POLICYANALYSIS
TOXIC
CHEMlCALS
Are Toxics Release Inventory Reductions Real? THOMAS E. NATAN, JR. AND CATHERINE G. MILLER Hampshire Research Institute 1600 Cameron Street, Suite 100 Alexandria, VA 22314
Since 1987, U.S. industrial facilities have reported annually to the Toxics Release Inventory (TRI) the amounts of TRI-listed toxic chemicals they have released to the environment or transferred off site for treatment or disposal. Although the amounts reported have decreased over the years, TRI offers no explanation for the reductions. To determine the extent to which reported reductions are real and reflect facilities' source reduction activities, or instead arise only from paper changes in reporting, Hampshire Research conducted a telephone survey of 80 facilities that reported large decreases, from 1991 to 1994 in at least one TRI chemical. Hampshire found that just one tvDe of paper change redefining on-site recycling activities as in-process recovery which does not have to be reported accounted' for more than half of these facilities' 1QQ1-1QQ4 reportpH reductinnQ in the
amounts o f T"pi
chemicals thev generated in waste Reductions SDecificallv in the release and disnosal cateaorv however were much mnre likplv tn hp rpal V h a n g p s in plant nnpra tinns and nrnri r t i n n l P V P K a r m ntprl fnr °00/
oT ins TdciiitiGS reductions in rGiGSSG or GiS~ I
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posal. Few of these changes resulted in decreased use of toxic chemicals from source reduction activities.
368
A • AUG. 1, 1998 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS
The U.S. Toxics Release Inventory (TRI) was mandated by the Emergency Planning and Community Right-to-Know Act of 1986 (i). In the aftermath of the methyl isocyanate gas leak at the Union Carbide plant in Bhopal, India, a groundswell of citizen action in the United States arose, in which citizens demanded to know what chemicals industrial plants were using in their neighborhoods. Shortly thereafter, a small accidental release of aldicarb oxime and other chemicals occurred at the Union Carbide plant in Institute, W.Va. Some states, such as New Jersey, passed right-toknow laws that culminated in the federal TRI. Today, TRI is the best source of data nationwide on toxic chemical releases to the environment from manufacturing facilities and on how operational losses are managed as waste. Where they meet reporting requirements, facilities must submit a TRI form for each chemical. Public availability of TRI data has provided communities with information that allows them to approach facilities with a clear picture of their releases, rather than relying on facilities to provide the data. In turn, this knowledge has led to more constructive dialogue between facilities and communities, resulting in better community relations as well as in reductions in environmental releases and off-site transfers of waste (2). Source reduction as national policy The federal Pollution Prevention Act of 1990 mandated an environmental management hierarchy that made source reduction the preferred method of reducing environmental releases. Source reduction— reducing industrial pollution at the source—is defined as practices that reduce toxic waste generation, before any recycling, treatment, or disposal. Rather than generating waste that they must then manage, facilities take action to reduce or eliminate the toxic waste before it is generated, making waste management unnecessary. Many such projects focus on process or product changes that use less of the chemical or reduce the amount of it that enters the waste stream. Source reduction prevents pollution protects worker health, and reduces the potential for community exposure, as well as reducing treatment disposal and liability costs for the facility. In the environmental management hierarchy, wastes not amenable to source reduction should be managed by, in preferential order, recycling, energy recovery, and treatment. Any remaining waste would then, as a last resort, be released on site or sent off site for disposal. Facilities do not have to measure every release and transfer, but they must submit their best estimates. Through 1994, TRI covered some 300 toxic chemi0013-936X/98/0932-368AS15.00/0 © 1998 American Chemical Society
cals. The list expanded to about 600 beginning in 1995. Since 1991, TRI has also collected a broader range of waste management data about TRI chemicals, called for by the Pollution Prevention Act. Facilities report the amounts of TRI chemicals in waste that they recycle, burn for energy recovery, or treat on or off site as well as the amount they release or dispose of (see box at right). Together, they represent a facility's total production-related waste of a TRI chemical amounts of the chemical brought or produced on site that do not end up as or in product or inventory during the year. The release and disposal amount equates to the on-site releases and off-site transfers to disposal that have been reported to TRI from its inception. One-time releases, such as accidents or remedial cleanup operations are also reported but they are considered nonproduction-related. Reductions in releases and transfers are significant indicators of potential progress in reducing threats to human health and the environment from TRI-listed toxic chemicals. Knowing whether such reductions represent real progress is important. Because the Pollution Prevention Act promotes source reduction as a national policy, it is also important to know whether decreases in production-related waste are real. Changes in the amount of waste over time can indicate if the environmental management hierarchy is being followed. In theory, a decrease in production-related waste could be considered source reduction if it did not result from a decrease in production. In practice, this is not the case. Although the Pollution Prevention Act expanded the scope of industrial toxic waste data that TRI provides, these data fail to give a clear view of source reduction. Two information gaps account for this incomplete picture: The amount of waste not generated because of source reduction is not reported, and no explanation of year-to-year changes is supplied. Facilities do indicate what source reduction activities they have engaged in during the year, but this information cannot be directly linked to any specific reduction. They also report to TRI an index that compares current production with that of the prior year, but again this index cannot be linked to specific reductions. Changes in production tire but one ofseveral influences on a facility's waste generation and environmental releases. Measuring progress Assessments of industry's progress in source reduction since TRI was implemented usually rely in the first instance on release-and-transfer data, because this information has been collected from the origins of the program. Total releases and transfers have decreased steadily since 1988, the year that EPA uses as its baseline. Total releases have decreased 46% for TRI chemicals that have been continuously reported from 1988 to 1995, with no change in their reporting definitions, while off-site transfers to treatment and disposal of these chemicals decreased 36%. Since 1991, when TRI began collecting waste management data, production-related waste increased 7%. The portion of such waste released or disposed of, however, decreased 25% in that period (3). TRI does not require facilities to explain how these
Data reported to TRI Since 1991, facilities have had to report additional data to TRI. From 1987 to present
Added in 1991
On-site releases • Air emissions • Water discharges • Land disposal
Production-related waste • Release and disposal • On-site: recycling0, energy recoveryc, and treatment0 • Off-site: recycling0, energy recovery0 and treatment0
Off-site transfers • to treatment3 • to disposal
Nonproduction-related waste • Other0 due to accidents, spills, and remedial actions
a
Including publicly owned treatment works. Includes on-site releases and off-site transfers for disposal. c N e w requirement.
Why amounts reported to TRI can change Real changes Source reduction: In this study, source reduction includes changes in process or product that reduce chemical use or waste generated, as well as changes that add in-process recovery to existing operations. Source reduction activities include substitution of raw materials, changes in maintenance operations, product reformulations, process efficiency changes, and others. Selling waste as a product: Selllng as a product what was previously deemed a waste is not considered source reduction in this study, because it requires no changes in plant operations or actions to reduce chemical use. This practice does, however, result in real reductions in waste at the facility. Change in production level: :eclininn groduction nften, althhoug hot always, results in less waste generation. Paper changes Change in calculation method: Amounts reported to TRI can be estimates or measurements. A change from estimation to measurement, or a change in estimation method, may reduce the amount reported, but these revisions do not alter the physical amount of a chemical in waste or the amount released or disposed of. Change in definition: A facility may report on-site recycllng in one year, but decide not to report it in a subsequent year, considering the activity to be in-process recovery instead. If no new actions were taken to install in-process recovery, this is a definition change, which does not reduce the physical amount of the chemical in waste.
reductions occurred. Without asking facilities, it is impossible to determine whether reductions in releases since 1988 were accomplished by facilities' source reduction efforts or by their shifting the wastes to waste management options such as recycling, which was not reported to TRI before 1991 (see text box above). In addition, early studies (4,5) indicated that many decreases in industrial releases reported to TRI arose from paper changes, such as changes in estimation methods, rather than from actual reduction projects AUG. 1, 1998/ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS • 3 6 9 A
TABLE
FIGURE 1
TRI reporting by facilities
Changes in TRI reporting
Total production-related waste from all TRI facilities increased from 20.0 billion pounds in 1991 to 21.6 billion pounds in 1994, an increase of 8%. The quantity released and disposed of concurrently decreased from 2.6 billion pounds to 2.2 billion pounds, or 17%. The 80 facilities in this survey reported a reduction of 3.8 billion pounds in productionrelated waste and 218 million pounds in release and disposal.
The net change in all TRI reporting of productionrelated waste was about 1.6 billion pounds. TRI reports of the 80 surveyed facilities accounted for 47% of all TRI-reported production-related decreases. From 1991 to 1994, nearly 1900 facilities reported a decrease in release and disposal for at least one TRI chemical, amounting to a reported total decrease of 1.2 billion pounds, or 61%, in the release and disposal quantity. The survey analyzes 218 million pounds (19%) of these decreases.
Change 1991 to 1994
1991 Millions of pounds
1994 Millions of pounds
Millions of pounds
Percent
20,031 2595
21,637 2159
1606 -436
8.0 -16.8
TRI forms with decreases in production-related waste from 1991 to 1994 4891 From all TRI facilities 12,881 962 From surveyed facilities 4712
-7990 -3750
-62.0 -79.6
TRI forms with decreases in release and disposal from 1991 to 1994 727 From all TRI facilities 1885 98 From surveyed facilities 316
-1158 -218
-61.4 -69.0
All TRI facilities Production-related waste Release and disposal
Note: Chemicals added, redefined, or deleted from TRI list since 1988 are not included. Ozone depleters are not included. Metals and associated compounds are combined. Source: Data are from Reference 9.
(see text box on previous page). In some cases, industrial facilities with nearly identical operations could report data that differed by more than 100%, just by the choice of estimation method. EPA itself chose 1988 as its baseline year for comparisons, rather than 1987. A study comparing 1987 with 1988 data found that many of the reductions seen in the second year of TRI were not real (6). Some facilities, for example, reported in the first year on their nonmanufacturing operations, although TRI is limited to manufacturing. When the facilities did not subsequently report on these operations, apparent reductions in releases and transfers occurred. For many facilities, the first year's estimates were followed in later years by reporting based on more precise analysis and measurement of chemicals in the waste stream. Again, apparent reductions resulted, quite apart from any real change in the amounts of TRI chemicals released or transferred. As part of a previous analysis for Toxics Watch 1995 (7), a study conducted for INFORM with support from EPA and others, the Hampshire Research Institute contacted facilities with large increases and decreases in production-related waste between 1991 and 1992 to determine why these reported changes occurred. The majority of the reported large changes in production-related waste were due to redefining on-site recycling rather than actual reduction activities. The Pollution Prevention Act allows facilities not to report inprocess recovery—the amounts recycled where the recycling is "integral to and necessary for the production of a product" (8). Several technical terms, such as "recirculation" and "hard-piped recycling," apply to this 3 7 0 A • AUG. 1, 1998 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS
Note: Chemicals added, redefined, or deleted from the TRI list since 1988 are not included; ozone depleters are not included; and metals and associated compounds are combined.
type of recycling. The descriptor, "in-process recovery," was chosen to avoid confusion among the types of recycling. Neither the Pollution Prevention Act nor the TRI reporting instructions, however, define inprocess recovery. A facility may report a drop in its quantity recycled on site to zero simply by reclassifying this recycling as in-process recovery. If the facility does this without revising reports for previous years, a paper reduction appears. Similarly, deciding that an operation is not in-process recovery could result in an apparent increase in on-site recycling, even though the process has not changed. Without actually contacting the facilities, it is impossible to determine whether changes in production-related waste were real or simply redefinitions.
Framing the analysis TRI does not collect information on the amount of waste not generated due to source reduction. The
FIGURE 2
TABLE 2
Influence of ozone depleters on TRI reporting
Reductions in production-related waste
Production-related waste of all TRI chemicals increased 7% during 1991-1994; however, the exclusion of ozone depleters raises this increase to 8%. Excluding ozone depleters changes the decrease in release and disposal from 21% to 17%.
Of real reductions in production-related waste between 1991 and 1994 for facilities surveyed, 61% arose from innovative source reductions representing a change in product or process that resulted in chemical use reduction and 16% reflected installation of in-process recovery systems. Paper changes accounted for 51% of the decrease in production-related waste among facilities contacted for this study. The vast majority of these (82%) were reclassifications of existing activities as in-process recovery.
Note: Chemicals addedd redefined, or deleled from the TRT list since 1988 are not included.
FIGURE 3 Real versus paper reductions Real reductions (process and product source reductions, installation of new in-process recovery equipment, recovering waste to sell as product, decreases in production, and one-time activities) accounted for 38% of the decrease in production-related waste. Of the reductions in release and disposal between 1991 and 1994 for surveyed facilities, only 8% were paper changes, or changes in estimation method rather than in-plant operations, while 92% arose from real nhannss in antivity.
Note: Chemicals added, redefined, or deleted from the TRI list since 1988 are not included; ozone depleters are not included; and metals and associated compounds are combined.
only way to gather information on amounts of source reduction is to contact individual facilities. This study endeavors to determine how much source reduction has been occurring since the Pollution Prevention Act was implemented and to see whether paper changes continue to be prevalent. Hampshire Research Institute contacted me 80 facilities widi the largest reductions in production-related waste from 1991 to 1994, the most recent data available at the time of the survey. Each facility had reduced production-related waste by at least 10 million pounds for at least one chemical. For any chemical for which the waste was reduced by at least 1 million pounds, facilities were asked to explain the reasons for re-
ported reductions and, in particular, for any decreases in die portion of production-related waste reported as release and disposal. The study focused on production-related waste, because source reduction is concerned with reducing waste generated as well as releases and transfers. Analyses looked at total production-related waste and, more closely, at die release and disposal quantity within that total. Total production-related waste from all TRI facilities (9) is indicated in Table 1. The 80 facilities in this survey played a notable role in TRI reductions over the time period analyzed (Figure 1). All data reflect the chemical coverage and reporting described below. Of the nearly 25,000 facilities reporting to TRI from 1991 to 1994, some 15,000 showed a decrease in production-related waste for at least one chemical from 1991 to 1994. Together, these facilities accounted for a decrease of 8.0 billion pounds, or 62% of dieir 1991 production-related waste (Table 1). The 80 facilities selected for this study accounted for 3.8 billion pounds of the decrease. This analysis excludes chemicals that were added to the TRI list, redefined for reporting purposes, or deleted since 1988, TRI's baseline year. Metals were summed with their metal compounds for each facility to determine total decreases for diose particAUG. 1, 1998/ENVIRONMENTAL SCIENCE & TECHNOLOGY/NEWS • 3 7 1 A
TABLE 3 Top six real reductions in TRI chemicals in production-related waste The top reductions in production-related waste, reported by five facilities, amounted to nearly 556 million pounds of TRI chemicals over this time period. Chemical/activity
Facility
Reduction, pounds
National Co-op Refinery, Propylene McPherson, Kans. Reduced on-site energy recovery by improving C 3 /C 4 split
257,015,772
Phillips 66 Company, Old Ocean, Tex.
113,797,448
Cyclohexane Increased process efficiency for on-site recycling
Champion International, Chlorine Courtland, Ala. Reduced on-site treatment by switching to chlorine dioxide bleaching
53,889,600
National Co-op Refinery, Ethylene McPherson, Kans. Reduced on-site energy recovery by improving C 3 /C 4 split
47,291,124
Vista Chemical, Westlake, La.
Hydrochloric acid Reduced on-site treatment by selling the waste as product
45,463,693
Neste Resins, Winnifield, La.
Formaldehyde Reduced on-site treatment by selling the waste as product
38,212,086
Note: Chemicals added, redefined, or deleted from TRI list since 1988 are not included. Ozone deDleters are not included.
ular substances, because facilities often report for a metal one year and its compound category the next (for example, lead versus lead compounds). Ozonedepleting chemicals were also excluded from this study because the United States has restricted their production and use, in adherence to the Montreal Protocol. These chemicals had a substantial impact onTRI reporting between 1991 and 1994 (Figure 2). All amounts of chemicals analyzed in this study are those that facilities reported to TRI in 1991 and 1994. Data are not normalized, for example, for production changes: The survey sought to determine reasons for the changes, including differences in production levelfromyear to year Moreover no revisions made to facility data except to exclude all reporting forms submitted for chemicals added, redefined or deletedfromTRI over the years and all forms for ozone depleters Facility responses Facility representatives, usually the TRI technical contact, were phoned and asked to characterize the waste reduction in general terms, but with enough detail to fit, where possible, into these categories: • change in activity—a change in process or product to use less of the specific chemical; • change in definition of process—such as paper changes from on-site recycling to in-process re3 7 2 A • AUG. 1, 1998 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS
covery or reclassifying on-site energy recovery to fuel consumption; • change in calculation method; or • decrease in production. Facilities also gave other reasons to account for waste reduction, including selling the waste as product, installing a new in-process recovery system, outsourcing the process, one-time or periodic activities such as maintenance, and errors either in the TRI database or in their own reporting. The facility representatives usually had no difficulty in supplying a reason for the decrease in production-related waste. Very few expressed concern about confidentiality, probably because they were not being asked for truly specific information. They were only asked to provide enough detail to verify the reasons they stated for the decrease. Occasionally, a follow-up call was necessary to clarify details. The survey succeeded in accounting for 97% of the waste reduction reported by the targeted facilities. About 3% could not be accounted for because facility representatives could not be reached or were not able to characterize the reduction. It should be emphasized that Hampshire Research Institute took the facilities at their word for their explanations and questioned the facility representatives further only when an explanation was confusing or at odds with the data. Some decisions to label an activity in-process recovery, as described in the telephone conversations, strain credibility. In addition, some facilities installed systems that they designated as inprocess recovery that should in fact have been considered on-site recycling, reportable to TRI. Nonetheless, Hampshire Research Institute did not secondguess facilities' reclassification of activities, because the survey sought to identify the reasons for changes in the data actually reported to TRI. Reductions in production-related waste between 1991 and 1994 for facilities surveyed are indicated in Figure 3 and Table 2. Half of the total decrease arose from paper changes, especially redefining existing activities as in-process recovery (Table 2). Descriptions of the six largest real reductions in production-related waste (other than quantity released and disposed of) appear in Table 3. These were accomplished by five of the facilities surveyed. On the other hand, many more of the reductions in release and disposal appear to be genuine (see Table 4). Figure 3 also shows reductions in the release and disposal of TRI chemicals between 1991 and 1994 for facilities in this study. The five largest real decreases in the quantity released and disposed of appear in Table 5. Some efficiency gains reported by facilities studied were from plants or processes that began operation late in 1990, whose higher 1991 waste quantities came from variations in the first full year of operation. As operators became more familiar with the equipment and processes, operations were made more efficient, and production-related waste quantities decreased. Some 350 million pounds of reduction in production-related waste can be attributed to decreases from first-year operations among facilities contacted for this study. These changes are con-
sidered process and product modifications because they were described that way, but they should also be distinguished from modifications to longstanding processes and products for which reduction opportunities were less evident to the facilities. Another significant feature of real decreases in production-related waste is the amount of research and development recounted by facilities that installed what they called in-process recovery units. This was particularly true among battery manufacturers, who invested large amounts of time and money in determining how much waste mat contained lead compounds could be used in individual new battery products without compromising product quality. Although facility representatives were not asked specifically what motivated reduction projects, not surprisingly the majority of respondents cited cost of raw materials and costs of off-site transfers of wastes as primary reasons for undertaking projects, especially for installing in-process recovery and selling waste streams as product. In the latter case, however, it was also clear that should the market price for the product fall, the facilities would consider shipping the waste off-site again.
Interpretation of findings Lack of a definition for on-site recycling is clearly distorting the reporting of production-related waste. Nearly 42% of the reported waste decrease between 1991 and 1994 for facilities in this study was a paper change from on-site recycling to inprocess recovery (Table 2). Although the studies for Toxics Watch 1995 (7) also indicated that paper increases in on-site recycling could offset the decreases in the national production-related waste totals, paper reductions definitely have an effect on analysis of individual facilities and reductions. Many of these illusory reductions could be eliminated if facilities would revise previous years' data for consistency, regardless of the definition they choose. This is not a particularly difficult task when on-site recycling drops to zero. In survey conversations, Hampshire Research Institute recommended that facilities revise their data. Many representatives were reluctant to file revisions because there is no compelling reason to do so, given what they view as EPA's slow track record at entering revisions into the TRI database. Not only does the TRI program not require facilities to revise the data, because these are changes in estimation methods and not errors, but many facility contacts stated that they do not use their TRI Section 8 data for in-house tracking of WclSte 2611CFcition Others were reluctant to file revisions that might cause a re-examination of their data as a whole The end result is that it is still not possible to attribute a decrease in production-related waste to real reductions without checking with the facilities Widespread reporting of paper changes also results in underestimating the percentage reduction brought about by changes in plant operations. When paper changes are eliminated from the totals, source reduction activities (process and product changes and installation of in-process recovery systems) account for 77% of the real reduction in production-related waste
TABLE 4 Reductions in release and disposal Real reductions account for 92% of total reductions, including 47% from installation of in-process recovery systems and 40% from selling waste as product. However, only 5% of the real reductions were from innovative source reduction activities. Release and disposal Reduction, millions of pounds
Percent of total
Total decrease for facilities surveyed
218
100.0
Real reductions Source reduction Process/product changes Install in-process recovery Sell waste as product Decrease in production One-time activities
201 114 10 103 88 0 0
92.4 52.1 4.7 47.4 40.2 0.0 0.0
100.0 56.4 5.1 51.3 43.6 0.0 0.0
17 0 2
7.6 0.0 0.7
100.0 0.0 9.5
15
6.9
90.5
0
0.0
Paper changes Redefine to in-process recovery Redefine on-site energy recovery/treatment Change calculation method Other
Percent of subcategories
Note: Chemicals added, redefined, or deleted from TRI list since 1988 are not included. Ozone depleters are not included, Metals and associated compounds are combined.
TABLE 5 Top five real reductions in release and disposal of TRI chemicals Reductions reported by the top five facilities amounted to more than 177 million pounds of TRI chemicals during this time period. Reduction, pounds
Facility
Chemical/activity
IMC-Agrico, Saint James, La.
Phosphoric acid In-process recovery
72,714,807
IMC-Agrico, Uncle Sam, La.
Phosphoric acid In-process recovery
30,566,772
Vulcan Chemicals, Wichita, Kans.
Hydrochloric acid Sell waste as product
29,681,202
Inland Steel, East Chicago, Ind.
Manganese compounds Sell waste as product
27,585,965
DuPont, Louisville, Ky.
Hydrochloric acid Sell waste as product
16,766,871
Note: Chemicals added, redefined, or deleted from TRI list since 1988 are not included. Ozone depleters are not included.
for facilities in this study, with decreases in production accounting for 9% (Table 2). The picture is quite different for release and disposal (Figure 3). Although some facilities are still changing their estimation methods, particularly for fugitive air emissions, the bulk of these reductions are genuine and represent a real environmental benefit. The majority of release and disposal reductions AUG. 1, 1998 / ENVIRONMENTAL SCIENCE & TECHNOLOGY / NEWS • 3 7 3 A
for facilities in this study were made by installing inprocess recovery systems. These accounted for more than half (56%) of the real reductions in quantities released and disposed of (Table 4). Another significant contribution to TRI release and disposal reductions came from facilities' recovering waste streams and selling them as product, especially acid streams (Table 5). However, only 5% of the reductions were made by changes to process or products that resulted in decreased chemical use (Table 4), as opposed to 23% for production-related waste as a whole (Table 2). This suggests that facilities still look to the end of the pipe in making reductions to release and disposal systems, rather than altering their products or processes significantly. That paper changes accounted for half of the largest reductions in production-related waste of TRI chemicals from 1991 to 1994 emphasizes the importance of EPA's lack of definition of on-site recycling. Without official guidance, such changes remain at the discretion of reporting facilities. That paper changes amounted to only 8% of the reductions in release and disposal, however, indicates that facilities' changes in measurement methodology may be stabilizing. Earlier studies that found higher rates for unreal reductions also depended on reporting prior to 1991, where transfers to recycling were not clearly separated from other types of off-site transfers. This has been corrected with the additional reporting elements. Among real reductions in release and disposal, this survey shows relatively little progress in innovative source reduction between 1991 and 1994, the highest priority of the environmental management hierarchy.
For the facilities surveyed (those with the largest reductions in production-related waste), installation of in-process recovery systems and recovery of waste streams to sell as product far outweighed more innovative activities. Just 5% of the release and disposal reductions resulted from direct actions, such as changes to process or product, intended to reduce toxic chemicals in waste before they occur. Acknowledgments Hampshire Research Institute thanks facility representatives contacted for this study for their time and assistance. This project was supported by EPA under cooperative agreement X822086-01-0.
References (1) Superfund Amendments and Reauthorization Act. PuPlib Law 99-499, Title III, Section 313, 1986. (2) The Right Stuff: Using the Toxic Release Inventory, OMB Watch and Unison Institute: Washington, DC, luly 1995. (3) Toxics Release Inventory: Public Data Releasel 1995; U.S. Environmental Protection Agency, U.S. Government Printing Office: Washington, DC, April 1997. (4) Manufacturing Pollution: A Survey of the Nation's Toxic Polluters; Citizens Fund: Washington, DC, May 1990. (5) Fisher, R. A.. Lev-on, M. On TRI Data Usage: Pitfalls and Benefits. Presented at the AIChE Summer National Meeting, Seattle, WA, August 16, 1993. (6) Phantom Reductions: Tracking Toxic Trends; National Wildlife Federation: Washington, DC, August 1990. (7) Toxics in Waste: Overview and Key Facilities and Methods of Calculating On-site Recycling. Toxics Watch 1995; INFORM: New York, NY, ,1995 Chapter 4 and Apppndix B. (8) Pollution Prevention Act. Public Law 101-508, Sectton 6603 (4)(B), 1990. (9) Toxics Release Inventory: Public Data Releasel 1994; U.S. Environmental Protection Agency, U.S. Government Printing Office: Washington, DC, lune 1996.
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