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A Clearer View New Jersey’s Reporting Requirements as a Model for the United States A Preliminary Report by INFORM of Toxics

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Page 1: A Clearer View of Toxics · 2018-06-13 · A Clearer View of Toxics: New Jersey’s Reporting Requirements as a Model for the United States INFORM, Inc., is a nonprofit environmental

A Clearer View

New Jersey’s Reporting Requirements as a Model for the United States

A Preliminary Report by INFORM

of Toxics

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INFORM, Inc. 381 Park Avenue South New York, NY 10016-8806

Tel 2 12-689-4040 Fax 212-447-0689

© 1994 INFORM, Inc. All rights reserved Printed in the United States of America

A Clearer View of Toxics: New Jersey’s Reporting Requirements as a Model for the United States

INFORM, Inc., is a nonprofit environmental research organization that identifies solutions to problems related to chemical hazards, municipal solid waste, and air quality and alternative fuels. Founded in 1974, INFORM publishes its research in books, reports, articles, and a quar- terly newsletter. INFORM is supported by individual, foundation, gov- ernment, and corporate contributions.

Printed on recycled paper

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Table of Contents

Glossary

Introduction This INFORM report

The need for public information New Jersey's Law: Showing the Way The National TRI: What's Missing Lessons from New Jersey Federal and State Proposals Methodology

Charts and diagrams: Comparing New Jersey DEPE and EPA/TRI reporting requirements at four New Jersey plants

Bar chart: Merck & Co. (Rahway) dichloromethane reporting data Diagram: Merck & Co. (Rahway) 1991 dichloromethane waste and

product streams Bar chart: General Electric Co. (Moorestown) Freon 113 reporting data Diagram: General Electric Co. (Moorestown) 1991 Freon 113 waste

and product streams Bar chart: Amerada Hess (Woodbridge) anthracene reporting data Diagram: Amerada Hess (Woodbridge) anthracene waste and product

streams Bar chart: Okonite (Paterson) lead reporting data Diagram: Okonite (Paterson) 1991 lead waste and product streams

Federal and State Proposals: Reducing Public Information

Effects of 5000-pound release/transfer cutoff (proposed on the national level)

Charts and diagrams: Comparing New Jersey DEPE and EPA/TRI reporting requirements at four New Jersey plants of chemicals that are released by those plants in quantities of less than 5000 pounds

Bar chart: Shell Oil Co. (Woodbridge) benzene reporting data Diagram: Shell Oil Co. (Woodbridge) 1991 benzene waste

and product streams Bar chart: Dupont Chemicals (Pennsville) phosgene reporting data Diagram: Dupont Chemicals (Pennsville) 1991 phosgene waste and

product streams

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Bar chart: Kuehne Chemical Co. (Kearny) chlorine reporting data Diagram: Kuehne Chemical Co. (Kearny) 1991 chlorine waste and

product streams Bar chart: Hatco Corp. (Woodbridge) phosgene reporting data Diagram: Hatco Corp. (Woodbridge) 1991 phosgene waste and

product streams

Effects of redefining "pollution prevention" (Proposed in New Jersey)

Maps: Chemicals transferred to and from New Jersey counties for recycling in 1991 Chemical recycling in New Jersey: All chemicals transferred into and

Recycling carcinogens: Carcinogens transferred into and from New

Recycling metals: Metals transferred into and from New Jersey counties

from New Jersey counties for recycling

Jersey counties for recycling

for recycling

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Glossary

Anthracene Used widely in dyes and petroleum process- ing. The chemical bioaccumulates in the environment.

Benzene A volatile solvent known to cause cancer in humans.

Bioaccumulators Chemicals that build up in organisms, such as fish and plants, and can have adverse effects on both human health and the environment. INFORM has in- cluded in this category all 22 chemicals defined by US EPA as bioaccumulators (1991 Toxics Release Inventory,

Carcinogen A chemical that may cause cancer. The list of chemicals considered carcinogens for this report’s tables and fact sheets includes 123 chemicals and is taken from the Occupational Safety and Health Administration (OSHA) hazard communications standards (29 CFR 1910.1200). US EPA has used this list in the past to define carcinogens, such as in the EPA report Toxics in the Com- munity (EPA560/4-92-014, September 1991, the last TRI report published by EPA).

Chlorine Chlorine, used in the manufacture of paper, plastics, and chlorinated chemicals, is especially toxic to the lungs when inhaled in concentrated form; chlorine is also of concern because it forms chlorinated organic com- pounds, which can have significant adverse effects on human health.

Dichloromethane Dichloromethane (also known as methylene chloride or methylene dichloride) causes toxic effects to the brain and/or nervous system and is also a known human carcinogen.

Freon 113 Freon 11 3, when released into the environ- ment, depletes the earth’s ozone layer, which may result in increased skin cancers and devastating effects on plant life.

Lead Lead is extremely toxic to almost every organ in the body, including the brain, liver, kidneys, and the blood. No safe level of exposure has been determined for lead.

EPA 745-R93-003).

Non-product output Total waste generated prior to re- cycling, treatment anddisposal. Using New Jersey through- put data this figure can be calculated as follows: (starting inventory + quantity brought on-site + quantity produced) - (quantity consumed in the process + quantity shipped off-site as product + ending inventory).

Off-site transfers Chemical wastemovedoff the grounds of a facility. The chemical may have been moved for pur- poses of recycling at a recycling plant or for transfer to a treatment, storage, or disposal facility: either a hazardous waste facility, a publicly-owned sewage treatment plant, or a municipal landfill. The transfer may result in some of the chemical in the waste being released to the environ- ment.

Ozone depleters Chemicals known to deplete the earth’s ozone layer. INFORM included as ozone depleters all 11 chemicals defined as ozone depleters by US EPA (I991 Toxics Release Inventory EPA 745-R-93-003).

Phosgene is used extensively in industrial processes; the chemical is extremely toxic, especially to the liver, kid- neys, and lungs.

Pollution prevention Industrial pollution prevention refers to industrial source reduction and/or toxic chemical use reduction. It does not include any type of waste man- agement, such as recycling or treatment of pollutants. As it is likely that some of a chemical will be released during its use in the facility or during recycling, pollution preven- tion is a more effective strategy than recycling for reduc- ing the total amount of toxic chemicals released into the environment.

Recycling Chemical recycling entails reprocessing and/ or repurifying chemical waste so that a chemical may be used again. Recycling, however, is not 100 percent effi- cient. Some of the chemical will be lost in the recycling process and may be released into the environment. Addi- tionally, it is likely that some of the chemical was released into the environment during its use in the facility. Thus,

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pollution prevention, in which the amount of toxic chemi- cal used is decreased from the start, is much more effec- tiveinreducing the total amount of toxic chemicals released into the environment.

Releases Chemicals released to the air, water, or land at the site of the reporting facility.

Releases and transfers Chemicals released to the air, water, or land or transferred to another facility which then treats, stores, or disposes of the chemical waste.

Source reduction A strategy for reducing pollution that involves preventing the generation of waste in the first place rather than cleaning it up, treating it, or recycling it after it has been produced. Industrial source reduction is included in the definition of pollution prevention, and some consider source reduction a more precise term. The following definition is taken primarily from the Federal Pollution Prevention Act of 1990: Source reduction in- cludes practices that 1 .) reduce the amount of any pollut- ant entering any waste (pollutant) stream or otherwise released into the environment; and 2.) reduce the hazards to public health and the environment associated with the release of pollutants. The term includes equipment or technology modifications, process or procedure modifi- cations, reformulation or redesign of products, substitu- tionofraw materials, andimprovementsin housekeeping, maintenance, training, or inventory control.

Use A term employed throughout this report, use is de- fined as the starting inventory of a chemical, plus the amount produced, plus the amount brought on-site, minus the ending inventory.

Waste Chemicals released to the air, water, or groundwa- ter; chemicals disposedof on landon-site; chemicals trans- ferred off-site; and chemicals destroyed on-site by treatment. Waste generated by a plant can be calculated two ways:

Using the throughput data reported under the New Jersey Community Right-to-Know Act, total waste generated equals (starting inventory + quantity brought on-site + quantity produced) - (quantity consumed in the process + quantity shipped off-site as product + ending inventory).

Using the releases and transfer information re- ported under both US EPA's Toxics Release In- ventory and New Jersey's Community Right-to- Know Act: total waste generated equals releases + on-site land disposal + off-site transfers + quan- tity destroyed on-site.

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Introduction In just 50 years, in the United States and aroundthe world, we have seen the explosive growth of the synthetic or- ganic chemical industry — an industry whose myriad industrial and consumer products have made it central to our ways of living inindustrialized societies. But the great contribution these products have made to modem life — in the form of plastics, solvents, adhesives, pharmaceuti- cals, and much more — has also resulted in the prevalence of toxic chemicals in use and in widespread environmen- tal contamination.

Facilities making and using chemicals in this country number more than 200,000, and the number of chemicals actually produced and in commercial use has grown to more than 70,000 — with another thousand coming into commerce each year. With the rapid growth of the chemi- cal industry has come public concern for the potential risks to our health and the environment posed by the vast array of toxic chemicals in our society. The health and environmental risks associated with only about 10 per- cent of the chemicals are understood; potential threats posed by more than 90 percent of the thousands of chemi- cals in our midst have never been well characterized. And with public concern has come an awareness of the impor- tance of solid, thorough information — providing a full picture of the use and movement of these toxic chemicals as a basis for evaluating their impact.

This INFORM Report This INFORM report presents both an analysis of the in- depth data on toxic chemical uses and wastes required of industry by one state -New Jersey - and a comparison of such thorough reporting with the much narrower data requirements imposed by the federal government through its Toxics Release Inventory (TRI). This report also as- sesses the likely impact of proposals now being debated in New Jersey and in Washington, DC, that would weaken reporting. New Jersey’s proposal would cloud the state’s data that now clearly show what progress companies are making in reducing their waste at the source - a goal

recognized by the US Environmental Protection Agency (EPA) and business leaders as the top priority.

The Need to Monitor Chemical Use Information about the chemicals that are known or sus- pected to be toxic or hazardous is crucial on several ac- counts:

As a basis for assessing the threats they pose to workers, the community, and the environment.

As a means of tracking regional and national trends that may reveal damage to public health or to our air, land, and water in the future.

As an aid to assessing problems related to toxics in products.

As a tool for evaluating progress in toxics use and source reduction and in making companies accountable for the proper handling of toxic materials.

All of the more than 300 chemicals for which reports must be filed with both the New Jersey Department of Environ- mental Protection and Energy (DEPE) as well as the US EPA are federally recognized as toxic or hazardous sub- stances. Every one has a capacity, depending on the type of chemical and the degree and duration of exposure, to damage human health or the environment. Some, like benzene, vinyl chloride, and dichloromethane, can cause cancer. Others, like phosgene and lead, can cause nerve damage. Still others, like chlorine, are both toxic and highly reactive. In New Jersey alone, 700 facilities reported use of more than 15 billion pounds of toxic chemicals in 1991, the last year for which data have been analyzed.

From the moment any of these chemicals are brought into a plant site - as they are stored on the site, moved from one storage vat or tank to another, used in production, integrated as constituents of products - they pose poten- tial risks of routine or accidental human and environmen- tal exposures. When they leave the plant as part of product, depending on their handling, they may create risks in prod- uct use, recycling, or disposal.

When chemicals are lost from the industrial process as

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waste — whether as emissions into the air, water, or land or as transfers to ‘other sites for recycling, treatment, or disposal - again, depending on how they are managed, they may pose risks. Furthermore, efforts needed to pre- vent exposure and adverse effects associated with use and releases are expensive and time-consuming to businesses, government agencies, and other oversight groups.

The only totally safe ways to protect workers, the public, or the environment from the toxic risks posed by these chemicals in use are to use them in closed systems or to substituteless toxic chemicals. The only totally safewaste stream is one that is not created in the first place; hence, in recent years, focus on waste treatment and disposal has given way to recycling and “source reduction” as the high- est priority, front-line response to the toxic chemical waste challenge. The safety of products containing toxic chemi- cals is more and more being considered the responsibility of manufacturers as stewards for safe use.

The Need for Public Information Amazing as it may seem, until 1984 there was no public accounting of the toxic chemicals in use or in discharges into the air, water, and land. Neither the Federal nor state governments required information that would give our public leaders or communities any overview of the use, movement, and disposal of toxic materials.

The single exception was an obscure toxic chemical in- dustrial research survey conducted by New Jersey envi- ronmental officials in the late 1970s. In this survey, all of the state’s thousands of chemical-using and waste-gener- ating facilities were asked to voluntarily provide facts, on a chemical-by-chemical basis, on the use, storage, and discharge as waste of 155 chemicals. This survey served as the model for New Jersey’s 1984 Community Right-to- Know Act; unearthed and publicized by INFORM in 1985- 86, it also inspired the national Toxics Release Inventory, mandated by Congress in 1986, that is discussed below.

New Jersey’s Law: Showing the Way New Jersey’s 1984 law made the state’s original research survey mandatory. New Jersey thus became the first state — and remains one of the very few states — that requires the reporting of data on toxic chemicals both as waste and at key stages of the production process. New Jersey’s sur- vey offers the most complete picture now available of the

path followed by toxic chemicals in the state. The Act requires that facilities making and using threshold amounts (manufacture of 25,000 pounds or use of 10,000 pounds a year) of the target toxic chemicals — which also make up the national TRI list - report annually on a chemical- by-chemical basis these key pieces of data: Chemical Uses Product Stream)

The amount brought onto the plant site.

The amount in inventory at the beginning and end

The amount produced on the site.

The amount consumed in production.

The amount going into products shipped off site.

The amount of waste generated before recycling, treatment, or disposal (known as “non-product

of each year.

Chemical Waste Waste Stream)

output”). Releases to air, land, and water.

Off-site transfers to recycling, treatment, and dis- posal.

These data are essential though not always sufficient to assess: 1.) the possible effects of hazardous substances on workers, including the risk of possible accidents; 2.) the risks to local community health and safety posed by the chemicals’ storage, transport, use, and discharge of waste; and 3.) the potential risks of products containing toxic constituents once they’ve left the plant as product and are integrated into the commercial stream.

The National TRI: What’s Missing The results of New Jersey’s original survey of the late 1970s generated national debate over the need for public information on toxics. This led in 1986 to Congress’s in- cluding a provision in the Emergency Planning and Com- munity Right-to-Know Act (the re-authorized Superfund law) requiring the Environmental Protection Agency to initiate a national Toxics Release Inventory (TRI). This marked a revolutionary improvement nationwide in pub- lic information on chemical waste. Published annually are reports to EPA, from nearly 24,000 (in 1991) facilities, of environmental releases and off-site transfers of more than 300 individual toxic chemicals and chemical categories. TRI’s annual figures, tallied and made widely available to the public, have provided government, business, and citi- zens alike withnational and local insights into US industry’s releases, into the air, land, and water, and its transfers, to

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waste treatment, recycling, and disposal sites, of toxic chemicals.

As a result of the 1990 Pollution Prevention Act, other data elements were added to make it possible to determine the total “non-product output” — important to any assess- ment of annual progress toward source reduction. The data have been widely used by local and national environ- mental and citizens groups to hold plants accountable for their waste and to negotiate environmental changes — particularly source reduction, instead of costly end-of- the-pipe waste management. The TRI data have become the main measurement chemical companies point to in publicly affirming their progress in managing their wastes - and especially in reducing them at the source.

But the national TRI data provide the basis for assessing only those potential risks caused by toxic waste, not their general presence at reporting facilities and in their prod- ucts. Valuable as they have been, the TRI statistics do not provide a full view of the role of toxics. They cover only the waste stream; they do not provide information on the product stream beyond estimates of the maximum quan- tities of TRI chemicals stored on-site. A shortcoming of both the TRI and New Jersey programs is that only about 300 of the toxic chemicals in use are included. Furthermore, TRI covers only chemical manu- facturing and processing facilities, not the many busi- nesses that use chemicals. And they cover, as noted earlier, only a small percentage of those chemical producers: manu- facturers and processors of more than 25,000 pounds of any listed chemical, and other users of at least 10,000 pounds.

EPA is considering doubling the numbers of reportable chemicals to include others that are internationally recog- nized as toxic. Even then, however - because the TRI reports only emissions into the environment and transfers of waste to other sites - it will still fail to give us the full picture: It will not tell us about the toxics that come into a plant, that are used and stored in it, and that leave it as product. (And, as discussed below, EPA is also consider- ing a proposal that would base the thresholds for reporting on amounts of chemical releases in addition to levels of manufacture and use - a change that would vastly reduce public information vital to evaluating environmental and public health threats and trends.)

Lessons from New Jersey What can we learn from New Jersey’s more thorough data? A few examples from INFORM’S analysis of the 199 1

data illustrate their immense value:

TRI data revealed that more than 203 million pounds of the 300-plus reported toxics were gen- erated as waste and were either released to the en- vironment or transferred elsewhere for recycling, treatment, or disposal. The New Jersey data re- veal, in addition to the waste numbers, a total use of all TRI chemicals amounting to nearly 15.2 bil- lion pounds.

Within this category of use, the New Jersey survey docu- ments:

Total use of carcinogens was reported by 210 fa-

More than 717 million pounds of metals and cilities at more than 1.5 billion pounds.

metal compounds was reported used by 210 fa- cilities. Nearly 90 million pounds of chemicals that ac-

cumulate in the environment (“bioaccumulators”) was reported used by 49 facilities.

that deplete the ozone came to nearly 200 million pounds, as reported by 129 facilities.

The New Jersey data also make evident the fact that pro- duction, use, and release of chemicals vary significantly among facilities, making reporting of the full range of dataessential. Merck & Co.’s Rahway plant, for example, released or transferred 99 percent of the 1.59 million pounds of the carcinogen dichloromethane it used, while the Okonite Co.’s Paterson plant released or transferred less than 1 percent of the nearly 5.4 million pounds of lead compounds it used. General Electric’s plant in Moorestown released or transferred 99 percent of the nearly 95,000 pounds of the ozone- depleting Freon 11 3 that it used; the Amerada Hess plant in Woodbridge, on the other hand, released or transferred less than 1 percent of the 34.4 million pounds of anthracene, a bioaccumulator, brought on site.

From a different angle, some of the same company ex- amples tell another valuable story: Under TRI, the public learns only that Amerada Hess, for example, released or transferred a mere 67 pounds of anthracene in 199 1 -not that it had handled more than 34 million pounds. With New Jersey’s data, the public can learn that Okonite’s 252,000 pounds of released or transferred lead compounds represented only a sliver of the nearly 5.4 million pounds used.

Companies using toxic materials of these types and mag- nitudes surely should be accountable. If plant workers,

Total use of chemicals and chemical compounds

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local communities, local fire and health agencies, and government bodies are to be capable of fulfilling their missions to the public health and the environment most effectively, they need an integrated source of data on the kinds and quantities of chemicals traveling through and being handled in their neighborhoods.

INFORM’S analysis showsthereal-worldimportanceof New Jersey’s reporting requirements. The power of such infor- mation is that, once in the hands of the public, it makes businesses accountable for what they do and motivates them to improve those practices. Even New Jersey’s model could be improved — for example, by requiring informa- tion on the specific types of uses, both on-site and in prod- ucts; by improving the quality control of the data base; and by making the data more widely available to the public for maximum impact. Then, New Jersey’s reporting system would serve as a truly excellent model for all states.

Federal and State Proposals Proposals now being debated at the federal level and in New Jersey could significantly diminishthe value of New Jersey’s toxics data base. On the national level, the US Environmental Protection Agency is considering a request to modify the national TRI reporting threshold so that, of the facilities currently reporting to TRI (those that manu- facture, import, or process more than 25,000 pounds, or that use 10,000 or more pounds of a listed chemical), only those that release or transfer 5,000 or more pounds would report.

The New Jersey information now available gives evidence of how the federal and state proposed changes would se- riously dilute the public’s access to facts that are critical to recognizing and dealing with potential toxic chemical risks.

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Methodology The New Jersey data have only recently become readily accessible to the public; thus the perspectives contained in this preliminary report are relatively new.

INFORM’S research for the background tables and facility graphs and drawings came directly from the New Jersey Community Right-to-Know database, which we purchased from the state Department of Environmental Quality. The 1990 and 1991 data were analyzed using a spreadsheet (Lotus 1-2-3). INFORM has all of the tables available on diskette (in .wk1 files) and will provide them to individu- als who wish to do their own spreadsheet analyses. Note that these tables were run to answer three specific ques- tions:

How do toxics data reported to USEPA and NJ DEPE compare?

What impact would a pending proposal to the US EPA, to add a 5,000 pound release threshold for plants reporting to TRI, have on federal and NJ data?

What impact would a proposed legislative initia- tive to redefine pollution prevention in the New Jersey Pollution Prevention Act have on New Jer- sey data?

The tables also were run to give initial background infor- mation on the database.

The maps illustrate by county where chemicals intended for recycling are shipped (to and from) in New Jersey. The first number on the county map is the total amount of chemicals (in thousands of pounds) that were shipped into the county from other counties or states. The second num- ber is the amount of chemicals sent from facilities in the county to other counties or states. Note that the amount of chemicals sent out of state significantly exceeds the amount retained in the state.

Except for pages 1, 2, and 3, and several of the facility examples, thedatainthe spreadsheettables (separate docu- ment available from INFORM) are calculated from what we term “consistent data.” Our test for consistency is sup- plied within the self-verification portion of the New Jer- sey form (DEQ 114). With consistent data, the sum of starting inventory + quantity produced + quantity brought on site should approximately equal the sum of quantity consumed + quantity shipped off site as product or waste + quantity destroyed on site + total air emissions + total wastewater discharges + ending inventory. A difference of more than 2 percent is considered inconsistent. Note that we have used this definition of consistency to help present a clearer interpretation of the data. The fact that we have determined a particular form to have inconsistent data does not mean the data are wrong. In most instances such “inconsistency” arises from the uncertainty in mak- ing estimates in large use numbers.

Page 1 of the tables, which sets forth such items as state- wide releases, includes the entire database in order to give a more complete picture of the state representation.

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1991 Chemical Waste and Product Streams at Merck & Co., Rahway, NJ

Dichloromethane (in pounds)

Data reported to NJ DEPE [A through H) compared with data reported to the national

Toxics Release Inventory [A and B)

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Merck & Co. Dichloromethane (in thousand Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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1991 Chemical Waste and Product Streams at General Electric Co., Moorestown, NJ

Freon 113 (in pounds)

Data reported to N I DEPE [A through H) compared with data reported to the national

Toxics Release Inventory (A and B)

Waste stream data A = Environmental releases and transfers

(only includes releases for this chemical and facility) B = Nonproduct output

(all wastes generated before recycling, treatment. and disposal)

Product stream data C = Amount brought onsite D,E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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General Electric Freon 113 (in thousand Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever

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1991 Chemical Waste and Product Streams at Amerada Hess, Woodbridge, NJ

Anthracene (in pounds)

Data reported to NJ DEPE (A through H) compared with data reponed to the national

Toxics Release Inventory (A and B)

Waste stream data A = Environmental releases and transfers

(only includes releases for this chemical and facility) B = Nonproduct output

(all wastes generated before recycling, treatment, and disposal)

Product stream data C = Amount brought on site D,E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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Amerada Hess Anthracene (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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1991 Chemical Waste and Product Streams at Okonite Co., Paterson, NJ

Lead (in pounds)

Data reported to NJ DEPE [A through H) compared with data reponed to the national

Toxics Release Inventory (A and E)

Waste stream data A

B = Nonproduct output

= Environmental releases and transfers (only includes releases for this chemical and facility)

(all wastes generated before recycling, treatment, and disposal)

Product stream data C = Amount brought on-site D.E = Starting. ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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Okonite Co. Lead (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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Effects of 5,000 lb. Release/Transfer Cutoff: Proposed on the national level

The US Environmental Protection Agency is considering eliminating the reporting requirement under the Toxics Release Inventory (TRI) of chemical releases and trans- fers of less than 5,000 pounds. This change would affect New Jersey reporting requirements because New Jersey collects its supplementary information under the state's Community Right-to-Know Act only from facilities and on chemicals covered by TRI. This proposal would result in a major reduction in instances of chemicals reported.

All Chemicals 60 percent of chemical forms required currently

would no longer be reported. (2,650 forms, i.e., individual reports on the use* of a toxic chemical, were reported under TRI for New Jersey in 1991.)

waste,** and 1 percent of total releases and trans- fers of the chemical would not be reported. (Total chemical releases and transfers for New Jersey amounted to 203.27 million pounds in 1991.)

26 percent of use, 20 percent of generated

Carcinogens 72 percent of chemical forms required currently

for carcinogens would not be reported. (331 forms reporting carcinogen use were submitted to New Jersey in 1991.)

waste of carcinogens would not be reported. (To- tal carcinogen releases and transfers for New Jer- sey amounted to 8.90 million pounds in 1991.)

27 percent of use and 7 percent of generated

Metals and Metal Compounds 72 percent of chemical forms for metals and

metal compounds would not be reported. (498 forms reporting metal and metal compound re- leases and transfers were submitted to New Jer- sey in 1991.)

pounds, 1 percent of metal-generated waste, and 51 percent of use of metals and metal com-

1 percent of total metal and metal compound re- leases and transfers would no longer be reported. (Total metal and metal compound releases and transfers for New Jersey amounted to 38.17 mil- lion pounds in 1991.)

Examples (detailed on facility drawings)

These examples illustrate how facilities may have rela- tively large uses and/or generated waste of a chemical, but small releases and transfers. No reporting at all would be done on these chemicals if a 5,000 pound threshold were in place.

Shell Oil Co. - Benzene - Shell used 110.30 mil- lion pounds of benzene in 199 l, released or trans- ferred just 4,876 pounds, brought on site 110.43 million pounds, had an ending inventory of 4.46 million pounds, and shipped 110.3 1 million pounds in product.

DuPont Chemical - Phosgene - DuPont used 58.40 million pounds of phosgene in 1991, re- leased and transferred just 1,298 pounds, pro- duced 58.40 million pounds, and consumed 57.80 million pounds

used 57 million pounds of chlorine in 1991, re- leased or transferred zero, brought on site 57 mil- lion pounds, had an ending inventory of 900,000 pounds, consumed 49 million pounds, and shipped 8 million pounds in product.

Hatco Corporation - Phosgene - Hatco used 4.85 million pounds of phosgene in 1991, re- leased and transferred 2 pounds, brought on-site 4.87 million pounds, had an ending inventory of 42,000 pounds, and consumed 3.88 million pounds.

Kuehne Chemical Co. - Chlorine - Kuehne

* Use definition: starting inventory + amount produced + amount brought-on-site - ending inventory.

** Waste definition: releases + on-site land disposal i off-site transfers + destroyed.

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1991 Chemical Waste and Product Streams at Shell Oil Co., Woodbridge, NJ

Benzene (in pounds)

Data reported to NI DEPE (A through H) compared with data reported to the national

Toxics Release lnventory (A and 8)

Waste stream data A

B = Nonproductoutput

= Environmental releases and transfers (only includes releases for this chemical and facility)

(all wastes generated before recycling treatment, and disposal)

Product stream data C = Amount brought on-site D,E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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Shell Oil Co. Benzene (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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1991 Chemical Waste and Product Streams at Dupont Chemicals, Pennsville, NJ

Phosgene (in pounds)

Data reported to NJ DEPE (A through H) compared with data reported to the national

Toxics Release lnventory (A and E)

Waste stream data A

(only includes releases for this chemical and facility) B = Nonproduct output

(all wastes generated before recycling, treatment, and disposal)

= Environmental releases and transfers

Product stream data C = Amount brought onsite D,E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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DuPont Chemicals Phosgene (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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1991 Chemical Waste and Product Streams at Kuehne Chemical Co., Kearny, NJ

Chlorine (in pounds)

Data reported to NJ DEPE (A through H) compared with data reported to the national

Toxics Release Inventory (A and B)

Waste stream data A = Environmental releases and transfers

(only includes releases for this chemical and facility) B = Nonproductoutput

(all wastes generated before recycling. treatment, and disposal)

Product stream data C = Amount brought onsite D,E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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Kuehne Chemical Co. Chlorine (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear

numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

on the figure, although the

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1991 Chemical Waste and Product Streams at Hatco Corp., Woodbridge, NJ

Phosgene (in pounds)

Data reported to NJ DEPE (A through H) compared witb data reported to the national

Toxics Release Inventory (A and B)

Waste stream data A = Environmental releases and transfers

(only includes releases for this chemical and facility) B = Nonproductoutput

(all wastes generated before recycling, treatment, and disposal)

Product stream data C = Amount brought onsite D.E = Starting, ending inventory F,G = Amounts produced, consumed H = Amount in product shipped

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Hatco Corp. Phosgene (in million Ib.)

For New Jersey, only data with numbers greater than 0 appear on the figure, although the numbers are in some cases so small that the bar may not be visible. For federal data, only A & B are ever reported.

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Recycling Carcenogens in New Jersey (1991)

All chemicals brought into New Jersey counties for recycling/ All chemicals shipped out of New Jersey counties for recycling elsewhere

(thousands of pounds)

Total shipped to New Jersey counties: 2.4 million pounds Total shipped from New Jersey counties: 5.3 million pounds Total shipped out of state from all New Jersey counties: 41.6 million pounds

Source: New Jersey Community Right-to-Know Data (Form DEQ-114)

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Recycling Carcinogens in New Jersey (1991)

Carcinogens brought into New Jersey counties for recycling/ Carcinogens shipped out of New Jersey counties for recycling elsewhere

(thousands of pounds)

Total shipped to New Jersey counties: 9.1 million pounds Total shipped from New Jersey counties: 68.8 million pounds Total shipped out of state from all New Jersey counties: 40.8 million pounds

Source: New Jersey Community Right-to-Know Data (Form DEQ-114)

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Recycling Metals in New Jersey (1991)

Metals brought into New Jersey counties for recycling/ Metals shipped out of New Jersey counties for recycling elsewhere

(thousands of pounds)

Total shipped to New Jersey counties: 1.5 million pounds Total shipped from New Jersey counties: 32.2 million pounds Total shipped out of state from all New Jersey counties: 18.1 million pounds

Source: New Jersey Community Right-to-Know Data (Form DEQ-114)