achieving the recognized goals of the EPCRA in Michigan. The ultimate objective of this dissertation is to illustrate that the recognized goal of decreasing overall risk by reducing the amounts of toxic chemicals stored or discharged into the environment is not achieved by the EPCRA’S current reporting requirements. Therefore, the dissertation suggests that efforts to decrease risk by reducing toxic chemicals in the environment are not directed appIOpriately. The dissertation illustrates that TRI data analysis must incorporate factors other than quantity if toxics reduction efforts are to be made efficient by focusing on those specific chemicals that pose the greatest risk due to their inherent toxicity. This re-focusing of toxics reductions efforts will accelerate the rate at which the recognized goals of the EPCRA will be achieved, if they are to be achieved at all. A further objective of the dissertation is to suggest a more appropriate method for TRI data compilation and analysis that will result in a more USCfiJl format for the presentation of the data to the average citizen. The dissertation illustrates that the adaptation and application of existing risk assessment principles to the TRI data not only produces a more SOphisticated analysis of the data, but also provides information that is nfifi' .»\ ..ad '1. I» H h‘ u an. 7 a; '36 6" {h a .1 .\.. 4 2d 21‘ D H. vs.» " 5'; 'nl hulk . ‘u. in the. 4 critical for achieving the recognized goals of the EPCRA. Presentation of the TRI data in the appropriate format can empower the average citizen with the information necessary to evaluate the potential risks presented by the presence of TRI chemicals to which they may be exposed. This information will also enable the average citizen to engage in informed, intelligent decision-making concerning those toxic chemicals and possible exposures. It is through this empowerment of the average citizen through presentation of the EPCRA data in a format that incorporates fundamental risk assessment principles that the recognized goals of the EPCRA may best be achieved. The dissertation proposes that these goals may be better accomplished by integrating the principles of existing risk assessment paradigms with the TRI data and that a more appropriate method of TRI data analysis and presentation is necessary. B) Study Organization aid Dat_a_Collection The dissertation contains seven chapters separated into four general parts. The four general parts are: Background, Literature Review, Data Compilation and Data Analysis and Conclusions. Part One of the dissertation contains two chapters. Chapter One will provide background information on events such as the disaster at Bhopal, India. It was the Bhopal disaster that provided the impetus for US. legislators to implement assorted Right-To- Know legislation. Further, this part will provide detailed background on the EPCRA and the TRI set against the broad background of right-to-know legislation. Chapter Two will outline the problem statement, methods used and the design of this dissertation. I ,3'9'1' 'C :~_,~: .fi - TL... "in : !'\ i ‘u‘. . ”$11. - - v , ..Iks.|\ \- AI 0 9 L1 4“- n 'O— _ l V I ...... H n. I i Io .3 A... \ Ff~§~ ' . E vvw 'i ..AA~' 5‘-” 0.. \.l._‘ ‘Dr‘- 5. V. f-I‘ 5 Part Two of the dissertation contains one chapter. Chapter Three will provide a general review of the existing literature regarding fundamental risk assessment concepts. This chapter includes the review of literature addressing the use of hazard value scoring methods in assessing risk. The purpose of this section is to provide the necessary breadth of review of existing risk assessment alternatives to allow for the reasonable selection of an appropriate tool to perform an analysis of the TRI data. Part Three of the dissertation contains two chapters. Chapter Four reviews the structure and conceptual framework of the TRI database. Also, this chapter outlines the process for the selection of specific toxic chemicals to be analyzed and the use of on-line computer resources as a method of data collection to be used in the dissertation. Finally, this chapter includes the compilation of the appropriate TRI data for each selected toxic chemical. Chapter Five adapts the hazard value scoring method selected in Part Two, Chapter Three for use in the analysis of the toxic chemicals selected. The adapted hazard value scoring method is then be applied to the specific TRI data compiled in Chapter Four. The resulting data is compiled in this chapter for analysis. Part Four of the dissertation contains two chapters. Chapter Six of the dissertation compares the quantity data provided in the TRI with the computed hazard value data for the specific toxic chemicals compiled in Chapter Five. Also, this chapter provides the analysis of the compiled data. Considering this analysis, Chapter Seven presents the conclusions of the dissertation. Based on these conclusions, this chapter makes recommendations for fiiture research. Part I BACKGROUND, PROBLEM STATEMENT, AND METHODS iv . -! .97 r’ 64 Ll.» IUJ ‘ , 'p- I ..1 . '-v\ a E Q? Va CHAPTER ONE A) Backggound 1. 1984 Bhopal Disaster The most catastIOphic toxic chemical release recorded occurred on December 4, 1984 at a Union Carbide pesticide manufacturing facility in Bhopal, India.4 The Union Carbide facility in Bhopal released approximately 20 tons of methyl isocyanate (“MIC”), an extremely toxic intermediate used in the production of pesticides, into the atmosphere.5 The gas cloud spread over the shantytowns surrounding the facility killing more than 2,000 and seriously injuring more than 200,000 others.‘5 2. Toxic Chemicals in the United States The risks presented by the use, storage and discharge of toxic chemicals are not unknown in the United States. Concomitant with the presence of toxic chemicals is the inevitability of accidental release.7 For example, it is estimated that between 1982 and 1986 there were more than 11,048 accidental releases of hazardous substances that 4 The Bhopal Tragedy: Social and Legal Issue: A Symposium, 20 TEX. INT'L LJ. 267 (1985) 5 Sidney M. Wolf, Fear And Loathing About The Public Right T 0 Know: The Surprising Success Of The Emergency Planning And Community Right-To-Know Act, 11 J. LAND USE & ENVTL. L. 217 (1996). 6 Bradford C. Mank, Preventing Bhopal: “Dead Zones " and Toxic Death Risk Index Taxes, 53 OHIO ST. LJ. 761 (1992); see also Richard Schwadron, The Bhopal Incident: How the Courts have Faced Complex International Litigation, 5 EU. INT'L LI. 445 (1987) 7 A broad review of the accidental releases of toxic chemicals is provided in the U.S.E.P.A.’s Accidental Release Information Program, available in INTERNET, . 7 (aw-- gtfva p a - :\ tL. t-., C. 8 directly caused 309 deaths, over 11,000 injuries and the evacuation of almost one half a million people.8 Several accidental releases gained more notoriety than others. For example, a series of 15 reported releases (over an 18 week period) of various toxic chemicals from chemical plants on Staten Island, New York received considerable notoriety. These releases threatened cities in New Jersey and necessitated the dispatch of the environmental and medical response teams into Union and Middlesex Counties.9 The most notable single release in the United States occurred in August 1985, in Institute, West Virginia at a pesticide plant which produced the same pesticide that the Bhopal plant produced. The release was caused by a leak in a 500 gallon storage tank containing aldicarb oximine.lo While no deaths occurred, the release produced a toxic cloud which drifted over Institute, West Virginia and other local communities causing eye, throat and lung irritation in 135 people.ll Aside from the similarity in the pesticide end- product produced, this release probably gained such notoriety since it, like the Bhopal release, was from a facility owned by Union Carbide. ‘2 8 See 5. REP. NO. 228, 101-228, at 134 (1989); id. 9 Hearing on PL. 99-499 Before the Committee on Small Business, 9911‘ Cong, (June 18, 1985). Inquiry concerning the details of the 15 releases and the risks posed to citizens of both New York and New Jersey was the focus of a line of questioning by the US. Senator from the State of New York, Alphonse D’Amato. ‘0 See Jayne S.A. Pritchard, Comment, A Closer Look at Title II] of SARA: Emergency Planning and Community Right-to-Know Act of 1986, 6 PACE ENVTL. L. REV. 203, 203- 04 (1988); Steam in Chemical Storage Tank Named As Likely Cause of Union Carbide Accident, 16 ENV'T REP. (BNA) 635 (Aug. 16, 1985) [hereinafter Union Carbide Accident]; (Aldicarb oximine is an intermediate used with MIC to produce a pesticide. The Union Carbide facility in Institute, West Virginia is the only manufacturer of MIC in the United States). 11 See Pritchard, id. at 203; Union Carbide Accident. id. at 635. '2 Casey Bukro, Carbide Plant Leaks, 150 CH]. TRIB. 1 (1985). if. ‘~'~ .I]. r L7. .IEDILH—‘lr...(.r-.i fr. 0 liki- ...Hbuuu. .....H m: a . 3. The Political Debate During the debates in the United States Congress regarding community right-to- know legislation, a parallel was drawn between the Bhopal facility and American facilities. This parallel was expanded by including a review of the number of chemicals produced in this country and an estimate of accidents involving toxic chemicals in the United States.13 Finally, in an attempt to increase public concern, one Congressman extended the parallel and predicted the inevitability of “corpses in the street.”14 While predicting “corpses in the street” may have been extreme and unnecessary, the Congressional testimony in support of right-to-know indicated that the primary 13 In testimony at the Hearing on PL. 99-499 Before the Sub—Comm on Commerce, Transportation and Tourism of the Comm on Energy and Commerce, 99th Cong, 10 (1985), Congressman Sikorski stated: Just 1 year ago, 1 year ago and 2 weeks, the worst chemical disaster in history lefi over 2,000 people dead and over 200,000 people injured in India. . .. That was in India, but an American company was operating that facility, a replica of an American facility. And in America today, 60,000 chemicals are produced in over 6,000 communities, and last year 5,700 toxic chemical accidents occurred. Id. 14 1d. Congressman Sikorski reduced the above estimates to the absurd and stated: The effect of these chemicals--the dioxin, PCB'S, asbestos, benzenes--is often not clear overnight. The corpses are not in far- distant country streets. The corpses are waiting in America's hospitals and hospices, and they come from American playgrounds, they come from American blue collar neighborhoods and factories, they come from American suburban homes that are built in areas that were the dumping grounds 20 and 30 years ago for industries. Now despite 20 years of environmental regulation of toxic substances, thousands of pages of data and cases of brain cancer, liver cancer, and mutations and birth defects, we still cannot answer basic questions about even the most common and deadly toxic chemicals. Id. v .5. {I CI;- f" 71' .h.’ F . 10 purpose of the legislation was to protect the “fiIndamental rights” of the citizenry by providing them with information concerning toxic chemicals to which they might be exposed. 15 B) Right-to-Know LegiLation in the United Stat_as Right-To-Know (“RTK”) legislation is designed to provide information to the common citizen that will allow that citizen to understand ongoing activities that may personally affect him/her.l6 The ultimate goal of RTK legislation is to allow each citizen to make better decisions regarding those activities that do personally affect him/her and to . . . . . . 7 become more active In community and/or personal decrsron-making processes.l ‘5 Id. Congressman Sikorski described community right-to-know as a “fundamental right” and stated: Millions of Americans in thousands of neighborhoods exposed to toxic chemicals have a Simple, fiindamental right to know about what chemicals, toxic chemicals, are being released into their environment hour after hour, day after day, year after year. The House bill, through our efforts, guarantees that Americans will be provided with this information. Id ‘6 See also SUSAN HADDEN, A CITIZEN’S RIGHT TO KNow: RISK COMMUNICATION AND PUBLIC POLICY (Westview Press 1989) (providing a broad view of right-to-know legislation). For example, Professor Hadden uses the practice of food labeling in the United States to demonstrate RTK laws stating that “the government requires manufacturers to list ingredients but leaves it to consumers to determine whether the risks of any ingredients are unacceptable to them.” '7 Id. at 16. Further, Professor Hadden states that the once the government provides the citizenry with new information, it is only reasonable that the government provide that citizenry with a venue through which it can participate in the decision-making process. Id. Expanding on the concept of “information as power,” Professor Hadden states that this system increases the burden placed on the public “to evaluate information and actually make choices rather than leaving them to government or industry.” Id. Whether the average citizen has the ability to “actually make choices” or even if actual “choices” exist are foundation issues in “Right-To-Act” movements and legislation that are a logical, and necessary, extension to RTK legislation. As Paulette L. Stenzel stated, right-to-act (footnote continued) 11 However, merely providing a citizen with raw information does not indicate that the citizen will be able to intelligently participate or contribute in a positive way to any decision-making processes. The nexus between full information and effective decision- making requires that the citizen has reached a certain level of understanding of the information provided. The mere provision of information does not necessarily imply that the citizen has either the ability or the resources to reach a useful level of understanding of that raw information. The underlying and unanswered question in the area of RTK law is “Right-To-Know M?“ A fundamental problem with some RTK legislation is that the average citizen does not have, nor is the citizen provided the tools necessary to understand the information supplied by that legislation. However, it would clearly not be possible to provide every citizen with the tools necessary to understand all information provided through RTK legislation. The result of this inadequacy in RTK legislation is a potential for misinterpretation of the information provided, which could produce a negative impact on participation in decision-making processes. The answer to this quandary is not that RTK legislation should not be enacted. Rather, the information provided through the legislation must be in a format (i.e., a format described by Hadden as “understandable and legislation is “designed to empower workers and other community residents to ‘do something’ about the hazards to which they are exposed.” Paulette L. Stenzel, Right T 0 Act: Advancing The Common Interests 0f Labor And Environmentalists, 57 ALB. L. REV. 1(1993) ‘8 Achieving the stated goals or purposes of RTK legislation: requires not only that the information be available but that it be understandable and appropriate. Thus government may have to help citizens interpret or manipulate the data they obtain in order to make it germane to community decisions, not just to ensure its availability. HADDEN, supra note 16, at 16 (emphasis added). 09> v _ ... -- . -.. .-. .a be) (If. 9 .. I “-4.. F. r—4 [(1. It? ‘ ) I 12 appropriate”) that would allow the average citizen to reach a level of comprehension sufficient to make those decisions that would protect his/her own interests. '9 In turn, this heightened level Of comprehension of complex issues allows for the indirect influence of industry and government to self-regulate thereby fiirthering the interests of the citizenry.20 C) Emergency Planningand Community Right-to-Know Act LSARA, Title III‘. 42 USC §§ 11001 et segg) The Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) was passed by the US. Congress in 1980.21 The CERCLA was amended by ’9 The interplay between a citizen’s fundamental understanding of complex issues and how that citizen should be afforded the opportunity to impact upon those issues in a society has been a profound source of tension throughout history. In the American democratic system, this issue was eloquently addressed by Thomas Jefferson in an often quoted letter to William Charles Jarvis: I know no safe depository of the ultimate powers of the society but the people themselves; and if we think them not enlightened enough to exercise their control with a wholesome discretion, the remedy is not to take it from them, but to inform their discretion. Letter from Thomas Jefferson (Sept. 28, 1820) (quoted in Natural Resources Defense Council v. Nuclear Regu_latory Comm’n, 547 F.2d 633, 655 (DC. Cir. 1976) 2° Professor Hadden states: Policies that emphasize information provision may also serve as indirect incentives to self-regulation. Thus, facilities that must report emissions to the environment or the fact that they store extremely volatile and hazardous chemicals might prefer to reduce the emissions or change the substances they use rather than make public information that could damage their reputations. HADDEN, supra note 16, at 16. How the citizenry chooses to influence industry and government in furtherance of individual interests varies. Whether citizens choose to exert their influence through simple “green boycotts” or through the extremism of “eco-terrorism,” the power the informed citizen wields is undeniable. See, e. g., THE GREENING OF AMERICAN BUSINESS: MAKING BOTTOM-LINE SENSE OF ENVIRONMENTAL RESPONSIBILITY (THOMAS S.P. SULLIVAN ed, Government Institutes, Inc. 1992). 2‘ 42 USC § 9601 et seq. (1988). s . .\ AIM . r. v A . u l . . . , . .p. .\v A L E , -. .pq hrs In. . . v. .9. M: sh Hm an“ ., a. ..Is .... «I. if .3 .tu i... ..2 min de I\\ fit; at; to}... t'h .- 13 Congress through the SuperfiJnd Amendments and Reauthorization Act (“SARA”) in 1986.22 The Emergency Planning and Community Right-to-Know Act (“EPCRA”) was incorporated into SARA as Title III of those amendments.23 Expansion of the goals of the CERCLA through the incorporation of the EPCRA into the SARA was a result of two critical factors. First, there were the early efforts of environmental groups in addressing local events similar to those in New Jersey and West Virginia described above and second, there was the general post-Bhopal recognition of the risks presented by the use, storage and discharge of toxic chemicals.“ The drafters of EPCRA and other similar RTK legislation specifically related to toxic chemicals stated that a primary goal of the legislation was to provide citizens with a higher degree of safety than existing systems in either the United States or India had demonstrated. Senator Lautenberg (New Jersey), a member of the Environment and Public Works Committee stated: The right to know means public information about what hazardous substances are being stored and released into the environment in our communities. It means planning for emergency releases before they happen. It means that our citizens will be safer and better prepared for the threats from chemical releases. It means that this Nation will not tolerate Bhopal- or Chernobyl-type tragedies.25 22 Superfund Amendments and Reauthorization Act, Pub. L. No. 99-499, 100 Stat. 1613 (codified in part at 42 U.S.C. §§ 9601-75 (1988)) [hereinafter SARA]. 23 Emergency Planning and Community Right-to-Know Act, Pub. L. No. 99-499, §§ 300- 30, 100 Stat. 1613, 1728-58 (codified at 42 U.S.C. §§ 11,001-050 (1988)) [hereinafter EPCRA]. 2‘ 131 CONG. REC. D1471. Senator Lautenberg defended the inclusion of the EPCRA in the SARA amendments when he stated: In response to Bhopal and Institute, W.Va., crises, Title III of our bill provides for comprehensive community right-to-know and emergency response programs. Id. (statement of Sen. Lautenberg). 25 132 CONG. REC. 814895-02 (daily ed. Oct. 3 1986) (statement of Sen. Lautenberg). L? 14 The amendment of the CERCLA through RTK legislation relating to toxic chemicals such as the EPCRA was not intended to alter the ultimate goals of the existing legislation, but rather enhance the efficacy of that legislation by increasing citizen safety through the provision of information.26 EPCRA is divided into three major divisions. The first being the “Emergency Planning and Notification” provisions (“Subchapter 1”) which mandate the creation of various state and local emergency planning and response committees.27 The second major division contains the “Reporting Requirements” provisions (“Subchapter II”) which requires industry to provide specific information concerning toxic chemical usage and releases.28 Within the Reporting Requirements, the section containing provisions relating to toxic chemicals is commonly known as the “Community Right-To-Know” section.29 The third major division of the EPCRA is the “General Provisions” section which 2“ 131 CONG. REC. D1471 (daily ed. Sept. 7 1985). Discussing the use of the SARA and the EPCRA to expand the CERCLA, Senator Lautenberg stated: Congress enacted [CERCLA] to give the Federal Government the authority it needed to . . . protect public health and the environment from releases of manmade hazardous substances. The legislation before us today does not change the basic thrust of [that] Program. Instead, the consensus bill amends and refines the program to reflect what 5 years of experience and detailed analysis have taught us. Id. (statement of Sen. Lautenberg). 2’ EPCRA, supra note 23, §§ 301-05. 281d §§ 311-13 29 Id § 313. ...v 11.... ~ C55? 83': EP- 1t .1 15 addresses issues such as trade secrets, enforcement and citizen suits.3O The focus of this dissertation is on the “Community Right-To-Know” provisions of the EPCRA.“ The right-to-know provisions of the EPCRA only apply to certain facilities. First, the facility must fall within Standard Industrial Classification (“SIC”) Codes 20-39.32 3° Id. §§ 321-30. 3‘ The distinction between the provisions within the first two divisions of the EPCRA is quite clear. For example, while crossover may occur, the chemicals addressed by the “Emergency Planning” provisions EPCRA, supra note 21, § 302 are not necessarily those addressed by the “Community Right-To-Know” provisions at § 313. While less acutely toxic, the category of chemicals addressed in the “Community Right-To-Know” provisions of the EPCRA pose serious risks to the environment and public health and can easily separated for purposes of this dissertation. Further, the third major division of the EPCRA focuses on mechanical legal issues that are unrelated to the focus of this dissertation and therefore, also easily separated from the analysis herein. 32 Id § 313(b)(1)(A). SIC Codes 20-39 include the following industries: SIC 20-Food and Kindred Products SIC 21-Tobacco Products SIC 22-Textile Mill Products SIC 23-Apparel and Other Finished Products made from Fabrics and Other Similar Materials SIC 24-Lumber and Wood Products, Except Furniture SIC 25-Furniture and Fixtures SIC 26-Paper and Allied Products SIC 27-Printing, Publishing, and Allied Industries SIC 28-Chemicals and Allied Products SIC 29-Petroleum Refining and Related Industries SIC 30-Rubber and Miscellaneous Plastics Products SIC 31-Leather and Leather Products SIC 32-Stone, Clay, Glass and Concrete Products SIC 33-Primary Metal Industries SIC 34-Fabricated Metal Products, except Machinery and Transportation Equipment SIC 35-Industrial and Commercial Machinery and Computer Equipment SIC 36-Electronic and Other Electrical Equipment and Components, Except Computer Equipment SIC 37-Transportation Equipment SIC 38-Measuring, Analyzing, and Controlling Instruments; Photographic, Medical and Optical Goods; Watches and Clocks SIC 39-Miscellaneous Manufacturing Industries I1! t'»! ’1‘ — 16 These classification codes are broad and could be construed as covering almost any manufacturing facility. This breadth is most apparent in SIC Code 30 which includes facilities that fall within the “miscellaneous manufacturing industries” class?3 Second, the facility must have ten or more full-time employees.34 Third, the EPCRA only applies to the manufacture, process or use of those toxic chemicals on the Extremely Hazardous Substances List (the “List”)35 by a facility in the normal course of business.36 Finally, the facility must store or discharge a quantity of the toxic chemical in excess of the threshold quantities published by the US. Environmental Protection Agency (“U.S.E.P.A.”).37 The 33 Further, under President Clinton’s direction, Exec.Order No. 12,856, 58 FedReg. 41,981 required federal agencies (SIC Codes 91-97) to comply with the EPCRA beginning in 1994. SIC Codes 91-97 include the following industries: SIC 91-Executive, Legislative, and General Government, Except Finance SIC 92-Justice, Public Order, and Safety SIC 93-Public Finance, Taxation, and Monetary Policy SIC 94-Administration of Human Resource Programs SIC 95-Administration of Environmental Quality and Housing Programs SIC 96-Administration of Economic Programs SIC 97-National Security and International Affairs The addition of these new SIC Codes dramatically broadened the EPCRA classification system. 3“ Id. 35 A complete list of EPCRA §313 chemicals appears at 40 CPR §372.65 (1995). See also 42 U.S.C. §1 1,002(b)( 1); 40 C.F.R. §302.4 (1995). This list is subject to revision and has been amended since it was published in 1987. 36 This “normal course of business” parameter is distinctly different from the emergency release situation addressed in the Emergency Planning provisions of the EPCRA. 37 These threshold quantities are: A) 10,000 pounds of each toxic chemical used at the facility; or B) 25,000 pounds of each toxic chemical processed or manufactured at the facility in each year after 1989. EPCRA, supra note 23, § 313(f)(1). ‘-." 5‘" p' ‘ & ...; IQ. l7 conceptual illustration of the applicability of the EPCRA to a facility is provided in Figure 1 on the following page.38 The original List contained 320 toxic chemicals.39 The EPCRA also provides for the addition or deletion of specific chemicals from the List.40 While there have been several deletions and additions of toxic chemicals since it was first drafted, a substantial number of toxic chemicals were recently added to the list putting the total number of toxic chemicals covered by the EPCRA at over 600.“ The EPCRA requires that covered facilities file annual reports regarding toxic chemicals."2 3“ U.S.E.P.A. Office or Pollution Prevention and Toxics, Toxic Chemical Release Inventory Reporting Form R and Instructions'Revised 1995 Version 6, Figure 1, EPA/745/K-96-001 [hereinafter Form R Instructions]. 39 The EPCRA provides that: [t]he toxic chemicals subject to [its requirements] are those chemicals on the list in Committee Print Number 99-169 of the Senate Committee on Environment and Public Works and is entitled "Toxic Chemicals Subject to Section 313 of the Emergency Planning and Community Right to Know Act of 1986.” [42 U.S.C. §11023](including any revised version of the list as may be made pursuant to subsection ((1) or (e) of this section). EPCRA, supra note 23, § 313(c). 4° Id. § 313(d). 4' 40 C.F.R. §372. The number of chemicals on the list immediately prior to the 1994 addition was 368. In 1994, 286 chemicals were added bringing the total number of toxic chemicals subject to the EPCRA to 654. While this number may appear significant, it is actually a relatively small portion of the total number of chemicals in commercial use. The total number of chemicals in commercial use was estimated in 1984 to be approximately 60,000. See NATIONAL ACADEMY OF SCIENCES, TOXICITY TESTING: STRATEGIES TO DETERMINE NEEDS ANI) PRIORITIES ( 1984). ‘2 EPCRA, supra note 23, § 313. 18 Y” _l Douyouruclmymw Ma ormontull-ttmo .- _ _ amnion“? ”””” -| (accumulating-got) ' I 1.. I , layoutacl cinnamon 1" ----- I mangoes!“ Ab " Wiener 20mm " ---- humming. l (ac-Tubhmu-CO) | behavioral.” I .. ... _. _‘_ _ _. Yes I Douyourhclmy I manufactura.procou,or I Mucus-mum Ab _] Mic-law“ ————————— W (autumn-ounce) I Yes mnutactumorProceu I omens-u“ 016mm Whoa-omen M: Figure 1. Determining Applicability of the. EPCRA Section 31338 nJ . .7. CL {an .....7 ..\.. .— n. \4... iC‘ Dr 19 Clearly, the annual reports filed by covered facilities are the cornerstone of the EPCRA. Due to the sheer volume of toxic chemicals used by manufacturing facilities in the United States, a significant body of data is contained in these reports.43 The EPCRA provides that the task of data management falls to the U.S.E.P.A. This considerable task is accomplished by creating an inventory of toxic chemicals reports from which information is extracted and then compiled and centrally located in a national repository. As required by the EPCRA, this national repository, holding all toxic chemical data reported, is compiled into a national computer database known as the Toxic Release Inventory (“TRI”).44 The TRI is the first chemical specific accounting or inventory of toxic chemicals mandated by federal law in the United States. D) TRI Conceptual Framework_ and Structure 1. Reporting TRI Data Reporting of toxic chemicals data under the EPCRA is accomplished through the submission of a toxic chemical release form commonly known as “Form R.”45 The EPCRA mandates that the U.S.E.P.A. create Form R and that it include information concerning the type, location and amount of toxic chemicals stored or released, including the fate (e. g, incineration or release into a public sewer) of the chemicals after use and 43 The first annual report issued by the U.S.E.P.A. stated that over 20 billion pounds of toxic chemicals were reported under the EPCRA for 1987. This amount was more than expected by anyone and was considered to be both “staggering” and “startling.” See, Data From EPCRA Emissions Reporting Called 'Startling' by Environmental Agency, 19 ENV’T REP. (BNA) 2628, 2629 (April 21, 1989). ‘4 EPCRA, supra note 23, § 313(j). ‘5 Id. §313(a). I n‘r.”“ .3 2E 20 disposal.46 The U.S.E.P.A. publishes Form R in the Federal Register and has provided various mechanisms for its submission by industry.“ Even with the U.S.E.P.A.’s attempts to facilitate compliance with the reporting requirements of the EPCRA, one limitation of the TRI has been the failure of industry to submit toxic chemical data.48 This remains true despite the EPCRA’S provision for civil penalties of $25,000.00 per day for each failure to comply with its reporting requirements.49 The EPCRA provides that compliance with its Form R reporting requirements can be accomplished using “readily available data.”50 The EPCRA does not include enhanced monitoring or measurement requirements beyond what is required under existing statutes applicable to toxic chemicals.51 Regarding toxic chemical quantities that must be reported ‘6 Id. §313(g)(l). 47 The U.S.E.P.A. published Form R at 40 C.F.R. § 372.85 (1995); see Appendix A; see also Form R Instructions, supra note 38. Submission of Form R by computer can be accomplished using the U.S.E.P.A.’s Tier 11 Reporting and Inventory System . ‘8 Regarding this limitation: Anyone who works with TRI DATA is aware of its limitations. In 1988, an estimated 29,000 facilities should have reported, but only approximately 19,000 facilities actually did. There are even more facilities that are not required to report under EPCRA although information from them is needed for a comprehensive picture of pollution in our communities. Gary D. Bass & Alair MacLean, Enhancing the Public ’5 Right-to-Know About Environmental Issues, 4 VILL. ENVTL. LI. 287, 300 (1993). ‘9 EPCRA, supra note 23, § 325(c). 5° Id §313(g)(2). 5’ Id The Form R Instructions provided by the U.S.E.P.A. serve as a guideline for the estimation of toxic chemical quantities. Form R Instructions, supra note 38, at 24-42. For example, with respect to total on-site releases the Form R Instructions state: No additional monitoring or measurement of the quantities or concentrations of any toxic chemical released into the environment, or of the frequency of such releases beyond that which is required (footnote continued) \ inf-”van? 8": Mala. ' Dru 21 on Form R, the EPCRA only requires an “estimate” of the total quantities in pounds.52 Also, calculating the concentration and weight of the toxic chemical if it is only a part of a mixture is also estimated.53 These estimates are typically performed by engineers or environmental specialists at the facility and are “certified” for accuracy and completeness by a senior official.54 The use of estimates by industry in reporting total quantities of toxic chemicals has been questioned by the environmental community.55 under the provisions of law or regulation or as part of routine plant operations, is required for the purpose of completing Form R. Id at 28. 52 For example, again with respect to estimation of total on—site releases, the Form R Instructions state: You must estimate, as accurately as possible, the quantity (in pounds) of the toxic chemical or chemical category that is released annually to each environmental medium. Id 53 See 40 CFR 372.30(b) (1994). These estimates may often create a significant burden on industry. For example, it is possible that the only method of calculation of toxic chemical quantities could include complex mass balance equations. It is also interesting to note that these mass balance equations may be based on assumptions and estimates of the efficiency of treatment programs, making the resulting numbers even “softer.” See EPA, Estimating Release And Waste Treatment Eficiencies For The Toxic Chemical Release Inventory Form, EPA 560/4-88-002 (Dec. 1982). ’4 EPCRA, supra note 23, § 325(c). 55 Concerning the limitations of toxic chemical quantity estimation by industry: Manufacturers report their own emissions based on their own estimates, and the reported emissions may, therefore, be underestimated. EPA requires no standardization in methods of estimation, creating wide variance in reporting between similar types of companies. Furthermore, there is little opportunity to verify the estimates that are reported. Actual formaldehyde emissions tests at a California factory owned by Louisiana-Pacific, for example, revealed that the company had only reported half the volume of their releases in 1989. Bass & MacLean, supra note 48, at 301 (citations omitted). 22 2. Compilation of Data into TRI Database The EPCRA not only requires that all nationwide toxic chemical data reported to the EPA through the submission of Form R be compiled annually, but it also requires that the data compiled into the TRI be made publicly available through the computer 6 Further, the EPCRA mandates that this computer database be accessible to database.5 the public on a cost only basis.57 3. TRI Framework The TRI data available on-line is divided into six major categories.58 Each of these categories provides detailed data regarding the storage, use and discharge of toxic chemicals.59 The TRI data is presented from various perspectives. It is possible to perform a simple search of the TRI data for an individual chemical or a specific facility, but the TRI ” also provides lists containing specific “categories. For example, the TRI provides a list ’6 EPCRA, supra note 23, § 313(d). 57 Id. 58 The broad categories within the TR] are: Facility Identification Substance Identification Environmental Releases of Chemical Waste Treatment Off-Site Waste Transfer Source Reduction and recycling 59 The Toxic Chemical Release Inventory Fact Sheet states: The data include the names, addresses and public contacts of plants manufacturing, processing or using the reported chemicals, the maximum amount stored on site, the estimated quantity errritted into the air (point and non-point emissions), discharged into bodies of water, injected underground, or released to land, methods used in waste treatment and their efficiency, and data on the transfer of chemicals off-site for treatment/disposal, either to publicly owned treatment works or elsewhere. INTERNET (last modified Nov. 16, 1994). A flH‘EIdu » .4... vlk rLl vllk 23 of the “Top 50 Facilities with the Largest Increase In Air/Water/Land Releases” for each reporting year.60 Unfortunately, without further detailed analysis of the releases themselves, the TRI data user may equate the companies on this list with being the “least environmentally conscious” or “worst” companies. While this may not have been the intended end use of the TRI data in its present format, it is an apparent inevitability. E) Use of TRI Data The EPCRA states that Form R data is intended to provide information to the Federal, State, and local governments and the public, including citizens of communities surrounding covered facilities.“ Further, the EPCRA provides that the Form R data submitted under Title 111 shall be used to inform the citizenry about releases of toxic chemicals to the environment; to assist governmental 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.62 It is apparent that the TRI data obtained through Form R submission by industry is used by a number of groups quite effectively. The incentive to industry to reduce the amounts of toxic chemicals stored or discharged is through the avoidance of the 6° Id It should be noted that the TRI also provides a list of the “Top 50 Facilities with the Largest Decrease In Air/Water/Land Releases” (the “best” companies). Other examples of categorical lists provided by the TRI and available in TQXNET are: the “Top 50 Facilities with the Largest Total Releases,” the “Top 10 Parent Companies with the Largest Total Releases” and the “Top 10 Chemicals with Largest Land Releases.” 6’ EPCRA, supra note 23, § 313(h). ‘52 1a. .-\ rink 24 embarrassment and bad image realized by a particular company by being listed in the popular press as less than environmentally conscious.63 The use of the TRI data to influence industry and government has been clearly effective for both toxic chemical use reduction and other forms of “regulation.”64 The groups that use the TRI data most effectively have been environmental and citizen organizations, environmental activists and the press. For example, one environmental organization publishes a comprehensive three volume set examining TRI releases across the country, by state and providing a “report card” on several facilities with the highest TRI releases.65 Examples of environmental activists using the TRI data can be cited across the country.66 The popular press has been perceived as being a major user of the TRI, which may be the best current use of this data.67 The members of the press generally 63 See, e.g., Mary Beth Regan, An Embarrassment of Clean Air, BUSINESS WEEK, May 31, 1993, at 34 (referring to the use of TRI data as a form of “regulation by embarrassment”); F. Rice, FORTUNE, July 26, 1993, at 114-22 (listing of 10 best and 10 worst environmentally conscious corporations based on TRI ranking). 64 Kevin J. F into, Regulation by Information Through EPCRA, 4 NAT. RESOURCES & ENV'T. 13 (1990); see also EPA Office Of Pesticides & Toxic Substances, T oxics In The Community: National And Local Perspectives, The 1989 T oxics Release Inventory National Report 307, EPA/560/4-9l-014 (pointing to the use of TRI data by the press and citizen’s groups to mobilize public response to specific problems). 6’ Citizens Fund, CITIZENS FUND POISONS IN OUR NEIGHBORHOODS: TOXIC POLLUTION IN THE US, VOL. 1: NATIONAL OVERVIEW, VOL. 2: TOXIC WASTE IN THE STATES, ALABAMA - MICHIGAN, VOL. 32 TOXIC WASTE IN THE STATES, MINNESOTA - WYOMING (Nov. 1993). 66 See Wolf, supra note 5, at 217 (describing the utilization of TRI data by activists: in California to convince IBM to phase out use of CF C8; in Lima, Ohio to obtain finding for the first state airborne toxic substances monitoring project; in New Jersey to induce a company to adopt a chemical hazard accident plan; in North Carolina to support the passage of airborne toxic substances legislation and in Massachusetts to persuade a defense contractor to replace ozone depleting chemicals). 67 United States General Accounting Oflice, Report To Congress, TOXIC CHEMICALS: EPA'S TOXIC RELEASE INVENTORY IS USEFUL BUT CAN BE IMPROVED 26 (June 1991) (GAO/RCED-91-121). (Ibotnote continued) A vi lain-Ii urinate-r. 25 perceive the TRI as a useful tool.68 However, rather than performing their own, independent analysis of the TRI data, most members of the press incorporate into press articles a second hand analysis of the data performed by outside groups. It is possible that a second hand analysis may be performed by an outside group with an unknown, unique bias or specific agenda. As the outside group performing the analysis of the TRI data may have a unique bias or specific agenda, which may not be accurate, congruent with that of the popular press and possibly even unknown, this use of the TRI data may be critically flawed.69 Whatever the use of the TRI data by the average citizen, either intended by the EPCRA or actual, a concern remains regarding the public’s ability to understand the TRI The perception that the press may be the “highest use” of the TRI data at this time does not imply that the press presents the TRI data in an enhanced format or superior format, but that the press serves as the best tool to “inform the discretion” of the people at this time; see supra note 19. 68 Bud Ward, American Journalism Has A New Arrow In Its Quiver, ENVTL. HEALTH, Feb. 1992, at 63. ‘9 Alair MacLean & Paul Orum, PROGRESS REPORT: COMMUNITY RlGHT-TO-KNOW 13 (July 1992). Less than twenty percent of reporters accessed the TRI while most reporters only relied on second hand information received from alternative sources or environmental groups. Id at 8. The Right-To-Know Computer Network (“RTK-NET”) is an on-line computer database operated by Unison Institute and OMB Watch which publish papers and assorted documents concerning public right-to-know issues. RTK-NET is funded through private donations and government funds, including monetary support from the U.S.E.P.A.. Both Unison Institute and OMB Watch are members of the consortium of numerous local, state and national environmental groups that published the PROGRESS REPORT which, in turn, cites the RTK-NET as an alternative source used by various environmental groups. See INTERNET or see also TELNET (TELNET requires the use of an access code and password, available at no cost). 26 data as it is presented in the current format.70 All parties concerned have an interest in assuring that the TRI data is used appropriately. For example, the Chemical Manufacturers Association (“CMA”), whose members are responsible for a significant portion of the toxic chemicals reported under the EPCRA, claims that the TRI data does not provide the average citizen the proper context to judge the dangers posed by toxic chemical releases. In a statement before the US. Senate Committee on Environment and Public Works, the CMA stated: The public has a right to understand what the [TRI] release data does, and does not, mean. For instance, they have the right to understand the meaning of the [TRI] data in terms of actual, real-life risks. The [TRI] program does not give them the type of information that is necessary to understand these actual risks.71 70 A.Horvath et al., Toxic Emissions Indices for Green Design and Inventory, 29(2) ENVT’L.SC1.TECH. 86A (1995) stated: The Toxics Release Inventory (TRI) is the most comprehensive and widely reported information on hazardous discharges to the environment in the United States. Unfortunately, the fledgling nature of the TRI may lead to simplistic interpretations of the results. Id. at 86A. This dissertation is predicated, in part, on a similar theory. 71 Statement of the Chemical Manufacturers Association on the Proposed “Right T 0 Know More Act " (June 27, 1991); see Bass & MacLean, supra note 48, at 302. CHAPTER TWO PROBLEM STATEMENT AND METHODS A) Problem Statement Achieving recognized goals through full public access to information is an underlying principle in the right-to-know paradigm. The EPCRA is a typical example of RTK legislation. The recognized goals of the EPCRA are two-fold. One immediate goal of the EPCRA was to provide local citizenry with the information necessary to make informed, rational decisions about the presence of toxic chemicals to which they may ultimately be exposed. Further, the reporting requirements of the EPCRA were designed to achieve a second, recognized goal of decreasing the risk posed by the catastrophic release of toxic chemicals such as occurred at Bhopal by providing an incentive to industry to reduce the amounts of toxic chemicals stored or discharged into the environment. Attempting to achieve the first goal, the EPCRA requires the reporting of toxic chemical data (e. g., data regarding toxic chemicals other than common chemical name and CAS number) in terms of total quantities. However, provision of this toxic chemicals data to the community in this format alone does not allow the average citizen to readily make an informed assessment regarding the potential risks presented by the existence of the toxic chemicals listed. By only supplying the public with a single critical factor on which an analysis can be based, the average citizen will only be capable of performing a limited 27 28 one-dimensional assessment based on that singular factor.72 Assessment of the presence of toxic chemicals and issues of potential exposure clearly present a multi-dimensional problem.73 Presentation of this data in this format severely limits the ability of the average citizen to reach valid conclusions concerning the presence of toxic chemicals to which he/she may ultimately be exposed. Thus the average citizen may easily draw erroneous conclusions based on a the limited information that is provided and, at best, may be able to 4 . . 7 . . , arrive at a Simple answer to a complex problem. In the extreme, a Citizen 5 use of the 72 The EPCRA requires that Material Safety Data Sheets (“MSDSs”) be submitted, when available, by each facility for each toxic chemical. EPCRA, supra note 23, § 311. It has been suggested that these MSDSS serve as a primary source of health effects information for evaluating the TRI data. However, the MSDSs were designed to be utilized by workers, not the average citizen, they are typically too technical and generally do not address key issues of concern. When considering the use of MSDSs as a tool for TRI data analysis: The usefiilness of the MSDSS is limited, however. MSDSs are often confilsing because brief MSDSS tend to contain difficult to understand abbreviations and longer MSDSs tend to include various types of data in large quantities. Further, MSDSS present this data with no evaluation and fail to provide a full risk assessment. Stenzel, supra note 17, at 9 (citation omitted). A similar argument applies to the toxicological profiles prepared by the Agency for Toxic Substances and Disease Registry under SARA. See 42 U.S.C § 9604(1) (1994). 73 See, e. g., C.Q. Jia et al., Toxic Release Inventories: Opportunities for Improved Presentation and Interpretation, 30(2) ENVTL. SCI. TECH. 86A-91A (1996). 7‘ An example of this level of gross inefficiency is found in the following example: [I]t is grossly inefficient for the United States to spend $6 billion or more annually cleaning up hazardous waste sites, which EPA estimates together probably cause fewer than 500 excess cancer deaths per year, when we are spending only approximately $100 million per year to control indoor radon, which may cause a 8 many as 20,000 excess annual cancer deaths. J. Main, The Big Cleanup Gets It Wrong, FORTUNE, May 20, 1991; see also, WORST THINGS FIRST: THE DEBATE OVER RISK-BASED NATIONAL ENVIRONMENTAL PRIORITIES (Finkel, AM. & Golding, D., eds, Resources for the Future, 1995). 29 information currently presented by the EPCRA’S incomplete and thus misleading format could exacerbate the risks presented by the presence of the toxic chemicals.75 Further, the EPCRA was designed, in part, to achieve the more concrete goal of decreasing the risks posed to the local citizenry by providing an incentive to industry to reduce the amounts of toxic chemicals stored or discharged into the environment. With regard to the use of the EPCRA as a tool for reduction of total quantities, Senator Kerry stated: An important avenue to encourage pollution prevention has been something known as the multimedia data base, the toxics release inventory, or the TRI, as it is known in shorthand. This requires businesses to report on their toxic emissions to the air, land, and water. It * III So we have recognized this right, that the private sector has to live up to, and we have understood that very valuable information is compiled by the Environmental Protection Agency in its TRI data base. 7’ For example, lacking adequate information concerning the toxic chemicals being used at the Union Carbide pesticide plant, the citizens of Bhopal ran towards the plant when the alarm was sounded. This increased their exposure to the methyl isocyanate being released from the plant into the air. This lack of information and fundamental understanding was responsible for increased levels of fatality. See Hearing on PL. 99-499 Before the Com on Small Business, 99'h Cong. (1985) (statement of Dr. Moore). 7" Supra note 2. A clear demonstration of the recognized goal of directly reducing amounts of toxic chemicals is the “33/50 Program.” This program addressed a list of 17 “priorin chemicals” calling for reduction in their total emissions 33% by 1992 and 50% by 1995. The goal of reducing risk by reducing toxic chemical amounts is apparent in the enactment of the Pollution Prevention Act of 1990, Pub.L.No. 101-508, §§6601-6610, 104 Stat. 1388, 1388-321 to 1388-327 (codified at 42 U.S.C. §§13,101-13,109 (1991)), which was designed to provide incentive to industry improve source reduction efforts. The relative merit in using specific legislation, such as the EPCRA, to reduce the use of toxic chemicals has been addressed by various authors. See, e. g., Francine Laden, T oxics Use Reduction: Pro and Con, 4 RISK I.H.S. 213 (1993). 30 However, the EPCRA does not include any aspects of classic risk assessment paradigms that would allow for estimating any decrease in overall risk.77 By only presenting the data concerning releases in the one-dimensional format of total quantity, the EPCRA does not allow for a realistic or reliable evaluation of the success of this endeavor. While the data presented by the EPCRA will readily state whether there has been a decrease in total quantity of toxic chemicals discharged, this information does not provide a means of determining if there has been an improvement in the form of a decrease in the overall risk potential or potential for impact to the environment. It is possible that the decreases in total quantities of toxic chemicals reported under the EPCRA may represent a decraase in totalfl, but it is also possible that the same decrease in total quantities may correspond to a direct increase in total risk.78 As a correlation between a decrease in total quantity of toxic chemicals reported under the EPCRA and a decrease in the potential risks presented by those chemicals does not necessarily exist, an alternative to the 77 This is similar to the situation presented in note 74, in which a policy decision is made without incorporating risk assessment principles and resources (there in the form of money) are expended in an arguably inefficient manner. No single paradigm exists that can solve every problem that involves risk assessment issues. However, various useful methodologies (e.g., comparative risk assessment) in setting priorities in environmental policy, such as the EPCRA, currently exist. See WORST THINGS FIRST, supra note 74, for a general overview of issues relating to reducing “the worst risks first” with a review of the setting of national health and environmental priorities by the U.S.E.P.A. utilizing risk-based priority methodologies. 78 See Jia, supra note 73, at 86A. Jia presents a scenario suggested by Horvath in which the quantity of chemicals discharged to the atmosphere by company A is larger, by an order of magnitude, than the quantity of chemicals discharged by company B, but once the respective discharges are adjusted to incorporate toxicological considerations such as toxicity and exposure factors, the toxicity index for company B’s discharges is greater than company A’s by a factor of 4-5. This example demonstrates that there is no direct correlation between quantity and risk potential or possible impact. 31 presentation of the EPCRA data in its current format is absolutely essential if it is to be the most useful tool for the local citizenry.79 The presentation of the EPCRA data in the one-dimensional format of total quantity is inadequate to serve its intended purposes. In order to optimize the use of the EPCRA both as a useful resource that will empower citizen to engage in informed, intelligent decision-making and as a practical risk assessment tool useful for efficiently directing resources towards reducing the amounts of toxic chemicals stored or discharged into the environment, a multi-dimensional analysis of the TRI data is absolutely essential. B) Study Design and Approach The dissertation approaches the problem presented by performing a multi- dimensional analysis of the toxic chemical data for carcinogens compiled in the TRI. The dissertation uses Michigan as a case study and uses only a portion of the toxic chemicals listed for the study. Specific carcinogens will be selected (based on IARC and OSHA categories and the availability of data) and the appropriate TRI data compiled for reporting years 1987 through 1994. 79 It is possible to theorize that the drafters of the EPCRA only intended to decrease total quantities of toxic chemicals without consideration for the overall risks presented by exposure to the total toxics remaining. However, this theory would, by necessity, be premised on the concept of federal legislators accepting the possibility of an increased risk to their constituents from implementation of the EPCRA. It is not probable that this premise is true, nor is its veracity supported by the Congressional testimony regarding the passage of the EPCRA. The more probable assumption is that the drafters of the EPCRA legislation did not consider the various dimensions of risk assessment in drafting the legislation. an” \‘cs Iarl‘. It}: c! ..I~ .. ..L 0'. ll ell) 32 The existing literature will be reviewed to select an appropriate algorithm which will be effective in performing an analysis of the TRI data. The algorithm selected will incorporate relevant toxicological factors such as toxicity and exposure factors with reported quantities to determine a total hazard value that can be used for the purposes of comparison. The selected algorithm will be applied to the Michigan data to calculate relative total hazard values for each toxic chemical in the study. Finally, the comparison of the total calculated hazard values and the total quantities released for the select group of toxic chemicals in each reporting year will be performed. The goal of this comparison is to evaluate the correlation between the total quantities of the selected toxic chemicals in Michigan (“quantity”) and the hazard values as calculated by the modified algorithm (“risk”). The correlation illustrated by this comparison will support the conclusion that observed decreases in the total quantity of TRI chemicals does not correspond to a decrease in overall risk from carcinogens. Based on this conclusion, the dissertation suggests that the recognized goals of the EPCRA are not being achieved, that efforts to decrease risk by reducing toxic chemicals in the environment are not directed appropriately and that a more appropriate method of TRI data analysis and presentation is necessary. Part II LITERATURE REVIEW 33 CHAPTER THREE APPLICABLE RISK ASSESSMENT LITERATURE A) General Risk Assessment Concepts “Risk Assessment,” a fundamental principle in toxicology, is defined as “the characterization of the potential for adverse health effects of human exposures to environmental hazards.”80 More specifically, risk assessment may be defined as: a process whereby relevant biological, dose-response, and exposure data are combined to produce a qualitative or quantitative estimate of adverse outcome from a defined activity or chemical agent.81 In its current format, the TRI data compilation does not incorporate any “biological, dose- response, or exposure data.” The larger rubric known as “Risk Assessment” is typically separated into four distinct components: hazard identification, dose-response analysis, exposure assessment and risk characterization.82 Hazard identification is the first and most easily recognized step in risk assessment. It is the process of using data from human or animal studies to determine whether exposure to a substance could cause a disease or other adverse health effect. Further, the 8" CASARE'IT AND DOULL’S TOXICOLOGY: THE BASIC SCIENCE OF POISONS 37 (M. O. Amdur et al. eds, 4‘” ed. 1991) (quoting NAS: Risk Assessment in the Federal Government: Managing the Process, National Academy Press, Washington DC. (1983)) [hereinafter CASARETI AND DOULL’S TOXICOLOGY]. 8‘ Id at 986. 82 NAS, Risk Assessment in the Federal Government: Managing the Process (1983). Also, the EPA incorporates into most of its risk assessment guidelines the following description: ‘Risk assessment includes one or more of the following components: hazard identification, dose-response assessment, exposure assessment, and risk characterization." Guidelines for Carcinogen Risk Assessment, 51 Fed. Reg. 33,992, 33,993 (1986). 34 IS‘J . | . “it t I ll- mit as exposure» ; cizperzmertx rcdence o concept 1r. at rzsi a»; SPtCilic p “$105111: illillOUgl‘. _ y c ~lllhff it: islets :1. 1d at ‘13, 1" Fur 8i 35 specific disease or adverse health effect (i.e., the toxicological endpoint of the possible exposure) is also determined at this stage. The toxicological endpoints observed in experimental studies range from simple allergic reactions to increased mortality and incidence of cancer.83 The dose-response relationship is considered “the most fundamental and pervasive ”84 A dose-response analysis builds on the hazard identification step concept in toxicology. of risk assessment by quantifying the relationship between the dose of an agent and the probability and/or severity of a specific adverse effect in laboratory animals. On its simplest level, a dose-response relationship is “characterized by a dose-related increase in the severity of the response.”85 Exposure assessment quantifies the exposure and uptake of a substance by a specific population using field measurements and other estimates. Specific components of exposure include “intensity; frequency; schedule; route and duration of the exposure [through any combination of oral, inhalation and/or dermal routes of exposure]; and the “3 See CASARETT AND DOULL’s TOXICOLOGY, supra note 80, at 988. The text states that “[t]he key element in this step is the linking of the agent or activity with the effect and reflects the strength and plausibility of the association.” Id. 84 Id at 18. 85 Id. Further, in practical applications: there are two types of dose-response relationships: (1) that which describes the response of an individual to varying doses of a chemical, often referred to as “graded” responses because the measured effect is continuous over a range of doses, and (2) that which characterizes the distribution of responses to different doses in a population of individuals. Id. (emphasis added). ... 1"" féi‘llé. size are com 2:: TE: mmanze panties I irritations poiitzcai i; Bl 51m; Sc :hemicais that 1m: det‘islnng unite“; 5531631 fr. Are 55) Gr 36 ”86 nature, size, and makeup of the potential (or actually) exposed population. These data are combined to estimate the potential uptake of the substance by the exposed population. The most important part of a risk assessment, the risk characterization, summarizes and interprets the information collected from previous activities, identifies and quantifies the probability of risk in a specific population. It is at this final stage that the limitations and the uncertainties in estimating risk are presented and various social and/or political judgments (e. g.,safety factors) are incorporated.” B) Alternative Hazard Value Scoring Methods Several weighting systems for performing a comparative analysis of toxic chemicals have been proposed. All the systems proposed suffer from similar deficiencies that limit their usefulness. First, missing or incomplete data prevent all proposed weighting systems from being broadly applicable. Second, each system requires subjective decisions in determining data input which mitigate against any single system becoming iniversally accepted. To varying degrees, these deficiencies have prevented any one ystem from being recognized as the definitive risk assessment tool in this arena. Below re several of the alternative hazard value scoring systems that have been proposed as :ing applicable to TRI data. Further, this aspect of risk assessment is referred to as the “most neglected aspect of the k assessment process.” Id. at 988. EPA has published guidelines for many stages and types of risk assessment. See, e. g, idelines for Carcinogen Risk Assessment, 51 Fed. Reg. 33,992 (1986); Guidelines for imating Exposures, 51 Fed. Reg. 34,042 (1986); Guidelines for the Health Assessment Suspect Developmental T oxicants, 51 Fed. Reg. 34,028 (1986); Guidelines for the zlth Risk Assessment of Chemical Mixtures, 51 Fed. Reg. 34,014 (1986); and delines for Mutagenicity Risk Assessment, 51 Fed. Reg. 34,006 (1986). An Setsances rmewdt lViiA ninth ssmil' ‘3 i’lfi SLAM h netted f, nuns; 37 l. lnteragency Testing Committee Workshop (Welch & Ross) An early scoring system for toxic chemicals was developed by the Toxic Substances Control Act-lnteragency Testing Committee (“ITC”).88 That system was reviewed by a group of experts from academia, government and industry in February 1979.89 A three day workshop sponsored by the U.S.E.P.A.’s Office of Toxic Substances and the ITC was held in August 1979 to further review of the principles of this scoring system. The results of this second workshop and the final iteration of the scoring system were subsequently reported by Welch & Ross.90 In this study, the authors recognized the need for the integration of a scoring method for setting priorities when dealing with “problem chemicals” that present the greatest possible risk (assuming some exposure). Welch & Ross stated: When dealing with a large number of problem chemicals, the use of a systematic method is one approach to insure that those chemicals with the greatest potential risk are identified and reviewed first. Scoring can be viewed as a tool to provide a framework for the consistent evaluation of information used in the early stages of the chemical assessment process. The purpose of scoring is to select from the large number of existing chemicals those chemicals that have a high probability of requiring review for control or testing. Toxic Substances Control Act-lnteragency Testing Committee, Initial Report to the lministrator, EPA 560/10-78/001, US. Environmental Protection Agency: Washington, C., February 1977. R. H. Welch & J. L. Welch, Proceedings of the EPA Workshop on the Environmental oring of Chemicals, EPA 560/11-80-010, US. Environmental Protection Agency: [shingtom D.C., February 1979. J. L. Welch & R. H. Ross, An Approach T o Scoring 0f Toxic Chemicals for vironmental Effects, 1 ENVTL. TOXICOL. CHEM. 95 (1982). he EPC R ‘dea's mth Welch it Rt tic} :hcrnb tie inpiem S€~ 5.”. 5U 72 sister; c 2 4 -.,. . EDD CLt‘N‘, .' a" '4‘ muhfi \_ M at C!'_ .. 1d “bid: a" ‘3‘. gr 1‘1 at mi 38 The EPCRA, in focusing on toxic chemicals with the goal of reducing potential risk, also “deals with a large number of problem chemicals.” However, the approach suggested by Welch & Ross (or a similar approach) was not included in the requirements of the EPCRA and therefore, there is no way of knowing whether the overall risk has been decreased or if the implementation of the EPCRA is efficient (i. e., if those chemicals with “the greatest potential risk” are addressed first). The ITC scoring system addressed various environmental effects “that covered seven subfactors dealing with human health and ecological concerns.”91 The scoring system “consisted of three segments: environmental (biotic) effects, environmental fate, and ecosystem effects” and incorporated parameters such as lethal dose, persistence and mobility.92 However, the system had several distinct “drawbacks.”93 9’ Id. at 96. 921d 93 Welch & Ross stated: The proposed approach is reasonable in concept, but there are several drawbacks to the system. The system does not address abiotic effects or effects on ecosystem processes. Another drawback is the lack of systematic identification of specific areas that may require testing, but it was felt that fiirther study of chemicals with high scores would identify data voids and testing needs. In closely examining the system after the workshop adjourned, several problem areas became evident. The mobility concept needs fiirther clarification and better definition of criteria for scoring. In addition, combining the toxicity with appropriate exposure media needs more thought. Exposure route in the effects tests should be linked more closely to environmental exposure routes. at 100-101. “El for in: it did scoring 53 11‘s.. it: stipend-.- tumor. 1 mam-‘73 H03?) 6‘: Cflflitm 1) stem is Shil‘t‘Cil'it‘ Probima judgmem i [‘1 at 30.13an 39 For the purposes of this dissertation, one drawback to using the scoring system is that it did not provide a quantitative analysis of the toxicity for each chemical. The scoring system only grouped chemicals generally according to relative concern (e. g., “high, medium, and low concern”) and did not quantitatively rank each chemical independently.94 Further, the Welch & Ross scoring system proposed substituted expert opinion when data was completely unavailable.95 Welch & Ross perceived the incorporation of expert opinion to be a distinct advantage for their scoring system.96 However, for the purposes of this dissertation, the reliance on the incorporation of expert opinion is not an option and therefore is a drawback to using the Welch & Ross scoring system. The use of general groupings based on relative concern and the reliance on subjective opinion in place of available data makes this system less than desirable for 9“ Id. at 102. The approach taken by Welch & Ross only provided a comparative analysis of the chemicals included in the study and therefore, the scoring system was not useful in analysis of individual chemicals outside the system. Welch & Ross, id. at 102, recognizing his, stated: it is important to emphgsize that the utility of a chemical’s score is not so much the score itself, but in enablingpne to compile it with other chemicals. Scoring is a tool to sort chemicals into several groups (for example, high, medium, and low concern) with chemicals in each group being of relatively similar degree of concern; the actual [inkingis less immrta_nt. '. at 102 (emphasis added). Id. at 100. A lack of experimental data was not perceived by Welch and Ross to be Dblematic. The authors, id, simply state that: “Expert scorers will use their professional lgment in generating a score even if some information is not available.” Id. Id. at 100. Welch & Ross, id, in illustrating this perspective state: “[The model’s] rantages are it simplicity, minimal information requirements, and reliance on fessional judgment.” Id. sszens P3 their s 516.. risl. nor IS carnage filling l; . chemicals attemptzr \\ the one»; Therein: for use» (Wt/Eire, 101ml: 40 assessing risk on an individual chemical basis.97 As one of the earliest chemical scoring systems proposed, Welch & Ross admitted to and reviewed the inherent limitations of their system. Therefore, the Welch & Ross scoring system is not useful for fully assessing risk, nor is it the single best analysis paradigm available for assessing TRI data. 2. U.S.E.P.A. Conference (Forman, et al.) A system designed specifically for Maryland TRI data analysis was proposed by Forman in 1993.98 This system indexed the toxic chemicals by rank order based on relative toxicity. The ranking system was applied to both carcinogens and non- carcinogens and used oral reference doses (Rfl)s) and cancer potency factors (CPFs) in setting toxicity levels. This system is limited in that it only provides a relative ranking of Chemicals by toxicity without quantifying the specific risk presented by each chemical nor lttempting to account for exposure factors. While the chemical ranking system proposed by Forman et a1. might be usefiil for 3 onfi-dimensional analysis of Michigan data, it is not useful for fiilly assessing risk. erefore, this chemical scoring system is not the single best analysis paradigm available asseSSing TRI data. \ later system was proposed by Ross in conjunction with O’Bryan that incorporated tn Parameters, included measures of hazard and exposure such as mutagenicity, Dgenicity and lethal doses, in determining the relative ranking of toxic chemicals. System also included expert opinion when other data was unavailable. See, T. R. Van & R. H. Ross, Chemical Scoring System for Hazard and Exposure Weation, 1 J .TOXIC.ENVTL.HEALTH 119 (1988). L- F orman et al., Proceedings of the T oxics Release Inventory (T RI) Data Use r?nce, March 29-31, 1993, Chicago, IL, EPA/745-R-93-004, US. Environmental 31011 Agency: Washington, D.C., July 1993. is. -l 1....— l - (ten Te: GENE Oi l 5 1.. if‘ELL‘PmC H2333)" 11".". Tr. I. Sister.) ' 41 3. University of Tennessee Study (CCPCT; Davis, et al.) A study done by the University of Tennessee’s Center for Clean Products and Clean Technologies (“CCPCT Study”) also proposed a chemical scoring system.99 The purpose of the CCPCT Study was to propose a system that would “support the design and development of products whose manufacture, use, recycle and disposal represent reduced . - ml )0 impacts on the envrronment. ‘ The chemical scoring system proposed by the CCPCT Study (the “CCPCT System”) built on the chemical scoring systems suggested in the existing literature but integrated aspects of relative risk assessment. On the issue of risk assessment and the C CPCT System, the CCPCT Study provides that: Risk-based chemical ranking and scoring combines an assessment of both the toxic effects of chemicals and the potential exposure to those chemicals, to provide a relative evaluation of risk. Risk assessment is an integral part of the environmental equation for successful protection and sustainability. 10' The CCPCT System addressed issues of both human health and environmental risk ’rom direct chemical exposure and evaluated “the potential hazard of TRI releases to umans, terrestrial animals and fish.”102 The conceptual illustration of the CCPCT System roposed in the C CPCT Study is provided in Figure 2 on the following page. ‘03 G. A. Davis et al., Chemical Hazard Evaluation for Management Strategies: A Method " Ranking and Scoring Chemicals by Potential Human Health and Environmental pacts, EPA/600/R-94/l77, US Environmental Protection Agency, Washington, D.C., 3t. 1994 [hereinafter CCPCT Study]. Id. at iii. Id. 'd. at 19. 'd. at 20. U..C0..£iv - I , _ _ 1---. 1 . 1053m03XW so» .€.~C.au~nlv-nw Nuwowxoin. tun-COECQFCICW fivcnlcnwEJI 42 839%»: E36: magnum REESE \o 38: 3238on .N 839m 1, .895 m3 8:250 , can. _ .285 m3 Bau< L1 . a «E... cognac. Bao< __ __ finance“? 522283035 _ 850 . , . 23:2: 2:020 3320: 1T .358 - Eh , 252$de :33.sz l— mcnfiaz _ o~=u< c2609.. 655:5 2:8 xm 36:8... 5.559“. «85 .0 23¢ co 2; . _ 2:020 ._. 8832 Samoa—Kw gazed... 43 Hazard values used in the C CPCT System for each chemical were derived using data on “seven toxicological endpoints and exposure assessments.”104 Simply stated, the seven toxicological endpoints used in the CCPCT Study to determine hazard values are “human health effects data [that] include acute oral and inhalation toxicity, carcinogenicity, and other specific effects,” and “environmental effects [that] include acute mammal and fish mortality and chronic sublethal effects in fish.”105 Each of these seven toxicological endpoints was assigned a hazard value between zero and five and effects - - 106 were treated as additive. '04 Id. at 21; see also id.,at 10, tbl. 2. ‘05 Id. at 9. “Other specific effects” are defined in the CCPCT study as mutagenicity, developmental toxicity, reproductive toxicity, chronic toxicity and/or neurotoxicity. See id, app. A, at A-10. The CCPCT Study further defines these terms as: Mutagenicity: Chemicals are indicated as possible mutagens in humans if positive results in bioassays are reported in the reference source (ICF, 1989). Developmental Toxicity: Chemicals are indicated as exhibiting developmental toxicity if data in the reference source support concern that the chemical may cause embryotoxicity, fetotoxicity or teratogenicity in humans (ICF, 1989). Reproductive Toxicity: Chemicals are indicated as exhibiting reproductive effects if data in the reference source support concern that the chemical has adverse effects on male or female reproductive performance (ICF, 1989). Chronic Toxicity: Chemicals are indicated as exhibiting chronic toxicity if adverse effects other than cancer occur at doses less than or equal to 1 g/kg/day following inhalation, oral or dermal exposure for more than 90 days (ICF, 1989). Neurotoxicity: Chemicals are indicated as neurotoxic if chronic (at least 90 days) inhalation, oral or dermal exposure to doses less than or equal to 1 g/kg/day results in neurotoxic effects (ICF, 1989). Id. at 21. The CCPCT System incorporates the use of decision trees in assigning :cific hazard values. See id. at app. A. A hazard value of zero indicates that the >mical is nontoxic while a hazard value of five indicates that the chemical is extremely ic. 1d. 44 The CCPCT System incorporated a Release Weighting Factor (RWF), defined as “a multiplicative used to weight toxicity hazard values for each chemical according to the ”107 amount of its annual releases or transfers to air and water. This weighting system was necessary to ensure that neither the hazard values nor the release amounts dominated the 108 algorithm. Four weighting systems were evaluated for calculating the RWF. The authors selected a scheme that “[multiplied] specific hazard values by the natural log of the ”109 releases to air, water, or the sum of air and water. A cutoff point of 60,000 pounds was selected for the CCPCT study.110 This cutoff point was obtained by subtracting ten from the natural log of the releases in calculating the RWF. 1“ The RWFs were applied to the hazard values determined for the toxicological endpoints for each type of release.”2 Potential exposure parameters used in the CCPCT System for each chemical “includes persistence and bioaccumulation along with annual TRI releases as an overall ”[13 ' ' - ' u ' n measure. Persrstence and bioaccumulation factors were consrdered pivotal and were "’7 Id. at 24. “’8 Id. at 23. ‘09 Id. at app. A, at A-24. The use of the natural log “gives the data a normal distribution [with] a range of 10 integers over the range of release amounts.” Id. Id. 1” Id. Subtracting ten from the natural log of any releases below 60,000 pounds will result in a weighting factor that is always equal to one for those releases. ”2 Id. In the CCPCT System the RWFs were applied in the following manner: 0 The weighting factor for air releases (RWFm) was applied to the hazard value assigned for the inhalation rodent LCso. o The weighting factor for water releases (RWFwatcr) was applied to the oral rodent LDso, fish LCso, and fish NOEL. 0 The weighting factor for the total air and water releases (RWle) was applied to the chronic toxicological endpoints for carcinogenicity and other specific effects. Id. “3 Id. at 13. 45 :refore included as multiplicative factors with hazard values between one and two and .e-half.”4 Also, while not including them in the CCPCT System, the CCPCT Study ated that the incorporation of “fate and transport models” (i.e., multi-media models, ifra) was “pivotal” and could be included in site-specific exposure assessments.115 The CCPCT System used peer-reviewed experimental data whenever those data 116 were available. However, as with all chemical ranking systems reviewed in this study, certain toxicological data were unavailable. For missing experimental data, the CCPCT System used both qualitative and quantitative structure analysis (SAR and QSAR, 117 respectively) to estimate toxicological endpoints. Lacking experimental data, or SAR or QSAR analyses the CCPCT System assumed minimum and maximum hazard values for each toxicological endpoint.118 By performing calculations using both the minimum and maximum hazard values, the CCPCT study provided a range of the total hazard value (THVs) for the missing toxicological data. As its analysis tool, the CCPCT System utilizes an algorithm that equates the THV of a specific chemical with the sum of the human health effects and environmental effects ”4 Id. at 21. A hazard value of one indicates that the chemical is not persistent or it does not bioaccumulate while a hazard value of two and one-half indicates that the chemical is highly persistent or has a high tendency to bioaccumulate. Id. ”5 Id. at 13. “6 Id. at 5. The CCPCT study uses the Hazardous Substances Data Bank (HSDB) as an eigample of a source of peer-reviewed experimental data used “whenever possible.” Id. Id. ”8 Id. Originally, the hazard value for an endpoint that was missing data was set to zero. See id, app. A, at 1. However, in the final analysis of data in the CCPCT System, the hazard value for the endpoints with missing data were set to the minimum and maximum values (i.e., zero and five, respectively) for comparison. 1d. at 26. 1 al 46 :iplied by the exposure potential.119 In determining the individual hazard values for tan health effects, environmental effects and exposure potentials, the CCPCT System . . . . . 120 l vanous deCISton tree analysrs to assess available data. The variables representing the hazard values incorporated into the CCPCT System »rithm are listed and defined as: HVonl 1.050 = Hazard Value for the oral rodent LDso HV,.,-,,-,.-.,, Lcso = Hazard Value for the inhalation rodent LC50 Hch-m = Hazard Value for Carcinogenicity I-Ithcr = Hazard Value for “other specific effects” HVfish LCSO = Hazard value for FlSh LCso HVM, NOEL = Hazard Value for Fish No Observed Effect Level HVBOD = Hazard Value for Biological Oxygen Demand Half-Life HVhydmlosis = Hazard Value for Hydrolysis Half-Life HVBCF = Hazard Value for Aquatic Bioconcentration Factor121 ' Id. at 19. A general discussion of the Algorithm and its components is found in the CPCT Study, see supra at Chapter 4. 3 Id., app. A. ‘ Id. See also Chapter 3. The CCPCT Study defines the following terms: Hle L050 : The concentration of a substance, expressed in mass of the substance per mass of the animal, that will kill half of a group of rodents within 14 days when administered orally as a single dose. HVimh-im, Lcso : The concentration of a substance in air (gas or dust) that will kill half of a group of rodents when inhaled continuously for 8 hours or less, scaled to 4 hours. HVfish Lcso : The concentration of a chemical, in water, that causes death of 50 percent of the fish tested. HVMI NOEL : The highest dose administered that does not produce toxic effects (Casarett and Doull, 1986). HVBOD = The BOD half-life is the time (in days) required for a chemical to biodegrade such that its BOD in water is decreased to half of the original amount. HVhydrolmi, : The hydrolysis half-life is the time (in days) required for the amount of a substance to decrease to one-half of the original amount through hydrolysis reaction in water at pH 7. HVBCF : The ratio of the concentration of a chemical in fish to its concentration in water at steady-state conditions. This factor is a measure of the chemical’s ability to bioaccumulate and is typically reported in log units. Id. at app. A. 47 Illustration of the CCPCT System algorithm and its individual components is provided in Figure 3 on the following page. 122 While the CCPCT System was not explicitly designed for the analysis of TRI data, 140 TRI chemicals were included in the CCPCT study. 123 Further, the incorporation of potential exposure factors and toxicity values for each chemical into the chemical ranking algorithm make the CCPCT System a useful tool for performing the type of multi- dimensional analysis proposed in this dissertation. 4. Carnegie Mellon University (Horvath, et al) Horvath, et al. recently proposed a scoring system designed specifically for the 124 analysis of TRI data. This scoring system proposed a method for weighting TRI release using threshold limit values (TLVs).125 The TLVs used in the study were developed by the American Conference of Governmental Industrial Hygienists (ACGIH).126 The 122 Id. at 22. '23 Id. at 6-7. The 140 TRI chemicals were selected from the 1989 TRI report which listed 270 total chemicals. TRI chemicals incorporated in the CCPCT study were selected based on total quantities released. TRI chemicals that constituted 99 percent of the total releases or transfers reported were included in the CCPCT study. Twenty-one high volume pesticides were also included in the study. See id. '24 See Horvath, supra note 70. ‘2’ 1d. at 88A. ‘26 Id. With regard to the derivation of the ACGIH TLVs, Horvath stated: [t]he ACGIH TLV-TWA [Total Weighted Average] has the same meaning as the Occupational Safety and Health Administration’s (OSHA) permissible exposure limit-time-weighted average (PEL- TWA). Indeed, nearly all of OSHA’s PELs were adopted from the ACGIH TLV index: 48 assess-38 2: .m can HERE.» gauge» Esme: ...... $2 «:8 «ms n .325 . uua>- + assist + magi u gaunt 233nm 3 u as as as: + as as: + as as: u 385 3552.... ..m «a u 5.5 . is: + is: + as 5.2.x: + gals: u sake ~38: .333: 2:33 3.53... 9385M 18853 Beansnfiscm + 3853 ..38: 5255» u 8.3» 3362 335 _ E 85:0»? 2:. 49 ACGIH TLVs were designed as a tool for the protection of workers exposed, through inhalation, to various chemicals over varying periods of time. 127 The approach taken by Horvath et al. has merit and is enlightening. Further, it may be directly applicable to the Michigan TRI data. However, the use of TLVs to weight toxicity factors and the incorporation of inhalation as the only exposure factor indicate that this approach may be limited in application. Therefore, the chemical scoring system proposed by Horvath et al. is not the single best analysis paradigm available for assessing TRI data. 5. University of Toronto (Jia, et al) In 1996 Jia, et al., building on past efforts, proposed a more complicated chemical scoring system designed specifically for the analysis of TRI data.128 In the 1996 paper, Jia et al. recognized that the TRI database is an inefficiently utilized resource presented in a format that may by misleading. '29 Id. at 88A. 127 Id 128 Jia, supra note 73. ‘29 Id. Jia states that: Considerable effort and expense are devoted to the acquisition and publication of Toxics Release Inventory (TRI) data, but it is suggested that this invaluable resource is underexploited and can be misinterpreted. A more accurate expression of the impact of these discharges can be developed through indices that combine the emission data with toxicity, environmental persistence, and the potential for multimedia partitioning. Id. at 86A. By integrating “toxicity, environmental persistence, and the potential for multimedia partitioning” (i. e., factors that are necessary to assessing risk), it was the goal of Jia that the “TRI data may be better interpreted, and thus may play a more effective role in chemical stewardship.” Id This, of course, is one objective of this dissertation. 50 The system proposed by Jia et al. is divided into four indices; two proposed in the previous literature and two new. The first two indices, which were carried over from the previous literature, are the analysis of emissions using total quantity (i. e., the current TRI format) and the analysis of the emissions using both total quantity and a weighted toxicity factor (i.e., the approach adopted by Horvath, et al.). The two new indices proposed by Jia, et al. are: a) the analysis of the emissions using total quantity, a weighted toxicity factor am] incorporating the persistence of the chemical; and b) analysis of the emissions using total quantity, a weighted toxicity factor, persistence and incorporating environmental mobility (i.e., incorporation of multi-media fate modeling). The incorporation of chemical persistence is a usefiil addition to the paradigms suggested by the earlier literature. Subsequent systems, including the CCPCT System suggested by Davis et al., generally included some persistence factor.“ 0 However, while the incorporation of multi-media fate models may prove to be useful to fiiture risk assessment practices, the current status of the technology and lack of acceptable data indicate that they are of limited utility. It has been suggested that these models are not usefiil tools without “decades of funding research, monitoring, and assessment.”131 Until ‘30 The CCPCT System uses biological demand half-life and hydrolysis half-life as parameters to measure persistence. See, CCPCT Study, supra note 99, at 14. '3‘ 1d. Jia makes extremely optimistic predictions about the use of multi-media fate nodels, however, these predictions illustrate the current limitations of their use as a risk tssessment tool. For example, Jia states: Implementing [the use of multi-media fate models] will require the environmental science community to arrive at some level of agreement about the key properties of chemicals. We regard this as (footnote continued) 51 ose “decades of funding research, monitoring, and assessment” for all chemicals have :en realized, these models remain of limited utility.132 Therefore, the chemical scoring Iodel proposed by Jia et al. is not the single best analysis paradigm available for assessing TRI data. C) Multi-media Fate Models The Society for Environmental Toxicology and Chemistry (“SETAC”) recently reviewed various multi-media fate models.133 While multi-media fate models were not incorporated into earlier chemical scoring systems, the principles on which they are based are recognized as having significant utility in enhancing chemical scoring systems.134 feasible, at least for the well-studied, high-volume chemicals for which there are extensive fate and effects data. Surely, this is possible after the decades of funding research, monitoring, and assessment. Id. at 91A. This prediction is hopeful at best, and if true, presently only applies to a small number of chemicals. Therefore, multi-media fate models are currently of limited utility. Id. ‘32 The University of Toronto study only used pentachlorobenzene and styrene to illustrate the approach of the proposed model. For these 2 chemicals, Jia estimated persistence using various sources. However, Jia recognized that persistence data, while available to some extent, are incomplete and stated: Extensive compilations of atmospheric reaction persistences, or half lives, are now available as a result of the studies by Atkinson (Citation omitted). Persistences in other media are less well documented, but estimates are becoming available (Citation omitted). Reaction persistences can also be estimated from multimedia environmental models. Id. at 88A. 133 SOCIETY OF ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY (SETAC), THE MULTI- MEDIA FATE MODEL: A VITAL TOOL FOR PREDICTING THE FATE OF CHEMICALS, (Cowan, C.E., etal. eds, SETAC Press 1995) [hereinafter SETAC REVIEW]. 134 See, e. g, CCPCT Study, supra note 99. 52 Further, these types of models are often integral to and required by the more sophisticated and recent chemical hazard evaluation systems if they are to be effectively utilized at some time in the fiiture (e. g., see the fourth index discussed above by Jia, et al.). Multi-media fate models combine: a chemical’s intrinsic properties and emission patterns with the characteristics of the environment into which it is released to predict how advective and inter-media transport and transformation processes will affect the distribution of the chemical among the various environmental media, and thus the concentrations that will . - 3 result In each medium.1 5 The goal of this type of model is to provide detailed chemical data in a format that, when taken in combination with adverse effects information, will allow for the assessment of risk to human health and the environment. While it is recognized that at some point in the future multi-media fate models may be widely used as a risk assessment tool, the existing lack of review by the scientific community prevents effective implementation in current risk assessment endeavors.136 Further, the level of sophistication presently found in these models coupled with the lack 35 Id. at 1. 36 Addressing the lack of peer review, the SETAC Review stated: Despite the recognition that multi-media fate models are vital and even essential tools for assessing the fate of chemicals released to the environment, there has never been a systematic, international evaluation of their strengths, limitations and precision, and accuracy when used to address the specific needs of organizations and scientists in their various assessment activities. TAC REVIEW, supra note 133, at 2. 53 of data necessary for their effective utilization also prohibit their widespread use.1 7 For these reasons, the use of multi-media fate models is not incorporated into this study. D) Selection of lizard Value SconnLMethod l. The CCPCT System Each of the chemical scoring systems discussed in this chapter is imperfect in some respect. Further, the deficiencies inherent in each chemical scoring system indicates that no individual system is the single best analysis paradigm available for assessing TRI data. However, review of the CCPCT System proposed by Davis et al. clearly demonstrates that it is superior to the other chemical scoring systems reviewed. The CCPCT System is superior to other chemical scoring systems because of its incorporation of human health and environmental risk factors in combination with direct chemical exposure data using the broadest, most complete experimental data available. The selection by other researchers of the CCPCT System for the analysis of TRI data supports the proposition that it is the superior chemical scoring system and analysis tool. 2. University of New Orleans (Lea. et al) A group at the University of New Orleans undertook an analysis of TRI data using n approach similar to that used in this dissertation.138 The New Orleans group In the SETAC review of multi-media fate models, several recommendations were made ncerning the need for further development of specific components of existing models It are currently deficient. Id at x-xi. Until issues such as harmonization of different idels, documentation, validation and inclusion of more detailed input parameters in each del compartment can be addressed, the acceptance of a single model for practical risk essment applications is not possible. 54 questioned the validity of the TRI as an indicator of environmental quality or as a useful tool for assessing toxic chemical releases to the environment. The group adapted the CCPCT System suggested by Davis, et al. and used Louisiana specific TRI data for reporting years 1987-1990 to demonstrate the inadequacy of the existing TRI data presentation. Lea et al. concluded that the TRI data, as currently presented, fails to assess the impact of toxic chemicals on human health and to the environment.‘39 The New Orleans study was too narrow in some respects for it to be usefiil in assessing the long term success of the EPCRA. For example, the study only reviewed Louisiana TRI data for a 3 year reporting period. While some end users (e. g., the average citizen) may only analyze TRI data on a “year to year” basis, accurately assessing the long term success of the EPCRA and the resulting trends in the affected industries requires that the largest reporting period available be reviewed. The selection of the CCPCT System (proposed by Davis, et al.) by Lea et al. for TRI data analysis suggests that it is as the preferred chemical scoring system for that type of data. Therefore, adaptation of the CCPCT System in a fashion similar to that attempted by Lea et al., using select Michigan specific TRI data, is likely to provide the most 3 8 W. R. Lea et al., Comparative Risk Analysis of the T RI Data as an Environmental ndicator -A Louisiana Case Study; Paper presented to the Air & Waste Management .ssociation’s 88th Annual Meeting & Exhibition, San Antonio, Texas, June 18-23, 1995. 9 In conclusion, Lea stated: The traditional method of analyzing the TRI data fails to address the true concerns about chemical emission to the environment: human health effects, environmental effects, persistence in the environment, and bioaccumulation. Furthermore, the TRI “top polluters” lists are intentionally or unintentionally punitive in their failure to address the actual impact to the environment and human health. at 8. 55 effective method for performing the type of multi-dimensional analysis that is necessary to achieve the objectives of this dissertation. Part III DATA COMPILATION 56 i CHAPTER FOUR TRI DATA A) Method of Data Collection 1. TRI Data Availability Text versions of TRI data for all reporting years are readily available from the U.S.E.P.A. National Center for Environmental Publications and Information (“NCEPI”) with support for usage of the printed volumes from Toxic Release Inventory User 140 Support. Further, the EPCRA mandate that the TRI data be compiled into a publicly accessible computer database has resulted in various other computer accessible forms of the TRI data being made availablem For example, TRI data are available on floppy diskette (5.25 and 3.5 inch), CD-ROM and magnetic tape from National Technical Information Service (“NTIS”) in dBase and Lotus formats.142 Environmental groups, such as those responsible for RTK-NET, also provide free remote computer access to TRI data through the Internet.143 Further, the TRI is publicly accessible using personal computers through the National Library of Medicine’s (“NLM’s”) Toxicological Data NetworkC‘TOXNET”).H4 NLM’s TOXNET is a subpart of the NLM’s Medical ”0 To obtain this information, contact: NCEPI, Attn: Publications Orders, PO. Box 2419, Cincinnati, OH 45242-2419. ” See supra note 38. 2 To obtain this information, contact: NTIS, 5285 Port Royal Road, Springfield, VA 2161. (Only reporting years 1987-1992 are currently available through this service.) 1 See supra note 69. To obtain this information, contact: Right-to-Know Computer :twork, 1742 Connecticut Avenue, NW, Washington, DC. 20009-1171. TQXNET, National Library of Medicine, Specialized Information Services, 8600 ickville Pike, Bethesda, MD 20894. See also INTERNET or see 0 TELNET (access code and password required, subject to a ). 57 ’ s a V 58 Literature Analysis and Retrieval System (“MEDLARS”) which also contains files on toxicology, hazardous chemicals and other related topics.145 The TRI data publicly accessible through MEDLARS on TOXNET are fiJlly searchable using a free text search and full Boolean logic. “‘6 2. INTERNET Collection of TRI Data All methods of data collection listed above provide similar access to the same information, however the presentation of the data is different for each. Factors such as cost, accessibility and ease of use were taken into consideration in selecting a search tool for collecting data for this dissertation. The most current form of the TRI data is provided through the INTERNET resources. ”7 Initial TRI data review for this study was performed on-line using TELNET to access TOXNET through MEDLARS.148 At that time, direct on-line access to TOXNET using MEDLARS was the superior means of data collection due to the relative ”5 NLM, TOXicology Data NETwork: A Brief Guide To Searching Its Files (October 1995). (TOXNET contains the following databases: the Hazardous Substances Data Bank (HSDB); the Registry of Toxic Effects of Chemical Substances (RTECS); the Chemical Carcinogenesis Research Information System (CCRIS); the Integrated Risk Information System (IRIS); GENE-TOX; the Environmental Mutagen Information Center-Front and Back Files (EMIC/EMICBACK); the Developmental and Reproductive Toxicology Database/Environmental Teratology Information Center Backfile (DART/ETICBACK); the Toxic Chemical Release Inventory (TRI) and the Toxic Chemicals Release Inventory Facts Sheets (TRIFACTS)). I46 Id ”7 Francis M. Lynn & Jack D. Kartez, Environmental Democracy In Action: I he T oxics Release Inventory, 18(4) ENVTL. MGMT. 511 (1994). ”8 Initial TRI data review was performed in October/November 1995. 59 sophistication of its search capabilities. The final TRI data used in this study were updated and recompiled using the RTK-NET on-line resource. ”9 B) Collection and Compilation of Michigan TRI QuantityI Data 1. Carcinogens Between 1987 and 1994, the TRI required reporting of specific data on approximately 320 toxic chemicals.15 To maintain a reasonable level of manageability, the toxic chemicals addressed in this dissertation can not include all 320 TRI chemicals and therefore, the field must be restricted. ”1 ”9 The RTK-NET is recognized as a reliable on-line source of TRI data. For example, the U.S.E.P.A. only lists NLM’s TOXNET and the RTK-NET as sources of available on-line TRI data in its yearly TRI public data release. See, e. g., 1993 T oxics Release Inventory - Public Release Data, EPA 745-R-95-010. In the period of time between the initial review of the TRI data and the final data compilation for this study, the RTK-NET was redesigned. The redesigned RTK-NET has improved interactive search and retrieval capabilities which made it the superior tool for collecting the specific TRI data desired. Another software search tool not yet discussed is “Grateful Med.” Gratefiil Med software provides an alternative search engine for searching NLM’s TOXNET. However, the current INTERNET version of Grateful Med (“IGM”) does not provide for this type of focused search. Therefore, Gratefiil Med was not selected as a research tool for this study. Gratefiil Med does intend to provide this service in the near future. '50 Id. This number is only an estimate for all reporting years. For example, while the original list contained 320 chemicals, through additions and deletions, the 1993 list contained 316 chemicals and 20 chemical categories. Further, while the number of toxic chemicals on the list may appear to be static, the combination of additions and deletions indicates that the individual chemicals listed may be distinctly different. Id ’5’ This reality presents a quandry in that while narrowing the field of chemicals to be reviewed is desirable, it directly limits the applicability of the study in future analysis. However, the purpose of this study is to assess the overall success of the EPCRA in retrieving its recognized goals using a narrow field of chemicals as indicators of that uccess. The purpose of this study is not to definitively state the total hazard values or isk that the TRI data represents. Further, as a practical matter, analysis of all TRI hemicals is problematical due to the absence of detailed toxicological data for each hemical. This absence of data requires that numerous assumptions be embedded in the Ialysis, which bring the validity of the paradigm into question. 60 All chemicals subject to the EPCRA and listed in the TRI are “toxic” by definition. Therefore, there is a certain level of risk realized by an individual if that individual were to be exposed to any of these TRI chemicals. However, even a cursory analysis of the approximately 320 toxic chemicals subject to the reporting requirements of the EPCRA indicates that they are not “equal” in all respects. One factor recognized by toxicologists to distinguishes between toxic chemicals is the response, or adverse effect, observed from exposure to that chemical in clinical tests.152 As discussed earlier, the possible spectrum of observed adverse effects may be quite broad.153 It is possible to narrow the field of toxic chemicals by selecting a single adverse effect and only addressing toxic chemicals which produce that specific toxicological endpoint. For example, after analyzing the 1994 TRI data, the Greater Boston Physicians for Social Responsibility and the Massachusetts Public Interest Research Group Education Fund (Greater Boston Physicians Study) issued a report focusing on “known or suspected reproductive hazards.”154 Any observed adverse effect (e.g., “known or suspected reproductive hazards”) may serve as a parameter for narrowing this study. In discussing why the Greater Boston Physicians Study chose “known or suspected reproductive hazards” as the toxicological endpoint for purposes of that study, Dr. Gina Solomon stated that “...peOple have traditionally focused on the cancer risks from toxic chemicals.”155 Carcinogenicity as an adverse effect or toxicological endpoint is “traditionally” selected by toxicologists as a parameter for 52 See Pt. II, Ch. 3, See. A for discussion of risk assessment paradigm. See also, EASARETI‘ AND DOULL’S TOXICOLOGY, supra note 80 at 987-988 (discussion of the rinciples of hazard identification and “typical end points”). $3 ‘ Id. “ See PLASTIC IZERS, PESTICIDES, METALS RELEASES PLAYED BY PUBLIC INTEREST ROUPS AS REPRODUCTIVE HAZARDS, 6 PEST.TOX.CHEM.NEWS 4101. ”l 61 narrowing fields of chemicals for study since it is one of the effects “most feared” by the '56 Whether this fear is justified is often brought into question. For example, public. narrowing the field of chemicals to only carcinogens will exclude the chemical that caused the deaths at Bhopal from review in this study. The obvious limitations of taking this approach in this study were considered. It is recognized by the author that the limitations of the study may restrict the application of the results and/or conclusions stated herein outside the four corners of this dissertation. However, as the purpose of this study is not to definitively state the total hazard values or total risk that the TRI data represents, but rather to assess the overall success of the EPCRA in achieving its recognized goals, using a narrow field of chemicals as indicators of that success is appropriate and serves the 157 purposes of this study. Therefore, the toxicological endpoint selected as a parameter for narrowing the field of review in this dissertation is carcinogenicity. 155 Id. ‘56 W. Brock Neely, INTRODUCTION To CHEMICAL EXPOSURE AND RISK ASSESSMENT, 43 (Lewis Publishers, 1994). Regarding the use of carcinogenicity as an adverse effect or toxicological endpoint as a parameter for narrowing fields of chemicals for study, Neely states that: Among the effects of chemicals on biological systems (Chapter 3), one of the most feared is the initiation of cancer. The presence of such chemicals (known as carcinogens) in the environment has become synonymous with environmengl contamination. Id. (emphasis added). 5 7 Narrowing the field of chemicals to only review carcinogens does not completely 1i sregard the concerns of the Congress in enacting the EPCRA. Congress recognized that d dressing Bhopal type releases was not the primary focus of the EPCRA. In testimony efore Congress concerning community right-to-know legislation, Representative Tkorski, focusing on chemical quantity production and estimates of toxic chemical :cidents, indicated that Bhopal-like releases were not perceived as endangering citizens in nerica today. Representative Sikorski states: Those releases and those accidents were not the dramatic Bhopal-like kind of releases. (footnote continued) 62 The definition of a carcinogen varies for numerous reasons.l58 The definition of carcinogen used in this dissertation, is: ...all neoplasm-inducing agents. Chemical carcinogens are defined operationally by their ability to induce neoplasms. Four types of response have generally been accepted as evidence of induction of neoplasms: (1) an increase in the incidence of tumor types that occur in controls; (2) the development of tumors earlier than in controls; (3) the presence of types of tumors not seen in controls; and (4) an increased multiplicity of tumors. ”9 Simply stated, like toxic chemicals in general, all carcinogens are not “equal” in all respects. Even within carcinogens as a smaller subset of toxic chemicals, there is a more finite hierarchy. This hierarchical classification is also based on specific adverse effects observed from exposure to that chemical in clinical tests. Classification of carcinogens within hierarchical systems is performed by various state and federal agencies. However, the categories within each classification system are fairly similar.I60 Again, to maintain a They were others that even more endangered our citizens. Supra note 13. '58 Regarding the definition of carcinogen, CASARETT AND DOULL’S TOXICOLOGY states: The term carcinogen literally means giving rise to carcinomas, i.e., epithelial malignancies. This definition, however, is not adhered to for several reasons. First, the suffix gen implies ab initio genesis, but in fact the responses to a chemical that are accepted as evidence of carcinogenesis include increases in the occurrence of cryptogenic neoplasms. Also, agents that produce sarcomas of mesenchymal origin are generally called carcinogens, although the term sarcomagen or oncogen would be more correct. In practice, carcinogen is used for any agent that induces malignancies. Supra note 80 at 129. 59 Id. 60 Two agencies that provide alternative classification systems for carcinogens are the nternational Agency for Research on Cancer (“IARC”) and the Occupational Safety and [ealth Administration (“OSHA”). As examples of the similarities between the systems: 1e IARC Group 1 and the OSHA Group A agents are carcinogenic to humans; the IARC (footnote continued) run-r 63 reasonable level of manageability, this study only focuses on toxic chemicals recognized in the TRI data as “known or suspect” carcinogens. ‘61 2. Selection of Specific Carcinogens for Analysis The TRI provides data on 78 individual chemicals or groups classified as known or suspect carcinogens.162 Of these 78 individual TRI chemicals or groups, review of RTK- NET files revealed that 28 had no reported releases in Michigan for any reporting year.163 These 28 chemicals were therefore excluded from this study. Chemicals that had any reported releases, even if the releases repOrted were zero, were retained in the study.164 However, four more individual chemicals that had no reported release for the most recent ‘65 Since its inception, the TRI list of six reporting years were deleted from the study. chemicals has been in almost constant flux. Recognition of the changing status of the TRI list has prompted the regulated community to pIOpose that 1997 be used as a new Group 2A and the OSHA Group B agents are probably carcinogenic to humans and the I ARC Group ZB and the OSHA Group C agents are possibly carcinogenic to humans. '61 TRI classification of a specific toxic chemical as a “known or suspect” carcinogen is derived from, and congruent with, various alternative classification systems, including those outlined by the IARC and the OSHA classification schemes. ”2 7R! Releases of Known or Suspect Carcinogens to Air, Water, and Land (1993), supra Iote 149 at tbl. 1—43. See app. B. 53 See app. C. 4 A report of zero releases for a reporting year indicates that a company did submit an PCRA Form R for that chemical for that year, even though the EPCRA does not require is type of action. Reports of zero releases have no impact or effect on the calculations the algorithm or the results of this study. These chemicals were only retained in this dy to facilitate fixture analysis. The four chemicals excluded from the study are 1,4-dichlorobenzene, 1,4-dioxane, ha-napthylarnine, and nitrilotriacetic acid. There have been no reported releases of Ia-napthylamine since 1987, no reported releases of 1,4—dichlorobenzene since 1989; no reported releases of 1,4—dioxane or nitrilotriacetic acid since 1990. 64 baseline.166 This state of flux and proposed new baseline year supports the exclusion of chemicals that show no reported releases in six years. Further, the exclusion of these four chemicals from this study is justified as these chemicals represent only a minor percentage of either the total environmental releases of all known or suspect carcinogens or the total hazard value calculated for all known or suspect carcinogens.167 The remaining 46 specific known or suspect carcinogens are the focus of this study. "’8 The TRI data for the 46 specific carcinogens addressed in this study could be compiled and assessed for any state or on a national level. However, proof of the thesis of this dissertation does not require that such an extensive undertaking be attempted. Therefore, for purposes of manageability, the data for the 46 specific carcinogens analyzed in this study is limited to Michigan specific TRI reports. Limiting the breadth of the study to only Michigan source data insures that the study is narrow enough to maintain its manageability while broad enough to retain its integrity and test the thesis of the dissertation. Further, the TRI data is now available for the years 1987-1994. Therefore, it is possible to compile and assess the TRI data for the 46 specific carcinogens addressed in '66 David J. Hansen, T oxics Release Inventory Report Shows Chemical Emissions Continuing To Fall, CHEMENVNEWS 29 (July 15, 1996). ‘67 The total Mchigan releases for 1,4-dichlorobenzene, 1,4-dioxane, alpha-napthylamine, .nd nitrilotriacetic acid for all reporting years is 39,105 pounds. This represents on 4.57 f 10'2 percent of all environmental releases of known or suspect carcinogens (which were 5,631,328 pounds) during the same period. Further, the calculated THV for 1,4- Chlorobenzene, 1,4-dioxane, alpha-napthylamine, and nitrilotriacetic acid for the same :riod is $597.94 which is only 2% of the calculated THV for all environmental releases ' known or suspect carcinogens (which was 231,990.08) during the same period. Ierefore, exclusion of these chemicals will not dramatically affect the conclusions of this Idy. Id. 65 this study for all eight years of available data. In order to accurately assess the long term, overall success of the EPCRA and the resulting trends, the Michigan TRI source data regarding the 46 specific carcinogens for all eight reporting years will be analyzed in this study. This breadth of review helps to ensure the validity of this study. 3. Compilation of TRI Quantity Data for Specific Carcinogens Not all TRI data available in RTK-NET for each specific carcinogen was needed for this Study. However, selection of the RTK-NET standard format that provided the level of detail necessary to this study also presented a significant amount of detail beyond what was useful. '69 '69 The RTK-NET presents the TRI data in several (Summary, Low, Medium and High) formats, each providing an increased level of detail. A “medium level” of report presentation, which gives a basic summary of all data plus a breakdown of releases by chemical for each facility, was used for this study. An RTK-NET “medium level” presentation of TRI data consists of the following data points: facility id; state; region; facility closure status; facility name; alternative facility name; street; alternative street; city; county; zip; parent corporation; parent (Dun & Bradstreet id); U.S.E.P.A. id; Dun & Bradstreet id; primary SIC; federal facility type; federal agency affiliation; mailing name; mailing street; mailing city; mailing state; mailing zip; alternative mailing name; alternative mailing street; latitude; longitude; reason change; reporting year; public contact name; public contact phone; technical contact name; technical contact phone; control number; reporting year; trade secret; CAS; chemical name; alternative public contact name; alternative public contact phone; mixture composition name; recycling on-site —current year; recycling off-site -current year; energy recovery on-site -current year; energy recovery off-site -current year; treatment on-site - current year; treatment off-site -current year; release off-site -current year; remedial releases; production index; SIC 1; NPDES id 1; NPDES id 2; NPDES id 3; NPDES id 4; NPDES id 5; source reduction activity 1; source reduction activity 2; source reduction activity 3; source reduction activity 4; source reduction activity 5; source reduction activity 6; release 1 (fugitive air); release 2 (stack air); release 3 (water releases); release 4 (underground injection); (footnote continued) 66 An individual on-line search was performed through the RTK-NET for all Michigan data regarding each of the 46 specific carcinogens for each reporting year. This search produced data on a total of 4,627 individual reported releases spanning the reporting years 1987-1994. The TRI data produced by the search was compiled incorporating all the detail presented in an RTK-NET medium detail reporting format. Limited summaries of this TRI data, including only the specific release and transfer data necessary to the study, were compiled for each of the specific carcinogens.170 The limited summaries compiled for and used in this study contained the following data for each release: facility identification; state; facility name; reporting year; total fugitive air releases; total stack air releases; total water releases; total underground injections; total land releases; total transfers to POTWs; total off-site transfers and total environmental releases. m Reformatting the TRI data compiled in the limited summaries into a format that was compatible with the CCPCT System was necessary. Therefore, the limited summary for each specific carcinogen was further refined and re-compiled. The refinement of the limited summaries was accomplished by combining the specific categories of release into release 5 (land releases); release 6 (transfers to POTWS); release 7 (off-site transfers); total releases; source reduction code; waste generated -previous year; waste generated -current year; all waste generated; SIC all (12 possible); all chemical id; TRI code change translation; SIC translation; maximum amount TRI submission. ’z/pra note 69. '0 Compilation of this data, even in this abridged form, is voluminous and is therefore not rovided as an appendix to this study. ' The eight individual data points regarding the specific type of release (i.e., specific edia or release endpoint) were compiled for each of the 4,627 individual TRI chemical )orts resulting in a total of 37,016 individual data points. These 37,016 data points ve as the primary data for this study and were incorporated into this dissertation. 67 the more general and more apprOpriate categories of release. The narrow categories of total fugitive air releases and total stack air releases were combined into the general category of “air releases;” the general categories of total water releases, total underground injections and total land releases were combined into the general category of “water releases;” and the general category of “total releases” was created by subtracting the total transfers to POTWS and the total off-site transfers from the total environmental releases.172 The air releases, water releases and total releases for each of the 46 specific chemicals in each reporting year were then re-compiled in a CCPCT System compatible format for use in this study. This re—compiled and reformatted data is presented, infra, in Tables 4-49.173 ‘72 This re—categorization of releases into broader or more general categories is similar to the approach taken in the CCPCT Study. The CCPCT Study stated: To determine the release amount assigned to air and water categories, the following scheme was applied to the release data. It was assumed that: o stack and fiigitive releases went to air; 0 land, injection, water and POTW release went to water; 0 annual pesticide usage amounts were assigned to the water release category; 0 off-site transfers to an incineration facility were assumed to be destroyed and transfers to a recycling facility were assumed reused and therefore not released to the environment; and 0 all other off-site transfers (land, injection, etc.) were assumed released to water. Incineration and recycling amounts were subtracted from total off-site transfers to determine the remainder of off-site transfers released to water. Supra note 99, at 24. ‘73 See app. D. CHAPTER FIVE HAZARD VALUE SCORING METHOD A) Adaptation of CCPCT Study Algorithm to Michigan Specific Data Limited modification of the algorithm proposed in the CCPCT System is necessary to accommodate the Michigan specific data used in this Study. The hazard values presented in the CCPCT Study, with the exception of estimates used for missing data, are appropriate for use in this study Also, the release weighting factors used in the CCPCT Study are appropriate, however they require modification. The modifications are discussed below. 1. Hazard Values (HVs) The hazard values presented in the CCPCT System, calculated using various toxicological endpoints and exposure assessments including human health effects, environmental effects and exposure factors, are appropriate for use in this study and generally do not require modification. m ”4 Human health effects include acute oral and inhalation toxicity, carcinogenicity, and other specific effects. Environmental effects include acute mammal and fish mortality and chronic sublethal effects in fish. Potential exposure parameters include persistence and bioaccumulation. These factors include: Oral Hazard Value (Oral HV) Inhalation Hazard Value (Inhalation HV) Carcinogenic Hazard Value (Carc. HV) Other Hazard Value (Other HV) Fish Hazard Value (Fish HV) Fish NOEL Hazard Value (Fish NOEL HV) Biological Oxygen Demand Hazard Value (BOD HV) Hydrolysis Hazard Value (Hydrolysis HV) Bioconcentration Factor Hazard Value (BCF HV) Id p. 44. The specific hazard values are provided in the CCPCT Study. Id, app. C, RANKING RESULTS: HORIZONTAL TABLES. (footnote continued) 68 69 In addressing missing data, the CCPCT Study assigned minimum and maximum hazard values.175 This approach provided a hazard range, based on the assigned hazard values, which allowed for a comparison of the chemicals addressed in the CCPCT Study. It is not disputed that the relative hazard presented by individual chemicals within any discreet class of chemicals may be represented by a range. Further, as the CCPCT Study addressed a broad array Of chemicals, which may present a wide spectrum of relative hazard, this approach may have been valid in that application. In a manner similar to the CCPCT Study, a range of hazard values might have been assigned to the toxicological endpoints and exposure assessments which lacked supporting data in this Study. However, this study only focuses on chemicals that are known or suspect carcinogens. This study assumes that, relative to all EPCRA chemicals, the known or suspect carcinogens addressed herein are the most potent toxics and therefore present the highest level of inherent hazardm’ The potency of, or inherent hazard presented by, known or suspect carcinogens suggests that the use of a range of hazard values is not necessary and may be misleading. Therefore, this study assigns maximum hazard values when necessary . . . 7 data 15 missrng.17 In this study, as in the CCPCT System, Oral HV, Inhalation HV, Carc. HV, Other HV, Fish HV and Fish NOEL HV were assigned a hazard value between zero and five and treated as additive effects while BOD HV, Hydrolysis HV and BCF HV were assigned hazard values between one and two and one-half and treated as multiplicative factors. See id, app. C. ”5 Id See supra, note 118. 176 This assumption disregards any type of quantity or exposure data (e. g., acute exposures such as occurred at Bhopal). ”7 An assumed hazard value of 5 is assigned to the Oral HV, Inhalation HV, Carc. HV, Other HV, Fish HV, and Fish NOEL HV if data is missing for those calculations. A hazard value of 2.5 is assigned to BOD HV, Hydrolysis HV and BCF HV if data is (footnote continued) 70 2. Release Weighting Factors (RWFS) The CCPCT System algorithm incorporated RWFs to ensure that neither hazard values nor release amounts dominated the calculations. '78 The CCPCT System scheme for weighting releases incorporated the use of the natural log in the RWF.179 The RWF scheme in the CCPCT System provided for calculation of a cutoff point for releases of 60,000 pounds by subtracting ten from the natural log of the releases.180 However, since one objective of this study is to assess total hazard by analyzing all releases of each of 46 specific carcinogens in all reporting years, a cutoff point for releases of 60,000 pounds or assigning a weighted hazard value of zero or below (i. e., a negative number) to any release is not appropriate. ‘8' The method of calculating the RWF in the CCPCT System is easily adapted to the purposes of this study. Using the natural log of the release and not adjusting the calculation by subtracting ten will provide an analysis of all releases without producing hazard values that are either zero or less or dominated by the release quantity.182 The “*n missing for those calculations. Chemicals with missing data are denoted by an in the appropriate appendix. Infra, app. E. To test the sensitivity of this analysis scheme, a second series of calculations were performed assigning a hazard value of 2 to the Oral HV, Inhalation HV, Carc. HV, Other HV, Fish HV, and Fish NOEL HV and a hazard value of l to BOD HV, Hydrolysis HV and BCF HV if data is missing for those values. ”8 See supra notes 107-112 and accompanying text. 179 I d '80 See supra note 110 and accompanying text 18‘ Applying the CCPCT System approach in calculating RWFs for releases less than 22,026 pounds would result in a weighted hazard value below zero (i.e., a negative number) which is clearly not appropriate in either the CCPCT Study or this study. ’82 While not incorporating a weighting scheme for releases will result in a risk assessment that is driven solely by release quantities, incorporating a weighting scheme may also contain limitations. For example, if the natural log is used to weight releases, a one hundred percent increase in release quantity will not result in a one hundred percent (footnote continued) 71 Release Weighting Factor Equation can be applied to values that are specific to a particular media. Figure 4, below, shows the general method of calculating the RWF used in this study to evaluate Michigan releases of specific carcinogens. RWF = In release Figure 4. Release Weighting Factor Equation TRI data for lead releases illustrates the use of the modified Release Weighting Factor Equation in the dissertation. '83 Individual releases of lead to all media in Michigan in 1987 reported under the EPCRA were compiled. These data were totaled by category (“Air Releases,” “Water Releases” and “Total Releases”) and recompiled. 184 Air Releases of lead in 1987 were reported to be 20,719 pounds; Water Releases were reported to be 1,303 pounds; and Total Releases were calculated to be 22,022 pounds. ‘85 The RWFs derived by applying the modified Release Weighting Factor Equation to the reported release values are provided in Figure 5 on the following page. increase in risk (e.g., if a specific reported release increases from 100 pounds to 200 pounds, the calculated RWF, incorporating the natural log, will only increase from 4.61 to 5.3). ’83 Any toxic chemical addressed in this study may be selected to illustrate the calculations made using the modified CCPCT algorithm. Lead was selected at random. ‘84 See supra note 172 and accompanying text. '85 See infra tbl. 34, app. D. 72 RWF.-.....- (lead) = In (1,303) = 7.17 RWFair (lead) = In (20,719) = 9.94 RWF.,,.,,l (lead) = In (22,022) = 10.00 Figure 5. 1987 Release Weighting Factors for Lead RWFs for each general category of release were calculated, as illustrated using lead as an example, for each of the 46 specific carcinogens addressed in this study. Total Releases of carcinogens in Michigan addressed in this study ranged between zero and 10,633,270 pounds. Therefore, the use of the modified Release Weighting Factor Equation resulted in RWFS ranging between zero and 16.18 in this study. This range is appropriate for the purposes of this Study. B) Compilation of Hazard Value Data and Michigan TRI Quantity Data for Specific Carcinogens Total Michigan Water Releases, Total Michigan Air Releases and Total Michigan Releases for each of the 46 specific carcinogens addressed in this study were compiled for ‘86 Further, based on the above revisions to the CCPCT System, the each reporting year. appropriate hazard values for the 46 carcinogens addressed in this study release were compiled for each reporting year. Also, the RWFs for each general category of release were calculated, as illustrated above, for each of the 46 specific carcinogens addressed in this study compiled for each reporting year. These data are combined and presented in Tables 50-57 for further analysis. ‘87 ‘86 See supra note 149 and accompanying text. ‘87 See app. E. 73 C) Appligttion ofModified Haaard Value Scoring Method to Specific Carcingens The CCPCT System algorithm is applied to the Michigan release data for each individual release of the 46 specific carcinogens and each reporting year addressed in this study. The application of the algorithm integrated the RWFs adapted to the Michigan specific data and the modified CCPCT System hazard values. As stated, supra, the CCPCT System algorithm utilizes an algorithm that equates the THV of a specific chemical with the sum of the human health effects (HHE) and environmental effects (EE) multiplied by the exposure potential factor (EF). Each component of the CCPCT algorithm, as it is used in this study, is described below. 1. Weighted Human Health Effects (WHHE) Figure 6, below, Shows the Weighted Human Health Effects (WHHE) equation used in this study. The WHHE is used to estimate the human health effects resulting from . . . . 8 Michigan releases of specrfic carcrnogens.18 WHHE = (Oral HV)*(RWmer) + (Inhalation HV)*(RWF.i,) + (Carc. HV + Other HV) * (RWme) where: RWF.”:er = Release Weighting Factor for Water Releases RWF," = Release Weighting Factor for Air Releases RWme = Release Weighting Factor for Total Releases Figure 6. WHHE Equation/89 '88 This estimate does not include exposure data. 74 The 1987 Michigan data compiled for lead illustrates the use of the WHHE Equation in this study. The RWFS for water, air and total lead releases, supra Figure 5, are 7.17, 9.94 and 10.00 respectively. The Oral Hazard Value, Inhalation Hazard Value, Carcinogenic Hazard Value and Other Hazard Value variables in the WHHE Equation are derived and presented in the CCPCT Study and are appropriate for use in this study. ‘90 Hazard values for lead required in the WHHE Equation are presented below in Figure 7. Oral Hazard Value (lead) = Oral HV (lead) = 0.9 Inhalation Hazard Value (lead) = Inhalation HV (lead) = 5.0 Carcinogenic Hazard Value (lead) = Carcinogenic HV (lead) = 3.5 Other Hazard Value (lead) = Other HV (lead) = 4.0 Figure 7. Human Health Hazard Values for Lead These Human Health Hazard Values for lead along with the 1987 Michigan RWFs for lead are incorporated into the WHHE Equation to derive a 1987 Michigan lead WHHE of131.15 in Figure 8 below. ‘91 WHHE (lead) = [(0.9)*(7.17)]+[(5.0)*(9.94)]+[(3.5+4.0)*(10.00)] = 131.15 Figure 8. 1987 WHHE Calculation for Lead '89 The WHHE equation is the same as that used in the CCPCT System, however the underlying data (i.e., the hazard values and the RWFs) have been modified. See supra note 99, app. A, at A-25. ’90 See supra note 174 and accompanying text. See also app. E. '9‘ All “effects” and other “hazard” values in this study are unitless. 75 2. Weighted Environmental Effects (WEE) Figure 9, below, Shows the Weighted Environmental Effects (WEE) equation used in this study. The WEE is used to estimate the environmental effects resulting from the . . . . 9 Michigan releases of specrfic carcrnogens.l 2 WEE = (Oral HV + Fish HV + Fish NOEL HV)*(RWFW.¢.,) where: RWF-me, = Release Weighting Factor for Water Releases Figure 9. WEE Equation1 93 The 1987 Michigan data compiled for lead illustrates the use of the WEE Equation in this study. The RWF for lead releases to water in Michigan, supra Figure 5, is 7.17. The Oral Hazard Value, Fish Hazard Value and Fish NOEL Hazard Value variables in the WEE Equation are derived and presented in the CCPCT Study and are appropriate for use 194 in this study. The hazard values for lead required in the WEE Equation are presented below in Figure 10. Oral Hazard Value (lead) = Oral HV (lead) = 0.9 Fish Hazard Value (lead) = Fish HV (lead) = 3.8 Fish NOEL Hazard Value (lead) = Fish NOEL HV (lead) = 4.3 Figure 10. Environmental Hazard Values for Lead ‘92 Supra note 188. 193 The WEE equation is the same as that used in the CCPCT System, however the underlying data (i.e. the hazard values and the RWFs) have been modified. See supra note 99, app. A, at A-25. 194 See supra note 174 and accompanying text. See also app. E. 76 In Figure 11, below, the Environmental Hazard Values for lead along with the 1987 RWF for water releases of lead in Michigan are incorporated into the WEB Equation to derive a 1987 Michigan lead WEE of 64.53. WEE (lead) = [(0.9) + (3.8) + (4.3)] * (7.17) = 64.53 Figure 11. I 98 7 WEE (.‘alculation for Lead 3. Exposure Factor (EF) This study uses the equation proposed in the CCPCT System to calculate the Exposure Factor (EF). That equation, as proposed in the CCPCT System and without unique weighting or filrther adaptation of the variables therein is shown below in Figure 12. EF = BOD HV + Hydrolysis HV + BCF HV Figure 12. EF Equation)” The Michigan data compiled for lead illustrates the calculation of the EF in this study. The Biological Oxygen Demand Hazard Value, Hydrolysis Hazard Value and the Bioconcentration Factor Hazard Value variables in the EF Equation are derived and ‘95 Id. See I he CC PC T Algorithm, supra note 122, fig. 3. 77 presented in the CCPCT Study and are appropriate for use in this study.196 The hazard values for lead required in the EF Equation are presented below in Figure 13. Biological Oxygen Demand Hazard Value (lead) = BOD HV (lead) = 2.5 Hydrolysis Hazard Value (lead) = Hydrolysis HV (lead) = 2.5 Bioconcentration Factor Hazard Value (lead) = BCF HV (lead) = 1.39 Figure 13. Exposure Potential Hazard Values for Lead These Exposure Potential Hazard Values for lead are incorporated into the EF Equation to derive a EF for lead of 6.39 in Figure 14 below. EF (lead) = (2.5) + (2.5) + (1.39) = 6.39 Figure 14. EF Calculation for Lead 4. Total Hazard Value (THV) The equations for WHHE, WEE and EF, supra, provide the basis for calculating the relative total hazard value (THV) presented by each of the 46 specific carcinogens addressed in this study. ‘96 See supra note 174 and accompanying text. See also app. E. 78 This study uses the equation proposed in the CCPCT System to calculate the THV. That equation, as proposed in the CCPCT System and without unique weighting or fidrther adaptation of the variables therein is shown below in Figure 15. THV = (WHHE + WEE) * EF Figure 15. T H V Equation] 97 The 1987 Michigan data compiled for lead illustrates the calculation of the THV in this study. The WHHE, WEE and the EF variables calculated, supra, for the 1987 Michigan releases of lead and required in the THV Equation are presented below in Figure I 6 - WHHE (lead) = 131.15 WEE (lead) = 64.53 EF (lead) = 6.39 R Figure 16. Algorithm Variablesfor Lead These values for lead are incorporated into the THV Equation to derive a 1987 Michigan THV for lead of approximately 1,250.40 in Figure 17 below. THV (lead) = ((131.15) + (64.53)] * (6.39) = 1,250.40 Figlne 17. 77-] V Calculation for Lead \ 197 See supra note 189. 79 D) C_o_n_1p_ilation of Total Releases and THVs The adapted CCPCT System algorithm is applied to the Michigan specific primary chemical data and hazard values compiled in Appendix E, Tables 50-57. The WHHE, WEE, EF and THV for the Michigan releases of each of the 46 specific carcinogens are calculated in each reporting year, the values compiled and presented in Tables 58-65.198 The sum of the Total Michigan Releases for all 46 specific carcinogens, as compiled and presented in Appendix E, were re-compiled for each reporting year addressed in this study. The sum of the THVs for all 46 specific carcinogens, as compiled and presented in Appendix F, were re-compiled for each reporting year addressed in this study. Further, total releases of all chemicals reported under the EPC RA were compiled and totaled for each reporting year addressed in this study. '99 These data are re-compiled in Table 66 on the following page. ‘ i: See app. F. These data, referred to as “Total TRI Releases,” were compiled directly through on- line computer sources. None of the values were manipulated after being compiled. See Sapra note 99. 80 T_ab_le_fi - Total Releases and Hazard Values for All Reporting Years200 year TOTAL TRI TOTAL TOTAL HAZARD RELEASES RELEASES or VALUE FOR (in pounds)201 CARCINOGENS CARCINOGENS (in pounds)202 203 1987 174,884,325 16,009,348 25,108 1988 1 14,433,091 13,704,405 23,200 1989 123,076,468 20,625,808 27,190 1990 102,362,394 9,677,906 26,492 1991 93,934,593 8,583,453 26,257 1992 84,820,383 5,798,956 24,596 1993 81,637,986 5,477,251 26,245 1994 82,620,035 5,715,096 26,285 200 All data contained in this table are Michigan Specific. 20‘ This column contains the total sum reported under the EPCRA for each reporting year, in pounds, of all toxic chemicals released to all media. 202 This column contains the total sum reported under the EPCRA for each reporting year, in pounds, of the 46 specific carcinogens addressed in this study released to all media. 203 The Total Hazard Values listed in this column are unitless. Using the low end HV assumption for purposes of comparison, a second series of calculations were performed. See supra note 177. The data produced through these calculations are presented in Table 67 below. Table 67 - Total Hazard Values for All Reporting Years (Minimum HV) year TOTAL HAZARD VALUE FOR CARCINOGENS (low range HV) 1987 21,851 1988 20,744 1989 22,218 1990 23,188 1991 22,659 1992 21,320 1993 22,019 1994 22,053 flirt—IX. DATA ANALYSIS AND CONCLUSIONS 81 CHAPTER SIX ANALYSIS OF MICHIGAN TRI DATA A) Comparison of Michigan TRI Quantity Data (Quantity Analysis) and Computed Michigan Hazard Value Data (“Risk”) for Specific Carcinogens 1. Total TRI Releases The inclusion of Total TRI Releases in Table 66 serves two purposes. First, these data illustrate that there is an overall decrease in the total quantity of TRI chemicals released into the environment. These data are presented to the general public by proponents of the reporting requirements of the EPCRA (e. g., the U.S.E.P.A.) to Show the “success” of the EPCRA concerning the decrease in total releases of TRI chemicals.204 This “success” and the misleading nature of the presentation of these data to the general public in this format is one focus of this study. Second, these data are included in Table 66 to support the accuracy of the data collection in this study. A numerical analysis of these data shows a 52.76 per cent decrease in total releases of all TRI chemicals reported in the State of Michigan under the EPCRA. Using 1988 as the baseline year for purposes of analysis, in accord with U.S.E.P.A. practices,205 the data presented in Table 66 shows a 27.80 per cent decrease in total releases of all TRI chemicals reported in Michigan under the EPCRA.206 The 1993 Annual TRI Report issued by the U.S.E.P.A. states that the 204 See supra note 166. 205 The U.S.E.P.A. selected to use 1988 as the baseline year due to the problems inherent in industry “estimating” releases. See Chapter 1(D), TRI Conceptual Framework and Structure. The Introduction of the 1993 Annual TRI Report states: “Although the first data were collected for calendar year 1987, 1988 has been selected as the baseline year because of concerns about the data quality of industry’s first year submissions.” Supra note 149. This study uses 1987 as the baseline year unless otherwise noted. Id 206 Supra note 149 at tbl. 3-4. 82 83 decrease in total releases in Michigan for all TRI chemicals between reporting years 1988 and 1993 is 27.50 per cent.207 As the decrease in total releases in Michigan for all TRI chemicals determined in this study is effectively the same as the value presented to the public by the U.S.E.P.A., it is reasonable to assume that the method of data collection and the resulting data set used in this study were appropriate. The graphical representation of the data presented in Table 66 for Total TRI Releases is provided below in Figure 18. 1 1 ToTALTRIRurAsrs 1 ' 1 I 1 1 . E 1 1 ea 1 z > 1 I 5°- 1 1 73‘ g 1 1 “ é ‘ 1 1 1 _ 1 ‘ 8 1 v 1 ‘ 1987 1988 1989 1990 1991 1992 1993 1994 1 Reporting Year [_ -L 1 Figure 18. Total TRI Releases 207 The 3/10 of one percent discrepancy in these values is not significant. However, the data provided in Table 3-4 is qualified as “not including data for aluminum oxide, delisted chemicals, or chemicals added in 1990 and 1991” which accounts for the discrepancy. Id 84 2. Total Releases of Carcinogens The graphical representation of the data presented in Table 66 for Total Releases of Carcinogens is provided below in Figure 19. TOTAL RELASIS 0F CARCINOGI'NS 1987 1988 1989 1990 1992 1992 1993 1994 Reporting Year Figure 19. Total Releases of Carcinogens Analysis of the data presented in Table 66 and Figure 19 regarding the Total Releases of Carcinogens shows a 64.30 per cent decrease in these specific releases reported in Michigan under the EPCRA. Again using 1988 as the baseline year for purposes of analysis, Table 66 shows a 58.30 per cent decrease in Total Releases of Carcinogens reported in Michigan. As the percentage decrease in the Total Releases of Carcinogens is greater than the percentage decrease in Total TRI Releases, Table 66 and Figure 19 suggest that efforts to decrease the releases of individual toxic chemicals are directed appropriately. 85 3. Total Hazard Values Graphical representation of the Total Hazard Value data for carcinogens presented in Table 66 is provided below in Figure 20. 208 1__Th '7 —~ -"”_ _7 1 TOTAL HAZARD VALUE FOR CARCINOGE‘IS 1 27.50 2700 - 26.50 26.00 25.50 25.00 4 24.50 J- 2400 . 23.50 . 1 23.00 4 L . . 1 1987 1988 1989 1990 1991 1992 1993 1994 i (In thousands) Total Heard Value Reporting Year I1 Figure 20. Total Hazard Values for Carcinogens 2"“ Using the low end HV assumption for purposes of comparison, the graphical representation of the Total Hazard Value data for carcinogens, in contrast to the data presented in Table 66 and Figure 20, is provided below in Figure 21. See supra note 177. 1 TOTAL HAZARD VALUES FOR CARCINOGIINS i (high and low range HV) 1 28.00 .. 23.50 ‘ I: A2700 .3 23.00 1 h '1 .‘ a 3 E 26.00 -- 22.50 1523 i ._ .12200 - F = 25.00 - 1 e ' 5 . 2150 G - ‘- - §— § 24.00 4» .. 2100 23.00 29.50 1987 1988 1989 1990 1991 1992 i993 1994 Reporting Year : High Rahge Assumed HV _L0wRanger-Assumed HV ‘ Figure 21 . Total Hazard Values for Carcinogens (high and low range H10 86 Analysis of the Total Hazard Value data for carcinogens presented in Table 66 and Figure 20 does not show a decrease similar to those observed for Total TRI Releases or Total Releases of Carcinogens. Conversely, analysis of these data show a 4.69 per cent We in the Total Hazard Values for carcinogens reported in Michigan under the EPCRA. Again using 1988 as the baseline year for purposes of analysis, Table 66 shows a 13.30 percent m in Total Hazard Values for Carcinogens reported in Michigan under the EPCRA.209 4. Compilation and Comparison of All Data To facilitate analysis, the observed numerical changes in reported releases and calculated hazard values addressed in this study and discussed in the previous section are calculated and compiled below in Table 68. M - Observed Numerical Changes in Releases210 TOTAL TRI TOTAL TOTAL HAZARD RELEASES RELEASES OF VALUE FOR (in pounds) CARCINOGENS CARCINOGENS (in pounds) Overall Numerical Change 52.76% 64.30% 4.69% (1987 baseline) decrease decrease increase Overall Numerical Change 27.80% 58.30% 13.300/0 (1988 baseline) decrease decrease increase 209 See infia Table 68. Using the low end HV assumption for purposes of comparison, supra note 177, a 1 percent increase in the Total Hazard Values for carcinogens reported in Michigan under the EPCRA using 1987 as the baseline year and a 5.94 percent increase in Total Hazard Values for Carcinogens reported in Michigan using 1988 as the baseline. 21° All data contained in this table is Michigan specific. 87 Table 68 suggests that some relationship between overall decreases in Total TRI Releases and Total Releases of Carcinogens exists. However, Table 68 does not suggest any correlation between the decrease in total releases (“quantity”) and a decrease in total hazard values (“risk”) for carcinogens in Michigan}211 The decrease in both the Total TRI Releases and the Total Releases of Carcinogens shown in Table 66 suggests that efforts to decrease the release of individual toxic chemicals may be directed appropriately. However, the increase in the Total Hazard Values for Carcinogens reported in Michigan suggests that this conclusion is specious. Graphical representation of the Total Releases of Carcinogens and the Total Hazard Values for Carcinogens data provided in Table 66 is provided in Figure 22 on the following page. As suggested by the data presented in Table 68, Figure 22 illustrates that while Total Releases of Carcinogens appear to decrease between the reporting years of 1987 through 1994 there is Q9 corresponding decrease in the Total Hazard Values for Carcinogens observed in the same reporting years. To the contrary, the numerical data analysis indicates an increase in the Total Hazard Values for Carcinogens occurring in the same reporting period. This analysis is supported by the graph in Figure 22 on the following page.212 2” Based on the data presented in Table 68, it could be inferred that an inverse relationship between quantity and risk exists. 2'2 Using the low end HV assumption for purposes of comparison, the graphical representation of the Total Hazard Value data for carcinogens, in contrast to the data presented in Table 66 and Figure 22, is provided in Figure 23 on the following page. See supra note 177. (fimtnote continued) 88 Comparison onuantity and "Risk" 1987 1988 1989 1990 1991 1992 1993 Reporting Year l 994 lTolal Releases ofCarcinogens (in millions of poiinds) .Total Hazard Values for Carcinogens (in thousands) Figure 22. Comparison of Quantity and “Risk” As suggested by the data presented in Tables 66 and 68, Figure 22 suggests that there is no correlation between the decrease in total releases (“quantity”) and a decrease in total hazard values (“risk”) for carcinogens on Michigan. i Comrison dQuantity and "Risk" (high Jr low range HV) 1 7 _ 1987 1988 l989 1990 I991 1992 1993 Reporting Year llTotal Releases of Carcinogens (in millions of pounds) iITotal Hazard Values for Carcinogens (high HV'; in thousands) ‘lTotal Hazard Values for Carcinogens (lowllV; in thousands) ‘ Figure 23. Comparison of Quantity and “Risk" (high and low range H10 89 B) Statistical Analysis of Quantity and “Risk” for TRI Dat_a Statistical concepts and methods can be used to determine the nature of the relationship between variables. The linear regression is a method for finding the straight line that best fits the observed data (the “best fit line”). A linear regression analysis can be performed to detemtine how a single dependent variable is affected by a second, independent variable.213 How closely the observed data is “scattered” around the best fit line is used to determine the association between the two variables. A large amount of scatter about the best fit line indicates a weak association between the two variables. Conversely, a small amount of scatter about the best fit line indicates a strong association between the two variables.214 Using statistics, the “numerical measure of [the relationship between the observed data scattered about the best fit line] is called the sample correlation coefficient or, sometimes. Pearson’s product moment correlation coe ficient.”215 1. Linear Regression Analysis and the Correlation Coefficient A second, separate analysis of the Michigan TRI data addressed in this study was performed using a linear regression analysis. Using the values presented in Table 66, supra, the Total Releases of Carcinogens were used as independent variables and the 2‘3 Gouri K. Bhattacharyya & Richard A. Johnson, STATISTICAL CONCEPTS AND METHODS 334 (John Wiley & Sons, 1977), states: Regression analysis is a body of statistical methods dealing with the formulation of mathematical models that depict relationships among variables, and the use of these modeled relationships for the purpose of prediction and other statistical inferences. Id. 2” Id. at 402. 215 Id. 90 Total Hazard Values for Carcinogens were used as dependent variables.216 These variables and the resulting line plot produced by the regression analysis are presented in Figure 24 below. ”-50 ‘ T ~. »- f“- TT “ I ' ; . 26.00 1 25.00 0 I 24.50 8 . ~ .. - — i 24.000_ii'7j.»-:;‘ifl’ _ ,. ,, . ». _ . . l 23.50 1 5.00 7.00 9.00 11.00 13.00 15.00 17.00 19.00 21.00 I l 1 [DWARREGMBSKWUUVUHSB l l Total Hazard Values for Carcinogens (in thousands) Total Releases of Carcinogens (in millions of pounds) .'.__.._‘ l 0 Observed Data Points +Predictcd Best Fit Linej ;.__.___-L__z-_, _.___. _L . ___ ..__.2- __ 2.__.__ _ __L ____-L._-_-. ELL _ __ _ ____ Figure 24. Linear Regression Analysis Using the data derived from the linear regression analysis presented in Figure 24, the sample correlation coefficient (r) was calculated. An r value of 0.04 was derived for the specific data presented in this dissertation regarding Total Hazard Values and Total 216 The Total Releases of Carcinogens presented in Table 66 are not classic examples of independent variables (i.e., they were not set by the author). However, due to the nature of the variables, the Total Releases of Carcinogens may be considered to be an independent variable. For example, in addressing “what to do if the predictor variable can not be controlled by the experimenter,” Bhattacharyya & Johnson state: as long as x is viewed as the causal variable that influences y and the objective of sampling is to make predictions about y from the value of x, the operational steps of analysis are the same . . . . Bhattacharyya & Johnson, supra note 213, at 357. 91 Releases of Carcinogens. Again, using 1988 as the baseline year for purposes of analysis, an r value of O. 11 was derived for the same data.217 2. Analysis of the Correlation Coefficient The value of r has a range of -l S r S 1. An r value equal to or near either -1 or 1 indicates a strong correlation between the variables being tested. Conversely, an r value equal to or near 0 indicates a weak correlation between the variables being tested. An r value of 0.04, as derived above, indicates that only a weak correlation, if any, exists between Total Releases of Carcinogens and the Total Hazard Values for Carcinogens. If the baseline year of 1988 and the resulting r value of O. 11 is used, the correlation between Total Releases of Carcinogens and the Total Hazard Values for Carcinogens, if any, is also weak. C) Summary The numerical, graphical and statistical analyses of the Total Releases of Carcinogens and the Total Hazard Values for Carcinogens data in Michigan presented in this chapter support two propositions. First, the data clearly shows a decrease in Total TRI Releases, a decrease in Total Releases of Known or Suspect Carcinogens and an increase in Total Hazard Values for \ 217 Using the low end HV assumption for purposes of comparison, an r value of -0.07 was deriVed for the specific TRI data presented in this dissertation regarding Total Hazard VaIUes and Total Releases of Carcinogens using 1987 as the baseline year and an r value 0f ~0.04 was derived for the same data using 1988 as the baseline year. See supra note 177. These derived r values also indicate that only a weak correlation, if any, exists between Total Releases of Carcinogens and the Total Hazard Values for Carcinogens. 92 Known or Suspect Carcinogens reported under the EPCRA, in Michigan, between 1987 and 1994. Second, the correlation, if any, between the decrease in Total Releases of Known or Suspect Carcinogens (“quantity”) and the decrease in Total Hazard Values for Known or Suspect Carcinogens (“risk”) is weak. CHAPTER SEVEN CONCLUSIONS AND RECOMMENDATIONS A) Conclusions One recognized goal of the US. Congress in implementing the EPCRA was to improve the relative safety of the population by decreasing the risks posed by the presence of toxic chemicals in industrial processes. The Congress chose to achieve this goal by imposing reporting requirements on industry that would provide an incentive to reduce the amounts of toxic chemicals stored or discharged into the environment. Based on a glossary analysis of the TRI data as it is currently presented, it is commonly recognized that the reporting requirements of the EPCRA have achieved the intermediate goal of reducing the amounts of toxic chemicals stored or discharged into the environment. The success of the EPCRA in achieving this intermediate goal may be a reasonable conclusion. However, it is not possible to extrapolate this analysis to support the proposition that the reporting requirements of the EPCRA have achieved the higher, recognized goal of decreasing the risks posed by the presence of toxic chemicals. The analysis of the TRI data simply does not support this proposition. The analysis of Michigan specific TRI data performed in this dissertation suggests that the EPCRA has n_ot_ achieved the recognized goal of decreasing risk by reducing the amount of toxic chemicals stored or discharged into the environment in Michigan. To the contrary, the analysis performed in this dissertation suggests that the reduction of total toxic chemicals without attention to individual reductions of specific toxic chemicals resulted in an overall increase in risk. At a minimum, analysis of these data generally 93 94 indicates that there is no correlation between reducing the amount of toxic chemicals stored or discharged into the environment (“quantity”) and decreasing risk (“risk”) in Michigan. The thesis of this dissertation is that TRI toxic chemical data reported in compliance with the EPCRA does not demonstrate an improvement in the form of decreased risks posed by the presence of toxic chemicals in Michigan. The analysis performed supports this thesis. Further, the analysis of select carcinogens in Michigan using a algorithm modified for hazard valuation indicates a significant misallocation of resources in the effort to improve the relative safety of the population by reducing the amounts of toxic chemicals stored or discharged into the environment by industry. The dissertation also suggests that presentation and evaluation of the TRI toxic chemical data reported in compliance with the EPCRA, using total quantity as the only analysis parameter, is inappropriate and misleading. Presentation of these data in this one dimensional format does not provide the information necessary to evaluate the success of the EPCRA and it generally limits the ability of the end user (e. g., the average citizen or other stakeholder) to perform an accurate assessment of the EPCRA data and the potential risks presented by the TRI chemicals. Examples of the deficiencies of the TRI data presentation are as follows: 1) First, presentation of the TRI data in the format currently used does not allow the average citizen to determine which geographic area is most affected by toxic chemicals. Lacking an analysis based on region TRI reports, the EPCRA is not useful to 95 the average citizen in determining individual exposures or resulting risk. Even the data as presented in this dissertation does not include a regional analysis. 2) Second, presentation of the TR] data in the format currently used does not allow the end user to determine whether a specific industry classification presents the most risk due to toxic chemical storage and release. It is possible that one specific class of industry is responsible for storage and/or release of the majority of TRI chemical quantities, thereby driving the observed total risk. More narrowly, presentation of the TRI data in the format currently used does not allow the end user to make a similar determination concerning a specific company or companies which may be responsible for driving the overall observed risk. 3) Third, presentation of the TRI data in the format currently used does not indicate which specific toxic chemicals represent the highest degree of risk. For example, the data presented in this dissertation does not indicate which specific carcinogens are responsible for the observed increase in overall risk presented by the group of carcinogens. It is possible, and in fact likely, that the more potent carcinogens are driving the observed increase in total risk. Without the increased level of detail and heightened analysis described above, it is impossible to appropriately allocate resources toward reducing the amount of the specific toxic chemicals, stored or discharged into the environment, that would efficiently advance the recognized goal of decreasing risk.218 If the EPCRA is to be used efficiently by the 213 It is important to note that this “increased level of detail” currently exists. Form R provides the level of detail that would allow for a “heightened analysis” of the TRI data. See note 59 and Form R, Appendix A. See also note 169. 96 public as a tool for understanding the risks to which they are exposed, so that some action to decrease those risks may be taken (e. g., exertion of pressure upon government and industry), that action should be directed toward the specific toxic chemicals, entities and geographic areas which present the most significant overall risk. B) Recommendations for Future Research 1. Study Containing More Complete Detail All Michigan TRI data available on-line for every chemical in every reporting year should be compiled at the highest level of detail available. The algorithm used as an analysis tool in this dissertation should then be applied to each of these releases to generate a usefirl set of analysis parameters. These parameters should be used to reasonably assess the various successes or failures of the EPCRA (e.g., the decrease of risk through the reduction of total quantity of toxic chemicals stored or discharged into the environment) in Michigan. This study was limited to the analysis of carcinogens which restricts the application of the results and/or conclusions stated herein outside the four corners of this dissertation. Recognizing this limitation, future research should be broadened to include all TRI chemicals. Further, future research should narrow the focus of analysis to specific categories. Future studies should incorporate parameters that serve to narrow chemical classifications so that the direct correlation, if any, can be determined between specific TRI chemicals or groups and specific environmental effects. For example, at a minimum, TRI chemical data should be analyzed in future studies using chemical type, total chemical 97 volumes or chemical structure; industrial classification of the reporting industry; specific companies; and specific media. Limiting the scope of review to only include carcinogens in Michigan was useful for the purposes of this dissertation, broad application of the conclusions reached in this study can only be accomplished afier fiiture research that incorporates more complete detail. 2. Focusing on Local Areas of Concerns If done properly, the TR] data as compiled could be a USCfiJl tool for assessing risks to individuals by region. The TRI data provides specific location information (including longitude and latitude) for total amounts of TRI chemicals. Incorporating the use of geographic information systems (“618”) in TRI data analysis would be effective in indicating localized regions that demonstrated inordinately high levels of toxic chemicals reported as stored and/or released into the environment (i.e., “hotspots”). Overlaying readily available census data (e. g, population, gender, race and economic status) with this TRI data concerning hotspots, using GIS, will be useful in determining whether specific individuals and/or discrete groups are exposed to increased risk. 3. Review of the Utility of Chemical Use Initiatives The current legislative trends towards chemical use analysis needs to be reassessed. The U.S.E.P.A.’s movement towards requiring chemical use data as a means of advancing the recognized goals of the EPCRA are not usefirl. While chemical use data may be of marginal use in reducing overall quantities of toxic chemicals stored or released into the environment by specific industry (and thereby affect overall risk), this method 98 does nothing to increase the efficiency of the allocation of resources in the efforts to decrease risk. As Senator Lott stated on this issue: the addition of chemical use data would not further EPCRA'S goal of reducing chemical releases. Chemical use bears no direct relationship to emissions, waste generation, health risks or environmental hazards. Risk is a function of hazard and exposure. Chemical use will not indicate exposure. Furthermore, EPA's plans to expand regulatory requirements under the Toxic Substances Control Act to gather chemical use data is equally inappropriate. For all of these reasons, I believe that this program requires reexamination and redirection-not expansion along the lines that EPA intends. Clearly, there is an immediate need to first compare the reduction in risks by recent substantial reductions in emissions, before simply adding new informational requirements or facilities. Riskszrlrpw need to be evaluated on a benefit-to-cost or a risk-to-risk basis. This refocusing on risk is absolutely necessary and can be furthered by research indicating the limited utility of focusing limited resources on chemical use reporting. 4. Refocusing on Risk Issues by the U.S.E.P.A. Congruent with the efforts suggested in the preceding section, a general refocusing on risk issues is of paramount concern. Evaluation of the utilization of existing right-to- know laws by the public, similar to the effort made in this dissertation, is absolutely necessary to insure that the public’s right-to-know laws continue to serve a practical purpose. Research regarding the effectiveness of right-to-know initiatives is paramount to insure that the laws are utilized to the fiillest extent possible. Decreasing overall risk and enhancing communication between government agencies and the public can be more 219 141 CONG. REC. 514366-03. (daily ed. Sept. 27, 1995) (statement of Sen. Lott). 99 efficiently achieved by maximizing the use of the data available rather than attempting to implement new approaches to right-to know paradigms. Reviewing the U.S.E.P.A.’s on this issue, Representative Lewis issued the following directive: Despite new information-gathering initiatives, EPA has proposed no improvement in the collection, analysis, and communication of information to the public on its own priorities, performance, or the effectiveness of such initiatives in improving the public's "right-to- know." Moreover, EPA has not sufficiently considered options to maximize the use of information already reported by facilities and available to citizens locally under the federal Emergency Planning and Community Right-to-Know Act (EPCRA) in its efforts to expand TRI to include more data on chemical uses. The conferees thus direct a study by the General Accounting Office to: (1) Identify options for improving the right-to-know program to more effectively address community concerns regarding risks associated with chemicals and to communicate risks to the public; . . .220 22° 142 CONG. REC. H10733-Ol. (daily ed. 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F orrnan et al., Proceedings of the T oxics Release Inventory (TRI) Data Use Conference, March 29-31, 1993, Chicago, IL, EPA/745-R-93-004, US. Environmental Protection Agency: Washington, D.C., July 1993. Genetic Toxicity Chemical Information System (GENE-TOX); TELNET . Guidelines for Carcinogen Risk Assessment, 51 Fed. Reg. 33,992, 33,993 (1986). Guidelines for Estimating Exposures, 51 Fed. Reg. 34,042 (1986). SUSAN HADDEN, A CITIZEN’S RIGHT TO KNOW: RISK COMMUNICATION AND PUBLIC POLICY (Westview Press 1989). C. Hansch and AJ. Leo, SUBSTITUENT CONSTANTS FOR CORRELATION ANALYSIS IN CHEMISTRY AND BIOLOGY. (John Wiley and Sons, 1971). David J. Hansen, T oxics Release Inventory Report Shows Chemical Emissions Continuing To Fall, CHEM.ENV.NEWS 29 (July 15, 1996). Hazardous Substances Data Bank (HSBD); TELNET . A. Horvath et al., Toxic Emissions Indices for Green Design and Inventory, 29(2) ENVT’LSCITECH. 86A (1995). ICF, Inc., SARA Section 313 Roadmaps Data Base User's Manual- Version 2.10, US. DEPARTMENT OF COMIVIERCE NATIONAL TECHNICAL INFORMATION SERVICE (PB-174855) (1989) Integrated Risk Information System (IRIS); TELNET . INTERNET . INTERNET . INTERNET . 102 C. Q. Jia et al., Toxic Release Inventories: Opportunities for Improved Presentation and Interpretation, 30(2) ENVTL. SCI. TECH. 86A-91A (1996). H. KOnemann, and R. Visser, Selection of chemicals with high hazard potential: Part 1: WS-Scoring System. 17 CHEMOSPHERE 1905 (1988). Francine Laden, Toxics Use Reduction: Pro and Con, 4 RISK I.H.S. 213 (1993). W. R. Lea et al., Comparative Risk Analysis of the T RI Data as an Environmental Indicator -A Louisiana Case Study; Paper presented to the Air & Waste Management Association’s 88th Annual Meeting & Exhibition, San Antonio, Texas, June 18-23, 1995. Francis M. Lynn & Jack D. Kartez, Environmental Democracy In Action: The T oxics Release Inventory, 18(4) ENVTL. MGMT. 511 (1994). D. Mackay, Finding fugacity feasible, 12 ENVIRON. SCI. TECHNOL. 1218 (1979). Alair MacLean & Paul Orum, PROGRESS REPORT: C(_)MMUN1TY RIGHT-TO-KNOW 13 (July 1992), available in RTK-NET. J. Main, The Big Cleanup Gets It Wrong, FORTI INE, May 20, 1991. Bradford C. Mank, Preventing Bhopal: “Dead Zones" and Toxic Death Risk Index Taxes, 53 OHIO ST. L]. 761 (1992). D. B. McGregor, CHEMICALS CLASSIFIED BY IARC: THEIR POTENCY IN TESTS FOR CARCINOGENICITY IN RODENTS AND THEIR GENOTOXICITY AND ACUTE TOXICITY (1992). NATIONAL ACADEMY OF SCIENCES, Risk Assessment in the Federal Government: Managing the Process, National Academy Press, Washington DC. (1983). NATIONAL ACADEMY OF SCIENCES, TOXICITY TESTING: STRATEGIES TO DETERMINE NEEDS AND PRIORITIES (1984). W. Brock Neely, INTRODUCTION TO CHEMICAL EXPOSURE AND RISK ASSESSMENT, 43 (Lewis Publishers, 1994). NLM, T OXicology Data NET work: A Brief Guide T 0 Searching Its Files (October 1995); TELNET . NLM, T OXicology Data NE T work; TELNET . T. R. O’Bryan & R. H. Ross, Chemical Scoring System for Hazard and Exposure Identification, I J.TOXIC.ENVTL.HEALTH 119 (1988). 103 PLASTICIZERS, PESTICIDES, METALS RELEASES FLAYED BY PUBLIC INTEREST GROUPS AS REPRODUCTIVE HAZARDS, 6 PEST.TOX.CHEM.NEWS 4101. Jayne S.A. Pritchard, Comment, A Closer Look at Title III of SARA: Emergency Planning and Community Right-to-Know Act of I 986, 6 PACE ENVTL. L. REV. 203, 203-04 (1988). Mary Beth Regan, An Embarrassment of Clean Air, BUSINESS WEEK, May 31, 1993. Registry of Toxic Effects of Chemical Substances (RTECS); TELNET . F. Rice, FORTUNE, July 26, 1993. Richard Schwadron, The Bhopal Incident: How the Courts have Faced Complex International Litigation, 5 EU. INT'L L]. 445 (1987). Steam in Chemical Storage Tank Named As Likely Cause of Union Carbide Accident, l6 ENV'T REP. (BNA) 635 (Aug. 16, 1985). Paulette L. Stenzel, Right To Act: Advancing The Common Interests 0f Labor And Environmentalists, 57 ALB. L. REV. 1 (1993). SOCIETY OF ENVIRONMENTAL TOXICOLOGY AND CHEMISTRY (SETAC), THE MULTI- MEDIA FATE MODEL: A VITAL TOOL FOR PREDICTING THE FATE OF CHEMICALS (Cowan, C.E., et al. eds, SETAC Press 1995). THE GREENING OF AMERICAN BUSINESS: MAKING BOTTOM-LINE SENSE OF ENVIRONMENTAL RESPONSIBILITY (THOMAS S.P. SULLIVAN ed, Government Institutes, Inc.l992) I 993 T oxics Release Inventory - Public Release Data, EPA 745-R-95-010. The Bhopal Tragedy: Social and Legal Issue: A Symposium, 20 TEX. INI’I. L]. 267 (1985) TELNET . TELNET . The Toxic Chemical Release Inventory Fact Sheet: TELNET . Tier 11 Reporting and Inventory System < http ://www.epa. gov//swercepp/tools. html>. Toxic Chemical Release Inventory (TRI); TELNET ; TELNET . 104 Toxic Chemical Release Inventory Reporting Form R and Instructions'Revised 1995 Version 6, EPA/745/K-96-001. Toxic Chemicals Release Inventory Facts Sheets (TRIFACTS); TELNET . Toxic Substances Control Act-lnteragency Testing Committee, Initial Report to the Administrator, EPA 560/10-78/001, US. Environmental Protection Agency: Washington, D.C., February 1977. United States General Accounting Office, Report To Congress, Toxic Chemicals: EPA 's Toxic Release Inventory Is Useful But Can Be Improved 26 (June 1991) (GAO/RCED- 91-121). M. Weiss, W. KOrdel, D. Kuhnen-Clausen, A.W. Lange and W. Klein, Priority Setting of existing chemicals, 17 CIIEMOSPIIERE 1419 (1988). J. L. Welch & R. H. Ross, An Approach To Scoring ()f Toxic Chemicals for Environmental Effects, 1 ENVTL. TOXICOL. CHEM. 95 (1982). R. H .Welch & J. L. Welch, Proceedings of the EPA Workshop on the Environmental Scoring of Chemicals, EPA 560/11-80-010, US. Environmental Protection Agency: Washington, D.C., February 1979. Sidney M. Wolf, Fear And Loathing About The Public Right T 0 Know: The Surprising Success Of The Emergency Planning And Community Right-To-Know Act, 11 J. LAND USE & ENVTL. L. 217 (1996). Bud Ward, American Journalism Has A New Arrow In Its Quiver, ENVTL. HEALTH, Feb. 1992. WORST THINGS FIRST: THE DEBATE OVER RISK-BASED NATIONAL ENVIRONMENTAL PRIORITIES (Finkel, AM. & Golding, D., eds, Resources for the Future, 1995). APPENDICES Appendix A EPCRA Form R 105 Appendix A EPCRA Form R mwmmm WANT: Typowmmmmwm; Willi-£1102 TOXIC CHEMICAL RELEASE GEPA FORM INVENTORY REPORTINGFORM UnIIOdStatfl EnvironmentalProtoction waradumwmmmmumm mmurmutuuwmwmm “IMO“ I. EPCRAWCW z WESTATECFFDE WHERETOSEND P..O 8am (SumnWF) COMPLErEpFOMIS: WW yum ATTN: mxcmmm IMPORTANT: Soc lnatructlona to determine when ”Not Applicable (NA)" boxes should be checked. PART I. FACILITY IDENTIFICATION INFORMATION | SECTION ‘ SECTION 2. TRADE SECRET INFORMATION ' Anyouclainangthetoxicchomicalidantlfiodmpagoamm? REPORTING 2.1 Yes (Mu-imam No (Donatmzz; ma Attachaibatantlatlontotm) Bobs-wont!) 19 2,2 ItyocanJJatIiaoopy: [:1 WSW secnou 3. cennncanon (Important: Read and clan m completing all tonn um) thercoyccrtitytnatthavemviowodmeanacheddowmnuandmttombcudmywmwmn submitted tntormatton is true and complete and that the amounts and vakraa in this report are mt. traced on naconablccsttmatcsuatngdataavaihbletotheproparoraotmropon. mummdwuwmm] 'Wl 0am SECTION 4. FACILITY IDENTIFICATION Of EPAmeI (M. IWI-mm‘flm 106 Aggndix A EPCRA Form R EPA FORM n gag-EA PART I FACILITY IDENTIFICATION imy"“°'“"“"""'°”°°°" ' INFORMATION (CONTINUED) SECTION 4. FACILITY IDENTIFICATION (Continued) Thie report containa information tor: a. D An entire b.I:| Part of a c. CI A Federal ‘2 W: check a 91 b: Check C it applicable) facility facility IacIlity ‘ Ilene Tmmtmuum» 43 Technical Contact ‘ ' Nam Imammaumt 4.4 Public Contact —] 4.5 SIC Code (“‘9") a. 9.1 c. d. e. I. mu m ‘5 mun“ Degreu tin. m Deuce than Sewn Longitude 4.7 Dun & Bradetreet Number(e) (9 digite) 4.8 EPA identification Number(e)‘ (RCRA i.D. No.) I (12 charactere) 4,9 Facility NPDES Permit Number“) (9 charactere) 4.10 Underground injection Well Code (UIC) I.O. "mm-l (12 digite) 99.69»??er SECTION 5. PARENT COMPANY INFORMATION map-mom ] 5.1 D NA mmmamm ] 5.2 , __|j NA (9 digita) SAMMIMJmter-eflulnm. 107 Appendix A EPCRA Form R Pagaofl GEPA Unitod States Environmental Protection W PART II. CHEMICAL-SPECIFIC EPA FORM R INFORMATION sECTION ‘I. TOXIC CHEMICAL IDENTITY W= 0° NOT mm- w- eectionltyouoompteteSectioanelou.) 1.1 CASNuInbeI (W: mmmwmmmmuwmu mmmnmumm.) 1.2 Tmmamcmm (W mmmmm-Immuwmm 1.3 momm (W Oman-animusumztuwm' wmmumm SECTION 2. MIXTURE COMPONENT IDENTITY “W °° ”WWW aecflonltyoucompieteiectiontabove.) 2.1 mmmmwmtwmdmmmmmum) SECTION 3. ACTIVITIES AND USES OF THE TOXIC CI-IEIICAI. AT THE FACILITY (inportant: Chectt al that apply.) 11mm: a.DProduce e.gForon-eiteueelproceeehp 3.1 “m b. [:1 iInport d. E] ForeaIe/detriution thetoxic chemical: e.gAaabyproduct I.[:]Aeanimpurity 3.2 m D.CIAsareactant CDAaanattiDIecoInponent chu:I:d: b.[:]AaeIonnuIationcomponent d.[:]Flepeckaginp 3.3 mm?“ a.I_—_IAeachemicaiproceacingaid C.I:]Anciilaryorotheruee cheatizal: DDAeamanutectumDald SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT ANY m flame THE CALENDAR YEAR 4.1 (Entertwo-digit code Irorn inatmction package.) EPAFoIIIImo-tlflevarPtmeMeueu-m. 108 Apfingix A EPCRA Form R aEPA EPA FORM R Wm PART II. CHEMICAL-SPECIFIC W INFORMATION (CONTINUED) SECTION 5. 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IIIIIIIIIII b’\’\’\’\’\’\’\’\’\’\ I Landtreetmetfl ......u... IIIIIIIIIII b’\’\’\’\’\'\’\’\’\’\ mm" “II...“ I'\’\'\’\’\’\’\’\’\’\ s\\\\\\\\\\ IIIIIIIIII4 b\\\\\\\\\\ IIIIIIIIII h\\\\\\\\\\ IIIIIIIIIII |\\\\\\\\\\ IIIIIIIIIII t\\\\\\\\\\ .I‘I‘I‘I‘I‘I‘I‘I‘I‘I‘I IIIIIIIIIII \\\\\\\\\\ IIIIIIIIIII 5.5 b’\’\’\’\’\’\’\’\’\’\ .4 Otherdiapoed NA uuuuu I ‘I‘I‘I‘I‘I‘I‘I‘I\I ‘4 AAAAAAA‘AA :Cmmomnummmwmmbmmmsambm — F EPAFauIMIIIivarPIm-eauelem. ”cm Ant-tom ecu-tum Com-”pent. 109 Appendix A EPCRA Form R R “EPA W 5"“ PART I . HEMI - I ...... iNFORMATION (CONTINUED) SECTION 5.3 ADDITIONAL lNFORMATION ON RELEASES OF THE TOXIC CHEMICAL TO THE ENVIRONMENT ON-SITE Diechargeetoreceiving A.TotalIIeieeeeW Eleeieot C.'/.FroIII 5.3 atreamaorwaterbodiee MIWWMM Eathnue m (enter one name per box) Mam) (ea-I code) 5.3._ SbeamorWaterBodyName 5.3. StreemorWaterBodyName 5.3._ Sb'eamorWeterBodyName SECTION 8. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO OFF-SITE LOCATIONS 6.1 DISCHARGES TO PUBLICLY OWNED TREATMENT WORKS (POTW) 5.1.A Total Quantity TraneterredtoPOTWemd BaeieoIEetimete 5.1.A.1 Toni Tandem (mum 5.1M Beele oI Eatinde (enter range code or eetimete) ‘ (ereer code) 5.1.3 POTW Name and Location lntormatIon ‘1 .B._ M 6.1.B._ M s... M LII-.1 EM ueddlflondpapuotPutfl,Secflom5.3m&1ueathched.decathohlnumbud pageelnthiebox [:3 andindicetewhichPertII,Sectlone5.3lB.1papethieie,here.D “MMIWJWPPWMHM (W:1.2.3.“.) ”Cote: Ant-tom sundown; Guam-”m 110 mm EPCRA Form R n vEPA unitedsmee mm W EPA FORM R PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS u—MEPAWWFCRADM] "isT-mmmJ ELM EH 93L! :4 .... mam“ Dv- :1» 2mm rm? °WWWW.. 1. 1. 1. fl 2- 2- LL 3. 3. 4. 4. 4._! SECTION 6.2 TRANSFERS TO OTHER OFF-SITE LOCATIONS 5.2.- OII-mEPAIo-Iuammmcamuufl ‘ WWMJ sun-Imus | EL] FEEL.) Pu ~—-J"°°* mam“ Elv- [3»- mm... "fifi" °WWWWR 1. 1. LJ 2. 2. LI 3- L.- 4. 4. 4-_fl EAFamm-‘I (M. IWPPmmflM' NeddlflonflpaguotPutl,Secflon51methched,hdiceudutoulnunbaotpepum0ie box [3 andlndicatewhichPartli,Sectlon6.2pegethIeie,here.D (ox-Imus...» mean-I: Ant-tom Butt-mount: ham-tum 111 Appendix A EPCRA Form R PageTOIO SEPA United States Environmental EPA FORM R mm PART II. CHEMICAL-SPECIFIC INFORMATION (CONTINUED) SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY D NotAppIicabIe(NA) - Checkhereiinpon—sitevraetetreetmentieappliedtoeny waste stream containing the toxic chemical or chemical category. Leaner! DWIINTWWIIM CMGM dyst- Camden mgr» WWW!” cam-m m moan? W 7A.1a 7"“, II . 2‘ 7A.1c 7A.1d 7A.1e -[__s.___.| . .. .. °|__J 7 'Z__, 7A.2e "'2” II I 2I 7A.2c 7m 7A.2e =C:I . 5l v. a. 6 I 7 .. . , % 7A.3e "'3" 1I . 2: 7A.3c 7m 7A.3e 3L— 4 5 Yes No S I 7| D 7. 7A.4e 7"“ tI I 2I I 7M: 7A.4d 7A.4e - ‘ 5 Y. m '___l.7[___J '.___, 9‘ CI 7A.5a "-5” 1 r I 2I_ ______, 7A.5c 7m 7A.5e 3F I 4I I 5I___;_ Yes No SI I TI I DI I % El haddMomIcophedmgeTmamcMIndicaumetoulnumberotpegeemmb box I: andindicatewhichpegeflhiels,hen.[j (”1.2.3.“) EPAFoImtfio-unemmtymefiaeanm. 112 Appendix A EPCRA Form R 6 EPA EPA FORM R m m PART II. CHEMICAL-SPECIFIC W INFORMATION (CONTINUED) SECTION 73. ON-SITE ENERGY RECOVERY PROCESSES [j NotAppIicabIe(NA)- Checkhereltnpon-eiteenergyrecoveryleappiiedtoanyvraete stI-eatnconteiningthetoXicchemioelorchemicelcategory. mummy-Irena“: 1- 2- 3- 4- SECTION 7C. ON-SITE RECYCLING PROCESSES [j NotAppiicabIe(NA)- mmummmbwmmm «mummchemicelorchemiceicategory manual-um“: EPAHIIIIMIW.M-mmeuem 113 Appendix A EPCRA Form R EPA FORM R 3 EPA WSW“ PART II. CHEMICAL-SPECIFIC w INFORMATION (CONTINUED) SECTION 6. SOURCE REDUCTION AND RECYCLING ACTIVITIES Manama! CquIhnA Winter-Dwayne. ml"? Column! ColumnD ' Current me Second WY. WV“ WY.- W W W Ouentitytreated oft-site Ouantityreleesedtotheenvlronmentaearesultot remedial actions, catastrophic events, or one-time evente notassociatedwithproductlonproceeeee (pounds/year) Productionratiooractivitylndex 6.10 mmmmhmmmmmmmm thereportingyear? IInot.enter'NA' in Section 3.10.1 and answer Section 6.11. Sotucefleduction Activities mummurhrmi 6.10.1 I“ 0000(0)] C. 6.10.2 C. 6.10.3 6.10.4 PFPP 6.11 IsaddidoneloptlauIIMormadononaourcenducfloerDMor pollutioncontroiactivltieeinciudedwithtl'tierepa't? (Checkonebox) [:1 1:] ‘RaportreleaeeepuruatttDEPCRASectionaaflm . .or mmm-umww-mmsam into the WE DO 3w 'won-eleoroh-ehe. Appendix B TRI Releases of Known or Spspect Carcinogens (1993) 114 Appendix B TRI Releases of Known or Suspect Carcinogens (1993) Table 1 - TRI Releases of Known or Suspect Carcinogens (1993).a Surface Total Air CAS Total Air Water Releases Water/Land Number“ Chemical Emissions Discharges to Land Releases Pounds Pounds Pounds Pounds 75-07-0 Acetaldehyde 6.507.137 35,127 951 6,543,215 60-35-5 Acetamide 15 1 0 16 79-06-1 Acrylamide 28,558 2,261 168 30,987 107-13-1 Acrylonitrile 1.393618 3.078 6.934 1,403,630 60-09-3 4-Arninoazobenzene 1 0 0 l 92-67-1 4-Aminobiphenyl 0 0 0 0 90-04-0 o—Anisidine 877 81 1 16 1,074 7440-38-2 Arsenic 33,988 1.643 311,263 346,894 1332-21-4 Asbestos (friable) 8.383 255 537,783 546,421 71-43-2 Benzene 10,799,125 18.793 27,515 10,845,433 92-87-5 Benzidine 16 0 0 l6 98—07-7 Benzoic trichloride 6.135 O 0 6.135 7440-41-7 Beryllium 903 24 14,594 15,521 542-88-1 Bis(chloromethy1) ether 255 0 0 255 106-99-0 1,3-Butadiene 3,274,316 7,595 350 3,282,261 7440-43-9 Cadmium 15.290 412 56.665 72.367 56-23-5 Carbon tetrachloride 2,228,909 1,453 79 2,230,441 67-66-3 Chloroform 13,808,692 451,362 32,926 14,292,980 107-30-2 Chloromethyl methyl ether 2.241 5 0 2,246 XX Chlorophenols 9.906 34 0 9,940 7440-47-3 Chromium 426,198 21,960 1,157,200 1,605,358 8001-58-9 Creosote 1,152,129 8,039 1,528 1,161,696 120-71-8 p-Cresidine 410 5 85 500 135-20-6 Cupferron 59 0 0 59 615-054 2,4-Diaminoanisole 13 0 0 13 101-804 4,4'-Diaminodiphenyl 1 19 2,137 5 2,261 ether 25376-45-8 Diaminotoluene 17,364 989 113 18,466 (mixed isomers) 95-80-7 2,4-Diaminotoluene 1,790 0 0 1.790 106-93-4 1,2—Dibromoethane 2 5, 199 80 254 25,533 25321-22-6 Dichlorobenzene 6,886 0 30 6,916 (mixed isomers) 106-46-7 1,4-Dichlorobenzene 357,891 1,265 1,112 360,268 91-94-1 3,3'-Dichlorobenzidine 10 O 0 10 115 Appendix B TRI Releases of Known or Suspect Carcinogens (1993) Table 1 (con’t) 107-06-2 1,2-Dichloroethane 2.304.877 6.806 303 2,31 1,986 75—09-2 Dichloromethane 64.313.21 1 62,909 78,267 64,454,387 542-75-6 1.3-Dichloropropylene 3 3. 164 2 0 33, 166 1 17-81-7 Di-(2-Cthylhexyl) 578,940 1,1 18 92,887 672,945 phthalate 64-67-5 Diethyl sulfate 22.016 5 5 22,026 1 19-90-4 3.3'-Dimethoxybenzidine 0 4 0 4 57-14-7 1. l-Dimethyl hydrazine 194 0 0 194 77-78-1 Dimethyl sulfate 5.755 0 5 5,760 123-91-1 1,4-Dioxane 434.017 477,896 2,236 914,149 106-89-8 Epichlorohydrin 384,132 3.642 2.356 390,130 140-88-5 Ethyl acrylate 186,391 1,200 21 187,612 151-56-4 Ethyleneimine 0 0 O 0 75-21-8 Ethylene oxide 1,147.222 2.634 11,222 1,161,078 96-45-7 Ethylene thiourea 270 0 0 270 50-00-0 Formaldehyde 11,371,021 418,503 418,220 12,207,744 1 18-74-1 Hexachlorobenzene 636 476 0 1, 1 12 302-01-2 Hydrazine 16.452 784 5 17.241 10034-93-2 Hydrazine sulfate 1 0 0 l 7439-92-1 Lead 695,894 24,575 3,336,155 4,056,624 58-89-9 Lindane 575 0 5 580 101-14-4 4,4'-Methylenebis 15 O 0 15 (2-chloroaniline) 101-77-9 4.4’-Methy1enedianiline 18.274 291 135 18.700 90-94-8 Michler's ketone 1,542 0 0 1,542 134-32-7 alpha-Naphthylamine 10 0 0 10 7440-02-0 Nickel 321.926 38,098 427,911 787,935 XX Nickel compounds 178,880 56,096 2,864,701 3,099,677 139-13-9 Nitrilotriacetic acid 12 6,442 0 6,454 79-46-9 2-Nitropropane 48.328 1,200 0 49.528 XX Polybrominated biphenyls 0 0 0 0 1336-36-3 Polychlorinated biphenyls 0 0 265 265 (PCBs) 1120-71-4 Propane sultone 250 0 0 250 75-55-8 Propyleneimine 339 O 0 339 75-56-9 Propylene oxide 1,123,896 6,390 6,197 1,136,483 81-07-2 Saccharin (manufacturing) 301 0 0 301 100-42-5 Styrene 32,570,591 28,274 177,580 32.776.445 96-09-3 Styrene oxide 344 0 0 344 127-184 Tetrachloroethylene 10,942,019 10.152 618.026 1 1,570,197 62-56-6 Thiourea 1,372 2,61 1 288 4,271 116 Appendix B TRI Releases of Known or Suspect Carcinogens (1993) Table 1 (con’t) 584-84-9 Toluene-2.4-diisocyanate 58.869 0 0 58,869 91-08-7 Toluene-2.6-diisocyanate 6,695 0 0 6,695 26471-62-5 Toluenediisocyanate 42.223 0 288 42,511 (mixed isomers) 95-53-4 o-Toluidine 18.401 1,266 7 19.674 88-06-2 2.4.6-Trichlorophenol 69 56 0 125 5 1-79-6 Urethane 12. 200 0 0 12.200 593-60-2 Vinyl bromide 1.657 0 0 1,657 75—01-4 Vinyl chloride 1.013.962 277 6 1,014,245 Subtotal [167,963,376 1,708,306 I 10,186,762 | 179,858,444] Total for All TRI 1.672.127,735 271,152,864 289,052,581 2,232,333,180 Chemicals * Compund categories do not have CAS numbers (XX). 3 Source: 1993 T oxics Release Inventory - Public Release Data, Table 1-43, EPA 745-R- 95-010. Appendix C Known or Suspect Carcinogens in Michigan 117 Appendix C Known or Suspect Carcinogens In Michigan Table 2 - Known or Suspect Carcinogens With Reported Releases in Michigan CAS Chemical Number Name 7 5-07-0 Acetaldehyde 7 9-06-1 Acrylamide 107-13-1 Acrylonitrile 7440-3 8-2 Arsenic 1332-21-4 Asbestos (fn'able) 71-43-2 Benzene 7440-41-7 Beryllium 542-88—1 Bis(chloromethy1) ether 1 06-99-0 1 ,3-Butadiene 7440-43-9 Cadmium 56-23-5 Carbon tetrachloride 67-66-3 Chloroform 107-30-2 Chloromethyl methyl ether XX Chlorophenols (mixed isomers) 7440-47-3 Chromium 8001-58-9 Creosote 25376-45-8 Diaminotoluene 1 06-93-4 1,2-Dibromoethane 106-46-7 l ,4-Dichlorobenzene 91-94-1 3,3'-Dichlorobenzidine 107-06-2 1,2-Dichloroethane 75-09-2 Dichloromethane 542-75-6 1 ,3-Dichloropropy1ene 117-81-7 Di-(2-ethy1hexy1) phthalate 7 7 -7 8-1 Dimethyl sulfate Table 2 (con’t) 118 Appendix C Known or Suspect Carcinogens In Michigan 123-91-1 l ,4-Dioxane 1 06-89-8 Epichlorohydrin 140-88-5 Ethyl acrylate 7 5-21-8 Ethylene oxide 96-45-7 Ethylene thiourea 50-00-0 Formaldehyde 302-0 1 -2 Hydrazine 743 9-92-1 Lead 134-32-7 alpha-Naphthylamine 7440-02-0 Nickel N495 Nickel compounds 139-13-9 Nitrilotriacetic acid 79-46-9 2-Nitropropane 1336-36-3 Polychlorinated biphenyls 75-56-9 Propylene oxide 100-42-5 Styrene 127-18-4 Tetrachloroethylene 62-56-6 Thiourea 584-84-9 Toluene-2,4-diisocyanate 91-08-7 Toluene-2,6-diisocyanate 26471-62-5 Toluenediisocyanate 95-53-4 o-Toluidine 88-06-2 2,4,6-Trichlorophenol 5 1-79-6 Urethane 75-01-4 Vinyl chloride 119 Appendix C Known or Suspect Carcinogens In Michigan Table 3 - Known or Suspect Carcinogens With No Reported Releases in Michigan 60-35-5 Acetamide 60-09-3 4-Aminoazobenzene 92-67-1 4-Aminobipheny1 90-04-0 o-Anisidine 92-87-5 Benzidine 98-07-7 Benzoic tn'chloride 120-7 1-8 p-Cresidine 1 3 5-20-6 Cupferron 61 5-05-4 2,4-Diaminoanisole 10 1-80-4 4,4'-Diaminodiphenyl ether 95-80-7 2,4-Diaminotoluene 2532 1-22-6 Dichlorobenzene 64-67-5 Diethyl sulfate 1 19-90-4 3,3'-Dimethoxybenzidine 5 7-1 4-7 1 , 1 Dimethyl hydrazine 1 5 1-56-4 Ethyleneimine 1 18-74-1 Hexachiorobenzene 10034-93-2 Hydrazine sulfate 58-89-9 Lindane 1 0 1 -14-4 4,4'-Methy1enebis 101-77-9 4,4'—Methy1enedianiline 90-94-8 Michler's ketone N575 Polybrominated biphenyls 1120-71-4 Propane sultone 7 5-5 5-8 Propyleneimine 81-07-2 Saccharin (manufacturing) 96-09-3 Styrene oxide 593-60-2 Vinyl bromide Appendix D CCPCT Compatible Summaries for Specific Chemicals 120 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 4 - Total Acetaldehyde Releases (in pounds) 1294K MEDIA air water total releases releases releases 1987 183766 326 184092 1988 79100 30 79130 1989 71566 33 71599 1990 37584 31 37615 1991 10575 10 10585 1992 8360 8 8368 1993 7527 0 7527 1994 11458 11463 me; - Total Acrylamide Releases (in pounds) 1194K MEDIA air water total releases releases releases 1987 750 3030 3770 1988 551 800 1351 1989 539 4005 4544 1990 5122 1752 6874 1991 933 1924 2857 1992 1034 0 1034 1993 1054 689 1743 1994 1432 630 2062 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 6 - Total Acrylonitrile Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 35684 750 36434 1988 29098 600 29698 1989 53677 629 54306 1990 16938 406 17344 1991 11508 168 11676 1992 20053 243 20296 1993 21633 145 21778 1994 19516 145 19661 Mel - Total Arsenic Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 0 1988 127 0 127 1989 0 0 0 1990 12 2050 2062 1991 9 1455 1464 1992 12 826 838 1993 26 1420 1446 1994 33 1220 1253 122 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 8 - Total Asbestos (friable) Releases (in pounds) YlkLR M ED“ air water total releases releases releases 1987 1251 0 1251 1988 1250 0 1250 1989 750 0 750 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 0 0 0 1994 0 0 0 T_abl_e§ - Total Benzene Releases (in pounds) 1294K MEDIA air water total releases releases releases 1987 762682 1891 764573 1988 658656 4533 663189 1989 574900 6643 581543 1990 528700 13291 541991 1991 481307 11890 493197 1992 234372 5729 240101 1993 182152 14735 196887 1994 190372 8730 199102 123 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 10 - Total Beryllium Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 0 1988 0 0 0 1989 250 0 250 1990 25 5 5 260 1991 250 1000 1250 1992 750 0 750 1993 5 0 5 1994 5 0 5 M31211 - Total Bis (chloromethyl) ether Releases (in pounds) YEAR [MEDIA air water total releases releases releases 1987 0 0 0 1988 0 0 0 1989 0 0 0 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 O O O 1994 0 O O 124 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 12 - Total 1,3-Butadiene Releases (in pounds) 1231K MEDIA air water total releases releases releases 1987 63472 0 63472 1988 34300 0 34300 1989 15990 0 15990 1990 30373 2 30375 1991 28359 0 28359 1992 47709 73 47782 1993 10415 0 10415 1994 20176 20176 12111194; - Total Cadmium Releases (in pounds) YIDLR MEDIA air water total releases releases releases 1987 500 250 750 1988 1250 0 1250 1989 500 0 500 1990 3035 6350 9385 1991 534 2700 3234 1992 347 1045 1392 1993 328 721 1304 1994 320 2514 2834 Table 14 - Total Carbon tetrachloride Releases (in pounds) Appendix D CCPCT Compatible Summaries for Specific Chemicals YIDIR M ED“ air water total releases releases releases 1987 183766 326 184092 1988 79100 30 79130 1989 71566 33 71599 1990 37584 31 37615 1991 10575 10 10585 1992 8360 8368 1993 7527 7527 1994 11458 11463 1;b_1;_1_5 - Total Chloroform Releases (in pounds) 1231K MEDIA air water total releases releases releases 1987 540334 10038 550372 1988 320989 11755 332744 1989 365130 3547 368677 1990 296246 2296 298542 1991 190387 1688 192075 1992 133061 1299 134360 1993 123607 1464 125071 1994 99173 706 99879 Table 16 - Total Chloromethyl methyl ether Releases (in pounds) 126 Appendix D CCPCT Compatible Summaries for Specific Chemicals YEAR MEDIA air water total releases releases releases 1987 250 0 250 1988 0 0 0 1989 1 0 1 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 15 0 15 1994 6 0 6 Table 17 - Total Chlorophenols (mixed isomers) Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 1988 0 O 1989 380 17 397 1990 330 17 347 1991 342 74 416 1992 349 19 368 1993 333 20 353 1994 334 20 354 127 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 18 - Total Chromium Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 17388 38832 56220 1988 33609 75287 108896 1989 18550 92061 110611 1990 12661 90821 103482 1991 17050 83430 100480 1992 13546 48076 61622 1993 23230 60456 83686 1994 26406 47311 73717 Law - Total Creosote Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 O 0 1988 0 0 0 1989 0 O 0 1990 O O O 1991 O O O 1992 0 O O 1993 7519 0 7519 1994 7818 O 7818 128 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 20 - Total Diaminotoluene Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 500 500 1000 1988 500 500 1000 1989 500 360 860 1990 10 115 125 1991 10 64 74 1992 10 52 62 1993 10 25 5 265 1994 10 255 265 Ia_bl§_2_l - Total 1,2-Dibromoethane Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 0 1988 0 0 0 1989 0 0 0 1990 O 0 0 1991 0 0 0 1992 0 0 0 1993 0 0 0 1994 0 0 0 129 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 22 - Total 3,3’-Dichlorobenzidine Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 3 2 5 1988 251 2 253 1989 251 1 252 1990 10 1 1 1 1991 10 0 10 1992 10 0 10 1993 10 0 10 1994 10 0 10 12113323 - Total 1,2-Dichloroethane Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 239503 24000 263503 1988 201249 3500 204749 1989 139854 20050 159904 1990 98373 44311 142684 1991 37759 905 38664 1992 12386 945 13331 1993 24159 990 25149 1994 25548 405 25953 130 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 24 - Total Dichloromethane Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 10259612 373658 10633270 1988 8163900 273808 8437708 1989 15754293 612640 16366933 1990 5349136 175261 5524397 1991 4596324 354893 4951217 1992 2485426 193094 2678520 1993 1963318 169862 2133180 1994 2279695 98601 2378296 Table 25 - Total 1,3-Dichloropropy1ene Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 500 O 500 1988 600 0 600 1989 292 0 292 1990 227 0 227 1991 224 O 224 1992 224 0 224 1993 231 0 231 1994 235 0 235 Table 26 - Total Di-(2-ethylhexyl) phthalate Releases (in pounds) 131 Appendix D CCPCT Compatible Summaries for Specific Chemicals YEAR MEDIA air water total releases releases releases 1987 24539 0 24539 1988 3561 0 3561 1989 65030 0 65030 1990 382279 0 382279 1991 370118 10 370128 1992 10285 0 10285 1993 25124 250 25374 1994 31502 0 31502 W - Total Dimethyl sulfate Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 1988 0 0 1989 250 0 251 1990 0 0 1991 0 0 1992 33 0 33 1993 33 0 33 1994 250 0 250 132 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 28 - Total Epichlorohydrin Releases (in pounds) ITQIR MEDIA air water total releases releases releases 1987 7680 0 7680 1988 1560 0 1560 1989 2719 0 2719 1990 3085 5 3090 1991 5223 251 5473 1992 4931 0 4931 1993 2306 0 2306 1994 2010 2010 TM - Total Ethyl acrylate Releases (in pounds) IILIR MEDIA air water total releases releases releases 1987 812 0 812 1988 329 0 329 1989 40 0 40 1990 379 0 379 1991 371 O 371 1992 145 0 145 1993 136 0 136 1994 936 0 936 133 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 30 - Total Ethylene oxide Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 55350 2050 57400 1988 57780 1460 59240 1989 43635 1000 44635 1990 43655 256 43911 1991 19208 405 19613 1992 13157 255 13412 1993 13105 255 13360 1994 12260 255 12515 w - Total Ethylene thiourea Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 O 1988 0 0 0 1989 0 0 0 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 O O 0 1994 0 0 0 134 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 32 - Total Formaldehyde Releases (in pounds) ITQIR MEDIA air water total releases releases releases 1987 531656 101598 633254 1988 938786 19657 958443 1989 401849 24114 425963 1990 483391 15049 498440 1991 395712 11701 407413 1992 417739 10949 428688 1993 380590 12296 392886 1994 265769 5549 271318 Table}; - Total Hydrazine Releases (in pounds) ilnik MEDIA air water total releases releases releases 1987 0 0 0 1988 3 0 3 1989 500 0 500 1990 10 0 10 1991 10 0 10 1992 0 0 0 1993 0 0 0 1994 0 0 0 135 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 34 - Total Lead Releases (in pounds) YTDIR MEDIA air water total releases releases releases 1987 20719 1303 22022 1988 26207 105635 131842 1989 44608 238072 282680 1990 27911 226228 254139 1991 21603 162507 184110 1992 15451 79229 94680 1993 15133 133902 149035 1994 16509 183344 199853 Table 35 - Total Nickel Releases (in pounds) 1194K MEDIA air water total releases releases releases 1987 16412 12563 28975 1988 15004 10025 25029 1989 16937 39436 56373 1990 14198 10854 25052 1991 14095 22415 36510 1992 13165 21436 34601 1993 18228 14625 32853 1994 19156 4930 24086 136 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 36 - Total Nickel Compounds Releases (in pounds) 1291K MEDIA air water total releases releases releases 1987 9650 4250 13900 1988 12364 4831 17195 1989 11507 4720 16227 1990 8130 5268 13398 1991 6963 2650 9613 1992 6346 2563 8909 1993 5329 346 5675 1994 11440 103 11543 M - Total 2-Nitropropane Releases (in pounds) YZLIR MEDIA air water total releases releases releases 1987 18250 0 18250 1988 13000 0 13000 1989 10500 0 10500 1990 5 0 5 1991 0 0 0 1992 32 0 32 1993 0 0 0 1994 0 0 137 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 38 - Total Polychlorinated biphenyls Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 250 0 250 1988 0 1 1 1989 0 0 0 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 0 0 0 1994 0 0 0 m - Total Propylene oxide Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 158791 382000 540791 1988 144458 93950 238408 1989 132796 75350 208146 1990 73921 66250 140171 1991 56584 5050 61634 1992 49981 1250 31981 1993 23083 500 23583 1994 27165 500 27665 138 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 40 - Total Styrene Releases (in pounds) 1134K MEDIA air water total releases releases releases 1987 1361539 750 1362289 1988 1636020 6580 1642600 1989 1406354 578 1406932 1990 1472907 345 1473252 1991 1377353 405 1377758 1992 1669769 1778 1671547 1993 1980224 4480 1984704 1994 l1994876 3385 1998261 TAMI - Total Tetrachloroethylene Releases (in pounds) 1294K MEDIA air water total releases releases releases 1987 729900 250 730150 1988 710820 80 710900 1989 343302 386 343688 1990 104139 80 104219 1991 154572 154574 1992 163834 163834 1993 118433 118435 1994 122710 34 122744 139 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 42 - Total Thiourea Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 0 0 0 1988 0 0 0 1989 500 0 500 1990 510 0 510 1991 505 0 505 1992 505 0 505 1993 510 0 510 1994 10 0 10 1a_b_1_e_4_3_ - Total Toluene-2,4-diisocyanate Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 2413 250 2663 1988 2907 250 3157 1989 3882 2950 6832 1990 777 0 777 1991 1021 0 1021 1992 364 O 364 1993 434 0 434 1994 197 0 197 140 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 44 - Total Toluene-2,6-diisocyanate Releases (in pounds) YILLR MEDIA air water total releases releases releases 1987 1258 250 1508 1988 1792 0 1792 1989 3287 11150 14437 1990 13771 0 13771 1991 1022 0 1022 1992 301 0 301 1993 317 0 317 1994 312 0 312 Table—45 - Total Toluenediisocyanate Releases (in pounds) ITDLR MEDIA air water total I releases releases releases 1987 0 0 0 1988 0 0 1989 0 0 1990 7428 250 7678 1991 1485 5 1490 1992 1501 250 1751 1993 1411 250 1661 1994 2138 250 2388 141 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 46 - Total o-Toluidine Releases (in pounds) ITQIR MEDIA air water total releases releases releases 1987 0 0 0 1988 O O 0 1989 250 250 500 1990 0 0 0 1991 0 0 0 1992 10 10 20 1993 10 10 20 1994 10 10 20 Table 47 - Total 2,4,6-Trichlorophenol Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 O 250 250 1988 250 50 300 1989 113 14 127 1990 78 79 157 1991 80 2 82 1992 86 1 87 1993 69 56 125 1994 199 65 264 142 Appendix D CCPCT Compatible Summaries for Specific Chemicals Table 48 - Total Urethane Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 2950 0 2950 1988 0 0 0 1989 0 0 0 1990 0 0 0 1991 0 0 0 1992 0 0 0 1993 0 0 0 1994 0 0 0 w - Total Vinyl Chloride Releases (in pounds) YEAR MEDIA air water total releases releases releases 1987 2203 2203 1988 800 0 800 1989 2308 11 2319 1990 923 24 947 1991 5084 0 5084 1992 7032 0 7032 1993 6240 0 6240 1994 6230 0 6230 Appendix E Primagy Chemical Data With Hazard Values 143 ndix E Primary Chemical Data With Hazard Values A >= 58 >= .113»: >2 :2 .502 >= ...-e... :3.- Eu— >= .35 >2 ...4 Ede—e8 >= cede; .930 ESE u: lei—10.: loan—Ill— EB 82.5 ES: .23 58 8256 SEE 52 - on 2.3 144 A endix E Primary Chemical Data With Hazard Values 3.“ >2 ...-3 >2 .uuaU L3H .._< 5132 .2314: h?! 150 82; was: as, can EEO DEE :2 - a 2.3 145 A ndix E Primary Chemical Data With Hazard Values >2 hon >2 55...}: >2 n8 AHOZ >2 5...- EH L31 >2 >2 .._< Macao—em >2 Lea-.5 >2 .345 .930 L31 5310—: epa.—dal— El 15 mosfi> v§2 5:5 8.5 Roi—Ono bag—E owo— - «a wing. 46 1 A n ix E Primary Chemical Data With Hazard Values >2 :8 .0.-ID i Sea—e8 >2 Lea-3 as: 5.632: 131.. as: 8:3, .58: 5.3 .28 32565 SEE 82 - a 2...; 147 A endix E Primary Chemical Data With Hazard Values >2 52 >: 25.5.»: >2 :8 AHOZ >2 in... an: 5..- >= :45 >= .2 .383. >= ...-3 ...-O .5: 5.532: 8.5.1. .5: 8:; .55.: 5.3 2.5 32565 SEE as - 4w 2.3 148 n ix E Primary Chemical Data With Hazard Values A >2 >2 .1 Sade—ax >2 Se? 2. .15 ...-O Es: .2332: 55:... .55. 1.0 as...» .58: 5.3 25 R2566 E2...... 82 - a 2.3 149 A endix E Primary Chemical Data With Hazard Values >2 LO: >2 2522.: >2 as JHOZ > 2 .e—ch In... .252 . Mags. . . . . ., 21..-... I 1 i , . i «mummy .1111 1 1 .W‘ I c:"1"‘". I 1 " 1,5". N'"---I 1 l I I 1 I 1.4 ‘ ’ - " ~vIN,-rw‘vuIv-I,vi , . N “I”! l I N I l —v 2m m. . II it I In ... - .1 ......w.‘ .-.. . I I «)mInvanmI— mini-«NI I 1 ‘ I 1 1 mm. 1 l I I I 1 'Iv.lemImv v ‘0‘ vrflOIOI-nI-nIOIm‘O I I 1'11 IN 3:23. >: 5. 23...: 22...}... I41 2 >= >= .2 .....O ....O ...... 83.; 33:2 5.3 8ND 32825 EST—.2 mao— - on 03.2. 150 A endix E Primary Chemical Data With Hazard Values >2 boa >= 2.29.1: >2 can .502 >2 1:.- 3.; .52 >2 ...—2O >= .939 ...< $.23. >= ...-.5 SE ...<-&:2: 8.3:... .55. ills-O as...» 2.3: 5.3 28 R2566 .55.... .32 - IR 2...; Apgendix F Calculated Hazard Values for Sgecific Carcinogens 151 Aggendix F Calculated Hazard Values for Specific Carcinogens Table 58 - 1987 Calculated Hazard Values for Specific Carcinogens CAS Number Chemical WHHE WEE EF THV 75-07-0 Acetaldehvde 0.00 0.00 4.65 0.00 79-06-1 Acrvlamide 97.45 42.49 4.65 650.69 107-13-1 Acrxlonitrile 119.59 59.58 3.07 550.05 7440-38-2 Arsenic 0.00 0.00 6.75 0.00 1332-21-4 Asbestos (friable) 42.79 0.00 6.00 256.74 7143-2 Benzene 108.38 39.23 4.83 712.96 7440-41-7 Ben'llium 0.00 0.00 7. 50 0.00 542-88-1 Bis(chloromethvl)ether 0.00 0.00 7.50 0.00 106-99-0 1.3-Butadiene 82. 94 0.00 6.01 498.46 7440-43-9 Cadmium 81.00 71.23 7.25 1103.62 56-23-5 Carbon Tetrachloride 81.12 28.36 5.52 604.28 67-66-3 Chloroform 103.58 40.54 5.13 739.33 107-30-2 Chloromethvl methvl ether 82.82 0.00 7. 50 621. 16 XX C hlorophenols (mixed isomers) 0.00 0.00 4.78 0.00 7440-47-3 Chromium 145.08 88.76 6.65 1555.08 8001-58-9 Creosote 0.00 0.00 7.50 0.00 25376-45-8 Diaminotoluene 75.90 38.53 6.00 686.59 106-93-4 1.2-Dibromoethane 0.00 0.00 7.50 0.00 91-94-1 3.3'-Dichlorobenzidine 25.05 10.40 7.50 265.88 107-06-2 1,2-Dichloroethane 124.07 35.30 5.13 817.55 7 5-09-2 Dichloromethane 83 .07 21.81 5.3 3 559.04 542-75-6 1.3-Dichloropropjlene 93 .22 0.00 7. 50 699. 14 117-81-7 Di-Q-ethvlhexvl) chalate 126.35 0.00 5.97 754.31 77-78-1 Dimethyl sulfate 0.00 0.00 7 .50 0.00 106-89-8 Epichlorohvdrin 93 .04 0.00 4. 50 418.69 140-88-5 Ethvl acrvlate 100.49 0.00 7.50 753.69 75-21-8 Ethvleneoxide 138.66 19.83 4.50 713.19 96-45-7 Ethvlene thiourea 0.00 0.00 7.50 0.00 50-00-0 Formaldehyde 152.00 78.40 6.00 1382.37 302-01-2 Hydrazine 0.00 0.00 7.50 0.00 7439-92-1 Lead 131.15 64.55 6.39 1250.52 7440—02-0 Nickel 148.66 71.73 6.30 1388.45 N495 Nickel Compounds 138.06 63.50 6.30 1269.83 79-46-9 2-Nitropropane 87.33 0.00 6.00 523.96 1336-36 Polvchlorinated biphenyls 65.15 0.00 7.50 488.65 75-56-9 Propvlene Oxide 154.76 32.13 3.25 607.42 100-42-5 Stvrene 116.70 60.24 5.22 923.66 127-18-4 Tetrachloroethylene 109.36 31.47 6.29 885.82 62-56-6 Thiourea 0.00 0.00 7.50 0.00 584-84-9 Toluene-2.4-diisocvanate 74.44 19.88 4.50 424.41 91-08-7 Toluene-2.6-diisocvanate 68.62 19.88 4.50 398.24 26471-62-5 Toluenediisocvanate 0.00 0.00 4.50 0.00 95-53-4 o-Toluidine 0.00 0.00 7.50 0.00 88—06-2 2.4,6-Trichlorophenol 82.82 82.82 7.50 1242.33 51-79-6 Urethane 119.84 0.00 7.50 898.83 75-01-4 Vinyl chloride 100.07 0.00 4.63 463.32 152 Appendix F Calculated Hazard Values for Specific Carcinogens Table 59 - 1988 Calculated Hazard Values for Specific Carcinogens CAS Number Chen_ii_c3| WHHE WEE EF THV 75-07-0 Acetaldehyde 0.00 0.00 4.65 0.00 79-06-1 Acrylamide 85 .40 3 5.43 4.65 561.87 107-13-1 Acrylonitrile 116.98 57.57 3.07 535.87 7440-38-2 Arsenic 62.97 0.00 6.75 425.08 1332-21-4 Asbestos (friable) 42.79 0.00 6.00 256.71 71-43-2 Benzene 107.24 43.78 4.83 729.42 7440—41-7 Beryllium 0.00 0.00 7.50 0.00 542-88-1 Bis(chloromethvl)ether 0.00 0.00 7.50 0.00 106-99-0 1.3-Butadiene 78.32 0.00 6.01 470.71 7440-43-9 Cadmium 71.31 0.00 7.25 516.99 56-23-5 Carbon Tetrachloride 74.67 16.67 5.52 504.19 67-66-3 Chloroform 100.23 41.24 5.13 725.75 107-30-2 Chloromethyl methyl ether 0.00 0.00 7.50 0.00 XX Chlorophenols (mixed isomers) 0.00 0.00 4.78 0.00 7440-47-3 Chromium 154.27 94.32 6.65 1653.12 8001-58-9 C reosote 0.00 0.00 7. 50 0.00 25376—45-8 Diaminotoluene 75.90 38.53 6.00 686.59 106-934 1.2-Dibromoethane 0.00 0.00 7. 50 0.00 91-94-1 3L3'-Dichloroben7.idine 86.43 10.40 7. 50 726. 18 107-06-2 1.2-Dichloroethane 119.43 28.56 5.13 759.18 75-09-2 Dichloromethane 81.78 21.28 5.33 549.3 5 542—75-6 1.3-Dichloropropvlene 95.95 0.00 7. 50 719.65 117-81-7 Di-(2-ethvlhexvl) pthalate 102.22 0.00 5.97 610.27 77-78-1 Dimethyl sulfate 0.00 0.00 7.50 0.00 106-89-8 Epichlorohvdrin 76.47 0.00 4.50 344.09 140-88-5 Ethvl acrylate 86.94 0.00 7.50 652.06 75-21-8 Ethylene oxide 138.33 18.94 4.50 707.72 96-45-7 Ethylene thiourea 0.00 0.00 7. 50 0.00 50-00-0 Formaldehvde 152.93 67.23 6.00 1320.93 302—01-2 Hydrazine 16.48 0.00 7.50 123.59 7439-92-1 Lead 149.70 104.11 6.39 1621.84 7440-02-0 Nickel 146.61 70.02 6.30 1364.74 N495 Nickel Compounds 141.25 64.47 6.30 1296.03 79-46-9 2-Nitropropane 84.31 0.00 6.00 505.84 1336-36 Polychlorinated biphenyls 0.00 0.00 7.50 0.00 75-56-9 Propylene Oxide 145.29 28.63 3.25 565.22 100-42-5 Styrene 120.75 80.01 5.22 1047.92 127-18-4 Tetrachloroethylene 109. 14 24.98 6.29 843 .61 62-56-6 Thiourea 0.00 0.00 7 .50 0.00 584-84-9 Toluene-2.4-diisocyanate 76.13 19.88 4.50 432.04 91-08-7 Toluene-2.6-diisocvanate 71 . 17 0.00 4. 50 3 20.24 26471-62-5 Toluenediisocyanate 0.00 0.00 4.50 0.00 95-53-4 o-Toluidine 0.00 0.00 7.50 0.00 88-06-2 2.4,6-Trichlorophenol 104.21 58.68 7.50 1221.64 51-79-6 Urethane 0.00 0.00 7.50 0.00 75-01-4 Vinyl chloride 86.90 0.00 4.63 402.35 153 Appendix F Calculated Hazard Values for Specific Carcinogens Table 60 - 1989 Calculated Hazard Values for Specific Carcinogens CAS Number Chemical WHHE WElL__EF THV 75-07-0 Acetaldehyde 0.00 0.00 4.65 0.00 79-06-1 Acrylamide 98.97 43.97 4.65 664.64 107-13-1 Acrylonitrile 122.88 58.00 3.07 555.28 7440-38-2 Arsenic 0.00 0.00 6.75 0.00 1332-21—4 Asbestos (friable) 39.72 0.00 6.00 238.32 71-43-2 Benzene 106.19 45.77 4.83 733.94 7440-41-7 Beryllium 82.82 0.00 7.50 621.16 542-88-1 Bis(chloromcthyflcther 0.00 0.00 7 .50 0.00 106-99-0 1.3-Butadiene 72.60 0.00 6.01 436.31 7440-43-9 Cadmium 62.15 0.00 7.25 450.56 56-23-5 Carbon Tetrachloride 74.06 17.13 5.52 503.39 67-66-3 Chloroform 99.53 35. 96 5.13 695.08 107-30-2 Chloromethyl methvl ether 0.00 0.00 7.50 0.00 XX Chlorophenols (mixed isomers) 68.61 20.97 4.78 428.15 7440-47-3 Chromium 151.97 96.01 6.65 1649.10 8001-58-9 Creosote 0.00 0.00 7.50 0.00 25376-45-8 Diaminotoluene 74.38 36.49 6.00 665.26 106-93-4 1.2-Dibromoethane 0.00 0.00 7 .50 0.00 91-94-1 3. 3'-Dichlorobenzidine 82 .92 0.00 7. 50 621.91 107-06-2 1.2-Dichlorocthane 1 19.33 34.67 5.13 790.04 75-09-2 Dichloromethane 85.41 22.65 5.33 575.97 542-75-6 1.3-Dichloropropvlene 85.15 0.00 7.50 638.63 117-81-7 Di-(2-ethvlhcxvl) pthalate 138.53 0.00 5.97 827.04 77-78-1 Dimethyl sulfate 82.86 0.00 7.50 621.46 106-89-8 Epichlorohydrin 82.24 0.00 4. 50 370. 10 140-88-5 Ethvl acrvlate 55.33 0.00 7.50 415.00 75-21-8 Ethvlene oxide 134.37 17.96 4.50 685.47 96-45-7 Ethylene thiourea 0.00 0.00 7 .50 0.00 50-00-0 Formaldchvde 145.47 68.62 6.00 1284.54 302-01-2 Hydrazine 93.22 0.00 7.50 699.14 7439-92-1 Lead 158.81 111.42 6.39 1726.80 7440-02-0 Nickel 156.31 80.43 6.30 1491.45 N495 Nickel Compounds 140.38 64.29 6.30 1289.45 79-46-9 2-Nitropropane 82.41 0.00 6.00 494.44 1336-36 Polychlorinated biphenyls 0.00 0.00 7.50 0.00 75-56-9 Propylene Oxide 143.63 28.07 3.25 558.04 100-42-5 Styrene 116.64 57.87 5.22 910.95 127-18-4 Tetrachloroethylene 103.25 33.95 6.29 863.00 62-56-6 Thiourea 93.22 0.00 7.50 699. 14 584-84-9 Toluene-2.4-diisowanate 81 .05 28.76 4. 50 494. 17 91-08-7 Toluene-2.6-diisocyanate 83.59 33.55 4.50 527.12 26471-62-5 Toluenediisocvanate 0.00 0.00 4.50 0.00 95-53-4 o-Toluidine 117.36 82.82 7.50 1501.37 88-06-2 2.4.6-Trichlorophcnol 85.27 39.59 7.50 936.45 51-79-6 Urethane 0.00 0.00 7.50 0.00 75-01-4 Vinyl chloride 104.79 9.11 4.63 527.38 154 Appendix F Calculated Hazard Values for Specific Carcinogens Table 61 - 1990 Calculated Hazard Values for Specific Carcinogens CAS Number Chepigm WHHE WEE EF THV 75-07-0 Acetaldehyde 0.00 0.00 4.65 0.00 79-06-1 Acrylamide 104.26 39.58 4.65 668.87 107-13-1 Acmonitnle 110.69 54.06 3.07 505.77 7440-38-2 Arsenic 109.32 77.78 6.75 1262.91 1332-21-4 Asbestos (friable) 0.00 0.00 6.00 0.00 71-43-2 Benzene 105.62 49.37 4.83 748.64 7440-41-7 Bervllium 91.36 24.14 7.50 866.26 542-88-1 Bis(chloromethylEther 0.00 0.00 7.50 0.00 106-99-0 L3 -Butadiene 77 .62 5.27 6.01 498.15 7440-43-9 Cadmium 113.47 112.96 7.25 1641.62 56-23-5 Carbon Tetrachloride 69.85 16.83 5.52 478.47 67—66-3 Chloroform 97.53 34.05 5.13 675.01 107-30-2 Chloromethyl methvl ether 0.00 0.00 7 .50 0.00 XX C hlorcmhenols (mixed isomers) 67.17 20.97 4.78 421.27 7440-47-3 Chromium 149.62 95.90 6.65 1632.72 8001-58-9 Creosote 0.00 0.00 7.50 0.00 25376-45-8 Diaminotoluene 45.73 29.42 6.00 450.89 106-93-4 1.2-Dibromoethane 0.00 0.00 7.50 0.00 91-94-1 3,3'-Dichlorobenzidine 35.49 0.00 7.50 266. 19 107-06-2 1.2-Dichloroethane l 19.02 37.45 5.13 802.66 75-09-2 Dichloromethane 79.52 20.53 5.33 533.25 542-75-6 1,3-Dichloropropvlene 81.37 0.00 7.50 610.31 117-81-7 Di-(Z-ethvlhexyl) pthalate 160.67 0.00 5.97 959.22 77-78-1 Dimethyl sulfate 0.00 0.00 7.50 0.00 106-89-8 Epichlorohydrin 89.20 12.39 4.50 457.18 140-88-5 Ethvl acrylate 89.06 0.00 7.50 667.97 75-21-8 Ethvlene oxide 131.36 14.42 4.50 655.99 96-45-7 Ethvlene thiourea 0.00 0.00 7.50 0.00 50-00-0 Formaldehyde 146.07 65.41 6.00 1268.85 302-01-2 Hydrazine 34.54 0.00 7.50 259.04 7439-92-1 Lead 155.62 110.96 6.39 1703.49 7440-02-0 Nickel 146.49 70.62 6. 30 1367.80 N495 Nickel Compounds 137.32 65.13 6.30 1275.43 79-46-9 2-Nitropropane 14.32 0.00 6.00 85.94 1336-36 Polychlorinated biphenyls 0.00 0.00 7.50 0.00 75-56-9 Propylene Oxide 139.01 27.75 3.25 541.99 100-42-5 Styrene 116.37 53.18 5.22 885.06 127-18-4 Tetrachloroethylene 93.59 24.98 6.29 745.78 62-56-6 Thiourea 93.52 0.00 7.50 701.37 584-84-9 Toluene-2,4-diisocyanate 63.23 0.00 4.50 284.52 91-08-7 Toluene-2.6-diisocyanate 90.54 0.00 4.50 407.42 26471-62-5 Toluenediiwate 84. 82 19.88 4. 50 47 l. 15 95-53-4 o-Toluidine 0.00 0.00 7 .50 0.00 88-06-2 2,4y6-Trichloropienol 94.19 65.54 7.50 1 198.01 51-79-6 Urethane 0.00 0.00 7.50 0.00 75-01-4 Vinyl chloride 94.39 12.08 4.63 492.95 155 Appendix F Calculated Hazard Values for Specific Carcinogens Table 62 - 1991 Calculated Hazard Values for Specific Carcinogens CAS Nurjnber Chemical WHHE WEE EF THV 75-07-0 Acetaldehyde 59.26 0.00 4.65 275.56 79-06-1 Acrylamide 94.53 40.08 4.65 625.94 107-13-1 Acrylonitrile 104.31 46.12 3.07 461.79 7440-38-2 Arsenic 103.53 74.28 6.75 1200.22 1332-21-4 Asbestos (friable) 0.00 0.00 6.00 0.00 71—43-2 Benzene 104.87 48.79 4.83 742.19 7440-41-7 Beryllium 133.46 103.62 7.50 1778.04 542-88-1 Bis(chloromethvl)ether 0.00 0.00 7.50 0.00 106-99-0 1.3-Butadiene 76.90 0.00 6.01 462.14 7440-43-9 Cadmium 98.32 101.92 7.25 1451.79 56-23-5 Carbon Tetrachloride 61.16 11.28 5.52 399.87 67-66-3 Chloroform 94.07 32.70 5.13 650.33 107-30-2 Chloromethyl methyl ether 0.00 0.00 7.50 0.00 XX Chlorophenols (mixed isomers) 71.58 31.85 4.78 494.38 7440-47-3 Chromium 150.69 95.19 6.65 1635.07 8001-58-9 C reosote 0.00 0.00 7. 50 0.00 25376-45-8 Diaminotoluene 41.62 25.79 6.00 404.41 106-93-4 1.2-Dibromoethane 0.00 0.00 7.50 0.00 91-94-1 333'-Dichlorobenzidine 34.54 0.00 7.50 259.04 107-06-2 1.2-Dichloroethane 102.82 23.83 5.13 649.73 75-09-2 Dichloromethane 79.59 21.73 5 . 33 540.02 542-75-6 1.3-Dichloropropylene 81.17 0.00 7. 50 608.81 117-81-7 Di-(2-ethylhexyl) pthalate 160.27 22.34 5.97 1090.15 77-78-1 Dimethyl sulfate 0.00 0.00 7.50 0.00 106-89-8 Epichlorohydrin 108.74 42.55 4.50 680.77 140-88-5 Etpy’l acrylate 88.74 0.00 7.50 665.57 75-21-8 Ethylene oxide 123.26 15.61 4.50 624.93 96-45-7 Ethylene thiourea 0.00 0.00 7.50 0.00 50-00-0 Formaldehyde 143.60 63.70 6.00 1243.82 302-01-2 Hydrazine 34.54 0.00 7.50 259.04 7439-92-1 Lead 151.63 107.99 6.39 1658.92 7440-02-0 Nickel 150.84 76. 13 6.30 1429.95 N495 Nickel Compounds 132.59 59.91 6.30 1212.69 79-46-9 2-Nitropropane 0.00 0.00 6.00 0.00 1336-36 Polychlorinated biphenyls 0.00 0.00 7.50 0.00 7 5-56-9 Propylene Oxide 127.61 21.32 3.25 484.03 100-42-5 Styrene 116.05 54.64 5.22 890.98 127-18-4 Tetrachloroethylene 96.78 3.95 6.29 633.61 62-56-6 Thiourea 93.37 0.00 7.50 700.26 584-84-9 Toluene-214-dnsocyanate 65.82 0.00 4. 50 296. 19 91-08-7 Toluene-2.6-diisocyanate 65.83 0.00 4. 50 296.24 26471-62-5 Toluenediisocvanate 69.40 5.79 4. 50 338. 35 95-53-4 o-Toluidine 0.00 0.00 7.50 0.00 88-06-2 2,4,6-Trichlorophenol 69.44 10.40 7.50 598.80 51-79-6 Urethane 0.00 0.00 7.50 0.00 75-01-4 Vinyl chloride 110.94 0.00 4.63 513.65 156 Appendix F Calculated Hazard Values for Specific Carcinogens Table 63 - 1992 Calculated Hazard Values for Specific Carcinogens CAS Number Chemical WHHE WEE EF THV 75-07-0 Acetaldehyde 59.51 0.00 4.65 276.70 79-06-1 Acrylamide 65.94 0.00 4.65 306.63 107-13-1 Acrylonitrile 110.67 49.44 3.07 491.54 7440-38-2 Arsenic 97.84 68.51 6.75 1 122.86 1332-21-4 Asbestos (friable) 0.00 0.00 6.00 0.00 71-43-2 Benzene 99.11 45.00 4.83 696.04 7440-41-7 Beryllium 99.30 0.00 7.50 744.76 542-88-1 Bis(chloromethyl)ether 0.00 0.00 7.50 0.00 106-99-0 1,3-Butadiene 82.10 32.61 6.01 689.36 7440-43-9 Cadmium 88.38 89.68 7.25 1290.90 56-23-5 Carbon Tetrachloride 59.54 10.19 5.52 384.91 67-66-3 Chloroform 91.26 31.55 5.13 629.97 107-30-2 C hloromethyl methyl ether 0.00 0.00 7.50 0.00 XX Chlorophenols (mixed isomers) 68.01 21.79 4.78 429.22 7440-47-3 Chromium 145.01 90.56 6.65 1566.49 8001-58-9 Creosote 0.00 0.00 7.50 0.00 25376-45-8 Diaminotoluene 40.21 24.50 6.00 388.23 106-93-4 1.2-Dibromoethane 0.00 0.00 7. 50 0.00 91-94-1 3, 3'-Dichlorobcnzidine 34. 54 0.00 7. 50 259.04 107-06-2 1,2-Dichloroethane 93.33 23.98 5.13 601.82 75-09-2 Dichloromethane 76.34 20.69 5.33 517.17 542-75-6 L3-Dichloropropvlene 81. 17 0.00 7. 50 608.81 117-81-7 DiiZ-ethylhexyl) pthalate 115.48 0.00 5.97 689.42 77-78-1 Dimethyl sulfate 52.45 0.00 7.50 393.36 106-89-8 Epichlorohydrin 88.43 0.00 4.50 397.95 140-88-5 Ethyl acrylate 74.65 0.00 7.50 559.88 75-21-8 Ethvlene oxide 118.04 14.41 4.50 596.00 96-45-7 Ethylene thiourea 0.00 0.00 7.50 0.00 50-00-0 Formaldehyde 143.96 63.25 6.00 1243.25 302-01-2 Hydrazine 0.00 0.00 7.50 0.00 7439-92-1 Lead 144.32 101.52 6.39 1570.90 7440-02-0 Nickel 149.99 75.79 6.30 1422.42 N495 Nickel Compounds 131.45 59.65 6.30 1203.94 79-46-9 2—Nitropropane 30.85 0.00 6.00 185.07 1336-36 Polychlorinated biphenyls 0.00 0.00 7 .50 0.00 75-56-9 Propylene Oxide 119.57 17.83 3.25 446.54 100-42-5 Styrene 119.31 68.10 5.22 978.29 127-18-4 Tetrachloroethylene 97.25 0. 00 6.29 61 1.72 62-56-6 Thiourea 93.37 0.00 7.50 700.26 584-84-9 Toluene-2.4-diisocyanate 56.02 0.00 4. 50 252. 10 91-08-7 Toluene-2,6-diisocyanate 54.22 0.00 4.50 243.98 26471-62-5 Toluenediisocyanate 70. 18 19. 88 4. 50 405.24 95-53-4 o-Toluidine 52.98 34. 54 7. 50 656.41 88-06-2 2,4,6-Trichlorophenol 66.93 0.00 7.50 501.98 51-79-6 Urethane 0.00 0.00 7.50 0.00 75-01-4 Vinyl chloride 115.16 0.00 4.63 533.18 157 Appendix F Calculated Hazard Values for Specific C arcinogens Table 64 - 1993 Calculated Hazard Values for Specific Carcinogens CAS Npipber Chemical WHHE Will? THV 75-07-0 Acetaldehyde 58.87 0.00 4.65 273.73 79-06-1 Acrylamide 88.19 34.64 4.65 571.17 107-13-1 Acrylonitrile 109.81 44.79 3.07 474.61 7440-38-2 Arsenic 108.62 74.04 6.75 1232.91 1332-21-4 Asbestos (friable) 0.00 0.00 6.00 0.00 71-43-2 Benzene 97.52 49.91 4.83 712.10 7440-41-7 Beryllium 24.14 0.00 7.50 181.06 542-88-1 Bis(chloromethyl)ether 0.00 0.00 7.50 0.00 106-99-0 1.3-Butadiene 69.38 0.00 6.01 416.99 7440-43-9 Cadmium 86.68 84.89 7.25 1243.85 56-23-5 Carbon Tetrachloride 58.02 0.00 5.52 320.27 67-66-3 Chloroform 90.90 32.07 5.13 630.83 107-30-2 Chloromethyl methyl ether 40.62 0.00 7.50 304.66 XX Chlorophenols (mixed isomers) 67.66 22.17 4.78 429.36 7440-47-3 Chromium 150.20 92.48 6.65 1613.85 8001-58-9 Creosote 133.88 0.00 7.50 1004.08 25376-45-8 Diaminotoluene 51.54 34.36 6.00 515.35 106-93-4 1.2-Dibromoethane 0.00 0.00 7.50 0.00 91-94-1 3,3’-Dichlorobenzidine 34.54 0.00 7.50 259.04 107-06-2 1.2-Dichloroethane 99.09 24.14 5.13 632.18 75-09-2 Dichloromethane 75 . 21 20.47 5.3 3 510.01 542-75-6 liDichloropropylene 81.64 0.00 7. 50 612.27 117-81-7 Di-(2-ethy1hexyl) pthalate 126.72 53.56 5.97 1076.25 77-78-1 Dimethyl sulfate 52.45 0.00 7.50 393.36 106-89-8 Epichlorohydrin 80.53 0.00 4.50 362.39 140-88-5 Ethyl acrylate 73.69 0.00 7 .50 552.67 75-21-8 Ethylene oxide 117.99 14.41 4.50 595.81 96-45-7 Etlylene thiourea 0.00 0.00 7 .50 0.00 50-00-0 Formaldehyde 143.35 64.04 6.00 1244.33 302-01-2 Hydrazine 0.00 0.00 7. 50 0.00 7439-92-1 Lead 148.09 106.24 6.39 1625.17 7440-02-0 Nickel 150.47 72.89 6.30 1407. 18 N495 Nickel Compounds 123.16 44.43 6.30 1055.86 79-46-9 Z-Nitropropane 0.00 0.00 6.00 0.00 1336-36 Polychlorinated biphenyls 0.00 0.00 7 .50 0.00 75-56-9 Propylene Oxide 114.39 15.54 3.25 422.25 100-42-5 Styrene 121.74 76.51 5.22 1034.87 127-18-4 Tetrachloroethylene 94.63 3.95 6.29 620.04 62-56-6 Thiourea 93. 52 0.00 7. 50 701 .37 584-84-9 Toluene-2.4-diisocvanate 57.69 0.00 4.50 259.62 91-08-7 Toluene-2 .6-diisocyanate 54. 71 0.00 4. 50 246. 19 26471-62-5 Toluenediisocvanate 69.63 19.88 4.50 402.78 95-53-4 o-Toluidine 52.98 34.54 7.50 656.41 88-06-2 L4y6-Trichlorophenol 89.58 60. 38 7. 50 1 124.7 1 51-79-6 Urethane 0.00 0.00 7. 50 0.00 75-01-4 Vinyl chloride 113.60 0.00 4.63 525.98 158 Appendix F Calculated Hazard Values for Specific Carcinogens Table 65 - 1994 Calculated Hazard Values for Specific Carcinogens CAS Number Chemipajr WHHE WEE EF THV 75-07-0 Acetaldehyde 66.28 34.79 4.65 469.96 79-06-1 Acrylamide 89.82 34.16 4.65 576.51 107-13-1 Acrylonitrile 108.83 44.79 3 .07 471.62 7440-38-2 Arsenic 107.95 72.49 6.75 1217.95 1332-21-4 Asbestos (friable) 0.00 0.00 6.00 0.00 71-43-2 Benzene 97.61 47.19 4.83 699.38 7440-41-7 Beryllium 24.14 0.00 7.50 181.06 542-88-1 Bis(chloromethyl)ether 0.00 0.00 7 .50 0.00 106-99-0 11 3-Butadiene 74. 34 0.00 6.01 446.79 7440-43-9 Cadmium 95.66 101.00 7.25 1425.78 56-23-5 Carbon Tetrachloride 61.40 7.89 5.52 382.45 67-66-3 Chloroform 88.45 28.86 5.13 601.81 107-30-2 Chloromethyl methyl ether 26.88 0.00 7. 50 201.57 XX Chlorophenols (mixed isomerg 67.69 22.17 4.78 429.50 7440-47-3 Chromium 149.37 90.42 6.65 1594.63 8001-58-9 Creosote 134.46 0.00 7 .50 1008.47 25376-45-8 Diaminotoluene 51.54 34.36 6.00 515.35 106-934 1.2-Dibromoethane 0.00 0.00 7.50 0.00 91-94-1 3 . 3'-Dichlorobenzidine 34. 54 0.00 7.50 259.04 107-06-2 1.2-Dichloroethane 98.24 21.01 5.13 611.79 75-09-2 Dichloromethane 75.27 19.55 5.33 505.37 542-75-6 1.3-Dichloropropylene 81.89 0.00 7. 50 614.20 117-81-7 Di-(2-ethylhexyl) pthalate 129.47 0.00 5.97 772.95 77-78-1 Dimethyl sulfate 82.82 0.00 7 .50 621.16 106-89-8 Epichlorohydrin 79. 10 0.00 4. 50 3 55.96 140-88-5 Ethyl acrylate 102.62 0.00 7 .50 769.68 75-21-8 Ethylene oxide 117.26 14.41 4.50 592.50 96-45-7 EMene thiourea 0.00 0.00 7 .50 0.00 50-00-0 Formaldehyde 138.16 58.63 6.00 1 180.70 302-01-2 Hydrazine 0.00 0.00 7.50 0.00 7439-92-1 Lead 151.01 109.07 6.39 1661.90 7440-02-0 Nickel 146.17 64.62 6.30 1328.02 N495 Nickel Compounds 130.36 35.22 6.30 1043.19 79-46-9 2-Nitropropane 0.00 0.00 6.00 0.00 1336-36 Polychlorinated biphenyls 0.00 0.00 7.50 0.00 75-56-9 Propylene Oxide 116.07 15.54 3.25 427.71 100-42-5 Styrene 121.46 73.96 5.22 1020.08 127-18-4 Tetrachloroethylene 94.91 20. 10 6.29 723 .44 62-56-6 Thiourea 34.54 0.00 7.50 259.04 584-84-9 Toluene-2.4-diisocyanate 50. 19 0.00 4.50 225.86 91-08-7 Toluene-2.6-diisocyanate 54. 56 0.00 4. 50 245.51 26471-62-5 Toluenediisocyanate 73 .34 19.88 4.50 419.48 95-53-4 o—Toluidine 52.98 34.54 7.50 656.41 88-06-2 234,6-Trichlorophenol 103. 10 62.62 7.50 1242.85 51-79-6 Urethane 0.00 0.00 7. 50 0.00 75-01-4 Vinyl chloride 113.58 0.00 4.63 525.89