1. Announcements
2. Current Events
3. How to Reduce the Amount of
Hazardous Waste Produced
RCRA some reduction (also indirect
reduction because of increased costs), but focus is on management (tracking)
CERCLA some reduction (also
indirect because of liability concern), but focus is on cleanup
Is another approach that has had
more impact on waste reduction. Bit of background:
Work for Syntex March, 1985.
December 1984 Union Carbide plant in Bhopal, India explosion, release methyl isocyanate
killed thousands. Syntex Board wanted to make sure couldnt happen their chemical
plants. Emergency Prevention and Response Program: Investigation and reports potential
each plant with recommendations for corrections. Board approved money and set up committee
to monitor changes. Audit team (including me) to each plant several times to audit
progress, audit reports to committee. Included information for community about plants and
what to do in emergency.
EPCRA: Congress also
responded to Bhopal tragedy. Superfund Amendments and Reauthorization Act of 1986. One
part, Title III, what is called Emergency Planning and Community Right to Know Act
(EPCRA).
Two parts:
Develop emergency plans for
responding to unanticipated releases of "extremely hazardous substances"
Collect and disseminated
information on toxic releases to environment
Covered businesses: required
to notify state and local emergency planning entities of presence and quantities in
inventory certain chemicals and to notify federal, state and local authorities of planned
and unplanned releases to environment. Heavy penalties for failing to comply.
EPA using data collected as
building blocks other substantive regulatory programs and citizen groups using data for
public disclosure and litigation
EPCRA Emergency Planning: First
Part: Emergency Planning: enables states and community to respond to releases of
certain hazardous substances
State Emergency Planning Committee
(SERC) and Local Emergency Planning Committees (LEPC) responsible for developing and
implementing emergency response plans required by EPCRA.
Facilities at which specified
"extremely hazardous substances" are present in excess of "threshold
planning quantities" required to do two things:
Must notify SERC that those
substances present and provide their LEPC with name facility rep who will participate in
planning process
Must report releases of extremely
hazardous substances in excess of "reportable quantities" as well as releases of
other CERCLA substances in excess of RQs to LEPC, SERC, and National Response Center
Note: CERCLA has separate release
reporting requirement for CERCLA substances:
CERCLA Reporting Requirements:
Person in charge of facility
Immediately
CERCLA Hazardous Substance
In excess of reportable quantity
Notify NRC.
Regulations list hazardous
substances and RQ for each substance.
EPCRA Reporting Requirements: Second
Part: Reporting Requirements:
Facilities at which "hazardous
chemicals" are present in excess of specified thresholds are required to submit
copies of Material Safety Data Sheets (MSDSs) or list of substances with MSDSs to SERC,
LEPC, and local fire department.
Notice to emergency planners and
responders
Annually must also submit yearly
and daily inventory information on quantities those materials and locations at facility
(Form R)
Annual reporting to EPA and state
on environmental releases of listed "toxic chemicals" manufactured, processed,
or otherwise used at facility in excess of specified threshold quantities (note
includes releases to all environmental media). (Note also only for listed toxic
chemicals and only if above threshold quantities). See below for reporting of
unplanned releases under CERCLA.
b and c based on "reasonably
available data", including monitoring and emission measurements but if no such data
exists reasonable estimates may be used. If estimates, must state basis for estimate
(monitoring data, mass balance data, emission factors, or best
engineering judgment).
Covered businesses for
Release reporting:
Covered Businesses:
1. Manufacturing operations (SIC
codes 20 through 39)
2. 10 or more full-time employees,
and
3. Manufactures, imports,
processes, or otherwise uses any of toxic chemicals on EPA list of 651 chemicals in
amounts greater than "threshold"1 quantities.
1992 manufactures in US reported
release 3.1 billion pounds of toxic chemicals into environment. Also transferred 4.3
billion pounds off-site for disposal. Information from toxic release reports available to
public. Citizen groups regularly publish data to try to bring pressure on companies to
reduce releases.
Syntex Graph
Caveat: Not all facilities covered
and reports not include all, or even most of pollution.
Known problems in data collection
methods:
1. Some facilities may not be
complying, either by failing to report or reporting only for some of covered chemicals.
(EPA survey estimated 66% compliance 1987: EPA believes better now because of outreach and
enforcement.)
2. Much of reporting based on
estimated data; does not require monitoring of releases.
3. EPA limited number of data
quality inspections; otherwise data not independently verified. (EPA survey 1987 over 75%
facility estimates within factor of 2 of EPA engineers best estimates.
EPA actions to improve data,
including outreach, inspections, enforcement, sharing data with states to make sure
receiving same data.
Some release amounts estimated
using monitoring data or measurements for process; may also be calculated using mass
balance, published emission factors, or other approaches such as engineering calculations
or best engineering judgment.
Known problems in measurement
methods:
1. Reflects releases of chemicals,
not exposures of the public to those chemicals.
2. Release estimates aggregate
annual estimates and do not provide information about peak concentrations
3. Estimation techniques not exact
science; needs further research and development.
But TRI certain advantages:
Multi-media (air, land, water,
underground separately and how much sent off-site
All quantities in pounds
Congressionally mandated to be
publicly available
Example RTK NET on Internet; EDF on
Internet. Will discuss more in Class #8.
Reminder:
Current event reports important
part of class. Welcome at any time.