To: Members & Subscribers From: National Office Date: May 14, 1997 Re: RA 97-10 Improving Toxic Release Inventory Reporting Accuracy -
The Public's Right-To-KnowOver the past several months, AMSA has been working on completing a report on EPA's Toxic Release Inventory (TRI) program. The enclosed report was developed in response to long-standing concerns about the quality of information collected by TRI reporting and misrepresentation of TRI data relating to industrial discharges to POTWs. AMSA conducted the study to assess the accuracy of the current TRI reporting program and its ability to apprise communities of the potential risks of toxic chemical exposure. Overall, AMSA concluded that TRI data on chemicals released to POTWs tends to be over-reported versus under-reported and in some cases not reported correctly. Several "common errors" were found, including using estimates as basis for TRI reporting instead of actual sampling values. To correct some of these "common errors," the report recommends that EPA revise the TRI reporting form instructions to allow industries to report actual amounts of TRI chemicals utilized and released. The report also recommends that EPA redefine releases so that any discharge of a TRI chemical to a POTW that is in compliance with permit limits should not be considered a release to the environment.
We encourage our members to distribute this report and to use it as a resource to respond to questions regarding the validity of the TRI reporting program. The report strongly urges EPA to provide better outreach with the release of TRI reports to assist the public in interpreting the nature of the data. The report also urges that public education efforts highlight the success of the national discharge permitting program, national industrial pretreatment program and biosolids beneficial use efforts.
AMSA will also forward copies of this report to EPA headquarters and EPA regions in an effort to prompt EPA to take action and work with us to implement our recommendations. The report will also be forwarded to the Environmental Working Group (EWG) and the Public Interest Research Group (PIRG) in response to their recent publication, "Dishonorable Discharge: Toxic Pollution of America's Waters."
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