Improving Toxic Release Inventory Reporting Accuracy -
The Public's Right-to-Know the Facts
EXECUTIVE SUMMARY
The Association of Metropolitan Sewerage Agencies (AMSA)
has long-standing concerns about the type and quality of information
generated by the TRI reporting program. AMSA believes that misinterpretation
of the National Toxic Release Inventory (TRI) information can
mistakenly associate the use of chemicals by industry with the
release of these chemicals into the environment and subsequent
impacts. These interpretations do not account for pollutant recapture
or chemical alterations that may occur prior to discharge, or
further treatment or control by publicly owned treatment works,
or the relative toxicity of the pollutant at levels released to
the environment. Improper interpretation of data produced by
the TRI program sends the wrong message to the public; namely,
that the volume of pollutants being released by industries is
directly linked to environmental integrity and quality.
To that end, AMSA has conducted a study, Improving Toxic Release
Inventory Reporting Accuracy - The Public's Right-to-Know the
Facts, to assess the accuracy of the current TRI reporting
program and its ability to apprise communities of the potential
risks of toxic chemical exposure and, where necessary, to offer
potential remedies. To assess the accuracy of the TRI reporting
information and relevance of the TRI as it relates to industrial
discharges to publicly owned treatment works (POTWs), selected
industries from six AMSA members were evaluated to verify TRI
information, determine how the data were derived, and comment
on the accuracy of the data.
The overall conclusion from this evaluation is that the TRI data
on chemicals released to POTWs tend to be over-reported versus
under-reported, or in some cases not reported correctly. Some
common errors include the following:
Industries did not base TRI reporting on actual sampling, but
estimates.
Acids which were neutralized prior to discharge were incorrectly
reported as actual acid releases.
Chemicals utilized for treatment were not adjusted for purity
and thus incorrectly reported as 100% pure.
Incorrect determination of quantities reported versus actual releases.
Mid-point values for loading categories were entered into the
data base instead of the values reported by the industry.
AMSA urges the U.S. Environmental Protection Agency (EPA) to make
the following changes to the TRI reporting process:
EPA should revise the TRI reporting forms and instructions to
enable industries to report actual amounts of TRI chemicals utilized
and released. As an example, clear instructions need to be provided
so that mineral acids used in industrial applications (i.e. product
manufacturing, waste treatment, etc.) which are neutralized in
accordance with Clean Water Act requirements (³5.0
for discharges to POTWs and ³6.0
for discharges under the NPDES system) should not be reported
as releases under TRI. Another example would be for the instructions
to clearly require industries to insure that the TRI information
is consistent with other kinds of reporting data such as National
Pollutant Discharge Elimination System monitoring reports.
Releases should be redefined so that any discharge of a TRI chemical
to a POTW that is in compliance with the National Industrial Pretreatment
Program should not be considered as a release to the environment
unless verified to be so by the POTW.
EPA should expand its discussion of the TRI report to assist the
general public in understanding and interpreting the nature in
which the chemicals are being used and released into the environment.
In addition, EPA needs to convey the message that TRI toxic pollutants
are only toxic in toxic amounts based on the magnitude, duration,
and frequency of exposure sufficient to induce adverse biological
impacts in the receiving stream.
EPA has indicated that a five-year evaluation of the TRI program
will be performed. This should include an evaluation of trends
in the amounts of chemicals being released to the environment.
The Agency should recalculate prior reported quantities, using
the criteria referenced in this report, before a trend analysis
is performed.
EPA should provide an explanation stating why certain chemicals
which were included in past TRI reporting, such as acetone, are
no longer part of the existing database. Furthermore, the Agency
should note which industries, which were previously cited among
the largest users of TRI chemicals in past reports, are no longer
in operation.
EPA should include a discussion in the report that documents the
success of national initiatives such as the NPDES program, National
Industrial Pretreatment Program, and Biosolids Beneficial Use
efforts to further public understanding of TRI data.
AMSA is committed to working collaboratively with EPA to implement
these recommendations to improve the utility of the TRI program.
For more information, please contact AMSA, 1000 Connecticut Avenue,
NW, Suite 410, Washington, DC 20036; (202) 833-AMSA.