Poisoning Our Water

How the Government Permits Pollution

Jeremiah Baumann
U.S. Public Interest Research Group Education Fund

Richard Caplan
U.S. Public Interest Research Group Education Fund

Richard Puchalsky
Grassroots Connection

February 2000
Poisoning Our Water
How the Government Permits Pollution

Jeremiah Baumann
U.S. Public Interest Research Group Education Fund

Richard Caplan
U.S. Public Interest Research Group Education Fund

Richard Puchalsky
Grassroots Connection

February 2000
Acknowledgments

The authors would like to thank the citizen outreach and field staff for their work in promoting
environmental reforms. Without their efforts, this report could not have been written.

In addition, we would like to thank the following people for their help with the research and
writing of this report: Carolyn Hartmann for offering critical guidance; Ed Mierzwinski for data
management advice; Jim Hecker of Trial Lawyers for Public Justice and Nancy Stoner of Natural
Resources Defense Council for reviewing a draft of the text and suggesting valuable insight;
Anna Aurilio and Liz Hitchcock of U.S. PIRG for their editing expertise; and Allison LaPlante
for her work on previous reports analyzing water pollution reported to TRI. We would also like
to thank Jim Amspacher, Rick Trilsch, Jen Mueller, and Tim Green for their assistance with the
production and distribution of this report.

U.S. PIRG Education Fund’s Toxics Right to Know Campaign is made possible through the
support of the Pew Charitable Trusts and the Bauman Foundation. The views expressed in this
report do not necessarily reflect the views of these supporters.

U.S. PIRG Education Fund is a non-profit, non-partisan consumer and environmental watchdog
organization. U.S. PIRG Education Fund, in association with the State PIRGs in 25 states,
conducts research and public education on public health, environmental, consumer, and
democracy issues.

The Grassroots Connection is an environmental consulting business specializing in the analysis of

environmental data and design of programs that provide public access to environmental data.

Cover photo: © Jim Richardson/CORBIS

This report is available on the web at www.pirg.org. Copies may be ordered by sending a check
or money order for $30 to:

U.S. PIRG Education Fund

218 D Street, S.E.
Washington, DC 20003
 Table of Contents
Page

Executive Summary i

I. The State of Our Nation’s Waters 1

II. Documenting the Pollution of America’s Waterways 3

A. Reported Toxic Releases: The Toxics Release Inventory 3

B. Illegal Discharges: Violations of Clean Water Act Permits 6

III. Findings: Our Waterways Are Used as Dumping Grounds 7

A. Reported Toxic Releases to Waterways in 1997 7

B. Polluters Violating the Law 11

IV. Discussion: Why Our Laws Have Failed to Stop Water Pollution 12

A. The Government Has Failed 12

B. Polluters Are Allowed to Evade the Law 13

C. The Public’s Right to Know Has Not Been Fully Recognized 17

V. Conclusions and Recommendations 21

Appendices

Appendix A: Toxic Discharge Data

Appendix B: Permit Compliance Data

Appendix C: EPA Memorandum

Appendix D: Discharge Summaries for Major Multi-State Bodies of Water

Appendix E: State-Specific Discharge and Compliance Data

 Executive Summary

When Congress passed the Clean Water Act in 1972, there was a visible water crisis that made a
compelling case for action. The Cuyahoga River literally caught on fire in 1969, and a spill off
the coast of California had left millions of gallons of oil along the coastline. The goals of the Act
– clearly stated – were to return all waterways to fishable and swimmable conditions by 1983 and
to eliminate the discharge of all pollutants by 1985. Nearly 30 years later, while the visible signs
of pollution may not be as evident as a burning river, a careful examination of the facts reveals a
continuing water pollution crisis in this country. Approximately 40% of our waters are still not
safe for swimming or fishing; there have been nearly 30,000 beach closings and advisories since
1988; and in 1998, 47 states issued fish consumption advisories because of high levels of
dangerous chemicals.

In order to look at exactly where we have failed in moving toward the goals of the Clean Water
Act, this report analyzes two different government databases on pollution. One is the
government’s publicly available Toxics Release Inventory (TRI), which details the amounts of
toxic chemicals being discharged to our waterways. The second is the government’s listing of
facilities that are in “Significant Non-Compliance” with their Clean Water Act permits,
information that can only be obtained through the Freedom of Information Act. Together they
provide a comprehensive overview of the amounts and types of pollution being discharged into
waterways, as well as the facilities that are in serious and chronic violation of the law.

Our research shows that current laws allow widespread toxic pollution of our rivers, lakes, and
streams, and that major polluters regularly violate even these inadequate laws. We found that
large companies and sewage treatment plants dumped almost 270 million pounds of toxic
chemicals into our waterways in 1997. In addition, while many of these releases may be allowed
under the law, nearly 30% of major facilities examined were in Significant Non-Compliance with
their Clean Water Act permits for at least one quarter from September, 1997 through December,
1998.

Among the report’s other major findings:

• The rivers receiving the largest amounts of toxic chemical releases were the
Mississippi River, the Connequenessing Creek (PA), the Brazos River (TX), the
Alafia River (FL), and the Houston Ship Channel (TX).

• More than 8 million pounds of persistent toxic metals (like lead and mercury) were
released into our waterways, an increase of more than 50% from the previous year
and the largest amount since at least 1992.

• Nearly 900,000 pounds of reproductive toxins (like toluene) were released into our
waterways, an increase of 60% from the previous year and the largest amount
released since at least 1992.

• More than 2.5 million pounds of carcinogens (like vinyl chloride and benzene) were
released into our waterways.

• The top ten states with the greatest number of major facilities in Significant Non-
Compliance were Texas, Florida, Ohio, New York, Alabama, Louisiana,
Pennsylvania, Indiana, Tennessee, and North Carolina.

i
 • The top ten states with the highest percentage of major facilities in Significant Non-
Compliance were Utah, Florida, Rhode Island, Ohio, Alabama, Tennessee,
Connecticut, Wyoming, Nebraska, and Indiana.

The continued dumping of hundreds of millions of pounds of toxic chemicals into our waterways
and the significant violation of the Clean Water Act by nearly 2,000 large facilities stems from
several specific policy failures. At the most basic level, the government, including both state
agencies and the U.S. EPA, have failed to properly deter polluters. Meanwhile, the courts have
eroded citizens’ ability to file suits in order to enforce the Clean Water Act. In addition,
regulators have failed to progressively lower permitted amounts of pollution in order to move
toward the zero-discharge goal of the Clean Water Act.

Community right-to-know laws have been another missed opportunity in the government’s efforts
to reduce and eliminate pollution. The Emergency Planning and Community Right to Know Act
which created the TRI led to significant voluntary reductions in reported toxic releases in the
early years that TRI data was released. In recent years, however, toxic pollution has begun to
increase. Also, because TRI has focused on end-of-the-pipe releases, the generation of toxic
waste has consistently risen even in cases where direct releases have decreased, meaning that
government and industry are failing to prevent pollution.

In order to make progress toward the basic goals of the Clean Water Act, U.S. PIRG recommends
the following:

1) Mandatory minimum penalties should be set that prevent polluters from profiting by breaking
the law. This approach has proved successful for New Jersey, which passed a tough Clean
Water Enforcement Act in 1990 which helped to reduce the state’s overall ranking in terms of
percentage of major facilities in Significant Non-Compliance to 41st (not including U.S.
territories). In 1995 they were ranked 16th, and in 1997 they were ranked 36th by percentage
of major facilities in Significant Non-Compliance.

2) The obstacles citizens face in the courts should be removed. This means that citizens should
be able to sue for past violations and be able to sue federal facilities.

3) Congress and the EPA should expand the current right-to-know program in order to fully
honor the public’s right to know and to effectively use public information as a tool for
eliminating pollution. This means requiring all polluting facilities to report all of their
pollution, much of which is currently exempted. Congress and EPA should also require
reporting not just on end-of-the-pipe pollution, but on toxic chemical use. This ‘materials
accounting’ reporting is required in Massachusetts and New Jersey, and both states have seen
dramatic reduction not just in direct releases, but in the generation of toxic wastes and in the
overall use of toxic chemicals.

ii
I. Introduction: The State of Our Nation’s Waters

In 1969, the Cuyahoga River near Cleveland burst into flames as a result of toxic contamination.
In the same year, an offshore oil rig near Santa Barbara spilled undetermined millions of gallons
of oil along the California coastline. These events highlighted an increasing problem: the waters
of the United States were facing a pollution crisis. The extent of the problem was emphasized
when the Council on Environmental Quality under President Nixon found that only 10 percent of
U.S. waters remained classified as unpolluted or even moderately polluted.1

In response, Congress passed, over a veto by President Nixon, the Federal Water Pollution
Control Act Amendments of 1972, better known as the Clean Water Act (CWA). The CWA
established a specific mandate: “to restore and maintain the chemical, physical and biological
integrity of the Nation’s waters.”2 In order to fulfill this mandate, Congress established the
following goals:

• Reduce pollution so that all waterways are fishable and swimmable by 1983, and

• Eliminate the discharge of pollutants into the Nation’s waterways by 1985.

In addition, the Clean Water Act increased the Federal government’s ability to enforce pollution.
Previous to the 1972 Amendments, under enforcement provisions such as the Water Pollution
Control Act of 1948, “reasonable periods of time” to take action against polluters were often
extended for lengthy periods of time. This was vastly streamlined by the provisions in Section
309 of the 1972 Act. If the Administrator of the U.S. EPA learned of any violation, she was able
to issue an administrative order requiring compliance or to initiate a civil suit against the
polluter.3

Troubled Waters
While the Act has made strides in cleaning up some waterways, the goals of the Act have clearly
never been met. The “fishable and swimmable” goal of the 1972 Act remains the unmet
benchmark of water quality in the United States:

• Approximately 40% of our rivers, lakes, and estuaries are still too polluted for safe
fishing or swimming.4

• From 1988 through 1998, there were over 29,996 closings and advisories for U.S. ocean,
bay, and Great Lake beaches, and 114 extended (6–12 weeks) closings and advisories.5

• 47 states issued fish consumption advisories in 1998, urging limited consumption of fish
from their waters due to contamination caused by substances like mercury, PCBs,

1
Council on Environmental Quality, Second Annual Report, at 218.
2
33 U.S.C. § 1251 (a) [C.W.A. § 101 (A)]
3
The Water Environment Federation. The Clean Water Act of 1987, 1987.
4
Charles Fox, Assistant Administrator for the Office of Water at the U.S. EPA, in testimony
before the House Agriculture’s Subcommittee on Department Operations, Oversight, Nutrition,
and Forestry on October 28, 1999.
5
Natural Resources Defense Council, Testing the Waters IX: A Guide to Water Quality at
Vacation Beaches, July 1999.

1
 chlordane, dioxins, and DDT and its byproducts (which continue to persist in our
environment).6

Although alarming events like a river catching fire may seem like the distant past, it is clear that
the level of pollution in U.S. waterways remains unacceptably high. Furthermore scientists are
increasingly finding that the threats to human health and the environment are more insidious than
once thought. Many toxic chemicals are able to persist in ecosystems for months, years, and even
decades, and can accumulate up the food chain and in human body tissues. Even small amounts
of these chemicals released into the environment pose a significant threat, and as a result almost
all Americans are at risk of consuming dangerous levels of chemicals that pose a serious risk of
cancer, immune suppression, or reproductive harm. The most recent summary of research on
dioxin – a substance linked to each of these health effects – concludes that Americans’ average
daily intake of dioxin is already above several federal guidelines and in the mid-range of
international guidelines for exposure.7

As troubling as these findings are, the true picture could be even worse. According to a report
written by current and former environmental officials, the U.S. Environmental Protection Agency
(EPA) is not rigorous in their monitoring of water quality. In fact, the report concludes that the
states are “free to manipulate numbers in order to falsely portray continuing progress in water
quality when, in fact, what fragmentary reliable information exists often suggests the exact
opposite.”8 A February 1999 PIRG Report found this to be true even for some of the most
dangerous pollutants. 9 Despite the fact that forty states have issued mercury advisories warning
citizens to limit fish consumption for at least one body of water, twelve states conduct no or very
limited monitoring of their waterways for mercury-contaminated fish.

America’s Dumping Grounds

The reason that American waterways have not recovered in accordance with the Clean Water
Act’s goals is simple: polluters continue to use our waterways as dumping grounds. This report
documents two aspects of this negligent and destructive habit. EPA allows too much pollution to
occur and then does not enforce the limits it sets.

First, for a glimpse of the pollution that enters our waterways, we examine water pollution data as
reported to the Toxics Release Inventory (TRI) for 1997. The TRI is the best source of public
information about toxic pollution in our environment, and consists of pollution estimates reported
by industrial facilities across the country. In order to create a more real picture of how these
releases impact our environment and our communities, we summarize the TRI data by body of
water.

Inconsistencies among EPA’s environmental programs and in EPA’s data management make it
nearly impossible to cross-reference TRI reports with the amounts of pollution that EPA or state
agencies have permitted. Among other problems, the Clean Water Act and the TRI cover
different sets of facilities (i.e. some facilities required to obtain Clean Water Act permits are not
required to report their pollution to TRI) and different sets of chemicals (similarly, facilities may
be required to report releases of certain toxic chemicals to TRI, but are not required to obtain

6
U.S. EPA, Update: National Listing of Fish and Wildlife Advisories, Office of Water, July 1999, EPA-
823-F-99-005.
7
Center for Health, Environment, and Justice, America’s Choice: Children’s Health or Corporate Profit –
the American People’s Dioxin Report (peer-reviewed summary of recent scientific findings). 1999.
8
Public Employees for Environmental Responsibility. Murky Waters, May 1999.
9
U.S. PIRG Education Fund. Fishing for Trouble, February 1999.

2
permits in order to release them). However, since industries report this information to EPA, the
toxic releases represented are at least tolerated, if not legally permitted, by EPA.

EPA or authorized states issue water permits to facilities through the National Pollutant
Discharge Elimination System (NPDES), established by EPA under the Clean Water Act. This
system requires all public and private entities intending to discharge pollutants into surface
waterways to obtain and comply with individual discharge permits. The permits generally contain
limitations on the quantity or concentration of pollutants that the facility can discharge.

Although the Act was premised upon a goal of zero discharge, its implementation has not come
close to that goal. EPA has sanctioned a permit-to-pollute system rather than a pollution
elimination system. The elimination of water pollution was to be accomplished through a gradual
tightening of permits based on emerging control technologies. Progressive permit tightening,
coupled with enforcement action against permit violators, would eventually reduce industrial and
municipal pollution levels to achieve the interim Clean Water Act goal of fishable and
swimmable waterways, and ultimately zero discharge.

Progressive permit tightening, however, has not occurred. The hundreds of millions of pounds of
reported toxic discharges documented in the TRI (and discussed in Section IIIA of this report)
show that the federal government has failed to move toward the goals which even the permitting
system’s name reflects – the elimination of polluting discharges.

In addition to the hundreds of millions of pounds of toxic water pollution legally allowed by EPA
every year and reported in the TRI database, water quality is further compromised by the
government’s failure to enforce the permitted limits on pollution and reporting. Many facilities
are in significant non-compliance with their permits, as defined by the EPA. This means they
discharge amounts of pollutants which far exceed designated limits and/or fail to file required
reports in a reasonable time frame.

U.S. PIRG has released several reports throughout the 1990s documenting this problem, and
showing that major point-source polluters seriously and chronically violate the law. 10 The
findings of this report, similar to our findings in other reports published in the past decade,
confirm that non-compliance with the Clean Water Act remains consistently and unacceptably
high.

II. Documenting the Pollution of America’s Waterways

A. Reported Toxic Releases: The TRI

The cataloging of toxic discharges in this report is based on data collected in EPA’s Toxics
Release Inventory (TRI) for the reporting year 1997, the most recent year available, as well as the
two previous years, 1996 and 1995. A previous version of this report summed 1992-1996 TRI
data; most results in this report use the 1997 TRI reporting year by itself, and sometimes give
separate results for 1996 and 1995 for comparison.

10
In 1997, PIRG found nearly 20% of major facilities were in Significant Non-Compliance (SNC) with
their CWA permits during at least one quarter between January 1995 and March 1996. In 1995, PIRG
found 20.5% of major facilities were in SNC between July 1993 and December 1994. In 1993, we found
21% of majors in SNC between October 1991 and September 1992. Because the time period covered and
reporting rules are not identical in all surveys, direct comparisons are inappropriate.

3
The Toxics Release Inventory was established by the Emergency Planning and Community Right
to Know Act (EPCRA) in 1986, a landmark law which gave the public the right to know about
the contamination of our environment and shined the spotlight on polluters nationwide (for more
background on EPCRA and TRI, see Section IV of this report).

The reporting requirements of the TRI apply only to manufacturing industries and, starting in
1994, federal facilities. This narrow focus excludes a large universe of water polluters, including
sewage treatment plants, oil drilling and gas extraction facilities, mining industries, incinerators
and other waste disposal facilities, farms, and stormwater systems. After a successful effort by
several public interest groups, including the State PIRGs, EPA in 1997 expanded the list of
industry sectors required to report their toxic discharges, but those facilities reported for the 1998
reporting year and that data will not be made available until later in 2000. However, even after
this expansion, many of the significant dischargers of toxic chemicals will not be required to
report toxic releases to the environment, including medical waste incinerators and industrial dry
cleaners.

The TRI is further limited in several ways:

• Companies were required to report the releases of only about 620 chemicals out of at least
70,000 chemicals regularly used in commerce, most of which have not been thoroughly tested for
basic toxicity.11

• In order to avoid burdening small businesses, EPA has exempted facilities with less than 10
employees from reporting their toxic releases.

• A facility only has to report toxic releases of chemicals for which more than 25,000 pounds
were “manufactured or processed” or more than 10,000 pounds were “otherwise used” during the
year. In October of 1999, EPA issued regulations reducing those thresholds for a narrow list of
substances known to persist in the environment or accumulate in the food chain or in human
tissues. However, the first reporting year for which those thresholds apply will be 2000, with data
expected to be made public in 2002.

With these significant limitations in place, the TRI data, while the most comprehensive
cataloguing of pollution, reflect only a portion of the actual pollution taking place.

Analyzing Direct Discharges by Body of Water

Discharges from TRI facilities were assigned to a given waterway based on the "receiving
stream" reported to the EPA. Most waterways reported as "tributary" streams were included with
their respective rivers in this report when both were listed. Rivers themselves, however, were not
considered part of larger watersheds. For example, a "Tributary to the Mississippi River" was
counted as Mississippi River, while the Missouri River was not, even though it eventually runs
into the Mississippi. Small streams receiving large quantities of discharges such as Gravely Run
in Virginia and Clear Creek in Colorado are reported individually, as reported to the TRI. Water
bodies with the same name in different states were not assumed to be contiguous without
verification. To avoid adding creeks from different states together, creeks had their state added to
their name if that name existed in more than one state (e.g. “Clear Creek, Colorado”). The same
was done for rivers unless it was verified that the same river ran through the multiple states in

11
EPA is currently embarking on a joint project with Environmental Defense and the Chemical
Manufacturers Association to conduct basic toxicity testing for approximately 2,700 of the chemicals
produced in the largest quantities in the U.S.

4
question. More than 1,800 different water body names were listed in the TRI database for this
period.

We calculated river by river totals for persistent toxic metals, carcinogens and chemicals known
to cause reproductive effects, based on information characterizing the toxic properties of these
substances previously published by the U.S. Environmental Protection Agency and the State of
California.12,13 References for chemical characterizations and lists of chemicals included are
found in Appendix A, Table 17.

Reporting Toxics Dumped Down the Drain

Enormous quantities of toxic chemicals are discharged to waterways via sewer systems. These
so-called “transfers” of toxic chemicals to publicly owned treatment works (POTWs) totaled
nearly 270 million pounds in 1997, compared to 218 million pounds of direct discharges to waters
reported in the same year (see Section III for more discussion of the amounts discharged to
POTWs in 1997). While the EPA does not count these transfers as environmental releases, they
estimate that 25 percent of these transfers flow through sewer systems untreated.14

To better estimate the amount of toxic chemicals that actually make it into the nation’s waters
each year, we used an estimated “pass-through percentage” for each chemical. This is the
percentage of the chemical that would pass through a sewer system and be released when the
chemical is transferred to a “typical” POTW. Pass-through percentages were obtained from
EPA's OPPT Risk Screening Environmental Indicators computer program (v1.0, 1988-1997 TRI
data).15 For some chemicals, a POTW pass-through percentage was not estimated in this source,
and for those we had to use EPA's general 25 percent estimate. Appendix A, Table 17 includes,
along with the chemical characterizations, the pass-through percentage used for each chemical. In
the charts used in this report, the amounts of direct releases to water are combined with “indirect”
releases estimated by multiplying the amount of each chemical sent to a POTW by its pass-
through percentage. Of the nearly 270 million pounds of toxic chemicals sent to POTWs in 1997,
we estimate that 51 million passed through and were released to surface waters. Unless otherwise
indicated, analyses and tables listed in this report include both reported direct toxic releases and
toxic releases estimated to have reached a waterway after passing through a POTW.

To identify the waters to which sewage treatment plants discharge effluent, we used an existing
survey of the top 50 POTWs receiving TRI transfers. Most of these had their effluent receiving
waters identified by the Environmental Working Group (EWG) for a previous version of this
report. In addition, we identified the receiving waters for many more POTWs by examining the
Permit Compliance System (PCS) water permits for municipal facilities in the city that the TRI
transfers were sent to. In all, receiving waters were identified for 234 of the top POTW cities
receiving TRI transfers in 1997. (It is often impossible to tell which municipal facility in a city is
being used from TRI information, so only cities in which all facilities discharged to the same
water body were included). The POTW cities with identified receiving waters accounted for
about 67 percent of the TRI chemicals sent to POTWs in 1997. POTW transfers whose receiving
waters were not identified were still included in all tables that do not summarize data by body of
water.

12
U.S. EPA, list of carcinogens used in the Public Data Release for the 1997 Toxics Release Inventory.
13
California Environmental Protection Agency, Lists of carcinogens and reproductive and developmental
toxins under Prop 65, version dated September 1999.
14
U.S. EPA. National water Quality Inventory: 1994 Report to Congress. Office of Water, December
1995.
15
U.S. EPA. Risk-Screening Environmental Indicators (CD-ROM), v1.0 (1988-1997 TRI data). July 1999.

5
B. Illegal Discharges: Violations of Clean Water Act Permits
Unfortunately, no centralized database with direct compliance information is easily available to
the public from EPA at this time. Therefore, in order to produce this report, U.S. PIRG has
obtained enforcement and compliance data from EPA under a Freedom of Information Act
(FOIA) request.

Permit Violators: Significant Non-Compliance Data

The data comes from the EPA’s Permit Compliance System (PCS) database. It is derived from
Discharge Monitoring Reports (DMRs), the periodic self-monitoring reports submitted by
permitted facilities to EPA regional offices and to state regulatory agencies in states with
delegated implementation authority. States and regions should be entering DMR data into the
PCS regularly, on a quarterly basis, so that EPA and citizens have accurate, up-to-date
compliance information on which to base enforcement or citizen suit targeting decisions.

The PCS screens the information from DMRs to identify “Reportable” and “Significant”
instances of permit non-compliance, which are violations of permit limits or reporting
requirements that have occurred at frequencies and magnitudes EPA considers to be of concern.
“Significant Non-Compliance” (SNC) is a screening tool used by EPA to identify and track the
most severe and chronic violations reported to the PCS.

The specific criteria used by EPA to identify the five basic types of violations that can earn a
facility SNC status are as follows:16

1. Exceeding a Monthly Effluent Limitation (E): This occurs when a facility discharges a
pollutant in an amount or concentration that exceeds the limit in its permit over a certain period of
time. A 40% exceedence of conventional pollutant limits or a 20% exceedence of toxic pollutant
limits that occurs for two months in a six month period, or any exceedence that occurs for four
months in a six month period, constitutes SNC.

2. Exceeding a Non-Monthly Effluent Limitation (X): The criteria here are the same as above,
except that when a permit has both a monthly average limit and a non-monthly average limit, a
facility would only be considered in SNC for the non-monthly limits if the monthly average is
also violated to some degree (but less than SNC).

3. Failure to Submit a Discharge Monitoring Report (D): This occurs when agency records
show no receipt of a required periodic self-monitoring report from the facility. Non-receipt of a
discharge monitoring report after 30 days may constitute SNC.

4. Violation of a Compliance Schedule (S): A compliance schedule is an agreement between a

permittee in violation of its permit and the enforcing regulatory agency. The compliance
schedule established a timeline and plan under which the violator will return to compliance. A
violation of a milestone or limitation in that compliance schedule may constitute SNC.

5. Failure to Submit a Compliance Schedule Report (T): This occurs when agency records
show no receipt of a mandated compliance schedule report for which a facility on an approved
compliance schedule is responsible.

16
See 40 C.F.R. part 123, and also U.S. EPA Memorandum from Steven A. Herman, Assistant
Administrator, “Revision of NPDES Significant Noncompliance (SNC) Criteria to Address Violations of
Non-Monthly Average Limits,” September 21, 1995.

6
EPA’s SNC enforcement screening tool applies only to “major” facilities. Thus, the data
presented in this report covers only the approximately 6,670 major industrial, municipal, and
federal facilities in the U.S. and its territories. Federal and industrial facilities are designated as
“major” based on an EPA scoring system that considers a combination of factors, including toxic
pollutant potential, streamflow volume, public health impacts, and proximity to coastal waters.
For example, a major municipal facility is a publicly owned treatment works (POTW) that serves
a population of 10,000 or more, discharges one million gallons or more of wastewater daily, or
has a significant impact on water quality.

Virtually no compliance information regarding the approximately 50,000 additional “minor”

NPDES facilities is available to the public. Due to the lack of public oversight and accountability
with respect to these smaller facilities, it is reasonable to expect that minor facility non-
compliance rates are even more substantial than those of the major facilities examined in this
report.

For many reasons, the SNC data still represents only a fraction of the problem regarding illegal
water pollution. As mentioned above, some states are free to manipulate numbers in order to
falsely portray continuing progress in water quality, and in addition states often fail to submit
their discharge monitoring reports in a timely manner. The problem of illegal pollution
continues, and a 1993 GAO report concluded that self-reporting NPDES facilities may have
incentives to hide rather than report environmental violations.17

Another problem is that SNC data sets an arbitrary definition of “significant.” To anyone living
near a facility discharging highly toxic substances, any violation is significant. A related problem
is highlighted in a memo to all Regional Water Management Division Directors from the
Assistant Administrator of the Office of Enforcement and Compliance Assurance: “I wish to
remind the Regions (and States) that they may remove SNC indicators in PCS for those
occasional violations that technically meet the SNC criteria but, in reality, do not constitute a
significant infraction.”18 This bureaucratic double-speak is a minimization of the harm caused by
polluting corporations and an abdication of EPA’s enforcement responsibilities.

Although the data should be correctly reported by industries and states, the Data Management
Branch at EPA notified all PCS state and regional coordinators in an additional message to verify
all data that was sent to U.S. PIRG (See Appendix C). In addition, in a personal communication
with the Data Management Branch, it was confirmed that coordinators were repeatedly notified in
monthly PCS conference calls that data should be verified.19

III. Findings: Our Waterways Are Used as Dumping Grounds

A. Reported Toxic Releases to Waterways in 1997

Almost 220 million pounds (218,423,778) of toxic chemicals were directly discharged to
America’s waters in 1997, according to Toxics Release Inventory (TRI) records (Appendix A,
Table 1). In addition, nearly 270 million pounds of toxic chemicals were discharged into sewer
systems and reported as “transferred” to publicly owned treatment works (POTWs).
17
General Accounting Office. Environmental Enforcement: EPA Cannot Ensure the Accuracy of Self-
Reported Compliance Monitoring Data, GAO/RCED-93-21, March 1993.
18
Herman 1995.
19
Personal communication with Lisa Raymer, Data Management Branch, January 6, 2000.

7
Conservative estimates suggest that nearly 51 million pounds of toxic substances made their
way through POTWs to rivers and other waters. This brings the total amount of toxic
chemicals released to America’s waterways in 1997 to nearly 270 million pounds (269,134,333).
Again, unless otherwise indicated, the specific amounts of toxic releases reported in this report
indicate both direct releases and our calculations of the amount reaching the body of water after
passing through a POTW.

The amount of toxic chemicals discharged to our waterways is increasing. Releases in 1997
were 18.7 percent higher than in 1996. While the U.S. EPA consistently points to greater than
40% reductions in toxic chemical releases overall since the TRI was established, this report
shows that industry and government are not reducing toxic chemicals releases across the board.

The Most Polluted Waters

The Mississippi River received the largest amounts of toxic discharges in 1997, nearly 60 million
pounds (Appendix, Table 3). The next five waterways receiving the largest amounts of reported
toxic releases were the Connoquenessing Creek in Pennsylvania, the Brazos River in Texas, the
Ohio River, the Alafia river in Florida, and the Houston Ship Channel in Texas.

This report analyzes data on toxic discharges for more than 1,500 water bodies. For 72 percent
of these water bodies, one polluter accounted for all reported toxic discharges during 1997;
for 89% of all polluted waters, three or fewer polluters accounted for all reported toxic discharges
during this time. These figures suggest that substantial improvements in local watersheds might
be possible through efforts that target a few major polluters.

States discharging the largest amounts of water pollution (Appendix A, Table 4)were Louisiana,
Pennsylvania, Texas, Mississippi, Ohio, Florida, and New Jersey, each discharging more than 9
million pounds of toxics to their waterways. Louisiana and Pennsylvania each discharged more
than 40 million pounds.

The Biggest Polluters

The facilities releasing the largest amounts of toxic pollution to water in 1997 can be seen in
Appendix A, Table 5. The top three facilities were the PCS Nitrogen Fertilizer facility in
Geismar, Louisiana, releasing nearly 30 million pounds; the Armco facility in Butler,
Pennsylvania, releasing more than 26 million pounds, and the BASF facility in Freeport, Texas,
releasing more than 14 million pounds. The PCS Nitrogen Fertilizer facility in Louisiana
discharged nearly 30 million pounds of toxic chemicals to the Mississippi River, meaning more
than half of the pollution entering the Mississippi (which received more than any other water
body in the U.S.) came from a single facility.

When year-to-year trends are examined, it is again clear that targeting these top polluters would
likely make substantial improvements in the long-term quality of local watersheds. Nine of the
ten biggest polluters were among the top 25 water polluters for all three years between 1995 and
1997; five were among the top 10 in all three years.

The parent corporations responsible for the most toxic releases to waterways in 1997 (Appendix
A, Table 6)were: Armco Inc., with nearly 32 million pounds of releases; PCS Nitrogen Fertilizer
LP, with more than 30 million pounds; BASF Corp., with more than 16 million pounds; E. I. Du
Pont De Nemours & Co. Inc., with nearly 9 million pounds; and Vicksburg Chemical Co., with
more than 8 million pounds.

8
It is important to note that many other facilities which released smaller amounts of toxic pollution
may have released pollutants with more potential to harm human health. Later discussion in this
report on carcinogens, persistent toxic metals, and reproductive toxins (see the next section, “The
Most Dangerous Pollutants”) will examine the facilities releasing the largest amounts of these
substances.

Chemicals Released in the Largest Amounts

The chemical discharged to America’s waterways in the largest amounts in 1997 (see Appendix
A, Table 7) were nitrate compounds (more than 156 million pounds), phosphoric acid (nearly 48
million pounds), methanol (more than 14 million pounds), and ammonia (more than 12 million
pounds). Nitrate compounds, phosphoric acid, and ammonia present serious threats to the aquatic
environment when discharged in large quantities like those reported here, because they are
converted to the nutrients nitrogen and phosphorus in water.

Through the process of eutrophication, phosphorus can ultimately deprive the freshwater
ecosystem of the oxygen needed to sustain life. Phosphorus pollution has been responsible for
numerous fish kills in the past. Nitrogen can contribute to this same process in salt water and
presents a serious threat to the health and economic viability of many of the nation’s bays and
estuaries. Phosphorus and nitrogen are primarily responsible for the low-oxygen conditions that
threaten whole ecosystems such as the Chesapeake Bay and portions of the Gulf of Mexico.

The Most Dangerous Pollutants

These releases present serious threats to human health and the environment. Every TRI chemical
is reported to the TRI because EPA considers it to be toxic. However, some TRI chemicals
present additional concerns because of their carcinogenicity, their ability to persist in the
environment for long periods of time, or reproductive toxicity (see Appendix A, Table 2). Nearly
11 million pounds (10,718,011) of carcinogens, persistent toxic metals, and reproductive
toxins were released to America’s waters in 1997. This figure represents the largest amount
reported since at least 1992.20 Of those releases:

• more than 8 million pounds of persistent toxic metals (like lead and mercury) were released, an
increase of more than 50% from the previous year and the largest amount since at least 1992.

• more than 400,000 pounds of reproductive toxins (like toluene) were released..

• more than 2.5 million pounds of carcinogens (like vinyl chloride and benzene) were released.

It should be noted that total discharges for these three categories do not add up to the 11 million
pounds cited above because some chemicals fall into more than one category (e.g. are both
reproductive toxins and carcinogens) but were only counted once in calculating the total.

Persistent Toxic Metals

The Ohio River received the largest amounts of persistent toxic metals in 1997 (see Appendix A,
Table 8), with 641,150 pounds of these compounds that natural systems are unable to break down
and will thus pose a long-term threat to the environment. The Ohio River was followed by the
Mississippi River, with 580,764 pounds; the Alabama River, with 488,424 pounds; Lake Erie
with 365, 481; and the Savannah River (GA, SC), with 312,596 pounds. Releases to Lake Erie
are of particular concern because of the already severe contamination of the Great Lakes by
persistent bioaccumulative toxic chemicals. This is problem is so severe that the International
20
Data on releases from 1992-1996 is summarized in U.S. PIRG, Troubled Waters, August 1998.

9
Joint Commission (a joint U.S.-Canadian governing body that handles Great Lakes issues) has
called for eliminating releases of persistent toxic chemicals.21 Despite such calls from
organizations and governments alike, this report demonstrates that the pollution of Lake Erie
continues at dangerous levels.

The facilities releasing the largest amounts of persistent toxic metals in 1997 (Appendix A, Table
9) were: Elkem Metals in Marietta, OH (453,000 pounds into the Ohio River); the Georgia-
Pacific facility in Zachary, Louisiana (260,000 pounds into the Mississippi); the International
Paper facility in Selma, Alabama (247,100 pounds into the Alabama River); the Champion
International facility in Courtland, Alabama (246,000 into the Tennessee River); the Georgia-
Pacific facility in Ashdown, Arkansas (243,000 into the Red River); and the Millennium
Inorganic facility in Ashtabula, Ohio (200,000 pounds into Lake Erie). The presence of two
Georgia-Pacific facilities among the top 5 releasers of carcinogens shows an outstanding level of
environmental irresponsibility. In fact, five of the top 6 facilities (all except Elkem Metals) are
owned by corporations that have more than one facility among the top 50 releasers of persistent
toxic metals. International Paper has at least seven facilities that are among the top 50; Georgia-
Pacific and Champion International each have at least five; and Millennium Inorganic has at least
three.

Alabama, Ohio, Georgia, Louisiana, and South Carolina were the states releasing the largest
amounts of persistent toxic metals to their waterways in 1997 (Appendix A, Table 10). Alabama
also stands out for the dramatic 207% increase since 1996 (355,974 pounds in 1996, 1,125,091
pounds in 1997). While Ohio registered a nearly 25% decrease in persistent toxic metal releases,
Georgia and Louisiana each had increases of more than 130%.

Reproductive Toxins
The water body receiving the largest amounts of chemicals that are toxic to the reproductive
system was the Delaware River, receiving an estimated 92,548 pounds of reproductive toxins
from facilities in Delaware, New Jersey and Pennsylvania (Appendix A, Table 11). The other
water bodies in the top 5 for reproductive toxin releases in 1997 were the Hudson River (NY,
NJ) with 41,039 pounds; the New York Harbor with 30,721 pounds; an unknown body of water
receiving 29,757 pounds from a POTW in Mentor, OH; and the Calcasieu River in Louisiana,
receiving 23,135 pounds. Notably, the New York Harbor received nearly ten times the amount of
reproductive toxins discharged to that body in either 1995 or 1996.

The facilities releasing the largest amounts of reproductive toxins in 1997 (Appendix A, Table
12) were: the Du Pont Chamber Works facility in Deepwater, New Jersey (82,802 pounds to the
Delaware River); the Wyeth Ayerst Pharmaceuticals facility in Pearl River, New Jersey (40,903
to the Hudson River); the Uniroyal Chemical facility in Painesville, Ohio (29,757 pounds through
a POTW to an unknown body of water); the Cardolite facility in Newark, New Jersey (26,988
pounds to the New York Harbor); and PPG Industries, Inc. in Lake Charles, Louisiana (23,000
pounds to the Calcasieu River). The bodies of water discharged into by these five facilities are the
facilities receiving the largest amounts of reproductive toxins, demonstrating again the severe
impact that one facility’s discharges can have on a body of water.

New Jersey, New York, Texas, Ohio, and Louisiana were the states discharging the largest
amounts of reproductive toxins in 1997 (Appendix A, Table 13). The state discharging the most,
New Jersey, discharged nearly 3 times the quantity of reproductive toxins discharged by the state
with the second largest amount (New York).

21
International Joint Commissions, Ninth Biennial Report on Great Lakes Water Quality. 1997.

10
Carcinogens
The Delaware River received the largest amount of carcinogen releases in 1997: 172,150 pounds
released from facilities in Delaware, New Jersey, and Pennsylvania (Appendix A, Table 14). The
water body receiving the second largest amount of carcinogens was an unknown water body in
San Diego, California. The releases were discharged to a water treatment facility there, which did
not report the name of the water body into which it was releasing chemicals. The other water
bodies in the top 5 for largest amounts of carcinogens released in 1997 were the Mississippi
River, receiving 127,749 pounds; the Houston Ship Channel (TX) receiving 124,200; and the
Atlantic Ocean, receiving 102,740 pounds from facilities in Maine, Puerto Rico, and Rhode
Island.

The facilities discharging the largest amounts of carcinogens in 1997 (Appendix A, Table 15)
were Rodel, Inc. in Newark, DE (104,550 pounds into the Delaware River); Fluid Sys. Corp. in
San Diego, CA (101,543 pounds through a POTW to an unknown body of water); Schering-
Plough Products Inc. in Manati, Puerto Rico (65,088 pounds into the Atlantic Ocean); Filtec
Corp. in Edina, MN (63,210 pounds through a POTW in St. Paul, MN, to an unknown body of
water); and Eastman Kodak Co. in Rochester, NY (56,499 pounds into the Genessee River).

The states with the highest amounts of carcinogens released to waterways in 1997 (Appendix A,
Table 16) were California, Texas, and Delaware. South Carolina, West Virginia,
Washington, New Jersey, Louisiana, Minnesota, Alabama, and Puerto Rico also each had
more than 100,000 pounds of carcinogens released to waterways. Alabama had more than 30%
more carcinogens released in 1997 than in 1996, and Louisiana had more than a 40% increase. In
Ohio, reported releases of carcinogens decreased by nearly 50%.

B. Polluters Violating the Law

Facilities in “Significant Non-Compliance”

An evaluation of the EPA’s Permit Compliance System data reveals that a total of nearly 30%
(29.36%) of major facilities (1,958 facilities) in the U.S., Puerto Rico, and U.S. Virgin Islands
were in Significant Non-Compliance, as defined by EPA, with their Clean Water Act NPDES
permits for at least one quarter during the 15 months beginning September 1, 1997 and ending
December 31, 1998. A total of 228 major facilities were in SNC during the entire 15 month
period (Appendix B, Table 7).

Industrial Facilities
A total of 661, or 26%, of the 2,555 major industrial facilities were in SNC during at least one of
the five quarters covered (Appendix B, Tables 5 and 6).

Municipal Facilities
A total of 1258, or 31%, of the 3,999 major municipal facilities were in SNC during at least one
of the five quarters covered (Appendix B, Tables 3 and 4). Most municipal facilities in this report
are POTWs. POTWs are designed to treat municipal sewage, but their non-compliance is often
the result of discharges from industrial “users” who discharge into sewer systems rather than
surface waters. Because most POTWs are not designed to treat many industrial chemicals, toxics
discharged into sewers either pass through the POTW untreated or contaminate the facility’s
sludge. The industrial users which create this pollution are not readily identified in the NPDES
reporting system analyzed in this report. While we have been able to determine for many

11
facilities discharging toxics to POTWs which POTW they discharge to, one cannot look at the
data on a particular POTW and determine where their toxics are coming from.

Federal Facilities
A total of 37, or 32% of the 114 major federal facilities were in SNC during at least one of the
five quarters covered. Considering that the federal government is supposed to be responsible for
implementation of our Clean Water Act and therefore should be setting an example, these figures
are particularly alarming.

States With the Most Violators

The top ten states with the greatest number of major facilities in SNC were Texas, Florida,
Ohio, New York, Alabama, Louisiana, Pennsylvania, Indiana, Tennessee, and North Carolina
(see Appendix B, Table 1). Texas, Florida, Ohio, Pennsylvania, Louisiana, New York, and
Alabama were also among the top ten in PIRG’s Dirty Water Scoundrels, covering non-
compliance data from January 1995 through March 1996.

The top ten states with the highest percentage of major facilities in SNC were Utah, Florida,
Rhode Island, Ohio, Alabama, Tennessee, Connecticut, Wyoming, Nebraska, and Indiana
(Appendix B, Table 2). Florida, Utah, Rhode Island, and Tennessee are repeat offenders on
PIRG’s top ten percentage list.

The above top ten lists do not include either Puerto Rico or the U.S. Virgin Islands, which rank
number one and three respectively for percentage of major facilities in SNC when included with
the 50 states. Puerto Rico also ranks sixth overall when compared to the 50 states and the Virgin
Islands in terms of number of major facilities in SNC.

Additional tables in Appendix B break down, state by state, industrial and municipal facilities
violating their permits. Table 7 in Appendix B lists each of the facilities in violation and what the
violation was for.

One state provides a good example of the effects of strong enforcement. New Jersey PIRG
worked to pass the New Jersey Clean Water Enforcement Act of 1990. This law includes
mandatory minimum penalties for serious violations and significant noncompliance, and requires
that penalties recover the economic gain polluters have realized through noncompliance. New
Jersey is now ranked 41st among states by percentage of facilities in SNC, a compliance rate
correlated to improvements in Clean Water Act enforcement.

IV. Discussion: Why Our Laws Have Failed to Stop Water Pollution

A. The Government Has Implemented a “Permit to Pollute” System Rather Than a

Pollutant Discharge Elimination System
The State of New Jersey provides a perfect example of where regulators’ permitting systems have
gone wrong. As mentioned above, in 1990, New Jersey PIRG worked to pass the New Jersey
Clean Water Enforcement Act. This law, with mandatory minimum penalties for serious
violations and significant noncompliance, and requirements that penalties recover the economic
gain polluters have realized through noncompliance, forced polluters to comply with permits at a
much higher rate. In this report, New Jersey ranks 41st among states by percentage of facilities in
SNC.

12
However, the TRI data discussed in Section III show that New Jersey ranks 1st in the nation for
releases of reproductive toxins and 7th for releases of carcinogens. New Jersey is also ranked 7th
in the nation for total releases of toxic chemicals. While compliance with Clean Water Act
permits has been relatively good since passage of state Clean Water Enforcement legislation, the
continued release of large amounts of hazardous chemicals reinforces the fact that the
government is simply granting facilities a license to pollute. New Jersey has fixed one aspect of
the problem – non-compliance – but failed to carry out the intention of the Clean Water Act, that
permits would be tightened in order to eventually eliminate dangerous pollution.

The practice of permitting dangerous pollution, rather than issuing progressively tighter permits
in order to eliminate dangerous pollution, is reflected by the TRI data nationally. This report
documents 270 million pounds of releases of chemicals considered by EPA to be toxic –
including 11 million pounds of carcinogens, persistent toxic metals, and reproductive toxins. If
EPA were regulating pollution with the Clean Water Act’s goal of eliminating water pollution in
mind, this level of toxic discharges would not be allowed. Furthermore, water pollution reported
to TRI is rising – 20% since 1996. Any permitting system which included the gradual tightening
of permits should not result in increases in toxic pollution.

B. Polluters Are Allowed to Evade the Law

In addition to having failed to progressively tighten permits, regulators have failed to enforce the
permits they issue. Three main reasons for the widespread, serious, and chronic violations of the
Clean Water Act are explored below.

1. Government Enforcement Has Been Weak and Sporadic

The most obvious explanation is that government enforcement of the Clean Water Act has been
lax. EPA and many of the delegated state agencies charged with implementing the Act have
lacked both the resources and the political will to enforce the law aggressively and provide a
credible deterrent against illegal pollution.

This series of U.S. PIRG Clean Water non-compliance reports, as well as studies by the General
Accounting Office22, the EPA Inspector General’s Office23,24,25 states26, law reviews27,28, and
others29,30 demonstrate that serious and chronic discharge violations are routinely ignored. These

22
General Accounting Office. Water Pollution – Many Violations Have Not Received Appropriate
Enforcement Attention, GAO/RCED-96-23, March 1996.
23
EPA Office of the Inspector General, Region 10's Wastewater Permit Program Needs Improvement to
Protect Water Quality in Alaska and Idaho, E1HWF7-10-0012-8100076, 1998.
24
EPA Office of the Inspector General, EPA’s Office of Water Data Integration Efforts Need to Be More
Focused and Significant, E1NWG6-15-0001-8100177, 1998.
25
EPA Office of the Inspector General, Region III Water Quality Standards, Monitoring, and Reporting,
E1HWF7-03-0160-9100118, 1999.
26
Joint Legislative Audit and Review Commission of the Virginia General Assembly, Review of the
Department of Environmental Quality, 1996.
27
Flatt, Victor B. “A Dirty River Runs Through It (The Failure of Enforcement in the Clean Water Act),”
25 Boston College Environmental Affairs Law Review, Fall 1997.
28
Yeo, Derek A. and Roy A. Hoagland, “United States v. Smithfield (972 F. Supp. 338 (E.D. Va. 1997)): A
Paradigmatic Example of Lax Enforcement of the Clean Water Act by the Commonwealth of Virginia,”
William and Mary Environmental Law and Policy Review, vol. 23, no. 2 (Spring 1999), p. 513-56.
29
Worth, Robert. “Asleep On The Beat,” The Washington Monthly, November 1999.
30
Cushman, John H., Jr. “E.P.A. and States Found to be Lax on Pollution Law: Enforcement is Faulted:
Agencies Are Failing to Inspect, Issue Permits and Report Violations, Audit Says,” New York Times, June
7, 1998.

13
studies have also argued that enforcement actions taken by EPA and states are frequently
ineffective in returning violators to compliance.

• According to Nikki Tinsley, EPA’s Inspector General, penalties assessed for polluters
are often too small to offset the economic gain received by breaking the law,
establishing a perverse incentive to pollute while creating a competitive disadvantage
for law-abiding companies. This, in addition to the large disparity between state
penalties, exacerbates the “race to the bottom” for states trying to attract polluting
industries that the Clean Water Act was designed in part to prevent.31

• In the past, despite serious and chronic violations, most enforcement actions have
been “informal slaps on the wrist” rather than formal actions, such as administrative
fines and penalties.32

• According to The Washington Monthly, one EPA regional official said her
administrator “will reduce or eliminate [their] enforcement response after
congressmen get in touch with him.” Despite being an egregious violation of EPA’s
ethics rules – aside from the damage it does to the public’s health and the Agency’s
credibility – she said it happens in up to one quarter of the cases she oversees.33

Unfortunately, the situation is getting worse, not better. At EPA headquarters, the number of
people doing enforcement work dropped from 340 in 1993 to 140 in 1997. According to a recent
report, prosecution of environmental crimes has fallen sharply during the Clinton administration.
One US attorney said, “Under the Clinton administration, environmental crimes have only been a
paper priority; there has been no real commitment of resources, expertise or organizational
muscle.”34 And on the state level, good enforcement work can be grounds for demotion, as
exemplified by Captain Ronald Gatto, a police officer with New York City’s Department of
Environmental Protection. After making 156 arrests for environmental crimes in the 1990s with a
100 percent conviction rate, Captain Gatto was harassed by Mayor Giuliani’s administration,
denied pay raises and promotions, and eventually reassigned away from enforcement.35

In a January 19, 2000 Press Release, the EPA announced what it described as record setting
enforcement numbers for 1999. Administrator Browner stated that, "This year's enforcement
statistics again send a strong signal that we will unfailingly take action against those who illegally
pollute the environment of our country." She put it even more bluntly at a recent press
conference announcing a $30 million fine – the largest in the history of federal environmental
laws – against Koch Industries, Inc. The company had more than 300 oil spills from its pipelines
and oil facilities in six states, totaling more than three million gallons of crude oil, gasoline, and
other products that leaked into ponds, lakes, rivers, and streams from 1990 to 1997.
Administrator Browner said, “It’s this simple: You pollute, you pay.”36 Unfortunately, polluters
are routinely breaking the law, and 30% of major facilities in Significant Non-Compliance
demonstrates that current enforcement is still not deterring polluters.

31
Worth, 1999.
32
Hembra, Richard. Director of Environmental Protection Issues at U.S. General Accounting Office,
Testimony before House Public Works Committee’s Subcommittee on Water Resources, May 1991.
33
Worth 1999.
34
Public Employees for Environmental Responsibility, Uneven Justice, December 1998.
35
“City Accused of Leashing Water Pollution Officer,” New York Times, June 19, 1999; and Worth 1999.
36
Fialka, John. J. “Koch Industries to Pay $30 Million Fine, Largest Under U.S. Environmental Law,”
Wall Street Journal, January 14, 2000.

14
Citizens Face Obstacles to Bringing Citizen Enforcement Suits
A second reason why polluters continue to violate the law at unacceptably high rates is that court
decisions, in addition to inadequate access to information, have limited the ability of citizens to
bring citizen enforcement suits against illegal polluters in their communities.

In light of the government inaction described above, citizens in affected communities are often
the only parties with the will to take firm action against polluters. Thus citizens are forced to play
an important role, filling in the void left by government by taking the most effective enforcement
actions against public and private offenders. However, this valuable and important role has been
made more difficult for citizens with recent court decisions, beginning particularly with a
decision in 1987.

After the total number of citizen suits brought (and won) under the Clean Water Act began to
increase in the 1980s, industry began to look for a way out of paying for their pollution. The
general counsel of the Chemical Manufacturers Association complained that his members would
have contested permit provisions of the Clean Water Act if they had known that their permits
were going to be enforced.37 Their solution: focus on the language of section 505 of the Act,
which authorizes suits against any person “alleged to be in violation” of the Act.

Using this language, the Supreme Court decided in 1987 that Gwaltney of Smithfield, which
operated a meat-packing plant that repeatedly violated its permit for five pollutants including
fecal coliform (31 violations), chlorine (34 violations), and total Kjeldahl nitrogen (87 violations),
could not be sued for its past violations. This case, Gwaltney of Smithfield v. Chesapeake Bay
Foundation38 opened a major loophole to polluters. Because citizens, unlike EPA or the states,
are required to provide polluters with 60 days notice of their intent to sue, violators often turn off
discharge pipes or install temporary fixes, so that once a suit is filed, the facility is no longer in
violation. Thus, they avoid litigation under the Gwaltney rule. Ironically, despite the fact that on
remand a Federal court determined that a violation is not considered ongoing if remedial
measures ensure that there is no reasonable prospect for recurrence,39 the same food processing
facility at the center of the debate was later cited by EPA for over 5,000 days of Clean Water Act
violations in 5 years.40 Smithfield was found liable and fined $12.6 million for multiple
violations of the Clean Water Act, and the decision to grant summary judgment by the District
Court was recently affirmed.41

Another barrier to citizen suits is presented by polluters’ sweetheart deals with state agencies.
The Clean Water Act prevents citizen suits from going forward when the government is
“diligently” enforcing the law against a particular polluter, and the courts have perversely
interpreted the definition of diligence. For example in Arkansas Wildlife Federation v. ICI
Americas, Inc.,42 one of the world’s largest chemical companies was fined $1,000 by the state in
April 1991 for 30 Clean Water Act violations over four years. When the Arkansas Wildlife
Federation (AWF) notified ICI of its intent to sue on those violations and others in July 1991, the
state “corrected” its consent order with ICI to cover the violations listed in the notice letter

37
Percival, Robert, et. al., Environmental Regulation: Law, Science, and Policy, Little, Brown and
Company, 1992.
38
484 U.S. 49 (1987)
39
Chesapeake Bay Foundation v. Gwaltney of Smithfield, Ltd., 844 F.2nd 170 (4th Cir. 1998)
40
Washington Post, October 23, 1996
41
U.S. v. Smithfield, 191 F. 3d 516 (4th Cir., 1999)
42
842 F. Supp. 1140 (E.D. Ark, 1993), aff’d 29 F. 3d 376 (8th Cir., 1994)

15
without increasing the fine. AWF filed suit in October 1991, and ICI continued violating its
permit while the case was pending. During the next year, the state “amended” the order three
times to: include the continuing violations, repeatedly extend the compliance deadline, waive
stipulated penalties for past violations, waive in advance penalties for future violations, and
suspend ICI’s monitoring and reporting obligations. The district court found in 1993 that these
actions by the state constituted diligent prosecution and dismissed the citizen suit, a decision later
affirmed by an appellate court.

Another disturbing recent trend in the courts is the erosion of citizens’ ‘standing’ to sue. The
U.S. Supreme Court has defined standing as comprising three requirements. One, the plaintiff
must show that she has suffered an ‘injury in fact.’ Two, she must establish ‘causation,’ meaning
that the injury “fairly can be traced to the challenged action.” Three, she must show that the
injury “is likely to be redressed by a favorable decision” of the court.43 The erosion of standing
can be demonstrated by some recent court decisions.

In 1997, a federal appeals court ruled that citizens living along a river in New Jersey and
represented by NJPIRG lacked standing under the Clean Water Act to sue a chemical company
for discharges into the river resulting in 155 separate permit violations.44 In 1998, the U.S.
Supreme Court ruled in Steel Company v. Citizens for a Better Environment that an organization
representing citizens living near an industrial plant in Illinois lacked standing to challenge a
company’s failure, over a period of seven years, to file TRI reports documenting the use and
storage of hazardous chemicals at the plant.45 This ruling came despite the fact that the steel
company in question came into compliance only after Citizens for a Better Environment had
investigated the company’s violations and filed a formal notice of its intent to bring suit.46

The most recent case the Supreme Court has heard on this subject is Friends of the Earth v.
Laidlaw Environmental Services,47 regarding a hazardous waste incinerator in Roebuck, South
Carolina. The polluter here released mercury into the North Tyger River,48 committing over
1,800 permit violations in all.49 Even though the polluter came into compliance only during the
course of the litigation, the trial court ruled that injunctive relief was no longer necessary.

The United States Court of Appeals for the Fourth Circuit, when looking at the case, made two
noteworthy decisions. Extending the decision in the Steel Company case mentioned above, the
appeals court ruled that the suit had to be dismissed as moot because, even though the incinerator
was still discharging excess levels of mercury when the suit was filed in 1992, the operator
acquired new anti-pollution equipment and stopped the discharges soon thereafter.50 Second, the
court reversed the trial court’s award of lawyers’ fees and court costs, becoming the only
appellate court to reject the so-called catalyst theory. Thus even though the polluter had only

43
Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-61 (1992)
44
Public Interest Research Group v. Magnesium Elektron, 123 F.3d 111 (3rd Cir. 1997).
45
Steel Company v. Citizens for a Better Environment, 118 S.Ct. 1003 (1998).
46
Echeverria, John D. and Jon T. Zeidler. Barely Standing: The Erosion of Citizen “Standing” to Sue to
Enforce Federal Environmental Law, Environmental Policy Project, Georgetown University Law Center,
1999.
47
Friends of the Earth, Inc., et al. v. Laidlaw Environmental Services (TOC), Inc., No. 98—822.
Argued October 12, 1999–Decided January 12, 2000.
48
Glaberson, William “Novel Antipollution Tool Is Being Upset by Courts,” New York Times, June 5,
1999.
49
Echeverria and Zeidler, 1999.
50
Greenhouse, Linda. “High Court Is Urged to Uphold ‘Citizen Suit’ to Curb Pollution,” New York Times,
October 13, 1999.

16
come into compliance as a result of the lawsuit (i.e. the suit was the catalyst for compliance), the
plaintiffs were entitled to no recovery for the time spent by their attorneys in achieving that result.
This undermines the intent of the CWA citizen suit provision by allowing polluting companies to
extend citizen suits, thus providing enough time to come into compliance by the time a judgment
is entered and avoid liability.

The Supreme Court’s ruling was a partial victory for the public and the environment. The Court
did rule that, where polluters continue to violate the law after the filing of a complaint, citizens do
have standing. But Laidlaw only applies where violations continued after the filing of the
complaint; otherwise Steel Company still applies. The majority opinion argued that civil
penalties could redress the plaintiff’s harm by deterring the polluter from future violations.
However, Justice Stevens’s argument that a suit should never be moot so long as civil penalties
are still at issue was not joined by any other Justices. In addition, the Court deferred ruling on the
question of attorney’s fees, noting only that the 4th Circuit issued its ruling in the absence of a
trial court decision awarding fees. This ruling, while an important victory, still does not address
the lack of standing to sue for past violations.

A further limitation of the ability of citizen suits to enforce the law exists because citizen
enforcers are prohibited from bringing penalty actions against the federal government for past
violations, which limits enforcement against federal facilities that violate their permits. In 1992
the Supreme Court created a double standard by which private water polluters and local
governments are subject to penalties while federal facilities that violate the Clean Water Act get
away paying nothing.51 In the most recent session of Congress, the attack on our environment
grew even more outrageous, with the signing into law of a rider, introduced by Senator Ted
Stevens (AK), which would exempt defense agencies from payment of fines or penalties for any
environmental violation by any military installation unless the payment was “specifically
authorized” by Congress.52 Instead of exempting its own facilities from complying with
environmental laws, the government, one of the nation’s worst polluters, should be leading the
effort for clean and safe water by example.

C. The Public’s Right to Know Has Not Been Fully Recognized

Citizen access to information about environmental problems and the polluters that are the source
of those problems can be a powerful tool in the fight to preserve our environment and protect our
health. The landmark law that first acknowledged not only the public’s right to know about toxic
chemicals released to our environment, but also the power of that information, was the
Emergency Planning and Community Right to Know Act (EPCRA). EPCRA, passed as an
amendment to Superfund reauthorization legislation, established the Toxics Release Inventory
(TRI), one source of data for this report. EPCRA requires certain industries to report to EPA and
to the public their releases of approximately 600 chemicals to the air, land, and water, as well as
certain types of waste management involving those chemicals. Perhaps the most crucial aspect of
the TRI is that it is made available to the public in a comprehensive, online database.

51
State of Ohio v. U.S. Department of Energy, 112 S.Ct. 1627 (1992).
52
Editorial. “Reverse Rider,” Washington Post, November 17, 1999.

17
Requiring polluting industries to publicly
report their hazards provides citizens, Communities Use Right-to-Know Information
communities, and decision-makers with
information they need to make informed Northfield, MN: Using TRI data, labor unions and
community groups successfully negotiated a new
decisions and to fight pollution. These may labor contract to include an agreement to reduce
include decisions on where to live, where to and eliminate the use of methylene chloride, a
work, or where to send children to school. At probable carcinogen.
the community level, these may include Arcata, CA: TRI data gave citizens the information
decisions to file enforcement suits or decisions they needed to file a citizen suit alleging that a
on strategies for reducing pollution. Louisiana-Pacific facility’s formaldehyde releases
Information provided in TRI has also provided violated California’s Prop 65, which requires
many citizens’ groups with the information companies to actively warn citizens about potential
they need to convince government officials or exposure to unsafe levels of toxic chemicals.
industry representatives to take action to reduce New York, NY: A facility in Brooklyn had been
pollution (see box on previous page). releasing the chemical toluene in such quantities
that residents suffered headaches and nausea. For a
By shining a public spotlight on the polluters, citizens’ group that had been pushing for
right-to-know laws also provide polluting government action for 12 years, TRI data provided
industries with a public incentive to reduce the final impetus for the state agency to issue
their discharges. Through analysis provided by tighter regulations.
Source: Working Group on Community Right-to-Know,
government, media, and public interest groups, Working Notes.
public attention is focused on those facilities
and companies who are creating the greatest
hazards to public health and the environment through the pollution they release. This attention, in
turn, pressures facilities to reduce their pollution (see box at left), even in situations where
government may be failing to enforce or tighten permitted pollution limits.

The TRI has been one of the most successful environmental programs, given the reduction in
pollution achieved in the absence of new regulatory action by the government. The success of the
Industries Respond to the Public Pressure TRI points to the potential for public
Created by Right-to-Know Information information to be used under other laws, such
“The law is having an incredible effect on as the Clean Water Act, to be used in
industries to reduce emission, and that’s good. achieving the goals of those laws. In
There’s not a chief executive officer around who addition, the TRI’s successes exaggerate its
wants to be the biggest polluter in Iowa.” own flaws and gaps and point to the potential
Tom Ward, Monsanto’s Muscatine, IA facility, for this landmark right-to-know program to
Quad City Times, June 8, 1990 move the country closer toward eliminating
pollution.
“We were doing things to reduce emissions because
of the TRI program. I’ll be honest with you. It
probably would not have occurred if that data had The Public’s Right to Know About Clean
not become public information. It was something Water Enforcement
that caught everyone’s attention, including the President Clinton, Vice President Gore, and
corporate leaders.” EPA Administrator Browner have each
Harold Bozarth, Chemical Industry Council of New publicly and repeatedly committed to
Jersey, Asbury Park Press, March 28, 1993 protecting and expanding the public’s right to
know, and have made significant expansions
“Quite frankly, we want to get off that list.” of the TRI database of toxic chemical
Joe Fallon, Slater Steels Corporation
discharges. However, this commitment has
Indianapolis Star, April 10, 1990
not extended to citizens’ ability to access
discharge information that they not only have the right to know about, but also need to know in
order to fight illegal water pollution in their communities.

18
Accessing Permit and Compliance Information
The most basic problem in this area is that EPA has not made all information from its Clean
Water Act Permit Compliance System (PCS) database available on-line to the public. This
information, which is already collected and simply needs to be made accessible, would help
communities to take action against polluters. Yet despite being organized and easily
communicable with the public, it is still not easy to retrieve. The average citizen should not have
to file a Freedom of Information Act request and wait several months for data on whether
facilities are operating in accordance with the law. In addition, EPA has failed to exercise its
authority to post safety warnings at access points to polluted waterways used for fishing and
swimming.

Understanding Permit and Compliance Information

A second problem in accessing EPA’s data on permits and compliance is our inability to compare
that information with other information maintained by EPA. Because the permit compliance
system database consists of data gathered under different parameters, we could not determine in
this report whether, for a specific facility, the discharge reported to TRI was in compliance with
the facility’s permit or not. For example, many permits are written in terms of the maximum
concentration of a given pollutant allowed in the facility’s wastewater stream. The permitted
amount may be in parts per million. However, facilities report their estimated discharges to TRI
by the number of pounds released over the course of an entire year. A direct comparison is
difficult, and on a national level, nearly impossible.

Allowing Polluters to Keep the Public in the Dark

Finally, states are passing “audit privilege” or “immunity” laws that dangerously undermine the
public’s right to know. Even though most companies are already required to find and correct
their own violations under the environmental statutes, audit privilege laws are premised on the
notion that companies need an incentive to comply with the law. The incentive provided is the
ability to conceal information from law enforcement officials and the public, and to obtain
complete penalty immunity for self-reported violations. State audit laws like these promote
corporate secrecy and prevent citizens in affected communities from holding corporations
accountable for the pollution they create.

The Erosion of Compliance Standards

Finally, the states and EPA allow the erosion of the standards by which compliance is judged.
Initiatives such as EPA’s Project XL (eXcellence and Leadership) threaten to erode uniform
compliance standards and decentralize monitoring and reporting systems to the detriment of both
the public’s right to know and the enforcement of our environmental laws. The purpose of
Project XL is to provide greater regulatory flexibility to industry, often by streamlining reporting
and eliminating permit reviews. Some of the XL programs include: a temporary exemption from
hazardous waste storage, handling, and shipment rules for Molex Incorporated, an electronics
corporation; allowing annual certification to replace monthly reporting for Weyerhaeuser, a large
timber and paper company; removing hazardous waste pretreatment requirements for HADCO
Corporation, also an electronics corporation; and streamlining hazardous waste removal processes
and granting “flexibility” in wetlands mitigation, reporting requirements, and risk assessment
criteria and analyses for Exxon.53

53
U.S. EPA. Project XL: From Pilot to Practice: A Journey to System Change. September 1999. EPA
100-R-99-007

19
The Toxics Release Inventory: Successful, but Limited
The TRI has often been called one of the United States’ most successful environmental programs.
The EPA points to a reduction in reportable on- and off-site releases of more than 40% (for
chemicals reported on in all years) since the TRI was first created.54 While significant decreases
were recorded in the first years that the TRI was published, in recent years the decrease has
slowed. In fact, 1997 was the first year to show an overall increase (2.2%) in direct releases.55 As
discussed in this report, the increase in releases to waterways between 1996 and 1997 was even
more dramatic.

Even for the significant reductions in toxic releases triggered by TRI, most studies have found
that some actual reductions have occurred, but that many reported reductions are due to
‘phantom’ reductions. These include changes in estimation methods or definitions (like that of
recycling) which result in fewer toxic releases reported, but not necessarily fewer released. Other
false reductions occur when facilities make changes that result in actual reduction in direct
releases, but not necessarily in the use of fewer or less toxic chemicals or in the generation of less
toxic waste. For example, some facilities may contract highly polluting processes out to other
companies, switch to a chemical for which no reporting is required (but may not be any safer), or
even incorporate toxic chemicals into products.

The TRI’s biggest failure has been in the area of pollution prevention. TRI reporting has focused
on ‘end-of-the-pipe’ toxic releases and on management of toxic waste. This has led industries to
respond with measures that allow them to report fewer releases; meanwhile, the generation of
toxic waste has steadily increased. Total production-related waste has risen by more than 8%
since 199156, showing that even though facilities are releasing less waste directly to the
environment, more is being generated overall. While the facilities themselves may not release the
waste directly to the environment, most of it ends up being disposed of in ways that negatively
impact the environment and public health – being discharged by POTWs (as documented in this
report), being converted to toxic sludge, or being incinerated, among other waste disposal means.

This means that facilities and regulators are failing to prevent pollution. To truly protect the
environment and human health, facilities need to focus on pollution prevention – process and
product changes that result in less use of toxic chemicals and less generation of toxic waste –
rather than on efforts to limit the amount of pollution that reaches the environment once toxic
waste has already been produced. One of the simplest ways to promote pollution prevention
would be to fill in gaps in the current TRI and to focus reporting on information relevant to
pollution prevention.

One reason that facilities have failed to prevent pollution, and ultimately to protect the
environment and human health, is that the reporting requirements under the Right to Know Act
allow major sources of toxic chemicals to go unreported. In addition they fail to provide the
information necessary to accurately track pollution prevention.

Direct releases are under-reported because major industrial polluters are not among the industrial
sectors who are required to report. Until a 1997 EPA rulemaking, facilities like mines, utilities,
and hazardous waste incinerators are not required to report. Those facilities did not report for the
1997 reporting year, and so are not included in the findings of this report. While toxics reports

54
U.S. EPA, 1997 Toxics Release Inventory. 1999.
55
Ibid.
56
Ibid. Analysis includes only chemicals which were on the reported list for all years, 1991-1997.

20
from new industrial sectors will be released in 2000, many polluters will still not be included.
Among them are medical waste incinerators and industrial dry cleaners.

In addition, TRI does not include information on facilities’ use of toxic chemicals. This type of
reporting, often referred to as ‘materials accounting,’ provides the public and policymakers with
information on chemicals brought on-site, including how they are transported through facilities,
used in facilities where neighbors or family members may work, and placed in products. In
addition, focusing reporting on chemical use focuses reduction efforts on chemical use and
pollution prevention.

The State PIRGs worked to pass strong right-to-know laws in Massachusetts and New Jersey,
which require materials accounting. The results in Massachusetts show the power of right-to-
know and the effectiveness of pollution prevention: facilities there have reduced toxic chemical
use by 24%, toxic waste generation by 41%, and toxic chemical releases by 80%.57 In addition,
the pollution prevention resulting from these strong right-to-know laws has shown how process
changes resulting in less waste can save corporations money. A 1995 study estimated that for
every $1 spent on additional reporting requirements in New Jersey, facilities saved $5-$8 because
they spent less on purchasing expensive raw materials and on treating or disposing of hazardous
wastes.58

V. Conclusions and Recommendations

A. Strengthen Implementation and Enforcement of the Clean Water Act

Now more than 25 years after passage of the Clean Water Act, and with its most basic promises
still unfulfilled, it is clear that we need to strengthen enforcement of the law. Unless illegal
pollution is stopped and vigorously punished, and legal pollution is phased out by technological
improvements, the Act’s vision of waters safe enough for fishing and swimming and free of toxic
pollutants that threaten our health and our future will never be realized.

The PIRGs have worked hard for over two decades to strengthen enforcement of the Clean Water
Act. New Jersey PIRG helped pass the nation’s strongest Clean Water Enforcement law in 1990
and CALPIRG helped pass the Clean Water Enforcement and Pollution Prevention Act in the
summer of 1999.

Based on experiences with successful policies at the state level, the State PIRGs strongly
recommend the following solutions.

1. Set Mandatory Minimum Penalties for Permit Violations

Consistency and deterrence are fundamental components of a successful enforcement program.
Non-compliance must be addressed quickly rather than waiting for patterns of chronic violation,
something that has been made clear by the state of New Jersey. As a result of the passage of New
Jersey’s Clean Water Enforcement Act, which requires mandatory minimum penalties for the
worst polluters, the state now has one of the lowest percentages of facilities in SNC in the
country. In addition, swift, consistent and predictable enforcement in New Jersey has deterred

57
Massachusetts Department of Environmental Protection, press release, 1999.
58
U.S. EPA, Report to President Clinton – Expansion of Community Right-to-Know Reporting to Include
Chemical use Data: Phase III of the Toxics Release Inventory.

21
dischargers from allowing compliance problems to become chronic, resulting in a decrease in the
number of penalty actions and the amount of penalties assessed.

Congress should make government enforcement programs more credible, consistent, effective,
and equitable by amending the Clean Water Act to require state programs to establish mandatory
minimum penalties for significant violations of the Act. Mandatory minimum penalties will help
ensure that polluters, not taxpayers, pay for the damage they create. The worst polluters should
know that there will be repercussions for breaking the law, and Congress should consider
revoking NPDES permits for repeat offenders.

2. Prohibit Profits From Polluting

The existing Clean Water Act allows “economic benefits” to be taken into consideration when
assessing penalties. Unfortunately this authority is greatly underutilized; penalties rarely recover
the profits companies gain from their noncompliance. In other words, under current Clean Water
enforcement practices, it pays to pollute illegally, which creates incentives to break the law,
allows states and violators to cut sweetheart deals, and places those who comply with the law at a
competitive disadvantage.

Congress should amend the Act and create a strong disincentive to break the law. In order to do
this, courts and administrative hearing officers must assess a penalty that exceeds the amount of
economic benefit gained by the polluter as the result of its non-compliance. To assist in this
effort, any state with an authorized Clean Water Act program should be required to collect and
report all fines levied and collected against polluters so that there will be accountability in the
system.

3. Remove Current Obstacles to Citizen Suits

Citizens Should Be Able to Sue For Past Violations

Congress should amend the Clean Water Act to allow citizens to sue for past violations.
Congress amended the Clean Air Act in 1990 to allow citizens to commence an action against any
person “who is alleged to have violated, if there is evidence that the alleged violation has been
repeated, or to be in violation” of the Act. We urge Congress to similarly amend the Clean Water
Act, thus harmonizing the two statutes and remedying the effects of Gwaltney.

Citizen Suits Should Not Be Precluded by Inadequate Government Enforcement Actions

Citizens should not be barred from bringing actions against polluters by a loophole in the law that
allows sweetheart deals between violators and government regulators. Congress should amend
the CWA by deleting the provision that allows certain government enforcement actions to
preclude citizen enforcement. In addition, Congress should explicitly clarify that only judicial or
enforcement actions that recoup the full economic benefit gained by violating the law should be
allowed to preclude subsequent citizen enforcement. At the same time, to ensure that defendants
will not be penalized unduly for the same violation, the Act should be amended to allow courts to
offset penalties imposed in a prior enforcement action.

Citizens Should Be Able to Bring Penalty Actions Against Polluting Federal Facilities
Federal facilities that pollute illegally should be subject to the same enforcement pressures as
other facilities. Congress should explicitly waive the federal government’s sovereign immunity
and specifically authorize citizens, as well as EPA and the states, to bring penalty actions against
federal facilities for past violations.

4. Expand Whistleblower Protections

22
The best source of information about what a facility is actually doing or not doing is often its own
employees. However, for employees to provide information, they must be assured that they will
not lose their jobs or otherwise suffer retaliation by the polluter.

However, the whistleblower provisions in the Clean Water Act provide only limited protection to
employees. Congress should amend the Act by extending the statute of limitations from 30 days
to one year, amending the burden of proof to make it uniform with the burden of proof provided
federal employees pursuant to the Whistleblower Protection Act, and requiring posting of
employee rights by CWA permittee.

B. Expand the Public’s Right to Know

Public access to information on pollution problems is a powerful catalyst for reducing pollution.
Congress should take action to: increase citizen access to Clean Water Act permit and compliance
information; expand the TRI to include all sources of toxic pollution and information on the use
of toxic chemicals; and integrate the information gathered under various environmental programs
so that citizens can make meaningful comparison, better understand the problems facing our
environment, and take action to solve those problems. Legislation currently before Congress,
H.R. 1657, would expand the information currently gathered under TRI to include chemical use
or ‘materials accounting’ information.

1. Increase Access to Compliance Data and Discharge Reporting

Access to accurate and consistent reporting is fundamental to the success of the
Clean Water Act’s permitting and enforcement programs. Without it, protection of our
waterways is impossible. Congress should amend the Clean Water Act by requiring that:

(a) all “major” facilities discharging to ground waters, surface waters, or treatments
works facilities must submit discharge monitoring reports (DMRs) on a monthly
basis; other permit holders must submit DMRs on at least a quarterly basis, and
states should be required to input this data into the EPA Permit Compliance
System;
(b) all Significant Industrial Users of Publicly Owned Treatment Works (POTWs)
must file DMRs monthly with the treatment works, states, and EPA regional
offices, and states should be required to input this data into the EPA Permit
Compliance System;
(c) EPA must make compliance data on its computerized Permit Compliance System
database easily available to the public, including online Internet access which
should be searchable by facility and location in a national database format;
(d) EPA should integrate environmental reporting and access to environmental data
across different programs so that citizens can more easily determine various
environmental conditions relevant to their geographic area or to a particular
facility.

2. Expand right-to-know reporting to include toxic chemical use information.

Currently the public only receives information on toxic chemical releases to the environment and
certain types of toxic waste management. The public is left in the dark about chemicals used in
the workplace, transported through communities, and placed in products we buy. Without this
chemical use, or “materials accounting” information, the public is kept in the dark, industry will
miss many valuable opportunities to significantly lower pollution costs, and public policy makers
will be unable to create strategies that will most effectively prevent toxic chemical hazards.

23
3. Require reporting to the Toxics Release Inventory from all significant sources of toxic
pollution, including sewage treatment plants, medical and solid waste incinerators, and the
oil and gas industry.
The Clinton Administration has made some significant expansions to the public’s right to know
by adding seven new industries to the Toxics Release Inventory, including hazardous waste
treatment facilities, sections of the mining industry, and utilities (a major source of mercury
pollution in our waters). However, many other significant sources of water pollution are still
exempt from reporting requirements, including sewage treatment plants, medical and solid waste
incinerators, and the oil and gas industry.

4. Lower reporting thresholds for all toxic substances which persistent in the environment
or accumulate up the food chain or in human tissues.
The Clinton Administration in October 1999 issued regulations lowering the reporting thresholds
that have let releases of many of the most dangerous substances, used and released in small but
dangerous quantities, go unreported in the past. The regulations cover toxic chemicals that have a
tendency to persist in the environment and bioaccumulate as they move up the food chain, and as
such are extremely dangerous in very small quantities. Unfortunately, the regulations cover only
substances which both persist and bioaccumulate, neglecting dangerous substances like cadmium,
which are highly toxic and persistent, but which may not accumulate up the food chain. In
addition, the regulations do not yet apply to lead and lead compounds – highly toxic substances
that both persist and bioaccumulate. The EPA is currently developing rules that will lower
thresholds for lead, but the process has been delayed twice. We urge the EPA to swiftly finalize
regulations requiring industries to report all releases of lead and lead compounds and to act to
require complete reporting on environmental releases of other persistent bioaccumulative
substances not covered by the October 1999 rulemaking.

24
Appendix A:

Toxic Discharge Data Tables

Table 1
Total Direct and Indirect Toxic Releases to Water, 1995-1997
Year Direct releases (lbs) Indirect releases (lbs) Total releases (lbs)
1995 175819177 51195812 227014989
1996 179229835 47428830 226658665
1997 218423778 50710555 269134333

Table 2
Total Releases to Water of Carcinogens, Reproductive Toxins, and Persistent Toxic Metals (incl.
estimated discharges through POTWs)
Percent of lbs
Total releases Total releases Total releases (lbs) from POTWs
Type (lbs) 1995 (lbs) 1996 1997 1997
OSHA Carcinogens 2,775,565 2,790,503 2,564,959 52.3
Prop 65 Reproductive Toxins 658,312 535,797 425,685 53.9
Persistent Toxic Metals 4,364,835 5,369,466 8,092,212 12.7
All special toxic categories 7,397,049 8,331,756 10,718,011 22.7
All TRI chemicals 227,014,989 226,658,665 269,134,333 18.8
Note: Some chemicals fall into more than one category (e.g. are both reproductive toxins and carcinogens).
Because theses are included in each category total but are only counted once in the total for all specal toxic
categories, the total for all categories does not equal the sum of each category.

Source: U.S. PIRG, Compiled from the U.S. EPA’s 1997 Toxics Release Inventory.

Appendix A, Tables 1 & 2

Table 3
Water Bodies Receiving the Largest Discharges of Toxic Chemicals
Toxic Percent of lbs
release (lbs) from POTWs
Rank Receiving waters States 1997 1997
1 Mississippi River AR, IA, IL, KY, LA, MN, MO, MS 57,698,880 2.9
2 Connoquenessing Creek PA 29,809,300 0
3 Brazos River TX 14,366,370 0
4 Ohio River IL, IN, KY, OH, PA, WV 9,394,678 13
5 Alafia River FL 7,047,663 0
6 Houston Ship Channel TX 6,868,275 85.2
7 Cape Fear River NC 4,825,901 0
8 Savannah River GA, SC 4,771,110 1
9 Delaware River DE, NJ, PA 4,378,209 14.1
10 Rock River, IL IL 3,818,291 0
11 Schuylkill River PA 3,558,161 0
12 Canal -- UNNAMED INDUSTRIAL CANAL (state: TX) TX 3,139,790 0
13 Willamette River OR 2,982,633 1.8
14 Hudson River NJ, NY 2,861,894 9.4
15 Kanawha River WV 2,500,552 0
16 Pacific Ocean CA, HI, OR 2,181,424 25.2
17 Tennessee River AL, KY, TN 2,147,554 1.1
18 Muskingum River OH 2,069,438 0
19 Columbia River OR, WA 1,859,047 47.3
20 Raritan River NJ 1,818,400 100
21 Big Sioux River SD 1,811,575 0.6
22 Gravelly Run VA 1,662,429 88.9
23 Little Attapulgus Creek GA 1,651,075 0
24 Fox River, WI WI 1,604,257 2.9
25 Morses Creek NJ 1,600,004 0
26 Kiskiminetas River PA 1,549,075 3
27 Cedar River IA 1,372,282 37.5
28 Illinois River IL 1,361,999 73.9
29 Curtis Bay MD 1,309,261 0
30 Snake River ID, OR 1,263,681 0.9
31 Wisconsin River WI 1,260,502 0
32 Bachman Run PA 1,257,830 100
33 Big Blue River IN, MO, NE 1,219,431 0
34 Utah Lake UT 1,213,779 0
35 Detroit River MI 1,197,665 96.4
36 James River, VA VA 1,135,614 0
37 New York Harbor NJ 1,135,338 100
38 Tombigbee River AL 1,129,130 0
39 Pagan River VA 1,064,298 0
40 Okatoma Creek MS 1,042,400 0
41 Iowa River IA 996,765 0
42 Unknown - POTW release in Lake Norden, SD SD 984,658 100
43 Oak Creek, OR OR 965,000 0
44 Lake Erie NY, OH, PA 949,146 63.1
45 Nimishillen Creek OH 943,922 0
46 New River, VA VA 879,925 0
47 Yazoo River MS 872,088 0
48 Center Creek MO 828,802 0
49 Carquinez Strait CA 820,935 0
50 Allegheny River PA 805,082 0

Source: U.S. PIRG, Compiled from EPA's 1997 Toxics Release Inventory. Unless otherwise indicate, figures include estimated discharges through POTWs.

Appendix A, Table 3
Table 4
States With the Largest Toxic Releases to Waterways in 1997
Total releases Percent of lbs from
Rank State (lbs) 1997 POTWs 1997
1 Louisiana 46,991,144 0.2
2 Pennsylvania 40,713,054 5.4
3 Texas 27,833,927 25.3
4 Mississippi 12,022,166 0.6
5 Ohio 9,798,549 38.1
6 Florida 9,735,503 11.3
7 New Jersey 9,130,836 40.9
8 Georgia 8,208,989 12.5
9 North Carolina 7,400,967 12.7
10 Illinois 7,392,747 34.3
11 California 7,240,874 41
12 West Virginia 7,189,617 5.8
13 Virginia 6,100,174 36.7
14 New York 5,539,367 21.2
15 Oregon 5,378,815 20.7
16 Missouri 5,248,477 36.5
17 Alabama 5,026,111 5.3
18 Wisconsin 4,978,900 40.3
19 South Carolina 4,129,213 35.9
20 Iowa 4,123,227 36.5
21 Indiana 3,394,437 31.9
22 Michigan 3,263,676 83.8
23 South Dakota 2,819,344 36.2
24 Washington 2,768,155 11
25 Tennessee 2,641,406 40.6
26 Maryland 2,392,639 15.3
27 Minnesota 2,065,114 84.3
28 Arkansas 1,851,915 2.8
29 Kentucky 1,366,017 51
30 Utah 1,342,709 8.4
31 Idaho 1,321,069 14.6
32 Colorado 1,191,392 22.1
33 Connecticut 1,117,623 40
34 Kansas 1,040,800 45.1
35 Maine 1,030,804 3.3
36 Oklahoma 951,725 24.8
37 Nebraska 784,168 30.7
38 Massachusetts 685,921 92.8
39 Delaware 673,703 65.9
40 North Dakota 552,962 20.5
41 Puerto Rico 373,007 95.3
42 Alaska 333,613 0
43 Arizona 290,258 98.4
44 New Hampshire 210,365 45.4
45 Vermont 189,417 0.2
46 Montana 97,358 0.2
47 Rhode Island 84,409 97.4
48 New Mexico 50,112 83.9
49 Virgin Islands 25,723 0
50 Nevada 9,406 100
51 Wyoming 7,518 0.4
52 Hawaii 2,119 0
53 District Of Columbia 228 97.8

Source: U.S. PIRG, compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 4
Table 5
Facilities Releasing the Largest Amounts of Toxics to Water in 1997.
Total Percent of lbs
releases (lbs) from POTWs
Rank Facility Name City State 1997 1997
1 PCS Nitrogen Fertilizer L.P. Geismar LA 29,775,103 0
2 Armco Inc. Butler Ops. Butler PA 26,004,479 0
3 BASF Corp. Freeport TX 14,011,739 0
4 Vicksburg Chemical Co. Vicksburg MS 8,139,102 0
5 Mulberry Phosphates Inc. Mulberry FL 7,046,420 0
6 IMC-Agrico Co. Faustina Plant Saint James LA 4,982,487 0
7 Exxon Co. USA Baton Rouge Baton Rouge LA 4,100,844 0
8 IBP Inc. Joslin IL 3,800,505 0
9 Armco Inc. Butler Ops. Butler PA 3,800,377 0
10 Smithfield Packing Co. Inc. Tar Heel NC 3,683,194 0
11 Carpenter Tech. Corp. Reading PA 3,243,035 0
12 Bayer Corp. New Martinsville WV 3,206,967 0
13 Air Prods. Inc. Pasadena TX 3,160,857 100
14 Bayer Corp. Baytown Baytown TX 3,139,790 0
15 Du Pont Chambers Works Deepwater NJ 3,086,517 0
16 IMC-Agrico Co. Uncle Sam Plant Uncle Sam LA 2,555,826 0
17 Finch Pruyn & Co. Inc. Glens Falls NY 2,464,200 0
18 DSM Chemicals N.A. Inc. Augusta GA 2,417,169 0
19 Du Pont Belle Plant Belle WV 2,412,000 0
20 Armco Inc. Coshocton Ops. Coshocton OH 2,016,573 0
21 John Morrell & Co. Sioux Falls SD 1,802,925 0.2
22 IBP Inc. Columbus Junction IA 1,710,500 0
23 J & L Specialty Steel Inc. Midland PA 1,700,309 0
24 Engelhard Corp. Attapulgus Attapulgus GA 1,651,075 0
25 Bayway Refining Co. Linden NJ 1,600,004 0
26 Louisiana-Pacific Corp. Samoa Samoa CA 1,528,210 0
27 Allegheny Ludlum Corp. Leechburg PA 1,502,110 0
28 BASF Corp. Geismar LA 1,402,410 0
29 Fort James Operating Co. Green Bay WI 1,400,250 0
30 Grace Davison Baltimore MD 1,309,261 0
31 Hercules Inc. Aqualon Div. Parlin NJ 1,295,881 100
32 Wacker Siltronic Corp. Portland OR 1,295,182 0.6
33 Williamsport Wirerope Works Williamsport PA 1,258,080 100
34 Geneva Steel Vineyard UT 1,213,779 0
35 Wah Chang Albany Albany OR 1,106,487 0
36 Allegheny Ludlum Corp. New Castle IN 1,104,810 0
37 Smithfield Packing Co. Inc. Smithfield VA 1,067,030 0.3
38 Sanderson Farms Inc. Collins MS 1,042,400 0
39 Engelhard Corp. Savannah Ops. Savannah GA 1,012,787 0
40 Davisco Lake Norden Food Lake Norden SD 984,658 100
41 Oregon Metallurgical Corp. Albany OR 965,000 0
42 J & L Specialty Steel Inc. Louisville OH 940,218 0
43 U.S. Army Radford Army Radford VA 859,208 0
44 BWX Techs. Lynchburg VA 858,876 0
45 Hercules Inc. Hopewell VA 858,717 100
46 Dyno Nobel Carthage MO 828,802 0
47 Shell Martinez Refining Co. Martinez CA 820,930 0
48 Mississippi Chemical Corp. Yazoo City MS 795,942 0
49 Elkem Metals Co. Marietta OH 784,000 0
50 Syntex Agribusiness Inc. Springfield MO 781,672 100

Source: U.S. PIRG, Compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 5
Table 6
Parent Companies Releasing the Most Toxics to Water in 1997
Percent of lbs
Total releases from POTWs
Rank Parent company (lbs) 1997 1997
1 Armco Inc. 31,875,913 0
2 PCS Nitrogen Fertilizer LP 30,451,913 0.1
3 BASF Corp. 16,192,599 1.8
4 E. I. Du Pont De Nemours & Co. Inc. 8,682,727 2.3
5 Vicksburg Chemical Co. 8,139,102 0
6 IMC-Agrico Co. 7,613,323 0
7 Mulberry Corp. 7,046,420 0
8 Smithfield Foods Inc. 6,948,289 4.7
9 Bayer Corp. 6,694,359 3.5
10 IBP Inc. 5,983,902 1.1
11 Allegheny Teledyne Inc. 5,599,615 0.9
12 Exxon Corp. 5,141,109 0.1
13 Air Prods. & Chemicals Inc. 3,531,092 90.1
14 Carpenter Tech. Corp. 3,260,653 0.5
15 J & L Specialty Steel Inc. 2,790,634 5.4
16 Engelhard Corp. 2,727,152 2.3
17 Georgia-Pacific Corp. 2,688,358 1.6
18 GMC 2,569,272 89.6
19 International Paper Co. 2,528,470 11.6
20 Finch Pruyn & Co. Inc. 2,464,200 0
21 DSM Chemicals Holding Co. Inc. 2,417,169 0
22 Hercules Inc. 2,222,798 99.5
23 Fort James Operating Co. 2,206,361 0
24 Sanderson Farms Inc. 2,195,343 0.2
25 Tosco Refining Corp. 2,132,295 3.7
26 Shell Oil Co. 1,917,900 0.1
27 Louisiana-Pacific Corp. 1,785,777 0
28 Dyno Nobel Inc. 1,515,204 0
29 W. R. Grace & Co. 1,349,080 1
30 Wacker Siltronic Corp. 1,295,182 0.6
31 Eastman Kodak Co. 1,292,029 5.2
32 Williamsport Wirerope Works Inc. 1,258,080 100
33 Geneva Steel 1,213,779 0
34 Stone Container Corp. 1,171,179 82.6
35 GE Co. 1,160,156 40
36 Amoco Corp. 1,142,384 1.7
37 U.S. Department Of Defense 1,140,378 0.8
38 Boise Cascade Corp. 1,076,478 66.5
39 Davisco Foods Intl. Inc. 984,658 100
40 Mccain Foods Ltd. 894,936 0
41 Kimberly-Clark Corp. 892,565 0
42 Mississippi Chemical Corp. 889,104 0
43 Chevron Corp. 884,750 0.2
44 Mcdermott Intl. Inc. 858,876 0
45 Weyerhaeuser Co. 852,424 0
46 Champion Intl. Corp. 840,061 0
47 Gold Kist Inc. 803,426 1.2
48 Elkem Metals Co. 784,000 0
49 Syntex USA Inc. 781,839 100
50 Temple-Inland Inc. 758,418 0

Source: U.S. PIRG, Compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 6
Table 7
Chemical Discharged in the Largest Amounts to U.S. Waters in 1997
Percent of lbs
Reason for Total releases from POTWs
Rank Chemical Name Concern (lbs) 1997 1997
1 Nitrate compounds 1 156,260,860 4.7
2 Phosphoric acid 1 47,637,698 8.7
3 Methanol 1 14,044,416 50
4 Ammonia 1 12,810,373 44.8
5 Glycol ethers 1 9,308,254 96.4
6 Nitric acid 1 4,828,531 91.3
7 Manganese compounds 1,3 4,447,113 5.4
8 Ethylene glycol 1 2,839,891 77.5
9 Hydrochloric acid 1 2,077,297 99.9
10 Zinc compounds 1,3 1,340,824 10.2
11 Sodium nitrite 1 1,237,292 61.1
12 Sulfuric acid 1 1,137,484 97.9
13 Barium compounds 1,3 1,026,674 8.4
14 Chlorine 1 879,774 65.8
15 Bromine 1 780,805 100
16 Hydrogen fluoride 1 524,857 94
17 tert-Butyl alcohol 1 515,500 94.3
18 Formaldehyde 1,2 436,805 43.5
19 N,N-Dimethylformamide 1,2 370,998 87.7
20 1,4-Dioxane 1,2 336,417 41.7
21 Manganese 1,3 331,933 55.5
22 Acetaldehyde 1,2 280,653 20.4
23 Diethanolamine 1 278,963 46
24 Phenol 1 277,754 80.5
25 Chloroform 1,2 271,825 39.4
26 Methyl tert-butyl ether 1 271,481 39.7
27 Formic acid 1 252,374 86.1
28 n-Butyl alcohol 1 239,585 66.7
29 Cyanide compounds 1 238,554 72.6
30 N-Methyl-2-pyrrolidone 1 157,946 82.3
31 Copper compounds 1,3 157,787 32.9
32 Chromium compounds 1,3 152,847 34.9
33 Nickel compounds 1,2,3 151,855 38.5
34 Molybdenum trioxide 1 144,342 72.5
35 Acetonitrile 1 139,722 94.7
36 Triethylamine 1 127,193 85.5
37 Dichloromethane 1,2 119,264 92
38 1,3-Phenylenediamine 1 116,838 10.9
39 Aniline 1,2 100,893 88.9
40 Antimony compounds 1,3 98,495 72.3
41 Methyl ethyl ketone 1 90,403 53.8
42 Copper 1,3 88,652 54.4
43 Cyclohexane 1 82,124 1.7
44 m-Dinitrobenzene 1,4 81,587 0
45 Propylene oxide 1,2 71,644 68
46 2-Methoxyethanol 1,4 68,134 76.5
47 Nickel 1,2,3 65,297 61.8
48 N,N-Dimethylaniline 1 62,817 97.8
49 Carbon disulfide 1,4 61,534 53.4
50 Toluene 1,4 61,247 49.4
Reason for Concern: 1 = Meets EPA's TRI Toxicity criteria
2 = Known, possible, or probable carcinogen
3 = Persistent toxic metal
4 = Reproductive toxin

Source: U.S. PIRG, Compiled from EPA's 1997 Toxics Release Inventory. Figures include discharges through POTWs.

Appendix A, Table 7
Table 8
Water Bodies Receiving the Most Discharges of Persistent Toxic Metals, 1997
Percent of lbs
Total releases from POTWs
Rank Water Body States (lbs) 1997 1997
1 Ohio River IL, IN, KY, OH, PA, WV 641,150 7.1
AR, IA, IL, KY, LA, MN, MO,
2 Mississippi River MS, TN, WI 580,764 7.8
3 Alabama River AL 488,424 0
4 Lake Erie NY, OH, PA 365,481 5.8
5 Savannah River GA, SC 312,596 0
6 Tennessee River AL, KY, TN 271,357 0
7 Red River, AR AR 243,000 0
8 Androscoggin River ME, NH 211,571 0
9 Coosa River AL, GA 192,699 0.1
10 Catawba River NC, SC 171,616 0.2
11 St. Croix River ME, WI 169,400 0
12 Patapsco River MD 156,562 0
13 Neches River TX 149,065 0
14 Kickapoo Creek IL 146,761 100
15 Sulphur River TX 135,461 0
16 Pearl River LA, MS 113,556 0
17 Genesee River NY 111,330 0
18 Eleven Mile Creek FL 111,000 0
19 Wateree River SC 100,007 0
20 Tombigbee River AL 98,675 0
21 Mobile River AL 95,402 0
22 Columbia River OR, WA 81,567 2
23 Willamette River OR 80,669 0.1
24 Houston Ship Channel TX 76,501 9.4
25 Great Pee Dee River SC 76,497 0
26 Grays Harbor WA 75,400 0
27 Bellingham Bay WA 74,812 0
28 Cooper River SC 73,531 0
29 Pigeon River NC, TN 69,199 0
30 Tennessee Tombigbee Waterway MS 67,962 0
31 Hudson River NJ, NY 62,529 3.3
32 Staulkinghead Creek LA 59,670 0
33 Chattahoochee River AL, GA 53,548 1.7
34 Thames River CT 52,692 0
35 Roanoke River NC, VA 52,472 0
36 Pacific Ocean CA, HI, OR 52,212 50.2
37 Black Creek, AL AL 51,800 0
38 Unknown - POTW release in St. Paul, MN MN 47,707 100
39 Fenholloway River FL 47,300 0
40 Sampit River SC 46,090 0
41 Chesapeake Bay MD 43,376 100
42 Paper Mill Creek TX 42,593 0
43 Wabash River IL, IN, OH 42,144 6.5
44 Menominee River MI, WI 39,126 0
45 Garland Creek, OK OK 37,053 0
46 Harmon Creek WV 36,612 0
47 Utoy Creek GA 35,000 0
48 Unknown - POTW release in Tyndall Air Force Base, FL 33,873 100
49 Escatawba River MS 33,568 0
50 Delaware River DE, NJ, PA 31,035 20.7

Source: U.S. PIRG, Compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 8
Table 9
Facilities Discharging the Largest Amounts of Persistent Toxic Metals
Total releases
Rank Facility Name City State Water Body (lbs) 1997
1 Elkem Metals Co. Marietta OH Ohio River 453,000
2 Georgia-Pacific Corp. Port Zachary LA Mississippi River 260,000
3 International Paper Riverdale Selma AL Alabama River 247,100
4 Champion Intl. Courtland Mill Courtland AL Tennessee River 246,000
5 Georgia-Pacific Ashdown Ops. Ashdown AR Red River, AR 243,000
6 Millennium Inorganic Ashtabula OH Lake Erie 200,000
7 International Paper Augusta Augusta GA Savannah River 170,740
8 Georgia-Pacific Corp. Woodland ME St. Croix River 169,400
9 Bowater Inc. Coated Paper & Catawba SC Catawba River 168,208
10 Millennium Inorganic Baltimore MD Patapsco River 150,000
11 Anamet Electrical Inc. Mattoon IL Kickapoo Creek 146,760
12 Inland Eastex Evadale TX Neches River 145,600
13 Mellennium Inorganic Ashtabula OH Lake Erie 140,000
14 International Paper Co. Domino TX Sulphur River 135,461
15 International Paper Jay ME Androscoggin River 134,800
16 PCS Nitrogen Fertilizer L.P. Geismar LA Mississippi River 129,600
17 Alabama River Pulp Co. Inc. Perdue Hill AL Alabama River 122,000
18 Georgia-Pacific Corp. Monticello MS Pearl River 112,896
19 Eastman Kodak Co. Kodak Park Rochester NY Genesee River 111,330
20 Champion Intl. Corp. Cantonment FL Eleven Mile Creek 111,000
21 Inland Paperboard & Packaging Rome GA Coosa River 110,650
22 Union Camp Corp. Eastover SC Wateree River 99,600
23 Kemira Pigments Inc. Savannah GA Savannah River 90,700
24 Weirton Steel Corp. Weirton WV Ohio River 84,721
25 U. S. Alliance Coosa Pines Coosa Pines AL Coosa River 81,400
26 Gulf States Paper Corp. Demopolis AL Tombigbee River 80,800
27 Crown Paper Co. Berlin Mill Berlin NH Androscoggin River 76,770
28 International Paper Mobile Mobile AL Mobile River 75,500
29 Weyerhaeuser Pulp Mill Cosmopolis WA Grays Harbor 75,400
30 Weyerhaeuser Co. Longview WA Columbia River 75,354
31 Georgia-Pacific West Inc. Bellingham WA Bellingham Bay 74,812
32 Champion Intl. Corp. Canton NC Pigeon River 69,170
33 Macmillan Bloedel Packaging Pine Hill AL Alabama River 61,600
34 International Paper Co. Bastrop LA Staulkinghead Creek 59,670
35 Columbus Pulp & Paper Complex Columbus MS Tennessee Tombigbee Waterway 59,350
36 Smurfit Newsprint Corp. Newberg OR Willamette River 59,210
37 Union Camp Corp. Prattville AL Alabama River 57,000
38 Great Southern Paper Co. Cedar Springs GA Chattahoochee River 52,620
39 Pfizer Inc. Groton Site Groton CT Thames River 52,500
40 Gulf States Steel Inc. Gadsden AL Black Creek, AL 51,800
41 Union Camp Corp. Savannah GA Savannah River 50,700
42 Champion Intl. Corp. Roanoke Rapids NC Roanoke River 47,400
43 Buckeye Florida L.P. Perry FL Fenholloway River 47,300
44 Champion Intl. Corp. East Houston TX Houston Ship Channel 47,160
45 Crown Paper Co. Saint Francisville LA Mississippi River 47,000
46 International Paper Co. Georgetown SC Sampit River 46,090
47 Willamette Ind. Inc. Marlboro Bennettsville SC Great Pee Dee River 45,535
48 Finch Pruyn & Co. Inc. Glens Falls NY Hudson River 44,200
49 Twin City Tanning Co. LLP South Saint Paul MN Unknown - POTW release in St. Paul, MN 43,134
50 Westvaco Corp. Kraft Div. North Charleston SC Cooper River 42,900

Source: U.S. PIRG, Complied from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 9
Table 10
States With the Largest Releases of Persistent Toxic Metals in 1997
Total Percent of lbs
releases from POTWs
Rank State 1997 (lbs) 1997
1 Alabama 1,125,091 0.7
2 Ohio 946,970 8.5
3 Georgia 594,588 5.1
4 Louisiana 562,679 0.1
5 South Carolina 501,891 5.5
6 Texas 484,761 4.8
7 Maine 334,117 5
8 Arkansas 281,929 2.2
9 Mississippi 270,975 0.8
10 New York 261,869 24.6
11 Maryland 259,072 21.6
12 Illinois 252,843 83.1
13 Washington 249,679 0.4
14 Florida 224,939 16.4
15 North Carolina 168,405 9.7
16 Indiana 167,084 32.7
17 Pennsylvania 141,532 18.5
18 West Virginia 130,991 1.5
19 Michigan 120,543 39.3
20 Oregon 110,921 2.8
21 Kentucky 97,631 19.9
22 Minnesota 96,461 61.7
23 Tennessee 92,899 25.1
24 New Hampshire 78,127 1.2
25 Wisconsin 75,443 39
26 Connecticut 63,857 6.2
27 Virginia 61,742 30.7
28 Missouri 50,775 87.8
29 California 48,550 73.7
30 Oklahoma 46,009 12.8
31 New Jersey 37,358 54.1
32 Delaware 32,716 7.1
33 Iowa 26,115 78.9
34 Nebraska 20,200 19.1
35 Utah 14,627 21.1
36 Massachusetts 13,144 89.8
37 Idaho 8,771 1.7
38 New Mexico 8,223 2.1
39 Colorado 6,254 29.1
40 Kansas 5,225 60
41 Montana 5,110 1.7
42 Vermont 4,203 1.6
43 Rhode Island 3,733 93.5
44 Arizona 1,873 97.7
45 Puerto Rico 1,684 48.8
46 South Dakota 224 97.8
47 District Of Columbia 223 100
48 North Dakota 37 8.1
49 Hawaii 10 0
50 Wyoming 6 100
51 Nevada 0 0

Source: U.S. PIRG, compiled from EPA's Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 10
Table 11
Bodies of Water Receiving the Largest Amounts of Reproductive Toxins
Percent of lbs
Total releases from POTWs
Rank Water Body States (lbs) 1997 1997
1 Delaware River DE, NJ, PA 92,548 10.3
2 Hudson River NJ, NY 41,039 99.7
3 New York Harbor NJ 30,721 100
4 Unknown - POTW release in Mentor, OH OH 29,757 100
5 Calcasieu River LA 23,135 0
6 Illinois River IL 22,379 92.7
7 Houston Ship Channel TX 17,879 96.3
8 Ohio River IL, IN, KY, OH, PA, WV 12,466 3
9 San Jacinto Bay TX 10,318 0
AR, IA, IL, KY, LA, MN,
10 Mississippi River MO, MS, TN, WI 9,590 40.4
11 Tombigbee River AL 8,698 0
12 Bouie River MS 6,905 0
13 Trinity River TX 6,760 100
14 Unknown - POTW release in San Diego, CA CA 6,386 100
15 Unknown - POTW release in Loudon, TN TN 6,158 100
16 Congaree River SC 5,800 0
17 Appomattox River VA 5,544 100
18 Maumee Bay OH 4,709 0
19 Pacific Ocean CA, HI, OR 4,607 100
20 Vermillion River IL 4,591 100
21 Unknown - POTW release in Plymouth, MA MA 4,494 100
22 Mobile River AL 3,849 0
23 Unknown - POTW release in Kansas City, KS KS 3,666 100
24 Dixon Creek TX 3,455 0
25 Unknown - POTW release in Tonawanda, NY NY 3,336 100
26 Atlantic Ocean ME, PR, RI 3,106 100
27 Holston River TN 2,333 0
28 Unknown - POTW release in Greenville, SC SC 2,175 100
29 Merrimack River MA, NH 2,064 100
30 Kanawha River WV 1,961 0
31 Grand Calumet River IN 1,800 0
32 Detroit River MI 1,645 63.5
33 Unknown - POTW release in Salt Lake City, UT UT 1,612 100
34 Unknown - POTW release in West Deptford, NJ NJ 1,469 100
35 Gravelly Run VA 1,404 15.6
36 Arkansas River AR, CO, KS, OK 1,284 0
37 Allegheny River PA 1,176 0
38 Boston Harbor MA 1,173 100
39 Great Miami River OH 1,170 100
40 Cumberland River TN 1,100 0
41 Red Draw Reservoir TX 1,100 0
42 Chickasaw Creek AL 1,002 0
43 Unknown - POTW release in Oakmont, PA PA 999 100
44 Unknown - POTW release in Lynchburg, VA VA 951 100
45 Unknown - POTW release in St. Paul, MN MN 865 100
46 Naugatuck River CT 849 100
47 Lake Michigan IL, IN, MI, WI 829 100
48 Watauga River TN 750 0
49 Unknown - POTW release in Jefferson, LA LA 748 100
50 Walnut River KS 740 0

Source: U.S. PIRG, compiled from EPA's Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 11
Table 12
Facilities Releasing the Largest Amounts of Reproductive Toxins
Total
releases (lbs)
Rank Facility Name City State Water Body 1997
1 Du Pont Chambers Works Deepwater NJ Delaware River 82,802
2 Wyeth Ayerst Pharmaceuticals Pearl River NY Hudson River 40,903
3 Uniroyal Chemical Co. Inc. Painesville OH Unknown - POTW release in Mentor, OH 29,757
4 Cardolite Corp. Newark NJ New York Harbor 26,988
5 PPG Ind. Inc. Lake Charles LA Calcasieu River 23,000
6 Viskase Corp. Bedford Park IL Illinois River 17,834
7 Du Pont La Porte Plant La Porte TX San Jacinto Bay 10,318
8 Occidental Chemicals Plant Pasadena TX Houston Ship Channel 9,630
9 Ciba Specialty Chemicals Corp. Mc Intosh AL Tombigbee River 8,698
10 OSI Specialties Inc. Friendly WV Ohio River 7,235
11 Sun Refining & Marketing Co. Marcus Hook PA Delaware River 6,996
12 Hercules Inc. Hattiesburg MS Bouie River 6,905
13 Cuplex Inc. Garland TX Trinity River 6,760
14 Fluid Sys. Corp. San Diego CA Unknown - POTW release in San Diego, CA 6,386
15 Viskase Corp. Loudon TN Unknown - POTW release in Loudon, TN 6,158
16 Eastman Chemical Co. Carolina Eastman Columbia SC Congaree River 5,800
17 B.I. Chemicals Inc. Petersburg VA Appomattox River 5,544
18 BP Oil Co. Toledo Refy. Oregon OH Maumee Bay 4,709
19 Devro-Teepak Inc. Danville IL Vermillion River 4,591
20 Tech-Etch Inc. Plymouth MA Unknown - POTW release in Plymouth, MA 4,494
21 Union Carbide Corp. Taft/Star Taft LA Mississippi River 4,132
22 Lyondell-Citgo Refining Co. Houston TX Houston Ship Channel 4,129
23 Harcros Chemicals Inc. Kansas City KS Unknown - POTW release in Kansas City, KS 3,666
24 3M Tonawanda Tonawanda NY Unknown - POTW release in Tonawanda, NY 3,336
25 Noramco Of Delaware Inc. Wilmington DE Delaware River 2,520
26 Olin Chemicals & Chlor Alkali Brandenburg KY Ohio River 2,408
27 Tennessee Eastman Div. Kingsport TN Holston River 2,333
28 Courtaulds Fibers Inc. Axis AL Mobile River 2,300
29 Mobil Oil Torrance Refinery Torrance CA Pacific Ocean 2,230
30 Amp Circuits Greenville SC Unknown - POTW release in Greenville, SC 2,175
31 Hadco Corp. Derry NH Merrimack River 2,064
32 Phillips 66 Co. A Div.Of Borger TX Dixon Creek 2,040
33 Mapco Petroleum Inc. Memphis TN Mississippi River 1,952
34 Rhone-Poulenc Institute Plant Institute WV Kanawha River 1,899
35 U.S. Steel USS Gary Works Gary IN Grand Calumet River 1,800
36 Crown Central Petroleum Corp. Pasadena TX Houston Ship Channel 1,736
37 Akzo Nobel Chemicals Inc. Mc Cook IL Illinois River 1,638
38 BF Goodrich Co. Henry IL Illinois River 1,562
39 Fairmount Chemical Co. Inc. Newark NJ New York Harbor 1,480
40 Garlock Bearings Inc. Thorofare NJ Unknown - POTW release in West Deptford, NJ 1,469
41 Phillips Chemical Co. Philtex Borger TX Dixon Creek 1,415
42 Tosco Refining Co. Los Carson CA Pacific Ocean 1,364
43 Allied-Signal Inc. Hopewell Hopewell VA Gravelly Run 1,358
44 Malllinckrodt Inc. Saint Louis MO Mississippi River 1,332
45 Alliance Chemical Inc. Newark NJ New York Harbor 1,306
46 Merck Sharp & Dohme Quimica Barceloneta PR Atlantic Ocean 1,201
47 Baker Petrolite Corp. Sand Springs OK Arkansas River 1,187
48 Techmetals Inc. Dayton OH Great Miami River 1,170
49 Hoechst-Celanese Chemical Pasadena TX Houston Ship Channel 1,102
50 Du Pont Old Hickory Plant Old Hickory TN Cumberland River 1,100

Source: U.S. PIRG, compiled from EPA's Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 12
Table 13
States With the Largest Releases of Reproductive Toxins in 1997

Total releases Percent of lbs

Rank State 1997 (lbs) from POTWs 1997
1 New Jersey 116,018 28.6
2 New York 44,858 98.7
3 Texas 42,760 58.1
4 Ohio 37,077 86.3
5 Louisiana 29,318 2.6
6 Illinois 28,076 92.4
7 Alabama 15,048 2.1
8 Tennessee 13,242 66.6
9 California 12,510 97.8
10 Pennsylvania 10,794 75.3
11 West Virginia 10,297 0.5
12 South Carolina 9,403 31.8
13 Virginia 8,420 79.8
14 Mississippi 6,970 0.2
15 Massachusetts 6,184 100
16 Kansas 4,420 82.9
17 Kentucky 3,777 13.5
18 Puerto Rico 3,771 99.5
19 Delaware 2,704 94.2
20 Indiana 2,698 8.6
21 Michigan 2,186 63.4
22 New Hampshire 2,122 100
23 Missouri 1,972 97.6
24 Utah 1,847 94.8
25 Oklahoma 1,325 2.7
26 Connecticut 1,307 99.6
27 Minnesota 1,182 89.7
28 Wisconsin 1,026 100
29 Georgia 918 22.4
30 North Carolina 744 95.3
31 Washington 661 0
32 Florida 640 83.6
33 Wyoming 520 0
34 Arkansas 377 0
35 Arizona 222 100
36 Oregon 81 100
37 Iowa 66 0
38 Virgin Islands 65 0
39 Montana 27 0
40 Nebraska 25 60
41 Vermont 13 100
42 Maryland 6 33.3
43 Rhode Island 1 0
44 Nevada 1 100
45 Colorado 0 0

Source: U.S. PIRG, compiled from EPA's Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 13
Table 14
Water Bodies Receiving the Largest Amounts of Carcinogens
Total Percent of lbs
releases (lbs) from POTWs
Rank Water Body States 1997 1997
1 Delaware River DE, NJ, PA 172,150 88
2 Unknown - POTW release in San Diego, CA CA 137,716 100
AR, IA, IL, KY, LA, MN, MO,
3 Mississippi River MS, TN, WI 127,749 17.4
4 Houston Ship Channel TX 124,200 97.5
5 Atlantic Ocean ME, PR, RI 102,740 99.9
6 Ohio River IL, IN, KY, OH, PA, WV 69,595 31.9
7 Unknown - POTW release in St. Paul, MN MN 66,098 100
8 Tennessee River AL, KY, TN 62,526 0
9 Genesee River NY 56,499 0
10 Columbia River OR, WA 55,128 3.3
11 Unknown - POTW release in South Charleston, WV WV 54,049 100
12 Kalamazoo River MI 49,123 99.9
13 Unknown - POTW release in Huntington, WV WV 48,830 100
14 Connecticut River CT, MA, NH, VT 47,195 99.2
15 Holston River TN 46,295 0
16 Unknown - POTW release in Oceanside, CA CA 45,605 100
17 Pacific Ocean CA, HI, OR 43,023 44.8
18 Brazos River TX 39,353 0
19 Wabash River IL, IN, OH 34,770 3.5
20 New York Harbor NJ 32,826 100
21 Black Creek, SC SC 29,405 0
22 Bellingham Bay WA 28,926 0
23 Mobile River AL 28,890 0
24 Minnesota River MN 28,589 100
25 Cooper River SC 27,072 0
26 Arthur Kill NJ 27,041 95.2
27 Ward Cove AK 26,000 0
28 Tombigbee River AL 25,433 0
29 Great Pee Dee River SC 24,809 0
30 Unknown - POTW release in Rahway, NJ NJ 22,402 100
31 Neuse River NC 21,384 0
32 Unknown - POTW release in Tyndall Air Force Base, FL 21,116 100
33 Grand River, MI MI 20,902 99.8
34 Niagara River NY 19,841 99.2
35 Puget Sound WA 17,593 0.4
36 Catawba River NC, SC 15,836 0.1
37 Neches River TX 14,711 0
38 Lake Erie NY, OH, PA 13,939 97.9
39 Sacramento River CA 13,579 100
40 Flint River, GA GA 13,248 0
41 Everett Harbor WA 12,400 0
42 Kanawha River WV 11,589 0
43 Cuyahoga River OH 11,297 99.9
44 Leaf River MS 11,220 0
45 Cape Fear River NC 11,066 0
46 Wisconsin River WI 11,031 0
47 Naugatuck River CT 9,807 91.5
48 Jackson River VA 9,800 0
49 Unknown - POTW release in Greenville, SC SC 9,787 100
50 Illinois River IL 9,642 58.9

Source: U.S. PIRG, compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 14
Table 15
Facilities Discharging the Largest Amounts of Carcinogens
Total releases
Rank Facility Name City State Water Body (lbs) 1997
1 Rodel Inc. Newark DE Delaware River 104,550
2 Fluid Sys. Corp. San Diego CA Unknown - POTW release in San Diego, CA 101,543
3 Schering-Plough Prods. Inc. Manati PR Atlantic Ocean 65,088
4 Filmtec Corp. Edina MN Unknown - POTW release in St. Paul, MN 63,210
5 Eastman Kodak Co. Kodak Park Rochester NY Genesee River 56,499
6 BASF Corp. Huntington WV Unknown - POTW release in Huntington, WV 47,650
7 Arco Chemical Co. Bayport Div. Pasadena TX Houston Ship Channel 47,044
8 Solutia Inc. Springfield MA Connecticut River 46,254
9 Hydranautics Oceanside CA Unknown - POTW release in Oceanside, CA 45,550
10 Pharmacia & Upjohn Co. Prod. Portage MI Kalamazoo River 44,873
11 Tennessee Eastman Div. Kingsport TN Holston River 44,105
12 Union Carbide Corp. South Charleston WV Unknown - POTW release in South Charleston, WV 42,327
13 Weyerhaeuser Co. Longview WA Columbia River 42,080
14 Dow Chemical Co. Freeport TX Brazos River 38,811
15 ISP Chemicals Inc. Calvert City KY Tennessee River 33,399
16 Clinton Labs. Clinton IN Wabash River 33,250
17 Pharmacia & Upjohn Caribe Inc. Arecibo PR Atlantic Ocean 30,287
18 Hoechst-Celanese Chemical Pasadena TX Houston Ship Channel 30,098
19 Wellman Inc. Palmetto Plant Darlington SC Black Creek, SC 29,400
20 Georgia-Pacific West Inc. Bellingham WA Bellingham Bay 28,926
21 Osmonics Inc. Minnetonka MN Minnesota River 28,583
22 Cardolite Corp. Newark NJ New York Harbor 26,975
23 Union Carbide Corp. Taft/Star Taft LA Mississippi River 26,757
24 Kimberly-Clark Corp. Mobile AL Mobile River 26,000
25 Ketchikan Pulp Co. Ketchikan AK Ward Cove 26,000
26 Usf Filtration & Separations San Diego CA Unknown - POTW release in San Diego, CA 22,470
27 Merck & Co. Inc. Rahway NJ Unknown - POTW release in Rahway, NJ 22,400
28 Louisiana-Pacific Corp. Samoa Samoa CA Pacific Ocean 22,000
29 Merck & Co. Inc. Rahway NJ Arthur Kill 21,606
30 Noramco Of Delaware Inc. Wilmington DE Delaware River 21,360
31 Stone Container Corp. Panama City FL Unknown - POTW release in Tyndall Air Force Base, 21,116
32 Du Pont Kinston Plant Kinston NC Neuse River 20,634
33 Simpson Pasadena Paper Co. Pasadena TX Houston Ship Channel 18,622
34 Olin Chemicals & Chlor Alkali Brandenburg KY Ohio River 18,407
35 Du Pont Florence Site Florence SC Great Pee Dee River 18,300
36 Buffalo Color Corp. Buffalo NY Niagara River 17,360
37 Simpson Tacoma Kraft Co. Tacoma WA Puget Sound 17,240
38 Ciba Specialty Chemicals Corp. Mc Intosh AL Tombigbee River 16,426
39 Cincinnati Specialties Inc. Cincinnati OH Ohio River 15,261
40 Amoco Chemical Co. Decatur AL Tennessee River 15,000
41 PCS Nitrogen Fertilizer L.P. Geismar LA Mississippi River 14,000
42 Georgia-Pacific Resins Inc. Elk Grove CA Sacramento River 13,489
43 Du Pont Cooper River Plant Charleston SC Cooper River 13,090
44 Merck & Co. Inc. Flint River Albany GA Flint River, GA 12,940
45 Kimberly-Clark Tissue Co. Everett WA Everett Harbor 12,400
46 Ferro Corp. Grant Chemical Zachary LA Mississippi River 12,340
47 Solutia Port Plastics Addyston OH Ohio River 12,000
48 Westvaco Corp. Wickliffe KY Mississippi River 11,750
49 Arco Chemical Co. South Charleston WV Unknown - POTW release in South Charleston, WV 11,718
50 UOP Separex Membrane Systems Anaheim CA Pacific Ocean 11,295

Source: U.S. PIRG, compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 15
Table 16
States With the Largest Releases of Carcinogens in 1997
Total releases Percent of lbs from
Rank State 1997 (lbs) POTWs 1997
1 California 258,149 88
2 Texas 210,663 59.5
3 Delaware 142,611 95.1
4 South Carolina 129,599 15.4
5 West Virginia 124,221 82.8
6 Washington 118,816 0.8
7 New Jersey 113,868 81.9
8 Louisiana 113,390 2.5
9 Minnesota 107,194 89.6
10 Alabama 104,288 1.4
11 Puerto Rico 103,225 99.8
12 New York 97,913 31.6
13 Michigan 95,617 87.5
14 Tennessee 89,584 35.5
15 Ohio 85,523 67.3
16 Kentucky 77,852 8.5
17 North Carolina 62,084 9.4
18 Indiana 53,392 22.3
19 Massachusetts 50,834 99.4
20 Pennsylvania 46,004 55.1
21 Georgia 45,158 9
22 Illinois 39,093 70.5
23 Florida 37,315 66.8
24 Mississippi 35,221 21.3
25 Wisconsin 26,408 28.6
26 Alaska 26,000 0
27 Virginia 24,994 27.6
28 Connecticut 22,710 48.1
29 Maine 17,465 6
30 Maryland 14,955 53.1
31 Oregon 14,675 22
32 Missouri 13,583 77
33 New Hampshire 13,115 6.6
34 Arkansas 10,330 16.4
35 Idaho 7,812 0.6
36 Kansas 6,726 77.1
37 Iowa 6,093 16.2
38 Oklahoma 5,781 34
39 Utah 3,415 85.4
40 Montana 3,354 0.1
41 Nebraska 2,689 59.4
42 Arizona 1,048 99.4
43 Rhode Island 793 93.4
44 Colorado 605 88.3
45 Wyoming 263 1.1
46 New Mexico 256 31.3
47 District Of Columbia 154 100
48 North Dakota 45 86.7
49 Vermont 26 23.1
50 Hawaii 25 0
51 Virgin Islands 17 0
52 South Dakota 5 100
53 Nevada 0 0

Source: U.S. PIRG, compiled from EPA's 1997 Toxics Release Inventory. Figures include estimated discharges through POTWs.

Appendix A, Table 16
Table 17
Properties and POTW Pass-through Percentages of TRI Chemicals Used in this Report
POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Abamectin 71751412 Added in 1995 1.8
Acephate 30560191 Added in 1995 54.6
Acetaldehyde 75070 X 7.9
Acetamide 60355 X 7.9
Acetonitrile 75058 24.7
Acetophenone 98862 Added in 1994 7.8
Acifluorfen, sodium salt 62476599 Added in 1995 X 25
Acrolein 107028 7.8
Acrylamide 79061 X 7.9
Acrylic acid 79107 7.9
Acrylonitrile 107131 X 7.8
Alachlor 15972608 Added in 1995 X 11.2
Allyl alcohol 107186 Added in 1990 7.9
Allyl chloride 107051 X 15.6
Aluminum (fume or dust) 7429905 33.6
Aluminum oxide (fibrous forms) 1344281 Guidance changed in 1990 100
Ametryn 834128 Added in 1995 45.3
Ammonia 7664417 Guidance changed in 1994 40.1
Aniline 62533 X 7.9
o-Anisidine 90040 X 24.8
p-Anisidine 104949 7.9
Anthracene 120127 5.8
Antimony 7440360 X 68.5
Antimony compounds N010 X 68.5
Arsenic 7440382 X X 51.4
Arsenic compounds N020 X 51.4
Asbestos (friable) 1332214 X 100
Atrazine 1912249 Added in 1995 X 74.3
Barium 7440393 X 31
Barium compounds N040 X 31
Benzal chloride 98873 0
Benzene 71432 X X 5.9
Benzoic trichloride 98077 X 0
Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Benzoyl chloride 98884 0
Benzoyl peroxide 94360 3.3
Benzyl chloride 100447 X 22
Beryllium 7440417 X X 62.6
Beryllium compounds N050 X X 62.6
Biphenyl 92524 1.1
Bis(2-chloroethyl) ether 111444 X 77.2
Bis(2-chloro-1-methylethyl) ether 108601 49.5
Bis(tributyltin) oxide 56359 Added in 1995 25
Boron trifluoride 7637072 Added in 1995 25
Bromacil 314409 Added in 1995 53.1
Bromine 7726956 Added in 1995 25
Bromomethane 74839 X 22.5
1,3-Butadiene 106990 X 2.7
Butyl acrylate 141322 7
n-Butyl alcohol 71363 7.9
sec-Butyl alcohol 78922 7.9
tert-Butyl alcohol 75650 54.3
1,2-Butylene oxide 106887 24
Butyraldehyde 123728 7.8
Cadmium 7440439 X X 31.8
Cadmium compounds N078 X X 31.8
Captan 133062 X 23.2
Carbaryl 63252 6.7
Carbofuran 1563662 Added in 1995 7.3
Carbon disulfide 75150 X 12.8
Carbon tetrachloride 56235 X 7.4
Carboxin 5234684 Added in 1995 23.8
Catechol 120809 7.9
Chlordane 57749 X 1.3
Chlorine 7782505 100
Chlorine dioxide 10049044 100
Chloroacetic acid 79118 7.9
1-(3-Chloroallyl)-3,5,7-triaza-1-azoniaadamantane chloride 4080313 Added in 1995 54.6
p-Chloroaniline 106478 Added in 1995 X 53.8

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Chlorobenzene 108907 14.7
1-Chloro-1,1-difluoroethane (HCFC-142b) 75683 Added in 1994 3.4
Chlorodifluoromethane (HCFC-22) 75456 Added in 1994 100
Chloroethane 75003 X 15.6
Chloroform 67663 X 29.2
Chloromethane 74873 12.3
Chloromethyl methyl ether 107302 X 0
3-Chloro-2-methyl-1-propene 563473 Added in 1995 X 4.2
Chlorophenols N084 X 27.1
Chloroprene 126998 4.3
1-Chloro-1,1,2,2-tetrafluoroethane (HCFC-124a) 354256 Added in 1994 0.5
2-Chloro-1,1,1,2-tetrafluoroethane (HCFC-124) 2837890 Added in 1994 0.5
Chlorothalonil 1897456 X 17.2
2-Chloro-1,1,1-trifluoroethane (HCFC-133a) 75887 Added in 1995 0.9
Chlorotrifluoromethane (CFC-13) 75729 Added in 1995 0.2
Chromium 7440473 X 23.6
Chromium compounds N090 X 23.6
C.I. Acid Red 114 6459945 Added in 1995 X 0.1
C.I. Basic Red 1 989388 0.5
C.I. Direct Blue 218 28407376 Added in 1995 X 25
C.I. Direct Brown 95 16071866 X 0.3
C.I. Disperse Yellow 3 2832408 16.3
C.I. Food Red 15 81889 X 53.6
Cobalt 7440484 X X 67.9
Cobalt compounds N096 X X 67.9
Copper 7440508 X 27.5
Copper compounds N100 X 27.5
Creosote 8001589 Added in 1990 X 100
p-Cresidine 120718 X 53.9
m-Cresol 108394 7.6
o-Cresol 95487 7.6
p-Cresol 106445 7.7
Cresol (mixed isomers) 1319773 7.6
Crotonaldehyde 4170303 Added in 1995 7.7
Cumene 98828 1.9

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Cumene hydroperoxide 80159 23.8
Cyanazine 21725462 Added in 1995 X 76.5
Cyanide compounds N106 100
Cycloate 1134232 Added in 1995 X 6.1
Cyclohexane 110827 11.3
Cyclohexanol 108930 Added in 1995 X 7.8
Cyfluthrin 68359375 Added in 1995 0.1
2,4-D (acetic acid) 94757 X 6.2
Dazomet 533744 Added in 1995 3.3
Dazomet, sodium salt 53404607 Added in 1995 54.3
Decabromodiphenyl oxide 1163195 0.9
2,4-D 2-Ethylhexyl ester 1928434 Added in 1995 X 0
4,4'-Diaminodiphenyl ether 101804 X 23.6
Diaminotoluene (mixed isomers) 25376458 X 15.4
Diazinon 333415 Added in 1995 7
Dibenzofuran 132649 3.6
1,2-Dibromoethane 106934 X X 45.6
Dibutyl phthalate 84742 0.8
Dicamba 1918009 Added in 1995 52.8
Dichloran 99309 Added in 1995 48.6
1,2-Dichlorobenzene 95501 26.2
1,3-Dichlorobenzene 541731 22.5
1,4-Dichlorobenzene 106467 X 24.7
3,3'-Dichlorobenzidine 91941 X 31.6
3,3'-Dichlorobenzidine dihydrochloride 612839 Added in 1995 X 31.6
1,2-Dichloro-1,1-difluoroethane (HCFC-132b) 1649087 Added in 1995 4.9
Dichlorodifluoromethane (CFC-12) 75718 Added in 1991 0.7
1,2-Dichloroethane 107062 X 42
1,2-Dichloroethylene 540590 27.7
1,1-Dichloro-1-fluoroethane (HCFC-141b) 1717006 Added in 1994 9.2
Dichlorofluoromethane (HCFC-21) 75434 Added in 1995 28.6
Dichloromethane 75092 X 17.8
2,4-Dichlorophenol 120832 5.2
1,2-Dichloropropane 78875 X 32.1
2,3-Dichloropropene 78886 Added in 1990 34.1

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
1,3-Dichloropropylene 542756 X 17
Dichlorotetrafluoroethane (CFC-114) 76142 Added in 1991 0.1
1,2-Dichloro-1,1,2-trifluoroethane (HCFC-123a) 354234 Added in 1994 2.6
2,2-Dichloro-1,1,1-trifluoroethane (HCFC-123) 306832 Added in 1994 2.6
Dichlorvos 62737 X 24.7
Dicyclopentadiene 77736 Added in 1995 3.3
Diethanolamine 111422 7.9
Di-(2-ethylhexyl) phthalate 117817 X 0.1
Diethyl sulfate 64675 X 4.9
Dihydrosafrole 94586 Added in 1994 X 29.2
Diisocyanates N120 Added in 1995 25
Dimethoate 60515 Added in 1995 54.5
3,3'-Dimethoxybenzidine dihydrochloride 20325400 Added in 1995 X 54.4
Dimethylamine 124403 Added in 1995 7.9
N,N-Dimethylaniline 121697 51.3
3,3'-Dimethylbenzidine 119937 X 23.2
N,N-Dimethylformamide 68122 Added in 1995 X 7.9
2,4-Dimethylphenol 105679 23.4
2,6-Dimethylphenol 576261 Deleted in 1997 25
Dimethyl phthalate 131113 7.8
Dimethyl sulfate 77781 X 3
m-Dinitrobenzene 99650 Added in 1990 X 54.2
o-Dinitrobenzene 528290 Added in 1990 X 54
p-Dinitrobenzene 100254 Added in 1990 X 54.2
Dinitrobutyl phenol 88857 Added in 1995 X 53.6
4,6-Dinitro-o-cresol 534521 53.1
2,4-Dinitrophenol 51285 24.5
2,4-Dinitrotoluene 121142 X X 53.5
2,6-Dinitrotoluene 606202 X X 53.1
Dinitrotoluene (mixed isomers) 25321146 Added in 1990 52.9
1,4-Dioxane 123911 X 54.5
Diphenylamine 122394 Added in 1995 11.6
Diuron 330541 Added in 1995 49.5
Epichlorohydrin 106898 X X 53.9
2-Ethoxyethanol 110805 X 7.9

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Ethyl acrylate 140885 X 7.6
Ethylbenzene 100414 10.2
Ethyl chloroformate 541413 18
Ethyl dipropylthiocarbamate 759944 Added in 1995 X 40.1
Ethylene 74851 0.9
Ethylenebisdithiocarbamic acid, salts and esters N171 Added in 1994 25
Ethylene glycol 107211 7.9
Ethylene oxide 75218 X X 7.8
Ethylene thiourea 96457 X X 54.6
Ethylidene dichloride 75343 Added in 1994 X 23.8
Famphur 52857 Added in 1995 23.6
Fluometuron 2164172 51.7
Fluorine 7782414 Added in 1995 25
Folpet 133073 Added in 1995 X 20.1
Fomesafen 72178020 Added in 1995 46.6
Formaldehyde 50000 X 7.9
Formic acid 64186 Added in 1994 7.9
Freon 113 76131 0.5
Glycol ethers N230 100
Heptachlor 76448 X X 0.7
Hexachlorobenzene 118741 X X 1.6
Hexachloro-1,3-butadiene 87683 5.2
Hexachlorocyclopentadiene 77474 1.2
Hexachloroethane 67721 X 22.5
n-Hexane 110543 Added in 1995 0.1
Hexazinone 51235042 Added in 1995 15.4
Hydramethylnon 67485294 Added in 1995 X 0.3
Hydrazine 302012 X 100
Hydrazine sulfate 10034932 X 100
Hydrochloric acid 7647010 Guidance changed in 1995 100
Hydrogen cyanide 74908 28
Hydrogen fluoride 7664393 100
Hydroquinone 123319 7.9
3-Iodo-2-propynyl butylcarbamate 55406536 Added in 1995 22.8
Isobutyraldehyde 78842 7.8

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Isopropyl alcohol (manufacturing) 67630 7.9
4,4'-Isopropylidenediphenol 80057 14.3
Lead 7439921 X X 36.5
Lead compounds N420 X 36.5
Lindane 58899 X 24.6
Linuron 330552 Added in 1995 X 40.6
Lithium carbonate 554132 Added in 1995 X 25
Malathion 121755 Added in 1995 7.2
Maleic anhydride 108316 0
Maneb 12427382 X 28
Manganese 7439965 X 61.1
Manganese compounds N450 X 61.1
Mecoprop 93652 Added in 1995 X 42.2
2-Mercaptobenzothiazole 149304 Added in 1995 51.7
Mercury 7439976 X 31.4
Mercury compounds N458 X 31.4
Metham sodium 137428 Added in 1995 X X 24.1
Methanol 67561 7.9
Methoxone 94746 Added in 1995 X 39.3
2-Methoxyethanol 109864 X 7.9
Methyl acrylate 96333 7.7
Methyl tert-butyl ether 1634044 47.1
Methyl chlorocarbonate 79221 Added in 1994 0.4
4,4'-Methylenebis(2-chloroaniline) 101144 X 18.4
Methylene bromide 74953 44.3
4,4'-Methylenedianiline 101779 X 24.6
Methyl ethyl ketone 78933 7.9
Methyl iodide 74884 X 24.7
Methyl isobutyl ketone 108101 7.7
Methyl methacrylate 80626 7.6
N-Methylolacrylamide 924425 Added in 1995 X 7.9
2-Methylpyridine 109068 Added in 1994 7.9
N-Methyl-2-pyrrolidone 872504 Added in 1995 7.9
Metribuzin 21087649 Added in 1995 54
Molinate 2212671 Added in 1995 40.3

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Molybdenum trioxide 1313275 100
Monochloropentafluoroethane (CFC-115) 76153 Added in 1991 0.1
Nabam 142596 Added in 1995 X 25
Naled 300765 Added in 1995 24.7
Naphthalene 91203 4
Nickel 7440020 X X 61.7
Nickel compounds N495 X X 61.7
Nicotine and salts N503 Added in 1995 25
Nitrapyrin 1929824 Added in 1995 X 34.2
Nitrate compounds N511 Added in 1995 10
Nitric acid 7697372 100
Nitrilotriacetic acid 139139 X 7.9
p-Nitroaniline 100016 Added in 1995 54.3
5-Nitro-o-anisidine 99592 X 54.2
Nitrobenzene 98953 X 7.7
Nitroglycerin 55630 24.6
2-Nitrophenol 88755 46.6
4-Nitrophenol 100027 0.5
2-Nitropropane 79469 X 24.3
Oxyfluorfen 42874033 Added in 1995 3.1
Paraquat dichloride 1910425 Added in 1995 54.6
Pebulate 1114712 Added in 1995 1.6
Pendimethalin 40487421 Added in 1995 1.2
Pentachloroethane 76017 Added in 1994 42.1
Pentachlorophenol 87865 X 3.8
Peracetic acid 79210 7.9
Permethrin 52645531 Added in 1995 0.1
Phenanthrene 85018 Added in 1995 5.9
Phenol 108952 7.8
1,2-Phenylenediamine 95545 Added in 1995 X 54.6
1,3-Phenylenediamine 108452 Added in 1995 54.6
p-Phenylenediamine 106503 54.6
2-Phenylphenol 90437 5.1
Phosphoric acid 7664382 100
Phosphorus (yellow or white) 7723140 40.2

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
Phthalic anhydride 85449 0.7
Picloram 1918021 Added in 1995 90.4
Piperonyl butoxide 51036 Added in 1995 3
Polychlorinated alkanes N583 Added in 1995 25
Polycyclic aromatic compounds N590 Added in 1995 X 25
Potassium bromate 7758012 Added in 1995 X 25
Potassium dimethyldithiocarbamate 128030 Added in 1995 X 23.4
Prometryn 7287196 Added in 1995 55.7
Propachlor 1918167 Added in 1995 23.5
Propanil 709988 Added in 1995 43.5
Propargite 2312358 Added in 1995 X X 0
Propargyl alcohol 107197 Added in 1995 7.9
Propionaldehyde 123386 7.8
Propoxur 114261 7.8
Propylene 115071 1.1
Propylene oxide 75569 X 7.8
Pyridine 110861 7.9
Quinoline 91225 24.1
Quinone 106514 48.2
Quintozene 82688 10.1
Saccharin (manufacturing) 81072 X 24.9
Safrole 94597 X 33.5
Selenium 7782492 X 56.3
Selenium compounds N725 X 56.3
Silver 7440224 X 33.5
Silver compounds N740 X 33.5
Simazine 122349 Added in 1995 76.6
Sodium azide 26628228 Added in 1995 25
Sodium dicamba 1982690 Added in 1995 52.8
Sodium dimethyldithiocarbamate 128041 Added in 1995 X 23.4
Sodium nitrite 7632000 Added in 1995 25
Styrene 100425 X 5.1
Sulfuric acid 7664939 Guidance changed in 1994 100
Terbacil 5902512 Added in 1995 X 53.7
1,1,1,2-Tetrachloroethane 630206 Added in 1994 41.2

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
1,1,2,2-Tetrachloroethane 79345 X 66.8
Tetrachloroethylene 127184 X 11.1
1,1,1,2-Tetrachloro-2-fluoroethane 354110 Added in 1995 38.2
Tetrachlorvinphos 961115 11.1
Tetracycline hydrochloride 64755 Added in 1995 X 54.6
Thallium 7440280 X 46.4
Thiabendazole 148798 Added in 1995 51.4
Thiodicarb 59669260 Added in 1995 X 24.5
Thiophanate-methyl 23564058 Added in 1995 X 24.7
Thiourea 62566 X 24.9
Thiram 137268 Added in 1994 24.5
Thorium dioxide 1314201 X 100
Toluene 108883 X 5
Toluene-2,4-diisocyanate 584849 X 0.5
Toluenediisocyanate (mixed isomers) 26471625 Added in 1990 X 0.5
o-Toluidine 95534 X 0.1
Tributyltin fluoride 1983104 Added in 1995 25
Tributyltin methacrylate 2155706 Added in 1995 25
S,S,S-Tributyltrithiophosphate 78488 Added in 1995 0.1
1,2,4-Trichlorobenzene 120821 13.5
1,1,1-Trichloroethane 71556 12.2
1,1,2-Trichloroethane 79005 X 60.2
Trichloroethylene 79016 X 19
Trichlorofluoromethane (CFC-11) 75694 Added in 1991 2.5
2,4,6-Trichlorophenol 88062 X 8.7
1,2,3-Trichloropropane 96184 Added in 1995 X 47.9
Triethylamine 121448 Added in 1995 51.8
Trifluralin 1582098 2.6
1,2,4-Trimethylbenzene 95636 5.9
Urethane 51796 X X 54.6
Vanadium (fume or dust) 7440622 68.2
Vinyl acetate 108054 X 7.6
Vinyl chloride 75014 X 7.6
Vinylidene chloride 75354 8
m-Xylene 108383 3.7

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
 POTW pass-
Chemical Name CAS # Change? Carc. Repro. Tox. PBT through %
o-Xylene 95476 4.2
p-Xylene 106423 3.9
Xylene (mixed isomers) 1330207 3.9
2,6-Xylidine 87627 X 52.9
Zinc (fume or dust) 7440666 X 33.8
Zinc compounds N982 X 33.8
NA 25
Trade secrets 999999999 25

Source: U.S. PIRG; chemical properties from U.S. EPA and State of California; pass-through percentages from EPA's OPPT Risk Screening Environmental Indicators program.

Appendix A, Table 17
Appendix B:

Permit Compliance Data Tables

Table 1
States and Territories Ranked by Number of Major Facilities in SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE TOTAL # OF FACILITIES % IN SNC # IN SNC
1 TX 570 31.23% 178
2 FL 238 59.24% 141
3 OH 279 45.16% 126
4 NY 362 33.70% 122
5 AL 210 44.76% 94
6 PR 98 83.67% 82
7 LA 243 32.92% 80
8 PA 389 18.25% 71
9 IN 177 39.55% 70
10 TN 150 42.00% 63
11 NC 218 23.85% 52
12 MI 183 27.87% 51
13 GA 175 26.86% 47
14 MA 149 31.54% 47
15 CT 108 41.67% 45
16 MO 147 30.61% 45
17 SC 190 19.47% 37
18 ME 94 36.17% 34
19 WI 132 25.76% 34
20 IA 123 26.83% 33
21 IL 269 12.27% 33
22 KY 127 25.98% 33
23 OK 91 36.26% 33
24 VA 146 22.60% 33
25 NJ 170 15.88% 27
26 MN 80 32.50% 26
27 AR 109 22.02% 24
28 NE 60 40.00% 24
29 UT 35 68.57% 24
30 WA 90 26.67% 24
31 WV 95 25.26% 24
32 KS 57 38.60% 22
33 MS 86 25.58% 22
34 CA 239 6.69% 16
35 NH 69 23.19% 16
36 MD 89 16.85% 15
37 RI 27 55.56% 15
38 CO 105 11.43% 12
39 OR 71 15.49% 11
40 VT 34 32.35% 11
41 WY 27 40.74% 11
42 AZ 39 23.08% 9
43 AK 47 17.02% 8
44 MT 44 18.18% 8
45 ID 67 10.45% 7
46 NM 34 20.59% 7
47 SD 31 12.90% 4
48 VI 6 66.67% 4
49 DC 4 25.00% 1
50 HI 27 3.70% 1
51 NV 10 10.00% 1
52 DE 24 0.00% 0
53 ND 26 0.00% 0

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 1
Table 2
States and Territories Ranked by Percentage of Major Facilities in SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE TOTAL # OF FACILITIES % IN SNC # IN SNC
1 PR 98 83.67% 82
2 UT 35 68.57% 24
3 VI 6 66.67% 4
4 FL 238 59.24% 141
5 RI 27 55.56% 15
6 OH 279 45.16% 126
7 AL 210 44.76% 94
8 TN 150 42.00% 63
9 CT 108 41.67% 45
10 WY 27 40.74% 11
11 NE 60 40.00% 24
12 IN 177 39.55% 70
13 KS 57 38.60% 22
14 OK 91 36.26% 33
15 ME 94 36.17% 34
16 NY 362 33.70% 122
17 LA 243 32.92% 80
18 MN 80 32.50% 26
19 VT 34 32.35% 11
20 MA 149 31.54% 47
21 TX 570 31.23% 178
22 MO 147 30.61% 45
23 MI 183 27.87% 51
24 GA 175 26.86% 47
25 IA 123 26.83% 33
26 WA 90 26.67% 24
27 KY 127 25.98% 33
28 WI 132 25.76% 34
29 MS 86 25.58% 22
30 WV 95 25.26% 24
31 DC 4 25.00% 1
32 NC 218 23.85% 52
33 NH 69 23.19% 16
34 AZ 39 23.08% 9
35 VA 146 22.60% 33
36 AR 109 22.02% 24
37 NM 34 20.59% 7
38 SC 190 19.47% 37
39 PA 389 18.25% 71
40 MT 44 18.18% 8
41 AK 47 17.02% 8
42 MD 89 16.85% 15
43 NJ 170 15.88% 27
44 OR 71 15.49% 11
45 SD 31 12.90% 4
46 IL 269 12.27% 33
47 CO 105 11.43% 12
48 ID 67 10.45% 7
49 NV 10 10.00% 1
50 CA 239 6.69% 16
51 HI 27 3.70% 1
52 DE 24 0.00% 0
53 ND 26 0.00% 0

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 2
Table 3
States and Territories Ranked by Percentage of Major Municipal Facilities in SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE # MUNICIPAL # MUNICIPAL IN SNC MUNICIPAL % SNC
1 PR 37 36 97.30%
2 RI 19 13 68.42%
3 UT 26 17 65.38%
4 FL 112 64 57.14%
5 LA 96 52 54.17%
6 TN 96 50 52.08%
7 VI 2 1 50.00%
8 WY 12 6 50.00%
9 OH 166 80 48.19%
10 OK 60 28 46.67%
11 ME 63 27 42.86%
12 MN 53 22 41.51%
13 CT 63 26 41.27%
14 IN 106 40 37.74%
15 NY 230 86 37.39%
16 NE 35 13 37.14%
17 MA 95 34 35.79%
18 GA 125 44 35.20%
19 MI 97 34 35.05%
20 AZ 20 7 35.00%
21 AL 113 39 34.51%
22 TX 363 123 33.88%
23 VT 27 9 33.33%
24 WV 39 13 33.33%
25 NC 129 43 33.33%
26 MO 99 33 33.33%
27 NH 43 13 30.23%
28 IA 91 27 29.67%
29 MS 53 15 28.30%
30 AR 66 18 27.27%
31 VA 86 23 26.74%
32 WI 84 22 26.19%
33 KS 42 11 26.19%
34 KY 69 18 26.09%
35 SC 105 26 24.76%
36 MD 44 10 22.73%
37 NM 24 5 20.83%
38 AK 21 4 19.05%
39 OR 48 9 18.75%
40 PA 263 43 16.35%
41 NJ 99 16 16.16%
42 WA 46 7 15.22%
43 NV 7 1 14.29%
44 IL 184 24 13.04%
45 MT 26 3 11.54%
46 ID 28 3 10.71%
47 CO 69 6 8.70%
48 CA 165 13 7.88%
49 SD 21 1 4.76%
50 DC 1 0 0.00%
51 DE 8 0 0.00%
52 ND 16 0 0.00%
53 HI 7 0 0.00%

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 3
Table 4
States and Territories Ranked by Number of Major Municipal Facilities in SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE # MUNICIPAL # MUNICIPAL IN SNC MUNICIPAL % SNC
1 TX 363 123 33.88%
2 NY 230 86 37.39%
3 OH 166 80 48.19%
4 FL 112 64 57.14%
5 LA 96 52 54.17%
6 TN 96 50 52.08%
7 GA 125 44 35.20%
8 PA 263 43 16.35%
9 NC 129 43 33.33%
10 IN 106 40 37.74%
11 AL 113 39 34.51%
12 PR 37 36 97.30%
13 MA 95 34 35.79%
14 MI 97 34 35.05%
15 MO 99 33 33.33%
16 OK 60 28 46.67%
17 ME 63 27 42.86%
18 IA 91 27 29.67%
19 CT 63 26 41.27%
20 SC 105 26 24.76%
21 IL 184 24 13.04%
22 VA 86 23 26.74%
23 MN 53 22 41.51%
24 WI 84 22 26.19%
25 KY 69 18 26.09%
26 AR 66 18 27.27%
27 UT 26 17 65.38%
28 NJ 99 16 16.16%
29 MS 53 15 28.30%
30 NH 43 13 30.23%
31 RI 19 13 68.42%
32 WV 39 13 33.33%
33 NE 35 13 37.14%
34 CA 165 13 7.88%
35 KS 42 11 26.19%
36 MD 44 10 22.73%
37 VT 27 9 33.33%
38 OR 48 9 18.75%
39 AZ 20 7 35.00%
40 WA 46 7 15.22%
41 CO 69 6 8.70%
42 WY 12 6 50.00%
43 NM 24 5 20.83%
44 AK 21 4 19.05%
45 MT 26 3 11.54%
46 ID 28 3 10.71%
47 VI 2 1 50.00%
48 SD 21 1 4.76%
49 NV 7 1 14.29%
50 DC 1 0 0.00%
51 DE 8 0 0.00%
52 ND 16 0 0.00%
53 HI 7 0 0.00%

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 4
Table 5
States and Territories Ranked by Number Of Major Industrial Facilties IN SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE # INDUSTRIAL # INDUSTRIAL IN SNC INDUSTRIAL % SNC
1 FL 123 74 60.16%
2 TX 203 55 27.09%
3 AL 91 52 57.14%
4 PR 60 46 76.67%
5 OH 111 45 40.54%
6 NY 129 34 26.36%
7 PA 125 28 22.40%
8 IN 68 28 41.18%
9 LA 145 28 19.31%
10 CT 45 19 42.22%
11 MI 86 17 19.77%
12 WA 41 15 36.59%
13 MA 54 13 24.07%
14 KY 54 13 24.07%
15 WI 48 12 25.00%
16 MO 46 12 26.09%
17 NJ 71 11 15.49%
18 WV 56 11 19.64%
19 NE 25 11 44.00%
20 SC 84 10 11.90%
21 NC 85 9 10.59%
22 IL 82 9 10.98%
23 VA 53 8 15.09%
24 KS 12 8 66.67%
25 MS 32 7 21.88%
26 UT 9 7 77.78%
27 ME 31 6 19.35%
28 TN 39 6 15.38%
29 IA 31 6 19.35%
30 AR 42 5 11.90%
31 MT 18 5 27.78%
32 WY 15 5 33.33%
33 MD 38 4 10.53%
34 MN 27 4 14.81%
35 CO 29 4 13.79%
36 AK 26 4 15.38%
37 NH 25 3 12.00%
38 VI 4 3 75.00%
39 GA 45 3 6.67%
40 OK 28 3 10.71%
41 SD 7 3 42.86%
42 CA 67 3 4.48%
43 ID 37 3 8.11%
44 RI 8 2 25.00%
45 VT 7 2 28.57%
46 OR 23 2 8.70%
47 DC 2 1 50.00%
48 NM 9 1 11.11%
49 AZ 16 1 6.25%
50 DE 16 0 0.00%
51 ND 8 0 0.00%
52 HI 16 0 0.00%
53 NV 3 0 0.00%

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 5
Table 6
States and Territories Ranked by Percentage of Major Industrial Facilities in SNC
OCTOBER 1997 - DECEMBER 1998
RANK STATE # INDUSTRIAL # INDUSTRIAL IN SNC INDUSTRIAL % SNC
1 UT 9 7 77.78%
2 PR 60 46 76.67%
3 VI 4 3 75.00%
4 KS 12 8 66.67%
5 FL 123 74 60.16%
6 AL 91 52 57.14%
7 DC 2 1 50.00%
8 NE 25 11 44.00%
9 SD 7 3 42.86%
10 CT 45 19 42.22%
11 IN 68 28 41.18%
12 OH 111 45 40.54%
13 WA 41 15 36.59%
14 WY 15 5 33.33%
15 VT 7 2 28.57%
16 MT 18 5 27.78%
17 TX 203 55 27.09%
18 NY 129 34 26.36%
19 MO 46 12 26.09%
20 RI 8 2 25.00%
21 WI 48 12 25.00%
22 MA 54 13 24.07%
23 KY 54 13 24.07%
24 PA 125 28 22.40%
25 MS 32 7 21.88%
26 MI 86 17 19.77%
27 WV 56 11 19.64%
28 ME 31 6 19.35%
29 IA 31 6 19.35%
30 LA 145 28 19.31%
31 NJ 71 11 15.49%
32 TN 39 6 15.38%
33 AK 26 4 15.38%
34 VA 53 8 15.09%
35 MN 27 4 14.81%
36 CO 29 4 13.79%
37 NH 25 3 12.00%
38 SC 84 10 11.90%
39 AR 42 5 11.90%
40 NM 9 1 11.11%
41 IL 82 9 10.98%
42 OK 28 3 10.71%
43 NC 85 9 10.59%
44 MD 38 4 10.53%
45 OR 23 2 8.70%
46 ID 37 3 8.11%
47 GA 45 3 6.67%
48 AZ 16 1 6.25%
49 CA 67 3 4.48%
50 DE 16 0 0.00%
51 ND 8 0 0.00%
52 HI 16 0 0.00%
53 NV 3 0 0.00%

Source: U.S. PIRG, 2000. Compiled from the U.S. Environmental Protection Agency
Permit Compliance System data, October 1997 - December 1998

Appendix B, Table 6
Table 7
Facilities with CWA Permits in SNC ALL 5 QUARTERS

State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98

AL ECC AMERICA CALCIUM SYLACAUGA D D E E D

AL FLORENCE CITY OF CYPRESS CREEK X X S X X
AL JIM WALTER RESOURCES MINE 4 E D E E X
AL RUSSELLVILLE CITY OF WWTP X X S S S
AL JIM WALTER RESOURCES MINE 7 E E E D D
AL JIM WALTER RESOURCES MINE 5 E E D D D
AL MERSCOT AUBURN LTD H C MORGAN S X D E E
AL GULF STATES STEEL INC E E E E E
AR FORT SMITH, CITY OF (MASSARD W S S S S S
AR FORT SMITH, CITY OF ("P" STREE S S S S S
AZ TOLLESON, CITY OF X X X X X
CT MILLSTONE NUCLEAR POWER STA D D D D D
CT SOLVENTS RECOVERY OF N.E.,INC. D D D D D
CT MIDDLETOWN STP/WATER&SEWER S S S S S
CT PLYMOUTH WPCF E E E E E
CT MONTVILLE STP E E E E E
CT STAMFORD STP X X X X X
CT NORWALK STP X D D D D
FL IMC\_AGRICO CO \_ PORT SUTTON S S S S S
FL USN NAS JACKSONVILLE STP D D D D D
FL USN NAS PENSACOLA STP D D D D X
FL NEW SMYRNA BEACH STP X X X X X
FL NEW PORT RICHEY WTP D D X X X
FL DAYTONA BCH REG/BETH PT WWTP'S X D X X X
FL PRATT & WHITNEY (IW) D D D X D
FL HILLSBOROUGH CO\_SOUTHWEST WTP S S S S S
FL TAMPA ELECTRIC CO\_DINNER LAKE D D D D D
SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
FL ATLANTIC BEACH WWTP S D D D D
FL APALACHICOLA, CITY OF S S S S S
FL PUNTA GORDA WWTP S S S S S
FL MACCLENNY WTP S D D D D
FL HARDEE POWER STA\_TECO PWR STA D D D D D
FL TAMPA ELEC\_POLK POWER STATION D D D D D
FL AMERISTEEL CORPORATION D D D D D
FL BRIDGEWAY ACRES CLASS I D D D D D
GA SWAINSBORO WPCP E E E E E
GA CAMILLA WPCP E E E E E
GA HARTWELL WPCP E E E E E
GA STOCKBRIDGE WPCP E E E E E
HI US NAVY X X X X X
IA OTTUMWA CITY OF STP S S S S S
IL EXCEL AUTOMOTIVE E E E E E
IN U.S. STEEL \_ GARY WORKS, USX C S S S S S
IN PSI WABASH RIVER GEN. STATION E E E E E
IN ELI LILLY & CO. TIPPECANOE LAB D D D D D
IN EAST CHICAGO_MUNICIPAL STP E E E E E
IN GARY WASTEWATER TREATMENT PLT S S S S S
IN HAMMOND MUNICIPAL STP E E S S S
IN NEW ALBANY MUNICIPAL STP S S S S S
IN VINCENNES MUNICIPAL STP X X X X X
IN FORT WAYNE MUNICIPAL STP T T T E E
IN CRAWFORDSVILLE MUNICIPAL STP S S S S S
IN DECATUR MUNICIPAL STP S S S S S
KS TOPEKA MWWTP (NORTH PLANT) D D D D D
KS JO. CO. MILL CK REGIONAL WWTP D D D D D
KY MT STERLING STP X X X X X
KY MCCRACKEN CO SD #3 REIDLAND D D D E D

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
KY SOMERSET STP X X X S X
KY ARVIN ROLL COATER INC D E X E E
LA AIR PROD & CHEM INC\_NEW ORLEAN S S S S S
LA FORMOSA PLASTICS\_BATON ROUGE X E E E D
LA NESTE RESINS CORP \_ WINNFIELD E E E E E
LA LAKE CHARLES, CITY OF (PLANT C X S X X X
LA E BATON ROUGE CITY\_PAR (SOUTH) S S S S S
LA BATON ROUGE PH CENTRAL STP S S S S S
LA E BATON ROUGE CITY\_PAR (NORTH) E E X X X
LA HOMER, CITY OF \_ WWTP E E E E E
LA GONZALES, TOWN OF X E E E S
LA MONROE, CITY OF (WPC CNTR) E X X X X
LA JENNINGS, CITY OF E E E D D
LA NEW IBERIA, CITY OF (ADMIRAL D D E E E E
LA PONCHATOULA, CITY OF E E E E E
LA ST MARY PARISH WARDS 5 & 8\_MO S S S S S
MA SOUTH ESSEX SEWERAGE DIST S S S S S
MA PLYMOUTH W W T P S S S X S
MA WINCHENDON W P C F X X X X X
MA EAST FITCHBURG W W T F X X X X X
MA CHARLTON W W T P D D D E E
MA MIDDLEBOROUGH WPCF E E E E E
MD BALTI CITY DPW ASHBURTON FILT S S S S S
MI TENNECO PACKAGING INC D D D D D
MI NAT STEEL CORP\_GLD\_ECORSE X X X X X
MI MEDUSA CEMENT CO\_CHARLEVOIX D D D D S
MI GOGEBIC\_IRON WW AUTHORITY WWTP X X E E X
MI WAYNE CO\_DPW WYANDOTTE WWTP E E X X X
MI BAY CITY WWTP E E D S S
MI BIG RAPIDS WWTP E E E E T

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
MI BUCHANAN WWTP T T T T T
MI DETROIT WWTP E E S S S
MI FLINT WWTP E E E E E
MI MIDLAND WWTP S S S S S
MI PETOSKEY WWTP E E E E E
MI WYOMING WWTP S S S S S
MI GRAND RAPIDS WWTP T T T T T
MI BIL MAR FOODS X S S S S
MI GREAT LAKES PULP & FIBRE S S S S S
MN CAMBRIDGE D D D D D
MN CYPRUS NORTHSHORE MINING CORP D D D D D
MN MOORHEAD S S S S S
MN FERGUS FALLS D D D D D
MN NORTHSHORE MINING/SILVER BAY P S S S S S
MO FESTUS\_CRYSTAL CITY STP X X X X X
MT POLSON\_ CITY OF (E) D D D D D
NC CLEVELAND MILLS COMPANY X X X X X
NC TRYON WWTP, TOWN OF X X X X X
NC WILSON WWTP, TOWN OF E E E E E
NC HIGH POINT, WEST SIDE WWTP X X X X X
NC WAYNESVILLE WWTP, TOWN OF D S S S S
NC FUQUAY\_VARINA WWTP (EXISTING) X X X X X
NE IBP INC DAKOTA CITY S S S S S
NE BEATRICE WWTF E E E E E
NE MCCOOK WWTF E E E E E
NE AURORA WWTF S S S S S
NE KAWASAKI MOTORS CORP E E X D D
NE COZAD WWTF S E S S S
NH PITTSFIELD W W T F E E E E S
NJ RAHWAY VALLEY SEWERAGE AUTH D D D D D

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
NJ RIDGEWOOD VILLAGE OF WPCP E E E E E
NJ FIRMENICH INCORPORATED D D D D D
NY CIBA\_GEIGY CORP D D D D D
NY BINGHAMTON\_JOHNSON CITY JNT BD X X X X X
NY CORNING (C) STP E E S S X
NY JAMAICA WPC X X X X X
NY FULTON (C) WPCP X X X X X
NY DUNKIRK (C) WWTP D D X D D
OH DETREX CORP. X S S S S
OH TITANIUM METALS CORP. S S S S E
OH AMHERST, CITY OF S S S S S
OH HEATH, CITY OF E E E E E
OH STEUBENVILLE, CITY OF S S S S S
OH WASHINGTON C.H., CITY OF S S S S S
OH LAKE CO. BD OF COMM. S S S S S
OH PICKAWAY CORRECTIONAL FACILIT E E E E E
OH RESERVE ENVIRONMENTAL SERVICES X X X X X
OK POTEAU, CITY OF (POTEAU RIVER) E E E E E
OK FORT GIBSON UTILITIES AUTHORIT D E E S S
OK SEMINOLE, CITY OF WASTEWATER F E E S S S
OK CHECOTAH PWA D D S S S
PA GPU GENCO INC E E E E E
PA KOPPEL STEEL CORP E E E E E
PA ZINC CORP OF AMERICA \_ PALMERT E E E E E
PA AMBLER BORO E E E E E
PA SCHUYLKILL HAVEN MUN AUTH S E S S S
PR LILLY DEL CARIBE INC. D D D D D
PR CARIBBEAN PETROLEUM CORPORATON X X X X X
PR UNION CARBIDE CARIBE LLC X X X X X
PR GENERAL ELECTRIC CONTROLS X D X X D

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
PR BACARDI CORP D D D D D
PR PUERTO RICO ELECTRIC PWR AUTH X X X X X
PR BILCHEM LTD D D D D D
PR PUERTO RICO CEMENT INC. X X X X X
PR FLORIDA LIME CORPORATION X X D D D
PR PUERTO RICO ELECTRIC PWR AUTH S S S S S
PR PUERTO RICO ELECTRIC PWR AUTH S S S S S
PR SAN JUAN CEMENT CO INC E E E E E
PR PUERTO RICO ELECTRIC PWR AUTH S S S S S
PR PRASA AGUAS BUENAS X X X X X
PR PRASA CEIBA S S S S S
PR PRASA CIALES X X X X X
PR PRASA COROZAL X X X X X
PR PRASA DORADO X X X X X
PR PRASA JUNCOS X X X X X
PR PRASA OROCOVIS X X X X X
PR PRASA PATILLAS X X X X X
PR PRASA SAN GERMAN X X X X X
PR PRASA SAN LORENZO X X X X X
PR PRASA VEGA ALTA X X X X X
PR TEXACO GUAYANILLA TERMINAL D D D D X
PR BETTER ROADS ASPHALT CORP D D D D D
PR PRASA BARCELONETA X X X X X
PR SYNTEX F.P. INC D D D D D
PR CARIBE ISOPRENE CORP D D D D D
PR PRASA PONCE STP S S S S S
PR PRASA YAUCO STP E E E E E
PR PRASA VEGA BAJA STP E E E E E
PR PRASA FAJARDO STP X X X X X
PR PRASA YABUCOA STP S S S S S
PR SB PHARMCO X X X X X
SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
PR PRASA TOA ALTA HEIGHTS X X X X X
PR PRASA ISABELA X X X X X
PR PRASA WTP SERGIO CUEVAS S S S S S
PR PRASA WTP GUAYNABO S S S S S
PR PRASA WTP ENRIQUE ORTEGA S S S S S
PR PRASA WTP AGUAS BUENAS X X X X X
PR PRASA WTP LAJAS FILTER PLANT S S S S S
PR MAYAGUEZ WATER TREATMENT CO IN E E E E E
PR PRASA ARECIBO X X X X X
PR PRASA BAYAMON X X X X X
PR PRASA AGUADILLA X X X X X
PR PRASA CAMUY X X X X X
PR PRASA SANTA ISABEL X X X X X
PR PRASA MAYAGUEZ R W W T P E E E E E
PR PRASA WTP EL YUNQUE FILTR PLT X X X X X
PR PRASA WTP CIALES X S S S S
PR PRASA WTP NEGROS X X X X X
PR GUERRERO THERAPEUTICAL E E D D D
PR ZARZAL PENAL CAMP WASTE WTP S S S S S
PR GUAVATE PENAL CAMP WTP X X X D X
PR PRASA LAS CAROLINAS STP. X X X X X
PR PRASA CAYEY RWWTP X X X X X
PR PRASA HUMACAO WWTP X X X X X
PR PRASA GUAYAMA REGIONAL WWTP X X X X X
PR PRASA AIBONITO WWTP E E E E E
PR PRASA SAN SEBASTIAN WWTP X X X X X
PR PRASA COMERIO WASTE WATER TREA X X X X X
PR PRASA LARES WWTP X X X X X
PR PRASA \_ CAGUAS RWWTP X X X X X
PR ECOELECTRICA LNG & COGENERATIO D D D D D

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
State Facility Name OCT-DEC97 JAN-MAR98 APR-JUN98 JUL-SEP-98 OCT-DEC98
RI NARRAGANSETT BAY COMM\_BUCKLIN X X X X X
RI WOONSOCKET WWTF S S E E E
SC CHESTER/ROCKY CREEK PLANT E X X E E
TN MURRAY INC. E E E E E
TN LAWRENCEBURG STP E E E D E
TN BRISTOL STP #2 X X X X X
TN BROWNSVILLE STP X X X X X
TX UNION ACQUISITION CORP. X X X X X
TX MARLIN, CITY OF E E E E E
TX WYMAN\_GORDON FORGINGS, INC. E D E E E
TX HARLINGEN, CITY OF (STP #0002) S E E X E
TX SOUTHWESTERN ELEC PWR\_WILKES E E E E E
TX PHARR, CITY OF E E E S S
UT TREMONTON CITY CORP D D D D D
UT SUNNYSIDE COAL COMPANY D D D D D
VI WATER & POWER AUTHORITY D D D D X
VI DEPT OF PUB WORKS\_CHARLOTTE AM D D E D D
VT POULTNEY MTP S S S S S
WI WI ELECTRIC POWER CO PL PRAIRI X X X X X
WV QUALA SYSTEMS, INCORPORATED D D D D E

SNC Codes: E=monthly effluent violation; X=non-monthly effluent violation; S=compliance schedule violations; D=DMR non-receipt; T=compliance
schedule report
Appendix B, Table 7
Appendix C:

EPA Memorandum
Appendix D:

Discharge Summaries for Major Multi-State

Bodies of Water
 The Mississippi River
Total toxic pollution reported in 1997: 57,698,880 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Mississippi River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Mississippi River in
(pounds) 1997.
Louisiana 45,580,758 79
Mississippi 8,218,709 14.2 Carcinogens 127,749 Pounds
Missouri 2,257,442 3.9
Persistent Toxic Metals 580,764 Pounds
Tennessee 510,112 0.9
Reproductive Toxins 9,590 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 684,963 Pounds
chemicals to the Mississippi River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Mississippi River in 1997.
PCS Nitrogen Fertilizer L.P. Geismar, LA 29,773,715
Vicksburg Chemical Co. Vicksburg, MS 8,122,845 Top dischargers of carcinogens* to the Mississippi River in 1997.
IMC-Agrico Co. Faustina Plant Saint James, LA 4,982,487
Facility Facility City Carcinogens
released to
Exxon Co. USA Baton Rouge Baton Rouge, LA 4,100,718 water (lbs)
IMC-Agrico Co. Uncle Sam Plant Uncle Sam, LA 2,555,826 Union Carbide Corp. Taft/Star Taft, LA 26,757
BASF Corp. Geismar, LA 1,402,410 PCS Nitrogen Fertilizer L.P. Geismar, LA 14,000
Dyno Nobel Inc. Lomo Plant Louisiana, MO 680,000 Ferro Corp. Grant Chemical Zachary, LA 12,340
Mapico Inc. Saint Louis, MO 641,837 Westvaco Corp. Wickliffe, KY 11,750
CF Ind. Inc. Donaldsonville, LA 583,105 Buckman Labs. Inc. Memphis, TN 9,957
Biokyowa Inc. Cape Girardeau, MO 535,843
Top dischargers of persistent toxic metals to the Mississippi River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theMississippi River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Georgia-Pacific Corp. Port Zachary, LA 260,000
(pounds)
Phosphoric acid 36,655,438 PCS Nitrogen Fertilizer L.P. Geismar, LA 129,600
Crown Paper Co. Saint Francisville, LA 47,000
Nitrate compounds 17,290,391
Westvaco Corp. Wickliffe, KY 28,800
Ammonia 2,164,392
Hermann Oak Leather Co. Saint Louis, MO 13,698
Methanol 381,048
Manganese compounds 322,114 Top dischargers of reproductive toxins* to the Mississippi River in
1997.
Zinc compounds 121,808
Facility Facility City Reproductive
Acetonitrile 104,413 toxins to
water (lbs)
Formic acid 84,331 Union Carbide Corp. Taft/Star Taft, LA 4,132
Barium compounds 81,192 Mapco Petroleum Inc. Memphis, TN 1,952
Ethylene glycol 49,079 Malllinckrodt Inc. Saint Louis, MO 1,332
PM Resources Inc. Bridgeton, MO 457
3M Cordova Plant Cordova, IL 350

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Ohio River
Total toxic pollution reported in 1997: 9,394,678 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Ohio River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Ohio River in 1997.
(pounds)
West Virginia 4,227,903 45 Carcinogens 69,595 Pounds
Ohio 2,661,287 28.3
Persistent Toxic Metals 641,150 Pounds
Pennsylvania 1,716,498 18.3
Indiana 392,598 4.2 Reproductive Toxins 12,466 Pounds
Total ** 711,537 Pounds
Table 2. Polluters discharging the greatest amounts of toxic
chemicals to the Ohio River in 1997. Table 5. Polluters reporting the greatest amounts of carcinogens*,
Facility Facility Location Toxic chemical persistent toxic metals, and reproductive toxins*
release to water discharged to the Ohio River in 1997.
(pounds)
Bayer Corp. New Martinsville, WV 3,206,967 Top dischargers of carcinogens* to the Ohio River in 1997.
J & L Specialty Steel Inc. Midland, PA 1,700,309 Facility Facility City Carcinogens
Elkem Metals Co. Marietta, OH 784,000
released to
water (lbs)
Shell Chemical Co. Belpre, OH 520,849 Olin Chemicals & Chlor Alkali Brandenburg, KY 18,407
Cytec Ind. Willow Island, WV 425,085 Cincinnati Specialties Inc. Cincinnati, OH 15,261
Shepherd Chemical Co. Cincinnati, OH 353,101 Solutia Port Plastics Addyston, OH 12,000
Cincinnati Specialties Inc. Cincinnati, OH 288,720 Willamette Ind. Inc. Hawesville, KY 3,848
Alcoa Warrick Ops. Newburgh, IN 207,104 Hilton Davis Inc. Cincinnati, OH 3,815
GE Plastics Co. Mount Vernon, IN 183,494
Du Pont Washington Works Washington, WV 179,717 Top dischargers of persistent toxic metals to the Ohio River in 1997.
Facility Facility City Persistent
Table 3. Toxic chemicals discharged in the greatest amounts to metals to
theOhio River in 1997. water (lbs)
Elkem Metals Co. Marietta, OH 453,000
Chemical Toxic chemical
release to water Weirton Steel Corp. Weirton, WV 84,721
(pounds) Willamette Ind. Inc. Hawesville, KY 30,281
Nitrate compounds 6,802,098 Sun Chemical Corp. Cincinnati Cincinnati, OH 20,102
Ammonia 776,356 CDR Pigments & Dispersions Woodlawn, OH 15,335

Manganese compounds 510,941

Top dischargers of reproductive toxins* to the Ohio River in 1997.
Methanol 480,827
Facility Facility City Reproductive
Glycol ethers 234,589 toxins to
water (lbs)
Cyanide compounds 108,303 OSI Specialties Inc. Friendly, WV 7,235
Sodium nitrite 98,326 Olin Chemicals & Chlor Alkali Brandenburg, KY 2,408
Phosphoric acid 58,990 Shenango Inc. Pittsburgh, PA 500
Countrymark Refinery Mount Vernon, IN 500
Zinc compounds 44,225
PPG Ind. Inc. New Martinsville, WV 372
Ethylene glycol 38,843

** The sum of carcinogens, persistent toxic metals, and reproductive

toxins listed in Table 3 may be larger than the total because a chemical
may be in more than one category. Chemicals were counted only once for
the total in Table 3.
* Carcinogens and reproductive toxins defined by the State of California
Proposition 65 and U.S. EPA. See full report for references.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Savannah River
Total toxic pollution reported in 1997: 4,771,110 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Savannah River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Savannah River in
(pounds) 1997.
Georgia 4,569,060 95.8
South Carolina 202,050 4.2 Carcinogens 8,620 Pounds
Persistent Toxic Metals 312,596 Pounds
Reproductive Toxins 674 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 318,450 Pounds
chemicals to the Savannah River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Savannah River in 1997.
DSM Chemicals N.A. Inc. Augusta, GA 2,417,169
Engelhard Corp. Savannah Ops. Savannah, GA 1,012,787 Top dischargers of carcinogens* to the Savannah River in 1997.
Union Camp Corp. Savannah, GA 338,670
Facility Facility City Carcinogens
released to
PCS Nitrogen Fertilizer L.P. Augusta, GA 290,500 water (lbs)
Clariant Corp. Martin Plant Martin, SC 201,950 Kemira Pigments Inc. Savannah, GA 2,700
International Paper Augusta Augusta, GA 200,646 Union Camp Corp. Savannah, GA 2,120
Kemira Pigments Inc. Savannah, GA 91,470 International Paper Augusta Augusta, GA 1,425
PCS Nitrogen Fertilizer LP Port Wentworth, GA 69,791 Stone Savannah River Pulp & Port Wentworth, GA 1,157
Monsanto Co. Augusta, GA 44,489 Fort James Operating Co. Rincon, GA 730
Stone Savannah River Pulp & Port Wentworth, GA 42,371
Top dischargers of persistent toxic metals to the Savannah River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theSavannah River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
International Paper Augusta Augusta, GA 170,740
(pounds)
Nitrate compounds 4,061,687 Kemira Pigments Inc. Savannah, GA 90,700
Union Camp Corp. Savannah, GA 50,700
Methanol 200,794
DSM Chemicals N.A. Inc. Augusta, GA 351
Ammonia 179,249
Searle Monsanto-Augusta GA Augusta, GA 99
Manganese compounds 153,300
Zinc compounds 91,651 Top dischargers of reproductive toxins* to the Savannah River in
1997.
Barium compounds 55,200
Facility Facility City Reproductive
Chromium compounds 9,000 toxins to
water (lbs)
Glycol ethers 3,720 Union Camp Corp. Savannah, GA 630
Nickel compounds 3,439 Rutgers Organics Corp. Augusta, GA 24
Acetaldehyde 3,387 Searle Monsanto-Augusta GA Augusta, GA 15
DSM Chemicals N.A. Inc. Augusta, GA 3
International Flavors & Augusta, GA 2

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Delaware River
Total toxic pollution reported in 1997: 4,378,209 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Delaware River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Delaware River in
(pounds) 1997.
New Jersey 3,696,975 84.4
Delaware 490,419 11.2 Carcinogens 172,150 Pounds
Pennsylvania 190,815 4.4
Persistent Toxic Metals 31,035 Pounds
Reproductive Toxins 92,548 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 278,660 Pounds
chemicals to the Delaware River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Delaware River in 1997.
Du Pont Chambers Works Deepwater, NJ 3,086,517
Du Pont Repauno Plant Gibbstown, NJ 410,074 Top dischargers of carcinogens* to the Delaware River in 1997.
Ciba Specialty Chemicals Corp. Newport, DE 185,302
Facility Facility City Carcinogens
released to
Mallinckrodt Baker Inc. Phillipsburg, NJ 176,920 water (lbs)
Allied-Signal Inc. Frankford Philadelphia, PA 107,022 Rodel Inc. Newark, DE 104,550
Rodel Inc. Newark, DE 104,550 Noramco Of Delaware Inc. Wilmington, DE 21,360
GMC NAO Wilmington Assembly Wilmington, DE 68,575 Rohm & Haas Co. Philadelphia Philadelphia, PA 10,630
Star Enterprise Delaware City, DE 50,769 Du Pont Chambers Works Deepwater, NJ 10,466
Sun Refining & Marketing Co. Marcus Hook, PA 36,845 Star Enterprise Delaware City, DE 6,782
Noramco Of Delaware Inc. Wilmington, DE 31,075
Top dischargers of persistent toxic metals to the Delaware River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theDelaware River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Du Pont Chambers Works Deepwater, NJ 14,001
(pounds)
Nitrate compounds 2,636,493 Star Enterprise Delaware City, DE 7,670
Sun Refining & Marketing Co. Marcus Hook, PA 3,413
Ammonia 352,277
NVF Co. Yorklin Complex Yorklyn, DE 1,885
Methanol 259,315
USS Fairless Works Fairless Hills, PA 1,700
Sodium nitrite 238,230
Nitric acid 235,394 Top dischargers of reproductive toxins* to the Delaware River in
1997.
N,N-Dimethylformamide 113,768
Facility Facility City Reproductive
Glycol ethers 112,273 toxins to
water (lbs)
1,3-Phenylenediamine 104,112 Du Pont Chambers Works Deepwater, NJ 82,802
m-Dinitrobenzene 81,587 Sun Refining & Marketing Co. Marcus Hook, PA 6,996
2,4-Dinitrophenol 48,869 Noramco Of Delaware Inc. Wilmington, DE 2,520
Star Enterprise Delaware City, DE 150
Zeneca Specialties A Business New Castle, DE 28

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Hudson River
Total toxic pollution reported in 1997: 2,861,894 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Hudson River in 1997.
State Toxic chemical Percent of total
release to water release Table 4. Total carcinogens*, persistent toxic metals, and
(pounds) reproductive toxins* discharged to the Hudson River in
New York 2,859,798 99.9 1997.
New Jersey 2,096 0.1
Carcinogens 4,303 Pounds
Persistent Toxic Metals 62,529 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Reproductive Toxins 41,039 Pounds
chemicals to the Hudson River in 1997. Total ** 107,686 Pounds
Facility Facility Location Toxic chemical
release to water Table 5. Polluters reporting the greatest amounts of carcinogens*,
(pounds) persistent toxic metals, and reproductive toxins*
Finch Pruyn & Co. Inc. Glens Falls, NY 2,464,200 discharged to the Hudson River in 1997.
Wyeth Ayerst Pharmaceuticals Pearl River, NY 149,483
GE Co. Silicone Prods. Waterford, NY 96,694 Top dischargers of carcinogens* to the Hudson River in 1997.
Facility Facility City Carcinogens
Nycomed Inc. Rensselaer, NY 52,243
released to
GE Plastics Selkirk, NY 30,885 water (lbs)
BASF Corp. Coatings & Rensselaer, NY 29,360 Wyeth Ayerst Pharmaceuticals Pearl River, NY 3,811
Engelhard Corp. Peekskill Peekskill, NY 24,088 BASF Corp. Coatings & Rensselaer, NY 214
Uhlich Color Co. Inc. Hastings On Hudson, 4,780 GE Plastics Selkirk, NY 190

NY Allied-Signal Inc. Friction Green Island, NY 75

Kings Electronics Co. Inc. Tuckahoe, NY 4,769 GE Co. Silicone Prods. Waterford, NY 10
Coca-Cola Bottling Co. Of New Elmsford, NY 2,297
Top dischargers of persistent toxic metals to the Hudson River in
1997.
Table 3. Toxic chemicals discharged in the greatest amounts to
Facility Facility City Persistent
theHudson River in 1997.
metals to
Chemical Toxic chemical
water (lbs)
release to water Finch Pruyn & Co. Inc. Glens Falls, NY 44,200
(pounds)
GE Co. Silicone Prods. Waterford, NY 15,400
Nitrate compounds 2,418,964
BASF Corp. Coatings & Rensselaer, NY 1,149
Methanol 193,628
GE Plastics Selkirk, NY 755
Triethylamine 67,314 Wyeth Ayerst Pharmaceuticals Pearl River, NY 662
Ammonia 51,046
2-Methoxyethanol 40,494 Top dischargers of reproductive toxins* to the Hudson River in
1997.
Manganese compounds 38,958 Facility Facility City Reproductive
Copper compounds 9,916 toxins to
water (lbs)
Zinc compounds 6,520 Wyeth Ayerst Pharmaceuticals Pearl River, NY 40,903
Barium compounds 6,236 GE Co. Silicone Prods. Waterford, NY 120

Acetonitrile 6,183 GE Plastics Selkirk, NY 10

Nycomed Inc. Rensselaer, NY 6
Spraylat Corp. Mount Vernon, NY 0

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Pacific Ocean
Total toxic pollution reported in 1997: 2,181,424 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Pacific Ocean in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Pacific Ocean in
(pounds) 1997.
California 2,084,092 95.5
Oregon 95,228 4.4 Carcinogens 43,023 Pounds
Hawaii 2,104 0.1
Persistent Toxic Metals 52,212 Pounds
Reproductive Toxins 4,607 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 91,613 Pounds
chemicals to the Pacific Ocean in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Pacific Ocean in 1997.
Louisiana-Pacific Corp. Samoa Samoa, CA 1,528,210
Mobil Oil Torrance Refinery Torrance, CA 98,405 Top dischargers of carcinogens* to the Pacific Ocean in 1997.
Seagate Recording Media Anaheim, CA 95,212
Facility Facility City Carcinogens
released to
Arco Prods. Co. La Refinery Carson, CA 76,480 water (lbs)
Tosco Refining Co. Los Carson, CA 70,069 Louisiana-Pacific Corp. Samoa Samoa, CA 22,000
Georgia-Pacific West Corp. Toledo, OR 53,198 UOP Separex Membrane Systems Anaheim, CA 11,295
International Paper Gardiner Gardiner, OR 42,030 Mobil Oil Torrance Refinery Torrance, CA 4,842
Filtrol Corp. Los Angeles, CA 36,892 International Paper Gardiner Gardiner, OR 900
Sony Electronics Inc. Sony San Diego, CA 35,104 Tosco Refining Co. Los Carson, CA 709
Phibro-Tech Inc. Santa Fe Springs, CA 29,283
Top dischargers of persistent toxic metals to the Pacific Ocean in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
thePacific Ocean in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Georgia-Pacific West Corp. Toledo, OR 25,400
(pounds)
Methanol 1,599,488 Power Circuits Inc. Santa Ana, CA 13,981
Mobil Oil Torrance Refinery Torrance, CA 5,157
Ammonia 171,864
Arco Prods. Co. La Refinery Carson, CA 2,640
Nitrate compounds 117,300
Kwikset Corp. Anaheim, CA 944
Methyl tert-butyl ether 90,419
Diethanolamine 68,146 Top dischargers of reproductive toxins* to the Pacific Ocean in
1997.
Acetaldehyde 23,440
Facility Facility City Reproductive
Phenol 18,110 toxins to
water (lbs)
Manganese compounds 15,005 Mobil Oil Torrance Refinery Torrance, CA 2,230
Copper 14,590 Tosco Refining Co. Los Carson, CA 1,364
Glycol ethers 12,811 Arco Prods. Co. La Refinery Carson, CA 918
Details Inc. Anaheim, CA 58
Edgington Oil Co. Long Beach, CA 28

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Tennessee River
Total toxic pollution reported in 1997: 2,147,554 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Tennessee River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Tennessee River in
(pounds) 1997.
Alabama 1,373,237 63.9
Tennessee 651,339 30.3 Carcinogens 62,526 Pounds
Kentucky 122,978 5.7
Persistent Toxic Metals 271,357 Pounds
Reproductive Toxins 363 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 317,601 Pounds
chemicals to the Tennessee River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Tennessee River in 1997.
Amoco Chemical Co. Decatur, AL 670,290
Inland Paperboard & Packaging New Johnsonville, TN 380,005 Top dischargers of carcinogens* to the Tennessee River in 1997.
Champion Intl. Courtland Mill Courtland, AL 341,958
Facility Facility City Carcinogens
released to
Laroche Ind. Inc. Cherokee, AL 225,723 water (lbs)
Du Pont Chattanooga Plant Chattanooga, TN 169,074 ISP Chemicals Inc. Calvert City, KY 33,399
Air Prods. & Chemicals Inc. Calvert City, KY 78,553 Amoco Chemical Co. Decatur, AL 15,000
Du Pont Johnsonville Plant New Johnsonville, TN 72,735 Mead Containerboard Stevenson, AL 5,700
Solutia Inc. Decatur, AL 48,452 Champion Intl. Courtland Mill Courtland, AL 4,600
3M Decatur, AL 41,778 Tenneco Packaging Counce, TN 1,000
ISP Chemicals Inc. Calvert City, KY 39,288
Top dischargers of persistent toxic metals to the Tennessee River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theTennessee River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Champion Intl. Courtland Mill Courtland, AL 246,000
(pounds)
Nitrate compounds 1,186,089 Amoco Chemical Co. Decatur, AL 19,900
Chemetals Inc. New Johnsonville, TN 1,285
Ammonia 599,587
Yale Security Inc. Lenoir City, TN 1,005
Manganese compounds 179,599
ISP Chemicals Inc. Calvert City, KY 865
Barium compounds 68,000
Formaldehyde 33,610 Top dischargers of reproductive toxins* to the Tennessee River in
1997.
Phosphoric acid 19,100
Facility Facility City Reproductive
Cobalt compounds 15,000 toxins to
water (lbs)
Methanol 14,083 Norandal USA Inc. Scottsboro Scottsboro, AL 250
Acetaldehyde 7,787 Westlake Monomers Corp. Calvert City, KY 106
Zinc compounds 5,792 BF Goodrich Co. Calvert City, KY 5
3M Decatur, AL 2

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Columbia River
Total toxic pollution reported in 1997: 1,859,047 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Columbia River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Columbia River in
(pounds) 1997.
Washington 1,013,815 54.5
Oregon 845,232 45.5 Carcinogens 55,128 Pounds
Persistent Toxic Metals 81,567 Pounds
Reproductive Toxins 0 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 136,615 Pounds
chemicals to the Columbia River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Columbia River in 1997.
Boise Cascade Corp. Saint Helens, OR 715,555
Weyerhaeuser Co. Longview, WA 274,902 Top dischargers of carcinogens* to the Columbia River in 1997.
Fort James Camas LLC Camas, WA 222,750
Facility Facility City Carcinogens
released to
SEH America Inc. Vancouver, WA 151,310 water (lbs)
Sandvik Special Metals Corp. Kennewick, WA 119,000 Weyerhaeuser Co. Longview, WA 42,080
Coastal St. Helens Chemical Saint Helens, OR 110,870 Fort James Camas LLC Camas, WA 8,600
Longview Fibre Co. Longview, WA 102,415 Boise Cascade Paper Div. Wallula, WA 2,488
Boise Cascade Paper Div. Wallula, WA 93,766 Boise Cascade Corp. Saint Helens, OR 1,385
Unocal Agricultural Prods. Kennewick, WA 37,475 SEH America Inc. Vancouver, WA 410
Lamb-Weston Inc. Boardman, OR 11,805
Top dischargers of persistent toxic metals to the Columbia River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theColumbia River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Weyerhaeuser Co. Longview, WA 75,354
(pounds)
Methanol 952,039 Boise Cascade Paper Div. Wallula, WA 2,092
Fort James Camas LLC Camas, WA 1,900
Nitrate compounds 522,765
Boise Cascade Corp. Saint Helens, OR 1,672
Formic acid 130,764
Fort James Operating Co. Clatskanie, OR 330
Ammonia 86,570
Manganese compounds 57,894 Top dischargers of reproductive toxins* to the Columbia River in
1997.
Formaldehyde 40,804
Facility Facility City Reproductive
Zinc compounds 14,192 toxins to
water (lbs)
Chlorine 11,820
Acetaldehyde 9,837
Barium compounds 7,362

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Snake River
Total toxic pollution reported in 1997: 1,263,681 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Snake River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Snake River in 1997.
(pounds)
Idaho 1,137,081 90 Carcinogens 7,516 Pounds
Oregon 126,600 10
Persistent Toxic Metals 7,376 Pounds
Reproductive Toxins 0 Pounds
Total ** 14,876 Pounds
Table 2. Polluters discharging the greatest amounts of toxic
chemicals to the Snake River in 1997. Table 5. Polluters reporting the greatest amounts of carcinogens*,
Facility Facility Location Toxic chemical persistent toxic metals, and reproductive toxins*
release to water discharged to the Snake River in 1997.
(pounds)
J. R. Simplot Co. Heyburn Heyburn, ID 614,159 Top dischargers of carcinogens* to the Snake River in 1997.
Mccain Foods USA Burley, ID 469,601 Facility Facility City Carcinogens
Ore-Ida Foods Inc. Ontario, OR 126,600
released to
water (lbs)
Potlach Corp. Idaho Pulp & Lewiston, ID 41,860 Potlach Corp. Idaho Pulp & Lewiston, ID 7,500
Avonmore West Inc. Twin Falls, ID 8,927 Blount Inc. CCI Ops. Lewiston, ID 16
Lamb-Weston Inc. Twin Falls, ID 2,507
Blount Inc. CCI Ops. Lewiston, ID 27

Top dischargers of persistent toxic metals to the Snake River in

1997.
Table 3. Toxic chemicals discharged in the greatest amounts to Facility Facility City Persistent
theSnake River in 1997. metals to
water (lbs)
Chemical Toxic chemical
Potlach Corp. Idaho Pulp & Lewiston, ID 7,350
release to water
(pounds) Blount Inc. CCI Ops. Lewiston, ID 26
Nitrate compounds 1,210,259
Methanol 26,500
Ammonia 11,705
Formaldehyde 5,200
Top dischargers of reproductive toxins* to the Snake River in 1997.
Zinc compounds 3,900 Facility Facility City Reproductive
toxins to
Manganese compounds 3,200
water (lbs)
Chloroform 1,200
Acetaldehyde 1,100
Barium compounds 250
Catechol 250

** The sum of carcinogens, persistent toxic metals, and reproductive

toxins listed in Table 3 may be larger than the total because a chemical
may be in more than one category. Chemicals were counted only once for
* Carcinogens and reproductive toxins defined by the State of California the total in Table 3.
Proposition 65 and U.S. EPA. See full report for references.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Big Blue River
Total toxic pollution reported in 1997: 1,219,431 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Big Blue River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Big Blue River in
(pounds) 1997.
Indiana 1,105,078 90.6
Nebraska 113,853 9.3 Carcinogens 755 Pounds
Missouri 500 0
Persistent Toxic Metals 6,327 Pounds
Reproductive Toxins 0 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 6,327 Pounds
chemicals to the Big Blue River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Big Blue River in 1997.
Allegheny Ludlum Corp. New Castle, IN 1,104,810
Agrium U.S. Inc. Homestead Beatrice, NE 40,309 Top dischargers of carcinogens* to the Big Blue River in 1997.
Friskies Petcare Co. Inc. Crete, NE 38,925
Facility Facility City Carcinogens
released to
Farmland Ind. Inc. Beatrice, NE 24,143 water (lbs)
Farmland Foods Inc. Crete, NE 10,221 Petersen Mfg. Co. Inc. De Witt, NE 250
GS Techs. Operating Co. GST Kansas City, MO 500 Allegheny Ludlum Corp. New Castle, IN 250
Petersen Mfg. Co. Inc. De Witt, NE 255 Textron Automotive Co. Morristown, IN 250
Textron Automotive Co. Morristown, IN 250 Farmland Ind. Inc. Beatrice, NE 5
Freudenberg-Nok Morristown Morristown, IN 18

Top dischargers of persistent toxic metals to the Big Blue River in

Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theBig Blue River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Allegheny Ludlum Corp. New Castle, IN 4,800
(pounds)
Nitrate compounds 1,194,059 Farmland Ind. Inc. Beatrice, NE 505
GS Techs. Operating Co. GST Kansas City, MO 500
Ammonia 15,706
Petersen Mfg. Co. Inc. De Witt, NE 255
Manganese compounds 4,300
Textron Automotive Co. Morristown, IN 250
Methanol 3,300
Zinc compounds 517 Top dischargers of reproductive toxins* to the Big Blue River in
1997.
Nickel compounds 505
Facility Facility City Reproductive
Nickel 250 toxins to
water (lbs)
Lead compounds 250
Copper compounds 250
Chromium compounds 250

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Lake Erie
Total toxic pollution reported in 1997: 949,146 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Lake Erie in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Lake Erie in 1997.
(pounds)
Ohio 540,864 57 Carcinogens 13,939 Pounds
Pennsylvania 401,936 42.3
Persistent Toxic Metals 365,481 Pounds
New York 6,346 0.7
Reproductive Toxins 0 Pounds
Total ** 373,677 Pounds
Table 2. Polluters discharging the greatest amounts of toxic
chemicals to the Lake Erie in 1997. Table 5. Polluters reporting the greatest amounts of carcinogens*,
Facility Facility Location Toxic chemical persistent toxic metals, and reproductive toxins*
release to water discharged to the Lake Erie in 1997.
(pounds)
International Paper Erie Mill Erie, PA 291,630 Top dischargers of carcinogens* to the Lake Erie in 1997.
Millennium Inorganic Ashtabula, OH 200,000 Facility Facility City Carcinogens
Mellennium Inorganic Ashtabula, OH 140,000
released to
water (lbs)
Mallinckrodt Inc. Calsicat Erie, PA 102,424 Day-Glo Color Corp. Cleveland, OH 6,335
GE Co. Ivanhoe Road Plant Cleveland, OH 89,566 Ferro Corp. Cleveland, OH 2,203
Ford Motor Co. Ohio Assembly Avon Lake, OH 44,748 Mallinckrodt Inc. Calsicat Erie, PA 1,852
BF Goodrich Avon Lake Avon Lake, OH 15,327 International Paper Erie Mill Erie, PA 661
Mtd Prods. Inc. Cleveland, OH 14,400 Mcgean-Rohco Inc. Cleveland, OH 463
Day-Glo Color Corp. Cleveland, OH 6,993
Erieview Metal Treating Co. Cleveland, OH 5,641 Top dischargers of persistent toxic metals to the Lake Erie in 1997.
Facility Facility City Persistent
Table 3. Toxic chemicals discharged in the greatest amounts to metals to
theLake Erie in 1997. water (lbs)
Millennium Inorganic Ashtabula, OH 200,000
Chemical Toxic chemical
release to water Mellennium Inorganic Ashtabula, OH 140,000
(pounds) Ferro Corp. Cleveland, OH 5,502
Manganese compounds 347,542 Mallinckrodt Inc. Calsicat Erie, PA 3,126
Methanol 280,589 Esab Group Inc. Ashtabula, OH 2,906

Sodium nitrite 85,051

Top dischargers of reproductive toxins* to the Lake Erie in 1997.
Nitrate compounds 72,665
Facility Facility City Reproductive
Ammonia 71,214 toxins to
water (lbs)
Glycol ethers 41,765 Aerosol Sys. Macedonia, OH 0
tert-Butyl alcohol 8,000
Formaldehyde 6,664
Ethylene glycol 5,601
Chlorine 5,600

** The sum of carcinogens, persistent toxic metals, and reproductive

toxins listed in Table 3 may be larger than the total because a chemical
may be in more than one category. Chemicals were counted only once for
the total in Table 3.
* Carcinogens and reproductive toxins defined by the State of California
Proposition 65 and U.S. EPA. See full report for references.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Wabash River
Total toxic pollution reported in 1997: 732,319 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Wabash River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Wabash River in
(pounds) 1997.
Indiana 732,319 100
Carcinogens 34,770 Pounds
Persistent Toxic Metals 42,144 Pounds
Reproductive Toxins 0 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 76,681 Pounds
chemicals to the Wabash River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Wabash River in 1997.
Tippecanoe Labs. Shadeland, IN 460,515
A. E. Staley Mfg. Co. Lafayette, IN 99,337 Top dischargers of carcinogens* to the Wabash River in 1997.
Clinton Labs. Clinton, IN 78,170
Facility Facility City Carcinogens
released to
A. E. Staley Mfg. Co. Lafayette, IN 67,324 water (lbs)
Schering-Plough Animal Health Terre Haute, IN 13,640 Clinton Labs. Clinton, IN 33,250
Inland Paperboard & Packaging Newport, IN 6,000 A. E. Staley Mfg. Co. Lafayette, IN 655
Cummins Engine Co. Inc. Columbus, IN 2,032 A. E. Staley Mfg. Co. Lafayette, IN 377
Industrial Plating Inc. Lafayette, IN 1,422 Tippecanoe Labs. Shadeland, IN 255
Jefferson Smurfit Corp. Wabash, IN 1,000 Subaru-Isuzu Automotive Inc. Lafayette, IN 154
Impact Forge Inc. Columbus, IN 635
Top dischargers of persistent toxic metals to the Wabash River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theWabash River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Clinton Labs. Clinton, IN 39,005
(pounds)
Nitrate compounds 610,605 Industrial Plating Inc. Lafayette, IN 1,422
NTN Driveshaft Inc. Columbus, IN 522
Zinc compounds 40,631
Subaru-Isuzu Automotive Inc. Lafayette, IN 330
N,N-Dimethylformamide 33,005
Golden Casting Corp. Columbus, IN 281
Ammonia 22,292
Methanol 13,490 Top dischargers of reproductive toxins* to the Wabash River in
1997.
tert-Butyl alcohol 5,155
Facility Facility City Reproductive
Ethylene glycol 1,917 toxins to
water (lbs)
Glycol ethers 1,010
Chlorine 750
Acetaldehyde 655

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Missouri River
Total toxic pollution reported in 1997: 622,932 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Missouri River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Missouri River in
(pounds) 1997.
Nebraska 379,817 61
Iowa 154,521 24.8 Carcinogens 1,337 Pounds
Missouri 87,764 14.1
Persistent Toxic Metals 1,783 Pounds
North Dakota 810 0.1
Reproductive Toxins 52 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 3,018 Pounds
chemicals to the Missouri River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Missouri River in 1997.
PCS Nitrogen Fertilizer L.P. Bellevue, NE 370,250
Terra Nitrogen Sergeant Bluff, IA 103,955 Top dischargers of carcinogens* to the Missouri River in 1997.
Prime Tanning Corp. Saint Joseph, MO 67,478
Facility Facility City Carcinogens
released to
Kind & Knox Gelatine Sergeant Bluff, IA 50,500 water (lbs)
Bayer Corp. Agriculture Div. Kansas City, MO 16,579 Bayer Corp. Agriculture Div. Kansas City, MO 1,006
Cargill Corn Milling Blair, NE 8,372 Omnium LLC Saint Joseph, MO 164
Hillyard Ind. Inc. Saint Joseph, MO 2,742 Ag Processing Inc. Saint Joseph, MO 154
Asarco Inc. Omaha Plant Omaha, NE 1,190 Fermenta Animal Health Co. Elwood, KS 10
Amoco Oil Co. Mandan Refinery Mandan, ND 810 Albaugh Inc. Saint Joseph, MO 3
Omnium LLC Saint Joseph, MO 315
Top dischargers of persistent toxic metals to the Missouri River in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theMissouri River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Asarco Inc. Omaha Plant Omaha, NE 1,190
(pounds)
Nitrate compounds 464,000 PCS Nitrogen Fertilizer L.P. Bellevue, NE 250
Ag Processing Inc. Saint Joseph, MO 154
Ammonia 142,401
Prime Tanning Corp. Saint Joseph, MO 152
Methanol 8,322
Friskies Petcare Saint Joseph, MO 34
Glycol ethers 2,994
Ethylene glycol 1,068 Top dischargers of reproductive toxins* to the Missouri River in
1997.
Formaldehyde 1,006
Facility Facility City Reproductive
Phosphoric acid 735 toxins to
water (lbs)
Zinc compounds 550 Bayer Corp. Agriculture Div. Kansas City, MO 43
Lead compounds 493 Zeneca Inc. Omaha, NE 5
Arsenic compounds 255 Omnium LLC Saint Joseph, MO 4

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Lake Michigan
Total toxic pollution reported in 1997: 578,019 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Lake Michigan in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Lake Michigan in
(pounds) 1997.
Wisconsin 427,500 74
Indiana 114,274 19.8 Carcinogens 5,188 Pounds
Michigan 34,945 6
Persistent Toxic Metals 20,932 Pounds
Illinois 1,300 0.2
Reproductive Toxins 829 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 25,241 Pounds
chemicals to the Lake Michigan in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Lake Michigan in 1997.
Amoco Oil Co. Whiting Refinery Whiting, IN 111,654
Racine Water Utility Racine, WI 69,000 Top dischargers of carcinogens* to the Lake Michigan in 1997.
Bell Aromatics Milwaukee, WI 55,368
Facility Facility City Carcinogens
released to
Red Star Yeast Milwaukee, WI 54,750 water (lbs)
Pfister & Vogel Leather Milwaukee, WI 44,747 Aldrich Chemical Co. Inc. Milwaukee, WI 1,114
Kohler Co. Brass Div. Kohler, WI 40,030 Borden Chemical Sheboygan, WI 884
Tenneco Packaging Inc. Filer City, MI 34,945 Plastics Eng. Co. Sheboygan, WI 830
S. C. Johnson & Son Inc. Sturtevant, WI 25,067 Hercules Inc. Milwaukee, WI 751
Milport Ent. Inc. Milwaukee, WI 23,026 Tenneco Packaging Inc. Filer City, MI 558
Mccann Barrel Inc. Milwaukee, WI 22,610
Top dischargers of persistent toxic metals to the Lake Michigan in
Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theLake Michigan in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Pfister & Vogel Leather Milwaukee, WI 10,263
(pounds)
Nitrate compounds 194,939 Eagle Ottawa Milwaukee Milwaukee, WI 2,453
Amoco Oil Co. Whiting Refinery Whiting, IN 2,354
Glycol ethers 98,608
Paul Flagg Leather Co. Sheboygan, WI 708
Chlorine 71,050
Cudahy Tanning Co. Cudahy, WI 478
Ammonia 68,382
Sodium nitrite 55,552 Top dischargers of reproductive toxins* to the Lake Michigan in
1997.
Sulfuric acid 22,610
Facility Facility City Reproductive
Methyl tert-butyl ether 11,236 toxins to
water (lbs)
Manganese compounds 10,143 Borden Chemical Sheboygan, WI 405
Methanol 9,971 Hercules Inc. Milwaukee, WI 403
Phosphoric acid 8,889 Borden Chemical Inc. Oak Creek, WI 21
Aldrich Chemical Co. Inc. Sheboygan Falls, WI 0
Hydrite Chemical Co. Milwaukee, WI 0

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

 The Ouachita River
Total toxic pollution reported in 1997: 572,807 Pounds
Table 1. States discharging the greatest amounts of toxic chemicals
to the Ouachita River in 1997.
State Toxic chemical Percent of total Table 4. Total carcinogens*, persistent toxic metals, and
release to water release reproductive toxins* discharged to the Ouachita River in
(pounds) 1997.
Louisiana 325,773 56.9
Arkansas 247,034 43.1 Carcinogens 9,553 Pounds
Persistent Toxic Metals 15,888 Pounds
Reproductive Toxins 0 Pounds
Table 2. Polluters discharging the greatest amounts of toxic Total ** 23,766 Pounds
chemicals to the Ouachita River in 1997.
Facility Facility Location Toxic chemical Table 5. Polluters reporting the greatest amounts of carcinogens*,
release to water persistent toxic metals, and reproductive toxins*
(pounds) discharged to the Ouachita River in 1997.
Angus Chemical Co. Sterlington, LA 217,062
Georgia-Pacific Paper Ops. Crossett, AR 173,550 Top dischargers of carcinogens* to the Ouachita River in 1997.
Koch Nitrogen Co. Sterlington, LA 96,314
Facility Facility City Carcinogens
released to
International Paper Co. Camden, AR 41,919 water (lbs)
U.S. Vanadium Corp. Hot Springs, AR 31,195 Angus Chemical Co. Sterlington, LA 4,313
Riverwood Intl. Corp. West Monroe, LA 12,397 Georgia-Pacific Paper Ops. Crossett, AR 2,825
Celotex Corp. Camden, AR 250 Riverwood Intl. Corp. West Monroe, LA 1,444
Arkansas Aluminum Alloys Inc. Hot Springs, AR 120 International Paper Co. Camden, AR 755
U.S. Vanadium Corp. Hot Springs, AR 195

Top dischargers of persistent toxic metals to the Ouachita River in

Table 3. Toxic chemicals discharged in the greatest amounts to 1997.
theOuachita River in 1997. Facility Facility City Persistent
metals to
Chemical Toxic chemical
water (lbs)
release to water
Riverwood Intl. Corp. West Monroe, LA 7,500
(pounds)
Methanol 206,471 International Paper Co. Camden, AR 4,678
Georgia-Pacific Paper Ops. Crossett, AR 1,500
Nitrate compounds 205,676
Angus Chemical Co. Sterlington, LA 1,459
Ammonia 134,917
Koch Nitrogen Co. Sterlington, LA 286
Zinc compounds 12,682
Acetaldehyde 4,843 Top dischargers of reproductive toxins* to the Ouachita River in
1997.
2-Nitropropane 2,789
Facility Facility City Reproductive
Nickel 1,459 toxins to
water (lbs)
Manganese compounds 750
Phenol 645
Catechol 438

** The sum of carcinogens, persistent toxic metals, and reproductive

* Carcinogens and reproductive toxins defined by the State of California toxins listed in Table 3 may be larger than the total because a chemical
Proposition 65 and U.S. EPA. See full report for references. may be in more than one category. Chemicals were counted only once for
the total in Table 3.

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org

Source: U.S. PIRG. Compiled from U.S. Environmental Protection Agency, Toxics Release Inventory, 1997.

Phone: 202-546-9707 Fax: 202-546-2461 Email: [email protected] Web: www.pirg.org