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Where the Wastes Are: Highlights from the Records of the More
than 5,000 Facilities that Receive Transfers of TRI Chemicals

by
Alair MacLean and Rich Puchalsky

What follows is the text of "Where the Wastes Are: Highlights from the Records of the More than 5,000 facilities that receive transfers of TRI chemicals." The report was written by Alair MacLean, OMB Watch, and Rich Puchalsky, Unison Institute. It was published in April 1994.

If you would like a hard copy of the report, contact OMB Watch at:

1731 Connecticut Ave, NW
Washington, D.C. 20009
(202) 234-8494

EXECUTIVE SUMMARY

In June of 1992, a Rhone-Poulenc factory in Martinez, California, exploded. Sulfuric acid had spilled and caught fire when it came in contact with hot machinery. Two workers were critically injured. One later died.
A year later, Gibraltar Chemical Resources in Winona, Texas, where waste chemicals are injected deep underground, was ordered to clean up contaminated groundwater on its site. By the fall, Gibraltar's environmental problems had grown so large that the state ordered the company to stop doing business temporarily.
What do these two facilities have in common? Each is among the top facilities receiving transfers of toxic chemicals according to information contained in the Toxics Release Inventory (TRI).

Earth Day Events

Soon, as it has for the last five years, the Environmental Protection Agency will release its annual report on the fate of toxic chemicals used in manufacturing, the TRI. The approximately 300 chemicals listed on the TRI are considered among the most dangerous to human health and the environment. For example, many can cause cancer. This year, as in the past, the media, the public and regulators will focus on the pounds of toxic chemicals emitted from manufacturing facilities around the country. Press releases will compare this year's reported emissions to last. Discussion will center on whether these facilities have reduced chemical emissions or not.
But the Toxics Release Inventory tells another, little-noticed story as well. Contained within manufacturers' yearly reports are records of more than 80,000 transfers of chemicals to what are called off-site facilities: recyclers, landfills, and incinerators. In all, the approximately 23,000 manufacturers sent their toxic chemicals to more than 5,000 off-site facilities. And, if history is any guide, these facilities may pose health and environmental dangers in the future. As of 1991, at least 112 sites on the federal Superfund list had previously been engaged in recycling hazardous waste.
Manufacturers reported releasing 3.4 billion pounds of toxic chemicals to the air, land, and water in 1991, the most recent year for which data are available. But they sent just as many pounds of chemicals to be disposed at other facilities. In 1991, manufacturers reported more than 3.4 billion pounds of transfers to off-site destinations.
Some past analyses have looked at the aggregate number of pounds of toxic chemicals sent from or received by different states. Yet, so far, no one has compiled a national record of the actual sites that receive these toxic chemical shipments. The difficulty of collating and correcting the information has presented a formidable obstacle. And there is a general perception that transferring chemicals "solves" the pollution problems associated with releases.
But these transfers may just move short-term accidents and long-term contamination from one site to another. And the towns that host off-site destinations end up serving as a dumping ground for the problems of industrial production.
This report presents the first examination of the top facilities around the country that receive shipments of TRI chemicals in waste. (For a previous examination of the destinations by state see Nancy Lilienthal, Trading Toxics Across State Lines, INFORM, New York, 1990.) Using the 1991 TRI data, we have prepared a list of the off-site destinations that receive the greatest poundage of transfers of TRI chemicals from manufacturers. The facilities receiving TRI chemicals are named and ranked (see Table 1: Top Forty Facilities Receiving TRI Chemical Transfers). The top 40 facilities account for 1.7 billion pounds, 48 percent of all chemicals transferred. (Less than 1 percent of the facilities receive only slightly less than one half of all TRI transfers.) For example, the first, third and eighth largest recipients of TRI chemicals are Rhone-Poulenc facilities in Hammond, Indiana, Carson, California, and Baton Rouge, Louisiana. The second and seventh largest recipients of TRI chemicals are General Chemical facilities. A Timken facility in Canton, Ohio, is the fourth largest recipient of TRI chemicals, and a Coulton Chemical facility in Oregon, Ohio, is the fifth largest recipient. A Horsehead Resource Development facility in Palmerton, Pennsylvania, is the sixth largest recipient. Gibraltar Chemical in Winona, Texas, and Petro-Chem Processing in Detroit, Michigan, occupy the number nine and number ten spots. These top ten facilities receive more than one quarter of all the TRI chemicals sent off-site.
The report also identifies the largest recipients of TRI chemicals within specific categories, such as landfills and incinerators. The landfill receiving the most TRI chemicals was operated by Pennfill in Taylor, Michigan. The largest incinerator was operated by Rollins in Baton Rouge, Louisiana. The company receiving the most TRI chemicals for energy recovery was Arco Chemical in Channelview, Texas. The facility receiving the most pounds of TRI chemicals to be injected underground was Gibraltar in Winona, Texas. Rhone Poulenc's facility in Hammond, Indiana, was number one on the list of facilities receiving TRI chemicals for acid regeneration.
The report looks in detail at six companies that dominate selected disposal or recycling methods: incineration, landfilling, underground injection, energy recovery and acid regeneration. These destinations for off-site transfers of TRI chemicals share a history of short-term accidents and long-term contamination.

Recipients of TRI transfers have allegedly contaminated water supplies:

Recipients of TRI transfers have had potentially dangerous accidents:

Recipients of TRI transfers have allegedly received illegal waste shipments:

Facilities receiving TRI chemicals have been ordered closed by local and federal regulators:

At least one of the companies has had prior involvement with a Superfund site:

Recommendations

Many of the actions described above represent a failure of compliance on the part of facilities that receive TRI chemicals. To prevent the top recipients of TRI transfers from becoming the Superfund sites of the future, greater attention should be focused on these sites.
Shippers of TRI chemicals should try to reduce their use of toxic chemicals in the first place. Toxics use reduction would limit the number of pounds sent to off-site facilities. Additionally, reduction of the use of toxic chemicals would lead to a decrease in emissions of toxic chemicals as well.
Recipients of TRI chemicals should have to report their own releases and transfers of the chemicals, in order to increase accountability. Current law only covers certain large manufacturing facilities. In 1991, these manufacturers reported that they sent more pounds of chemicals off-site than they emitted directly to the environment. Yet, the recipients of these off-site transfers do not now have to report their own emissions to the environment. Requiring landfills, incinerators and other hazardous waste recycling and disposal sites to report their emissions of TRI chemicals would greatly increase the accountability created by the Right-to-Know.
Recipients of TRI chemicals should publicize their plans to prevent chemical accidents, as well as back-up plans for responding to chemical accidents should they occur. Local Emergency Planning Committees, established by the law that created the TRI, could theoretically take an active role in requiring manufacturers to prepare accident prevention plans and in making those plans available to the public. More recently, the Clean Air Act Amendments established the first framework for making corporate plans for chemical accidents publicly available. Under the current draft of the regulations, manufacturers must allow the public to see their assessments of the worst-case accidents. Hazardous waste landfills and incinerators pose dangers as well. They should also be required to enlist the public in planning for accidents.
Shippers of TRI chemicals should monitor the regulatory and environmental histories of the companies to whom they ship waste. The Superfund ensures that companies who ship waste that ends up in an uncontrolled waste site must bear some share of the burden of clean-up. With this expanded definition of liability, it is in TRI shippers interest to monitor the fate of chemicals shipped off-site.
EPA should ensure that the facilities receiving TRI wastes can legally handle those wastes. While the largest recipients of TRI transfers are likely to have permits to receive such waste. A number of facilities that may not actually have permits to receive TRI chemicals.
EPA should include examinations of off-site recipients in future analyses of the Toxics Release Inventory. Through its annual report on TRI chemicals, EPA each year spotlights manufacturers' releases of toxic chemicals. But the agency has not consistently examined the recipients of transfers. In the future, EPA should include lists of the names of off-site destinations in its analyses of TRI data.

Methodology

Toxics Release Inventory forms are filled out by the shippers of the waste, not by the receivers. In order to determine the total number of pounds received by different facilities, the 80,590 individual reported transfers needed to be added. But common errors can make one destination look like two or more. The name or address of a destination may be misspelled. This makes totaling the number of pounds shipped to a particular destination difficult. For example, Gibralter Chemical in Wynona, Texas, according to a cursory examination of the database, would not be grouped with Gibraltar Chemical of Winona, Texas.
We took a number of steps to correct common errors. First, a computer program was used to standardize spelling for the names and addresses of the transfers. After the computer had decreased the number of apparent recipients of TRI transfers from 80,590 to approximately 20,000 facilities, our staff examined the groups of transfers that resulted to find matches that the computer could not detect. Staff members searched through telephone directories to find the phone numbers and then called the facilities to check the addresses. Staff members also compared destinations listed in the TRI with EPA's FINDS database (Facility Index System, a list of all EPA-regulated facilities in most of EPA's major programs) to see if they existed. And staff compared counties and states used in TRI off-site transfer addresses with a reference dataset listing the county and state of each zip code in the U.S. Finally, staff looked at each individual transfer going to the largest poundage destinations to make sure that none had been mis-assigned.
By using these methods, the 80,590 initial transfers were grouped into about 5,300 destinations. We are confident that the possible error introduced through grouping transfers will not greatly affect the totals given for the destinations listed in this report.

A Few Words About the Totals in This Report

Totals given in this report are generally rounded off to the nearest million pounds. In general, reporting all digits in a TRI total should not be done since EPA only requires no more than 2 significant digits for reporting releases (Toxic Chemical Releases Inventory Reporting Form R and Instructions, pg. 27). For this report, transfers that were reported as "release ranges" were counted as a number of pounds equal to the center of the range (i.e. 1-10 pounds = 5 lbs, 11-499 lbs = 250 lbs, 500-1000 lbs = 750 lbs). Transfers to publicly-owned treatment works, or POTWs, are not examined in this report and are not counted into any of our totals.

INTRODUCTION

After the fatal accident in Bhopal, India, where a cloud of toxic gas from a Union Carbide factory killed more than 2,000 people, the U.S. Congress was spurred into action. Legislators drafted a law, the Emergency Planning and Community Right-to-Know Act, that would provide communities with the information and tools they needed to plan for emergencies involving chemical accidents. One component of this planning was an inventory of all of the toxic chemicals that manufacturing facilities produce or use.
More than just giving individuals information about the chemicals on-site, however, the Toxics Release Inventory allows anyone who looks at it to get a clearer picture of where the toxic chemicals in wastes are going. Companies have to report, for example, that they released 200 pounds of chlorine to the air and another 300 pounds to the water (see Appendix A, "What Information Does the TRI Contain?"). In addition, companies have to report if they are sending these toxic chemicals to other destinations, such as landfills or incinerators, to be disposed, treated or recycled. (A helpful resource for those interested in the Emergency Planning and Community Right-to-Know Act is Community Right-to-Know Deskbook, published by the Environmental Law Institute in Washington, D.C.) Using these manufacturers' reports, we have generated lists of incinerators, landfills and other off-site destinations that received transfers of TRI chemicals. (See Appendix C for a detailed list of the top hundred off-site destinations for TRI chemicals and the amounts of toxic chemicals that manufacturers reported sending to these facilities.)
With the exception of off-site transfers, companies' reports to the TRI are fairly straight-forward. In 1991, for example, Chevron's asphalt refinery reported emitting 1,400 pounds of Benzene to the air in Portland, Oregon. By contrast, the actual fate of the 500 pounds of the chemical that Chevron sent to be incinerated by the Chemical Handling Company in Broomfield, Colorado, is less certain. This uncertainty is a function of the reporting structure of the TRI. While manufacturing facilities such as Chevron are required to report what they do with toxic chemicals, waste-handling facilities such as the Chemical Handling Company are not.
When TRI chemicals arrive at off-site destinations they can be treated or disposed of in various ways. Before 1991, TRI chemicals sent to be recycled did not have to be reported. With the passage of the Pollution Prevention Act, however, manufacturers began to report these chemicals sent for recycling.
Many of the companies that we looked at have had recent regulatory and environmental problems. For example, several of the dominant hazardous waste firms have histories of allegations that they failed to comply with federal and local environmental laws. The compliance problems range from inadequate reporting to groundwater contamination. A number of federal, state and local enforcement actions have been initiated against these companies. In one particular case involving the Safety-Kleen Corporation, an EPA region has devoted resources to bringing facilities in several states into compliance with the laws. Other companies have violated their permits. In several cases, facilities have been forced to cease operating for a time. Several of the facilities have experienced accidents endangering workers and nearby residents. These are not small or insignificant dumps, but the companies that handle a large portion of the country's toxic wastes. They are companies that, in most cases, have at least two facilities among the top ten incinerators, landfills, and recyclers of TRI chemicals. Their actions illustrate practices for disposing of some of the most dangerous by-products of modern production. They reveal a pattern of problems with protecting local health and the environment.
Our examination of common destinations for off-site transfers of TRI chemicals led to a frightening conclusion. Shipping toxic chemicals to other off-site facilities may simply move short-term accidents and long-term contamination from one location to another.
Such actions, by other companies, gave rise, more than a decade ago, to the Superfund law. In 1942, the Hooker Chemical Company began dumping chemicals into a canal. Eleven years and 42 million pounds of chemicals later, the company covered the canal over with dirt and sold it to the local government. A school was built on top. It wasn't until the seventies that the chemicals began to seep into nearby basements. After a state health survey concluded that the contamination had endangered local residents' health, the Federal Government offered to move people in an emergency relocation. And the name Love Canal became a catch-phrase for the fall-out from chemical production.
Shortly after the emergency move of the 239 families from upstate New York, Congress passed the Comprehensive Emergency Response Compensation and Liability Act (CERCLA) to help contain the problem of uncontrolled hazardous waste disposal sites like Love Canal. This federal legislation set up a system and a fund to help with such emergencies and to help protect the health of people living near such sites. At the time, the extent of contamination was unknown. Most hazardous waste sites lay in uncharted territory. The Superfund was established to provide an efficient means of cleaning up these sites and providing immediate help for the people who were subjected to the kinds of contamination that had imperilled the residents of Love Canal.

THE LIST

More than a decade after the original legislation to clean up these uncontrolled sites was passed, there are now more than 1,200 sites listed on the National Priorities List (NPL). The sites receive, in theory, remedial clean-up, coordinated by the EPA. The NPL was created and is updated through a constant process of screening. First, neighbors, owners or regulators bring a site to the attention of the EPA. After notification, the sites may be slated for "removal" of any contamination, and are put on the CERCLIS list. In approximately 90 percent of these cases, short-term removal actions clean up the immediate problem. The EPA performs an initial assessment of the site, looking through the site's history and testing soil and water samples. The site is given a Hazard Ranking Score. If this score is above 28.5, as it has been in approximately 10 percent of the cases, the site is added to the NPL and targeted for remedial action. (Perry Beider, The Total Costs of Cleaning Up Nonfederal Superfund Sites: A CBO Study, Congressional Budget Office, January 1994.)
The Superfund established a unique system of liability for the sites that are listed on the NPL. Anyone who had a hand in sending waste to the site could later become liable. This could include generators of waste that was sent to the site, as well as the transportation companies that sent the waste to the site. The liability was also retroactive. Companies that had been operators, owners, or shippers in the past could also be held liable for the cost of clean-up. In another twist, the Superfund did not allow the non-negligence of potentially responsible parties to play into the judgement. Whether or not companies were aware that they were potentially contaminating a site, they were still liable for the clean-up costs.
An assessment of the sites on the National Priorities List conducted in 1990 found that certain types of environmental threats typically led to the listing of a site on the List. Groundwater impacts were the most common cause, figuring in about 85 percent of all sites, drinking water and soil impacts each figured in slightly more than 70 percent of all sites. Common contaminants included organic and inorganic chemicals. (National Research Council (U.S.). Committee on Environmental Epidemiology. Environmental epidemiology. Washington, D.C.: National Academy Press, 1991, p.67.)

THE SHAPE OF THINGS TO COME

While there are more than 1,200 sites listed on the National Priorities List, the ultimate size of the list remains anyone's guess. Conservative estimates have placed the ultimate number of sites at anywhere from 2,000 to 10,000. In addition, it is estimated by GAO that there are up to 400,000 sites in the country that have received toxic or hazardous wastes. Approximately 10 percent of sites so far examined are targeted for clean-up. So, the ultimate number of Superfund sites may be as high as 40,000. These sites may need to be cleaned up because of the danger they pose to health of nearby residents and the environment. (See Beider and National Research Council for discussion of total number of National Priorities List sites.)
It seems logical then, that the Superfund sites of the future might be listed among those companies that today are receiving much of the hazardous waste generated by industrial production. (An Environmental Protection Agency rule published in 1985, includes information about 67 incidents involving threats to the environment at hazardous waste recycling facilities. See "Appendix A--Summary of Damage Incidents Resulting From Recycling of Hazardous Wastes," Federal Register, January 4, 1985, Vol. 50, No. 3, p. 658-670. And another report identifies 112 sites on the federal Superfund list that involved recycling. See Paul Orum, et al., The "Recycling" Loophole in the Toxics-Release Inventory: Out of Site, Out of Mind, Working Group on Community Right-to-Know, Washington, D.C., p. 21.) While these sites do so in a climate much more regulated than the 1940s, when the Hooker Chemical could choose a canal in a populated area for its own personal dump, these companies are also dealing with a world that contains many more chemicals and in a much greater profusion and volume than the world of the forties. A cursory glance at some of the facilities that today receive toxic chemical shipments shows that the amounts received in just one year can equal the contents of Love Canal over an eleven year period.
It would be unfair to conclude that just because companies are receiving toxic chemical shipments they are somehow endangering health and the environment. So, we wanted to look in closer detail at some of the facilities that are receiving these wastes to determine if they might become the uncontrolled, dangerous hazardous waste sites of tomorrow. Are these major recipients of TRI chemicals Superfund sites waiting to happen? The records of some of the largest toxic waste disposal firms are not heartening.

THE FATE OF TRI CHEMICALS TRANSFERRED OFF-SITE

Manufacturers reported releasing 3.4 billion pounds of toxic chemicals to the air, land, and water in 1991, the most recent year for which data are available. This information comes from the Toxics Release Inventory (TRI), a record of the fate of toxic chemicals used by manufacturers. Environmental regulators, reporters and activists have long used the information as a guide to toxics in the environment. Hundreds of reports have been written detailing manufacturers' toxic releases.
But the Toxics Release Inventory also includes information about toxic chemicals that manufacturers report sending to "off-site" facilities. In 1991, manufacturers reported approximately 3.5 billion pounds of transfers to these destinations, a quantity even larger than the amount that these same manufacturers reported releasing directly to the air, land and water. (All figures derived from an analysis of the 1991 Toxics Release Inventory performed by the Unison Institute and OMB Watch. All totals exclude information about chemicals sent to Publicly Owned Treatment Works (POTWs).) Contained within manufacturers' yearly reports are records of more than 80,000 transfers of chemicals to what are called off-site facilities. In all, manufacturers sent their toxic chemicals to more than 5,000 such facilities. Every year, the Environmental Protection Agency has produced statistical analyses showing the number of pounds of toxic chemicals sent from or received by different states. Yet, so far, no one has compiled a record of the actual sites that receive these toxic chemical shipments. The difficulty of collating and correcting the information has presented a formidable obstacle.
This report presents the first examination of the facilities--landfills, incinerators, sulfuric acid regenerators, energy recovery facilities--that receive shipments of toxic chemicals. Using the 1991 TRI data, we have prepared a list of the off-site destinations that receive the greatest volume of transfers of TRI chemicals from manufacturers (see Table 1: Top Forty Facilities Receiving TRI Chemical Transfers).
The facilities receiving TRI chemicals are named and ranked. By far the largest recipient of TRI chemicals is the Rhone-Poulenc facility in Hammond, Indiana. In fact, the third and eighth largest recipients of TRI chemicals are also Rhone-Poulenc facilities. The second and seventh largest recipients of TRI chemicals are General Chemical facilities. A Timken facility in Canton, Ohio is the fourth largest recipient of TRI chemicals. A Coulton Chemical facility in Oregon, Ohio, is the fifth largest recipient. A Horsehead Resource Development facility in Palmerton, Pennsylvania, is the sixth largest recipient. Gibraltar Chemical in Winona, Texas, and Petro-Chem Processing in Detroit, Michigan, occupy the number nine and number ten spots on the list.
Table 2 shows the amount of TRI chemicals sent off-site for different types of disposal. There are five major categories of disposal: recycling, energy recovery, treatment, disposal and unknown. The two most common methods of recycling are metals recovery and acid regeneration, in which the waste is re-used in production. While recycling generally has a positive appeal, some of the problems uncovered in this examination reveal that recycling TRI chemicals is not problem-free. For example, acid regenerators risk accidents with sulfuric acid, an explosive substance. Energy recovery means that the chemicals are burned and energy from the heat produced is used for some other purpose. Treatment means the waste is altered in some way before disposal, for example, by burning. In the unknown category, we have grouped all the pounds of TRI chemicals for which a final fate could not be determined.
Manufacturers most commonly report sending TRI chemicals to be recycled. Nearly two thirds of all TRI chemicals sent off-site are sent to be recycled. The next most common fate for TRI off-site transfers is energy recovery. Various forms of disposal, most notably landfilling, account for a significant portion of all toxic chemicals sent off-site. This report also provides a more detailed glimpse of the specific facilities that handle TRI wastes. The report identifies the largest recipients of TRI chemicals within specific categories, such as landfills and incinerators. The facility receiving the most TRI chemicals to be landfilled was operated by Pennfill in Taylor, Michigan. The largest incinerator was operated by Rollins in Baton Rouge, Louisiana. The company receiving the most TRI chemicals for energy recovery was Arco Chemical in Channelview, Texas. The facility receiving the most pounds of TRI chemicals to be injected underground was Gibraltar in Winona, Texas. Rhone Poulenc's facility in Hammond, Indiana, was number one on the list of facilities receiving TRI chemicals for acid regeneration.
Acid Regenerators, who recycle TRI chemicals, receive the second greatest volume of TRI chemicals shipped off-site, 835 million pounds or 24 percent. The top 10 facilities received almost all of the pounds of chemicals transferred off-site for acid regeneration. (See Table 3: Top Ten Facilities Performing Acid Regeneration with TRI Chemicals.) The top ten facilities dominate acid regeneration. Together they account for nearly all of the TRI transfers sent to this method of disposal.
The acid regeneration process takes a variety of forms. Because of the explosive nature of sulfuric acid, this type of recycling poses particularly acute dangers. Usually an acid regenerator takes in waste sulfuric acid from gas refining and chemical production industries and purifies the waste into usable sulfuric acid. The industry leader, Rhone-Poulenc, uses a process that involves burning the waste acid to purify it. (Busch, Gretchen, "Gasoline reform lends new life to regen sulfuric; regenerated sulfuric acid; Heavy & Ag Chemicals," Chemical Marketing Reporter, March 2, 1992, Vol. 241, No. 9, p. 7.)
The third largest method used for TRI chemicals transferred off-site was energy recovery. In 1991, 346 million pounds or 10 percent, of the TRI chemicals transferred off-site were sent to these facilities. And the top 10 energy recovery facilities received slightly more than a third of the chemicals disposed of in this way. (See Table 4: Top Ten Facilities Receiving TRI Chemical Transfers for Energy Recovery.)
In order to classify as being used for energy recovery, chemicals had to be burned in an industrial boiler, furnace or kiln. The heat generated had to be used for energy. If, however, a chemical does not have a high enough heat content, manufacturers should not report the chemical as being used for energy recovery, but instead as having been incinerated. (Toxic Chemical Release Inventory Reporting Form R and Instructions: Revised 1992 Version, EPA 745-K93-001, United States Environmental Protection Agency, Office of Pollution Prevention and Toxics, January 1993, p. 36.) Approximately two percent of the chemicals manufacturers reported sending off-site for energy recovery did not actually have a high enough BTU content to be used for energy recovery, and therefore should have been classified as incinerated.
Most environmental regulators consider incineration to be a less desirable end than energy recovery. When waste is incinerated, no use is gained from the burning. Although manufacturers reported sending less waste to be incinerated than for energy recovery, the amount thus disposed of is still large, approximately 159 million pounds, less than 5 percent of TRI transfers. The top 10 incinerators received almost half of the TRI chemicals transferred to be incinerated. (See Table 5: "Top Ten Facilities Incinerating TRI Chemical Transfers.")
Landfills are perhaps the most familiar destination for waste. And indeed, landfills account for more than 5 percent of the TRI transfers off-site, or 171 million pounds. (See Table 6: "Top Ten Facilities Landfilling TRI Chemical Transfers.") Though the volume of TRI chemicals received is low, these disposal sites have presented particular environmental problems. In 1990, approximately 20 percent of all Superfund sites had been landfills. (Alair MacLean, "The Case of the Landfill: Is OMB Trashing EPA?" Government Information Insider, March 1991.) Many different landfill companies around the country receive TRI chemicals. Unlike acid regeneration, where the top ten facilities account for nearly all of the chemicals disposed in this way, the top 10 landfills accounted for less than one third of the chemicals disposed in this way.
The operators of these relatively simple disposal sites are required by law to protect nearby groundwater. They must ensure that the proper liners and monitoring systems are in place. In most cases, landfills can receive only certain kinds of wastes. (Hazardous Waste Land Treatment, SW-874, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, April 1983.) Manufacturers reported sending TRI chemicals to approximately 1,000 apparent municipal landfills in 1991.
Less than 1 percent of all TRI chemicals transferred off-site, or 48 million pounds, was sent to underground injection wells. (See Table 7: Top Six Underground Injection Facilities Receiving TRI Chemicals.) The majority of the wells accepting hazardous waste have been built in the South. Louisiana, with 70, and Texas, with 112, together accounted for 69 percent of these underground injection wells in 1986. And the top 6 facilities, 4 of them in Texas, received more than 95 percent of all transfers of TRI chemicals to be injected underground.
According to EPA regulations for underground injection, the waste must be injected at least a quarter mile below the nearest water source. To get a permit for underground injection, companies have to guarantee that the waste either will not come into contact with a water source for 10,000 years, or will no longer be hazardous if it does reach water. Several states, including Oregon, Idaho, and Wisconsin, have banned all underground injection. (J. Russell Boulding, Assessing the Geochemical Fate of Deep-Well-Injected Hazardous Waste: A Reference Guide, EPA/625/6-89/025a, U.S. Environmental Protection Agency, Office of Research and Development, June 1990.)

PROFILES IN DISPOSAL

THE COMPANIES THAT DOMINATE ACID REGENERATION, ENERGY RECOVERY, INCINERATION, LANDFILLING, AND UNDERGROUND INJECTION

It would be unfair to conclude that just because companies are receiving toxic chemical shipments they are somehow endangering health and the environment. So, we wanted to look in closer detail at some of the facilities that are receiving these wastes to determine if they might become the uncontrolled, dangerous hazardous waste sites of tomorrow. Are these major recipients of TRI chemicals Superfund sites waiting to happen? The records of some of the largest toxic waste disposal firms are not heartening.
In order to examine more closely the impact of these facilities on health, safety and the environment, we have looked at specific companies that dominate different, important sectors: acid regeneration, energy recovery, incineration, landfilling, and underground injection. Rhone-Poulenc operates three of the top ten overall recipients of TRI chemicals and five of the top ten facilities receiving TRI chemicals sent for acid regeneration. In energy recovery, four Safety-Kleen facilities account for 13 percent of waste. Rollins Environmental Services operated the top three incinerators receiving TRI chemicals, accounting for almost a third of all TRI chemicals incinerated off-site. Chemical Waste Management operates the sixth and tenth largest landfills receiving TRI transfers, along with five other Chemical Waste Management landfills around the country. And Gibraltar Resources underground injection facility received almost half of all the TRI chemicals sent to be disposed of in this manner.

ACID REGENERATION: RHONE-POULENC

In 1991, Rhone-Poulenc received more than 10 percent of the TRI chemicals transferred off-site, and more than three-quarters of the chemicals sent for acid regeneration. The company operates six such facilities in the U.S., five of which were among the top ten recipients of waste sent for acid regeneration (see Table 3: Top Ten Facilities Performing Acid Regeneration with TRI Chemical Transfers). Acid Regeneration is the second most common destination for transfers of TRI chemicals. The acid regeneration process takes a variety of forms. Usually an acid regenerator takes in waste sulfuric acid from the gas refining and chemical production industries and purifies the waste into high-quality sulfuric acid. Rhone-Poulenc burns the acid to purify it. (Busch, Gretchen, "Gasoline reform lends new life to regen sulfuric; regenerated sulfuric acid; Heavy & Ag Chemicals," Chemical Marketing Reporter, March 2, 1992, Vol. 241, No. 9, p. 7.)
In addition to receiving transfers of waste to be recycled, Rhone-Poulenc facilities also reported their own releases and transfers to the TRI. This is because, unlike CWM, Rollins and Safety-Kleen, Rhone-Poulenc has activities classified in the manufacturing sector, and so is required to report to the TRI (see Appendix A "What Information Does the TRI Contain?").
In 1991, the company reported more than 34 million pounds of toxic releases and transfers. Two facilities, one in Baytown, Texas, and one in Institute, West Virginia, accounted for more than three quarters of these releases and transfers. Neither of these facilities rate as the top recipients of TRI transfers. In fact, the Hammond, Indiana, facility, to which companies reported shipping more than 20 million pounds of toxic chemicals for disposal, reported only 42,000 pounds of toxic releases and transfers of its own. The Rhone Poulenc facility in Carson, California, was third on the list of companies receiving transfers of TRI chemicals, receiving slightly more than 111 million pounds of TRI transfers, but it reported only 1.5 million pounds of its own toxic releases and transfers.
In September of 1993, the EPA found the Rhone-Poulenc facility in Hammond, Indiana, the number one facility for acid regeneration receipts, had violated its permit. The agency proposed a $37,350 fine for the permit violations. ("EPA seeks nearly $20 million for incinerator violations," United Press International, September 28, 1993.)
Several of Rhone-Poulenc's facilities had accidents involving sulfuric acid. In June of 1992, the Martinez and Baytown facilities each had serious accidents involving sulfuric acid. In Baytown, which is not among the top facilities for acid regeneration, a loading pipe broke and sent a cloud of sulfuric acid floating across the Houston ship channel. At least thirty people were injured by the acid. ("RP Hit by SO2 Spill," Chemical Week, June 24, 1992, p. 4.) In Martinez, the ninth largest recipient of TRI transfers for acid regeneration, sulfuric acid spilled and caused a fire. Two workers suffered serious burns. One of the workers later died. (Erin Hallissy, "Martinez Chemical Plant to Pay $1 Million to Settle Claims," The San Francisco Chronicle, October 27, 1992, p. A17.)

ENERGY RECOVERY: SAFETY-KLEEN

Safety-Kleen has a large share of the market for TRI chemicals sent for energy recovery. (See Table 5: "Top Ten Facilities Receiving TRI Chemical Transfers for Energy Recovery.") Four of Safety-Kleen's facilities account for 13 percent of waste sent for energy recovery. Safety Kleen is a large company with many different parts, primarily cleaning auto parts and industrial machines. Its large-scale facilities burn TRI chemicals through fuel blending. Wastes are taken in from other companies and made into fuels that power cement kilns.
Safety-Kleen's facilities are the destination of choice for many facilities shipping TRI chemicals. In addition to operating the 3rd and 4th largest energy recovery facilities in Holly Hill, South Carolina, and New Castle, Kentucky, the company owns the sixth largest incinerator of TRI chemicals, in Manati, Puerto Rico (see Table 4: Top Ten Incinerators Receiving TRI Chemical Transfers).
In 1991, the Holly Hill, South Carolina, energy recovery facility received 125 transfers from 29 shippers. The New Castle, Kentucky, facility received 1,310 transfers from 552 shippers. And the Safety Kleen incinerator in Manati, PR, received 172 transfers from 62 shippers.
Safety-Kleen's Annual Report show-cases a series of beautiful photographs. From the cover photograph of the rolling pink and orange desert hills at sunset, to an interior image of pale grey boats docked in a bay, a small yellow van or truck with the black and red Safety-Kleen emblem appears to be making its rounds. No people inhabit these pictures; the truck leads the viewer to places where she might want to vacation or retire.
The reality is, unfortunately, not as pretty as the pictures. In 1992, EPA Region IV targeted Safety-Kleen for enforcement actions at more than a dozen facilities, including the New Castle, Kentucky, facility where waste has seeped into the Bartlett Fork Creek. This potential contamination parallels the situation found at many of the sites that have now been prioritized for Superfund remedial action. (Press Release from Environmental Protection Agency Region IV, March 3, 1992.)
In the same year, the company violated its permit at its Manati, Puerto Rico, facility. Safety-Kleen was allowed to handle only a certain amount of waste. But the facility was storing more than 800,000 pounds of excess toxic waste on-site. In addition, the facility was storing more than a million more pounds of hazardous waste in un-permitted tanks on the north and south coasts of Puerto Rico. Some of the effluent had not been properly treated. In response to these problems, waste was shipped off to the mainland. And the Puerto Rican Environmental Quality Board recently fined Safety-Kleen more than $1.4 million dollars. (See Safety-Kleen Corp. 1992 Annual Report and H. Lee Murphy, "$ 3.3-million fine erodes Safety-Kleen's record," Crain's Chicago Business, August 31, 1992, p. 9.)

INCINERATION: ROLLINS ENVIRONMENTAL SERVICES

In 1970, Rollins Environmental Services opened the first large scale commercial hazardous waste incinerator. (Rollins Environmental Services Annual Report, 1992.) The company has maintained its dominance of this sector of the business ever since (see Table 4: Top 10 Facilities Receiving TRI Chemical Transfers for Energy Recovery). In 1991, Rollins operated the top three incinerators receiving TRI chemicals, accounting for almost a third of all TRI chemicals incinerated off-site.
The company has already been involved in several federal cases involving the Superfund. In 1988, the Bridgeport, New Jersey, Rollins facility was found to be a Potentially Responsible Party at nearby Superfund site, the Kin-Buc Landfill. (See "Absolute Fire Protection Co," EPA Docket Database Case Number: 02-87-0285, File Date: May 16, 1988; "Price Charles, et al.," EPA Docket Database Case Number: 02-80-0007, File Date: December 22, 1980; and "Bridgeport Rental & Oil," EPA Docket Database Case Number: 02-91-0245, File Date: June 30, 1992. The search was done on RTK NET's copy of EPA's DOCKET database on March 22, 1994.) Companies that had sent waste to Rollins were also implicated. At least two major companies had been sending waste to the Rollins site during the time that the incinerator had been in turn sending its waste to the landfill that became a Superfund site. Unfortunately for Rollins, these companies had made the incinerator company sign an agreement protecting them from liability.
In the 1970s, Rollins agreed to bear liability for litigation resulting from regulatory changes that could end up costing its customers money. Ironically, one of the companies that Rollins tried to implicate as a Potentially Responsible Party, because the company had sent Rollins hazardous waste, was the Hooker Chemical Company, the same company that caused the Love Canal contamination. The other company, the Polaroid Corporation, has so far successfully argued that Rollins should shoulder the blame for any contamination that might potentially involve Polaroid. ("Indemnification Agreements Executed Before CERCLA Applicability To CERCLA Liability," Massachusetts Lawyers Weekly, January 10, 1994, p. 12.)
In the south, the Rollins incinerator near Baton Rouge continues to be the site of controversy. Residents complain of odors and burning flares. The facility is less than a half mile away from the Alsen neighborhood, a predominately African-American neighborhood in North Baton Rouge. One of the residents says that she can see smoke rising from the incinerator from her porch. In 1985, the state of Louisiana ordered the incinerator closed due to pollution problems. The company refused to close the facility until the state began to levy $100,000 fines for each day the facility continued operating. Nearby residents initiated a $1 billion class action suit, claiming that the incinerator had destroyed their quality of life and health. Following the forced shut-down, the incinerator became the only facility in Louisiana ever to be denied an extension of its tax abatement. The Louisiana Department of Economic Development has been notoriously free with such tax abatements, causing complaints from legislators concerned with revenue and environmentalists concerned that companies are given no incentives not to pollute in Louisiana. But, according to the Chief of the Economic Development Department, Rollins's environmental problems were too extreme. (George J. Siomkos, "Conceptual and methodological propositions for assessing responses to industrial crises," Review of Business, March 22, 1992.)
And Rollins's Deer Park, Texas, facility has also recently been the target of environmental complaints. The incinerator was on a list of facilities that have received radioactive waste. The list became public when a House of Representatives committee began hearings on Department of Defense disposal of radioactive waste. According to information that came out in the hearing, the Deer Park incinerator had been receiving and burning the waste for at least 11 years. Department of Defense officials claimed the secrecy surrounding the disposal of the radioactive waste was necessary to protect national security. (Ruth Rendon, "Burning of nuclear waste protested," The Houston Chronicle, February 29, 1992, p. 30.)

LANDFILLING: CHEMICAL WASTE MANAGEMENT

Like other waste handlers, Chemical Waste Management, an industry leader in landfilling, has also had problems with compliance. A photo in the company's annual report recalls the movie 2001. In an aisle between two rows of dark blue and black metal barrels, a figure encased in a pale yellow plastic sheath bends over. The ghostly figure's white plastic gloves hold a glass tube that is inserted in one of the barrels. A vacuum cleaner hose leads from the back of a large astronaut-like helmet and connects to a spiraling, skinny wire tube. Reflections obscure the helmet's glass face protector. A caption reads: "CWM's facilities carefully sample and analyze materials in on-site laboratories to ensure that they are properly managed." But in a number of cases involving some of CWM's largest facilities, the EPA has alleged that this careful analysis is exactly what CWM fails to do.
Chemical Waste Management is a subsidiary of the giant Waste Management Incorporated (WMX). Chemical Waste Management, with revenue of $1.5 billion in 1992, dwarfs most other hazardous waste management companies. The company operates seven active landfills, two deep well injection facilities and six stabilization units. The company operates the sixth and tenth largest hazardous waste landfills in the country. CWM's landfill in Carlyss, Louisiana received 734 transfers of waste. The Emelle, Alabama, landfill received a staggering 1,205 transfers from 405 different TRI shippers (see Table 6: "Top Ten Facilities Landfilling TRI Chemical Transfers"). Chemical Waste Management also operates the third largest underground injection facility in the country in Vickery, Ohio. (Chemical Waste Management, Inc. Annual Report 1992.)
The Emelle, AL, landfill has been the site of a series enforcement actions involving hazardous wastes. In 1987, the company illegally stored and transferred Agent Orange. The waste had been given to CWM by the state of Louisiana. The company stored 30 gallons of the highly toxic herbicide in a warehouse in Louisiana before finally transferring it to the landfill. Two Chemical Waste Management employees and one state employee have pled guilty. (Mark Schleifstein, "Inaction Probed in Waste Decision," The Times-Picayune, August 21, 1993, p. A7.)
The Carlyss, Louisiana, Chemical Waste Management landfill has also been involved in a number of enforcement actions brought by the state. Beginning in 1988, the state of Louisiana has carried out a number of inspections at the landfill. In addition to failing to identify certain areas, the facility's operators may have allowed hazardous wastes to contaminate the nearby ground and water. Materials that may have been hazardous were not tested and allowed to remain in the area where trucks are washed, potentially contaminating the nearby roads. Wastewater leaks have been a consistent problem turned up by Louisiana Department of Environmental Quality inspections between 1990 and 1992. The company recently settled with DEQ on 17 different matters of compliance, including penalties. One issue causing the state's crackdown was a series of eight un-reported fires in the year between 1988 and 1989. ("DEQ Going After Chem Waste," Louisiana Industry Environmental Alert, September, 1992.)

UNDERGROUND INJECTION: GIBRALTAR CHEMICAL RESOURCES

Less than one fiftieth of all TRI chemicals transferred off-site, or 48 million pounds, was sent to underground injection wells. Although low in quantity, injection facilities pose particular risks because they rely on geology to protect nearby groundwater. The EPA regulates companies that inject hazardous waste underground. According to the agency, the waste must be injected at least a quarter mile below the nearest water source. To get a permit for underground injection, companies have to guarantee that the waste either will not come into contact with a water source for 10,000 years, or will no longer be hazardous if it does reach water. Several states, including Oregon, Idaho, and Wisconsin, have banned underground injection. (J. Russell Boulding, Assessing the Geochemical Fate of Deep-Well-Injected Hazardous Waste: A Reference Guide, EPA/625/6-89/025a, U.S. Environmental Protection Agency, Office of Research and Development, June 1990.)
The first of Gibraltar's wells began accepting hazardous waste more than ten years ago. The company drilled a hole deep into the Texas ground. A casing around the hole separates the injected waste from the nearby aquifer. In 1989, Gibraltar applied for and received clearance to build a second well for disposal of hazardous waste. The Natural Resources Defense Council and the Hazardous Waste Treatment Council sued the EPA, protesting that an un-built well could not be given carte blanche. Finally, in January of 1993, the agency decided to withdraw its earlier approval.
In 1991, Gibraltar ranked at the top of the list of underground injection wells receiving such chemicals (see Table 7: Top six Underground Injection Facilities Receiving TRI Chemical Transfers).
On January 7, 1993, a chemical reaction in a 15,000 gallon tank at Gibraltar Chemical Resources in Winona, Texas, released a toxic plume. ("TACB-TWC Hit Gibraltar," Texas Industry Environmental Alert, February 2, 1993.> Less than a month later, the Environmental Protection Agency officially revoked the company's right to inject hazardous waste into one of its two underground injection wells. Though the EPA had initially allowed the injection, the agency decided that an 800 foot gap in the concrete that circled the well was just too much of a hazard to the environment.<$F"Underground Injection Control Program; Hazardous Waste Disposal Injection Restrictions; Petition for Exemption--Class I Hazardous Waste Injection Gibraltar Chemical Resources, Inc., Winona, TX," Federal Register, Vol. 58, No. 31, February 18, 1993, pp. 8944-8945.)
If anything, the following summer was more eventful. In early July, the Texas Water Commission ordered Gibraltar to clean up contaminated groundwater and modify the facility's operations. ("Agreed Order: Requiring Gibraltar Chemical Resources, Inc., to Undertake Corrective Measures related to Its Waste Analysis Procedures and to Remediate Soil and Ground Water Contamination Associated with its Facility in Smith County, Texas," Texas Water Commission, July 14, 1993.) The company estimated that the changes would cost Gibraltar $1 million, a hefty sum for a company whose previous year's revenues totalled just $43 million. Two weeks later, for three days, residents complained of odors coming from the plant. But the Air Control Board declared the emissions routine and not a nuisance. (Toni K. Laxson, "Some in town link illness to firm's wastes Company says complaints, allegations not supported," The Dallas Morning News, August 11, 1993, p. 29A. And see Mobley Environmental Services Annual Report, 1992.)
By the fall, however, Gibraltar's involvement with state regulators took a dramatic turn. The state's regulators had consolidated environmental enforcement into one body, the Texas Natural Resource Conservation Commission (TNRCC). Gibraltar executives failed to report a September 9 chemical accident until the day after it occurred. Two weeks later, reflecting on Gibraltar's history of environmental problems, the TNRCC ordered Gibraltar to temporarily stop receiving hazardous wastes. ("Emergency Order No. 93-8E: Requiring Gibraltar Chemical Resources, Inc., to Cease Receipt Operations Pending Implementation of Remedial Measures," Texas Natural Resource Conservation Commission, September 23, 1993.)
Gibraltar receives waste from a variety of sources. In 1991, companies reported 693 transfers of assorted TRI chemicals to the company's East Texas facility. For example, Peterbilt Motors, in Denton, TX, sent almost 8,000 pounds of Ethylene Glycol to be injected. And Rhone-Poulenc, in Carson, CA, reported sending more than 1 million pounds of sulfuric acid. As Gibraltar's regulatory problems mount, these companies risk being associated with a hopelessly contaminated site. If the facility were declared a Superfund site all sources of waste could become potentially responsible parties.

RECOMMENDATIONS

While many of the actions described above represent a failure of compliance on the part of facilities that receive TRI chemicals, certain steps could be taken to limit the dangers posed by off-site recipients of TRI chemicals.
Recipients of TRI chemicals should have to report their own releases and transfers of the chemicals, in order to increase accountability. When Congress drafted the TRI law, only manufacturing facilities had to report. In 1991, these manufacturers reported that they sent more pounds of chemicals off-site than they emitted directly to the environment. Yet, the recipients of these off-site transfers do not now have to report their own emissions to the environment. Requiring landfills, incinerators and other hazardous waste disposal sites to report their emissions of TRI chemicals would greatly increase the accountability created by the Right-to-Know. Recipients of TRI chemicals must publicize their plans to prevent and respond to chemical accidents. The Clean Air Act Amendments established the first framework for making corporate plans for chemical accidents publicly available. Under the current draft of the regulations, manufacturers must allow people to see their assessments of the worst-case accidents. Hazardous waste landfills and incinerators pose no less danger than manufacturers. They should also be required to enlist the public in planning for accidents.
Shippers of TRI chemicals should monitor the regulatory and environmental histories of the companies to whom they ship waste. The Superfund ensures that companies who ship waste that ends up in an uncontrolled waste site must bear some share of the burden of clean-up. With this expanded definition of liability, it is in TRI shippers interest to monitor the fate of chemicals shipped off-site.
EPA must ensure that the facilities receiving TRI wastes are actually permitted to handle these wastes. While our report covers the largest facilities to handle TRI chemicals, facilities most likely permitted to receive such wastes, there are a number of facilities that may not actually have permits to receive TRI chemicals. Uncovering these facilities will take research, but EPA must take the time to do this.
EPA should include examinations of off-site recipients in future analyses of the Toxics Release Inventory. Through its annual report on TRI chemicals, EPA each year spotlights manufacturers' releases of toxic chemicals. But the agency has not given similar attention to the recipients of transfers. In the future, EPA should include lists of the names of off-site destinations in its analyses of TRI data.

APPENDICES

APPENDIX A: WHAT INFORMATION DOES THE TRI CONTAIN?

The Toxic Release Inventory, or TRI, is a database of information collected by the U.S. EPA. It holds information reported by manufacturing facilities about the toxic waste that they generate and release. They must report how many pounds of each waste chemical they release to the air, land, and water, how much they inject underground, and how much they transfer off-site. Although there are limitations on who must report, the TRI is best tool currently available to the public for tracking toxic waste from manufacturing facilities.
A representative for a facility (from here on referred to as a "respondent") must fill out a TRI form if all of the four conditions below are fulfilled:

  1. Only manufacturing facilities must report. Utilities, waste treatment facilities, and mining and transportation facilities do not have to report. Currently, federal facilities do not have to report, though they will begin reporting in future years.
  2. The facility must have 10 or more full-time employees (so small businesses do not have to report).
  3. The facility only reports data for the 350 listed TRI toxic chemicals. Other chemicals are not reported. EPA recently has proposed expanding this list. If the proposal is approved, the number of chemicals in the TRI could double.
  4. The facility only reports data for a chemical if it produced or imported more than 25,000 pounds of the chemical during the year, or used more than 10,000 pounds during the year.

U.S. EPA, some states, and some environmental groups have issued reports summarizing TRI year-by-year. In addition, TRI has been used extensively to look at local and global air pollution and water pollution problems. However, few to date have extensively examined the TRI data on shipments of waste off-site.

APPENDIX B: METHODOLOGY

The major difficulty in preparing data for this report was in grouping individual TRI transfers together by destination. For an explanation of this difficulty, a few definitions of TRI terms are required. "TRI facilities" are the individual manufacturers who fill out TRI Form R's to report releases and transfers of TRI chemicals. "TRI submissions" are copies of the identifying parts of these Form R's; these is one TRI submission for each chemical that a TRI facility reports. Finally, "TRI off-site transfers" (just called _transfers_ in this report) are data from the Form R submissions that report the amount of the chemical that is sent to a particular off-site destination. The amount given for each transfer is the total pounds of a TRI chemical sent by the TRI facility to the off-site destination during the year. (Transfers to publicly-owned treatment works, or POTWs, are not examined in this report and are not counted into any of our totals). There were 80,590 non-zero transfers in the 1991 TRI database. To find out information about individual destinations of waste, these transfers had to be grouped together by destination.
Each set of transfer information contains the name, address, and RCRA ID number of the off-site destination of the waste, along with a code indicating what method of recycling, treatment, or disposal was used on the waste. With this information, it would seem to be a simple matter to add up all of the transfers going to a particular destination -- just find all of the ones with the same name and address, or the same RCRA ID. Unfortunately, the names, addresses, and RCRA Ids in the TRI database are often incomplete or incorrect.
To understand why this is so, remember that the TRI forms are filled out by the shippers of the waste, not by the receivers. Common errors or problems that occur are:

Most of the data quality work that has gone into this report was intended to correct these problems. First, a computer program was used to standardize spelling for the names and addresses of the transfers. Blanks and punctuation were removed for comparison purposes, and common words were changed to standard abbreviations or removed (for instance, INCORPORATED, INC., and INC were removed from facility names; FIRST was changed to 1ST in street names). Some city names also had to be regularized, such as SAINT LOUIS and ST. LOUIS. After this stage, the groups of transfers that resulted were examined by our staff to find matches that the computer could not detect. This often involved using the telephone to call the destination in question to find out the correct addresses. Destinations were also compared with EPA's FINDS database (Facility Index System, a list of all EPA-regulated facilities in most of EPA's major programs) to see if they existed in that database. A reference dataset which gave the county and state of each zip code in the U.S. was used to check the counties and states used in the transfer addresses. Finally, staff looked at all of the individual transfers going to the largest poundage destinations to try to make sure that none had been mis-assigned. By using these methods, the 80,590 transfers were grouped into about 5,300 destinations. Although we can not guarantee that no transfer has been mis-assigned to a destination, we are confident that the possible error introduced is low enough so that it should not greatly affect the totals given for the destinations listed in this report.
Totals are given in this report are generally rounded off to the nearest million pounds. In general, reporting all digits in a TRI total should not be done since EPA only requires no more than 2 significant digits for reporting releases (Toxic Chemical Releases Inventory Reporting Form R and Instructions, pg. 27). For this report, transfers that were reported as "release ranges" were counted as a number of pounds equal to the center of the range (i.e. 1-10 pounds = 5 lbs, 11-499 lbs = 250 lbs, 500-1000 lbs = 750 lbs).
The TRI off-site shipments offer a wealth of information about incinerators, hazardous waste landfills, and waste recyclers. For instance, assume that you are interested in a particular incinerator. The incinerator does not have to report to TRI, since it is not a manufacturing facility. But if any TRI facility sends waste there, they must report the name and address of the incinerator along with the amount of waste that was sent. It is possible to search TRI for all shipments going to the incinerator and add them up. This gives you a list of chemicals that the incinerator is known to burn, a minimum amount of each chemical that is burnt, and a partial customer list for the incinerator. We have done this for all facilities in the 1991 reporting year of TRI (the latest year of data available at the time this report was written). The facilities that waste was sent to range from well-known hazardous waste recycling, treatment, disposal facilities to small municipal solid waste dumps and farms. Figuring out which TRI off-site transfers were going to which sites was difficult. TRI respondents often misspell the names and address of off-site facilities, or give incomplete information. U.S. EPA does not check the off-site names and addresses for misspellings or missing information. Therefore, we had to use a complicated computer procedure and our own judgement to try to figure out where the waste was going in many cases. The first question to consider is the size of the total waste stream in the TRI "universe" of facilities. How much total waste is being shipped each year? Surprisingly enough, even this basic question can be answered differently depending on how you phrase the question. To start to see why, look at the table below (all numbers are given to two significant digits, since that is the level of accuracy required by TRI): 

Year  Total Lbs Shipped* Total Lbs Shipped & Released 

1987   2.0 billion       21.0 billion 

1988   1.9 billion        8.2 billion 

1989   1.0 billion        5.9 billion 

1990   0.9 billion        5.0 billion 

1991   3.5 billion        7.2 billion 

* does not include pounds shipped to POTWs]

The table shows the total off-site shipments, or transfers, for each year. It also shows the total amount of TRI chemicals released and transferred by year. The first thing you might notice is that the totals decrease rapidly after the first year, then increase again in the last year. Both the decrease after 1987 and the increase in 1991 are, to a large extent, artifacts of the way the data was reported rather than indications of a true increase or decrease in waste. The decrease after 1987 was mainly due to changes in which chemicals were on the TRI reporting list. The TRI chemical list is supposed to contain chemicals which meet certain criteria for toxicity. Every year, some chemicals may be added to or subtracted from the list by EPA either on its own authority or in response to petitions from the public. After 1987, EPA granted petitions to "de-list" a few of the largest poundage chemicals in TRI. Since these chemicals did not have to be reported in future years, the totals in future years declined precipitously, although no actual change in waste production may have occurred. Another reporting change caused the large increase in the 1991 totals. In that year, EPA implemented the Pollution Prevention Act of 1990 (PPA), a law which forced TRI respondents to start reporting off-site shipments to recycling and waste-to-energy facilities. Before the PPA, TRI respondents only had to report off-site shipments to treatment or disposal facilities. In U.S. EPA's official yearly TRI data release, year-to-year comparisons are made by removing from the database all records of chemicals that were added or subtracted from the chemical list. Also, EPA compares transfers from multiple years by attempting to screen out transfers to recycling or waste-to-energy facilities. This allows year-to-year comparisons to be made while removing most changes that are due to changes in reporting requirements. In our report, we have left all records in the database, since we are considering only the 1991 data year. Therefore totals from this report may not match the numbers given out in other sources.

Source: RTK Net, Washington, DC

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